osha’s hexavalent chromium standards, etc.chromium ... dunbar osha...osha’s hexavalent chromium...

OSHA’s Hexavalent Chromium Standards, etc.

OSHA’s Hexavalent Chromium Standards, etc.Chromium Standards, etc.Chromium Standards, etc.

Doug Dunbar, CSP, CIHEHS Department

Sassaman LLC April 28, 2011April 28, 2011

This presentation has been tailored to the applications in the welding industry and focuses on the application of industrial hygiene principles and may discuss OSHA’s intent and general requirements. It is not inclusive of all potential requirements based on specific applications.

Please refer to the applicable standard for a full discussion of the regulatory requirements.

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Hexavalent Chromium Hexavalent Chromium

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Performance Based StandardsOSHA Regulatory Standards

Performance Based StandardsOSHA Regulatory Standards

Examples of chemical specific performance based standards

Lead 29CFR 1910 1025 Lead - 29CFR 1910.1025 Cadmium - 29CFR 1910.1027 Asbestos – 29 CFR 1910.1001 &

1926 11011926.1101 Hexavalent Chromium

– General Industry - 29CFR 1910.10261910.1026

– Construction - 29CFR 1926.1126– Shipyards - 29 CFR 1915.1026

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Chromium and Its Valence StatesChromium and Its Valence StatesChromium and Its Valence StatesChromium and Its Valence States

Chromium can exist as base Chromium Metal

metal (Cr 0), divalent chromium (Cr II), and trivalent chromium (Cr III) and hexavalent chromium Di l t(Cr III), and hexavalent chromium (Cr VI)

Trivalent chromium (Cr III) is the

Divalent Chromium

most stable state; naturally occurring

Cr VI is less chemically stable;

Trivalent Chromium

Cr VI is less chemically stable; most compounds are man made Hexavalent

Chromium

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Chromium VI CompoundsChromium VI Compoundspp Man-made substances used in industrial

applications

Hexavalent chromium compounds have many varied uses in industry and are often used for their anti corrosive often used for their anti-corrosive properties in metal coatings, protective paints, dyes, and pigments.

Hexavalent chromium can be formed when performing “hot work” such as welding on stainless steel, melting chromium metal, or heating refractory bricks in kilns, or performing hot work on steel structures with chromates in the coatings.

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the coatings.

Chromium VI CompoundsChromium VI CompoundsppPortland cement

contains trace levels contains trace levels of hexavalent chromium

Formally exempt from the standard

OSHA has used other OSHA has used other general standards provision to enforce

t ti f protection from overexposure

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OSHA PELOSHA PELOSHA PELOSHA PELPermissible E Li it Exposure Limit

(PEL)8-hour time-

5 µg/m3 TWA8

in the air8 hour timeweighted average

exposure limit (TWA)

in the air

(TWA)

Action Level 2.5 µg/m3 TWA8Action Level (AL)

0.5 of PEL

µg/ 8

in the air

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Routes of ExposureRoutes of ExposureRoutes of ExposureRoutes of ExposureHow Can Hexavalent Chromium Enter the

Body?Body? Inhalation of dusts, mists, or fumes created during processes g pinvolving the use of Cr VI compounds or hot processes that cause the processes that cause the formation of Cr VI

Eye or skin contact Eye or skin contact with powder, dusts, or liquids containing Cr VI

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Cr VI

OSHA’s Hexavalent Chromium StandardsWho does the Ne Standard appl to?OSHA’s Hexavalent Chromium StandardsWho does the Ne Standard appl to?Who does the New Standard apply to?Who does the New Standard apply to?

ScopeScope– General Industry 29 CFR 1910.1026– Shipyards 29 CFR 1915.1026py– Construction 29 CFR 1926.1126

Are you affected? – Review applications for use of chromium

containing materials including surface coatings.A l MSDS h t f h t t– Analyze your MSDS sheets for chrome content

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OSHA’s Hexavalent Chromium StandardsWhat o need to kno !OSHA’s Hexavalent Chromium StandardsWhat o need to kno !What you need to know!What you need to know!

Does the New Standard apply to your operations? What is the Cr(VI) exposure of each potentially

exposed worker? If i i t l t i di t l If engineering controls are not immediately

available, then protect any worker over the PEL with a respirator!

Plan, evaluate and implement permanent engineering and work practice controls!

Th b d f t tl t lli The burden of not permanently controlling exposures!

The importance of communications and

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The importance of communications and recordkeeping!

