Small entity compliance guide for the hexavalent chromium standards

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Small Entity Compliance Guide for the Hexavalent Chromium Standards
OSHA 3320-10N 2006
Employers are responsible for providing a safe and healthful workplace for their employees. OSHA’s role is to assure the safety and health of America’s employees by setting and enforcing standards; pro-viding training, outreach and education; establishing partnerships; and encouraging continual improve-ment in workplace safety and health.
This handbook provides a general overview of a par-ticular topic related to OSHA standards. It does not alter or determine compliance responsibilities in OSHA standards or theOccupational Safety and Health Act of 197.0Because interpretations and en-forcement policy may change over time, you should consult current OSHA administrative interpretations and decisions by the Occupational Safety and Health Review Commission and the Courts for additional guidance on OSHA compliance requirements.
This publication is in the public domain and may be reproduced, fully or partially, without permission. Source credit is requested but not required.
This information is available to sensory impaired individuals upon request. Voice phone: (202) 693-1999; teletypewriter (TTY) number: (877) 889-5627.
Small Entity Compliance Guide for the Hexavalent Chromium Standards
Occupational Safety and Health Administration U.S. Department of Labor
OSHA 3320-10N 2006
Introduction Scope Definitions Permissible Exposure Limit (PEL) Exposure Determination Regulated Areas Methods of Compliance Respiratory Protection Protective Work Clothing and Equipment Hygiene Areas and Practices Housekeeping Medical Surveillance Communication of Cr(VI) Hazards to Employees
3 4 5 6 7 9 9 11 11 13 14 15 16
Cover photo: An employee welds a stainless steel flange using a tungsten inert gas (TIG) welding process (courtesy Bath Iron Works).
Recordkeeping 17 Dates 18 OSHA Assistance 19 Appendix I: OSHA Cr(VI) Standards 22 Appendix II: Industry Operations or Processes Associated with Occupational Exposure to Cr(VI) 40 Appendix III: A. OSHA Area Offices 47 B. OSHA Regional Offices 52 C. States with Approved Occupational Safety and Health Plans 53 D. OSHA Consultation Project Directory 55
Occupational Safety and Health Administration
This guide is intended to help small businesses com- section explains which employers are covered by the ply with the Occupational Safety and Health standards and describes the exceptions to coverage of Administration’s (OSHA) Hexavalent Chromium the standards. The employer may consult a section (Cr(VI)) standards. Employees exposed to Cr(VI) are at that is of particular interest, or may proceed through increased risk of developing serious adverse health the sections in sequence to gain a better understand-effects including lung cancer, asthma and damage toing of the standards in their entirety. A section cdriebs-the nasal passages and skin. This guide describes the ing additional OSHA resources available to assist steps that employers are required to take to protect employers is also included. employees from the hazards associated with exposure The Cr(VI) standards for general industry (29 CFR to Cr(VI). 1910.1026), shipyards (29 CFR 1915.1026), and con-This document provides guidance only, and does struction (29 CFR 1926.1126) are included in Appendix not alter or determine compliance responsibilities, I. Appendix II presents information on industry opera-which are set forth in OSHA standards and the tions and processes associated with exposure to Occupational Safety and Health A.cTt to assist employers in identifying Cr(VI) expo- Cr(VI)his guide does not replace the official Hexavalent Chromium stan- sures in their workplaces. Appendix III contains list-dards, which are contained in Appendix I of this docu- ings of OSHA Area and Regional offices; the address-ment. The employer must refer to the appropriate es and phone numbers of state agencies that adminis-standard to ensure that they are in compliance. ter OSHA-approved State Plans; and the addresses Moreover, because interpretations and enforcement and phone numbers of OSHA Consultation Service policy may change over time, for additional guidance offices. on OSHA compliance requirements the reader should consult current administrative interpretations andWHERE TO GO FOR ADDITIONAL ASSISTANCE decisions by the Occupational Safety and Health