All surfaces must be maintained as free as practicable of
accumulations of cadmium.

* All spills and sudden releases of material containing cadmium
must be cleaned up as soon as possibie.

* Whenever possible, surfaces contaminated with cadmium
must be cleaned by vacuuming or other methods that minimize
the likelihood of cadmium becoming airborne. HEPA-filtered
vacuuming equipment or other equally effective filtration
methods must be used for vacuuming. The equipment must
be used and emptied in a manner that minimizes the reentry of
cadmium into the workplace.

* Shoveling, dry or wet sweeping, and brushing may be used
only where vacuuming or other methods that minimize the
likelihood of cadmium becoming airborne have been tried and
found to be ineffective.

* Compressed air must not be used to remove cadmium from
any surface unless the compressed air is used in conjunction
with a ventilation system designed to capture the dust cloud
created by the compressed air.

+ Waste, scrap, debris, bags, containers, equipment, and
clothing contaminated with cadmium and consigned for
disposal must be collected and disposed of in sealed
impermeable bags or other closed impermeable containers.
These bags and containers must be labeled according to the
provisions of the rule, and disposed of according to applicable
federal, state, and local regulations.

Training Program

The employer is responsible for instituting a training program that
is accessible to all employees who are potentially exposed to
cadmium, ensuring employee participation in the program, and
maintaining a record of the contents of such a program. The
training must be provided prior to or at the time of the employee’s
initial assignment to a job that involves potential exposure to
cadmium and at least annually thereafter. Additionally, the em-
ployer must make the training program understandable to the
employee and must ensure that each employee is informed of the
following:

* The health hazards associated with cadmium exposure.

14


« Acopy of the information provided to the physician as required
under this rule.

in accordance with the provisions of 29 CFR 1910.20, the em-
ployer must retain the medical surveillance records for the duration
of the employee’s employment plus 30 years.

The employer must make available either to the employee, or to
anyone having the written consent of the employee, within 15 days
after a request, all required medical records. After an employee’s
death or incapacitation such records also must be given within 15
days of a request to the employee's family.

Similarly, the employer is responsible for the proper transfer of
these records when he or she ceases to do business.

Regulated Areas

An employer must establish a regulated area whenever an
employee’s exposure to airborne concentrations of cadmium,
regardless of respirator use, is or can reasonably be expected to
be in excess of the PEL. Regulated areas must:

* Be set apart from the rest of the workplace in a way that
establishes and alerts employees to the boundaries of the
area;

* Be entered ONLY by authorized persons;
« Be entered ONLY by persons using proper respirators; and,

+ Be accessibie to employees who refrain from eating, drinking,
smoking, chewing tobacco or gum, and applying cosmetics in
such areas. Employees must not carry, store, or use products
associated with such activities into these areas.

Warning signs bearing the following information must be posted at
all approaches to regulated areas:

DANGER...CADMIUM...CANCER HAZARD...CAN CAUSE
LUNG AND KIDNEY DISEASE...AUTHORIZED PERSONNEL
ONLY...RESPIRATORS REQUIRED IN THIS AREA.

Similarly, warning labels containing the following information must
be placed on shipping and storage containers containing cadmium,


educational programs, reach out to workers and employers for
whom their program is appropriate, and provide these programs to
workers and employers. Grants are awarded annually, with a

1 -year renewal possible. Grant recipients are expected to contrib-

ute 20 percent of the total grant cost.

ECALs for Processes in Seiected industries
SECAL
Industry sector Processes or PEL
(ug/m3)
Nickel cadmium battery ....| Piate making, piate preparation 50
All other processes .... 15
Zink/cadmium refining ....... Cadmium refining, casting, melting, oxide
production, sinter plant ..... 50
All other processes ..... 5
Pigment manufacture........ Calcining, crushing, milling, blending
operations ...... 50
All other processes 15
Stabilizers .| Cadmium oxide charging, crushing, drying,
blending operations 50
All other processes .... 5
Lead smelting ............sss+ Sinter plant, blast furnace, baghouse,
YAP AFCA... scesesecesesseseesecsesecssesnssecstenceneey 50
All other proc 5
Plating ......sseccessessescnsenessnces Mechanical plating .. 15
All other processes 5

Source: Federal Register 57 (178): 42222, Table VIlI-B1, September 14, 1992.

18


Contents

Page
INtrOGUCTION .........esececesersesesesssceseccscssessscessecescncassecessssssacasscessecsacsecs 1
Scope and Application... eseesecesessseceseseeessseseesseseenseenesesene 2

Provisions of the Rule ..
Exposure Limits ...
Exposure Monitoring
Medical Surveillance
Regulated Areas

Methods of Compliance
Written Compliance Program...
Engineering and Work Practice Controis
Personal Protective Equipment...

Respirators........... 12
Hygiene Facilities . +13
Housekeeping Practices .

Training Program

Conclusion ....

Sources of OSHA Assistance ...
State Programs ..............
Consultation Services ....
Voluntary Protection Programs ....
Safety and Health Program Management Guidelines.
Training and Education ......

Related OSHA Publications...
States with Approved Plans...
OSHA Consultation Project Directory .


