L1608 C12 - School of Engineeringengr.uconn.edu/~baholmen/docs/ENVE290W/National Chromium Files F… · L1608_C12.fm Page 489 Monday, ... Cr plating regulations were enforced in selected

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12

Chromium Policy and Regulations

CONTENTS

12.1 U.S. Chromium Policies and Regulations ............................................49012.1.1 Industrial History of Chromium .............................................49012.1.2 Waste Regulations ......................................................................49112.1.3 Air Regulations...........................................................................49212.1.4 Drinking Water Regulations.....................................................492

12.1.4.1 Recent Developments in California Policy............49412.1.5 Setting Drinking Water Standards:

The Regulatory Process .............................................................49712.1.6 Review and Revision of Drinking Water Standards ............49912.1.7 Regulatory Implications of Drinking Water Standards .......50112.1.8 Beyond Regulations ...................................................................50112.1.9 Case Study: Glendale, California.............................................50212.1.10 Other Impacted Regions ...........................................................503

Bibliography ........................................................................................................50312.2 Worldwide Chromium Regulations ......................................................504

12.2.1 Overview of Chromium Regulatory Agencies......................50412.2.1.1 European Union .........................................................50412.2.1.2 Japan.............................................................................50512.2.1.3 South Africa ................................................................50512.2.1.4 United States...............................................................506

12.2.2 Air Quality...................................................................................50612.2.3 Water Quality ..............................................................................50912.2.4 Soil Quality..................................................................................51012.2.5 Waste Disposal............................................................................51012.2.6 Work Place Exposure ................................................................. 511

12.2.6.1 Labeling of Packages and Containers .................... 51112.2.6.1.1 European Union ..................................... 51112.2.6.1.2 United States...........................................513

12.2.6.2 Material Safety Data Sheets (MSDS).......................51312.2.6.2.1 European Union .....................................51312.2.6.2.2 United States...........................................514

12.2.6.3 Induction and Training of Employees....................51512.2.6.4 Environmental Control and Monitoring ................515

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Chromium(VI) Handbook

12.2.6.4.1 European Union .....................................51612.2.6.4.2 Japan ........................................................51712.2.6.4.3 South Africa ............................................51812.2.6.4.4 United States...........................................518

12.2.6.5 Chemical Management .............................................51812.2.7 Product Stewardship..................................................................51912.2.8 Tools..............................................................................................519

12.2.8.1 Life Cycle Inventory/Life Cycle Assessment(LCI/LCA)...................................................................519

12.2.9 International Standards Organization (ISO)..........................52012.2.10 Ecolabeling ..................................................................................520

Bibliography ......................................................................................... 521

12.1 U.S. Chromium Policies and Regulations

Elisabeth L. Hawley and James Jacobs R.G.

12.1.1 Industrial History of Chromium

Chromium (Cr) is an elemental metal that is used for a variety of industrialpurposes, including metal plating, wood treatment, paint production, leathertanning, and corrosion inhibition in cooling towers. A brief summary ofhistorical uses of chromium for industrial purposes is described here. A moredetailed description can be found by referencing the International ChromiumDevelopment Association (ICDA, 2001).

The modern era of metal surface finishing began with the invention ofelectrolytic solutions and the galvanic dipping cells in the early 1800s. By themiddle of the 19th century, chromium (Cr), silver (Ag), gold (Au), copper (Cu),and brass plating was commercially performed. The first plating efforts werefocused on decorations, jewelry, lamps, and hardware. Large metal parts weremanufactured using an electroplating method called electroforming. With thevariety of mechanical devices and the generation of electrical generators pro-duced in late 1800s, electroplating became even more widespread. Metalmachine components, hardware, and automotive parts were protected fromthe elements and harsh conditions by Cr plating.

Owing to the hardness and surface sealing qualities, Cr plating providedcorrosion-enhanced properties, and enhanced appearance. The aircraftindustry in World War I and II further developed and refined the Cr platingindustry by adding such processes as anodizing, conversion coating, Crplating, bronze alloy plating, nickel plating, chemical milling and phosphate



491

treating, along with numerous other plating processes. Plating equipmentoriginally consisted of manually operated wooden process dip tanks. Theprocess evolved into automated equipment, capable of processing thousandsof kilograms per hour of parts (ref).

The war years of 1940 to 1945 created a need for military use of metals.Metals rationing was commonplace and there was a general lack of platedluxury and metal-containing household items at this time. With the conclusionof World War II, plating of household and luxury items increased greatly.During the 1950s, Cr plating was found in building materials, furniture,fixtures, car bumpers, radios, and other consumer goods. New processeswere developed for Cr surfacing such as electro-painting, electro-lessplating, electro-polishing, vacuum metalizing, mechanical plating, elec-trostatic painting, electrolytic painting, and powder coating (ref).

12.1.2 Waste Regulations

Before the formation of the U.S. Environmental Protection Agency (USEPA)in 1970, the Cr plating industry was not subject to Federal environmentalregulations. Instead, Cr plating regulations were enforced in selected areasof the U.S. with local ordinance. For example, in 1969, the Chicago Metro-politan Sanitary District passed a law regulating the discharge of concen-trated chemicals, including Cr and Cr wastes from the finishing process, tothe sewer system and to surface waters (ref).

In 1970 the USEPA was formed, creating regulations for industrial dis-chargers to the surface waters of the U.S. under the Water Pollution ControlAct (WPCA; Public Law 92-500). By 1977, Congress had given the USEPApower to regulate sewer discharges under the Clean Water Act (CWA; PublicLaw 95-217). Under the direction of Congress, USEPA passed regulationslimiting mass and concentrations of pollutants that could be present inwastewater discharged by industries. The USEPA also studied and providedtechnical information on technologies that could be employed to complywith the new regulations.

The EPA regulated chromium discharges by requiring the installation ofpretreatment systems. These pretreatment systems were designed toremove heavy metals based on expected flowrate. In addition, the 1976Resource Conservation and Recovery Act (RCRA) required the Cr platingand manufacturing industry to treat and dispose off wastes generated fromsurface finishing operations and pretreatment systems in an environmen-tally sound and appropriate manner. RCRA required generators to estimatewaste volumes and record acquisition, discharge, sales etc. in their inven-tories. In response to the increased cost of waste handling and disposal, theCr plating and manufacturing industry responded by developing alternateprocesses that generated less waste or less toxic waste. Pretreatment systemswere developed that recycled/recovered chromium or employed waterconservation.

Au: Please cite the referred ref. here and else where in text


492


With the 1980 Comprehensive Environmental Response, Compensationand Liability Act (CERCLA), more regulations and financial responsibilitieswere placed on chromium generators, transporters and disposers. The Super-fund Amendments and Reauthorization Act of 1986 (SARA) provided morefunds for cleanup of the most polluted properties in the nation, 306 of whichcontained Cr as a major contaminant (ref).

12.1.3 Air Regulations

Like the first wastewater regulations, the first air quality regulations underthe 1963 Clean Air Act (CAA) required metal industries to remove Cr dustfrom air exhaust streams with technology controls. The USEPA uses broadcategories for specific industries, rather than numerical emission standards,and defines a maximum achievable control technology (MACT) standard foreach industry. MACT standards are based on performance of technologiesinstalled in similar facilities.

In 1970, the Occupational Safety and Health Act (OSHA, Public Law 91-596) set up two new Federal agencies designed to monitor and protectworkers from injury and illnesses. Both agencies developed numerical cri-teria for airborne Cr concentrations. The Office of Safety and Health Admin-istration (OSHA) published legally binding standards known as PermissibleExposure Limits (PELs). The National Institute of Occupational Safety andHealth (NIOSH) independently evaluated and published risk-based guide-lines for workers.

The Office of Safety and Health Administration set the PEL ceiling forCr(VI) compounds at 100

m

g/m

3

measured as CrO

3

. Concentrations of Cr(II)and Cr(III) salts are regulated at 500

m

g/m

3

as an 8-h time-weighted average(TWA). Cr metals and insoluble salts are regulated at 1000

m

g/m

3

8-h TWA(NIOSH, 2004).

