OSHA’s Public Cadmium Poisoning Assessment Tool

As of today, January 2, 2013, the US Environmental Protection Agency (EPA) is withdrawing the final Toxic Substances Control Act (TSCA) Rule that was issued on December 3, 2012 regarding cadmium. The rule being withdrawn would have required some manufacturers of consumer goods containing cadmium to report on health and safety data to EPA. 

In an unrelated move but worth mentioning, some factions of the U.S. government (led by OSHA*) have developed and made available a tool for cadmium poisoning mitigation. The idea is that you interview someone who may have been dangerously exposed to cadmium. You enter their answers into the tool, called the OSHA Cadmium Biological Monitoring Advisor.

The data you enter, simple answers to simple questions, is rationalized, then crunched against known data points and thresholds for cadmium exposures of various types. Instructions for quickly and rightly mitigating any toxicity related damage are provided instantly.

Technically, the tool exists to address the federal monitoring and surveillance requirements of the general industry Cadmium Standard (summary can be found here). But if you feel you or an employee may have been overexposed to cadmium, read on.

The OSHA Cadmium Biological Monitoring Advisor. The tools works by prompting the user with key questions and relying on data from biological monitoring tests to determine an appropriate course of action. This Advisor analyzes biological monitoring lab results for currently exposed workers. It determines the biological monitoring and medical surveillance requirements of the general industry Cadmium Standard, 29 CFR 1910.1027, applicable to those results.

Technically, the tool is designed for experienced medical professionals, but it is also available to workers and the general public. There’s no requirement for using the OSHA Cadmium Biological Monitoring Advisor. The results presented by the tool are, obviously, critically dependent upon the accuracy of the input data.

If you have any questions or concerns, OSHA asks that you contact them directly or find the advice of an expert.

There are subtleties to the restrictions around industries regarding cadmium exposure. For instance:
For general industry, an employer has 30 days to reassess the employee’s occupational exposure to cadmium. For the construction industry, there’s no time limit to reassess occupational exposure. (The logic of this escapes me, perhaps someone can clarify in the comments section.)

Similar rule notes can be found here: a few subtleties.

Cadmium poisoning sites and signs.  In its elemental form, cadmium is either a blue-white metal or a grayish-white powder found in lead, copper, and zinc sulfide ores. However, most cadmium compounds are highly colored from brown to yellow and red. Cadmium’s uses vary from an electrode component in alkaline batteries to a stabilizer in plastics.

OSHA estimates that approximately 70,000 employees in the US construction industry are potentially exposed to cadmium. Specifically, OSHA asks employers to establish regulated areas whenever the following construction activities are conducted:

  1. Electrical grounding with cadmium welding
  2. Cutting, brazing, burning, grinding, or welding on surfaces that are painted with cadmium-containing paints
  3. Electrical work using cadmium-coated conduits
  4. Using cadmium-containing paints
  5. Cutting and welding cadmium-plated steel
  6. Brazing or welding with cadmium alloys
  7. Fusing of reinforced steel by cadmium welding
  8. Maintaining or retrofitting cadmium-coated equipment
  9. Wrecking and demolishing where cadmium is present

Symptoms of cadmium poisoning are listed here.

Start using the tool here: OSHA Cadmium Advisor.* Groups who made the Advisor Tool available: Occupational Safety and Health Administration of the Department of Labor (OSHA), along with the Office of the Solicitor of Labor (Who?) and the Office of the Assistant Secretary of Labor for Policy (OASP)

Cadmium Banned in Europe in November

The European Commission announced May 20 that the European Union will ban cadmium in jewelry, brazing sticks and plastics beginning this November. A Commission press release states that the new legislation, which will be adopted as an amendment under the EU’s Registration, Evaluation, Authorization and Restriction of Chemicals (REACH) regulation, will prohibit the use of cadmium in all types of jewelry products, except antiques; brazing sticks, which are used to join dissimilar materials; and — in theory — all plastics.  

We say “in theory” in regards to the cadmium ban in “all plastics” because the Commission notice on the updated cadmium restriction appears to have inconsistencies regarding plastics.

The notice on World Trade Interactive suggests that cadmium will be banned in all plastics (with the exception of some recycled PVC).  But an article in British Plastics & Rubber points out semantic oddities in the Commission’s draft document.

The draft references the proposed amendment to Restriction 23 of Annex XVII, which covers cadmium and its compounds.  However, the Commission’s report contained no changes from the 2010 document regarding the list of materials that would be affected.  The wording of the recent statement says “all plastics” would be affected by the ban, but the itemized list of named plastics remains the same.

This leaves the door open for some agents to interpret that plastics not itemized on the list are exempt.

This language snarl is worth being aware of.  In the long view however, while it may delay a revision, it likely won’t stop the fact that cadmium use in virtually “all plastics” will be banned in the EU either in Q4 of this year or shortly thereafter.