For additional assistance in complying with the Cr(VI) Review Commission and the courts. standards, contact the nearest OSHA Area Office. If In 24 states and two territories, OSHA standards you are unable to contact the OSHA Area Office, you are enforced by the state agency responsible for the can contact the appropriate OSHA Regional Office OSHA-approved State Plan. These states and territo- for information or assistance. If you are located in a ries are: Alaska, Arizona, California, Connecticut, state that operates an OSHA-approved State Plan, you  Hawaii, Indiana, Iowa, Kentucky, Maryland, Michigan, may contact the responsible state agency for informa-Minnesota, Nevada, New Jersey, New Mexico, New tion and assistance. See Appendix III for the address-York, North Carolina, Oregon, Puerto Rico, South es and phone numbers of these offices. Carolina, Tennessee, Utah, Vermont, Virgin Islands, The OSHA Consultation Service is another impor- Virginia, Washington, and Wyoming. Connecticut, tant resource for additional assistance. The service is New Jersey, New York, and the Virgin Islands operate largely funded by OSHA and is delivered by state OSHA-approved State Plans limited in scope to state governments using well-trained professional staff. and local government employees. State Plans must ri int sses, the consul-adopt and enforce standards that are either identicalPrimalyended for sofm cahllaerr busine to or at least as effective as the federal standards.tcaotimopnl eptreolgy rsaemp aisr aftree ef rom the gOe StHo Ae imnsplpoeycetiros na enfdf oirst. They must also extend the coverage of their standards The consultation services do not issue citations or to state and local government employees. propose penalties. Additional information on the OSHA Consultation Service, as well as other sources HOW TO USE THIS GUIDEof help from OSHA, can be found in the OSHA assis-The guide is divided into sections that correspond to tance section of the guide. the major provisions of the Cr(VI) standards. Each sec-tion follows the same organization as the correspond-ing paragraph of the standards, providing more detail than the standards to help employers better understand the requirements. For example, the Scope
Scope The standards apply to all occupational exposures to not regulate where another federal agency, such as Cr(VI), with only limited exceptions. OSHA has separate EPA, enforces occupational safety and health standards. standards for Cr(VI) exposures in general industry, ship- The exemption pertains only to the application of yards, and construction. Most of the requirements are pesticides and not to the manufacture of Cr(VI)-con-the same for all sectors. Where there are differences, taining pesticides, which is covered by the standards. they will be explained in this guide. The use of wood treated with pesticides containing Cr(VI) is present in many different compounds that Cr(VI) is also covered by the standards. have a variety of industrial applications. Examples of major industrial uses of Cr(VI) compounds include: chro-PORTLAND CEMENT mate pigments in dyes, paints, inks, and plastics; chro- The standards do not cover exposure to Cr(VI) in port-mates added as anticorrosive agents to paints, primers, land cement. Trace amounts of Cr(VI) are usually pres-and other surface coatings; and chromic acid electroplat-ent in portland cement. However, the concentration of ed onto metal parts to provide a decorative or protectiveCr(VI) is so low that employee exposures to Cr(VI) from coating. Examples of Cr(VI) compounds include: working with portland cement are typically well below • ammonium dichromate ((N4)H2Cr2O7); the action level. • calcium chromate (CaCr4b dluohs erawa eEms eroyplrasd oththattander sO;) • chromium trioxide or chromic acid (C3r;)O ra ealecnip sepotod eeoyexs  tcelpme ot torpdp roltna • lead chromate (PbCr4or fitim lerusopxe elbissiO) ;s a perm OSHA hacmene.t • potassium chromate (2CKrO4); portland cement (see 29 CFR 1910.1000 for general • potassium dichromate (2KCr2O7);55 fructonst .pAoi)nirtarppoonrspee tero pal-cindusrt;y2  9FC R915100.1fo0 shr yaip;sdr 92 1RFC.629 • sodium chromate (N2OCra4 c); or • strontium chromate (SrCr4011. R91 9FCee2 en-or g32 f; anO)dp orivedm su tebed when d and ustiw op hkrowgni-enem(st lart cnde evittnempiuq • zinc chromate (ZnCr4ral eRFC 92 ;yrtsudnishr fo2 155.91 1 .)Os;rdyaipRCF9  2 Employers can consult their suppliers or examine 1926.95 for construction). Adequate washing facilities material safety data sheets (MSDSs) to identify Cr(VI)-must also be provided in all sectors (see 29 CFR containing materials that are present in the workplace. 