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OSHA 1926.1126

Chromium (VI) scope and definitions

Subpart Z

48 Questions & Answers
10 Interpretations

Questions & Answers

Under 1926.1126(a), what workplace exposures to chromium (VI) does the construction standard cover and what are the main exclusions?

This standard covers occupational exposures to chromium (VI) in all forms and compounds in construction, except for the listed exclusions. See 1926.1126(a).

  • The standard generally applies to all chromium (VI) exposures in construction 1926.1126(a)(1).
  • Exclusions: exposures during the application of pesticides regulated by EPA or another Federal agency 1926.1126(a)(2); exposures to portland cement 1926.1126(a)(3); and materials/processes for which objective data show they cannot release chromium (VI) at or above 0.5 µg/m3 as an 8‑hour TWA under expected conditions 1926.1126(a)(4).

Under 1926.1126(a)(2), are exposures to chromium (VI) from pesticide application covered by this construction standard?

No. Exposures that occur during the application of pesticides regulated by the Environmental Protection Agency or another Federal agency are excluded from this standard. See 1926.1126(a)(2).

  • If your work involves pesticide application regulated by EPA (for example, certain wood preservatives), use the pesticide regulatory requirements rather than 1926.1126 for chromium (VI) compliance.

Under 1926.1126(a)(3), is portland cement regulated by the chromium (VI) standard?

No. Exposures to portland cement are explicitly excluded from the chromium (VI) standard. See 1926.1126(a)(3).

  • Employers should follow any other applicable standards and guidance for handling cement, but 1926.1126 does not apply to portland cement exposures.

Under 1926.1126(a)(4), what does an employer need to show with objective data to exclude a material, process, or activity from coverage?

An employer must show with objective data that the material or specific process cannot release dusts, fumes, or mists of chromium (VI) at concentrations at or above 0.5 µg/m3 (8‑hour TWA) under any expected conditions of use. See 1926.1126(a)(4).

  • Objective data can include industry air monitoring surveys or calculations based on the material's composition and properties.
  • The data must reflect workplace conditions closely resembling your current processes, materials, controls, work practices, and environmental conditions (see the definition and performance requirements in 1926.1126(d)(3)).

Under 1926.1126(b), what is the action level for chromium (VI) and how is it calculated?

The action level for chromium (VI) is 2.5 micrograms 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 1926.1126(b).

  • Employers use this action level to trigger periodic monitoring and other required actions under the standard.

Under 1926.1126(b), how does the standard define "chromium (VI)"?

Chromium (VI) is defined as chromium with a valence of positive six, in any form and in any compound. See the definition in 1926.1126(b).

  • This means all hexavalent chromium compounds and forms (dusts, fumes, mists, soluble and insoluble compounds) are covered unless expressly excluded by the scope.

Under 1926.1126(b), how does the standard define "employee exposure" for chromium (VI) monitoring?

"Employee exposure" means the airborne chromium (VI) exposure that would occur if the employee were not using a respirator. See the definition in 1926.1126(b).

  • Employers must base exposure determinations on unprotected exposures; respirator use does not reduce the measured exposure for compliance purposes.

Under 1926.1126(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 1926.1126(c).

  • Employers must ensure no employee's 8‑hour TWA exceeds this limit.

Under 1926.1126(d)(1)-(2), what are the two options an employer may use to determine employee 8‑hour TWA exposures?

An employer must determine each employee's 8‑hour TWA exposure using either the scheduled monitoring option or the performance‑oriented option. See 1926.1126(d)(1).

  • The scheduled monitoring option requires initial and periodic air sampling according to the rules in 1926.1126(d)(2).
  • The performance‑oriented option allows using a combination of air monitoring, historical monitoring, and objective data to accurately characterize exposures per 1926.1126(d)(3).

Under 1926.1126(d)(2)(i), how should an employer perform initial monitoring when using the scheduled monitoring option?

The employer must perform initial monitoring with a sufficient number of personal breathing‑zone samples to accurately characterize full‑shift exposures on each shift, for each job classification and work area; if representative sampling is used, sample the employee(s) expected to have the highest chromium (VI) exposures. See 1926.1126(d)(2)(i).

  • Focus sampling on the highest‑exposure tasks or workers when doing representative sampling.

Under 1926.1126(d)(2)(iii)-(iv), how often must employers perform periodic monitoring if exposures reach the action level or exceed the PEL?

If monitoring shows exposures at or above the action level, perform periodic monitoring at least every six months; if exposures exceed the PEL, perform periodic monitoring at least every three months. See 1926.1126(d)(2)(iii) and 1926.1126(d)(2)(iv).

