Update: Hexavalent Chromium Cr(VI)

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Update Hexavalent Chromium Cr(VI)

• Drawn from the Preambles and Training Materials
  from the National Office and Regions 5 and 6

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Purpose
Present an overview of the major provisions of
OSHAs Cr(VI) standard (71 FR 10100, February 28,
2006). Note This presentation is for training
purposes only. Consult the Federal Register on
OSHAs web site for the complete requirements of
this standard.
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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
• Can be created during certain hot work
  processes where the original form of chromium was
  not hexavalent

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Is Chrome a Carcinogen or Necessary Element?

• Chrome III is an essential nutrient for
  maintaining blood glucose levels
• Chrome VI is classified as a known human
  carcinogen

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Operations with Cr(VI) Exposure

• Electroplating
• Welding/cutting/torching/grinding painted
  surfaces
• Welding/cutting/grinding stainless steel, chrome
  alloys and even carbon steel
• Applying/removing coatings with chrome
• Glass production
• Chemical synthesis
• Chromium catalyst users
• Printing ink production

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Routes of Exposure

• 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) with skin absorption possible
• Ingestion through contamination of food and drink
  (controversy over extent of issue)

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Major Health Effects

• Lung cancer
• Nasal septum ulcerations and perforations
• Asthma
• Skin ulcers
• Allergic and irritant contact dermatitis

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History of Exposure Limits

• 1943 ANSI standard was the source of OSHAs 1971
  standard of 1mg/10 m3 Cr(III) or 52 µg/m3 CR(VI)
• Mounting evidence of carcinogenicity
• 1974 by ACGIH
• 1975 by NIOSH
• 1984 by EPA
• 1990 by IARC

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Occupational Exposure Limits

• NIOSH REL
• 0.001 mg Cr VI/M3 10-hr TWA
• ACGIH TLV
• Water-Soluble Cr VI compounds as Cr
• 0.05 mg/M3 TWA
• Insoluble Cr VI compounds as Cr
• 0.01 mg/M3 TWA
• ACGIH BEI
• Total chromium in urine BEIs (2) for Chrome VI
  water soluble fume

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History of New Standard

• In 1993 the Health Research Group petitioned for
  ETS of 0.5 µg/m3
• OSHA unable to demonstrate grave danger
• In 1997 HRG sued to complete rulemaking process
  and lost
• In 2002 HRG sued to complete rulemaking process
  and won
• Proposed rule to be issued 10/4/04
• Final rule to be issued 1/18/06
• Final rule was issued 2/28/06

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Steps to Complete a Rule

1. Review all research on health effects
2. Peer review of OSHA review
3. Develop risk assessment
4. Justify significance of risk assessment
5. Perform Economic Analysis and Regulatory
   Flexibility Analysis with SBREFA Assessment 6
   issues for each potential PEL
6. Submit to OMB 5 laws
7. Proposed rule with Questions
8. Hearings
9. Final Rule

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Case Law for Health Standards

• 1980 Supreme Court decision on benzene requires
  examination of significance of risk
  (cost-benefit)
• 1981 Lead and Cotton Dust cases gave concept of
  technological and economical feasibility in view
  of financial health and profitability of industry
  and impact on unit pricing

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Greater Risk Than Asbestos

• At the new technologically and economically
  feasible PEL, the cancer risk from Cr(VI) is
  higher than other regulated carcinogens
• Methylene Chloride 3.6 per 1000 workers
• Asbestos 6.7 deaths per 1000 workers
• Benzene 10 deaths per 1000 workers
• Cr VI 10-45 excess lung cancer deaths per 1000
  workers for 45 years of exposure at new PEL of 5
  ug/M3
• 2/28/06 FR p. 10225

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Three Cr(VI) Standards

• 1910.1026 General Industry
• 1926.1126 Construction
• 1915.1026 Shipyards

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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

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Scope Who is Coveredby the Standard?
All occupational exposures to Cr(VI) compounds
except

• Exposures that occur in the application of
  pesticides
• Application is already covered by EPA Standards
• The manufacture of pesticides and handling of
  pesticide treated materials are covered under new
  OSHA standard

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Scope Who is Coveredby the Standard?
All occupational exposures to Cr(VI) compounds
except

• Exposures that occur in the application of
  pesticides
• Exposures to portland cement
• American portland cement usually contains only
  trace amounts
• Would typically be over PEL for PNOR before over
  on Cr(VI)
• Use PNOR, Personal Protective Equipment and
  Hazard Communication Standards for protection

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Scope Who is Coveredby 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

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Permissible Exposure Limit (PEL) and Action Level
(AL)

• PEL 5 µg/m3 - TWA
• AL 2.5 µg/m3 - TWA

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Exposure Determination
Two options allowed for determining employee
exposures

• Scheduled monitoring option
• Performance-oriented option

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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

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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

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General Requirementsfor Exposure Determination

• Affected employees must be notified where
  exposures exceed the PEL

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General Requirementsfor Exposure Determination

• Affected employees must be notified where
  exposures exceed the PEL
• Methods used for air monitoring and analysis must
  be sufficiently accurate /- 25 and within a
  statistical confidence level of 95 at AL

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General Requirementsfor Exposure Determination

• Affected employees must be notified where
  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

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Regulated Areas

• For general industry employers only

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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

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Methods of Compliance

• Establishes engineering and work practice
  controls as the primary means of achieving the PEL

