1. HEXAVALENT CHROMIUM A Standard In Review
Paul Watson
CIH, CSP,
ATC Associates
Adopted from presentation developed under the 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.
Chrome III is an essential nutrient for maintaining blood glucose levels
The hexavalent, Cr(VI) or chromate, is the second most stable state. It rarely occurs naturally; most Cr(VI) compounds are man made.

3. What is Hexavalent Chromium? (“chrome 6”)
A toxic form of chromium metal, generally man-made.
Used in many industrial applications, primarily for its anti-corrosive properties.
Can be generated during welding on stainless steel or metal structures coated with chromate paint.
Used in electroplating (chrome plating)
“Chromium is a metal that exists in several forms or “valence states” - divalent, trivalent, and hexavalent. The hexavalent form of chromium, sometimes called “chromium or chrome 6”, is a form that is known to be very toxic.
Hexavalent chromium is not the same as metallic chromium you see on vehicles with chrome-plating.
“It can exist as many different compounds that vary from highly water soluble (electroplating) to being practically insoluble in water. (most chromate paints)
“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, or performing hot work on steel structures with chromates in the coatings. In these situations, the chromium is not originally hexavalent but the high temperatures cause oxidation that converts the chromium to hexavalent chromium.” 3

4. Products that contain hexavalent chromium
Types of Hexavalent Chromium Chemicals
pigments in paints, inks, and plastics
lead chromate (chrome yellow, chrome green, molybdenum orange) zinc chromate barium chromate calcium chromate potassium dichromate sodium chromate
anti-corrosion coatings (chrome plating, spray coatings)
chromic trioxide (chromic acid) zinc chromate barium chromate calcium chromate sodium chromate strontium chromate
stainless steel and other high chromium alloys
hexavalent chromium (when cast, welded, or torch cut)
textile dyes
ammonium dichromate potassium chromate potassium dichromate sodium chromate
wood preservation
chromium trioxide
leather tanning
ammonium dichromate
If a metal structure, airplane or vehicle has a green primer, it probably is zinc chromate. But you can’t tell by color alone and often a paint chip would need to be sent to a lab to analyze for hexavalent chromium.
The use of hexavalent chromium in wood preservation and leather tanning had declined greatly in recent years. The operation of treating wood with hexavalent chromium is not covered by this standard, but construction activities using treated lumber is covered. 4

5. Common jobs with potential chrome 6 exposure
Chrome plating or electroplating
Welding or cutting on stainless steel or grinding on objects painted with chromate paint
Painting:
Auto body repair
Aircraft spray painting
“Electroplating uses a water soluble form of hexavalent chromium. Depending on the type of electoplating, workers in electroplating operations can be exposed to chrome 6 mist and splashes or spills of liquid onto the skin.
Welding on stainless steel is one of the most common activity where workers would be exposed to chrome 6. Stainless steel contains 12% - 30 % chromium metal. High heat from welding on stainless steel creates hexavalent chromium in the welding fumes. Hexavalent chromium is found in chromate paints (lead and zinc chromates as examples.) Spray painting with chromate paints is one job where exposure to high levels of chrome 6 can occur.
A much less common job is the production of chromate pigment and chemicals containing chrome 6. 5

6. Other jobs with potential chrome 6 exposure
Chromium dye and catalyst production
Glass manufacturing
Plastic colorant production
Construction
Traffic painting
Refractory brick restoration
Paint removal from bridges
Hazardous waste site work
Road strip painting
The green paint on this bridge is likely lead or zinc chromate
bridge work 6

7. Health Effects Ingestion Hazards Eyes Respiratory Tract Skin
Erosive to stomach, Hemorrhaging and death are likely
Eyes
Direct eye contact with chromic acid or chromate dusts can cause permanent eye damage.
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.
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.

