In comments submitted on behalf of its 4,500 contributing contractor firms, SMACNA explained that the proposed OSHA standard for hexchrome, as it relates to welding, is not based on good, sound, modern science or realistic economic data.

In support of this position, SMACNA noted that most of the studies, exposures, and data cited by OSHA relate to industries that manufacture, produce, or use hexchrome in forms that are far different from welding operations.

In fact, there does not appear to be sufficient research evidence to indicate that welding is a likely source of the significant hazards and exposures that may, or may not, be in other industries that produce and use chromium, including hexchrome. In addition, conducting this necessary research may prove difficult due to the many exposure variables in welding operations that would have to be tested.

Also, the relationship of hexchrome to lung cancer and other adverse health effects in welders has not been adequately identified and quantified, according to SMACNA. In development of the proposed hexchrome standard, it is noted that OSHA relied heavily on two outdated exposure studies of chrome production workers to estimate the lung cancer risk to all workers exposed to hexchrome. Neither study effectively provides a correlation between lung cancer and welders.

In seeking out more relevant research data, SMACNA suggests that OSHA resolve the issue of causes of lung cancer among welders including exposures to asbestos and tobacco smoke in relation to exposures to hexchrome or other chemicals in the welding process.

SMACNA maintains that OSHA's existing standards on welding provide a sufficient level of protection for workers, and the association supports OSHA conducting a public outreach program to assist employers by reminding them of these requirements and how those standards help address exposures to hexchrome.

Publication date: 01/31/2005