Hexavalent Chromium “New OSHA Standard”

1. Hexavalent Chromium “New OSHA Standard” Informational Web Cast

2. Presented by MSA John Hierbaum Product Line Manager Air Purifying Respirators & Meghan Swanson Staff Chemist

3. WELCOME Thank You for joining us today

4. CAUTION! • This presentation is an overview of the new standard • This presentation does not represent the complete standard as published by OSHA • It is important that all participants review the entire standard before implementing a program within the workplace

5. AGENDA • Timetable for the new Hexavalent Chromium Standard • Workers most notably affected • What is Hexavalent Chromium? • What are its health hazards? • Elements of the New Standard • Steps to comply with the new standard • Q & A

6. New OSHA StandardHexavalent Chromium • Covers • General Industry - 1910.1026 • Shipyards - 1915.1026 • Construction - 1926.1126 • Most requirements are generally the same for all industries

7. Exceptions to the New Standard • Does not impact application of some pesticides (EPA regulated) • Does not impact exposures to portland cement • Does not impact situations in which the employer has objective data demonstrating that a material containing chromium or specific operation or activity cannot release Cr (VI) in concentrations at or above 0.5 µg/m3 as an 8 hour TWA

8. Significant Dates to Remember • February 28, 2006 - OSHA published the new standard • May 30, 2006 – Effective date • Enforced 180 days from the effective date with exceptions • Nov 27, 2006 – 20 or more employees • May 31, 2007 – less than 20 employees • May 31, 2010 - engineering control requirements

9. What Activities are the Sources of Chromium (VI)? • Welding and cutting of stainless steel and other chromium containing metals • Heavy Painting and coating • Electroplating • Handling of chrome based pigments

10. How Many Workers are Exposed? • About 558,000 workers are exposed to Cr(VI) • Several workers will be required to use respiratory protection • Welders represent the highest single worker group exposed

11. WHAT IS HEXAVALENT CHROMIUM?

12. Cr(VI) • Hexavalent chromium (Cr(VI)) compounds exist in several forms, known as chromates • Typically particulates • Yellow, orange, or red in color • Trivalent chromium (Cr(III)) is the most stable state; naturally occuring • Cr(VI) is less chemically stable; most compounds are man made

13. Chromates have Varying Solubilities • Highly soluble in water: • Sodium dichromate • Chromic acid • Slightly soluble in water: • Calcium chromate • Strontium chromate • Zinc chromate • Insoluble in water: • Lead chromate • Barium chromate

14. Exposure Routes • Inhalation • Particulates, such as: • Paint spray • Welding fumes • Chromate dust • Skin exposure

15. Health Effects • Respiratory • Lung cancer • Damage to nasal membranes • Asthma • Dermal • Skin damage • Internal organs • Kidney • Liver

16. Carcinogenic Effects: Lung Cancer • Cells uptake Cr(VI) • Faster for soluble forms of Cr(VI) • Insoluble chromates concentrate • Particles < 10 µm contact target cells • Cells react with Cr(VI) to form Cr(III) and toxic byproducts, Reactive Oxygen Species • DNA is damaged • Cell replication disturbed

17. Other Respiratory Effects • Nasal Irritation • Nasal Ulcerations • Nasal Septum Perforations • Asthma • Cr(VI) is an airway sensitizer • Exposure prompts immune response • Bronchitis

18. Additional Health Effects • Dermal • Contact dermititis • Skin ulcers • Internal • Gastrointestinal ulcers • Kidney disease • Liver damage

19. Summary of Health Issues • Major health effects • Lung cancer • Damage to nasal passages • Skin rashes and ulcers • A high % of workers exposed can get lung cancer • This standard is intended to reduce these health risks

20. Major Elements of the New Standard • Permissible Exposure Level • Exposure Determination • Engineering Controls • Personal Protection • Medical Surveillance • Worker Education and communication

21. Permissible Exposure • PEL • Reduced from 52 micrograms of Cr(VI) per cubic meter of air as an eight-hour time weighted average (TWA) to 5 µg/m3 • This cannot be achieved by rotation of employees • Note: OSHA originally wanted to reduce the PEL to 1 µg/m3 • Draft standard • Action Level • 2.5 micrograms per cubic meter of air

