Q: OSHA’s relatively new hexavalent chromium standard remains somewhat confusing when trying to implement at our plant. Could you provide some insight on how to obtain compliance? S.H.
A: We could easily fill many pages to answer your question. To keep it simple, we recommend a five-step approach for compliance with the Hexavalent Chromium Standard, 29 CFR 1026.
First, evaluate your plant for potential areas of hex chrome exposure. Operations such as chrome plating, chromate dip baths, metal spray and stainless steel welding can lead to airborne exposures. If you are unsure if hex chrome exists in your plant, consult with your suppliers or examine material safety data sheets. Keep in mind that “hot work” activities, such as welding and thermal cutting, can create hex chrome as a result of oxidation.
|Exposure Data||Exposure Monitoring Requirements||Respirators Required||Medical Surveillance||Regulated |
|<0.5 ug/m3||standard not applicable.|
|0.5 < 2.5 (action level) µg/m3||NA||NA||NA||NA||good house-keeping|
|2.5 < 5.0 µg/m3||every 6 months||NA||annual||NA||washing/changing/ house-keeping|
5.0 (PEL) & >mg/m3
|every 3 months||Yes||Annual||demarcate area(s)||washing/ changing/ housekeeping/ engineering controls|
Second, determine your employees’ exposure concentration (µg/m3 ) in order to determine applicability of the standard. Exposure levels must be determined by one of two methods: personal monitoring or using objective data to determine an 8-hr time-weighted average. If you decide to utilize personal monitoring, we recommend the sampling be designed and supervised by an industrial hygienist. “Objective data” means data, other than employee monitoring, that demonstrates expected employee exposure to hex chrome; information that can serve as “objective data” includes industry-wide air monitoring surveys, trade association data, or calculations based on the composition, chemical and physical properties of the chemical as well as operating conditions of the process. This data must closely resemble your workplace conditions. If exposures are determined to be less than 0.5 µg/m3 , than this standard does not apply.
When exposures are determined to exceed the 0.5 µg/m3 applicability time-weighted average, utilize the following table to assist in obtaining compliance depending upon exposure:
As you can see, due to the ongoing monitoring and medical surveillance requirements, it’s highly desirable that workplace changes occur to get exposures to below the Action Level of 2.5 µg/m3 .
We’ve found this feasible by implementing best management practices to provide employees maximum protection:
Fourth, provide ongoing Hazard Communication Training. Make certain employees are aware of the contents of the Hex
Chrome standard and its availability for their review.
Fifth, inform employees of the exposure results. Employers must notify each affected employee if exposure determination indicates their exposure exceeds the Permissible Exposure Limit (PEL) of 5.0 µg/m3. Additionally, if the PEL is exceeded, employees must be provided with information related to corrective actions the employer is taking to reduce exposures to below the PEL.
For additional guidance, review OSHA’s “Small Entity Compliance Guide for the Hexavalent Chromium Standards” www.osha.gov/Publications/OSHA_small_entity_comp.pdf or type in “Hexavalent Chromium” in the search window at www.osha.gov.