1. Update: Hexavalent Chromium Cr(VI) Drawn from the Preambles and Training Materials from the National Office and Regions 5 and 6

2. Purpose Present an overview of the major provisions of OSHA’s Cr(VI) standard (71 FR 10100, February 28, 2006). Note: This presentation is for training purposes only. Consult the Federal Register on OSHA’s web site for the complete requirements of this standard.

3. What is Hexavalent Chromium? Toxic form of chromium metal that is generally man-made Used in many industrial applications primarily for its anti-corrosive properties Can be created during certain “hot” work processes where the original form of chromium was not hexavalent

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. Electroplating Welding/cutting/torching/grinding painted surfaces Welding/cutting/grinding stainless steel, chrome alloys and even carbon steel Applying/removing coatings with chrome Glass production Chemical synthesis Chromium catalyst users Printing ink production Operations with Cr(VI) Exposure

6. Routes of Exposure Inhalation of dusts, mists, or fumes created during processes involving the use of Cr(VI) compounds or hot processes that cause the formation of Cr(VI) Eye or skin contact with powder, dusts or liquids containing Cr(VI) with skin absorption possible Ingestion through contamination of food and drink (controversy over extent of issue)

7. Major Health Effects Lung cancer Nasal septum ulcerations and perforations Asthma Skin ulcers Allergic and irritant contact dermatitis

8. History of Exposure Limits 1943 ANSI standard was the source of OSHA’s 1971 standard of 1mg/10 m3 Cr(III) or 52 µg/m3 CR(VI) Mounting evidence of carcinogenicity  1974 by ACGIH  1975 by NIOSH  1984 by EPA  1990 by IARC

9. Occupational Exposure Limits NIOSH REL  0.001 mg Cr VI/M3 10-hr TWA ACGIH TLV  Water-Soluble Cr VI compounds as Cr 0.05 mg/M3 TWA  Insoluble Cr VI compounds as Cr 0.01 mg/M3 TWA ACGIH BEI  Total chromium in urine BEIs (2) for Chrome VI water soluble fume

10. History of New Standard In 1993 the Health Research Group petitioned for ETS of 0.5 µg/m3  OSHA unable to demonstrate “grave danger” In 1997 HRG sued to complete rulemaking process and lost In 2002 HRG sued to complete rulemaking process and won  Proposed rule to be issued 10/4/04  Final rule to be issued 1/18/06  Final rule was issued 2/28/06

11. Steps to Complete a Rule 1. Review all research on health effects ** 2. Peer review of OSHA review 3. Develop risk assessment ** 4. Justify significance of risk assessment 5. Perform Economic Analysis and Regulatory Flexibility Analysis with SBREFA Assessment – 6 issues for each potential PEL ** 6. Submit to OMB – 5 laws 7. Proposed rule with Questions 8. Hearings 9. Final Rule

12. Case Law for Health Standards 1980 Supreme Court decision on benzene requires examination of significance of risk (cost-benefit) 1981 Lead and Cotton Dust cases gave concept of technological and economical feasibility in view of financial health and profitability of industry and impact on unit pricing **

13. Greater Risk Than Asbestos At the new technologically and economically feasible PEL, the cancer risk from Cr(VI) is higher than other regulated carcinogens  Methylene Chloride: 3.6 per 1000 workers  Asbestos: 6.7 deaths per 1000 workers  Benzene: 10 deaths per 1000 workers  Cr VI: 10-45 excess lung cancer deaths per 1000 workers for 45 years of exposure at new PEL of 5 ug/M3 2/28/06 FR p. 10225

14. Three Cr(VI) Standards 1910.1026General Industry 1926.1126Construction 1915.1026Shipyards

15. Major Provisions of the Standards Scope Permissible Exposure Limit (PEL) Exposure Determination Regulated areas * Methods of Compliance Respiratory Protection Protective Work Clothing and Equipment * General industry only Hygiene Areas and Practices Housekeeping* Medical Surveillance Communication of Hazards Recordkeeping Dates

16. Scope: Who is Covered by the Standard? Exposures that occur in the application of pesticides  Application is already covered by EPA Standards  The manufacture of pesticides and handling of pesticide treated materials are covered under new OSHA standard All occupational exposures to Cr(VI) compounds except:

17. Scope: Who is Covered by the Standard? Exposures that occur in the application of pesticides Exposures to portland cement  American portland cement usually contains only trace amounts  Would typically be over PEL for PNOR before over on Cr(VI)  Use PNOR, Personal Protective Equipment and Hazard Communication Standards for protection All occupational exposures to Cr(VI) compounds except:

