Working with Hexavalent Chromium (Chromium VI)

1. Working with Hexavalent Chromium (Chromium VI)

2. Meeting Training Requirements • Preview this program and include your specific workplace information before conducting the training. Modify, add, delete, or otherwise customize slides as needed for your workplace. • It is recommended that you keep an attendance roster for your records to document training.

3. How To Use This PowerPoint Program • Users with PowerPoint can download, edit, and use the program for training with a laptop and multimedia projector. • Additional information is also found in the Notes section of this presentation below the slides. You can read the text in quotations found in the Notes section or use your own words. • If you want to print out this program, the PDF file uses less computer memory and prints faster.

4. Occupational Exposure to Hexavalent Chromium(Chromium VI)

5. What This Training Will Cover • Characteristics of hexavalent chromium • Health hazards of hexavalent chromium • How you can be exposed to hexavalent chromium • Control of your hexavalent chromium exposure • Medical surveillance • OSHA rules on hexavalent chromium

6. Hexavalent Chromium Standard  Covers all occupational exposures to Hexavalent Chromium Exceptions • Agricultural operations • Exposures that occur in the application of pesticides • Exposures to portland cement • Objective data demonstrating that hexavalent chromium cannot be released in concentrations at or above 0.5 µg/m3 as an 8-hour time-weighted average (TWA8) under any condition of use

7. Permissible Exposure Limit (PEL) Exposure Determination Regulated areas* Methods of Compliance Respiratory Protection Protective Work Clothing and Equipment Hygiene Areas and Practices Housekeeping* Medical Surveillance Communication of Hazards Recordkeeping What Does the Standard Cover? *General industry only

8. What is Hexavalent Chromium? • Chromium VI or Cr(VI) • Toxic form of chromium metal, generally man-made • Used in many industrial applications, primarily for its anti-corrosive properties • Can be created during certain “hot” work processes (such as welding and grinding metals) where the original form of chromium was not hexavalent

9. Sources of Occupational Exposure

10. Chrome plating/Electroplating Welding or grinding on chrome-containing metals (stainless steel, galvanized steel), or Cr (VI) painted surfaces Painting Aerospace Auto body repair Chromate pigmentand chemical production Sources of Occupational Exposure Major operations/job tasks resulting in potential Cr(VI) exposure: Chrome Plating Bath (a significant source of Cr VI)

11. Chromium dye and catalyst production Glass manufacturing Plastic colorant production Construction Traffic painting Refractory brick restoration Paint removal from bridges Sources of Occupational Exposure Major operations/job tasks resulting in potential Cr(VI) exposure: (cont.) Bridgework

12. Routes of Exposure How Can Hexavalent Chromium Enter the Body? • 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)

13. Major Health Effects Due to Significant Overexposure • Lung cancer • Nasal septum ulcerations and perforations • Asthma Permanent perforation of the nasal septum from continuous exposure performing chrome plating of small appliance parts

14. Major Health Effects Due to Significant Overexposure • Skin ulcers • Allergic and irritant contact dermatitis “Chrome hole” on finger. Can also occur on hands or forearms, and on bottom surfaces of feet from chrome salts permeating through boots or shoes.

15. Chromium VI Exposure The following operations/work areas where you may be exposed to Cr(VI) are: • [List the operations/employee work areas where Cr(VI) is present.] • Welding or Grinding on Stainless Steel or Other Base Metals with High Chrome Content

16. Permissible Exposure Limit 5 µg/m3 TWA8 in the air Permissible Exposure Limit (PEL) 8-hour time-weighted average exposure limit (TWA8) 2.5 µg/m3 TWA8 in the air Action Level (AL) 0.5 of PEL

17. Exposure Determination • Scheduled monitoring method • Performance-oriented monitoring method Two options for determining employee exposures:

18. Exposure Determination • Scheduled Monitoring

19. Exposure Determination • A list of “variables” to consider while collecting air • monitoring samples during welding and grinding • operations includes: • Actual time spent welding • (i.e., 2 hours, 3.5 hours, 45 minutes, etc.) • The item involved in the weld • (i.e., rectangular duct, tank, piping, etc.) • The size of the item / piece involved in the process • Size of the welding room / booth / space • Description of general / natural ventilation in the area • (the number of air changes) • Description of point of operation ventilation in the area • Ambient temperature and relative humidity • Workers head/face orientation to point of operation

20. Exposure Determination • A list of “variables” to consider while collecting air • monitoring samples during welding and grinding • operations includes: • Type of welding being conducted, for example: Shielded • Metal Arc Welding (SMAW), Gas Tungsten Arc Welding • (GTAW), Gas Metal Arc Welding (GMAW) • Is a shielding gas used? If so, what type • (i.e., argon, helium, etc.) • Type of base metal • (i.e., stainless steel, mild steel, galvanized steel, etc.) • Reported ingredients of the base metal • (i.e., x% chrome, x% nickel, x% iron, etc.) • Thickness of the base metal (i.e., 18 ga., 10 ga., etc.) • Type of welding electrode / rod / wire • Type of personal protective equipment worn by the welder • (i.e., respirator, helmet, gloves, etc.)

21. Exposure Determination • Performance-oriented Monitoring • Exposures determined using any combination of air monitoring data, historical monitoring data, or objective data sufficient to accurately characterize employee exposure to Cr(VI) • No fixed schedule for performing periodic monitoring • May be difficult to match air monitoring results due to the many variables involved

22. Exposure Determination General Requirements • Affected employees must be notified when 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

23. Notification of Results When exposure determination results are above the TWA8 permissible exposure limit (PEL), [insert your company’s name] must provide written notification of all the following within [15 or 5; see notes] business days: • Provide results of exposure determination • Describe corrective actions being taken to reduce exposure to or below the PEL

24. Exposure Determination These are the results of our employee exposure determination using [state which option/method you used]: [List results here.]