22. Exposure Determination • Employer has 2 choices • Scheduled monitoring • Performance oriented • Must determine the 8-hour TWA exposure for each employee

23. Scheduled Monitoring • Initial monitoring • Sufficient # of samples • Full-shift exposure • All job classifications • Follow-up monitoring • None if below action level • 6 months if above action level • 3 months if above PEL

24. Monitoring Guidelines • If employee exposure exceeds PEL • Employer must notify employee within 15 days • Post information • Written notification • Accuracy of measuring equipment • +/- 25% • Confidence level of 95% • Employees can observe monitoring • Employer to provide personal protection

25. Performance Oriented Option • Air monitoring data • Historical monitoring data • Objective data • If employee exposure exceeds PEL • Employer must notify employee within 15 days • Post information • Written notification

26. Engineering Controls • Engineering controls mandatory with exceptions • Effective date • May 31, 2010 • Shall reduce the exposure below the PEL • If not feasible, respiratory protection must be used

27. Exceptions to Eng. Controls • #1 - Aerospace • Painting large aircraft • Must reduce exposure below 25 micrograms • Unless not feasible • Supplement with proper respiratory protection • #2 - Employee is not exposed above PEL for 30 or more days per year

28. PPE • Respiratory Protection • To comply, one can use a traditional half-mask NIOSH approved respirator with N-95 filters. For maximum protection however, MSA recommends a P-100 filter with a full facepiece. • Respiratory program must be in accordance with 29 CFR 1910.134 • A copy of this is available on the MSA web site

29. Other PPE • Work clothing • Provided by employer where necessary • No cost to employee • Employer must ensure it is used • Must be cleaned properly, taking precautions to prevent contamination of other employees

30. Medical Surveillance • Employer to offer free of charge • All employees who may be exposed above the action level for 30 or more days per year • Employees showing signs of exposure • Employees exposed in an emergency

31. Medical Surveillance Frequency • Within 30 days of initial assignment, unless employee had Cr(VI) exam within last 12 months • Annually • Within 30 days of PLHCP’s recommendation for further exam • If employee shows signs or symptoms • Within 30 days of emergency exposure • At termination, unless last exam was within 6 months • Exam must include medical & work history, history of respiratory problems, other specific problems (listed in rule)

32. Medical Surveillance • Employer must provide to PLHCP: copy of this standard, a description of employees duties, employees exposure level to CrVI, description of PPE and how long used by employee, information on previous employee medical exams • PLHCP’s written medical opinion: furnished within 30 days of exam, any detected medical condition which affects work, employee limitations on work and PPE usage, statement that the PLHCP has explained results to employee • Employer must provide exam info in writing to employee within 2 weeks of exam

33. Employee Education and Communication • Employer must provide a copy of the standard to the employee • Employer must insure employee can demonstrate knowledge of: • The contents of this rule • The purpose and description of medical surveillance

34. Recordkeeping • Employer must keep records of • Air monitoring data • Historical monitoring data • Objective data • Medical surveillance

35. Methods of Compliance • Respiratory Protection • Half-Mask • Full Facepiece • PAPR • Air-Line Respirator • Exposure determination • Sampling Equipment

36. Advantage 200 LS Respirators • Any NIOSH approved filter • P-100 (as shown) is best • Can use up to 10X the PEL

37. Advantage 3000 Respirator • Full-Face Respirator • Any NIOSH approved filter • Can use up to 50X the PEL

38. Powered Respirator (PAPR) • Used with full-face respirator • High Efficiency P-100 filter • Can use up to 50X the PEL

39. Air Line Respirators • Constant- Flow • Positive Pressure • No filter required • Can be used up to 2000X the PEL • You cannot exceed the maximum use concentration.

40. Monitoring • To test exposure use an MSA Escort® Elf Sampling Pump • The procedure for hexavalent chromium calls for particle collection using a 37-mm, 5-µm pore size PVC filter.

41. QUESTIONS? Thanks for attending!