working with hexavalent chromium (chromium vi). meeting training requirements preview this program...

Working with Working with Hexavalent Chromium Hexavalent Chromium

(Chromium VI)(Chromium VI)

Meeting Training RequirementsMeeting Training Requirements

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Occupational Occupational Exposure to Exposure to Hexavalent Hexavalent ChromiumChromium

(Chromium VI)(Chromium VI)

What This Training Will CoverWhat This Training Will Cover

• Characteristics of hexavalent chromium

• Health hazards of hexavalent chromium

• How you can be exposed to hexavalent chromium

• Control of your hexavalent chromium exposure

• Medical surveillance

• OSHA rules on hexavalent chromium

Hexavalent Chromium StandardHexavalent Chromium Standard

ExceptionsExceptions Agricultural operationsAgricultural operations

Exposures that occur in the application of pesticidesExposures that occur in the application of pesticides

Exposures to portland cementExposures to portland cement

Objective data demonstrating that hexavalent chromium cannot Objective data demonstrating that hexavalent chromium cannot be released in concentrations at or above 0.5 be released in concentrations at or above 0.5 µµg/mg/m33 as an 8- as an 8-hour time-weighted average (TWAhour time-weighted average (TWA88) under any condition of use) under any condition of use

Covers all occupational exposures to Hexavalent Chromium

Permissible Exposure Limit Permissible Exposure Limit (PEL)(PEL)

Exposure DeterminationExposure Determination

Regulated areas*Regulated areas*

Methods of ComplianceMethods of Compliance

Respiratory ProtectionRespiratory Protection

Protective Work Clothing and Protective Work Clothing and EquipmentEquipment

Hygiene Areas and Hygiene Areas and PracticesPractices

Housekeeping*Housekeeping*

Medical SurveillanceMedical Surveillance

Communication of Communication of Hazards Hazards

RecordkeepingRecordkeeping

What Does the Standard What Does the Standard Cover?Cover?

*General industry only

What is Hexavalent Chromium?What is Hexavalent Chromium?

Chromium VI or Cr(VI)Chromium VI or Cr(VI)

Toxic form of chromium metal, Toxic form of chromium metal, generally man-madegenerally man-made

Used in many industrial Used in many industrial applications, primarily for its applications, primarily for its anti-corrosive propertiesanti-corrosive properties

Can be created during certain “hot” Can be created during certain “hot” work processes (such as welding and grinding work processes (such as welding and grinding metals) where the original form of chromium metals) where the original form of chromium was not hexavalentwas not hexavalent

Types of Hexavalent Chromium Chemicals Types of Hexavalent Chromium Chemicals

pigments in paints, inks, pigments in paints, inks, and plasticsand plastics

lead chromate (chrome yellow, chrome green, lead chromate (chrome yellow, chrome green, molybdenum orange) (Pbmolybdenum orange) (PbCrOCrO44)) zinc chromate (Znzinc chromate (ZnCrOCrO44))

barium chromate barium chromate calcium chromate calcium chromate potassium potassium dichromate dichromate sodium chromate sodium chromate

anti-corrosion coatings anti-corrosion coatings (chrome plating, spray (chrome plating, spray coatings) coatings)

chromic trioxide (chromic acid) chromic trioxide (chromic acid) zinc chromate (Znzinc chromate (ZnCrOCrO44))

barium chromate (Babarium chromate (BaCrOCrO44)) calcium chromate calcium chromate sodium sodium

chromate chromate strontium chromate (strontium chromate (SrCrOSrCrO44))

stainless steel, stainless steel, galvanized steelgalvanized steel

hexavalent chromium (when cast, welded, grinded or hexavalent chromium (when cast, welded, grinded or torch cut) torch cut)

textile dyestextile dyesammonium dichromate ammonium dichromate ((NH((NH44)2Cr)2Cr22OO77)) potassium potassium

chromate chromate potassium dichromate potassium dichromate sodium chromate sodium chromate

wood preservationwood preservation chromium trioxidechromium trioxide

leather tanningleather tanning ammonium dichromate ammonium dichromate ((NH((NH44)2Cr)2Cr22OO77))

Sources of Occupational ExposureSources of Occupational Exposure

Chrome plating/ElectroplatingChrome plating/Electroplating

Welding or grinding on chrome-Welding or grinding on chrome-containing metals (stainless steel, containing metals (stainless steel, galvanized steel), or Cr (VI) galvanized steel), or Cr (VI) painted surfacespainted surfaces

