Hexavalent Chromium Hexavalent Chromium “New OSHA Standard”“New OSHA Standard”

Informational Informational

Web CastWeb Cast

Presented by MSAPresented by MSAJohn HierbaumJohn Hierbaum

Product Line ManagerProduct Line ManagerAir Purifying RespiratorsAir Purifying Respirators

&&Meghan SwansonMeghan Swanson

Staff ChemistStaff Chemist

WELCOMEWELCOME

Thank You for joining us todayThank You for joining us today

CAUTION!CAUTION!

This presentation is an overview of This presentation is an overview of the new standard the new standard

This presentation does not represent This presentation does not represent the complete standard as published the complete standard as published by OSHAby OSHA

It is important that all participants It is important that all participants review the entire standard before review the entire standard before implementing a program within the implementing a program within the workplaceworkplace

AGENDAAGENDA

Timetable for the new Hexavalent Timetable for the new Hexavalent Chromium StandardChromium Standard

Workers most notably affectedWorkers most notably affected What is Hexavalent Chromium?What is Hexavalent Chromium?

• What are its health hazards?What are its health hazards? Elements of the New StandardElements of the New Standard Steps to comply with the new standardSteps to comply with the new standard Q & AQ & A

New OSHA StandardNew OSHA StandardHexavalent ChromiumHexavalent Chromium

CoversCovers• General Industry - 1910.1026General Industry - 1910.1026• Shipyards - 1915.1026Shipyards - 1915.1026• Construction - 1926.1126Construction - 1926.1126

Most requirements are generally the Most requirements are generally the same for all industriessame for all industries

Exceptions to the New StandardExceptions to the New Standard

Does not impact application of some Does not impact application of some pesticides (EPA regulated)pesticides (EPA regulated)

Does not impact exposures to portland Does not impact exposures to portland cementcement

Does not impact situations in which the Does not impact situations in which the employer has objective data employer has objective data demonstrating that a material containing demonstrating that a material containing chromium or specific operation or activity chromium or specific operation or activity cannot release Cr (VI) in concentrations at cannot release Cr (VI) in concentrations at or above 0.5 µg/mor above 0.5 µg/m33 as an 8 hour TWA as an 8 hour TWA

Significant Dates to RememberSignificant Dates to Remember

February 28, 2006 - OSHA published February 28, 2006 - OSHA published the new standardthe new standard

May 30, 2006 – Effective dateMay 30, 2006 – Effective date Enforced 180 days from the effective Enforced 180 days from the effective

date with exceptionsdate with exceptions• Nov 27, 2006 – 20 or more employeesNov 27, 2006 – 20 or more employees• May 31, 2007 – less than 20 employeesMay 31, 2007 – less than 20 employees• May 31, 2010 - engineering control May 31, 2010 - engineering control

requirementsrequirements

What Activities are the SourcesWhat Activities are the Sources of Chromium (VI)? of Chromium (VI)?

Welding and cutting of stainless steel Welding and cutting of stainless steel and other chromium containing and other chromium containing metals metals

Heavy Painting and coatingHeavy Painting and coating ElectroplatingElectroplating Handling of chrome based pigmentsHandling of chrome based pigments

How Many Workers are Exposed?How Many Workers are Exposed?

About 558,000 workers are exposed About 558,000 workers are exposed to Cr(VI)to Cr(VI)

Several workers will be required to Several workers will be required to use respiratory protectionuse respiratory protection

Welders represent the highest single Welders represent the highest single worker group exposedworker group exposed

WHAT IS WHAT IS HEXAVALENT HEXAVALENT CHROMIUM?CHROMIUM?

