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HEXAVALENT CHROMIUM A Standard In Review Paul Watson CIH, CSP, ATC Associates Adopted from presentation developed under the Susan Harwood Grant # 46E6.

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Presentation on theme: "HEXAVALENT CHROMIUM A Standard In Review Paul Watson CIH, CSP, ATC Associates Adopted from presentation developed under the Susan Harwood Grant # 46E6."— Presentation transcript:

1 HEXAVALENT CHROMIUM A Standard In Review Paul Watson CIH, CSP, ATC Associates Adopted from presentation developed under the Susan Harwood Grant # 46E6 – HT34

2 Background Information  Chromium is a metal that exists in several oxidation or valence states, ranging from chromium (-II) to chromium (+VI).  Chromium compounds are very stable in the trivalent state and occur naturally in this state in ores such as ferrochromite, or chromite ore.  Chrome III is an essential nutrient for maintaining blood glucose levels  The hexavalent, Cr(VI) or chromate, is the second most stable state. It rarely occurs naturally; most Cr(VI) compounds are man made.

3 What is Hexavalent Chromium? (“chrome 6”)  A toxic form of chromium metal, generally man-made.  Used in many industrial applications, primarily for its anti-corrosive properties.  Can be generated during welding on stainless steel or metal structures coated with chromate paint.  Used in electroplating (chrome plating)

4 ProductTypes of Hexavalent Chromium Chemicals pigments in paints, inks, and plastics  lead chromate (chrome yellow, chrome green, molybdenum orange)  zinc chromate  barium chromate  calcium chromate  potassium dichromate  sodium chromate anti-corrosion coatings (chrome plating, spray coatings)  chromic trioxide (chromic acid)  zinc chromate  barium chromate  calcium chromate  sodium chromate  strontium chromate stainless steel and other high chromium alloys  hexavalent chromium (when cast, welded, or torch cut) textile dyes  ammonium dichromate  potassium chromate  potassium dichromate  sodium chromate wood preservation  chromium trioxide leather tanning  ammonium dichromate Products that contain hexavalent chromium

5 Chrome plating or electroplating Welding or cutting on stainless steel or grinding on objects painted with chromate paint Painting:  Auto body repair  Aircraft spray painting Common jobs with potential chrome 6 exposure

6  Chromium dye and catalyst production  Glass manufacturing  Plastic colorant production  Construction  Traffic painting  Refractory brick restoration  Paint removal from bridges  Hazardous waste site work Other jobs with potential chrome 6 exposure bridge work Road strip painting

7 Health Effects  Ingestion Hazards  Erosive to stomach, Hemorrhaging and death are likely  Eyes  Direct eye contact with chromic acid or chromate dusts can cause permanent eye damage.  Respiratory Tract  Hexavalent chromium can irritate the nose, throat, and lungs.  Repeated or prolonged exposure can damage the mucous membranes of the nasal passages and result in ulcers.  Skin  Prolonged skin contact can result in dermatitis and skin ulcers.  Some workers develop an allergic sensitization to chromium. In sensitized workers, contact with even small amounts can cause a serious skin rash.

8 Health Effects  Cancer  Chrome VI is classified as a known human carcinogen  Hexavalent chromium is considered a potential lung carcinogen.  Studies of workers in the chromate production, plating, and pigment industries consistently show increased rates of lung cancer.  Insoluble forms such as zinc chromate are the most potent  20 year cancer latency

9 Greater Risk Than Asbestos  Cancer risk from Cr (VI) at new PEL is higher than asbestos and benzene risk at their PELs  Asbestos: 6.7 deaths per 1000 workers  Benzene: 10 deaths per 1000 workers  Chrome VI: excess lung cancer deaths per 1000 workers for 45 years of exposure at new PEL of 5 ug/m 3

10 Major Health Effects  Lung cancer  Nasal septum ulcers or perforations  Bronchitis or asthma Perforation of the nasal septum from chrome 6 exposure X-ray showing lung cancer

11 Chrome 6 effects on skin  Skin ulcers  Allergic and irritant contact dermatitis “Chrome hole” on finger Skin effects are not likely in welding, but can occur in electroplating or painting

12 New Cr VI OSHA Standard  Suit by Public Citizen Health Research Group; Paper, Allied Industrial, Chemical, and Energy Workers Union  4/2/ rd Circuit Court of Appeals rules standard by 1/18/2006  2/28/ Final Rule published  20 or more employees - November 27,  19 or fewer employees - May 30,  For all employers, engineering controls May 31,  OSHA and the Steelworkers engaged in settlement agreement required engineering controls on an expedited schedule (by December 31, 2008), but will have relief from certain respirator requirements in the interim.  Portland Cement is exempted.

