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From: (Bruce Hamilton)
Subject: ACGIH - was Re: Occupational exposure limit
Date: Tue, 4 Jun 1996 16:38:15 LOCAL

In article <>
"Cold Mountain, Cold Rivers" <> writes:

>acgih disclaims such uses because many of its tlv's were set based on nothing
>more than ambient factory levels for the chemical involved (ie what acgih
still defends as "protective of health" or some such phrase are actually what
manufacturers happened to have in the air at the time of study).

We went down this path in 1994, or  whenever, have you new
evidence to support you even more extravagent claim of fraud.

Frankly Tony, your continued attempts to besmirch the ACGIH are
becoming boring. As I pointed out at that time, the ACGIH publishes
an extensive series of monographs called " Documentation of TLVs "
which details the information used to arrive at the values.

>and such "studies" were done by companies like dow (whose toxicologists
>sat on the acgih cmtee approving the tlv's.  to this day acgih wont provide
>the documentation for many tlv's, because it simply doesn't exist, or because
>it is insufficient.

Evidence?. Which chemicals have you reqested the TLV documantation
for that the ACGIH have refused to supply?.

>acgih has done little, imo, to prevent the propagation of their tlvs as "safe
>exposure levels" by states & others.  go with niosh exposure levels, or
>those few osha levels that were not derived from tlv's.  see casleman &
>zeim, amongst others in the literature for documentation of this widespread &
>very consequential fraud.--

I'm sure the ACGIH might start to get concerned at the term " fraud "
*if* it was claimed by somebody consequential...

For those that arrived late, here is gutted part of my response at the time.
I recommend these paper to accompany the Castleman and Zeim paper
referenced by Tony Tweedale. I'm not going to revisit this again, unless
Tony has some compelling new information on the ACGIH conspiracy...

               Bruce Hamilton

From: (Bruce Hamilton)
Subject: ACGIH
Date: Thu, 20 Oct 1994 11:28:29 GMT

The ACGIH issues at least three compilations annually.

The first is the "Threshold Limit Values ( for Chemical
Substances and Physical Agents ) and Biological Exposure
Indices" 1990/1991 edition had ISBN 0936712-86-4
This is the one most commonly referred to as the TLVs,
and I've already quoted some of their criteria.

The second is the "Guide to Occupational Exposure Values"
The 1990 edition had ISBN 0-936712-86-2. This is intended
as a companion document to the above, and it also highlights
any compound that that has a lower OSHA or NIOSH limit.
This is a complete and comparative tabulation of the
following limits for chemical substances listed in any
of the sources.
ACGIH TLVs : TWA ( ppm or mg/m3 ) STEL/Ceil  ( ppm or mg/m3 )
OSHA PELs  : TWA    "       "     STEL/Ceil     "       "
NIOSH RELs : TWA    "       "     STEL/Ceil     "       "
DFG MAKs   : TWA    "       "     Peak
Carcinogens = listed by any of the above, and IARC or
NTP, and likely to be found in the occupational environment.

A quick perusal of the very convenient format indicates that
there are many cases where ACGIH are lower than OSHA or NIOSH,
and most are identical. Sure there are some that are higher,
but I haven't time to check them all, but most of the
differences were minor ( the carcinogen classifications
are harder to assess. as I didn't check, but NIOSH-X was
more frequent than others.).

The third is the "Documentation of the Threshold Limit
Values and Biological Exposure Indices" which is very
comprehensive, and is supposed to be consulted before
applying TLVs and BEIs in specific environments.
It provides the pertinent scientific information that
was used to base the reassessment value of each TLV or BEI.
[ The Castleman and Zeim saga ]
Tony posted three references, all by the same authors.

Unfortunately I don't have access to those journals.
I suspected such petulance wouldn't go uncommented on,
and sure enough I was able to find the following.

" Industrial Hygiene with no limits" Guest Editorial
by Eileen Seen Tarlau. Am.Ind.Hyg.Assoc.J.  Jan 1990
p A9-A10. [ Tarlau is listed as Member, AIHA ]
Tarlau supports some of the B.I.Castleman and G.E.Ziem
concepts and pushes the abolition of limits and the
use of the IRIS database to ascertain risk.

