Hexavalent Chromium Safety Bureau of Workers Compensation PA

Hexavalent Chromium Safety Bureau of Workers’ Compensation PA Training for Health & Safety (PATHS) 29 CFR 1910. 1026 Subpart Z – Toxic & Hazardous Substances 1910. 1026 – Chromium (VI) PPT-141 -01 1

Topics • Properties and Health Effects Bureau of Workers’ Compensation PA Training for Health & Safety (PATHS) • Exposure Limits and Monitoring Options • Compliance • Respiratory Protection & PPE • Hygiene Practices • Medical Surveillance • Hazard Awareness and Training PPT-141 -01 2

Hexavalent Chromium Safety 1910. 1026 – Chromium (VI) This standard applies to occupational exposures to chromium (VI) in all forms and compounds in general industry, meaning chromium with a valence of positive 6. It is estimated that 558, 000 workers are potentially exposed to Cr(VI) in the United States. PPT-141 -01 3

1910. 1026 Exceptions This standard does NOT apply to: • Exposures that occur in the application of pesticides regulated by the EPA or another Federal government agency (e. g. , the treatment of wood with preservatives) • Exposures to portland cement • Where objective data shows a material containing chromium or a specific process, operation, or activity cannot release dusts, fumes, or mists at or above 0. 5 μgm/m 3 as an 8 -hour time-weighted average (TWA) under any expected conditions of use. PPT-141 -01 4

Chromium Properties Chromium (VI) (Hexavalent Chromium) Synonyms: Chromium VI; Hexavalent Chromium; Cr(VI) CAS #: 18540 -29 -9 (hexavalent chromium) 1333 -82 -0 (chromium (VI) oxide) OSHA PEL: 5. 0 μgm/m 3 TWA Action Level: 2. 5 μgm/m 3 TWA NFPA: Health: 3; Flammability: 0; Instability: 0 May cause: Cancer (lung, nasopharynx, oropharynx, nasal passages, eye sensitizer and skin sensitization PPT-141 -01 5

Other Compounds Cr(VI) is widely used in pigments, metal finishing (electroplating), wood preservatives and fungicides, and in chemical synthesis as an ingredient and catalyst. Cr(VI) is present in many different compounds with various industrial Applications, such as, • Chromium trioxide or chromic acid (Cr. O 3) • Potassium chromate (K 2 Cr. O 4) • Sodium chromate (Na 2 Cr. O 4) PPT-141 -01 6

Chromium Incompatibilities May be incompatible or react with: § Combustible materials, § Organics § Other readily oxidizable materials such as paper, wood, sulfur, aluminum, plastics and others. § Corrosive to metals. PPT-141 -01 7

Health Effects Hexavalent chromium (Cr(VI)) is a toxic form of the element chromium. Hexavalent chromium is rarely found in nature and is generally man-made. • Lung cancer from breathing airborne Cr(VI) • Irritation or damage to the nose, throat and lungs (respiratory tract) if Cr(VI) is inhaled • Irritation or damage to the eyes and skin if Cr(VI) contacts these organs. PPT-141 -01 8

Health Effects • Toxic if swallowed, inhaled or absorbed through skin • Causes burns via all exposure routes • May cause allergic respiratory and skin reaction Target organs: § § § Blood & Kidneys Eyes & Skin Respiratory system Gastrointestinal System Mucous membranes PPT-141 -01 9

Those at Risk • Painters [Cr(III) and Cr(VI)] • Abrasive blasting workers [Cr(III) and Cr(VI)] • Workers involved in the maintenance and servicing of copying machines and the disposal of some toner powders from copying machines [Cr(VI)] • Battery makers [Cr(VI)] • Candle makers [Cr(III) and Cr(VI)] PPT-141 -01 10

Those at Risk • • • Dye makers [Cr(III)] Printers [Cr(III) and Cr(VI)] Rubber makers [Cr(III) and Cr(VI)] Cement workers [Cr(III) and Cr(VI)] Workers involved in welding, cutting, brazing, soldering, torch and other hot work operations [Cr(III) and Cr(VI)] PPT-141 -01 11

