The Mechanical Contractors Association of
America’s (MCAA) new Model Hexavalent Chromium Program was
developed by the Safety and Health Committee in response to OSHA’s Hexavalent
Chromium Standard, which came into effect for larger employers in November.
Hexavalent Chromium is a heavy metal
component of stainless steel that can increase the risk of lung cancer in
humans if inhaled in significant concentrations. Hexavalent Chromium is
sometimes referred to as Chromium (VI) or hex chrome. The major concern in the
mechanical construction industry is over exposure to hexavalent chromium from
fumes created by welding or torch cutting on stainless steel pipe and ducts.
The Occupational Safety and Health Administration
(OSHA) issued a standard in February 2006 to protect workers from over-exposure
to hexavalent chromium. Although the standard was issued because of a court
order concerning general industry applications, OSHA opted to make the general
industry-based standard applicable to the construction industry. As a result,
MCAA set out to prepare its members to comply with the standard.
MCAA’s Safety and Health Committee
developed and produced the (itals)Model Hexavalent Chromium Compliance Program
(enditals) to help mechanical construction companies comply with the standard,
and meet increasing owner/prime contractor demands for written hexavalent
chromium compliance programs.
Although the MCAA standard doesn’t require
employers to establish written hexavalent chromium programs, many owners,
construction managers and general contractors are requiring them. Effective
dates are as follows:
For employers with 20 or more employees (except engineering
control requirements) – November 27, 2006;
For employers with fewer than 20 employees (except engineering
control requirements) – May 30, 2007;
Engineering control requirements for all employers – May 31,
2010.
As a mechanical industry employer who is
affected by the standard, you have two options regarding the determination of
worker exposure levels to hexavalent chromium. Compliance requirements are
dictated by the exposure levels:
Option 1 – Conduct air monitoring to determine worker exposure
levels to hexavalent chromium, and implement appropriate protective measures
when necessary.
Option 2 – Use any combination of air monitoring, historical
data and objective data to determine worker exposure levels to hexavalent
chromium, and implement appropriate protective measures when necessary.
MCAA’s (ITALS)Model Hexavalent Chromium
Compliance Program (enditals) includes two model programs, one for each of the
options listed above. Also included is a summary of the OSHA standard,
information to help you choose the option that’s right for your company, and a
handy air monitoring checklist.
MCAA is in the process of collecting air
monitoring data covering hexavalent chromium exposure in the mechanical
construction industry. MCAA believes that the data may allow mechanical
construction companies to use a combination of historical and objective data in
lieu of costly air monitoring on every project.
OSHA’s Hexavalent Chromium Standard allows
employers to use a combination of historical and objective data instead of air
monitoring provided that the previous air monitoring methods used to establish
the data are within an accuracy range of 25 per cent and produce confidence
levels of 95 per cent for the concentrations of hexavalent chromium above
OSHA’s established Action Level. MCAA believes the data would apply only to
buildings or structures that are under construction, but it would likely
exclude high purity welding procedures. However, companies with well-ventilated
pre-fabrication shops could establish their own combinations of historical and
objective data to potentially forgo regular air monitoring requirements.
The Safety and Health Committee will
evaluate the collected data to determine whether exposure levels are
consistently low enough to justify the use of combination data, and whether it
meets the requirements of the standard. If the committee determines that more
air monitoring data is needed, it will likely recommend to MCAA that it conduct
the monitoring in early 2007. If your company has conducted air monitoring for
hexavalent chromium and would be willing to share it with MCAA, contact Pete
Chaney at
or call
1-800-556-3653.
To order the Model Hexavalent Chromium
Compliance program, visit MCAA’s online store at www.mcaa.org/store or call Linda Burke at
(301) 990-2200. The program cost is $18 (U.S.) for MCAA members and $36 for
non-members, plus shipping. Volume discounts are available.