1910.141(d) for general industry and shipyards; 29 CFR Cr(VI) can also be formed when performing “hot work” 1926.51(f) for construction). In addition, OSHA’s Hazard such as welding on stainless steel, melting chromium Communication standard (29 CFR 1910.1200) requires metal, or heating refractory bricks in kilns. In these situa-training for all employees potentially exposed to haz-tions the chromium is not originally hexavalent, but the ardous chemicals, including portland cement. high temperatures involved in the process result in oxi-dation that converts the chromium to a hexavalent state.WHERE EXPOSURES CANNOT EXCEED 0.5 µg/m3  Appendix II of this document presents a more extensive An exemption from the standards is provided for  description of the industry operations and processes that e e data d are typically associated with Cr(VI) exposure.tehmatp lao ymerast ewrihaol  choanvtea ionibnjgc tcihvromium oerm ao nssptercaitfiincg The Cr(VI) standards do not apply in three situa- process, operation, or activity involving chromium tions: Exposures that occur in the application of pesti- cannot release dusts, fumes, or mists of Cr(VI) in con-cides; exposures to portland cement; and where the centrations at or above 0.5 micrograms per cubic employer has objective data demonstrating that Cr(VI) meter of air (0.5µ /mg3) as an 8-hour time-weighted concentrations cannot exceed 0.5 micrograms per average (TWA) under any expected conditions of use. cubic meter of air as an 8-hour time-weighted average When using the phrase “any expected conditions of under any expected conditions of use. use,” OSHA is referring to any situation that can rea-sonably be foreseen by the employer. The meaning of APPLICATION OF PESTICIDESthe term “objective data” is discussed in the following The standards do not cover exposures to Cr(VI) that section. occur in the application of pesticides. Some Cr(VI)-con- This exception for situations where exposures are taining chemicals, such as chromated copper arsenate not likely to present significant risk to employees (CCA) and acid copper chromate (ACC), are used for allows employers to focus their resources on expo-wood treatment and are regulated by the Environmen- sures of greater occupational health concern. tal Protection Agency (EPA) as pesticides. OSHA does 4 Occupational Safety and Health Administration
Definitions are included in the standards to describe have been obtained during work operations conduct-the meaning of a number of terms used. Some of ed under workplace conditions that closely resemble these terms are further explained as follows: the processes, types of material, control methods, work practices, and environmental conditions in the Action level current operations. Historical monitoring employer’sis defined as an airborne concentration of 2.5 micrograms of Cr(VI) per cubic meter of air (2.5 data must also comply with confidence and accuracy µg/m3) calculated as an 8-hour time-weighted average specified in the exposure determination requirements (TWA) (i.e., employee exposures to Cr(VI) average 2.5 section of the standard. µg/m3over an eight-hour time period). Exposures at or above the action level trigger certain requirementsObjective datameans information, other than em-for exposure monitoring and medical surveillance. ployee monitoring, that demonstrates the expected employee exposure to Cr(VI) associated with a partic-Chromium (VI) [Hexavalent chromium or Cr(VI)]product or material or a specific process, opera-ular means chromium with a valence of positive six, in any tion, or activity. Information that can serve as objec-form or chemical compound in which it occurs. This tive data includes, but is not limited to, air monitoring term includes Cr(VI) in all states of matter, in any solu- data from industry-wide surveys; data collected by a tion or other mixture, even if it is encapsulated by trade association from its members; or calculations another substance. The term also includes Cr(VI) based on the composition or chemical and physical when it is created by an industrial process, such as properties of a material. Use of objective data is dis-when welding on stainless steel generates Cr(VI) cussed in the exposure determination section under fume. the “performance-oriented” option.
