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Model Hexavalent Chromium Program PDF Print E-mail

The Mechanical Contractors Association of America’s (MCAA) new Model Hexavalent Chromium Program was developed by the Safety and Health Committee in response to OSHA’s Hexavalent Chromium Standard, which came into effect for larger employers in November. 

Hexavalent Chromium is a heavy metal component of stainless steel that can increase the risk of lung cancer in humans if inhaled in significant concentrations. Hexavalent Chromium is sometimes referred to as Chromium (VI) or hex chrome. The major concern in the mechanical construction industry is over exposure to hexavalent chromium from fumes created by welding or torch cutting on stainless steel pipe and ducts. 

The Occupational Safety and Health Administration (OSHA) issued a standard in February 2006 to protect workers from over-exposure to hexavalent chromium. Although the standard was issued because of a court order concerning general industry applications, OSHA opted to make the general industry-based standard applicable to the construction industry. As a result, MCAA set out to prepare its members to comply with the standard. 

MCAA’s Safety and Health Committee developed and produced the (itals)Model Hexavalent Chromium Compliance Program (enditals) to help mechanical construction companies comply with the standard, and meet increasing owner/prime contractor demands for written hexavalent chromium compliance programs. 

Although the MCAA standard doesn’t require employers to establish written hexavalent chromium programs, many owners, construction managers and general contractors are requiring them. Effective dates are as follows:

  • For employers with 20 or more employees (except engineering control requirements) – November 27, 2006;
  • For employers with fewer than 20 employees (except engineering control requirements) – May 30, 2007;
  • Engineering control requirements for all employers – May 31, 2010.


As a mechanical industry employer who is affected by the standard, you have two options regarding the determination of worker exposure levels to hexavalent chromium. Compliance requirements are dictated by the exposure levels: 

  • Option 1 – Conduct air monitoring to determine worker exposure levels to hexavalent chromium, and implement appropriate protective measures when necessary.
  • Option 2 – Use any combination of air monitoring, historical data and objective data to determine worker exposure levels to hexavalent chromium, and implement appropriate protective measures when necessary.

MCAA’s (ITALS)Model Hexavalent Chromium Compliance Program (enditals) includes two model programs, one for each of the options listed above. Also included is a summary of the OSHA standard, information to help you choose the option that’s right for your company, and a handy air monitoring checklist. 

MCAA is in the process of collecting air monitoring data covering hexavalent chromium exposure in the mechanical construction industry. MCAA believes that the data may allow mechanical construction companies to use a combination of historical and objective data in lieu of costly air monitoring on every project. 

OSHA’s Hexavalent Chromium Standard allows employers to use a combination of historical and objective data instead of air monitoring provided that the previous air monitoring methods used to establish the data are within an accuracy range of 25 per cent and produce confidence levels of 95 per cent for the concentrations of hexavalent chromium above OSHA’s established Action Level. MCAA believes the data would apply only to buildings or structures that are under construction, but it would likely exclude high purity welding procedures. However, companies with well-ventilated pre-fabrication shops could establish their own combinations of historical and objective data to potentially forgo regular air monitoring requirements. 

The Safety and Health Committee will evaluate the collected data to determine whether exposure levels are consistently low enough to justify the use of combination data, and whether it meets the requirements of the standard. If the committee determines that more air monitoring data is needed, it will likely recommend to MCAA that it conduct the monitoring in early 2007. If your company has conducted air monitoring for hexavalent chromium and would be willing to share it with MCAA, contact Pete Chaney at This e-mail address is being protected from spam bots, you need JavaScript enabled to view it or call 1-800-556-3653. 

To order the Model Hexavalent Chromium Compliance program, visit MCAA’s online store at or call Linda Burke at (301) 990-2200. The program cost is $18 (U.S.) for MCAA members and $36 for non-members, plus shipping. Volume discounts are available.


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