* The quantity, location, use, release, and storage of cadmium in
the workplace and the specific nature of operations that could
result in cadmium exposure, especially exposures above the
PEL;

* The engineering controls and work practices associated with
the employee’s job assignment;

* The ways that employees can protect themselves from expo-
sure to cadmium, including modifying habits such as personal
hygiene and smoking; and the specific procedures the em-
ployer has implemented to protect employees from exposure
to cadmium, such as using appropriate work practices, emer-
gency procedures, and personal protective equipment;

« The purpose, proper selection, fit, use, and limitation of
respirators and protective clothing;

* The purpose and description of the medical surveillance
program required by the rule;

* The contents of the rule and its appendices; and

« The employee’s rights of access to his or her exposure and
medical records under 29 CFR 1910.20 (e).

Conclusion

OSHA has determined that cadmium in any form poses a signifi-
cant threat to the health of workers and can result in kidney
damage, lung cancer, or respiratory diseases. OSHA expects that
this final will reduce workers’ potential risk of serious health effects
from cadmium exposure.

Sources of OSHA Assistance

OSHA program services that are available to employers include
state plan programs, consultation services, voluntary protection
programs, safety and health management programs, and training
and education.

State Programs

States administering their own occupational safety and health
programs through plans approved under section 18 (b) of the OSH
Act of 1970 must adopt standards and enforce requirements that

15


DIRECTOR

Nevada Department of Indus-
trial Relations

Division of Occupational Safety
and Health

Capitol Complex

1370 S. Curry Street

Carson City, NV 89710

(702) 687-3032

SECRETARY

New Mexico Environment
Department

Occupational Health and
Safety Bureau

1190 St. Francis Drive

P.O. Box 26110

Santa Fe, NM 87502

(505) 827-2850

COMMISSIONER

New York Department of Labor
State Office Building

Campus 12-Room 457

Albany, NY 12240

(518) 457-2741

COMMISSIONER

North Carolina Department
of Labor

4 West Edenton Street

Raleigh, NC 27601

(918) 733-0360

ADMINISTRATOR

Oregon Occupational Safety
and Heaith Division

Oregon Department
of Insurance and Finance,

Room 160

21 Labor and Industries
Building

Summer and Chemeketa
Streets, NE

Salem, OR 97310

(503) 378-3272

SECRETARY

Puerto Rico Department
of Labor and Human
Resources

Prudencio Rivera Martinez
Building

505 Munoz Rivera Avenue

Hato Rey, PR 00918

(809) 754-2119

COMMISSIONER

South Carolina Department
of Labor

3600 Forest Drive

P.O. Box 11329

Columbia, SC 29211-1329

(803) 734-9594

COMMISSIONER

Tennessee Department of
Labor

501 Union Building

Suite “A” - 2nd Floor

Nashville, TN 37243-0655

(615) 741-2582

ADMINISTRATOR
Utah Occupational Safety
and Health
160 East 300 South
3rd Floor
P.O. Box 146600
Salt Lake City, UT 84110-6600
(801) 530-6880

COMMISSIONER

Vermont Department of Labor
and Industry

120 State Street

Montpelier, VT 05620

(802) 828-2288

2i


Safety and Health Program Management Guidelines

OSHA's recommended Safety and Health Program Management
Guidelines’ issued in 1989 provide a blueprint for employers who
seek guidance on how to effectively manage and protect worker
safety and health. The four main elements of an effective occupa-
tional safety and health program are (1) management commitment
and employee involvement, (2) work site analysis, (3) hazard
prevention and control, and (4) safety and health training. These
elements encompass principles such as establishing and commu-
nicating clear goals of a safety and health management program;
conducting work site examinations to identify existing hazards and
the conditions under which changes might occur; effectively
designing the job site or job to prevent hazards; and providing
essential training to address the safety and health responsibilities
of both management and employees. Instituting these practices,
along with providing the correct methods of compliance, can help
improve worker safety and health.

Training and Education

The OSHA Training Institute in Des Plaines, IL, provides basic and
advanced training and education in safety and health for federal
and state compliance officers; state consultants; other federal
agency personnel, and private sector employers, employees and
their representatives. Institute courses cover areas such as
electrical hazards, machine guarding, ventilation and ergonomics.
The Institute facility includes classrooms, laboratories, a library,
and an audiovisual unit. The laboratories contain various demon-
strations and equipment, such as power presses, woodworking
and welding shops, a complete industrial ventilation unit and a
sound demonstration laboratory. More than 70 courses are
available for personnel in the private sector dealing with subjects
such as safety and health in the construction industry and methods
of voluntary compliance with OSHA standards.

OSHA also provides funds to nonprofit organizations to conduct
workplace training and education in subjects where OSHA believes
there is a current lack of workplace training. OSHA identifies areas
of unmet needs for safety and health education in the workplace
annually and invites grant applications to address these needs.
Organizations awarded grants use funds to develop training and

7 Federal Register 54 (18): 3094-3916 on January 26, 1989. A single, free copy of
the guidelines is available by contacting the OSHA Publications Office at 200
Constitution Avenue, N.W., Room N3101, Washington, DC 20210, (202) 219-4667.

