Rebuttal.

We agree with a number of points that Mr. Samuels makes. We share his conclusions that worker education is key and that good housekeeping and other simple measures can effectively address wood dust exposures. We also share his optimism that conditions in the studies relied on by IARC are no longer present in today's workplaces. We join Mr. Samuels in recommending that employers voluntarily control wood dust exposure, thereby minimizing any potential risk and enhancing worker comfort.

IARC's findings

We disagree with several of Mr. Samuels' points regarding IARC's findings. First, Mr. Samuels notes that there are a number of studies on humans, but he does not distinguish the results found in studies conducted in Europe vs. studies in North America. The North American studies do not show the same risk as the European studies, upon which IARC primarily based its conclusion. In addition, as Mr. Samuels suggests, the conditions that prevailed when the workers who were studied were first exposed, no longer exist. The different results in North America may be attributable to some of the changed conditions that Mr. Samuels does note.

Mr. Samuels also blurs the distinction among different types of cancer findings. IARC was careful to note that its findings were based on an association between wood dust and only one type of tumor, adenocarcinoma of the nasal and paranasal sinuses, in these studies of past exposure.

We also disagree with the proposition that cancer occurs at any level of exposure. This has not been demonstrated in any of the studies reviewed by IARC. It is an assumption, not science. And while we agree that many of the workplaces in the studies presented other exposures besides wood dust, it is important to note that today we have other OSHA standards, Hazard Communication and other programs that have reduced or eliminated those exposures.

Education: The most important step

We agree wholeheartedly with Mr. Samuels that the education of both workers and management is a key step in addressing wood dust exposure. The IARC finding provides a good occasion for refreshing both workers' and management's awareness of simple precautions that can be taken to promote worker health and comfort. Hazard communication training should inform workers about potential hazards (such as fire hazards and irritation, as well as the IARC finding on cancer) and about how to interpret labels and MSDSs.

Effective wood dust controls

As Mr. Samuels says, good housekeeping, maintenance and work practices are very effective. These simple steps, rather than "high tech" solutions, are often the most effective way to control exposure. And we concur with Mr. Samuels that a good ventilation system reduces both wood dust exposure and other exposures. (Achieving good ventilation may not always be simple, but it is effective.)

Voluntary compliance

As Mr. Samuels further notes, these solutions can be adopted without any regulatory mandate. The Inter-Industry Wood Dust Committee continues to recommend that employers observe the 5 mg/[m.sup.3] (8-hour time-weighted average) standard for wood dust (2.5 mg/[m.sup.3] for western red cedar) that OSHA in 1989 concluded would be appropriate.

In referring to a standard set a generation ago, Mr. Samuels apparently refers to OSHA's 15 mg/[m.sup.3] nuisance dust standard. He overlooks the widespread adherence to the 5 mg/[m.sup.3] level which OSHA set more recently. Industry has voluntarily observed OSHA's 1989 levels, even though OSHA was forced to rescind its overall rulemaking covering many substances. Mr. Samuels also overlooks extensive workplace exposure monitoring data that was submitted to OSHA or is otherwise available.

Conclusion

In sum, we continue to recommend that employers educate their workers and themselves. We agree with Mr. Samuels that sensible and often simple precautions can minimize risk as well as improve worker comfort when working in wood and wood product occupations.