Hexavalent Chromium. (Chromium VI) Safety Training Course. 29 CFR Part General Industry 29 CFR Part Construction Industry

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1 Hexavalent Chromium (Chromium VI) Safety Training Course 29 CFR Part General Industry 29 CFR Part Construction Industry Copyright protected. All rights reserved.

2 Occupational Exposure to Hexavalent Chromium (Chromium VI) 2

3 Training Agenda Characteristics Health Hazards Welding Hazards Exposure Determination Communication of Hazards Methods of Compliance Respiratory Equipment Medical Surveillance Respirator Use and Care Training and Information Program Evaluation Question & Answer Session 3

4 Hexavalent Chromium Standard Covers all occupational exposures to Hexavalent Chromium Agricultural operations Exceptions Exposures that occur in the application of pesticides Exposures to portland cement Objective data demonstrating that hexavalent chromium cannot be released in concentrations at or above 0.5 µg/m 3 as an 8-hour timeweighted average (TWA 8 ) under any condition of use 4

5 What Does the Standard Cover? Permissible Exposure Limit (PEL) Exposure Determination Regulated areas* Methods of Compliance Respiratory Protection Protective Work Clothing and Equipment Hygiene Areas and Practices Housekeeping* Medical Surveillance Communication of Hazards Recordkeeping * General industry only 5

6 Characteristics of Hexavalent Chromium 6

7 What is Hexavalent Chromium? Chromium VI or Cr(VI) Toxic form of chromium metal, generally man-made Used in many industrial applications, primarily for its anti-corrosive properties Can be created during certain hot work processes where the original form of chromium was not hexavalent 7

8 Characteristics of Hexavalent Chromium Definitions Action level µg/m³ (8-hour TWA). Permissible Exposure Limit - 5 µg/m³ (8-hour TWA). This has been lowered from the past level of 52 micrograms per cubic meter of air (52 µg/m³). Objective data means: Information such as air monitoring data from industry-wide surveys; or Calculations based on the composition or chemical and physical properties of a substance. 8

9 Characteristics of Hexavalent Chromium Chromium is a metal that exists in several oxidation or valence states, ranging from chromium (-II) to chromium (+VI). Chromium compounds are very stable in the trivalent state and occur naturally in this state in ores such as ferrochromite, or chromite ore. The hexavalent, Cr(VI) or chromate, is the second most stable state. It rarely occurs naturally; most Cr(VI) compounds are man made. 9

10 Characteristics of Hexavalent Chromium OSHA has determined that the PEL of 5 µg/m3 is technologically feasible for all affected welding job categories OSHA has concluded that no carbon steel welders are exposed to Cr(VI) above 5 µg/m3, with the exception of a small portion of workers welding on carbon steel in enclosed and confined spaces. Many welding processes, such as tungsten-arc welding (TIG) and submerged arc welding (SAW), already achieve Cr(VI) exposures below the PEL because they inherently generate lower fume volumes. 10

11 Characteristics of Hexavalent Chromium Is Chrome a Carcinogen or Necessary Element? Chrome III is an essential nutrient for maintaining blood glucose levels. Chrome VI is classified as a known human carcinogen. 11

12 Coverage Characteristics of Hexavalent Chromium General Industry: 29 CFR Part Construction Industry: 29 CFR Part Basic difference: Construction and Shipyards Cr VI standards lack sections on Regulated Areas and Housekeeping. 12

13 Past Cr VI Sampling Under the old PEL: Little sampling was performed; Chrome plating was the main focus Some overexposures were noted Little welding sampling was performed A few spray painter exposures were evaluated They were VERY HIGH. Painting a plane in a bunker was 1000 X the PEL Consultation found 3250 ug/m 3, 650 X the new PEL Not much prior sampling for Cr VI exposures 13

14 Scope This standard applies to occupational exposures to chromium (VI) in all forms and compounds in construction, except: Exposures that occur in the application of pesticides; Exposures to portland cement; or Where the employer has objective data demonstrating that a material containing chromium or a specific process, operation, or activity involving chromium cannot release dusts, fumes, or mists of chromium (VI) in concentrations at or above 0.5 µg/m³ as an 8 hour time weighted average (TWA) under any expected conditions of use. 14

15 Sources of Occupational Exposure pigments in paints, inks, and plastics anti-corrosion coatings (chrome plating, spray coatings) stainless steel textile dyes wood preservation Types of Hexavalent Chromium Chemicals lead chromate (chrome yellow, chrome green, molybdenum orange) (PbCrO 4 ) zinc chromate (ZnCrO 4 ) barium chromate calcium chromate potassium dichromate sodium chromate chromic trioxide (chromic acid) zinc chromate (ZnCrO 4 ) barium chromate (BaCrO 4 ) calcium chromate sodium chromate strontium chromate (SrCrO 4 ) hexavalent chromium (when cast, welded, or torch cut) ammonium dichromate ((NH 4 )2Cr 2 O 7 ) potassium chromate potassium dichromate sodium chromate chromium trioxide leather tanning ammonium dichromate ((NH 4 )2Cr 2 O 7 ) 15

16 Sources of Occupational Exposure Major operations/job tasks resulting in potential Cr(VI) exposure: Chrome plating/electroplating Welding on stainless steel or Cr(VI) painted surfaces Painting Aerospace Auto body repair Chromate pigment and chemical production Chrome Plating Bath 16

17 Sources of Occupational Exposure Major operations/job tasks resulting in potential Cr(VI) exposure: Chromium dye and catalyst production Glass manufacturing Plastic colorant production Bridgework Construction Traffic painting Refractory brick restoration Paint removal from bridges 17

18 Routes of Exposure How Can Hexavalent Chromium Enter the Body? Inhalation of dusts, mists, or fumes created during processes involving the use of Cr(VI) compounds or hot processes that cause the formation of Cr(VI) Eye or skin contact with powder, dusts, or liquids containing Cr(VI) 18

19 Health Hazards of Hexavalent Chromium 19

20 Major Health Effects Lung cancer Nasal septum ulcerations and perforations Asthma Permanent perforation of the nasal septum from continuous exposure performing chrome plating of small appliance parts 20

21 Major Health Effects Cancer Hexavalent chromium is considered a potential lung carcinogen. Studies of workers in the chromate production, plating, and pigment industries consistently show increased rates of lung cancer. Insoluble forms such as zinc chromate are the most potent 20 year cancer latency. 21

