Hexavalent Chromium

OSHA 3373-10 2009
Occupational Safety and Health Act of 1970

“To assure safe and healthful working conditions

for working men and women; by authorizing

enforcement of the standards developed under

the Act; by assisting and encouraging the States in

their efforts to assure safe and healthful working

conditions; by providing for research, information,

education, and training in the field of occupational

safety and health.”

This publication provides a general overview of a

particular standards-related topic. This publication

does not alter or determine compliance responsibilities

which are set forth in OSHA standards, and the

Occupational Safety and Health Act. Moreover,

because interpretations and enforcement policy

may change over time, for additional guidance on

OSHA compliance requirements, the reader should

consult current administrative interpretations and

decisions by the Occupational Safety and Health

Review Commission and the courts.

Material contained in this publication is in the public

domain and may be reproduced, fully or partially,

without permission. Source credit is requested

but not required.

This information will be made available to sensory

impaired individuals upon request. Voice phone:

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889-5627.
U.S. Department of Labor

Occupational Safety and Health Administration

OSHA 3373-10

2009

Hexavalent

Chromium
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Contents

Introduction . . . 3

Worker Exposure and Health Consequences . . . 5

OSHA’s Hexavalent Chromium Standards . . . 5

Exposure Limits . . . 6

Exposure Monitoring and Determinations . . . 6

Scheduled Monitoring Option . . . 7

Regulated Areas . . . 10

Control Measures . . . 10

Requirements for Protective Work

Clothing and Equipment . . . 12

Hygiene Areas and Practices . . . 14

Housekeeping . . . 15

Medical Surveillance . . . 16

Worker Training and Communication . . . 19

Recordkeeping . . . 20

Effective Dates . . . 22

Additional Information . . . 22

References . . . 23

OSHA Assistance . . . 24

OSHA Regional Offices . . . 28
Introduction

This document is intended to supplement OSHA’s Small Entity

Compliance Guide for the Hexavalent Chromium Standards

published in 2006 (see Additional Information section for web link

to this document) and to give readers an overview of the provisions

and requirements of the Hexavalent Chromium standards for

general industry (29 CFR 1910.1026), shipyards (29 CFR 1915.1026),

and construction (29 CFR 1926.1126).

Hexavalent chromium (Cr(VI)) is a toxic form of the element

chromium. Hexavalent chromium is rarely found in nature and is

generally man-made. Cr(VI) is widely used in pigments, metal

finishing (electroplating), wood preservatives and fungicides, and

in chemical synthesis as an ingredient and catalyst. Table 1 on

the next page lists some selected Cr(VI) compounds with their

synonyms and common uses.

Hexavalent chromium may also be present in fumes generated

during the production or welding of chrome alloys. Chromium

metal is often alloyed with other metals or plated on metal and

plastic substrates to improve corrosion resistance and provide

protective coatings. The steel industry is a major consumer of

chromium metal in the production of stainless steel.

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This booklet is intended to provide information about

the Hexavalent Chromium standards for general industry

(29 CFR 1910.1026), shipyards (29 CFR 1915.1026), and

construction (29 CFR 1926.1126). The Occupational

Safety and Health Act requires employers to comply

with safety and health standards promulgated by OSHA

or by a state with an OSHA-approved state plan. However, this booklet is not itself a standard or regulation,

and it creates no new legal obligations.
Since 2000, there has been a decline in the use of chromates in

pigments for paints and coatings; printing inks; ceramic, glass and

construction materials; roofing and plastics. Employers are substituting less toxic inorganic and organic pigments where possible

(SRI Consulting, 2008).

Table 1. Selected Cr(VI) Compounds and Their Uses

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Chemical Name

Chromium Trioxide

Lead Chromate

Sodium Dichromate

Zinc Chromate

Synonyms

Chromic acid,

chromia, chromic

(VI) acid, chromic

trioxide, chromium

oxide, chromium

(VI) oxide

C.I. pigment Yellow

34, crocoite, lead

chromium oxide,

plumbous chromate

Disodium salt,

chromium sodium

oxide, dichromic

acid, disodium

dichromate, sodium

bichromate, sodium

dichromate

Zinc salt, chromium

zinc oxide, zinc

chromium oxide,

zinc tetraoxychromate

Uses

Most common uses:

chromium plating,

aluminum anodizing, and

chemical intermediate for

chromated copper arsenate

wood preservatives.

Other uses: ceramic glazes,

colored glass, metal

cleaning, inks, and paints

(inorganic pigments).

Decorating china, pigment

in industrial paints, rubber

and plastics, pigment in oil

paints and watercolors, and

printing fabrics.

Inks, oxidizing agent in the

manufacture of dyes and

many other synthetic

organic chemicals, electric

batteries, manufacture of

chromic acid, other

chromates and chrome

pigments, corrosion

inhibiting paints, component of wood preservatives,

and colorant for glass.

Priming paints for metals,

varnishes and pigments in

aerospace paints.

Adapted from: Meridian Research, 1994.
Worker Exposure and Health Consequences

Workplace exposure to Cr(VI) may cause the following health

effects:

■ lung cancer in workers who breathe airborne Cr(VI);

■ irritation or damage to the nose, throat and lungs (respiratory

tract) if Cr(VI) is inhaled; and

■ irritation or damage to the eyes and skin if Cr(VI) contacts these

organs.

