Hexavalent Chromium Presentation
Hexavalent Chromium Presentation
ATC Associates
Adopted from presentation developed under the Susan Harwood Grant # 46E6 HT34
Background Information
Chromium is a metal that exists in several oxidation or valence states, ranging from chromium (-II) to chromium (+VI).
Chromium compounds are very stable in the trivalent state and occur naturally in this state in ores such as ferrochromite, or chromite ore.
Chrome III is an essential nutrient for maintaining blood glucose levels The hexavalent, Cr(VI) or chromate, is the second most stable state. It rarely occurs naturally; most Cr(VI) compounds are man made.
A toxic form of chromium metal, generally man-made. Used in many industrial applications, primarily for its anti-corrosive properties. Can be generated during welding on stainless steel or metal structures coated with chromate paint. Used in electroplating (chrome plating)
molybdenum orange) zinc chromate barium chromate calcium chromate potassium dichromate sodium chromate
anti-corrosion coatings (chrome plating, spray coatings) stainless steel and other high chromium alloys textile dyes wood preservation leather tanning
cut)
Construction
Health Effects
Ingestion Hazards
Erosive to stomach, Hemorrhaging and death are likely
Eyes
Direct eye contact with chromic acid or chromate dusts can cause permanent eye damage.
Respiratory Tract
Hexavalent chromium can irritate the nose, throat, and lungs. Repeated or prolonged exposure can damage the mucous membranes of the nasal passages and result in ulcers.
Skin
Prolonged skin contact can result in dermatitis and skin ulcers. Some workers develop an allergic sensitization to chromium. In sensitized workers, contact with even small amounts can cause a serious skin rash.
Health Effects
Cancer
Chrome VI is classified as a known human carcinogen
Hexavalent chromium is considered a potential lung carcinogen.
Studies of workers in the chromate production, plating, and pigment industries consistently show increased rates of lung cancer.
Insoluble forms such as zinc chromate are the most potent 20 year cancer latency
Lung cancer
Nasal septum ulcers or perforations Bronchitis or asthma
X-ray showing lung cancer
Skin effects are not likely in welding, but can occur in electroplating or painting
Definitions
Action level - 2.5 g/m (8-hour TWA). Permissible Exposure Limit - 5 g/m (8-hour TWA).
This has been lowered from the past level of 52 micrograms per cubic meter of air (52 g/m).
5 micrograms per
cubic meter
in the air
Comparison of OELs
Potential Sources
Welding
Stainless steel
Aircraft Painting
Priming with zinc chromate primers Removing primers
Welding
Nearly half the workers covered under the new standard are welders Chromium in steel is oxidized to Cr VI by high welding temperatures
6,000 - 8,000 C for the SMAW, GTAW, GMAW, FCAW and SAW processes The hotter the process and the more oxygen that is present, more fume is generated
Stick welding: 50% of Cr produced is Cr VI TIG & MIG 4% of total Cr produced is Cr VI Stainless steel has between 10.5% - 27% chromium
Painting
Aluminum Primers
Zinc Chromate and Strontium Chromate
Also present in in adhesives/sealants
Chromates required for proper adhesion Chromate free primers are being researched
Other chromic acid exposures occur from chromic acid solution preparations.
Chromic acid flakes are dumped mixed into solutions for many chemical processes
Exposure Determination
Each employer who has a workplace or work operation covered by this section shall determine the 8-hour TWA exposure for each employee exposed to chromium (VI). This determination shall be made in accordance with either of the following methods:
Scheduled Monitoring Option
Performance-oriented Option
Exposure Determination
- Describe to you in writing what corrective actions we will take to reduce your exposure below the PEL.
25
Skin Sampling
1910.1026 does not require skin sampling! The final rule requires the employer to provide appropriate protective clothing and equipment where a hazard is present or is likely to be present from skin or eye contact with Cr (VI), but does not specify criteria to be used for determining when a hazard is present or is likely to be present. One of the tools which the employer can use is skin sampling. But, OSHA is not aware of any evidence that would allow establishment of a threshold concentration of Cr(VI) below which adverse skin or eye effects would not occur. The interpretation letter on the OSHA Web page states To determine whether there is a hazard (or potential hazard) from skin or eye contact with chromium (VI) in a particular workplace, the employer should use appropriate expertise in assessing hazards. (See nonmandatory appendices providing guidance on hazard assessment in 29 CFR 1910 Subpart I Appendix B; 29 CFR 1915 Subpart I Appendix A). The recommended approach involves a walkthrough survey to identify sources of chromium (VI) hazards to workers. Also recommended are reviews of occupational illness records to determine if past skin exposures have been recorded or if skin conditions were reported which may have been linked to chromium (VI) exposures, as well as a review of any exposure determination(s) for operations involving chromium (VI).
Methods of Compliance
Use engineering and work practice controls to reduce and maintain employee exposure to or below the PEL.
When not sufficient enough, Use of respiratory protection in Addition. If exposure above the PEL is less than 30 days per year, Use of respiratory protection alone to comply.
