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B. Work Practice Controls: involve adjustments in the way a task is performed, as well as the periodic inspection and maintenance of engineering control equipment. In many cases, work practice controls complement engineering controls in providing employee protection. C. Personal Protection Equipment: When engineering and work practice controls cannot reduce employee exposure to within the PEL, employers must provide respirators. OSHA’s Methods of Compliance states that: "If feasible engineering and work practice controls are not sufficient to reduce employee exposure to or below the PEL, then the employer must use them to reduce the exposure to the lowest level achievable before using respirators. Respirators must then be used to reduce employee exposure to or below the PEL." (2) Respirators are required during the period necessary to install or implement feasible engineering controls (by May 31, 2010) and during maintenance, repair and emergency situations. No one solution will fit all applications. Solutions frequently involve one or more methods of control to properly and ade- quately control employee exposure. Note (1): Small Entity Compliance Guide for the Hexavalent Chromium Standards, Pages 9, 10 and 11, OSHA 3320-10N 2006 Note (2): a) November 27, 2006 for employers with 20 or more employees. b) May 31, 2007 for employers with 19 or fewer employees. Welding Fume Control Methodology To thoroughly explore your welding fume control options, you should clearly identify and assess your actual needs and oper- ating conditions. The following Welding Fume Control Methodology, along with your Lincoln Electric Technical Sales Representative, can help you through this process, as he or she can bring expertise and resources to assist you as you go through this process. A. Engineering Controls 1. Substitution: Is it feasible and practical to modify or replace your current welding process, consumable, gas, welding procedure or equipment technology with an alternative process, consumable, gas, welding procedure or equipment technol- ogy that generates less welding hexavalent chromium. 2. Isolation Is it feasible and practical to isolate and separate your welding operation by moving it to a regulated area, by automating/ventilating the welding process and/or by placing a barrier between the employee and the source? 3. Ventilation: Is it feasible and practical to control the welding fume path between the source and the worker through source, local and/or general shop extraction/ventilation equipment? B. Safe Work Practice Controls Safe work practices complement each level of Engineering Controls and are designed to control the manner in which work is performed. These practices include such areas as safe welding habits (keeping your head out of the fumes, keeping fumes and gases away from your breathing zone and proper training & use of fume extraction equipment) as well as general housekeeping and general administrative procedures such as performing maintenance off shift to minimize potential exposure. C. Personal Protective Equipment (PPE) An important method of protecting employees in certain situations can be the use of PPE, including respirators; which require an initial employee medical evaluation, more frequent evaluation of worker exposure levels, training and recordkeeping. In addition, the OSHA PPE evaluation may determine the need for additional personal protection practices, including specific requirements for additional work clothing & equipment, as well as the need for a separate change room, shower and laundering service. (3) Note (3): see Small Entity Compliance Guide for the Hexavalent Chromium Standards OSHA 3320-10N 2006 for further details and references regarding compliance. Welding Fume Control Methodology Is it feasible and practical to replace your current welding process, consumable, gas, welding procedure or equipment technology with an alternative process, consumable, gas, welding procedure or equipment technology that can generate less hexavalent chromium? Lincoln Electric’s Suggested Welding Fume Control Methodology Engineering Controls Regulatory Assessment Have you determined potential employee exposure to hexavalent chromium from the welding consumable, base material and coating? Exposure Determination Is there any potential employee exposure to hexavalent chromium above the OSHA PEL? 1. Substitution Is it feasible and practical to isolate and separate your welding operation by moving it to a regulated area, by automating/ventilating the welding process and/or by placing a barrier between the employee and the source? 3. Ventilation Is it feasible and practical to control the welding fume path between the source and the worker through source, local and/or general shop extraction/ventilation equipment? Safe Work Practice Controls Is it feasible and practical to lower exposure to hexavalent chromium by use of safe wor...