Hexavalent Chromium STANDARD - Are you Ready for May 31, 2010?

Hexavalent Chromium Solutions xavalent chromium (Cr(VI)) compounds are a group of chemical substances that contain the metallic element chromium in its positive- 6 valence (hexavalent) state. Occupational exposures to Cr(VI) occur during the production of stainless steel, chromate chemicals, and chromate pigments. Cr(VI) exposures also occur during other work activities such as stainless steel welding, and thermal cutting. On February 28, 2006 the Occupational Safety and Health Administration (OSHA) published the final Hexavalent Chromium (CrVI) Standard. There are three versions of the standard: General Industry (1910.1026), Construction (1910.1126) and Shipyards (1515.1026); however, the requirements for compliance are very similar. The deadline for full compliance is upon us and it is time to ask yourself, “Are we on track to be in compliance with the May 31, 2010 deadline?” As an employer, you will be required to ensure that no employee (including those who are indirectly exposed) is exposed to an airborne concentration of chromium (VI) in excess of 5 micrograms per cubic meter of air (5 μg/m3), calculated as an 8-hour time-weighted average (TWA).  Permissible Exposure Limit CrVI exposure from any source is covered except exposures from Portland Cement and application of regulated pesticides, e.g. treatment of wood with pesticides (exposures resulting from sawing or sanding treated wood are covered). The permissible exposure limit (PEL) for all industries is 5μg/m3. The action level, or the level where requirements of the standard such as medical surveillance may be required, is 2.5μg/m3. There is no short term exposure limit (STEL).me plating. How Do I Know if My Employees are Exposed? First and foremost, the employee exposure must be determined. Before you can determine what protection methods are most applicable your job environment, you must first know the levels of chromium to which your employees are exposed while performing their job tasks. You will need an Industrial Hygienist to perform this air monitoring and provide you with your employees' TWA (time weighted average) for an 8-hour work day. How Can I Protect My Employees? Now you can determine how best to protect your employees from over-exposure. The OSHA regulation states, “The use of engineering and work practice controls to reduce and maintain exposure to chromium (VI) to or below the PEL is required unless it can be demonstrated that such controls are not feasible.” If the engineering and work practice controls are not sufficient to reduce employee exposure to or below the PEL, the employer shall use them to reduce employee exposure to the lowest levels achievable and shall supplement them by the use of respiratory protection.

To summarize, OSHA is expecting engineering controls to be put into place to eliminate employees' exposure to chromium (VI) and as a last resort you should rely on respirators to protect your employees. Respiratory protection requirements are the same in all three standards. Respirators are required in the following situations whenever exposure levels exceed the PEL: • While engineering and work practice controls are being developed • During maintenance and repair activities for which engineering and work practice controls are not feasible • When all feasible engineering and work practice controls are implemented • When employees are exposed above the PEL for fewer than 30 days per year and the employer has not elected to implement engineering and work practice controls • Emergencies What Else Does the OSHA Regulation Require? • Contaminated Clothing Contaminated clothing/equipment cannot leave the work place. You as the employer must either provide disposable clothing or clean, launder, repair and replace all protective clothing and equipment used by employees when being exposed to chromium (VI). • Changing Rooms Change rooms equipped with separate storage facilities for contaminated protective clothing and equipment and a separate area for street clothes to prevent cross-contamination are required. • Personal Hygiene Wash hands and face at the end of each shift and prior to eating or drinking. No eating or drinking in the work areas is permitted. • Medical Surveillance Medical surveillance is to be made available at no cost to the employee, and at a reasonable time and place, for all employees who are or may be occupationally exposed to chromium (VI) at or above the action level for 30 or more days a year, or those who are experiencing signs or symptoms of the adverse health effects associated with chromium (VI) exposure, or those exposed in an emergency. Important Dates The PEL, respiratory protection and engineering controls take effect on the following dates: • Employers with more than 20 employees - November 27, 2006 • Employers with less than 20 employees - May 30, 2007 • Feasible engineering controls must be in place - May 31, 2010 If you need assistance in complying with this regulation, visit www.hexchrome.com.