The National Institute of Occupational Safety and Health recommendedthat exposure to Cr(VI) compounds should be limited to 1

m

g/m

3

10-h TWA,and that Cr metal, Cr(II), and Cr(III) compounds be limited to 500

m

g/m

3

10-h TWA. NIOSH considers all Cr(VI) compounds potentially carcinogenicbased on current evidence (NIOSH, 2004). A summary of air quality regu-lations is shown in Table 12.1.1.

12.1.4 Drinking Water Regulations

Federal involvement in establishing public drinking water regulations beganwith the Public Health Service Act (PHSA) in 1912. Under this act, drinkingwater supplies used by interstate buses, trains, airplanes, and ships weresubject to water quality guidelines, which focused primarily on preventingmicrobial diseases. The PHSA established guidelines for all public watersupplies, but did not have enforcement power beyond the realm of interstatecarriers. The first guideline was developed in 1914, limiting coliform bacteria



493

to a count of 2 per 100 ml. In 1925, 1946, and 1962, standards were addedfor inorganics and dissolved solids, followed by synthetic detergents, radio-activity, and more inorganics. By 1962, 28 substances were regulated(National Research Council, 1999).

Chromium was first included in drinking water regulations in 1942, whenthe PHSA specified that Cr salts could not be used for drinking water treat-ment. Cr was known to damage people’s health, including their skin (chromicacid, H

2

CrO

4

, is corrosive), nasal tissue, respiratory tract, eyes, and kidneys(Akatsuka and Fairhall, 1934; Bloomfield and Blum, 1928; Blair, 1928; Carter,1929; Hunter and Roberts, 1932; Lieberman, 1941). It was also linked to lungcancer (Shimkin and Leiter, 1940). This knowledge was mostly gained fromoccupational exposure studies, in addition to accounts of accidental ingestion.

In 1974, the PHSA was revised to become the Safe Drinking Water Act(SDWA), enforceable for all public water supplies on the basis of the federal

TABLE 12.1.1

Air Quality Regulations and Guidelines for Chromium

DescriptionConcentration

(

m

g/m

3

) Guideline Agency

Workplace

Insoluble Cr(VI) compounds, TWA 10 Advisory ACGIHWater-soluble Cr(VI) compounds, TWA 50 Advisory ACGIHCr metal and Cr(III) compounds, TWA 500 Advisory ACGIHChromic acid (H

2

CrO

4

) and all Cr(VI) salts,10-h TWA

1 Advisory NIOSH

Elemental Cr/Cr metal and Cr(II) and Cr(III) salts, 10-h TWA

500 Advisory NIOSH

Chromic acid (H

2

CrO

4

) and chromates (CrO

42–

), PEL ceiling level

100 as CrO

3

Regulatory OSHA

Cr(II) and Cr(III) salts, 8-h TWA PEL 5,00 Regulatory OSHAElemental Cr/Cr metal and insoluble salts, 8-h TWA PEL

1,000 Regulatory OSHA

General

Hazardous air pollutant NA Regulatory USEPACancer potency factor/unit risk for inhalation 0.012 Regulatory USEPA

Source:

Adapted from Toxicological Profile for Chromium (ATSDR, 2000).

ACGIH = American Conference of Governmental Industrial HygienistsATSDR = Agency for Toxic Substances and Disease RegistryNA = Not applicableNIOSH

=

National Institute for Occupational Safety and HealthOSHA = Occupational Safety Health AdministrationPEL = Permissible Exposure Limit; highest level of Cr in air to which a worker may be exposed

averaged over an 8 h day, unless otherwise noted (10 h day)TWA = Time weighted average for a normal workday and a 40 h workweek to which nearly

all workers may be repeatedly exposedUSEPA = U.S. Environmental Protection Agency


494


government’s duty to protect human health. States that wanted to maintainprimary control of environmental activities were given the option to establisha state EPA that would meet or exceed requirements passed by the USEPA.Many states set up a state EPA department and adopted the PHSA guidelines(last revised in 1962) as water quality standards. A total of 22 contaminantswere regulated under the SDWA, including 1 microbial standard and 21chemical compounds. The standard for total Cr was set at 50

m

g/l. TheUSEPA chose to regulate total Cr rather than Cr(VI) because Cr can beconverted from Cr(III) to Cr(VI), making an analytical determination ofCr(VI) susceptible to underestimating actual health risks.

The 1974 SDWA also specified the process for developing water qualitystandards, introducing the terms Maximum Contaminant Level Goal(MCLG) and Maximum Contaminant Level (MCL). The MCLG is the con-centration of contaminant at which no adverse health effects are expected.This concentration is determined from a synthesis of available epidemiolog-ical and toxicological research and appropriate safety factors. The MCL isthen determined for each contaminant after taking into account practicalconsiderations associated with drinking water treatment. The MCLG is agoal; the MCL is a regulatory standard. The MCL may be higher than theMCLG owing to an inability to detect the compound at MCLG levels, or totechnical and/or economic limitations to meeting MCLGs with availabletreatment technology. In the case of chromium, the MCL was equal to theMCLG.

Seventeen years later, in 1991, the USEPA replaced the interim MCL/MCLGof 50

m

g/l with a final standard of 100

m

g/l, based on the reasoning thatCr(VI) was not carcinogenic via oral ingestion, as was originally assumed,making the interim standard overly conservative. State EPA departments didnot follow the federal lead in revising their Cr MCLs, possibly owing in partto the political implications of raising an environmental water quality stan-dard (DHS, 2004). In 1996, when the World Health Organization (WHO)developed drinking water standards, it adopted the more conservative stan-dard of 50

m

g/l total Cr (WHO, 1996).Currently, the USEPA MCL for total Cr in public drinking water supplies

is 100

m

g/l (USEPA, 2004). Individual states may set stricter standards andmost states regulate either total Cr or Cr(VI) at 50

m

g/l (ASTDR, 2000).Recently, the drinking water standards for Cr have been more closely exam-ined. The assumptions used in determining the Cr standard have been ques-tioned, particularly in California, which is in the process of revising thestate’s Cr regulations.

12.1.4.1 Recent Developments in California Policy

In 1996, Congress passed amendments to the SDWA. In the State of California,these amendments included legislation to develop risk-based standards fordrinking water contaminants that were protective of human health. The newstandards, known as Public Health Goals (PHGs), are similar to MCLG values



495

but have more implications for California public water system operations.While MCLGs are typically zero for carcinogens, PHGs correspond to a one-in-a-million (10

–6

) cancer risk. Under the 1996 SDWA Amendment, California’sOffice of Environmental Hazard and Health Assessment (OEHHA) was respon-sible for determining PHGs. OEHHA is a California government departmentthat develops health guidance.

In February 1999, OEHHA published a startlingly low PHG of 2.5

m

g/ltotal Cr (OEHHA, 1999). OEHHA assumed that Cr(VI) should be consideredcarcinogenic by ingestion. Using results from a mouse study (Borneff et al.,1968), an acceptable concentration of 0.2

m

g/l Cr(VI) in drinking water wascalculated. Assuming that 7.2% of total Cr was Cr(VI), the acceptable amountof total Cr would then be 2.5

m

g/l. Combined with concurrent public interestin Cr spawned by the movie

Erin Brockovich

, public concern mounted overOEHHA’s recommendation. Numerous bills were introduced in the StateCongress to fund occurrence studies, investigate the difference between thefederal and state findings, and to amend the discrepancy. The federal MCLGof 50

m

g/l was questioned, as was the validity of its principalassumption—that Cr(VI) was not carcinogenic if orally ingested. Californiafaced two choices: (1) revise the OEHHA public health goal; or (2) revise thestate MCL.

In March 1999, the California EPA Department of Health Services (DHS)gave notice that it would be evaluating the MCL for total Cr to determineif the standard should be revised. DHS also announced its intention toidentify Cr(VI) as an unregulated chemical for which monitoring in publicwater systems is required. In October 2000, the Association of CaliforniaWater Agencies publicly announced that they would cooperate with DHSin collecting new information in support of a revised state MCL for Cr. Theyrecognized the potential for the state to require occurrence monitoring forCr(VI), in order to assess the cost of meeting a stricter MCL standard. DHSbegan certifying laboratories to perform Cr(VI) analyses. In January 2001,Cr(VI) had been added to the list of unregulated chemicals that requiredmonitoring in all vulnerable drinking water sources.

