As a known carcinogen, regulators have taken measures to reduce workplace exposure to hexavalent chromium, a chemical produced by a number of industrial processes. This article will answer several key questions about safety and compliance for the Hexavalent Chromium OSHA Standard, including:
Hexavalent chromium, Cr(VI), is a toxic form of chromium and is commonly present in fumes emitted during production or welding of chrome alloys (e.g. stainless steel). Airborne Cr(VI) can be inhaled as a dust, fume, or mist. Hexavalent chromium, aka hex-chrome, is known to cause lung cancer, throat and lung damage, and irritation to the nose, eyes, and skin.
Because of the threat it poses to workers, OSHA has a designated standard for hex-chrome exposure. There are actually three versions of the standard: general industry; shipyards; and construction. These variations are largely the same, with the general industry standard incorporating housekeeping measures to reduce surface accumulations of Cr(VI).
The permissible exposure limit (PEL) for all three standards is an 8-hour time-weighted average (TWA) of 5 µg/m3. In other words, over the course of an 8-hour shift, a worker should not face an average exposure over 5 µg/m3.
There is also an “action level” set at 2.5 µg/m3, meaning that exposures above the action level trigger specific requirements for additional testing and monitoring.
Any business subject to the OSHA hexavalent chromium standard must determine the 8-hour TWA exposure for each worker exposed. If multiple workers perform the same job under the same conditions, a “representative sampling” may be used, as long as the data applies to the highest potential exposure level for any member of the representative group.
There are two options for exposure monitoring:
This process involves taking a sufficient number of personal breathing zone air samples to accurately determine exposure on each full shift, for each job, in each applicable work area. If the exposure levels are under the 2.5 µg/m3 action level, no additional monitoring is required unless conditions change that could impact the exposure level to workers.
If the initial exposure level readings fall between the 2.5 µg/m3 action level and the 5.0 µg/m3 PEL, additional periodic monitoring is required every six months.
If the exposure levels are above the 5.0 µg/m3 PEL, monitoring must be conducted every three months.
In performance monitoring, the TWA is determined by some combination of air monitoring data, historical monitoring data, or objective data sufficient to accurately determine worker exposure. Performance monitoring need not be conducted at any specific intervals, but exposure evaluation must be executed anytime there’s a change in the process or conditions that could impact the workers’ exposure levels.
To satisfy the OSHA requirements for hexavalent chromium testing, you must use a method of that delivers ∓25% accuracy at least 95% of the time for airborne concentrations. Therefore, only certain types of testing methods will satisfy OSHA standards, with the most common being OSHA method ID215 (version 2).
Applicable hex-chrome monitoring methods use a personal sampling pump and filter (you cannot use a direct-reading, badge-type monitor). The monitor uses a cassette to record the air samples, which are sent to a laboratory for analysis. The samples must be collect on a 37mm diameter polyvinyl chloride filter (5 micrometer (µm) pore size) using a flow rate of two liters per minute. Furthermore, welding samples must be analyzed within eight days of collection.
To comply with the standard, employers are required to maintain records related to their air monitoring data, historical monitoring data, and objective data. The records must indicate:
A major component of compliance to OSHA standards is proper recordkeeping – knowing and understanding how to maintain all the data required to avoid citations and fines.
OSHA and other regulatory standards can be complex, yet unforgiving for a lack of understanding or comprehension. The complexity and strict requirements of the OSHA hex-chrome standard demand that expertise with the equipment and recordkeeping guidance is necessary to ensure compliance. A professional safety consultant ensures your monitoring is accurate, effective, and meets all the regulatory requirements.
Utilizing an outsourced expert for hex-chrome monitoring also reduces your liability by sharing the responsibility of compliance. Additionally, the third party is independent and not influenced by company behaviors or conflicts of interest that could compromise compliance.
The cost of ensuring compliance is almost always less than the cost of failing to comply, which is why outsourcing to experts like SITEX makes hex-chrome testing easy and reliable. To speak with an expert about satisfying hex-chrome compliance for your business, fill out the form or call us at 888-655-1603.
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