The Obama administration’s standard for addressing beryllium exposure in the workplace has taken effect after a short delay by the Trump administration. The new rule contains standards for general industry, construction, and shipyards.
Today we will address the new beryllium standard for general industry and the looming compliance dates. Tomorrow we will offer tips for controlling beryllium exposure in your workplace.
Who Has to Worry?
According to the Occupational Safety and Health Administration (OSHA), about 62,000 workers are exposed to beryllium in their workplaces. The majority of workers affected by this new rule are exposed in general industry operations, such as:
- Beryllium metal and ceramic production;
- Nonferrous foundries;
- Fabrication of beryllium alloy products;
- Secondary smelting, refining, and alloying;
- Precision turned products;
- Copper rolling, drawing, and extruding;
- Welding; and
- Dental laboratories.
The standard for general industry applies to beryllium exposure in all forms, compounds, and mixtures. It does not apply to:
- Articles that contain beryllium and that employers do not process (see the definition of “article” in the Hazard Communication Standard); or
- Materials containing less than 0.1% beryllium by weight. However, employers must have objective data that exposure will remain below the action level of 0.1 micrograms per cubic meter of air (µg/m3) calculated as an 8-hour time-weighted average (TWA) under any foreseeable conditions.
Key Provisions
Key provisions of the new beryllium standard:
- Reduces the permissible exposure limit (PEL) for beryllium to 0.2 mg/m3, averaged over 8-hours;
- Establishes a new short-term exposure limit (STEL) for beryllium of 2.0 mg/m3 over a 15-minute sampling period;
- Requires employers to:
- Use engineering and work practice controls (such as ventilation or enclosure) to limit worker exposure to beryllium;
- Provide respirators when controls cannot adequately limit exposure;
- Limit worker access to high-exposure areas;
- Develop a written exposure control plan; and
- Train workers on beryllium hazards.
- Requires employers to make available medical exams to monitor exposed workers and provides medical removal protection benefits to workers identified with a beryllium-related disease.
When Must You Comply?
For those affected by the new beryllium standard, there are staggered compliance dates:
- March 12, 2018, is the deadline for complying with most elements of the new rule.
- March 11, 2019, is the deadline to provide required change rooms and showers.
- March 10, 2020, is the deadline to implement engineering controls.
Two of the most onerous requirements that are looming for compliance next year (March 12, 2018) are the development of a written beryllium exposure control plan and employee training.
Contents of Written Exposure Control Plan
Elements that the written beryllium exposure control plan must include are:
- 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;
- A list of required engineering controls, work practices, and respiratory protection;
- A list of required personal protective clothing and personal protective equipment (PPE); and
- Procedures for removing, laundering, storing, cleaning, repairing, and disposing of beryllium-contaminated personal protective clothing and PPE, including respirators.
Training
Next year (March 12, 2018) is also the deadline to have beryllium exposure control training in place. There must be initial training for any employee who has, or can reasonably be expected to have, airborne exposure to or dermal contact with beryllium. Then there must be annual refresher training.
Check tomorrow’s Advisor for some tips for controlling employee exposure to beryllium.