✓ Establish comprehensive government programs to reduce hazardous chemicals and improve indoor air quality in nail salons.
Despite the significant health and economic impacts, indoor air pollution does not have the benefit of a coordinated and focused risk reduction program at the state or federal level. The existing regulations that apply to indoor air quality are scattered across multiple agencies, leaving substantial gaps in the state’s ability to reduce indoor air pollution for workers and salon customers. The actions of many agencies such as the BBC affect indoor air quality, and a few like Cal/OSHA and CARB have limited authority over some aspect of indoor air quality, but no state (or federal) agency has the authority or mandate to conduct or coordinate a comprehensive indoor air pollution prevention and mitigation program.
Additionally there are gaps between environmental and occupational regulation of toxicants. Cal/ OSHA’s process for establishing permissible exposure limits (PEL) lacks a consistent scientific basis. A December 2007 report issued by OEHHA recommended using existing OEHHA cancer and non-cancer risk assessments to update occupational standards in California.48 The report also recommended new legislation similar to that considered in the 2007–08 legislative session, Assembly Bill 515 (Lieber). AB 515 would have required the Cal/OSHA Standards Board to prioritize the adoption of PEL’s for certain toxic materials. The bill would have also required each adoption to correspond, to the extent feasible, with the health-based occupational exposure level recommended by OEHHA.
Cal/OSHA PELs address individual chemicals and are usually based on 8–hour time-weighted
California Healthy Nail Salon Collaborative
average exposures. These standards tend not to be protective for nail salon workers who use many different toxic chemicals for short periods repeatedly over the course of the day. Under these use conditions, exposure monitoring for individual toxic chemicals averaged over an 8–hour period can show that they are below the Cal/OSHA PEL even though workers experience frequent high exposures which can have adverse health effects, especially during pregnancy. This is of particular concern since most Cal/OSHA PELs do not protect against reproductive and developmental toxicity, and workers in the nail salon industry are predominantly women of childbearing age.
Pass legislation similar to AB 515 in order to improve Cal/OSHA’s process for establishing PELs to ensure that they are based on quantitative risk assessments, protect against chronic toxicity such as cancer and reproductive and developmental damage, and correspond to the health-based occupational exposure limits recommended by OEHHA.
Give CARB authority to set emission standards for indoor air pollutants that pose human health risks.
Create a management system for indoor air quality that establishes and assigns authority and responsibility for assessing indoor health problems of consumers and workers, identifying the actions needed to reduce the most significant problems, and setting guidelines, emissions limits, or other requirements that will be effective in reducing the health impacts of indoor sources.49