Hexavalent Chromium Cr (VI)

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Hexavalent Chromium Cr (VI)

• National Emphasis Program

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New OSHA Instruction

• National Emphasis Program on
• Hexavalent Chromium
• Purpose To identify and reduce or eliminate
  the health hazards associated with occupational
  exposure to hexavalent chromium and other toxic
  substances in a select group of industries.

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Key Elements

• Information for selecting sites for inspection
• Procedures for conducting inspections with
  emphasis on IH evaluations
• Measures to ensure safety and health of OSHA
  compliance staff
• Program evaluation procedures
• Plans for outreach to train OSHA compliance staff
  and general public on hazards addressed by this
  NEP and effective abatement methods

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General Information

• Hexavalent chromium compounds all contain the
  chromium (6) ion (CAS 18540-29-9)
• Also written as Chromium (VI) or Cr(VI)
• Occupational Hazards
• Increased risk of lung cancer from inhalation
  exposures
• Irritation and sensitization to lungs, throat,
  nose, eyes, and skin

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What is Chromium (VI)?

• Toxic form of chromium metal that is generally
  man-made
• Exists as many types of CrVI compounds that vary
  in their solubility and use
• Used in many industrial applications primarily
  for its anti-corrosive properties

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What is Chromium (VI)?

• Chromium with valence of positive six, in any
  form or chemical compound in which it occurs
• CR(VI)? In all states of matter, any solution or
  other mixture, even if encapsulated by other
  substances
• Term also includes industrial process that
  creates Cr(VI) fumes

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How is Cr (VI) Formed?

• Created during hot work processes such as
  welding on stainless steel or the melting
  chromium metal

• Chromium metal is ionized into the fume? high
  temperatures and chemical reactions temporarily
  oxidizes the chromium ion into a hexavalent (6)
  state

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Hexavalent chromium compounds in industrial use

• Chromate pigments in dyes, paints, inks, and
  plastics
• Chromates added as anticorrosive agents to
  paints, primers, and other surface coatings
• Chromic acid electroplated onto metal parts to
  provide a decorative or protective coating

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Major Industries

• Chromium dye and catalyst production
• Glass manufacturing
• Plastic colorant production
• Construction
• Traffic painting
• Refractory brick restoration
• Paint removal from bridges

• Electroplating
• Welding on stainless steel or Cr(VI) painted
  surfaces
• Painting
• Aerospace
• Auto body repair
• Chromate pigment and chemical production

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Other Toxic Substances

• Number of toxic substances found to be present in
  same industrial applications where hexavalent
  chromium is or could be found

• Copper Fume
• Lead
• Iron Oxide
• Manganese

• Nickel
• Silver
• Tin
• Zinc Oxide

• Antimony
• Arsenic
• Cadmium
• Cobalt
• Calcium Oxide

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Program Procedures

• Industry Selection
• Inspection Scheduling
• Complaints and Referrals
• Voluntary Compliance Programs
• Strategic Partnerships
• Expanding Scope of Inspection
• Inspection Procedures
• Outreach
• Follow-Up and Monitoring
• Coordination
• Federal Agencies
• NEP Evaluation
• IMIS Coding Instructions

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Industry Selection

• Appendix A
• List of SIC Codes for industries determined
  likely to have employees exposed to Cr (VI) and
  other toxic substances
• Not a comprehensive list, but intended as primary
  source
• Industries not in Appendix A
• Known by Area Office, based on local knowledge
  may be added
• AO must document the addition and maintain such
  documentation for the duration of NEP

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Industry Selection

• Master List Generation
• Using DB employer listing, the Office of
  Statistical Analysis (OAS) will prepare master
  list for each AO
• Targeting Sources
• AOs may consider local sources including local
  manufacturing/services directories, telephone
  listings, local knowledge, and previous
  inspection history
• Establishments with fewer than 10 employees shall
  also be included

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Industry Selection

• Deletions
• AOs shall delete from inspection target list any
  facilities
• Not likely to have Cr (VI) hazards
• Known to be out of business
• Which have had health inspections in preceding
  two years addressing Cr (VI) and other toxic
  substance hazards, provided
• no citations were issued or
• that citation(s) were issued, but follow up
  inspection documented tangible appropriate and
  effective efforts to abate the serious hazards
  cited or OSHA received and confirmed that
  violations have been abated.

