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OSHA 1915.1026

Chromium (VI) scope and definitions

Subpart Z

47 Questions & Answers
10 Interpretations

Questions & Answers

Under 1915.1026(a)(1), what workplaces and operations does the Chromium (VI) standard cover?

The Chromium (VI) standard covers occupational exposures to chromium (VI) in all forms and compounds in shipyards, marine terminals, and longshoring. See Scope in 1915.1026(a). Employers must treat operations in those industries as covered unless a specific exclusion applies under the standard.

Under 1915.1026(a)(2), are pesticide applications that use chromium substances covered by this standard?

No — exposures that occur during the application of pesticides regulated by the EPA or another federal agency are excluded from this Chromium (VI) standard. The standard explicitly excludes such pesticide applications in 1915.1026(a)(2).

Under 1915.1026(a)(3), does the Chromium (VI) standard apply to exposures from portland cement?

No — exposures to portland cement are specifically excluded from this Chromium (VI) standard. The exclusion for portland cement is stated in 1915.1026(a)(3).

Under 1915.1026(a)(4), when can an employer rely on objective data to exclude a material or process from coverage?

An employer can use objective data to show a material or process cannot release chromium (VI) at or above 0.5 µg/m3 (8-hour TWA) under expected conditions and thereby exclude it from the standard. The conditions and allowance for objective data are in 1915.1026(a)(4).

Under 1915.1026(b), what is the action level and how is it expressed?

The action level is 2.5 micrograms of chromium (VI) per cubic meter of air (2.5 µg/m3), calculated as an 8-hour time-weighted average (TWA). See the definition of Action level in 1915.1026(b).

Under 1915.1026(b), how does OSHA define 'chromium (VI)' for compliance purposes?

OSHA defines chromium (VI) as chromium with a valence of positive six, in any form and in any compound. That exact definition appears in 1915.1026(b).

Under 1915.1026(c), what is the Permissible Exposure Limit (PEL) for chromium (VI)?

The PEL for chromium (VI) is 5 micrograms per cubic meter of air (5 µg/m3), calculated as an 8-hour time-weighted average (TWA). See Permissible exposure limit (PEL) in 1915.1026(c).

Under 1915.1026(d)(1) and (d)(2), when must an employer perform initial monitoring for chromium (VI)?

An employer must perform initial monitoring to determine the 8-hour TWA for each employee exposed to chromium (VI) using enough personal breathing zone samples to characterize full shift exposure on each shift, for each job classification, in each work area. The requirement to perform initial monitoring and the sampling expectations are in 1915.1026(d)(1) and 1915.1026(d)(2)(i).

Under 1915.1026(d)(2)(i), may employers use representative sampling instead of sampling every employee?

Yes — employers may perform representative sampling instead of sampling every employee, but when they do they must sample the employee(s) expected to have the highest chromium (VI) exposures. This representative-sampling allowance is described in 1915.1026(d)(2)(i).

Under 1915.1026(d)(2)(iii)-(iv), how often must periodic monitoring be done when exposures are at or above the action level or above the PEL?

If initial monitoring shows exposures at or above the action level, the employer must perform periodic monitoring at least every six months; if exposures are above the PEL, periodic monitoring must be at least every three months. These monitoring frequencies are specified in 1915.1026(d)(2)(iii) and 1915.1026(d)(2)(iv).

Under 1915.1026(d)(2)(v), when can an employer discontinue periodic monitoring?

An employer may discontinue monitoring for employees when periodic monitoring indicates exposures are below the action level and the result is confirmed by another monitoring taken at least seven days later. The discontinuation condition is in 1915.1026(d)(2)(v).

Under 1915.1026(d)(2)(vi), when must an employer perform additional monitoring?

An employer must perform additional monitoring whenever there is a change in production processes, raw materials, equipment, personnel, work practices, or controls that may create new or additional chromium (VI) exposures or whenever they have reason to believe new exposures have occurred. This requirement is in 1915.1026(d)(2)(vi).