Significant Dates to RememberSignificant Dates to Remember

February 28, 2006 - OSHA published the new standard

May 30, 2006 – Effective date Enforced 180 days from the effective date

ith tiwith exceptions– Nov 27, 2006 – 20 or more employees– May 31, 2007 – less than 20 employeesMay 31, 2007 less than 20 employees– May 31, 2010 - engineering control

requirements

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OSHA’s Hexavalent Chromium StandardsE D t i tiOSHA’s Hexavalent Chromium StandardsE D t i tiExposure DeterminationExposure Determination

It all starts with determining exposure!It all starts with determining exposure! Each employer shall determine the 8-hour TWA

exposure for each employee exposed to hexchrome. Two options for determining employee exposure:

– Performance-oriented option• Objective data• Objective data

(Manufacturer physical data andIndustry-wide exposure surveys)

• Historic monitoring data• Historic monitoring data(Company specific exposure data)

– Scheduled monitoring option

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OSHA’s Hexavalent Chromium StandardsE D t i tiOSHA’s Hexavalent Chromium StandardsE D t i tiExposure DeterminationExposure Determination

Scheduled Monitoring OptionScheduled Monitoring Option Purpose:

– Identify source(s) of exposure.Identify source(s) of exposure.– Determine extent and degree of exposure(s) at the

worksite.Prevent employee overexposure– Prevent employee overexposure

Perform initial monitoring of each employee, or establish similar exposure groupings and p g p gselect “representative” worst case exposure.

Utilize a Certified Industrial Hygienist.

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MonitoringMonitoringScheduled MonitoringIf initial Cr VI concentration is:

−Below the Action Level Discontinue monitoring

−At or Above the Action Level

Monitor every 6 monthsCan discontinue monitoring if exposures are below AL and Level exposures are below AL and confirmed

Monitor every 3 months−Above the PEL

Monitor every 3 monthsCan discontinue monitoring if exposures are below AL and confirmed

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Exposure MonitoringExposure MonitoringExposure MonitoringExposure Monitoring

Area Samplingp g– A screening technique

to help prioritize monitoringg

Employee Sampling– Evaluate personal

exposures

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M th d U d t M i t i EM th d U d t M i t i EMethods Used to Maintain Exposures Below the PEL:

Methods Used to Maintain Exposures Below the PEL:

E i i t l h l l h tEngineering controls—such as local exhaust ventilation

Warning signs to demark where an employee’sWarning signs to demark where an employee s exposure to Cr VI is at or above the PEL

Hygiene facilities and practicesProtective work clothing and equipmentRespiratory protection

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OSHA’s Hexavalent Chromium StandardsOSHA’s Hexavalent Chromium StandardsMethods of ControlMethods of Control

Substitution: reduce or eliminate fume bySubstitution: reduce or eliminate fume by changing the welding process and/ or procedurespIsolation: enclose or barricade the sourceVentilation: local exhaust ventilation (LEV)Ventilation: local exhaust ventilation (LEV)Safe Work Practices: operator techniquePersonal Protection Equipment: respirators

– Until May 30th, 2010

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OSHA’s Hexavalent Chromium StandardsM th d f C t lOSHA’s Hexavalent Chromium StandardsM th d f C t lMethods of ControlMethods of Control

“OSHA has determined that the use of an alternate welding process that reduces fume generation, such as switching from shielded metal arc weldingsuch as switching from shielded metal arc welding(SMAW) to gas metal arc welding (GMAW) could be effective in reducing a worker’s exposure to hexavalent chromium to a level at or below thehexavalent chromium to a level at or below the PEL.”

Source: Us Department of Labor; OSHA: Occupational Exposure Hexavalent Ch i Fi l R l P 10256 F b 28 2006Chromium, Final Rules, Page 10256 February 28, 2006

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SubstitutionGenerate less welding fume constituent by substituting: W ldi P Welding Process Consumable Type Gas Selection Gas Selection Welding Procedure Waveform Control Technologygy

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I l tiIsolationPlace a barrier between employees and the

fsource of exposure. Switch from manual welding to

automation and ventilate enclosureautomation and ventilate enclosure.

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OSHA has determined that … “local exhaust systems that capture airborne Cr(VI) near its source and remove it from the workplaceits source and remove it from the workplace . . . is generally preferred to dilutionventilation because it provides a cleaner pand healthier work environment.”