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Industry Selection

• Cycle Generation
• Sequential Number will be assigned
• After randomizing list, AO will create inspection
  cycles of five (5) or more establishments
• Subsequent cycles will be created until
  expiration of NEP or until all establishments on
  list have been assigned to a cycle
• When AO becomes aware of previously known
  establishment in one of targeting SICs, that
  establishment shall be added to master inspection
  targeting list for inclusion in selection process
  for next inspection cycle

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Inspection Scheduling

• May be scheduled in any order to make efficient
  use of resources
• Cycle must be completed before another cycle is
  started (except that establishment may be carried
  over in accordance with OSHA Instruction CPL
  02-00-025.)
• Beginning with current fiscal year
• Will continue until further notice or until all
  on list have been inspected
• Some establishments selected for inspection under
  this NEP may also be selected for inspection
  under current Site-Specific Targeting (SST) Plan
  or other NEPs and/or LEPs

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Inspection Scheduling

• Some targeted industries for this NEP overlap
  with other NEPs including those currently
  targeting combustible dust, lead, amputations and
  silica
• When possible, NEP inspection should be conducted
  concurrently with SST or other programmed
  inspections

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Complaints and Referrals

• General Industry
• Must be handled in accordance with procedures
  outlined in CPL 02-00-140- Complaint Policies and
  Procedures
• Considered high-gravity, serious and handled by
  inspection
• Construction
• Document status/condition of work operation,
  noting any serious hazard(s). (Documentation of
  events leading up to observation must be
  maintained in file.)
• Note location of worksite and name/address of
  employer(s) performing operation
• Handle in accordance with procedures in CPL
  02-00-140, Complaint Policies and Procedures and
  OSHA FOM, CPL 02-00-148
• When safety CSHO encounters site where Cr(VI)
  exposures may exist during course of any
  construction inspection, appropriate health
  referrals will be made

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Voluntary Compliance Programs

• Employers participating may be exempt from
  programmed inspections
• If establishment participates in VPP or SHARP?
  Follow procedures outlined in OSHA FOM (CPL
  02-00-148), Chapter 2

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Strategic Partnerships

• Shall be conducted in accordance with terms
  outlined in partnership agreement
• May be exempt from programmed inspection for six
  (6) months,
• or
• May qualify for focused (or limited scope)
  inspection

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Expanding Scope of Inspection

• May expand the scope of inspection under this NEP
  if other hazards or violation conditions are
  observed and/or brought to their attention
• CSHO shall follow guidelines in FOM when
  expanding scope of inspection

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Inspection Procedures
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Search OSHA/IMIS database for employer citation
fatality/ accident history prior to assignment of
inspection
CSHO determines if any other current NEP such as
amputations, combustible dust, lead or silica,
etc.
Inspection scheduled for identified establishment
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SIC Code NOT listed in Appendix A? Exit facility
without conducting inspection
At opening conference, CSHO verify w/ employer
correct SIC code for establishment
SIC Code NOT listed in Appendix A, but determined
employees using materials containing Cr(VI) or
other toxic substance ? Proceed with programmed
inspection

• CSHO to consider evaluate employee exposures
  compliance in regard to
• Regular Operations
• Setup preparation for regular operations
• Clearing process upsets
• Making Adjustments during operations
• Cleaning of process area
• Scheduled unscheduled maintenance
• Implementation of engineering controls
• Use of PPE
• Medical Surveillance programs
• Employee training education

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CSHO will verify w/ employer any process that may
produce Cr(VI) or other toxic substance exposures
are conducted at facility
Proceed with inspection with particular attention
to employee exposure to Cr(VI) or other toxic
substances
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Inspection Procedure
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If exposure monitoring is not conducted? A
thorough explanation for not monitoring is to be
included in inspection file
IH shall take properly calibrated instruments and
sampling media with them on FIRST day of
inspection
When present, MUST include personal exposure
monitoring in ALL cases
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If determined that operations with exposure to
Cr(VI) or other toxic substances are NOT present,
but establishment listed in another current NEP,
CSHO shall proceed with comprehensive inspection
If safety hazards are noted that cannot be
appropriately dealt with by IH CSHO, an
appropriate safety referral will be made
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ALL potential hazards observed in course of any
inspection conducted under this NEP shall be
appropriately addressed
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Protection of CSHOs

• Shall conduct hazard determination to establish
  presence of Cr (VI) (or other toxic substances)
  PRIOR to initiating the walk around
• Rely on information such as previous inspection
  history, material safety data sheets,
  professional judgment, and/or previous exposure
  monitoring surveys
• Personal Protective Equipment (PPE) to be used
  during inspection such as Respirators, gloves
  and/or protective clothing (made available to
  CSHOs prior to inspection) and WILL be worn
  based on CSHOs determination of their expected
  exposure to hazard
• Additional information can be found in Appendix B
• Any equipment utilized during course of any
  inspection initiated under this NEP should be
  appropriately decontaminated

