Welding Fume Standard

Document Number: Applies To: RHS00003 Standard – Administrative Wood Buffalo Region

Revision Date: 2017/12/22 Document Owner (Title): Manger, Regional IH & Revision: 1 Compliance Review Cycle: 3 years

Summary of Changes Section Rev No. Revision Made Changed 1 New Document

Scope This standard applies to all Suncor Energy Inc. Wood Buffalo Region employees, contractors, vendors and visitors and is part of Suncor’s EH&S management system.

Purpose This standard is intended to ensure that all Suncor employees and contractors in the Wood Buffalo region (Suncor Oil Sands, In Situ, Fort Hills and East Tank Farm) engaged in any work that could potentially lead to welding fume exposure are fully knowledgeable of the correct procedures to be followed to achieve adequate protection.

Compliance This document applies to work performed at Suncor Energy operating sites in the Wood Buffalo Region that includes Suncor Oil Sands, In Situ, Major Projects, Fort Hills and East Tank Farm.

Roles and The following individuals and groups have the following roles and responsibilities: Responsibilities

Document Owner • Ensures this document is reviewed according to the required revision cycle. • Ensures the document is updated to accommodate changes to Suncor, provincial, and federal regulation. • Ensures the document is updated to mitigate risks found as the result of an incident.

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Document Approver • Ensures this standard is necessary and that it aligns with management and company direction.

Employee • Participates in Industrial Hygiene welding fume air monitoring assessments. • Participates in Air Purifying Respirator Training. • Dons appropriate RPE when required. • Complies with LMS0052A Respiratory Protection. • Informs Suncor’s Health & Wellness of the date or approximate date of a health assessment from a previous employer that occurred within the preceding 2 years.

Supervisor • Ensures employees are given adequate time to participate in the Health Assessment Program (fit testing, audiometric testing, etc.). • Ensures employees are given adequate time to participate in the Industrial Hygiene air monitoring assessments. • Ensures employees are given adequate time to participate in the necessary training. • Ensures employees don adequate RPE when required. • Implements work practices to keep workers’ exposure as low as possible

Contractor • To meet or exceed Suncor’s requirements to provide health assessment to their employees. • Provides fit testing to their employees. • Provides Air Purifying Respirator Training to their employees. • Conducts personal welding fume air monitoring on their employees. • Ensure employees don adequate RPE when required. • Implements work practices to keep workers’ exposure as low as possible.

Business Area • Ensure workers undergo a health assessment every 2 years Management after the first health assessment, if assigned. • Pays costs (and travel) of the Health Assessment. • Ensures exposed employees meet the necessary training requirements

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Industrial Hygiene Performs air sampling for welding fumes on a regular basis. • Maintains list of jobs/tasks with potential for welding fume exposure and defines adequate RPE required for these jobs/tasks. • Communicates sampling results to affected employees and their supervisors in a timely manner. • Assists workers/supervisors and management in the selection of RPE and other control methods.  Recommends work practices and other controls to keep workers’ exposure as low as possible.

Health and Wellness • Performs health assessment for hazards related to welding (fit testing, audiometry testing) • Communicates results to affected employees in a timely manner. • Refers employees with abnormal results to Suncor’s Contract Physician, and facilitates referral to a family doctor for follow-up and ongoing care if necessary. • Advises Business Area of worker inability to don RPE. • Maintains medical records for a minimum of 30 years.

References • Alberta Occupational Health and Safety Code  LMS0052A Respiratory Protection Standard  LMS0061A Lead Exposure Control Standard  LMS0078A Industrial Hygiene Program  LMS0019A Erection, Identification and Removal of Flagging Standard  Welding Health and Safety: A Field Guide for OEHS Professionals (Michael K. Harris, 2002)  OSH Answers Fact Sheet Welding- Fumes and Gases (Canadian Centre for Occupational Health and Safety, 2017)

Terms, Definitions The following terms, definitions and acronyms are used in this standard: and Acronyms

Base Metal The metal being welded or cut.

Conjunctivitis (pink Inflammation and redness of the lining of the eye and eyelid. eye)

Electrode Used to conduct current through a work piece to fuse two pieces together.

Emphysema, A chronic respiratory condition due to inflation of the lung tissue (alveoli) in the lungs leading the decreased lung function and breathlessness.

Siderosis A chronic respiratory condition due to inhalation of iron leading to restriction of the airways.

