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Presentation on theme: "HEXAVALENT CHROMIUM OVERVIEW"— Presentation transcript:

29 CFR CHROMIUM (VI) 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. The hexavalent, Cr(VI) or chromate, is the second most stable state. It rarely occurs naturally; most Cr(VI) compounds are man made.

3 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. OSHA has determined that engineering and work practice controls are available to permit the vast majority (over 95 percent) of welding operations on carbon steel in enclosed and confined spaces to comply with a PEL of 5 µg/m3. The two most common welding processes, shielded metal arc welding (SMAW) and gas metal arc welding (GMAW), generate greater exposures and may require the installation or improvement of local exhaust ventilation.

4 Is Chrome a Carcinogen or Necessary Element?
Chrome III is an essential nutrient for maintaining blood glucose levels Chrome VI is classified as a known human carcinogen

5 Health Effects Cancer 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

6 Health Effects Ingestion Hazards Erosive to stomach
Hemorrhaging and death are likely Treatment for ingestion - dilution with milk or water and/or asorbic acid. This should only be given by someone qualified in first aid. Ingestion of ascorbic acid to reduce Cr VI to Cr III will work, but may cause renal failure (conversion of ascorbic acid to oxalate plugs the kidneys) Recommended that you seek medical assistance first.

7 Health Effects Eyes Respiratory Tract
Direct eye contact with chromic acid or chromate dusts can cause permanent eye damage. Treatment for eye contact – Flush eye(s) for 15 min. Seek medical assistance. 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. In severe cases, exposure causes perforation of the septum (the wall separating the nasal passages).

8 Health Effects 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. Kidney damage has been linked to high dermal exposures. Treatment for skin contact - Irrigate with water Possible use of 10% ascorbic acid topically (the acid reduces/changes Cr VI to Cr III) Recommended that you seek medical assistance first Vitamin C is a water-soluble nutrient and human vitamin essential for life and for maintaining optimal health, used by the body for many purposes. It is also known by the chemical name of its principal form, L-ascorbic acid.

9 New Cr VI OSHA Standard Suit by Public Citizen Health Research Group; Paper, Allied Industrial, Chemical, and Energy Workers Union (1997 & 2002) 4/2/ rd Circuit Court of Appeals ruling for OSHA Cr(VI) proposal to be published by 10/4/2004 and standard by 1/18/2006 2/28/ Final Rule published

10 Greater Risk Than Asbestos
Cancer risk from Cr (VI) at new PEL is higher than asbestos risk at asbestos PEL 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/m3

11 Past Cr VI Sampling Under the old PEL:
little sampling was performed; Chrome plating was the main focus Some overexposures were noted Little welding sampling was performed A few spray painter exposures were evaluated They were VERY HIGH. Painting a plane in a bunker was 1000 X the PEL Consultation found 3250 ug/m3, 650 X the new PEL Not much prior sampling for Cr VI exposures

12 Coverage General Industry
Basic difference: Construction and Shipyards Cr VI standards lack sections on Regulated Areas Housekeeping

13 Scope This standard applies to occupational exposures to chromium (VI) in all forms and compounds in construction, except: Exposures that occur in the application of pesticides; Exposures to portland cement; or Where the employer has objective data demonstrating that a material containing chromium or a specific process, operation, or activity involving chromium cannot release dusts, fumes, or mists of chromium (VI) in concentrations at or above 0.5 µg/m³ as an 8 hour time weighted average (TWA) under any expected conditions of use. The amount of Cr(VI) in American portland cement is generally less than 20 ug Cr(VI)/g cement. The primary intent of this rule is to protect workers from lung cancer resulting from inhalation of Cr(VI). Although reports vary, the weight of the evidence indicates that the vast majority of cement dermatitis cases do not involve Cr(VI) sensitization. The use of wood treated with pesticides containing Cr(VI) is also covered. 29 CFR (a)

14 What is Covered? Welding - Stainless Steel Welding - Carbon Steel
Painting Woodworking Refractory Brick Restoration & Maintenance Hazardous Waste Site Work Industrial Rehabilitation and Maintenance Portland Cement Producers – Portland Cement? Ready Mix Concrete – Portland Cement? Precast Concrete Products – Portland Cement?

