1. Final Rule to Protect Workers from Beryllium Exposure
INTRODUCTION TO OSHA Lesson
Final Rule to Protect Workers from Beryllium Exposure
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2. INTRODUCTION TO OSHA Lesson
Disclaimer
You should not construe any statements or information presented above to create (or to diminish) legal obligations under the Occupational Safety and Health Act, since these obligations are defined by federal regulations.
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3. INTRODUCTION TO OSHA Lesson
Beryllium
A metal that is stronger than steel and lighter than aluminum. Its strength-to-weight, high melting point, excellent thermal stability and conductivity make it an essential material in some industries.
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4. INTRODUCTION TO OSHA Lesson
Health Hazards
Chronic Beryllium Disease (CBD) is a serious pulmonary disease that can cause serious debilitation or death. Signs and symptoms of CBD can include shortness of breath, an unexplained cough, fatigue, weight loss, fever, and night sweats.
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5. INTRODUCTION TO OSHA Lesson
Overview
About 62,000 workers are exposed to beryllium in their workplaces. The majority of workers affected by this rule are exposed in general industry operations such as beryllium metal and ceramic production, non-ferrous foundries, and fabrication of beryllium alloy products.
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6. INTRODUCTION TO OSHA Lesson
Final Rule
On January 9, 2017, OSHA published its final rule, Ocupational Exposure to Beryllium. General Industry – Construction Industry – Shipyards –
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7. Notice of Proposed Rulemaking
INTRODUCTION TO OSHA Lesson
Notice of Proposed Rulemaking
On June 27, 2017, OSHA issued a Notice of Proposed Rulemaking, Occupational Exposure to Beryllium and Beryllium Compounds in Construction and Shipyard Sectors, to revoke the ancillary provisions of the Construction and shipyard standards, but retain the PELs
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8. INTRODUCTION TO OSHA Lesson
Key Provisions
Reduces the permissible exposure limit (PEL) for beryllium to 0.2 micrograms per cubic meter of air, averaged over 8-hours. Establishes a new short term exposure limit for beryllium of 2.0 micrograms per cubic meter of air, over a 15-minute sampling period.
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9. INTRODUCTION TO OSHA Lesson
Key Provisions
Use of engineering and work practice controls to limit worker exposure. 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.
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10. INTRODUCTION TO OSHA Lesson
Key Provisions
Requires employers to make available medical exams to monitor exposed workers Provides medical removal protection benefits to workers identified with a beryllium-related disease.
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11. INTRODUCTION TO OSHA Lesson
Key Limits
Action Level – 0.1 micrograms per cubic meter of air. Permissible Exposure Limit (PEL) – 0.2 micrograms per cubic meter of air. Short-Term Exposure Limit (STEL) – 2.0 micrograms per cubic meter.
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12. Overview of General Industry Standard
INTRODUCTION TO OSHA Lesson
Overview of General Industry Standard
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13. INTRODUCTION TO OSHA Lesson
a) Scope
Applies to occupational exposure to beryllium in all forms, compounds, and mixtures.
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14. INTRODUCTION TO OSHA Lesson
Exemptions
1) Articles as defined by HAZCOM which are not processed.
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15. INTRODUCTION TO OSHA Lesson
Article under HAZCOM
Article means a manufactured item other than a fluid or particle: (i) which is formed to a specific shape or design during manufacture; (ii) which has end use function(s) dependent in whole or in part upon its shape or design during end use; and (iii) which under normal conditions of use does not release more than very small quantities, e.g., minute or trace amounts of a hazardous chemical, and does not pose a physical hazard or health risk to employees.
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16. INTRODUCTION TO OSHA Lesson
Exemptions
2) This standard does not apply to materials containing less than 0.1% beryllium by weight where the employer has objective data demonstrating that employee exposure to beryllium will remain below the action level as an 8-hour TWA.
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17. b) Definitions – General Industry
INTRODUCTION TO OSHA Lesson
b) Definitions – General Industry
Beryllium work area means any work area: (i) Containing a process or operation that can release beryllium and that involves material that contains at least 0.1 percent beryllium by weight; and (ii) Where employees are, or can reasonably be expected to be, exposed to airborne beryllium at any level or where there is the potential for dermal contact with beryllium.
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18. b) Definitions – General Industry
INTRODUCTION TO OSHA Lesson
b) Definitions – General Industry
Regulated area means an area, including temporary work areas where maintenance or non-routine tasks are performed, where an employee's airborne exposure exceeds, or can reasonably be expected to exceed, either the time-weighted average (TWA) permissible exposure limit (PEL) or short term exposure limit (STEL).
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19. c) Permissible Exposure Limits
INTRODUCTION TO OSHA Lesson
c) Permissible Exposure Limits
The employer must ensure that no employee is exposed to an airborne in excess of: Permissible Exposure Limit (PEL) – 0.2 micrograms per cubic meter of air. Short-Term Exposure Limit (STEL) – 2.0 micrograms per cubic meter.