Standard 1. Technical Information

Item Description 1.1 Welding is a process for joining metals rendered liquid by heating, by pressure or both. The welding process generates significant quantities of gases and fumes. The fumes are a complex mixture of metals, particulates and metal oxides. The specific composition of the fume varies depending on the base metal, the welding method and the electrode.

1.2 In the Wood Buffalo Region, welding can be conducted in shops, and throughout the fixed plant areas and the mines. It can be conducted in welding shops, confined spaces or areas open to atmosphere.

Stick Welding 1.3 Shielded metal arc welding (SMAW) or stick welding is the most common weld process due to the simplicity of the equipment and process. It uses an electric current to form an electric arc between the electrode and the metals to be joined. The electrode and metals forms into a pool of molten metal known as the “weld pool” or “puddle” that cools to form a joint. Through the welding process the flux coating of the electrode disintegrates, giving off vapours that are a shielding gas to protect the weld from contaminates. Flux causes a lot of fume.

TIG welding 1.4 Gas Tungsten Arc Welding (GTAW) or TIG welding uses an electric arc between a non-consumable tungsten electrode and the metal to be welded. The weld is protected with a shielding gas such as argon or helium to protect the weld from atmospheric contaminates. TIG welding causes less fumes because it’s not covered with a flux.

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Item Description 1.5 TIG welding allows for greater controls over the weld compared to stick and MIG welding and produces stronger, higher quality welds.

MIG Welding 1.6 Gas metal arc welding (GMAW) or MIG welding is similar to TIG welding as it uses shielding gas to protect the weld from contaminates. It uses an electric arc to join the pieces and the electrode deposits into the welding area.

1.7 MIG welding is efficient, simple and less expensive than TIG welding. However, it produces more fumes, sparks and smoke during the welding process.

Thermal Spray 1.8 Thermal spray welding (THSP) uses a hot/molten material from a torch, which is Welding applied to a substrate. The material delivered to the torch may be a wire, rod, cord or powder.

1.9 Thermal spray welding can efficiently provide a corrosion resistant coating over a large area.

Plasma Cutting 1.10 Plasma cutting is used to cut materials such as steel, aluminium, brass and copper and is capable of cutting the material in varying thicknesses.

1.11 Plasma cutting uses a plasma arc at a high temperature (18,000 – 25,000 °C) to heat the metal to be cut. A high pressure gas is used to form a high velocity jet and removes the molten metal.

Gouging 1.12 Gouging is process where heat generated between an electrode and the metal to be cut, causes the metal to melt. Compressed air displaces the molten metal.

Base Metal and 1.13 Appendix 1 contains the common base metal and electrode used for the three Electrodes most common types of welding.

1.14 If a type of welding is conducted that is not listed contact Industrial Hygiene for information on the hazards.

2. Health Effects

Item Description 2.1 The routes of exposure for welding fumes are the respiratory system, skin and eyes. Effects can be acute in nature meaning that the effects are experienced immediately or they can be chronic. Chronic health problems develop slowly over time.

2.2 Table 1 summarizes the health and safety hazards associated with welding

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Item Description 2.3 Factors that affects worker exposure to hazardous products of welding are: • Type of welding being conducted • Base metal used • Electrode used • Type of coatings, if present • Location (confined space, maintenance shop, outdoors) • Ventilation • Work practices of welder  Position of welder while performing the task.  Positioning of exhaust hose of the ventilation system. • Other occupational exposures Table 1: Welding Health and Safety Hazards

Hazards Sources Type of Welding

Metal fumes Parent metal Stick, TIG, MIG welding, THSP Welding rod UV radiation burns to eyes and Electric arc Stick, TIG, MIG welding skin Photoretinitis or blue-light injury Electric arc Stick, TIG, MIG welding

Ozone and nitrogen dioxide Ionization of atmosphere gases TIG, MIG welding due to reduced shield of electric arc Thermal burns Spatter Stick, TIG, MIG welding, THSP Handling hot metal Handling hot electrodes stubs

Products of flux decomposition, Flux coating on welding rod Stick Welding, THSP including carbon monoxide

Particulate Spatter Stick, TIG welding Chipping cooled flux from weld Pre- or post weld grinding operations

Asphyxiation (in confined spaces) Inert shielding gases TIG welding Phosgene, chlorine and other Decomposition of products from TIG, MIG welding halogenated compounds chemical cleaners/degreasers Noise Gasoline or diesel-driven Stick, TIG, MIG welding, THSP, generators cutting, gouging Arc Compressed gases Shielding gas TIG, MIG welding Electrocution Damaged high-amperage welding Stick, TIG, MIG welding cables

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Item Desctiption 2.4 Appendix 2 contains common welding fume contaminates, sources and potential effects and symptoms. There is the potential for other contaminants to be present in welding fumes and these will be evaluated at the discretion of Industrial Hygiene.