17


+ Inform any person who launders or cleans protective clothing
or equipment contaminated with cadmium of the potentially
harmful effects of exposure to cadmium.

+ Inform any person who gives contaminated clothing or equip-
ment to another party to launder or clean to warn the party to
launder or clean the clothing or equipment in a manner that
avoids the release of airborne cadmium in excess of the PEL.
The labels must also be in compliance with the Hazard Com-
munication Standard and must state: “Danger...Contains
Cadmium...Cancer Hazard...Avoid Creating Dust...Can Cause
Lung and Kidney Disease.”

* Transport contaminated clothing and equipment in sealed

ad
impermeable b bags, oF other closed, i impermeable containers

as required by the rule.
Respirators

Where applicable, the employer must provide respirators at no cost
to employees and ensure that they are used in compliance with the
standard. Respirators shall be used in the following circum-
stances:

* When exposures exceed the PEL, during the time period
necessary to install or implement feasible engineering and
work practice controls;

« When exposures exceed the PEL and engineering and work
practice controls are either infeasible or not required;

+ When all the feasible engineering and work practice controls
are insufficient to reduce exposure to or below the PEL;

+ When there is an emergency, and whenever an employee who
is exposed at or above the action level requests a respirator;

* Ina designated regulated area;

« Whenever an employee is exposed above the PEL in an
industry where a SECAL is applicable; and

12


¢ Sampie at intervais no greater than 6 months where the initial
or periodic monitoring shows employee exposures are at or
above the action level. Employers may discontinue monitoring
if employee exposure has been confirmed to be below the
action level.

* Conduct additional monitoring whenever there has been a
change in raw materials and processes, equipment, personnel,
work practices, or finished products that may result in addi-
tional exposures to cadmium at or above the action level; that
may result in workers previously exposed at or above the
action level becoming exposed above the PEL; or whenever
employers suspect any other changes might result in such

further exposure.

. Notify each affected employee in writin
acn amecied em iat

receiving any exposure mor itorin results. Also, post the
noth: +7

results in an accessible location. The ¢
results in an accessioie iocation. ine notice Must S'

the PEL.

* Monitor and analyze airborne concentrations of cadmium > the
action level or PEL with a method that has an accuracy of + 25
percent and a confidence level of 95 percent.

The employer must offer employees or their designated represen-
tatives an opportunity to observe any monitoring. When this
involves entering an area where personal protective clothing or
equipment is required, the employer must provide such clothing
and equipment to the observer and must ensure they are used;
observers also must comply with all other applicable safety and
health procedures.

Exposure monitoring records must contain the following informa-

tion:

* The monitoring date, duration, and results in terms of an
8-hour TWA of each sample taken;

A descrintion of the sampling and
A Gescription of ine Sampiing ana

and evidence of their accuracy;


Rhode Island
South Carolina..

..(401) 277-2438
(803) 734-9599

South Dakota 605) 688-4101
Tennessee 615) 741-7036
Texas.... 512) 440-3834
Utah ... 801) 530-6868
Vermont (802) 828-2765
Virgini (804) 786-6613
Vi (809) 772-1315
Washington .. (206) 956-5441
West Virginia ... (304) 558-7890

Wisconsin .

Wyoming ..

...(608) 266-8579(H)
...(414) 521-5063(S)
...(307) 777-7786

H- Health S - Safety

24


Introduction

Cadmium, in its elemental state, is either a blue-white, lustrous
metal or a grayish-white powder found in lead, copper, and zinc
sulfide ores; most cadmium compounds are highly colored from
brown to yellow and red. Cadmium is used as an anticorrosive
electroplated onto steel, as an electrode component in alkaline
batteries, as a component of solders and welding electrodes, and
as a stabilizer in plastics. Workers in a wide variety of industries—
from manufactures of plastics, ceramics, and paint to industries
involving electroplating, metal machining, and welding—are
exposed to cadmium.

OSHA moved to protect these workers from cadmium exposure as
early as 1971, when it adopted the American National Standards
Institute’s (ANSI) threshold limit values (TLVs) for cadmium as a
national consensus standard under section 6 (a) of the Occupa-
tional Safety and Health (OSH) Act of 1970. The consensus
standard established, for general industry, an 8-hour time-weighted
average (TWA) permissible exposure limit (PEL) of 100 micro-
grams per cubic meter of air (100 g/m) and a ceiling concentra-
tion of 300 g/m for cadmium fumes; it also set a TWA PEL of
200 jig/m3 and a ceiling of 600 jxg/m? for cadmium dust. The
standard for the construction industry was a TWA PEL of

100 jig/m? for cadmium oxide fumes and 200 g/m? for metal
dust and soluble salts.

OSHA decided to reduce these limits in response to a June 18,
1986, petition by the Health Research Group of Public Citizen and
the international Chemical Workers Union, as well as evidence of
adverse health effects at the then existing PELs. The petitioners,
for example, cited several studies that they believed provided
evidence of lung cancer and kidney disease from occupationai
exposure to cadmium at and below the PELs. In July 1987, OSHA
determined the necessity for a rulemaking under section 6 (b) of
the OSH Act to reduce worker exposure to cadmium.