8. Health Effects
Cancer
Chrome VI is classified as a known human carcinogen
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

9. Greater Risk Than Asbestos
Cancer risk from Cr (VI) at new PEL is higher than asbestos and benzene risk at their PELs
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

10. Major Health Effects Lung cancer Nasal septum ulcers or perforations
Bronchitis or asthma
X-ray showing lung cancer
“The primary health effect of concern is lung cancer caused by airborne exposures to hexavalent chromium. Chronic inhalation increases the risk of lung cancer. All Cr(VI) compounds are considered to be carcinogenic.
“Symptoms from breathing Cr(VI) may include runny nose, sneezing, coughing, itching, and a burning sensation from irritation or damage to the nose, throat, and lung. In severe cases sores can develop in the nose and result in nosebleeds. Ulcers can develop and with continuous exposure, permanent perforations (holes) in the nasal septum (the wall separating the nasal passages) can occur, as seen in the photo of a worker employed in a chrome plating shop.
“In some cases employees become “allergic” and sensitized to hexavalent chromium so that inhaling chromate compounds can cause work-related asthma, such as wheezing and shortness of breath.”
Perforation of the nasal septum from chrome 6 exposure 10

11. Chrome 6 effects on skin Skin ulcers
Allergic and irritant contact dermatitis
“Hexavalent chromium in contact with skin acts as both sensitizer and irritant. Once developed, chrome sensitivity becomes fairly persistent; in such cases, even contact with chromate-dyed textiles or wearing of chromate-tanned leather shoes can cause or exacerbate contact dermatitis.
“Dermal exposures to hexavalent chromium can result in skin ulcers commonly referred to as “chrome holes” and may also lead to dermatitis. They have a corrosive action when they enter the skin through a minor nick or break in the skin, resulting in the formation of the ulcers. Typically, the lesions are found on fingers, hands or forearms. "Chrome holes" also occur on the bottom surfaces of the feet when chrome salts have been allowed to permeate boots or shoes. The lesions are usually painless and persist for many months before spontaneously healing with a permanent scar.”
“Chrome hole” on finger
Skin effects are not likely in welding, but can occur in electroplating or painting 11

12. New Cr VI OSHA Standard
Suit by Public Citizen Health Research Group; Paper, Allied Industrial, Chemical, and Energy Workers Union
4/2/ rd Circuit Court of Appeals rules standard by 1/18/2006
2/28/ Final Rule published
20 or more employees - November 27, 2006.
19 or fewer employees - May 30, 2007.
For all employers, engineering controls May 31, 2010.
OSHA and the Steelworkers engaged in settlement agreement required engineering controls on an expedited schedule (by December 31, 2008), but will have relief from certain respirator requirements in the interim.
Portland Cement is exempted.

13. General Industry 29 CFR 1910.1026 Scope Definitions
Permissible exposure limit (PEL).
Exposure determination.
Regulated areas
Methods of compliance
Respiratory protection
Protective work clothing and equipment
Hygiene areas and practices
Housekeeping
Medical surveillance
Communication
Recordkeeping
Dates

14. Construction Industry 29 CFR 1926.1126
No definition of a Regulated Area
Notify Employee’s within 5 days of receipt of results
15 days General Industry

15. 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).
But it is higher than the original proposed PEL of 1ug/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

16. Two limits for Chrome 6 in air
5 micrograms per cubic meter
in the air
Permissible Exposure Limit (PEL)
8-hour average exposure limit
2.5 micrograms per cubic meter
in the air
Action Level (AL)
half of the PEL
“The permissible exposure limit is the maximum average concentration of hexavalent chromium that you can be exposed to in air for a normal 8-hour working day and 40-hour week. The DOSH hexavalent chromium regulation states that we must make sure no employee is exposed to an airborne concentration of chrome 6 above the PEL.
The Action Level (AL) is ½ the PEL, or 2.5 micrograms of chrome 6 per cubic meter of air and if exceeded, triggers certain requirements for air monitoring and medical surveillance. More about those later.
These levels of chrome 6 are extremely low – think of a single grain of sand in 3 ft. square box, ground up to particles so fine they would be invisible and spread out evenly in the air in the box, as a rough comparison. 16