18. Scope: Who is Covered by the Standard? Exposures that occur in the application of pesticides Exposures to portland cement Where employers have objective data demonstrating that a material containing chromium or a process involving chromium cannot release Cr(VI) in concentrations at or above 0.5 µg/m 3 as an 8-hour time-weighted average (TWA) under any condition of use All occupational exposures to Cr(VI) compounds except:

19. Permissible Exposure Limit (PEL) and Action Level (AL) PEL: 5 µg/m 3 - TWA AL: 2.5 µg/m 3 - TWA

20. Exposure Determination Scheduled monitoring option Performance-oriented option Two options allowed for determining employee exposures:

21. Scheduled Monitoring Option Prescribes a schedule for performing initial and periodic personal monitoring If initial monitoring indicates exposures are:  Below the AL: monitoring can be discontinued  At or above the AL: monitor every 6 months  Above the PEL: monitor every 3 months

22. Performance-Oriented Option Exposures characterized using any combination of air monitoring data, historical monitoring data or objective data No fixed schedule for performing periodic monitoring

23. General Requirements for Exposure Determination Affected employees must be notified where exposures exceed the PEL

24. General Requirements for Exposure Determination Affected employees must be notified where exposures exceed the PEL Methods used for air monitoring and analysis must be sufficiently accurate [+/- 25% and within a statistical confidence level of 95% at AL]

25. General Requirements for Exposure Determination Affected employees must be notified where exposures exceed the PEL Methods used for air monitoring and analysis must be sufficiently accurate Employees or their representatives must be allowed to observe Cr(VI) monitoring

26. Regulated Areas For general industry employers only

27. Regulated Areas For general industry employers only Areas where exposures exceed or can be reasonably expected to exceed the PEL  Must be demarcated from other areas  Must limit access to employees who have a need to be there

28. Methods of Compliance Establishes engineering and work practice controls as the primary means of achieving the PEL

29. Methods of Compliance Exceptions:  Painting aircraft or large aircraft parts: Use engineering and work practice controls to achieve 25 µg/m 3 and supplement with respirators to achieve the PEL  Tasks or operations that do not result in exposures above the PEL for 30 or more days per year: Use of respirators alone allowed to achieve the PEL Establishes engineering and work practice controls as the primary means of achieving the PEL

30. Methods of Compliance Exceptions:  Painting aircraft or large aircraft parts:  Tasks or operations that do not result in exposures above the PEL for 30 or more days per year Establishes engineering and work practice controls as the primary means of achieving the PEL Prohibits job rotation to achieve compliance with the PEL

31. Respiratory Protection Required Periods necessary to install or implement feasible engineering and work practice controls Maintenance or repair operations where engineering and work practice controls are infeasible Operations where all feasible controls have been used and exposures are still above the PEL Operations where exposures do not exceed the PEL for 30 or more days per year Emergencies

32. Assigned Protection Factors Final Rule August 24, 2006 Type of Respirator 1,2 12 Half MaskFull Facepiece Helmet/ Hood Loose- Fitting 1. Air-Purifying Respirator10 3 3 50—— 2. Powered Air-Purifying Respirator (PAPR) 501,00025/1,000 4 4 25 3. Supplied-Air Respirator (SAR) or Airline Respirator Demand mode Continuous flow mode Pressure-demand or other positive- pressure mode 10 50 50 50 1,000 1,000 — 25/1,000 4 — 4 — 25 — 4. Self-Contained Breathing Apparatus (SCBA) Demand mode Pressure-demand or other positive- pressure mode (e.g., open/closed circuit) 10 — 50 10,000 —

33. Protective Work Clothing and Equipment Use where a hazard is present or is likely to be present from skin or eye contact with Cr(VI) Provided and paid for by the employer Remove Cr(VI)-contaminated clothing and equipment when work shift or task is completed Clean, store and label Cr(VI)-contaminated clothing and equipment

34. Hygiene Areas and Practices Must provide change rooms and washing facilities per 29 CFR 1910.141 Employees must wash their hands and face at the end of a work shift and prior to eating, drinking, smoking, etc. Employer-provided eating areas must be kept as free as practicable of Cr(VI) No eating, drinking, smoking etc. in regulated areas

35. Housekeeping For general industry employers only Keep all surfaces as free as practicable of accumulations of Cr(VI) Use HEPA vacuums or other methods that minimize exposure to Cr(VI) Use of compressed air prohibited unless:  Used in conjunction with a ventilation system to capture the dust cloud created by the compressed air, or  No alternative method is feasible Dispose of Cr(VI)-contaminated waste in labeled, impermeable bags/containers

36. Medical Surveillance Provisions for conducting baseline and periodic health assessments of exposed employees Provided by or under the supervision of a physician or other licensed health care professional (PLHCP) Provided at no cost to employee and at a reasonable place and time