Welding Controls
Fume extractor for stick welding on stainless steel
21
Welding on stainless steel in a confined space will most likely require both exhaust ventilation and the use of respirators.
22
Painting Controls
Substitute with non-Cr VI paint, if possible Conduct spray painting in an extremely welldesigned and maintained booth. (Think of controlling lead-based spray paint exposures, but having to control 10 times better.) Some grinders have a ventilated shroud on the grinder or needle gun, others may also have a perforated grinder disk Airline respirators Use Paint strippers to eliminate airborne exposures
All protective clothing and equipment contaminated with chromium (VI) must be:
Removed at the end of the work shift or at the completion of their tasks, whichever comes first; Stored and transported in sealed, properly labeled, impermeable bags or other closed, impermeable containers.
Use of outside service to launder or replace all protective clothing and other protective equipment Put your contaminated PPE in a sealed bag for laundering or repair
The person doing these tasks must be informed of the hazards of chrome 6
37
In some jobs involving chrome 6 exposure, you may need to wear a respirator. The type of respirator worn depends on the amount of chrome 6 in the air.
24
Respiratory Protection
Minimum N-95 Based on airborne exposure
Where protective clothing and equipment is required, the employer shall provide change rooms.
Separate storage for contaminated and clean clothes
Where skin contact with chromium (VI) occurs, the employer shall provide washing facilities:
Such facilities shall be in near proximity to the worksite and shall be so equipped as to enable employees to remove such substances. MUST BE WATER BASED CLEANING SYSTEM. Washing facilities shall be maintained in a sanitary condition. Use of these facilities when necessary shall be enforced.
29 CFR 1926.1126(h)
Change rooms separate storage facilities for PPE and street clothes
Washing facilities
Housekeeping
Keep all surfaces as free as practicable of accumulations of dust containing chrome 6. Promptly clean up all spills and releases of chrome 6 containing materials Use a HEPA vacuum or wet methods for cleaning areas contaminated with dust or other materials containing chrome 6 Dispose of chrome 6 contaminated waste in labeled & sealed bags or containers.
Medical Surveillance
A medical examination consists of:
A medical and work history; A physical examination of the skin and respiratory tract.
Information to PLHCP Employer shall obtain written opinion within 30 days containing:
Any detected conditions placing employee at increased risk of material impairment from Cr+6 exposure
Limitations of exposure or use of PPE Statement that Physician or other Licensed Health Care Professionals (PLHCPs) explained results of exam to employee
Any employee exposed at or above the action level for 30 or more days per year.
Any employee experiencing signs or symptoms of chrome 6 exposure. Any employee exposed in an uncontrolled release of large amounts of chrome 6 in any form.
Are done by or under the supervision of a physician or other licensed health care professional Provided at no cost to you at a reasonable place and time
45
40
Communication of Hazards
The employer shall ensure that each employee can demonstrate knowledge of at least the following:
The contents of this section; and The purpose and a description of the medical surveillance program.
Hazard Communication
29 CFR 1926.1126(j)
Background Information
OSHA has determined that the PEL of 5 g/m3 is technologically feasible for all affected welding job categories OSHA has concluded that no carbon steel welders are exposed to Cr(VI) above 5 g/m3, with the exception of a small portion of workers welding on carbon steel in enclosed and confined spaces. Many welding processes, such as tungsten-arc welding (TIG) and submerged arc welding (SAW), already achieve Cr(VI) exposures below the PEL because they inherently generate lower fume volumes.
Inspection Activity
Hexavalent chromium inspections
May 30, 2006 to December 31, 2007
Inspection Activity
72 inspections in General Industry with 1910.1026 violations
Breakdown of these 72 employers by SIC code:
(7) ---(5) ---(5) ---(3) ---(3) ---(3) ---(2) ---(2) ---(2) ---(2) ---(2) ---(2) ---(2) ---(1) ---3471 Electroplating, Plating, Polishing, Anodizing, and Coloring 3499 Fabricated Metal Products, Not Elsewhere Classified 3443 Fabricated Plate Work (Boiler Shops) 3444 Sheet Metal Work 3441 Fabricated Structural Metal 3325 Steel Foundries, Not Elsewhere Classified 7699 Repair Shops and Related Services, Not Elsewhere Classified 3743 Railroad Equipment 3728 Aircraft Parts and Auxiliary Equipment, Not Elsewhere Classified 3559 Special Industry Machinery, Not Elsewhere Classified 3535 Conveyors and Conveying Equipment 3442 Metal Doors, Sash, Frames, Molding, and Trim Manufacturing 2521 Wood Office Furniture etc., for (32) other SIC codes
Inspections
List of the 5-most cited Cr(VI) violations:
1910.1026(d)(1) - didn't determine exposure
Inspection Procedures
Conclusions
The Hexavalent Chromium standard can be a problem. It is a comprehensive vertical standard with many requirements, if it applies to you Recommendations
Evaluate your Workplace
(Stainless Steel is the trigger)
www.atcassociates.com