The Bedford, Texas-based Automotive Service Association (ASA), in its comments submitted to OSHA, says the agency needs to consider the potential financial impact of a new hexavalent chromium standard on its collision members.
"ASA asks the agency to re-evaluate the potential economic burdens for collision repairers if this proposed regulation were to move forward in its current form," the trade organization said in its comments to OSHA. "What is not entirely clear in the economic impact analysis of the proposal is whether the agency considered the cost of new equipment, the cost of physical alterations/additions, the cost of additional technical training and the cost of additional staff hours to comply with the proposed regulations, i.e. recordkeeping and medical monitoring."
The ASA's collision members use refinishing products in the repair of vehicles. Sanding of some vehicle parts, grinding and limited welding could also present opportunities for the proposed new exposure standard to be triggered.
"Collision repairers have taken a leadership role in establishing a voluntary national training organization, the Inter-Industry Conference on Auto Collision Repair (I-CAR), to assure that technical staffers have the most up-to-date repair and safety information available," the ASA said in its comments to OSHA. "ASA is the founder of the Automotive Management Institute (AMI), which encourages best management practices and workplace safety.
"ASA encourages the agency to fully evaluate the economic burdens placed on automotive repairers by this proposed regulation."
OSHA is proposing to lower its permissible exposure limit for hexavalent chromium (Cr[VI]) and for all Cr(VI) compounds in construction, shipyards and general industry from 52 to 1 microgram of Cr(VI) per cubic meter of air (1 µg/m3) as an 8-hour time weighted average. The proposed rule also includes 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 recordkeeping.
Cr(VI) compounds are widely used in the chemical industry in pigments, metal plating and chemical synthesis as ingredients and catalysts. Cr(VI) also can be produced when welding on stainless steel or Cr(VI)-painted surfaces. The major health effects associated with exposure to Cr(VI) include lung cancer; asthma; nasal septum ulcerations and perforations; skin ulcerations (or chrome holes); and allergic and irritant contact dermatitis, according to OSHA.