Acute Health 2.5 Irritation of the eyes and respiratory tract is the primary acute health effect from Effects exposure to welding fumes and gases. For the common acute effects, a single agent is seldom responsible. However on occasion, it is possible to identify a single offending agent. Cadmium, oxides of nitrogen, ozone, phosgene, chromium, nickel, copper, molybdenum, vanadium, and carbon monoxide are examples of fumes and/or gases that can cause acute health problems.

2.6 Significant acute health effects of welding arc to the eyes include pain and kerato conjunctivitis. UV radiation injury to the skin produces burns. Skin irritation and sensitization are caused by fumes containing chromium, nickel, cadmium, zinc, cobalt etc.

2.7 Fluorides in welding fumes cause acute irritation of the eyes and respiratory tract. Metal fume fever is one of the more common acute health effects seen in welders. Metal Fume Fever 2.8 Metal fume fever is induced by inhalation of microscopic particles of the following metals: zinc (from galvanized coatings on steel), copper, manganese, nickel, cobalt, and selenium. Symptoms similar to the flu such as chills, fever, cough; headache, nausea, thirst and pain in the limbs are likely. Acute metal fume fever symptoms may not appear until 12-24 hours after exposure. The effects of metal fume fever may not be readily noticeable in most individuals because the body becomes accustomed to inhaling the metal particles. With repeated exposure, symptoms may well disappear as the body accustoms itself to contaminant levels.

The majority of the chronic health effects impact the respiratory system. It is likely Chronic Health 2.9 that the chronic effects result from exposure to the constituents of the covered Effects electrodes or from repeated exposures to fumes originating from the materials being welded. The four most common chronic lung effects are bronchitis, emphysema, siderosis (iron dust in the lungs) and silicosis (likely from concurrent exposure to silica products used during welding activities). Manganese, lead, chromium, nickel, fluorides, vanadium and tin are substances which cause long term health concerns

Chronic health effects to the eyes include cataracts and damage to the retina with 2.10 loss of central vision from UV exposure. Exposure to nickel, cadmium and chromium have been linked with an increase in 2.11 lung cancer. Lung cancer in welders is also associated with past exposure to asbestos or individual smoking habits. Many of the acute and chronic respiratory health effects of over exposure to 2.12 welding fumes are much worse if the worker smokes and/or has been previously exposed to silica and/or asbestos.

3. Occupational Exposure Limits

Item Description 3.1 Worker exposure to welding fumes it to be kept as low as reasonably achievable and may not exceed the Occupational Exposure Limits (OELs) established under the Alberta Occupational Health and Safety (OHS) Code Schedule 1, Table 2. The OELs for welding fumes in the Alberta OHS Code (2009) can be seen in Table 2.

Table 2: Welding Fume OELs

Contaminant 8 hour OEL (mg/m3) 12 hour OEL (mg/m3) Short term exposure limit (STEL) (mg/m3)

Antimony 0.5 0.5 -

Beryllium 0.002 0.001 0.01

Cadmium 0.01 0.005 -

Carbon Monoxide 25 ppm 12.5 ppm -

Chromium 0.5 0.25 -

Chromium 6 (Insoluble) 0.01 0.005

Cobalt 0.02 0.01 -

Copper 0.2 0.1 -

Iron Oxide 5 2.5

Lead 0.05 0.025 -

Manganese 0.2 0.1 -

Molybdenum 10 5 -

Nickel 1.5 0.75 -

Vanadium 0.05 0.025

Zinc Oxide 2 1 10

4. Regulatory Requirements and Standards

Item Description Alberta OHS 4.1 The following are applicable regulatory requirements and standards for welding Code fumes in Alberta as listed in Schedule 1 of the Alberta OHS Code. Part 4, Section 16: An employer must ensure that a worker’s exposure to any substance listed in Schedule 1, Table 2 is kept as low as reasonably practicable, and does not exceed its occupational exposure limit. Refer to the occupational exposure limits for details. Part 4, Section 26(1) and Schedule 1, Table 2: Identifies beryllium, cadmium, lead and lead compounds as substances requiring a written code of practices to cover the storage, handling, use and disposal of streams and waste when it is present at a work site: • as pure substance in an amount exceeding 10 kg., or • In a mixture in which the amount of the substance is more than 10 kg, and at a concentration of 0.1 percent by weight or more.

