Respiratory Protection and OSHA's New Hexavalent Chromium Standards: You Have Questions. We Have Answers

Occupational Hazards, March 2007 | Go to article overview

Respiratory Protection and OSHA's New Hexavalent Chromium Standards: You Have Questions. We Have Answers


On Feb. 28, 2006, OSHA published final standards for occupational exposure to hexavalent chromium (Cr[VI]). The new permissible exposure limit (PEL) for Cr(VI) is 5 micrograms of Cr(VI) per cubic meter of air (5 [micro]g/[m.sup.3]) as an 8-hour time-weighted average (TWA).

As with any new standard, there are questions on how to best protect workers from exposure to the hazard until engineering controls can be put into place. The Cr(VI) standards cover general industry, construction and shipyards. The respiratory protection requirements for the three industries are similar. The standards require employers' respiratory protection programs--including respirator selection--to follow OSHA 1910.134 requirements.

For a complete copy of the standards, please refer to OSHA's Web site at http://www.osha.gov/SLTC/ hexavalentchromium/index.html.

Q: What is hexavalent chromium?

A: Hexavalent chromium is a metal particle that naturally can occur in rocks, but it is most commonly produced by industrial processes. It has the ability to gain electrons from other elements--it is a strong oxidizer--which means it easily can react to other elements. Because of its ability to react with other elements, it can produce hard coatings, which is why it is used in paints for cars, boats and aircraft.

Q: What type of contaminant is hexavalent chromium?

A: Cr(VI) is a metal particle. It can be filtered with an N95 filter or an R or P95 filter if oil mist is present.

Q: What Cr(VI) exposures are covered in the standards?

A: Cr(VI) exposures from any source are covered except:

* Portland cement.

* Applications of regulated pesticides such as treatment of wood with pesticides. Exposures resulting from sawing or sanding treated wood are covered by the standard.

* Where the employer has objective data demonstrating that a material containing chromium or a specific process, operation or activity involving chromium cannot release dusts, fumes or mists of chromium in concentrations above 5[micro]g/[m.sup.3] in an 8-hour TWA under any expected conditions of use.

Q: What are the main industries affected?

A: The primary industries affected, according to OSHA, are stainless steel fabrication, heavy-duty coatings and paints, electroplating and chrome-based pigment production.

Q: What are the main applications affected?

A: Welding (especially stainless steel), spraying heavy-duty coatings and paints and electroplating.

Q: When must I be in compliance?

A: Employers with 20 or more employees had to be in compliance by November 2006. Employers with 19 employees or fewer must be in compliance by May 30. Engineering controls, if they are determined feasible or necessary, must be in place by May 31, 2010. Until engineering controls are in place, respiratory protection must be used to help reduce exposure.

Editor's note: On Oct. 30, 2006, OSHA published a "minor amendment" to the Cr(VI) standard, allowing metal- and surface-finishing operations that chose to participate in a settlement agreement with the agency to have "relief from certain respirator requirements in the interim" if they agreed to implement engineering controls by Dec. 31, 2008. At press time, a lawsuit filed by Public Citizen Health Research Group and several other groups challenging OSHA's Cr(VI) standards was pending in the 3rd U.S. Circuit Court of Appeals.

Q: How does this affect me?

A: Employers must reassess their respirator programs, taking into consideration the lower exposure limit. More employers may have to provide respiratory protection to employees and assess the feasibility of engineering controls such as ventilation. …

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