In February 1990, OSHA published a notice of proposed
rulemaking on cadmium.1 Based on OSHA's review of major
epidemiological studies of lung cancer and renal dysfunction
among workers and studies of animals exposed to cadmium, and
based on the agency's quantitative risk assessment, OSHA
proposed PELs of either 5 g/m? or 1,1.9/m8 to reduce the level of
worker exposure to cadmium by more than 95 to 99 percent.

‘Federal Register 55 (25): 4052-4147 on February 6, 1990.




* Whenever an employee is exposed to cadmium above the
PEL, and engineering controls are not required under para-
graph (f)(1)(iii) of the rule (i. e., excludes the employer from
using engineering and work practice controls if he or she can
show that the empioyee’s cadmium exposure level is fewer
than 30 days per year and the employee is not otherwise
exposed to cadmium).

Hygiene Facilities

For employees whose airborne exposure to cadmium—regardless
of respirator use or other personal protective equipment—is above
the PEL, the employer also must provide clean change rooms,
showers, and handwashing and luncheon facilities that comply with
the following requirements:

* The employer must ensure that change rooms are equipped
with separate storage facilities for street clothes and for
protective clothing and are designed to prevent dispersing
cadmium and contaminating the employee’s street
clothes.

« Employees exposed to cadmium above the PEL must shower
during the end of the work shift and must wash their hands and
faces prior to eating, drinking, smoking, chewing tobacco or
gum, or applying cosmetics.

« Luncheon facilities must be readily accessible to employees;
tables for eating should be maintained free of cadmium; and
no employee in an eating facility should be exposed to cad-
mium at any time at or above a concentration of 2.5 pg/m3.

Employers must ensure that employees do not enter eating
facilities while wearing protective work clothing or equipment
unless surface cadmium has been removed from the clothing and
equipment by high-efficiency particulate air (HEPA)® vacuuming or
some other method that removes dust without causing the. cad-
mium to disperse.

Housekeeping Practices

Under the rule, the employer must adhere to the following require-
ments:

*At least 99.97 percent efficient against mono-dispersed particies of 0.3 microme-
ters or larger.

13


airborne exposure level and follow the provisions in the rule
applicable to that level. For example, this includes, among other
things, performing air monitoring and providing a respirator to any

ninvea who requests one. In
employee who requests one. In addition, if an employee's expo-

sures are at or above the action level on 30 or more days per year,
the employer must provide medical surveillance to that employee.
If exposures are determined to be below the action level, the rule
only requires that empioyers train the employees to work in a safe
and healthful manner and communicate to them the hazards of

exposure to any level of cadmium.

The SECAL is a separate exposure limit to be achieved in specified
processes and workplaces where it is not possible to achieve the
PEL of 5 pg/m3 through engineering and work practices alone. The
SECAL for cadmium is 15 g/m or 50 yg/m3, depending on the
processes involved (See page 18). The employer covered by the
SECAL is required to achieve that limit by engineering and work
practice controls to the extent feasible and to protect employees
from exposures above the PEL by any mix of compliance methods,
including engineering and work practice controls and respirators.

Exposure Monitoring

Each employer with a workplace or work operation covered by the
rule must determine whether any employee, without regard to the
use of respirators, may be exposed to! cadmium at or above the
action ievei. Employers must do this by measuring the employees’
breathing zone air samples to reflect their regular, daily 8-hour
TWA exposure to cadmium. Where several employees have
identical job classifications, tasks, work areas and work shifts and
the length, duration, and ievei of cadmium exposures are simiiar,
employers may monitor exposure levels by sampling a representa-
tive number of these employees instead of all employees. Repre-
sentative samples, however, shall include employees expected to
have the highest cadmium exposures.

Other provisions of exposure monitoring require employers to do
the following:

¢ Monitor employees to determine initial exposures. Monitoring
data gathered within 12 months prior to the effective date of

the rule may be used if the monitoring conditions closely

resemble prevailing ones and satisfy rall other monitoring
requirements of the rule. Employers also may rely upon
objective data in lieu of initial monitoring, where such data

de tha: Invees % wiet
demonstrate that employees will not be exposed at or above

the action level.


Related OSHA Publications

Single, free copies of the following publications can be obtained
from the OSHA Publications Office, U. S. Department of Labor,
200 Constitution Avenue, N. W., Room N3101, Washington, DC
20210, or from the nearest OSHA Regional Office listed in this
booklet. Send a self-addressed label with your request.

Access to Medical and Exposure Records—OSHA 3110
All About OSHA—OSHA 2056

Chemical Hazard Communication—OSHA 3084
Consultation Services for the Employer—OSHA 3047
Employee Workplace Rights—OSHA 3021

How to Prepare for Workplace Emergencies—OSHA 3000
Personal Protective Equipment—OSHA 3077

Respiratory Protection—OSHA 3079

The following publications are available from the Superintendents
of Documents, U. S. Government Printing Office, Washington, DC
20402, (202) 783-3238. Include GPO Order No. and make checks
payable to Superintendent of Documents.

Hazard Communication—A Compliance Kit—OSHA 3104

(A reference guide to step-by-step requirements for compliance
with the OSHA standard.)

