Compliance with OSHA Compliance with OSHA Hexavalent ChromiumHexavalent Chromium

StandardStandardStandardStandard

Spring 2007 EEI Safety and Health Spring 2007 EEI Safety and Health Committee ConferenceCommittee Conference

Compliance IssuesCompliance IssuesCompliance IssuesCompliance Issues

Exemption Level and Air MonitoringExemption Level and Air MonitoringRespirators for WeldersRespirators for WeldersppRegulated AreasRegulated AreasProtective ClothingProtective ClothingProtective ClothingProtective ClothingHousekeepingHousekeepingMedical SurveillanceMedical Surveillance

Potential ExposuresPotential ExposuresPotential ExposuresPotential Exposures

Welding and Hot Work Performed on Welding and Hot Work Performed on Chromium Containing AlloysChromium Containing AlloysWelding on mild steel in confined or Welding on mild steel in confined or enclosed spacesenclosed spacesenclosed spacesenclosed spacesCoal Combustion ProductsCoal Combustion ProductsL d Ch t P i tL d Ch t P i tLead Chromate PaintsLead Chromate PaintsCAA LumberCAA Lumber

Exemption Level and Air Exemption Level and Air Monitoring Monitoring

If exposure < 0.5 If exposure < 0.5 µg/mµg/m33 not in scopenot in scopeTargeted jobs that are expected to have Targeted jobs that are expected to have g j pg j plow exposureslow exposuresIf sufficient data then activity is exemptIf sufficient data then activity is exemptIf sufficient data then activity is exemptIf sufficient data then activity is exemptRequires periodic validationRequires periodic validationO l OSHA M th d 215O l OSHA M th d 215Only use OSHA Method 215Only use OSHA Method 215

WeldingWeldingWeldingWelding

RespiratorsRespiratorsAllow Disposable Filtering Face Piece Allow Disposable Filtering Face Piece p gp gRespirator if:Respirator if:

N100 or P100N100 or P100Pass Quantitative Fit TestPass Quantitative Fit TestExample 3M 8233 (N100)Example 3M 8233 (N100)P t ti F tP t ti F t 1010Protection Factor Protection Factor -- 1010

Same Requirements for ContractorsSame Requirements for Contractors

WeldingWeldingWeldingWelding

Regulated AreasRegulated AreasWeld Shops During Active Hot WorkWeld Shops During Active Hot Workp gp gDemarcate to Alert and Inform EmployeesDemarcate to Alert and Inform EmployeesTape and/or SignageTape and/or Signagep g gp g gNot required for Construction ActivitiesNot required for Construction Activities

Protective ClothingProtective ClothingProtective ClothingProtective ClothingNot determined necessary Not determined necessary

Coal Combustion ProductsCoal Combustion ProductsCoal Combustion ProductsCoal Combustion Products

For “Normal” Plant Activities Exempt from For “Normal” Plant Activities Exempt from StandardStandardNo evidence that Skin Contact is a No evidence that Skin Contact is a Health Hazard due to Cr(VI) ContentHealth Hazard due to Cr(VI) Content( )( )Protective Clothing not NecessaryProtective Clothing not Necessary

HousekeepingHousekeepingHousekeepingHousekeeping

Purpose Purpose –– to Ensure that Cr(VI) Containing to Ensure that Cr(VI) Containing Material is ReMaterial is Re--Entrained in the AirEntrained in the AirNot Sure what to Clean up in Welding AreasNot Sure what to Clean up in Welding AreasUse LEV System to Perform CleanupUse LEV System to Perform CleanupIn General, Dust Debris in Coal Powered Plant In General, Dust Debris in Coal Powered Plant is not in Scope of Standard and Housekeeping is not in Scope of Standard and Housekeeping P i i i t T i dP i i i t T i dProvision is not TriggeredProvision is not Triggered

Medical Surveillance and Medical Surveillance and TrainingTraining

Medical Exam Incorporated into our Medical Exam Incorporated into our Annual OSHA Medical Surveillance Annual OSHA Medical Surveillance ProgramProgramTraining Provided by Computer Based Training Provided by Computer Based g y pg y pTrainingTraining

Questions ?Questions ?