And that, of course, is the “heads up.”  (For more on the language snarl, see article, Cadmium — banned or not?)

Cadmium backstory. Cadmium has many uses. It’s used in paint as a pigment, for starters. Or was. EPA and regulatory bodies around the world have been trying to restrict or prohibit cadmium use in paint for years. Often trace amounts of cadmium result in public-perception denigration and expensive product recalls that affect the bottom line; such events are arguably more of a deterrent for industry than the anti-cadmium regulations themselves.

Last summer, for instance, REACH compliance watchdogs found traces of cadmium in Shrek glasses for children. The glasses were manufactured to be sold at McDonald’s as part of the Shrek film promotion. McDonald’s had to recall over 12 million of the glasses that would have retailed for $2 each; that’s a loss of $24 million, plus the operational costs of the recall.

Many think recall events due to substances like cadmium are primarily a supply chain communication failure. While that is true, recalls also point to a regulatory gap and a supply chain that quite naturally tries to cut corners.

The EU appears to be ready to send a clear message:  no cadmium. And to many manufacturers — although probably not to the manufacturers of cadmium pigment — a clear regulation is a welcome regulation. Last year, EPA moved on this item as well when cadmium turned up in kids’ jewelry.

Cadmium alternatives. There’s no reason we need to be using cadmium in this day and age, right?  Problem is, especially for industrial uses, cadmium is very effective as a plating over steel as it’s remarkably resistant to corrosion.

A cadmium alternative for components must be, among other things:

  1. A panacea: act as a general corrosion coating for all seasons
  2. Specific protection: provide good salt spray and scribed corrosion protection
  3. Non-crackable case: cannot succumb to hydrogen embrittlement or stress corrosion cracking.

As a coating, the cadmium alternatives must, among other things:

  1. Retain thread profile/detail underneath, especially in jewelry
  2. Be solderable
  3. Be usable in electrical equipment in terms of conductivity and heat-effect limits.

At minerals.usgs.gov, the government says that coatings of zinc or vapor-deposited aluminum can substitute for cadmium in plating applications.

In 2002, a group published an evaluation of cadmium replacement alternatives for aircraft with notable results. Typically aircraft are exempt from cadmium legislation because of a “no known alternative” clause. In other words, nothing works as well so it is allowed for now.

This still creates a cost and a wrench in manufacturing process, however, due primarily to the problem of disposal of this known-toxic material at end-of-life. Where does cadmium go to die? We’ve all heard of the aircraft boneyard.  Aircraft manufacturers are responsible for end of life disposal of all parts and components (and substances).  The costs associated with end-of-life makes alternatives to cadmium look better and better.  For more on aircraft and replacements, see the Rowan Technology Group 2002 report on cadmium replacements.  It’s an interesting document.  Spoiler alert:  the report concludes that aluminum (Al) is the best cadmium replacement for uses in aerospace, automotive and electronic components in terms of behaving most like cadmium.

The point is that there are alternatives to cadmium — depending on application. For the most part, the replacements are sister- or cousin-metals.

For more on the cadmium ban coming in November under REACH regulation, review the European Commission’s press release.  Also, keep an eye on this blog as we’ll keep you posted on the critical cadmium (and similar) regulatory update status as we go through 2011.

RoHS Recast of November 2010

The consolidated text of the Restriction of Hazardous Substances (RoHS) Recast has been adopted by the European Commission.  On Nov. 24, the European Parliament’s environment committee adopted a compromise deal on updating existing legislation on the Restriction of Hazardous Substances (RoHS) in electronic and electrical equipment.  In an overwhelming margin, 640 votes were in favor, three against and 12 abstained.

The RoHS Directive will apply to more types of electronic and electrical equipment, including mechanized toys and lab equipment. This update to EU legislation notes a likely forthcoming review that would consider adding new substances to the current blacklist.

The current RoHS blacklist is as follows:

The RoHS Recast is still subject to further processes prior to final publication in the OJEC, the Official Journal of the European Community.  One aspect of that is confirmation by the European Parliament.

The National Measurement Office of the U.K. is responsible for enforcing the implemented RoHS Regulations only and is not directly involved in this process. They are providing advice and guidance on the future implementation in the meantime until the final version is published.  Advice and guidance is based on the most up to date information available at the time it is given.

Policy questions should be directed to BIS / the European Commission.Commission Decision 2010/571/EU

Exemptions under RoHS recast

Here is what you need to know about exemptions so far.

1.There are no exemptions from RoHS Regulations for products containing either PBB or PBDE.
2.There is one exemption for products containing hexavalent chromium.
3.There are six exemptions for products containing cadmium.
4.There are about 35 exemptions for products containing either mercury or lead.

For a full list of exemptions, click here to go straight to the official site.

Here is some extra help in the form of Guidance from the RoHS site in the UK.  We’ll be sure to post breaking news on this subject as events warrant.