Chromium Action Levels Action level means a concentration of airborne chromium (VI) of 2. 5 micrograms per cubic meter of air (2. 5 μgm/m³) calculated as an 8 -hour timeweighted average (TWA). PPT-141 -01 12

Permissible Exposure Level PEL The employer ensures no employee is exposed to an airborne concentration of chromium (VI) in excess of 5 micrograms per cubic meter of air (5 μgm/m³), calculated as an 8 -hour time-weighted average (TWA). PPT-141 -01 13

Permissible Exposure Level Calculating Time-Weighted Average Exposures Both the PEL and the action level are expressed as timeweighted average (TWA) exposures. TWA measurements account for variable exposure levels over the course of a work shift, averaging periods of higher and lower exposures. The TWA exposure for an 8 -hour work shift is computed using a simple formula: TWA = (Ca Ta+Cb Tb+. . . Cn Tn)÷ 8 Where: TWA is the time-weighted average exposure for the work shift; C is the concentration during any period of time (T) where the concentration remains constant; and T is the duration in hours of the exposure at the concentration (C). PPT-141 -01 14

Permissible Exposure Level Example, assume that an employee is subject to the following exposure to Cr(VI): Two hours exposure at 10 μg/m 3 Two hours exposure at 5 μg/m 3 Four hours exposure at 1 μg/m 3 Substituting this information in the formula, we have: (2 x 10 + 2 x 5 + 4 x 1)÷ 8 = 4. 25 μg/m 3 Since 4. 25 μg/m 3 is more than 2. 5 μg/m 3, the action level has been exceeded. However, as 4. 25μg/m 3 is less than 5 μg/m 3, the PEL has not been exceeded. PPT-141 -01 15

Exposure Determination The employer shall determine the 8 -hour TWA exposure for each employee exposed to chromium (VI). Two (2) methods are assigned: • Scheduled Monitoring Option • Performance-Oriented Option PPT-141 -01 16

Scheduled Monitoring Option Initial monitoring to determine the 8 -hour TWA exposure for each employee on the basis of a sufficient number of personal breathing zone air samples to accurately characterize full shift exposure on; • Each shift • For each job classification • In each work area PPT-141 -01 17

Scheduled Monitoring Option If initial monitoring indicates exposures are below the action level, the employer may discontinue monitoring for those employees whose exposures are represented by such monitoring. If monitoring reveals employee exposures to be at or above the action level, the employer shall perform periodic monitoring at least every six months. PPT-141 -01 18

Scheduled Monitoring Option If monitoring reveals employee exposures to be above the PEL, employer shall perform periodic monitoring at least every three months. If this indicates employee exposures are below the action level, and the result is confirmed by the result of another monitoring taken at least seven days later, the employer may discontinue the monitoring for those employees whose exposures are represented by such monitoring. PPT-141 -01 19

Scheduled Monitoring Option Perform additional monitoring when there has been any change in the • Production process • Raw materials • Equipment • Personnel • Work practices • Control methods that may result in new or additional exposures to chromium (VI), or when the employer has any reason to believe new or additional exposures have occurred. PPT-141 -01 20

Performance-Oriented Option Employer shall determine the 8 -hour TWA exposure for each employee on the basis of, • Any combination of air monitoring data • Historical monitoring data • Objective data sufficient to accurately characterize employee exposure to chromium (VI). PPT-141 -01 21

Results Notification Within 15 work days after exposure determination: • Employer shall individually notify each affected employee in writing of results • Post results in appropriate location accessible to all affected employees When exposure is above the PEL, employer shall describe in the written notification corrective action(s) being taken to reduce employee exposure to or below the PEL. PPT-141 -01 22

Measurement Accuracy • Air monitoring will use a method that can measure chromium (VI) within an accuracy of plus or minus 25 percent (± 25%) and • Can produce accurate measurements to within a statistical confidence level of 95 percent for airborne concentrations at or above the action level. PPT-141 -01 23

Monitoring Observation • Affected employees or their designees are given the opportunity to observe any monitoring. • Observers also provided with PPE to observe. PPT-141 -01 24

