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BIG problem.......hexavalent chromium

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  • BIG problem.......hexavalent chromium

    What are you guys doing to meet the new hexavalent chromium rules?

    I have a state "Industrial Hygienist" busting my ***** on the issue. He is threatening to shut me down or fine me into bankruptcy, if I don't comply to his version of the requirements.

    Apparently, the gov doesn't differentiate between a factory that employs hundreds of people, doing nothing but welding stainless 3 shifts a day, and a one man shop that does small repairs on occasion.

    He said an Speedglas Adflo type fresh air supplied helmet or respirator, and an exhaust fan wont suffice, and wants downdraft tables (like that would work with mig/tig), an elaborate "emission collection system", and a filtration system that would scrub all of the air in the shop,.....He also wants me to hire a independent company (read... expensive) to monitor the exposure levels.

    A preliminary look into equipment and prices looks to be well in excess of $50,000.


    I tried the "I wont weld stainless anymore" line,. but he stated that if there is even 1 welding machine in the shop, I cant prove that I wont and HAVE to comply, or go out of business.



    SO,.............. what are you guys doing (if any of you are) to comply with these new regs?
    The regs are so long winded (typical gov mumbo-jumbo)....... I can hardly even wrap my mind around them, and many states have added their own.

    http://www.osha.gov/SLTC/hexavalentc...standards.html

    It looks like this stuff is the new "Asbestos" of the welding industry, and poised to put a real hurt on alot of us.

  • #2
    Hexavalent Chromium Hazards

    BB: What State do you live in?

    Dave

    Comment


    • #3
      Thats a new one on me.I believe he is an idiot to state that if a machine is present you must abide by the rules dictated by the gov. even if no welding is done on chromium.This is a time to seek legal advice.

      Comment


      • #4
        Hmmmm, as I read it you can use a resparator with a Hepa filtratiion system. The rest of it is kinda vague, and can be taken to imply all sorts of things which really is not relevant to your job as a welder.

        Comment


        • #5
          We just went thru this today at my work. Galvanised and SS welding where i work you must wear a half face Hepa filter. Or they can't weld. End of story...Bob

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          • #6
            BBchevy396,
            I would need to know a little more about your particular manufacturing facility before I could comment accurately concerning this issue. A asked by another member, what state are you in? How many welders do you have? How many welding machines do you run at any given time? How high are your ceilings? What kind of exhaust system do you have? As far as the exposure levels go, get ahold of OSHCON. I will post a link to the website. They are very good, free, and they DO NOT report to OSHA. We were very happy with their service.

            http://www.oshcon.com/

            I find it very odd that this person is telling you all this with no bench mark of exposure levels. How does he know you are exceeding them?

            As for the Speedglas ADFLO, if the proper filters are used, it should be sufficient.

            I will do some digging through OSHA regs concerning this, as it has been awhile since I have looked at them. Here is a start.

            http://www.osha.gov/pls/oshaweb/owad...RDS&p_id=10699

            jrw159

            Comment


            • #7
              Originally posted by jrw159 View Post
              BBchevy396,
              I would need to know a little more about your particular manufacturing facility before I could comment accurately concerning this issue. A asked by another member, what state are you in? How many welders do you have? How many welding machines do you run at any given time? How high are your ceilings? What kind of exhaust system do you have? As far as the exposure levels go, get ahold of OSHCON. I will post a link to the website. They are very good, free, and they DO NOT report to OSHA. We were very happy with their service.

              http://www.oshcon.com/

              I find it very odd that this person is telling you all this with no bench mark of exposure levels. How does he know you are exceeding them?

              As for the Speedglas ADFLO, if the proper filters are used, it should be sufficient.

              I will do some digging through OSHA regs concerning this, as it has been awhile since I have looked at them. Here is a start.

              http://www.osha.gov/pls/oshaweb/owad...RDS&p_id=10699

              jrw159


              I live in WA state. I think the guy is dead wrong, but, like in dealing with other gov agencys, the people have a little authority and tend to like to abuse it.

              To answer your other questions, I have many welders, but 1 weldor(Me), have only one running at a time, have 20' ceilings, in a 40x60' building, a 30" exhaust fan in the peak of the roof, and 18' high x 20' doors.

              This guy seemed unconcerned with the facts of my operation, or if there were any exposure at all. He stated that there is a POSSIBILITY of exposure, ALL precautions and equipment must be in place.

              I have another meeting with this P-R-I-C-K in the near future, and my just have to go above his head, or have an attorney do it.

