November 19, 2004
Ministry of Labour
The OELs Update Project
12th Floor, 400 University Avenue
Toronto, Ontario
M7A 1T7
Dear Sir/Madam:
To Whom it may concern
Please find enclosed the Ontario Public Service Employees Union’s (OPSEU) submission in response to the Ontario Ministry of Labour’s (MOL) proposed changes to the occupational exposure limits (OELs) announced on September 20, 2004.
As one of Ontario’s largest unions, OPSEU represents over 100, 000 workers from a variety of jobs and sectors who are exposed to many types of chemicals in their workplaces.
The MOL’s current proposal includes changes to the exposure limits of 66 chemical agents (making 63 more protective and 3 less protective), and setting limits for 26 agents not currently regulated.
OPSEU supports reducing Ontario’s OELs at a minimum, to the current threshold limit values (TLVs) set by the American Conference of Governmental Industrial Hygienists (ACGIH). However, OPSEU disagrees with the proposal to raise allowable levels of 3 substances (butane, 1-hexenne, and toluene diisocyanate).
As you will see from our document, we believe that the ACGIH’s TLVs are often too high and are often set at levels that employers have already met in their workplaces. Numerous studies have documented flaws in the ACGIH’s TLV process over the years. We continue to be concerned that ACGIH TLV levels, which Ontario’s MOL
uses as a baseline, may not be protective enough.
Our outrage that workplaces often serve as testing grounds for new substances leads us to suggest in our submission that Ontario ought to implement a process such as toxicity testing that will ensure that substances are safe before they are introduced into workplaces. Workers, their families and their unions should not
have to bear the burden to demonstrate that these substances cause harm.
We appreciate the opportunity to contribute our opinions on such an important issue, and look forward to your actions in regard to the issues we raise in our submission.
Yours truly,
Leah Casselman
President
The Ontario Public Service Employees Union’s (OPSEU) submission
