Section 18 HEXAVALENT CHROMIUM PROGRAM Hexavalent Chromium Program Purpose To provide protection to our employees from occupational injury resulting from exposure to hexavalent chromium. Definitions The following definitions are important terms used in the hexavalent chromium standard in this section: Hexavalent Chromium (Cr (VI)) – chromium with a valence of +6 in any form or chemical compound in which it occurs. Action Level (AL) – a concentration of Cr (VI) of 2.5ug/m3 averaged over an 8 hour period. Permissible Exposure Limit (PEL) – a concentration of Cr (VI) of 5.0ug/m3 averaged over an 8 hour period. Regulated Area – a controlled access to an area where exposure to Cr (VI) exceeds the PEL. Training Program Murray Sheet Metal Co. Inc. shall institute a training program for all employees who are subjected to Cr (VI) above the action level without regard to respirator use. Those employees shall participate in the training before commencing work. General Determination of airborne exposure levels shall be made from air samples that are representative of each employee exposure to Cr (VI) over an 8 hour period. Employee exposure is that exposure which would occur if the employee were not wearing a respirator. Personal samples shall be collected during a full shift of 7 hours (preferred); however, partial shifts are acceptable if tasks involving possible exposure to Cr (VI) last less than 7 hours. These samples include one for each classification, such as welding and burning. Frequency If the initial monitoring reveals the exposure to be below the action level of 2.5ug/m3, then no corrective action is necessary and the area can be deregulated. If the monitoring reveals the exposure to be at least 2.5 ug/m3 but below the PEL (5.0 ug/m3), the area may be deregulated with respect to personal protection equipment and demarcation areas. Monitoring shall be conducted at least every 6 months until results indicate exposure below the AL. If the monitoring reveals exposure at or above the PEL, the area must continue to be regulated. Monitoring will continue until 2 consecutive samples reveal concentrations below the AL. Where regulated areas are established, only authorized employees will be allowed entry. All employees entering regulated areas will be required to have been trained and shall use the proper personal protective equipment. Additional Monitoring Whenever there has been a production, process or control change which may result in new or additional exposure to Cr (VI), additional monitoring shall be conducted. Exposure Control Engineering controls are the preferred method of controlling exposure to Cr (VI). Ventilation is the most common engineering control and can be achieved by using vents, air movers or exhaust hoods to remove welding fumes or dust away from individual employees. Any work method which reduces the levels of dust or fumes will lower employee exposure. Proximity and employee positioning can also be used to lower exposure to Cr (VI) and should be used whenever practical. Regulated Areas Where exposure levels dictate an area needs to be regulated, these areas will be barricaded with tape or rope and appropriate signage. Signs will be placed at the entrance(s) to regulated areas. The areas will remain regulated until monitoring indicates levels below the PEL. Signage Signs posted at entrances to regulated areas will be maintained to insure they are readily visible and shall state: DANGER CHROMIUM (VI) CANCER HAZARD CAN DAMAGE SKIN, EYES, NASAL PASSAGES AND LUNGS AUTHORIZED PERSONNEL ONLY RESPIRATOR REQUIRED Respirator Usage When working in areas where initial monitoring is being performed, where exposure levels exceed the PEL, or inside the regulated area, respirators are required to be worn. Upon satisfactory completion of mandatory fit testing and authorized medical approval to wear a respirator, select a respirator from the chart below depending on concentration: Airborne Concentration Required Respirator 10 X PEL or less Half face air purifying respirator with P100/HEPA filters 25 X PEL or less Powered air-purifying respirator (PAPR) with loose fitting hood or helmet equipped with P- 100/HEPA filters, or supplied air respirator with loose fitting hood or helmet face piece operated in the continuous flow mode 50 X PEL or less Full face piece air-purifying respirator equipped with 100/HEPA filters, or a PAPR with tight fitting half mask equipped with P-100/HEPA filters, or a supplied air respirator (SAR) with a tight fitting half mask operated in the continuous flow mode. 250 X PEL or less PAPR with a tight-fitting face piece equipped with P-100/HEPA filters or a SAR with a tight fitting full face piece operated in the continuous flow mode 