Emergencymeans any occurrence that results, or isPhysician or other licensed health care professional likely to result, in an uncontrolled release of Cr(VI).[PLHCP]is an individual whose legally permitted Such an occurrence may be the result of equipment scope of practice (i.e., license, registration, or certifica-failure, rupture of containers, or failure of control tion) allows him or her to independently provide or be equipment. To constitute an emergency, the exposure delegated the responsibility to provide some or all of must be unexpected and significant. If an incidental the particular health care services required by the release of Cr(VI) can be controlled at the time of the medical surveillance provisions of this standard. release by employees in the immediate release area, or by maintenance personnel, it is not considered anRegulated areameans an area, demarcated by the emergency. For example, a minor spill that can be employer, where an employee’s exposure to airborne cleaned up by an employee with minimal airborne or concentrations of Cr(VI) exceeds, or can reasonably be dermal exposure to Cr(VI) would not be considered an expected to exceed, the PEL. The employer has the emergency. Instances that do constitute an emer- responsibility to determine and demarcate the bound-gency trigger requirements for medical surveillance aries of the regulated area. OSHA has not included and the use of respiratory protection. requirements for regulated areas in construction or shipyard workplaces. Employee exposuremeans exposure to Cr(VI) that would occur if the employee were not using a respira-tor. Thus, exposure levels should be determined out-side of the respirator for those employees wearing a respirator.
Historical monitoring datai s data from Cr(VI) expo-sure monitoring conducted prior to May 30, 2006 (the effective date of this Cr(VI) standard). In order for an employer to rely upon historical data, the data must
The standards establish an 8-hour time-weighted average exposure limit of 5 micrograms of Cr(VI) per cubic meter of air (5 µg/3m). This means that over the course of any 8-hour work shift, the average exposure to Cr(VI) cannot exceed 5 µg/3m.
Calculation of Time-Weighted Average Exposures
Both the PEL and the action level are expressed as time-weighted average (TWA) exposures. TWA measurements account for variable exposure levels over the course of a work shift, averaging peri-ods of higher and lower exposures. The TWA exposure for an 8-hour work shift is computed using a simple formula:
TWA = (CaTa+CbTb+. . .CnTn)÷8 Where: TWA is the time-weighted average exposure for the work shift; C is the concentration during any period of time (T) where the concentration remains constant; and T is the duration in hours of the exposure at the concentration (C).
For example, assume that an employee is subject to the following exposure to Cr(VI):
Two hours exposure at 10 µg/3m Two hours exposure at 5 µg/3m Four hours exposure at 1 µg/3m
Substituting this information in the formula, we have:
(2x10 +x524 + x1)÷8 = 4.25 µg3/m
Since 4.25 µg/3mis more than 2.5 µg/3m, the action level has been exceeded. However, as 4.25 µg/m3is less than 5 µg/3m, the PEL has not been exceeded.
Occupational Safety and Health Administration
Exposure Determination Employers must determine the 8-hour time-weighted Requirements for periodic monitoring depend on average exposure to Cr(VI) for each employeep oesxedthe results of initial monitoring. If the initial monitor-to Cr(VI). This assessment allows the indicates that employee exposures are below the ingmployer to identify and prevent overexposures; collect exposure action level, no further monitoring is required unless data so that proper control methods can be selected; changes in the workplace may result in new or addi-and evaluate the effectiveness of those methods. An tional exposures. If the initial monitoring reveals em-accurate exposure determination also provides impor- ployee exposures to be at or above the action level tant information concerning occupaotnial Cr(VI) expo-but at or below the PEL, the employer must perform sures to the physician or othelircensed health care periodic monitoring at least every six months. If the professional who performs medical examinations on initial monitoring reveals employee exposures to be employees. Employers can choose between two above the PEL, the employer must perform periodic options for performing exposure determinations: a monitoring at least every three months. scheduled monitoring option, or a performance-ori- If periodic monitoring results indicate that employ-ented option. In addition, employers must comply ee exposures have fallen below the action level, and with certain requirements regarding employee notifi- those results are confirmed by consecutive measure-cation of the results of the exposure determination, ments taken at least seven days apart, the employer accuracy of measurement methods, and observation may discontinue monitoring for those employees of monitoring. whose exposures are represented by such monitor-ing. Similarly, after initial monitoring shows expo-SCHEDULED MONITORING