Monitoring Frequency Below Action Level (<2. 5 μgm/m 3) No periodic monitoring required At or above Action Level but at or below PEL (2. 5 μgm/m 3 to 5 μgm/m 3) Monitor every 6 months Above PEL (>5 μgm/m 3) Monitor every 3 months PPT-141 -01 25

Regulated Areas • Establish a regulated area wherever an employee's exposure to airborne concentrations of chromium (VI) is, or can reasonably be expected to be, in excess of the PEL. • Regulated areas are separated from the rest of the workplace in a manner that adequately establishes and alerts employees of the boundaries of the regulated area. PPT-141 -01 26

Regulated Area Access • Persons authorized by the employer and required by work duties to be present in the regulated area • Any person entering such an area as a designated representative of employees for the purpose of exercising the right to observe monitoring procedures under paragraph (d) of this section • Any person authorized by the OSHAct PPT-141 -01 27

Compliance Methods Engineering & Work Practice Controls • Use engineering and work practice controls to reduce and maintain employee exposure to chromium (VI) to or below the PEL unless the employer can demonstrate that such controls are not feasible. • Supplement with respiratory protection to achieve the PEL. PPT-141 -01 28

Compliance Methods Where the employer can demonstrate that a process or task does not result in any employee exposure to chromium (VI) above the PEL for 30 or more days per year (12 consecutive months): • Requirement to implement engineering and work practice controls to achieve the PEL does not apply to that process or task. PPT-141 -01 29

Respiratory Protection Where respiratory protection is required supply each employee with an appropriate respirator. Program shall be in accordance with 29 CFR 1910. 134. Respiratory protection is required during: • Periods necessary to install or implement feasible engineering and work practice controls • Work operations, such as maintenance and repair activities, for which engineering and work practice controls are not feasible PPT-141 -01 30

Respiratory Protection • Work operations for which an employer has implemented all feasible engineering and work practice controls and such controls are not sufficient to reduce exposures to or below the PEL • Work operations where employees are exposed above the PEL for fewer than 30 days per year, and the employer has elected not to implement engineering and work practice controls to achieve the PEL • Emergencies PPT-141 -01 31

Respiratory Protection Program NIOSH Pocket Guide to Chemical Hazards: Note in Chromic acid and chromates to include Chromium (VI) compounds: Scba. F: Pd, Pp/Sa. F: Pd, PP: Ascba Note: at concentrations above the NIOSH REL, or where there is no REL, at any detectable concentration. Scba. F: Pd, Pp= APF of 10, 000; any self-contained breathing apparatus that has a full facepiece and is operated in a pressure-demand or other positive-pressure mode. Sa. F: Pd, PP: Ascb=APF of 10, 000; any supplied-air respirator that has a fullfacepiece and is operated in a pressure-demand or other positive-pressure mode in combination with an auxiliary self-contained breathing apparatus operated in pressure-demand or other positive-pressure mode. PPT-141 -01 32

Personal Protective Equipment Where hazard is present or likely to be present from skin or eye contact with chromium (VI), the employer will provide appropriate personal protective clothing and equipment (PPE) • Prevent skin and eye contact • Eyeglasses and safety goggles • Chemical apron PPT-141 -01 33

PPE: Removal/Storage • Remove all contaminated PPE at shift end or task completion whichever comes first • No employee removes contaminated PPE from the workplace, except to launder, clean, maintain, or dispose of such clothing or equipment PPT-141 -01 34

PPE: Removal/Storage • When removed for laundering, cleaning, maintenance, or disposal, it is stored and transported in sealed, impermeable bags or other closed, impermeable containers. • Ensure that bags or containers of contaminated protective clothing or equipment are labeled in accordance with the requirements of the Hazard Communication Standard, § 1910. 1200. PPT-141 -01 35

PPE: Cleaning/Replacing • Clean, launder, repair and replace all PPE as needed to maintain effectiveness. • Prohibit chromium removal from PPE by blowing, shaking, or any other means that disperses chromium (VI) into the air or onto an employee's body. • Inform person laundering or cleaning contaminated PPE that it should be laundered or cleaned to minimizes skin or eye contact with chromium (VI) in excess of the PEL. PPT-141 -01 36