22 Major Health Effects Ingestion Hazards Erosive to stomach Hemorrhaging and death are likely Treatment for ingestion - dilution with milk or water and/or asorbic acid. This should only be given by someone qualified in first aid. Ingestion of ascorbic acid to reduce Cr VI to Cr III will work, but may cause renal failure (conversion of ascorbic acid to oxalate plugs the kidneys) Recommended that you seek medical assistance first. 22

23 Major Health Effects Eyes Direct eye contact with chromic acid or chromate dusts can cause permanent eye damage. Treatment for eye contact Flush eye(s) for 15 min. Seek medical assistance. Respiratory Tract Hexavalent chromium can irritate the nose, throat, and lungs. Repeated or prolonged exposure can damage the mucous membranes of the nasal passages and result in ulcers. In severe cases, exposure causes perforation of the septum (the wall separating the nasal passages). 23

24 Major Health Effects Skin Prolonged skin contact can result in dermatitis and skin ulcers. Some workers develop an allergic sensitization to chromium. In sensitized workers, contact with even small amounts can cause a serious skin rash. Kidney damage has been linked to high dermal exposures. Treatment for skin contact - Irrigate with water Possible use of 10% ascorbic acid topically (the acid reduces/changes Cr VI to Cr III) Recommended that you seek medical assistance first. Chrome hole on finger. Can also occur on hands or forearms, and on bottom surfaces of feet from chrome salts permeating through boots or shoes. 24

25 Major Health Effects Cancer risk from Cr (VI) at new PEL is higher than asbestos risk at asbestos PEL Asbestos: 6.7 deaths per 1000 workers Benzene: 10 deaths per 1000 workers Chrome VI: excess lung cancer deaths per 1000 workers for 45 years of exposure at new PEL of 5 ug/m 3 25

26 Permissible Exposure Limit Permissible Exposure Limit (PEL) 8-hour time-weighted average exposure limit (TWA 8 ) 5 µg/m 3 TWA 8 in the air Action Level (AL) 2.5 µg/m 3 TWA 8 in the air 0.5 of PEL 26

27 Welding Hazards of Hexavalent Chromium 27

28 What is Covered? Welding - Stainless Steel Welding - Carbon Steel Painting Woodworking Refractory Brick Restoration & Maintenance Hazardous Waste Site Work Industrial Rehabilitation and Maintenance Portland Cement Producers Portland Cement? Ready Mix Concrete Portland Cement? Precast Concrete Products Portland Cement? 28

29 Welding Hazards Nearly half the workers covered under the new standard are welders Chromium in steel is oxidized to Cr VI by high welding temperatures. 6,000-8,000 C for the SMAW, GTAW, GMAW, FCAW and SAW processes The hotter the process and the more oxygen that is present, more fume is generated. 29

30 Welding Hazards Overexposures are POSSIBLE when welding stainless steel or high chrome steel and proper procedures are not followed. Stainless steel has between 10.5% - 27% chromium Nickel is also present in some types of stainless 30

31 Welding Hazards Potential for overexposure when welding CARBON steel and proper procedures are not followed. Position of head during welding is number one problem Anywhere the welding fume is more confined, such as welding in a tight corner Reason: 10% of carbon steel has chromium in more than trace amounts 31

32 Welding Hazards Stick welding: High likelihood of overexposure to Cr VI 50% of total Cr produced is Cr VI (FR pg col 3) TIG & MIG generates lower fume amounts 4% of total Cr produced from MIG is Cr VI 32

33 Welding Hazards Submerged arc generates lower fume amounts Conclusion: Switch to MIG from stick if you can 33

34 Exposure Determination 34

35 Exposure Determination Two options for determining employee exposures: Scheduled monitoring method Performance-oriented monitoring method 35

36 Exposure Determination Scheduled Monitoring If initial Cr(VI) concentration is: Below the AL At or above the AL Above the PEL Discontinue monitoring Monitor every 6 months Can discontinue monitoring if exposures are below AL and confirmed Monitor every 3 months Can discontinue monitoring if exposures are below AL and confirmed 36

37 Exposure Determination Scheduled Monitoring Option Representative sampling may be performed instead of sampling all employees in order to meet this requirement. In this case, the employer shall sample the employee(s) expected to have the highest chromium (VI) exposures. Perform initial monitoring to determine the 8-hour TWA exposure for each employee. Additional monitoring when: There has been any change that may result in new or additional exposures to chromium (VI), or When the employer has any reason to believe that new or additional exposures have occurred. 37

38 Exposure Determination Performance-oriented Monitoring Exposures determined using any combination of air monitoring data, historical monitoring data, or objective data sufficient to accurately characterize employee exposure to Cr(VI) No fixed schedule for performing periodic monitoring. The employer shall determine the 8-hour TWA exposure for each employee on the basis of any combination of: Air monitoring data; Historical monitoring data (prior to 5/30/2006); or Objective data. 38

39 Exposure Determination Each employer who has a workplace or work operation covered by this section shall determine the 8-hour TWA exposure for each employee exposed to chromium (VI). This determination shall be made in accordance with either of the following methods: Scheduled Monitoring Option Performance-oriented Option 39

40 Exposure Determination If samples show < Action Level May discontinue monitoring If samples show Action Level Periodic monitoring every six months If samples show Permissible Exposure Level Periodic monitoring every three months Additional monitoring where process has changed 40

41 Employee Notification of Results If sampling shows > PEL, the employer has 5 working days to post results or provide it in writing. Where sampling shows > PEL, the employer must describe, in the written notification, the corrective action being taken to reduce employee exposure to a level to or below the PEL. REMEMBER TO: 1. Provide results of exposure determination. 2. Describe corrective actions being taken to reduce exposure to or below the PEL 41

42 Accuracy of Sampling Accuracy Method and analysis +/- 25% w/ a CI of 95% Example would be the OSHA ID-215 Method 42

43 Observation of Monitoring Where air monitoring is performed to comply with the requirements of this section Provide affected employees or their designated representatives an opportunity to observe. The employer shall provide the observer with clothing and equipment and shall assure that the observer uses such clothing and equipment and complies with all other applicable safety and health procedures. 43

44 Regulated Areas Areas where exposures exceed or can be reasonably expected to exceed the PEL Regulated areas are clearly marked Access is limited to Authorized persons required by work duties to be there. Designated representatives of employees for the purpose of observing monitoring procedures. Persons authorized by the State or Federal government regulations to be there. 44

