Transcript Hexavalent chromium – 2

Update:
Hexavalent Chromium Cr(VI)
Drawn from the
Preambles and Training
Materials from the
National Office and
Regions 5 and 6
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.
What is Hexavalent
Chromium?
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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
Is Chrome a Carcinogen or
Necessary Element?
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Chrome III is an essential nutrient for
maintaining blood glucose levels
Chrome VI is classified as a known
human carcinogen
Operations with Cr(VI) Exposure
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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
Routes of Exposure
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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)
Major Health Effects
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Lung cancer
Nasal septum
ulcerations and
perforations
Asthma
Skin ulcers
Allergic and irritant
contact dermatitis
History of Exposure Limits
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1943 ANSI standard was the source of
OSHA’s 1971 standard of 1mg/10 m3 Cr(III)
or 52 µg/m3 CR(VI)
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Mounting evidence of carcinogenicity
 1974 by ACGIH
 1975 by NIOSH
 1984 by EPA
 1990 by IARC
Occupational Exposure Limits
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NIOSH REL
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0.001 mg Cr VI/M3 10-hr TWA
ACGIH TLV
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Water-Soluble Cr VI compounds as Cr
0.05 mg/M3 TWA
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Insoluble Cr VI compounds as Cr
0.01 mg/M3 TWA
ACGIH BEI
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Total chromium in urine BEIs (2) for Chrome VI water
soluble fume
History of New Standard
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In 1993 the Health Research Group petitioned for
ETS of 0.5 µg/m3
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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
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Proposed rule to be issued 10/4/04
Final rule to be issued 1/18/06
Final rule was issued 2/28/06
Steps to Complete a Rule
1.
2.
3.
4.
5.
6.
7.
8.
9.
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
Case Law for Health Standards
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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 **
Greater Risk Than Asbestos
At the new technologically and economically
feasible PEL, the cancer risk from Cr(VI) is
higher than other regulated carcinogens
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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
2/28/06 FR p. 10225
Three Cr(VI) Standards
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1910.1026 General Industry
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1926.1126
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1915.1026 Shipyards
Construction
Major Provisions of the Standards
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Scope
Permissible Exposure
Limit (PEL)
Exposure Determination
Regulated areas*
Methods of Compliance
Respiratory Protection
Protective Work Clothing
and Equipment
*General industry only
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Hygiene Areas and
Practices
Housekeeping*
Medical Surveillance
Communication of
Hazards
Recordkeeping
Dates
Scope: Who is Covered
by the Standard?
All occupational exposures to Cr(VI) compounds
except:
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Exposures that occur in the application of
pesticides
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Application is already covered by EPA Standards
The manufacture of pesticides and handling of
pesticide treated materials are covered under new
OSHA standard
Scope: Who is Covered
by the Standard?
All occupational exposures to Cr(VI) compounds
except:
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Exposures that occur in the application of
pesticides
Exposures to portland cement
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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
Scope: Who is Covered
by the Standard?
All occupational exposures to Cr(VI) compounds
except:
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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
Permissible Exposure Limit (PEL)
and Action Level (AL)
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PEL: 5 µg/m3 - TWA
AL: 2.5 µg/m3 - TWA
Exposure Determination
Two options allowed for determining
employee exposures:
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Scheduled monitoring option
Performance-oriented option
Scheduled Monitoring Option
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Prescribes a schedule for
performing initial and periodic
personal monitoring
If initial monitoring indicates
exposures are:
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Below the AL: monitoring can
be discontinued
At or above the AL: monitor
every 6 months
Above the PEL: monitor every 3
months
Performance-Oriented Option
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Exposures characterized using any
combination of air monitoring data,
historical monitoring data or objective
data
No fixed schedule for performing
periodic monitoring
General Requirements
for Exposure Determination
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Affected employees must be notified
where exposures exceed the PEL
General Requirements
for Exposure Determination
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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]
General Requirements
for Exposure Determination
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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
Regulated Areas
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For general industry employers only
Regulated Areas
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For general industry employers only
Areas where exposures exceed or
can be reasonably expected to
exceed the PEL
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Must be demarcated from other areas
Must limit access to employees who
have a need to be there
Methods of Compliance
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Establishes engineering and work practice
controls as the primary means of achieving the
PEL
Methods of Compliance
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Establishes engineering and work practice
controls as the primary means of achieving the
PEL
 Exceptions:
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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
Methods of Compliance
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Establishes engineering and work practice
controls as the primary means of achieving the
PEL
 Exceptions:
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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
Respiratory Protection Required
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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
Assigned Protection Factors
Final Rule August 24, 2006
Type of Respirator1,2
Half Mask
Full
Facepiece
Helmet/
Hood
LooseFitting
1. Air-Purifying Respirator
103
50
—
—
2. Powered Air-Purifying Respirator
(PAPR)
50
1,000
25/1,0004
25
3. Supplied-Air Respirator (SAR) or
Airline Respirator
• Demand mode
• Continuous flow mode
• Pressure-demand or other positivepressure mode
10
50
50
50
1,000
1,000
—
25/1,0004
—
—
25
—
4. Self-Contained Breathing Apparatus
(SCBA)
• Demand mode
• Pressure-demand or other positivepressure mode (e.g., open/closed circuit)
10
—
50
10,000
50
10,000
—
—
Protective Work Clothing
and Equipment
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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
Hygiene Areas and
Practices
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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
Housekeeping
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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:
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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
Medical Surveillance
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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
Purpose of Medical Surveillance
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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
Which Employees Must Be
Provided Medical Surveillance?
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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
Medical Examination
Requirements
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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
When Must Medical
Examinations Be Offered?
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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
Communication of Hazards
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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
Recordkeeping
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No requirement to maintain training records
Must maintain records per 29 CFR
1910.1020 for:
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Air monitoring data
Historical monitoring data
Objective data
Medical surveillance information, including:
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PLHCP’s written opinions
Information provided to the PLHCP
Compliance Start-Up Dates
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Effective date: May 30, 2006
Start-up dates:
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All provisions except engineering
controls
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For employers with 19 or fewer
employees: May 30, 2007
For all others: November 27, 2006
Engineering Controls
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For all employers: May 31, 2010
Hexavalent Chromium
Some practical issues
FR Preamble: Exposure Ranges
Task
1-5 µg/m3
Above PEL
Electroplating
11%
13%
GI
13%
31%
Const
15%
27%
GI & Const
12%
6%
GI
3%
17%
Const
16%
7%
Stainless Steel
GI
25%
7%
Carbon Steel
GI
0.5%
7%
Iron & SteelFoundries
GI
15%
5%
Woodworking
GI
0%
14%
Const
22%
11%
Welding
Stainless Steel
Carbon Steel
Painting
Steel Mills
OSHA Internal Training on
Hexavalent Chromium Sampling
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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
Cr VI SLTC Analysis OSHA ID215
as of 6/2006
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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
Interferences –
Welding Fume Sampling
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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
Interferences –
Plating Sampling
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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
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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
Filter Blanks
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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
Other Sampling Methods
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1% NaOH coated binderless quartz fiber filter wipe
sample method is available
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A colorimetric wipe test will be available soon. You
will be able to perform wipe tests in lunchrooms,
etc., and demonstrate evidence of contamination
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New sampling method is under review: OSHA
analytical method ID215 may be updated to use
buffer solution in the field