Lincoln Electric Welding Fume Control warranty Regulatory Assessment, Exposure Determination

Welding Fume Control Methodology

This information is abstracted from OHSA’s document enti- tled "Small Entity Compliance Guide for the Hexavalent Chromium Standards", OSHA 3320-10N 2006. (http://www.osha.gov/publications/osha_small_entity_comp.pdf)

Employers are responsible for providing a safe and healthful workplace for their employees. OSHA’s role is to assure the safety and health of America’s employees by setting and enforcing standards, providing training, outreach and educa- tion; establishing partnerships; and encouraging continual improvement in workplace safety and health.

Methods of Compliance: Engineering & Work Practice Controls (1)

Welding Fume Control Methodology

To thoroughly explore your welding fume control options, you should clearly identify and assess your actual needs and oper- ating conditions. The following Welding Fume Control Methodology, along with your Lincoln Electric Technical Sales Representative, can help you through this process, as he or she can bring expertise and resources to assist you as you go through this process.

A.Engineering Controls

1.Substitution:

Is it feasible and practical to modify or replace your current welding process, consumable, gas, welding procedure or equipment technology with an alternative process,

Lincoln Electric’s Suggested

Welding Fume Control Methodology

Regulatory Assessment	Have you determined potential employee exposure to hexavalent chromium
			NO	Employer
	from the welding consumable, base material and coating?
				Exposure
		YES
				Assessment

Employers must use Engineering and Work Practice Controls as the primary means to reduce and maintain employee expo- sures for Cr(VI) to or below the PEL, unless the employer can demonstrate that such control measures are not feasible.

A.	Engineering Controls: include substitution,
	isolation and ventilation.
B. Work Practice Controls: involve adjustments in the
	way a task is performed, as well as the periodic
	inspection and maintenance of engineering control
	equipment. In many cases, work practice controls
	complement engineering controls in providing
	employee protection.
C.	Personal Protection Equipment: When engineering

consumable, gas, welding procedure or equipment technol- ogy that generates less welding hexavalent chromium.

2. Isolation

Is it feasible and practical to isolate and separate your welding operation by moving it to a regulated area, by automating/ventilating the welding process and/or by placing a barrier between the employee and the source?

3. Ventilation:

Is it feasible and practical to control the welding fume path between the source and the worker through source, local and/or general shop extraction/ventilation equipment?

B. Safe Work Practice Controls

Exposure Determination	Is there any potential employee exposure to hexavalent chromium
			NO
	above the OSHA PEL?
		YES

Engineering Controls
1. Substitution	Is it feasible and practical to replace your current welding process, consumable,
	gas, welding procedure or equipment technology with an alternative process,
	consumable, gas, welding procedure or equipment technology that can
	generate less hexavalent chromium?

Employer

Periodic

Assessment

and work practice controls cannot reduce employee

exposure to within the PEL, employers must provide

respirators. OSHA’s Methods of Compliance states that:

"If feasible engineering and work practice controls are not sufficient to reduce employee exposure to or below the PEL, then the employer must use them to reduce the exposure to the lowest level achievable before using respirators. Respirators must then be used to reduce employee exposure to or below the PEL." (2)

Respirators are required during the period necessary to install or implement feasible engineering controls (by May 31, 2010) and during maintenance, repair and emergency situations.

No one solution will fit all applications. Solutions frequently involve one or more methods of control to properly and ade- quately control employee exposure.

Safe work practices complement each level of Engineering Controls and are designed to control the manner in which work is performed. These practices include such areas as safe welding habits (keeping your head out of the fumes, keeping fumes and gases away from your breathing zone and proper training & use of fume extraction equipment) as well as general housekeeping and general administrative procedures such as performing maintenance off shift to minimize potential exposure.

C. Personal Protective Equipment (PPE)

An important method of protecting employees in certain situations can be the use of PPE, including respirators; which require an initial employee medical evaluation, more frequent evaluation of worker exposure levels, training and recordkeeping.

In addition, the OSHA PPE evaluation may determine the need for additional personal protection practices,

2.Isolation

3.Ventilation

Safe Work Practice Controls

Is it feasible and practical to isolate and separate your welding operation by	YES
moving it to a regulated area, by automating/ventilating the welding process
and/or by placing a barrier between the employee and the source?

Is it feasible and practical to control the welding fume path between the source and the worker through source, local and/or general shop extraction/ventilation equipment?

Is it feasible and practical to lower exposure to hexavalent chromium by use of safe work practice and/or administrative controls?

NO

Feasible &	YES	Below	YES
Practical		PEL
NO		NO

Note (1): Small Entity Compliance Guide for the Hexavalent Chromium Standards, Pages 9, 10 and 11, OSHA 3320-10N 2006

Note (2): a) November 27, 2006 for employers with 20 or more employees.

b)May 31, 2007 for employers with 19 or fewer employees.

including specific requirements for additional work clothing & equipment, as well as the need for a separate change room, shower and laundering service. (3)

Note (3): see Small Entity Compliance Guide for the Hexavalent Chromium Standards OSHA 3320-10N 2006 for further details and references regarding compliance.

Personal Protective Equipment	Can the employee be protected from hexavalent chromium by use
			YES
	of a respirator?
		NO		Important Compliance Note: Employers must refer to applicable
				OSHA and state regulations for specific legal requirements.
				This information should be used for informational purposes only.

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