OPTIONsures above the PEL, if periodic measurements indi-Employers who select the scheduled monitoring cate that exposures are at or below the PEL but are at option must conduct initial exposure monitoring to or above the action level, the employer may reduce determine employee exposure to Cr(VI). This monitor- the frequency of the monitoring to at least every six ing is performed by sampling the air within the months. employee’s breathing zone. Monitoring must repre- Employers must perform additional monitoring sent the employee’s time-weighted average exposure when workplace changes may result in new or addi-to airborne Cr(VI) over an 8-hour workday. tional exposures to Cr(VI). These changes include Employers must accurately characterize the expo- alterations in the production process, raw materials, sure to Cr(VI) for each employee. In some cases, this equipment, personnel, work practices, or control will entail monitoring all exposed employees. In other methods used in the workplace. For example, if an cases, monitoring “representative” employees is suffi- employer has conducted monitoring for an electro-cient. Representative exposure sampling is permitted plating operation while using fume suppressants, and when a number of employees perform essentially the the use of fume suppressants is discontinued, then same job under the same conditions. For such situa- additional monitoring would be necessary to deter-tions, it may be sufficient to monitor a fraction of mine employee exposures under the modified condi-these employees in order to obtain data that are tions. In addition, there may be other situations which “representative” ofthe remaining employees. can result in new or additional exposures to Cr(VI) Representative personal sampling for employees which are unique to an employer’s work situation. For engaged in similar work involving similar Cr(VI) expo- instance, a welder may move from an open, outdoor sures is achieved by monitoring the employee(s) rea- location to an enclosed or confined space. Even sonably expected to have the highest Cr(VI) expo- though the task performed and materials used may sures. For example, this may involve monitoring the remain constant, the changed environment could rea-Cr(VI) exposure of the employee closest to an expo- sonably be expected to result in higher exposures to sure source. This exposure result may then be attri- Cr(VI). In these special situations, OSHA requires the buted to the remaining employees in the group. employer to perform additional monitoring whenever Monitoring must accurately characterize exposures on the employer has any reason to believe that a change each shift, for each job classification, and in each work has occurred which may result in new or additional area. exposures to Cr(VI). Additional monitoring is not S M A L L E N T I T Y C O M P L I A N C E G U I D E F O R T H E7 H E X A V A L E N T C H R O M I U M S T A N D A R D S
required simply because a change has been made, if employee’s exposure to or below the PEL (e.g., use of the change is not reasonably expected to result in respirators or the engineering controls that will be new or additional exposures to Cr(VI). For example, implemented). monitoring may be conducted in an establishment The general industry standard requires employers when welding was performed on steel with 15% to notify employees within 15 working days from chromium content. If the establishment switches to a when monitoring results are received (or when the steel with 10% chromium content without changing exposure determination is made for those following any other aspect of the work operation, then addition- the performance-oriented option). In construction and al exposures to Cr(VI) would not reasonably be shipyards, employers must notify each affected expected, and additional monitoring would not be employee as soon as possible but not more than 5 required. working days later. A shorter time period for notifica-tion is mandated in construction and shipyards PERFORMANCE-ORIENTED OPTIONbecause of the often short duration of operations and The performance-oriented option allows the employer employment in particular locations in these sectors. to determine the 8-hour TWA exposure for each employee on the basis of any combination of air mon-ACCURACY OF MEASUREMENTS itoring data (i.e., data obtained from initial and period-The standard does not specify a particular method of ic Cr(VI) monitoring), historical monitoring data, or sampling and analysis that must be used to measure objective data sufficient to accurately characterize employee exposures to Cr(VI). The employer may use employee exposure to Cr(VI). This option is intended any method as long as it meets certain accuracy to allow employers flexibility in assessing the Cr(VI) requirements. Many laboratories presently have meth-exposures of their employees. Where the employer ods to measure Cr(VI) at the action level with at least elects to follow this option, the exposure determina- the required degree of accuracy. One example of an tion must be performed prior to the time the work acceptable method of monitoring and analysis