5. Evaluation

Item Description 5.1 Approved exposure assessment strategies will be used to characterize and monitor workers’ potential exposure to welding fumes. The evaluation will consider the type of welding, rod and base metal, location and available controls.

Air Monitoring 5.2 Suncor’s industrial hygiene will conduct air monitoring to evaluate occupational exposure of worker(s) to welding fumes, according to acceptable methodologies by the OHS Code. Information gathered during the evaluation will be captured in Suncor IH’s Welding Fume Sampling Information Form.

5.3 Sampling procedures, analytical methods, and equipment used for the monitoring of welding fumes must conform to current NIOSH methods, or equivalent. Welding fume analysis must be conducted by an AIHA accredited laboratory. Proof of participating in a quality control program, or equivalent, must be available. The workers’ air monitoring results will be used to: 5.4 • Ensure that personal exposures to welding fumes do not exceed established regulatory limits. • Determine the effectiveness of specific engineering/administrative controls and of work practices in minimizing exposures to welding fumes. • Determine the adequacy of selected respiratory protection.

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Item Description 5.5 Welding fume air monitoring must consider the type of welding being conducted, the base metal and electrode. Examples of how welding fumes can vary based on the base metal are: • Fluxes containing silica or fluoride produce amorphous silica, metallic silicates and fluoride fumes. • Fumes from mild steel welding contain mostly iron with small amounts of additive metals (chromium, nickel, manganese, molybdenum, vanadium, titanium, cobalt, copper etc.). • Stainless steels have larger amounts of chromium or nickel in the fume and lesser amounts of iron. • Nickel alloys have much more nickel in the fume and very little iron. Where the assessment discloses there is a potential for workers (individually or as 5.6 defined by the use of similar exposure groups) to inhale welding fumes and that the health of the worker or workers may be affected, Suncor shall develop, establish, implement and maintain measures and procedures to further evaluate and control the exposure of the worker / occupational group. Records of air monitoring results will be used and maintained as per Industrial 5.7 Hygiene requirements. Health 5.8 In the Wood Buffalo Region, baseline and periodic assessments are completed for Assessments workers exposed to health hazards. The aim is to detect abnormalities early and Surveillance enough to prevent or limit disease progression by designing control measures to prevent injury and illness and initiating health intervention. As there is no regulatory requirement for workers exposure to welding fumes to 5.9 have a health assessment in Alberta, Suncor recommends that at a minimum fit testing be performed every two years for workers required to wear RPE. During the fit test, the Health and Wellness advisor will review a medical questionnaire with the worker. Occupational 5.10 Conducted by Health and Wellness Advisor. Information obtained directly from History the worker includes: • Occupational exposure to welding fumes and carcinogens (historical to present), • Any significant exposure to welding fumes or carcinogens during recreational or hobby activities,  Dates occupations or jobs commenced and ended,  Kinds of operations or processes in which the worker was involved, and  Use of PPE such as respiratory equipment, protective clothing.

6. Controls

Item Description 6.1 The selection of the most appropriate control option(s) shall be governed by the specific task and specific work area and will be based on results from the initial evaluation. Effective use of ventilation is the first step in the control of welding fumes. Local Engineering 6.2 Controls exhaust ventilation must be used in maintenance shops when welding. The ventilation system must adhere to the manufacturer’s preventative maintenance requirements.

6.3 When using local exhaust ventilation position the exhaust hood above and to the side of the weld so that the motion of the plume is captured.

6.4 Local exhaust ventilation (LEV) is used to protect those working in the immediate area of the welding. This includes but is not limited to the welder’s helper, other welder and other workers in the area.