However, in March 2001, DHS asked the University of California toconvene an expert panel (Chromate Toxicity Review Panel) to assessOEHHA’s assumptions. DHS essentially asked OEHHA to revise the PHG,although technically they asked OEHHA to develop a Cr(VI)-specificPHG. The UC committee report concluded that OEHHA’s assumption ofCr(VI) carcinogenicity via ingestion was not scientifically based, owing toflaws in the 1968 Borneff study (Chromate Toxicity Review Committee,2001).

In November 2001, OEHHA withdrew the PHG and began the process ofdeveloping a Cr(VI)-specific PHG. DHS will use the new PHG to develop aCr(VI)-specific MCL by January 2004, in accordance with state bill SB351. Ifthe new PHG is drastically less than the current MCLG, California’s workcould impact federal Cr regulations and that of other states. A summary ofdrinking water regulations is shown in Table 12.1.2.


496


TABLE 12.1.2

Drinking Water Quality Regulations and Guidelines for Chromium

DescriptionConcentration

(

m

g/l) Agency Standard

Cr(VI) 50 WHO AdvisoryTotal Cr MCL 100 USEPA RegulatoryTotal Cr MCLG 100 USEPA AdvisoryTotal Cr in groundwater 50 USEPA RegulatoryWater quality criteriaFreshwater 11 USEPA RegulatorySaltwater 50Water and organism NAOrganism only NAHealth advisories for total Cr10 kg child, 1 day 100 USEPA Advisory10 kg child, 10 days 10010 kg child, longer term 20070 kg adult, longer term 80070 kg adult, lifetime 10070 kg adult, drinking water

equivalent level200

Bottled water limit for Cr 100 FDA RegulatoryCr drinking water standardsAlabama 50 States RegulatoryAlaskaArizonaColoradoConnecticutDelawareFloridaGeorgiaHawaiiIdahoIllinoisIowaKansasKentuckyMaineMarylandMassachusettsMinnesotaMississippiMontanaMissouriNebraskaNew Hampshire

Source:

Adapted from Toxicological Profile for Chromium (ATSDR, 2000).ATSDR = Agency for Toxic Substances and Disease RegistryFDA = Food and Drug AdministrationMCL = Maximum Contaminant LevelMCLG = Maximum Contaminant Level GoalNA = Not ApplicableTWA = Time weighted average for a normal workday and a 40 h workweek to which

nearly all workers may be repeatedly exposedWHO = World Health OrganizationUSEPA = U.S. Environmental Protection Agency



497

12.1.5 Setting Drinking Water Standards: The Regulatory Process

As apparent from drinking water standards summarized in Table 12.1.2,different regulatory agencies have set different regulations for chromium,raising some questions:

• What is the current process for setting the federal MCLG? • What process will California follow when setting the state MCL? • In the meantime, and for the rest of the country, how were the

current standards set? • Where did the concentrations 50 and 100

m

g/l originate, since theyare the basis for regulatory action?

These questions will be addressed in this section. The MCLG value for carcinogens is set at zero. For noncarcinogens, a

threshold value is assumed. After the typical threshold is defined, the accept-able 10

–6

risk is taken into account. So is the sensitivity of others (sick people,elderly people, pregnant women, and young children), and possible syner-gistic effects between that contaminant and others.

Toxicologists and others performed research about inhalation, ingestion,and dermal sorption exposure to Cr(VI). The following charts from theUSEPA show a summary of Cr exposures and symptoms (USEPA, ref).

The federal process of adopting new MCLs is essentially the same as thatof California. California Health and Safety Code § 116365(a) requires DHSto establish a contaminant MCL at a level as close to PHGs as is technicallyand economically feasible. The PHG for total Cr or Cr(VI) is the contami-nant’s concentration in drinking water that does not pose any significantrisk to health, derived from a human health risk assessment.

As part of the MCL development process, DHS evaluates the technical andeconomic feasibility of regulating Cr(VI). Technical feasibility includes anevaluation of commercial laboratories’ ability to analyze for and detect totalCr, Cr(VI), and Cr(III) in drinking water, the costs of monitoring, and thecosts of treatment required to remove Cr(VI). DHS must consider the costof complying with new MCLs. To determine the technical and economicfeasibility, DHS typically:

• Receives the Cr(VI) PHG from OEHHA• Selects possible draft Cr(VI) MCL concentrations for evaluation• Evaluates occurrence data• Evaluates available analytical methods and estimate monitoring

costs at various draft MCL concentrations• Estimates population exposures at various draft MCL concentra-

tions of Cr or Cr(VI)• Identifies best available technologies (BAT) for Cr(VI) treatment


498


• Estimates treatment costs at the possible draft MCL concentrations• Reviews the costs and associated health benefits (health risk reduc-

tions) that result from Cr(VI) treatment at the possible draft MCLconcentrations

• Selects an MCL for proposal from the possible draft MCL concen-trations considered above

The MCL is then put into place. It is subject to periodic review and/orrevision, as described in the following section.

FIGURE 12.1.1

Cr(VI) exposure (

inhalation

). Health effects from breathing chromium [primarily chromium(VI)].

0.002

0.0018

0.0016

0.0014

0.0012

0.0010

0.0008

0.0006

0.0004

0.0002

0

0.05

2

4

0.04

0.03

0.02

0.01

0.008

0.006

0.004

0.002

0.00002

0

NASALPERFORATION

NASALIRRITATIONMLD LUNGEFFECTS

MINIMAL RISKFOR EFFECTSOTHER THAN CANCER

SHORT-TERM EXPOSURE(LESS THAN OR EQUAL TO 14 DAYS)

LONG-TERM EXPOSURE(GREATER THAN 14 DAYS)

DEATH 50

EFFECTSIN

ANIMALS

CONC. INAIR

(mg/m3)

CONC. INAIR

(mg/m3)

EFFECTSIN

HUMANS

EFFECTSIN

HUMANS

EFFECTSIN

ANIMALS

IRRITATION OFNASAL MUCOSA

NASALPERFORATION

~~

~~

~~

~~



499

12.1.6 Review and Revision of Drinking Water Standards

The process for reviewing and revising drinking water standards and guid-ance is a combination of science and policy. While the underlying assumptionsare based on science, margins of safety are added to make the value protective.The process costs time and money, and is slow. The primary questionanswered during review is as follows. Assuming future work has been donesince the date of the previous MCL, does the work indicate that a lower orhigher standard is appropriate, or does it corroborate the original value?

FIGURE 12.1.2

Cr(VI) exposure (ingestion). Health effects from ingesting chromium [primarily chromium(III)and chromium(VI)].



EFFECTSIN

ANIMALSDOSE

(mg/kg/day)DOSE

(mg/kg/day)

EFFECTSIN

HUMANS

EFFECTSIN

HUMANS

EFFECTSIN

ANIMALS

2500

2000

1500

1000

500

100

80

60

40

20

10

0

0.006

0.004

0.002

0

SAFE AND ADEQUATILEVELS FORHUMAN NUTRITION[Cr(III)]

QUANTITATIVEDATA WERENOTAVAILABLE

DEATH [Cr(III),ONE DOSE]

NERVOUSSYSTEMEFFECTS[Cr(VI), 7 DAYSIN DRINKINGWATER]

DEATH [Cr(VI)],ONE DOSEPLACEDDIRECTLYIN ANIMAL’SSTOMACH

NO EFFECT ONNERVOUSSYSTEM [Cr(VI),7 DAYS INDRINKING WATER]

~~

~~


500


To answer this question for Cr or any other drinking water contaminantof concern, the 1996 SDWA Amendments set up a process for reviewing EPAdrinking water standards. The USEPA must review information on existingcontaminants (68 chemical contaminants) every 6 years and decide whichones need to be revised (USEPA, 2002). The USEPA looks for new informa-tion on the following:

• Health effects• Analytical methods• Treatment technologies• Occurrence or exposure estimates• Economics

Similarly, the state of California is in the process of reviewing MCLs inresponse to PHGs. The process is similar to the USEPA’s. If the PHG is lowerthan the current MCL, DHS looks for any changes in available health effects

FIGURE 12.1.3

Cr(VI) exposure (

dermal sorption

). Health effects from skin contact with chromium [primarilychromium (VI)].



