1. Working with Hexavalent Chromium (Chromium VI)

2. Meeting Training Requirements
Preview this program and include your specific workplace information before conducting the training. Modify, add, delete, or otherwise customize slides as needed for your workplace.
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FULL DISCLAIMER
These materials 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 every Washington workplace. Employers have the responsibility of making sure that hazards and issues specific to their worksites are addressed in their safety and health and training programs.
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, DOSH 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 DOSH’s website at

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4. Occupational Exposure to Hexavalent Chromium (Chromium VI)

5. What This Training Will Cover
Characteristics of hexavalent chromium
Health hazards of hexavalent chromium
How you can be exposed to hexavalent chromium
Control of your hexavalent chromium exposure
Medical surveillance
OSHA rules on hexavalent chromium
“You are being given this training because you may be exposed to hexavalent chromium at work. This training is done to meet Washington State safety and health regulations to make sure you are protected from any chemical hazards.
“You will also be given refresher training annually.”

6. Hexavalent Chromium Standard
 Covers all occupational exposures to Hexavalent Chromium
Exceptions
Agricultural operations
Exposures that occur in the application of pesticides
Exposures to portland cement
Objective data demonstrating that hexavalent chromium cannot be released in concentrations at or above 0.5 µg/m3 as an 8-hour time-weighted average (TWA8) under any condition of use
“The standard covers all occupational exposures to Cr(VI) from all Cr(VI) compounds with these exceptions:
“Agricultural operations covered by Agriculture Safety Standards
“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 another federal government 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 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.
“Where the employer has objective data demonstrating that a material containing chromium or a specific process, operation, or activity involving chromium cannot release dusts, fumes, or mists of chromium (VI) in concentrations at or above 0.5 µg/m3 as an 8-hour time-weighted average (TWA) under any expected conditions of use.”

7. What Does the Standard Cover?
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 of Hazards
Recordkeeping
“Listed here are the various provisions of the standard. “The provisions for regulated areas and housekeeping apply only to general industry.”
*General industry only

8. What is Hexavalent Chromium?
Chromium VI or Cr(VI)
Toxic form of chromium metal, generally man-made
Used in many industrial applications, primarily for its anti-corrosive properties
Can be created during certain “hot” work processes (such as welding and grinding metals) where the original form of chromium was not hexavalent
“Chromium is a metal that exists in several forms or “valence states” - divalent, trivalent, and hexavalent. The hexavalent form of chromium, chromium VI, is a form that is known to be toxic.
“It can exist as many different compounds that vary from highly water soluble to slightly water soluble to those which are practically insoluble in water.
“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.”

9. Sources of Occupational Exposure
Types of Hexavalent Chromium Chemicals
pigments in paints, inks, and plastics
lead chromate (chrome yellow, chrome green, molybdenum orange) (PbCrO4) zinc chromate (ZnCrO4) barium chromate calcium chromate potassium dichromate sodium chromate
anti-corrosion coatings (chrome plating, spray coatings)
chromic trioxide (chromic acid) zinc chromate (ZnCrO4) barium chromate (BaCrO4) calcium chromate sodium chromate strontium chromate (SrCrO4)
stainless steel, galvanized steel
hexavalent chromium (when cast, welded, grinded or torch cut)
textile dyes
ammonium dichromate ((NH4)2Cr2O7) potassium chromate potassium dichromate sodium chromate
wood preservation
chromium trioxide
leather tanning
ammonium dichromate ((NH4)2Cr2O7)
“Some major industrial sources of hexavalent chromium:”

10. Sources of Occupational Exposure
Major operations/job tasks resulting in potential Cr(VI) exposure:
Chrome plating/Electroplating
Welding or grinding on chrome- containing metals (stainless steel, galvanized steel), or Cr (VI) painted surfaces
Painting
Aerospace
Auto body repair
Chromate pigment and chemical production
Chrome Plating Bath
(a significant source of Cr VI)

11. Sources of Occupational Exposure
Major operations/job tasks resulting in potential Cr(VI) exposure:
(cont.)
Chromium dye and catalyst production
Glass manufacturing
Plastic colorant production
Construction
Traffic painting
Refractory brick restoration
Paint removal from bridges
Bridgework