Administrative 6.5 Welding safety procedures for each area must be followed. Controls The following personal protective equipment (PPE) is required when welding, Personal 6.6 cutting or grinding: Protective • Even in the presence of ventilation a minimum of a half mask respirator with Equipment P100 filter must be used while welding. In the event of potential for hydrocarbon exposures ensure combination P100 and OV filters are used. • Single hearing protection • For gouging, double hearing protection is required (options include 3M Speedglas 9100 MP Welding Helmet or 3M Peltor Low Profile Ear Muffs) • Welding helmet or hood • Flame resistant gloves • Protective clothing suitable for the work being conducted • All other PPE required for the area Gouging, plasma cutting, overlaying and hardsurfacing generates copious Gouging, Plasma 6.7 amounts of fume. If practical these tasks are to be conducted outdoors. If Cutting, gouging and plasma cutting cannot be conducted outdoors, the fumes must be Overlaying and extracted from the shop to the exterior. Hardsurfacing For these activities a minimum of a half mask respirator with P100 filters is 6.8 required. 6.9 Welding helpers and those working in the area immediately adjacent to welders must don similar respiratory protection, hearing protection, and eye protection to the welders. If welding in a confined space dilution ventilation or local exhaust ventilation must Confined Spaces 6.10 be used. Respiratory protection must also be used. Industrial Hygiene must be consulted to advise on ventilation and respirator requirements. A minimum of a half mask respirator with P100 cartridges must be used for welders and others in the confined space during welding. This requirement may be increased for certain types of welding, insufficient ventilation and number of welders in the confined space. Controls will be evaluated by Industrial Hygiene for efficiency and further controls may be required.

Continued on next page WARNING - Uncontrolled when printed. The current revision of this document is available in ECMS. Approved By: Sheila Chernys, Director OS Enviro & Reg; Shamini Samuel, Manager, Regional IH & Compliance, Page 11 of 17 Subject: Welding Fume Standard Number: RHS00003 Rev: 1

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Item Description Where available LEV must be used to protect others working in the shop from 6.11 Maintenance welding fume contaminants. The welder must don a minimum of a half mask Shop respirator with P100 filters.

The LEV cannot be relied on as the only control measure to protect the welder due 6.12 to:  inconsistent welder work practice (for example not using the LEV correctly)  inconsistent air flow of LEV (for example due to degrading system or the air flow being split between several ventilation arms)  inability to conduct LEV verification regularly Outdoors 6.13 Outdoor welding is considered any welding conducted outside a confined space or welding shop. A minimum of a half mask respirator with P100 cartridges is required for all welding, cutting, gouging outdoors.

7. Safe Work Practice

Item Description 7.1 If local exhaust ventilation is not used a restricted work area must be established and access must be physically restricted to those using proper PPE.

7.2 Personnel shall don PPE as identified in Section 6.

7.3 Good housekeeping practices must be followed after welding. Those cleaning welding fume residues must follow the same PPE requirements as those conducting the welding.

End of Standard

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WARNING - Uncontrolled when printed. The current revision of this document is available in ECMS. Approved By: Sheila Chernys, Director OS Enviro & Reg; Shamini Samuel, Manager, Regional IH & Compliance, Page 13 of 17 Subject: Welding Fume Standard Number: RHS00003 Rev: 1 Appendix 1- Types of Welding, Base Metals and Electrodes Types of Welding Bases metals commonly welded Electrodes commonly used and possible metals in the electrodes

Stick welding  Carbon and low alloy steels  Low alloy steel electrodes  Stainless steel o Iron  Cast iron o Molybdenum  Copper and its alloys o Chronmium  Nickel and its alloys o Nickel o Manganese  Electrodes for cast iron o Nickel  Electrodes for hardfacing o Chromium o Cobalt o Copper o Iron o Manganese o Molybdenum o Nickel o Vanadium

TIG welding  Aluminium alloys  Tungsten  Beryllium  Cast iron  Carbon as well as nearly all alloy steels  Chromium alloys  Copper and its alloys including bronze, brass and copper-nickel  Heat resistant alloys with iron, nickel and/or cobalt as primary metals  Magnesium alloys  Nickel and its slloys  Stainless steels  Titanium alloys

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Types of Welding Bases metals commonly welded Electrodes commonly used and possible metals in the electrodes

MIG welding  Aluminium alloys  Carbon steel as well as nearly any allor steels  Chromium alloys  Copper and its alloys including bronze, brass, and copper-nickel  Heat-resistant alloys of iron, nickel, and/or cobalt as primary metals  Magnesium  Nickel and its alloys

