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  1. #21
    Join Date
    Jun 2004
    Location
    nj
    Posts
    204

    Default

    Based on my limited experience dealing with the issue (wasn't just chromium exposure, but also other issues as well)

    IF you are subject to the requirements (have employees that may be exposed), AND a case can be made by the inspector that there may be a level that exceeds the action level (which is LESS than the maximum allowable), you need to deal with it. They don't need to show that you DO exceed the action level to make your life difficult, only to fine you (though you can be fined for procedural and documentation issues even if you don't violate the standard)

    You may be able to establish without testing that the exposure is not likely to be exceed the action level based on standard data, but it isn't going to be easy if you deal with any stainless. Yes, they need to demonstrate that you have exceeded before you can be penalized (if they don't demonstrate this, your attorney will giggle like a schoolgirl on the way to court), but you don't want to go there. It is NOT cheap at that point. If there is concern expressed, you MUST test to avoid liability.

    The standards require that you establish that you test first. Initial sampling and testing to determine WHAT the potential exposure is easiest if you bring in someone with the right gear to do the job. The setup I am familiar with (not the only way) used a sampler on a belt clip pump sampler with a tube on a neck lanyard to hold the inlet end near the mouth and nose. Wear it for a shift and the collected sample is tested and the result is calculated based on how much air was drawn through the unit. I don't know what it cost, but a commercial service came in with the units and did the evaluation. It didn't break the bank. A set of parameters came out of this for which the action level should not be exceeded and no further testing is needed.

    The requirement is engineering controls if practical, PPE if engineering controls don't do the job, and testing after implementation to insure that the engineering controls/PPE do control the exposure.

  2. #22
    Join Date
    Jul 2008
    Location
    Oklahoma
    Posts
    56

    Default

    Quote 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.
    First, it appears that you could be exempt. Second, If you are not exempt, I would venture to guess that given the info, you might not exceed the PEL. Again, I would suggest getting ahold of OSHCON. It very well could be as simple as a phone call to them to confirm if you are or are not exempt. Worst case scenario, the will come set up a monitor and take samples, for free, with no report to OSHA one way or the other. Plus you will have a report from them to show this and any other inspector in the future.

    jrw159

  3. #23
    Join Date
    Sep 2002
    Location
    Clark County, NV
    Posts
    2,696

    Default

    You said you are the only weldor, but are there other employees?

  4. #24
    Join Date
    Nov 2007
    Posts
    19

    Default

    Quote Originally Posted by Bodybagger View Post
    I'm going to do a little math problem to show you what you're up against.

    ........


    So cutting, grinding, and stick welding will put you way over the PEL in a hurry. And drawing it out with negative pressure will put the people downwind above the PEL. But the PEL is so low that even TIG welding might do it.

    I'm glad I didn't pi$$ off whoever you pi$$ed off!
    Very good post. It's a much bigger problem by the numbers, than it seemed initially.

    I guess there two things that come up. One is OSHA and posters seem to think he's exempt.

    The second is just his own personal health. I'm sure BB wears steel boots, gloves, and safety glasses. His lungs need protection also. 'A little bit, once in a while' times 52 weeks times 40 years is a whole lot of exposure. Do you have any suggestions on where BBCHEVY396 should be starting to look for solutions that hopefully would also be low cost (CHEAP)

  5. #25
    Join Date
    Feb 2009
    Location
    Lodi, CA
    Posts
    1,254

    Default

    As I recall,,,, the people I have direct knowledge about, had to mount the suctions directly above the CNC table,,,,,, nobody cared too much about where the actual mig or tig welding was taking place.

    Second,,,, even if the guy is "self-employed" ...... what's the business structure???? If he incorporated,,,, he is now technically an "employee" ,,,, and all OSHA, MSHA, etc. regulations now apply.

  6. #26
    Join Date
    Jul 2008
    Location
    Oklahoma
    Posts
    56

    Default

    BB,
    Any updates on this issue?

    jrw159

  7. #27

    Default

    Quote Originally Posted by Broccoli1 View Post
    "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

    BigBlockChev is surely dealing with WISHA, our state's slightly more onerous version of OSHA. Like OSHA, WISHA has the job of protecting employees, not single proprietors. A couple of small employers I know have found the State people very reasonable and easy to work with, so I'd like to know the name of this industrial hygenist (PM me if you don't want to put it out here, BigBlock). Meanwhile, if WISHA does apply to you, make the guy bring you the relevant documentation, and tell him he also has to prove you're in violation. The bullying kind of inspector usually doesn't want to do any work, and will likely forget you and go bully someone else.