Workers can inhale airborne Cr(VI) as a dust, fume or mist

while, among other things, producing chromate pigments, dyes

and powders (such as chromic acid and chromium catalysts);

working near chrome electroplating; performing hot work and

welding on stainless steel, high chrome alloys and chrome-coated

metal; and applying and removing chromate-containing paints and

other surface coatings. Skin exposure can occur while handling

solutions, coatings and cements containing Cr(VI).

OSHA’S Hexavalent Chromium Standards

OSHA has separate standards for Cr(VI) exposures in general

industry, shipyards and construction. Most of the requirements are

the same for all sectors, with the exception of provisions for

regulated areas, hygiene areas and practices, and housekeeping.

Where there are differences, they will be explained in this booklet.

The standards generally apply to occupational exposures to Cr(VI)

in all forms and compounds in general industry, shipyards and

construction, with specific exceptions outlined in the box below.

States that administer their own OSHA-approved occupational

safety and health plans may have different requirements. See the

Additional Information section for a list of State plans and their

contact information.

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Exceptions

The Cr(VI) standards do not apply in three situations:

■ exposures that occur in the application of pesticides;

■ exposures to Portland cement; and

■ where the employer has objective data demonstrating that a

material containing Cr(VI) or a specific process, operation, or

activity involving Cr(VI) cannot release dusts, fumes or mists

of Cr(VI) in concentrations at or above 0.5 micrograms per

cubic meter (μg/m3) of air as an 8-hour time-weighted

average (TWA) under any expected conditions of use.

Exposure Limits

The final Cr(VI) rule establishes an 8-hour TWA permissible

exposure limit (PEL) of 5 μg/m3 measured as Cr(VI). This means

that over the course of any 8-hour work shift, the average exposure

to Cr(VI) cannot exceed 5 μg/m3.

The Action Level is set at 2.5 μg/m3 of Cr(VI) calculated as an 8-

hour TWA.

Exposures above the Action Level trigger specific requirements, and exposures above the PEL trigger additional requirements. The substantive provisions of the Cr(VI) standard are

described below.

Exposure Monitoring and Determinations

Each employer who has a workplace or work operation covered

by the Cr(VI) standards must determine the 8-hour TWA exposure

for each worker exposed to Cr(VI). To comply with this provision,

employers can choose between two options for performing exposure

determinations:

■ a scheduled monitoring option; or

■ a performance-oriented option.

When monitoring for Cr(VI), employers must use a method of

monitoring and analysis that provides values within plus or minus

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25 percent of the true value at least 95 percent of the time for

airborne concentrations at or above the Action Level. Examples of

methods that meet these criteria are OSHA method ID215 (version

2) and NIOSH methods 7600, 7604, 7605 and 7703.

Scheduled Monitoring Option

The Initial Monitoring

Employers who select the scheduled monitoring option must

conduct initial exposure monitoring to determine exposure to

Cr(VI) for each worker. This involves taking a sufficient number of

personal breathing zone air samples to accurately characterize full

shift exposure on each shift, for each job classification, in each

work area. Monitoring results must indicate the worker’s timeweighted average exposure to airborne Cr(VI) over a typical 8-

hour workday.

In some cases the employer will need to monitor all exposed

workers, while in other cases it will be sufficient to monitor

“representative” personnel. Representative exposure sampling is

permitted when a number of workers perform essentially the same

job under the same conditions. For example, an employer may

choose one welder to sample as a representative of several welders

who work in a welding shop for determining exposure as long as all

of the welders represented by the monitoring perform the same job

under the same conditions. Representative personal sampling for

workers engaged in similar work involving similar Cr(VI) exposures

is achieved by monitoring the worker(s) reasonably expected to

have the highest Cr(VI) exposures. For example, this may involve

monitoring the Cr(VI) exposure of the worker closest to an exposure

source. This exposure result may then be used to represent the

exposure of other workers in the group. The employer must take at

least one sample characteristic of the entire work shift or consecutive representative samples taken over the length of the shift.

Periodic Monitoring

Periodic monitoring is required if the initial monitoring shows

that the worker’s exposure is at or above the Action Level (See

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Table 2, below, for monitoring frequency.)

Table 2. Monitoring Frequency

If initial monitoring shows exposures above the PEL, but subsequent periodic measurements indicate that exposures have

fallen to levels at or below the PEL, but still above the Action Level,

the employer may reduce the frequency of periodic monitoring to

every six months. In addition, an employer may discontinue

periodic monitoring for workers represented by monitoring results

indicating that exposures have fallen below the Action Level if

those results are confirmed by a second measurement taken at

least seven days later.

Additional Monitoring

Additional monitoring is necessary when a workplace change may

result in new or additional exposures to Cr(VI) or the employer

has any reason to believe that new or additional exposures have

occurred. These changes may include alterations in the production

process, raw materials, equipment, personnel, work practices, or

control methods used in the workplace.

