Assessment of health risks and responsibilities of exposure to Chromium-6. Outcome of the tROM project



ABSTRACT - Between 2004 and 2012, approximately 800 unemployed persons took part in the tROM reintegration project run by the municipality of Tilburg. They were legally obligated to acquire work experience in this way in order to be eligible for social welfare benefits. The participants in the tROM project helped restore museum trains in a NedTrain workshop in Tilburg. They were engaged in removing old paint layers from the trains in the workshop. In 2015, indications surfaced that the paint layers had contained chromium-6, a hazardous substance. At the request of the Tilburg municipality, RIVM followed up by investigating this issue. This report presents the results. It describes the work conditions, the exposure to chromium-6, and the health risks for participants, supervisors, and other persons involved in the tROM project. 

Exposure to chromium-6 and potential health risks  - The study concluded that the old paint layers on the museum trains did indeed contain chromium-6. Participants in the tROM project and their project supervisors from the Tilburg municipality were exposed to chromium-6 at the tROM location via sanding dust. Persons who did not work on the trains but were present in the same hall could also have been exposed to chromium-6, although to a lesser degree. The exposure occurred because the control measures in the workplace were not implemented consistently, although they were formally mandatory. The personal protective equipment was also not adequate. Such equipment was handed out, but it was often of an inferior quality or not available in sufficient amounts. 

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Responsibilities of the Tilburg municipality and other parties - The Tilburg municipality was responsible for the working conditions at the tROM workplace. In practice, this responsibility was delegated to the management of the tROM project. During the tROM project, the project management did not know anything about the possible presence of chromium-6 on the trains. The participants in the tROM project, their project supervisors, and other persons from the Tilburg municipality involved in the project also knew nothing about this. The position of NS/NedTrain in this regard was different. NS/NedTrain was formally involved in the tROM project and provided support, supervision, and materials. At the start of the tROM project in 2004, NS/NedTrain was aware that, until the beginning of the 90s, the NS had used paint for its trains that contained the hazardous chromium-6 compound.  In a Risk Inventory and Evaluation (RI&E) report prepared by an external agency in 2005 for the tROM project, the presence of sanding dust in the workshop was mentioned as a point for improvement. However, the potential presence of chromium-6 in the dust was not recognised as a risk factor in that regard. After the RI&E, control measures were implemented, but these were not sufficient to adequately reduce the exposure to sanding dust. 

The tROM project did not have any systematic occupational health & safety structure in place. The information and instructions given to tROM participants on how to deal with hazardous substances was inadequate. The participants also did not receive any support or supervision from an occupational health perspective, and no physical medical examination or screening was offered. Most of the tROM participants who were asked to work on the trains did not do so voluntarily. They also had little freedom to choose which work activities they were to carry out. Relevant legislation and regulations indicate that persons who were exposed to chromium-6 at the tROM location and who suffered harm to their health that can be ascribed to chromium-6 to a sufficient degree are eligible for compensation. The Tilburg municipality, NedTrain, and possibly other parties, including agencies supplying temporary workers, can be held liable. 

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