Under 1915.1026(d)(3), what data sources can an employer use under the performance-oriented option to determine employee exposure?

Under the performance-oriented option, an employer may use any combination of current air monitoring data, historical monitoring data (pre-May 30, 2006), or objective data sufficient to accurately characterize employee exposures to chromium (VI). This flexibility is described in 1915.1026(d)(3).

Under 1915.1026(d)(4)(i)-(ii), how and when must employees be notified of exposure determination results?

Employers must notify each affected employee in writing or post the results in an accessible location within 5 work days after making an exposure determination; if exposures are above the PEL, the notice must describe corrective actions being taken to reduce exposures. See the notification requirements in 1915.1026(d)(4)(i) and 1915.1026(d)(4)(ii).

Under 1915.1026(d)(5), what accuracy and confidence must monitoring methods achieve?

Air monitoring methods must be able to measure chromium (VI) within ±25% accuracy and produce measurements with 95% statistical confidence for concentrations at or above the action level. Those precision and confidence requirements are in 1915.1026(d)(5).

Under 1915.1026(d)(6)(i)-(ii), what rights do employees or their representatives have when monitoring is performed?

Employees and their designated representatives have the right to observe any monitoring of employee exposure to chromium (VI), and if observation requires entry into areas needing protective clothing, the employer must provide that clothing and ensure it is used. These observation rights are set out in 1915.1026(d)(6)(i) and the protective-equipment provision in 1915.1026(d)(6)(ii).

Under 1915.1026(e)(1)(i)-(ii), when are engineering and work-practice controls required and when may they be waived?

Employers must use engineering and work-practice controls to reduce chromium (VI) exposures to or below the PEL wherever feasible; the requirement to implement such controls does not apply to a process or task that the employer demonstrates will not result in employee exposure above the PEL for 30 or more days per year. The general control mandate and the 30-day allowance are in 1915.1026(e)(1)(i) and 1915.1026(e)(1)(ii).

Under 1915.1026(e)(2), can employers rotate employees among jobs to comply with the PEL?

No — the standard specifically prohibits rotating employees to different jobs as a means to achieve compliance with the PEL. See the prohibition in 1915.1026(e)(2).

Under 1915.1026(f)(1), in which situations is respiratory protection required for chromium (VI)?

Respiratory protection is required during periods necessary to install engineering controls, for maintenance or repair where controls are not feasible, when controls cannot reduce exposures to the PEL, for tasks where exposures are above the PEL fewer than 30 days per year if the employer elects not to implement controls, and during emergencies. These circumstances are listed in 1915.1026(f)(1)(i)-(v).

Under 1915.1026(f)(2), what respiratory program must employers use when respirators are required?

When respirator use is required by this section, employers must institute a respiratory protection program in accordance with 29 CFR 1910.134 covering each employee required to use a respirator. The program requirement is in 1915.1026(f)(2) and the referenced respirator standard is 1910.134.

Under 1915.1026(g)(1)-(3), what PPE must employers provide and what laundering and removal rules apply for chromium (VI) contaminated clothing?

Employers must provide appropriate protective clothing and equipment at no cost where skin or eye contact hazards from chromium (VI) are present or likely, ensure contaminated clothing is removed at shift end or task completion, prohibit employees from removing contaminated protective clothing from the workplace (except designated laundry staff), and ensure contaminated items removed for laundering are stored in sealed impermeable bags and labeled per the Hazard Communication Standard. These requirements are in 1915.1026(g)(1), 1915.1026(g)(2)(i)-(iii), 1915.1026(g)(3)(i)-(iii), and the label requirement referencing the Hazard Communication Standard 1910.1200.

Under 1915.1026(g)(3)(ii), are employers allowed to remove chromium (VI) from protective clothing by blowing or shaking?

No — the employer must prohibit removing chromium (VI) from protective clothing and equipment by blowing, shaking, or any means that disperses chromium (VI) into the air or onto an employee's body. That prohibition is in 1915.1026(g)(3)(ii).

