Hexavalent Chromium Compliance

1. Purpose

a) The purpose of this hexavalent chromium compliance program is to help ensure that ESCO Group employee exposure levels to hexavalent chromium are accurately assessed, and that employees are not exposed to hexavalent chromium at levels that are above the Permissible Exposure Limit (PEL)(5 ug/m3 ). 

b) Where hexavalent chromium is present in concentrations above the PEL, the compliance procedures described in this program will be implemented.  

c) Where exposure levels are at or below the PEL, the applicable procedures described in this program will be implemented as required.

2. Health Factors

a) Potential symptoms:

i. Irritation of respiratory system; bronchitis, asthma, nosebleeds, nasal septum ulceration and perforation; liver, kidney damage; leukocytosis (increased blood leukocytes), leukopenia (reduced blood leukocytes), eosinophilia; eye injury, conjunctivitis; skin ulcer, irritant and allergic contact dermatitis; [potential occupational carcinogen] 

b) Health Effects:  

i. Lung cancer (HE1); Asthma (HE9); Nasal perforation, ulceration; dermatitis (HE14) 

c) Affected organs:

i. Blood, respiratory system, liver, kidneys, eyes, skin

3. Hexavalent Chromium Emitting Activities

a) Activities at job sites where ESCO Group employees may be exposed to hexavalent chromium are as follows:

i. ESCO Group employees may be installing stainless steel pipe supports. They will be using electric arc welders to connect the joints. Although fumes will be present while welding is being conducted, the task is of short duration and point of operation ventilation is not feasible for this application.

ii. ESCO Group employees may be plasma cutting a hole in a stainless steel plate that would generate a fume.  Although fumes will be present while plasma cutting is being conducted, the task is of short duration and point of operation ventilation is not feasible for this application.

iii. ESCO Group employees may be assigned to work in an area designated by the industrial employer or independent outside contractor as a Hexavalent Chromium exposure area.   ESCO Group will inform the employer or contractor of our intent to limit exposure by conducting our activities during their non-production hours to minimize exposure or, if this is not feasible, through the use of respiratory protection as a secondary means.  

iv. ESCO Group employees may saw stainless steel conduit using a bandsaw.  This will typically produce a large particle and is not respirable.  Employees will use normal PPE (gloves and sleeves) to prevent skin exposure to particle.

v. ESCO Group employees that perform housekeeping duties will ensure that waste, scrap, debris, and any other materials contaminated with chromium (VI) and consigned for disposal are collected and disposed of in sealed, impermeable bags or other closed, impermeable containers.

4. Exposure Determination

a) Employee exposure levels will be determined by existing  air monitoring data conducted by The ESCO Group, historical data and objective data from OSHA or NIOSH; AND/OR air monitoring data and historical data from the facilities of the industrial employer or outside independent contractor.

b) When exposure levels exceed the Permissible Exposure Limit all employees will be notified immediately. 

c) Written notification will be established to describe the corrective action being taken to reduce employee exposure levels to a point that is at or below the Permissible Exposure Limit. 

d) The Safety Director will ensure that the air monitoring methods that were used for exposure determination purposes were within an accuracy range of 25 percent, and produce a statistical confidence level of 95 percent for concentrations at or above the Action Level. 

e) Affected employees and their representatives will be permitted to observe any air monitoring.

f) Appropriate personal protective equipment will be provided for any observers. 

g) Copies of all initial and periodic air monitoring results records, historical data, and objective data will be attached to this program or are available from the Safety Director.  The records will include the following:

i. Air Monitoring Records

1. The date of measurement for each sample taken;

2. A description of the operation being monitored;

3. A description of the sampling and analytical methods used, and evidence of their accuracy;

4. A description of the types of personal protective equipment used;

5. The name, social security number, and job classification of each employee represented by the monitoring;

6. Identification of the employees who were monitored.

ii. Historical Data Records

1. A description of how collection methods meet accuracy requirements;

2. A description of how the processes and work practices in use when the data was collected are essentially the same as those to be used during the job;

