Chromium is a naturally occurring metal that can be found in many metal alloys and salts. It is even used as a dietary supplement in over-the-counter preparations. Occupational exposures to chromium can occur in the form of dusts, fumes and mists – including total chromium, trivalent chromium (III), hexavalent chromium (VI), chromic acid, chromates and dichromates. In 1976 the National Institutes of Occupational Safety and Health (NIOSH) published its Criteria for Recommended Standard for Occupational Exposure to Chromium VI based on its carcinogenicity. The International Agency for Research on Cancer has listed Chromium VI as a carcinogen based on an association with lung cancer. Following their rulemaking process in 2006, the Occupational Safety and Health Administration (OSHA) issued their comprehensive standards for Chromium VI. It is one of a handful of standards for health hazards issued by OSHA that have many requirements for employers beyond just establishing eight-hour time-weighted-average (8Hr-TWA) permissible exposure limits (PELs).
Uses of Chrome VI
Chrome VI is used as a pigment in paints and in various applications for its resistance to
corrosion. Spray painting of planes and ships was a common use of Chrome VI being
applied as a mist. It is also applied to bridges and structures exposed to saltwater.
Cutting or grinding on these surfaces can release airborne dust and fumes. Stainless
steel commonly contains Chrome VI; so hot work will generate Chrome VI fumes, and
grinding or cutting can produce airborne dust. Chrome VI is also used in the plating
industry for coating metal parts with chromic acid as well as many other applications.
What Are the Steps for OSHA Compliance
The first step for employers is to review the Safety Data Sheets for chemicals, products and base materials used in their facilities for the presence of Chrome VI. If present, then an industrial hygiene air sampling plan will need to be developed and implemented with samples analyzed by an AIHA-accredited laboratory – following the strict rules for rapid handling and analysis. The results will then be compared to the OSHA action level of 2.5 micrograms per cubic meter of air (ug/m3) and PEL of 5.0 ug/m3 for 8Hr-TWA exposures.
If the results are at or over the action level, the air monitoring will need to be repeated every six months until such time that two rounds of testing have results below the action level. Employees that are exposed will require training on the health hazards (lung cancer, cancer, and damages to the nose and nasal passageways) of Chrome VI, results of the air testing, steps they can take to reduce exposures, proper use of personal protective equipment (PPE), and the need to employ good hygiene practices. If employees are exposed above the action level for more than 30 days per year, the OSHA standard also calls for a medical surveillance program for those employees.
If the results are at or over the PEL, the air monitoring will need to be repeated every three months until such time that two rounds of testing have results below the PEL. In addition to the steps listed above, the use of respiratory protection, medical evaluations, and using change rooms and showers to minimize skin contact will be required. The employer will also have to document steps being taken to reduce exposures to Chrome VI. These may include substitution of materials with no or less Chrome VI content, engineering controls (such as localized or general ventilation) and proper housekeeping efforts. Many welding and brazing systems can be equipped with close-capture ventilation. Work surfaces will need to be maintained as free as practical from the accumulation of Chrome VI. Work areas with potential exposures at or over the PEL will need to be demarcated as “regulated areas” – which indicates PPE is required and decontamination is a must when leaving the regulated area before putting on street clothing, eating, drinking, smoking or applying cosmetics.
Other OSHA standards may also be applicable to Chrome Vi exposures – including Hazard Communication; Dipping and Coating Operations; and Ventilation in Welding, Cutting and Heating (hot work) Operations.
Conclusion
Compliance with OSHA’s comprehensive standard for occupational exposure to Chrome VI is critical in protecting long-term worker health. Training is a vital component, so that workers understand the health effects of overexposure to Chrome VI, proper use of engineering controls to reduce exposures, personal hygiene requirements, and the proper use of selected PPE. Based on exposure levels, medical surveillance by trained occupational health professionals may be required. Employers will also need to rely on an industrial hygienist
to assist with the proper evaluation of airborne exposures to Chrome VI, as well as the design and evaluation of engineering controls such as localized exhaust systems. Exposure evaluations are required initially and depending on exposure levels repeated every three or six months.
HETI…Here to Help
HETI can help businesses comply with OSHA requirements, ensure safe workplaces, and avoid costly penalties. By offering customized training programs, employing expert trainers, ensuring comprehensive compliance documentation, and providing continuous support, HETI serves as an essential partner for businesses aiming to meet regulatory requirements and create safe working environments.
References:
Small Compliance Guide for Hexavalent Chromium OSHA 3320-10N
NIOSH Criteria for a Recommended Standard for Occupational Exposure to Chromium VI, 1975
SGS Galson Sampling Guide Hexavalent Chromium updated OSHA ID 125 for Hexavalent Chromium, 2006
OSHA 29 CFR 1910.1026 for General Industry, 1926.1126 for Construction and 1915.1026 for Maritime Industries
To find out more about this and other HETI industrial hygiene services, please contact us.
Dennis Francoeur, Jr., CIH, CSP, CMI
Senior Industrial Hygienist
Phone: 978.263.4044
development@hetiservices.com