Under 1915.1026(g)(3)(iii), what must employers tell laundry workers who clean chromium (VI)-contaminated clothing?

Employers must inform any person who launders or cleans chromium (VI)-contaminated clothing about the potential harmful effects of chromium (VI) exposure and instruct them to launder or clean the items in a way that minimizes skin/eye contact and prevents release of airborne chromium (VI) above the PEL. This communication requirement is in 1915.1026(g)(3)(iii).

Under 1915.1026(g)(2)(iv), how must bags or containers of contaminated protective clothing be labeled when removed for laundering?

Bags or containers of contaminated protective clothing removed from change rooms for laundering, cleaning, maintenance, or disposal must be labeled in accordance with the Hazard Communication Standard, 1910.1200, as required by 1915.1026(g)(2)(iv).

Under 1915.1026(h)(1), what hygiene facilities must be provided when protective clothing is required?

When protective clothing and equipment are required, employers must provide change rooms in conformance with 29 CFR 1910.141. See the hygiene-area requirement in 1915.1026(h)(1) and the facility standard at 1910.141.

Under 1915.1026(b), how does the standard define an 'emergency' involving chromium (VI)?

An 'emergency' is any occurrence that results, or is likely to result, in an uncontrolled release of chromium (VI); incidental releases that employees in the immediate area or maintenance personnel can control are not considered emergencies. The emergency definition appears in 1915.1026(b).

Under 1915.1026(b), who qualifies as a Physician or other Licensed Health Care Professional (PLHCP) under the Chromium (VI) standard?

A PLHCP is an individual whose legally permitted scope of practice (license, registration, or certification) allows them to independently provide or be delegated responsibility to provide some or all of the health care services required by paragraph (i) of the standard. See the PLHCP definition in 1915.1026(b).

Under 1915.1026(b), what is the HEPA filter definition used for respirators and other controls?

A HEPA filter is defined as a filter at least 99.97% efficient in removing mono-dispersed particles of 0.3 micrometers in diameter or larger. The HEPA definition is in 1915.1026(b).

Under 1915.1026(d)(6)(ii), if an employee representative must enter a high-exposure area to observe monitoring, who provides and enforces use of protective clothing and equipment?

The employer must provide the observer with the required protective clothing and equipment and must ensure the observer uses that gear and follows applicable safety and health procedures. This obligation is in 1915.1026(d)(6)(ii).

Under 1915.1026(d)(3), what is 'historical monitoring data' and when can it be used?

Historical monitoring data are chromium (VI) monitoring results conducted prior to May 30, 2006, obtained during work operations closely resembling the employer's current operations; such data can be used as part of the performance-oriented option to characterize exposures. See the historical monitoring-data definition and use in 1915.1026(d)(3).

Under 1915.1026(d)(5), what should employers consider when choosing a laboratory method for chromium (VI) air samples?

Employers should choose monitoring and analysis methods that can measure chromium (VI) with ±25% accuracy and provide 95% confidence for concentrations at or above the action level, and should confirm the lab's analytical method meets those criteria. The method-accuracy requirement is in 1915.1026(d)(5).

Under 1915.1026(h)(3)(i), what washing facilities must an employer provide when skin contact with chromium (VI) occurs?

The employer must provide readily accessible washing facilities capable of removing chromium (VI) from the skin and ensure affected employees use them when necessary.

  • Ensure facilities are located so employees can use them promptly after exposure.
  • Facilities should include soap, running water, and clean towels or air dryers; they must be adequate to remove the contaminant from skin.

See the requirement in 1915.1026(h)(3)(i) and the general washing-facility reference at 1915.97.

Under 1915.1026(h)(3)(ii), when must employees wash their hands and faces if they have had skin contact with chromium (VI)?

Employees who have skin contact with chromium (VI) must wash their hands and faces at the end of the work shift and before eating, drinking, smoking, chewing tobacco or gum, applying cosmetics, or using the toilet.

  • Employers must ensure compliance with this timing to prevent ingestion or further contamination.

