Update: Hexavalent Chromium Cr(VI)

1. Update: Hexavalent Chromium Cr(VI) Drawn from the Preambles and Training Materials from the National Office and Regions 5 and 6

2. Purpose Present an overview of the major provisions of OSHA’s Cr(VI) standard (71 FR 10100, February 28, 2006). Note: This presentation is for training purposes only. Consult the Federal Register on OSHA’s web site for the complete requirements of this standard.

3. What is Hexavalent Chromium? • Toxic form of chromium metal that is generally man-made • Used in many industrial applications primarily for its anti-corrosive properties • Can be created during certain “hot” work processes where the original form of chromium was not hexavalent

4. Is Chrome a Carcinogen or Necessary Element? • Chrome III is an essential nutrient for maintaining blood glucose levels • Chrome VI is classified as a known human carcinogen

5. Operations with Cr(VI) Exposure • Electroplating • Welding/cutting/torching/grinding painted surfaces • Welding/cutting/grinding stainless steel, chrome alloys and even carbon steel • Applying/removing coatings with chrome • Glass production • Chemical synthesis • Chromium catalyst users • Printing ink production

6. Routes of Exposure • Inhalation of dusts, mists, or fumes created during processes involving the use of Cr(VI) compounds or hot processes that cause the formation of Cr(VI) • Eye or skin contact with powder, dusts or liquids containing Cr(VI) with skin absorption possible • Ingestion through contamination of food and drink (controversy over extent of issue)

7. Major Health Effects • Lung cancer • Nasal septum ulcerations and perforations • Asthma • Skin ulcers • Allergic and irritant contact dermatitis

8. History of Exposure Limits • 1943 ANSI standard was the source of OSHA’s 1971 standard of 1mg/10 m3 Cr(III) or 52 µg/m3 CR(VI) • Mounting evidence of carcinogenicity • 1974 by ACGIH • 1975 by NIOSH • 1984 by EPA • 1990 by IARC

9. Occupational Exposure Limits • NIOSH REL • 0.001 mg Cr VI/M3 10-hr TWA • ACGIH TLV • Water-Soluble Cr VI compounds as Cr 0.05 mg/M3 TWA • Insoluble Cr VI compounds as Cr 0.01 mg/M3 TWA • ACGIH BEI • Total chromium in urine BEIs (2) for Chrome VI water soluble fume

10. History of New Standard • In 1993 the Health Research Group petitioned for ETS of 0.5 µg/m3 • OSHA unable to demonstrate “grave danger” • In 1997 HRG sued to complete rulemaking process and lost • In 2002 HRG sued to complete rulemaking process and won • Proposed rule to be issued 10/4/04 • Final rule to be issued 1/18/06 • Final rule was issued 2/28/06

11. Steps to Complete a Rule • Review all research on health effects ** • Peer review of OSHA review • Develop risk assessment ** • Justify significance of risk assessment • Perform Economic Analysis and Regulatory Flexibility Analysis with SBREFA Assessment – 6 issues for each potential PEL ** • Submit to OMB – 5 laws • Proposed rule with Questions • Hearings • Final Rule

12. Case Law for Health Standards • 1980 Supreme Court decision on benzene requires examination of significance of risk (cost-benefit) • 1981 Lead and Cotton Dust cases gave concept of technological and economical feasibility in view of financial health and profitability of industry and impact on unit pricing **

13. Greater Risk Than Asbestos At the new technologically and economically feasible PEL, the cancer risk from Cr(VI) is higher than other regulated carcinogens • Methylene Chloride: 3.6 per 1000 workers • Asbestos: 6.7 deaths per 1000 workers • Benzene: 10 deaths per 1000 workers • Cr VI: 10-45 excess lung cancer deaths per 1000 workers for 45 years of exposure at new PEL of 5 ug/M3 2/28/06FR p. 10225

14. Three Cr(VI) Standards • 1910.1026 General Industry • 1926.1126 Construction • 1915.1026 Shipyards

15. Scope Permissible Exposure Limit (PEL) Exposure Determination Regulated areas* Methods of Compliance Respiratory Protection Protective Work Clothing and Equipment *General industry only Hygiene Areas and Practices Housekeeping* Medical Surveillance Communication of Hazards Recordkeeping Dates Major Provisions of the Standards

16. Scope: Who is Coveredby the Standard? All occupational exposures to Cr(VI) compounds except: • Exposures that occur in the application of pesticides • Application is already covered by EPA Standards • The manufacture of pesticides and handling of pesticide treated materials are covered under new OSHA standard

