September 12, 2011 at 11:49 AM

While you may be aware of OSHA’s National Emphasis Program (NEP), the Regional Offices have their priorities as well “the Local Emphasis Program (LEP).”  

Local Emphasis Programs (LEPs) are enforcement strategies designed and implemented at the OSHA regional office and/or area office levels. These programs are intended to address hazards or industries that pose a particular risk to workers in the office's jurisdiction. Often times, these LEPs will be accompanied by outreach intended to make employers in the area aware of the program as well as the hazards that the programs are designed to reduce or eliminate. 

One of Region 3’s Priorities pertains to Hexavalent Chromium (VI) “Chromium 6” Exposures.  The priority covers General Industry, as well as construction and shipyard workplaces.  The Cr(VI) standards have lowered the permissible exposure limit (PEL) to 5 μg/m3 of hexavalent chromium.  In addition, the standards established an action level for airborne concentrations of hexavalent chromium at 2.5 μg/m3.  Both the PEL and the action level are measured as 8-hour time-weighted average (TWA) exposures. 

The intent of the LEP is to target workplaces with potential employee exposures to Cr(VI) that cause (or are capable of causing) occupational illnesses while maximizing the Agency’s inspection resources.  Area Offices will add to the master list general industry, construction and shipyard employment establishments where Cr(VI) exposures exceeding the “Action Level” have occurred in the three years preceding the October 1, 2010 effective date of this directive.  

If an establishment has received a comprehensive health inspection which addressed Cr(VI) exposures since the effective date of the standard the establishment will be deleted from the list of establishments to be inspected.  In addition, based on local knowledge, Area Offices may delete establishments that do not have employee exposures to Cr(VI) or exposures are known to be less than the “Action Level” or the establishment is known to be out of business. Documentation for the basis for the determinations will be maintained. 

If any processes associated with Cr(VI) operations are present in the workplace, the CSHO shall proceed with the inspection with particular attention to employee exposure to Cr(VI).  

The CSHO should consider and evaluate employee exposures during any of the following:

• Regular operation of equipment.
• Setup and preparation for regular operations.
• Clearing upset conditions.
• Making running adjustments while the machine is operating.
• Cleaning of the machine.Scheduled/unscheduled maintenance.
• Engineering controls implemented.
• Personal protective equipment utilized.
• Medical surveillance programs.
• Exposure monitoring programs.
• Training and education of employees.

If there are no processes associated with Cr(VI) present in the workplace, the CSHO will exit the facility and code the OSHA-1 “No Inspection”.

The followng is a list of Representative industries which may be subject to inspection under this rule.

• NonClay Refractory Manufacturing 
• Glass Container Manufacturing
• Electromettalurgical Ferroalloy Product Manufacturing
• Steel Mills, Steel Foundaries and Copper Foundaries
• Fabricated Structural Metal, Sheet Metal, and Plate Work Manufacturing
• Many Others...  

A complete list is available in Guidance Document, Click Here. Still have questions, contact the Fairfax Compliance Group at info@fairfaxgrp.com or call 888.976.7799.

Please add a comment

Leave a Reply

Name:

Email:
(Your email will not be publicly displayed.)

Please type the letters and numbers shown in the image.