  8. #28
    Join Date
    Feb 2010
    Location
    Winnipeg
    Posts
    29

    Default Thanks for the calculations

    Quote Originally Posted by Bodybagger View Post
    I'm going to do a little math problem to show you what you're up against.

    The PEL for Cr[VI] is 5 micrograms/m^3.

    Lets plasma cut a 1/8" thick sheet of 304SS.

    304SS is 18-20% Chromium. We will assume it is 19% for the calculation.

    We will also assume that in the plasma arc, all metalic chromium is oxidized to the +6 valence. We will use a 1/8" kerf for the calculations as well.

    SS has a density of 8000kg/m^3 or 8g/CC. So each CC of stainless has 19% of 8g, or 1.52g chromium.

    A cut 1/8" thick by 1/8" wide is .32cmx.32cm. To get 1CC, the cut needs to be 1/(.32^2) or 9.76cm long. This is 3.84" long. This is how long the cut must be to vaporize 1 CC of stainless (which vaporizes 1.52g of chromium).

    1.52 grams is 304,000 times 5 micrograms, so you'd need to dilute it in 304,000 cubic meters of air to meet the PEL of 5ug/m^3.

    Assuming 16' tall ceilings (4.88m), the empty building of air needed to dilute this amount of chromium would have to be 62,300 sq meters or 671,000 sq feet. This is a 15.4 acre building with 16' high ceilings.

    Even if only 1% was oxidized to +6 and suspended in the air, you'd need 6,700 sq feet to dilute it to the PEL!

    And thats for cutting about 4" of 1/8" stainless.

    How much do you cut in a typical project? 10 feet? 100 feet?

    A football field (including end zones) is 360'x160'. If you cut 100 feet of 1/8" stainless, and only 1% stayed airborne, you'd need the air contained over 36.4 football fields with a 16' ceiling to dilute it to the PEL.

    So cutting, grinding, and stick welding will put you way over the PEL in a hurry. And drawing it out with negative pressure will put the people downwind above the PEL. But the PEL is so low that even TIG welding might do it.

    I'm glad I didn't pi$$ off whoever you pi$$ed off!
    ,

    man ,I'm about to start a small stainless project in the garage (with doors open), and your calculations really put things into perspective, I thought I would be fine with the natural ventilation from the open garage door, but I'm thinking about getting at least a half-facemask respirator now. The concentration of hexavalent chromium is very likely higher near the site of welding as well.

  9. #29

    Default

    Although some of these laws are well intentioned, the end result is the destruction of our country. Bureaucrats are moving at full speed to regulate citizens and businesses every move as well as adding costs from taxes, fees, and continous new regulations.

    Just look at the new law for 1099's that was hidden in the health care bill. It will require all businesses to give a 1099 to any individual or corporation that they buy $600.00 of goods or services from in a year. Just think, the next time you go to Costco and buy a computer for your business you will need you will need to collect Costco's tax payer id and provide them as well as the IRS with a 1099 at years end.

    http://money.cnn.com/2010/05/05/smal...ange/index.htm

    With all the taxes, fees and regulations it is nearing the point where there is no incentive to be in business unless perhaps you are a major corporation.
    We are burdened with the cost of being in business whether you make a profit or not.

    The prevailing attitude from bureaucrats and many members of the public seems to be that if you are in business you have deep pockets and can absorb any costs they impose on you. With the economy the way it is these costs could not come at a worse time.

    It is no surprise the US has problems competing. I have to wonder what the business landscape will look like in another 2 years.


    Big D
    Last edited by Big D; 05-26-2010 at 08:04 AM.
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  10. #30
    Join Date
    Mar 2010
    Posts
    485

    Default

    I have to wonder what the business landscape will look like in another 2 years.
    Like a bunch of folks trying to skirt every idiotic law since the government imposing them has forfeited all moral authority and citizens should no longer confuse loyalty to government (whose job is to serve the country) with loyalty to the country it no longer serves.

    Thank Obama, those who elected him, and those who would have voted against him but ignored their civic duty and stayed home.

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