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SmallEntityComplianceGuide for the Hexavalent Chromium Standards
Occupational Safety and Health Administration U.S. Department of Labor
OSHA 3320-10N 2006
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Contents
Introduction Scope Definitions Permissible Exposure Limit (PEL) Exposure Determination Regulated Areas Methods of Compliance Respiratory Protection Protective Work Clothing and Equipment Hygiene Areas and Practices Housekeeping Medical Surveillance Communication of Cr(VI) Hazards to Employees
3 4 5 6 7 9 9 11 11 13 14 15 16
Cover photo: An employee welds a stainless steel flange using a tungsten inert gas (TIG) welding process (courtesy Bath Iron Works).
Recordkeeping 17 Dates 18 OSHA Assistance 19 Appendix I: OSHA Cr(VI) Standards 22 Appendix II: Industry Operations or Processes Associated with Occupational Exposure to Cr(VI) 40 Appendix III: A. OSHA Area Offices 47 B. OSHA Regional Offices 52 C. States with Approved Occupational Safety and Health Plans 53 D. OSHA Consultation Project Directory 55
Occupational Safety and Health Administration
Introduction
This guide is intended to help small businesses com- section explains which employers are covered by the ply with the Occupational Safety and Health standardsand describes the exceptions to coverage of Administration’s (OSHA) Hexavalent Chromium the standards. The employer may consult a section (Cr(VI)) standards. Employees exposed to Cr(VI) are at that is of particular interest, or may proceed through increased risk of developing serious adverse health the sections in sequence to gain a better understand-effectsincludinglungcancer,asthmaanddamagetoingofthestandardsintheirentirety.Asectioncdriebs-the nasal passages and skin. This guide describes the ing additional OSHA resources available to assist steps that employers are required to take to protect employers is also included. employees from the hazards associated with exposure The Cr(VI) standards for general industry (29 CFR to Cr(VI). 1910.1026), shipyards (29 CFR 1915.1026), and con-This document provides guidance only, and does struction (29 CFR 1926.1126) are included in Appendix not alter or determine compliance responsibilities, I. Appendix II presents information on industry opera-which are set forth in OSHA standards and the tions and processes associated with exposure to Occupational Safety and Health A.cTt to assist employers in identifying Cr(VI) expo- Cr(VI)his guide does not replace the official Hexavalent Chromium stan- sures in their workplaces. Appendix III contains list-dards, which are contained in Appendix I of this docu- ingsof OSHA Area and Regional offices; the address-ment. The employer must refer to the appropriate es and phone numbers of state agencies that adminis-standard to ensure that they are in compliance. ter OSHA-approved State Plans; and the addresses Moreover, because interpretations and enforcement and phone numbers of OSHA Consultation Service policy may change over time, for additional guidance offices. on OSHA compliance requirements the reader should consult current administrative interpretations andWHERE TO GO FOR ADDITIONAL ASSISTANCE decisions by the Occupational Safety and Health Foradditional assistance in complying with the Cr(VI) Review Commission and the courts. standards, contact the nearest OSHA Area Office. If In 24 states and two territories, OSHA standards you are unable to contact the OSHA Area Office, you are enforced by the state agency responsible for the can contact the appropriate OSHA Regional Office OSHA-approved State Plan. These states and territo- for information or assistance. If you are located in a ries are: Alaska, Arizona, California, Connecticut, state that operates an OSHA-approved State Plan, you Hawaii, Indiana, Iowa, Kentucky, Maryland, Michigan, may contact the responsible state agency for informa-Minnesota, Nevada, New Jersey, New Mexico, New tion and assistance. See Appendix III for the address-York, North Carolina, Oregon, Puerto Rico, South es and phone numbers of these offices. Carolina, Tennessee, Utah, Vermont, Virgin Islands, The OSHA Consultation Service is another impor-Virginia, Washington, and Wyoming. Connecticut, tant resource for additional assistance. The service is New Jersey, New York, and the Virgin Islands operate largelyfunded by OSHA and is delivered by state OSHA-approved State Plans limited in scope to state governments using well-trained professional staff. and local government employees. State Plans must ri int sses, the consul-adoptandenforcestandardsthatareeitheridenticalPrimalyendedforsofmcahllaerrbusine tooratleastaseffectiveasthefederalstandards.tcaotimopnleptreolgyrsaempaisraftreeefromthegOeStHoAeimnsplpoeycetirosnaenfdfoirst. They must also extend the coverage of their standards The consultation services do not issue citations or to state and local government employees. propose penalties. Additional information on the OSHA Consultation Service, as well as other sources HOW TO USE THIS GUIDEof help from OSHA, can be found in the OSHA assis-The guide is divided into sections that correspond to tance section of the guide. the major provisions of the Cr(VI) standards. Each sec-tion follows the same organization as the correspond-ing paragraph of the standards, providing more detail than the standards to help employers better understand the requirements. For example, the Scope