12. Routes of Exposure How Can Hexavalent Chromium Enter the Body?
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)

13. Major Health Effects Due to Significant Overexposure
Lung cancer
Nasal septum ulcerations and perforations
Asthma
Permanent perforation of the nasal septum from continuous exposure performing chrome plating of small appliance parts
“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. Zinc chromate is the strongest carcinogen of the chromates used in industry.
“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. Sores can develop in the nose and result in nosebleeds. Ulcers can develop and with continuous exposure, also permanent perforations (holes) in the nasal septum (the wall separating the nasal passages), as seen in the top photo of a young woman who was employed in chrome plating small appliance parts.
“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.”

14. Major Health Effects Due to Significant Overexposure
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 integument, resulting in the formation of chronic, ulcerative lesions known as "chrome holes". 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 permanent atrophic scar.”
“Chrome hole” on finger. Can also occur on hands or forearms, and on bottom surfaces of feet from chrome salts permeating through boots or shoes.

15. Chromium VI Exposure
The following operations/work areas where you may be exposed to Cr(VI) are:
[List the operations/employee work areas where Cr(VI) is present.]
Welding or Grinding on Stainless Steel or Other Base Metals with High Chrome Content
[Note to Employer: list or describe the operations and work areas where Cr(VI) is present.]

16. Permissible Exposure Limit
5 µg/m3 TWA8
in the air
Permissible Exposure Limit (PEL)
8-hour time-weighted average exposure limit (TWA8)
2.5 µg/m3 TWA8
in the air
“The PEL covers all Cr(VI) compounds.
“The Time-weighted average (TWA) exposure limit is the maximum average concentration of a chemical in air for a normal 8-hour working day and 40-hour week. We must ensure that no employee is exposed to an airborne concentration of chromium (VI) in excess of the PEL, which is 5 micrograms per cubic meter of air, calculated as an 8-hour time-weighted average (TWA).
“With the PEL there is also an associated Action Level (AL) at ½ the PEL, or 2.5 micrograms of Cr(VI) per cubic meter of air.”
(The AL triggers Medical Surveillance for employees who are or may be exposed to Cr(VI) at or above the action level for thirty or more days a year.)
[Note: An action level set at one-half of the PEL is consistent with other standards, e.g., inorganic arsenic, benzene, and methylene chloride.]
Action Level (AL)
0.5 of PEL

17. Exposure Determination
Two options for determining employee exposures:
Scheduled monitoring method
Performance-oriented monitoring method
“We determine your exposure to Cr(VI) using one of two options for characterizing employee exposures: a scheduled monitoring approach or a performance-oriented option.”

18. Exposure Determination
Scheduled Monitoring
If initial Cr(VI) concentration is:
Below the AL
Discontinue monitoring
At or above the AL
Monitor every 6 months Can discontinue monitoring if exposures are below AL and confirmed
Above the PEL
Monitor every 3 months Can discontinue monitoring if exposures are below AL and confirmed
“This option follows a fixed schedule for performing initial and periodic exposure air monitoring, where periodic monitoring is based on the results of the initial monitoring.
“If periodic monitoring indicates that employee exposures are below the action level, and the result is confirmed by the result of another monitoring taken at least seven days later, monitoring may be discontinued for those employees whose exposures are represented by such monitoring.
“Additional monitoring will be performed when there has been any change in the production process, raw materials, equipment, personnel, work practices, or control methods that may result in new or additional exposures to chromium (VI), or when there is any reason to believe that new or additional exposures have occurred.”
[Note: The scheduled monitoring approach is the traditional approach like that for other health standards. The frequencies for monitoring listed here are similar to those required by many WISHA health standards.]

19. Exposure Determination
A list of “variables” to consider while collecting air
monitoring samples during welding and grinding
operations includes:
Actual time spent welding
(i.e., 2 hours, 3.5 hours, 45 minutes, etc.)
The item involved in the weld
(i.e., rectangular duct, tank, piping, etc.)
The size of the item / piece involved in the process
Size of the welding room / booth / space
Description of general / natural ventilation in the area
(the number of air changes)
Description of point of operation ventilation in the area
Ambient temperature and relative humidity
Workers head/face orientation to point of operation
“In the performance-oriented option, exposures are characterized using any combination of air monitoring, historical monitoring, or objective data.”

