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Hexavalent Chromium; The New OSHA Rule
Recently OSHA passed the Hexavalent Chromium Rule
(29 CFR 1910.1026). This rule went into effect in
February of 2006. All employers with greater than 20
employees were required to comply with all requirements
except for engineering controls by November of 2006 and
all employers with less than 19 employees are required
to comply with all requirements except for engineering
controls by May 30 of 2007. By May 31 of 2010 all
employers are required to comply with all facets of the
standard.
This rule covers all exposures to Hexavalent
Chromium (Cr(VI)) except for applications as pesticides
and exposures to Portland Cement. In addition, when an
employer can demonstrate, with the use of objective air
monitoring data, that the product or activity involving
Cr(VI) will not, under any conditions, release Cr(VI)
in concentrations at or above 0.5ug/m3 for an
8-hour time weighted average, the requirements of the
rule do not apply. However, in all other instances the
rule does apply. Compliance with the rule includes a
number of requirements including engineering controls,
personal protective equipment, worker training, exposure
monitoring and medical monitoring of employees.
Chromium and its compounds are utilized in a
variety of manufacturing products such as pigments,
wood preservatives, stainless steel, textile dyes,
leather tanning produces, and anti- corrosion coatings
and plating products. Employees can inhale airborne
hexavalent chromium as a dust, fume or mist during
production of these products; when working near chrome
electroplating processes; during welding and hot-working
with stainless steel, high chrome alloys and
chrome-coated metal; and when applying and removing
chromate-containing paints and other surface coatings.
Skin exposure can also occur during direct handling of
solutions, coatings and cements that contain hexavalent
chromium.
Exposure to Cr(VI) is dangerous because it can
cause many ailments such as, skin irritation,
ulceration, and allergic dermatitis; nasal perforations,
rhinitis, nosebleed, respiratory tract inflamation and
irritation, occupational asthma, and pulmonary
congestion and edema; eye irritation and damage;
perforated eardrums; kidney and liver damage; gastric
pain; erosion and discoloration of the teeth; and
cancers of the lung, nasal passages and sinuses.1,2
The National
Institute of Occupational Safety and Health considers
all Cr(VI) compounds to be potential occupational
carcinogens.2
Often the Material Safety Data Sheet will list one of
the following compounds; Strontium Chromate, Calcium
Chromate, Barium Chromate, Lead Chromate, Zinc Chromate,
Ammonium Dichromate, Chromium Trioxide, Potassium
Chromate, Potassium Dichromate, and Sodium Chromate as
an ingredient in a product being used to indicate
potential chromate exposure. However, there are
instances where potential Chromate exposure is not so
obvious. For example, during heavy MIG welding of
mild steel using straight CO2 as the shield
gas, concentrations of Cr(VI) ranging from 0.3 ug/m3
to 1.0 ug/m3 have been released.
Because of this, parts of the OSHA rule are applicable.
It has been reported that switching the shield gas from
straight CO2 to a mixture of 75% Argon and
25% CO2 will reduce the amount of Cr(VI)
emitted to below 0.06 ug/m3 and allow an
exclusion from the requirements of the OSHA standard3.
It is important that you be aware of the facts and
requirements of the standard and the different job
functions that may be regulated under this standard. It
is also important to understand what aspects of this
standard apply to your business and your employees.
For further information about what this standard might
mean for your business contact the professionals at EHI.
Our professionals are fully versed in all aspects of
exposure assessment, air monitoring, and OSHA compliance
programs and are available to assist you meet these new
requirements.
References:
1. OSHA Fact Sheet, Health Effects of
Hexavalent Chromium
2. NIOSH, Safety and Health Topic:
Hexavalent Chromium
3. Presentation by Edward Struber,
CIH, Galson Laboratories, Chromium VI Current Monitoring
Issues. Presentation given during AIHA Northeast
Conference, December 1, 2006.
4. Small Entity Compliance Guide for
the Hexavalent Chromium Standards. OSHA Publication
3320, (2006).
Environmental
Health Investigations, Inc.
655 West Shore Trail
Sparta NJ 07871
Phone: 973-729-5649
E-mail:
info@ehi-inc.com |