S M A L L E N T I T Y C O M P L I A N C E G U I D E F O R T H E H E X A V A L E N T C H R O M I U M S T A N D A R D S
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Scope The standards apply to all occupational exposures to not regulate where another federal agency, such as Cr(VI), with only limited exceptions. OSHA has separate EPA, enforces occupational safety and health standards. standards for Cr(VI) exposures in general industry, ship- The exemption pertains only to the application of yards, and construction. Most of the requirements are pesticidesand not to the manufacture of Cr(VI)-con-the same for all sectors. Where there are differences, taining pesticides, which is covered by the standards. they will be explained in this guide. Theuse of wood treated with pesticides containing Cr(VI) is present in many different compounds that Cr(VI) is also covered by the standards. have a variety of industrial applications. Examples of major industrial uses of Cr(VI) compounds include: chro-PORTLAND CEMENT mate pigments in dyes, paints, inks, and plastics; chro- The standards do not cover exposure to Cr(VI) in port-mates added as anticorrosive agents to paints, primers, land cement. Trace amounts of Cr(VI) are usually pres-andothersurfacecoatings;andchromicacidelectroplat-entinportlandcement.However,theconcentrationof edontometalpartstoprovideadecorativeorprotectiveCr(VI)issolowthatemployeeexposurestoCr(VI)from coating. Examples of Cr(VI) compounds include: working with portland cement are typically well below • ammonium dichromate ((N4)H2Cr2O7); the action level. • calcium chromate (CaCr4bdluohserawaeEmseroyplrasdoththattandersO;) • chromium trioxide or chromic acid (C3r;)Oraealecnipsepotodeeoyexstcelpmeottorpdproltna • lead chromate (PbCr4orfitimlerusopxeelbissiO);sapermOSHAhacmene.t • potassium chromate (2CKrO4); portland cement (see 29 CFR 1910.1000 for general • potassium dichromate (2KCr2O7);55fructonst.pAoi)nirtarppoonrspeeteropal-cindusrt;y29FCR915100.1fo0shryaip;sdr921RFC.629 • sodium chromate (N2OCra4 c); or • strontium chromate (SrCr4011.R919FCee2en-org32f;anO)dporivedmsutebedwhendandustiwophkrowgni-enem(stlartcndeevittnempiuq • zinc chromate (ZnCr4raleRFC92;yrtsudnishrfo2155.911.)Os;rdyaipRCF92 Employers can consult their suppliers or examine 1926.95 for construction). Adequate washing facilities material safety data sheets (MSDSs) to identify Cr(VI)-must also be provided in all sectors (see 29 CFR containing materials that are present in the workplace. 1910.141(d) for general industry and shipyards; 29 CFR Cr(VI) can also be formed when performing “hot work” 1926.51(f) for construction). In addition, OSHA’s Hazard such as welding on stainless steel, melting chromium Communication standard (29 CFR 1910.1200) requires metal,orheatingrefractorybricksinkilns.Inthesesitua-trainingforallemployeespotentiallyexposedtohaz-tions the chromium is not originally hexavalent, but the ardous chemicals, including portland cement. high temperatures involved in the process result in oxi-dation that converts the chromium to a hexavalent state.WHERE EXPOSURES CANNOT EXCEED 0.5 µg/m3 Appendix II of this document presents a more extensive An exemption from the standards is provided for description of the industry operations and processes that e e data d aretypicallyassociatedwithCr(VI)exposure.tehmatplaoymerastewrihaolchoanvteaionibnjgctcihvromiumoermaonssptercaitfiincg The Cr(VI) standards do not apply in three situa- process, operation, or activity involving chromium tions: Exposures that occur in the application of pesti- cannotrelease dusts, fumes, or mists of Cr(VI) in con-cides; exposures to portland cement; and where the centrations at or above 0.5 micrograms per cubic employer has objective data demonstrating that Cr(VI) meter of air (0.5µ/mg3) as an 8-hour time-weighted concentrations cannot exceed 0.5 micrograms per average (TWA) under any expected conditions of use. cubic meter of air as an 8-hour time-weighted average Whenusing the phrase “any expected conditions of under any expected conditions of use. use,” OSHA is referring to any situation that can rea-sonably be foreseen by the employer. The meaning of APPLICATION OF PESTICIDESthe term “objective data” is discussed in the following The standards do not cover exposures to Cr(VI) that section. occur in the application of pesticides. Some Cr(VI)-con- This exception for situations where exposures are taining chemicals, such as chromated copper arsenate not likely to present significant risk to employees (CCA) and acid copper chromate (ACC), are used for allows employers to focus their resources on expo-wood treatment and are regulated by the Environmen- sures of greater occupational health concern. tal Protection Agency (EPA) as pesticides. OSHA does 4 Occupational Safety and Health Administration