Cr(VI)Cr(VI)

Hexavalent chromium (Cr(VI)) Hexavalent chromium (Cr(VI)) compounds exist in several forms, compounds exist in several forms, known as chromatesknown as chromates• Typically particulates Typically particulates • Yellow, orange, or red in colorYellow, orange, or red in color

Trivalent chromium (Cr(III)) is the Trivalent chromium (Cr(III)) is the most stable state; naturally occuringmost stable state; naturally occuring

Cr(VI) is less chemically stable; most Cr(VI) is less chemically stable; most compounds are man madecompounds are man made

Chromates have Varying Chromates have Varying SolubilitiesSolubilities

Highly soluble in water:Highly soluble in water:• Sodium dichromateSodium dichromate• Chromic acidChromic acid

Slightly soluble in water:Slightly soluble in water:• Calcium chromateCalcium chromate• Strontium chromateStrontium chromate• Zinc chromateZinc chromate

Insoluble in water:Insoluble in water:• Lead chromateLead chromate• Barium chromateBarium chromate

Exposure RoutesExposure Routes

InhalationInhalation• Particulates, such as:Particulates, such as:• Paint sprayPaint spray• Welding fumesWelding fumes• Chromate dustChromate dust

Skin exposureSkin exposure

Health EffectsHealth Effects

RespiratoryRespiratory• Lung cancerLung cancer• Damage to nasal membranes Damage to nasal membranes • AsthmaAsthma

DermalDermal• Skin damageSkin damage

Internal organsInternal organs• KidneyKidney• LiverLiver

Carcinogenic Effects: Lung CancerCarcinogenic Effects: Lung Cancer

1.1. Cells uptake Cr(VI)Cells uptake Cr(VI) Faster for soluble forms of Cr(VI)Faster for soluble forms of Cr(VI) Insoluble chromates concentrateInsoluble chromates concentrate Particles < 10 µm contact target cellsParticles < 10 µm contact target cells

2.2. Cells react with Cr(VI) to form Cr(III) Cells react with Cr(VI) to form Cr(III) and toxic byproducts, Reactive and toxic byproducts, Reactive Oxygen SpeciesOxygen Species

3.3. DNA is damagedDNA is damaged4.4. Cell replication disturbedCell replication disturbed

Other Respiratory EffectsOther Respiratory Effects

Nasal IrritationNasal Irritation Nasal UlcerationsNasal Ulcerations Nasal Septum Perforations Nasal Septum Perforations AsthmaAsthma

• Cr(VI) is an airway sensitizerCr(VI) is an airway sensitizer• Exposure prompts immune responseExposure prompts immune response

BronchitisBronchitis

Additional Health EffectsAdditional Health Effects

DermalDermal• Contact dermititisContact dermititis• Skin ulcersSkin ulcers

InternalInternal• Gastrointestinal ulcersGastrointestinal ulcers• Kidney diseaseKidney disease• Liver damageLiver damage

Summary of Health IssuesSummary of Health Issues

Major health effects Major health effects • Lung cancerLung cancer• Damage to nasal passagesDamage to nasal passages• Skin rashes and ulcersSkin rashes and ulcers

A high % of workers exposed can get A high % of workers exposed can get lung cancerlung cancer

This standard is intended to reduce This standard is intended to reduce these health risksthese health risks

Major Elements of the New Major Elements of the New StandardStandard

Permissible Exposure LevelPermissible Exposure Level Exposure DeterminationExposure Determination Engineering ControlsEngineering Controls Personal ProtectionPersonal Protection Medical SurveillanceMedical Surveillance Worker Education and Worker Education and

communicationcommunication

Permissible Exposure Permissible Exposure

PELPEL• Reduced from 52 micrograms of Cr(VI) per Reduced from 52 micrograms of Cr(VI) per

cubic meter of air as an eight-hour time cubic meter of air as an eight-hour time weighted average (TWA) to 5 µg/mweighted average (TWA) to 5 µg/m33

This cannot be achieved by rotation of employeesThis cannot be achieved by rotation of employees

• Note: OSHA originally wanted to reduce the Note: OSHA originally wanted to reduce the PEL to 1 µg/mPEL to 1 µg/m33