15 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 Up to 10, ,000° C for the PAW process SMAW – Stick Welding GTAW – TIG GMAW – MIG FCAW - Flux Core Arc Welding SAW - Submerged Arc Welding Oxy-fuel cutting – 16000F

16 Welding Overexposures are POSSIBLE when welding stainless steel or high chrome steel and proper procedures are not followed. Stainless steel has between 10.5% - 27% chromium Nickel is also present in some types of stainless

17 Welding Potential for overexposure when welding CARBON steel and proper procedures are not followed. Position of head during welding is number one problem Anywhere the welding fume is more confined, such as welding in a tight corner Reason: 10% of carbon steel has chromium in more than trace amounts

18 Welding Stick welding: High likelihood of overexposure to Cr VI
50% of total Cr produced is Cr VI ( FR pg col 3) TIG & MIG generates lower fume amounts 4% of total Cr produced from MIG is Cr VI

19 Welding Submerged arc generates lower fume amounts
Conclusion: Switch to MIG from stick if you can

20 Definitions Action level - 2.5 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). OSHA previously determined (based in part on research conducted by Leidel et al.) that where exposure measurements are above one-half the PEL, the employer cannot be reasonably confident that the employee is not exposed above the PEL on days when no measurements are taken 29 CFR (b)

21 Definitions 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 Types of information that may serve as objective data include, but are not limited to, air monitoring data from industry-wide surveys; data collected by a trade association from its members; or calculations based on the composition or chemical and physical properties of a material. 29 CFR (b)

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 Employers must accurately characterize the exposure of each employee to Cr(VI). In some cases, this will entail monitoring all exposed employees. In other cases, monitoring of ‘‘representative’’ employees is sufficient. Exposure monitoring should include, at a minimum, one full-shift sample taken for each job function in each job classification, in each work area, for each shift. If the initial monitoring indicates that employee exposures are below the action level, no further monitoring is required unless changes in the workplace result in new or additional exposures. If the initial determination reveals employee exposures to be at or above the action level but at or below the PEL, the employer must perform periodic monitoring at least every six months. If the initial monitoring reveals employee exposures to be above the PEL, the employer must repeat monitoring at least every three months. 29 CFR (d)

23 Exposure Determination
Scheduled Monitoring Option Perform initial monitoring to determine the 8-hour TWA exposure for each employee. Additional monitoring when: There has been any change that may result in new or additional exposures to chromium (VI), or When the employer has any reason to believe that new or additional exposures have occurred. In construction, employers must notify each affected employee as soon as possible but not more than 5 working days after the exposure determination indicates that employee exposure exceeds the PEL. When using the term ‘‘affected employees’’ in this provision, OSHA is referring to all employees considered to be above the PEL. 29 CFR (d)(2)

24 Exposure Determination
Scheduled Monitoring Option Representative sampling may be performed instead of sampling all employees in order to meet this requirement. In this case, the employer shall sample the employee(s) expected to have the highest chromium (VI) exposures. 29 CFR (d)(2)

25 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 29 CFR (d)(2)

26 Exposure Determination
Performance-oriented Option The employer shall determine the 8-hour TWA exposure for each employee on the basis of any combination of: Air monitoring data; Historical monitoring data (prior to 5/30/2006); or Objective data. Where typical exposures are below 0.25 µg/m3, an industry survey might be used to show that exposures for a given operation would be below 0.5 µg/m3 under any expected conditions of use. 29 CFR (d)(3)

27 Employee Notification
If sampling shows > PEL, 5 working days to post results or provide in writing Where sampling shows > PEL, Employer must describe in the written notification the corrective action being taken to reduce employee exposure to or below the PEL 29 CFR (d)(4)

28 Accuracy of Sampling Accuracy Example would be the OSHA ID-215 Method
Method and analysis +/- 25% w/ a CI of 95% Example would be the OSHA ID-215 Method 29 CFR (d)(5)

29 Observation of Monitoring
Where air monitoring is performed to comply with the requirements of this section Provide affected employees or their designated representatives an opportunity to observe. The employer shall provide the observer with clothing and equipment and shall assure that the observer uses such clothing and equipment and complies with all other applicable safety and health procedures. 29 CFR (d)(6)

30 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. No exposure above the PEL for 30 or more days per year or not feasible, Use of respiratory protection alone to comply. No rotation of employees to different jobs to achieve compliance with the PEL. OSHA intends for this exception to be process-or task-based: i.e., it is specific to a process where engineering controls might be implemented to reduce exposures to or below the PEL. Engineering controls can be grouped into three main categories: (1) Substitution; (2) isolation; and (3) ventilation, both general and localized. Quite often a combination of these controls can be applied to an industrial hygiene control problem to achieve satisfactory air quality. It may not be necessary to apply all these measures to any specific potential hazard. 29 CFR (e)

31 Engineering Controls To the extent feasible, designed to eliminate or reduce exposure to hazards based on the following principles: If feasible, design the facility, equipment, or process to remove the hazard and/or substitute something that is not hazardous or is less hazardous. If removal is not feasible, enclose the hazard to prevent exposure in normal operations. Where complete enclosure is not feasible, establish barriers or local ventilation to reduce exposure to the hazard in normal operations.

