Hexavalent Chromium Bryan Seal, CIH, CSP

What is it? Hexavalent chromium (Cr(VI)) is a toxic form of the element chromium. Hexavalent chromium is rarely found in nature and is generally man-made. There has been a general decline in the use of chromates in favor of less toxic inorganic and organic pigments where possible.

Health Effects Lung Cancer Irritation or damage to nasal passage and respiratory tract Irritation or damage to the eyes and skin

Industries –Aerospace –Automotive –Steel Mills/Foundries –Chemical and Dye Producers –Shipyards –Construction

Whos at risk? Tasks –Electroplating & Aluminum Etching –Welding –Painting –Sanding, Grinding, Cutting –Salvage operations –Woodworking

How workers can help? Identify Reduce exposure Wear PPE Hygiene

What Is OSHA Doing? Standards –Final Rule – Federal Register, Vol. 71, No. 39, February 28, 2006 Outreach (Guidance Documents) –Small Entity Compliance Guide for the Hexavalent Chromium Standards (OSHA N-2006) –Hexavalent Chromium (OSHA )

What is OSHA Doing? National Emphasis Program –National Emphasis Program – Hexavalent Chromium (CPL , 2/23/2010) –Regional Emphasis Program Involving Exposure to Hexavalent Chromium (VI) ( CPL 04, October 2012) Compliance Directive –Inspection Procedures for the Chromium (VI) Standards (CPL , 1/24/2008)

Letters of Interpretation (LOIs) 11/14/ (d)(3) Use of "objective data" to accurately characterize employee exposures to hexavalent chromium during welding operations. 01/25/ (h)(1) Wearing short-sleeved shirts while performing a thermal spray operation with exposure to hexavalent chromium fumes. 05/31/ ; 1026(a)(4); 1026(b); 1026(c); 1026(f)(1); 1026(j); 1026(j)(3)(i) Use of feasible engineering/work practice controls for exposure to Cr(VI) for welding in confined spaces; housekeeping and disposal of large/bulky waste materials.

LOIs 2008/ /27/ Clarification of employer's obligation to include social security numbers on employee exposure records. 06/29/ OSHA has no authority to ban use of hexavalent chromium.

LOIs 2010/ /30/ ; 1026(d)(2); 1026(j) Clarification of monitoring and sampling requirements for hexavalent chromium. 02/23/ ; 1026(i); 1026(j) Applicability of the hexavalent chromium standard to welders. Applicability of the hexavalent chromium standard to welders. [02/23/2011] 09/02/ ; 1026(h)(1); 1026(i)(1) Clarification of the Chromium (VI) Standard - Change Rooms and Hygiene Practices.

Wrap-up Identify, Quantify, Control Questions?? Thank you for your attention