45 Communication of Hazards 45

46 Communication of Hazards The employer shall ensure that each employee can demonstrate knowledge of at least the following: The contents of this section; and The purpose and a description of the medical surveillance program. 46

47 Communication of Hazards 29 CFR Part (h) (1) Employers shall provide employees with effective information and training on hazardous chemicals in their work area at the time of their initial assignment, and whenever a new physical or health hazard the employees have not previously been trained about is introduced into their work area. Information and training may be designed to cover categories of hazards (e.g., flammability, carcinogenicity) or specific chemicals. Chemical-specific information must always be available through labels and material safety data sheets. 47

48 Communication of Hazards 29 CFR Part (h) - continued (2) "Information." Employees shall be informed of: (i) The requirements of this section; (ii) Any operations in their work area where hazardous chemicals are present; and, (iii) The location and availability of the written hazard communication program, including the required list(s) of hazardous chemicals, and material safety data sheets required by this section. 48

49 Communication of Hazards 29 CFR Part (h) - continued (3) "Training." Employee training shall include at least: (i) Methods and observations that may be used to detect the presence or release of a hazardous chemical in the work area; (ii) The physical and health hazards of the chemicals in the work area; 49

50 Communication of Hazards 29 CFR Part (h) - continued (3) "Training." Employee training shall include at least: (iii) The measures employees can take to protect themselves from these hazards, including specific procedures the employer has implemented to protect employees from exposure to hazardous chemicals, such as appropriate work practices, emergency procedures, and personal protective equipment to be used; and, (iv) The details of the hazard communication program developed by the employer, including an explanation of the labeling system and the material safety data sheet, and how employees can obtain and use the appropriate hazard information. 50

51 Methods of Compliance Engineering controls Work practice controls 51

52 Risk Management

53 Methods of Compliance Establish engineering and work practice controls as the primary means of achieving the PEL/reducing exposures. When not sufficient enough, use of respiratory protection in addition. No exposure above the PEL for 30 or more days per year or not feasible, Use of respiratory protection alone to comply. Prohibit job rotation to achieve compliance with the PEL 53

54 Engineering Controls To the extent feasible, designed to eliminate or reduce exposure to hazards based on the following principles: If feasible, design the facility, equipment, or process to remove the hazard and/or substitute something that is not hazardous or is less hazardous. If removal is not feasible, enclose the hazard to prevent exposure in normal operations. Where complete enclosure is not feasible, establish barriers or local ventilation to reduce exposure to the hazard in normal operations. 54

55 Elimination by Design Some examples of designing facilities, equipment, or processes so that the hazard is no longer present are: Redesigning, changing, or substituting equipment to remove the source of excessive temperature, noise, or pressure; Redesigning a process to use less toxic chemicals; Redesigning a workstation to relieve physical stress and remove ergonomic hazards; and Designing general ventilation with sufficient fresh outdoor air to improve indoor air quality and generally to provide a safe, healthful atmosphere. 55

56 Enclosure of Hazards When you can not remove a hazard and cannot replace it with a less hazardous alternative, the next best control is enclosure. While this may control employee exposure during production, it may not control exposures during maintenance. 56

57 Enclosure of Hazards Some examples of enclosure designs are: Complete enclosure of moving parts of machinery; Complete containment of toxic liquids or gasses from the beginning of the process using or producing them to detoxification, safe packing for shipment, or safe disposal of toxic waste products; Glove box operations to enclose work with dangerous microorganisms, radio nuclides, or toxic substances; and Complete containment of noise, heat, or pressure. 57

58 Barriers or Local Ventilation When the potential hazard cannot be removed, replaced, or enclosed, the next best approach is a barrier to exposure, or, in the case of air contaminants, local exhaust ventilation to remove the air contaminant from the workplace. This engineered control involves potential exposure to the worker even in normal operations, consequently, it should be used only in conjunction with other types of controls, such as safe work practices designed specifically for the site condition and/or personal protective equipment. 58

59 Welding Controls Fume extractor for stick and MIG/TIG welding on stainless steel Fume extractor for enclosed welding on any kind of steel Weld using lower temperatures Avoid stick welding on steel containing chrome, if possible 59

60 How is welding fume controlled? Change the welding procedures; Stick to MIG or even better TIG Use welding wires/rods designed for lower fume generation; Change power sources; Change shielding gases; or Fume removal / extraction. 60

61 Fume Removal / Extraction Low Vacuum (High Volume) Low Vacuum systems remove a large amount of air at low velocity and low vacuum pressure. In welding fume extraction, low vacuum systems use articulated arms roughly 8 inches in diameter and can be from 12 to 18 inches from the welding arc. These arms typically draw between 600 and 900 CFM per arm. If access to the joint prevents the use of fume guns or suction heads, low vacuum may be the better solution. If the weldment smokes considerably after welding due to die oils or paint, fume guns will not work since they are removed after welding. 61

62 Low Vacuum (High Volume) Mobiflex 100-NF Portable Fan For hard to reach areas, exhaust the fume Connect to 6 in. diameter, 16 ft. long hose set with magnet mounted hood exhaust or extension hose set. Does not provide filtration. 62

63 Low Vacuum (High Volume) Mobiflex 200-M Base Unit - Mobile Welding Fume Extractor A portable, low vacuum/high volume disposable filtration system designed for intermittent or continuous extraction and filtration of welding fumes. On-board internal extraction fan and is designed specifically for weld applications. The particulate is collected on the inside of the cartridge, minimizing exposure to particulate during filter maintenance and disposal. 63

64 Fume Removal / Extraction High Vacuum (Low Volume) High Vacuum systems capture fume as close to the arc as possible using integrated fume extraction guns or heads that use small diameter hose inches, about 4 to 6 inches from the welding arc. These systems use much smaller hose or duct because they draw only between 35 and 150 CFM. Fume is captured before it reaches the operators breathing zone. Using fume guns, the suction automatically follows the arc, eliminating repositioning necessary with low vacuum arms. Since only a small volume of air is processed, the strain on heating and cooling systems is minimal. Portable and mobile high vacuum units are smaller and less expensive than mobile low vacuum units. 64

65 High Vacuum (Low Volume) Miniflex - Portable Welding Fume Extractor A portable, high vacuum, low volume system specifically designed for the removal and filtration of welding fumes. It can be completely disassembled in a matter of minutes for cleaning and maintenance. With an automatic start/stop function, the unit automatically turns on and off during welding. It can be used in confined spaces and other locations that are not accessible with other welding fume extractors. 65