Order No. 929-022-00000-9; Cost $18.00 domestic; $22.50
foreign.

Hazard Communication Guidelines for Compliance—OSHA 3111
Order No. 029-016-00127-1; Cost $1.00

Job Hazard Analysis—OSHA 3071
Order No. 029-016-00142-5; Cost $1.00

Principal Emergency Response and Preparedness Requirements
in OSHA Standards and Guidance for Safety and Health
Programs—OSHA 3122

Order No. 029-016000136-1; Cost $2.50

Training Requirements in OSHA Standards and Training

Guidelines—OSHA 2254
Order No. 029-016-00137-9; Cost $4.25

19


Occupational Exposure  <&
to Cadmium >

U.S. Department of Labor
e) pationa afe and



At a minimum, medical surveillance provisions require an initial
limited pre-placement examination, a periodic full medical exami-
nation within 1 year after the initial examination and biennially
thereafter, and annual biological monitoring. The three required
biological monitoring tests are cadmium in urine, cadmium in
blood, and beta-2-microglobulin in urine. The recommended
employer actions triggered by the results of biological monitoring
are identified in Appendix A under the rule.5

Medical examinations and biological monitoring results may
require employers to reassess factors such as work practices,
personal hygiene, smoking history and status, respiratory protec-
tion, hygiene facilities, personal protective equipment, engineering
controls, and correct any deficiencies responsible for excess
exposures.

All medical examinations and procedures required by this rule shall
be performed under the supervision of a licensed physician
(medical doctor) who has read and is familiar with the health
information provided in the preamble of the rule, the regulatory
text, and Appendices A, D, and F of the rule. Examinations and
procedures must be provided without cost to, and at a time and
place that is reasonable for, the employee.

Employers must notify employees of their right to seek a second
medical opinion after completion of the initial medical examination
or consultation. The employer and employee may agree upon the
use of any alternate form of physician determination, in lieu of
more than one medical opinion (multiple physician review), as long
as the alternative is expeditious and equally as protective.

The employer must obtain a written, signed, medical opinion from
the examining physician that, to the extent relevant to the
employee's exposure to cadmium, includes the following: (1) the
physician’s diagnosis and any opinion on the status of the
employee’s medical condition that would place the employee at
increased risk from further exposure to cadmium; (2) the results of
any employee tests that reveal cadmium exposure; any limitations
on the employee’s work activities; and (3) a statement by the
physician that he or she has clearly and carefully explained the
important medical facts to the employee.

SAppendix A—Substance Safety Data Sheet, Tables A and B, Federal Register 57
(178): 42399-42404, September 14, 1992.

6


* The type of respiratory protective device, if any, worn by the
monitored employee and by any other employee whose
exposure the monitoring represents; and

« Anotation of any other conditions that might have affected the
monitoring results.

The employer is responsible for maintaining this record for at least
30 years in accordance with the requirements of 29 CFR 1910.20,
“Access to Employee Exposure and Medical Records.” Such data
must show that a particular product or material containing cad-
mium or a specific process, operation, or activity involving cad-
mium cannot release dust or fumes in concentrations at or above
the action level, even under a worst case scenario. Data can be
obtained from an industrywide study or from laboratory product test
results by manufacturers of cadmium-containing products or
materials.

The data the employer uses from an industrywide survey must be
obtained under workplace conditions that closely resemble the
processes, types of material, control methods, work practices, and
environmental conditions in the employer's current operations.

Medical Surveillance

Employers must provide a medical surveillance program for all
employees who are exposed or might previously have been
exposed at or above the action level, unless the employer can
demonstrate that the employee (1) is not exposed to airborne
concentrations of cadmium at or above the action level on 30 or
more days per year; and (2) did not, prior to December 14, 1992,
work for the employer in jobs with exposure to cadmium for an
aggregated total of more than 60 months.

Employers must comply with various procedures to satisfy the
medical surveillance provisions of the cadmium rule. These
include (1) providing medical examinations and biological monitor-
ing tests; (2) taking any necessary corrective actions required by
monitoring results; (3) ensuring that medical procedures meet
OSHA recommendations, and that employees are allowed to use
multiple physician reviews and alternative medical determination
procedures, if needed; and (4) giving to and obtaining from physi-
cians the necessary information and data to evaluate an
employee’s health status. Physicians who require more guidance
on the content of these examinations should refer to Appendices A
and F in the rule.4

4See Federal Register 57 (178) 42399-42404; 42418-4247, September 14, 1992.