Examples of Situations Requiring Additional Monitoring

Example 1: If an employer has conducted monitoring for an electroplating operation while using fume suppressants, and the use

of fume suppressants is discontinued, then additional monitoring

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Exposure Scenario

Below the Action Level (< 2.5

μg/m3

)

At or above the Action Level but

at or below the PEL (2.5 μg/m3 to

5 μg/m3)

Above the PEL (> 5 μg/m3

)

Required Monitoring Activity

No periodic monitoring required

for workers represented by the

initial monitoring.

Monitor every six months.

Monitor every three months.
would be necessary to determine worker exposures under the

modified conditions.

Example 2: A welder may move from an open, outdoor location

to an enclosed or confined space. Even though the task performed and materials used may remain constant, the changed

environment could reasonably be expected to result in higher

exposures to Cr(VI).

Performance-Oriented Option

The performance-oriented option allows the employer to determine

the 8-hour TWA exposure for each worker on the basis of any

combination of air monitoring data, historical monitoring data, or

objective data sufficient to accurately determine current worker

exposure to Cr(VI). This option is intended to allow employers

flexibility in assessing the Cr(VI) exposures of their personnel.

Where the employer elects to use this option, the exposure determination must be performed prior to the time that the work

operation commences and must provide the same degree of

assurance that worker exposures have been correctly characterized

as is provided for under the scheduled monitoring option. Like

under the scheduled monitoring option, the employer is expected

to reevaluate worker exposures when there is any change in the

production process, raw materials, equipment, personnel, work

practices, or control methods that may result in new or additional

exposures to Cr(VI). However, the employer using the performanceoriented option does not have to follow any particular fixed

schedule for performing reevaluations.

Objective Data

The Objective data means information that demonstrates the

expected worker exposure to Cr(VI) associated with a particular

product or material or a specific process, operation, or activity.

Information that can serve as objective data includes, but is not

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limited to, air monitoring data from an industry-wide survey;

data collected by a trade association from its members; or calculations based on the composition or chemical and physical

properties of a material. The data must reflect workplace conditions closely resembling the processes, types of material,

control methods, work practices and environmental conditions

in the employer’s current operations.

Regulated Areas

The Cr(VI) standard for general industry includes requirements for

regulated areas wherever a worker’s exposure to airborne concentrations of Cr(VI) is or is reasonably expected to be above the PEL.

However, OSHA has not included this requirement in the construction and shipyard standards due to the expected practical difficulties of establishing regulated areas for operations in these sectors.

Employers are required to distinguish the regulated area from

the rest of the workplace in a manner that adequately establishes

and alerts workers to the boundaries of the regulated area. The

standard does not specify how employers are to indicate the

regulated areas. Warning signs, gates, ropes, barricades, lines,

textured flooring, or other methods may be appropriate. Whatever

methods are chosen must effectively warn workers not to enter

the area unless they are authorized. Authorized personnel are

those persons required by their job duties to be present in the

area and may include maintenance/repair personnel, managers

and quality control engineers. Also, designated worker representatives may enter the regulated area to observe exposure monitoring.

All persons who enter the regulated area must use proper protective equipment, including respirators when appropriate.

Control Measures

To protect workers from Cr(VI) hazards, whenever exposures

exceed the PEL employers must use engineering and work

practice controls to reduce and maintain Cr(VI) exposures to or
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below the PEL. These are the most effective controls. Whenever

feasible engineering and work practice controls are not sufficient

to reduce exposures to or below the PEL, the employer must use

such controls to reduce exposures to the lowest levels achievable

and supplement them by the use of respiratory protection.

Engineering controls include substitution (using a less toxic

material or process that results in lower exposures), isolation

(such as enclosing the source of exposure), and ventilation (such

as using a local exhaust system that captures airborne Cr(VI) near

its source).

Work practice controls involve adjustments in the way a task is

performed. Workers must know the proper way to perform a task

in order to minimize their exposure and to maximize the effectiveness of the control. For example, a welder should be properly

trained to correctly position himself and the local exhaust ventilation to minimize exposure to the welding fume. In many cases,

work practice controls complement engineering controls in

providing worker protection.

Employers are not permitted to rotate workers to different

jobs as a means of achieving compliance with the PEL.

Exceptions to the general requirement for primary use of

feasible engineering and work practice controls to reduce

worker exposures to within permissible limits:

■ In the aerospace industry, when workers are painting aircraft

or large aircraft parts (e.g., the interior or exterior of whole

aircraft, aircraft wings or tail sections, or comparably sized

aircraft parts), the employer must use feasible engineering

and work practice controls to reduce worker Cr(VI) exposures

to levels at or below 25 μg/m3. The employer must supplement its engineering and work practice controls with

respiratory protection to achieve the PEL.

■ If the employer can demonstrate that a particular process or

task does not result in worker exposures to Cr(VI) exceeding

the PEL for 30 or more days during any 12 consecutive

months, the employer is allowed to use any combination of
controls, including respirators alone, to achieve the PEL.

Historical data, objective data, or exposure monitoring data

may be used for this purpose.

Respiratory Protection

Employers are required to provide workers with respirators when

feasible engineering and work practice controls are unable to

reduce worker exposure to Cr(VI) to levels at or below the PEL.

