Hexavalent Chromium “New OSHA Standard” Informational Web Cast

Presented by MSA John Hierbaum Product Line Manager Air Purifying Respirators & Meghan Swanson Staff Chemist

WELCOME Thank You for joining us today

CAUTION! This presentation is an overview of the new standard This presentation is an overview of the new standard This presentation does not represent the complete standard as published by OSHA This presentation does not represent the complete standard as published by OSHA It is important that all participants review the entire standard before implementing a program within the workplace It is important that all participants review the entire standard before implementing a program within the workplace

AGENDA Timetable for the new Hexavalent Chromium Standard Timetable for the new Hexavalent Chromium Standard Workers most notably affected Workers most notably affected What is Hexavalent Chromium? What is Hexavalent Chromium? What are its health hazards?What are its health hazards? Elements of the New Standard Elements of the New Standard Steps to comply with the new standard Steps to comply with the new standard Q & A Q & A

New OSHA Standard Hexavalent Chromium Covers Covers General Industry General Industry Shipyards Shipyards Construction Construction Most requirements are generally the same for all industries Most requirements are generally the same for all industries

Exceptions to the New Standard Does not impact application of some pesticides (EPA regulated) Does not impact application of some pesticides (EPA regulated) Does not impact exposures to portland cement Does not impact exposures to portland cement Does not impact situations in which the employer has objective data demonstrating that a material containing chromium or specific operation or activity cannot release Cr (VI) in concentrations at or above 0.5 µg/m 3 as an 8 hour TWA Does not impact situations in which the employer has objective data demonstrating that a material containing chromium or specific operation or activity cannot release Cr (VI) in concentrations at or above 0.5 µg/m 3 as an 8 hour TWA

Significant Dates to Remember February 28, OSHA published the new standard February 28, OSHA published the new standard May 30, 2006 – Effective date May 30, 2006 – Effective date Enforced 180 days from the effective date with exceptions Enforced 180 days from the effective date with exceptions Nov 27, 2006 – 20 or more employeesNov 27, 2006 – 20 or more employees May 31, 2007 – less than 20 employeesMay 31, 2007 – less than 20 employees May 31, engineering control requirementsMay 31, engineering control requirements

What Activities are the Sources of Chromium (VI)? Welding and cutting of stainless steel and other chromium containing metals Welding and cutting of stainless steel and other chromium containing metals Heavy Painting and coating Heavy Painting and coating Electroplating Electroplating Handling of chrome based pigments Handling of chrome based pigments

How Many Workers are Exposed? About 558,000 workers are exposed to Cr(VI) About 558,000 workers are exposed to Cr(VI) Several workers will be required to use respiratory protection Several workers will be required to use respiratory protection Welders represent the highest single worker group exposed Welders represent the highest single worker group exposed

WHAT IS HEXAVALENT CHROMIUM?

Cr(VI) Hexavalent chromium (Cr(VI)) compounds exist in several forms, known as chromates Hexavalent chromium (Cr(VI)) compounds exist in several forms, known as chromates Typically particulatesTypically particulates Yellow, orange, or red in colorYellow, orange, or red in color Trivalent chromium (Cr(III)) is the most stable state; naturally occuring Trivalent chromium (Cr(III)) is the most stable state; naturally occuring Cr(VI) is less chemically stable; most compounds are man made Cr(VI) is less chemically stable; most compounds are man made

Chromates have Varying Solubilities Highly soluble in water: Highly soluble in water: Sodium dichromateSodium dichromate Chromic acidChromic acid Slightly soluble in water: Slightly soluble in water: Calcium chromateCalcium chromate Strontium chromateStrontium chromate Zinc chromateZinc chromate Insoluble in water: Insoluble in water: Lead chromateLead chromate Barium chromateBarium chromate

Exposure Routes Inhalation Inhalation Particulates, such as:Particulates, such as: Paint sprayPaint spray Welding fumesWelding fumes Chromate dustChromate dust Skin exposure Skin exposure

Health Effects Respiratory Respiratory Lung cancerLung cancer Damage to nasal membranesDamage to nasal membranes AsthmaAsthma Dermal Dermal Skin damageSkin damage Internal organs Internal organs KidneyKidney LiverLiver