is operation commences and must provide the same OSHA method ID215, which is a fully validated analyt-degree of assurance that employee exposures have ical method used by OSHA to measure Cr(VI) expo-been correctly characterized as air monitoring would. sures. The employer is expected to reevaluate employee exposures when there is any change in the productionOBSERVATION OF MONITORING process, raw materials, equipment, personnel, work practices, or control methods that may result in new Employers must provide affected employees or their or additional exposures to Cr(VI). adnesyi gmnoatnietdo rrienpgr eosf eentmaptilvoeyse ea ne xoppopsourtrue ntitoy  Ctro( VoIb)serve required by this standard. When observation of moni-EMPLOYEE NOTIFICATIONtoring requires entry into an area where the use of Employers must notify each affected employee if the protective clothing or equipment is required, the exposure determination indicates that their exposure employer must provide the observer with these items, to Cr(VI) exceeds the PEL. “Affected employees” are and assure that the observer uses them and complies all employees considered to be exposed above the with all other safety and health procedures. PEL, including those employees who are not actually subject to personal monitoring, but who are repre-sented by an employee who is sampled. Affected employees also include employees whose exposures have been deemed to be above the PEL on the basis of historical orobjective data. The employer must either notifyeach affected employee in writing or post the determination results in an appropriate loca-tion accessible to all affected employees (e.g., a bul-letin board accessible to all employees). In addition, the written notification must describe the corrective action(s) being taken by the employer to reduce the
Occupational Safety and Health Administration
Regulated Areas
The Cr(VI) standard for general industry includes lishes and alerts employees of the boundaries of the requirements for regulated areas. The purpose of a regulated area. The standard does not specify how regulated area is to ensure that employees are aware employers are to demarcate regulated areas. Warning of the presence of Cr(VI) at levels above the PEL, and signs, barricades, lines and textured flooring, or other to limit Cr(VI) exposure to as few employees as possi- methods may be appropriate. Whatever methods are ble by requiring the employer to mark areas where chosen must effectively warn employees not to enter employee exposure is likely to exceed the PEL and the area unless they are authorized, and then only if limit access to these areas to authorized persons. The they are using proper protective equipment, such as standard includes provisions for establishment of reg- respirators. ulated areas; demarcation of regulated areas; and access to regulated areas. The requirements are notACCESS included in the standards for construction or ship- Employers must limit access to regulated areas. The ycaarbdles  ibn etchaeussee  etnhveiyr oanrem ceontnss.idered generally impracti-only individuals allowed access to a regulated area are: Persons authorized by the employer andq uriered ESTABLISHMENTby work duties to be present in the regulated Employers must establish regulated areas wherever area (this may include maintenance and repair an employee’s exposure to Cr(VI) is, or can reasonably personnel, management, quality control engi-be expected to be, in excess of the PEL. Information neers, or other personnel if job duties require obtained during the exposure determination can be their presence in the regulated area); used along with reasonable judgment to determine • Any person entering the area as a designated where regulated areas are required, and to establish representative of employees to observe Cr(VI) the boundaries of regulated areas. exposure monitoring; or • Any person authorized by thOepuccioatlna DEMARCATIONSafety and Health Actor regulations issued under it to be in a regulated area (e.g., OSHA oRfe tghuel atweodr kaprleaacse  imn uas t mbaen dniesrt itnhgauti sahdeedq furaotmel yt hees traebs-tenforcement personnel).
Methods of Compliance
Employers must use engineering and work practice controls as the primary means to reduce and maintain employee exposures to Cr(VI) to or below the PEL, unless the employer can demonstrate that such con-trol measures are not feasible. Engineering controls include: • Substitution (e.g., using a less toxic material instead of Cr(VI), or substituting a process that results in lower exposures for another type of process that results in higher exposures);
• Isolation (e.g., enclosing the source of exposure, or placing a barrier between employees and the source of exposure); and • Ventilation (e.g., local exhaust systems that cap-ture airborne Cr(VI) near its source and remove it from the workplace, or general ventilation that dilutes Cr(VI) concentrations by circulating large quantities of air – a local exhaust system is gen-erally preferred to dilution ventilation because it provides a cleaner and healthier work environ-ment).
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