Respirators are required during:

■ Work operations such as maintenance and repair activities for

which engineering and work practice controls are not feasible;

■ Emergencies (i.e., any occurrence that results or is likely to result

in an uncontrolled release of Cr(VI) that is not an incidental

release that can be controlled by workers in the immediate area

or by maintenance personnel);

■ Where workers are exposed above the PEL for fewer than 30

days per year and the employer has opted not to implement

engineering/work practice controls to achieve the PEL;

■ Periods necessary to install or implement feasible engineering

and work practice controls; or

■ Operations where all feasible engineering and work practice

controls have been implemented but are not sufficient to reduce

exposures to or below the PEL.

Where respirator use is required, the employer must establish

a respiratory protection program in accordance with OSHA’s

Respiratory Protection standard (29 CFR 1910.134). The respiratory

protection program addresses procedures for properly selecting,

using and maintaining respirators in the workplace. OSHA has

prepared the document, a Small Entity Compliance Guide for the

Revised Respiratory Protection Standard (see the Additional

Information section at page 22).

Requirements for Protective Work Clothing

and Equipment

Employers are required to provide and ensure the proper use of

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appropriate protective clothing and equipment whenever a hazard

evaluation of the workplace has identified that skin or eye contact

with Cr(VI) presents or is likely to present a hazard to workers.

Where such a hazard is identified, the employer must select the

clothing and equipment needed to protect workers from Cr(VI)

hazards. Some examples of protective clothing and equipment

that may be necessary include, but are not limited to, gloves,

aprons, coveralls, foot coverings and goggles. Normal street

clothing and uniforms or other accessories that do not protect

workers from Cr(VI) hazards are not considered protective clothing

or equipment under the standard. Employers must provide and

maintain the clothing and equipment at no cost to the worker.

The following precautions must be taken to protect workers

and others who handle protective clothing and equipment:

■ The employer must ensure that workers remove protective

clothing and equipment that has become contaminated with

Cr(VI) either at the end of their work shift or when they complete

their tasks involving Cr(VI) exposure, whichever comes first.

■ The employer must not allow any worker to remove contaminated protective clothing or equipment from the workplace, except

for those workers whose job it is to launder, clean, maintain, or

dispose of the clothing or equipment.

■ When contaminated protective clothing or equipment is

removed for laundering, cleaning, maintenance or disposal, the

employer must ensure that it is stored and transported in sealed,

impermeable bags or other closed, impermeable containers.

■ Bags or containers of contaminated protective clothing or

equipment that are removed from change rooms for laundering,

cleaning, maintenance or disposal must be labeled in accordance

with OSHA’s Hazard Communication standard at 29 CFR

1910.1200.

■ The employer must clean, launder, repair and replace protective

clothing and equipment as necessary to ensure that the effectiveness of the clothing and equipment is maintained.

■ The employer must inform any person who launders or cleans

protective clothing or equipment contaminated with Cr(VI) of the

potentially harmful effects of Cr(VI) exposure, and that the

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clothing and equipment should be laundered or cleaned in a

manner that minimizes skin or eye contact with Cr(VI) and

prevents exposure to Cr(VI) in excess of the PEL. Removal of

Cr(VI) from protective clothing and equipment by blowing,

shaking, or any other means that disperses Cr(VI) into the air or

onto a worker's body is prohibited.

Hygiene Areas and Practices

The Cr(VI) standards include requirements for change rooms, washing facilities, and eating and drinking areas to minimize exposure to

Cr(VI). They are:

Change rooms are only required when workers must change

out of their street clothes to use protective clothing and equipment.

The change rooms must conform to 29 CFR 1910.141 (for general

industry and shipyards) and 29 CFR 1926.51 (for construction),

prevent Cr(VI) contamination of street clothes, and be equipped

with separate storage facilities for protective clothing and

equipment and for street clothes. This provision is intended to

limit exposures after the work shift ends and avoid the contamination of workers’ cars and homes.

Washing facilities must be provided and must be readily

accessible and capable of removing Cr(VI) from the skin.

Washing facilities must comply with OSHA’s sanitation requirements at 29 CFR 1910.141 (for general industry), 29 CFR 1926.51

(for construction), and 29 CFR 1915.97 (for shipyards). The employer must ensure that affected workers use these facilities when

necessary. This includes making sure that workers who have

skin contact with Cr(VI) wash their hands and faces at the end of

the work shift and prior to eating, drinking, smoking, chewing

tobacco or gum, applying cosmetics, or using the toilet.

Eating and drinking areas and surfaces must conform with 29

CFR 1910.141 (for general industry), 29 CFR 1926.51 (for construction), and 29 CFR 1915.97 (for shipyards) and be maintained as

free as practicable of Cr(VI) whenever employers allow workers to

consume food or beverages at a worksite where Cr(VI) is present.

Employers are also required to ensure that workers do not enter

eating and drinking areas wearing protective clothing or equip-
ment, unless the protective clothing or equipment is properly

cleaned beforehand. Employers may use any method for removing

surface Cr(VI) from clothing and equipment that does not disperse

the dust into the air or onto the worker’s body. For example, if a

worker is wearing coveralls for protection against Cr(VI), thorough

HEPA vacuuming of the coveralls could be performed prior to

entry into a lunchroom. Do NOT blow dust off protective clothing

and equipment.