See 1915.1026(h)(3)(ii).

Under 1915.1026(h)(2), what must change rooms include to prevent cross-contamination of protective clothing and street clothes?

Change rooms must be equipped with separate storage facilities for protective clothing and equipment and for street clothes, and these facilities must prevent cross-contamination.

  • Provide clearly designated lockers or storage areas that physically separate contaminated items from street clothes.
  • Implement procedures (e.g., sealed bags, labeled lockers, cleaning schedules) to keep protective clothing from contaminating personal clothing.

See 1915.1026(h)(2).

Under 1915.1026(h)(4)(i) and (ii), what controls must an employer follow if employees are allowed to eat or drink at a worksite where chromium (VI) is present?

If employees are allowed to eat or drink where chromium (VI) is present, the employer must ensure eating and drinking areas and surfaces are maintained as free as practicable of chromium (VI), and employees must not enter these areas wearing protective work clothing or equipment unless surface chromium (VI) has been removed by methods that do not disperse it.

  • Keep dedicated, regularly cleaned eating surfaces separated from work areas.
  • Require removal or decontamination of protective clothing and equipment before entry using wet-wiping, HEPA vacuuming, or other non-dispersive cleaning methods.

See 1915.1026(h)(4)(i) and 1915.1026(h)(4)(ii), and consult 1915.97 for washing/eating-area guidance.

Under 1915.1026(h)(5), what activities are prohibited in areas where skin or eye contact with chromium (VI) occurs?

The employer must ensure employees do not eat, drink, smoke, chew tobacco or gum, or apply cosmetics in areas where skin or eye contact with chromium (VI) occurs; they also must not carry or store items associated with these activities in those areas.

  • Prohibit personal food, drink, tobacco products, and cosmetics in contamination zones.
  • Provide alternative, clean areas for these activities and enforce the prohibition through training and supervision.

See 1915.1026(h)(5).

Under 1915.1026(i)(1)(i), which employees must be offered medical surveillance for chromium (VI) exposure?

Medical surveillance must be made available at no cost and at a reasonable time and place for employees who are or may be occupationally exposed to chromium (VI) at or above the action level for 30 or more days a year, employees experiencing signs or symptoms of chromium (VI) effects, and employees exposed during an emergency.

  • Track work schedules and exposure measurements to determine who meets the 30-days-per-year threshold.
  • Offer surveillance immediately to symptomatic employees and after emergency exposures.

See 1915.1026(i)(1)(i)(A)-(C).

Under 1915.1026(i)(2), how often must medical examinations be provided to employees covered by the chromium (VI) medical surveillance program?

Employers must provide medical examinations within 30 days after initial assignment (unless a valid exam was done within the prior 12 months), annually, within 30 days after a PLHCP recommends one, whenever the employee shows signs or symptoms of chromium (VI) effects, within 30 days after an emergency exposure that results in an uncontrolled release, and at termination of employment (unless the last exam was within six months).

  • Maintain scheduling systems to ensure annual and event-driven exams occur within required timeframes.

See 1915.1026(i)(2)(i)-(vi).

Under 1915.1026(i)(3), what must a chromium (VI) medical examination include?

A chromium (VI) medical examination must include a medical and work history focused on chromium (VI) exposure and respiratory/skin problems, a physical examination of the skin and respiratory tract, and any additional tests the PLHCP deems appropriate.

  • Collect smoking history, prior nasal or skin conditions, and exposure histories to help the PLHCP assess risk.
  • PLHCP may order chest x-rays, pulmonary function tests, or dermatology evaluations as needed.

See 1915.1026(i)(3)(i)-(iii).

Under 1915.1026(i)(4), what information must an employer provide to the PLHCP who examines employees for chromium (VI)?

The employer must ensure the examining PLHCP has a copy of the chromium (VI) standard and provide a description of the employee’s duties related to chromium (VI) exposure, the employee's past/current/anticipated exposure levels, a description of personal protective equipment used (including duration), and any relevant prior work-related medical records under employer control.

