Standard Interpretations - Table of Contents
• Standard Number: 1910.1026; 1910.1026(h); 1910.1026(i)

February 23, 2011

Mike Harris
Hamlin & Harris, Inc.
1728 Cloverdale AVe.
Baton Rouge, LA 70808

Dear Mr. Harris:

Thank you for your November 11, 2010, letter to the Occupational Safety and Health Administration (OSHA), Directorate of Enforcement Programs (DEP).  You requested OSHA's interpretation of requirements related to the protection of employees who perform welding and are exposed to hexavalent chromium.  This letter constitutes OSHA's interpretation only of the requirements discussed and may not be applicable to any questions not delineated within your original correspondence.  Based on the discussion we had, your paraphrased question and our responses are below.

Question 1:  Do welders who are exposed above the permissible exposure limit (PEL) for hexavalent chromium (Cr(VI)) have to follow the requirements in the Cr(VI) standard for protective work clothing and equipment (29 CFR 1910.1026(h)) and hygiene areas and practices (29 CFR 1910.1026(i))?  If they do not, what are the applicable exceptions?
 
Response:  Section 1910.1026(h)(1), which addresses the provision and use of protective work clothing and equipment, states:

"Where a hazard is present or is likely to be present from skin or eye contact with chromium (VI), the employer shall provide appropriate personal protective clothing and equipment at no cost to employees, and shall ensure that employees use such clothing and equipment."

Section CFR 1910.1026(i)(1), which contains general requirements for hygiene areas and practices, states:

"General. Where protective clothing and equipment is required, the employer shall provide change rooms in conformance with 29 CFR 1910.141.  Where skin contact with chromium (VI) occurs, the employer shall provide washing facilities in conformance with 29 CFR 1910.141. Eating and drinking areas provided