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20. d) Exposure Assessment
INTRODUCTION TO OSHA Lesson
d) Exposure Assessment
The employer must assess the airborne
exposure of each employee who is or may
reasonably be expected to be exposed to
airborne beryllium in accordance with either
the:
Performance Option or
Scheduled Monitoring Option
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21. d) Exposure Assessment
INTRODUCTION TO OSHA Lesson
d) Exposure Assessment
Performance Option – Must asses 8-hour TWA 15-minute STEL on the basis of any combination of air monitoring data and objective data.
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22. d) Exposure Assessment
INTRODUCTION TO OSHA Lesson
d) Exposure Assessment
Performance Option – The performance option is intended to allow employers flexibility in assessing the beryllium exposures of their employees.
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23. d) Exposure Assessment
INTRODUCTION TO OSHA Lesson
d) Exposure Assessment
Scheduled Monitoring Option TWA – The employer must perform initial monitoring to assess the 8-hour TWA exposure for each employee on the basis of one or more personal breathing zone air samples that reflect the airborne exposure of employees on each shift, for each job classification, and in each work area.
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24. d) Exposure Assessment
INTRODUCTION TO OSHA Lesson
d) Exposure Assessment
Monitoring Option STEL– The employer must perform initial monitoring to assess the short- term exposure from 15-minute personal breathing zone air samples measured in operations that are likely to produce airborne exposure above the STEL for each work shift, for each job classification, and in each work area.
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25. d) Exposure Assessment – Monitoring Option
INTRODUCTION TO OSHA Lesson
d) Exposure Assessment – Monitoring Option
If initial monitoring indicates that airborne exposure is below the action level and at or below the STEL, the employer may discontinue monitoring for those employees whose airborne exposure is represented by such monitoring. (DISCONTINUE)
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26. d) Exposure Assessment – Monitoring Option
INTRODUCTION TO OSHA Lesson
d) Exposure Assessment – Monitoring Option
Where the most recent exposure monitoring indicates that airborne exposure is above the STEL, the employer must repeat such monitoring within three months of the most recent short-term exposure monitoring until two consecutive measurements, taken 7 or more days apart, are below the STEL, at which time the employer may discontinue short-term exposure monitoring (3 MONTHS)
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27. d) Exposure Assessment – Monitoring Option
INTRODUCTION TO OSHA Lesson
d) Exposure Assessment – Monitoring Option
Where the most recent exposure monitoring indicates that airborne exposure is above the TWA PEL, the employer must repeat such monitoring within three months of the most recent 8-hour TWA exposure monitoring. (3 MONTHS)
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28. d) Exposure Assessment – Monitoring Option
INTRODUCTION TO OSHA Lesson
d) Exposure Assessment – Monitoring Option
Where the most recent exposure monitoring indicates that airborne exposure is at or above the action level but at or below the TWA PEL, the employer must repeat such monitoring within six months of the most recent monitoring. (6 MONTHS)
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29. d) Exposure Assessment – Monitoring Option
INTRODUCTION TO OSHA Lesson
d) Exposure Assessment – Monitoring Option
The facility continues to sample in accordance with the monitoring plan and ….
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30. d) Exposure Assessment – Monitoring Option
INTRODUCTION TO OSHA Lesson
d) Exposure Assessment – Monitoring Option
Where the most recent (non-initial) exposure monitoring indicates that airborne exposure is below the action level, the employer must repeat such monitoring within six months of the most recent monitoring until two consecutive measurements, taken 7 or more days apart, are below the action level, at which time the employer may discontinue 8-hour TWA exposure monitoring. (6 MONTHS, DISCONTINUE)
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31. d) Reassessment of Exposure
INTRODUCTION TO OSHA Lesson
d) Reassessment of Exposure
Reassessment: Under certain circumstances, such as a change in the production, process, control, equipment, materials, personnel, or work practices may reasonably be expected to result in new or additional airborne exposures at or above the AL or STEL.
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32. d) Employee Notification
INTRODUCTION TO OSHA Lesson
d) Employee Notification
Within 15 working days after completing the exposure assessment, the employer must notify each employee whose airborne exposure is represented by the assessment of the results of the assessment individually in writing or post the results.
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33. d) Employee Notification
INTRODUCTION TO OSHA Lesson
d) Employee Notification
IF exposure assessment, above TWA PEL or STEL, the employer must describe in writing Corrective action taken to reduce exposure.
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34. d) Employee Notification
INTRODUCTION TO OSHA Lesson
d) Employee Notification
Observation and Monitoring – The employer must provide an opportunity to observe any exposure monitoring.
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35. INTRODUCTION TO OSHA Lesson
e) Establishment
Paragraph (e) sets forth the requirements for establishing, maintaining, demarcating, and limiting access to certain areas of the workplace to aid in minimizing employee exposure to beryllium.