17. Scope: Who is Coveredby the Standard? All occupational exposures to Cr(VI) compounds except: • Exposures that occur in the application of pesticides • Exposures to portland cement • American portland cement usually contains only trace amounts • Would typically be over PEL for PNOR before over on Cr(VI) • Use PNOR, Personal Protective Equipment and Hazard Communication Standards for protection

18. Scope: Who is Coveredby the Standard? All occupational exposures to Cr(VI) compounds except: • Exposures that occur in the application of pesticides • Exposures to portland cement • Where employers have objective data demonstrating that a material containing chromium or a process involving chromium cannot release Cr(VI) in concentrations at or above 0.5 µg/m3 as an 8-hour time-weighted average (TWA) under any condition of use

19. Permissible Exposure Limit (PEL) and Action Level (AL) • PEL: 5 µg/m3 - TWA • AL: 2.5 µg/m3 - TWA

20. Exposure Determination Two options allowed for determining employee exposures: • Scheduled monitoring option • Performance-oriented option

21. Scheduled Monitoring Option • Prescribes a schedule for performing initial and periodic personal monitoring • If initial monitoring indicates exposures are: • Below theAL: monitoring can be discontinued • At or above theAL: monitor every 6 months • Above thePEL: monitor every 3 months

22. Performance-Oriented Option • Exposures characterized using any combination of air monitoring data, historical monitoring data or objective data • No fixed schedule for performing periodic monitoring

23. General Requirementsfor Exposure Determination • Affected employees must be notified where exposures exceed the PEL

24. General Requirementsfor Exposure Determination • Affected employees must be notified where exposures exceed the PEL • Methods used for air monitoring and analysis must be sufficiently accurate [+/- 25% and within a statistical confidence level of 95% at AL]

25. General Requirementsfor Exposure Determination • Affected employees must be notified where exposures exceed the PEL • Methods used for air monitoring and analysis must be sufficiently accurate • Employees or their representatives must be allowed to observe Cr(VI) monitoring

26. Regulated Areas • For general industry employers only

27. Regulated Areas • For general industry employers only • Areas where exposures exceed or can be reasonably expected to exceed the PEL • Must be demarcated from other areas • Must limit access to employees who have a need to be there

28. Methods of Compliance • Establishes engineering and work practice controls as the primary means of achieving the PEL

29. Methods of Compliance • Establishes engineering and work practice controls as the primary means of achieving the PEL • Exceptions: • Painting aircraft or large aircraft parts: • Use engineering and work practice controls to achieve 25 µg/m3 and supplement with respirators to achieve the PEL • Tasks or operations that do not result in exposures above the PEL for 30 or more days per year: • Use of respirators alone allowed to achieve the PEL

30. Methods of Compliance • Establishes engineering and work practice controls as the primary means of achieving the PEL • Exceptions: • Painting aircraft or large aircraft parts: • Tasks or operations that do not result in exposures above the PEL for 30 or more days per year • Prohibits job rotation to achieve compliance with the PEL

31. Respiratory Protection Required • Periods necessary to install or implement feasible engineering and work practice controls • Maintenance or repair operations where engineering and work practice controls are infeasible • Operations where all feasible controls have been used and exposures are still above the PEL • Operations where exposures do not exceed the PEL for 30 or more days per year • Emergencies

32. Assigned Protection FactorsFinal Rule August 24, 2006

33. Protective Work Clothingand Equipment • Use where a hazard is present or is likely to be present from skin or eye contact with Cr(VI) • Provided and paid for by the employer • Remove Cr(VI)-contaminated clothing and equipment when work shift or task is completed • Clean, store and label Cr(VI)-contaminated clothing and equipment

34. Hygiene Areas and Practices • Must provide change rooms and washing facilities per 29 CFR 1910.141 • Employees must wash their hands and face at the end of a work shift and prior to eating, drinking, smoking, etc. • Employer-provided eating areas must be kept as free as practicable of Cr(VI) • No eating, drinking, smoking etc. in regulated areas

35. Housekeeping • For general industry employers only • Keep all surfaces as free as practicable of accumulations of Cr(VI) • Use HEPA vacuums or other methods that minimize exposure to Cr(VI) • Use of compressed air prohibited unless: • Used in conjunction with a ventilation system to capture the dust cloud created by the compressed air, or • No alternative method is feasible • Dispose of Cr(VI)-contaminated waste in labeled, impermeable bags/containers