Draft standardDraft standard

Action LevelAction Level• 2.5 micrograms per cubic meter of air 2.5 micrograms per cubic meter of air

Exposure DeterminationExposure Determination

Employer has 2 choicesEmployer has 2 choices• Scheduled monitoringScheduled monitoring• Performance orientedPerformance oriented

Must determine the 8-hour TWA Must determine the 8-hour TWA exposure for each employeeexposure for each employee

Scheduled MonitoringScheduled Monitoring

Initial monitoringInitial monitoring• Sufficient # of samplesSufficient # of samples• Full-shift exposureFull-shift exposure• All job classificationsAll job classifications

Follow-up monitoringFollow-up monitoring• None if below action levelNone if below action level• 6 months if above action level6 months if above action level• 3 months if above PEL 3 months if above PEL

Monitoring GuidelinesMonitoring Guidelines

If employee exposure exceeds PELIf employee exposure exceeds PEL• Employer must notify employee within 15 daysEmployer must notify employee within 15 days• Post informationPost information• Written notificationWritten notification

Accuracy of measuring equipment Accuracy of measuring equipment +/- 25%+/- 25%

Confidence level of 95%Confidence level of 95% Employees can observe monitoringEmployees can observe monitoring

• Employer to provide personal protectionEmployer to provide personal protection

Performance Oriented Performance Oriented OptionOption

Air monitoring dataAir monitoring data Historical monitoring dataHistorical monitoring data Objective dataObjective data If employee exposure exceeds PELIf employee exposure exceeds PEL

• Employer must notify employee within Employer must notify employee within 15 days15 days

• Post informationPost information• Written notificationWritten notification

Engineering ControlsEngineering Controls

Engineering controls mandatory with Engineering controls mandatory with exceptionsexceptions

Effective dateEffective date• May 31, 2010May 31, 2010

Shall reduce the exposure below the Shall reduce the exposure below the PELPEL

If not feasible, respiratory protection If not feasible, respiratory protection must be usedmust be used

Exceptions to Eng. ControlsExceptions to Eng. Controls

#1 - Aerospace#1 - Aerospace• Painting large aircraftPainting large aircraft• Must reduce exposure below 25 Must reduce exposure below 25

microgramsmicrograms Unless not feasibleUnless not feasible Supplement with proper respiratory Supplement with proper respiratory

protectionprotection

#2 - Employee is not exposed above #2 - Employee is not exposed above PEL for 30 or more days per yearPEL for 30 or more days per year

PPEPPE

Respiratory ProtectionRespiratory Protection• To comply, one can use a traditional To comply, one can use a traditional

half-mask NIOSH approved respirator half-mask NIOSH approved respirator with N-95 filters. For maximum with N-95 filters. For maximum protection however, MSA recommends a protection however, MSA recommends a P-100 filter with a full facepiece.P-100 filter with a full facepiece.

• Respiratory program must be in Respiratory program must be in accordance with 29 CFR 1910.134accordance with 29 CFR 1910.134

A copy of this is available on the MSA web A copy of this is available on the MSA web sitesite

Other PPE Other PPE

Work clothing Work clothing • Provided by employer where necessaryProvided by employer where necessary• No cost to employeeNo cost to employee• Employer must ensure it is usedEmployer must ensure it is used• Must be cleaned properly, taking Must be cleaned properly, taking

precautions to prevent contamination of precautions to prevent contamination of other employeesother employees

Medical SurveillanceMedical Surveillance

Employer to offer free of chargeEmployer to offer free of charge All employees who may be exposed All employees who may be exposed

above the action level for 30 or more above the action level for 30 or more days per yeardays per year