13 General Industry 29 CFR  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  Recordkeeping  Dates

14 Construction Industry 29 CFR  No definition of a Regulated Area  Notify Employee’s within 5 days of receipt of results  15 days General Industry

15 Definitions  Action level µg/m³ (8-hour TWA).  Permissible Exposure Limit - 5 µg/m³ (8-hour TWA).  This has been lowered from the past level of 52 micrograms per cubic meter of air (52 µg/m³).  But it is higher than the original proposed PEL of 1ug/m 3

16 Two limits for Chrome 6 in air 5 micrograms per cubic meter in the air 2.5 micrograms per cubic meter in the air Permissible Exposure Limit (PEL) 8-hour average exposure limit Action Level (AL) half of the PEL

17 Comparison of OELs

18 Potential Sources  Welding  Stainless steel  Carbon steel (confined spaces)  Aircraft Painting  Priming with zinc chromate primers  Removing primers  Chrome Plating  Chromic Acid  Excluded  Portland Cement  Pesticide Application (Wood Preservative)

19 Welding  Nearly half the workers covered under the new standard are welders  Chromium in steel is oxidized to Cr VI by high welding temperatures  6, ,000° C for the SMAW, GTAW, GMAW, FCAW and SAW processes  The hotter the process and the more oxygen that is present, more fume is generated  Stick welding: 50% of Cr produced is Cr VI  TIG & MIG 4% of total Cr produced is Cr VI  Stainless steel has between 10.5% - 27% chromium

20 Painting  Aluminum Primers  Zinc Chromate and Strontium Chromate Also present in in adhesives/sealants  Chromates required for proper adhesion  Chromate free primers are being researched  Exposure occurs during spray painting Special sample handling required  Exposures occur during sanding and bead blasting

21 Plating and Chromic Acid  Chrome Plating produces chromic acid mists over the plating tanks.  The mist is created by the electroplating currents causing bubbles in the solution. The bubbles pop at the surface and create a mist over the tank  Tank ventilation systems are common, but are frequently deficient.  Other chromic acid exposures occur from chromic acid solution preparations.  Chromic acid flakes are dumped mixed into solutions for many chemical processes

22 Exposure Determination  Each employer who has a workplace or work operation covered by this section shall determine the 8-hour TWA exposure for each employee exposed to chromium (VI).  This determination shall be made in accordance with either of the following methods:  Scheduled Monitoring Option  Performance-oriented Option  Objective data means:  Information such as air monitoring data from industry-wide surveys; or  Calculations based on the composition or chemical and physical properties of a substance

23 How do you Sample?  Air sampling  OSHA ID-215  Ship within 24 hours  Note type of operation  In breathing zone  Under welding visor  Surfaces  W-4001  Target value is µg/100 cm 2

24 Exposure Determination  If samples show < Action Level  May discontinue monitoring  If samples show ≥ Action Level  Periodic monitoring every six months  If samples show ≥ Permissible Exposure Level  Periodic monitoring every three months  Additional monitoring where process has changed

25 25 Notification of air monitoring results If air monitoring shows chrome 6 levels in the air exceed the PEL we must: - Notify you within 5 days in construction or within 15 days in general industry - Describe to you in writing what corrective actions we will take to reduce your exposure below the PEL.

26 Skin Sampling  does not require skin sampling! The final rule requires the employer to provide appropriate protective clothing and equipment where a hazard is present or is likely to be present from skin or eye contact with Cr (VI), but does not specify criteria to be used for determining when a hazard is present or is likely to be present”. One of the tools which the employer can use is skin sampling. But, OSHA is not aware of any evidence that would allow establishment of a threshold concentration of Cr(VI) below which adverse skin or eye effects would not occur.  The interpretation letter on the OSHA Web page states “To determine whether there is a hazard (or potential hazard) from skin or eye contact with chromium (VI) in a particular workplace, the employer should use appropriate expertise in assessing hazards. (See non- mandatory appendices providing guidance on hazard assessment in 29 CFR 1910 Subpart I Appendix B; 29 CFR 1915 Subpart I Appendix A). The recommended approach involves a walkthrough survey to identify sources of chromium (VI) hazards to workers. Also recommended are reviews of occupational illness records to determine if past skin exposures have been recorded or if skin conditions were reported which may have been linked to chromium (VI) exposures, as well as a review of any exposure determination(s) for operations involving chromium (VI)”.

27 Methods of Compliance  Use engineering and work practice controls to reduce and maintain employee exposure to or below the PEL.  When not sufficient enough, Use of respiratory protection in Addition.  If exposure above the PEL is less than 30 days per year, Use of respiratory protection alone to comply.  No rotation of employees to different jobs to achieve compliance with the PEL.