1000 X PEL or less SAR with half mask or full face piece operated in the pressure-demand or other positive pressure mode 1000 X PEL or less Self-contained breathing apparatus with a full face piece Unknown operated in the pressure-demand or other positive pressure mode, or a SAR with a full face piece operated in the pressure-demand or other positive pressure mode, and equipped with an auxiliary escape-type self-contained breathing apparatus operated in the pressure-demand mode Personal Protective Equipment When employee exposure to Cr (VI) exceeds the PEL without regard to respirator use, personal protective equipment must be utilized. This equipment includes coveralls (or similar full body clothing), head covers, foot covers, gloves and eye/face protection. When working on hot work, off ladders, or during other instances where the use of foot covers presents a greater hazard, foot covers can be discontinued provided that employee’s footwear is decontaminated prior to leaving regulated area by a HEPA vacuum and/or wet washing. PPE can be disposable or reusable. Reusable PPE would include cloth coveralls, cloth or leather gloves, cloth hoods, and shoes or boots only worn at work. Disposable PPE includes paper or synthetic clothing, shoe and head covers. When performing hot work, appropriate cloth coveralls should be used. Disposable coveralls (paper and the like) are not allowed when performing hot work. Protective clothing shall be maintained so that it retains its integrity. This includes cleaning, laundering, repairing and replacing when necessary. Disposable clothing may be used repeatedly as long as the integrity is not impaired. Cleaning Reusable Clothing When laundering Cr (VI) contaminated clothing, provisions must be made to minimize exposure to laundry personnel. Commercial laundry services must be notified of the presence of Cr (VI) contamination. Contaminated clothing shall be placed in a closed container and labeled as follows: CAUTION! – Clothing contaminated with hexavalent chromium. Do not remove by blowing or shaking. Dispose of hexavalent chromium contaminated wash water in accordance with applicable local, State or Federal Regulations. Hygiene & Facilities In an effort to prevent employees from spreading contamination to other work place areas and to areas away from work, the following practices shall be utilized: A. Change Rooms When feasible, clean change rooms should be provided for storing employees personal clothing and other personal items. Clean and contaminated clothing shall have provisions to be stored separately. If a change room is not feasible, Non-contaminated personal clothing may be stored in containers, vehicles or other areas outside the regulated area. Personal protective equipment shall be donned before entering the work area. When leaving the work area during the work shift, all personal protective equipment shall be HEPA vacuumed, removed and left outside the entrance to the regulated area. Employees shall wash their hands and face before eating, drinking or smoking. B. General No smoking, eating, drinking or applying cosmetics shall take place when working with Cr (VI). Compressed air is not to be used for decontamination. Decontaminate all protective gear, respirators and tools according to standard procedures. Medical Surveillance Employees who are or will be exposed at or above the AL for Cr (VI) for 30 or more days in any consecutive 12 month period shall be included in a medical surveillance program. Medical surveillance will also be offered to any employee who experience signs and symptoms of Cr (VI) exposure or are exposed in emergency situations resulting in uncontrolled release of Cr (VI). Training An employee training program will be given to all employees who have a potential exposure to Cr (VI). The training program will consist of: 1. Health hazards associated with Cr (VI) exposure; 2. Sources of exposure and necessary protective steps; 3. Purpose, proper use and limitations of respirators; 4. Purpose & description of medical surveillance program; 5. Engineering controls and work practices that employees can take to protect themselves; and 6. A review of the OSHA Standard. Recordkeeping and Notification A. Exposure Monitoring Records Cr (VI) exposure monitoring records must be kept for the duration of employment plus 30 years. B. Medical Surveillance Records Cr (VI) medical surveillance records must be kept for the duration of employment plus 30 years. C. Training Records Training records will be retained until the next refresher or 5 years, whichever is shorter. D. Notification Results of air monitoring, medical findings or opinions will be made available to employees within 5 working days of receipt.