Protection from Hex Chrome

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 Areas	Hygienic Practices
<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:

Verify proper ventilation of hex chrome tanks
Investigate better ways to rinse parts as they are removed from baths to avoid airborne droplets
Remove parts from tank baths more slowly
Reduce cross air drafts from doors or fans
Use recirculation pumps instead of air for tank agitation
Investigate use of wetting agents to lower surface tension of the bath (e.g., fume suppressants)
Evaluate the use of liquid chrome additives in place of dry flake materials
Avoid dry broom sweeping of floor; clean area by vacuum with HEPA-filter, wet mop area floors, or use oil-based floor sweep absorbent
Verify proper PPE such as rubber gloves, apron, safety glasses, and boots are used appropriately
Train authorized employees on use of the PPE and the hazards of hex chrom,
Perform routine inspections of the regulated area to verify PPE is utilized, and inspect for chrome sores on hands and arms
Do not permit employees to wear clothing or carry equipment contaminated with hex chrome from the facility
Place contaminated items that are to leave the plant (i.e., laundering) into containers that are leak-proof, sealed, and labeled in accordance with the Hazard Communication Standard
Inform your laundry provider of the potential hazards associated with hex chrome
Provide a changing room that has 1 shower per 10 employees and can prevent cross contamination of work and street clothing; keeping clothing in sealed containers will help
Encourage employees to take a shower prior to leaving, or at a minimum, thoroughly wash hands, arms, and face with warm water and soap
Encourage employees to take a shower prior to leaving, or at a minimum, thoroughly wash hands, arms, and face with warm water and soap
Frequently wash hands and arms, particularly prior to breaks
Prohibit eating, drinking, smoking, and food storage within regulated areas
Store containers of hex chrome materials only in a designated area
Dispose of accumulated items/soils by spill-proof container and in accordance with state and USEPA requirements
Provide annual physicals for hard chrome plating employees in accordance with OSHA 29 CFR 1910.1026(k) (Hexavalent
Chrome Standard) and 29 CFR 1910.124(h)(4) (Coating and Dipping Operations)
Maintain on file exposure determination, monitoring results, and medical surveillance records in accordance with 29 CFR 1910.1020 (Medical Records).

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.