36. Medical Surveillance • Provisions for conducting baseline and periodic health assessments of exposed employees • Provided by or under the supervision of a physician or other licensed health care professional (PLHCP) • Provided at no cost to employee and at a reasonable place and time

37. Purpose of Medical Surveillance • Determine if an individual can be exposed to the Cr(VI) present in their workplace without experiencing adverse health effects • Indentify Cr(VI)-related adverse health effects so that appropriate intervention measures can be taken • Determine the employee’s fitness to use PPE, such as respirators

38. Which Employees Must Be Provided Medical Surveillance? • Exposed at or above the action level(2.5 µg/m3) for 30 or more days per year • Experiencing signs or symptoms of Cr(VI) exposure • Exposed in an emergency

39. Medical Examination Requirements • Medical and work history, with emphasis on: • Cr(VI) exposure (past, present, future) • History of respiratory system dysfunction • History of asthma, dermatitis, skin ulceration or nasal system perforation • Smoking status and history • Physical examination, with emphasis on the respiratory tract and skin • Any additional tests deemed appropriate by the PLHCP

40. When Must MedicalExaminations Be Offered? • Within 30 days after initial assignment and annually thereafter • Within 30 days after a PLCHP recommends additional examinations • When employees shows signs or symptoms of Cr(VI) exposure • Within 30 days after exposure during an emergency • At the termination of employment

41. Communication of Hazards • Provide employee training in accordance with OSHA’s Hazard Communication standard (29 CFR 1910.1200) • Additional training on the contents of the Cr(VI) standard and the purpose and description of the medical surveillance program required by the standard

42. Recordkeeping • No requirement to maintain training records • Must maintain records per 29 CFR 1910.1020 for: • Air monitoring data • Historical monitoring data • Objective data • Medical surveillance information, including: • PLHCP’s written opinions • Information provided to the PLHCP

43. Compliance Start-Up Dates • Effective date: May 30, 2006 • Start-up dates: • All provisions except engineering controls • For employers with 19 or fewer employees: May 30, 2007 • For all others: November 27, 2006 • Engineering Controls • For all employers: May 31, 2010

44. Hexavalent Chromium Some practical issues

45. FR Preamble: Exposure Ranges

46. OSHA Internal Training on Hexavalent Chromium Sampling • Most pre-existing sampling was for total chrome, probably due to low cost • $50 for total metals analysis via ICP • $150 for Cr(VI) analysis • No way to separate or back calculate Cr(VI) exposures from total chrome (ICP) • Comments at 5/2006 AIHCE “Ask the Experts” Cr(VI) session indicate little new Cr(VI) sampling has been done • Conclusion: Exposure levels are not known WE NEED TO SAMPLE

47. Cr VI SLTC Analysis OSHA ID215as of 6/2006 • Closed face 37mm PVC filter @ 2 lpm • Lab extraction of Cr VI from filter using an aqueous solution of sodium carbonate/sodium bicarbonate • Ion chromatography for Cr VI with postcolumn UV/visible detector set at 540nm wavelength • Limit of detection: 0.003 ug/M3 • SAE: varies, approx 0.112

48. Interferences – Welding Fume Sampling • While in the cassette, Cr+6 reacts with iron Fe+2 to form Cr+3 • Cr+3 is not analyzed by method ID215 • In 6 days you lose 10% of Cr+6 through the Fe+2 reduction reaction • SHIP SAMPLE TO LAB IMMEDIATELY • If mailing will be delayed, get buffer solution from the lab ahead of time. While in the field you put the filters in the buffer solution to stabilize Cr+6

49. Interferences – Plating Sampling • While in the cassette, Cr+6 reacts with acids from the plating baths to form Cr+3 • Cr+3 is not analyzed by method ID215 • In 6 days you lose 10% of Cr+6 through this acid reduction reaction • Order sodium hydroxide coated filters from the lab on an as needed basis for plating sampling • NaOH neutralizes the acid to cut down on Cr+6 loss • Helps maintain Cr+6 on the filter for 30 days • 1-3 month expiration date on these coated filters SHIP SAMPLE TO LAB IMMEDIATELY

50. Filter Blanks • PVC filters are normally cut from sheet filter stock using a stainless steel cutter • Stainless steel contains chromium, and stainless steel cutters leave chrome VI contamination on filters • OSHA uses PVC filters cut with a teflon coated stainless cutter to reduce/avoid background chrome contamination • Some employers may be taking samples with filters contaminated by stainless cutters. • SEND FILTER BLANKS! 5 ug/M3 is a minute amount of material, and filter blanks will help avoid employer objections to your sample results