Nothing pushes a safety or health topic onto the radar faster than an upward spike in OSHA citations. Although hexavalent chromium isn’t anywhere near the top of the “Most Cited OSHA Standards” list, it has popped up a couple of times lately with some of my clients. These citations remind us of the relevance of these rather loftily technical regulations to some garden-variety businesses, many of which were mistakenly assuming the hex chrome rules were for someone else.
OSHA is looking to write hex chrome citations. There is plenty of fertile ground in industries reliant on food-grade equipment, such as groceries, restaurants, food processing plants, and candy manufacturing. OSHA considers stainless steel welding to be the most likely source of hex chrome exposures, and they know the food-related trades will always involve stainless steel and welding at some point for either building or repairing the equipment. There’s lots of other industries where hex chrome can be present, such as electroplating and cement production, but welding shouldn’t be overlooked.
The common citation I’m seeing lately is for not doing any initial exposure assessment. This applies even to a single person doing a little welding to fix a crack or a replace worn floor in a chute. There is an exception to air monitoring if the employer has “objective data”.
Although it is quite possible the amount of stainless steel welding might not ever be enough to release enough hex chrome to be a problem, OSHA set the bar very high for what constitutes “objective data”. Objective data is what we would use to negate the need for initial air monitoring, but it’s defined in the chrome rules in a way that makes it very hard to use objective data. Air monitoring is often going to be the easiest way to comply.
I’ve also seen employers slapped with fines for not educating employees on the hex chrome rules. This is a provision that exceeds the normal training on the safety data sheets required by the chemical hazard communication rules. It’s been cited even where OSHA has no data to show an overexposure. Just the act of welding on stainless steel has been enough. In time, I’m sure we’ll see other areas of the rules cited. There are a lot of them.
It’s a complicated rule, and highly technical. If you have stainless steel welding in any quantity, however small, and would prefer to go about things the easy way, please take this column as helpful advice and look into how accurate measurements of hex chrome is being released, and what you will need to comply with the rules.
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