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Statement of Need: Under Table Z-1 of the 1971 air contaminants rule, OSHA enforces a permissible exposure limit of 5 mg/m3 for mineral oil mists, but evidence suggests this level is outdated and that exposure to metalworking fluids can lead to cancer, non-malignant lung disease and dermatitis. Giving a SAC the opportunity to examine and comment upon current studies and data concerning the risks associated with all metalworking fluid mixtures (straight oils, synthetic, and semisynthetic) will provide valuable information the Agency can use to develop a proposed rule for metalworking fluids. The SAC will also report on related regulatory issues such as fluid management, engineering controls, medical surveillance, and economic and technological feasibility.

Alternatives: The Agency recognizes the complex and difficult nature of the issues surrounding the regulation of metalworking fluids and believes a SAC can best alleviate some areas of confusion. The Committee has a unique opportunity to provide needed data and academic and professional expertise, as well as large and small industry and labor perspectives. Through OSHA's exhaustive Priority Planning Process and NACOSH recommendation, metalworking fluids was identified as a regulatory candidate that could be handled most successfully through a SAC. The option of going directly to 6(b) rulemaking has been passed up because of the added benefits the Agency will gain from the deliberations of the SAC; the ability to learn more from the SAC recommendations than from any other data gathering method, and the opportunity to build some consensus before the proposal is issued.

Anticipated Costs and Benefits: Because the SAC has yet to meet, the form of the Committee's recommendations is unknown at the present time. However, once the SAC report is written, the scope of the proposed rule will be determined. Quantitative estimates of costs and benefits will be made only after the proposed rule has been drafted.