The employer must ensure that workers do not eat, drink,

smoke, chew tobacco or gum, or apply cosmetics – or carry or

store products associated with these activities – in regulated areas

or in areas where skin or eye contact with Cr(VI) occurs.

Housekeeping

The Cr(VI) standard for general industry includes housekeeping

measures. OSHA did not include these requirements in the construction and shipyard standards due to the expected practical

difficulties of complying with such requirements in those sectors.

Proper housekeeping requirements are important because they

target sources of exposure to Cr(VI) that engineering controls are

generally not designed to address (such as skin exposures).

Employers must ensure that all surfaces are maintained as free as

practicable of accumulations of Cr(VI). Spills and releases of

Cr(VI)-containing material must be cleaned up promptly. The

requirement to maintain surfaces “as free as practicable” is

performance-oriented. The standard does not specify what an

allowable surface loading of Cr(VI) contamination in work areas

would be. Instead, the requirement for “as free as practicable” is

met when the employer is vigilant in efforts to ensure that surfaces

are kept free of accumulation of Cr(VI) dust. OSHA will consider

the employer’s housekeeping schedule, the possibility of exposure

from the surfaces in question, and the characteristics of the

workplace. (OSHA, Jan. 13, 2003, Letter of Interpretation.)

Cleaning Methods

Surfaces contaminated with Cr(VI) must be cleaned by HEPAfiltered vacuuming or other methods that minimize exposure to

15
Cr(VI), including wet methods such as wet sweeping or wet

scrubbing. Dry methods (e.g., dry shoveling, dry sweeping and

dry brushing) are only allowed in cases where HEPA-filtered

vacuuming or other methods that minimize the likelihood of

exposure to Cr(VI) have been tried and found not to be effective.

The use of compressed air for cleaning surfaces is only allowed

when used in conjunction with a ventilation system designed to

capture the dust cloud or when no alternative method is feasible.

Employers should use caution whenever compressed air is used

as a cleaning method, since the air will spread the contamination

further unless the dust is appropriately collected. Compressed air

should never be directed at workers and should not be used to

clean protective clothing or equipment.

Employers must ensure that waste, scrap, debris and any other

materials contaminated with Cr(VI) are collected and disposed of

in sealed, impermeable bags or other closed, impermeable containers. Additionally, bags or containers of waste, scrap, debris

and any other materials contaminated with Cr(VI) must be labeled

in accordance with the requirements of the Hazard Communication

standard, 29 CFR 1910.1200.

Medical Surveillance

The purpose of medical surveillance is to determine if an individual

can be exposed to Cr(VI) at his or her workplace without experiencing adverse health effects; to identify Cr(VI)-related adverse

health effects when they do occur so that appropriate intervention

measures can be taken; and to determine a worker’s fitness to use

personal protective equipment such as respirators.

All medical examinations and procedures required by the

standards must be performed by or under the supervision of a

physician or other licensed healthcare professional (PLHCP).

When medical surveillance is required it must be provided at no

cost to workers and at a reasonable time and place. If participation

requires travel away from the worksite, the employer must bear

the cost. Workers must be paid for time spent taking medical

examinations, including travel time.

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Employers must provide medical surveillance

to workers who are:

■ Exposed or may be exposed to Cr(VI) at concentrations at or

above the Action Level (as an 8-hour TWA) for 30 or more

days per year;

■ Experiencing signs and symptoms of adverse health effects

associated with Cr(VI) exposures (e.g., blistering lesions,

redness or itchiness of exposed skin, shortness of breath

or wheezing that worsens at work, nosebleeds, a whistling

sound while inhaling or exhaling); or

■ Exposed in an emergency situation (i.e., any occurrence that

results or is likely to result in an uncontrolled release of

Cr(VI) that is not an incidental release that can be controlled

by workers in the immediate area or by maintenance personnel).

Frequency of Medical Examination

Medical examinations must be given:

■ Within 30 days after initial assignment to a job involving Cr(VI)

exposure, unless the worker has received an examination that

meets the requirements of the standard within the last 12

months;

■ Annually;

■ Within 30 days after a PLHCP's written medical opinion

recommends an additional examination;

■ Whenever a worker shows signs or symptoms of the adverse

health effects associated with Cr(VI) exposure;

■ Within 30 days after exposure during an emergency which

results in an uncontrolled release of Cr(VI); or

■ At the termination of employment, unless the last examination

provided was less than six months prior to the date of termination.

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Contents of the Medical Exams

■ A medical and work history which focuses on: the worker’s

past, present and anticipated future exposure to Cr(VI); any

history of respiratory system dysfunction; any history of

asthma, dermatitis, skin ulceration or nasal septum

perforation; and smoking status and history.

■ A physical examination of the skin and respiratory tract.

■ Any additional tests that the examining PLHCP considers

appropriate for that worker.

Note: The standards do not specify tests or procedures that

must be provided to all workers. Rather, the information

obtained from the medical and work history along with the

physical examination of the skin and respiratory tract (the main

targets of Cr(VI) toxicity) allow the PLHCPs to use their medical

judgment to determine what tests, if any, are warranted.

