A Standard In Review
Adopted from presentation developed under the
Susan Harwood Grant # 46E6 – HT34
Chromium is a metal that exists in several oxidation or
valence states, ranging from chromium (-II) to chromium
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
The hexavalent, Cr(VI) or chromate, is the second most
stable state. It rarely occurs naturally; most Cr(VI)
compounds are man made.
What is Hexavalent Chromium?
A toxic form of chromium metal,
Used in many industrial applications,
primarily for its anti-corrosive
Can be generated during welding on
stainless steel or metal structures
coated with chromate paint.
Used in electroplating (chrome plating)
Products that contain hexavalent chromium
Product Types of Hexavalent Chromium Chemicals
lead chromate (chrome yellow, chrome green,
pigments in paints, molybdenum orange) zinc chromate barium
inks, and plastics chromate calcium chromate potassium
dichromate sodium chromate
chromic trioxide (chromic acid) zinc chromate
barium chromate calcium chromate sodium
chromate strontium chromate
stainless steel and
hexavalent chromium (when cast, welded, or torch
ammonium dichromate potassium chromate
potassium dichromate sodium chromate
wood preservation chromium trioxide
leather tanning ammonium dichromate
Common jobs with potential chrome 6 exposure
Chrome plating or
Welding or cutting on
stainless steel or grinding
on objects painted with
Auto body repair
Aircraft spray painting
Other jobs with potential chrome 6 exposure
Chromium dye and catalyst
Plastic colorant production
Road strip painting
Refractory brick restoration
Paint removal from bridges
Hazardous waste site work
Erosive to stomach, Hemorrhaging and death are likely
Direct eye contact with chromic acid or chromate dusts can
cause permanent eye damage.
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.
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.
Chrome VI is classified as a known
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
Greater Risk Than Asbestos
Cancer risk from Cr (VI) at new PEL is higher than
asbestos and benzene risk at their PELs
Asbestos: 6.7 deaths per 1000 workers
Benzene: 10 deaths per 1000 workers
Chrome VI: 10-45 excess lung cancer deaths per
1000 workers for 45 years of exposure at new PEL
of 5 ug/m3
Major Health Effects
Nasal septum ulcers or lung cancer
Bronchitis or asthma
Perforation of the nasal septum
from chrome 6 exposure
Chrome 6 effects on skin
Allergic and irritant
“Chrome hole” on finger
Skin effects are not likely in welding, but
can occur in electroplating or painting
New Cr VI OSHA Standard
Suit by Public Citizen Health Research Group; Paper, Allied
Industrial, Chemical, and Energy Workers Union
4/2/2003 - 3rd Circuit Court of Appeals rules standard by
2/28/2006 - Final Rule published
20 or more employees - November 27, 2006.
19 or fewer employees - May 30, 2007.
For all employers, engineering controls May 31, 2010.
OSHA and the Steelworkers engaged in settlement
agreement required engineering controls on an expedited
schedule (by December 31, 2008), but will have relief from
certain respirator requirements in the interim.
Portland Cement is exempted.
General Industry 29 CFR 1910.1026
Permissible exposure limit (PEL).
Methods of compliance
Protective work clothing and equipment
Hygiene areas and practices
Construction Industry 29 CFR 1926.1126
No definition of a Regulated Area
Notify Employee’s within 5 days of receipt of results
15 days General Industry
Action level - 2.5 µg/m³ (8-hour TWA).
Permissible Exposure Limit - 5 µg/m³ (8-hour
This has been lowered from the past level of 52
micrograms per cubic meter of air (52 µg/m³).
But it is higher than the original proposed PEL of
Two limits for Chrome 6 in air
Limit (PEL) 5 micrograms per
8-hour average exposure limit
in the air
Action Level (AL) 2.5 micrograms
per cubic meter
half of the PEL in the air
Comparison of OELs
Carbon steel (confined spaces)
Priming with zinc chromate primers
Pesticide Application (Wood Preservative)
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%
Zinc Chromate and Strontium Chromate
• Also present in in adhesives/sealants
Chromates required for proper adhesion
Chromate free primers are being researched
Exposure occurs during spray painting
• Special sample handling required
Exposures occur during sanding and bead blasting
Plating and Chromic Acid
Chrome Plating produces chromic acid mists over
the plating tanks.
