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Coalition asks OSHA for guidance on regulations E-mail
Tuesday, 01 August 2006

The Automotive Service Association (ASA) has signed a coalition letter to the Occupational Safety and Health Administration (OSHA) requesting compliance guidance with respect to air monitoring and hexavalent chromium Cr(VI) exposure. 

The letter was sent to Edwin G. Foulke Jr., assistant secretary of labor from a coalition consisting of the American Bakers Association. National Automobile Dealers Association, Sheet Metal and Air Conditioning Contractors National Association, The Steel Tank Institute/Steel Plate Fabricators Association along with ASA. 

The guidance request is specific to welding procedure associated with employee exposure to Cr(VI). According to rules 29 CFR 1910.1026(d)(3) and 29 CFR 1926.1126(d)(3), the use of "objective data" is sufficient to recognize whether employees are exposed to Cr(VI).

Objective data is defined in the standard as: "information such as air monitoring data from industry-wide surveys or calculations based on the composition or chemical and physical properties of a substance demonstrating the employee exposure to chromium (VI) associated with a particular product or material or a specific process, operation or activity. The data must reflect workplace conditions closely resembling the processes, types of material, control methods, work practices and environmental conditions in the employer's current operations." [29 CFR 1910.1026(b) and 29 CFR 1926.1126(b)].

The coalition developed an air monitoring protocol to consistently collect objective data specific for air monitoring, taking advantage of the objective data option to fulfill the November 2006 compliance deadline. The coalition is asking that OSHA comply with this request prior to the November 2006 deadline.

ASA is pursuing another meeting with OSHA to discuss the hexavalent chromium regulation and how it relates to painting vehicles in body shops.

 

Protocol for Obtaining Objective Information that Demonstrates Expected Employee Exposure to Chromium (VI) in Welding Operations
 

29 CFR 1910.1026(d)(3) and 29 CFR 1926.1126(d)(3)

General Requirements

• Air sampling is to be conducted in accordance with Sampling Method ID-215 or

other approved analytical method.

• Air sampling is to be conducted in accordance with generally accepted industrial

hygiene practices

Air sampling shall consider the following:

• Variables affecting the concentration of Cr(VI) generated in welding fumes:

    1. Primary type of welding process performed.

        a. Flux-core arc welding (FCAW)

        b. Shielded metal arc welding (SMAW)

        c. Plasma arc welding (PAW)

        d. Arc gouging

        e. Gas metal arc welding (GMAW)

        f. Gas tungsten arc welding (GTAW)

        g. Submerged arc welding (SAW)

    2. Concentration (in percent by weight) of materials.

        a. American Welding Society (AWS) electrode/wire classification and reported ingredients

        (percentage chromium by weight) in consumable

        b. Reported ingredients (percentage chromium by weight) in base metal

    3. Presence of chromate coatings on base metal.

        a. Provide type of coating (e.g., zinc chromate, lead chromate, strontium chromate, etc.).

        b. Provide the concentrations (i.e., mg/kg) of the chromates in the coating, if known.

    4. Description of ancillary/secondary operations performed that may contribute to the amount

        of Cr(VI) in the welding fume (e.g., torch cutting, intermittentoperations, etc.).

    5. Thickness of the base metal (i.e., 18 ga., 10 ga., thickness of steel plate, etc.).

• Environmental conditions that impact average airborne concentration of

welding fume samples:

    1. Ratio of estimated time spent welding to actual sample time.

        a. Estimated time spent welding (i.e., 120 minutes, 210 minutes, 45 minutes, etc.)

        b. Sample duration (in minutes)

    2. Relative position of the welder's breathing zone to the welding point of operation.

        a. Proximity

        b. Orientation of welding position

        c. Description of item(s) being welded (size and configuration)

    3. Description of point of operation ventilation (i.e., local exhaust ventilation).

        a. Provide type and size of exhaust hood and face velocity and/or capture velocity,

            if readily known.

    4. Location of personal air sample (i.e., inside or outside the welding helmet).

    5. Size (i.e., volume) of welding room, booth, space, etc. where welding operation is performed.

    6. Description of general and natural ventilation (may include the number of room air changes,

        if readily known).

    7. Description of adjacent welding/burning activities performed in the same room/space.

Recordkeeping

• The employer shall maintain an accurate record of all objective data relied upon, as

required in 29 CFR 1910.1026(m) or 29 CFR 1926.1126(m)

 
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