  • Periodic monitoring frequency depends on the measured exposure level.

Under 1926.1126(d)(2)(v), when may an employer discontinue monitoring for employees represented by prior monitoring?

An employer may discontinue monitoring when periodic results are below the action level and a second monitoring result taken at least seven days later confirms the first result. See 1926.1126(d)(2)(v).

  • Both results must represent the same employee population or job classification to discontinue monitoring.

Under 1926.1126(d)(2)(vi), when is additional monitoring required?

Additional monitoring is required whenever there is any change in production, raw materials, equipment, personnel, work practices, or control methods that may cause new or additional chromium (VI) exposures, or whenever the employer has reason to believe new exposures have occurred. See 1926.1126(d)(2)(vi).

  • Treat process changes as triggers to reassess exposures promptly.

Under 1926.1126(d)(3), what does the performance‑oriented option allow an employer to use to determine exposures?

The performance‑oriented option allows an employer to determine exposures using any combination of air monitoring data, historical monitoring data, or objective data sufficient to accurately characterize employee exposure. See 1926.1126(d)(3).

  • The key requirement is that the combination of data must accurately represent current workplace exposures.

Under 1926.1126(d)(4), what are the employer's notification requirements after making an exposure determination?

Within 5 work days after making the exposure determination, the employer must individually notify each affected employee in writing of the results or post the results in a location accessible to affected employees; if exposures are above the PEL, the notification must also describe corrective actions being taken. See 1926.1126(d)(4)(i) and 1926.1126(d)(4)(ii).

  • Keep written records accessible or post results where employees can see them.

Under 1926.1126(d)(5), what accuracy is required for air monitoring methods used for chromium (VI)?

Air monitoring methods must be able to measure chromium (VI) with an accuracy of ±25% and produce measurements at a 95% statistical confidence level for concentrations at or above the action level. See 1926.1126(d)(5).

  • Use validated sampling and analytical methods that meet these performance criteria.

Under 1926.1126(d)(6), can employees observe chromium (VI) air monitoring and what conditions apply?

Yes. Employers must give affected employees or their designated representatives the opportunity to observe monitoring of chromium (VI) exposures. If observing requires entry into an area where protective clothing or equipment is required, the employer must provide appropriate clothing and equipment and ensure the observer uses them and follows safety procedures. See 1926.1126(d)(6)(i) and 1926.1126(d)(6)(ii).

  • Observers must be protected to the same extent as workers in the area.

Under 1926.1126(e)(1), are employers required to use engineering and work practice controls to meet the PEL?

Yes. Employers must use engineering and work practice controls to reduce and maintain chromium (VI) exposure to or below the PEL unless they can demonstrate such controls are not feasible. See 1926.1126(e)(1)(i).

  • If controls cannot achieve the PEL, use them to lower exposure as much as feasible and supplement with respiratory protection per 1926.1126(e)(1).
  • An exception applies for tasks that do not result in exposure above the PEL for 30 or more days per year if the employer can demonstrate that (see 1926.1126(e)(1)(ii)).

Under 1926.1126(e)(2), can employers rotate employees between jobs to comply with the PEL?

No. The standard explicitly prohibits rotating employees to different jobs for the purpose of achieving compliance with the PEL. See 1926.1126(e)(2).

  • Employers must control exposures by engineering, work practices, or respiratory protection, not by rotating workers.

Under 1926.1126(f), when is respiratory protection required and what program must the employer follow?

Respiratory protection is required in specific situations such as during implementation of controls, for tasks where engineering controls are not feasible, when controls can't lower exposures to the PEL, for operations with exposures above the PEL for fewer than 30 days per year if controls are not used, and during emergencies; when respirators are required the employer must institute a respiratory protection program in accordance with 1910.134. See 1926.1126(f)(1)(i)–(v) and 1926.1126(f)(2).

  • The respiratory program must meet the requirements in 1910.134, including fit testing, medical evaluations, and maintenance.

Under 1926.1126(g), what are employer duties for protective clothing and equipment when skin or eye contact with chromium (VI) is possible?

The employer must provide appropriate personal protective clothing and equipment at no cost and ensure employees use it when a hazard from skin or eye contact with chromium (VI) is present or likely. See 1926.1126(g)(1).