The mist is created by the electroplating currents
causing bubbles in the solution. The bubbles pop at
the surface and create a mist over the tank
Tank ventilation systems are common, but are
Other chromic acid exposures occur from chromic
acid solution preparations.
Chromic acid flakes are dumped mixed into solutions
for many chemical processes
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
Objective data means:
Information such as air monitoring data from industry-wide
Calculations based on the composition or chemical and
physical properties of a substance
How do you Sample?
Ship within 24 hours
Note type of operation
In breathing zone
Under welding visor
Target value is 0.050 µg/100 cm2
If samples show < Action Level
May discontinue monitoring
If samples show ≥ Action Level
Periodic monitoring every six months
If samples show ≥ Permissible Exposure Level
Periodic monitoring every three months
Additional monitoring where process has changed
Notification of air monitoring results
If air monitoring shows chrome 6 levels in
the air exceed the PEL we must:
- Notify you within 5 days in construction
or within 15 days in general industry
- Describe to you in writing what
corrective actions we will take to reduce
your exposure below the PEL.
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 non-
mandatory 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
If exposure above the PEL is less than 30 days per year, Use
of respiratory protection alone to comply.
No rotation of employees to different jobs to achieve
compliance with the PEL.
Fume extractor for stick welding on
Use MIG/TIG welding on stainless steel
Fume extractor for enclosed welding on
any kind of steel
Weld using smaller rods
Weld using lower amperage (temperature)
Keep head out of rising plume
Welding work practices
When welding, keep your
head out of the welding
Use available local exhaust
ventilation at all times.
Welding in confined spaces
Welding on stainless steel in a confined space will
most likely require both exhaust ventilation and
the use of respirators.
Substitute with non-Cr VI paint, if possible
Conduct spray painting in an extremely well-
designed 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
Use Paint strippers to eliminate airborne exposures
Personal Protective Equipment
When exposure to hazards cannot be engineered completely
out of normal operations or maintenance work, and when
safe work practices cannot provide sufficient additional
protection, a further method of control is using protective
clothing or equipment.
1910.1026(f)(1)(ii) Where painting of aircraft or large aircraft
parts is performed in the aerospace industry, the employer
shall use engineering and work practice controls to reduce
and maintain employee exposure to chromium (VI) to or
below 25 µg/m3. The employer shall supplement such
engineering and work practice controls with the use of
respiratory protection that complies with the requirements of
paragraph (g) of this section to achieve the PEL.
Protective Work Clothing and Equipment
Where a hazard is present or is likely to be present from skin
or eye contact with chromium (VI);
Provide appropriate personal protective clothing and equipment
at no cost to employees, and
Ensure that employees use such clothing and equipment.
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.
Protective Work Clothing and Equipment
No employees may remove chromium (VI)-contaminated
protective clothing or equipment from the workplace, except
for those employees whose job it is to launder, clean,
maintain, or dispose of such clothing or equipment.
All protective clothing and equipment required by this section
shall be cleaned, laundered, repaired and replaced as
needed to maintain its effectiveness.
The removal of chromium (VI) from protective clothing and
equipment by blowing, shaking, or any other means that
disperses chromium (VI) into the air or onto an employee's
body is prohibited.
Protective Work Clothing and Equipment
Use where skin or eye contact with chrome 6 will occur or is likely to
Normal welding PPE (welding helmet, gloves and welding leathers)
is O.K. for welders
Remove all PPE when work shift or task is completed. Don’t wear or
take it home.
Protective Work Clothing Use
Don’t remove chrome 6 dust or residue from clothing by
blowing, shaking, or any other means that disperses the dust
into the air or onto the body.
Don’t shake out dusty
Don’t use compressed coveralls or clothes
air to clean clothing
Laundering and Cleaning PPE
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
Types of Respirators for Chrome 6
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.
