Document owner and change code Document Owner Aaron Perronne Title HSSE Manager Mark X Change Code Description X N/A First Issue A Typographical/Grammatical correction; formatting change; text clarification-no action required B Change requiring minor adjustment to process and/or records; users to be informed-no retraining required C Major change to the process and/or records; retraining of involved personnel to be conducted Table of Contents Document Owner and Change Code...1 1. Objective..2 2. Definition....2 3. Hazard Identification..3 4. Hazard Controls.. 3 5. Respiratory Protection.. 5 6. Exposure Levels.. 6 7. Exposure Determination. 7 8. Medical Surveillance....8 9. Training..... 9 10. Recordkeeping.....9 Page 1 of 9
1 OBJECTIVE Mechanical Systems, Inc. s primary goal is to provide a safe and healthy workplace for all employees. The purpose of this program is to reduce and/or eliminate workplace exposure and subsequent employee health effects to hexavalent chromium through welding activities and to comply with OSHA s 29 CFR 1926.1126 standard. Mechanical Systems, Inc. has established this program to ensure potential hexavalent chromium hazards are identified, evaluated and controlled according to 29 CFR 1926.1126. The program will be implemented by: Training employees regarding specific hazards associated with their work environment, including the content of any hexavalent chromium standard compliance plan in effect, the danger of hexavalent chromium to their bodies, exposure prevention techniques, and their rights under the standard. Performing air quality monitoring on welding activities that will reflect workplace conditions that closely resemble the process, types of material, control methods, work practices, and environmental conditions in Mechanical Systems, Inc. s current operations. Performing additional monitoring if there are any changes in the production process, raw materials, equipment, work practices, or control methods that may result in new or additional exposures. A copy of this program and applicable standards will be made readily available without cost to all affected employees. 2 DEFINITIONS Action Level Means a concentration of airborne chromium (VI) of 2.5 micrograms per cubic meter of air (2.5ug/m3) calculated as an 8-hour time weighted average (TWA). Chromium (VI) [hexavalent chromium or Cr(VI)] - Chromium with a valence of positive six, in any form and in any compound. Permissible Exposure Limit The employer shall ensure that no employee is exposed to an airborne concentration of chromium (VI) in excess of 5 micrograms per cubic meter (5.0ug/m3), calculated as an 8 hregulated 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. Page 2 of 9
Demarcation 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. 3 HAZARD IDENTIFICATION The primary exposure to hexavalent chromium for Mechanical Systems, Inc. employees occurs when welding on metals containing chromium, particularly stainless steel or other high chromium steels. Characteristics CR (VI) is a metal particle that can occur naturally in rocks but is most commonly produced by industrial processes. It has the ability to gain electrons from other elements (a strong oxidizer) which means it can react easily with other elements. Because of its ability to react with other elements, it can produce hard coatings. The most common sources of occupational exposure in the mechanical industry are the welding of metals containing chromium, particularly stainless steel or other high chromium steels. The primary industries affected, according to OSHA, are stainless steel fabrication, heavy-duty coatings and paints, electroplating and producers of chrome based pigments. Health Effects Calcium chromate, chromium trioxide, lead chromate, strontium chromate, and zinc chromate are known human carcinogens. An increase in incidents of lung cancer has been observed among workers in industries that produce chromate and manufacture pigments containing chromate. An increased rate of lung cancer has also been reported among producers and consumers of pigment containing chromate. One study of chromium-nickel alloy foundry workers showed a statistically significant increase in lung cancers. For industrial exposure, inhalation and skin contact are the primary routes of exposure. Overexposure from inhalation can cause nasal damage, asthma and lung cancer. Skin contact can cause irritations such as ulcers and contact dermatitis. 4 HAZARD CONTROLS Engineering controls and safe work practices are important techniques to utilize during the welding process to reduce workplace exposure. Mechanical Systems, Inc. will ensure that no employee is exposed to an airborne concentration of chromium (VI) in excess of 5 micrograms per cubic meter of air (5 μg/m3), calculated as an 8-hour time-weighted average (TWA). Engineering and work practice controls will be provided to reduce exposure to the lowest feasible level. If employees can demonstrate Page 3 of 9
