THE COHEN GROUP
  Environmental Health & Safety Consulting Services

The Cohen Group Newsletter - Volume 8  Issue 3, Article 3.  September, 2006

 Hexavalent Chromium Standard Update
Tim Bormann, CIH

In the last issue of Current Issues (May 2006), we discussed the new Federal OSHA standard for hexavalent chromium (29 CFR 1910.1026) which was scheduled to become effective May 30, 2006. At the time, however, it appeared the federal standard would be stayed and would not go into effect on that date. Despite some challenges, the federal hexavalent chromium standard was upheld and is indeed now in effect. In accordance with the federal standard promulgation, Cal/OSHA adopted new Hexavalent Chromium standards which can be found in the Construction Safety Orders in § 1532.2, the General Industry Safety Orders (GISO) in §5206, and the Ship Building Safety Orders in §8359. These were approved by the Cal/OSH Standards Board at its July 2006 meeting. The federal standard and the California standard are essentially identical.

Hexavalent chromium is used in a variety of industrial activities, including the manufacture of stainless steel, welding, painting, pigment application, electroplating and other surface coating processes. If hexavalent chromium is present and/or used at your work site and there is a potential for worker exposure, we recommend that you promptly conduct an air monitoring survey to establish exposure levels or determine if alternative objective exposure data exists that can be used to characterize and determine worker exposures.

It is important to note that the Permissible Exposure Limit (PEL) for hexavalent chromium has been significantly lowered to 5 micrograms per cubic meter (µg/m³). The action level is 2.5 µg/m³. The previous Cal/OSHA PEL was 100 µg/m as a ceiling limit and there was no action level.

Like the federal standard, Cal/OSHA is providing a transition period for compliance based on the size of the employer. For employers with 20 or more employees, requirements for compliance with all elements except engineering controls commence on November 27, 2006. Employers with fewer than 20 employees will need to be in compliance with all elements of the standard except engineering controls by May 30, 2007. Engineering controls required for all employers must be implemented no later than May 30, 2010.

Please call us if we may be of assistance in evaluating potential exposures to chromium and/or other hazardous materials.