Henry,

I've been looking for solid answers on this topic myself.  The more I look, the more I wonder how schools are held accountable for things like Chrome 6

I think the best way to get an understanding of all this may be to discuss with OSHA specifically about who must comply and why or why not.

We are spec-ing out a new lab and I used OSHA Hex Chrome standards as the benchmark for ventillation along with the AWS guide for building training facillities.

More importantly, being exempt from OSHA inspection (if you are) does not mean that you are above the law or may expose employees (teaching staff) or student learners to hazardous conditions. States out of OSHA jurisdiction must have their own standards.....(I think most simply refer back to OSHA)

Also, There are state OSHA and federal OSHA bodies, both with similar but different roles.

Here are some paragraphs from a NIOSH website that provides some language (but not clairity) The bold emphasis is mine:

http://www.cdc.gov/niosh/docs/2004-101/chap1.html
OSHA is a Federal Agency that promulgates and enforces standards dealing with occupational safety and health as they apply to private and Federal employees in the workplace. The legislative mandate for OSHA comes from the Occupational Safety and Health Act of 1970. Under the Act, OSHA does not have jurisdiction over State and local government employees, including those in public schools.

Section 18 of the Occupational Safety and Health Act allows States to develop OSHA-approved State plans giving the State regulatory and enforcement responsibilities for occupational safety and health within its borders (refer to the section "Federal Government Agencies, OSHA State-Plan States" in Appendix A: (Resource Agencies and Organizations). Section 18 requires these "State-plan" States to have standards and enforcement that are identical to (or at least as protective as) Federal OSHA standards. These State plans are also required to extend their coverage to all State and local government workers, including those in public schools. Twenty-six States have OSHA-approved State plans. These States, in addition to enforcement programs, have extensive voluntary compliance programs, including on-site consultation services available to public sector employees.

In States under Federal OSHA without State plans, OSHA has no authority to inspect or enforce standards in public schools. However, the local Federal OSHA office may be able to provide hazard recognition assistance and technical support. Extensive compliance assistance information is also available on OSHA's Web site (http://www.osha.gov) and in Federal and State publications. In addition, the U.S. Environmental Protection Agency (EPA) may enforce certain OSHA standards, such as Hazardous Waste Operations (29 CFR 1910.120) or relevant EPA standards in public schools.

When students are compensated for work done outside the school, as they are in cooperative educational programs, they are defined as workers under the Occupational Safety and Health Act or an OSHA-approved State plan. In such cases, the students will be covered by the standards.

OSHA issues standards in the Federal Register that are compiled in the Code of Federal Regulations (CFR), described below. The OSHA-approved State plan states issue-comparable standards that are identical to or "at least as effective as" Federal OSHA's standards:

29 CFR 1910 for General Industry Standards
29 CFR 1915 for Shipyard Employment
29 CFR 1917 for Marine Terminals
29 CFR 1918 for Longshore Safety
29 CFR 1926 for Construction Standards
29 CFR 1928 for Agricultural Standards

Henry,

I made a few calls and have a bit more data.

Schools (Teachers, Students, Administration, Facilities etc) must comply with State OSHA... There is no exemption for things like:

Resparatory compliance

MSDS

Lockout Tagout procedures

Grinder/Machine tool safety

Faculty and Facilities must comply... Learners must be trained in safe usage.

State OSHA is almost always a direct cut from Federal except in instances where the state regulations exceed those of the feds.

The term "exemption" found in some texts is most certainly not an excuse for some penny pincher to ignore safety compliance in either purchasing or compliance :)

Schools must comply with Hexavalent Chromium requirements just like everybody else... Now a good reading of the code itself may lead to information on just how much exposure (type of fume and time exposed) will require engineering modification of existing fume extraction practices.

We have gotten by for the time being by limiting our welding of stainless to GTAW and small amounts of GMAWP.... plasma cutting, SMAW and FCAW as well as high amp spray transfer is done very small quantities until our fume extraction systems are updated.   Now a program that requires heavy fume processes will have to take action rather than put smokey processes on the shelf.

Keep us posted on what you find out too.