32 Elimination by Design Some examples of designing facilities, equipment, or processes so that the hazard is no longer present are: Redesigning, changing, or substituting equipment to remove the source of excessive temperature, noise, or pressure; Redesigning a process to use less toxic chemicals; Redesigning a workstation to relieve physical stress and remove ergonomic hazards; and Designing general ventilation with sufficient fresh outdoor air to improve indoor air quality and generally to provide a safe, healthful atmosphere.

33 Enclosure of Hazards When you can not remove a hazard and cannot replace it with a less hazardous alternative, the next best control is enclosure. While this may control employee exposure during production, it may not control exposures during maintenance.

34 Enclosure of Hazards Some examples of enclosure designs are:
Complete enclosure of moving parts of machinery; Complete containment of toxic liquids or gasses from the beginning of the process using or producing them to detoxification, safe packing for shipment, or safe disposal of toxic waste products; Glove box operations to enclose work with dangerous micro-organisms, radio nuclides, or toxic substances; and Complete containment of noise, heat, or pressure.

35 Barriers or Local Ventilation
When the potential hazard cannot be removed, replaced, or enclosed, the next best approach is a barrier to exposure, or, in the case of air contaminants, local exhaust ventilation to remove the air contaminant from the workplace. This engineered control involves potential exposure to the worker even in normal operations, consequently, it should be used only in conjunction with other types of controls, such as safe work practices designed specifically for the site condition and/or personal protective equipment.

36 Welding Controls Fume extractor for stick and MIG/TIG welding on stainless steel Fume extractor for enclosed welding on any kind of steel Weld using lower temperatures Avoid stick welding on steel containing chrome, if possible

37 How is welding fume controlled?
Change the welding procedures; Stick to MIG or even better TIG Use welding wires/rods designed for lower fume generation; Change power sources; Change shielding gases; or Fume removal / extraction.

38 Fume Removal / Extraction
Low Vacuum (High Volume) Low Vacuum systems remove a large amount of air at low velocity and low vacuum pressure. In welding fume extraction, low vacuum systems use articulated “arms” roughly 8 inches in diameter and can be from 12 to 18 inches from the welding arc. These arms typically draw between 600 and 900 CFM per arm. If access to the joint prevents the use of fume guns or suction heads, low vacuum may be the better solution. If the weldment smokes considerably after welding due to die oils or paint, fume guns will not work since they are removed after welding.

39 Low Vacuum (High Volume)
Mobiflex 100-NF Portable Fan For hard to reach areas, exhaust the fume Connect to 6 in. diameter, 16 ft. long hose set with magnet mounted hood exhaust or extension hose set. Does not provide filtration.

40 Low Vacuum (High Volume)
Mobiflex 200-M Base Unit - Mobile Welding Fume Extractor A portable, low vacuum/high volume disposable filtration system designed for intermittent or continuous extraction and filtration of welding fumes. On-board internal extraction fan and is designed specifically for weld applications. The particulate is collected on the inside of the cartridge, minimizing exposure to particulate during filter maintenance and disposal. The lightweight and rugged design of the Mobiflex™ 200-M along with the standard front caster and rear wheels allows for easy portability. It is ideal for facilities that require welding fume extraction in multiple locations, including maintenance departments, general fabrication and job shops, and industrial welding environments. The Mobiflex™ 200-M can be configured with Lincoln’s® LFA 3.1 or LFA 4.1 fume extraction arms or with the 203 mm (8 in.) diameter, 5 m (16 ft.) long flexible hose and hood set. Lincoln Electric’s® fume extraction arms are designed to provide operators with optimal motion and reach for their specific welding position(s) and work area. The arm lengths range from 3.0 meter (10 ft.) to 4.0 meters (13 ft.). For hard to reach areas such as confined spaces, the flexible hose set can be easily carried to locations where an extraction arm is not feasible.