  • Provide accurate exposure monitoring results and PPE practices so the PLHCP can make informed recommendations.

See 1915.1026(i)(4)(i)-(iv).

Under 1915.1026(i)(5), what must the PLHCP include in the written medical opinion given to the employer, and what must not be revealed?

The PLHCP’s written medical opinion to the employer must state whether the employee has any detected medical conditions increasing risk from chromium (VI), any recommended limitations on chromium (VI) exposure or PPE use (including respirators), and confirm that the PLHCP explained the exam results and any related medical conditions to the employee; the PLHCP must not reveal specific findings or diagnoses unrelated to occupational chromium (VI) exposure.

  • Employers must provide the PLHCP’s opinion to the examined employee within two weeks of receipt.

See 1915.1026(i)(5)(i)-(iii).

Under 1915.1026(j)(1) and (j)(2), how must employers communicate chromium (VI) hazards and training requirements to employees?

Employers must include chromium (VI) in their Hazard Communication Program under the HCS, ensure employees can access container labels and safety data sheets, and train employees so they can demonstrate knowledge of the standard’s contents and the purpose and description of the medical surveillance program.

  • Training must address at least cancer, skin sensitization, and eye irritation hazards associated with chromium (VI).
  • Make a copy of 1915.1026 available to affected employees at no cost.

See 1915.1026(j)(1) and 1915.1026(j)(2).

Under 1915.1026(k)(1)(ii), what information must an employer record for air monitoring used to comply with the chromium (VI) standard?

Air monitoring records must include at least the date of each measurement; the operation being monitored; sampling and analytical methods and evidence of accuracy; number, duration, and results of samples; type of PPE worn (such as respirators); and the names and job classifications of employees represented by the monitoring, indicating who was actually monitored.

  • Keep clear chain-of-custody and method validation documentation to show accuracy.

See 1915.1026(k)(1)(ii)(A)-(F).

Under 1915.1026(k)(2)(ii), what conditions must be met when an employer relies on historical monitoring data to determine chromium (VI) exposure?

When relying on historical monitoring data, the employer must record that the data were collected using methods meeting the accuracy requirements of paragraph (d)(5); that processes, work practices, material characteristics, and environmental conditions are essentially the same as those for the current job; and include any other data relevant to the operation.

  • Document comparisons that show equivalence (e.g., same tasks, equipment, controls, and materials) and retain that documentation as required.

See 1915.1026(k)(2)(ii)(A)-(E) and the accuracy requirement at 1915.1026(d)(5).

Under 1915.1026(k)(3)(ii), what must be included in records of objective data relied on to show that a material or process does not release chromium (VI)?

Records of objective data must include the chromium-containing material in question; the source of the objective data; the testing protocol and results or analysis for chromium (VI) release; a description of the process/operation/activity and how the data support the determination; and any other relevant data.

  • Keep original test reports, method details, and descriptions of the conditions under which testing occurred to demonstrate applicability.

See 1915.1026(k)(3)(ii)(A)-(E) and record availability requirements at 1915.1026(k)(3)(iii).

Under 1915.1026(k)(4), what medical surveillance records must employers maintain for employees covered by the chromium (VI) medical program?

Employers must maintain an accurate medical record for each medical-surveillance-covered employee that includes the employee’s name, a copy of the PLHCP’s written opinions, and a copy of the information provided to the PLHCP as required by paragraph (i)(4).

  • These medical records must be maintained and made available in accordance with 29 CFR 1910.1020.

See 1915.1026(k)(4)(i)-(iii).

Under 1915.1026(l), when did most employer obligations and engineering-control deadlines for chromium (VI) compliance begin?

For employers with 20 or more employees, obligations (except engineering controls) began November 27, 2006; for employers with 19 or fewer employees they began May 30, 2007; and engineering controls required by paragraph (e) had to be implemented no later than May 31, 2010.

  • Employers must still comply with ongoing requirements such as monitoring, medical surveillance, and recordkeeping.

See 1915.1026(l)(1)-(3).