U.S. EPA and Workplace Exposure: Air Toxics and Worker Health in Texas Industries

Introduction 

Texas manufacturing, refining, and petrochemical sectors are a significant component of American industry. These production facilities sit at the intersection of worker protection and environmental regulation. The U.S. Environmental Protection Agency (U.S. EPA) air toxics standards are designed to safeguard surrounding neighborhoods but the same chemical contaminants can create risks for facility workers behind the fence line. 

Why is it important?  It protects the workforce that drives operations and production. Industries should look ahead and expect more scrutiny by U.S. EPA and the Occupational Safety and Health Administration (OSHA) in the future. 

U.S. EPA’s Role in Workplace Exposure 

The National Emission Standards for Hazardous Air Pollutants (NESHAP), as administered by the U.S. EPA through the Clean Air Act, mandates the installation of strict controls to lower air emissions of hazardous air pollutants (HAPs) like benzene, chromium, nickel, and manganese. These substances can also cause cancer, brain damage, and other chronic illnesses. NESHAP targets emissions to ensure air quality is preserved, while other regulations like the Toxic Substances Control Act (TSCA), control the handling of chemicals to prevent exposure of workers and safeguard public health in industrial facilities. Overall, these regulations work towards minimizing the occupational and environmental hazards which workers and nearby communities are exposed to daily. 

OSHA’s Perspective: Protection of the Individual Worker 

OSHA’s focus is on protecting the worker rather than the community. They set Permissible Exposure Limits (PELs) for many of the same hazardous substances regulated by U.S. EPA.  

For example: 

• OSHA limits the concentration of benzene a worker can be exposed to within an eight-hour day. 

• OSHA requires engineering controls such as ventilation to be in place if a worker is exposed to a contaminant, such as benzene, above the PEL. Additional controls such as respiratory protection may also be required depending on exposure levels. 

Texas industries frequently have to comply with both standards simultaneously: U.S. EPA with emissions and OSHA with concentrations in the workplace. 

Texas Industry Examples: Where the Overlap Counts 

Refineries and Petrochemicals: U.S. EPA’s Refinery Sector Rule requires fence line monitoring of benzene concentrations. While the rule benefits surrounding neighborhoods, that same data can also be used to identify hazards for refinery workers who are repeatedly exposed to benzene. 

Metal Fabrication and Welding: U.S. EPA emissions standards placed on chromium, nickel, and manganese are interdependent from OSHA limits for welder and maintenance staff exposure. Emissions controls can prevent regulatory risks and maintain workers’ health. 

Chemical Production and Storage: U.S. EPA is extremely strict with volatile organic compound (VOC) emissions regulations. However, the VOCs may also be present in operators’ and maintenance worker locations, which could trigger OSHA compliance with ventilation and air contaminant standards. 

Why You Should Pay Attention 

This is not simply a matter of ‘compliance fatigue’ affecting Environmental, Health, and Safety (EHS) managers and facility owners. It reflects a broader need to recognize that: 

• U.S. EPA compliance can also function as protection for workers. By becoming environmentally compliant, you may be avoiding workplace dangers from occurring in the first place. 

• Regulatory pressure is increasing. U.S. EPA and OSHA have both stepped up enforcement in Texas—especially in refining and manufacturing activities. 

Employees are an organization’s most valuable asset. Employees recognize when companies are investing in keeping them healthy. Effective compliance programs can aid retention, safety culture, and credibility with the community. 

What’s Ahead 

U.S. EPA is accelerating its air toxics programs through risk and technology reviews (RTRs). OSHA, in turn, is under pressure to modernize outdated PELs and enhance workplace chemical safety standards. To the Texas industry, this translates into the regulatory intersection of environmental and occupational regulations being on the rise. 

What should you do now? 

• Verify emissions inventories to both U.S. EPA and OSHA considerations—seeing how air toxics impact not only the environment, but also workers inside the facility.  

• Dual-use compliance data: Fenceline monitoring results, stack tests, and emissions modeling can also inform the development of worker exposure control strategies. 

• Get ahead of changing standards. Don’t wait for an inspection, complaint, or citation to examine your comprehensive responsibilities when it comes to worker exposures. 

How ALL4 Can Help 

At ALL4, our focus is to assist facilities and bridge the regulatory impact gap to the workplace. Whether interpreting benzene fence line data, worker exposure assessments (industrial hygiene), or NESHAP compliance assurance, we partner with facilities to turn regulatory requirements into usable strategies that safeguard communities and employees alike. If you have any questions or would like assistance in evaluating how U.S. EPA air toxics standards intersect with workplace exposures at your facility, contact Kevin Chaplin at kchaplin@all4inc.com or Molly Vaziri at mvaziri@all4inc.com. ALL4 will continue to track updates to additional guidance or rulemaking regarding U.S. EPA and OSHA worker exposure requirements.