OSHA Issues Enforcement Procedures Directive for New Hexavalent Chromium Standards

The U.S. Department of Labor’s Occupational Safety and Health Administration (OSHA) has issued a new compliance directive for occupational exposure to Hexavalent Chromium (Cr(VI)). The directive, OSHA Instruction CPL 02-02-074, Inspection Procedures for the Chromium (VI) Standards, was effective January 24, 2008. The Cr(VI) standards were originally published in the Feb. 28, 2006, Federal Register.

“This new directive provides guidance for enforcement of the final rule on Hexavalent Chromium standards,” stated Assistant Secretary of Labor for OSHA Edwin G. Foulke, Jr. “OSHA anticipates these efforts will reduce the risks of exposure to Cr(VI), thereby improving the safety and health of employees affected by this hazard.”

The standards became effective on May 30, 2006. Employers with 20 or more employees were given six months from the effective date to comply with most of the provisions. Employers with less than 20 employees were allowed 12 months from the effective date to come into compliance with most of the provisions. All employers were given four years from the effective date to install feasible engineering controls.

The Cr(VI) standards are applicable to general industry, construction and shipyards (Sections 29 CFR 1910.1026, 29 CFR 1926.1126 and 29 CFR 1915.1026, respectively). Highlights of the new Cr(VI) directive include procedures for reviewing an employer’s air sampling records to determine exposure levels; guidance on how employers can implement effective engineering and work practice controls to reduce and maintain exposure below approved permissible exposure limits; requirements for employers to provide hygiene areas to minimize employees’ exposure to Cr(VI); guidelines requiring employers to maintain exposure and medical surveillance records; and a requirement that CSHOs evaluate Portland cement wherever it is being used.

The standards lower the permissible exposure limit for Hexavalent Chromium to 5 micrograms of Cr(VI) per cubic meter of air as an 8-hour time-weighted average. Hexavalent Chromium compounds are regularly used in the chemical industry in pigments, metal plating and chemical synthesis. Significant health effects associated with exposure to Cr(VI) are lung cancer, nasal septum ulcerations and perforations, skin ulcerations, and allergic and irritant contact dermatitis.