              The issue at hand now, is I cannot prove that I dont weld SS 24hrs a day, being I have machines capable of it, so according to him........ I do.

              If this Ahole was a cop, he'd give you speeding tickets just because you own a car capable of speeding. I'm not sure how this fight is going to pan out. just want to hear what kind of hassle any of you guys may be having with it.
              Last edited by BBchevy396; 05-15-2009, 04:01 PM.

              Comment


              • #8
                "Fuming Mad"

                Originally posted by BBchevy396 View Post
                I live in WA state. I think the guy is dead wrong, but, like in dealing with other gov agencys, the people have a little authority and tend to like to abuse it.

                To answer your other questions, I have many welders, but 1 weldor(Me), have only one running at a time, have 20' ceilings, in a 40x60' building, a 30" exhaust fan in the peak of the roof, and 18' high x 20' doors.

                This guy seemed unconcerned with the facts of my operation, or if there were any exposure at all. He stated that there is a POSSIBILITY of exposure, ALL precautions and equipment must be in place.

                I have another meeting with this P-R-I-C-K in the near future, and my just have to go above his head, or have an attorney do it.

                The issue at hand now, is I cannot prove that I dont weld SS 24hrs a day, being I have machines capable of it, so according to him........ I do.

                If this Ahole was a cop, he'd give you speeding tickets just because you own a car capable of speeding. I'm not sure how this fight is going to pan out. just want to hear what kind of hassle any of you guys may be having with it.
                BB: If you don't mind me asking, was this a result of a random inspection or neighboring complaint? It just seems somewhat unusual that an agent from the Industrial Commision shows up, clip board in hand, ready to write non-compliance citiations. Occasionally, when Fire Departments are doing code inspections, some of these issues surface, but from the nature of your post, this sounds like an all out arbritrary assault on your business.

                Keep us posted

                Dave

                Comment


                • #9
                  The corporation I work for told us about this "hexavalent chromium" deal last year, and said it occurs during SS SMAW. We only TIG, or MIG SS. We haven't heard anything else about it.

                  Comment


                  • #10
                    Jimmie,
                    If you haven't got a handle on the problem by the time we return from vacation, I'll go talk with an ex-conductor friend that now heads the OSHA office in Gillette. Maybe he can make heads or tails out of the govspeak.

                    Personally...don't those oysters need some fertilizer now and then??? Nothing filled with fertilizer like a fully weighted inspector.

                    Comment


                    • #11
                      There's an OSHA office in Gillette????

                      Comment


                      • #12
                        BBchevy, we had a company down here needed to put one of those in, suctions, filters the whole works. Discharges outside, but supposedly removes all the bad stuff first.

                        $50,000 plus ...

                        Comment


                        • #13
                          "Note: Twenty-four states, Puerto Rico and the ****** Islands have OSHA-approved State Plans and have adopted their own standards and enforcement policies. For the most part, these States adopt standards that are identical to Federal OSHA. However, some States have adopted different standards applicable to this topic or may have different enforcement policies."

                          http://www.osha.gov/dcsp/osp/stateprogs/washington.html

                          Comment


                          • #14
                            I just want to say that I've done some scuba diving in the ****** Islands. Neat place!

                            Keep us posted, Jimmy. I think you need to write a letter, respectfully asking questions like you've asked here (incl. the one about your car) and address it to the guy's boss. Use signature confirmation and mail it from the PO.

                            Comment


                            • #15
                              BB
                              You mentioned the size of the building and having numerous welding machines, But, how many others work there or are you the owner and SOLE employee? If so then based on Federal Law you are exempt-Don't know if Washington Law is different most States just copy Fed Laws but under Federal Law Self employed with NO employees are exempt as shown below. So if you are a one man show, he needs to go pester someone else. Also the 'red' site has a CD on this topic and how to comply.

                              As defined by the Act, an employer is any "person engaged in a business affecting commerce who has employees, but does not include the United States or any State or political subdivision of a State." Therefore, the Act applies to employers and employees in such varied fields as manufacturing, construction, longshoring, agriculture, law and medicine, charity and disaster relief, organized labor and private education. Such coverage includes religious groups to the extent that they employ workers for secular purposes.

                              The following are not covered under the Act:

                              * Self-employed persons;
                              * Farms at which only immediate members of the farm employer's family are employed; and
                              * Working conditions regulated by other federal agencies under other federal statutes.

                              Taken from:
                              http://www.osha.gov/doc/outreachtrai.../introsha.html

                              Comment

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