S OSHA S ll E tit C li G id f th H l tSource: OSHA Small Entity Compliance Guide for the Hexavalent Chromium Standards, Page 9, OSHA 3320-10N 2006

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OSHA’s Hexavalent Chromium StandardsM th d f C t lOSHA’s Hexavalent Chromium StandardsM th d f C t lMethods of ControlMethods of ControlVentilation

G l E t ti &

Local Extraction

General Extraction & Ventilation

Source Extraction

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Safe Work PracticesSafe Work PracticesComplement Engineering Controls: Proper operator welding techniques Proper operator welding techniques Proper usage of ventilation systems Periodic inspection and maintenance Periodic inspection and maintenance. Rotation of employees (to reduce

exposure) not allowed except for crossexposure) not allowed except for cross-training and ergonomics

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Welding ProcessesWelding Processes

Percent fume produced by diff t ldi

Welding ProcessesWelding Processes

different welding processes (as % of pounds of consumable used)

Submerged Arc (SAW) 0.02 – 0.1%MIG Wire (GMAW) 0.3 – 0.8%Cored Wire (FCAW-GS) 0.8 – 1.5%Stick (SMAW) 1.0 – 2.5%Cored Wire (FCAW-SS) 1.3 – 4.0%

E ti t i di t SMAW d GMAWEstimates indicate SMAW and GMAW on mild steel, stainless steel, and aluminum are performed by 70% of welders

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welders

RespiratorsRespiratorsProvide respiratory protection p y p

when:– Employee exposure to Cr VI is

at or exceeds the PELat, or exceeds the PEL– Engineering and work practice

controls are not sufficient to reduce exposure levels to or below the PEL (Must be in place)

– An employee requests a Half Mask P 100p y qrespirator

Half-Mask P-100 Respirator

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OSHA’s Hexavalent Chromium StandardsP l P t ti E i tOSHA’s Hexavalent Chromium StandardsP l P t ti E i tPersonal Protective EquipmentPersonal Protective Equipment

OSHA h d t i d th t “If f iblOSHA has determined that “If feasible engineering and work practice controls are not sufficient to reduce employee exposure to or below the PEL, theexposure to or below the PEL, the employer must use them to reduce the exposure to the lowest levelachievable. Respirators must then be pused to reduce employee exposure to or below the PEL.”

Source: OSHA Small Entity Compliance Guide for the Hexavalent Chromium Standards, Page 10, OSHA 3320-10N 2006

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R i tRespiratorsExposure determination trigger: > PELC ( f )– Cannot be used (after May 31, 2010) without implementing engineering solutions.

– Engineering and work practice controls haveEngineering and work practice controls have reduce exposures to the lowest levels achievable but exposure is still above the PEL

– Employee exposure to Cr(VI) above the PEL are less than 30 days per year. (12 consecutive months)

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)


Hygiene & ClothingHygiene & ClothingExposure determination trigger: Judgment– Employer must provide appropriate protective p y p pp p p

clothing & equipment if needed.– Employer must make sure they use the clothing

& equipment properly& equipment properly.– Ensure employees with skin contact wash their

hands and faces (skin & eye contact)( y )– Ban eating, drinking & chewing in regulated

areas (ingestion)

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Hygiene Facilities and PracticesHygiene Facilities and PracticesHygiene Facilities and PracticesHygiene Facilities and PracticesWhere airborne exposure to Cr VI is at, or exceeds the PEL

Change rooms – separate storage facilities for PPE and street clothes

Washing facilities— Wash hands and face:

•at the end of the work shift•prior to eating, drinking, smoking, chewing tobacco or gum, applying cosmetics, or using the toilet

—Employees are required to shower after work and must not leaveEmployees are required to shower after work and must not leave their work area wearing any protective clothing or equipment worn during their shift

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OSHA’s Hexavalent Chromium StandardsR l t d AOSHA’s Hexavalent Chromium StandardsR l t d ARegulated AreaRegulated Area

Establishment of a Regulated AreaEstablishment of a Regulated AreaExposure determination trigger: > PEL

Regulated area means an “area, demarcatedRegulated area means an area, demarcated by the employer, where an employee’s exposure to airborne concentrations of Cr(VI) exceeds, or can reasonably be expected to exceed, the PEL.”

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OSHA’s Hexavalent Chromium StandardsH k iOSHA’s Hexavalent Chromium StandardsH k iHousekeepingHousekeeping

Purpose:pExposure Determination trigger: Judgment– Surfaces maintained as free as “practicable”– Methods for cleaning surfaces and spills

• Do USE vacuum HEPA-filter• Do USE wet methods• Do NOT use compressed air• Do NOT use dry methods.

– Proper disposal of contaminated materials toProper disposal of contaminated materials to minimize contact

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OSHA’s Hexavalent Chromium StandardsM di l S illOSHA’s Hexavalent Chromium StandardsM di l S illMedical SurveillanceMedical Surveillance

Purpose:Purpose: Exposure determination trigger: >ALThe purpose is to:

– Determine if exposure can occur without adverse health effects.

– Identify adverse health effects when they occurIdentify adverse health effects when they occur.– Specify who, when, what and how medical

surveillance is to be provided.D t i fit t PPE h– Determine fitness to use PPE such as a respirator.