PaintingPainting AerospaceAerospace Auto body repairAuto body repair

Chromate pigmentChromate pigmentand chemical productionand chemical production

Major operations/job tasks resulting in potential Cr(VI) exposure:


Chrome Plating Bath(a significant source of Cr VI)

Chromium dye and catalyst Chromium dye and catalyst productionproduction

Glass manufacturingGlass manufacturing

Plastic colorant productionPlastic colorant production

ConstructionConstruction Traffic paintingTraffic painting Refractory brick restorationRefractory brick restoration Paint removal from bridgesPaint removal from bridges

Major operations/job tasks resulting in potential Cr(VI) exposure:


Bridgework

(cont.)

Inhalation of dusts, mists, or Inhalation of dusts, mists, or fumes created during processes fumes created during processes involving the use of Cr(VI) involving the use of Cr(VI) compounds or hot processes compounds or hot processes that cause the formation of that cause the formation of Cr(VI)Cr(VI)

Routes of ExposureRoutes of ExposureHow Can Hexavalent Chromium Enter the How Can Hexavalent Chromium Enter the Body?Body?

Eye or skin contact with Eye or skin contact with powder, dusts, or liquids powder, dusts, or liquids containing Cr(VI)containing Cr(VI)

Major Health Effects Due to Major Health Effects Due to Significant OverexposureSignificant Overexposure

Lung cancerLung cancer

Nasal septum Nasal septum ulcerations and ulcerations and perforationsperforations

AsthmaAsthma

Permanent perforation of the nasal septum from continuous exposure performing chrome plating of small appliance parts

Major Health Effects Due to Major Health Effects Due to Significant Overexposure Significant Overexposure

Skin ulcersSkin ulcers

Allergic and Allergic and irritant contact irritant contact dermatitisdermatitis“Chrome hole” on finger. Can also

occur on hands or forearms, and on bottom surfaces of feet from chrome salts permeating through boots or shoes.

The following operations/work areas where you may be exposed to Cr(VI) are:

[List the operations/employee work areas where Cr(VI) is present.]

• Welding or Grinding on Stainless Steel or Other Base Metals with High Chrome Content

•

•

•

Chromium VI ExposureChromium VI Exposure

Permissible Exposure LimitPermissible Exposure Limit

5 µg/m3 TWA8

in the air

2.5 µg/m3 TWA8

in the air

Permissible Exposure Limit

(PEL)

8-hour time-weighted average exposure limit (TWA8)

Action Level (AL)

0.5 of PEL

Scheduled monitoring Scheduled monitoring methodmethod

Performance-oriented Performance-oriented monitoring methodmonitoring method

Two options for determining employee exposures:


Exposure DeterminationExposure Determination• Scheduled Monitoring

If initial Cr(VI) concentration is:If initial Cr(VI) concentration is:

− Below the ALBelow the AL Discontinue monitoringDiscontinue monitoring

− At or above the ALAt or above the AL

Monitor every 6 monthsMonitor every 6 monthsCan discontinue monitoring if Can discontinue monitoring if exposures are below AL and exposures are below AL and confirmedconfirmed

− Above the PELAbove the PEL

Monitor every 3 monthsMonitor every 3 monthsCan discontinue monitoring if Can discontinue monitoring if exposures are below AL and exposures are below AL and confirmedconfirmed

1919

Exposure DeterminationExposure DeterminationA list of “variables” to consider while collecting airmonitoring samples during welding and grindingoperations includes:

• Actual time spent welding (i.e., 2 hours, 3.5 hours, 45 minutes, etc.)

• The item involved in the weld (i.e., rectangular duct, tank, piping, etc.)

• The size of the item / piece involved in the process• Size of the welding room / booth / space • Description of general / natural ventilation in the area

(the number of air changes)• Description of point of operation ventilation in the area• Ambient temperature and relative humidity• Workers head/face orientation to point of operation

2020

Exposure DeterminationExposure DeterminationA list of “variables” to consider while collecting airmonitoring samples during welding and grindingoperations includes:

• Type of welding being conducted, for example: Shielded Metal Arc Welding (SMAW), Gas Tungsten Arc Welding (GTAW), Gas Metal Arc Welding (GMAW) • Is a shielding gas used? If so, what type (i.e., argon, helium, etc.)• Type of base metal (i.e., stainless steel, mild steel, galvanized steel, etc.)• Reported ingredients of the base metal (i.e., x% chrome, x% nickel, x% iron, etc.)• Thickness of the base metal (i.e., 18 ga., 10 ga., etc.)• Type of welding electrode / rod / wire• Type of personal protective equipment worn by the welder (i.e., respirator, helmet, gloves, etc.)


