HI~ CHROME Hex-Chrome Regs and the Operational, Economical Impact on Metal Finishers OSHA rule puts spotlight on worker exposure monitoring. Presented by the Policy Group, Washington, D.C. G et test data--you have to know where you are. This stern advisory came from Jeff Hannapel, vice presi- dent of Navista, speaking on behalf of the Policy Group during a special session held at SUR/FIN. Hannapel's presentation provided the latest information regarding hexa- valent chromium PELs as they relate to metal finishers, offering critical information relative to four areas: key provi- sions of OSHA's final rule for hexavalent chromium; the impacts on the industry; OSHA's rationale behind the ruling; and an outlook/strategy. Following are excerpts from that session: Key provisions of OSHA's final rule for hexavalent chromium: Successfully raised proposed PEL of 1.0 to 5.0 }Jg/m3; action level of 2.5 ~g/m3; exemption for operations under 0.5 l~g/m3 and exemption for exposures of less than 30 calendar days a year; secured four years to implement engineering controls (May 31, 2010); and respirators need- ed until engineering controls are implemented-- if employees exposed at levels greater than 5 pg/m 3. Regarding compliance deadlines, facilities with 20 or more employees have until Nov. 27, 2006, while facilities with fewer than 20 employees have until May 30, 2007, to comply. This essentially entails exposure monitoring, medical surveillance, personal protective equipment, housekeeping, hygiene practices and change rooms, train- ing and hazard communication, and recordkeeping. According to the final rule, the following surface finish- ing operations are impacted: hard chrome plating; decora- tive chrome plating; chromic acid anodizing; chromate conversion coatings (e.g., Zn, Cd and A1); plating on plas- tics; passivation; maintenance and welding; and chemical mixing and blending. OSHA also identified nickel risks in its final rulemaking as factor in elevated workplace can- cer risks in combination with chromium (See Table II). "Keeping exposure data is essential," Hannapel said. "When it was 52, you didn't need to do testing; you knew where you were." Hannapel said the new limits can be reached via engineering controls and work practices. This entails the installation, upgrade and maintenance of LEV systems; facility air-flow evaluation; parts transfer and rins- ing practices; fume suppression and surface tension man- agement; chemical bath circulation technology (e.g., educ- tors); and liquid chemical additions in lieu of dry. "Finishers have reduced their exposures by following the guidelines," Hannapel noted. In fact, many finishers are already on the path, according Table I Table II to Joelie Zak, who co-chaired the session. As vice president of Scientific Control Labs, Chicago, she has seen a lot of review of data on exposures. '~[he data we received from finishers shows the majority are coming in below 2.5," she said, citing differences in methodoligies (specifically, how older methods did not detect lower PEL). "However, there are many that are above [those limits]. Hard-chrome platers, in particular, are struggling." TECHNOLOGICAL FEASIBILITY: SELECTED OSHA ARGUMENTS Improved Maintenance: "Some firms may not need to upgrade their local exhaust systems, but must ensure that their current exhaust systems are working according to design specification." Remedy operating deficiencies: "...none of the [hard 48 www.metalfinishing.com
Transcript
H I ~ CHROME
Hex-Chrome Regs and the Operational, Economical Impact on Metal Finishers OSHA rule puts spotlight on worker exposure monitoring. Presented by the Policy Group, Washington, D.C.
G et test data--you have to know where you are. This stern advisory came from Jeff Hannapel, vice presi- dent of Navista, speaking on behalf of the Policy
Group during a special session held at SUR/FIN. Hannapel's presentation provided the latest information regarding hexa- valent chromium PELs as they relate to metal finishers, offering critical information relative to four areas: key provi- sions of OSHA's final rule for hexavalent chromium; the impacts on the industry; OSHA's rationale behind the ruling; and an outlook/strategy.
Following are excerpts from that session: Key provisions of OSHA's final rule for hexavalent
chromium: Successfully raised proposed PEL of 1.0 to 5.0 }Jg/m3; action level of 2.5 ~g/m3; exemption for operations under 0.5 l~g/m 3 and exemption for exposures of less than 30 calendar days a year; secured four years to implement engineering controls (May 31, 2010); and respirators need- ed until engineering controls are implemented- - if employees exposed at levels greater than 5 pg/m 3.
Regarding compliance deadlines, facilities with 20 or more employees have until Nov. 27, 2006, while facilities with fewer than 20 employees have until May 30, 2007, to comply. This essential ly entails exposure monitoring, medical surveillance, personal protective equipment, housekeeping, hygiene practices and change rooms, train- ing and hazard communication, and recordkeeping.
According to the final rule, the following surface finish- ing operations are impacted: hard chrome plating; decora- tive chrome plating; chromic acid anodizing; chromate conversion coatings (e.g., Zn, Cd and A1); plating on plas- tics; passivation; maintenance and welding; and chemical mixing and blending. OSHA also identified nickel risks in its final rulemaking as factor in elevated workplace can- cer risks in combination with chromium (See Table II).
"Keeping exposure data is essential," Hannapel said. "When it was 52, you didn't need to do testing; you knew where you were." Hannapel said the new limits can be reached via engineering controls and work practices. This entails the installation, upgrade and maintenance of LEV systems; facility air-flow evaluation; parts transfer and rins- ing practices; fume suppression and surface tension man- agement; chemical bath circulation technology (e.g., educ- tors); and liquid chemical additions in lieu of dry. "Finishers have reduced their exposures by following the guidelines," Hannapel noted.