66 Work Practice Controls Position of head during welding operations When welding outside, having the wind at your back with the fumes being pushed away from your head. Preplan your work. 66

67 Some Painting Controls Chromates provide excellent corrosion control. With what data exists, airborne spray painting exposures are high. Recommendations: Substitute with non-cr VI paint, if possible Conduct spray painting in an extremely well-designed and maintained booth. (Think of controlling lead-based spray paint exposures, but having to control 10 times better.) Airline respirators 67

68 Some Painting Controls Ventilated grinders have been designed for silica and lead exposures Some grinders have a ventilated shroud on the grinder or needle gun, others may also have a perforated grinder disk If the paint contains zinc chromate or other chromates, Cr VI exposures will be high 68

69 Some Painting Controls Ventilated tools, ventilated enclosures, and increased levels of PPE are recommended Use Paint strippers to eliminate airborne exposures 69

70 Personal Protective Equipment When exposure to hazards cannot be engineered completely out of normal operations or maintenance work, and when safe work practices cannot provide sufficient additional protection, a further method of control is using protective clothing or equipment. These include face shields, steel-toed shoes, hard hats, respirators, hearing protection, gloves and safety glasses. 70

71 Break Time Coming Up Next Respiratory Program Requirements

72 Respiratory Program Requirements 29 CFR Part General Industry 72

73 Respiratory Protection When will you need a respirator? Periods necessary to install or implement feasible engineering and work practice controls Maintenance or repair operations where engineering and work practice controls are not feasible Operations where all feasible controls have been used and exposures are still above the PEL Operations where exposures do not exceed the PEL for 30 or more days per year and the employer has elected not to implement engineering and work practice controls to achieve the PEL Emergencies 73

74 Respiratory Protection Program The employer shall implement a written respiratory protection program with required worksite-specific procedures and elements for required respirator use including: Procedures for selecting respirators for use in the workplace Medical evaluations of employees required to use respirators Fit testing procedures for tight-fitting respirators Procedures for proper use of respirators in routine and reasonably foreseeable emergency situations CFR (c)(1)

75 Respiratory Protection Program The employer shall implement a written respiratory protection program with required worksite-specific procedures and elements for required respirator use including: Procedures and schedules for cleaning, disinfecting, storing, inspecting, repairing, discarding, and otherwise maintaining respirators Procedures to ensure adequate air quality, quantity, and flow of breathing air for atmosphere-supplying respirators Training of employees in the respiratory hazards to which they are potentially exposed during routine and emergency situations Training of employees in the proper use of respirators, including putting on and removing them, any limitations on their use, and their maintenance and Procedures for regularly evaluating the effectiveness of the program. 75

76 Respiratory Protection Program Where respirator use is not required: An employer may provide respirators at the request of employees or permit employees to use their own respirators, if the employer determines that such respirator use will not in itself create a hazard. If the employer determines that any voluntary respirator use is permissible, the employer shall provide the respirator users with the information contained in Appendix D to this section ("Information for Employees Using Respirators When Not Required Under the Standard") and In addition, the employer must establish and implement those elements of a written respiratory protection program necessary to ensure that any employee using a respirator voluntarily is medically able to use that respirator, and that the respirator is cleaned, stored, and maintained so that its use does not present a health hazard to the user. 76

77 Respiratory Protection Program The employer shall designate a program administrator who is qualified by appropriate training or experience that is commensurate with the complexity of the program to administer or oversee the respiratory protection program and conduct the required evaluations of program effectiveness. 77

78 Respiratory Equipment 78

79 Types of Respiratory Protective Equipment Dust, Fume and Mist Respirators: Mechanical filter respirators offer protection against airborne matter including dusts, mists, metal fumes and smoke. Mechanical filter respirators do not provide protection against gases, vapors, or oxygen deficiency. 79

80 Types of Respiratory Protective Equipment Chemical Cartridge Respirators: Chemical Cartridge Respirators afford protection against concentrations of certain acid gases and organic vapors utilizing various chemical agents to purify the inhaled air. They shall not be used in atmospheres which are oxygen deficient. Chemical Cartridge Respirators (1/2 mask) shall not be used for protection against: Gaseous material that is extremely toxic in small concentrations (hydrogen cyanide and sulfide). Exposure to harmful gaseous material which cannot be detected by odor (carbon monoxide). Gaseous material in concentrations which are highly irritating to the eyes. 80

81 Types of Respiratory Protective Equipment Air Supplied Hood: The Air Supplied Hood is normally used where the user only requires protection against levels of material or requires an air flow for cooling purposes. This equipment shall not be used in any situation where the user would be endangered. 81

82 Types of Respiratory Protective Airline Respirator: Equipment The airline respirator consists or a full face mask supplied with breathing air by a compressor or multiple stationary cylinders. Care must be exercised to prevent damage to the hose and regulator while in use, and the assembly shall be stored in such a way that damage will be avoided. 82

83 Types of Respiratory Protective Equipment Cylinder Type Self-Contained Breathing Apparatus: The SCBA utilizes compressed breathing air and will provide protection in any atmosphere regardless or contamination or oxygen. Although this equipment should provide breathing air for approximately 30 minutes, caution or emotional strain may reduce the rated time. Users of this equipment shall immediately begin exiting the hazardous atmosphere when the low pressure alarm sounds. 83

84 Selection of Respirators An appropriate NIOSH certified respirator will be selected and provided based on the respiratory hazard(s) to which workers are exposed and all relevant workplace and user factors that affect respirator performance and reliability. An evaluation of the respiratory hazard(s) in the workplace will be conducted and will include a reasonable estimate of employee exposures to respiratory hazard(s) and an identification of the contaminant's chemical state and physical form. Where the respiratory hazards or a reasonable estimate of the employee exposure cannot be identified, the atmosphere will be considered IDLH. 84

85 Selection of Respirators Employees will be allowed to select the respirator to be used from a sufficient number of respirator models and sizes so that the respirator is acceptable and correctly fits. In IDLH atmospheres, one of the following respirators must be used: A full facepiece pressure demand SCBA certified by NIOSH for a minimum service life of thirty minutes, or A combination full facepiece pressure demand supplied air respirator (SAR) with auxiliary self-contained air supply. Respirators provided only for escape from IDLH atmospheres shall be NIOSH certified for escape from the atmosphere in which they will be used. All oxygen deficient atmospheres shall be considered IDLH. 85

