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Hexavalent Chromium Bryan Seal, CIH, CSP
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What is it? Hexavalent chromium (Cr(VI)) is a toxic form of the element chromium. Hexavalent chromium is rarely found in nature and is generally man-made. There has been a general decline in the use of chromates in favor of less toxic inorganic and organic pigments where possible.
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Health Effects Lung Cancer Irritation or damage to nasal passage and respiratory tract Irritation or damage to the eyes and skin
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Industries –Aerospace –Automotive –Steel Mills/Foundries –Chemical and Dye Producers –Shipyards –Construction
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Whos at risk? Tasks –Electroplating & Aluminum Etching –Welding –Painting –Sanding, Grinding, Cutting –Salvage operations –Woodworking
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How workers can help? Identify Reduce exposure Wear PPE Hygiene
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What Is OSHA Doing? Standards –Final Rule – Federal Register, Vol. 71, No. 39, February 28, 2006 Outreach (Guidance Documents) –Small Entity Compliance Guide for the Hexavalent Chromium Standards (OSHA 3320-10N-2006) –Hexavalent Chromium (OSHA 3373-10-2009)
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What is OSHA Doing? National Emphasis Program –National Emphasis Program – Hexavalent Chromium (CPL 02-02-076, 2/23/2010) –Regional Emphasis Program Involving Exposure to Hexavalent Chromium (VI) (2012-02 CPL 04, October 2012) Compliance Directive –Inspection Procedures for the Chromium (VI) Standards (CPL 02-02-074, 1/24/2008)
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Letters of Interpretation (LOIs) 11/14/20061910.1026(d)(3) Use of "objective data" to accurately characterize employee exposures to hexavalent chromium during welding operations. 01/25/20071910.1026(h)(1) Wearing short-sleeved shirts while performing a thermal spray operation with exposure to hexavalent chromium fumes. 05/31/20071910.1026; 1026(a)(4); 1026(b); 1026(c); 1026(f)(1); 1026(j); 1026(j)(3)(i) Use of feasible engineering/work practice controls for exposure to Cr(VI) for welding in confined spaces; housekeeping and disposal of large/bulky waste materials.
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LOIs 2008/2009 03/27/20081910.1026 Clarification of employer's obligation to include social security numbers on employee exposure records. 06/29/20091910.1026 OSHA has no authority to ban use of hexavalent chromium.
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LOIs 2010/2011 09/30/20101910.1026; 1026(d)(2); 1026(j) Clarification of monitoring and sampling requirements for hexavalent chromium. 02/23/20111910.1026; 1026(i); 1026(j) Applicability of the hexavalent chromium standard to welders. Applicability of the hexavalent chromium standard to welders. [02/23/2011] 09/02/20111910.1026; 1026(h)(1); 1026(i)(1) Clarification of the Chromium (VI) Standard - Change Rooms and Hygiene Practices.
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Wrap-up Identify, Quantify, Control Questions?? Thank you for your attention
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