20. Exposure Determination
A list of “variables” to consider while collecting air
monitoring samples during welding and grinding
operations includes:
Type of welding being conducted, for example: Shielded
Metal Arc Welding (SMAW), Gas Tungsten Arc Welding
(GTAW), Gas Metal Arc Welding (GMAW)
Is a shielding gas used? If so, what type
(i.e., argon, helium, etc.)
Type of base metal
(i.e., stainless steel, mild steel, galvanized steel, etc.)
Reported ingredients of the base metal
(i.e., x% chrome, x% nickel, x% iron, etc.)
Thickness of the base metal (i.e., 18 ga., 10 ga., etc.)
Type of welding electrode / rod / wire
Type of personal protective equipment worn by the welder
(i.e., respirator, helmet, gloves, etc.)
“In the performance-oriented option, exposures are characterized using any combination of air monitoring, historical monitoring, or objective data.”

21. Exposure Determination
Performance-oriented Monitoring
Exposures determined using any combination of air monitoring data, historical monitoring data, or objective data sufficient to accurately characterize employee exposure to Cr(VI)
No fixed schedule for performing periodic monitoring
May be difficult to match air monitoring results due to the many variables involved
“In the performance-oriented option, exposures are characterized using any combination of air monitoring, historical monitoring, or objective data.”

22. Exposure Determination
General Requirements
Affected employees must be notified when 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
“When the exposure determination indicates that employee exposures exceed the PEL, the affected employees must be notified within 15 working days (5 days in construction and shipyards).
“Where air monitoring is performed to comply with the requirements, the employer shall use a method of monitoring and analysis that can measure chromium (VI) to within an accuracy of plus or minus twenty-five percent and can produce accurate measurements to within a statistical confidence level of ninety-five percent for airborne concentrations at or above the action level.
“Employees or their representatives must be allowed the opportunity to observe monitoring of Cr(VI) exposures.”

23. Notification of Results
When exposure determination results are above the TWA8 permissible exposure limit (PEL), [insert your company’s name] must provide written notification of all the following within [15 or 5; see notes] business days:
Provide results of exposure determination
Describe corrective actions being taken to reduce exposure to or below the PEL
[Written notification within 15 business for general industry; within 5 business days for construction and shipyards]
[Note to Employer: Describe 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. You must describe the actions being taken to reduce exposures to or below the PEL.]

24. Exposure Determination
These are the results of our employee exposure determination using [state which option/method you used]:
[List results here.]

25. Regulated Areas
Areas where exposures exceed or can be reasonably expected to exceed the PEL
Regulated Areas for General Industry only (not Construction)
Regulated areas are clearly marked
Access is limited to
authorized persons required by work duties to be there
designated representatives of employees for the purpose of observing monitoring procedures
persons authorized by OSHA or other regulations to be there
[Note: applies to General Industry only]
“Regulated areas are defined areas where employees’ exposure to airborne concentrations of chromium (VI) is, or can reasonably be expected to be, in excess of the PEL. The boundaries of regulated areas are well marked so you can recognize them from the rest of the workplace.
“Access is restricted to authorized persons so that exposure is limited to as few employees as possible:
Persons authorized by the employer and required by work duties to be present in the regulated area
Any person entering such an area as a designated representative of employees for the purpose of exercising the right to observe monitoring procedures under WAC ;
Any person authorized by the Washington Industrial Safety and Health Act (WISHA) or regulations issued under it to be in a regulated area.”
[Note to employer: Regulated areas are to be demarcated from other areas but the employer has the flexibility to use any means he/she chooses as long as the method 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.]

