ASSE: Not Enough Scientific Evidence to Support Proposed Hex Chrome Exposure Limit

American Society of Safety Engineers (ASSE) President Gene Barfield, CSP, has sent a letter to OSHA lauding the agency for its efforts to update the permissible exposure limit for hexavalent chromium but adding that more scientific evidence is needed to support the proposed standard.

In his letter to OSHA, Barfield said that hexavalent chromium (CR[VI] or Hex Chrome) is a risk to employees at the current permissible exposure limit (PEL), and that an update is needed to reduce the risks employees exposed to Hex Chrome face in developing lung cancer, asthma and damage to the nasal epithelia and skin.

"However, ASSE does not believe that enough scientific evidence exists at this time to support the 8-hour time-weighted average permissible exposure limit of 1 microgram of Cr(VI) per cubic meter of air (1 µg/m3) for all Cr(VI) this rulemaking would set," Barfield wrote. "While our members fully agree a new, more stringent standard is needed, they believe additional research is needed before this or any specific standard can be supported."

Still, Barfield said that when the standard moves forward, requirements for the highest level of professional safety and health management are needed to meet the complexity of the risks posed by Hex Chrome. Those risks require establishing sophisticated engineering and work practice controls; ensuring proper provision and use of personal protective equipment (PPE); managing hazards communication; extensive recordkeeping; and appropriate training. Each factor, Barfield noted, is vitally important to managing the difficult risk associated with Hex Chrome and should, at the very least, call for the oversight of a safety professional with appropriate experience and education.

To increase safety, Barfield urged future rulemaking to include the mandate that these activities be administered under a required safety and health management plan prepared by a safety professional with a voluntary certification accredited by the industry-recognized and accredited certifying bodies Council on Engineering and Scientific Specialties Board (CESB) or National Commission on Certifying Agencies (NCCA). At this time, environmental safety and health designations that fit this requirement are Certified Safety Professional (CSP), Certified Industrial Hygienist (CIH) and Certified Hazardous Materials Managers (CHMM).

Barfield also expressed concern that the proposed standard's requirements for the construction industry will be less effective than those proposed for general industry.

"ASSE's members in the construction industry are deeply concerned that the proposed standard for Hex Chrome 'has no teeth and therefore will not benefit our industry,'" Barfield said. "They believe the standard for the construction industry should have the same medical testing, exposure monitoring and training requirements as the general industry standard. One member stated, 'If the proposed construction standard remains unchanged, there will be no compliance in the construction industry and therefore no benefit to the workers who are supposed to be protected.'"

Barfield commended OSHA for recognizing throughout the standard that effective training is an essential element to any program. He said ASSE urges reference to ANSI Z490.1 standard, "Criteria for Accepted Practices in Safety, Health and Environmental Training," which provides employers who hire safety and health trainers useful guidance in ensuring they receive the value and effectiveness they need from such training.

Barfield's letter addressed other concerns, including:

  • The need to address exposure risks from water-soluble Hex Chrome;
  • The need for employers to be solely responsible for providing protective clothing and equipment as well as laundering, cleaning, maintaining and disposing of such equipment;
  • That OSHA should reference in any future Hex Chrome rulemaking the ANSI Z87 Standard entitled, "Safety Requirements for Protection of Faces and Eyes of Persons in Occupational, Educational, Recreational and Sports Activities."

For more information and a full copy of the comments, visit ASSE's web site at

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