41 Fume Removal / Extraction
High Vacuum (Low Volume) High Vacuum systems capture fume as close to the arc as possible using integrated fume extraction guns or heads that use small diameter hose 1.5–1.75 inches, about 4 to 6 inches from the welding arc. These systems use much smaller hose or duct because they draw only between 35 and 150 CFM. Fume is captured before it reaches the operators breathing zone.

42 Fume Removal / Extraction
High Vacuum (Low Volume) Using fume guns, the suction automatically follows the arc, eliminating repositioning necessary with low vacuum arms. Since only a small volume of air is processed, the strain on heating and cooling systems is minimal. Portable and mobile high vacuum units are smaller and less expensive than mobile low vacuum units.

43 High Vacuum (Low Volume)
Miniflex - Portable Welding Fume Extractor A portable, high vacuum, low volume system specifically designed for the removal and filtration of welding fumes. It can be completely disassembled in a matter of minutes for cleaning and maintenance. With an automatic start/stop function, the unit automatically turns on and off during welding. It can be used in confined spaces and other locations that are not accessible with other welding fume extractors.

44 Work Practice Controls
Position of head during welding operations When welding outside, having the wind at your back with the fumes being pushed away from your head. Preplan your work.

45 Some Painting Controls
Chromates provide excellent corrosion control. With what data exists, airborne spray painting exposures are high. Recommendations: 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.) Airline respirators

46 Some Painting Controls
Ventilated grinders have been designed for silica and lead exposures Some grinders have a ventilated shroud on the grinder or needle gun, others may also have a perforated grinder disk If the paint contains zinc chromate or other chromates, Cr VI exposures will be high

47 Some Painting Controls
Ventilated tools, ventilated enclosures, and increased levels of PPE are recommended Use Paint strippers to eliminate airborne exposures

48 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. These include face shields, steel-toed shoes, hard hats, respirators, hearing protection, gloves and safety glasses.

49 Respiratory Protection
Provide respiratory protection for employees during: Installing or implementing feasible engineering and work practice controls; Work operations where exposed above the PEL for fewer than 30 days per year and the employer has elected not to implement engineering and work practice controls to achieve the PEL; or Emergencies. Where respirator use is required by this section, the employer shall institute a respiratory protection program in accordance with 29 CFR OSHA considers the process or task to be the appropriate basis for applying this exception, rather than basing an exception on the number of days that an individual worker is exposed. OSHA likewise believes that an air-purifying respirator equipped with any filter certified for particulates by NIOSH will be efficient in preventing the penetration of particles with diameters of 2 micrometers or more, because filters will be more efficient in protecting against particles larger than 0.3 micrometers in diameter. See APF for respirators Handout #2 29 CFR (f)

50 Respiratory Protection Program
The employer shall implement a written respiratory protection program with required worksite-specific procedures and elements for required respirator use including: Procedures for selecting respirators for use in the workplace Medical evaluations of employees required to use respirators Fit testing procedures for tight-fitting respirators Procedures for proper use of respirators in routine and reasonably foreseeable emergency situations 29 CFR (c)(1)

51 Respiratory Protection Program
Where respirator use is not required: An employer may provide respirators at the request of employees or permit employees to use their own respirators, if the employer determines that such respirator use will not in itself create a hazard. If the employer determines that any voluntary respirator use is permissible, the employer shall provide the respirator users with the information contained in Appendix D to this section ("Information for Employees Using Respirators When Not Required Under the Standard") and In addition, the employer must establish and implement those elements of a written respiratory protection program necessary to ensure that any employee using a respirator voluntarily is medically able to use that respirator, and that the respirator is cleaned, stored, and maintained so that its use does not present a health hazard to the user. 29 CFR (c)(2)

52 Types of Respiratory Protective Equipment
Dust, Fume and Mist Respirators: Mechanical filter respirators offer protection against airborne matter including dusts, mists, metal fumes and smoke. Mechanical filter respirators do not provide protection against gases, vapors, or oxygen deficiency.

53 Types of Respiratory Protective Equipment
Chemical Cartridge Respirators: Chemical Cartridge Respirators afford protection against concentrations of certain acid gases and organic vapors utilizing various chemical agents to purify the inhaled air. They shall not be used in atmospheres which are oxygen deficient. Chemical Cartridge Respirators (1/2 mask) shall not be used for protection against: Gaseous material that is extremely toxic in small concentrations (hydrogen cyanide and sulfide). Exposure to harmful gaseous material which cannot be detected by odor (carbon monoxide). Gaseous material in concentrations which are highly irritating to the eyes.