that such controls are not feasible, we will use engineering/work controls to reduce employee exposure to the lowest levels achievable, and shall supplement them by the use of respiratory protection. The following standard practices must be followed: Employees must keep their head out of the plume at all times. Where a hazard is present or is likely to be present from skin or eye contact with chromium (VI), appropriate personal protective clothing and equipment will be provided at no cost to employees. Employees should use the ventilation that is available (elephant trunks, box fans, HEPA Vacs, etc.). Surfaces shall be maintained as free as practicable of accumulation of chromium. All spills and releases of chromium shall be cleaned promptly. Methods of cleaning include HEPA filtered vacuums, dry or wet sweeping, shoveling or other methods to minimize exposure. When putting up box fans, employees should take the time to put them up on the down-wind side of the shack facing out, with a hole on the up wind side to provide proper cross ventilation. No eating, drinking, smoking, chewing tobacco or gum in areas where skin or eye contact with chromium (VI) occurs. Washing facilities shall be readily accessible for removing chromium from the skin. Employees must remove all protective clothing and equipment contaminated with chromium (VI) at the end of the work shift or at the completion of their tasks involving chromium (VI) exposure, whichever comes first. No employee should 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. When contaminated protective clothing or equipment is removed for laundering, cleaning, maintenance, or disposal, it must be stored and transported in sealed, impermeable bags or other closed, impermeable containers. Bags or containers of contaminated protective clothing or equipment that are removed from change rooms for laundering, cleaning, maintenance, or disposal must be labeled in accordance with the requirements of the Hazard Communication Standard, 29 CFR 1910.1200. Mechanical Systems, Inc. will clean, launder, repair and replace all protective clothing and equipment required by this section 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. Mechanical Systems, Inc. will inform any person who launders or cleans protective clothing or equipment contaminated with chromium (VI) of the potentially harmful effects of exposure to Page 4 of 9
chromium (VI) and that the clothing and equipment should be laundered or cleaned in a manner that minimizes skin or eye contact with chromium (VI) and effectively prevents the release of airborne chromium (VI) in excess of the PEL. Where protective clothing and equipment is required, change rooms will be provided in conformance with 29 CFR 1926.51 Where skin contact with chromium (VI) occurs, washing facilities will be provided in conformance with 29 CFR 1926.51. Eating and drinking areas will also be in conformance with 29 CFR 1926.51 Change rooms must be equipped with separate storage facilities for protective clothing and equipment and for street clothes. Readily accessible washing facilities capable of removing chromium (VI) from the skin will be provided, and affected employees should use these facilities when necessary. Employees who have skin contact with chromium (VI) must wash their hands and faces at the end of the work shift and prior to eating, drinking, smoking, chewing tobacco or gum, applying cosmetics, or using the toilet. Employees are not allowed to enter eating and drinking areas with protective work clothing or equipment unless surface chromium (VI) has been removed from the clothing and equipment by methods that do not disperse chromium (VI) into the air or onto an employee's body. Regulated areas will be established when an employee's exposure is or is expected to be in excess of the PEL. Regulated areas will be marked with warning signs to alert employees. Access is restricted to "authorized persons". 5 RESPIRATORY PROTECTION Where exposure levels deem respiratory protection necessary, Mechanical Systems, Inc. will provide each employee an appropriate respirator. Respiratory protection is required during: Periods necessary to install or implement feasible engineering and work practice controls; Work operations, such as maintenance and repair activities, for which engineering and work practice controls are not feasible; Work operations for which an employer has implemented all feasible engineering and work practice controls and such controls are not sufficient to reduce exposures to or below the PEL; Work operations where employees are exposed above the PEL for fewer than 30 days per year, and the employer has elected not to implement engineering and work practice controls to achieve the PEL; or Emergencies. Page 5 of 9
Mechanical Systems, Inc. s Respiratory Protection Program, which is in accordance with OSHA 29 CFR 1910.134, must be followed for any employee required to use a respirator. 6 EXPOSURE LEVELS When welding on any types of alloy, Mechanical Systems, Inc. classifies the potential exposure and prevention techniques into the following four exposure levels. Regardless of the level that the welds fall under, there are standard practices that must be adhered to by all welders involved with any alloy welding. Exposure Level 1 (0-2.49) Below Action Level Follow standard practices No additional PPE required Natural or mechanical ventilation may be required depending upon historical Exposure Level 2 (2.5-4.9) Below Permissible Exposure Limit (PEL) Follow standard practices Half mask required (3M 8212, 6200 Series, 7500 Series or any additional approved half masks). Natural or mechanical ventilation may be required depending upon historical monitoring data. See Mechanical Systems, Inc. s Air Sampling Table for more direction. Exposure Level 3 (5.0-50.0) Above PEL Follow standard practices. Half mask required (3M 8212, 6200 Series, 7500 Series or any other half masks that have been pre-approved). Additional layer of protective clothing required. This clothing is to be removed at the end of the shift or when employee is finished working on chromium (VI). At no times is this clothing to be worn inside a break trailer or removed from the jobsite. When discarding this clothing, it must be stored and transported in sealed impermeable bags, with proper identification on the bag. Also, there will need to be an area where employees exposed to chromium (VI), will be able to change their clothes. This will be called the change room, and these must have separate areas for protective clothing and street clothing, to avoid cross-contamination. Page 6 of 9