3. A description of how the characteristics of the hexavalent chromium containing materials in use when the data was collected are the same as those on the job for which exposure is being determined;

4. A description of how the environmental conditions at the time the data was collected are the same as those conditions on the job for which exposure is being determined;

5. A description of any other relevant data.

iii. Objective Data Records 

1. A description of the hexavalent chromium material;

2. A description of the source of objective data;

3. A description of the testing protocol and results of the testing, or analysis of the material for release of hexavalent chromium;

4. A description of the process, operation, or activity and how the data supports the determination;

5. A description of any other relevant data.

5. Means of Achieving Compliance

a) The means that ESCO Group will use to achieve compliance with the standard are as follows:

i. Our employees will use industrial fans to keep welding fumes away from their respective breathing zones.  The employees will also keep their welding face shields tucked in close to their chests so that fumes will not rise up under their shields.

ii. During the period in which ESCO Group is implementing any engineering or work practice controls, respirators shall be used to comply with the new PEL.

iii. If a process or task causes associate exposures to Hexavalent chromium that exceed the PEL on 29 or fewer days during any 12 consecutive months, ESCO Group is allowed to use any combination of controls (Engineering/Work practices/PPE), including respirators alone, to achieve the reduction in the PEL. Respirators are less reliable than engineering and work practice controls and create their own safety and health hazards. This provision is intended to cover situations in which Hexavalent chromium exposures are infrequent and is not meant to permit the use of respirators in lieu of inexpensive, mobile engineering controls.

iv. ESCO Group will not use associate rotation as a means of compliance, unless a single employee cannot feasibly be expected to safely perform that task during a normal shift.  Only the Safety Director will have the discretion to make that judgment call.

v. ESCO employees who voluntarily use respirators to protect themselves from Hexavalent chromium exposures, at less than the PEL, will comply with the applicable provisions of 29 CFR 1910.134 Respiratory Protection Appendix D.

vi. ESCO Group will provide appropriate protective clothing and equipment at no cost to employees where a hazard is present or is likely to be present from skin or eye contact with Hexavalent chromium.  Ordinary street clothing and work uniforms or other accessories that do not protect employees from Hexavalent chromium hazards are not considered protective clothing or equipment under these standards. ESCO Group is also required to ensure employee use of any clothing and equipment provided.

vii. Employees will comply with the work practices section of this program.

6. Program Implementation Schedule

February 1, 2011 – It was determined that employees with ESCO Group could be exposed to hexavalent chromium above the PEL while performing specific tasks.
February 1, 2011 – All other employers on the job site will be notified about the hexavalent chromium hazard that is specifically created by ESCO Group.
February 1, 2011 – Engineering and work practice controls will be implemented, if feasible.
February 1, 2011 – Respiratory protection training, fit-testing and equipment will be provided if necessary.
February 1, 2011 – Appropriate hexavalent chromium hazard signs will be posted. 
February 1, 2011 – Personal protective clothing will be provided.
February 1, 2011 – Appropriate hygiene facilities will be provided and proper hygiene practices will be established.
February 1, 2011 – Hand- and face-washing facilities will be provided for affected employees.
February 1, 2011 – Medical surveillance will be implemented.
February 1, 2011 – Affected employees will receive advanced training on hexavalent chromium hazards, effects and protective measures.
February 1, 2011 – Regular air monitoring will be conducted.
February 1, 2011 – Proper housekeeping procedures will be implemented.
February 1, 2011 – Medical removal protection procedures will be implemented if necessary.
February 1, 2011 – Appropriate recordkeeping procedures will be implemented. 

