Hexavalent Chromium PDF
Hexavalent Chromium PDF
Hexavalent Chromium PDF
OSHA 3373-10
2009
Contents
Introduction . . . 3
Exposure Limits . . . 6
Regulated Areas . . . 10
Control Measures . . . 10
Housekeeping . . . 15
Medical Surveillance . . . 16
Recordkeeping . . . 20
Effective Dates . . . 22
Additional Information . . . 22
References . . . 23
OSHA Assistance . . . 24
2
Introduction
3
Since 2000, there has been a decline in the use of chromates in
pigments for paints and coatings; printing inks; ceramic, glass and
construction materials; roofing and plastics. Employers are substi-
tuting less toxic inorganic and organic pigments where possible
(SRI Consulting, 2008).
4
Worker Exposure and Health Consequences
Workplace exposure to Cr(VI) may cause the following health
effects:
lung cancer in workers who breathe airborne Cr(VI);
irritation or damage to the nose, throat and lungs (respiratory
tract) if Cr(VI) is inhaled; and
irritation or damage to the eyes and skin if Cr(VI) contacts these
organs.
Workers can inhale airborne Cr(VI) as a dust, fume or mist
while, among other things, producing chromate pigments, dyes
and powders (such as chromic acid and chromium catalysts);
working near chrome electroplating; performing hot work and
welding on stainless steel, high chrome alloys and chrome-coated
metal; and applying and removing chromate-containing paints and
other surface coatings. Skin exposure can occur while handling
solutions, coatings and cements containing Cr(VI).
5
Exceptions
The Cr(VI) standards do not apply in three situations:
exposures that occur in the application of pesticides;
exposures to Portland cement; and
where the employer has objective data demonstrating that a
material containing Cr(VI) or a specific process, operation, or
activity involving Cr(VI) cannot release dusts, fumes or mists
of Cr(VI) in concentrations at or above 0.5 micrograms per
cubic meter (g/m3) of air as an 8-hour time-weighted
average (TWA) under any expected conditions of use.
Exposure Limits
The final Cr(VI) rule establishes an 8-hour TWA permissible
exposure limit (PEL) of 5 g/m3 measured as Cr(VI). This means
that over the course of any 8-hour work shift, the average exposure
to Cr(VI) cannot exceed 5 g/m3.
The Action Level is set at 2.5 g/m3 of Cr(VI) calculated as an 8-
hour TWA.
Exposures above the Action Level trigger specific require-
ments, and exposures above the PEL trigger additional require-
ments. The substantive provisions of the Cr(VI) standard are
described below.
6
25 percent of the true value at least 95 percent of the time for
airborne concentrations at or above the Action Level. Examples of
methods that meet these criteria are OSHA method ID215 (version
2) and NIOSH methods 7600, 7604, 7605 and 7703.
Periodic Monitoring
Periodic monitoring is required if the initial monitoring shows
that the workers exposure is at or above the Action Level (See
7
Table 2, below, for monitoring frequency.)
Additional Monitoring
Additional monitoring is necessary when a workplace change may
result in new or additional exposures to Cr(VI) or the employer
has any reason to believe that new or additional exposures have
occurred. These changes may include alterations in the production
process, raw materials, equipment, personnel, work practices, or
control methods used in the workplace.
8
would be necessary to determine worker exposures under the
modified conditions.
Performance-Oriented Option
The performance-oriented option allows the employer to determine
the 8-hour TWA exposure for each worker on the basis of any
combination of air monitoring data, historical monitoring data, or
objective data sufficient to accurately determine current worker
exposure to Cr(VI). This option is intended to allow employers
flexibility in assessing the Cr(VI) exposures of their personnel.
Where the employer elects to use this option, the exposure deter-
mination must be performed prior to the time that the work
operation commences and must provide the same degree of
assurance that worker exposures have been correctly characterized
as is provided for under the scheduled monitoring option. Like
under the scheduled monitoring option, the employer is expected
to reevaluate worker exposures when there is any change in the
production process, raw materials, equipment, personnel, work
practices, or control methods that may result in new or additional
exposures to Cr(VI). However, the employer using the performance-
oriented option does not have to follow any particular fixed
schedule for performing reevaluations.
Objective Data
The Objective data means information that demonstrates the
expected worker exposure to Cr(VI) associated with a particular
product or material or a specific process, operation, or activity.
Information that can serve as objective data includes, but is not
9
limited to, air monitoring data from an industry-wide survey;
data collected by a trade association from its members; or cal-
culations based on the composition or chemical and physical
properties of a material. The data must reflect workplace con-
ditions closely resembling the processes, types of material,
control methods, work practices and environmental conditions
in the employers current operations.