86 Selection of Respirators In atmospheres that are not IDLH, one of the following respirators must be used: For protection against gases and vapors, one of the following respirators must be used: An atmosphere supplying respirator, or An air purifying respirator, provided that: The respirator is equipped with an end-of-service-life indicator (ESLI) certified by NIOSH for the contaminant; or If there is no ESLI appropriate for conditions in the employer's workplace, the employer implements a change schedule for canisters and cartridges that is based on objective information or data that will ensure that canisters and cartridges are changed before the end of their service life. 86

87 Selection of Respirators In atmospheres that are not IDLH, one of the following respirators must be used: continued For protection against particulates, one of the following respirators must be used: An atmosphere supplying respirator; or An air purifying respirator equipped with a filter certified by NIOSH under 30 CFR part 11 as a high efficiency particulate air (HEPA) filter, or an air purifying respirator equipped with a filter certified for particulates by NIOSH under 42 CFR part 84; or For contaminants consisting primarily of particles with mass median aerodynamic diameters (MMAD) of at least 2 micrometers, an air purifying respirator equipped with any filter certified for particulates by NIOSH CFR (d)

88 Selection of Respirators The respirator selected must have an assigned protection factor adequate for the particular workplace exposure. Divide the airborne contaminant concentration by the Threshold Limit Value (TLV) to obtain a hazard ratio. To select an appropriate respirator, select from the following table a respirator with an equal or greater protection factor. 88

89 Assigned Protection Factors Type of Respirator 1,2 Quarter Mask Half Mask Full Facepiece Helmet /Hood Loose-Fitting Facepiece 1. Air-Purifying Respirator Powered Air-Purifying Respirator (PAPR) 50 1, Supplied-Air Respirator (SAR) or Airline Respirator 25/ 1, Demand mode Continuous flow mode 50 1,000 25/ 1, Pressure-demand or other positive-pressure mode 50 1, Self-Contained Breathing Apparatus (SCBA) Demand mode Pressure-demand or other positive-pressure mode (e.g., open/closed circuit) 10,000 10,000 89

90 Respirator Selection Steps 1. Identify the air contaminants present in the workplace. Include chemical name and form (i.e. dust, mist, fume, gas, or vapor). DUST - Dusts are created when solid material breaks down and gives off fine particles that float in the air before settling by gravity. MISTS - Mists are particles formed from liquid materials by atomization and condensation processes. FUMES -Fumes are created when solid materials vaporize under high heat. The metal vapor cools and condenses into small particles, with a size generally less then one micrometer in diameter. GASES - Gases are substances that are similar to air in their ability to diffuse or spread freely throughout a container or area. VAPORS - Vapors are the gaseous state of substances that are either liquids or solids at room temperature. They are formed when solids or liquids evaporate. 90

91 Respirator Selection Steps 2. Determine the concentration of the contaminant. Air sampling is recommended. *Note: If the concentration is unknown, select either a positive pressure self-contained breathing apparatus (SCBA) or positive pressure supplied air respirator with an auxiliary SCBA. 91

92 Respirator Selection Steps 3. Is the oxygen concentration or could the oxygen concentration become less than 19.5%. *Note: If the concentration of oxygen is less than 19.5%,select either a positive pressure self-contained breathing apparatus (SCBA) or positive pressure supplied air respirator with an auxiliary SCBA. 92

93 Respirator Selection Steps 4. What are the exposure limits as published by the American Conference of Governmental Industrial Hygienists or by the National Institute for Occupational Safety and Health. 5. Is the chemical airborne concentration greater than the IDLH concentration? *Note: If the airborne concentration is greater than the IDLH concentration, select either a positive pressure self-contained breathing apparatus (SCBA) or positive pressure supplied air respirator with an auxiliary SCBA. 93

94 Respirator Selection Steps 6. Is the chemical airborne concentration greater than 1000 times the TLV? *Note: If the airborne concentration is greater than 1000 times the TLV, select either a positive pressure self-contained breathing apparatus (SCBA) or positive pressure supplied air respirator with an auxiliary SCBA. 94

95 Respirator Selection Steps 7. Is the chemical airborne concentration greater than 50 times the TLV? If the chemical airborne concentration is greater than 50 times the TLV go to 8. If the chemical airborne concentration is not greater than 50 times the TLV go to Is the contamination form identified in step 1 a particulate? If YES, select either a Powered AIR Purifying Respirator (PAPR) or a supplied air respirator (except Half-Mask versions). If NO, select a supplied air respirator (except Half-Mask versions). 95

96 Respirator Selection Steps 9. Is the chemical airborne concentration greater than 10 times the TLV? If yes, go to 10. If no, select the Maintenance free or dual cartridge Half-Mask respirator that is design for the chemical involved. 10. Is the contaminant form identified is step 1 a particulate? If yes, select a full facepiece respirator with appropriate particulate filters (high efficiency filters recommended) or supplied air respirator. If no, select a full facepiece respirator with cartridges designed for the chemical involved. 96

97 Respirator Selection Steps 11. Are any other air contaminants present at the same time? If yes, note the respirator suggested, and repeat the entire procedure. If no, go to step Was more than one respirator recommendation required for a specific exposure situation? If yes, note all respirator recommendations. If your list contains more than one respirator and all are air purifying respirators, select the one with the highest assigned protection factor ( see the beginning of this section ) and the one that can remove all of the contaminants, if available. 97

98 Personal Protective Equipment (PPE) Protective Work Clothing and Equipment Use where a hazard is present or is likely to be present from skin or eye contact with Cr(VI) Remove all PPE and equipment when work shift or task is completed 98

99 Personal Protective Equipment (PPE) Protective Work Clothing and Equipment Do not remove Cr(VI) from PPE by blowing, shaking, or any other means that disperses into the air or onto the body Do not remove contaminated PPE from the workplace, except for laundering, disposal, etc. by employees with such job duties Clean and replace Cr(VI)-contaminated clothing and equipment as needed 99

100 Personal Protective Equipment (PPE) Laundering and Cleaning of PPE Store and transport contaminated PPE in sealed, impermeable bags or closed containers. Make sure they are properly labeled. Inform any person who launders/ cleans PPE of the potentially harmful effects of Cr(VI) exposure When laundering: Minimize skin or eye contact with Cr(VI) Prevent the release of airborne levels in excess of the PEL 100