26. These are the Regulated Areas at [insert your company’s name]:
[List all areas and specific locations]
[Describe policies/procedures for entering and exiting regulated areas]
[Note to Employer: Discuss the locations of regulated areas at your workplace and the policies/procedures for entering and exiting these areas]

27. Methods of Compliance
Establish engineering and work practice controls as the primary means of achieving the PEL/reducing exposures.
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
“Engineering and work practice controls must be considered and used as the primary methods for achieving the PEL and reducing exposures. Respirators are less reliable than engineering and work practice controls and may create additional problems. You must use respiratory protection, gloves, and protective clothing when controls aren’t feasible or if they can't completely remove the hazard.
“There are special provisions/exceptions:
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.”

28. Methods of Compliance
Tasks or operations that do not result in exposures above the PEL for 30 or more days per year:
Use of respirators alone is allowed to achieve the PEL
2. “An exception is also allowed where exposures to hexavalent chromium 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.)
“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.)
Prohibit job rotation to achieve compliance with the PEL

29. Control Measures to Reduce Exposures
We use the following controls to reduce the amount of chromium VI you are exposed to:
[List controls here]
[Employer: When feasible, you must consider first using engineering controls rather than personal protective equipment to prevent overexposure. You must use respiratory protection, gloves, and protective clothing when controls aren’t feasible or if they can't completely remove the hazard.
Make sure you customize controls to your workplace.]

30. Required Work Practices
We follow these work practices:
[List worksite-specific work practices that reduce or control exposures here.]
[Employer: list or describe the practices you require.]

31. Respiratory Protection
When will you need a respirator?
Periods necessary to install or implement feasible engineering and work practice controls
Maintenance or repair operations where engineering and work practice controls are not feasible
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 and the employer has elected not to implement engineering and work practice controls to achieve the PEL
Emergencies
“Listed here are the situations where respiratory protection is required.”
[Instructor: Show or describe the respirators used at the specific jobsite or task. Training on the use of these respirators can be done here or separately.]

32. Respiratory Protection
When respirator use is required, a respirator program will be followed that meets the appropriate OSHA or state-OSHA respiratory protection standards.

33. Type of Respirator You Will Use
[List or describe what respirators must be used under what conditions, job tasks, or locations here]
[Instructor: Show or describe the respirators used at the specific jobsite or task. Training on the use of these respirators can be done here or separately.]

34. Personal Protective Equipment (PPE)
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)
Remove all PPE and equipment when work shift or task is completed
[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.
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.]
[Insert your company’s name] will provide your PPE at no cost.

35. Personal Protective Equipment (PPE)
Protective Work Clothing and Equipment (cont.)
Do not remove Cr(VI) from PPE by blowing, shaking, or any other means that disperses into the air or onto the body
Do not remove contaminated PPE from the workplace, except for laundering, disposal, etc. by employees with such job duties
Clean and replace Cr(VI)-contaminated clothing and equipment as needed

36. Personal Protective Equipment (PPE)
Laundering and Cleaning of PPE
Store and transport contaminated PPE in sealed, impermeable bags or closed containers. Make sure they are properly labeled.
Inform any person who launders/ cleans PPE of the potentially harmful effects of Cr(VI) exposure
When laundering:
– Minimize skin or eye contact with Cr(VI)
– Prevent the release of airborne levels in excess of the PEL

37. Hygiene Areas and Practices
When employee exposure is at/above the PEL:
Change rooms – separate storage facilities for PPE and street clothes
Washing facilities
Wash hands and face:
at the end of the work shift
prior to eating, drinking, smoking, chewing tobacco or gum, applying cosmetics, or using the toilet
“You must use the Change Rooms, separate storage facilities for PPE and street clothes to prevent contamination of your clothes.
“You must use the washing facilities to remove Cr(VI) from your skin. Wash your hands and face: …”
[Note to Employer: Where employees must change their clothes to use protective clothing and equipment, 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.]
Use these facilities when necessary!

