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HEXAVALENT CHROME PEL PAGE
Questions? Ask the PEL expert.
On February 28, 2006,
OSHA published a final
rule for a hexavalent chromium permissible exposure limit (PEL) that
applies to the metal finishing industry and other sectors. The
new limit is 5.0 micrograms per cubic meter (µg/m3)
(as CrO3) with an action level of 2.5 µg/m3 (as
CrO3). Â It applies to all forms of hexavalent chromium,
including chromic acid and chromates, lead chromate, and zinc chromate.Â The
new PEL is significantly lower than the level under which industry
has been operating: 52 µg/m3 (as CrO3).
As part of the new rule,
OSHA published other ancillary provisions for employee protection
such as preferred methods for controlling exposure, respiratory
protection, protective work clothing and equipment, hygiene areas
and practices, medical surveillance, hazard communication, and
to comply with requirements of the final rule are as follows:
or Fewer Employees
or More Employees
except engineering controls.
*Under a settlement agreement with OSHA,
companies that "opt-in" by November 27, 2006, would not have
to put employees exposed over the PEL in respirators in exchange
for accelerated implementation of engineering controls (12/31/08).
What is a PEL?
A permissible exposure
limit (PEL) is an occupational exposure limit established by OSHA's
regulatory authority. It may be a time-weighted average (TWA) limit
or a maximum concentration exposure limit (i.e., ceiling). About
600 of the most common chemicals have PELs; including chromium.
Why did OSHA Lower the
Hexavalent Chromium PEL?
OSHA is operated under
a court-ordered deadline. Here is a summary of what transpired:
Is a Lower PEL Really
- In 1993, Public Citizen's
Health Research Group (HRG) and the Oil, Chemical and Atomic
Workers Union (OCAW, now PACE) petitioned OSHA to lower the PEL
to 0.5 µg/m3.
- OSHA denied the petition,
but determined that exposures at the permitted levels may result
in an excess risk of cancer.
- OSHA announced that
it would publish a rule on hexavalent chromium no later than
March 1995, but failed to do so.
- In 1997, after OSHA's
continued inaction on the rulemaking, HRG and OCAW sued to force
OSHA to take action. Despite its statement that the existing
standard was inadequate to protect worker health, OSHA again
failed to complete the rulemaking, citing numerous reasons, including
competing agency priorities and uncertainty in the data.
- The Court dismissed
Public Citizen's request for action, concluding that the facts
did not demonstrate that OSHA's actions had been unreasonable.
OSHA was given a new deadline of September 1999, which it again
failed to meet.
- In February 2002,
Public Citizen again sued OSHA to force action on the matter.
- In December 2002,
the Court published a scathing opinion critical of OSHA's delay
and ordered mediation between the parties to assist the Court
in setting a reasonable and workable schedule for the hexavalent
- On April 2, 2003,
with the parties unable to agree on a rulemaking schedule, the
Court adopted the mediator's recommendation and directed OSHA
to publish a proposed hexavalent chromium rule no later than
October 4, 2004 and a final standard no later than January 18,
2006. The Court subsequently granted OSHA an extension to February
28, 2006 for publication of the final rule.
Most sources agree that
the PEL for hexavalent chromium should be lower; however, there
is disagreement on how low is necessary.
The major illnesses associated
with hexavalent chromium are dermatoses and lung cancer. The current
OSHA PEL for these compounds was adopted from a 1943 ANSI Standard.
The justification for the ANSI Standard is based on 1924 and 1928
reports on the non-malignant effects (dermatitis and skin ulceration
and perforations of the nasal septum) of chromium compounds. The
current PEL does not take into account cancer risks of exposure
to hexavalent chromium. Evaluations by the California Department
of Health Services, the U.S. Environmental Protection Agency, and
the U.S. Agency for Toxic Substances and Disease Registry indicate
that the risk of lung cancer to exposed workers is significant.
In 1993, Public Citizen's
Health Research Group (HRG) and the Oil, Chemical and Atomic Workers
Union (OCAW, now PACE) petitioned OSHA to lower the PEL to 0.5 µg/m3.
A report published by an industry group contractor suggested, among
other alternatives, that OSHA consider a Cr+6 PEL of
44 µg/m3 (time-weighted average).
- NIOSH Issues Chromium Assessment and New Limit. On January 24, 2013, the National Institute for Occupational Safety and Health (NIOSH) posted a document entitled Criteria for a Recommended Standard: Occupational Exposure to Hexavalent Chromium in which NIOSH reviews the critical health effects studies of hexavalent chromium compounds to update its assessment of the potential health effects of occupational exposure to hexavalent chromium compounds and its recommendations to prevent and control these workplace exposures. The document provides a new Recommended Exposure Limit (REL) of 0.20 µg/m3 for workplaces.
Rule, Federal Register: November 28, 2006 (Volume 71, Number
Rule, Federal Register: October 4, 2004 (Volume 69, Number
- OSHA Safety and Health
Topics: Hexavalent Chromium
- Jack Faucett Associates,
Alternatives To OSHA's Draft Proposed Hexavalent Chromium Standards
For General Industry, Maritime Operations, and Construction,
Final Report (prepared for the U.S. Small Business Administration,
Office of Advocacy), March 29, 2004.