Hexavalent Chromium

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Hexavalent Chromium New OSHA Standard

• Informational
• Web Cast

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Presented by MSA

• John Hierbaum
• Product Line Manager
• Air Purifying Respirators
• Meghan Swanson
• Staff Chemist

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WELCOME

• Thank You for joining us today

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CAUTION!

• This presentation is an overview of the new
  standard
• This presentation does not represent the complete
  standard as published by OSHA
• It is important that all participants review the
  entire standard before implementing a program
  within the workplace

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AGENDA

• Timetable for the new Hexavalent Chromium
  Standard
• Workers most notably affected
• What is Hexavalent Chromium?
• What are its health hazards?
• Elements of the New Standard
• Steps to comply with the new standard
• Q A

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New OSHA StandardHexavalent Chromium

• Covers
• General Industry - 1910.1026
• Shipyards - 1915.1026
• Construction - 1926.1126
• Most requirements are generally the same for all
  industries

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Exceptions to the New Standard

• Does not impact application of some pesticides
  (EPA regulated)
• Does not impact exposures to portland cement
• Does not impact situations in which the employer
  has objective data demonstrating that a material
  containing chromium or specific operation or
  activity cannot release Cr (VI) in concentrations
  at or above 0.5 µg/m3 as an 8 hour TWA

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Significant Dates to Remember

• February 28, 2006 - OSHA published the new
  standard
• May 30, 2006 Effective date
• Enforced 180 days from the effective date with
  exceptions
• Nov 27, 2006 20 or more employees
• May 31, 2007 less than 20 employees
• May 31, 2010 - engineering control requirements

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What Activities are the Sources of Chromium (VI)?

• Welding and cutting of stainless steel and other
  chromium containing metals
• Heavy Painting and coating
• Electroplating
• Handling of chrome based pigments

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How Many Workers are Exposed?

• About 558,000 workers are exposed to Cr(VI)
• Several workers will be required to use
  respiratory protection
• Welders represent the highest single worker group
  exposed

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WHAT IS HEXAVALENT CHROMIUM?
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Cr(VI)

• Hexavalent chromium (Cr(VI)) compounds exist in
  several forms, known as chromates
• Typically particulates
• Yellow, orange, or red in color
• Trivalent chromium (Cr(III)) is the most stable
  state naturally occuring
• Cr(VI) is less chemically stable most compounds
  are man made

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Chromates have Varying Solubilities

• Highly soluble in water
• Sodium dichromate
• Chromic acid
• Slightly soluble in water
• Calcium chromate
• Strontium chromate
• Zinc chromate
• Insoluble in water
• Lead chromate
• Barium chromate

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Exposure Routes

• Inhalation
• Particulates, such as
• Paint spray
• Welding fumes
• Chromate dust
• Skin exposure

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Health Effects

• Respiratory
• Lung cancer
• Damage to nasal membranes
• Asthma
• Dermal
• Skin damage
• Internal organs
• Kidney
• Liver

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Carcinogenic Effects Lung Cancer

• Cells uptake Cr(VI)
• Faster for soluble forms of Cr(VI)
• Insoluble chromates concentrate
• Particles lt 10 µm contact target cells
• Cells react with Cr(VI) to form Cr(III) and toxic
  byproducts, Reactive Oxygen Species
• DNA is damaged
• Cell replication disturbed

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Other Respiratory Effects

• Nasal Irritation
• Nasal Ulcerations
• Nasal Septum Perforations
• Asthma
• Cr(VI) is an airway sensitizer
• Exposure prompts immune response
• Bronchitis

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Additional Health Effects

• Dermal
• Contact dermititis
• Skin ulcers
• Internal
• Gastrointestinal ulcers
• Kidney disease
• Liver damage

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Summary of Health Issues

• Major health effects
• Lung cancer
• Damage to nasal passages
• Skin rashes and ulcers
• A high of workers exposed can get lung cancer
• This standard is intended to reduce these health
  risks

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Major Elements of the New Standard

• Permissible Exposure Level
• Exposure Determination
• Engineering Controls
• Personal Protection
• Medical Surveillance
• Worker Education and communication

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Permissible Exposure

• PEL
• Reduced from 52 micrograms of Cr(VI) per cubic
  meter of air as an eight-hour time weighted
  average (TWA) to 5 µg/m3
• This cannot be achieved by rotation of employees
• Note OSHA originally wanted to reduce the PEL
  to 1 µg/m3
• Draft standard
• Action Level
• 2.5 micrograms per cubic meter of air