37. Purpose of Medical Surveillance Determine if an individual can be exposed to the Cr(VI) present in their workplace without experiencing adverse health effects Indentify Cr(VI)-related adverse health effects so that appropriate intervention measures can be taken Determine the employee’s fitness to use PPE, such as respirators

38. Which Employees Must Be Provided Medical Surveillance? Exposed at or above the action level (2.5 µg/m 3 ) for 30 or more days per year Experiencing signs or symptoms of Cr(VI) exposure Exposed in an emergency

39. Medical Examination Requirements Medical and work history, with emphasis on:  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 PLHCP

40. When Must Medical Examinations Be Offered? Within 30 days after initial assignment and annually thereafter Within 30 days after a PLCHP recommends additional examinations When employees shows signs or symptoms of Cr(VI) exposure Within 30 days after exposure during an emergency At the termination of employment

41. Communication of Hazards Provide employee training in accordance with OSHA’s Hazard Communication standard (29 CFR 1910.1200) Additional training on the contents of the Cr(VI) standard and the purpose and description of the medical surveillance program required by the standard

42. Recordkeeping No requirement to maintain training records Must maintain records per 29 CFR 1910.1020 for:  Air monitoring data  Historical monitoring data  Objective data  Medical surveillance information, including: PLHCP’s written opinions Information provided to the PLHCP

43. Compliance Start-Up Dates Effective date: May 30, 2006 Start-up dates:  All provisions except engineering controls For employers with 19 or fewer employees: May 30, 2007 For all others: November 27, 2006  Engineering Controls For all employers: May 31, 2010

44. Hexavalent Chromium Some practical issues

45. FR Preamble: Exposure Ranges Task1-5 µg/m 3 Above PEL Electroplating11%13% WeldingStainless SteelGI13%31% Const15%27% Carbon SteelGI & Const12%6% PaintingGI3%17% Const16%7% Steel MillsStainless SteelGI25%7% Carbon SteelGI0.5%7% Iron & SteelFoundriesGI15%5% WoodworkingGI0%14% Const22%11%

46. OSHA Internal Training on Hexavalent Chromium Sampling Most pre-existing sampling was for total chrome, probably due to low cost  $50 for total metals analysis via ICP  $150 for Cr(VI) analysis No way to separate or back calculate Cr(VI) exposures from total chrome (ICP) Comments at 5/2006 AIHCE “Ask the Experts” Cr(VI) session indicate little new Cr(VI) sampling has been done Conclusion: Exposure levels are not known WE NEED TO SAMPLE

47. Cr VI SLTC Analysis OSHA ID215 as of 6/2006 Closed face 37mm PVC filter @ 2 lpm Lab extraction of Cr VI from filter using an aqueous solution of sodium carbonate/sodium bicarbonate Ion chromatography for Cr VI with postcolumn UV/visible detector set at 540nm wavelength Limit of detection: 0.003 ug/M3 SAE: varies, approx 0.112

48. Interferences – Welding Fume Sampling While in the cassette, Cr+6 reacts with iron Fe+2 to form Cr+3 Cr+3 is not analyzed by method ID215 In 6 days you lose 10% of Cr+6 through the Fe+2 reduction reaction SHIP SAMPLE TO LAB IMMEDIATELY If mailing will be delayed, get buffer solution from the lab ahead of time. While in the field you put the filters in the buffer solution to stabilize Cr+6

49. Interferences – Plating Sampling While in the cassette, Cr+6 reacts with acids from the plating baths to form Cr+3 Cr+3 is not analyzed by method ID215 In 6 days you lose 10% of Cr+6 through this acid reduction reaction Order sodium hydroxide coated filters from the lab on an as needed basis for plating sampling  NaOH neutralizes the acid to cut down on Cr+6 loss  Helps maintain Cr+6 on the filter for 30 days  1-3 month expiration date on these coated filters SHIP SAMPLE TO LAB IMMEDIATELY

50. Filter Blanks PVC filters are normally cut from sheet filter stock using a stainless steel cutter Stainless steel contains chromium, and stainless steel cutters leave chrome VI contamination on filters OSHA uses PVC filters cut with a teflon coated stainless cutter to reduce/avoid background chrome contamination Some employers may be taking samples with filters contaminated by stainless cutters. SEND FILTER BLANKS! 5 ug/M3 is a minute amount of material, and filter blanks will help avoid employer objections to your sample results

51. Other Sampling Methods 1% NaOH coated binderless quartz fiber filter wipe sample method is available A colorimetric wipe test will be available soon. You will be able to perform wipe tests in lunchrooms, etc., and demonstrate evidence of contamination New sampling method is under review: OSHA analytical method ID215 may be updated to use buffer solution in the field