Regulated Areas
The Cr(VI) standard for general industry includes requirements for
regulated areas wherever a workers exposure to airborne concen-
trations of Cr(VI) is or is reasonably expected to be above the PEL.
However, OSHA has not included this requirement in the construc-
tion and shipyard standards due to the expected practical difficul-
ties of establishing regulated areas for operations in these sectors.
Employers are required to distinguish the regulated area from
the rest of the workplace in a manner that adequately establishes
and alerts workers to the boundaries of the regulated area. The
standard does not specify how employers are to indicate the
regulated areas. Warning signs, gates, ropes, barricades, lines,
textured flooring, or other methods may be appropriate. Whatever
methods are chosen must effectively warn workers not to enter
the area unless they are authorized. Authorized personnel are
those persons required by their job duties to be present in the
area and may include maintenance/repair personnel, managers
and quality control engineers. Also, designated worker representa-
tives may enter the regulated area to observe exposure monitoring.
All persons who enter the regulated area must use proper pro-
tective equipment, including respirators when appropriate.
Control Measures
To protect workers from Cr(VI) hazards, whenever exposures
exceed the PEL employers must use engineering and work
practice controls to reduce and maintain Cr(VI) exposures to or
10
below the PEL. These are the most effective controls. Whenever
feasible engineering and work practice controls are not sufficient
to reduce exposures to or below the PEL, the employer must use
such controls to reduce exposures to the lowest levels achievable
and supplement them by the use of respiratory protection.
Engineering controls include substitution (using a less toxic
material or process that results in lower exposures), isolation
(such as enclosing the source of exposure), and ventilation (such
as using a local exhaust system that captures airborne Cr(VI) near
its source).
Work practice controls involve adjustments in the way a task is
performed. Workers must know the proper way to perform a task
in order to minimize their exposure and to maximize the effective-
ness of the control. For example, a welder should be properly
trained to correctly position himself and the local exhaust ven-
tilation to minimize exposure to the welding fume. In many cases,
work practice controls complement engineering controls in
providing worker protection.
Employers are not permitted to rotate workers to different
jobs as a means of achieving compliance with the PEL.
11
controls, including respirators alone, to achieve the PEL.
Historical data, objective data, or exposure monitoring data
may be used for this purpose.
Respiratory Protection
Employers are required to provide workers with respirators when
feasible engineering and work practice controls are unable to
reduce worker exposure to Cr(VI) to levels at or below the PEL.
Respirators are required during:
Work operations such as maintenance and repair activities for
which engineering and work practice controls are not feasible;
Emergencies (i.e., any occurrence that results or is likely to result
in an uncontrolled release of Cr(VI) that is not an incidental
release that can be controlled by workers in the immediate area
or by maintenance personnel);
Where workers are exposed above the PEL for fewer than 30
days per year and the employer has opted not to implement
engineering/work practice controls to achieve the PEL;
Periods necessary to install or implement feasible engineering
and work practice controls; or
Operations where all feasible engineering and work practice
controls have been implemented but are not sufficient to reduce
exposures to or below the PEL.
Where respirator use is required, the employer must establish
a respiratory protection program in accordance with OSHAs
Respiratory Protection standard (29 CFR 1910.134). The respiratory
protection program addresses procedures for properly selecting,
using and maintaining respirators in the workplace. OSHA has
prepared the document, a Small Entity Compliance Guide for the
Revised Respiratory Protection Standard (see the Additional
Information section at page 22).
12
appropriate protective clothing and equipment whenever a hazard
evaluation of the workplace has identified that skin or eye contact
with Cr(VI) presents or is likely to present a hazard to workers.
Where such a hazard is identified, the employer must select the
clothing and equipment needed to protect workers from Cr(VI)
hazards. Some examples of protective clothing and equipment
that may be necessary include, but are not limited to, gloves,
aprons, coveralls, foot coverings and goggles. Normal street
clothing and uniforms or other accessories that do not protect
workers from Cr(VI) hazards are not considered protective clothing
or equipment under the standard. Employers must provide and
maintain the clothing and equipment at no cost to the worker.
The following precautions must be taken to protect workers
and others who handle protective clothing and equipment:
The employer must ensure that workers remove protective
clothing and equipment that has become contaminated with
Cr(VI) either at the end of their work shift or when they complete
their tasks involving Cr(VI) exposure, whichever comes first.
The employer must not allow any worker to remove contaminat-
ed protective clothing or equipment from the workplace, except
for those workers whose job it is to launder, clean, maintain, or
dispose of the clothing or equipment.