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Exposure Determination

• Employer has 2 choices
• Scheduled monitoring
• Performance oriented
• Must determine the 8-hour TWA exposure for each
  employee

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Scheduled Monitoring

• Initial monitoring
• Sufficient of samples
• Full-shift exposure
• All job classifications
• Follow-up monitoring
• None if below action level
• 6 months if above action level
• 3 months if above PEL

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Monitoring Guidelines

• If employee exposure exceeds PEL
• Employer must notify employee within 15 days
• Post information
• Written notification
• Accuracy of measuring equipment
• /- 25
• Confidence level of 95
• Employees can observe monitoring
• Employer to provide personal protection

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Performance Oriented Option

• Air monitoring data
• Historical monitoring data
• Objective data
• If employee exposure exceeds PEL
• Employer must notify employee within 15 days
• Post information
• Written notification

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Engineering Controls

• Engineering controls mandatory with exceptions
• Effective date
• May 31, 2010
• Shall reduce the exposure below the PEL
• If not feasible, respiratory protection must be
  used

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Exceptions to Eng. Controls

• 1 - Aerospace
• Painting large aircraft
• Must reduce exposure below 25 micrograms
• Unless not feasible
• Supplement with proper respiratory protection
• 2 - Employee is not exposed above PEL for 30 or
  more days per year

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PPE

• Respiratory Protection
• To comply, one can use a traditional half-mask
  NIOSH approved respirator with N-95 filters. For
  maximum protection however, MSA recommends a
  P-100 filter with a full facepiece.
• Respiratory program must be in accordance with 29
  CFR 1910.134
• A copy of this is available on the MSA web site

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Other PPE

• Work clothing
• Provided by employer where necessary
• No cost to employee
• Employer must ensure it is used
• Must be cleaned properly, taking precautions to
  prevent contamination of other employees

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Medical Surveillance

• Employer to offer free of charge
• All employees who may be exposed above the action
  level for 30 or more days per year
• Employees showing signs of exposure
• Employees exposed in an emergency

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Medical Surveillance Frequency

• Within 30 days of initial assignment, unless
  employee had Cr(VI) exam within last 12 months
• Annually
• Within 30 days of PLHCPs recommendation for
  further exam
• If employee shows signs or symptoms
• Within 30 days of emergency exposure
• At termination, unless last exam was within 6
  months
• Exam must include medical work history, history
  of respiratory problems, other specific problems
  (listed in rule)

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Medical Surveillance

• Employer must provide to PLHCP copy of this
  standard, a description of employees duties,
  employees exposure level to CrVI, description of
  PPE and how long used by employee, information on
  previous employee medical exams
• PLHCPs written medical opinion furnished within
  30 days of exam, any detected medical condition
  which affects work, employee limitations on work
  and PPE usage, statement that the PLHCP has
  explained results to employee
• Employer must provide exam info in writing to
  employee within 2 weeks of exam

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Employee Education and Communication

• Employer must provide a copy of the standard to
  the employee
• Employer must insure employee can demonstrate
  knowledge of
• The contents of this rule
• The purpose and description of medical
  surveillance

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Recordkeeping

• Employer must keep records of
• Air monitoring data
• Historical monitoring data
• Objective data
• Medical surveillance

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Methods of Compliance

• Respiratory Protection
• Half-Mask
• Full Facepiece
• PAPR
• Air-Line Respirator
• Exposure determination
• Sampling Equipment

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Advantage 200 LS Respirators

• Any NIOSH approved filter
• P-100 (as shown) is best
• Can use up to 10X the PEL

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Advantage 3000 Respirator

• Full-Face Respirator
• Any NIOSH approved filter
• Can use up to 50X the PEL

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Powered Respirator (PAPR)

• Used with full-face respirator
• High Efficiency P-100 filter
• Can use up to 50X the PEL

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Air Line Respirators

• Constant- Flow
• Positive Pressure
• No filter required
• Can be used up to 2000X the PEL
• You cannot exceed the maximum use concentration.

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Monitoring

• To test exposure use an MSA Escort Elf Sampling
  Pump
• The procedure for hexavalent chromium calls for
  particle collection using a 37-mm, 5-µm pore size
  PVC filter.

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QUESTIONS?

• Thanks for attending!