" Occupational Exposure Limits: Their critical role in
Preventive Medicine and Risk Management" Guest
Editorial Dennis J.Paustenbach. Am.Ind.Hyg.Assoc.J
May 1990 p A332-336.
Paustenbach carefully dissects Tarlau's, and Castleman
and Zeim's claims. He demonstrates her approach has
not worked in the past, and that their attacks on the
integrity of earlier ACGIH members  is not bourne out
by the facts. I'll just quote a little from his final
" To understand the unfairness of the claims that the
TLVs were established in an "irregular" matter, one need
only read some of the papers published in the 1950s.
Interestingly, the committe was so proud of its
scientific methods that the members encouraged others to
critique them ( as evidenced by the more than 50 papers
published in scientific journals which documented the
committee's approach ). To infer that some of the
forefathers of industrial hygiene were pawns of special
interest groups illustrates a poor understanding of their
motives and their actions. By today's standards they would
be considered zealots or a fringe group whose only purpose
was to protect workers from disease."

TLVs used to be known as MACs, and the same issue of
Am.Ind.Hyg.Assoc.J. May 1990 p A363-A366 has a very
interesting reprint of " The Case for Maximum Allowable
Concentrations " Hervey B. Elkins ( from Am.Ind.Hyg.
Quarterly v9 p22-25   1948 ).
Yes! - a 45 year old discussion/debate on why they should
be used, and if they were appropriate and sensibly arrived
at ( some were just guesswork based on chemical
relationships to known toxic cussies ).

From: (Bruce Hamilton)
Newsgroups: sci.environment
Subject: Re: Science editorial on new EPA standards
Date: Fri, 11 Jul 1997 20:19:17 GMT

rparson@spot.Colorado.EDU (Robert Parson) wrote:
>In article <...>,  <> wrote:
>>again, should _science_ allow abelson's more extreme editorial writings,
>>considering both the influence of the magazine and its readership on
>>society (their word eems to me to be taken as near gospel by the mass
>>media and by society), and the 'science first, opinions last' tone of
>>the vast malority of their editorials?
> The editorials in _Science_ represent the opinions of the scientific
> community. Abelson represents the opinion of a large fraction of
> the community of working scientists.

I would have thought that they represented their author's perceptions,
and being published as editorials doesn't automatically make them
representative of the community. As editor, Abelson can choose whose
perceptions he wants to present. I've certainly read some that would
not necessarily represent a large fraction of the community, but the
perception would interest a large fraction of the community :-).
>> one reason i like _rachel's_ is his practice of referencing his claims.
> So does Dixy Lee Ray. The question is, do the references support the
> claim, and are they representative of the actual literature. Bruce
> Hamilton's "FRED" essays demonstrated the bias in Montague's articles
> quite well, by deliberately inverting them.

What prompted me to waste time with that was because Montague launched
a full scale attack on ACGIH TLVs without once referencing the
primary document " Documentation of the Threshold Limit Values and
Biologiocal Exposure Indices " which lists the pertinent scientific
information and data, along with reference to literature sources used
to establish the TLVs and BEIs. That documentation is the fundamental
base that clearly showed the evidence used to establish limits. Any
discussion on the validity of those occupational limits should start
by examining that base.

Montague didn't even refer to it, instead basing his article on
the Zeim/Castleman papers - ( of the four references he cited, two were
theirs ). Their attack on the TLVs had already been responded to in
detail, yet he chose to ignore the responses. He also chose to ignore
all the published debates about the limits - certainly there have always
been some in the ACGIH who have quesstioned the validity and usefulness
of TLVs, and a scan of the literature will soon find the cut and thrust
debates that have occurred every decade. However the TLVs have emerged
stronger from every debate. Each TLV is regularly reviewed, any new
information is assessed, and the limits are changed if necessary.

Montague also conveniently omitted historical data, and didn't review
any of the actual data - instead impunging the motives of these
occupational health professionals. I provided references to papers
that both supported and criticised TLVs in FRED, and what I found
in our small library in half an hour demonstrated that Montague had
not even read the readily-available literature. Instead, he had
focussed on, and built upon, claims in two papers that already had
been responded to, and limited his selection of references to those
that suited his initial perception.

If science is a building, and papers are the bricks, then references
are the mortar that joins them. To be strong, the references must be
well formulated and mixed. It's easy to select a few that suit your
perception, but such a weak mix will soon fail. That's why peer-review
exists. Without it, additional bricks would cause a subsequent collapse
when the weak mortar failed, and much subsequent good work would also
be lost.

Perhaps Abelson succeeds because his training has taught him how
to quickly find diverse references and distill the essence of
those papers into a short, well-balanced perception. Most research
centres have somebody who achieves by writing reviews of scientific
endeavours, rather than by continuing to perform front line research.

There is a place for such work, as a good review is a time-saving
treasure for most active researchers. It's easy to write articles
that appear scientific because they have references, but if you
choose only those that match your perception, and ignore important
references because they are inconvenient, then the article will
be perverted.

       Bruce Hamilton

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