Hexavalent Chromium New OSHA Standard Informational Web Cast

Hexavalent Chromium “New OSHA Standard” Informational Web Cast

Presented by MSA John Hierbaum Product Line Manager Air Purifying Respirators & Meghan Swanson Staff Chemist

WELCOME Thank You for joining us today

CAUTION! n n n 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

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

New OSHA Standard Hexavalent Chromium n Covers • General Industry - 1910. 1026 • Shipyards - 1915. 1026 • Construction - 1926. 1126 n Most requirements are generally the same for all industries

Exceptions to the New Standard n n n 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/m 3 as an 8 hour TWA

Significant Dates to Remember n n n 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

What Activities are the Sources of Chromium (VI)? n n Welding and cutting of stainless steel and other chromium containing metals Heavy Painting and coating Electroplating Handling of chrome based pigments

How Many Workers are Exposed? n n n 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

WHAT IS HEXAVALENT CHROMIUM?

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

Chromates have Varying Solubilities n Highly soluble in water: • Sodium dichromate • Chromic acid n Slightly soluble in water: • • • n Calcium chromate Strontium chromate Zinc chromate Insoluble in water: • Lead chromate • Barium chromate

Exposure Routes n Inhalation • Particulates, such as: • Paint spray • Welding fumes • Chromate dust n Skin exposure

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

Carcinogenic Effects: Lung Cancer 1. Cells uptake Cr(VI) n n n 2. 3. 4. Faster for soluble forms of Cr(VI) Insoluble chromates concentrate Particles < 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

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

Additional Health Effects n Dermal • Contact dermititis • Skin ulcers n Internal • Gastrointestinal ulcers • Kidney disease • Liver damage

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

Major Elements of the New Standard n n n Permissible Exposure Level Exposure Determination Engineering Controls Personal Protection Medical Surveillance Worker Education and communication

Permissible Exposure n PEL • Reduced from 52 micrograms of Cr(VI) per cubic meter of air as an eight-hour time weighted average (TWA) to 5 µg/m 3 n This cannot be achieved by rotation of employees • Note: OSHA originally wanted to reduce the PEL to 1 µg/m 3 n n Draft standard Action Level • 2. 5 micrograms per cubic meter of air

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

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

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

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

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

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

PPE n 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 n A copy of this is available on the MSA web site

Other PPE n 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

Medical Surveillance n n 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

Medical Surveillance Frequency n n n n Within 30 days of initial assignment, unless employee had Cr(VI) exam within last 12 months Annually Within 30 days of PLHCP’s 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)

Medical Surveillance n n n Employer must provide to PLHCP: copy of this standard, a description of employees duties, employees exposure level to Cr. VI, description of PPE and how long used by employee, information on previous employee medical exams PLHCP’s 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

Employee Education and Communication n n 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

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

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

Advantage 200 LS Respirators n n n Any NIOSH approved filter P-100 (as shown) is best Can use up to 10 X the PEL

Advantage 3000 Respirator n n n Full-Face Respirator Any NIOSH approved filter Can use up to 50 X the PEL

Powered Respirator (PAPR) n n n Used with full-face respirator High Efficiency P 100 filter Can use up to 50 X the PEL

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

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

QUESTIONS? Thanks for attending!