On August 17, 2006 Cal/OSHA adopted new regulations regarding chromium(VI), also known as Cr(VI) and hexavalent chromium. The permissible exposure limit (PEL) for airborne exposure to Cr(VI) has been lowered to 5 micrograms per cubic meter (μg/m3) as an 8-hour time-weighted average (TWA). The new PEL can be found in Title 8 of the California Code of Regulations, §5155. The much lower PEL for strontium chromate that was already in effect has not changed.
Workers exposed to Cr(VI) are at an increased risk of developing lung cancer. Occupational exposure to Cr(VI) may also result in asthma, nasal septum ulcerations and perforations, skin ulcerations, and dermatitis. Some of the processes during which exposure may occur include spray coating with chromate containing materials, chrome plating, and stainless steel welding and cutting.
Besides the change in PEL, Cal/OSHA adopted expanded standards for Cr(VI) in Construction (§1532.2), General Industry (§5206), and Ship Building, Ship Repairing, and Ship Breaking (§8359). Although there are some differences between these separate standards, for the most part they are the same.
The expanded standards apply to all occupational exposures to Cr(VI) except:
Employers with 20 or more employees must comply with all applicable requirements, except engineering controls, by November 27, 2006. Employers with less than 20 employees must comply by May 30, 2007.
Exposure determination. The employer must determine the 8-hour TWA exposure for each employee exposed to Cr(VI). This can be done by air monitoring alone, or through any combination of air monitoring, historical monitoring data, or objective data. Employees who are found to be exposed above the PEL must be notified of their exposures. Periodic air monitoring must be conducted if initial air monitoring finds exposures above either the action level, which is 2.5 μg/m3, or the PEL.
Regulated Areas. In General Industry, a regulated area must be established wherever an employee’s exposure to Cr(VI) exceeds, or is expected to exceed, the PEL. Regulated areas must be demarcated with access limited to authorized persons.
Engineering and Work Practice Controls. When employee exposures exceed the PEL, engineering and work practice controls must be implemented to reduce exposures to or below the PEL. If it is not feasible to reduce exposures sufficiently, engineering and work practice controls must still be used to reduce exposures to the lowest level achievable. Required engineering controls must be implemented no later than May 31, 2010.
The requirement to implement engineering and work practice controls does not apply to processes or tasks where exposures above the PEL occur less than 30 days per year. However, the employer is prohibited from rotating employees to achieve compliance with the PEL. Less stringent requirements for reducing exposures using engineering and work practice controls apply to the painting of aircraft or large aircraft parts.
Respiratory Protection. Because employee exposures must be kept at or below the PEL, respiratory protection is required in the following circumstances:
Protective work clothing and equipment. Appropriate personal protective clothing and equipment must be provided and worn when necessary to prevent hazardous skin and eye contact with Cr(VI). There are special requirements for laundering, cleaning, maintaining, transporting, storing, and disposing of protective clothing and equipment.
Hygiene areas and practices. Where protective clothing and equipment is required, the employer must provide change rooms equipped with storage facilities for street clothes plus separate storage facilities for protective clothing.
Where skin contact with Cr(VI) occurs, washing facilities must be provided. Employees who have skin contact with Cr(VI) must wash their hands and faces at the end of the work shift and prior to eating, drinking, smoking, chewing tobacco or gum, applying cosmetics, or using the toilet.
Eating and drinking areas must be located and maintained to prevent the contamination of food and beverages. Eating, drinking, smoking, chewing tobacco or gum, and applying cosmetics are prohibited in regulated areas or areas where skin or eye contact with Cr(VI) occurs. Products associated with these activities must be kept out of these areas.
Housekeeping. There are specific housekeeping requirements for General Industry. Surfaces must be maintained as free as practicable of accumulations of Cr(VI). HEPA-filtered vacuuming or other methods that minimize likelihood of exposure must be used. Dry shoveling, dry sweeping, dry brushing, and the use of compressed air for cleaning are only allowed in certain circumstances. Cr(VI) contaminated materials must be properly contained and labeled for disposal.
Medical surveillance. Medical surveillance must be made available at no cost to employees exposed at or above the action level for 30 or more days per year. It must also be made available to employees experiencing signs or symptoms of health effects associated with Cr(VI) and for those exposed during an emergency involving an uncontrolled release.
Communication of hazards. In addition to the requirements of the Hazard Communication standard (§5194), employees must be trained on the contents of the Cr(VI) standard and the purpose and description of the medical surveillance program. A copy of the Cr(VI) standard must be readily available to employees.
Recordkeeping. Specific records related to the exposure determination and medical surveillance must be maintained.
For More Information
The complete Cal/OSHA regulations can be found at http://www.dir.ca.gov/samples/search/query.htm. Additional information on Cr(VI) can be found at http://www.osha.gov/SLTC/hexavalentchromium/index.html.
The above evaluations and/or recommendations are for general guidance only and should not be relied upon for legal compliance purposes. They are based solely on the information provided to us and relate only to those conditions specifically discussed. We do not make any warranty, expressed or implied, that your workplace is safe or healthful or that it complies with all laws, regulations or standards.