28 Welding Controls  Fume extractor for stick welding on stainless steel  Use MIG/TIG welding on stainless steel whenever possible  Fume extractor for enclosed welding on any kind of steel  Weld using smaller rods  Weld using lower amperage (temperature)  Keep head out of rising plume

29 When welding, keep your head out of the welding plume. Welding work practices Use available local exhaust ventilation at all times. 21

30 Welding in confined spaces Welding on stainless steel in a confined space will most likely require both exhaust ventilation and the use of respirators. 22

31 Painting Controls  Substitute with non-Cr VI paint, if possible  Conduct spray painting in an extremely well- designed and maintained booth. (Think of controlling lead-based spray paint exposures, but having to control 10 times better.)  Some grinders have a ventilated shroud on the grinder or needle gun, others may also have a perforated grinder disk  Airline respirators  Use Paint strippers to eliminate airborne exposures

32 Personal Protective Equipment  When exposure to hazards cannot be engineered completely out of normal operations or maintenance work, and when safe work practices cannot provide sufficient additional protection, a further method of control is using protective clothing or equipment.  (f)(1)(ii) Where painting of aircraft or large aircraft parts is performed in the aerospace industry, the employer shall use engineering and work practice controls to reduce and maintain employee exposure to chromium (VI) to or below 25 µg/m3. The employer shall supplement such engineering and work practice controls with the use of respiratory protection that complies with the requirements of paragraph (g) of this section to achieve the PEL.

33 Protective Work Clothing and Equipment  Where a hazard is present or is likely to be present from skin or eye contact with chromium (VI);  Provide appropriate personal protective clothing and equipment at no cost to employees, and  Ensure that employees use such clothing and equipment.  All protective clothing and equipment contaminated with chromium (VI) must be:  Removed at the end of the work shift or at the completion of their tasks, whichever comes first;  Stored and transported in sealed, properly labeled, impermeable bags or other closed, impermeable containers.

34 Protective Work Clothing and Equipment  No employees may remove chromium (VI)-contaminated protective clothing or equipment from the workplace, except for those employees whose job it is to launder, clean, maintain, or dispose of such clothing or equipment.  All protective clothing and equipment required by this section shall be cleaned, laundered, repaired and replaced as needed to maintain its effectiveness.  The removal of chromium (VI) from protective clothing and equipment by blowing, shaking, or any other means that disperses chromium (VI) into the air or onto an employee's body is prohibited.

35  Use where skin or eye contact with chrome 6 will occur or is likely to occur.  Normal welding PPE (welding helmet, gloves and welding leathers) is O.K. for welders  Remove all PPE when work shift or task is completed. Don’t wear or take it home. Protective Work Clothing and Equipment

36  Don’t remove chrome 6 dust or residue from clothing by blowing, shaking, or any other means that disperses the dust into the air or onto the body. Protective Work Clothing Use Don’t use compressed air to clean clothing Don’t shake out dusty coveralls or clothes

37 37 Laundering and Cleaning PPE Use of outside service to launder or replace all protective clothing and other protective equipment Put your contaminated PPE in a sealed bag for laundering or repair The person doing these tasks must be informed of the hazards of chrome 6

38 Types of Respirators for Chrome 6 In some jobs involving chrome 6 exposure, you may need to wear a respirator. The type of respirator worn depends on the amount of chrome 6 in the air. 24

39 Respiratory Protection  Minimum N-95  Based on airborne exposure

40 Hygiene Areas and Practices  Where protective clothing and equipment is required, the employer shall provide change rooms.  Separate storage for contaminated and clean clothes  Where skin contact with chromium (VI) occurs, the employer shall provide washing facilities:  Such facilities shall be in near proximity to the worksite and shall be so equipped as to enable employees to remove such substances. MUST BE WATER BASED CLEANING SYSTEM.  Washing facilities shall be maintained in a sanitary condition.  Use of these facilities when necessary shall be enforced. 29 CFR (h)

41 Hygiene Areas and Practices  Change rooms – separate storage facilities for PPE and street clothes  Washing facilities Be sure to wash hands and face:  at the end of the work shift  before eating, drinking, smoking, chewing tobacco or gum, applying cosmetics, or using the toilet If you have a job where chrome 6 can get on your skin or in your eyes, the employer must provide the following:

42  Keep all surfaces as free as practicable of accumulations of dust containing chrome 6.  Promptly clean up all spills and releases of chrome 6 containing materials  Use a HEPA vacuum or wet methods for cleaning areas contaminated with dust or other materials containing chrome 6  Dispose of chrome 6 contaminated waste in labeled & sealed bags or containers. Housekeeping

