2.2.4 Oocupational Safety and Health Act (OSHA) 



With regard to organotins, the focus of the Occupational Safety and Health 

 Act (OSHA) , P.L. 91-596, would be on the health and safety of shipyard and 

 marina workers and "do it yourself" boat owners exposed to organotin com- 

 pounds during application or removal of antifouling paints. Research in 

 the area of worker protection is being conducted by the Navy and by the 

 paint companies. Evaluation of protection strategies to assure the safety 

 of workers during the handling and use of TBT antifouling paints is being 

 conducted by the Navy which includes hull sealing mobile spray paint en- 

 closures, paint spray collection mechanisms and dry dock clean up means. 

 Investigations are also underway by the Navy on disposal alternatives for 

 spent paint film and grit resulting from the removal of spent paint films. 



Worker exposure and TBT body burden studies have been conducted by M&T 

 Chemical Corporation. Alternative worker protection coverings were also 

 investigated in the study which was conducted in response to the Data Call 

 in Notice (Dd) from EPA under FIFRA rather than under OSHA. The OSHA 

 regulations for permissible paint exposure currently exist and no evidence 

 has been uncovered to date that these regulations are being evaluated or 

 revised. Any such revision would be unlikely until the conclusion of the 

 EPA Special Review. 



2.2.5 Resource Conservation and Recovery Act (RCRA) 



As a result of the Clean Air Act, the Clean Water Act and other Federal 

 and State laws respecting public health and the environment, greater 

 amounts of solid waste (in the form of residues) have been created. Simi- 

 larly, inadequate and environmentally unsound disposal practices for the 

 disposal or use of solid waste have created greater amounts of air and 

 water pollution and other environmental and public health risks. The 

 Resource Conservation and Recovery Act (RCRA) , P.L. 91-596, is for wastes 

 classified as hazardous, and applies to all wastes which can cause harm to 

 the environment or human health. With regard to organotin compounds, the 

 waste products are the paint residues (chips, particles, dust, etc.) that 

 arise from removing spent antifouling paint from boat bottoms by sand 

 blasting, scraping, etc. , that contains TBT. At present EPA does not have 

 special disposal requirements for these waste materials, they can go with 

 general solid wastes such a household wastes (trash and garbage) to 

 sanitary landfills. 



2.2.6 Marine Protection, Research and Sanctuaries Act (MPRSA) 



The "Marine Protection, Research, and Sanctuaries Act of 1972" is commonly 

 called the "Ocean Dumping Act", P.L. 92-532. In this Act Congress de- 

 clared that it is the policy of the U.S. to regulate the dumping of all 

 types of materials into ocean waters which would adversely affect human 



II-4 



