Employers are under pressure to comply with the new hexavalent chromium (Cr(VI)) standard as it applies to the welding industry. Christopher J. Cole, MS, CIH, CSP and the Welding Health and Safety Coordinator at The Lincoln Electric Company, notes that the key to determining the level of effort needed to comply with the new standard is to understand how OSHA has intentionally structured the standard.

What you need to know

Does the new standard apply to my welding operations? Are you welding on stainless or alloy steel, or hard-facing alloys, that contain chromium? Is there any surface coating or plating that contains chromium? Do the consumables you are using contain chromium? If the answer is yes to any of these questions then the standard applies to you.

What is the exposure of each potentially exposed worker? Before you can determine what requirements apply to you, you have to determine each employee's exposure level.

You have time to evaluate and plan the best permanent engineering controls for your operations! In the interim, you can use personal protective equipment to protect your employees until May 31, 2010.

Determine the financial burden of not being able to permanently control exposures! Increased personal protective equipment usage, on-going medical surveillance, increased sampling costs are direct costs that hit you every year; whereas the cost of engineering controls can be spread out over many years.

Hazard communications and record-keeping requirements demonstrate your compliance! Regardless of the level of requirements with which you must comply, you must perform and maintain these requirements properly.

OSHA's Hexavalent Chromium Standards:

• General Industry 29 CFR 1910.1026
• Shipyards 29 CFR 1915.1026
• Construction 29 CFR 1926.1126

These standards are the same, with the exception that general industry has additional housekeeping and regulated area requirements.

Exposure Determination

There are two options for determining each employee's potential exposure. A performance-oriented option based on a company's historical monitoring data. Or, a second option based on performing scheduled monitoring, where the frequency of sampling is specified and an incentive is offered to discontinue monitoring. As each employee's exposure has to be determined, there is an incentive to group employees into “similar exposure groups,” for which OSHA specifies the worst cast exposure be determined. For the construction and shipbuilding industries, a task-based exposure assessment might be used to develop exposure classes. Because so many judgments and decisions are based on these “numbers,” it is in an employer's best interest to use a Certified Industrial Hygienist to set up the exposure groupings and characterize the employees' exposure. Professional industrial-hygiene monitoring services may be obtained through OSHA's free state consultation service.

Methods of Control

For welding applications the primary route of exposure is direct inhalation of the welding fume. Secondary routes of exposure could occur through surface contamination and poor hygiene. Evaluation of the primary route of exposure is determined by air sampling. Evaluations of the secondary routes of exposure are based upon a qualitative assessment using “reasonable” judgment. OSHA requires that employers to use “engineering and work practice controls as the primary means to reduce and maintain employee exposures to Cr(VI) below the Permissible Exposure Limit (PEL).” (OSHA Small Entity Compliance Guide for the Hexavalent Chromium Standards, page 9, OSHA 3320-10N 2006). Engineering and work practice controls consist of substitution, isolation, ventilation and work practices. OSHA believes that 60% of the current stainless steel SMAW operations may need to switch to gas metal arc welding (GMAW) as the “cheapest and most effective method” to reduce Cr(VI) exposures.

There are two caveats here: 1) welding fume generation is dependent upon more than the consumable used, so the total impact of the welding process needs to be considered — consumable, amperage, shielding gas, and other technology on fume generation; 2) One engineering control may not be enough to reduce employee exposure below the PEL or below the Action Limit (AL), in which case a systems approach to permanent fume control may include not only a reduction in fume generation but also the use of ventilation and complementary work practices.

OSHA has determined that “local exhaust systems that capture airborne Cr(VI) near its source and remove it from the workplace … is generally preferred to dilution ventilation because it provides a cleaner and healthier work environment.” The greatest challenges are in construction and shipbuilding, where temporary ventilation solutions involve more high-vacuum/low-volume systems and require a larger degree of employee involvement to move the ventilation hood frequently.

OSHA recognized that applications like welding need to be thoroughly investigated to determine the most feasible and practical engineering solutions and thus extended the implementation date for adopting new engineering controls until May 31, 2010. Work practices should be implemented now, such as keeping the worker's head out of the “fume plume.” Employers should begin evaluations and exploring solutions now for two reasons: 1) it will take time to thoroughly explore all the options available to be in compliance; and 2) there are significant costs, including hidden productivity costs, with not being able to permanently control exposures with engineering controls below the AL.

Some of these costs include increased personal protective-equipment costs, hygiene facilities, restricted areas, medical surveillance, ongoing monitoring costs, and all of their direct and productivity loses are incurred by not being able to utilize engineering and work practiced controls to reduce exposures below the AL. Whereas the cost of engineering controls can be spread out over several years, personal compliance costs hit in the current fiscal year and are incurred per worker year after year. Employers must follow the requirements with which they must comply, and perform and maintain these requirements properly in order to demonstrate that they are in compliance.