Although it exempts portland cement, the new Chrome VI (CrVI, known as hexavalent chrome, or simply chrome six) standard impacts operators who (1) cut
BOB ECKHARDT
Although it exempts portland cement, the new Chrome VI (CrVI, known as hexavalent chrome, or simply chrome six) standard impacts operators who (1) cut or weld stainless steel, or (2) use pigments containing CrVI. Elemental chrome forms two general compounds: CrIII comprises more stable, inert compounds, while CrVI compounds are far more toxic. Addressing only the latter, CrVI, the new standard in 29 CFR 1910.1026 became effective February 28, 2006. The Notice of Rulemaking applied to general industry as well as construction.
The primary modes of workplace exposure are airborne and skin contact. Chrome VI exposures are associated with lung cancer, asthma, skin ulcerations and dermatitis. CrVI can be present in smoke or fine dust particles liberated during cutting, welding or grinding of stainless steel. Elemental chrome added to steel gives it a shiny, corrosion-resistant quality; and, since rebar contains only trace amounts of Cr, CrVI is not liberated during normal cutting, welding, or grinding of mild steel such as rebar. Nevertheless, local ventilation is required during mild-steel operations to satisfy less stringent smoke- and dust-exposure limits prescribed by OSHA for these materials.
The permissible exposure limit (PEL) for CrVI was reduced from 52 to 5 micrograms of CrVI per cubic meter of air, as an eight-hour, time-weighted average. Accordingly, employers who expose workers to CrVI must hire a qualified industrial hygienist to monitor airborne exposure and conduct wipe samples to identify CrVI in the work environment. If airborne CrVI is below the PEL and wipe samples do not identify CrVI dust, then monitoring periodically and when a workplace change occurs is sufficient.
If the PEL is exceeded, however, or CrVI dusts are identified, the standard includes provisions for employee protection through engineering and workplace exposure control, monitoring, medical surveillance, training, record maintenance, the use of protective clothing, respirators, and established dedicated hygiene areas. In effect, the new standard outlines production of a full employer industrial health program.
For the few employers facing CrVI exposures, monitoring will identify whether or not a full CrVI program is warranted. Should excessive exposures be detected, a producer may wish to evaluate the cost of program implementation and health risk versus the use of alternative, non-CrVI-generating processes or materials. Elimination of CrVI-containing products or processes in the workplace is the only way to avoid initial monitoring responsibilities, if an employer has a CrVI exposure problem.
COMMON CITATION TRAPS
Training records
Every employer should have an accurate and easily accessible record-keeping system for all OSHA-required training. Included in all training records must be the date of original instruction as well as dates of recurrent or refresher training. Paper tests with the employee’s name on it or digital systems proving the employee was tested must also be maintained.
Fire extinguisher training
OSHA’s annual fire-extinguisher refresher-training regulation requires that employees actually use a fire extinguisher to put out a fire. To accomplish that end, everyone can go to a local safety council, which has the equipment to provide the training; or, a portable unit specifically designed to perform this function can be purchased by the employer. Available at local safety suppliers, such units provide an instantly re-ignitable flame for extinguishing. Documentation of the training is required.
Chemical inventory form
The chemical inventory must be up to date, bearing this year’s date and listing all chemicals according to their workplace common name, in alphabetical order, and with an updated MSDS for each item. Record-keepers are advised to avoid stuffing the chemical inventory list and MSDSs with other notations, including safety meeting training materials, policies or other materials. OSHA considers such extra information an impediment in the search for an MSDS, constituting a legitimate, citable violation of the standard.
Inspection documentation
In whatever manner documented, an employer must be able to produce regular inspection records of almost all equipment, including mobile units, cranes, come-alongs, ladders, combustion equipment such as boilers and steam generators, electrical cords and power tools, fire extinguishers, eye-wash and emergency shower systems, compressed-air systems, welding and cutting equipment, compressed-air cylinder storage areas, grinding wheel pre-use ping test, and fall protection equipment as well as the general workplace.
Annual program review documentation
Many OSHA-required programs stipulate annual reviews and verifying documentation. Employers are advised to schedule an annual review date for each safety program, though not all programs specifically demand an annual update. While annual reviews are essential for lockout/tagout, PPE, respiratory protection, and emergency plans, most programs require a review whenever a process change is implemented.
Employee knowledge
In accordance with OSHA act provisions, agency representatives are authorized to privately question employees on the job. That right was justified as a means of allowing the OSHA inspector to evaluate the effectiveness of training. Typical questions for which employees must have answers include the following:
- Where are the MSDSs maintained?
- What are the hazards associated with the chemicals you use?
- What are the hazards associated with your job?
- What are the emergency and evacuation procedures?
Posters
Three posters OSHA always looks for are (1) the standard OSHA workplace poster, (2) the poster of Hearing Regulations in environments that exceed 85dBA, and (3) the OSHA 300A, required for posting from February 15 through April 30 of the following year.
DOT hours of service
DOT inspectors immediately spot hours-of-service logs showing exactly the same number of driving hours every day or recorded hours that unfailingly total the exact limit. Perfect logs that do not show stops, start and return times are suspect. Recognizing traffic congestion, delivery delays and other issues that cause occasional hours-of-service compliance problems, DOT inspectors expect some violations, and most do not cite the employer for such infractions.
CRANE COMPLIANCE CHECKLIST
Use of hoists as well as overhead, mobile, and locomotive cranes is governed by OSHA regulations, which also incorporate American National Standards Institute (ANSI) standards for cranes and hoists. The following condensed checklist can assist producers in verifying their compliance status.
Load test
- Has the crane had initial load testing and additional load testing when major repairs or modifications were performed?
- Has the crane been periodically load tested as required in California state regulation?
Inspections
- Do cranes have a complete periodic (usually annual) inspection by a competent person to evaluate all the working components of the crane (usually a crane service company)?
- Do cranes have a frequent inspection (usually monthly) that identifies ANSI specific components?
- Does each operator conduct a documented daily inspection for every shift the crane is used?
- Have critical inspection findings been documented and corrected?
Training
- Does the employer have documentation for each operator indicating training and testing on the crane the operator is using?
- Has each operator received annual refresher training?
Certifications
Is all lifting equipment, such as hooks, shackles, spreader bars, and specialty lifting devices, manufactured and supplied by lifting equipment suppliers? Spreader bars, for example, must have the manufacturer’s name, date of manufacture, rated capacity, and load test date on the spreader bar certification plate.