When contaminated protective clothing or equipment is
removed for laundering, cleaning, maintenance or disposal, the
employer must ensure that it is stored and transported in sealed,
impermeable bags or other closed, impermeable containers.
Bags or containers of contaminated protective clothing or
equipment that are removed from change rooms for laundering,
cleaning, maintenance or disposal must be labeled in accordance
with OSHAs Hazard Communication standard at 29 CFR
1910.1200.
The employer must clean, launder, repair and replace protective
clothing and equipment as necessary to ensure that the effec-
tiveness of the clothing and equipment is maintained.
The employer must inform any person who launders or cleans
protective clothing or equipment contaminated with Cr(VI) of the
potentially harmful effects of Cr(VI) exposure, and that the
13
clothing and equipment should be laundered or cleaned in a
manner that minimizes skin or eye contact with Cr(VI) and
prevents exposure to Cr(VI) in excess of the PEL. Removal of
Cr(VI) from protective clothing and equipment by blowing,
shaking, or any other means that disperses Cr(VI) into the air or
onto a worker's body is prohibited.
14
ment, unless the protective clothing or equipment is properly
cleaned beforehand. Employers may use any method for removing
surface Cr(VI) from clothing and equipment that does not disperse
the dust into the air or onto the workers body. For example, if a
worker is wearing coveralls for protection against Cr(VI), thorough
HEPA vacuuming of the coveralls could be performed prior to
entry into a lunchroom. Do NOT blow dust off protective clothing
and equipment.
The employer must ensure that workers do not eat, drink,
smoke, chew tobacco or gum, or apply cosmetics or carry or
store products associated with these activities in regulated areas
or in areas where skin or eye contact with Cr(VI) occurs.
Housekeeping
The Cr(VI) standard for general industry includes housekeeping
measures. OSHA did not include these requirements in the con-
struction and shipyard standards due to the expected practical
difficulties of complying with such requirements in those sectors.
Proper housekeeping requirements are important because they
target sources of exposure to Cr(VI) that engineering controls are
generally not designed to address (such as skin exposures).
Employers must ensure that all surfaces are maintained as free as
practicable of accumulations of Cr(VI). Spills and releases of
Cr(VI)-containing material must be cleaned up promptly. The
requirement to maintain surfaces as free as practicable is
performance-oriented. The standard does not specify what an
allowable surface loading of Cr(VI) contamination in work areas
would be. Instead, the requirement for as free as practicable is
met when the employer is vigilant in efforts to ensure that surfaces
are kept free of accumulation of Cr(VI) dust. OSHA will consider
the employers housekeeping schedule, the possibility of exposure
from the surfaces in question, and the characteristics of the
workplace. (OSHA, Jan. 13, 2003, Letter of Interpretation.)
Cleaning Methods
Surfaces contaminated with Cr(VI) must be cleaned by HEPA-
filtered vacuuming or other methods that minimize exposure to
15
Cr(VI), including wet methods such as wet sweeping or wet
scrubbing. Dry methods (e.g., dry shoveling, dry sweeping and
dry brushing) are only allowed in cases where HEPA-filtered
vacuuming or other methods that minimize the likelihood of
exposure to Cr(VI) have been tried and found not to be effective.
The use of compressed air for cleaning surfaces is only allowed
when used in conjunction with a ventilation system designed to
capture the dust cloud or when no alternative method is feasible.
Employers should use caution whenever compressed air is used
as a cleaning method, since the air will spread the contamination
further unless the dust is appropriately collected. Compressed air
should never be directed at workers and should not be used to
clean protective clothing or equipment.
Employers must ensure that waste, scrap, debris and any other
materials contaminated with Cr(VI) are collected and disposed of
in sealed, impermeable bags or other closed, impermeable con-
tainers. Additionally, bags or containers of waste, scrap, debris
and any other materials contaminated with Cr(VI) must be labeled
in accordance with the requirements of the Hazard Communication
standard, 29 CFR 1910.1200.
Medical Surveillance
The purpose of medical surveillance is to determine if an individual
can be exposed to Cr(VI) at his or her workplace without experi-
encing adverse health effects; to identify Cr(VI)-related adverse
health effects when they do occur so that appropriate intervention
measures can be taken; and to determine a workers fitness to use
personal protective equipment such as respirators.
All medical examinations and procedures required by the
standards must be performed by or under the supervision of a
physician or other licensed healthcare professional (PLHCP).