  • Contaminated protective clothing must be removed at shift end or task completion 1926.1126(g)(2)(i).
  • Employees (except launderers/cleaners) may not remove contaminated clothing from the workplace 1926.1126(g)(2)(ii).
  • When removed for laundering/cleaning, clothing must be stored/transported in sealed impermeable bags/containers and labeled per the Hazard Communication Standard 1926.1126(g)(2)(iii)-(iv). See 1910.1200 for labeling requirements.

Under 1926.1126(g)(3)(i), what must employers do about cleaning and replacement of protective clothing and equipment?

Employers must clean, launder, repair, and replace all protective clothing and equipment as needed to maintain its effectiveness. See 1926.1126(g)(3)(i).

  • Establish procedures to ensure protective gear remains effective and is promptly repaired or replaced when compromised.

Under 1926.1126(d)(6)(ii), who must provide PPE for observers of monitoring when entry into a required PPE area is necessary?

The employer must provide the observer with the required protective clothing and equipment and must assure the observer uses that clothing and equipment and follows other applicable safety procedures. See 1926.1126(d)(6)(ii).

  • Observers must be afforded the same PPE and safety protections as workers in the area they are observing.

Under 1926.1126(g)(3)(ii), can employees remove chromium (VI) from protective clothing by blowing, shaking, or similar methods that disperse the contaminant into the air or onto a person?

No — removing chromium (VI) from protective clothing or equipment by blowing, shaking, or any method that disperses it into the air or onto a person is prohibited. See the prohibition in 1926.1126(g)(3)(ii).

  • Use methods that do not generate airborne dust or transfer the contaminant onto skin (for example: enclosed laundering, HEPA‑equipped vacuuming where appropriate, or other controlled cleaning methods).
  • Inform laundering services and follow the requirements in 1926.1126(g)(3)(iii) about minimizing exposure during cleaning.

Under 1926.1126(g)(3)(iii), what must an employer tell a laundry or cleaner who will launder chromium (VI)-contaminated clothing or equipment?

The employer must inform any person who launders or cleans chromium (VI)-contaminated clothing or equipment that chromium (VI) can be harmful and that the clothing/equipment must be laundered or cleaned in a way that minimizes skin or eye contact and prevents releasing airborne chromium (VI) above the PEL. See this requirement in 1926.1126(g)(3)(iii).

  • Provide written instructions and, if applicable, the appropriate safety data sheets and precautions required by the Hazard Communication Standard, 1910.1200.
  • Consider providing or requiring PPE and engineering controls at the laundering facility if necessary to prevent exposures above the PEL.

Under 1926.1126(h)(1), when must employers provide change rooms and washing facilities for employees who work with chromium (VI)?

Employers must provide change rooms when protective clothing or equipment is required and must provide washing facilities where skin contact with chromium (VI) occurs; eating and drinking areas must also meet the requirements in [1926.51]. See 1926.1126(h)(1) and 1926.51.

  • Change rooms and washing facilities must conform to the general requirements of 1926.51.
  • Provide these facilities at no cost and in locations that are reasonably accessible to affected employees.

Under 1926.1126(h)(2), how must change rooms be set up to prevent cross-contamination between protective clothing and street clothes?

Change rooms must have separate storage for protective clothing and equipment and for street clothes, and those storage facilities must prevent cross-contamination. See 1926.1126(h)(2).

  • Use physically separate lockers or clearly segregated compartments to keep contaminated clothing apart from personal clothing.
  • Maintain cleaning and housekeeping practices to avoid transfer of chromium (VI) between areas.

Under 1926.1126(h)(3), what washing facilities and hygiene practices must an employer provide when employees have skin contact with chromium (VI)?

The employer must provide readily accessible washing facilities capable of removing chromium (VI) from the skin and ensure affected employees use them; employees who have skin contact must wash hands and faces at the end of a shift and before eating, drinking, smoking, using the toilet, applying cosmetics, or chewing. See 1926.1126(h)(3)(i) and 1926.1126(h)(3)(ii).

  • Washing facilities must effectively remove chromium (VI) and be located where they can be used when needed.
  • Employers should train employees on when and how to use these facilities.

Under 1926.1126(h)(4), what must an employer do to eating and drinking areas at worksites where chromium (VI) is present?

The employer must ensure eating and drinking areas and surfaces are kept as free as practicable of chromium (VI), and employees must not enter those areas wearing contaminated protective work clothing or equipment unless surface chromium (VI) has been removed by methods that do not disperse the contaminant into the air or onto a person. See 1926.1126(h)(4)(i) and 1926.1126(h)(4)(ii).

  • Provide designated clean eating areas away from contaminated work zones.
  • Implement cleaning procedures that avoid dispersion (no blowing/shaking) when removing surface contamination from clothing or equipment.

