In prior posts, we covered the new exposure limits for beryllium and the requirements for exposure assessment, work areas, written exposure control plan, engineering controls, respiratory protection and personal protective clothing and equipment. In our final post of this three-part series, we will cover the information related to medical surveillance, training, recordkeeping and effective dates. While the Trump administration is delaying this and other OSHA rules 60 days for review, bringing your organization into compliance with all proposed regulations is likely the right path to take at this time.
A medical surveillance program is required for Employees exposed to beryllium levels above beryllium’s new action level for more than 30 days, those who show signs or symptoms of chronic beryllium disease (CBD) or other beryllium related health effects, employees exposed to beryllium during an emergency, or those workers with a recent written medical opinion that recommends periodic medical surveillance. The medical surveillance is required within 30 days of determining the need for a medical examination, or at least every two years. The medical examination should include:
- A medical and work history with emphasis on beryllium.
- A physical examination with emphasis on the respiratory system and skin rashes.
- Pulmonary function tests.
- A standardized Beryllium Lymphocyte Proliferation Test (BeLTP) or equivalent test.
- A low dose computed tomography (LDCT) scan when recommended by the physician or other licensed health care professional (PLHCP) and other tests deemed appropriate by the PLHCP.
Multiple requirements surround the medical surveillance program. The details of the program, medical exams, medical removal eligibility, and associated employer responsibilities and employee rights can be found within the standard. Refer to OSHA’s final rule for beryllium for more details should your organization determine that medical surveillance is required. MEMIC policyholders are welcome to contact their MEMIC Safety Management Consultant.
The employer must provide initial and annual training to affected employees about beryllium health hazards, including CBD signs and symptoms, the written exposure control plan, use and limitations of personal protective equipment, applicable emergency procedures, measures employees can take to protect themselves, purpose and description of the medical surveillance program, the standard content, and record access rights.
The employer should maintain information about all exposure assessments:
- Date of each assessment.
- Task monitored.
- Sampling and analytical methods used.
- The number, duration and results of samples obtained.
- Personal protective equipment used by monitored employees.
- Name, social security number, and job classification of each employee represented by the monitoring, including which employees were actually monitored.
If objective data was used, the employer must document the data relied upon, the material containing beryllium, the source of the objective data, a description of the process, tasks, or activity in which the objective data were based, and other relevant data. Data related to the medical surveillance and training should also be kept.
Effective Dates (as originally published, now subject to the Trump administration regulatory freeze)
The final rule was to take effect on March 10, 2017. Employers have one year to comply with most of the requirements, two years to provide any required change rooms and showers, and three years from the effective date to implement engineering controls.
(The information provided here is a summary. It should not be interpreted to be the complete text of the OSHA standard.)