38. Hygiene Areas and Practices (cont.)
Eating and Drinking Areas and Surfaces
– maintained as free as practicable of Cr(VI)
DO NOT:
Enter eating and drinking areas with PPE
Eat, drink, smoke, chew tobacco or gum, or apply cosmetics in areas where skin or eye contact with Cr(VI) occurs
Carry or store the products associated with the above activities in areas where skin or eye contact with Cr(VI) occurs
“Employee work practice policies here at [insert your company’s name]:
“You do not enter eating and drinking areas with PPE unless surface Cr(VI) has been removed from the PPE by methods that do not disperse Cr(VI)
“You do not eat, drink, smoke, chew tobacco or gum, or apply cosmetics in regulated areas, or in areas where skin or eye contact with Cr(VI) occurs
“You do not carry the products associated with these activities, or store such products, in regulated areas”
[Note: 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, ensure that eating and drinking areas are as free as practicable of Cr(VI).]
[Refer to and ]

39. Housekeeping
Keep all surfaces as free as practicable of accumulations of Cr(VI)
Promptly clean up all spills and releases of Cr(VI)- containing materials
Use HEPA vacuums or other methods that minimize exposure to Cr(VI)
Dispose of Cr(VI)-contaminated waste in labeled, impermeable bags/containers
[Note: applies to General Industry.]
“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.
“Do not use compressed air to remove chromium (VI) from any surface unless:
The compressed air is used in conjunction with a ventilation system designed to capture the dust cloud created by the compressed air; or
No alternative method is feasible.
“Handle cleaning equipment in a manner that minimizes the reentry of chromium (VI) into the workplace.
“Collect and dispose of waste, scrap, debris, and any other materials contaminated with Cr(VI) and consigned for disposal in sealed, impermeable bags or other closed, impermeable containers.
“Label bags or containers of waste, scrap, debris, and any other materials contaminated with chromium (VI) that are consigned for disposal.” [Refer to WAC ]

40. 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.
“Some employees may experience signs and symptoms of Cr(VI) exposure with less than 30 days exposure and therefore 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.”

41. Medical Surveillance (cont.)
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

42. Medical Surveillance (cont.)
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
Determine the employee’s fitness to use PPE, such as respirators
“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.

43. Medical Examinations 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 PLHCP
“A medical examination consists of
“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”

44. Medical Examinations
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
“[Insert your company’s name here] will provide a medical examination:
“Within….
“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.”

45. Information Provided to PLCHP
Copy of the Federal OSHA (or state plan OSHA) Hexavalent Chromium standard
Description of employee's former, current, and anticipated duties related to occupational exposure to Cr(VI)
Employee's former, current, and anticipated levels of occupational exposure to Cr(VI)
Description of any PPE used or to be used by the employee
Information from records of previous employment-related medical examinations

46. PLHCP's Written Medical Opinion
Provided to [insert your company name] by PLHCP within thirty days
Specific findings or diagnoses unrelated to occupational exposure to Cr(VI) not revealed
We must provide a copy of the PLHCP's written medical opinion to you within two weeks after receiving it
“The PLHCP provides [insert your company name] his/her written medical opinion within thirty days. The medical opinion contains information regarding
- 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 PLHCP has explained to the employee the results of the medical examination and any special provisions for use of protective clothing or equipment
“Specific findings or diagnoses unrelated to occupational exposure to Cr(VI) are not revealed
“We must provide copy of the PLHCP's written medical opinion to you within two weeks after we receive it.”

47. Worksite Medical Surveillance Program
[Describe details of worksite specific medical surveillance program here.]
[Instructor: describe medical surveillance program here.
In addition to discussing your medical surveillance program include specific directions as to how obtain evaluations in the event of an emergency exposure.]

48. Medical and Air Monitoring Records
You have the right to see any of your medical records related to Cr(VI).
You also have the right to see results of any air sampling we have done, or other exposure data we have used.
“Medical records are kept at [name location] and you can see them.”
[Note to Employer: If you have any records of air samples taken at the job site, inform your employees where these results can be viewed or post them, or give copies to affected employees.]

49. Hexavalent Chromium Regulations
Federal OSHA Standard for Hexavalent Chromium are:
General Industry –
Construction –
Maritime –
State OSHA Programs will have different standards
“The points we have covered here are required in this standard. We have given you copies of information about hexavalent chromium which covers the health effects of hexavalent chromium, what to do in an emergency, and other requirements of the standard plus additional information about the physical characteristics of this chemical. You can also get a copy of the standard at the following location:”
[Instructor: specify location]