Contact: Paula Weis
(202) 974-5282

FOR IMMEDIATE RELEASE

SPI COMMENTS ON HEXAVELENT CHROMIUM EXPOSURE
OSHA Proposal has Widespread Impact on Plastics Industry

WASHINGTON (January 10, 2005) - In extensive comments submitted to the U.S. Occupational Safety and Health Administration (OSHA) last week, The Society of the Plastics Industry, Inc. (SPI) asked the Agency to consider including changes in its Proposed Rule on Occupational Exposure to Hexavelent Chromium (CrVI) to accommodate the needs of small business and the plastics industry. SPI was one of more than 230 organizations to comment on the proposal.

The proposed rule, which would lower the permissible exposure limit from 52 micrograms to one microgram of CrVI per cubic meter of air, was published in the October 4, 2004, Federal Register. OSHA, under a court-ordered deadline to finalize the standard by January 18, 2006, identified plastic colorant manufacturers and users among those industry groups that are most affected by the proposal. The proposal is of significant concern to nearly every sector of the plastics industry because chrome +6 exposure can occur via:

• Use of hexavalent chromium-containing pigments used in colorants for plastics;



• Trace amounts of hexavalent chromium-containing pigments in mixed and blended pigments;



• Welding of stainless steel or other high chromium steels - i.e., welding operations associated with maintenance or construction; and



• Chrome plating of plastic substrates.

"A significant portion of welding activities in plastics facilities are performed by contract welders who are likely to have more than 30 days per year of ambient exposures above the permissible exposure limit (PEL)," said Susan Howe, SPI's senior technical director of worker health & safety. "This means that either directly or indirectly, the plastics industry will bear the costs of any required engineering controls."

In its comments, SPI applauds OSHA's proposal to allow the use of respirators as an effective means of compliance where employees' exposure above the proposed PEL does not exceed 29 days per year. The trade association calls this provision "especially practical" for plastics facilities where spot welding activities are performed for short periods of time throughout the year. SPI is encouraging OSHA to expand this exclusion to 59 days and to consider setting separate engineering control air limits ("SECALS") that allow the use of respirators. OSHA's proposed engineering controls, however, will place a significant burden on the plastics industry. SPI estimates the cost of one recommended control device to fall in the range of $90,000.

In addition, SPI asks OSHA to:

• Undertake outreach on OSHA's hazard communication and personal protective equipment standards as they apply to dermal exposure to CrVI for general industry, rather than require clean rooms, storage facilities, washing facilities and separate eating and drinking areas at worksites where CrVI is present. The U.S. Small Business Advocacy Review Panel estimates a clean room facility for 20 employees would cost nearly $50,000. Such an expense would place an undue burden on many small employers.



• Forego proposed action level requirements for general industry if OSHA intends to exempt identical activities performed in the construction industry from these requirements.



• Allow facilities more time to coordinate compliance with their air permitting needs and to provide more than 90 days to implement and meet other requirements in the proposed rule.



• Extend the exclusion for portland cement operations in the construction industry to general industry maintenance activities where the same types of exposures to portland cement occur on a much smaller scale.



• Specifically exclude CrVI generated by welding from all provisions of the rule not directed at inhalation hazards, to better reflect OSHA's determination that welding poses only CrVI inhalation hazards.

"While we understand the time constraint that OSHA is under to finalize the proposed standard, we sincerely hope that they will consider and incorporate SPI's input with respect to the effects this proposal would have on the plastics industry," said Howe. OSHA can and should craft a regulatory system that works to the benefit of all, she said. "We want this to be a win-win for both the plastics industry and the workplace."

Founded in 1937, The Society of the Plastics Industry, Inc., is the trade association representing one of the largest manufacturing industries in the United States. SPI's members represent the entire plastics industry supply chain, including processors, machinery and equipment manufacturers and raw materials suppliers. The U.S. plastics industry employs 1.4 million workers and provides nearly $310 billion in annual shipments. For more information, visit SPI on the Web at www.plasticsindustry.org.

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