101 Hygiene Areas and Practices When employee exposure is at/above the PEL: Change rooms separate storage facilities for PPE and street clothes Washing facilities Wash hands and face: at the end of the work shift prior to eating, drinking, smoking, chewing tobacco or gum, applying cosmetics, or using the toilet 101

102 Hygiene Areas and Practices Eating and Drinking Areas and Surfaces maintained as free as practicable of Cr(VI) 102

103 Housekeeping Keep all surfaces as free as practicable of accumulations of Cr(VI) Promptly clean up all spills and releases of Cr(VI)- containing materials Use HEPA vacuums or other methods that minimize exposure to Cr(VI) Dispose of Cr(VI)-contaminated waste in labeled, impermeable bags/containers 103

104 Medical Evaluation 104

105 Respirator Medical Evaluation Using a respirator may place a physiological burden on employees that varies with the type of respirator worn, the job and workplace conditions in which the respirator is used, and the medical status of the employee. Accordingly, all employee s required to use a respiratory protective device will be given, before the employee is fit tested or required to use the respirator in the workplace, a medical evaluation to determine the employee's ability to use a respirator. 105

106 Respirator Medical Evaluation Medical evaluations may be performed by using a medical questionnaire or an initial medical examination that obtains the same information as the medical questionnaire. A follow-up medical examination will be provided for an employee if the PLHCP determines the need from the questionnaire or the initial medical examination demonstrates the need for a follow-up medical examination. 106

107 Respirator Medical Evaluation The follow-up medical examination shall include any medical tests, consultations, or diagnostic procedures that the PLHCP deems necessary to make a final determination. The medical questionnaire and examinations shall be administered confidentially during normal working hours or at a time and place convenient to the employee. 107

108 Respirator Medical Evaluation The following information will be provided to the PLHCP before the PLHCP makes a recommendation concerning an employee's ability to use a respirator: The type and weight of the respirator to be used by the employee; The duration and frequency of respirator use (including use for rescue and escape); The expected physical work effort; Additional protective clothing and equipment to be worn; and Temperature and humidity extremes that may be encountered. 108

109 Respirator Medical Evaluation Any supplemental information provided previously to the PLHCP regarding an employee need not be provided for a subsequent medical evaluation if the information and the PLHCP remain the same. In determining the employee's ability to use a respirator, the employer must obtain a written recommendation regarding the employee's ability to use the respirator from the PLHCP including any limitations on respirator use, and the need, if any, for follow-up medical evaluations. 109

110 Respirator Medical Evaluation Employees will be provided with a copy of the PLHCP's written recommendation. If the respirator is a negative pressure respirator and the PLHCP finds a medical condition that may place the employee's health at increased risk if the respirator is used, a PAPR will be used, if the PLHCP's medical evaluation finds that the employee can use such a respirator. 110

111 Respirator Medical Evaluation At a minimum, additional medical evaluations that comply with the requirements of this program will be provided if: An employee reports medical signs or symptoms that are related to ability to use a respirator; A PLHCP, supervisor, or the respirator program administrator informs the employer that an employee needs to be reevaluated; Information from the respiratory protection program, including observations made during fit testing and program evaluation, indicates a need for employee reevaluation; or A change occurs in workplace conditions (e.g., physical work effort, protective clothing, temperature) that may result in a substantial increase in the physiological burden placed on an employee. 111

112 Fit Testing Before an employee is required to use any respirator: The employee must pass an appropriate qualitative fit test (QLFT) or quantitative fit test (QNFT) with the same make, model, style, and size of respirator that will be used. Fit testing is required: Prior to initial use of the respirator, Whenever a different respirator facepiece (size, style, model or make) is used, and At least annually thereafter. 112

113 Fit Testing An additional fit test will be required: Whenever the employee reports, or The PLHCP, supervisor, or program administrator makes visual observations of changes in the employee's physical condition that could affect respirator fit. The fit test shall be administered using an OSHA accepted QLFT or QNFT protocol. 113

114 Medical Surveillance 114

115 Medical Surveillance Medical surveillance must be made available at no cost to the employee, and at a reasonable time and place, for all employees: Who are or may be occupationally exposed to chromium (VI) at or above the action level for 30 or more days a year; Experiencing signs or symptoms associated with chromium (VI) exposure; or Exposed in an emergency. 115

116 Medical Surveillance Medical examination provided: Within 30 days after initial assignment, a Physician or other Licensed Health Care Professional s (PLHCP's) written recommendation, or exposure during an emergency; Annually. 116

117 Medical Surveillance Medical examination provided: Whenever there are signs or symptoms of the adverse health effects; At the termination of employment, unless the last examination that satisfied the requirements of paragraph (i) of this section was less than six months prior to the date of termination. 117

118 Medical Surveillance Medical examination provided: Whenever there are signs or symptoms of the adverse health effects; At the termination of employment, unless the last examination that satisfied the requirements of paragraph (i) of this section was less than six months prior to the date of termination. 118

119 Medical Surveillance A medical examination consists of: A medical and work history; A physical examination of the skin and respiratory tract. The employer shall obtain a written medical opinion from the PLHCP within 30 days. 119

120 Information to PLHCP 1. Copy of standard 2. Description of employee s duties of exposure 3. Employee s former, current and anticipated levels of exposure 4. PPE used and duration of use 5. Information from records of employment related medical examinations 120

121 PLHCP s Written Medical Opinion A medical examination consists of: A medical and work history; A physical examination of the skin and respiratory tract. The employer shall obtain a written medical opinion from the PLHCP within 30 days. 121

122 Records Medical and Air Monitoring Records You have the right to see any of your medical records related to Cr(VI). You also have the right to see results of any air sampling we have done, or other exposure data we have used. 122

123 Respirator Use and Care 123

124 Use of Respirators Respirators with tight fitting facepieces cannot be worn by employees who have: Facial hair that comes between the sealing surface of the facepiece and the face or that interferes with valve function; or Any condition that interferes with the face-to-facepiece seal or valve function CFR (g)

125 Use of Respirators If an employee wears corrective glasses or goggles or other personal protective equipment, such equipment must be worn in a manner that does not interfere with the seal of the facepiece to the face of the user. For all tight fitting respirators, a user seal check must be preformed each time they put on the respirator CFR (g)

