Hexavalent Chromium (Cr(VI)) Compliance Plan
Written compliance plan for Cr(VI) exposure — stainless steel welding, chrome plating, chromate paints, leather tanning, CCA wood preservation. All three parallel standards covered (1910.1026 general; 1926.1126 construction; 1915.1026 shipyard).
When this template is required
Required wherever hexavalent chromium [Cr(VI)] exposure occurs — stainless steel welding/cutting, chrome electroplating, painting with chromate paints, chromate-containing coatings, leather tanning, wood preservation (CCA), pigment manufacturing. PEL: 5 µg/m³ 8-hour TWA; Action Level: 2.5 µg/m³. Cr(VI) is a Group 1 carcinogen (lung).
Why this template
Triple standard coverage
Cr(VI) has three parallel OSHA standards (general industry, construction, shipyard) that closely mirror each other. The plan covers all three with crosswalk so a mixed-operations employer uses one plan.
Stainless welding fume
Stainless steel welding generates Cr(VI) at potentially significant levels — typical exposures during sustained stainless welding without effective LEV exceed the PEL. The plan includes the welding-specific trigger procedure.
Chrome plating controls
Chrome electroplating tanks generate Cr(VI) mist. Engineering controls (tank covers, push-pull ventilation, fume suppressants) are usually required to achieve the PEL. The plan documents the typical control package.
Group 1 carcinogen — substantial risk
IARC classifies Cr(VI) as Group 1 carcinogen (lung). The standard's exposure controls reflect the high risk; OSHA aggressively enforces Cr(VI) compliance.
What you receive
- Hexavalent Chromium [Cr(VI)] Compliance Plan (Word .docx) — written program per (d)-(n)
- Initial exposure determination procedure (PEL: 5 µg/m³; Action Level: 2.5 µg/m³)
- Air monitoring schedule (initial + periodic + change-triggered)
- Methods of compliance — engineering & work practice controls hierarchy
- Respiratory protection program crosswalk (with 1910.134)
- Medical surveillance protocol (PLHCP examination, blood/biological tests as applicable)
- Regulated area designation procedure (where exposures exceed the PEL)
- Housekeeping and hygiene procedures
- Employee training outline (annual refresher requirement)
- Recordkeeping requirements (exposure: 30 years; medical: employment + 30 years)
- Stainless welding trigger task assessment
- Chrome electroplating engineering controls (covers, exhaust)
- Aerospace painting exemption documentation (where applicable)
How you get it
This document is written and reviewed against the standard it cites, and it is ready now. The download link is emailed as soon as your payment clears.
Revisions included — if something about your operation changes what the document should say, reply to the delivery email and we will amend it.
Who buys this
- Stainless steel and chromium alloy welding shops
- Chrome electroplating facilities (decorative and hard chrome)
- Painting contractors using chromate primers
- Leather tanning operations
- CCA wood preservation facilities
- Aerospace and aviation maintenance (chromate primers, hard chrome)
- Cement and refractory manufacturing
Frequently asked
When does Cr(VI) exposure occur in welding?
Welding any material containing chromium can generate Cr(VI). Stainless steel typically contains 16-26% chromium; high-chrome carbon steels (Cr-Mo, Cr-V) contain 1-9%. Welding processes that aerosolise the base metal (MIG, TIG, stick, FCAW) generate Cr(VI) fume. Plasma cutting and gouging are particularly high-emission. Typical sustained stainless welding without effective LEV produces exposures above the 5 µg/m³ PEL.
What about decorative vs. hard chrome plating?
Decorative chrome plating (thin chrome layer for appearance) operates at lower current densities and shorter cycle times — typical exposures are lower but still often above the AL. Hard chrome plating (thick chrome layer for wear resistance) operates at much higher current densities and longer cycles — exposures routinely exceed the PEL without effective controls. Both are covered; the plan documents the typical control package for each.
Are aerospace painting operations exempt?
Partially. 1910.1026(f)(1)(ii) provides a limited exemption for certain aerospace painting operations from the engineering controls requirement, allowing reliance on respirators to achieve the PEL — recognizing the difficulty of engineering controls for large aircraft painting. The exemption has specific eligibility criteria; the plan documents the criteria and the alternative requirements.
What's the connection to welding rod manufacturing?
Welding rod manufacturers must produce rods with disclosed Cr(VI) content per the HazCom standard. Many low-Cr alloys (carbon steel) still produce small but measurable Cr(VI) fume. The plan includes the procedure for getting welding rod Cr(VI) data from manufacturers (typically in SDS or technical data sheets).
What's the medical surveillance protocol?
1910.1026(i) requires medical surveillance for employees with exposure above the AL for 30+ days/year, OR experiencing signs/symptoms of Cr(VI) effects (skin/respiratory irritation, nasal septum issues), OR exposed during emergency. Examination includes: medical/work history (lung, skin, respiratory tract focus); physical exam (nostrils, respiratory, skin); other tests as PLHCP indicates. No specific biomonitoring is required (unlike lead and cadmium) — Cr(VI) doesn't have a reliable blood/urine biomarker for chronic exposure.