By now you have probably read several advisories regarding the Final Occupational Exposure Standard for Cadmium (57 Federal Register, dated September 14, 1992, page 42102). If your company performs cadmium plating, you probably have scrambled to comply with the initial exposure monitoring requirements, medical monitoring requirements and written compliance program requirements.

Buried in the final regulations (Section 1910.1027[m], page 42397 of 57 FR, dated September 14, 1992) are provisions that you might have overlooked, based on the number of calls we have been getting. The section is important enough to warrant a verbatim transcript:

From The Regulation:

(m) Communication of cadmium hazard to employees.

(1) General

In communications concerning cadmium hazards, employers shall comply with the requirements of OSHAs Hazard Communication Standard, 29 CFR 1910.1200, including but not limited to the requirements concerning warning signs and labels, material safety data sheets (MSDS), and employee information and training. In addition, employers shall comply with the following requirements:

(2) Warning Signs

(i) gaming signs shall be provided and displayed in regulated areas. in addition, warning signs shall be posted at all approaches to regulated areas so that an employee may read the signs and take necessary protective steps before entering the area.

(ii) Warning signs required by paragraph (m)(2)(i) of this section shall bear the following information:

DANGER

CADMIUM

CANCER HAZARD

CAN CAUSE LUNG AND KIDNEY

DISEASE

AUTHORIZED PERSONNEL ONLY

RESPIRATORS REQUlRED IN THIS AREA

(iii) The employer shall assure that signs required by the paragraph are illuminated,

cleaned, and maintained as necessary so that the legend is readily visible.

(3) Warning Labels

(i) Shipping and storage containers containing cadmium, cadmium compounds, or cadmium contaminated clothing, equipment, waste, scrap, or debris shall bear appropriate warning labels, as specified in paragraph (m)(3)(ii) of this section.

(ii) The warning labels shall include at least the following information:

DANGER

CONTAINS CADMIUM

CANCER HAZARD

AVOID CREATING DUST

CAN CAUSE LUNG AND KIDNEY DISEASE

(iii) Where feasible, installed cadmium products shall have a visible label or other indication that cadmium is present.

Labeling is Necessary

Some cadmium platers have received requests from their clients to label all shipments of cadmium plated parts in accordance with the OSHA standards. Other cadmium platers have received no such requests and are asking if labeling is really necessary.

The answer is "yes," it really is necessary. Furthermore, the regulations continue to emphasize that requirements of the OSHA Hazard Communication Standard (HCS) 29 CFR 1910.1200 must be complied with. The HCS has required Material Safety Data Sheets be provided to employers by manufacturers of hazardous materials since 1984.

As for the label, there are no guidelines for color scheme or size. One label developed by a plater is illustrated on the next page.

More difficult to interpret is paragraph (iii), which talks about installed cadmium products." Following a few phone calls to people who should know, the best Interpretation we can provide is that you are also required to label any equipment installed in your plant that you know contains cadmium, if it Is feasible to do so. Therefore, if you have equipment that you know contains cadmium, you must add the label to indicate "cadmium is present."

As for the Material Safety Data Sheet, the final standard contains some guidance about what the sheet should contain (excerpted from 57 FR, September 14, 1992):

A. Physical and Chemical Data

1. Substance Identification:

Chemical Name: Cadmium

Formula: Cd

Molecular Weight: 112.4

Chemical Abstracts Service (CAS) Registry No.7740-43-9

Other Identifiers: RETCS EU9800000; EPA D006, DOT 2570 53

Synonyms: Colloidal Cadmium; Kadmium (German); Cl 77180

2. Physical Data:

Boiling Point: 765 degrees C (760 mm Hg)

Melting Point: 321 degrees C

Specitic Gravity: (H20 = @ 20 degrees C) 8.64

Solubility: Insoluble in water; soluble in dilute nitric acid and in sulfuric acid.

Appearance: son blue-white, malleable, lustrous metal or grayish white powder.

Fire, Explosion, Reactivity Data

1. Fire and Explosion Hazards

The finely divided metal is pyrophoric, that is, dust is a severe fire hazard and moderate explosion hazard when exposed to heat or flame. Burning material reacts violently with extinguishing agents such as water, foam, carbon dioxide, and halons.

