Chromium VI by fjzhangweiqun

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									Hexavalent Chromium Cr (VI)
    National Emphasis Program
New OSHA Instruction
      National Emphasis Program on
          Hexavalent Chromium

Purpose: “To identify and reduce or
 eliminate the health hazards associated
 with occupational exposure to hexavalent
 chromium and other toxic substances in a
 select group of industries.”
Key Elements
• Information for selecting sites for inspection
• Procedures for conducting inspections with
  emphasis on IH evaluations
• Measures to ensure safety and health of OSHA
  compliance staff
• Program evaluation procedures
• Plans for outreach to train OSHA compliance
  staff and general public on hazards addressed
  by this NEP and effective abatement methods
General Information
• Hexavalent chromium compounds all
  contain the chromium (+6) ion (CAS
• Also written as Chromium (VI) or Cr(VI)
• Occupational Hazards:
  – Increased risk of lung cancer from inhalation
  – Irritation and sensitization to lungs, throat,
    nose, eyes, and skin
What is Chromium (VI)?
• Toxic form of chromium metal that is
  generally man-made
• Exists as many types of CrVI compounds
  that vary in their solubility and use
• Used in many industrial applications
  primarily for its anti-corrosive properties
What is Chromium (VI)?
• Chromium with valence of positive six, in
  any form or chemical compound in which it
• CR(VI) In all states of matter, any
  solution or other mixture, even if
  encapsulated by other substances
• Term also includes industrial process that
  creates Cr(VI) fumes
How is Cr (VI) Formed?
• Created during “hot” work processes such
  as welding on stainless steel or the
  melting chromium metal
  – Chromium metal is ionized
    into the fume high
    temperatures and chemical
    reactions temporarily oxidizes
    the chromium ion into a
    hexavalent (+6) state
Hexavalent chromium compounds
in industrial use

 – Chromate pigments in dyes, paints, inks, and
 – Chromates added as anticorrosive agents to
   paints, primers, and other surface coatings
 – Chromic acid electroplated onto metal parts to
   provide a decorative or protective coating
Major Industries
• Electroplating            • Chromium dye and
                              catalyst production
• Welding on stainless
  steel or Cr(VI) painted   • Glass manufacturing
                            • Plastic colorant
• Painting                    production
   – Aerospace
   – Auto body repair       • Construction
                               – Traffic painting
• Chromate pigment and         – Refractory brick
  chemical production            restoration
                               – Paint removal from
Other Toxic Substances
• Number of toxic substances found to be
  present in same industrial applications
  where hexavalent chromium is or could be
  •Antimony        •Copper Fume   •Nickel
  •Arsenic         •Lead          •Silver
  •Cadmium         •Iron Oxide    •Tin
  •Cobalt          •Manganese     •Zinc Oxide
  •Calcium Oxide
Program Procedures
•   Industry Selection
•   Inspection Scheduling
•   Complaints and Referrals
•   Voluntary Compliance Programs
•   Strategic Partnerships
•   Expanding Scope of Inspection
•   Inspection Procedures
•   Outreach
•   Follow-Up and Monitoring
•   Coordination
•   Federal Agencies
•   NEP Evaluation
•   IMIS Coding Instructions
Industry Selection
• Appendix A
  – List of SIC Codes for industries determined likely to
    have employees exposed to Cr (VI) and other toxic
  – Not a comprehensive list, but intended as primary
• Industries not in Appendix A
  – Known by Area Office, based on local knowledge may
    be added
  – AO must document the addition and maintain such
    documentation for the duration of NEP
Industry Selection
• Master List Generation
  – Using D&B employer listing, the Office of
    Statistical Analysis (OAS) will prepare master
    list for each AO
• Targeting Sources
  – AOs may consider local sources including
    local manufacturing/services directories,
    telephone listings, local knowledge, and
    previous inspection history
  – Establishments with fewer than 10 employees
    shall also be included
Industry Selection
• Deletions
  – AOs shall delete from inspection target list
    any facilities:
     • Not likely to have Cr (VI) hazards
     • Known to be out of business
     • Which have had health inspections in preceding
       two years addressing Cr (VI) and other toxic
       substance hazards, provided
        – no citations were issued or;
        – that citation(s) were issued, but follow up inspection
          documented tangible appropriate and effective efforts to
          abate the serious hazards cited; or OSHA received and
          confirmed that violations have been abated.
Industry Selection
• Cycle Generation
  – Sequential Number will be assigned
  – After randomizing list, AO will create inspection cycles
    of five (5) or more establishments
  – Subsequent cycles will be created until expiration of
    NEP or until all establishments on list have been
    assigned to a cycle
  – When AO becomes aware of previously known
    establishment in one of targeting SICs, that
    establishment shall be added to master inspection
    targeting list for inclusion in selection process for next
    inspection cycle
Inspection Scheduling
• May be scheduled in any order to make efficient
  use of resources
• Cycle must be completed before another cycle is
  started (except that establishment may be carried over in accordance with
   OSHA Instruction CPL 02-00-025.)
• Beginning with current fiscal year
• Will continue until further notice or until all on list
  have been inspected
• Some establishments selected for inspection
  under this NEP may also be selected for
  inspection under current Site-Specific Targeting
  (SST) Plan or other NEPs and/or LEPs
Inspection Scheduling
• Some targeted industries for this NEP
  overlap with other NEPs including those
  currently targeting combustible dust, lead,
  amputations and silica
• When possible, NEP inspection should be
  conducted concurrently with SST or other
  programmed inspections
Complaints and Referrals
• General Industry
   – Must be handled in accordance with procedures outlined in CPL
     02-00-140- Complaint Policies and Procedures
   – Considered high-gravity, serious and handled by inspection
• Construction
   – Document status/condition of work operation, noting any serious
     hazard(s). (Documentation of events leading up to observation must be
     maintained in file.)
   – Note location of worksite and name/address of employer(s)
     performing operation
   – Handle in accordance with procedures in CPL 02-00-140,
     Complaint Policies and Procedures and OSHA FOM, CPL 02-
   – When safety CSHO encounters site where Cr(VI) exposures
     may exist during course of any construction inspection,
     appropriate health referrals will be made
Voluntary Compliance Programs
• Employers participating may be exempt
  from programmed inspections
• If establishment participates in VPP or
  SHARP Follow procedures outlined in
  OSHA FOM (CPL 02-00-148), Chapter 2
Strategic Partnerships
• Shall be conducted in accordance with
  terms outlined in partnership agreement
• May be exempt from programmed
  inspection for six (6) months,
• May qualify for focused (or limited scope)
Expanding Scope of Inspection
• May expand the scope of inspection under
  this NEP if other hazards or violation
  conditions are observed and/or brought to
  their attention
• CSHO shall follow guidelines in FOM
  when expanding scope of inspection
   Inspection Procedures
                                     Search OSHA/IMIS database for
Inspection scheduled for                                                             CSHO determines if any other current
                                     employer citation & fatality/
identified establishment                                                             NEP such as amputations,
                                     accident history prior to
                                                                                     combustible dust, lead or silica, etc.
                                     assignment of inspection

