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OSHA Consultation Services

The OSHA State Consultation Service, available in every State, can assist with assessing exposure to respiratory hazards in the workplace, including welding fumes, to determine whether concentrations have reached hazardous levels (some insurance companies provide this service, as well). For more information on OSHA’s Consultation Services go to:

OSHA’s consultation assistance is available on request to employers who want help in establishing and maintaining a safe and healthful workplace. Largely funded by OSHA, the service is provided at no cost to the employer. Primarily developed for smaller employers with more hazardous operations, the consultation service is delivered by state governments employing professional safety and health consultants. Comprehensive assistance includes an appraisal of all mechanical systems, work practices, and occupational safety and health hazards of the workplace and all aspects of the employer’s present job safety and health program. No penalties are proposed or citations issued for hazards identified by the consultant. OSHA provides consultation assistance to the employer with the assurance that his or her name and firm and any information about the workplace will not be routinely reported to OSHA enforcement staff.

OSHA Citations on Respiratory Protection

"The OSHA standard for Respiratory Protection, Title 29 CFR 1910.134 is one of the top four most frequently cited OSHA standards (the other three are scaffolding, fall protection and hazard communication)". This standard directs employers to establish and maintain a respiratory program to protect employees from contaminants that contribute to or cause occupational diseases. The standard contains requirements for program administration, worksite-specific procedures, respiratory selection, employee training, fit testing, medical evaluation, respirator use, cleaning, maintenance, and repair.

Some of the most frequent sections of the 1910.134 standard cited by OSHA in inspections:
  • Failure to establish and implement a written program [1910.134 (c)(1)]

  • Failure to conduct medical evaluations [1910.134 (e)(1)]

  • Failure to provide Appendix D when voluntary use deemed permissible [1910.134 (c)(2)(i)]

  • Failure to fit test initially, upon change of respirator, and annually thereafter [1910.134 (f)(2)]

  • Failure to ID and evaluate respiratory hazards [1910.134 (d)(1)(iii)]

OSHA’s Hexavalent Chromium Standard

The Occupational Safety and Health Administration’s (OSHA) final Hexavalent Chromium Cr(VI) Standard states the new permissible exposure limit (PEL) for Cr(VI) is 5ug/m3 (micrograms per cubic meter) as an eight-hour time-weighted average (TWA). There are three standards for different industries—General Industry (1910.1026); Construction (1926.1126); and Shipyards (1915.1026). The respiratory protection requirements for the three standards are similar. The standards require employers in these industries to make an exposure determination to establish whether they are in compliance with the new exposure limit. They all require the respiratory protection program, including respirator selection to be in compliance with OSHA 1910.134.

According to OSHA, the main industries affected, but are not exclusive, are stainless steel fabrication, manufacturers of heavy-duty coatings and paints, electroplating operations and producers of chrome-based pigments. Operations include the production of chromate pigments and powders, chromic acid, chromium catalysts, dyes and coatings. Employees who are working near chrome electroplating; those who are welding and hot-working stainless steel, high chrome alloys and chrome-coated metal; applying and removing chromate-containing paints and other surface coatings are affected as well. Airborne particles of chromium dust can also contaminate hands, clothing, beards, food, and beverages.

Health effects include lung cancer in workers who breathe airborne hexavalent chromium, irritation or damage to the nose, throat, and lungs (if hexavalent chromium is breathed at high levels), and irritation or damage to the eyes and skin (if hexavalent chromium contacts these organs in high concentrations).

For a complete copy of the standard please refer to OSHA’s website at
www.osha.gov. OSHA also has available their Small Entity Compliance Guide for the Hexavalent Chromium Standards: www.osha.gov/Publications/OSHA_small_entity_comp.pdf

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