Flash Point: Flammable (dust) Extinguishing Media: Dry sand, dry dolomite, dry graphite, or sodium chloride.

2. Reactivity

Conditions Contributing to Instability:

Stable when kept in sealed containers under normal temperatures and pressure, but dust may ignite upon contact with air. Metal tarnishes in most air.

Incompatibilities:

Ammonium nitrate, fused: Reacts violently or explosively with cadmium dust below20degrees C. Hydrazoic acid: Violent explosion occurs after 30 minutes. Acids: Reacts violently, forms hydrogen gas. Oxidizing agents or metals: Strong reaction with cadmium dust. Nitrylfluoride at slightly elevated temperature: Glowing or white incandescence occurs. Selenium: Reacts exothermically. Ammonia: Corrosive reaction. Sulfur Dioxide: Corrosive reaction. Fire Extinguishing Agents (water, foam, carbon dioxide, halon): Reacts violently. Tellurium: Incandescent reaction in hydrogen atmosphere.

Hazardous decomposition products: The heated metal rapidly forms highly toxic brownish fumes of oxides of cadmium.

Spill Leak and Disposal Procedures

Steps to be taken if materials released or spilled: Do not touch spilled material. Stop leak if you can do it without risk Do not get water inside container. For large spills, dike spill for later disposal. Keep unnecessary persons away. Isolate hazard area and deny entry. The Superfund Amendments and Reauthorization Act of 1986, Section 304, requires that a release equal to or greater that one pound must be immediately reported to the local emergency planning committee, the state emergency response commission, and the National Response Center (800) 424-8802 (in Washington, DC, 426-2675).

Health Hazard Data

TWA PEL: Five micrograms of cadmium per cubic meter of air, time weighted average for an eight hour work day.

Routes of Exposure: Cadmium can cause local skin/eye irritation. Cadmium can affect you if you inhale it or if you swallow it.

Effects of Overexposure

1. Short term (acute) exposure: Cadmium is much more dangerous by inhalation than by ingestion. High exposures to cadmium that may be immediately dangerous to life or health occur in jobs where workers handle large quantities of cadmium dust or fumes; heat cadmium containing compounds or cadmium coated surfaces; weld with cadmium solders or cut cadmium containing materials such as bolts. Severe exposures may occur before symptoms appear. Early symptoms may include mild irritation of the upper respiratory tract, a sensation of constriction of the throat, a metallic taste or cough. A period of 1-10 hours may precede onset of rapidly progressing shortness of breath, chest pain, and flu like symptoms with weakness, fever, headache, chills, sweating, and muscular pain. Acute pulmonary edema usually develops within 24 hours and reaches a maximum by three days. If death by asphyxia does not occur, symptoms may resolve within a week

2. Long term (chronic) exposure: Repeated or long term exposure to cadmium, even at relatively low concentrations, may result in kidney damage and an increased risk of cancer of the lung and of the prostate.

Emergency/first Aid Procedures

1. Eye Exposure: Direct contact may cause redness and pain. Wash eyes immediately with large amounts of water, lifting the upper and lower eyelids. Get medical attention immediately.

2. Skin exposure: Direct contact may result in irritation. Remove contaminated clothing and shoes immediately. Wash affected area with soap and water or mild detergent and large amounts of water. Get medical attention immediately.

3. Ingestion: Ingestion may result in vomiting, abdominal pain, nausea, diarrhea, headache and sore throat .Treatment for symptoms must be administered by medical personnel. Under no circumstances should the employer allow any person whom he retains, employs, supervises, or controls, to engage in therapeutic chelation. Such treatment is likely to translocate cadmium from pulmonary or other tissue to renal tissue. Get medical attention immediately.

4. Inhalation If large amounts of cadmium are inhaled, the exposed person must be moved to fresh air at once. If breathing has stopped, perform cardiopulmonary resuscitation. Administer oxygen if available. Keep the affected person warm and at rest. Get medical attention immediately.

5. Rescue: Move the affected person from the hazardous exposure. If the exposed person has been overcome, attempt rescue only after notifying at least one other person of the emergency and putting into effect established emergency procedures. Do not become a casualty yourself. Understand your emergency rescue procedures and know the location of the emergency equipment before the need arises.