54 Types of Respiratory Protective Equipment
Air Supplied Hood: The Air Supplied Hood is normally used where the user only requires protection against levels of material or requires an air flow for cooling purposes. This equipment shall not be used in any situation where the user would be endangered.

55 Types of Respiratory Protective Equipment
Airline Respirator: The airline respirator consists or a full face mask supplied with breathing air by a compressor or multiple stationary cylinders. Care must be exercised to prevent damage to the hose and regulator while in use, and the assembly shall be stored in such a way that damage will be avoided.

56 Types of Respiratory Protective Equipment
Cylinder Type Self-Contained Breathing Apparatus: The SCBA utilizes compressed breathing air and will provide protection in any atmosphere regardless or contamination or oxygen. Although this equipment should provide breathing air for approximately 30 minutes, caution or emotional strain may reduce the rated time. Users of this equipment shall immediately begin exiting the hazardous atmosphere when the low pressure alarm sounds. When anticipating the use of this apparatus, consideration shall be given to the life of the cylinders. Whenever compressed air apparatus is used in atmosphere immediately dangerous to life, a standby man or men shall be present with suitable rescue equipment

57 Selection of Respirators
Employees will be allowed to select the respirator to be used from a sufficient number of respirator models and sizes so that the respirator is acceptable and correctly fits. 29 CFR (d)

58 Selection of Respirators
In IDLH atmospheres, one of the following respirators must be used: A full facepiece pressure demand SCBA certified by NIOSH for a minimum service life of thirty minutes, or A combination full facepiece pressure demand supplied‑air respirator (SAR) with auxiliary self‑contained air supply. Respirators provided only for escape from IDLH atmospheres shall be NIOSH‑certified for escape from the atmosphere in which they will be used. All oxygen‑deficient atmospheres shall be considered IDLH. 29 CFR (d)

59 Selection of Respirators
In atmospheres that are not IDLH, one of the following respirators must be used: For protection against gases and vapors, one of the following respirators must be used: An atmosphere‑supplying respirator, or In atmospheres that are not IDLH, one of the following respirators must be used: so long as the respirator selected is adequate to protect the health of the employee and ensure compliance with all other OSHA statutory and regulatory requirements, under routine and reasonably foreseeable emergency situations. 29 CFR (d)

60 Selection of Respirators
In atmospheres that are not IDLH, one of the following respirators must be used: An air‑purifying respirator, provided that: The respirator is equipped with an end‑of‑service‑life indicator (ESLI) certified by NIOSH for the contaminant; or If there is no ESLI appropriate for conditions in the employer's workplace, the employer implements a change schedule for canisters and cartridges that is based on objective information or data that will ensure that canisters and cartridges are changed before the end of their service life. 29 CFR (d)

61 Selection of Respirators
In atmospheres that are not IDLH, one of the following respirators must be used: Cont. For protection against particulates, one of the following respirators must be used: An atmosphere‑supplying respirator; or An air‑purifying respirator equipped with a filter certified by NIOSH under 30 CFR part 11 as a high efficiency particulate air (HEPA) filter, or an air‑purifying respirator equipped with a filter certified for particulates by NIOSH under 42 CFR part 84; or For contaminants consisting primarily of particles with mass median aerodynamic diameters (MMAD) of at least 2 micrometers, an air‑purifying respirator equipped with any filter certified for particulates by NIOSH. 29 CFR (d)

62 Assigned Protection Factors5
Type of Respirator1,2 Quarter Mask Half Mask Full Facepiece Helmet/Hood Loose-Fitting Facepiece 1. Air-Purifying Respirator 5 10 3 50 2. Powered Air-Purifying Respirator (PAPR) 1,000 25/ 1,000 4 25 3. Supplied-Air Respirator (SAR) or Airline Respirator • Demand mode 10 • Continuous flow mode • Pressure-demand or other positive-pressure mode 4. Self-Contained Breathing Apparatus (SCBA) • Pressure-demand or other positive-pressure mode (e.g., open/closed circuit) 10,000 1)Employers may select respirators assigned for use in higher workplace concentrations of a hazardous substance for use at lower concentrations of that substance, or when required respirator use is independent of concentration. 2)The assigned protection factors in Table 1 are only effective when the employer implements a continuing, effective respirator program as required by this section (29 CFR ), including training, fit testing, maintenance, and use requirements. 3)This APF category includes filtering facepieces, and half masks with elastomeric facepieces. 4)The employer must have evidence provided by the respirator manufacturer that testing of these respirators demonstrates performance at a level of protection of 1,000 or greater to receive an APF of 1,000. This level of performance can best be demonstrated by performing a WPF or SWPF study or equivalent testing. Absent such testing, all other PAPRs and SARs with helmets/hoods are to be treated as loose-fitting facepiece respirators, and receive an APF of 25. 5)These APFs do not apply to respirators used solely for escape. For escape respirators used in association with specific substances covered by 29 CFR 1910 subpart Z, employers must refer to the appropriate substance-specific standards in that subpart. Escape respirators for other IDLH atmospheres are specified by 29 CFR (d)(2)(ii).

