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U.S. Department of Labor | ![]() |
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Occupational Safety & Health Administration |
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Standard Interpretations
11/14/2006 - Use of "objective data" to accurately characterize employee exposures to hexavalent chromium during welding operations. |
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Standard Number: | 1910.1026(d)(3); 1926.1126(d)(3) |
November 14, 2006 American Bakers Association Automotive Service Association National Automobile Dealers Association Sheet Metal and Air Conditioning Contractors National Association The Steel Tank Institute/Steel Plate Fabricators Association c/o Mr. Douglas Greenhaus National Automobile Dealers Association 8400 Westpark Drive McLean, VA 22101-3591 Dear Mr. Greenhaus: Thank you for your letter to the Occupational Safety and Health Administration (OSHA) concerning the new standards for hexavalent chromium. This reply letter constitutes OSHA's interpretation only of the requirements discussed and may not be applicable to any question not detailed in your original correspondence. Your paraphrased request and our response are below. Request: You requested guidance on whether your air sampling protocol to accurately characterize employee exposures to hexavalent chromium during welding operations was acceptable to use by employers represented by your industry groups to comply with the "objective data" option in 29 CFR 1910.1026(d)(3) and 29 CFR 1926.1126(d)(3). Response: The air sampling protocol you attached for our review specifies that air sampling for hexavalent chromium shall be conducted in accordance with [OSHA] Sampling Method ID-215 or other approved analytical method, and that the air sampling is to be conducted in accordance with generally accepted industrial hygiene practices. In addition, you listed several parameters of the workplace operation and other environmental factors that would be important in documenting the conditions affecting the exposure results, including: the type of welding process; the amount of chromium in materials used; the orientation of the welder to his work and other work practices; the presence of any engineering controls, such as local exhaust ventilation; and several other factors. At the outset, it should be noted that OSHA does not approve or endorse any specific air monitoring guidelines/protocols used to obtain objective information regarding expected employee exposures to air contaminants. Your attached protocol is generally consistent with accepted industrial hygiene practices for air sampling. However, we do recommend you also account for whether and what type of shielding gas is used in the welding operation; the distance from the point of welding to the local exhaust ventilation, if used; and whether the welding operation is performed indoors, outdoors, or in a confined space. We further refer you to OSHA's website,http://www.osha.gov, where you may follow the links for Chemical Sampling Information, leading to specific sampling and analytical methods for hexavalent chromium or chromium (VI). You will find that OSHA recently updated its OSHA Sampling Method ID-215 for improved accuracy. We offer a few other comments concerning your air sampling protocol for employers planning to use the resulting data as "objective data" under the standard:
Sincerely, Edwin G. Foulke, Jr. [Reviewed; consistent with current policy 2/15/2008] |
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