Information Provided to the PLHCP

The employer must ensure that the PLHCP has a copy of the Cr(VI)

standard, and must provide the PLHCP with:

■ A description of the affected worker’s former, current and

anticipated duties as they relate to Cr(VI) exposure;

■ Information on the worker’s former, current and anticipated

Cr(VI) exposure levels;

■ A description of any personal protective equipment used or to

be used by the worker, including when and for how long the

worker has used that equipment; and

■ Information from records of employment-related medical examinations previously provided to the affected worker, currently

within the control of the employer.

TheWritten Medical Opinion

The employer must obtain a written medical opinion from the

PLHCP for each medical examination performed. The written

medical opinion must be obtained within 30 days of the exam-
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ination, and must contain:

■ The PLHCP's opinion as to whether the worker has any detected

medical condition(s) that would place the worker at increased

risk of material impairment to health from further exposure to

Cr(VI);

■ Any recommended limitations on the worker’s exposure to

Cr(VI) or on the use of personal protective equipment such as

respirators; and

■ A statement that the PLHCP has explained to the worker the

results of the medical examination, including any medical

conditions related to Cr(VI) exposure that require further

evaluation or treatment, and any special provisions for the use

of protective clothing or equipment.

The PLHCP must not reveal to the employer any specific findings

or diagnoses that are not related to workplace Cr(VI) exposure. The

employer is required to provide a copy of the written medical

opinion to the examined worker within two weeks after receiving it.

Worker Training and Communication

It is critically important that workers recognize the hazards

associated with exposure to Cr(VI) and understand the measures

they can take to protect themselves. OSHA’s Hazard Communication

standard (29 CFR 1910.1200) establishes requirements for

employers to provide workers with information on hazardous

chemicals such as Cr(VI) through comprehensive chemical hazard

communication programs that include material safety data sheets

(MSDSs), labels and worker training. Employers must follow the

requirements of the Hazard Communication standard with regard to

workers exposed to Cr(VI). These requirements include, but are not

limited to, informing workers of any operations in their work area

where Cr(VI) is present and training workers on the hazards of Cr(VI)

and measures theys can take to protect themselves from these

hazards (e.g., appropriate work practices, emergency procedures

and protective equipment to be used).

In addition, the Cr(VI) standards require the employer to provide

information and training sufficient to ensure that workers can

demonstrate knowledge of:
■ The requirements of the Cr(VI) standard; and

■ The medical surveillance program required by the standard,

including recognition of the signs and symptoms of adverse

health effects that may result from Cr(VI) exposure.

The employer must also make a copy of the Cr(VI) standard

available without cost to affected workers.

Recordkeeping

Accurate records can demonstrate employer compliance with the

standard and can assist in diagnosing and identifying workplacerelated illnesses. Therefore, employers are required to maintain

records of worker Cr(VI) exposures (including air monitoring data,

historical monitoring data and objective data) and medical surveillance records.

Air Monitoring Data

Employers must keep an accurate record of all air monitoring

performed to comply with the standard. The record must indicate:

■ The date of the measurement for each sample taken;

■ The operation involving exposure to Cr(VI) that was monitored;

■ Sampling and analytical methods used and evidence of their

accuracy;

■ The number, duration and results of samples taken;

■ The type of personal protective equipment used (e.g., type of

respirators worn); and

■ The name, social security number and job classification of all

workers represented by the monitoring, specifying which

workers were actually monitored.

Historical Monitoring Data

When an employer relies on historical monitoring data to determine

worker exposures to Cr(VI), an accurate record of the historical

monitoring data must be maintained. The record must show:

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■ That the data was collected using methods that meet the

accuracy requirements of the standard;

■ That the processes and work practices, characteristics of the

Cr(VI)-containing material, and environmental conditions at the

time the data was obtained are essentially the same as those of

the job for which current exposure is being determined; and

■ Any other relevant data regarding operations, materials, processes,

or worker exposures.

Objective Data

When an employer relies on objective data to comply with the

Cr(VI) standard, an accurate record of the objective data must be

maintained. The record must indicate:

■ The Cr(VI)-containing material in question;

■ The source of the objective data;

■ The testing protocol and results of testing, or analysis of the

material for the release of Cr(VI);

■ A description of the process, operation, or activity and how the

data support the determination; and

■ Any other relevant data regarding the processes, operations,

activities, materials, or worker exposures.

Medical Surveillance

The employer must maintain an accurate record for each worker

provided medical surveillance under the standard. The record

must include the following information about the worker:

■ Name and social security number;

■ A copy of the PLHCP’s written opinions; and

■ A copy of the information that the employer was required to

provide to the PLHCP (i.e., a description of the worker’s duties

as they relate to occupational Cr(VI) exposure; the worker’s

Cr(VI) exposure levels; a description of the personal protective

equipment used by the worker; and information from previous

employment-related medical examinations).

