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The Mine Safety and Health Administration's criterion threshold value policy increases miners' risk of pneumoconiosis
Author(s) -
Weeks James L.
Publication year - 2006
Publication title -
american journal of industrial medicine
Language(s) - English
Resource type - Journals
SCImago Journal Rank - 0.7
H-Index - 104
eISSN - 1097-0274
pISSN - 0271-3586
DOI - 10.1002/ajim.20318
Subject(s) - threshold limit value , medicine , limit (mathematics) , confidence interval , pneumoconiosis , value (mathematics) , statistics , environmental health , actuarial science , mathematics , economics , mathematical analysis , pathology
Background The Mine Safety and Health Administration (MSHA) proposes to issue citations for non‐compliance with the exposure limit for respirable coal mine dust when measured exposure exceeds the exposure limit with a “high degree of confidence.” This criterion threshold value (CTV) is derived from the sampling and analytical error of the measurement method. Conceptual Framework This policy is based on a combination of statistical and legal reasoning: the one‐tailed 95% confidence limit of the sampling method, the apparent principle of due process and a standard of proof analogous to “beyond a reasonable doubt.” Critique This policy raises the effective exposure limit, it is contrary to the precautionary principle, it is not a fair sharing of the burden of uncertainty, and it employs an inappropriate standard of proof. Its own advisory committee and NIOSH have advised against this policy. For longwall mining sections, it results in a failure to issue citations for approximately 36% of the measured values that exceed the statutory exposure limit. Discussion Citations for non‐compliance with the respirable dust standard should be issued for any measure exposure that exceeds the exposure limit. Am. J. Ind. Med. © 2006 Wiley‐Liss, Inc.