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Hexavalent Chromium OSHA Standard

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					Hexavalent Chromium
  OSHA Standard
    Capt Michael Moran
   Brooks City-Base, TX
                   Overview
•   Health effects of hexavalent chromium (Cr+6)
•   OSHA PEL
•   Compliance schedule
•   Monitoring requirements
•   Employee Training
•   Medical Surveillance
•   Engineering Controls &Work practices
                Health Effects
• Lung Cancer
   – Epidemiology (human data) and animal studies link
     chromate exposure to lung cancer
• Asthma
   – Airway sensitizer, not all become sensitized
• Nasal epithelia damage
• Skin damage
   – (Ulcers, dermatitis, allergic reactions, chrome hole)
          New OSHA PEL
• Permissible Exposure Limit (PEL)
  – 8-hr TWA of 5 mg/m3 as Cr+6

• Action Level (AL)
  – 8-hr TWA of 2.5 mg/m3 as Cr+6


• ACGIH TLV
  – 0.5 mg/m3 (Strontium Chromate as Cr)
       Compliance Schedule
• Effective Date: 30 May, 2006
• November 27, 2006
  – All requirements except engineering controls
     • Change rooms
     • Washing facilities
     • Sampling
• May 31, 2010
  – Engineering controls
       Monitoring Frequency
        Option 1, Scheduled
• 8-Hr TWA < Action Level
  – No additional monitoring required

• Action Level < 8-Hr TWA < PEL
  – Monitoring required every 6 months

• PEL < 8-Hr TWA
  – Monitoring required every 3 months
     Monitoring Frequency
   Option 2, Performance-based
• Historical data
• Objective data
  – Industry-wide surveys, calculations
• Initial/Periodic Monitoring

• * Must ACCURATELY characterize
  exposure
      Employee Information
• Hazcom
• Demonstrate knowledge of the purpose and
  description of medical surveillance program
       Medical Surveillance
• Employees who require surveillance
  – Exposed above action level for 30 or more
    days/yr
  – Shows signs /symptoms of adverse health
    effects associated with Cr+6 exposure
  – Exposed during emergency
         Medical Surveillance
• Surveillance Frequency
  –   Within 30 days of after initial assignment
  –   Annually
  –   Within 30 days of written medical opinion
  –   Shows signs/symptoms of exposure
  –   Within 30 days of exposure from emergency
  –   At termination of employment
       Engineering Controls
        and Work Practices
• New standard requires engineering controls
  and work practices to reduce exposures
  below PEL
  – Eliminate need for respiratory protection
• Aerospace Exception (painting aircraft)
  – Engineering controls & work practices must
    reduce exposure < 25 mg/m3
                    Mean Cr(VI) Exposures during Aircraft Corrosion Control
                     (Shaw, Cannon, Holloman, Nellis, Hill, Robins, Tinker, McChord)



                   1000
8-hr TWA (mg/m3)




                   100

                                                                                       25 mg/m3
                    10
                                                                                       5 mg/m3

                     1          5.51                 9.22                137


                    0.1
                              Sanding        Conversion Coat           Priming
       Engineering Controls
        and Work Practices
• Ventilation
  – Filter change out schedules
  – Performance assessments
     • Magnahelic Gauges
     • Quarterly Vent Surveys
     • Smoke generator
         Engineering Controls
          and Work Practices
• Sanding
  –   Use ventilated sander w/ HEPA vacuum
  –   Keep surface of sander as flat as possible
  –   Reduce the depth of sanding
  –   Avoid proximity of co-workers
      Engineering Controls
       and Work Practices
• Dust Removal
  – Use HEPA vacuum to remove dust from
    aircraft
  – Use HEPA vacuum to remove dust from hangar
    floor
  – Wipe aircraft twice with 1:1 isopropyl
    alcohol/water mixture
        Engineering Controls
         and Work Practices
• Priming
  – Proper body position
     • Keep side or back to the direction of airflow
     • Start priming from the end of the aircraft nearest the exhaust
  – Minimize # of painters (Ideally 1 person)
     • Avoid mirror painting
  – Ensure air pressures meet manufacturer’s
    recommendations
     • Wall, pressure pot and gun air cap
                         Maximum Cr(VI) Exposures Before & After Modified
                                    Procedures (Shaw AFB)

                   100
8-hr TWA (mg/m3)




                                                                      25 mg/m3

                   10
                                                                      5 mg/m3


                    1



                   0.1                                                  Before
                             Sanding      Dust Removal     Priming      After
                         Maximum Cr(VI) Exposures Before & After Modified
                                   Procedures (Cannon AFB)

                   100

                                                                               25 mg/m3
8-hr TWA (mg/m3)




                   10
                                                                               5 mg/m3



                    1



                   0.1                                                            Before
                         Sanding gears Sanding A/C Priming Gears Priming A/C      After
               Conclusion
• Compliance is a joint effort
  – Partnership with Bioenvironmental Engineering
    & Corrosion Control Community
  – Technical Support @ AFIOH
  – Sharing information (successes and failures)
Questions

				
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posted:9/14/2011
language:English
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