25. Regulated Areas Areas where exposures exceed or can be reasonably expected to exceed the PEL • Regulated Areas for General Industry only (not Construction) • Regulated areas are clearly marked • Access is limited to • authorized persons required by work duties to be there • designated representatives of employees for the purpose of observing monitoring procedures • persons authorized by OSHA or other regulations to be there

26. Regulated Areas These are the Regulated Areas at [insert your company’s name]: • [List all areas and specific locations] • [Describe policies/procedures for entering and exiting regulated areas]

27. Methods of Compliance • Establish engineering and work practice controls as the primary means of achieving the PEL/reducing exposures. • 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 Exceptions:

28. Methods of Compliance • Tasks or operations that do not result in exposures above the PEL for 30 or more days per year: • Use of respirators alone is allowed to achieve the PEL • Prohibit job rotation to achieve compliance with the PEL

29. Control Measures to Reduce Exposures We use the following controls to reduce the amount of chromium VI you are exposed to: • [List controls here]

30. Required Work Practices We follow these work practices: • [List worksite-specific work practices that reduce or control exposures here.]

31. Respiratory Protection When will you need a respirator? • Periods necessary to install or implement feasible engineering and work practice controls • Maintenance or repair operations where engineering and work practice controls are not feasible • 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 and the employer has elected not to implement engineering and work practice controls to achieve the PEL • Emergencies

32. Respiratory Protection When respirator use is required, a respirator program will be followed that meets the appropriate OSHA or state-OSHA respiratory protection standards.

33. Type of Respirator You Will Use [List or describe what respirators must be used under what conditions, job tasks, or locations here]

34. Personal Protective Equipment (PPE) Protective Work Clothing and Equipment • Use where a hazard is present or is likely to be present from skin or eye contact with Cr(VI) • Remove all PPE and equipment when work shift or task is completed [Insert your company’s name] will provide your PPE at no cost.

35. Personal Protective Equipment (PPE) Protective Work Clothing and Equipment (cont.) • Do not remove Cr(VI) from PPE by blowing, shaking, or any other means that disperses into the air or onto the body • Do not remove contaminated PPE from the workplace, except for laundering, disposal, etc. by employees with such job duties • Clean and replace Cr(VI)-contaminated clothing and equipment as needed

36. Personal Protective Equipment (PPE) Laundering and Cleaning of PPE • Store and transport contaminated PPE in sealed, impermeable bags or closed containers. Make sure they are properly labeled. • Inform any person who launders/cleans PPE of the potentially harmful effects of Cr(VI) exposure • When laundering: – Minimize skin or eye contact with Cr(VI) – Prevent the release of airborne levels in excess of the PEL

37. Hygiene Areas and Practices When employee exposure is at/above the PEL: • Change rooms – separate storage facilities for PPE and street clothes • Washing facilities Wash hands and face: • at the end of the work shift • prior to eating, drinking, smoking, chewing tobacco or gum, applying cosmetics, or using the toilet Use these facilities when necessary!

38. Hygiene Areas and Practices (cont.) • Eating and Drinking Areas and Surfaces – maintained as free as practicable of Cr(VI) DO NOT: • Enter eating and drinking areas with PPE • Eat, drink, smoke, chew tobacco or gum, or apply cosmetics in areas where skin or eye contact with Cr(VI) occurs • Carry or store the products associated with the above activities in areas where skin or eye contact with Cr(VI) occurs

39. Housekeeping • Keep all surfaces as free as practicable of accumulations of Cr(VI) • Promptly clean up all spills and releases of Cr(VI)-containing materials • Use HEPA vacuums or other methods that minimize exposure to Cr(VI) • Dispose of Cr(VI)-contaminated waste in labeled, impermeable bags/containers

40. Medical Surveillance Which Employees Must Be Provided Medical Surveillance? • 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

41. Medical Surveillance (cont.) • 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

42. Medical Surveillance (cont.) • Determine if an individual can be exposed to the Cr(VI) present in their workplace without experiencing adverse health effects • Identify 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

43. Medical Examinations • Medical and work history • 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

44. Medical Examinations • 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

45. Information Provided to PLCHP • Copy of the Federal OSHA (or state plan OSHA) Hexavalent Chromium standard • Description of employee's former, current, and anticipated duties related to occupational exposure to Cr(VI) • Employee's former, current, and anticipated levels of occupational exposure to Cr(VI) • Description of any PPE used or to be used by the employee • Information from records of previous employment-related medical examinations

46. PLHCP's Written Medical Opinion • Provided to [insert your company name] by PLHCP within thirty days • Specific findings or diagnoses unrelated to occupational exposure to Cr(VI) not revealed • We must provide a copy of the PLHCP's written medical opinion to you within two weeks after receiving it

47. Worksite Medical Surveillance Program [Describe details of worksite specific medical surveillance program here.]

48. Records Medical and Air Monitoring Records You have the right to see any of your medical records related to Cr(VI). You also have the right to see results of any air sampling we have done, or other exposure data we have used.

49. Hexavalent Chromium Regulations • Federal OSHA Standard for Hexavalent Chromium are: • General Industry – 1910.1026 • Construction – 1926.1126 • Maritime – 1915.1026 • State OSHA Programs will have different standards