OSHAOSHA’’s NEW CHROMIUM s NEW CHROMIUM VI STANDARD VI STANDARD –– 1910.10261910.1026

WHAT IS CHROMIUM VI?WHAT IS CHROMIUM VI?Hexavalent Chromium Cr(VI) is a Hexavalent Chromium Cr(VI) is a metal particle that can occur metal particle that can occur naturally in rocks but is most naturally in rocks but is most commonly produced by industrial commonly produced by industrial processes.processes.

Strong ability as an oxidizer makes Strong ability as an oxidizer makes it excellent for coatings, corrosion it excellent for coatings, corrosion resistance, etc.resistance, etc.

NEW TWA EXPOSURE LEVELSNEW TWA EXPOSURE LEVELS

Previous PEL Previous PEL –– 52 ug/m52 ug/m33

New PEL New PEL –– 5.0 ug/m5.0 ug/m33

OSHA Action Level OSHA Action Level -- 2.5 ug/m2.5 ug/m33

WHERE IS CHROMIUM VI FOUND?WHERE IS CHROMIUM VI FOUND?

Pigments (red or orange color)Pigments (red or orange color)Paints/CoatingsPaints/CoatingsMetal PlatingMetal PlatingPortland CementPortland CementSteel Mfg Steel Mfg –– Stainless Steel, AlloysStainless Steel, AlloysWelding or Cutting Stainless Steel Welding or Cutting Stainless Steel ––Most common form of exposureMost common form of exposure

WHERE IS CR VI FOUND IN WHERE IS CR VI FOUND IN FOOD PROCESSING INDUSTRY?FOOD PROCESSING INDUSTRY?

Welding Stainless Steel Welding Stainless Steel Stick Electrode WeldingStick Electrode Welding MIG/TIG WeldingMIG/TIG Welding

WHERE IS CR VI FOUND IN FOOD WHERE IS CR VI FOUND IN FOOD PROCESSING INDUSTRY?PROCESSING INDUSTRY?

Plasma Cutting Stainless Steel Plasma Cutting Stainless Steel

HEALTH HAZARDS HEALTH HAZARDS ASSOCIATED WITH CR VI ASSOCIATED WITH CR VI

Lung CancerLung Cancer

Nasal passage ulcerationsNasal passage ulcerations

Skin ulcerationsSkin ulcerations

Allergic and irritant contact dermatitisAllergic and irritant contact dermatitis

HOW DO EXPOSURES HOW DO EXPOSURES OCCUR?OCCUR?

InhalationInhalation -- chromium dust, mist, or fumes chromium dust, mist, or fumes from welding or cutting on stainless steelfrom welding or cutting on stainless steel

Skin ContactSkin Contact –– hands, beards, clothinghands, beards, clothing

IngestionIngestion –– food and beverage food and beverage contaminationcontamination

EXPOSURE DETERMINATIONEXPOSURE DETERMINATIONApproved ACGIH air monitoring methodsApproved ACGIH air monitoring methods

Initial monitoringInitial monitoring< 2.5 ug/m< 2.5 ug/m33 Action Level Action Level –– no action requiredno action required

Periodic monitoringPeriodic monitoring>>2.5 ug/m2.5 ug/m33 Action Level Action Level

–– Periodic monitoring every 6 months Periodic monitoring every 6 months

>>5.0 ug/m5.0 ug/m33 –– PEL PEL Periodic monitoring every 3 monthsPeriodic monitoring every 3 monthsEmployee notification of resultEmployee notification of result

Additional MonitoringAdditional MonitoringRequired if changes are made to process, materials, eq, etc.Required if changes are made to process, materials, eq, etc.

COMPLIANCE METHODS

Engineering/Work Practice Controls

PPE & Respiratory Protection

Hygiene Methods

Housekeeping

Medical Surveillance

ENGINEERING CONTROLSENGINEERING CONTROLSReduce employee exposure < PELReduce employee exposure < PEL

Reduce to lowest level possible then Reduce to lowest level possible then supplement with PPE.supplement with PPE.

Demonstrate no exposures >PEL for 30 or Demonstrate no exposures >PEL for 30 or more days/year then engineering controls not more days/year then engineering controls not needed.needed.