Hygiene Areas/Practices Where protective clothing and equipment is required, provide change rooms per 29 CFR 1910. 141. • Change Rooms • Washing Facilities • Eating and Drinking Areas PPT-141 -01 37

Hygiene Areas/Practices Change Rooms Separate storage facilities for protective clothing and equipment and for street clothes, and prevent cross-contamination. PPT-141 -01 38

Hygiene Areas/Practices Washing Facilities • Readily accessible • Capable of removing chromium (VI) from the skin • Shall ensure that affected employees use these facilities when necessary PPT-141 -01 39

Hygiene Areas/Practices Eating and Drinking Areas • Ensure that eating and drinking areas and surfaces are maintained as free as practicable of chromium (VI) • Do not enter eating and drinking areas with protective work clothing or equipment unless surface chromium (VI) has been removed from the clothing and equipment PPT-141 -01 40

Prohibited Activities • No eating, drinking, smoking, chewing tobacco or gum, or applying cosmetics in regulated areas, or • In areas where skin or eye contact occurs; or • Carry the products associated with these activities, or store such products in these areas. PPT-141 -01 41

Housekeeping • Maintain all surfaces free as practicable of accumulations of chromium (VI). • Clean-up all spills and releases of chromium (VI) promptly. PPT-141 -01 42

Cleaning Methods • Clean by HEPA-filter vacuuming or other methods that minimize the likelihood of exposure • Dry shoveling, dry sweeping, and dry brushing may be used only where HEPA-filtered vacuuming or other methods have been tried and found not to be effective PPT-141 -01 43

Compressed Air & Cleaning Compressed air is not allowed to clean any surface unless: • It is used in conjunction with a ventilation system designed to capture the dust cloud No alternative method is feasible PPT-141 -01 44

Disposal • Waste, scrap, debris, and any other materials contaminated with chromium (VI) and consigned for disposal are collected and disposed of in sealed, impermeable bags or other closed, impermeable containers • Bags or containers of waste, scrap, debris, and any other materials contaminated with chromium (VI) that are consigned for disposal are labeled per Hazard Communication Standard, 29 CFR 1910. 1200 PPT-141 -01 45

Medical Surveillance Available at no cost at a reasonable time and place for all employees who: • Are or may be exposed at or above action level for 30 or more days a year • Experiencing signs or symptoms of adverse health effects to chromium • Exposed in an emergency PPT-141 -01 46

Medical Surveillance Frequency • Within 30 days after initial assignment unless employee received a chromium related med exam that meets requirements of this paragraph within the last 12 months. PPT-141 -01 47

Medical Surveillance Frequency Annually • Within 30 days after a PLHCP's written medical opinion recommends an additional examination • Whenever an employee shows signs or symptoms of the adverse health effects associated with chromium (VI) exposure PPT-141 -01 48

Medical Surveillance Frequency Annually • Within 30 days after exposure during an emergency which results in an uncontrolled release of chromium (VI); • At the termination of employment, unless the last examination that satisfied the requirements of paragraph (k) of this section was less than six months prior to the date of termination PPT-141 -01 49

Medical Exam Contents Medical and work history, with emphasis on: • Past, present, and anticipated future exposure to chromium (VI); any history of respiratory system dysfunction • Any history of asthma, dermatitis, skin ulceration, or nasal septum perforation • Smoking status and history • Physical exam of skin and respiratory tract; and • Any additional tests deemed appropriate by examining PLHCP. PPT-141 -01 50

Information to PLHCP • Copy of this standard • Description of duties and levels related to exposure to chromium (VI) • Description of PPE used or to be used when and for how long the employee has used that PPE • Information from records of employment-related medical examinations previously provided to the affected employee, currently within the control of the employer PPT-141 -01 51

PLHCP’s Written Opinion Employer obtains PLHCP’s written medical opinion within 30 days for each med exam performed on each employee. PLHCP’s opinion contains: • If employee has any detected med condition(s) placing employee at increased risk of material impairment to health from further chromium exposure. • Recommended limitations upon employee’s exposure or upon the use of PPE, such as respirators. PPT-141 -01 52