Exposure Level 4 (Over 50.0) Extreme Areas Follow standard practices and Level 3 practices with the following additions: Half masks with supplied air required (this gives us protection up to 50 times the PEL). 7 EXPOSURE DETERMINATION Periodic monitoring shall be conducted at least every 6 months if initial monitoring shows employee exposure. Air monitoring will be performed at the beginning of each job task. If exposure monitoring results indicate exposure is above the PEL, a written notification must be included with the corrective action being taken to reduce exposure to or below the PEL. Mechanical Systems, Inc. will perform additional monitoring if there is any change in the production process, raw materials, equipment, work practices or control methods that may result in new or additional exposures. Observation of Monitoring Where additional air monitoring is performed to comply with the requirements of this program, Mechanical Systems, Inc. will provide affected employees or their designated representatives an opportunity to observe any monitoring of employee exposure to chromium (VI). When observation of monitoring requires entry into an area where the use of protective clothing or equipment is required, the observer will be provided with clothing and equipment. Mechanical Systems, Inc. will assure that the observer uses such clothing and equipment and complies with all other applicable safety and health procedures. Employee Notification Within 5 work days after making an exposure determination, Mechanical Systems, Inc. will individually notify each affected employee in writing of the results of that determination or post the results in an appropriate location accessible to all affected employees. Whenever the exposure determination indicates that employee exposure is above the PEL, Mechanical Systems, Inc. will describe in the written notification the corrective action being taken to reduce employee exposure to or below the PEL. Page 7 of 9
8 MEDICAL SURVEILLANCE Medical surveillance will be made available at no cost to the employee and at a reasonable time and place by Mechanical Systems, Inc. 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 of the adverse health effects associated with chromium (VI) exposure; or Exposed in an emergency. All medical examinations and procedures will be performed by or under the supervision of a physician or other licensed health care professional (PLHCP). Medical examinations will be provided: Whenever an employee shows signs or symptoms of the adverse health effects associated with chromium (VI) exposure Within 30 days after exposure during an emergency which results in an uncontrolled release of chromium (VI) A medical examination consists of: A medical and work history, with emphasis on: past, present, and anticipated future exposure to chromium (VI); any history of respiratory system dysfunction; any history of asthma, dermatitis, skin ulceration, or nasal septum perforation; and smoking status and history; A physical examination of the skin and respiratory tract; and Any additional tests deemed appropriate by the examining PLHCP. The examining PLHCP will be given a copy of this standard, and shall provide the following information: A description of the affected employee's former, current, and anticipated duties as they relate to the employee's occupational exposure to chromium (VI); The employee's former, current, and anticipated levels of occupational exposure to chromium (VI); A description of any personal protective equipment used or to be used by the employee, including when and for how long the employee has used that equipment; and Information from records of employment-related medical examinations previously provided to the affected employee, currently within the control of the employer. Page 8 of 9
Mechanical Systems, Inc. will obtain a written medical opinion from the PLHCP, within 30 days for each medical examination performed on each employee, which contains: The PLHCP's opinion as to whether the employee has any detected medical condition(s) that would place the employee at increased risk of material impairment to health from further exposure to chromium (VI); Any recommended limitations upon the employee's exposure to chromium (VI) or upon the use of personal protective equipment such as respirators; A statement that the PLHCP has explained to the employee the results of the medical examination, including any medical conditions related to chromium (VI) exposure that require further evaluation or treatment, and any special provisions for use of protective clothing or equipment. The PLHCP should not reveal to the employer specific findings or diagnoses unrelated to occupational exposure to chromium (VI). A copy of the PLHCP's written medical opinion will be provided to the examined employee within two weeks after receiving it. 9 TRAINING Mechanical Systems, Inc. will inform the employees about hazards according to the requirements of OSHA s Hazard Communication Standard 29 CFR 1910.1200 and the Standard for the construction industry, 29 CFR 1926.1126. Training will include the following: Content of hexavalent chromium standard Characteristics of hexavalent chromium Health hazards of hexavalent chromium Jobs where employees may be exposed Exposure prevention techniques Historical data and survey Purpose and description of medical surveillance program Each employee will be trained on their initial hire date. On an annual basis throughout their employment there will be refresher training. 10 RECORDKEEPING Mechanical Systems, Inc. will maintain records according to the requirements of 29 CFR 1926.1126(k)(1). Records will include employee exposure monitoring, medical surveillance and training records. Page 9 of 9