EFFECTSIN

ANIMALSDOSE

(mg/kg/day)DOSE

(mg/kg/day)

EFFECTSIN

HUMANS

EFFECTSIN

HUMANS

EFFECTSIN

ANIMALS

700

650

600

550

500

450

400

350

300

DEATH






501

data, analytical methods, technology, occurrence, etc. As soon as OEHHAcompletes the Cr(VI) PHG analysis, DHS will begin this process (DHS, 2004).

12.1.7 Regulatory Implications of Drinking Water Standards

The implications of a standard or guidance value for total Cr or Cr(VI) orfor any other contaminant are far-reaching in terms of both human healthconsequences and financial obligations. Water treatment plants may need toadd to the treatment process. Water currently used for groundwater rechargemay require treatment to meet the new regulatory levels. Industrial facilitiesmay be required to meet stricter pretreatment requirements. Cleanuprequirements at groundwater remediation sites may also change, requiringtreatment systems to operate for longer periods of time and cover a largerplume area.

12.1.8 Beyond Regulations

While many compound regulations are based on the concept of a thresholdvalue below which no adverse effects are anticipated, this is merely a bestguess that is dependent on the detection levels of today’s scientific practice.In the water litigation movie

Erin Brokovich,

centered around Cr(VI) contami-nation in Hinkley, CA, the lead attorney for the plaintiffs discusses the possi-bilities of risk beyond today’s scientific knowledge with the followingstatement:

“In Hinkley, the [chromium] levels went all the way to 24 parts permillion. It

’

s fairly easy to prove that can kill you. What we don

’

t knowis what [2 ppb] over 50 years will do . . . There isn

’

t anybody in this worldwho can give a prediction. All we can do is give a very educated guess.”

Edward Masry, Toxic Tort Specialist (Chromium Research Council, 2004)

This problem is often legally and scientifically gray when concentrations areapproximately equal to the regulatory standard. Water providers may arguethat no adverse health effects are associated with Cr concentrations below reg-ulatory action levels or guidelines. However, toxicologists must scale up frommice and other small rodents to humans and correlate exposure concentrationsand disease at low concentrations. Rodent lifespan, concentration dose, meta-bolic rate, mechanisms of carcinogenesis, synergistic effects and accumulationrates vary considerably between rodents and humans. Therefore, the resultsfrom animal cancer tests are not necessarily a good predictor of cancer risk tohumans at the usually low concentrations of human exposures.

Beyond these issues lies the fact that defining an “acceptable risk” to humans,wildlife, or the environment is not a scientific question. Water providers arewary of the legal traps associated with serving water to the public in the faceof uncertain regulations. Cities are taking initiative to provide themselves with


502


an additional factor of safety to address legal, political and potential healthconcerns, as illustrated by the case study of Glendale, a suburb of Los Angeles,California.

12.1.9 Case Study: Glendale, California

The San Fernando Valley groundwater basin serves as a drinking watersource for the Los Angeles (LA) metropolitan area, the unincorporated areaof La Crescenta and the cities of Glendale, Burbank, San Fernando, and LaCanada-Flintridge. In 1998, Cr(VI) was detected in shallow and deep potablesupply wells in the San Fernando Valley. While concentrations were belowthe state MCL of 50

m

g/l, approximately 35% of samples exceeded OEHHA’sdraft PHG of 2.5

m

g/l (Chromium Research Council, 2004). The ratio ofCr(VI) to total Cr ranged between 61 to 99% (Regional Water Quality ControlBoard (RWQCB), 2000).

After notifying USEPA and the State RWQCB, an interagency task forcewas set up to evaluate the problem. Approximately 250 potential sourceswere located with the help of the RWQCB (RWQCB, 2000). While concen-trations were within the range of naturally high background levels seen inother areas, the industrial history of the San Fernando Valley has led regu-lators to consider the contamination anthropogenic (RWQCB, 2000).

By 1980, chlorinated solvents used at defense-related facilities from the1940s to the 1970s were detected in the San Fernando Valley aquifer operatedas a water source for the City of Glendale. By the mid 1980s, the city stoppedpumping water from approximately 20 groundwater production wells andbegan importing all of its water. In 1987, the USEPA and LA Department ofWater and Power entered a cooperative agreement which required pumpingthe supply wells, treating the water to remove VOCs, and delivering waterto the public. The water treatment plant was installed in the early 1990s. Aspart of a 1993 USEPA agreement, the City of Glendale agreed to deliver thetreated water to the public. The treated water met all federal, state and localdrinking water requirements. At this time, Cr was not determined to be aproblem in the area.

When Cr was detected in the treated water, Glendale water managers andcity council agreed not to serve the water containing total Cr and Cr(VI) toGlendale water customers. Although the treated water was less than regula-tory VOC levels, the City of Glendale was concerned about the newly dis-covered Cr in the treated water and wanted to voluntarily comply with thenew public health goal of 2.5

m

g/l for total Cr. Well water from the Glendaletreatment plant measured as high as 17

m

g/l Cr(VI). Instead, the treated waterwas discharged into the concrete-lined Los Angeles River against the oppo-sition of the USEPA and the LA Metropolitan Water District. In subsequentlitigation, Glendale was forced to take the treated water or be fined up to$10,000 per day for noncompliance with the 1993 USEPA agreement.

A plan was developed in 2001 and was agreed upon by the City of Glendale,the USEPA and the Los Angeles Metropolitan Water District. The plan allowed



503

for water drawn from the underlying groundwater aquifer to be blended withclean water from the LA Metropolitan Water District resulting in a blendedCr(VI) concentration less than 1

m

g/l delivered to Glendale water consumers.In return, Glendale spends about $800,000 per month for water treatment. Even-tually, Glendale plans to spend $6 to $9 million on a new treatment plant toremove Cr(VI) and volatile organic compounds (RWQCB, 2000).

12.1.10 Other Impacted Regions

Cr(VI) has been found in many areas of California, mostly at defense-relatedbusinesses, aircraft manufacturing and industrial plating facilities. NorthernCalifornia locations of Cr(VI) impacted groundwater include Daly City, Davis,Brentwood, and Los Banos. Southern California Cr(VI) sites include Los Ange-les, Arcadia, San Marino, Compton, Redondo Beach, Pomona, La Verne, LongBeach, Industry, Hawthorne, and South Gate (RWQCB, 2000). Under a volun-tary State Cost Recovery Program administered by the Los Angeles RWQCB,many of these sites are being actively assessed and remediated.

Bibliography

ATSDR, 2000, Toxicological profile for chromium, Agency for Toxic Substances DiseaseRegistry, Public Health Service, U.S. Department of Health and Human Services.

Akatsuka, K and Fairhall, L.T., 1934,

The toxicology of chromium

, J. Ind. Hyg., 16, 128.Blair, J., 1928,

Chrome ulcers, Report on twelve cases

, J. Am. Med. Assoc., 90, 1927–1928.Bloomfield, J.J. and Blum, W., 1928,

Health hazards in chromium plating

, Public HealthReport, 43, 2330–2351.

Borneff, I., Engerlhardt, K., Griem, W., Kunte, H., and Reichert, J., 1968,

Carcinogenicsubstances in water and soil, XXII, Mouse drinking study with 3,4-benzpyrene andpotassium chromate

, Arch. Hyg., 152, 45–53. (German).California Department of Health Services (DHS), 2004,

Chromium-6 in drinking water:regulation and monitoring update

, http://www.dhs.ca.gov/ps/ddwem/chemi-cals/Chromium6/Cr+6index.htm

California Regional Water Quality Control Board (RWQCB), 2000, Special boardmeeting on chromium contamination, California Regional Water Quality Con-trol Board, Los Angeles Region, Glendale, CA, November 13.

Carter, W.W., 1929,

The effect of chromium poisoning on the nose and throat: The report ofa case

, Med. J. Rec., 130, 125–127.Chromium Research Council, 2004,

Cr-Cleanup, Local efficiency and nationwide utilityprotection

, http://www.cr-cleanup.comHunter, W.C. and Roberts, J.M., 1932,

Experimental study of the effects of potassiumbichromate on the monkey

’

s kidney

, Am. J. Pathol., 9, 133–147.International Chromium Development Association (ICDA), 2001, Health Safety and

Environment Guidelines for Chromium, International Chromium Develop-ment Association, December, pp. 19–38.