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Exposure and medical records must be maintained and made

available to workers and their representatives in accordance with

29 CFR 1910.1020, Access to Employee Exposure and Medical

Records. In general, exposure records must be kept for at least 30

years, and medical records must be kept for the duration of employment plus 30 years. It is necessary to keep these records for

extended periods because cancer often cannot be detected until

20 or more years after exposure, and exposure and medical

records can assist in diagnosing and identifying the cause of

disease.

Effective Dates

All provisions of the standard are currently in effect, except that

employers have until May 31, 2010 to implement required

engineering controls.

Additional Information

Small Entity Compliance Guide for the Hexavalent Chromium

Standards:

www.osha.gov/Publications/OSHA_small_entity_comp.pdf

Small Entity Compliance Guide for the Revised Respiratory

Protection Standard:

www.osha.gov/Publications/SECG_RPS/secg_rps.html

OSHA Fact Sheet: Health Effects of Hexavalent Chromium:

www.osha.gov/OshDoc/data_General_Facts/hexavalent_chromium

.pdf

Hexavalent Chromium General Industry standard:

www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=

STANDARDS&p_id=13096

Hexavalent Chromium Shipyard standard:

www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=

STANDARDS&p_id=13116

Hexavalent Chromium Construction standard:

www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=ST

ANDARDS&p_id=13117

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For a list of State plans and contact information:

www.osha.gov/dcsp/osp/index.html.

References

Meridian Research, Inc. 1994. Final Report: Selected Chapters of

an Economic Impact Analysis for a Revised OSHA Standard for

Chromium VI: Introduction, Industry Profiles, Exposure Profiles,

Technological Feasibility (for 6 industries) and Environmental

Impacts. Prepared for: Office of Regulatory Analysis, OSHA,

Prepared by: Meridian Research, Inc., Prepared under Contract

Number: J-9-F-4-0012, Task Order No. 1, Base Year, December 18,

1994, pages I-2 through I-7, Document ID Number OSHA-H054A2006-0064-0720 (formerly Exhibit Number 26).

OSHA. 2003. Clarification of “as free as practicable” and lead contamination under 29 CFR 1926.62. OSHA’s Letter of Interpretation

response to Mr. Frank White of Organization Resources

Counselors, Inc. January 13, 2003.

OSHA. 2006. Occupational Exposure to Hexavalent Chromium.

Final Rule. 71 FR 10099-10385. 2/28/2006.

OSHA Instruction. 2008. Inspection Procedures for the Chromium

(VI) Standards. Directive Number: CPL 02-02-074. Effective Date:

January 24, 2008.

SRI Consulting. 2008. Chemical Economics Handbook. Inorganic

Color Pigments. CEH Marketing Research Report. January 2008,

pages 575.3002A through 575.3002J.

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OSHA Assistance

OSHA can provide extensive help through a variety of programs,

including technical assistance about effective safety and health

programs, state plans, workplace consultations, and training and

education.

Safety and Health Management System Guidelines

Effective management of worker safety and health protection is a

decisive factor in reducing the extent and severity of work-related

injuries and illnesses and their related costs. In fact, an effective

safety and health management system forms the basis of good

worker protection, can save time and money, increase productivity

and reduce employee injuries, illnesses and related workers’ compensation costs.

To assist employers and workers in developing effective safety

and health management systems, OSHA published recommended

Safety and Health Program Management Guidelines (54 Federal

Register (16): 3904-3916, January 26, 1989). These voluntary

guidelines can be applied to all places of employment covered by

OSHA.

The guidelines identify four general elements critical to the

development of a successful safety and health management

system:

■ Management leadership and worker involvement,

■ Worksite analysis,

■ Hazard prevention and control, and

■ Safety and health training.

The guidelines recommend specific actions, under each of

these general elements, to achieve an effective safety and health

management system. The Federal Register notice is available online

at www.osha.gov.

State Programs

The Occupational Safety and Health Act of 1970 (OSH Act)

encourages states to develop and operate their own job safety

and health plans. Twenty-four states, Puerto Rico and the Virgin

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25

Islands currently operate approved state plans: 22 cover both

private and public (state and local government) employment;

Connecticut, New Jersey, New York and the Virgin Islands cover

the public sector only. States and territories with their own

OSHA-approved occupational safety and health plans must adopt

standards identical to, or at least as effective as, the Federal OSHA

standards.

Consultation Services

Consultation assistance is available on request to employers who

want help in establishing and maintaining a safe and healthful

workplace. Largely funded by OSHA, the service is provided at no

cost to the employer. Primarily developed for smaller employers

with more hazardous operations, the consultation service is

delivered by state governments employing professional safety and

health consultants. Comprehensive assistance includes an appraisal

of all mechanical systems, work practices and occupational safety

and health hazards of the workplace and all aspects of the employer’s

present job safety and health program. In addition, the service

offers assistance to employers in developing and implementing an

effective safety and health program. No penalties are proposed or

citations issued for hazards identified by the consultant. OSHA

provides consultation assistance to the employer with the assurance

that his or her name and firm and any information about the

workplace will not be routinely reported to OSHA enforcement staff.

For more information concerning consultation assistance, see

OSHA’s website at www.osha.gov.

