Occupational Exposure to Hexavalent Chromium [Cr(VI)] Doug Fletcher, CIH, CSP OSHA - OAO

Objective Present an overview of the major provisions of OSHA’s Cr(VI) standard (71 FR 10100, February 28, 2006). FULL DISCLAIMER These materials were developed by OSHA’s Office of Training and Education and are intended to assist employers, workers, and others as they strive to improve workplace health and safety. While we attempt to thoroughly address specific topics, it is not possible to include discussion of everything necessary to ensure a healthy and safe working environment in a presentation of this nature. Thus, this information must be understood as a tool for addressing workplace hazards, rather than an exhaustive statement of an employer’s legal obligations, which are defined by statute, regulations, and standards. Likewise, to the extent that this information references practices or procedures that may enhance health or safety, but which are not required by a statute, regulation, or standard, it cannot, and does not, create additional legal obligations. Finally, over time, OSHA may modify rules and interpretations in light of new technology, information, or circumstances; to keep apprised of such developments, or to review information on a wide range of occupational safety and health topics, you can visit OSHA’s website at www.osha.gov.

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 Created during certain “hot” work processes where the original form of chromium was not hexavalent The metal chromium is an element that exists in several forms or “valence states”. The hexavalent form of chromium is a stable form that is known to be toxic. Another stable form, trivalent chromium, is not thought to be toxic. Hexavalent chromium can exist as many different compounds that vary from highly water soluble to slightly water soluble to water insoluble. Hexavalent chromium compounds have many varied uses in industry and are often used for their anti-corrosive properties in metal coatings, protective paints, dyes, and pigments. Hexavalent chromium can also be formed when performing “hot work” such as welding on stainless steel, melting chromium metal, or heating refractory bricks in kilns. In these situations the chromium is not originally hexavalent but the high temperatures cause oxidation that converts the chromium to hexavalent chromium.

How Can Occupational Exposures to Hexavalent Chromium Occur? Inhalation of mists, dusts or fumes created during processes involving the use of hexavalent chromium (CrVI) compounds or hot processes that cause the formation of CrVI Eye or skin contact with powder, dusts or liquids containing CrVI

Major Industries or Operations Covered by the Cr(VI) Standard Electroplating Welding on stainless steel or Cr(VI) painted surfaces Painting Aerospace Auto body repair Chromate pigment and chemical production Chromium dye and catalyst production Glass manufacturing Plastic colorant production Construction Traffic painting Refractory brick restoration Paint removal from bridges Some of the major industries covered by the standard are listed here. They represent industries and operations where you find the major exposures to Cr(VI).

Major Health Effects Lung cancer Nasal septum ulcerations and perforations Asthma Skin ulcers Allergic and irritant contact dermatitis The primary health effect of concern is lung cancer caused by airborne exposures to hexavalent chromium. Airborne exposures can also cause ulcers and holes in the nasal septum and may cause asthma in chromium sensitized individuals. OSHA considers all Cr(VI) compounds to be carcinogenic. Dermal exposures to hexavalent chromium can result in skin ulcers commonly referred to as “chrome holes” and may also lead to dermatitis.

Three Cr(VI) Standards 1910.1026 General Industry 1926.1126 Construction 1915.1026 Shipyards The final rule covers general industry, construction and shipyards. These standards are basically identical with the exception that the final standard for general industry has additional requirements for regulated areas and housekeeping.

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 Listed here are the various provisions of the final standard. These are provisions commonly included in an OSHA comprehensive health standard. The provisions for regulated areas and housekeeping apply only to general industry. Based on evidence in the rulemaking record, OSHA believes that the variability in Cr(VI) exposures and the unique nature of work involving Cr(VI) exposures in construction and shipyard environments make it impractical to effectively establish regulated areas and perform housekeeping in these sectors.

