OSHA Instruction CPL 2-2.26A September 5, 1980 Office of Compliance Programming

SUBJECT: 29 CFR 1910.1000, Table Z-2, Citation Policy for Chromates and Chromic Acids

A. Purpose. This instruction provides guidance for citing violations resulting from employee exposure to chromates, dichromates and chromic acid mist.

B. Scope. This instruction applies 0SHA-wide.

C. Cancellation. OSHA Instruction CPL 2-2.26, December 10, 1979, is canceled.

D. Action. OSHA Regional Administrators and Area Directors shall assure that violations resulting from employee exposure to chromates be cited as follows:

1. Cite violations resulting from employee exposure to lead chromate and dichromate under the lead standard, 29 CFR 1910.1025.

2. Cite violations resulting from employee exposure to zinc chromate and dichromate as well as other chromates and dichromates under 29 CFR 1910.1000, Table Z-2 (PEL 0.1 mg/m3).

E. Federal Program Change. This instruction describes a Federal program change which affects State programs. Each Regional Administrator shall:

1. Ensure that this change is forwarded to each State designee.

2. Explain the technical content of the change to the State designee as requested.

3. Ensure that State designees are asked to acknowledge receipt of this Federal program change in writing, within 30 days of notification, to the

OSHA INSTRUCTION CPL 2-2.26A SEPT. 5, 1980 OFFICE OF COMPLIANCE PROGRAMMING

Regional Administrator. This acknowledgment should include a description either of the State's plan to implement the change or of the reasons why the change should not apply to that State.

4. Review policies, instructions and guidelines issued by the State to determine that this change has been communicated to State program personnel. Routine monitoring activities (accompanied inspections and case file reviews) shall also be used to determine if this change has been implemented in-actual performance.

F. Background.

1. OSHA has been citing all violations resulting from employee exposure to chromic acid mist, or dust from chromates and dichromates under 29 CFR 1910.1000, Table Z-2.

2. Certain chromate compounds are suspected to be carcinogenic, and since no safe levels of exposure to carcinogenic substance have been demonstrated, it has been OSHA's policy to attempt to minimize worker exposure to them to the greatest extent feasible.

3. The comprehensive standard for occupational exposure to lead is also applicable to lead chromate, and would provide greater protection to workers exposed to lead chromate than would be provided under the chromates standard. By instructing compliance officers to cite violations under the new lead standard, 29 CFR 1910.1025 (PEL 50 ug/m3), the permissible exposure to lead chromate is, in effect, lowered to less than 25 percent of what the chromates standard (29 CFR 1910.1000, PEL 0.1mg/m3) would allow. Thus, it becomes unnecessary and administratively burdensome to cite for violations of the chromates standard as well. The lead standard contains many additional

OSHA INSTRUCTION CPL 2-2.26A SEPT. 5 1980 OFFICE OF COMPLIANCE PROGRAMMING

protective provisions not found in the provisions applicable to chromates, such as exposure monitoring, medical surveillance, medical removal protection, and worker training and education.

Bruce Hillenbrand Acting Director, Federal Compliance and State Programs

DISTRIBUTION: National, Regional and Area Offices All Compliance Officers State Designees NIOSH Regional Program Directors

Page 3