43 Medical Surveillance  A medical examination consists of:  A medical and work history;  A physical examination of the skin and respiratory tract.  Information to PLHCP  Employer shall obtain written opinion within 30 days containing:  Any detected conditions placing employee at increased risk of material impairment from Cr+6 exposure  Limitations of exposure or use of PPE  Statement that Physician or other Licensed Health Care Professional’s ( PLHCP’s) explained results of exam to employee  Employer shall provide copy to employee within 2 weeks 29 CFR (i)

44  Any employee exposed at or above the action level for 30 or more days per year.  Any employee experiencing signs or symptoms of chrome 6 exposure.  Any employee exposed in an uncontrolled release of large amounts of chrome 6 in any form. Who Must Be Provided Medical Exams?

45 45 Medical Exams (cont.)  Are done by or under the supervision of a physician or other licensed health care professional  Provided at no cost to you at a reasonable place and time

46 Medical Exams will do the following:  Determine if you can be exposed to Chrome 6 without experiencing adverse health effects.  Identify chrome 6 related adverse health effects so that appropriate measures can be taken.  Determine your fitness to use respirators.

47  Medical and work history  Cr(VI) exposure (past, present, future)  History of respiratory system dysfunction  History of asthma, dermatitis, skin ulceration or nasal system perforation  Smoking status and history  Physical examination, with emphasis on the respiratory tract and skin  Any additional tests deemed appropriate by the healthcare professional Medical exams will include the following:

48  Within 30 days after initial assignment and annually thereafter  Within 30 days after a doctor recommends additional examinations  When employees shows signs or symptoms of Chrome 6 exposure  Within 30 days after exposure during an emergency  At the termination of employment Medical Exams are offered:

49  After your medical exam the health care professional will give a written medical opinion to us within thirty days  Specific findings or diagnoses unrelated to occupational exposure to chrome 6 will be not revealed to us Healthcare professional’s written medical opinion 40

50 Communication of Hazards  The employer shall ensure that each employee can demonstrate knowledge of at least the following:  The contents of this section; and  The purpose and a description of the medical surveillance program.  Hazard Communication 29 CFR (j)

51 WA State Department of Labor and Industries, Video  Six Modules Six Modules  Can down load for free from:  ardees/UWHexavalent/HexChromeVideos.asp

52 Background Information  OSHA has determined that the PEL of 5 µg/m3 is technologically feasible for all affected welding job categories  OSHA has concluded that no carbon steel welders are exposed to Cr(VI) above 5 µg/m3, with the exception of a small portion of workers welding on carbon steel in enclosed and confined spaces.  Many welding processes, such as tungsten-arc welding (TIG) and submerged arc welding (SAW), already achieve Cr(VI) exposures below the PEL because they inherently generate lower fume volumes.

53 Inspection Activity  Hexavalent chromium inspections  May 30, 2006 to December 31, 2007  78 Fed inspections with violations of  72 inspections in General Industry  6 inspections in Construction  0 inspections in Shipyards  # of total Cr(VI) violations = 155  $ amount of total current penalties = $157,534.00

54 Inspection Activity  72 inspections in General Industry with violations  Breakdown of these 72 employers by SIC code: (7) Electroplating, Plating, Polishing, Anodizing, and Coloring (5) Fabricated Metal Products, Not Elsewhere Classified (5) Fabricated Plate Work (Boiler Shops) (3) Sheet Metal Work (3) Fabricated Structural Metal (3) Steel Foundries, Not Elsewhere Classified (2) Repair Shops and Related Services, Not Elsewhere Classified (2) Railroad Equipment (2) Aircraft Parts and Auxiliary Equipment, Not Elsewhere Classified (2) Special Industry Machinery, Not Elsewhere Classified (2) Conveyors and Conveying Equipment (2) Metal Doors, Sash, Frames, Molding, and Trim Manufacturing (2) Wood Office Furniture (1) ---- etc., for (32) other SIC codes

55 Inspections  List of the 5-most cited Cr(VI) violations:  (d)(1) - didn't determine exposure  (c) - exposure exceeded PEL  (e)(1) - no regulated area  (k)(1)(i)(A) - no medical surveillance  (l)(2)(i)(A) - no employee knowledge of standard

56 Inspection Procedures

57 Conclusions  The Hexavalent Chromium standard can be a problem. It is a comprehensive vertical standard with many requirements, if it applies to you  Recommendations  Evaluate your Workplace (Stainless Steel is the trigger)  Conduct sampling  Evaluate exposure controls  Implement the full standard  Self check using the CPL

58 Your One-Stop Resource For Environmental, Health & Safety Solutions

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