63 Use of Respirators Respirators with tight‑fitting facepieces cannot be worn by employees who have: Facial hair that comes between the sealing surface of the facepiece and the face or that interferes with valve function; or Any condition that interferes with the face‑to‑facepiece seal or valve function. 29 CFR (g)

64 Use of Respirators If an employee wears corrective glasses or goggles or other personal protective equipment, such equipment must be worn in a manner that does not interfere with the seal of the facepiece to the face of the user. For all tight‑fitting respirators, a user seal check must be preformed each time they put on the respirator. 29 CFR (g)

65 User Seal Check Positive pressure check.
Close off the exhalation valve and exhale gently into the facepiece. The face fit is considered satisfactory if a slight positive pressure can be built up inside the facepiece without any evidence of outward leakage of air at the seal. For most respirators this method of leak testing requires the wearer to first remove the exhalation valve cover before closing off the exhalation valve and then carefully replacing it after the test. 29 CFR Appendix B

66 User Seal Check Negative pressure check.
Close off the inlet opening of the canister or cartridge(s) by covering with the palm of the hand(s) or by replacing the filter seal(s), inhale gently so that the facepiece collapses slightly, and hold the breath for ten seconds. The design of the inlet opening of some cartridges cannot be effectively covered with the palm of the hand. The test can be performed by covering the inlet opening of the cartridge with a thin latex or nitrile glove. If the facepiece remains in its slightly collapsed condition and no inward leakage of air is detected, the tightness of the respirator is considered satisfactory. 29 CFR Appendix B

67 Maintenance and Care of Respirators
All respirator users will be provided with a respirator that is clean, sanitary, and in good working order. The respirators shall be cleaned and disinfected at the following intervals: Assigned respirators Ccleaned and disinfected as often as necessary to be maintained in a sanitary condition; Multi user respirators Cleaned and disinfected before being worn by different individuals; Respirators maintained for emergency use shall be cleaned and disinfected after each use; and Respirators used in fit testing and training shall be cleaned and disinfected after each use. 29 CFR (h)

68 Maintenance and Care of Respirators
Respirators must be inspected as follows: All respirators used in routine situations shall be inspected before each use and during cleaning; All respirators maintained for use in emergency situations shall be inspected at least monthly and in accordance with the manufacturer's recommendations, and shall be checked for proper function before and after each use; and Emergency escape‑only respirators shall be inspected before being carried into the workplace for use. 29 CFR (h)

69 Maintenance and Care of Respirators
Respirator inspections must include the following: A check of respirator function, tightness of connections, and the condition of the various parts; and A check of elastomeric parts for pliability and signs of deterioration; All self‑contained breathing apparatus shall be inspected monthly.; All regulators and warning devices must function properly. Air and oxygen cylinders shall be maintained in a fully charged state and shall be recharged when the pressure falls to 90% of the manufacturer's recommended pressure level 29 CFR (h)

70 Breathing Air Quality and Use
All compressed air, compressed oxygen, liquid air, and liquid oxygen used for respiration must meet the following specifications: Compressed and liquid oxygen shall be medical or breathing oxygen; and Compressed breathing air shall meet at least the requirements for Type 1‑Grade D breathing. Oxygen concentrations greater than 23.5% must be used only in equipment designed for oxygen service or distribution. 29 CFR (i)

71 Identification of Filters, Cartridges, and Canisters
All filters, cartridges and canisters used in the workplace must be and remain labeled and color coded with the NIOSH approval label. 29 CFR (j)

72 Training and Information
Training must cover at least the following: Why the respirator is necessary and the dangers of improper fit, usage, or maintenance; What the limitations and capabilities of the respirator are; How to use the respirator effectively in emergency situations; How to inspect, put on and remove, use, and check the seals of the respirator; What the procedures are for maintenance and storage of the respirator; How to recognize medical signs and symptoms that may limit the effective use of respirators; and The general requirements of this section. 29 CFR (k)