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Methods of Compliance

• 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

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Methods of Compliance

• Establishes engineering and work practice
  controls as the primary means of achieving the PEL

• Exceptions
• Painting aircraft or large aircraft parts
• Tasks or operations that do not result in
  exposures above the PEL for 30 or more days per
  year

• Prohibits job rotation to achieve compliance with
  the PEL

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Respiratory Protection Required

• 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

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Assigned Protection FactorsFinal Rule August 24,
2006
Type of Respirator1,2 Half Mask Full Facepiece Helmet/ Hood Loose-Fitting
1. Air-Purifying Respirator 103 50
2. Powered Air-Purifying Respirator (PAPR) 50 1,000 25/1,0004 25
3. Supplied-Air Respirator (SAR) or Airline Respirator Demand mode Continuous flow mode Pressure-demand or other positive-pressure mode 105050 501,0001,000 25/1,0004 25
4. Self-Contained Breathing Apparatus (SCBA) Demand mode Pressure-demand or other positive-pressure mode (e.g., open/closed circuit) 10 5010,000 5010,000
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Protective Work Clothingand 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

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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

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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

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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

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Purpose of Medical Surveillance

• Determine if an individual can be exposed to the
  Cr(VI) present in their workplace without
  experiencing adverse health effects
• Indentify Cr(VI)-related adverse health effects
  so that appropriate intervention measures can be
  taken
• Determine the employees fitness to use PPE, such
  as respirators

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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

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Medical Examination Requirements

• 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

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When Must MedicalExaminations 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

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Communication of Hazards

• Provide employee training in accordance with
  OSHAs 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

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Recordkeeping

• No requirement to maintain training records
• Must maintain records per 29 CFR 1910.1020 for
• Air monitoring data
• Historical monitoring data
• Objective data
• Medical surveillance information, including
• PLHCPs written opinions
• Information provided to the PLHCP

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Compliance Start-Up Dates

• Effective date May 30, 2006
• Start-up dates
• All provisions except engineering controls
• For employers with 19 or fewer employees May 30,
  2007
• For all others November 27, 2006
• Engineering Controls
• For all employers May 31, 2010

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Hexavalent Chromium

• Some practical issues

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FR Preamble Exposure Ranges
Task 1-5 µg/m3 Above PEL
Electroplating 11 13
Welding Stainless Steel GI 13 31
Const 15 27
Carbon Steel GI Const 12 6
Painting GI 3 17
Const 16 7
Steel Mills Stainless Steel GI 25 7
Carbon Steel GI 0.5 7
Iron SteelFoundries GI 15 5
Woodworking GI 0 14
Const 22 11
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OSHA Internal Training on Hexavalent Chromium
Sampling

• Most pre-existing sampling was for total chrome,
  probably due to low cost
• 50 for total metals analysis via ICP
• 150 for Cr(VI) analysis
• No way to separate or back calculate Cr(VI)
  exposures from total chrome (ICP)
• Comments at 5/2006 AIHCE Ask the Experts Cr(VI)
  session indicate little new Cr(VI) sampling has
  been done
• Conclusion Exposure levels are not known
• WE NEED TO SAMPLE

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Cr VI SLTC Analysis OSHA ID215as of 6/2006

• Closed face 37mm PVC filter _at_ 2 lpm
• Lab extraction of Cr VI from filter using an
  aqueous solution of sodium carbonate/sodium
  bicarbonate
• Ion chromatography for Cr VI with postcolumn
  UV/visible detector set at 540nm wavelength
• Limit of detection 0.003 ug/M3
• SAE varies, approx 0.112

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Interferences Welding Fume Sampling

• While in the cassette, Cr6 reacts with iron Fe2
  to form Cr3
• Cr3 is not analyzed by method ID215
• In 6 days you lose 10 of Cr6 through the Fe2
  reduction reaction
• SHIP SAMPLE TO LAB IMMEDIATELY
• If mailing will be delayed, get buffer solution
  from the lab ahead of time. While in the field
  you put the filters in the buffer solution to
  stabilize Cr6

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Interferences Plating Sampling

• While in the cassette, Cr6 reacts with acids
  from the plating baths to form Cr3
• Cr3 is not analyzed by method ID215
• In 6 days you lose 10 of Cr6 through this acid
  reduction reaction
• Order sodium hydroxide coated filters from the
  lab on an as needed basis for plating sampling
• NaOH neutralizes the acid to cut down on Cr6
  loss
• Helps maintain Cr6 on the filter for 30 days
• 1-3 month expiration date on these coated filters
  
• SHIP SAMPLE TO LAB IMMEDIATELY

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Filter Blanks

• PVC filters are normally cut from sheet filter
  stock using a stainless steel cutter
• Stainless steel contains chromium, and stainless
  steel cutters leave chrome VI contamination on
  filters
• OSHA uses PVC filters cut with a teflon coated
  stainless cutter to reduce/avoid background
  chrome contamination
• Some employers may be taking samples with filters
  contaminated by stainless cutters.
• SEND FILTER BLANKS! 5 ug/M3 is a minute amount
  of material, and filter blanks will help avoid
  employer objections to your sample results

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Other Sampling Methods

• 1 NaOH coated binderless quartz fiber filter
  wipe sample method is available
• A colorimetric wipe test will be available soon.
  You will be able to perform wipe tests in
  lunchrooms, etc., and demonstrate evidence of
  contamination
• New sampling method is under review OSHA
  analytical method ID215 may be updated to use
  buffer solution in the field