Strategic Partnership Program

OSHA’s Strategic Partnership Program helps encourage, assist and

recognize the efforts of partners to eliminate serious workplace

hazards and achieve a high level of worker safety and health. Most

strategic partnerships seek to have a broad impact by building

cooperative relationships with groups of employers and workers.

These partnerships are voluntary relationships between OSHA,

employers, worker representatives, and others (e.g., trade unions,

trade and professional associations, universities, and other

government agencies).

For more information on this and other agency programs,
contact your nearest OSHA office, or visit OSHA’s website at

www.osha.gov.

OSHA Training and Education

OSHA area offices offer a variety of information services, such as

technical advice, publications, audiovisual aids and speakers for

special engagements. OSHA’s Training Institute in Arlington

Heights, IL, provides basic and advanced courses in safety and

health for Federal and state compliance officers, state consultants,

Federal agency personnel, and private sector employers, workers

and their representatives.

The OSHA Training Institute also has established OSHA Training

Institute Education Centers to address the increased demand for its

courses from the private sector and from other federal agencies.

These centers are colleges, universities and nonprofit organizations

that have been selected after a competition for participation in the

program.

OSHA also provides funds to nonprofit organizations, through

grants, to conduct workplace training and education in subjects

where OSHA believes there is a lack of workplace training. Grants

are awarded annually.

For more information on grants, training and education, contact

the OSHA Training Institute, Directorate of Training and Education,

2020 South Arlington Heights Road, Arlington Heights, IL 60005,

(847) 297-4810, or see Training on OSHA’s website at

www.osha.gov. For further information on any OSHA program,

contact your nearest OSHA regional office listed at the end of this

publication.

Information Available Electronically

OSHA has a variety of materials and tools available on its website

at www.osha.gov. These include electronic tools, such as Safety

and HealthTopics, eTools, Expert Advisors; regulations, directives

and publications; videos and other information for employers and

workers. OSHA’s software programs and eTools walk you through

challenging safety and health issues and common problems to find

the best solutions for your workplace.

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27

OSHA Publications

OSHA has an extensive publications program. For a listing of free

items, visit OSHA’s website at www.osha.gov or contact the OSHA

Publications Office, U.S. Department of Labor, 200 Constitution

Avenue, NW, N-3101, Washington, DC 20210; telephone (202) 693-

1888 or fax to (202) 693-2498.

Contacting OSHA

To report an emergency, file a complaint, or seek OSHA advice,

assistance, or products, call (800) 321-OSHA or contact your nearest

OSHA Regional or Area office listed at the end of this publication.

The teletypewriter (TTY) number is (877) 889-5627.

Written correspondence can be mailed to the nearest OSHA

Regional or Area Office listed at the end of this publication or to

OSHA’s national office at: U.S. Department of Labor, Occupational

Safety and Health Administration, 200 Constitution Avenue, N.W.,

Washington, DC 20210.

By visiting OSHA’s website at www.osha.gov, you can also:

■ File a complaint online,

■ Submit general inquiries about workplace safety and health electronically, and

■ Find more information about OSHA and occupational safety and

health.
OSHA Regional Offices

* These states and territories operate their own OSHA-approved job safety

and health programs and cover state and local government employees as

well as private sector employees. The Connecticut, Illinois, New Jersey,

New York and Virgin Islands plans cover public employees only. States with

approved programs must have standards that are identical to, or at least as

effective as, the Federal OSHA standards.

Note: To get contact information for OSHA Area Offices, OSHA-approved

State Plans and OSHA Consultation Projects, please visit us online at

www.osha.gov or call us at 1-800-321-0SHA.

28

Region I

(CT*, ME, MA, NH, RI, VT*)

JFK Federal Building, Room E340

Boston, MA 02203

(617) 565-9860

Region II

(NJ*, NY*, PR*, VI*)

201 Varick Street, Room 670

New York, NY 10014

(212) 337-2378

Region III

(DE, DC, MD*, PA, VA*, WV)

The Curtis Center

170 S. Independence Mall West

Suite 740 West

Philadelphia, PA 19106-3309

(215) 861-4900

Region IV

(AL, FL, GA, KY*, MS, NC*, SC*, TN*)

61 Forsyth Street, SW, Room 6T50

Atlanta, GA 30303

(404) 562-2300

Region V

(lL*, IN*, MI*, MN*, OH, WI)

230 South Dearborn Street

Room 3244

Chicago, IL 60604

(312) 353-2220

Region VI

(AR, LA, NM*, OK, TX)

525 Griffin Street, Room 602

Dallas, TX 75202

(972) 850-4145

Region VII

(IA*, KS, MO, NE)

Two Pershing Square

2300 Main Street, Suite 1010

Kansas City, MO 64108-2416

(816) 283-8745

Region VIII

(CO, MT, NO, SO, UT*, WY*)

1999 Broadway, Suite 1690

PO Box 46550

Denver, CO 80202-5716

(720) 264-6550

Region IX

(AZ*, CA*, HI*, NV,* and American

Samoa, Guam and the Northern

Mariana Islands)

90 7th Street, Suite 18-100

San Francisco, CA 94103

(415) 625-2547

Region X

(AK*, ID, OR*, WA*)

1111 Third Avenue, Suite 715

Seattle, WA 98101-3212

(206) 553-5930