• Leadership Update

Deadline Approaching for Compliance with Most of OSHA’s Beryllium Rule’s Requirements for General-Industry

While OSHA has said the general-industry rule has been the topic of “extensive settlement talks” with several parties, except for certain provisions requiring changing rooms and showers and some engineering controls, all aspects of the beryllium rule for general industry will be enforced beginning May 11, 2018.

What that means for ISRI members?

The rule (29 CFR 1910.1024), promulgated in January 2017, sets a new, lower eight-hour permissible exposure limit (PEL) of 0.2 micrograms per cubic meter and a new short-term (15-minute) exposure limit (STEL) of 2.0 micrograms per cubic meter.

The standard applies to occupational exposure to beryllium in all forms, compounds, and mixtures in general industry except for those specifically exempted.

End products containing beryllium and beryllium compounds are used in many industries including:

  • Aerospace (aircraft braking systems, engines, satellites, space telescope)
  • Automotive (anti- lock brake systems, ignitions)
  • Defense (components for  nuclear weapons, missile parts, guidance systems, optical systems)
  • Electronics (x- rays, computer parts, telecommunication parts, automotive parts)
  • Energy (microwave devices, relays)
  • Medicine (laser devices, electro-medical devices, X-ray windows)
  • Nuclear energy (heat shields, reactors)
  • Sporting goods (golf clubs, bicycles)
  • Telecommunications (optical systems, wireless base stations)

Exposure to beryllium can occur when cutting, torching, or welding of the materials listed above. Employees who torch or weld these materials run the greatest risk of exposure. Workers are primarily exposed to beryllium by breathing in dusts, fumes, or mists containing beryllium. Beryllium compounds can also get on the skin, contaminate clothing or food, and be ingested.

Employers must assess employee exposures to beryllium. That includes determining if material being received at the recycling facility contains beryllium. If it does then the employer must determine if dust, fumes, or mists are being created in the processing of the beryllium scrap. This can be done by monitoring employees and areas for in a manner similar to monitoring for other hazardous metals such as lead or cadmium.

Employers must establish and maintain a regulated area if employees are, or can reasonably be expected to be, exposed to airborne beryllium at levels above the listed TWA PEL or STEL in that work area. Employers must also provide and ensure that each employee entering a regulated area uses the appropriate respiratory protection and PPE.

Where the employer has identified regulated work areas a written exposure control plan must be developed that provides among other requirements:

  • A list of operations and job titles reasonably expected to involve airborne exposure to or dermal contact with beryllium;
  • A list of operations and job titles reasonably expected to involve airborne exposure at or above the action level;
  • A list of operations and job titles reasonably expected to involve airborne exposure above the TWA PEL or STEL;
  • Procedures for minimizing cross-contamination, including preventing the transfer of beryllium between surfaces, equipment, clothing, materials, and articles within beryllium work areas;
  • Procedures for keeping surfaces as free as practicable of beryllium;
  • Procedures for minimizing the migration of beryllium from beryllium work areas to other locations within or outside the workplace;
  • Procedures for removing, laundering, storing, cleaning, repairing, and disposing of beryllium-contaminated personal protective clothing and equipment, including respirators

The changing rooms and showers provisions of the rule are effective on March 11, 2019, and requirements for engineering controls for beryllium on March 10, 2020.

More specific information concerning the Beryllium Rule can be found at OSHA's Beryllium Rule Webpage.

Contact Terry Cirone if you have questions on the above information. 

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