DIVISION OF OCCUPATIONAL SAFETY AND HEALTH
POLICY AND PROCEDURES MANUAL
Hexavalent Chromium Inspection Guidelines
Issue Date: 3/10/09
AUTHORITY: California Labor Code Sections 142.3, 144.6, 6400, 6402 through 6404 and 9000 through 9009 and Title 8, California Code of Regulations (CCR) Sections 1527, 3203, 3204, 3360 through 3385, 5141, 5155, 5194, 5206, 1532.2 and 8559.
POLICY: It is the policy of the Division of Occupational Safety and Health to ensure that the Division effectively and uniformly enforces regulations covering all occupational exposures to airborne hexavalent chromium (when the substance is a carcinogen and a respiratory irritant and sensitizer) and to skin and eye exposures (when the substance is a skin sensitizer and eye irritant). Applicable provisions of Title 8 include hexavalent chromium regulations for general industry, construction and shipbuilding and also include regulations providing for proper use of personal protective equipment, training and others.Overview:
In 2006, three regulations were adopted (first by Federal OSHA and then by Cal/OSHA) for exposures to Hexavalent Chromium (Chrome VI) in the workplace: 8CCR 5206, 1532.2 and 8559 respectively in the General Industry, Construction and Shipbuilding Safety Orders. The primary intent of these standards is to prevent occupational lung cancer but Chrome VI can also cause asthma, nasal ulcerations and perforations, skin sensitization (both allergic contact and irritant contact dermatitis), skin ulcerations and eye irritations. Typical industries with Chrome VI exposures: electroplating, pigments, dyes, welding, spray painting and paint removal, primer paints in aerospace and auto refinishing. Welders make up half the employees exposed. Stainless steels contain 12 to 30% chromium; Chrome VI associated with stainless steel is created by the welding process.
Federal OSHA has adopted very detailed, specific Chrome VI inspection procedures, Inspection Procedures for the Chromium (VI) Standards [CPL 02-02-074]; as a state plan state Cal/OSHA must have inspection procedures that are at least as effective. Cal/OSHA Chrome VI inspections should be as comprehensive in scope as required by the Federal instructions but should be implemented by following the Cal/OSHA Policy and Procedure Manual.
This document primarily focuses on differences between Federal OSHA and Cal/OSHA Chrome VI regulations and procedures. This guideline will only lightly touch upon the main elements of Chrome VI inspection procedures that are common to Federal OSHA and Cal/OSHA; readers may refer to the Federal OSHA document for more detail:
Differences between Federal OSHA and Cal/OSHA Guidelines
Special Agreements Affecting Chrome VI Inspections in California
Chrome VI Sampling and Analysis in California
Chrome VI in California will almost always be analyzed utilizing OSHA Method ID215; alternative analytical methods should not be requested unless approved by Regional Senior Industrial Hygienists. Because Chrome VI is a very reactive species, welding and electroplating samples will suffer sample loss unless either the sample is field stabilized (generally this is not the sampling media to be utilized by Cal/OSHA) or the sample collected on a PVC filter is analyzed within the OSHA ID 215 prescribed time limits. For electroplating this is six days, for welding the period is eight days. Welding samples suffer loss proportional to the time since the sample was taken. (Ten percent of a welding sample is lost in eight days, 5% in four days.) Therefore, Chrome VI samples will be shipped via overnight mail.
Cal/OSHA Consultation and Enforcement Units will send samples to the appropriate laboratory under contract and send the appropriate e-mail notifications. Cal/OSHA staff should refer to the complete guidelines found on the DOSH intranet site, which is accessible to all in-house staff, to obtain specific procedural information.
Note: To avoid unnecessary delays in analysis, Cal/OSHA compliance inspectors should either request expedited analysis in block 9 of the Laboratory Sample Analysis Request Form (Cal/OSHA Form IH) unless verified arrangements exist with the contracted laboratory for analysis to be performed as soon as possible after the lab receives the samples.
See also sampling for Chrome VI Ceiling level in the section above on differences between California and Federal OSHA. For more information about the Federal OSHA sampling method, please see: http://www.osha.gov/dts/sltc/methods/inorganic/id215_v2/id215_v2.html
Additional Chrome VI Issues
The Chrome VI regulations allow the use of historic monitoring data as substitutes for monitoring since the new regulations took effect. The Federal Chrome VI guidance document makes it clear that this historic data must be well documented to represent conditions nearly the same as today’s exposures. The specificity on this data extends even to the detail and the accuracy of the sampling and analysis that was done in the past; this is necessary given what is now known about the possibility for sample loss under some of the older sampling and analytical procedures. See the Federal OSHA directive for further detail on the subject of historical data: http://www.osha.gov/OshDoc/Directive_pdf/CPL_02-02-074.pdf
Finally, Cal/OSHA inspectors should pay careful attention to the implementation dates for engineering controls that are embedded in the Chrome VI regulations. In some cases in which exposures over the PEL have been documented, citations would not be issued if proper respiratory protection has been utilized—that is, until the 2010 engineering control deadline. For more information on this topic, see http://www.osha.gov/OshDoc/Directive_pdf/CPL_02-02-074.pdf.