              SIC Code NOT listed in Appendix A Exit
              facility without conducting inspection                             At opening conference, CSHO verify w/
                                                                                 employer correct SIC code for establishment

  SIC Code NOT listed in Appendix A, but determined
  employees using materials containing Cr(VI) or other toxic
  substance  Proceed with programmed inspection
                                                                                            CSHO to consider & evaluate employee
                                                                                             exposures & compliance in regard to:
                                                                                           •Regular Operations
                                                                                           •Setup & preparation for regular operations
                                                                                           •Clearing process upsets
          CSHO will verify w/                         Proceed with inspection with         •Making Adjustments during operations
          employer any process that                   particular attention to
          may produce Cr(VI) or other                                                      •Cleaning of process area
                                                      employee exposure to Cr(VI)
          toxic substance exposures                                                        •Scheduled & unscheduled maintenance
                                                      or other toxic substances
          are conducted at facility                                                        •Implementation of engineering controls
                                                                                           •Use of PPE
                                                                                           •Medical Surveillance programs
                                                                                           •Employee training & education
Inspection Procedure
                                                                          If exposure monitoring is
When present, MUST                   IH shall take properly
                                                                          not conducted A thorough
include personal exposure            calibrated instruments and
                                                                          explanation for not
monitoring in ALL cases              sampling media with them
                                                                          monitoring is to be included
                                     on FIRST day of inspection
                                                                          in inspection file

       If determined that operations with
       exposure to Cr(VI) or other toxic             If safety hazards are noted that cannot be
       substances are NOT present, but               appropriately dealt with by IH CSHO, an
       establishment listed in another               appropriate safety referral will be made
       current NEP, CSHO shall proceed
       with comprehensive inspection

        ALL potential hazards observed
        in course of any inspection
        conducted under this NEP shall
        be appropriately addressed
Protection of CSHO’s
• Shall conduct hazard determination to establish presence of Cr (VI)
  (or other toxic substances) PRIOR to initiating the walk around