Carcinogenic Effects: Lung Cancer 1. Cells uptake Cr(VI) Faster for soluble forms of Cr(VI) Faster for soluble forms of Cr(VI) Insoluble chromates concentrate Insoluble chromates concentrate Particles < 10 µm contact target cells Particles < 10 µm contact target cells 2. Cells react with Cr(VI) to form Cr(III) and toxic byproducts, Reactive Oxygen Species 3. DNA is damaged 4. Cell replication disturbed

Other Respiratory Effects Nasal Irritation Nasal Irritation Nasal Ulcerations Nasal Ulcerations Nasal Septum Perforations Nasal Septum Perforations Asthma Asthma Cr(VI) is an airway sensitizerCr(VI) is an airway sensitizer Exposure prompts immune responseExposure prompts immune response Bronchitis Bronchitis

Additional Health Effects Dermal Dermal Contact dermititisContact dermititis Skin ulcersSkin ulcers Internal Internal Gastrointestinal ulcersGastrointestinal ulcers Kidney diseaseKidney disease Liver damageLiver damage

Summary of Health Issues Major health effects Major health effects Lung cancerLung cancer Damage to nasal passagesDamage to nasal passages Skin rashes and ulcersSkin rashes and ulcers A high % of workers exposed can get lung cancer A high % of workers exposed can get lung cancer This standard is intended to reduce these health risks This standard is intended to reduce these health risks

Major Elements of the New Standard Permissible Exposure Level Permissible Exposure Level Exposure Determination Exposure Determination Engineering Controls Engineering Controls Personal Protection Personal Protection Medical Surveillance Medical Surveillance Worker Education and communication Worker Education and communication

Permissible Exposure PEL PEL Reduced from 52 micrograms of Cr(VI) per cubic meter of air as an eight-hour time weighted average (TWA) to 5 µg/m 3Reduced from 52 micrograms of Cr(VI) per cubic meter of air as an eight-hour time weighted average (TWA) to 5 µg/m 3 This cannot be achieved by rotation of employees This cannot be achieved by rotation of employees Note: OSHA originally wanted to reduce the PEL to 1 µg/m 3Note: OSHA originally wanted to reduce the PEL to 1 µg/m 3 Draft standard Draft standard Action Level Action Level 2.5 micrograms per cubic meter of air2.5 micrograms per cubic meter of air

Exposure Determination Employer has 2 choices Employer has 2 choices Scheduled monitoringScheduled monitoring Performance orientedPerformance oriented Must determine the 8-hour TWA exposure for each employee Must determine the 8-hour TWA exposure for each employee

Scheduled Monitoring Initial monitoring Initial monitoring Sufficient # of samplesSufficient # of samples Full-shift exposureFull-shift exposure All job classificationsAll job classifications Follow-up monitoring Follow-up monitoring None if below action levelNone if below action level 6 months if above action level6 months if above action level 3 months if above PEL3 months if above PEL

Monitoring Guidelines If employee exposure exceeds PEL If employee exposure exceeds PEL Employer must notify employee within 15 daysEmployer must notify employee within 15 days Post informationPost information Written notificationWritten notification Accuracy of measuring equipment Accuracy of measuring equipment +/- 25% +/- 25% Confidence level of 95% Confidence level of 95% Employees can observe monitoring Employees can observe monitoring Employer to provide personal protectionEmployer to provide personal protection

Performance Oriented Option Air monitoring data Air monitoring data Historical monitoring data Historical monitoring data Objective data Objective data If employee exposure exceeds PEL If employee exposure exceeds PEL Employer must notify employee within 15 daysEmployer must notify employee within 15 days Post informationPost information Written notificationWritten notification

Engineering Controls Engineering controls mandatory with exceptions Engineering controls mandatory with exceptions Effective date Effective date May 31, 2010May 31, 2010 Shall reduce the exposure below the PEL Shall reduce the exposure below the PEL If not feasible, respiratory protection must be used If not feasible, respiratory protection must be used

Exceptions to Eng. Controls #1 - Aerospace #1 - Aerospace Painting large aircraftPainting large aircraft Must reduce exposure below 25 microgramsMust reduce exposure below 25 micrograms Unless not feasible Unless not feasible Supplement with proper respiratory protection Supplement with proper respiratory protection #2 - Employee is not exposed above PEL for 30 or more days per year #2 - Employee is not exposed above PEL for 30 or more days per year