17. Comparison of OELs

18. Potential Sources Welding Aircraft Painting Chrome Plating
Stainless steel
Carbon steel (confined spaces)
Aircraft Painting
Priming with zinc chromate primers
Removing primers
Chrome Plating
Chromic Acid
Excluded
Portland Cement
Pesticide Application (Wood Preservative)

19. 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
Stick welding: 50% of Cr produced is Cr VI
TIG & MIG 4% of total Cr produced is Cr VI
Stainless steel has between 10.5% - 27% chromium
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

20. Painting Aluminum Primers Zinc Chromate and Strontium Chromate
Also present in in adhesives/sealants
Chromates required for proper adhesion
Chromate free primers are being researched
Exposure occurs during spray painting
Special sample handling required
Exposures occur during sanding and bead blasting

21. Plating and Chromic Acid
Chrome Plating produces chromic acid mists over the plating tanks.
The mist is created by the electroplating currents causing bubbles in the solution. The bubbles pop at the surface and create a mist over the tank
Tank ventilation systems are common, but are frequently deficient.
Other chromic acid exposures occur from chromic acid solution preparations.
Chromic acid flakes are dumped mixed into solutions for many chemical processes

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
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
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.

23. How do you Sample? Air sampling OSHA ID-215 In breathing zone
Ship within 24 hours
Note type of operation
In breathing zone
Under welding visor
Surfaces
W-4001
Target value is µg/100 cm2

24. 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

25. Notification of air monitoring results
If air monitoring shows chrome 6 levels in the air exceed the PEL we must:
Notify you within 5 days in construction or within 15 days in general industry
Describe to you in writing what corrective actions we will take to reduce your exposure below the PEL.
Note to Employer: Tell how you will provide exposure determination results to employees. This can be accomplished by posting the results in a location that is accessible to all affected employees or by notifying employees individually. 25 25

26. Skin Sampling
does not require skin sampling! The final rule requires the employer to provide appropriate protective clothing and equipment where a hazard is present or is likely to be present from skin or eye contact with Cr (VI), but does not specify criteria to be used for determining when a hazard is present or is likely to be present”. One of the tools which the employer can use is skin sampling. But, OSHA is not aware of any evidence that would allow establishment of a threshold concentration of Cr(VI) below which adverse skin or eye effects would not occur.
The interpretation letter on the OSHA Web page states “To determine whether there is a hazard (or potential hazard) from skin or eye contact with chromium (VI) in a particular workplace, the employer should use appropriate expertise in assessing 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 walkthrough survey to identify sources of chromium (VI) hazards to workers. Also recommended are reviews of occupational illness records to determine if past skin exposures have been recorded or if skin conditions were reported which may have been linked to chromium (VI) exposures, as well as a review of any exposure determination(s) for operations involving chromium (VI)”.

27. 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.
If exposure above the PEL is less than 30 days per year, 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.

28. Welding Controls Fume extractor for stick welding on stainless steel
Use MIG/TIG welding on stainless steel whenever possible
Fume extractor for enclosed welding on any kind of steel
Weld using smaller rods
Weld using lower amperage (temperature)
Keep head out of rising plume

29. Welding work practices
When welding, keep your head out of the welding plume.
Use available local exhaust ventilation at all times.
“Since welding fumes typically go straight up, bending over a horizontal welding job like this puts the welder right in the welding plume. A local exhaust vent located close enough to the welding point to pull the fumes off to one side will greatly reduce the amount of welding fume containing chrome 6 in the welder’s breathing zone.” 21 29

30. Welding in confined spaces
Welding on stainless steel in a confined space will most likely require both exhaust ventilation and the use of respirators. 22

31. Painting Controls 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.)
Some grinders have a ventilated shroud on the grinder or needle gun, others may also have a perforated grinder disk
Airline respirators
Use Paint strippers to eliminate airborne exposures

32. 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.
(f)(1)(ii) Where painting of aircraft or large aircraft parts is performed in the aerospace industry, the employer shall use engineering and work practice controls to reduce and maintain employee exposure to chromium (VI) to or below 25 µg/m3. The employer shall supplement such engineering and work practice controls with the use of respiratory protection that complies with the requirements of paragraph (g) of this section to achieve the PEL.