In fact, many finishers are already on the path, according
Table I
Table II
to Joelie Zak, who co-chaired the session. As vice president of Scientific Control Labs, Chicago, she has seen a lot of review of data on exposures. '~[he data we received from finishers shows the majority are coming in below 2.5," she said, citing differences in methodoligies (specifically, how older methods did not detect lower PEL). "However, there are many that are above [those limits]. Hard-chrome platers, in particular, are struggling."
T E C H N O L O G I C A L F E A S I B I L I T Y : S E L E C T E D O S H A A R G U M E N T S Improved Maintenance: "Some firms may not need to upgrade their local exhaust systems, but must ensure that their current exhaust systems are working according to design specification."
R e m e d y operating deficiencies: "...none of the [hard
48 www.metalfinishing.com
HE)( CHROME
Table III
Table IV
chrome] systems inspected...were oper- a t ing at the designed capabilities. Many had disconnected supply lines or holes in the hoods and were working at 40 percent of their design capabilities."
E v e n def ic ient s y s t e m s are b e l o w 5.0 PEL: "Even with these deficiencies in engi- neering controls, more than 75% of [hard chrome] workers are below 5 Dg]m3. "
E C O N O M I C FEASIBILITY. O S H A ' S A R G U M E N T S S U P P O R T I N G PEL OF 5.O I~/m s • OSHA's est imated compliance cost at
PEL of 1.0 ug/m 3, for average facility: 2.7% of firm's revenue vs. OSHA "benchmark" of 2% (See Table VI). Note: Proposed PEL of 1.0 lJg/m 3 would force more than hal f the indus- try to close.)
• 65% of firm's profits vs. OSHA "benchmark" of 10%
• OSHA conclusion: A PEL of 1.0 pg/m 3 is not economically feasible, because it would "adversely alter the competi- tive s t ruc ture of the e lectroplat ing industry."
Table V
S T R A T E G I C A P P R O A C H Litigation: Challenge and defend PEL of 5 pg/m a. "We're backing out of litigation, al though Public Citizen will go forward," Hannapel reported. (See "OSHA Chrome PEL Rule" story on page 46.)
Technical/regulatory activities: se t t lement discussions with OSHA; industry protocol for exposure data; and reg- u la tory clarifications. "Steel, electrical, util i t ies and nuclear industr ies entered into se t t lement discussions with OSHA, and they were successful," Hannapel said.
• Patented energy recovery vestibules • Patented ceiling plenum used reduce air
velocities and temperature stratification. • Room lighting is flush with the room
ceiling to minimize powder build up. • System monitors the environmental
room via computer to run maintenance checks and help regulate the temperature and humidity.
• Algorithms control humidification, dehumidification, air flow, cooling & heat
ing functions automatically. • Pleated pre-filter in conjunction with a four (4) stage extended
surface cube filter as a final filter removes 100% of particles 2 microns or larger.
Circle 058 on reader information card or go to www.metalfinishing.com/advertisers
HEX CHROME
Table Vl Summary of settlement discussions: • Rel ief from resp i ra to ry protect ion requ i rements dur ing
30-month implemen ta t ion period; • Thresholds for r e sp i ra to r relief; • Cont inued use of resp i ra to r s for discreet activit ies; • Compliance p lans for reducing exposures; • In t e rp re t a t ion le t te r wi th regu la tory clarifications; • Make "Opt-in" option avai lable to SFIC members ; • Terms of se t t l emen t to be enforceable; • SFIC withdraws from litigation as petit ioner & intervenor
{
=
Polypropylene Exhaust Hood "Fa~o ly Mutua lApproved H PVC
_KCH
Energy Efficient Exhaust Fan
IP Spectra Chrome Mist Eliminator
E N G I N E E R E D S Y S T E M S
144 Industrial Drive Forest City North Caroli.a Phone: 828-245-9836 Fax: 828-245-1437 E-maih [email protected] www.kchservices.com
Fume Scrubber
Corrosion Resistant Ventilation Systems PVC & CPVC, Poly-Pro and FRP Ventilation Systems
Circle 057 on reader information card or go to veJwv.matalfinishing.com/advertisers
Rat ionale for se t t lement : • Use of r e s p i r a t o r s is bu rdensome , expens ive and not
protective; • Difficult to get PEL higher t han 5 pg/m 3; • F inanc ia l considerat ions; • Most facil i t ies can reduce below 5 pg/m 3; • Revisions to PEL m a n d a t e d by court can be addressed
in ru l emak ing
Jef f Hannapel has more than 20 years experience in envi- ronmental regulatory issues and has advised industry and government clients on numerous regulatory, compliance, legislative, and enforcement matters. He has practiced environmental law at several Washington, D.C., law firms. Prior to his current position, he worked for the U.S. Environmental Protection Agency in the Office of Solid Waste on waste and recycling issues. He has a B.S. in Biology from the University of Notre Dame; a J.D. from the Georgetown University; and an M.S.L. in Environmental Law from the Vermont Law School. He can be reached by contacting The Policy Group at 1155 15th Street, N.W., Suite 500, Washington, D.C., 20005; via phone, 202-457- 0630; or by e-mail at jhannapelthepolicygroup.com
Need OSHA Hexavatent Chromium Air Testing? New Air Test Kits Avai[ab[e
Full Service Laboratory, Consultation ~ Engineering Services