Lieberman, H., 1941,

Chrome ulcerations of the nose and throat

, New England JournalMedicine, 225, 132–133.


504


National Institute of Occupational Safety and Health (NIOSH), 2004, 1988 OSHAPEL project documentation. http://www.cdc.gov/niosh/pel88/pelstart.html

National Research Council, 1999,

Identifying future drinking water contaminants

, Na-tional Academy Press, Washington, DC. p. 22–32.

Office of Environmental Hazard and Health Assessment (OEHHA), 1999, Publichealth goal for chromium in drinking water, February.

Shimkin, M.B. and Leiter, J., 1940,

Induced pulmonary tumors in mice III, The role ofchronic irritation in the production of pulmonary tumors in strain, A mice,

J. Natl.Cancer Inst., 1, 241–254.

U.S. Environmental Protection Agency (USEPA), 2002, Fact sheet: Announcement ofthe results of EPA

’

s review of existing drinking water standards and requestfor public comment, EPA 815-F-02-002.

U.S. Environmental Protection Agency (USEPA), 2004, List of drinking water con-taminants and MCLs, U.S. Environmental Protection Agency, Office of GroundWater and Drinking Water http://www.epa.gov/safewater/mcl.html#mcls.

World Health Organization (WHO), 1996, Health criteria and other supporting in-formation,

in Guidelines for Drinking-Water Quality

, 2nd ed., 2, 940–949.

12.2 Worldwide Chromium Regulations

James Jacobs R.G.

Worldwide Figure 12.1.3: Cr(VI) exposure (dermal sorption) Cr regulationsare meant to protect health, safety, and the environment. Chromium regu-lations from the European Union (EU) (including France, Italy, U.K. andGermany), Japan, South Africa, and the U.S. are listed for air, dust, waste-water, drinking water, soil, and waste. Most of this information was compiledfrom the health safety and environment guidelines for Chromium and isused with permission from the International Chromium Development Asso-ciation (pp. 19–38; December, 2001).

12.2.1 Overview of Chromium Regulatory Agencies

12.2.1.1 European Union

Three directorates within the EU deal with Cr-related hazards.

• DG XI is responsible for environment, nuclear safety and civildefense issues with classification, labeling and packaging of dan-gerous substances

• DG V is responsible for employment, industrial relations, andsocial affairs deals with occupational health and safety includingsetting Occupational Exposure Limits (OEL).



505

• DG III is responsible for industrial affairs deals with the extensionof the dangerous substances regulations to all dangerous prepara-tions

These directorates enact decisions through EU directives or regulations,which either lay down legally binding requirements or set out minimumstandards for which authorities within member states may set moredemanding limits. National authorities may also impose additional acts orregulations.

Several EU directives deal with the pollution of water, namely 76/464/EEC concerning the “Discharge of Dangerous Substances into the AquaticEnvironment.” Cr appears in the “Grey List” of 20 metals. A water frame-work directive is being formulated based on the requirements of the abovedirective, the ESR Directive 793/93/EEC and the IPPC Directive 96/61/EC.

12.2.1.2 Japan

The Japanese Society for Occupational Exposure Limits (JSOH) recommendsOELs as reference values for preventing adverse health effects on workers.In addition, chromium is strictly regulated through legal controls by thefollowing:

• Industrial Safety and Health Law (workplace)• Poisonous and Deleterious Substances Control Law (workplace)• Wastes Disposal and Public Cleansing Law (wastes)• Water Pollution Control Law (water purity)

The first three are under the jurisdiction of the Ministry of Health, Labor,and Welfare. The Water Pollution Control Law is administered by the Min-istry of the Environment.

12.2.1.3 South Africa

At present all work-related matters fall under two government departments:the Department of Mineral and Energy Affairs and the Department of Man-power. The Department of Mineral and Energy Affairs specifies:

• Health surveillance: regular medical examination and chest X-rays• Pollutant levels in the workplace: airborne contamination— American

Conference of Governmental Industrial Hygienists (ACGIH)• Threshold Limit Values (TLVs) for occupational exposure limits

The Department of Manpower is responsible for administering the hazard-ous chemical substances regulations which are similar to U.K. regulations.


506


The primary focus is on medical surveillance, including biological monitor-ing, and exposure to gases and airborne particles.

12.2.1.4 United States

In the U.S., there are several government groups responsible for settingregulations to protect workers and the general public. There are also gov-ernment departments that develop recommendations or guidelines:

• Occupational Safety and Health Administration (OSHA) (work-place, regulatory)

• National Institute for Occupational Safety and Health (NIOSH)(workplace, advisory)

• American Conference of Governmental Industrial Hygienists(ACGIH)

• US Environmental Protection Agency (USEPA) (general public, reg-ulatory)

OSHA publishes a hazard communication standard to ensure that allhazards of produced or imported substances are assessed and that the infor-mation is passed on to employers and employees. These rules deal with thelabeling aspects, the preparation of Material Safety Data Sheets (MSDSs) andthe training of employees. OSHA also publishes Permissible Exposure Limits(PELs) for airborne exposure to chemical compounds.

Acting under the authority of the Occupational Safety and Health Actof 1970 (Public Law 91-596), NIOSH develops and periodically revisesrecommendations or limits of exposure to potentially hazardous sub-stances or conditions in the workplace. NIOSH also recommends appro-priate preventive measures designed to reduce or eliminate adverse healtheffects of these hazards. To formulate these recommendations, NIOSHevaluates available medical, biological, engineering, chemical, trade, andother information relevant to the potential hazard. These recommendationsare then published, and transmitted to OSHA for use in promulgatinglegal standards.

American Conference of Governmental Industrial Hygienists classifies,processes and recommends threshold limit values (TLVs) for use as guide-lines. USEPA generates and enforces all aspects of environmental regulation.

12.2.2 Air Quality

Table 12.2.1 and Table 12.2.2 give specific air and dust emission limits forreleases to the environment in countries for which information is available.Regulations are subject to review and changes; therefore it is essential toconfirm with local, national, or regional authorities before using the valuelisted in the tables.



507

TABLE 12.2.1

Ambient Air Regulations for Chromium

Cr(VI) Compounds CountryStandard (mg/m

3

)

Cr(VI) as strontium chromate (SrCrO

4

) Denmark 0.0005Cr(VI) as strontium chromate (SrCrO

4

) U.S. 0.0005Cr(VI) as calcium chromate (CaCrO

4

) U.S. 0.001Cr(VI) as chromic acid (H

2

CrO

4

) andchromates (CrO

42–

)Denmark 0.005

Cr(VI) Kazakhstan 0.01Insoluble Cr(VI) compounds U.S. 0.01Cr(VI) as lead chromate (PbCrO

4

) U.S. 0.01Cr(VI) as chromic acid (H2CrO4) Iceland 0.02Cr(VI) as chromates (CrO4

2–) Iceland 0.02Cr(VI) as chromic acid (H2CrO4) and

chromates (CrO42–)

Norway 0.02

Cr(VI) as lead chromate (PbCrO4) Norway 0.02Cr(VI) as chromates (CrO4

2–) Sweden 0.02Cr(VI) as chromic acid (H2CrO4) Sweden 0.02Cr(VI) compounds Germany 0.025Cr(VI) compounds European Union 0.05Cr(VI) compounds Finland 0.05Cr(VI) compounds France 0.05Cr(VI) as chromic acid (H2CrO4) France 0.05Cr(VI) compounds Germany 0.05Elemental Cr/Cr metal and Cr(III)compounds

Iceland 0.05

Cr(VI) compounds Japan 0.05Cr(VI) compounds South Africa 0.05Cr(VI) stel value Sweden 0.05Cr(VI) compounds Maximum ExposureLimit (MEL)

U.K. 0.5

Soluble Cr(VI) as zinc chromate (ZnCrO4) U.S. 0.05Cr as chromite ore processing U.S. 0.05Zinc Chromate (ZnCrO4) Germany 0.05 as CrCr(VI) compounds (except insolubles) Germany 0.05 as CrCr(VI) compounds in welding fumes fromMMA arc welding with coated electrodes