Exposures determined using any Exposures determined using any combination of air monitoring data, historical combination of air monitoring data, historical monitoring data, or objective data sufficient monitoring data, or objective data sufficient to accurately characterize employee to accurately characterize employee exposure to Cr(VI)exposure to Cr(VI)

No fixed schedule for performing periodic No fixed schedule for performing periodic monitoringmonitoring

May be difficult to match air monitoring May be difficult to match air monitoring results due to the many variables involvedresults due to the many variables involved

• Performance-oriented Monitoring

Affected employees must be notified when Affected employees must be notified when exposures exceed the PELexposures exceed the PEL

Methods used for air monitoring and analysis must Methods used for air monitoring and analysis must be sufficiently accuratebe sufficiently accurate

Employees or their representatives must be allowed Employees or their representatives must be allowed to observe Cr(VI) monitoringto observe Cr(VI) monitoring

Exposure DeterminationExposure DeterminationGeneral Requirements

When exposure determination results are above the TWA8 permissible exposure limit (PEL), [insert your company’s name] must provide written notification of all the following within [15 or 5; see notes] business days:

Notification of ResultsNotification of Results

• Provide results of exposure determination

• Describe corrective actions being taken to reduce exposure to or below the PEL

These are the results of our employee exposure determination using [state which option/method you used]:


[List results here.]

Regulated AreasRegulated Areas

Regulated Areas for General Industry only (not Construction)Regulated Areas for General Industry only (not Construction)

Regulated areas are clearly markedRegulated areas are clearly marked

Access is limited to Access is limited to

authorized persons required by work duties to be thereauthorized persons required by work duties to be there

designated representatives of employees for the purpose of designated representatives of employees for the purpose of observing monitoring proceduresobserving monitoring procedures

persons authorized by OSHA or other regulations to be therepersons authorized by OSHA or other regulations to be there

Areas where exposures exceed or can be Areas where exposures exceed or can be reasonably expected to exceed the PELreasonably expected to exceed the PEL

Regulated AreasRegulated Areas

[List all areas and specific locations]

•

•

•

[Describe policies/procedures for entering and exiting regulated areas]

These are the Regulated Areas at [insert your company’s name]:

1.1. Painting aircraft or large Painting aircraft or large aircraft parts:aircraft parts:

use engineering and use engineering and work practice controls to work practice controls to achieve 25 achieve 25 µµg/mg/m3 3 and and

supplement with respirators to supplement with respirators to achieve the PEL achieve the PEL

Establish engineering and work practice controls as the Establish engineering and work practice controls as the primary means of achieving the PEL/reducing exposures.primary means of achieving the PEL/reducing exposures.


Exceptions:Exceptions:


2.2. Tasks or operations that do not result Tasks or operations that do not result in exposures above the PEL for 30 or in exposures above the PEL for 30 or more days per year:more days per year:

Use of respirators alone is Use of respirators alone is allowed to achieve the PELallowed to achieve the PEL

• Prohibit job rotation to achieve compliance with the PEL

We use the following controls to reduce the amount of chromium VI you are exposed to:

[List controls here]

•

•

•

•

Control Measures to Reduce Control Measures to Reduce ExposuresExposures

[List worksite-specific work practices that reduce or control exposures here.]

•

•

•

•

Required Work PracticesRequired Work Practices

We follow these work practices:

Periods necessary to install or implement Periods necessary to install or implement feasible engineering and work practice controlsfeasible engineering and work practice controls

Maintenance or repair operations where Maintenance or repair operations where engineering and work practice controls are not feasibleengineering and work practice controls are not feasible

Operations where all feasible controls have been used and exposures Operations where all feasible controls have been used and exposures are still above the PELare still above the PEL

Operations where exposures do not exceed the PEL for 30 or more Operations where exposures do not exceed the PEL for 30 or more days per year and the employer has elected not to implement days per year and the employer has elected not to implement engineering and work practice controls to achieve the PELengineering and work practice controls to achieve the PEL

EmergenciesEmergencies

When will you need a respirator?


