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New rule, new equipment
Fabricators and manufacturers move toward Cr(VI) standard compliance
- By Stephanie Vaughan
- November 7, 2006
- Article
- Safety
A magazine article made Greg Faulkner think about improving welding ventilation at his workplace last year.
Faulkner, senior manufacturing engineer at Henny Penny Corp., an Eaton, Ohio-based food service manufacturer, knew that the high ceilings and air-conditioning equipment already in place were a good start.
But the company welds stainless steel plate and castings for the fryer pot assemblies used in its fryers. With the Occupational Safety and Health Administration's (OSHA) new ruling on permissible exposure levels (PELs) for hexavalent chromium [Cr(VI)], he knew more safeguards would be necessary.
OSHA's new standard requires that general industry, construction, and shipyards reduce the Cr(VI) PEL to 5 micrograms per cubic meter. The previous PEL was 52 micrograms per cubic meter.
Respiratory protection and engineering controls must be in place by Nov. 27 for employers with more than 20 employees and by May 30, 2007, for employers with fewer than 20 employees. Feasible engineering controls must be in place by May 31, 2010.
Determining a Need
"Nothing says healthy living like a breath of fresh air" was the article that made Faulkner start digging into Henny Penny's possible new welding ventilation needs (The FABRICATOR, August 2005, p. 42).
"I kept it as a reference because I liked the chart so much," Faulkner said. Although the company mostly uses gas tungsten arc welding (GTAW), has ceiling heights of at least 24 feet, and has an air-conditioning unit that exchanges air continuously, two manual gas metal arc welding (GMAW) stations that use stainless steel wire were a concern.
Faulkner read as much as he could about welding ventilation to understand the air-monitoring numbers involved. He spoke with his director of operations—a welding engineer by trade—and a company health and safety representative to start investigating ventilation systems that would help them meet OSHA's new standard.
At the time the company's GMAW stations were emitting 50 micrograms of Cr(VI) per cubic meter—below OSHA's previous standard, but above its new standard. But first Faulkner had to recalculate air-monitoring numbers because older measurement reports were in milligrams.
Faulkner visited other shops, many of which used robotic welding and RoboVent units from Great Lakes Air Systems, Clawson, Mich. Although Henny Penny doesn't automate any welding currently, the company is investigating different welding automation options.
Faulkner also noticed RoboVent systems in place at welding robotics integrator Genesis Systems Group, Davenport, Iowa, during a visit to discuss robotic welding.
Next Faulkner attended the FABTECH® International & AWS Welding Show in 2005 to talk with welding ventilation representatives to see what types of systems might fit their two GMAW stations.
Although he had seen the Great Lakes products intended only for robotic welding workcells, Faulkner stopped by the company's booth to investigate possible options for manual welding stations. Then he started talking with a Great Lakes representative from Northland Air Systems, Cleveland, who visited Henny Penny's manufacturing facility.
At the same time Faulkner spoke with Diversified Air Systems, Louisville, Ky., and other ventilation equipment-makers about their ventilation products.
Meeting OSHA's Cr(VI) standard: The other side of the story
One of the largest producers of fabricated metal products in West Virginia is just starting to figure out how to address OSHA's Cr(VI) standard.
A specialist in manufactauring coal handling equipment, power plant parts and equipment, and metal ore refining equipment, this company employs 170 workers in two shops and has built some of the largest pollution control absorbers in existence. The company fabricates and welds nickel alloys, copper, aluminum, aluminum bronze, and titanium.
Carl Smith, quality manager for the company, said that equipping the manufacturing facilities with new ventilation equipment promises to be an expensive endeavor that will completely change the manufacturer's pricing system as it relates to welding.
"At the present time the highest cost process in our shop is machining. I am afraid it will soon be welding," he said.
Smith said the company's nickel-alloy welding is one of the most problematic areas for welding fume exposure. Although respirators and fans are provided, the company soon will need more elaborate ventilation.
Currently the company is determining how many and what types of units it will need for its 112,000 square feet of manufacturing space.
"It is going to be difficult to establish the exact number and the type of extractors there is no way to make a central unit do the job," he said.
The company first is monitoring the workstations involved in fabricating chromium-bearing material and moving those operations to one area to minimize the number and size of the ventilation units needed. Smith said the company also is looking into portable units that can be moved around to different shop areas.
"We are currently considering Lincoln Electric and Torit equipment," Smith said. "Two of our local vocational career centers have the Lincoln equipment and it works very well for dust and fumes, but I am not sure about the particulate matter. I have a friend in New Orleans, at Louisiana State Tech, who has a new type of system that works well, but we can't fit it into our shop.
"Another problem is the proximity of the crane cables to the arm and hose on the units," Smith said. "If a welder has the respirator and welding hood on, it is difficult to know what is going on in the area. If a hook or cable happened to catch on the arm, it could be disastrous."
To help with the process, the company has hired a firm to monitor the shop and personnel. For testing, OSHA requires a licensed medical practitioner to be present. In addition, the monitoring company provides a licensed industrial hygienist.