33. 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.
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.
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.

34. Protective Work Clothing and Equipment
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.
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.

35. Protective Work Clothing and Equipment
Use where skin or eye contact with chrome 6 will occur or is likely to occur.
Normal welding PPE (welding helmet, gloves and welding leathers) is O.K. for welders
Remove all PPE when work shift or task is completed. Don’t wear or take it home.
[Note to Employer: Because some hexavalent chromium exposures 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 this situation exists. Electroplating is one example where rubber gloves, eye protection and rubber boots will likely be necessary. Grinding on chromate paint will likely generate enough dust that coveralls should be used. The normal PPE used by welders (leather gloves, welding helmet and welding leathers or coveralls) during welding on stainless steel will normally provide the needed protection for them.] 35

36. Protective Work Clothing Use
Don’t remove chrome 6 dust or residue from clothing by blowing, shaking, or any other means that disperses the dust into the air or onto the body.
Don’t shake out dusty coveralls or clothes
Don’t use compressed air to clean clothing 36

37. Laundering and Cleaning PPE
Use of outside service to launder or replace all protective clothing and other protective equipment
Put your contaminated PPE in a sealed bag for laundering or repair
The person doing these tasks must be informed of the hazards of chrome 6
This would not normally apply to welders welding on stainless steel. 37 37

38. Types of Respirators for Chrome 6
In some jobs involving chrome 6 exposure, you may need to wear a respirator.
The type of respirator worn depends on the amount of chrome 6 in the air.
Respirators are required if the amount in the air is more than the Permissible Exposure Limit (PEL). We provide the respirators at no cost to you. Respirators with cartridges are always the “P100” type which provide the highest filtering capacity of the various types of cartridges. You can tell them by the pink color of the cartridges. If the amount of lead in the air is more than 10 times the permissible limit, then we must provide you with respirators that provide better protection. If the levels in the air are really high, we must provide you with supplied air respirators where you get clean uncontaminated air from a backpack tank (like the lower photo) or a compressor through an airline respirator.
Employer: Training on the use of these respirators can be done here or separately. 24 38

39. Respiratory Protection
Minimum N-95
Based on airborne exposure

40. 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)

41. Hygiene Areas and Practices
If you have a job where chrome 6 can get on your skin or in your eyes, the employer must provide the following:
Change rooms – separate storage facilities for PPE and street clothes
Washing facilities
Be sure to wash hands and face:
at the end of the work shift
before eating, drinking, smoking, chewing tobacco or gum, applying cosmetics, or using the toilet
These procedures would not normally be required for welding operations. They would likely be required for electroplating, spray painting or removing chromate paints from metal surfaces. 41

42. Housekeeping
Keep all surfaces as free as practicable of accumulations of dust containing chrome 6.
Promptly clean up all spills and releases of chrome 6 containing materials
Use a HEPA vacuum or wet methods for cleaning areas contaminated with dust or other materials containing chrome 6
Dispose of chrome 6 contaminated waste in labeled & sealed bags or containers.
[Note: applies to General Industry. only]
“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. “ 42

43. Medical Surveillance A medical examination consists of:
A medical and work history;
A physical examination of the skin and respiratory tract.
Information to PLHCP
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
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).
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)