U. S. Department of Labor

Regional Offices

Region I

1 33° Portland Street

595 5 Giffin Street

Tst Floor
Boston, MA 02414

Room 602
Dallas, TX 75202

Telephone: (617) 565-7164

Telephone: (214) 767-4731

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

Region VII
(IA,* KS, MO, NE)

201 Varick Street
Room 670

911 Walnut Street, Room 406
Kansas City, MO 64106

New York, NY 10014
Telephone: (212) 337-2378

Telephone: (816) 426-5861

Telephone: 18) 596- 1201

Region VIII

(APL IV

Region 1X

Geom Samoa, "AZ," CA, *

Telephone: (41 5) 744-6670

230 South Dearborn Steet

Region xX

Ti Third Avenue

Room 3244
Chicago, IL 60604

Suite 715
Seattle, WA 98101-3212

Telephone: (312) 353-2220

Telephone: (206) 553-5930

“These states and territories operate their own OSHA-approved job safety and health
programs (the Connecticut and New York plans cover public employees only). States

with approved programs must have a standard that is identical to, or at least as
effective as, the federal standard.

wr U.S.G.P.O. 1992 342-557/74409





OSHA's final rule establishing a new PEL of 5 g/m? and other
protective provisions for cadmium was published on September
14, 1992, in the Federal Register under Title 29 CFR, Part
1910.1027 and is effective as of December 14, 1992.2 This
booklet is designed to help employers and employees understand
and comply with the rule.

Scope and Application

The rule applies to all occupational exposures to cadmium and
cadmium compounds, in all forms, and in all industries covered by
the OSH Act, including the general, maritime, and agricultural
industries. A separate regulation on occupational exposure to
cadmium has been issued for the construction industry.3

Provisions of the Rule

Among its provisions, the rule requires employers to (1) adhere to
a new PEL and, in a limited number of industrial processes, a
separate engineering control air limit (SECAL); (2) monitor the
levels of cadmium to which workers are exposed; (3) provide
adequate medical surveillance; (4) establish regulated work areas
whenever the cadmium levels exceed those mandated by the rule;
and (5) maintain records of both exposure monitoring and medical
surveillance for specified time periods.

Exposure Limits

Employers must ensure that no employee is exposed to excessive
airborne concentrations of cadmium as provided by the standard
according to the permissible exposure limit (PEL), the action level,
and the separate engineering control air limit (SECAL).

The PEL is a TWA concentration that must not be exceeded during
any 8-hour work shift of a 40-hour workweek. The standard
requires a PEL of 5 micrograms of cadmium per cubic meter of air
(5 g/m3) for all cadmium compounds, dust, and fumes.

The action level is a level of cadmium in the air of the workplace
that is half of the PEL, or 2.5 micrograms per cubic meter of air
{2.5 :g/m3), calculated as an 8-hour TWA. If exposure occurs that
may be at or above the action level, employers must determine the

?This booklet is not a substitute for requirements of the rule. The complete
regulatory text of the cadmium rule and appendices are published in the Federal
Register 57 (178): 42102-42463, September 14, 1992. .

*See 29 CFR 1926.63 for the cadmium standard for the construction industry.

2


are at least as effective as federal requirements. There are 23
states and 2 territories with their own OSHA-approved occupa-
tional safety and health plans; 23 cover the private and public
(state and local government) sectors and 2 cover the public sector
only. The states and territories that operate their own OSHA-
approved job safety and health programs are listed at the end of
this booklet.

Consultation Services

Employers who want help in recognizing and correcting safety and
health hazards and in improving their safety and health programs
can get it from a free consultation service funded mainly by OSHA.
A professional staff administers the service through the state
governments. Onsite consultation, among other things, helps
employees recognize hazards in the workplace, suggests ap-
proaches or options for solving safety or health problems, identifies
available sources of help, assists employers in developing or
maintaining an effective safety and health program, and offers
training and education for employers and employees at the work-
place.

The service is given primarily at the work site, but limited services
may be provided away from the work site. The service is provided
on request mainly to smaller companies in high-hazard industries
and will not result in citations or penalties for violations found. The
states with OSHA consultation projects are listed at the end of this
booklet.

Voluntary Protection Programs

Voluntary protection programs (VPPs) and on-site consultation
services, when coupled with an effective enforcement program,
expand worker protection to help meet the goals of the OSH Act.
The three levels of VPPs—Star, Merit, and Demonstration—are
designed to recognize outstanding achievement by companies that
have successfully incorporated comprehensive safety and health
programs into their total management system. They motivate
others to achieve excellent safety and health results in the same
outstanding way and they establish a cooperative relationship
among employers, employees, and OSHA.

For additional information on VPPs and how to apply, contact the
appropriate regional OSHA office listed at the end of this booklet.

16


COMMISSIONER

Virgin Islands Department
of Labor

2131 Hospital Street

Christiansted

St. Croix, VI 00840-4666

(809) 773-1994

COMMISSIONER

Virginia Department of Labor
and Industry

Powers-Taylor Building

13 South 13th Street

Richmond, VA 23219

(804) 786-2376

DIRECTOR

Washington Department
of Labor and Industries

General Administration
Building

P.O. Box 44001

Olympia, WA 98504-4001

(206) 753-6307

DIRECTOR
Department of Employment
Division of Employment Affairs
Occupational Safety

and Health Administration
Herschler Building
2nd Floor East
122 West 25th Street
Cheyenne, WY 82002
(307) 777-7672




cadmium compounds, or cadmium-contaminated clothing, equip-
ment, waste, scrap, or debris, as specified:

DANGER...CONTAINS CADMIUM...CANCER
HAZARD...AVOID CREATING DUST...CAN CAUSE LUNG
AND KIDNEY DISEASE.