Smith said that this particular company charges $1,300 per eight-hour day, $40 for each additional hour, and $85 per test sample. He estimates that it will take five days to test current employees and no more than five days to test retirees and about 50 temporary workers, whom they have to locate.
Clothing and floor debris will need to be disposed of in an identified, sealed container. The company also will have to provide a changing room for employees to remove their clothing for disposal and testing.
In addition, the company—ike many other manufacturing and fabrication facilities across the country—will have to inform its employees in writing about the potential health problems associated with Cr(VI).
"It will no doubt open a floodgate for the attorneys," Smith said. "This sort of thing has run up the costs of workers" compensation to the extent that we have now privatized our comp system."
The cost and the possibilities for litigation aren't Smith's biggest worries, though.
"My greatest fear is that this will deter youngsters from seeking a career in the welding industry," Smith said. "We are already facing a severe shortage of welders in our area. I get calls every day for welders and inspectors. We train youngsters at our local technical centers as rapidly and as efficiently as possible, but we are still unable to meet the demand."
The Right Fit
Ergonomically designed for the welder, Henny Penny's GMAW stations have everything the welder needs within reach, so Faulkner wanted to make sure that any ventilation system would capture the fumes at the source effectively—but wouldn't obstruct the welder's ergonomic setup. In addition, because only two stations needed to be fitted with new ventilation equipment, Faulkner didn't want to have to re-duct the entire manufacturing facility to install a permanent unit. Above all, the system had to help the company reduce its PELs.
Eventually Henny Penny decided to use Diversified's downdraft tables for its deburring applications and Great Lakes' WeldPro™ system for its GMAW stations. The WeldPro system, which is positioned at the back of the workstation, fit best.
"It draws a huge amount of air from all around the welder," Faulkner said, adding that its freestanding style is a plus. "We can pick it up with a forklift and move it around the plant. We can take it anywhere to a weld cell, anywhere we'd like."
During a WeldPro demonstration at Henny Penny, an Ohio Bureau of Workers' Compensation representative performed an eight-hour test to make sure that the PELs were compliant with OSHA's standard. The resulting PELs with the new ventilation system were 0.072 microgram per cubic meter—a third of the action level.
Although Henny Penny's situation was resolved relatively seamlessly, Faulkner acknowledged that this is just one example of re-engineering for OSHA compliance.
"Some people would laugh at me and say what you had to do was easy," he said.
Steps to Take
Faulkner is the first to admit that ventilation is an investment that must be considered wisely, especially from a financial standpoint.
"In any given environment, you can ask for only so much capital money in a year's time," he said. Henny Penny budgeted for new ventilation equipment at the beginning of the year to prepare for its investment.
But plenty of other factors also must be considered, according to Gary Q. Johnson, P.E.
An industrial ventilation consultant, Johnson has experience in health and environmental safety and is a member of the American Conference of Governmental Industrial Hygienists' (ACGIH's) Industrial Ventilation Committee.
Johnson said it's challenging to adhere to the more stringent OSHA fume exposure regulations with manual welding.
"It's a human process. The person's going to move," he said. Because of this, companies should develop ventilation approaches that won't interfere with the welder's work. "You have to consider the realities of the job they do."
One option is point-source fume capture, which isn't always practical.
"When a welder's on a good roll, he's not going to want to stop [to move a] point-source control," Johnson said. "Any point-source hood should be above where the welder's welding. You need to take advantage of the thermal buoyancy for the welding fumes to go up."
Another choice is a bench-type system. Johnson cautions that companies must make sure welding hoods aren't too close to the welding. In addition, he said, hoods can be limited in how much air they can capture, based on the suction hood's diameter and how far it is away from the work.
Johnson recommends taking the following steps when choosing a new ventilation system:
- Copy other shops' successful ventilation ideas if their manufacturing operations match or resemble yours.
- Find out what works for your company—welders might be forced to wear respiratory protection if an equipment solution can't be found.
- Work with your company's experienced welders to get them onboard with new ventilation practices to make sure that everyone is following them correctly.
- Demonstrate that the new standard works with air sample and ventilation system measurements.
- Establish a standard practice and train everyone on it.
- Put behavioral management in place to make sure everyone complies.
- Plan for routine exhaust ventilation system airflow or static pressure checks to demonstrate that the system continues to perform as demonstrated at start-up.
Once a system is in place, Johnson emphasizes that ducts will need to be cleaned regularly. The static pressure system-monitoring methods mentioned previously will give early warning of developing problems without the need to look inside the ducts.
"People need to realize that there's going to be more of the chrome stuff in the roof and up in the duct, so when workers clean it, companies need to have safe practices in place to deal with the exposure risk," he said.
Once new ventilation practices and systems are in place, everyone can work more safely and productivity will improve, Faulkner said.
"I talked to the welder who works this cell, and he loves the difference, the way he can do his work, the way he feels. There are all sorts of benefits to it," Faulkner said. "You get productivity improvements that are hard to quantify, but when people feel better, it makes productivity better."
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