THE COHEN GROUP
  Environmental Health & Safety Consulting Services

The Cohen Group Newsletter - Volume 18  Issue 2, Article 2.  May 2007

New Requirements and Standards for Portland Cement
By Julie V. Wellings, CIH

Cal/OSHA currently regulates airborne Portland Cement as a “particulate not otherwise regulated” with a PEL of 5 and 10 mg/m³ (milligrams per cubic meter of air) for respirable and total dust, respectively.  However, the ACGIH (American Conference of Governmental Industrial Hygienists) has recently issued an “NIC” (Notice of Intended Change) to reduce the recommended TLV (Threshold Limit Value) for Portland Cement from 5 to 1 mg/m³ (respirable fraction). An NIC is a notice of a proposed change to the TLV, allowing time for public comment.  Values remain on the NIC List for approximately one year after they have been ratified by the ACGIH

The new Cal/OSHA comprehensive standard for hexavalent chromium or “CrVI” (see Current Issues, September 2006) specifically exempts exposures from Portland Cement.  However, regardless of the exemption from the standard, the lowered PEL (0.005 mg/m³) applies to all airborne CrVI exposures.

Also, Federal OSHA has developed and issued to regional administrators and state designees a document entitled “Portland Cement Inspection Procedures”, to be published as an appendix to its “CrVI Directive”.  The document is part of a settlement agreement between OSHA and several labor unions, and provides specific enforcement procedures and an inspection checklist for compliance officers to follow at all construction sites where employees are working with Portland Cement.  A copy of the Portland Cement Inspection Procedures are available from the Federal OSHA website (www.osha.gov).

In the cover letter attached to the Portland Cement Inspection Procedures, Federal OSHA acknowledges that the settlement agreement does not apply in the 22 states with OSHA-approved state plans like California but “strongly encourages these states to honor and implement the terms of this agreement” by implementing the new Procedures.  It is likely that California will comply and implement, in at least similar form, the provisions of the Procedures.

The Portland Cement Inspection Procedures specifically address the following elements of worker exposure and protection:   personal protective equipment, sanitation, airborne exposures, hazard communication and training, and recordkeeping.  With regard to CrVI, the emphasis is on dermal (skin) and eye hazards and on hazard communication training and information regarding carcinogenic properties. 

The Procedures indicate that because there are only trace amounts of CrVI in Portland Cement, the current Federal OSHA PELs for Portland Cement of 5 and 15 mg/m³ (for respirable and total dust, respectively) are at least as protective for CrVI as the current PEL for CrVI of 0.005 mg/m³.  Cal/OSHA’s take on this may be more conservative.

If Portland Cement is used in your workplace, we recommend a review of your current handling and worker protection practices.   The Inspection Checklist attached to Federal OSHA’s Portland Cement Inspection Procedures may be useful in the review.  Please contact us for assistance with your review and implementation of the new standards and guidelines.