Inorganic Arsenic Compliance Plan — 29 CFR 1910.1018
Written compliance plan for inorganic arsenic exposure. PEL 10 µg/m³ TWA; Action Level 5 µg/m³. Covers primary metal smelting (copper/lead/zinc), legacy wood preservation operations, glass and ceramic manufacturing, and other arsenic-handling operations.
When this template is required
Required wherever inorganic arsenic exposure occurs. PEL: 10 µg/m³ 8-hour TWA; Action Level: 5 µg/m³. Inorganic arsenic is a Group 1 carcinogen (lung, skin, bladder). Sources include: primary copper/lead/zinc smelting (arsenic byproduct), wood preservation (legacy CCA), pesticide manufacturing (legacy), glass and ceramic manufacturing.
Why this template
Group 1 carcinogen — multiple tumor sites
Inorganic arsenic is unusual in causing cancer at multiple sites: lung (inhalation), skin (dermal/ingestion), bladder (ingestion). Worker exposure is primarily lung-cancer risk.
Smelter focus
Primary copper smelting is the dominant US arsenic exposure scenario. Copper ores contain arsenic; smelting concentrates it in flue dust and byproducts. The plan addresses smelter operations.
Skin cancer surveillance
Chronic low-level arsenic exposure causes characteristic skin changes (hyperkeratosis, hyperpigmentation) and skin cancer (squamous cell, basal cell, Bowen's disease). Medical surveillance includes dermatologic evaluation.
Legacy wood preservation
Chromated copper arsenate (CCA) wood preservation was banned for most residential uses in 2003 but continues for some industrial applications. Legacy CCA facilities still require compliance.
What you receive
- Inorganic Arsenic Compliance Plan (Word .docx) — written program per (d)-(n)
- Initial exposure determination procedure (PEL: 10 µg/m³; Action Level: 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 (examination by or under the supervision of a licensed physician, 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 and medical records: at least 40 years, or duration of employment plus 20 years, whichever is longer)
- Smelter-specific engineering controls
- Skin cancer screening protocol (chronic arsenic effect)
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
- Primary copper smelting (arsenic is a copper ore byproduct)
- Primary lead and zinc smelting
- Legacy CCA wood preservation operations
- Glass manufacturing (specific applications)
- Ceramic manufacturing (some pigments and glazes)
- Semiconductor manufacturing (specific compounds)
Frequently asked
Who's currently covered by the arsenic standard?
Primary copper, lead, and zinc smelters are the largest exposed population. Legacy CCA (chromated copper arsenate) wood preservation operations — though largely phased out for residential, still continuing for industrial poles, marine, and structural applications. Glass and ceramic manufacturing with specific arsenic compounds. Semiconductor manufacturing with arsine and arsenic compounds (though the gallium arsenide industry is small). Recent OSHA enforcement has focused on copper smelters and battery recycling (where lead processing generates arsenic byproducts).
What's the difference between inorganic and organic arsenic?
Inorganic arsenic — arsenic combined with elements other than carbon (arsenic trioxide, sodium arsenite, arsenic pentoxide, etc.). Highly toxic, carcinogenic. Covered by 1910.1018. Organic arsenic — arsenic combined with carbon (arsenobetaine, arsenosugars). Much less toxic; found naturally in seafood and not the regulated form. The standard covers only inorganic forms.
Is CCA wood preservation still legal?
Partially. EPA voluntary withdrawal in 2003 ended most CCA use for residential lumber. Industrial uses continue: utility poles, marine pilings, certain structural applications. Existing CCA wood remains in place. New CCA treatment operations continue with EPA registrations. The plan covers continuing CCA operations.
What's the medical surveillance protocol?
1910.1018(n) requires medical surveillance for employees exposed at or above the AL for 30+ days/year. Includes medical/work history; physical with particular attention to skin and respiratory tract; chest X-ray; urinary arsenic biological monitoring (when the examining physician determines appropriate); other tests as needed. Annual surveillance. Dermatologic evaluation for skin changes.
Are semiconductor operations covered?
Yes, when arsenic exposure exceeds the AL. Arsine gas (AsH3) handling, arsenic doping of silicon, and gallium arsenide production all can produce inorganic arsenic exposure. Semiconductor operations typically have well-engineered controls but still need 1910.1018 compliance documentation.