• Rely on information such as previous inspection history, material
  safety data sheets, professional judgment, and/or previous exposure
  monitoring surveys

• Personal Protective Equipment (PPE) to be used during inspection
  such as: Respirators, gloves and/or protective clothing (made
  available to CSHO’s prior to inspection) and WILL be worn based on
  CSHO’s determination of their expected exposure to hazard

• Additional information can be found in Appendix B

• Any equipment utilized during course of any inspection initiated
  under this NEP should be appropriately decontaminated
• Letters
    –   Employers
    –   Professional Associations
    –   Local Safety Councils
    –   Apprenticeship Programs
    –   Local Hospitals and Occupational Health Clinics
    –   Industry Employer Organizations
•   Speeches
•   Training Sessions
•   News Releases
•   Regional/Area Office Alliances
• Directorate of Science, Technology and
  Medicine has prepared materials
• Variety of online resources:
  – Technical link page specific to hexavalent
    chromium under the alphabetical “Site Index”
Follow-Up and Monitoring
• Follow up inspections conducted for all
  cases with documented
  – Exposures above any permissible exposure
    level (PEL)
  – Employer has failed to take appropriate action
• Follow up inspection conducted within
  three months after the final abatement
  date for cited violations
Follow-Up and Montoring
• CSHO shall verify employer’s abatement
  documentation/verification by carefully
  evaluating any and all
  – Air monitoring results
  – Implemented engineering controls
  – Personal Protective Equipment requirements
  – Housekeeping and employee information
  – Training
• In accordance with FOM, Chapter IX.A.
Follow-Up and Monitoring
• Personal air sampling- Conducted by
  OSHA staff in ALL situations, unless job
  task or job site is no longer active
• Use of employer generated monitoring
  data is NOT permitted for purpose of
  abatement verification under this NEP.
Follow-Up and Monitoring
• Abatement documentation/verification will be
  submitted to/collected by the Area Office
• Abatement information MUST be included in
  case file in a timely manner
• When possible, case file to be closed in the
  fiscal year in which intervention was conducted
  to allow the data to be applied to Agency’s
  Strategic Goal accomplishments
• Cases where implementation of engineering
  controls extend beyond fiscal year, case file will
  be closed as soon as possible
• National Office
  – Coordinated by the Office of Health
    Enforcement (OHE), Directorate of
    Enforcement Programs (DEP)
• Field Office
  – Each Regional Administrator is required to
    name a coordinator for this NEP
Federal Agencies
• Executive Order 12196, Section 1-201,
  and 29 CFR 1960.16 requires Federal
  Agencies to follow the enforcement policy
  and procedures contained in this Directive
NEP Evaluation
• Evaluated using data collected from case files
  and follow-up site visit reports submitted by each
  Area Office to the OHE
• Interim, current method used by Office of
  Statistics will continue to apply
• Once Office of Statistics has received
  reasonable number of case files and follow-up
  site visit reports, data will be evaluated to
  determine impact of OSHA inspections on
  reduction of hexavalent chromium exposures at
  each workplace
IMIS Coding Instructions
• All enforcement activities (inspections,
  complaints, and referrals) and compliance
  assistance (OSHA 55) conducted under this
  NEP must be coded with the NEP code:


  Entered in appropriate NEP field/item number on
  respective form
Sampling Information
• Two types of filters available for Air Sampling:
   – PVC Filters
   – Sodium Hydroxide (NaOH) Coated Quartz Fiber Filter
• PVC filters can be used for all hexavalent
  chromium air sampling but must be analyzed
  within six (6) days. *Overnight mail recommended*
• NaOH quartz filters can only be used for plating
  operations where a mineral acid chemical
  interference could occur. *These do not need to be sent
Additional Sampling Information
• Wipe samples for must be taken on PVC
  or Quartz Fiber Filters
• DO NOT USE Mixed Cellulose Ester
  (MCE), Ghost Wipes, Smear Tabs or
  Whatman Filters (these will react with any
  Cr(VI) changing it to Trivalent Chrome)
• You can order filters from lab using LISA
  or order by phone
Air Monitoring Job Aid
                                        AIR MONITORING
   For sample stability, use NaOH coated Quartz fiber filters when sampling chromium plating
    operations. The sodium hydroxide coated binderless quartz fiber filters, used to test for
    hexavalent chromium, come in an aluminized zip-lock type of bag. These are the same bags
    used to put the ozone samplers in, so there have been some mix-ups in the field. The bags will
    be clearly labeled so make sure you read the label and choose the right sampler.
 The NaOH neutralizes the acids used in the plating operation so the Chrome VI sample stays
 If you have to use a PVC filter, get it to SLTC Lab within 24 hours. In tests at SLTC, it was found
    that there is a 10% loss of Chrome VI (using PVC filters) if analysis was conducted 6 days after
    sample was taken (from chromium plating operations).