When respirator use is required, a respirator program will be followed that meets the appropriate OSHA or state-OSHA respiratory protection standards.


[List or describe what respirators must be used under what conditions, job tasks, or locations here]

Type of Respirator You Will UseType of Respirator You Will Use

Use where a hazard is present or is Use where a hazard is present or is likely to be present from skin or eye likely to be present from skin or eye contact with Cr(VI)contact with Cr(VI)

Remove all PPE and equipment Remove all PPE and equipment when work shift or task is completedwhen work shift or task is completed

Personal Protective Equipment Personal Protective Equipment (PPE)(PPE)

Protective Work Clothing and Equipment

[Insert your company’s name] will provide your PPE at no cost.


Do not remove Cr(VI) from PPE by blowing, shaking, or Do not remove Cr(VI) from PPE by blowing, shaking, or any other means that disperses into the air or onto the any other means that disperses into the air or onto the bodybody

Do not remove contaminated PPE from the workplace, Do not remove contaminated PPE from the workplace, except for laundering, disposal, etc. by employees with except for laundering, disposal, etc. by employees with such job dutiessuch job duties

Clean and replace Cr(VI)-contaminated clothing and Clean and replace Cr(VI)-contaminated clothing and equipment as neededequipment as needed

Protective Work Clothing and Equipment (cont.)


Store and transport contaminated Store and transport contaminated PPE in sealed, impermeable bags PPE in sealed, impermeable bags or closed containers. Make sure or closed containers. Make sure they are properly labeled. they are properly labeled.

Inform any person who launders/Inform any person who launders/cleans PPE of the potentially cleans PPE of the potentially harmful effects of Cr(VI) exposure harmful effects of Cr(VI) exposure

When laundering:When laundering:

– – Minimize skin or eye contact with Cr(VI)Minimize skin or eye contact with Cr(VI)

– – Prevent the release of airborne levels in excess of the PELPrevent the release of airborne levels in excess of the PEL

Laundering and Cleaning of PPE

Hygiene Areas and PracticesHygiene Areas and Practices

Change roomsChange rooms – separate storage facilities for PPE and street clothes – separate storage facilities for PPE and street clothes

Washing facilitiesWashing facilities

Wash hands and face:Wash hands and face:

at the end of the work shiftat the end of the work shift

prior to eating, drinking, smoking, prior to eating, drinking, smoking, chewing tobacco or gum, applying chewing tobacco or gum, applying cosmetics, or using the toiletcosmetics, or using the toilet

When employee exposure is at/above the PEL:When employee exposure is at/above the PEL:

Use these facilities when necessary!

Hygiene Areas and Practices Hygiene Areas and Practices (cont.)(cont.)

DO NOT:DO NOT:

Enter eating and drinking areas with PPEEnter eating and drinking areas with PPE

Eat, drink, smoke, chew tobacco or gum, or Eat, drink, smoke, chew tobacco or gum, or apply cosmetics in areas where skin or eye apply cosmetics in areas where skin or eye contact with Cr(VI) occurscontact with Cr(VI) occurs

Carry or store the products associated with the above activities in areas Carry or store the products associated with the above activities in areas where skin or eye contact with Cr(VI) occurswhere skin or eye contact with Cr(VI) occurs

Eating and Drinking Areas and SurfacesEating and Drinking Areas and Surfaces

– – maintained as free as practicable of Cr(VI)maintained as free as practicable of Cr(VI)

Keep all surfaces as free as practicable of accumulations of Keep all surfaces as free as practicable of accumulations of Cr(VI)Cr(VI)

Promptly clean up all spills and releases of Cr(VI)-Promptly clean up all spills and releases of Cr(VI)-containing materialscontaining materials

Use HEPA vacuums or other methods that minimize Use HEPA vacuums or other methods that minimize exposure to Cr(VI) exposure to Cr(VI)

Dispose of Cr(VI)-contaminated waste in labeled, Dispose of Cr(VI)-contaminated waste in labeled, impermeable bags/containers impermeable bags/containers

HousekeepingHousekeeping

Medical SurveillanceMedical Surveillance

Exposed at or above the action level Exposed at or above the action level (2.5 (2.5 µµg/mg/m33) for 30 or more days per year ) for 30 or more days per year

Experiencing signs or symptoms of Cr(VI) Experiencing signs or symptoms of Cr(VI) exposureexposure

Exposed in an emergencyExposed in an emergency

Which Employees Must Be Provided Which Employees Must Be Provided Medical Surveillance?Medical Surveillance?

