Appendix: Analysis of Proposed Benzene Standard

by Council on Wage and Price Stability on September 12, 1977
by Council on Wage and Price Stability

The Council on Wage and Price Stability is concerned that the proposed standard does not reflect sufficient study of the costs and attendant health benefits of some very costly parts of the standard. OSHA has not fully documented its case for adopting the proposed benzene exposure limit rather than a nore or less stringent one. In addition, having decided upon the 1 ppm standard OSHA has not adequately considered the problem of designing a standard that will foster compliance with minimum cost. A standard that encourages this minimization of cost must be based on detailed estimates of the health risks in all sectors of the affected industries as well as the costs of reducing these risks by varying amounts in each workplace and using different means of controlling exposure. In other words the feasibility, cost and efficacy of alternative modes of achieving compliance with the 1 ppm standard must be analyzed. In so far as is possible the final standard should be flexible enough in the area of permissible means of compliance to enable each industry to adopt those alternatives that present the least cost burden while protecting workers to at least the mandated degree.

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