Q: Are there are 25-mm PVC filters available for sampling hexavalent chromium? These are needed
    to fit under the welding helmets.
A: Yes, SLTC has 25-mm PVC filters available for sampling hexavalent chromium, and the OSHA
    method was validated for both the 25-mm and 37-mm cassettes.
Note: It’s important to submit welding samples as soon as possible. In tests at SLTC, it was found that
    there is a 10% loss of Chrome VI (using PVC filters) if analysis was conducted 8 days after
    sample was taken (from welding operations). The reason: Fe+3 in steel turns Chrome VI to
    Chrome III.
Air Monitoring Job Aid
   Air sampling around welders and in grinding operations are more difficult because the sampling
    cassettes become overloaded when sampling for hexavalent chromium. Overloaded samples may
    clog the pores in the filter, stopping the ability of the pump to function properly.
   It may be necessary to use several cassettes to collect samples if sampling employees over a
    long period of time. There is enough sensitivity in the method that a sample for as little as 2 hours
    may be taken.
o   In welding operations, the filter will look totally brown when it is getting loaded and needs to be
    replaced with a fresh cassette.
o   In grinding or blasting operations, change the cassette when you cannot see the filter anymore.

Q: How do you get the sampling cassette to stay in place under the welding helmet as the welders
    perform their jobs?
A: Suggestions:
 Route copper tubing through the sample tubing to provide rigidity to the assembly.
 Hold things in place with duct tape.
 There are helmet cassette holders available from SKC - helmet cassette holders can be obtained
    thru CTC’s AESP (FES0001035).
Q: Can sample results for hexavalent chromium be put up on the LISA website?
A: Yes, SLTC will put the hexavalent chromium results in with the lead and silica results on LISA.
Wipe Sampling Job Aid
                                        WIPE SAMPLING
   Wipe samples for hexavalent chromium should be taken with either PVC filters or binderless
    quartz fiber filters.
   Do not use the ghost wipes to collect hexavalent chrome. The chemicals on the ghost wipe and
    the fabric base destroys the hexavalent chromium collected. In tests at SLTC, it was found that a
    surface spiked with 100 ug hexavalent chromium and wiped with a ghost wipe had a result of
    none detected 24 hours later!
   Do not use Whatman filters or smear tabs to collect hexavalent chromium as they react with the
    hexavalent chromium changing it to trivalent chromium. This occurs at a rate of 20% per day.
   Validated direct reading wipe test kit for hexavalent chromium is available from CTC to aid in
    evaluating surface exposures. It has a dramatic indication changing to a bright pink-purple in the
    presence of hexavalent chromium and has been helpful to convince workers that they have
    hexavalent chromium in break rooms, desks, etc.
Note: One CSHO was having trouble convincing the employer and workers that there were high
    exposures to hexavalent chromium, as high as 251 ug hexavalent chromium on a microwave in a
    break room. The CSHO took samples with this test kit and showed them on-site the problem
   When handling the filters for wipe testing or making up cassettes for hexavalent chromium
    sampling, use plastic tweezers available from SLTC and CTC. The chromium from steel tweezers
    will be transferred and contaminate the filter, so metal tweezers should not be used. You can
    request plastic tweezers from SLTC.
Appendix A-
List of Selected Industries
  SIC      Description
2819 (L)   Industrial Inorganic Chemicals
7692       Welding & Repair
                                            (A)- SIC targeted by
3732       Boat Building                    the Amputation NEP
3721       Aircraft Parts
3713 (L)   Truck and Bus Bodies             (L)- SIC targeted by
2821 (L)   Plastic Materials and Resins     the Lead NEP
3325 (A)   Steel Foundries, NEC
3714 (A)   Motor Vehicle Parts
3479       Metal Coating
3471       Plating
 Appendix B-
 Field Hazard Bulletin

See OSHA Instruction
(NEP- Hexavalent
Chromium) for this
Appendix C-
List of Other Toxic Substances Often Found in
Conjunction with Hexavalent Chromium

 •   Antimony           •   Lead
 •   Arsenic            •   Iron Oxide
 •   Cadmium            •   Manganese
 •   Calcium Oxide      •   Nickel
 •   Cobalt             •   Silver
 •   Copper Fume        •   Tin
                        •   Zinc Oxide

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