Scope: Who is Covered by the Standard? All occupational exposures to Cr(VI) compounds except: 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/m3 as an 8-hour time-weighted average (TWA) under any condition of use The final standard covers all occupational exposures to Cr(VI) from all Cr(VI) compounds with three exceptions. Exposures that occur in the application of pesticides (such as treating wood with Cr(VI) containing pesticides, e.g., copper chromated arsenate) are not included because they are covered by regulations of the Environmental Protection Agency. However, exposures from handling or using wood treated with Cr(VI)-based pesticides are covered by the rule. Exposures to portland cement are exempted from the final rule. Cr(VI) is present in portland cement in such low concentrations that it does not result in airborne exposures that present significant lung cancer risks. OSHA believes that the remaining dermal risks can be effectively addressed through existing OSHA standards for PPE, hazard communication and hygiene practices. Evidence in the record indicates that some operations may have Cr(VI) air exposures comparable to those found with portland cement and thus OSHA has added a provision that would exempt exposures where employers can demonstrate that Cr(VI) will not be released at concentrations above 0.5 micrograms per cubic meter of air under any expected conditions of use.

Permissible Exposure Limit (PEL) and Action Level (AL) PEL: 5 µg/m3 - TWA AL: 2.5 µg/m3 - TWA The new PEL covers all Cr(VI) compounds The new PEL was selected to protect against significant lung cancer risks and is the lowest level that is both technologically and economically feasible for all industries. With the new PEL there is also an associated action level at ½ the PEL, or 2.5 micrograms of Cr(VI) per cubic meter of air. The action level triggers requirements for exposure monitoring and provision of medical surveillance. An action level set at one-half of the PEL is consistent with other standards, e.g., inorganic arsenic, ethylene oxide, benzene, and methylene chloride.

Exposure Determination Two options allowed for determining employee exposures: Scheduled monitoring option Performance-oriented option OSHA was convinced by comments submitted to the record that characterizing employee exposures is important in all work settings and that there are performance or task-based approaches that can be used when a scheduled monitoring approach is less practical. Therefore, OSHA is requiring exposure determination for all industry sectors and is allowing two options for characterizing employee exposures: a scheduled monitoring approach similar to previous OSHA health standards and a performance-oriented option.

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 The scheduled monitoring approach is the traditional approach OSHA has used in its previous health standards. Employers must determine if any employees are exposed to Cr(VI) at or above the AL. This option lays out a fixed schedule for performing initial and periodic exposure monitoring, where periodic monitoring is based on the results of the initial monitoring. The frequencies for monitoring listed here are similar to those required by many OSHA health standards.

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 The performance-oriented option allows employers flexibility to characterize exposures using any combination of air monitoring, historical monitoring, or objective data. This option allows employers who may find a fixed schedule less practical to choose alternatives such as task-based monitoring that might be more practical and more cost effective for their particular circumstance. Regardless of the option employers choose, the overriding obligation of this provision is to accurately characterize employee exposures. There is no required fixed schedule for monitoring. “Air monitoring data” means the initial and periodic Cr(VI) monitoring conducted to comply with this standard. “Historical monitoring data” means data from Cr(VI) monitoring conducted prior to the effective date (May 30, 2006) for operations/conditions closely resembling current operations. “Objective data” means information such as air monitoring data from industry-wide surveys or calculations based on the composition or chemical and physical properties for similar workplace conditions/processes.

General Requirements for Exposure Determination Affected employees must be notified where exposures exceed the PEL As of June 15, 2010, employers must notify employees of ALL CrVI exposure monitoring results. Methods used for air monitoring and analysis must be sufficiently accurate Employees or their representatives must be allowed to observe Cr(VI) monitoring Where the exposure determination indicates that employee exposures exceed the PEL, the employer must notify affected employees within 15 days (5 days in construction). This can be accomplished by posting the results in a location that is accessible to all affected employees, or by notifying employees individually. The employer must describe the action being taken to reduce exposures to or below the PEL. The method of monitoring and analysis must meet the accuracy requirements presented in the standard (paragraph (d)(5)). Employers must allow employees or their representatives an opportunity to observe monitoring of Cr(VI) exposures.