PPE Respiratory Protection Respiratory Protection To comply, one can use a traditional half-mask NIOSH approved respirator with N-95 filters. For maximum protection however, MSA recommends a P-100 filter with a full facepiece.To comply, one can use a traditional half-mask NIOSH approved respirator with N-95 filters. For maximum protection however, MSA recommends a P-100 filter with a full facepiece. Respiratory program must be in accordance with 29 CFR Respiratory program must be in accordance with 29 CFR A copy of this is available on the MSA web site A copy of this is available on the MSA web site

Other PPE Work clothing Work clothing Provided by employer where necessaryProvided by employer where necessary No cost to employeeNo cost to employee Employer must ensure it is usedEmployer must ensure it is used Must be cleaned properly, taking precautions to prevent contamination of other employeesMust be cleaned properly, taking precautions to prevent contamination of other employees

Medical Surveillance Employer to offer free of charge Employer to offer free of charge All employees who may be exposed above the action level for 30 or more days per year All employees who may be exposed above the action level for 30 or more days per year Employees showing signs of exposure Employees showing signs of exposure Employees exposed in an emergency Employees exposed in an emergency

Medical Surveillance Frequency Within 30 days of initial assignment, unless employee had Cr(VI) exam within last 12 months Within 30 days of initial assignment, unless employee had Cr(VI) exam within last 12 months Annually Annually Within 30 days of PLHCP’s recommendation for further exam Within 30 days of PLHCP’s recommendation for further exam If employee shows signs or symptoms If employee shows signs or symptoms Within 30 days of emergency exposure Within 30 days of emergency exposure At termination, unless last exam was within 6 months At termination, unless last exam was within 6 months Exam must include medical & work history, history of respiratory problems, other specific problems (listed in rule) Exam must include medical & work history, history of respiratory problems, other specific problems (listed in rule)

Medical Surveillance Employer must provide to PLHCP: copy of this standard, a description of employees duties, employees exposure level to CrVI, description of PPE and how long used by employee, information on previous employee medical exams Employer must provide to PLHCP: copy of this standard, a description of employees duties, employees exposure level to CrVI, description of PPE and how long used by employee, information on previous employee medical exams PLHCP’s written medical opinion: furnished within 30 days of exam, any detected medical condition which affects work, employee limitations on work and PPE usage, statement that the PLHCP has explained results to employee PLHCP’s written medical opinion: furnished within 30 days of exam, any detected medical condition which affects work, employee limitations on work and PPE usage, statement that the PLHCP has explained results to employee Employer must provide exam info in writing to employee within 2 weeks of exam Employer must provide exam info in writing to employee within 2 weeks of exam

Employee Education and Communication Employer must provide a copy of the standard to the employee Employer must provide a copy of the standard to the employee Employer must insure employee can demonstrate knowledge of: Employer must insure employee can demonstrate knowledge of: The contents of this ruleThe contents of this rule The purpose and description of medical surveillanceThe purpose and description of medical surveillance

Recordkeeping Employer must keep records of Employer must keep records of Air monitoring dataAir monitoring data Historical monitoring dataHistorical monitoring data Objective dataObjective data Medical surveillanceMedical surveillance

Methods of Compliance Respiratory Protection Respiratory Protection Half-MaskHalf-Mask Full FacepieceFull Facepiece PAPRPAPR Air-Line RespiratorAir-Line Respirator Exposure determination Exposure determination Sampling EquipmentSampling Equipment

Advantage 200 LS Respirators Any NIOSH approved filter Any NIOSH approved filter P-100 (as shown) is best P-100 (as shown) is best Can use up to 10X the PEL Can use up to 10X the PEL

Advantage 3000 Respirator Full-Face Respirator Any NIOSH approved filter Can use up to 50X the PEL Full-Face Respirator Any NIOSH approved filter Can use up to 50X the PEL

Powered Respirator (PAPR) Used with full-face respirator Used with full-face respirator High Efficiency P- 100 filter High Efficiency P- 100 filter Can use up to 50X the PEL Can use up to 50X the PEL

Air Line Respirators Constant- Flow Constant- Flow Positive Pressure Positive Pressure No filter required No filter required Can be used up to 2000X the PEL Can be used up to 2000X the PEL You cannot exceed the maximum use concentration.You cannot exceed the maximum use concentration.

Monitoring To test exposure use an MSA Escort® Elf Sampling Pump To test exposure use an MSA Escort® Elf Sampling Pump The procedure for hexavalent chromium calls for particle collection using a 37-mm, 5- µm pore size PVC filter. The procedure for hexavalent chromium calls for particle collection using a 37-mm, 5- µm pore size PVC filter.

QUESTIONS? Thanks for attending!