New OSHA hexavalent chromium standards

Questions and Answers

WWW.THEFABRICATOR.COM MAY 2007

May 8, 2007

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Compliance with the Occupational Safety and Health Administration (OSHA) hexavalent chromium [Cr(VI)] standards requires certain industries, including steel fabrication, to meet specific respiratory protection requirements. This Q and A article identifies affected industries and applications and discusses how to determine exposure and comply.

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Note: On Feb. 28, 2006, the Occupational Safety and Health Administration (OSHA) published the final hexavalent chromium Cr(VI) standard. The new permissible exposure limit (PEL) for Cr(VI) is 5 micrograms per cubic meter(g/m) as an eight-hour time-weighted average (TWA).

There are three standards for different industries—generaliIndustry, construction, and shipyards. The respiratory protection requirements for the three standards are similar.The standard requires the respiratory protection program, including respirator selection, to follow OSHA 1910.134 requirements.

For employers with more than 20 employees, the standard took effect Nov. 27, 2006. Employers with 19 or fewer employees must be in compliance by May 30, 2007. Feasible engineering controls must be in place by May 31, 2010.

For a complete copy of the standard, please refer to OSHA's Web site at www.osha.gov.

Q. What is hexavalent chromium?

A. Hexavalent chromium Cr(VI) is a metal particle that can occur naturally in rocks, but most commonly is produced by industrial processes. It has the ability to gain electrons from other elements; it is a strong oxidizer, which means it can react easily with other elements. Because of its ability to react with other elements, it can produce hard coatings, which is why it is used in paints for cars, boats, and aircraft.

Q. What type of contaminant is hexavalent chromium?

A. Cr(VI) is a metal particle. It can be filtered with an N95 filter or an R or P95 filter if oil mist is present.

Q. What Cr(VI) exposures are covered in the standard?

A. Cr(VI) exposures from any source are covered, except exposures from:

  • Portland cement.
  • Applications of regulated pesticides, such as wood treated with pesticides. Exposures resulting from sawing or sanding treated wood are covered by the standard.
  • Whenan employer has objective data demonstrating that a material containing chromium or a specific process, operation, or activity involving chromium cannot release dusts, fumes, or mists of chromium (VI) in concentrations of above 5g/m in an eight-hour TWA under any expected conditions of use.

Q. What are the main industries affected?

A. The primary industries affected, according to OSHA, are stainless steel fabrication, heavy-duty coatings and paints, electroplating, and chrome-based pigment production.

Q. What are the main applications affected?

A. Welding (especially stainless steel), spraying heavy-duty coatings and paints, and electroplating.

Q. When must I be in compliance?

A. Employers with 20 or more employees had to be in compliance by November 2006. Employers with 19 employees or fewer must be in compliance by May 30, 2007. Engineering controls, if they are determined feasible and /or necessary, must be in place by May 31, 2010. Until engineering controls are in place, respiratory protection must be used to help reduce exposure.

Q. How does this affect me?

A. Employers must reassess their respirator programs, taking into consideration the lower exposure limit. More employers may have to provide respiratory protection to employees and assess the feasibility of engineering controls, such as ventilation. If they have not already done so, employers in the affected industries should make an exposure determination to establish whether the new standard and its requirements apply and, if so, implement the necessary steps for compliance, including selecting proper respirators.

Q. How do I make an exposure determination?

A. The standard permits exposure determinations to be done either through monitoring or by estimating exposures using any combination of air sampling, historical monitoring data, and objective data. If historical or objective data is used, it must reflect workplace conditions closely resembling the processes, types of materials, control methods, work practices, and environmental conditions in the current operations.

Q. How do I monitor for Cr(VI)?

A. Monitoring is accomplished with a pump and filter—not a badge-type monitor. Refer to NIOSH Method ID-215. Consult an American Industrial Hygiene Association (AIHA)-accredited laboratory for assistance in selecting the appropriate sampling and analytical method. To contact an AIHA-accredited laboratory or industrial hygienist to do the monitoring, go to www.aiha.organd select Consultants or Laboratories.

Q. When are respirators required?

A. Respirators are required in the following situations when exposure levels exceed the PEL:

  • While engineering and work practice controls are being developed.
  • During maintenance and repair activities for which engineering and work practice controls are not feasible.
  • When all feasible engineering and work practice controls are implemented and are still not sufficient to reduce exposures to or below the PEL.
  • When employees are exposed above the PEL for fewer than 30 days per year and the employer has not elected to implement engineering and work practice controls.
  • Emergencies.

Q. Which respirator should I use?

A. Respirators should be chosen by the employer based on workplace conditions and contaminant levels.

  • N95 filters may be used where no oil aerosols are present.
  • R or P95 filters may be used where oil aerosols are present.
  • Filtering-facepiece respirators, elastomeric half-facepiece respirators, and fullfacepiece respirators, when qualitatively fit-tested, may be used up to 10x PEL with appropriate filters.
  • Full-facepiece respirators may be used up to 50x PEL when they are quantitatively fit-tested and are equipped with appropriate filters.
  • Loose-fitting facepieces may be used up to 25x PEL
  • Tight-fitting full facepieces, hoods, and helmets with supplied-air or powered-air purifying respirators may be used up to 1,000x PEL.

Q. I have not had a respiratory protection program in the past. What information do I need to get started?

A. The standard requires the respiratory protection program, including respirator selection, to follow OSHA 1910.134 requirements.

For more information, visit www.3M.com/OccSafetyor www.hexchrome.com. Fabricators can call 800-243-4630.



The 3M Occupational Health and Environmental Safety Division


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