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Outreach

• Letters
• Employers
• Professional Associations
• Local Safety Councils
• Apprenticeship Programs
• Local Hospitals and Occupational Health Clinics
• Industry Employer Organizations
• Speeches
• Training Sessions
• News Releases
• Regional/Area Office Alliances

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Outreach

• Directorate of Science, Technology and Medicine
  has prepared materials
• Variety of online resources
• www.osha.gov
• Technical link page specific to hexavalent
  chromium under the alphabetical Site Index

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Follow-Up and Monitoring

• Follow up inspections conducted for all cases
  with documented
• Exposures above any permissible exposure level
  (PEL)
• Employer has failed to take appropriate action
• Follow up inspection conducted within three
  months after the final abatement date for cited
  violations

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Follow-Up and Montoring

• CSHO shall verify employers abatement
  documentation/verification by carefully
  evaluating any and all
• Air monitoring results
• Implemented engineering controls
• Personal Protective Equipment requirements
• Housekeeping and employee information
• Training
• In accordance with FOM, Chapter IX.A.

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Follow-Up and Monitoring

• Personal air sampling- Conducted by OSHA staff in
  ALL situations, unless job task or job site is no
  longer active
• Use of employer generated monitoring data is NOT
  permitted for purpose of abatement verification
  under this NEP.

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Follow-Up and Monitoring

• Abatement documentation/verification will be
  submitted to/collected by the Area Office
• Abatement information MUST be included in case
  file in a timely manner
• When possible, case file to be closed in the
  fiscal year in which intervention was conducted
  to allow the data to be applied to Agencys
  Strategic Goal accomplishments
• Cases where implementation of engineering
  controls extend beyond fiscal year, case file
  will be closed as soon as possible

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Coordination

• National Office
• Coordinated by the Office of Health Enforcement
  (OHE), Directorate of Enforcement Programs (DEP)
• Field Office
• Each Regional Administrator is required to name a
  coordinator for this NEP

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Federal Agencies

• Executive Order 12196, Section 1-201, and 29 CFR
  1960.16 requires Federal Agencies to follow the
  enforcement policy and procedures contained in
  this Directive

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NEP Evaluation

• Evaluated using data collected from case files
  and follow-up site visit reports submitted by
  each Area Office to the OHE
• Interim, current method used by Office of
  Statistics will continue to apply
• Once Office of Statistics has received reasonable
  number of case files and follow-up site visit
  reports, data will be evaluated to determine
  impact of OSHA inspections on reduction of
  hexavalent chromium exposures at each workplace

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IMIS Coding Instructions

• All enforcement activities (inspections,
  complaints, and referrals) and compliance
  assistance (OSHA 55) conducted under this NEP
  must be coded with the NEP code
• Chrome6
• Entered in appropriate NEP field/item number on
  respective form

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Sampling Information

• Two types of filters available for Air Sampling
• PVC Filters
• Sodium Hydroxide (NaOH) Coated Quartz Fiber
  Filter
• PVC filters can be used for all hexavalent
  chromium air sampling but must be analyzed within
  six (6) days. Overnight mail recommended
• NaOH quartz filters can only be used for plating
  operations where a mineral acid chemical
  interference could occur. These do not need to
  be sent overnight

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Additional Sampling Information

• Wipe samples for must be taken on PVC or Quartz
  Fiber Filters
• DO NOT USE Mixed Cellulose Ester (MCE), Ghost
  Wipes, Smear Tabs or Whatman Filters (these will
  react with any Cr(VI) changing it to Trivalent
  Chrome)
• You can order filters from lab using LISA or
  order by phone

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Air Monitoring Job Aid
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Air Monitoring Job Aid
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Wipe Sampling Job Aid
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Appendix A- List of Selected Industries
(A)- SIC targeted by the Amputation NEP (L)- SIC
targeted by the Lead NEP
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Appendix B-Field Hazard Bulletin

• See OSHA Instruction
• (NEP- Hexavalent
• Chromium) for this
• form

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Appendix C-List of Other Toxic Substances Often
Found in Conjunction with Hexavalent Chromium

• Lead
• Iron Oxide
• Manganese
• Nickel
• Silver
• Tin
• Zinc Oxide

• Antimony
• Arsenic
• Cadmium
• Calcium Oxide
• Cobalt
• Copper Fume