OSHA supplementary standards

["Leif E. Peterson, Ph.D." <peterson@bcm.tmc.edu>]

Let me spell out what NASA does for astronaut limits.  There is a section of
29 CFR called "supplementary standards", which states something to the
effect that: "we can't meet the 5 cSv per year limit, so we want higher
limits."  To get the waiver, the Director of you agency/airline writes a
letter to the Secretary or undersecretary of Labor which states that:

1) your activities are needed to fulfil the mission of your institution.

2). we can't meet the 5 cSv limits since this impact operational objectives.

3). you need something like NCRP report 98 to say that "the NCRP has fully
investigated health effects at higher levels of exposure and our agency
concurs with their findings and recommendations.  For an airline, review the
literature. 

4).  Please accept this application for a waiver to use higher limits under
the Supplementary Standards.

If approved by Labor, you will get a short letter back that says something like:

"Your application for the proposed limits under Supplementary Standards" has
been accepted.  We are glad you are concerned with the health and well being
of your employees."

BTW, OSHA is the correct agency to go to when it does not appear that an
actitivity is under NRC, DoD, DoE, EPA, (etc.) or state guidance.  If a
"job" is involved, then you can guarantee that OSHA has some kind of purview.

-LP