Germany 0.05 as Cr

Cr(VI) compounds Germany 0.1Zinc chromate (ZnCrO4) Germany 0.1 as CrO3

Cr(VI) compounds (except insolubles) Germany 0.1 as CrO3

Cr(VI) compounds in welding fumes fromMMA arc welding with coated electrodes

Germany 0.1 as CrO3

Cr(VI) stel value France 0.1Chromic acid (H2CrO4) and chromates as CrO3 U.S. 0.1

Elemental Cr and Cr(III) Compounds

Cr as powder/soluble Cr(II) and Cr(III) salts Denmark 0.5Cr(III) compounds (OES) U.K. 0.05Cr, Cr(II), and Cr(III) compounds European Union 0.5Cr, Cr(II), and Cr(III) compounds Finland 0.5Cr(III) compounds South Africa 0.5

(Continued)


508 Chromium(VI) Handbook

TABLE 12.2.1

(Continued)

Cr(VI) Compounds CountryStandard (mg/m3)

Cr(III) compounds Occupational ExposureStandard (OES)

U.K. 0.5

Cr(II) and Cr(III) compounds U.S. 0.5Elemental Cr/Cr metal France 0.5Elemental Cr/Cr metal, Cr(II), and (III) Norway 0.5Elemental Cr/Cr metal South Africa 0.5Elemental Cr/Cr metal/inorganic Sweden 0.5Elemental Cr/Cr metal U.K. 0.5Elemental Cr/Cr metal and Cr(III) U.S. 0.5Cr metal U.S. 1

Other

Total Cr Kazakhstan 1ACGIH values, USA Italy NAACGIH values, USA Spain NAACGIH threshold limit values (TLVs) U.S. NA

Source: Adapted from ICDA, 2001.

TABLE 12.2.2

Other Air Regulations for Chromium

Chromium Source CountryStandard(mg/m3)

Cr(VI) Kazakhstan 0.0017Chromates of calcium, Cr(III), strontium and zinc,and zinc-potassium as Cr

U.K. 0.5

Total metals-atmospheric pollution by industrial plants European Union < 1Cr(VI) as Cr U.K. 1Total Cr Kazakhstan 4–4.8Total metals if total mass flow is >25 g/h Francea 5Chromates of calcium, Cr(III), strontium and zincif total mass flow is >5 kg/h

Germany 5

Cr(III) as Cr U.K. 5Inhalable dust containing chromates of calcium, Cr(III), strontium and zinc if total mass flow is >5g/h

Germany 1

Total dust U.K. 20Total dust if total mass flow is >1 kg/h France 40Total dust stack emission limit South Africa 40Total dust if total mass flow is >0.5 kg/h Germany 50Total dust if total mass flow is <1 kg/h France 100

Source: Adapted from ICDA, 2001.a Metals include Sb, Cr, Co, Cu, Sn, Mn, Ni, Pb, V, and Zn


Chromium Policy and Regulations 509

12.2.3 Water Quality

Chromium substances that are of particular concern in water include:

• Suspended particles containing chromium• Dissolved total chromium• Dissolved hexavalent chromium

These can be measured or monitored points of discharge or points ofseepage. Generally water quality regulations consider both instantaneousconcentrations (mass per liter) and flux (mass per time). Regulations forwastewater and drinking water from different countries are listed inTable 12.2.3 and Table 12.2.4 for reference.

TABLE 12.2.3

Wastewater Regulations

Scenario CountryStandard

(mg/l)

Cr(VI) Kazakhstan 0.005 – 0.03 Cr(VI) for freshwater – continuous (maximum) U.S. 0.01 (0.015)Cr(VI) for leather industry Germany 0.05Cr(VI) for salt water – continuous (maximum) U.S. 0.05 (1.1)Cr(VI) if total mass flow is >1 g/day France 0.1Cr(VI) for metal or chemical industry Germany 0.1Cr(III) 4-day avg – continuous (maximum) U.S. 0.18 (0.55)Total Cr if total mass flow is 5 g/day France 0.5Total Cr max for metal or chemical industry Germany 0.5Cr(VI) public water systems Japan 0.5 Total Cr South Africa 0.5 Total Cr max for leather industry Germany 1Total Cr in public water system Japan 2 Range for estuary and coastal water, based on water hardness, receptors salmonid and cyprinid

U.K. 5–250


TABLE 12.2.4

Drinking Water Regulation

Compound Country Standard (mg/l)

Total Cr Kazakhstan 0.0031Total Cr Germany 0.05Cr(VI) Japan 0.05Total Cr United Kingdom 0.05Total Cr South Africa 0.1Total Cr U.S. 0.1




12.2.4 Soil Quality

Table 12.2.5 lists soil regulations for selected countries.

12.2.5 Waste Disposal

Table 12.2.6 contains regulations regarding solid and liquid waste disposal. In Japan, ferrochromium slag with the Water-Leaching Test Value (as stip-

ulated by law) of less than 1.5 Cr(VI) mg/l must be dumped into a “con-trolled final disposal site” when it is categorized as an industrial waste. Thesame slag, however, can be used as civil engineering material for land rec-lamation or road construction.

In South Africa, a process authorization approach is being developed forlandfills in terms of the Environmental Conservation Act (No 73 of 1989).Draft guidelines for the authorization of landfill site have been preparedunder the auspices of the Department of Water Affairs (DWAF, 1993). TheDWAF guidelines require that the developer of a site submits various reports

TABLE 12.2.5

Soil Regulations

Scenario CountryStandard (mg/kg)

Cr(VI) Kazakhstan 0.558Threshold trigger for total Cr U.K. 25Threshold value for total Cr, varies with soil type Germany 30–100Draft soil screening level for total Cr, based on inhalation U.S. 140Provisional guidelines for total Cr, gardens and allotments U.K. 150Draft soil screening level for total Cr, based on ingestion U.S. 390Total Cr Kazakhstan 400Provisional guidelines for total Cr, residential without gardens, parks, open spaces, etc.

U.K. 1.000

Provisional guidelines for total Cr, commercial and industrial areas

U.K. 3,800


TABLE 12.2.6

Waste Leachate Disposal Regulations

Scenario Country Standard (mg/l)

Landfill disposal Cr(VI) Germany 0.5Landfill disposal Cr(VI) Japan 0.5Ocean disposal Cr(VI) Japan 1.5 Landfill disposal total Cra U.S. 5.0Wastewater disposal U.S. 2.77

Source: Adapted from ICDA, 2001.a

TCLP = Toxicity Characteristic Leaching Procedure



detailing the geology and hydrology of the site, the results of an environ-mental impact assessment, the methods of operation and the closure of thelandfill and a water quality monitoring program.

12.2.6 Work Place Exposure

Full information regarding health hazards related to chemical agents includ-ing metallurgical products or processes should be passed on to the employ-ees concerned. The following are the three main routes of workplaceinformation.

12.2.6.1 Labeling of Packages and Containers

12.2.6.1.1 European Union

Substances and preparations may be classified as hazardous for supplyor transport purposes. While there are many similarities between the twosystems, they are separate from each other and must be dealt with sep-arately.

The first step in all cases is to classify the material. Where it is not hazard-ous for supply or transport, there are no special requirements for packaging,labeling or documentation. Where it is classified as hazardous, certainnational and international regulations will apply. The decision on classifica-tion rests with the supplier, and must be based on good scientific data.

12.2.6.1.1.1 Supply — In the European Union, directives have creatednational regulations that include lists that specify the hazard classification fora large number of substances.

Where a substance is classified, the listed Risk (R) and Safety (S) phrasesmust be used on all labels and safety data sheets without alteration. Thelabel must also meet stringent requirements regarding content, hazard pic-tograms/symbols, size, position, method of attachment, and language(s).Where a substance is not listed, the manufacturer must use available datawithin strict rules to self classify the product correctly, that is, to assign theappropriate risk and safety phrases if it is hazardous or alternatively toclassify it as not hazardous for supply purposes.

12.2.6.1.1.2 Transport — If the above classification process has concludedthat the product is hazardous for transport purposes, then a series of inter-national regulations will apply depending on the method(s) of transport tobe used.

These regulations were created initially as a series of model regulationsby the UN (known as the Orange Book, or the UN Recommendations on theTransport of Dangerous Goods). They are updated every 2 years and are



then translated into a series of modal regulations for the different modes oftransport. These are:

• International Maritime Dangerous Goods Code (IMDG Code): Aset of legally enforceable international regulations for the transportof dangerous goods by sea.

