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OSHA Hexavalent Chromium Rule
June 25, 2010 RE: OSHA Hexavalent Chromium Rule To the Environmental, Health, & Safety Manager: This letter is in reference to the final rule recently published by OSHA stating that employees must be notified of all Hexavalent Chromium exposure in the workplace. Under the new rule, effective June 15, 2010 – employers are required to provide their employees with this information even if Hexavalent Chromium levels are below the Permitted Exposure Limit (PEL). As you may be aware, many (but not all) galvanizing companies utilize a Hexavalent Chromium Quench (Post Treatment) on products they galvanize. This post treatment is not called for in ASTM specifications and it does nothing to improve the galvanized coating. It does, however, prevent wet storage stain and allows the galvanized product to stay in a “shiny” state for a longer period of time. Eventually the Hexavalent Chromium washes off the material onto the ground and the material takes the characteristic dull gray appearance of weathered galvanized steel. My motivation for writing this letter to you is to make you aware of this rule so that you might evaluate if your organization is better off by requiring Hexavalent Chromium free products be delivered for use by your employees. Testing and monitoring for this unnecessary hazard would seem to be an unneeded expense. In some cases companies, like Tennessee Galvanizing, that do not use a Hexavalent Chromium quench system are excluded from galvanizing for certain companies; because the products do not stay “shiny” as long as our Hexavalent Chromium using competitor’s products do. Hot-Dip galvanizing is a superior form of corrosion protection and can play a prominent role in sustainable design and development. Hexavalent Chromium is not required and can be specified out of your purchases. Here is the weblink to OSHA’s Hexavalent Chromium final rule: http://osha.gov/pls/oshaweb/owadisp.show_document?p_table=NEWS_RELEASES&p_id=17769 For employers to properly check for Hexavalent Chromium on Hot-Dip Galvanizing, follow the procedures outlined in ASTM D6492-99 (2003) – Standard Practice For Detection of Hexavalent Chromium on Zinc and Zinc/Aluminum Alloy Coated Steel. Regards, David S. Ware, Sr.President/CEO
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