PLHCP’s Written Opinion Statement PLHCP has explained med exam results plus any medical conditions related to chromium (VI) exposure requiring further evaluation or treatment and any special provisions for use of PPE. • PLHCP shall not reveal to employer specific findings or diagnoses unrelated to chromium exposure. • Employer provides copy of written opinion to employee within 2 weeks after receiving it. PPT-141 -01 53

Exposure Control Engineered Controls Work Practice Controls Administrative Controls PPT-141 -01 PPE 54

Recordkeeping Accurate records are required: • Air monitoring data • Historical Monitoring date • Objective data • Medical surveillance PPT-141 -01 55

Air Monitoring Data • Date of the measurement for each sample taken; • Operation involving exposure to Cr(VI) that was monitored • Sampling and analytical methods used and evidence of their accuracy • Number, duration and results of samples taken • Type of personal PPE used (e. g. , type of respirators worn) • Name, social security number and job classification of all workers represented by the monitoring, specifying which workers were actually monitored PPT-141 -01 56

Historical Monitoring Data • 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 • Any other relevant data regarding operations, materials, processes, or worker exposures. PPT-141 -01 57

Objective Data • 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) • Description of the process, operation, or activity and how the data support the determination • Other relevant data regarding the processes, operations, activities, materials, or worker exposures PPT-141 -01 58

Medical Surveillance • Name and social security number • Copy of the PLHCP’s written opinions • Copy of the information that the employer was required to provide to the PLHCP; i. e. : o A description of the worker’s duties as they relate to occupational Cr(VI) exposure o The worker’s Cr(VI) exposure levels o A description of the personal protective equipment used by the worker o Information from previous employmentrelated medical examinations) PPT-141 -01 59

Hazard Awareness Communication of chromium (VI) hazards to employees • Chemical manufacturers, importers, distributors and employers shall comply with all requirements of the Hazard Communication Standard (HCS) (§ 1910. 1200) for chromium (VI). PPT-141 -01 60

Hazard Awareness In classifying the hazards of chromium (VI) at least the following hazards are to be addressed: • Cancer, • Eye irritation • Skin sensitization PPT-141 -01 61

Hazard Awareness Employers shall include chromium (VI) in the hazard communication program established to comply with the HCS (§ 1910. 1200). Ensure that each employee has, • Access to labels on containers of chromium (VI) • Access to safety data sheets • Is trained in accordance with the requirements of HCS and paragraph (l)(2) of this section PPT-141 -01 62

Information & Training The employer shall ensure that each employee can demonstrate knowledge of at least the following: • Contents of this section • Purpose and description of the required medical surveillance program • A copy of this section shall be made readily available without cost to all affected employees PPT-141 -01 63

Summary Enhance the safety of employees who use hexavalent chromium compounds through: • • The implementation of a safety program Proper administrative procedures Special work practices and Required PPE. PPT-141 -01 64

Contact Information Health & Safety Training Specialists 1171 South Cameron Street, Room 324 Harrisburg, PA 17104 -2501 (717) 772 -1635 RA-LI-BWC-PATHS@pa. gov Like us on Facebook! - https: //www. facebook. com/BWCPATHS PPT-141 -01 65

Questions PPT-141 -01 66

Bibliography 1910 Occupational Safety & Health Standards, Subpart Z – Toxic and Hazardous Substances, 29 CFR 1910. 1026 – Chromium (VI) NIOSH Pocket Guide to Chemical Hazards, DHHS, CDC, September 2007. Sax, N. Irving and Richard J. Lewis, Sr. , Hazardous Chemicals Desk Reference, Van Nostrand Reinhold Company, New York, 1987. PPT-141 -01 67

Bibliography https: //www. osha. gov/dts/chemicalsampling/data/CH _228697. html OSHA Publication 3373 -10, 2009, “Hexavalent Chromium” https: www. osha. gov/SLTC/hexavalenchromium/index. html “Small Entity Compliance Guide for the Hexavalent Chromium Standards, ” OSHA 3320 -10 N, 2006 http: //www. cdc. gov/niosh/npgd 0138. html PPT-141 -01 68