Based on airborne exposure
Hygiene Areas and Practices
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)
Hygiene Areas and Practices
If you have a job where chrome 6 can get on your skin or in
your eyes, the employer must provide the following:
– separate storage facilities for PPE and street clothes
Be sure to wash hands and face:
at the end of the work shift
before eating, drinking, smoking,
chewing tobacco or gum, applying
cosmetics, or using the toilet
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
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
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
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
Professional’s (PLHCP’s) explained results of exam to
Employer shall provide copy to employee within 2 weeks
29 CFR 1926.1126(i)
Who Must Be Provided Medical Exams?
Any employee exposed at or above the action level for 30
or more days per year.
Any employee experiencing signs or symptoms of chrome
Any employee exposed in an uncontrolled release of large
amounts of chrome 6 in any form.
Medical Exams (cont.)
Are done by or under the supervision of a
physician or other licensed health care
Provided at no cost to you at a reasonable
place and time
Medical Exams will do the following:
Determine if you can be exposed to Chrome 6 without
experiencing adverse health effects.
Identify chrome 6 related adverse health effects so that
appropriate measures can be taken.
Determine your fitness to use respirators.
Medical exams will include the following:
Medical and work history
Cr(VI) exposure (past, present, future)
History of respiratory system dysfunction
History of asthma, dermatitis, skin
ulceration or nasal system perforation
Smoking status and history
Physical examination, with emphasis on the
respiratory tract and skin
Any additional tests deemed appropriate by the
Medical Exams are offered:
Within 30 days after initial assignment and annually
Within 30 days after a doctor recommends additional
When employees shows signs or symptoms of Chrome 6
Within 30 days after exposure during an emergency
At the termination of employment
Healthcare professional’s written medical opinion
After your medical exam the health
care professional will give a written
medical opinion to us within thirty
Specific findings or diagnoses
unrelated to occupational exposure to
chrome 6 will be not revealed to us
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
29 CFR 1926.1126(j)
WA State Department of Labor and Industries, Video
Can down load for free from:
OSHA has determined that the PEL of 5 µg/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 µg/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.
Hexavalent chromium inspections
May 30, 2006 to December 31, 2007
78 Fed inspections with violations of 1910.1026
72 inspections in General Industry
6 inspections in Construction
0 inspections in Shipyards
# of total Cr(VI) violations = 155
$ amount of total current penalties = $157,534.00
72 inspections in General Industry with 1910.1026 violations
Breakdown of these 72 employers by SIC code:
• (7) ---- 3471 Electroplating, Plating, Polishing, Anodizing, and Coloring
• (5) ---- 3499 Fabricated Metal Products, Not Elsewhere Classified
• (5) ---- 3443 Fabricated Plate Work (Boiler Shops)
• (3) ---- 3444 Sheet Metal Work
• (3) ---- 3441 Fabricated Structural Metal
• (3) ---- 3325 Steel Foundries, Not Elsewhere Classified
• (2) ---- 7699 Repair Shops and Related Services, Not Elsewhere Classified
• (2) ---- 3743 Railroad Equipment
• (2) ---- 3728 Aircraft Parts and Auxiliary Equipment, Not Elsewhere Classified
• (2) ---- 3559 Special Industry Machinery, Not Elsewhere Classified
• (2) ---- 3535 Conveyors and Conveying Equipment
• (2) ---- 3442 Metal Doors, Sash, Frames, Molding, and Trim Manufacturing
• (2) ---- 2521 Wood Office Furniture
• (1) ---- etc., for (32) other SIC codes
List of the 5-most cited Cr(VI) violations:
1910.1026(d)(1) - didn't determine exposure
1910.1026(c) - exposure exceeded PEL
1910.1026(e)(1) - no regulated area
1910.1026(k)(1)(i)(A) - no medical surveillance
1910.1026(l)(2)(i)(A) - no employee knowledge of
The Hexavalent Chromium standard can be a
problem. It is a comprehensive vertical standard
with many requirements, if it applies to you
Evaluate your Workplace
• (Stainless Steel is the trigger)
Evaluate exposure controls
Implement the full 1910.1026 standard
Self check using the CPL
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