73 Training and Information
Retraining shall be administered annually, and when the following situations occur: Changes in the workplace or the type of respirator render previous training obsolete; Inadequacies in the employee's knowledge or use of the respirator indicate that the employee has not retained the requisite understanding or skill; or Any other situation arises in which retraining appears necessary to ensure safe respirator use. 29 CFR (k)

74 Training and Information
The basic advisory information on respirators, as presented in Appendix D of this section, shall be provided by the employer in any written or oral format, to employees who wear respirators when such use is not required by this program. 29 CFR (k)

75 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. OSHA does not anticipate that engineering and work practice controls will eliminate the need for protective clothing and equipment and hygiene facilities for protection from dermal hazards. To determine whether there is a hazard (or likely to be a hazard) from skin or eye contact with Cr(VI) in a particular workplace, the employer should ‘‘exercise common sense and appropriate expertise’’ in assessing the 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 walk-through survey to identify sources of hazards to workers. Review of injury/ accident data is also recommended. Information obtained during this process provides a basis for the evaluation of potential hazards. The Agency does not have sufficient evidence to demonstrate that a skin or eye hazard will necessarily occur when exposures exceed the PEL. 29 CFR (g)

76 Removal and Storage 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. 29 CFR (g)

77 Removal and Storage 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. 29 CFR (g)

78 Cleaning and Replacement
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. OSHA does not specify how often clothing and equipment must be cleaned, repaired or replaced. 29 CFR (g)

79 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. Change rooms that meet the requirements of 29 CFR (e) or 29 CFR (i) fulfill the change room requirements of this final Cr(VI) rule. The employer must provide readily accessible washing facilities capable of removing Cr(VI) from the skin and ensure that affected employees use these facilities when necessary. Also, the employer must ensure that employees who have skin contact with Cr(VI) wash their hands and faces at the end of the work shift and prior to eating, drinking, smoking, chewing tobacco or gum, applying cosmetics, or using the toilet. 29 CFR (h)

80 Eating and Drinking Areas
Eating and drinking areas and surfaces must be maintained as free as practicable of chromium (VI). Employees must not enter eating and drinking areas with protective work clothing or equipment unless surface chromium (VI) has been removed. Where the employer chooses to allow employees to consume food or beverages at a worksite where Cr(VI) is present, OSHA intends for the employees to be protected from Cr(VI) exposures in these areas. To this end OSHA is requiring the employer to ensure that eating and drinking areas are as free as practicable of Cr(VI). 29 CFR (h)

81 Prohibited Activities
Employees must not eat, drink, smoke, chew tobacco or gum, or apply cosmetics in areas where skin or eye contact with chromium (VI) occurs; or Carry the products associated with these activities, or store such products in these areas. 29 CFR (h)

82 Medical Surveillance Medical surveillance must be made available at no cost to the employee, and at a reasonable time and place, for all employees: Who are or may be occupationally exposed to chromium (VI) at or above the action level for 30 or more days a year; Experiencing signs or symptoms associated with chromium (VI) exposure; or Exposed in an emergency. If participation requires travel away from the worksite, the employer would be required to bear the cost. Employees would have to be paid for time spent taking medical examinations, including travel time. The fact that an employer may not be able to identify the specific exposure that caused a particular observed effect does not negate the value of identifying such effects and making sure that the affected employee gets the proper medical attention. 29 CFR (i)

83 Medical Surveillance Medical examination provided:
Within 30 days after initial assignment, a Physician or other Licensed Health Care Professional’s (PLHCP's) written recommendation, or exposure during an emergency; Annually; OSHA has interpreted the requirements to mean that Physician or other Licensed Health Care Professional’s (PLHCP’s) must be licensed in the states of residence for the employees they evaluate. OSHA can cite, using the Cr(VI) standard, an employer for using a health care professional who is not operating under his or her legal scope of practice. The requirement that the employer offer a medical examination at the termination of employment is intended to assure that no employee terminates employment while carrying an active, but undiagnosed, disease. 29 CFR (i)

84 Medical Surveillance Medical examination provided:
Whenever there are signs or symptoms of the adverse health effects; At the termination of employment, unless the last examination that satisfied the requirements of paragraph (i) of this section was less than six months prior to the date of termination. 29 CFR (i)