PPE & RESPIRATORY PPE & RESPIRATORY PROTECTIONPROTECTION

Protective clothing and equipmentProtective clothing and equipmentNo cost to employeeNo cost to employeeBased on exposure levelsBased on exposure levels

Respiratory protection is required when:Respiratory protection is required when:Welding outside of regulated areasWelding outside of regulated areasExposure > 5.0 ug/mExposure > 5.0 ug/m33 (PEL)(PEL)Exposure > 5.0 ug/mExposure > 5.0 ug/m33 (PEL) for fewer than 30 (PEL) for fewer than 30 daysdaysEmergenciesEmergencies

HYGIENE METHODSHYGIENE METHODSSpecialized laundry procedures for protective Specialized laundry procedures for protective clothing clothing

Change rooms and storage areasChange rooms and storage areas

Washing facilitiesWashing facilities

Food/drink prohibited in regulated areasFood/drink prohibited in regulated areas

HOUSEKEEPINGHOUSEKEEPING

HEPA filter vacuums required for cleanupHEPA filter vacuums required for cleanup

No compressed air allowed during cleanupNo compressed air allowed during cleanup

Hexavalent waste disposed of in sealed Hexavalent waste disposed of in sealed labeled bagslabeled bags

MEDICAL SURVEILLANCEMEDICAL SURVEILLANCEMedical surveillance required if AL is Medical surveillance required if AL is exceeded 30 days/yearexceeded 30 days/year

Initial evaluation within 30 days of assignmentInitial evaluation within 30 days of assignment

Annual evaluation Annual evaluation

Emergency evaluationEmergency evaluation

Termination of employment evaluationTermination of employment evaluation

SAFETY TRAININGSAFETY TRAINING

Elements of the Hexavalent Chromium Elements of the Hexavalent Chromium StandardStandard

Hazard Communication Hazard Communication

PPE & Respiratory ProtectionPPE & Respiratory Protection

Hygiene Hygiene

HousekeepingHousekeeping

COMPLIANCE DATESCOMPLIANCE DATESEffective Date Effective Date –– February 28, 2006February 28, 2006

Full Compliance Dates:Full Compliance Dates:November 27, 2006 November 27, 2006 -- 20 or more employees20 or more employeesMay 30, 2007 May 30, 2007 –– 19 or fewer employees19 or fewer employees

Engineering Controls Compliance Dates:Engineering Controls Compliance Dates:May 31, 2010 May 31, 2010 –– first standard to definitively state first standard to definitively state Engineering controls to be used by certain dateEngineering controls to be used by certain date

HEXAVALENT CHROMIUMHEXAVALENT CHROMIUM

How we handled 1910.1026!How we handled 1910.1026!

DEFINED ACTION PLAN

Determine whether standard applies

All plants tested via air sampling methods by 11-01-06

Communication of results to employees via training

IH SAMPLINGDetermine employee exposure while welding on stainless steel

Build historical database to show activities below threshold for:

Different types of welding –MIG/TIG/stick/plasmaStated activities on different dates at different plants

IH MONITORING RESULTS21 plants sampled

Sampling activities type: vat repair, equipment repair, etc.

Highest Exposures

Stick Welding

Plasma Cutting

ENGINEERING CONTROLSFixed Exhaust – shop

ENGINEERING CONTROLSPortable exhaust –welding on production floor

Ensure equipment is operating efficiently and employees use it!

RESPIRATORY PROTECTIONRESPIRATORY PROTECTIONTypeType

N95 respiratorN95 respiratorWhen to useWhen to use

Fabrication welding projects outside of Fabrication welding projects outside of designated welding areasdesignated welding areasPlasma Cutting Plasma Cutting

ENGINEERING/WORK ENGINEERING/WORK PRACTICE CONTROLSPRACTICE CONTROLS

Consistent and Proper Use of Local Exhaust Consistent and Proper Use of Local Exhaust Ventilation Controls Ventilation Controls –– snorkels/hoods etc.snorkels/hoods etc.

Discussion PointDiscussion Point

HYGIENE METHODSHYGIENE METHODSFood/drink prohibited in welding areasFood/drink prohibited in welding areas

Personal HygienePersonal HygieneWash Hands and Face After WeldingWash Hands and Face After Welding

HOUSEKEEPINGHOUSEKEEPING

All surfaces must be maintained as free as All surfaces must be maintained as free as practicable of accumulations of welding dust practicable of accumulations of welding dust and particles. and particles.

No compressed air allowed during cleanup. No compressed air allowed during cleanup. Cleaning equipment must be handled in Cleaning equipment must be handled in manner that minimizes reentry of welding manner that minimizes reentry of welding dust and particles.dust and particles.

HEXAVALENT CHROMIUM HEXAVALENT CHROMIUM AWARENESS TRAINING AWARENESS TRAINING

1910.10261910.1026

Wrapping It Up!Does it Apply?Exposure Analysis!Control Methods!Medical Surveillance!Employee Training!

Questions?Questions?