To inform employees about cadmium hazards, employers also
must comply with the requirements of the Hazard Communication
Standard (29 CFR 1910.1200) including such provisions as
warning signs and labels, material safety data sheets, and em-
ployee information and training.

Methods of Compliance

The employer is required to implement various methods to comply
with the PEL and, where applicable, the SECAL. Where the PEL
is exceeded, the employer must establish and implement a written
compliance program to reduce worker exposure. The written
program would include implementing engineering and work
practice controls; providing personal protective equipment where
necessary; installing proper, hygiene facilities; and adhering to
housekeeping practices.

Written Compliance Program

The employer's written compliance program must include at least
the following:

« Adescription of each operation that emits cadmium, inciuding
such factors as the type of machinery used, the kind of mate-
tial being processed, the types of controls in piace, the size of
the crew, the responsibilities of the empioyees, the kind of
operating procedures, and the type of maintenance practices;

¢ Adescription of the specific means used to achieve compli-
ance, including the engineering plans and studies used to
select methods to control exposure to cadmium and the use of
appropriate respiratory protection, when necessary, to
achieve the PEL;

* Areport on the technology considered in meeting the PEL;

* Air monitoring data thatdocument the sources of cadmium
emissions;


Personal Protective Equipment

Whenever an employee is exposed to cadmium above the PEL,
the employer must provide at no cost to the employee, and ensure
the employee uses, appropriate protective clothing and equipment
that prevent contamination of the employee and the employee’s
street clothes. Such equipment includes, but is not limited to,
respirators, coveralls or similar full-body clothing, gloves, head
coverings, boots, face shields, and vented goggles.

The employer is responsible for disposing of and/or properly
cleaning, laundering, repairing, and replacing personal protective
clothing and equipment. The following requirements pertain to
removing, storing, cleaning, replacing, and disposing of personal
protective clothing and equipment:

* Provide clean and dry personal protective clothing and equip-
ment at least weekly or more often as necessary to maintain
effectiveness.

* Do not allow employees to wear work clothing or take equip-
ment away from the job site. Under no circumstances shouid
cadmium-contaminated work clothes be laundered at home or
taken from the work site, except to be laundered professionally
or properly disposed of according to applicable federal, state,
or local regulations.

* Require that employees remove in designated change rooms,
all cadmium-contaminated personal protective clothing and
equipment when a work shift is completed.

« Place and store contaminated personal protective clothing and
equipment in closed impermeable containers prior to launder-
ing, cleaning, maintaining, or discarding.

¢ Properly label containers of contaminated protective clothing
and equipment when removing them from the change room or
workplace to launder, clean, maintain, or discard.

« Prohibit workers from removing cadmium from protective
clothing and equipment by blowing, shaking, or any other
means that disperses cadmium into the air.

Launder or clean contaminated equipment in the workplace in
a way that avoids releasing airborne cadmium in excess of the
PEL.

11


Occupational Exposure “@&
to Cadmium P

U.S. Department of Labor
Occupationai Safety and Heaith Administration

OSHA 3136
1992


States with Approved Plans

COMMISSIONER

Alaska Department of Labor
1111 West 8th Street

Room 306

Juneau, AK 99801

(907) 465-2700

DIRECTOR

Industrial Commission
of Arizona

800 W. Washington

Phoenix, AZ 85007

(602) 542-5795

DIRECTOR
California Department

of Industrial Relations
455 Golden Gate Avenue
4th Floor
San Francisco, CA 94102
(415) 703-4590

COMMISSIONER

Connecticut Department
of Labor

200 Folly Brook Boulevard

Wethersfield, CT 06109

(203) 566-5123

DIRECTOR

Hawaii Department of Labor
and Industrial Relations

830 Punchbowl Street

Honolulu, HI 96813

(808) 586-8844

COMMISSIONER

Indiana Department of Labor
State Office Building

402 West Washington Street
Room W195

Indianapolis, IN 46204-2287
(317) 232-2378

20

COMMISSIONER

lowa Division of Labor Services
1000 E. Grand Avenue

Des Moines, IA 50319

(515) 281-3447

SECRETARY

Kentucky Labor Cabinet

1049 U.S. Highway, 127 South
Frankfort, KY 40601

(502) 564-3070

COMMISSIONER
Maryland Division of Labor
and Industry
Department of Licensing
and Regulation
501 St. Paul Place, 2nd Floor
Baltimore, MD 21202-2272
(301) 333-4179

DIRECTOR

Michigan Department of Labor
Victor Office Center

201 N. Washington Square
P.O. Box 30015

Lansing, MI 48933

(517) 373-9600

DIRECTOR

Michigan Department of Public
Health

3423 North Logan Street

Box 30195

Lansing, MI 48909

(517) 335-8022

COMMISSIONER

Minnesota Department of Labor
and Industry

443 Lafayette Road

St. Paul, MN 55155

(612) 296-2342


The information contained in this publication is not
considered a substitute for any provisions of the
Occupational Safety and Health Act of 1970 or for
any standards issued by OSHA.

Material contained in this publication is in the public
domain and may be reproduced, fully or partially,
without permission of the Federal Government.
Source credit is requested but not required.

