SMACNA commented that there does not appear to be sufficient research evidence to indicate that welding presents a likelihood of the significant hazards and exposures that may, or may not, be present in other industries that produce and use chromium including hexchrome. In addition, conducting this necessary research may prove difficult due to the many exposure variables in welding operations that would have to be tested.

Also, the relationship of hexchrome to lung cancer and other adverse health effects in welders has not been adequately identified and quantified, says SMACNA. In development of the proposed hexchrome standard, it is noted that OSHA relied heavily on two exposure studies of chrome production workers to estimate the lung cancer risk to all workers exposed to hexchrome. Neither study effectively provides a correlation between lung cancer and welders, the association says.

In seeking out more relevant research data, SMACNA suggests that OSHA resolve the issue of causes of lung cancer among welders including exposures to asbestos and tobacco smoke in relation to exposures to hexchrome or other chemicals in the welding process.

Additionally, many of the requirements addressed in the proposed standard are applicable through existing OSHA standards that pertain to welding, says the association. These standards include 1910 Subpart Q for Welding; 1910 Subpart I for PPE and Respiratory Protection; 1910.1200 for Hazard Communication; and 1910.146 for Confined Spaces. These standards provide a sufficient level of protection for workers, SMACNA says. However, the association supports OSHA conducting a public outreach program to assist employers by reminding them of these requirements and how those standards help address exposures to hexchrome.

Publication date: 01/24/2005