Section 18

              Hexavalent Chromium Program

      To provide protection to our employees from occupational injury
      resulting from exposure to hexavalent chromium.
      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.
      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.
     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.
     Signs posted at entrances to regulated areas will be maintained to
     insure they are readily visible and shall state:

                 CHROMIUM (VI)
                CANCER HAZARD
              PASSAGES AND LUNGS

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

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

     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)

     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).


     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.

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