OSHA has released a new beryllium standard for both general industry and construction.
Update: This regulation has been delayed 60 days by President Trump’s administration Jan. 20 regulatory freeze and review instructions
OSHA just released a new beryllium standard for both general industry and construction. This is more than just a revised Permissible Exposure Limit (PEL). This is an entire compliance standard – one for general industry and one for construction. The most notable changes are that the current beryllium 2.0 microgram PEL (2.0 micrograms per cubic meter as an 8-hour time weighted average) will be lowered to 0.2 micrograms, the current 5.0 microgram ceiling limit will be eliminated, a 2.0 microgram Short Term Exposure Limit (STEL) will be added, and provisions to prevent skin contact will be added.
Although beryllium doesn’t get near the media attention that other metals get like lead or mercury, it does have a relatively high toxicity and exposure accounts for about 96 deaths per year. Beryllium overexposure has been linked to lung diseases including lung cancer and a condition called Chronic Beryllium Disease (formerly called berylliosis) which are both preventable. In this article, we will take a closer look at this new beryllium standard and compliance requirements. Although the new standard seems rather in-depth and complex, it’s really not that bad.
First, a little background. Beryllium is a light-weight metal that isn’t found naturally as a stand-alone metal. It occurs naturally as a complex with other chemicals. Consequently, elemental beryllium must be extracted from metal complexes. Beryllium’s low molecular weight and other properties make it ideal for X-ray and other high-tech scientific applications. It can be easily alloyed with other metals, especially copper. The resulting alloy is harder and more corrosion resistant which makes it ideal for aerospace applications. In standard industrial applications, beryllium is used in high-end acoustical systems, semi-conductors, and printed circuitry boards. It is also found in dental alloys.
How is beryllium harmful? Exposure to beryllium dusts, fume (welding), mists, and solutions can cause a lung condition called Chronic Beryllium Disease or CBD, formerly called berylliosis. Additionally, beryllium exposure has been linked to lung cancer. CBD is well known and well documented. In addition to lung diseases, beryllium is also a skin sensitizer which means that repeated skin exposure can cause problems as well.
How can workers be exposed to beryllium? Beryllium exposure is typically found in the manufacture of ceramics and metal alloys, smelting, dental laboratories where beryllium alloys are made, and coal-fired power generators where workers are exposed to fly ash. As with many metals, the primary exposure concern is the dusts, fumes, mists, and solutions that occur during the refining and processing steps. However, solid metallic beryllium is a skin sensitizer, so skin exposure to beryllium can cause rashes.
What is the scope of this new rule? This standard applies to general industry and construction applications where there is the potential exposure to beryllium by breathing and skin contact. For example, if you operate a warehouse that contains high-end acoustical equipment in sealed containers, then you do not fall under the scope of the standard (the article exemption). If you do any type of processing, machining, handling, or manipulating beryllium-containing materials, then you probably are covered by this standard.
When does this new rule take effect? Most provisions of this new beryllium standard take effect March 12, 2018. The requirement to provide showers (general industry) and change rooms (everybody) take effect March 11, 2019, and the engineering controls requirement takes effect March 10, 2020.
The new OSHA Beryllium General Industry Standard (29 CFR 1910.1024)
- If employees have a potential for beryllium exposure, their 8-hour time-weighted average exposure and their 15-minute short-term exposure must be determined by air sampling or the use of air sampling data that reflects their exposure. If air sampling is used, then employees must be notified of their results.
- Areas where employees can be exposed to beryllium at any level including skin contact must be designated as beryllium work areas. Beryllium work areas must be designated by signs or other means. If exposures in the beryllium work area are above the PEL or STEL, the area must be designated as a beryllium regulated area and marked with a specific sign.
- If there are areas in the facility with airborne or skin contact with beryllium, operations and job titles for employees working in these area must be identified in a written Exposure Control Plan. This plan must delineate areas in the facility where there is any exposure, exposures above the action level, and exposures above the PEL. The plan must identify other requirements in the different exposure areas (housekeeping, respiratory protection, PPE, etc.). Also, the plan must be reviewed annually.
- Employees who will have airborne exposures above the PEL (or STEL) or will have skin contact with beryllium must wear protective clothing separate from street clothing, must shower at the end of their shift, and are prohibited from eating, drinking, or using tobacco products while in a beryllium-regulated area.
- Employees exposed to beryllium at the Action Level of 0.1 micrograms for more than 30 days per year must be included in a medical surveillance program and must have a medical examination available to them every two years.
- Employees who have the potential for any beryllium exposure must be trained annually on the health hazards of beryllium, processes where beryllium is being used, methods of protection, beryllium work areas, beryllium regulated areas (if any), etc. Additionally, employees must be able to demonstrate knowledge of the training.
As a final note, the beryllium standard contains a lot of specifics that weren’t identified above. However, this gives a basic overview and a general direction if you have beryllium processing at your facility. This beryllium standard has a lot of similarities with existing metals standards like lead and arsenic. Consequently, if you have experience with lead or arsenic, you’ll have no problem with the new beryllium standard.