Under 1926.1126(h)(5), what activities are prohibited in areas where skin or eye contact with chromium (VI) occurs?

Employees are prohibited from eating, drinking, smoking, chewing tobacco or gum, applying cosmetics, and from carrying or storing items associated with those activities in areas where skin or eye contact with chromium (VI) occurs. See 1926.1126(h)(5).

  • Enforce the prohibition through signage, training, and supervision.
  • Provide separate clean areas for permitted personal activities.

Under 1926.1126(i)(1), which employees must be offered medical surveillance for chromium (VI)?

The employer must make medical surveillance available at no cost and at a reasonable time and place for employees who (A) are or may be occupationally exposed at or above the action level for 30 or more days a year, (B) experience signs or symptoms of chromium (VI) adverse health effects, or (C) are exposed in an emergency. See 1926.1126(i)(1)(i)(A)–(C).

  • Exams must be performed by or under supervision of a PLHCP as required in 1926.1126(i)(1)(ii).
  • Offer surveillance proactively when exposure monitoring shows action‑level triggers.

Under 1926.1126(i)(2), how often and under what circumstances must medical examinations be provided?

Employers must provide medical examinations within 30 days after initial assignment (unless a compliant exam was done in the prior 12 months), annually, within 30 days after a PLHCP recommends one, whenever signs/symptoms appear, within 30 days after exposure during an emergency uncontrolled release, and at termination (unless a qualifying exam occurred within the prior six months). See 1926.1126(i)(2)(i)–(vi).

  • Keep scheduling consistent so employees receive exams on time.
  • Ensure access is at no cost and at a reasonable time and place.

Under 1926.1126(i)(3), what must a chromium (VI) medical examination include?

A medical examination must include a medical and work history emphasizing past/current/anticipated chromium (VI) exposure and respiratory/skin problems, a physical exam of the skin and respiratory tract, and any additional tests the PLHCP deems appropriate. See 1926.1126(i)(3)(i)–(iii).

  • Provide accurate exposure and PPE histories to the PLHCP to support appropriate testing.

Under 1926.1126(i)(4), what information must the employer give the PLHCP who performs the medical exam?

The employer must ensure the 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 former/current/anticipated exposure levels, a description of PPE used and how long it has been used, and any employment-related medical exam records the employer controls. See 1926.1126(i)(4)(i)–(iv).

  • Accurate and complete information helps the PLHCP make appropriate medical recommendations.

Under 1926.1126(i)(5), what must the PLHCP include in the written medical opinion and what confidentiality limits apply?

The PLHCP must provide a written medical opinion within 30 days that states whether the employee has medical conditions placing them at increased risk from chromium (VI), any recommended exposure or PPE limitations, and that the PLHCP explained exam results to the employee. The PLHCP must not disclose unrelated specific findings or diagnoses to the employer. Employers must give a copy of the PLHCP's written opinion to the employee within two weeks of receiving it. See 1926.1126(i)(5)(i)–(iii).

  • Maintain employee medical confidentiality as required by the standard and by 1910.1020 for records access and retention.

Under 1926.1126(j), how must employers communicate chromium (VI) hazards to employees under the Hazard Communication Standard?

Employers must include chromium (VI) in their Hazard Communication program required by [1910.1200] and ensure employees have access to labels and safety data sheets and are trained on chromium (VI) hazards including cancer, eye irritation, and skin sensitization. See 1926.1126(j) and 1910.1200.

  • Training must cover the contents of the chromium (VI) standard and the medical surveillance program as required in 1926.1126(j)(2)(i).
  • Keep SDSs and labels available and current.

Under 1926.1126(j)(2)(ii), does an employer have to give employees a copy of the chromium (VI) standard?

Yes — the employer must make a copy of the chromium (VI) standard readily available without cost to all affected employees. See 1926.1126(j)(2)(ii).

  • Availability can be electronic or paper, but must be accessible during the work shift and at no cost to the employee.

Under 1926.1126(k)(1), what specific information must be kept in air monitoring records for chromium (VI)?

The employer must maintain accurate air monitoring records that include the date of measurement, the operation being monitored, the sampling and analytical methods used (and evidence of their accuracy), the number/duration/results of samples, the type of PPE (e.g., respirators) used, and the name and job classification of employees represented by the monitoring, indicating which employees were actually monitored. These records must be maintained and made available in accordance with [1910.1020]. See 1926.1126(k)(1)(ii)–(iii) and 1910.1020.

