Preparing for the OSHA Hexavalent Chrome Rule in an Aerospace Company

1. 1 Preparing for the OSHA Hexavalent Chrome Rule in an Aerospace Company Michael Dwyer The Boeing Company 2006 Air Force Corrosion Conference March 14, 2006

2. 2 Introduction 1993 - Request for emergency rulemaking to reduce hexavalent chrome PEL 2003 � Federal Appeals Court ruled that OSHA must produce new rule according to specified timetable (Oct 04, Jan 06; no specific PEL) Oct. 2004 � Draft rule released for public comment, PEL of 1.0 ug/m3 proposed Feb. 2006 � Promulgation of final rule

3. 3 Exposure limit-5 ug/m3 Aerospace painting limit-25 ug/m3 Increased air monitoring Regulated area requirement Engineering and work practice controls Respiratory protection Medical surveillance

4. 4 Chrome Use in Aerospace Corrosion-inhibiting primers containing CrVI are used on the majority all aluminum and steel aircraft parts Approximately 75% of the structural parts of some airplanes are painted with a CrVI primer

5. 5 Current State Many aerospace companies use state-of-the-art control measures: Engineering Controls Spray paint systems (such as electrostatic spray guns and HVLP) which minimize overspray Dry-filter paint booths with optimal ventilation PPE � Respiratory Protection Required for all CrVI spray painting operations Full-face and half-face, air-supplied or air-purifying Hood-type airline respirators

6. 6 Key Concerns Technical feasibility of controls Applicability of studies used for setting standards Financial impact to key suppliers and self Reduced productivity due to controls Attainability of PEL -Health Impacts -Tech impacts - -Health Impacts -Tech impacts -

7. 7 Chromate Substitution Few substitutes for hexavalent chrome are available Boeing has not identified a drop in replacement for chromate primer High priority programs continue to investigate chemical processes free from chromates: primers detackifier sealants conversion coatings

8. 8 Strategy Establish cross functional teams Create analysis processes used across enterprise Identify and fill data gaps Estimate costs and integrate into future budgets (capital and expense) Develop comments in response to OSHA comment period Create implementation plans based on PEL scenarios Implement �feasible� changes to materials and processes to reduce exposures and reduce standard impact

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10. 10 Primary Processes Impacted Spray application of primer coatings Spray application of chromic acid (Alodine) De-painting previously primed surfaces Chrome anodize Chrome plating Welding

11. 11 Exposure Assessment Aerospace processes that could exceed the OSHA PEL: Spray painting primers Major sanding or grinding on primed surfaces Paint booth filter change operations Aerospace processes that are probably below the OSHA PEL: General assembly or fabrication work Drilling and filling Background factory air Spray application of chromic acid Welding Tank line chemical adds

12. 12 Identifying Potentially Affected Population by Site

13. 13 Key Elements of Cost Model per Employee Annual cost for above PEL PPE Lost productivity Medical IH evaluations Equipment maintenance One time cost for above PEL Change rooms Engineering feasibility studies Engineering controls Implementation of Regulated Areas One time cost for all exposed Training Initial exposure assessment

14. 14 Cost Estimate Approach

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16. 16 Key Findings Significant initial and ongoing monitoring impact Spray applications, sanding, and grinding created highest exposures Costs were much higher than OSHA estimates � recurring costs were very high, capital not the major cost driver Aerospace painting variance for engineering controls appropriate

17. 17 Key Findings (continued) Some exposures can be eliminated by feasible process changes Cost estimating tools require modifications for small/large populations and process variation Material and process changes with customer and supplier involvement are critical Cannot over-communicate to internal and external stakeholders Create alliances