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OSHA’s Hexavalent Chromium StandardsH d C i tiOSHA’s Hexavalent Chromium StandardsH d C i tiHazards CommunicationHazards Communication

Follow the requirements of the HazardFollow the requirements of the Hazard Communication standard; 29CFR 1910.1200

Trigger = Scope of standard applies to you Th i t i l d The requirements include:

– Methods used to detect Cr(VI) in the workplace– Measures employees can take to protect themselves– The requirements of the standard– The medical surveillance program requirements

Training must be provided as often as is g pnecessary

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OSHA’s Hexavalent Chromium StandardsR dk iOSHA’s Hexavalent Chromium StandardsR dk iRecordkeepingRecordkeeping

PurposePurposeTrigger = Scope of standard applies to you.

Assist in identifying workplace-related illness. D t t l li Demonstrate employer compliance:

– Employee exposure assessment– Air sampling data– Historical data– Objective data– Medical surveillance– Hazard Communications

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OSHA’s Hexavalent Chromium StandardsR C li D t

OSHA’s Hexavalent Chromium StandardsR C li D tRecap: Compliance DatesRecap: Compliance Dates

Employers with 20 or more employees must comply by November 27, 2006.

Employers with 19 or fewer employees must comply by May 30, 2007.comply by May 30, 2007.

Engineering and work practice controls must be in place by May 31, 2010.

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OSHA’s Hexavalent Chromium StandardsA ti StOSHA’s Hexavalent Chromium StandardsA ti StAction StepsAction Steps

Perform the Exposure Determination– Recommend a Professional Industrial Hygienist

Immediately protect any worker who exceeds regulatory triggersregulatory triggers– Provide Respirator, other PPE, Housekeeping, etc.

Determine the Practicable Control Solutions– Substitute– Isolation– VentilateVentilate– Safe Work Practices – Personal Protective Equipment

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Maintain detailed records

OSHA’s Hexavalent Chromium StandardsROSHA’s Hexavalent Chromium StandardsRResources:Resources:

OSHA Small Entity Compliance Guidey p– http://www.osha.gov/Publications/OSHA_sma

ll_entity_comp.pdf LECO “OSHA Hexavalent Chromium

Standards” Brochurehtt // li l l t i /– http://www.lincolnelectric.com/en-us/education-center/welding-safety/Pages/welding-safety.aspxy g g y p

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Update: ACGIH NOIC for ManganeseUpdate: ACGIH NOIC for ManganeseUpdate: ACGIH NOIC for ManganeseUpdate: ACGIH NOIC for Manganese

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Update: ACGIH NOIC for ManganeseUpdate: ACGIH NOIC for Manganese

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Health Effects of FumesHealth Effects of Fumes

Manganese - Mng

– Occurs naturally in environment and, at low levels, is essential for maintaining good healthhealth

– Prolonged overexposure alleged to cause neurological injury

– Very common component of earth’s crustVery common component of earth s crust– Component in all mild steel products

• Largest user is steel industry (adds strength and hardness and removes sulphur contamination)

– Ingredient of flux in many SMAW and FCAW electrodesI di t f GMAW bl ll

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– Ingredient of GMAW consumables as well– Current ACGIH TLV® is 0.2 mg/m3

ACGIH Threshold Limit Values – Chemical S b d Ph i l ASubstances and Physical Agents

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Update: ACGIH NOIC for ManganeseUpdate: ACGIH NOIC for ManganeseUpdate: ACGIH NOIC for ManganeseUpdate: ACGIH NOIC for ManganeseBEI® Development

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Threshold Limit Value (TLV®)Threshold Limit Value (TLV®)

ACGIH term used to express the maximum ACGIH term used to express the maximum airborne concentration of a material which most workers can be exposed to daily throughout their working career without adverse health affects.working career without adverse health affects.

Not to be considered as a fine line between safe and unsafe exposures.

Not a relative index of toxicity Not a relative index of toxicity Intended for use in the practice of industrial

hygiene. Used as guidelines in the control of health hazards Used as guidelines in the control of health hazards

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Bench Testing & Exposures Assessment Trials

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AWS F1.2 Method – Fume Collection Apparatus

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Update: ACGIH NOIC for ManganeseSummary- Summary

ACGIH NOIC Mn TLV Respirable Mn – from 0.2 mg/m³ to 0.02 mg/m³ACGIH S i tifi B d ACGIH, Scientific Body –Makes TLVs as Guidelines

Basis For TLV Changes – Pre-clinical effects (Still controversial)controversial)

Many welding processes would require additional controls to Meet the Proposed TLVTLV

3rd Comment Period Ends –7/31/11

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osha’s hexavalent chromium standards, etc.chromium ... dunbar osha...osha’s hexavalent chromium...

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