85 Medical Surveillance A medical examination consists of:
A medical and work history; A physical examination of the skin and respiratory tract. The employer shall obtain a written medical opinion from the PLHCP within 30 days. CPMA cautioned that in the ‘‘current malpractice environment’’, a requirement for any additional examination deemed necessary by the PLHCP would result in licensed health care professionals ordering a battery of tests in order to prevent the possibility of malpractice claims, and the employer would be required to pay for them (Ex. 38–205). 29 CFR (i)

86 Information to PLHCP Copy of standard
Description of employee’s duties of exposure Employee’s former, current and anticipated levels of exposure PPE used and duration of use Information from records of employment –related medical examinations 29 CFR (i)

87 PLHCP’s Written Medical Opinion
A medical examination consists of: A medical and work history; A physical examination of the skin and respiratory tract. The employer shall obtain a written medical opinion from the PLHCP within 30 days. 29 CFR (i)

88 PLHCP’s Written Medical Opinion
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)

89 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. The final standard also requires that the employer make a copy of the standard readily available to employees without cost. Specifically, with regard to the purpose and description of the medical surveillance program, OSHA intends that employees be trained about the signs and symptoms of Cr(VI)-related adverse health effects. The communication of hazards elements proposed, but not included the final rule, are requirements for: Warning signs for regulated areas; Warning labels for Cr(VI)-contaminated work clothing and equipment and Cr(VI) wastes and debris; Employees to be provided training and training records; Initial training; Training that is understandable; Certain topics for training; and Additional training. The items removed address: the health hazards associated with Cr(VI) exposure; the location, manner of use and release of Cr(VI); engineering controls and work practices associated with the employee’s job assignment; the purpose, selection and use of respirators and protective clothing; emergency procedures; and measures employees can take to protect themselves. 29 CFR (j)

90 Communication of Hazards
29 CFR (h) (1) Employers shall provide employees with effective information and training on hazardous chemicals in their work area at the time of their initial assignment, and whenever a new physical or health hazard the employees have not previously been trained about is introduced into their work area. Information and training may be designed to cover categories of hazards (e.g., flammability, carcinogenicity) or specific chemicals. Chemical-specific information must always be available through labels and material safety data sheets. 29 CFR (j)

91 Communication of Hazards
29 CFR (h) (2) "Information." Employees shall be informed of: (i) The requirements of this section; (ii) Any operations in their work area where hazardous chemicals are present; and, (iii) The location and availability of the written hazard communication program, including the required list(s) of hazardous chemicals, and material safety data sheets required by this section. 29 CFR (j)

92 Communication of Hazards
29 CFR (h) (3) "Training." Employee training shall include at least: (i) Methods and observations that may be used to detect the presence or release of a hazardous chemical in the work area; (ii) The physical and health hazards of the chemicals in the work area; 29 CFR (j)

93 Communication of Hazards
29 CFR (h) (3) "Training." Employee training shall include at least: (iii) The measures employees can take to protect themselves from these hazards, including specific procedures the employer has implemented to protect employees from exposure to hazardous chemicals, such as appropriate work practices, emergency procedures, and personal protective equipment to be used; and, (iv) The details of the hazard communication program developed by the employer, including an explanation of the labeling system and the material safety data sheet, and how employees can obtain and use the appropriate hazard information.

94 Recordkeeping Record to include at least the following information:
The date of measurement; The operation involved; Sampling and analytical methods used and evidence of their accuracy; Number, duration, and the results of samples taken; Type of personal protective equipment used; and Name, social security number, and job classification of all employees represented by the monitoring, indicating which employees were actually monitored. Where objective data are used to satisfy the exposure determination requirement, the employer must establish and maintain an accurate record of the objective data upon which he or she relied. This record must include: The chromium-containing material in question; the source of the objective data; the testing protocol and results of testing, or analysis of the material for the release of chromium (VI); a description of the process, operation, or activity involved and how the data support the determination; and other data relevant to the process, operation, activity, material, or employee exposures 29 CFR (k)

95 Recordkeeping Each employee exposure record shall be preserved and maintained for at least thirty (30) years. 29 CFR (k)

96 Dates For employers with 20 or more employees, all obligations of this section, except engineering controls required by paragraph (e) of this section, commence November 27, 2006. For employers with 19 or fewer employees, all obligations of this section, except engineering controls required by paragraph (e) of this section, commence May 30, 2007. For all employers, engineering controls required by paragraph (e) of this section shall be implemented no later than May 31, 2010. 29 CFR (l)


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