7. Work Practice Requirements

a) Project Superintendent or his designee (Project Safety Manager) will:

i. Provide clean, dry coveralls. Coveralls and will be laundered on a weekly basis whenever hexavalent chromium levels exceed the PEL, without regard to respirator use, when hexavalent chromium compounds that could cause skin irritation are present or as necessary for interim protection;

ii. Provide protective clothing and equipment and, when necessary, will dispose of it properly;

iii. Repair or replace required protective clothing and equipment as needed to maintain their effectiveness;

iv. Ensure that all protective work clothing is removed at the completion of each work shift in specially provided change areas;

v. Ensure that contaminated protective work clothing that is to be cleaned, laundered or disposed of is placed in a closed container inside the established change area;

vi. Inform all persons who clean or launder protective clothing or equipment about the harmful effects of hexavalent chromium exposure;

vii. Ensure that each container of contaminated protective clothing and equipment is affixed with labels that state the following: 

1. Caution: Clothing contaminated with hexavalent chromium. Do not remove dust by blowing or shaking. Dispose of hexavalent chromium-contaminated wash water in accordance with applicable local, state or federal regulations.

viii. Prohibit the removal of hexavalent chromium from protective clothing by blowing, shaking or any other means that disperses hexavalent chromium into the air;

ix. Ensure that surfaces are kept free of hexavalent chromium dust as much as practicable; ensure that cleaning is done by vacuuming or other methods that minimize the likelihood of hexavalent chromium becoming airborne;

x. Ensure that vacuums are equipped with High Efficiency Particulate Air (HEPA) filters and emptied in a way that minimizes reentry of hexavalent chromium into the workplace;

xi. Ensure that compressed air is not used to remove hexavalent chromium from the workplace unless it is used in conjunction with a ventilation system designed to capture the airborne dust created by the compressed air;

xii. Ensure that employees do not have food, beverages, tobacco products or cosmetics in their possession when they are exposed to hexavalent chromium above the PEL, without regard to respirator use;

xiii. Provide clean change areas for employees who are exposed to hexavalent chromium above the PEL and as an interim protective measure;

xiv. Establish change areas with separate storage facilities for work clothing and equipment and street clothes;

xv. Ensure that employees do not leave the workplace wearing protective clothing or equipment that is required to be worn during the work shift;

xvi. Provide employees with shower facilities where feasible when they are exposed to hexavalent chromium at concentrations above the PEL;

xvii. Ensure that affected employees shower at the end of each work shift;

xviii. Provide cleansing agents and towels for affected employees;

xix. Provide clean, hexavalent chromium-free, readily accessible eating areas for employees who are exposed to hexavalent chromium above the PEL without regard to respirator use;

xx. Ensure that employees wash their hands and faces prior to eating, drinking, smoking or applying cosmetics when exposure to hexavalent chromium is above the PEL, without regard to respirator use; 

xxi. Ensure that employees do not enter eating facilities with work clothing unless surface hexavalent chromium dust has been removed by vacuuming, use of a downdraft booth or other methods that limit dispersion of hexavalent chromium dust;

xxii. Provide employees with adequate hand-washing facilities;

xxiii. Ensure that employees wash their hands and faces at the end of each work shift when showers are not provided.

8. Procedures for Multi-Employer Job Sites

a) All contractors on the job site whose employees could be exposed to hexavalent chromium will have a written notice delivered to their project managers by Project Superintendent.  The written notice will include the location of the hexavalent chromium, the materials in which hexavalent chromium is present, a brief summary of the hazards associated with hexavalent chromium exposure, a description of the protective measures to be implemented by ESCO Group and a description of the hexavalent chromium hazard warning signs to be posted.

9. Additional Relevant Information 

a) Each job site area where hexavalent chromium is present and all ESCO Group equipment in those areas will be inspected by Project Superintendent or his designee (Project Safety Manager) at the start of work each day where the possibility of hexavalent chromium exposure still exists.

10. Hexavalent Chromium Air Monitoring Checklist

a) Items and issues to take into account (and document) when conducting air monitoring for hexavalent chromium during welding operations:

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