Medical Surveillance Medical Surveillance (cont.)(cont.)

• Provided by or under the supervision Provided by or under the supervision of a physician or other licensed health of a physician or other licensed health care professional (PLHCP)care professional (PLHCP)

• Provided at no cost to employee and Provided at no cost to employee and at a reasonable place and timeat a reasonable place and time

Medical Surveillance Medical Surveillance (cont.)(cont.)

Determine if an individual can be exposed to the Cr(VI) Determine if an individual can be exposed to the Cr(VI) present in their workplace without experiencing adverse present in their workplace without experiencing adverse health effectshealth effects

Identify Cr(VI)-related adverse health effects so that Identify Cr(VI)-related adverse health effects so that appropriate intervention measures can be takenappropriate intervention measures can be taken

Determine the employee’s Determine the employee’s fitness to use PPE, such as fitness to use PPE, such as respiratorsrespirators

Medical and work historyMedical and work history

Cr(VI) exposure (past, present, future)Cr(VI) exposure (past, present, future) History of respiratory system dysfunctionHistory of respiratory system dysfunction History of asthma, dermatitis, skin History of asthma, dermatitis, skin

ulceration or nasal system perforationulceration or nasal system perforation Smoking status and historySmoking status and history

Physical examination, with emphasis on the respiratory Physical examination, with emphasis on the respiratory tract and skintract and skin

Any additional tests deemed appropriate by the PLHCPAny additional tests deemed appropriate by the PLHCP

Medical ExaminationsMedical Examinations

Within 30 days after initial assignment and annually Within 30 days after initial assignment and annually thereafterthereafter

Within 30 days after a PLCHP recommends additional Within 30 days after a PLCHP recommends additional examinationsexaminations

When employees shows signs or symptoms of Cr(VI) When employees shows signs or symptoms of Cr(VI) exposureexposure

Within 30 days after exposure during an emergencyWithin 30 days after exposure during an emergency

At the termination of employmentAt the termination of employment

Medical ExaminationsMedical Examinations

Copy of the Federal OSHA (or state plan OSHA) Hexavalent Copy of the Federal OSHA (or state plan OSHA) Hexavalent Chromium standard Chromium standard

Description of employee's former, current, and anticipated Description of employee's former, current, and anticipated duties related to occupational exposure to Cr(VI)duties related to occupational exposure to Cr(VI)

Employee's former, current, and anticipated levels of Employee's former, current, and anticipated levels of occupational exposure to Cr(VI)occupational exposure to Cr(VI)

Description of any PPE used or to be used by the employeeDescription of any PPE used or to be used by the employee

Information from records of previous employment-related Information from records of previous employment-related medical examinationsmedical examinations

Information Provided to PLCHPInformation Provided to PLCHP

Provided to Provided to [insert your company [insert your company name]name] by PLHCP within thirty days by PLHCP within thirty days

Specific findings or diagnoses Specific findings or diagnoses unrelated to occupational exposure to unrelated to occupational exposure to Cr(VI) not revealedCr(VI) not revealed

We must provide a copy of the We must provide a copy of the PLHCP's written medical opinion to PLHCP's written medical opinion to you within two weeks after receiving ityou within two weeks after receiving it

PLHCP's Written Medical PLHCP's Written Medical OpinionOpinion

[Describe details of worksite specific medical surveillance program here.]

Worksite Medical Surveillance Worksite Medical Surveillance ProgramProgram

RecordsRecords

You have the right to see any of your medical records related to Cr(VI).

Medical and Air Monitoring RecordsMedical and Air Monitoring Records

You also have the right to see results of any air sampling we have done, or other exposure data we have used.

Federal OSHA Standard for Hexavalent Chromium are:

• General Industry – 1910.1026

• Construction – 1926.1126

• Maritime – 1915.1026

State OSHA Programs will have different standards

Hexavalent Chromium Hexavalent Chromium RegulationsRegulations

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