126 User Seal Check Positive pressure check. Close off the exhalation valve and exhale gently into the facepiece. The face fit is considered satisfactory if a slight positive pressure can be built up inside the facepiece without any evidence of outward leakage of air at the seal. For most respirators this method of leak testing requires the wearer to first remove the exhalation valve cover before closing off the exhalation valve and then carefully replacing it after the test. 126

127 User Seal Check Negative pressure check. Close off the inlet opening of the canister or cartridge's) by covering with the palm of the hand or by replacing the filter seal, inhale gently so that the facepiece collapses slightly, and hold the breath for ten seconds. The design of the inlet opening of some cartridges cannot be effectively covered with the palm of the hand. The test can be performed by covering the inlet opening of the cartridge with a thin latex or nitrile glove. If the facepiece remains in its slightly collapsed condition and no inward leakage of air is detected, the tightness of the respirator is considered satisfactory. 127

128 User Seal Check Manufacturer's recommended user seal check procedures The respirator manufacturer's recommended procedures for performing a user seal check may be used instead of the positive and/or negative pressure check procedures provided that the employer demonstrates that the manufacturer's procedures are equally effective. 128

129 Use of Respirators Employees will be allowed to leave the respirator use area: To wash their faces and respirator facepieces as necessary to prevent eye or skin irritation associated with respirator use; or If they detect vapor or gas breakthrough, changes in breathing resistance, or leakage of the facepiece; or To replace the respirator or the filter, cartridge, or canister elements. 129

130 Use of Respirators If the employee detects vapor or gas breakthrough, changes in breathing resistance, or leakage of the facepiece, the respirator must be replaced or repaired before the employee will be allowed to return to the work area. 130

131 Use of Respirators For all IDLH atmospheres, the following procedures must be followed: At least one employee must be located outside the IDLH atmosphere; Visual, voice, or signal line communication must be maintained between the employee(s) in the IDLH atmosphere and the employee(s) located outside the IDLH atmosphere; The employee(s) located outside the IDLH atmosphere must be trained and equipped to provide effective emergency rescue; 131

132 Use of Respirators For all IDLH atmospheres, the following procedures must be followed: The direct supervisor or designee must be notified before the employee(s) located outside the IDLH atmosphere enter the IDLH atmosphere to provide emergency rescue; Employee(s) located outside the IDLH atmospheres must be equipped with: Respiratory protection Appropriate retrieval equipment. Equivalent means for rescue where retrieval equipment is not required. 132

133 Maintenance and Care of Respirators All respirator users will be provided with a respirator that is clean, sanitary, and in good working order. The respirators shall be cleaned and disinfected at the following intervals: Assigned respirators Cleaned and disinfected as often as necessary to be maintained in a sanitary condition; Multi user respirators Cleaned and disinfected before being worn by different individuals; Respirators maintained for emergency use shall be cleaned and disinfected after each use; and 133

134 Maintenance and Care of Respirators Respirators must be stored to protect them from damage, contamination, dust, sunlight, extreme temperatures, excessive moisture, and damaging chemicals, and they shall be packed or stored to prevent deformation of the facepiece and exhalation valve. Emergency respirators shall be: Kept accessible to the work area; Clearly marked; and Stored according to manufacturer instructions. 134

135 Maintenance and Care of Respirators Respirators must be inspected as follows: All respirators used in routine situations shall be inspected before each use and during cleaning; All respirators maintained for use in emergency situations shall be inspected at least monthly and in accordance with the manufacturer's recommendations, and shall be checked for proper function before and after each use; and Emergency escape-only respirators shall be inspected before being carried into the workplace for use. 135

136 Maintenance and Care of Respirators Respirator inspections must include the following: A check of respirator function, tightness of connections, and the condition of the various parts; and A check of elastomeric parts for pliability and signs of deterioration; All self-contained breathing apparatus shall be inspected monthly.; All regulators and warning devices must function properly. 136

137 Maintenance and Care of Respirators For respirators maintained for emergency use, the following must be completed: Certify the respirator by documenting the date the inspection was performed, the name (or signature) of the person who made the inspection, the findings, required remedial action, and a serial number or other means of identifying the inspected respirator; and Provide this information on a tag or label that is attached to the storage compartment for the respirator, is kept with the respirator, or is included in inspection reports stored as paper or electronic files. 137

138 Maintenance and Care of Respirators Any respirator that fails an inspection or is otherwise found to be defective must be removed from service, and discarded or repaired or adjusted in accordance with the following procedures: Repairs or adjustments to respirators are to be made only by trained and authorized persons; Repairs shall be made according to the manufacturer's recommendations and specifications; and Reducing and admission valves, regulators, and alarms shall be adjusted or repaired only by the manufacturer or a technician trained by the manufacturer. 138

139 Breathing Air Quality and Use All compressed air, compressed oxygen, liquid air, and liquid oxygen used for respiration must meet the following specifications: Compressed and liquid oxygen shall be medical or breathing oxygen; and Compressed breathing air shall meet at least the requirements for Type 1-Grade D breathing. Oxygen concentrations greater than 23.5% must be used only in equipment designed for oxygen service or distribution. 139

140 Breathing Air Quality and Use Cylinders used to supply breathing air to respirators must meet the following requirements: Cylinders are tested and maintained as prescribed in the Shipping Container Specification Regulations of the Department of Transportation; Cylinders of purchased breathing air have a certificate of analysis from the supplier that the breathing air meets the requirements for Type 1--Grade D breathing air; and The moisture content in the cylinder does not exceed a dew point of F ( C) at 1 atmosphere pressure. 140

141 Breathing Air Quality and Use Compressors used to supply breathing air to respirators must be constructed and situated so as to: Prevent entry of contaminated air into the air supply system; Minimize moisture content so that the dew point at 1 atmosphere pressure is 10oF (5.56o C) below the ambient temperature; Have suitable in-line air purifying sorbent beds and filters to further ensure breathing air quality. Have a tag containing the most recent change date and the signature of the person authorized by the employer to perform the change. The tag shall be maintained at the compressor. 141

142 Breathing Air Quality and Use Compressors used to supply breathing air to respirators must be constructed and situated so as to: For compressors that are not oil lubricated, carbon monoxide levels in the breathing air can not exceed 10 ppm. For oil lubricated compressors, a high temperature or carbon monoxide alarm, or both must be used to monitor carbon monoxide levels. All breathing air couplings must be incompatible with outlets for nonrespirable worksite air or other gas systems. All breathing gas containers must be marked in accordance with the NIOSH respirator certification standard. 142

