September 28, 2007
Presented at a Congressional Staff Briefing on S- Miner and Mine Health Enhancement Act
Respirable Dust Standards
The need to set appropriate dust standards is clear, however, even under the best circumstances, setting a exposure limits is a difficult process. NIOSH currently has sampling methods established for monitoring the respirable dust for both coal mines as well as other metal and non-metal mines (NIOSH methods 7603 and method 7500). These methods are purely physical in nature and do not distinguish between soluble and insoluble dust. It treats all dust as if they presented the same risk for morbidity and mortality. Because different dust materials are not the same, this methodology is fundamentally flawed.
Salt dust, as an example has never been shown to cause any health problems. On the contrary, in Europe, people with asthmatic conditions are often medically prescribed periods of time in working salt mines to breath in fine salt dust as this apparently has the ability to clear pulmonary alveoli and make breathing easier for extended periods.
The NIOSH method that relies exclusively upon solid particle analysis is a major technical flaw assessing the health risk of miners. Salt dust is benign and poses no risks that we know of. Different dusts from other mines will fall somewhere along the continuous health risk line from low to high, yet we do not have the methodology to determine exactly where on the line that risk lies. Aside from physical properties, the biochemical properties must also be determined if we are to get an accurate idea of risk. If these tests are to benefit the health of miners, prior to the implementation of RELs and PELs, the scientifically-determined risks posed by each form of dust must be determined.
Morton Satin
Director, Technical and Regulatory Affairs
Salt Institute
700 North Fairfax St.
Alexandria, VA 22314
Phone: (703) 549-4648
morton@saltinstitute.org
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