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 The purpose of a regulated area is to ensure that employees are aware of the presence of Cr(VI) at levels above the PEL, and to limit exposure to as few employees as possible. Regulated areas are to be demarcated from other areas but the employer has the flexibility to use any means they choose as long as the method they choose effectively warns employees not to enter the area unless they are authorized, and then only if they are wearing the proper personal protective equipment. It is important to note that while proper personal protective equipment is required in such areas, simply entering a regulated area doesn’t trigger a requirement for respiratory protection.

Methods of Compliance: What methods must employers use to achieve the PEL? Establishes engineering and work practice controls as the primary means of achieving the PEL Exceptions: Painting aircraft or large aircraft parts: Use engineering and work practice controls to achieve 25 µg/m3 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 Prohibits job rotation to achieve compliance with the PEL As in previous health standards, OSHA is following its long established practice of requiring that engineering and work practice controls be used as the primary method for achieving the PEL. Because respirators are less reliable than engineering and work practice controls and may create additional problems, OSHA believes that primary reliance on respirators for protection is inappropriate when feasible engineering and work practice controls are available. OSHA has established two special provisions with regards to its preferred methods: In the aerospace industry, where the entire aircraft or large aircraft parts are being painted, employers are only required to maintain employee exposure at or below 25 µg/m3 with engineering and work practice controls and then must use supplemental respiratory protection to further achieve the PEL. The evidence in the record indicates that 25 µg/m3 is the lowest level that is technologically feasible to achieve with engineering and work practice controls when performing these painting activities. An exception is also allowed where exposures to hex chrome do not exceed the PEL for 30 or more days per year (in 12 consecutive months). In these situations, respirators can be used to achieve the PEL. This relieves the burden on employers whose employees may only infrequently be exposed above the PEL. OSHA used a similar provision to this in its final standard for cadmium. Although job rotation may reduce the risk of cancer among individual workers, the practice places a larger pool of workers at risk. Since no threshold has been established for the carcinogenic effects of Cr(VI), rotation would not be expected to reduce the risk to the population of workers when considered as a whole. This provision does not prohibit job rotation for other reasons.

Respiratory Protection Respirators and a program per 29 CFR 1910.134 required during: 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 Listed here are the situations where respiratory protection is required. Respiratory protection for operations where exposures do not exceed the PEL for 30 or more days per year are only required where the employer has elected not to use engineering controls to achieve the PEL. This is allowed under the provisions for methods of compliance. However, in some cases, employers may choose to use engineering controls to achieve the PEL and respirators would not be necessary. Respirator selection is to be made in accordance with 1910.134. OSHA is in the process of establishing respirator selection provisions in the APF (Assigned Protection Factors) rulemaking which will modify 29 CFR 1910.134.

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 Because Cr(VI) may also result in adverse effects on the skin and eyes, employers are required to provide and pay for protective work clothing and equipment when a Cr(VI) hazard is present. Employers should exercise common sense and appropriate expertise in determining when a hazard is present and for selecting protective clothing and equipment appropriate for the particular hazard. This performance-oriented approach is consistent with current requirements under 29 CFR 1910.132. The employer is also required to ensure that employees use the clothing and equipment provided, and follow a number of specified practices to ensure that they are used and handled in a manner that is protective of employee health.

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 Where employees must change their clothes to use protective clothing and equipment, OSHA believes it is essential to have change rooms with separate storage facilities for street and work clothing to prevent contamination of employees’ street clothes. This provision will minimize employee exposure to Cr(VI) after the work shift ends, because it reduces the duration of time they may be exposed to contaminated work clothes. Potential exposure resulting from contamination of the homes or cars of employees is also avoided. Employers are not required to provide eating and drinking facilities to employees. However, 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).

