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Solid Height - Spring Manufacturers Institute

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OSHA Issues<br />

New Standard for<br />

Hexavalent Chromium<br />

What is hexavalent chromium? “Hexavalent<br />

chromium” means chromium with a valence<br />

of positive six, in any form and in any compound.<br />

It is not a type of chromium, but rather the state of<br />

the chromium. Here is the NIOSH definition:<br />

“Hexavalent chromium [Cr(VI] compounds<br />

are a group of chemical substances that contain<br />

the metallic element chromium in its positive-six<br />

valence (hexavalent) state. Occupational exposures<br />

to Cr(VI) occur during the production of stainless<br />

steel, chromate chemicals, and chromate pigments.<br />

Cr(VI) exposures also occur during other work activities,<br />

such as stainless steel welding, thermal cutting,<br />

chrome plating, painting and coating processes.”<br />

In response to a 2003 court order, OSHA has<br />

published a final standard for occupational exposure<br />

to hexavalent chromium in the February 28, 2006,<br />

Federal Register. The standard covers occupational<br />

exposure in general industry, construction and shipyards,<br />

and took effect on May 30, 2006.<br />

The new standard lowers OSHA’s permissible<br />

exposure limit (PEL) for hexavalent chromium, and<br />

all Cr(VI) compounds, from 52 to 5 micrograms<br />

of Cr(VI) per cubic meter of air as an eight-hour<br />

time-weighted average. The standard also includes<br />

provisions relating to preferred methods for controlling<br />

exposure, respiratory protection, protective<br />

work clothing and equipment, hygiene areas and<br />

practices, medical surveillance, hazard communication<br />

and record keeping.<br />

Hexavalent chromium compounds are widely<br />

used in industry as ingredients and catalysts in<br />

pigments, metal plating and chemical synthesis.<br />

Cr(VI) can also be produced when welding, burn-<br />

Jim Wood is an independent regulations<br />

compliance consultant to SMI. A certified<br />

instructor of the OSHA Out-Reach Program,<br />

Wood conducts seminars, plant Safety<br />

Audits and In-House Safety Training. These<br />

programs help companies create safer work<br />

environments, limit OSHA/Canadian Ministry<br />

of Labor violations and insurance costs,<br />

and prepare for VPP or SHARP certification.<br />

He also offers safety advice and information<br />

by phone at (630) 495-8597 or e-mail at regs@smihq.org.<br />

Be<br />

Aware<br />

Safety Tips<br />

from Jim Wood<br />

ing, or grinding on stainless steel or Cr(VI)-painted<br />

or -plated surfaces.<br />

This standard, CFR 29, 1910.1026 applies to<br />

occupational exposure to chromium (VI) in all forms<br />

and compounds in general industry, except: Where<br />

the employer has objective data demonstrating that<br />

the material containing chromium, or a specific process,<br />

operation or activity involving chromium, cannot<br />

release dust, fumes, or mists of chromium (VI) in<br />

concentrations at or above 0.5 micrograms per cubic<br />

meter of air as an eight-hour time-weighted average.<br />

Exposure Determination: Each employer who has<br />

a workplace or work operation covered by this standard<br />

shall determine the eight-hour time-weighted<br />

average exposure for each employee exposed to<br />

chromium.<br />

Monitoring: The employer shall perform initial monitoring<br />

to determine the eight-hour time-weighted<br />

average exposure for each employee on the basis of<br />

a sufficient number of personal-breathing-zone air<br />

samples to accurately characterize full shift exposure<br />

on each shift, for each job classification, in<br />

each work area.<br />

Action Level: If the concentration of airborne chromium<br />

(VI) is 2.5 micrograms per cubic meter of air as<br />

an eight-hour time-weighted average, the employer<br />

shall perform monitoring every six months.<br />

If monitoring reveals employee exposure to be<br />

above the PEL, the employer shall perform monitoring<br />

every three months and initiate a formal<br />

hexavalent chromium program for the protection of<br />

employees in the regulated areas.<br />

Prohibition of Rotation: The employer shall not<br />

rotate employees to different jobs to achieve compliance<br />

with the PEL.<br />

Jim’s Regulatory Tip: Don’t get caught short with<br />

this standard. OSHA is taking it very seriously.<br />

Ask your insurance carrier to perform air-sampling<br />

tests in any department where stainless steel operations<br />

include welding, burning, grinding, sawing or<br />

cutting. The same goes for chromium-plated materials<br />

or any other material containing chromium.<br />

Document all test results as part of the compliance<br />

program. v<br />

SPRINGS July 2006 35

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