• International Cargo Aircraft Only (ICAO) Technical Instructions:These are legally enforceable regulations covering the transport ofdangerous goods by air. These result in the publication of the IATADangerous Goods Regulations which in themselves are not legallyenforceable as it is an industry publication. However it is based onICAO and is preferred by most users as it is more user friendly.

• European Agreement concerning the International Carriage ofDangerous Goods by Road (ADR)/Regulation concerning Interna-tional Carriage of Dangerous Goods by Rail (RID)/ European Pro-visions concerning the International Carriage of Dangerous Goodsby Inland Waterways (ADN): These are regulations set up by agree-ment within Europe for the transport of dangerous goods by road,rail and inland waterways respectively. They are derived from theUN recommendations. Similar regulations exist outside Europe,with corresponding national regulations for each mode of trans-port, for example, CFR in the U.S.

In each case, they specify packaging, labeling, documentation require-ments, and signed declarations to ensure:

• Use of the correct type of approved tested and UN marked pack-aging

• Use of the correct type, and proper fitting of, approved diamonddescriptor hazard labels to the packages and, if traveling by sea,also the container

• Allocation and display of the correct Proper Shipping Name andUN number for the labeled material

• Proper marking of the vehicle transporting the goods• Proper training to all relevant members of staff including special

provisions for training vehicle drivers• Provision of documentation and emergency information for use by

the driver and emergency services in the event of an accident intransit

The regulations for supply and transport are quite specific and very exten-sive, such that a detailed description cannot be provided here. The reader isreferred to the international regulations above, and their own national reg-ulations for the various modes of transport for more detail. A key point to



remember however, is that the regulations for all modes of transport to beused must be fully complied with, so that where a given mode has a specialrequirement, this must be met along with other requirements for other trans-port modes in use.

12.2.6.1.1.3 Hazardous Waste — There are extensive rules governing theconsigning and disposal of hazardous wastes in most countries derived frominternational treaties. The transport rules will also apply where these mate-rials are classified for transport purposes.

12.2.6.1.1.4 Alloys: A Special Case — A decision in the European Union hasresulted in alloys being recognized as a special case within the DangerousPreparations Directive. This means that inappropriate classification by theuse of the current rules for preparations on alloys, which are not simplephysical mixtures, can be avoided.

The responsibility for this however, rests with the supplier who must pro-vide a body of evidence to prove the case for nonclassification of their alloy.

12.2.6.1.2 United States

All Cr-containing substances and mixtures must be labeled as hazardous.Massive alloys are also considered as mixtures and as such have to be

labeled. Cr(VI) should contain a cancer hazard warning. Under OSHA Haz-ard Communication Standard (HCS), the manufacturer, importer or distrib-utor shall ensure that each container of hazardous substances and mixturesis labeled, tagged, or marked with the following information:

• Identity of the hazardous substance• Appropriate hazard warning• Name and address of the substance manufacturer, importer, or

other responsible party

12.2.6.2 Material Safety Data Sheets (MSDS)

These documents are of prime importance for exporters, importers, andusers of Cr-containing products. They are compulsory in some, but not all,countries.


Directives 91/155/EC, 93/112/EC and 2001/58/EC lay out the MSDS formatwhich must contain information under the following obligatory headings:

• Identification of the substance/preparation and of the company• Composition (information on ingredients)• Hazards identification



• First-aid measures• Fire-fighting measures• Accidental release measures• Handling and storage• Exposure controls/personal protection• Physical and chemical properties• Stability and reactivity• Toxicological information• Ecological information• Disposal considerations• Transport information• Regulatory information• Other information

MSDS are adhered to by the EAA (European Economic Area) countries.


The MSDS is of prime importance in the OSHA Hazard CommunicationStandard (HCS). The most important rules can be summarized as follows:

• Chemical manufacturers and importers (and this includes the met-allurgical industries) shall obtain or develop a MSDS for each haz-ardous chemical they produce or import

• Users will have an MSDS for each hazardous chemical they use• Under the HCS, the definition of the label and MSDS (see below)

must be the result of an assessment made by the manufacturer,importer, or distributor, based on literature or other toxicologicaldata. This decision is said to be ‘‘performance orientated.”A writtenassessment must be kept available

Each MSDS will contain the following information:

• Identity of the product (either single substance or compound)• Physical and chemical characteristics of the hazardous chemical• Physical hazards linked with the hazardous chemical: fire, explo-

sion, reactivity• Health hazards linked with the hazardous chemical: symptoms

linked with exposure to the said substance and to the other sub-stances, which may be emitted during processing

• Primary routes of exposure• The OSHA PEL or the ACGIH TLV



• Whether the hazardous chemical is listed in the National Toxicol-ogy Program (NTP) Annual Report on Carcinogens or has beenfound to be a potential carcinogen in the International Agency forResearch on Cancer (IARC) monographs or by OSHA

• Any generally applicable precautions for safe handling and usewhich are known to the chemical manufacturer, importer oremployer preparing the MSDS, including appropriate hygienicpractices, protective measures during repair and maintenance ofcontaminated equipment and procedures for clean-up of spills andleaks

• Any applicable control measures, which are known to the manu-facturer, importer, or user preparing the MSDS such as engineeringcontrols, work practice, or personal protective equipment

• Emergency and first-aid procedures• Date of preparation of the MSDS or the latest modification• Name, address, and telephone number of the manufacturer,

importer, user

12.2.6.3 Induction and Training of Employees

Training of workers exposed to hazardous chemicals is obligatory in the U.S.(Hazard Communication Standard), in the EU (Directive 90/394/EEC) andmost other countries.

NOTE: The geographical regions or countries referenced above representthose areas with the strictest regulations in place. They can be used asguidelines with possible adaptation to the local regulatory trends or provi-sions. In addition, reference to the International Labor Organization (ILO)Convention No 170 and Recommendation No 177, published in June 1990and entitled “Safety in the use of chemicals at work” is also recommended.

12.2.6.4 Environmental Control and Monitoring

Effective control and monitoring of all emissions to air, water, and land isessential. Wastes deserve special mention because of the potential for theseto be moved from one region to another.

The materials may include:

• Recyclable metallic scrap• Slags or resiowings resulting from the manufacture of ferrochro-

mium and stainless steel or chemicals• Filter dust resulting from the production of ferrochromium and

stainless steel (including used filter bags)• Sludges from dust abatements• Metal finishing effluents, slurries, or wet cakes



• Used CCA treated wood• Used packaging (bags, drums, etc.) that contained Cr chemicals• Cr-containing refractories• Tanning process solid and liquid wastes• End of life articles

On an international basis, the UNEP “Basel Convention” of 22 March 1989on transboundary movements of hazardous wastes and their disposal wasimplemented in May 1992.

The OECD Decision of 30 March 1992 on the control of transfrontier move-ments of wastes destined for recovery operations classifies recyclable wastein three lists (green, amber, and red) according to the degree of risk–the redlist imposes the strictest procedures.

The lists are permanently under revision. (Refer to OECD Monograph No34 “Monitoring and Control of Transfrontier Movements of HazardousWastes–Updated July 1993”).

For the European Union, refer to the Council Regulation No 259/93 of 1February 1993 on the “Supervision and Control of Shipments of Waste Within,Into and Out of the European Community.” This text is also based on threecategories and became applicable as of May 1994. Under these regulations,it is obligatory for the contracting parties to declare such operations to allconcerned authorities, expedition and destination and countries of transit.


The Integrated Pollution Prevention and Control (IPPC) Regulations (96/61/EC) set out requirements for industries to apply Best Available Tech-niques (BAT) to control emissions to all environmental media (air, water,and land). These Regulations are supported by Best Reference Technology(BREF) notes for various industrial sectors and by other regulations ordirectives which apply to air, water, and waste classification, landfill, andincineration.

12.2.6.4.1.2 Air — Framework Directives 84/360/EEC and 89/369/EECdeal with atmospheric pollution from industrial plants and municipal wasteincineration plants respectively and 96/62/EC with air quality, Annex 1 ofwhich lists five agents for priority attention including three metals namelyarsenic (As), cadmium (Cd), and nickel (Ni).

