Compliance with OSHAs Final CrVI Standard

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Compliance with OSHAs Final Cr(VI) Standard

• By Joelie Zak CEF-4
• Scientific Control Laboratories, Inc.
• www.sclweb.com
• joeliezak_at_sclweb.com

NELAP A2LA Accredited
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New OSHA Cr6 PEL

• Compliance Dates
• gt20 employees
• November 27, 2006 (except engineering controls)
• lt20 employees
• May 30, 2007 (except engineering controls)
• Engineering Controls
• May 31, 2010

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Industry ImpactsMetal Finishing Operations
Affected

• Hard Chrome Plating
• Decorative Chrome Plating
• Chromic Acid Anodizing
• Chromate Conversion Coatings (e.g., Zn, Cd Al)
• Plating on Plastics
• Passivation
• Welding and Fabricating
• Polishing and Grinding
• Chemical Mixing Blending

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What Does My Company Have to Do?

• Evaluate exposures for ALL potential job tasks
  involving Cr(VI)
• Operators, Supervisors
• Lab Techs
• Maintenance Staff
• Special Tasks
• Wastewater Treatment Operators

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Initial Exposure Determination

• Air Monitoring Results
• lt Action Level (AL) No further monitoring
  required
• Second test must be conducted at least 7 days
  later is also below AL
• At or AL Monitor every 6 months
• gtPEL Every 3 months

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Accuracy of measurement

• Where air monitoring is performed to comply with
  the requirements of this section, the employer
  shall use a method of monitoring and analysis
  that can measure chromium (VI) to within an
  accuracy of plus or minus 25 percent (/- 25)
  and can produce accurate measurements to within a
  statistical confidence level of 95 percent for
  airborne concentrations at or above the action
  level.

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OSHA Method ID-215

• A fully validated OSHA analytical method that can
  analyze Cr(VI) well below the PEL within the
  accuracy of measure
• Ion Chromatography equipped with a UV-vis
  detector and a postcolumn reagent delivery module
  
• Method qualitative detection limit was 0.001 µg
  as Cr(VI) when using a 10-mL solution volume.
  This corresponds to 1.0 10-3 µg/m3 as Cr(VI)
  for a 960-L air volume

Ion Chromatography Unit
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Historical monitoring data

• Means data from chromium (VI) monitoring
  conducted prior to May 30, 2006
• Obtained during work operations conducted under
  workplace conditions closely resembling the
  processes, types of material, control methods,
  work practices, and environmental conditions in
  the employer's current operations
• (A) The (historical) data were collected using
  methods that meet the accuracy requirements of
  paragraph (d)(5) of this section

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Problems with Historical Monitoring Data

• Older Sampling Methods may not be valid
• Total Chromium (via AA)
• CrO3 via colorimetry vs. Cr6 ion
• Neither are sufficiently sensitive to quantitate
  at the proposed levels
• Hygienists have found several discrepancies
  between older results (gt2 yrs ago) and current
  sampling

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Air Monitoring for Cr(VI)

• Facilities can do their own air sampling
• OSHA will verify compliance with their own
  testing when they audit
• Sample under highest possible exposure conditions

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Why AREA Sampling is NOT Acceptable

• For several job titles with a significant point
  source of contamination, the area sampling
  methods significantly underestimated personal
  exposure estimates and were adjusted by the
  ratio of the two (from FR CrVI Standard
  Preamble pg 10116 Ex . 312211, p. 118).

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Air Monitoring

• Explain to employee what the monitoring is for
• Instruct operator to avoid touching the filter
  badge and pump
• Wear monitor all day (7 out of 8 hrs., minimum)
• Do not remove or turn off for breaks, lunch, etc.
• Have operator note about production, chemical
  adds, or any other important details

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Information to Collect During Monitoring

• Type of Process
• Type of Parts Handling (Hoist/Manual)
• Type of Parts Processed
• Job Tasks
• Ventilation System
• Weather (doors open/closed)
• Other

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Discontinuing Monitoring 1910.1026(d)(v)

• 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, the
  employer may discontinue the monitoring for those
  employees whose exposures are represented by such
  monitoring.
• The employer shall not rotate employees to
  different jobs to achieve compliance with the
  PEL (Page 281 of 287 of Fed Register).