  • Keep documentation of analytical accuracy (calibrations, QA/QC) with the monitoring record.

Under 1926.1126(k)(2), what conditions must be met for an employer to rely on historical monitoring data to determine chromium (VI) exposure?

When relying on historical monitoring data, the employer must maintain records showing that the data were collected using methods that meet the accuracy requirements of [1926.1126(d)(5)], that processes and work practices in use when the data were obtained are essentially the same as those for the current job, that the material characteristics are the same, that environmental conditions are the same, and any other relevant data. See 1926.1126(k)(2)(ii)(A)–(E) and the accuracy requirement in 1926.1126(d)(5).

  • Document comparisons clearly before relying on historical data, and retain these records per 1910.1020.

Under 1926.1126(k)(3), what records must an employer maintain if they rely on objective data to show that a material or operation will not release chromium (VI) above the PEL?

The employer must maintain accurate records of all objective data relied upon, including identification of the chromium-containing material, the source of the objective data, the testing protocol and results or analysis for release of chromium (VI), a description of the process/operation/activity and how the data support the determination, and other relevant data. These objective data records must be maintained and made available in accordance with [1910.1020]. See 1926.1126(k)(3)(ii)–(iii).

  • Keep test reports, analytical methods, and provenance of the objective data together so they can be reviewed during inspections or audits.

Under 1926.1126(k)(4), what medical surveillance records must employers keep for employees covered by the chromium (VI) medical program?

Employers must establish and maintain an accurate medical surveillance record for each employee covered by paragraph (i), including 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 [1926.1126(i)(4)]. These medical records must be maintained and made available in accordance with [1910.1020]. See 1926.1126(k)(4)(i)–(iii).

  • Ensure confidentiality and controlled access consistent with medical-records rules in 1910.1020.

Under 1926.1126(l)(1), when do the obligations of the Chromium (VI) construction standard start for employers with 20 or more employees (excluding engineering controls required by paragraph (e))?

Nov 27, 2006. Under 1926.1126(l)(1), employers with 20 or more employees must meet all obligations of the Chromium (VI) construction standard except for the engineering controls listed in paragraph (e) beginning on that date.

Under 1926.1126(l)(2), when do the obligations of the Chromium (VI) construction standard start for employers with 19 or fewer employees (excluding engineering controls required by paragraph (e))?

May 30, 2007. Per 1926.1126(l)(2), employers who have 19 or fewer employees must comply with all obligations of the Chromium (VI) construction standard, except the engineering controls in paragraph (e), beginning on May 30, 2007.

Under 1926.1126(l)(3), by what date must all employers implement the engineering controls required by paragraph (e) of the Chromium (VI) standard?

No later than May 31, 2010. 1926.1126(l)(3) requires that the engineering controls specified in 1926.1126(e) be implemented by all employers on or before May 31, 2010.

Under 1926.1126, do the earlier compliance start dates in paragraphs (l)(1) and (l)(2) include the engineering controls listed in paragraph (e)?

No. The start dates in 1926.1126(l)(1) and 1926.1126(l)(2) expressly exclude the engineering controls required by 1926.1126(e); those engineering-control obligations have a single later deadline for all employers under 1926.1126(l)(3).

Under 1926.1126(e) and 1926.1126(l)(3), what does "engineering controls required by paragraph (e)" mean and where can I find the specific measures I must implement?

It means the specific engineering control measures the Chromium (VI) construction standard lists in paragraph (e); those measures must be implemented by May 31, 2010. For the exact controls an employer must use (for example, any required ventilation, enclosures, or process changes specified by the standard), see 1926.1126(e). The deadline for implementing those paragraph (e) engineering controls for all employers is set by 1926.1126(l)(3).

Under 1926.1126, if my company reaches 20 or more employees after the listed start dates, when must we begin complying with the standard's obligations (excluding engineering controls)?

You must comply immediately once you meet the employer-size threshold because the standard's obligations already have effective start dates. 1926.1126(l)(1) established November 27, 2006 as the start date for employers with 20 or more employees, and 1926.1126(l)(2) set May 30, 2007 for employers with 19 or fewer employees; the engineering controls in 1926.1126(e) remain subject to the universal deadline in 1926.1126(l)(3).

Under 1926.1126(l), does the employer-size distinction change the deadline for implementing engineering controls required by paragraph (e)?

No — employer size does not change the engineering-controls deadline. 1926.1126(l)(3) makes the implementation deadline for the engineering controls in 1926.1126(e) the same for all employers: no later than May 31, 2010.