This information will be made available to sensory
impaired individuals upon request.

Voice phone: (202) 219-8615:

TDD Message referral phone: 1-800-326-2577


OSHA Consultation Project Directory

.-- felephone

Alabama (205) 348-3033
Alaska (907) 264-2599
Arizona (602) 542-5795
Arkansas (501) 682-4522
California . (415) 703-4441
Colorado .. (303) 491-6151
Connecticut (203) 566-4550
Deiaware ........ (302) 577-3908
District of Columbia .. (202) 576-6339
Florida . (904) 488-3044
Georgia (404) 894-8274
Guam... ... (671) 646-9244
Hawaii.. ... (808) 586-9116
Idaho ... ..- (208) 385-3283
Illinois .. «- (312) 814-2337
Indiana. .«. (317) 232-2688
lowa.. ... (515) 281-5352
Kansa: ..-(913) 296-4386
Kentucky... ... (502) 564-6895
Louisiana . ... (504) 342-9601
Maine... ...(207) 289-6460
Maryland.. ..-(301) 333-4218
Massachusetts .. ...(617) 727-3463
Michigan ..... (517) 335-8250(H)
seeeseeseees (517) 322-1809(S)
Minnesota ... (612) 297-2393
Mississippi .. ...(601) 987-3981
Missouri .. ... (314) 751-3403
Montana . ..-(406) 444-6401
Nebraska (402) 471-4717
Nevada ... (702) 486-5016
New Hampshire . ... (603) 271-2024
New Jersey... .-. (609) 292-7036
New Mexico (505) 827-2885
New York.... (518) 457-2481
North Carolina (919) 733-3949
North Dakota . (701) 221-5188

,o) (614) 644-2631
Oklahoma (405) 528-1500

Oregon ... (503) 378-3272
Pennsylvania . (412) 357-2561
Puerto Rico ...(304) 558-7890

H- Health S - Safety

23


Employers must temporarily remove employees from jobs with
exposure to cadmium at or above the AL on each occasion that a
physician determines in a written medical opinion that the em-
ployee should be removed from cadmium exposure, or where the
empioyee’s biological monitoring results are so high as to require
mandatory medical removal. The physician may determine the
need for medical removai based on biological monitoring results,
evidence of iliness, inability to wear a respirator, signs or symp-
toms of cadmium-reiated dysfunction or disease, or any other
reason deemed medicaily sufficient. When the removal is due to
the employee’s inability to wear a respirator, the removal need only
be from jobs with exposure to cadmium above the PEL.

The employer also must provide employees with the following:

* Acopy of the physician’s written medical opinion within 2
weeks after receipt;

¢ Acopy of the employee’s biological monitoring results within 2
weeks after receipt; and,

+ Information that is given to the physician under the provisions
of this rule, within 30 days of an employee’s request.

The employer also must establish and maintain an accurate
medical surveillance record for each employee to whom medical
surveillance is provided.

The medical surveillance record must include the following infor-
mation:

¢ The name, sociai security number, and description of the
duties of the employee;

« Acopy of the physician's written opinion;

¢ Acopy of the empioyee’s medical history, the results of any
physical examination and all test results that must be provided
by this rule, including biological tests, X-rays, and pulmonary
function tests; and any results that have been obtained to
further evaluate any condition that might be related to cad-
mium exposure;

* The employee’s medical symptoms that might be related to
exposure to cadmium; and


* Adetailed schedule for implementing the program, including
information on purchase orders for equipment, and construc-
tion contracts; and

* Awork practice program that includes hygiene fa
practices and a written plan for dealing with cadmium emer-
gencies.

The written compliance plan also must be reviewed and updated at
least annually, or more often if necessary, to reflect any significant
changes in the employer's compliance status.

Engineering and Work Practice Controls

Engineering and work practice controls are two primary methods
used to protect employees from occupational exposure to cad-
mium under the rule. Engineering controls reduce employee
exposure in the workplace by either removing or isolating the
hazard or isolating the worker from exposure. An example of an

engineering control is an exhaust system that captures the air-

borne concentrations of cadmium at the source.

Work practice controls involve the way a task is performed, such
as housekeeping and hygiene practices. For example, requiring
employees exposed to cadmium to wash their faces and hands
prior to eating, drinking, smoking, chewing tobacco or gum, or
applying cosmetics is a work practice control.

Employers must implement engineering and work practice controls
to reduce and maintain employee exposure at or below the PEL or
SECAL, unless the employer can demonstrate that such controls
are not feasible. The employer is exempt from implementing
engineering and work practice controls to achieve the PEL or,
where applicable, the SECAL if the employer demonstrates (1) that
the employee is exposed to cadmium above the PEL on fewer than
30 days per year; and (2) that the employee is not otherwise
exposed to cadmium.

Whenever engineering and work practice controls are not sufficient
to reduce employee exposure to or below the PEL or, where
applicable, the SECAL, the employer must still implement such
controls to reduce exposures to the lowest levels achievable.
Then, the employer must supplement such controls with respira-

tory nrotecti that complies he racniratnry reniiramante

tory protection inat complies with the tespiratory requiremer its of

the rule and achieve the PEL.

10