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Additional Air Monitoring

• Required when there are any changes in
• Production process
• Raw materials
• Equipment
• Personnel
• Work practices
• Control methods
• Any other reason employer suspects changes
  (increases) in exposure to Cr6
• Recommended at least annually

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Some Industry Data

• OSHA Method 215 Used
• Hard Chrome Plating Shop (March 2006)
• Manual Tank Operator 11 µg/m3
• Manual Line Supervisor 2.535 µg/m3
• Auto Line Supervisor 2.4 µg/m3
• Maintenance 2.3 µg/m3
• Decorative Chrome Plating (2005-2006 data)
• Ranges 0.03 - 11 µg/m3
• Hexavalent Conversion Coating (05-06 data)
• Barrel, 0.45 µg/m3 - 1.45 µg/m3
• Manual Rack, 4.8 - 15 µg/m3
• Stainless Steel Welding
• 0.27 µg/m3 7.0 µg/m3

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Employee Notification

• Employee Notification Required If Cr6gtPEL
• Within 15 days of data receipt
• Must include corrective action description
• Results can be posted on company bulletin board
  or delivered to each operator tested
• Employees have right to witness exposure
  monitoring

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Methods of Compliance

• Engineering Controls
• Local Exhaust Ventilation/Emission Elimination
  Devices
• Enclosed Tanks
• Merlin Hoods
• Fume Suppressants/Foam Blankets
• Replacement of Air Agitation
• Process substitutes

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Work Practices

• Minimizing splashing entrainment from rinsing
  of parts
• Minimizing exposures during chemical additions
• Minimizing exposures from drying parts with
  compressed air
• Letting tank cool
• Housekeeping
• Wet cleaning methods

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Respiratory Protection Options

• Respiratory Protection must be used if exposures
  are greater than PEL
• ½ Mask Air- Purifying
• Full Face Air Purifying
• Supplied Air
• Air monitoring is never done inside respiratory
  protection for PEL compliance

½ Mask Air-Purifying Respirator
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Air-Purifying Respirators

• Annual Fit Test Training Requirement
• Site Specific Written Policy Required
• Medical Exams can be done simultaneously with
  CrVI exams

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Regulated areas

• Establishment The employer shall establish a
  regulated area wherever an employee's exposure to
  airborne concentrations of chromium (VI) is, or
  can reasonably be expected to be, in excess of
  the PEL.
• Demarcation The employer shall ensure that
  regulated areas are demarcated from the rest of
  the workplace in a manner that adequately
  establishes and alerts employees of the
  boundaries of the regulated area.
• -Tape on the floor posting signage is
  acceptable

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Access to Regulated Areas

• The employer shall limit access to regulated
  areas to
• (i) Persons authorized by the employer and
  required by work duties to be present in the
  regulated area(ii) Any person entering such an
  area as a designated representative of employees
  for the purpose of exercising the right to
  observe monitoring procedures under paragraph (d)
  of this section or(iii) Any person authorized
  by the Occupational Safety and Health Act or
  regulations issued under it to be in a regulated
  area.

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Protective Work Clothing

• Employers provide protective all employees (i.e.
  uniforms, PPE) exposed to greater than 0.5 mg/m3
• Clarification from the Agency is being requested
• Protective clothing must not be taken off-site
• Employer is responsible for cleaning/laundering
  (or contract for off-site cleaning)
• Washing facilities and changing room must be
  provided for exposed employees

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Change Rooms/Washing Facilities

• Employees can not enter areas where food is
  served if clothing is contaminated
• Employees can not eat, drink, smoke, chew gum,
  chew tobacco, or apply cosmetics in areas where
  skin or eye contact with Cr6 can happen (or even
  carry these products on their person or store
  them in these areas)

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Medical Surveillance

• Provided by licensed health care professional
  paid for by employer
• For affected employees at or above AL more than
  30 days per year
• Or any employee experiencing symptoms
• Doctor or PLHCP will interview employees about
  health history, do a physical exam, look for
  signs of chromic acid exposure (skin nasal exam)

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Medical Exam

• For those employees exposed gt than the AL
• Within 30 days of hire Annually thereafter
• Within 30 days of an emergency involving Cr6
• Upon termination (unless last exam was within 6
  months of termination)
• Detailed requirements of what the exam must
  include are in the regulation
• Medical opinion must be received by employees
  within 30 days of exam
• Detailed requirements of what must be in the
  report and what stays confidential
• Employee gets a copy of report within 2 weeks of
  receipt by employer

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Employee Training Hazard Communication

• Communication is same as current 1910.1200
• Training on specifics of Cr(VI) hazards
  carcinogenicity
• Employer must demonstrate employee has knowledge
  of the purpose and description of medical
  surveillance program
• Detailed recordkeeping requirements
• Documented Training Logsheet(s)
• Employer must demonstrate employee has knowledge
  of this regulation
• Recommended A written site-specific CrVI
  Compliance Plan
• Air Monitoring Results
• Changes to Engineering Controls
• A copy of the CrVI standard

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SFIC Washington Forum

• May 23-25, 2006
• LEnfant Plaza
• Washington, D.C.
• Tabletop Exhibits
• Technical Speakers
• Alternative Technologies
• Regulatory Compliance
• Policy Speakers
• DOD, EPA, Dept. of Energy
• Legislative Hill Visits