Hexavalent Chromium Cr (VI)

National Emphasis Program

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.”

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

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

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

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

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

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

Major Industries

• Electroplating

• Welding on stainless steel or Cr(VI) painted surfaces

• Painting – Aerospace– Auto body repair

• Chromate pigment and chemical production

• Chromium dye and catalyst production

• Glass manufacturing

• Plastic colorant production

• Construction– Traffic painting– Refractory brick restoration– Paint removal from bridges

Other Toxic Substances

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

•Antimony

•Arsenic

•Cadmium

•Cobalt

•Calcium Oxide

•Copper Fume

•Lead

•Iron Oxide

•Manganese

•Nickel

•Silver

•Tin

•Zinc Oxide

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

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

Industry Selection• Master List Generation

– Using D&B 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

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.

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

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

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

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

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

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

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

Inspection Procedures

Inspection scheduled for identified establishment

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.

At opening conference, CSHO verify w/ employer correct SIC code for establishment

CSHO will verify w/ employer any process that may produce Cr(VI) or other toxic substance exposures are conducted at facility

SIC Code NOT listed in Appendix A Exit facility without conducting inspection

SIC Code NOT listed in Appendix A, but determined employees using materials containing Cr(VI) or other toxic substance Proceed with programmed inspection

Proceed with inspection with particular attention to employee exposure to Cr(VI) or other toxic substances

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

Inspection Procedure

When present, MUST include personal exposure monitoring in ALL cases

If exposure monitoring is not conducted A thorough explanation for not monitoring is to be included in inspection file

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

ALL potential hazards observed in course of any inspection conducted under this NEP shall be appropriately addressed

If safety hazards are noted that cannot be appropriately dealt with by IH CSHO, an appropriate safety referral will be made

IH shall take properly calibrated instruments and sampling media with them on FIRST day of inspection

Protection of CSHO’s• 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 CSHO’s prior to inspection) and WILL be worn based on CSHO’s 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

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

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”

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

Follow-Up and Montoring

• CSHO shall verify employer’s 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.

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.

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 Agency’s Strategic Goal accomplishments

• Cases where implementation of engineering controls extend beyond fiscal year, case file will be closed as soon as possible

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

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

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

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

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*

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

Air Monitoring Job Aid

AIR MONITORING

For sample stability, use NaOH coated Quartz fiber filters when sampling chromium plating operations. The sodium hydroxide coated binderless quartz fiber filters, used to test for hexavalent chromium, come in an aluminized zip-lock type of bag. These are the same bags used to put the ozone samplers in, so there have been some mix-ups in the field. The bags will be clearly labeled so make sure you read the label and choose the right sampler.

Notes: The NaOH neutralizes the acids used in the plating operation so the Chrome VI sample stays

stable. If you have to use a PVC filter, get it to SLTC Lab within 24 hours. In tests at SLTC, it was found

that there is a 10% loss of Chrome VI (using PVC filters) if analysis was conducted 6 days after sample was taken (from chromium plating operations).

Q: Are there are 25-mm PVC filters available for sampling hexavalent chromium? These are needed to fit under the welding helmets.

A: Yes, SLTC has 25-mm PVC filters available for sampling hexavalent chromium, and the OSHA method was validated for both the 25-mm and 37-mm cassettes.

Note: It’s important to submit welding samples as soon as possible. In tests at SLTC, it was found that there is a 10% loss of Chrome VI (using PVC filters) if analysis was conducted 8 days after sample was taken (from welding operations). The reason: Fe+3 in steel turns Chrome VI to Chrome III.

Air Monitoring Job Aid Air sampling around welders and in grinding operations are more difficult because the sampling

cassettes become overloaded when sampling for hexavalent chromium. Overloaded samples may clog the pores in the filter, stopping the ability of the pump to function properly.

It may be necessary to use several cassettes to collect samples if sampling employees over a long period of time. There is enough sensitivity in the method that a sample for as little as 2 hours may be taken.

o In welding operations, the filter will look totally brown when it is getting loaded and needs to be replaced with a fresh cassette.

o In grinding or blasting operations, change the cassette when you cannot see the filter anymore.

Q: How do you get the sampling cassette to stay in place under the welding helmet as the welders perform their jobs?

A: Suggestions: Route copper tubing through the sample tubing to provide rigidity to the assembly. Hold things in place with duct tape. There are helmet cassette holders available from SKC - helmet cassette holders can be obtained

thru CTC’s AESP (FES0001035).

Q: Can sample results for hexavalent chromium be put up on the LISA website? A: Yes, SLTC will put the hexavalent chromium results in with the lead and silica results on LISA.

Wipe Sampling Job Aid

WIPE SAMPLING

Wipe samples for hexavalent chromium should be taken with either PVC filters or binderless quartz fiber filters.

Do not use the ghost wipes to collect hexavalent chrome. The chemicals on the ghost wipe and the fabric base destroys the hexavalent chromium collected. In tests at SLTC, it was found that a surface spiked with 100 ug hexavalent chromium and wiped with a ghost wipe had a result of none detected 24 hours later!

Do not use Whatman filters or smear tabs to collect hexavalent chromium as they react with the hexavalent chromium changing it to trivalent chromium. This occurs at a rate of 20% per day.

Validated direct reading wipe test kit for hexavalent chromium is available from CTC to aid in evaluating surface exposures. It has a dramatic indication changing to a bright pink-purple in the presence of hexavalent chromium and has been helpful to convince workers that they have hexavalent chromium in break rooms, desks, etc.

Note: One CSHO was having trouble convincing the employer and workers that there were high exposures to hexavalent chromium, as high as 251 ug hexavalent chromium on a microwave in a break room. The CSHO took samples with this test kit and showed them on-site the problem areas.

When handling the filters for wipe testing or making up cassettes for hexavalent chromium sampling, use plastic tweezers available from SLTC and CTC. The chromium from steel tweezers will be transferred and contaminate the filter, so metal tweezers should not be used. You can request plastic tweezers from SLTC.

Appendix A- List of Selected Industries

SIC Description

2819 (L) Industrial Inorganic Chemicals

7692 Welding & Repair

3732 Boat Building

3721 Aircraft Parts

3713 (L) Truck and Bus Bodies

2821 (L) Plastic Materials and Resins

3325 (A) Steel Foundries, NEC

3714 (A) Motor Vehicle Parts

3479 Metal Coating

3471 Plating

(A)- SIC targeted by the Amputation NEP

(L)- SIC targeted by the Lead NEP

Appendix B-Field Hazard Bulletin

See OSHA Instruction

(NEP- Hexavalent

Chromium) for this

form

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

• Antimony

• Arsenic

• Cadmium

• Calcium Oxide

• Cobalt

• Copper Fume

• Lead

• Iron Oxide

• Manganese

• Nickel

• Silver

• Tin

• Zinc Oxide