44. Who Must Be Provided Medical Exams?
Any employee exposed at or above the action level for 30 or more days per year.
Any employee experiencing signs or symptoms of chrome 6 exposure.
Any employee exposed in an uncontrolled release of large amounts of chrome 6 in any form.
“There are three categories of employees who must be offered medical surveillance:
“Because routine exposures to chrome 6 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.
“Some employees may experience signs and symptoms of chrome 6 exposure with less than 30 days exposure, so it is required that medical surveillance be offered to such individuals.
“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.” 44

45. Medical Exams (cont.)
Are done by or under the supervision of a physician or other licensed health care professional
Provided at no cost to you at a reasonable place and time 45 45

46. Medical Exams will do the following:
Determine if you can be exposed to Chrome 6 without experiencing adverse health effects.
Identify chrome 6 related adverse health effects so that appropriate measures can be taken.
Determine your fitness to use respirators.
“ If you have never worn a respirator before, the health care professional needs to determine if you have any health issues that would prevent you from wearing one. Breathing through a respirator can be difficult for anyone with a heart condition, asthma or other lung health issues. 46

47. Medical exams will include the following:
Medical and work history
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 healthcare professional
“We must offer you the medical exams, but you are not necessarily obliged to take them. However, it would be to your benefit to do so.”
Employer: you can make medical exams a condition of employment. The hexavalent chromium standard simply requires you to make them available at no cost to the employee. 47

48. Medical Exams are offered:
Within 30 days after initial assignment and annually thereafter
Within 30 days after a doctor recommends additional examinations
When employees shows signs or symptoms of Chrome 6 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.” 48

49. Healthcare professional’s written medical opinion
After your medical exam the health care professional will give a written medical opinion to us within thirty days
Specific findings or diagnoses unrelated to occupational exposure to chrome 6 will be not revealed to us
The medical opinion contains information about:
- any medical conditions and any increased risk from further exposure to Cr(VI)
- recommended limitations regarding exposure or use of PPE such as respirators
- statement that healthcare professional explained to you the results of your medical examination and any special provisions for use of protective clothing or equipment “ 40 49

50. 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.
Hazard Communication
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)

51. WA State Department of Labor and Industries, Video
Six Modules
Can down load for free from:

52. 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.

53. Inspection Activity Hexavalent chromium inspections
May 30, 2006 to December 31, 2007
78 Fed inspections with violations of
72 inspections in General Industry
6 inspections in Construction
0 inspections in Shipyards
# of total Cr(VI) violations = 155
$ amount of total current penalties = $157,534.00

54. Inspection Activity
72 inspections in General Industry with violations
Breakdown of these 72 employers by SIC code:
(7) Electroplating, Plating, Polishing, Anodizing, and Coloring
(5) Fabricated Metal Products, Not Elsewhere Classified
(5) Fabricated Plate Work (Boiler Shops)
(3) Sheet Metal Work
(3) Fabricated Structural Metal
(3) Steel Foundries, Not Elsewhere Classified
(2) Repair Shops and Related Services, Not Elsewhere Classified
(2) Railroad Equipment
(2) Aircraft Parts and Auxiliary Equipment, Not Elsewhere Classified
(2) Special Industry Machinery, Not Elsewhere Classified
(2) Conveyors and Conveying Equipment
(2) Metal Doors, Sash, Frames, Molding, and Trim Manufacturing
(2) Wood Office Furniture
(1) ---- etc., for (32) other SIC codes

55. Inspections List of the 5-most cited Cr(VI) violations:
(d)(1) - didn't determine exposure
(c) - exposure exceeded PEL
(e)(1) - no regulated area
(k)(1)(i)(A) - no medical surveillance
(l)(2)(i)(A) - no employee knowledge of standard

56. Inspection Procedures

57. Conclusions
The Hexavalent Chromium standard can be a problem. It is a comprehensive vertical standard with many requirements, if it applies to you
Recommendations
Evaluate your Workplace
(Stainless Steel is the trigger)
Conduct sampling
Evaluate exposure controls
Implement the full standard
Self check using the CPL

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