Employees showing signs of Employees showing signs of exposureexposure

Employees exposed in an emergencyEmployees exposed in an emergency

Medical Surveillance FrequencyMedical Surveillance Frequency Within 30 days of initial assignment, unless Within 30 days of initial assignment, unless

employee had Cr(VI) exam within last 12 monthsemployee had Cr(VI) exam within last 12 months AnnuallyAnnually Within 30 days of PLHCP’s recommendation for Within 30 days of PLHCP’s recommendation for

further examfurther exam If employee shows signs or symptomsIf employee shows signs or symptoms Within 30 days of emergency exposureWithin 30 days of emergency exposure At termination, unless last exam was within 6 At termination, unless last exam was within 6

monthsmonths Exam must include medical & work history, Exam must include medical & work history,

history of respiratory problems, other specific history of respiratory problems, other specific problems (listed in rule)problems (listed in rule)

Medical SurveillanceMedical Surveillance Employer must provide to PLHCP: copy of this Employer must provide to PLHCP: copy of this

standard, a description of employees duties, standard, a description of employees duties, employees exposure level to CrVI, description of employees exposure level to CrVI, description of PPE and how long used by employee, information PPE and how long used by employee, information on previous employee medical examson previous employee medical exams

PLHCP’s written medical opinion: furnished within PLHCP’s written medical opinion: furnished within 30 days of exam, any detected medical condition 30 days of exam, any detected medical condition which affects work, employee limitations on work which affects work, employee limitations on work and PPE usage, statement that the PLHCP has and PPE usage, statement that the PLHCP has explained results to employeeexplained results to employee

Employer must provide exam info in writing to Employer must provide exam info in writing to employee within 2 weeks of examemployee within 2 weeks of exam

Employee Education and Employee Education and CommunicationCommunication

Employer must provide a copy of the Employer must provide a copy of the standard to the employeestandard to the employee

Employer must insure employee can Employer must insure employee can demonstrate knowledge of:demonstrate knowledge of:• The contents of this ruleThe contents of this rule• The purpose and description of medical The purpose and description of medical

surveillancesurveillance

RecordkeepingRecordkeeping

Employer must keep records ofEmployer must keep records of• Air monitoring dataAir monitoring data• Historical monitoring dataHistorical monitoring data• Objective dataObjective data• Medical surveillanceMedical surveillance

Methods of ComplianceMethods of Compliance

Respiratory ProtectionRespiratory Protection• Half-MaskHalf-Mask• Full FacepieceFull Facepiece• PAPRPAPR• Air-Line RespiratorAir-Line Respirator

Exposure determinationExposure determination• Sampling EquipmentSampling Equipment

Advantage 200 LS Advantage 200 LS RespiratorsRespirators

Advantage 200 LS Advantage 200 LS RespiratorsRespirators

Any NIOSH Any NIOSH approved filterapproved filter

P-100 (as shown) is P-100 (as shown) is bestbest

Can use up to 10X Can use up to 10X the PEL the PEL

Advantage 3000 RespiratorAdvantage 3000 RespiratorAdvantage 3000 RespiratorAdvantage 3000 Respirator

Full-Face Respirator

Any NIOSH approved filter

Can use up to 50X the PEL

Full-Face Respirator

Any NIOSH approved filter

Can use up to 50X the PEL

Powered Respirator (PAPR)Powered Respirator (PAPR)

Used with full-face Used with full-face respiratorrespirator

High Efficiency P-High Efficiency P-100 filter100 filter

Can use up to 50X Can use up to 50X the PELthe PEL

Air Line RespiratorsAir Line Respirators

Constant- FlowConstant- Flow Positive PressurePositive Pressure No filter requiredNo filter required Can be used up to 2000X the PELCan be used up to 2000X the PEL

• You cannot exceed the maximum use You cannot exceed the maximum use concentration. concentration.

MonitoringMonitoring

To test exposure To test exposure use an MSA use an MSA Escort® Elf Escort® Elf Sampling PumpSampling Pump

The procedure for The procedure for hexavalent hexavalent chromium calls for chromium calls for particle collection particle collection using a 37-mm, 5-using a 37-mm, 5-µm pore size PVC µm pore size PVC filter. filter.

QUESTIONS?QUESTIONS?

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