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This information is abstracted from OHSA’s document enti-
tled "Small Entity Compliance Guide for the Hexavalent
Chromium Standards", OSHA 3320-10N 2006.
(http://www.osha.gov/publications/osha_small_entity_comp.pdf)
Employers are responsible for providing a safe and healthful
workplace for their employees. OSHA’s role is to assure the
safety and health of America’s employees by setting and
enforcing standards, providing training, outreach and educa-
tion; establishing partnerships; and encouraging continual
improvement in workplace safety and health.
Methods of Compliance: Engineering & Work Practice
Controls (1)
Employers must use Engineering and Work Practice Controls
as the primary means to reduce and maintain employee expo-
sures for Cr(VI) to or below the PEL, unless the employer can
demonstrate that such control measures are not feasible.
A. Engineering Controls: include substitution,
isolation and ventilation.
B. Work Practice Controls: involve adjustments in the
way a task is performed, as well as the periodic
inspection and maintenance of engineering control
equipment. In many cases, work practice controls
complement engineering controls in providing
employee protection.
C. Personal Protection Equipment: When engineering
and work practice controls cannot reduce employee
exposure to within the PEL, employers must provide
respirators. OSHA’s Methods of Compliance states that:
"If feasible engineering and work practice controls are
not sufficient to reduce employee exposure to or below
the PEL, then the employer must use them to reduce
the exposur
e to the lowest level achievable before
using r
espirators. Respirators must then be used to
reduce employee exposure to or below the PEL." (2)
Respirators are required during the period necessary to install
or implement feasible engineering controls (by May 31, 2010)
and during maintenance, repair and emergency situations.
No one solution will fit all applications. Solutions frequently
involve one or more methods of control to properly and ade-
quately control employee exposure.
Note (1): Small Entity Compliance Guide for the
Hexavalent Chromium Standards, Pages 9, 10 and 11,
OSHA 3320-10N 2006
Note (2): a) November 27, 2006 for employers with
20 or more employees.
b) May 31, 2007 for employers with
19 or fewer employees.
Welding Fume Control Methodology
To thoroughly explore your welding fume control options, you
should clearly identify and assess your actual needs and oper-
ating conditions. The following Welding Fume Control
Methodology, along with your Lincoln Electric Technical Sales
Representative, can help you through this process, as he or
she can bring expertise and resources to assist you as you go
through this process.
A. Engineering Controls
1. Substitution:
Is it feasible and practical to modify or replace your current
welding process, consumable, gas, welding procedure or
equipment technology with an alternative process,
consumable, gas, welding procedure or equipment technol-
ogy that generates less welding hexavalent chromium.
2. Isolation
Is it feasible and practical to isolate and separate your
welding operation by moving it to a regulated area, by
automating/ventilating the welding process and/or by
placing a barrier between the employee and the
source?
3. Ventilation:
Is it feasible and practical to control the welding fume
path between the source and the worker through
source, local and/or general shop extraction/ventilation
equipment?
B. Safe Work Practice Controls
Safe work practices complement each level of
Engineering Controls and are designed to control the
manner in which work is performed. These practices
include such areas as safe welding habits (keeping
your head out of the fumes, keeping fumes and
gases away from your breathing zone and proper
training & use of fume extraction equipment) as well
as general housekeeping and general administrative
procedures such as performing maintenance off
shift to minimize potential exposure.
C. Personal Protective Equipment (PPE)
An important method of protecting employees in
certain situations can be the use of PPE, including
respirators; which require an initial employee medical
evaluation, more frequent evaluation of worker
exposure levels, training and recordkeeping.
In addition, the OSHA PPE evaluation may determine
the need for additional personal protection practices,
including specific requirements for additional work
clothing & equipment, as well as the need for a
separate change room, shower and laundering service. (3)
Note (3): see Small Entity Compliance Guide for the
Hexavalent Chromium Standards OSHA 3320-10N 2006 for
further details and references regarding compliance.
Welding Fume Control Methodology
www.lincolnelectric.com www.
lincolnelectric.com www.lincolnelectric.com
Is it feasible and practical to replace your current welding process, consumable,
gas, welding procedure or equipment technology with an alternative process,
consumable, gas, welding procedure or equipment technology that can
generate less hexavalent chromium?
Lincoln Electric’s Suggested
Welding Fume Control Methodology
Engineering Controls
Regulatory Assessment Have you determined potential employee exposure to hexavalent chromium
from the welding consumable, base material and coating?
Exposure Determination Is there any potential employee exposure to hexavalent chromium
above the OSHA PEL?
1. Substitution
Is it feasible and practical to isolate and separate your welding operation by
moving it to a regulated area, by automating/ventilating the welding process
and/or by placing a barrier between the employee and the source?
3. Ventilation
Is it feasible and practical to control the welding fume path between the source
and the worker through source, local and/or general shop extraction/ventilation
equipment?
Safe Work Practice Controls
Is it feasible and practical to lower exposure to hexavalent chromium
by use of safe work practice and/or administrative controls?
Personal Protective Equipment Can the employee be protected from hexavalent chromium by use
of a respirator?
YES
YES
NO
NO
NO
NO
YES
Employer
Periodic
Assessment
Employer
Exposure
Assessment
Feasible &
Practical
YES
YES
Below
PEL
NO NO
YES
2. Isolation
Important Compliance Note: Employers must refer to applicable
OSHA and state regulations for specific legal requirements.
This information should be used for informational purposes only.