OSHA has confirmed the June 15, 2010, effective date of its direct final rule revising the employee notification requirements in the exposure determination provisions of the Hexavalent Chromium (Cr(VI)) standards at 29 CFR 1910.1026, 29 CFR 1915.1026, and 29 CFR 1926.1126. The new OSHA Hexavalent Chromium standard requires employers to notify employees of the results of all exposure determinations, including exposures which do not exceed the permissible exposure limit (PEL). Dealerships and body shops will want to look into this issue and determine if it pertains to their specific site and see if any further action is needed.
Hexavalent chromium compounds are commonly used in the automotive industry. Exposure can result from painting and pigment application, the use of anti-corrosion coatings, and the use of other surface coating processes. Cr(VI) can also be produced when welding, cutting, or sanding on stainless steel, chrome or other metals that have been painted with Cr(VI). Exposure has been linked to lung cancer, nasal septum ulcerations and perforations, and dermatitis.
The new standard significantly lowers OSHA's permissible exposure limit (PEL) for hexavalent chromium, and for all Cr(VI) compounds, from 52 µg/m³ to 5 µg/m³ (micrograms per cubic meter of air) as an 8-hour time-weighted average. The new standard also greatly increases the provisions related to preferred methods for controlling exposure, respiratory protection, protective work clothing and equipment, hygiene areas and practices, medical surveillance, hazard communication, and recordkeeping.
What does our facility need to do?
Automotive facilities need to initially look at the individual factors related to the specific work they are doing on site and decide if there is any significant Cr(VI) exposure occurring.
How do we know if we have significant exposure?
Cr(VI) levels in newer products are relatively low, if present at all, but should still be investigated.
- Review your Material Safety Data Sheets for any hexavalent chromium compounds, specifically products like paints, under coatings, surface coatings and corrosion inhibitors.
- Talk to your paint and coating suppliers, ask them if you are using any of their products containing Cr(VI).
Are there other major sources of Cr(VI) we need to investigate?
Yes – if your facility performs the following activities, you need to investigate the likely exposure associated with them:
- Sanding, particularly sanding on older vehicles whose coatings are more likely to contain higher levels of Cr(VI).
- Welding, particularly welding on stainless steel, chrome plated metals, chromium alloys and older vehicles whose coatings are more likely to contain higher levels of Cr(VI).
What do we do if we believe our Cr(VI) exposure is possibly significant?
If your exposure investigation leads you to believe your worksite Cr(VI) levels are a concern, the next step would be to have an exposure determination, such as air sampling, performed using the appropriate and approved methods.
- If the initial monitoring indicates exposures below the action level (2.5 µg/m³), monitoring may be discontinued. Save your lab results as verification for any regulators who question this.
- Levels at or above the action level will require monitoring every six months.
- Levels above the Permissible
Exposure Limit (PEL) of 5 µg/m³ will require monitoring every 3 months and will
trigger many other compliance requirements, which are summarized on the
Automotive Facility Compliance Requirements
All requirements are now effective. Facilities with 20 or more employees had a November 27, 2006 deadline for all requirements except the required engineering controls. Smaller facilities had until May 30, 2007 to meet the requirements. The deadline for the engineering controls was May 31, 2010 for all facilities.
The new OSHA Hexavalent Chromium standard requires employers to notify employees of the results of all exposure determinations, including exposures which do not exceed the permissible exposure limit (PEL).. There are also requirements as to the accuracy of the monitoring and allowing employees to observe the monitoring process.
Dealerships and body shops will have to separate and limit access to areas that exceed the PEL. These areas will require warning signs.
Methods of Compliance
When feasible, dealerships and bodyshops will have to provide engineering solutions. If these engineering solutions cannot practically reduce levels below the PEL, then they must be supplemented by a respiratory protection program. An example of an engineering solution would be installation of a ventilation system.
Dealerships and bodyshops must implement a respiratory protection program in areas that conceivably could exceed the PEL.
Protective Work Clothing and Equipment
Employers must provide and ensure the use of protective clothing and equipment. This clothing must be removed at the end of the shift, cannot go home with the employee, and must be stored and transported in an impermeable container that is labeled with the appropriate warnings. The employer must launder the clothing, and warn those who do the laundering as to its contents and the possible health effects. The laundering process should not exceed the PEL. Clothing should not be blown or shaken in order to remove Cr(VI).
Hygiene Areas and Practices
Dealerships and body shops will be required to provide, and ensure the use of, changing rooms, washing facilities and clean eating and drinking areas. No eating, drinking or smoking can occur in an area exceeding the PEL.
Employers will have to ensure employees follow cleanup guidelines established by the new standard, including the use of HEPA-filtered vacuums and proper labeling of the Cr(VI) waste.
Dealerships and body shops will be required to provide medical surveillance for employees who are exposed to the action level for 30 or more days a year, or who are showing symptoms of exposure or who were exposed in an emergency. A medical examination must be provided to employees within 30 days of assignment and annually thereafter. Exams must also be provided under other circumstances, including the termination of an employee.
Employee Hazard Communication training must included the contents of the new hexavalent chromium standard, and employees should be able to demonstrate their knowledge of this standard.
Employers must maintain and make available specific records required by the new standard, including air monitoring data, historical monitoring data, objective data, and medical surveillance.
Body shops who would like more information on this subject can read OSHA’s “Small Entity Compliance Guide for the Hexavalent Chromium Standards” at: www.osha.gov/Publications/OSHA_small_entity_comp.pdf. KPA clients with additional questions on the new hexavalent chromium standard are encouraged to contact their KPA engineer.