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 OSHA did not include specific housekeeping requirements for construction and shipyard worksites, since operations in these settings involving Cr(VI) exposure are often of short duration, commonly performed outdoors under variable environmental conditions, and in locations that vary from day to day or even hour to hour within a shift. OSHA made the finding that for the majority of construction and shipyard settings, compliance with the housekeeping provisions in this standard is impracticable. Construction and shipyard employers will still need to comply with the general housekeeping requirements found at 29 CFR 1926.25 (for construction) and 29 CFR 1915.91 (for shipyards). Methods other than HEPA vacuums would include wet methods such as wet shoveling, wet sweeping or wet brushing. Dry shoveling, dry sweeping, and dry brushing may be used only where HEPA-filtered vacuuming or other methods that minimize the likelihood of exposure to Cr(VI) have been tried and found not to be effective.

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 The purpose of medical surveillance for Cr(VI) is to: Determine if an individual can be exposed to the Cr(VI) present in their workplace without experiencing adverse health effects, Identify Cr(VI)-related adverse health effects so that appropriate intervention measures can be taken, and Determine the employee’s fitness to use PPE such as respirators.

Which Employees Must Be Provided Medical Surveillance? Exposed at or above the action level (2.5 µg/m3) for 30 or more days per year Experiencing signs or symptoms of Cr(VI) exposure Exposed in an emergency There are three categories of employees who must be offered medical surveillance. Because routine exposures to Cr(VI) may cause adverse effects such as nasal septum ulcerations, asthma, skin ulcerations or dermatitis, the standard requires medical surveillance to be offered to employees exposed above the action level for 30 or more days per year. This approach is consistent with other OSHA health standards (e.g. methylene chloride, 1,3- butadiene). Some employees may experience signs and symptoms of Cr(VI) exposure with less than 30 days exposure and therefore OSHA requires that medical surveillance be offered to such individuals. OSHA is requiring medical surveillance after exposure during an emergency which results in an uncontrolled release of Cr(VI). Short-term effects such as skin ulcerations and dermatitis might result from high exposure during an emergency.

What Must the Medical Examination Include? 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

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 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.

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 OSHA has taken a simplified approach to the communication of hazards requirements for Cr(VI). Employee training must be consistent with OSHA’s Hazard Communication standard, and in addition must include training on the final Cr(VI) standard and the required medical surveillance program. OSHA intends that employees be trained about the signs and symptoms of Cr(VI)-related adverse health effects. This information will help to ensure that employees are able to adequately report these signs and symptoms when they occur in order to receive medical attention.

Recordkeeping 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 No requirement to maintain training records Air monitoring records must identify the monitored employee and all other employees whose exposure the monitoring represents, and accurately reflect those exposures. Records of historical monitoring data must show that the work being performed, the Cr(VI)-containing material being handled, and the environmental conditions at the time these historical data were obtained are the same as those on the job for which exposure is being determined. The records must also demonstrate that the data were obtained using a method sufficiently accurate per paragraph (d)(5) of the standard. Since historical monitoring and objective data may be used to exempt the employer from provisions of the standard or provide a basis for respirator selection, it is critical that this determination be carefully documented. Reliance on historical monitoring data and objective data is intended to provide the same degree of assurance that employee exposures have been correctly characterized as air monitoring would, and records must demonstrate a reasonable basis for the exposure determination.

When Must Employers Comply with Provisions of the Standards? Effective date: May 30, 2006 Start-up dates: All provisions except engineering controls For small businesses (19 or fewer employees): May 30, 2007 For all others: Nov. 27, 2006 Engineering Controls For all employers: May 31, 2010 Employers with 20 or more employees must comply with all provisions of the standards (except those for engineering controls) by November 27, 2006. Employers with 19 or fewer employees must comply with all provisions (except those for engineering controls) by May 30, 2007. All employers must comply with requirements for engineering controls by May 31, 2010.

Summary This program was an overview – not a substitute for the standard PEL of 5 µg/m3 – TWA Ancillary provisions for worker protection: Exposure determination Preferred control methods Respiratory protection Protective clothing and equipment Hygiene areas and practices Medical surveillance Recordkeeping For further assistance, see OSHA’s web site