12.2.6.4.1.3 Water — Directive 76/464/EEC refers to the “Discharge ofDangerous Substances into the Aquatic Environment” and Cr appears in the“Grey List” of 20 metals. A water framework directive is being formulatedbased on the requirements of the above directive, the Existing SubstancesRegulation (ESR), 793/93/EEC and the IPPC Directive 96/61/EC. TheDrinking Water Directive 98/83/EC lists limits for several metals.



12.2.6.4.1.4 Waste — The Directives 78/319/EEC (The Hazardous WasteDirective) amended by Council Decision 2001/118/CE, 91/689 EEC, and 94/31/EC along with Commission Decision 94/904/EC provide detailed lists ofwastes and a systematic basis for classification of wastes consistent with theprinciples used for classifying products and preparations. The Landfill Direc-tive (1999/31/EC) sets out criteria for preparation, operation, monitoring, andclosure of landfill sites according to the type or class of waste deposited.

12.2.6.4.2 Japan

12.2.6.4.2.1 Air — The purposes of the Air Pollution Control Law are,firstly, to protect public health and preserve the living environment withrespect to air pollution by controlling emissions of soot, smoke, and particlesfrom factories and other business establishments. Secondly, to control emis-sions of particulates when buildings are being demolished. Thirdly, to pro-mote various measures limiting the emission of hazardous air pollutants andby setting maximum permissible limits for automobile exhaust gases, etc.

12.2.6.4.2.2 Water — Under the Basic Environment Law, EnvironmentalQuality Standards (EQS) for water pollutants are target levels for waterquality to be achieved and maintained in public water. These standards areestablished to achieve two important goals: (1) to protect human health; and(2) conservation of the living environment. Cr(VI) is included in a list of EQSvalues for 26 substances for the protection of human health. An EQS forgroundwater pollution was also established in 1997. For the living environ-ment, EQS values have been established for Biochemical Oxygen Demand(BOD), COD, Dissolved Oxygen (DO), and other parameters. EQS values fornitrogen (N) and phosphorus (P) were established to prevent eutrophicationof lakes and coastal waters.

12.2.6.4.2.3 Waste — The purpose of the Wastes Disposal and PublicCleansing Law is to preserve the living environment and improve publichealth through restriction of waste discharge, the control of appropriatesorting, storage, collection, transportation, recycling, and disposal of wastes,and the conservation of a clean living environment.

12.2.6.4.2.4 Soil — Once soil is contaminated, the impacts last for a longtime. Therefore environmental quality standards are presently definedbased on the Basic Environmental Law for 27 items including Cr(VI). TheseEQS values are standards against which compliance is desirable for pro-tecting human health and conserving the living environment and arereviewed according to accumulated scientific data on an as necessary basis.The soil EQS stipulates standards considering water quality including puri-fication of groundwater and the farmland standard aims to conserve theproduction of food. These two standards are used to judge whether soil is



contaminated or not and give targets for designing measures to protectagainst pollution.

12.2.6.4.3 South Africa

The stack emission limit is generally 40 mg/m3 for total dust, but is subjectto revision with the appropriate authorities.


“Maximum Achievable Control Technology” (MACT)-based rules are beingdeveloped for major and area Cr emission sources on an industry by industrybasis.

In most cases, different standards will be determined for Cr(III) and Cr(VI).These regulations are based on the “CAA of 1990”, which identifies “Chro-mium Compounds” in its listing of hazardous air pollutants. Sources notcovered under MACT standards will be regulated at levels set by stateagencies.

12.2.6.5 Chemical Management

In an effort to improve the control and management of the widespread useof industrial chemicals, the OECD embarked upon a structured risk assess-ment review process for all chemicals.

This was set out in the Existing Substances Regulation 793/93/EC (ESR),under which producers or importers were required to submit StandardizedInformation Data Sets (SIDS) on a scheduled basis.

As a result of that process a group of five Cr(VI) products is undergoinga risk assessment review leading to further classification and risk reductionmeasures.

Because of slow progress on ESR, the International Council of ChemicalsAssociations (ICCA) launched a voluntary initiative under which industrywas encouraged to submit hazard data dossiers for its products.

In February 2001, the EU published a White Paper Strategy for a FutureChemicals Policy containing the following key elements:

• Making industry responsible for safety• Extending the responsibility along the supply chain• Authorization of substances of very high concern• Subscription of hazardous chemicals

Alongside these, a series of end of life directives is emerging in the EUcovering vehicles (ELV) Electrical and Electronic Equipment (WEED) andbuilding materials and another on restriction of hazardous substances.Both ELV and WEED mention Cr(VI): restriction under ELV, ban underWEED.



Under the precautionary principle on the one hand and sustainable devel-opment on the other, collectively these activities mean the following forindustries:

• Comprehensive characterization of products and their uses toenable human and environmental risk assessments to be made

• Replacement of hazardous by less hazardous substances• Best practice benchmarking to international standards• Waste minimization, recycling of waste, and end of life articles

In other words, Product Stewardship and Life Cycle Inventory/Assess-ment.

12.2.7 Product Stewardship

Under this regime, companies take visible responsibility for ensuring thatbest practice considerations apply to their products throughout the productlife cycle.

This includes addressing all of the features listed in Section 3 and Section5 above.

• Provide comprehensive information regarding products via com-munications such as MSDS.

This is particularly important for hazardous products and where identifieduses of an otherwise nonhazardous product can result in the generation ofhazardous products, for example, stainless steel and the formation of Cr(VI)in stainless steel welding fumes.

• Discourage inappropriate use(s) of products.• Work in an open and transparent way with customers and regu-

lators as appropriate to resolve issues of concern relating to prod-ucts and their uses. This may include advice on engineeringstandards, best practice standards for occupational exposurereduction and environmental controls, workforce education andtraining, waste minimization/recycling, and end-of-life solutionsin line with Sustainable Development.

12.2.8 Tools

12.2.8.1 Life Cycle Inventory/ Life Cycle Assessment (LCI/LCA)

Life Cycle Inventory is essentially a technique for accounting and evaluatingall of the inputs and outputs throughout the life cycle of a product underISO Standard 14040. LCA assembles the above data for different players in



the same industry enabling best practice benchmark values to be identifiedand it can also be used to compare alternative products that might be avail-able for the same end use and gives:

• To the producers, a set of benchmark data to support or defendcurrent and future business decisions particularly where there arealternatives

• To regulatory or other bodies, a set of current best practice datathat can be used to formulate or influence regulations

12.2.9 International Standards Organization (ISO)

Since 1993, several ISO standards have been developed and those relevantto the context of the guidelines are:

Members are strongly encouraged to set up and practice health, safety andenvironmental management systems that include all of the features set outabove and to seek corresponding ISO accreditation.

The ISO Standards relate all of the inputs and outputs throughout the lifecycle. The various inputs and outputs include: product, wastes (air, soil,water), end of life, transport, raw material, energy, and processes.

12.2.10 Ecolabeling

Ecolabeling is a tool to enable producers to indicate the environmental aspectsof a product or service. It may take the form of statements, symbols, or graphicson product or package labels, product literature, technical bulletins, etc.

An environmental aspect is an element of an organization’s activities,products, or services, which can interact with the environment.

Ecolabeling forms part of the ISO 14000 series of environmental manage-ment standards:

• ISO 14020 Basic principles• ISO 14021 Self-declaration environmental claims: terms and defi-

nitions• ISO 14022 Self-declaration environmental claim: environmental

labeling symbols

Environmental management systems ISO 14001, 14002, 14004Environmental auditing ISO 14010–14012, 14015Environmental labeling ISO 14020–14025Environmental performance evaluation ISO 14031Life cycle assessment ISO 14040–14043Occupational health and safetyManagement systems ISO 18001, 18002



• ISO 14023 Self-declaration environmental claims: testing and ver-ification methodologies

• ISO 14024 Environmental labeling type 1: guiding principles andprocedures

• ISO 14025 Environmental labeling type 111: guiding principles andprocedures 38

Bibliography

International Chromium Development Association (ICDA), 2001, Health Safety andEnvironment Guidelines for Chromium, International Chromium Develop-ment Association, December, pp. 19–3.



Documents

L1608 C12 - School of Engineeringengr.uconn.edu/~baholmen/docs/ENVE290W/National Chromium Files F… · L1608_C12.fm Page 489 Monday, ... Cr plating regulations were enforced in selected