HazCom’s Consumer Product Exemption
OSHA Issues Final Rule for Beryllium – Part II.

OSHA Issues Final Rule for Beryllium – Part I.

  Pieretti Posted by Luis Pieretti, PhD, CIH, CSP

In January 2017, OSHA issued its final rule for beryllium.  Standards were issued for the general industry (1910.1024), shipyard industry (1915.1024) and the construction industry (1926.1124).  More information on where beryllium is present in the workplace and the previous standard can be found here.  As expected, the new rule reduces the permissible exposure limit (PEL) for beryllium to 0.2 µg/m3 averaged over 8 hours (time weighted average or TWA) and also establishes a short term exposure limit (STEL) of 2 µg/m3.  This is the first of a three part series that addresses the general industry requirements.

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Exposure Assessment

The general industry standard requires employers to conduct exposure assessments.  These include (as specified in the standard) initial monitoring to assess short term exposures for each work shift/each job classification and each area where operations are likely to produce airborne exposures above the STEL. Additional monitoring may be required if exposures are above the new STEL and/or PEL.  Monitored employees should be notified of the results.  Where the exposure assessment indicates airborne exposures above the STEL or PEL, the employer must describe in the written notification the correction action taken to reduce airborne exposure to or below the limit exceeded where feasible corrective action exists but had not been implemented when the monitoring was conducted.

Work Areas

The employer must establish and maintain beryllium work areas (areas where employees are or can reasonably be expected to be exposed to airborne beryllium levels above the regulatory limits).  Areas must be identified and access should be limited. All employees entering the regulatory areas must be provided with respiratory protection and personal protective clothing.

Written Exposure Control Plan

Additionally, the employer shall develop a written exposure control plan.  This plan should list the operations and job titles expected to have dermal contact with beryllium, or airborne exposure at or above the STEL or PEL. It should also contain procedures to minimize cross-contamination including transfer of beryllium between surfaces, equipment, clothing, and materials within the beryllium work areas.   A list of engineering controls, work practices, and respiratory protection should also be included.  Lastly, identifying required personal protective clothing and procedures for removing, laundering, storing, cleaning, repairing and disposing beryllium-contaminated personal protective clothing and equipment, including the respirators is required. 

This plan should be reviewed at least annually or when necessary as stated in the standard.  Reviews are required if:

  • Any changes in production that can reasonably be expected to result in new or additional airborne exposure to beryllium.
  • The employer is notified that an employee is eligible for medical removal, referred for evaluation or shows signs or symptoms associated with airborne exposure to or dermal contact with beryllium.
  • The employer has any reason to believe that new or additional airborne exposure is, or could occur.

Engineering Controls

The employer must ensure that at least one of the following controls is in place for each operation in a beryllium work area that releases airborne beryllium:

  • Material/process substitution.
  • Isolation (full or partial ventilated enclosures).
  • Local exhaust ventilation at the point of operation, material handling and/or transfer.
  • Process controls such as wet methods and automation.

If controls cannot lower the airborne concentrations below the PEL, the employer must implement and maintain engineering and work practices controls to reduce the airborne concentration to the lowest feasible level and supplement these controls with respiratory protection.  The standard also states that rotating employees to different jobs to achieve compliance with the PEL is prohibited.

In our next post, we will cover the requirements for respiratory protection, personal protective clothing and equipment, hygiene practices and housekeeping.

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