WARNING - Uncontrolled when printed. The current revision of this document is available in ECMS. Approved By: Sheila Chernys, Director OS Enviro & Reg; Shamini Samuel, Manager, Regional IH & Compliance, Page 15 of 17 Subject: Welding Fume Standard Number: RHS00003 Rev: 1 Appendix 2- Welding Fume Contaminants, Sources and Potential Effects & Symptoms

Contaminant Source Potential Effects & Symptoms

Skin and upper respiratory tract irritation, chronic poisoning, functional disorders of the heart, Antimony Solders, sheet and pipe metal degeneration of the heart muscle. IARC-2B possibly carcinogenic to humans (antimony trioxide)

Irritant of the upper respiratory tract (as an oxide), dermatitis, tracheobronchitis, pneumonitis. Spark-resistant tools, some hard Beryllium Berylliosis, chronic beryllium disease, prolonged copper alloys overexposure may be fatal. IARC-1 human carcinogen.

Some silver solders, some Irritation of upper respiratory tract, brazing filler wires, some zinc tracheobronchitis, pneumonitis. Gastrointestinal Cadmium alloys, some paint pigments. symptoms, anemia, rhinitis, pulmonary edema, and Cadmium-plated hardware and kidney disease. Prolonged exposure may be fatal. fittings IARC-1 human carcinogen.

Severe irritation of the upper respiratory tract and Many steel alloys, including skin. Ulcerated nasal mucosa, separated nasal Chromium stainless steel, Inconel metals septa, rhinitis, pulmonary edema, kidney damage. IARC-1 human carcinogen.

Cough, dyspnea on exertion, hypersensitivity, High temperature applications and pneumonitis, chemical asthma, obstructive airways Cobalt hardfacing applications syndromes; IARC2-B possibly carcinogenic to humans

Brass, bronze and Monel metal, stainless steel filler wire; many Upper respiratory tract irritation and metal fume Copper filler wires ore copper coated for fever; possible eye irritation. Anemia and corrosion resistance while in discoloration of skin and hair. storage.

Ataxia, vomiting, headache, stupor, convulsions CAC-C rods (less than 1% will not and coma. CNC effects including restlessness, show up on the MSDS), leaded irritability and memory loss; damage to the central Lead steel, some painted surfaces, as well as peripheral nervous system, anemia, some solders, brass or bronze kidney damage. IARC-2B possibly carcinogenic to alloys humans.

May cause metal fume fever at high concentrations. Chronic manganese poisoning, headache, asthenia, irritability, progressive Manganese Many steel alloys psychological disorders, progresses to muscle weakness, speech impairment, neuromotor dysfunction, impotence and Parkinson-like symptoms

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Contaminant Source Potential Effects & Symptoms

Molybdenum Many steel alloys, particularly Low toxicity; molybdenum trioxide irritates the eyes 4130 steel (also known as and mucous membranes. chrome-moly steel and “one and a quarter chrome” steel). Also stainless steel.

Nickel Some steel alloys, stainless steel, Asthma, pulmonary fibrosis and pulmonary edema, Monel metal, substrate under contact dermatitis in sensitized individuals. chromium plating Possible increased incidence of lung and/or nasal cancer. Metal dust and fumes are IARC-2B possibly carcinogenic to humans, soluble and insoluble compounds are IARC-1 human carcinogens.

Vanadium Iron, some steels and grades of Vanadium pentoxide may be formed during stainless steel and some nickel extreme heating and cutting. It is an eye and alloys. Also common in boiler respiratory tract irritant and on wet skin, a skin firebox scale in boilers fired with irritant. Symptoms include acute bronchitis, heavy petroleum fuels (“six oil”) bronchospasm, cough, nasal hemorrhage. Airway restriction, green tongue.

Iron Oxide Steel alloys, cast iron Siderosis, a benign form of pneumoconiosis caused by deposition in the lungs.

Zinc Oxide Galvanized coatings, brass, some Metal fume fever paint pigments.

The following individuals have approved and signed this document.

UserName: Shamini Chandrasekaran (ssamuel) Title: Mgr Regional IH & Compliance Date: Friday, 22 December 2017, 01:25 PM Mountain Time Meaning: Approver 1 Signed ======

UserName: Sheila Chernys (schernys) Title: Dir OS Enviro & Reg Date: Tuesday, 26 December 2017, 07:41 AM Mountain Time Meaning: Approver 2 Signed ======