Benzene and Leukemia: The 0.1 ppm ACGIH Proposed Threshold Limit Value for Benzene

The American Conference of Governmental Industrial Hygienists (ACGIH) has proposed a threshold limit value (TLV) for benzene of 0.1 ppm. Individuals representing the American Petroleum Institute (API)and the Chemical Manufacturers Association (CMA) have argued that 1) the risk assessment by Rinsky .et al. which ACGIH partially relied upon for its proposed TLV overestimates the risk; however, at the exposures levels of interest - (e.g., 0.1 to 1.0 ppm) for establishing a benzene TLV, the Rinsky et al. assessment provides lower estimates of leukemia risk than most others; 2) ACGIH should not use the Dow study for direct observational evidence of leukemia risk associated with low-level benzene exposure because of confounding exposure; however, it is unlikely that confounding exposures played a role in the excess of leukemia demonstrated in the study, and the Dow cohort was exposed to an average benzene concentration of about 5.5 ppm benzene for 7.11 years (31:1.5 ppm-years), while some of the individuals in the study who died from leukemia were exposed to an average of only 1.0 ppm without the opportunity for highpeak exposures; 3) the Occupational Safety and Health Administration (OSHA) established an 8-hour time-weighted average (TWA) of 1.0 ppm in 1987, and there is no new evidence that would justify reducing the TWA below that level; however, the OSHA TWA of 1.0 ppm was based on economic feasibility and the level of excess risk remaining at 1.0 ppm, i.e., 10 excess leukemia deaths per 1000 workers over an occupational lifetime (45 years) according to OSHA's preferred estimate leaves behind I risk considered significant by OSHA. In addition, chromosomal studies among workers and in animals exposed to benzene indicate that low-level exposure, i.e., 1.0 ppm, is associated with elevated Cytogenetic damage. On the basis of adverse health effects data alone, in this author's opinion, it would be poor science and poor public health policy to establish a benzene TLV greater than 0.1 ppm.