When medical surveillance is required it must be provided at no
cost to workers and at a reasonable time and place. If participation
requires travel away from the worksite, the employer must bear
the cost. Workers must be paid for time spent taking medical
examinations, including travel time.
16
Employers must provide medical surveillance
to workers who are:
Exposed or may be exposed to Cr(VI) at concentrations at or
above the Action Level (as an 8-hour TWA) for 30 or more
days per year;
Experiencing signs and symptoms of adverse health effects
associated with Cr(VI) exposures (e.g., blistering lesions,
redness or itchiness of exposed skin, shortness of breath
or wheezing that worsens at work, nosebleeds, a whistling
sound while inhaling or exhaling); or
Exposed in an emergency situation (i.e., any occurrence that
results or is likely to result in an uncontrolled release of
Cr(VI) that is not an incidental release that can be controlled
by workers in the immediate area or by maintenance per-
sonnel).
17
Contents of the Medical Exams
A medical and work history which focuses on: the workers
past, present and anticipated future exposure to Cr(VI); any
history of respiratory system dysfunction; any history of
asthma, dermatitis, skin ulceration or nasal septum
perforation; and smoking status and history.
A physical examination of the skin and respiratory tract.
Any additional tests that the examining PLHCP considers
appropriate for that worker.
Note: The standards do not specify tests or procedures that
must be provided to all workers. Rather, the information
obtained from the medical and work history along with the
physical examination of the skin and respiratory tract (the main
targets of Cr(VI) toxicity) allow the PLHCPs to use their medical
judgment to determine what tests, if any, are warranted.
Recordkeeping
Accurate records can demonstrate employer compliance with the
standard and can assist in diagnosing and identifying workplace-
related illnesses. Therefore, employers are required to maintain
records of worker Cr(VI) exposures (including air monitoring data,
historical monitoring data and objective data) and medical surveil-
lance records.
20
That the data was collected using methods that meet the
accuracy requirements of the standard;
That the processes and work practices, characteristics of the
Cr(VI)-containing material, and environmental conditions at the
time the data was obtained are essentially the same as those of
the job for which current exposure is being determined; and
Any other relevant data regarding operations, materials, processes,
or worker exposures.
Objective Data
When an employer relies on objective data to comply with the
Cr(VI) standard, an accurate record of the objective data must be
maintained. The record must indicate:
The Cr(VI)-containing material in question;
The source of the objective data;
The testing protocol and results of testing, or analysis of the
material for the release of Cr(VI);
A description of the process, operation, or activity and how the
data support the determination; and
Any other relevant data regarding the processes, operations,
activities, materials, or worker exposures.
Medical Surveillance
The employer must maintain an accurate record for each worker
provided medical surveillance under the standard. The record
must include the following information about the worker:
Name and social security number;
A copy of the PLHCPs written opinions; and
A copy of the information that the employer was required to
provide to the PLHCP (i.e., a description of the workers duties
as they relate to occupational Cr(VI) exposure; the workers
Cr(VI) exposure levels; a description of the personal protective
equipment used by the worker; and information from previous
employment-related medical examinations).
21
Exposure and medical records must be maintained and made
available to workers and their representatives in accordance with
29 CFR 1910.1020, Access to Employee Exposure and Medical
Records. In general, exposure records must be kept for at least 30
years, and medical records must be kept for the duration of em-
ployment plus 30 years. It is necessary to keep these records for
extended periods because cancer often cannot be detected until
20 or more years after exposure, and exposure and medical
records can assist in diagnosing and identifying the cause of
disease.
Effective Dates
All provisions of the standard are currently in effect, except that
employers have until May 31, 2010 to implement required
engineering controls.
Additional Information
Small Entity Compliance Guide for the Hexavalent Chromium
Standards:
www.osha.gov/Publications/OSHA_small_entity_comp.pdf
Small Entity Compliance Guide for the Revised Respiratory
Protection Standard:
www.osha.gov/Publications/3384small-entity-for-respiratory-
protection-standard-rev.pdf
OSHA Fact Sheet: Health Effects of Hexavalent Chromium:
www.osha.gov/OshDoc/data_General_Facts/hexavalent_chromium
.pdf
Hexavalent Chromium General Industry standard:
www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=
STANDARDS&p_id=13096
Hexavalent Chromium Shipyard standard:
www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=
STANDARDS&p_id=13116
22
Hexavalent Chromium Construction standard:
www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=ST
ANDARDS&p_id=13117
For a list of State plans and contact information:
www.osha.gov/dcsp/osp/index.html.