143 Identification of Filters, Cartridges, and Canisters All filters, cartridges and canisters used in the workplace must be and remain labeled and color coded with the NIOSH approval label. 143

144 Training and Information 144

145 Training and Information Employees required to use a respirator must receive comprehensive, understandable, and annual training prior to using a respirator in the work place. 145

146 Training and Information Training must cover at least the following: Why the respirator is necessary and the dangers of improper fit, usage, or maintenance; What the limitations and capabilities of the respirator are; How to use the respirator effectively in emergency situations; How to inspect, put on and remove, use, and check the seals of the respirator; What the procedures are for maintenance and storage of the respirator; How to recognize medical signs and symptoms that may limit the effective use of respirators; and The general requirements of this section. 146

147 Training and Information Retraining shall be administered annually, and when the following situations occur: Changes in the workplace or the type of respirator render previous training obsolete; Inadequacies in the employee's knowledge or use of the respirator indicate that the employee has not retained the requisite understanding or skill; or Any other situation arises in which retraining appears necessary to ensure safe respirator use. 147

148 Program Evaluation 148

149 Program Evaluation Evaluations will be conducted of the workplace as necessary to ensure that the provisions of the current written program are being effectively implemented and that it continues to be effective. 149

150 Recordkeeping Records of medical evaluations required by this program must be retained and made available in accordance with 29 CFR Part

151 Recordkeeping A record will be established of the qualitative and quantitative fit tests administered to an employee including: The name or identification of the employee tested; Type of fit test performed; Specific make, model, style, and size of respirator tested; Date of test; and The pass/fail results for QLFTs or the fit factor and strip chart recording or other recording of the test results for QNFTs. Fit test records shall be retained for respirator users until the next fit test is administered. 151

152 PPE - Protective Work Clothing and Equipment Where a hazard is present or is likely to be present from skin or eye contact with chromium (VI); Provide appropriate personal protective clothing and equipment at no cost to employees, and Ensure that employees use such clothing and equipment. 152

153 PPE - Removal and Storage All protective clothing and equipment contaminated with chromium (VI) must be: Removed at the end of the work shift or at the completion of their tasks, whichever comes first; Stored and transported in sealed, properly labeled, impermeable bags or other closed, impermeable containers. 153

154 PPE - Removal and Storage No employees may remove chromium (VI)- contaminated protective clothing or equipment from the workplace, except for those employees whose job it is to launder, clean, maintain, or dispose of such clothing or equipment. 154

155 PPE - Cleaning and Replacement All protective clothing and equipment required by this section shall be cleaned, laundered, repaired and replaced as needed to maintain its effectiveness. The removal of chromium (VI) from protective clothing and equipment by blowing, shaking, or any other means that disperses chromium (VI) into the air or onto an employee's body is prohibited. 155

156 PPE - Hygiene Areas and Practices Where protective clothing and equipment is required, the employer shall provide change rooms. Separate storage for contaminated and clean clothes Where skin contact with chromium (VI) occurs, the employer shall provide washing facilities: Such facilities shall be in near proximity to the worksite and shall be so equipped as to enable employees to remove such substances. MUST BE WATER BASED CLEANING SYSTEM. Washing facilities shall be maintained in a sanitary condition. Use of these facilities when necessary shall be enforced. 156

157 PPE - Eating and Drinking Areas Eating and drinking areas and surfaces must be maintained as free as practicable of chromium (VI). Employees must not enter eating and drinking areas with protective work clothing or equipment unless surface chromium (VI) has been removed. Employees must not eat, drink, smoke, chew tobacco or gum, or apply cosmetics in areas where skin or eye contact with chromium (VI) occurs; or Carry the products associated with these activities, or store such products in these areas. 157

158 Recordkeeping Record to include at least the following information: The date of measurement; The operation involved; Sampling and analytical methods used and evidence of their accuracy; Number, duration, and the results of samples taken; Type of personal protective equipment used; and Name, social security number, and job classification of all employees represented by the monitoring, indicating which employees were actually monitored. Each employee exposure record shall be preserved and maintained for at least thirty (30) years. 158

159 Dates For employers with 20 or more employees, all obligations of this section, except engineering controls required by paragraph (e) of this section, commence November 27, For employers with 19 or fewer employees, all obligations of this section, except engineering controls required by paragraph (e) of this section, commence May 30, For all employers, engineering controls required by paragraph (e) of this section shall be implemented no later than May 31,

160 General Industry Changes 160

161 General Industry - Regulated Areas The employer shall establish a regulated area wherever an employee s exposure to airborne concentrations of chromium (VI) is, or can reasonably be expected to be, in excess of the PEL. The employer shall ensure that regulated areas are demarcated from the rest of the workplace in a manner that adequately establishes and alerts employees of the boundaries of the regulated area. 161

162 General Industry - Regulated Areas The employer shall limit access to regulated areas to: Persons authorized by the employer and required by work duties to be present in the regulated area; Any person entering such an area as a designated representative of employees for the purpose of exercising the right to observe monitoring procedures under paragraph (d) of this section; or Any person authorized by the Occupational Safety and Health Act or regulations issued under it to be in a regulated area. 162

163 General Industry - Housekeeping The employer shall ensure that: All surfaces are maintained as free as practicable of accumulations of chromium (VI). All spills and releases of chromium (VI) containing material are cleaned up promptly. The employer shall ensure that surfaces contaminated with chromium (VI) are cleaned by HEPA-filter vacuuming or other methods that minimize the likelihood of exposure to chromium (VI). Dry shoveling, dry sweeping, and dry brushing may be used only where HEPA-filtered vacuuming or other methods that minimize the likelihood of exposure to chromium (VI) have been tried and found not to be effective. 163

164 General Industry - Housekeeping The employer shall not allow compressed air to be used to remove chromium (VI) from any surface unless: The compressed air is used in conjunction with a ventilation system designed to capture the dust cloud created by the compressed air; or No alternative method is feasible. The employer shall ensure that cleaning equipment is handled in a manner that minimizes the reentry of chromium (VI) into the workplace. 164

165 General Industry - Housekeeping The employer shall 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. Bags or containers of waste, scrap, debris, and any other materials contaminated with chromium (VI) that are consigned for disposal are labeled in accordance with the requirements of the Hazard Communication Standard, 29 CFR Part

166 Questions 166

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