Dye makers upset over OSHA hazard alert Upset by the Occupational Safety & Health Administration's recent warning to employers and employees of the danger of exposure to benzi-dine-based dyes (C&EN, May 19, page 29), a dye industry organization has requested a change in the law that permits OSHA to issue such health hazard alerts.

Specifically, Stephan J. Kasprzak, executive director of the Dyes Envi­ronmental & Toxicology Organiza­tion, proposes that the Occupational Safety & Health Act be amended to provide a period of at least 30 days for industry and public comment before OSHA can issue health hazard alerts. This provision is similar to one used by the Consumer Product Safety Commission. Kasprzak made his re­quest in letters to chairmen of the two OSHA oversight committees—Sen. Harrison A. Williams (D.-N.J.) of the Committee on Labor & Human Re­sources, and Rep. Joseph M. Gaydos (D.-Pa.) of the Committee on Edu­cation & Labor.

The organization's action was precipitated by OSHA's preparation of an alert on dyes based on benzi­dine, o-tolidine, and o-dianisidine that the industry group believed to be predicated on limited and inconclu­sive data. An opportunity was re­quested to review the data and suggest changes. When a response was received a month later from OSHA's director of health standards Bailus Walker, it was considered largely unresponsive to the industry's concerns and was received on the same day the alert was issued.

Citing evidence of carcinogenicity, OSHA recommended that commer­cial use of the dyes be stopped and appropriate substitutes found.

Kasprzak objects to this "cavalier disregard of due process consider­ation and the scientific expertise of this [industry] organization." He further states that "OSHA's precipi­tous release of the health hazard alert based on erroneous and inadequate information has caused substantial harm to members of this industry."

The objections begin with OSHA's grouping together all three broad categories of dyes with only limited evidence that they may be carcino­genic. The dyes organization claims that there is no scientific basis for concluding that o-tolidine and o-dianisidine dyes are potential dan­gers.

Some small dye makers already have been hurt as a result of the alert, the group claims. The impact on the total industry is expected to be small,

however. Still, the alert has prompted some users to switch to substitutes that may not have the properties the user needs. Also, the industry group says, OSHA's recommendation to use substitute dyes is suspect, because even less is known about the health effects of the substitutes. D

Restraint urged in developing oil shale An oil shale industry producing 400,000 bbl per day could be created by 1990 using existing technologies and without additional leasing of federal land. But it would create so­cial and economic problems if current programs to overcome these problems aren't accelerated.

That's the gist of a new study made by the Office of Technology Assess­ment at the request of the Senate Committee on Energy & Natural Resources. The study, notes Sen. Orrin G.^Hatch (R.-Utah), a member of the OTA Congressional Board, lends credence to fears in the West regarding the inherent dangers of any crash federal programs to develop western lands.

"Utah and Colorado, with most of the nation's oil shale reserves," Hatch says, "are looking at the business end of a very large federal cannon, loaded with billions for synthetic fuels de­velopment."

In its assessment, OTA focused on four 1990 development targets: 100,000; 200,000; 400,000; and 1 mil­lion bbl per day. It studied these in terms of technology, economics, re­source acquisition, environment, water availability, and socioeco­nomics.

OTA notes six objectives for es­tablishing an oil shale industry— objectives held by disparate groups and that will influence the ultimate political decision of whether, how, and to what extent to develop oil shale:

• To gain information and expe­rience to position the industry for rapid deployment.

• To maximize energy supplies in light of potential economic and na­tional security problems.

• To minimize federal promotion by allowing an industry to develop in response to market pressures and opportunities.

• To phase development to eval­uate potential impacts and design and test controls that would maxi­mize ultimate environmental infor­mation and protection.

• To proceed at a gradual pace to maximize the integrity of the social environment.

• To achieve an efficient and cost-effective energy supply system in which the industry would be posi­tioned for long-term profitable op­erations.

Rating the four levels of develop­ment against these objectives gives a good sense of the trade-offs among objectives that inevitably will be re­quired in establishing policy. For ex­ample, OTA gives the 400,000 bbl-per-day industry the highest rating in terms of positioning the industry for rapid development. Atythis level, a wide variety of technologies and sites would be evaluated and substantial technical, environmental, and eco­nomic information obtained. The 1 million bbl-per-day level is rated lower because its accelerated con­struction schedule would preclude precommercial experiments and

Resources needed for shale oil depend on 1990 production

Resource

Institutional Design and construction services,

% of 1978 U.S. capacity neeôeà yearly

Plant equipment. % of 1978 U.S. capacity needed yearly

Economic and financial Loans, $ billion (1979 dollars) Equity, $ billion (1979 dollars) Total Annual, $ billion (1979 dollars)

maximum for five-year construction period

Water availability Water, acre-feet per year

Socioeconomic Workers New residents requiring housing and

community services

100,000

Minimal

Minimal

$0.9-$ 1.35 2 .1 - 3.15 3.0- 4.5

0.6-0.9

9,800-24,600

5,600 23,000

Target, bbl per day 400,000

12%

6-12

$3.6-$4.2 8.4- 9.8

12.0-14.0

2.4-2.8

39,200-98,400

17,600-22,400 82,000-95,000

1 million

35%

15-30

$9.0-$13.5 21.0- 31.5 30.0- 45.0

6.0-9.0

100,000-250,000

44,000-56,000 118,000-236,000

June 30, 1980 C&EN 5