References
Meridian Research, Inc. 1994. Final Report: Selected Chapters of
an Economic Impact Analysis for a Revised OSHA Standard for
Chromium VI: Introduction, Industry Profiles, Exposure Profiles,
Technological Feasibility (for 6 industries) and Environmental
Impacts. Prepared for: Office of Regulatory Analysis, OSHA,
Prepared by: Meridian Research, Inc., Prepared under Contract
Number: J-9-F-4-0012, Task Order No. 1, Base Year, December 18,
1994, pages I-2 through I-7, Document ID Number OSHA-H054A-
2006-0064-0720 (formerly Exhibit Number 26).
23
OSHA Assistance
State Programs
The Occupational Safety and Health Act of 1970 (OSH Act)
encourages states to develop and operate their own job safety
and health plans. Twenty-four states, Puerto Rico and the Virgin
24
Islands currently operate approved state plans: 22 cover both
private and public (state and local government) employment;
Connecticut, New Jersey, New York and the Virgin Islands cover
the public sector only. States and territories with their own
OSHA-approved occupational safety and health plans must adopt
standards identical to, or at least as effective as, the Federal OSHA
standards.
Consultation Services
Consultation assistance is available on request to employers who
want help in establishing and maintaining a safe and healthful
workplace. Largely funded by OSHA, the service is provided at no
cost to the employer. Primarily developed for smaller employers
with more hazardous operations, the consultation service is
delivered by state governments employing professional safety and
health consultants. Comprehensive assistance includes an appraisal
of all mechanical systems, work practices and occupational safety
and health hazards of the workplace and all aspects of the employers
present job safety and health program. In addition, the service
offers assistance to employers in developing and implementing an
effective safety and health program. No penalties are proposed or
citations issued for hazards identified by the consultant. OSHA
provides consultation assistance to the employer with the assurance
that his or her name and firm and any information about the
workplace will not be routinely reported to OSHA enforcement staff.
For more information concerning consultation assistance, see
OSHAs website at www.osha.gov.
25
For more information on this and other agency programs,
contact your nearest OSHA office, or visit OSHAs website at
www.osha.gov.
26
OSHA Publications
OSHA has an extensive publications program. For a listing of free
items, visit OSHAs website at www.osha.gov or contact the OSHA
Publications Office, U.S. Department of Labor, 200 Constitution
Avenue, NW, N-3101, Washington, DC 20210; telephone (202) 693-
1888 or fax to (202) 693-2498.
Contacting OSHA
To report an emergency, file a complaint, or seek OSHA advice,
assistance, or products, call (800) 321-OSHA or contact your nearest
OSHA Regional or Area office listed at the end of this publication.
The teletypewriter (TTY) number is (877) 889-5627.
Written correspondence can be mailed to the nearest OSHA
Regional or Area Office listed at the end of this publication or to
OSHAs national office at: U.S. Department of Labor, Occupational
Safety and Health Administration, 200 Constitution Avenue, N.W.,
Washington, DC 20210.
By visiting OSHAs website at www.osha.gov, you can also:
File a complaint online,
Submit general inquiries about workplace safety and health elec-
tronically, and
Find more information about OSHA and occupational safety and
health.
27
OSHA Regional Offices
Region I Region VI
(CT*, ME, MA, NH, RI, VT*) (AR, LA, NM*, OK, TX)
JFK Federal Building, Room E340 525 Griffin Street, Room 602
Boston, MA 02203 Dallas, TX 75202
(617) 565-9860 (972) 850-4145
Region IV Region IX
(AL, FL, GA, KY*, MS, NC*, SC*, TN*) (AZ*, CA*, HI*, NV,* and American
61 Forsyth Street, SW, Room 6T50 Samoa, Guam and the Northern
Atlanta, GA 30303 Mariana Islands)
(404) 562-2300 90 7th Street, Suite 18-100
San Francisco, CA 94103
Region V (415) 625-2547
(lL*, IN*, MI*, MN*, OH, WI)
230 South Dearborn Street Region X
Room 3244 (AK*, ID, OR*, WA*)
Chicago, IL 60604 1111 Third Avenue, Suite 715
(312) 353-2220 Seattle, WA 98101-3212
(206) 553-5930
* These states and territories operate their own OSHA-approved job safety
and health programs and cover state and local government employees as
well as private sector employees. The Connecticut, Illinois, New Jersey,
New York and Virgin Islands plans cover public employees only. States with
approved programs must have standards that are identical to, or at least as
effective as, the Federal OSHA standards.
Note: To get contact information for OSHA Area Offices, OSHA-approved
State Plans and OSHA Consultation Projects, please visit us online at
www.osha.gov or call us at 1-800-321-0SHA.
28