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36. e) Work and Regulated Areas – 1910 Regulations
INTRODUCTION TO OSHA Lesson
e) Work and Regulated Areas – 1910 Regulations
Must establish and maintain a beryllium work area wherever the criteria for a "beryllium work area" are met. Must identify each beryllium work area through signs or any other methods that adequately establish and inform each employee of the boundaries of each beryllium work area.
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37. Definitions – General Industry
INTRODUCTION TO OSHA Lesson
Definitions – General Industry
Beryllium work area means any work area: (i) Containing a process or operation that can release beryllium and that involves material that contains at least 0.1 percent beryllium by weight; and (ii) Where employees are, or can reasonably be expected to be, exposed to airborne beryllium at any level or where there is the potential for dermal contact with beryllium.
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38. e) Work and Regulated Areas – 1910 Regulations
INTRODUCTION TO OSHA Lesson
e) Work and Regulated Areas – 1910 Regulations
Establish and maintain a beryllium regulated area when exposure to airborne beryllium at Levels above the TWA, PEL, or STEL. Must identify each regulated area (warning signs).
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39. Definitions – General Industry
INTRODUCTION TO OSHA Lesson
Definitions – General Industry
Regulated area means an area, including temporary work areas where maintenance or non-routine tasks are performed, where an employee's airborne exposure exceeds, or can reasonably be expected to exceed, either the time-weighted average (TWA) permissible exposure limit (PEL) or short term exposure limit (STEL).
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40. f) Methods of Compliance
INTRODUCTION TO OSHA Lesson
f) Methods of Compliance
Paragraph (f) of the standard establishes methods for reducing employee exposure to Beryllium through the use of a written exposure control plan and engineering and work practice controls.
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41. f) Methods of Compliance
INTRODUCTION TO OSHA Lesson
f) Methods of Compliance
Written Exposure Control Plan - Requires employers to establish, implement, and maintain a written exposure control plan and specifies the information that must be included in the plan.
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42. f) Methods of Compliance
INTRODUCTION TO OSHA Lesson
f) Methods of Compliance
Engineering and work practice controls The employer must use engineering and work practice controls to reduce and maintain employee airborne exposure to beryllium to or below the PEL and STEL.
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43. f) Methods of Compliance – Engineering and Work Practice Controls
INTRODUCTION TO OSHA Lesson
f) Methods of Compliance – Engineering and Work Practice Controls
Beryllium Work Areas:
At least one of the following must be in place:
Material and/or process substitution
Isolation – ventilation partial or full enclosures
Local exhaust ventilation
Process controls
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44. f) Methods of Compliance – Engineering and Work Practice Controls
INTRODUCTION TO OSHA Lesson
f) Methods of Compliance – Engineering and Work Practice Controls
An employer is exempt from using the controls
listed to the extent that:
The employer can establish that such controls are not feasible; or
The employer can demonstrate that airborne exposure is below the action level
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45. f) Prohibition of Rotation
INTRODUCTION TO OSHA Lesson
f) Prohibition of Rotation
Worker rotation can potentially reduce exposures to individual employees, but increases the number of employees exposed. The employer must not rotate employees to different jobs to achieve compliance with the PELs.
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46. g) Respiratory Protection
INTRODUCTION TO OSHA Lesson
g) Respiratory Protection
Paragraph (g) of the standard establishes the requirements for the use of respiratory protection.
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47. h) Personal Protective Equipment and Clothing
INTRODUCTION TO OSHA Lesson
h) Personal Protective Equipment and Clothing
To protect employees from adverse health effects, these PPE requirements are intended to prevent dermal exposure to beryllium, and prevent the accumulation of airborne beryllium on clothing, shoes, and equipment, which can result in additional inhalation exposure.
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48. h) Personal Protective Equipment and Clothing
INTRODUCTION TO OSHA Lesson
h) Personal Protective Equipment and Clothing
Requires employers to provide employees with personal protective clothing and equipment (PPE) where employee exposure exceeds or can reasonably be expected to exceed the TWA PEL or STEL and where there is reasonable expectation of dermal contact with beryllium.
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49. h) Personal Protective Equipment and Clothing
INTRODUCTION TO OSHA Lesson
h) Personal Protective Equipment and Clothing
Provisions and Use
Removal and Storage
Cleaning and Replacement
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50. i) Hygiene Areas and Practices – General Industry
INTRODUCTION TO OSHA Lesson
i) Hygiene Areas and Practices – General Industry
For each employee working in a beryllium work area, the employer must provide employees with readily accessible washing facilities to remove beryllium from the hands, face, and neck.
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51. i) Hygiene Areas and Practices – General Industry
INTRODUCTION TO OSHA Lesson
i) Hygiene Areas and Practices – General Industry
For each employee working in a beryllium work area, the employer must provide employees with a designated change room.
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52. i) Hygiene Areas and Practices – General Industry
INTRODUCTION TO OSHA Lesson
i) Hygiene Areas and Practices – General Industry
Showers - Requires employers in general Industry to provide and ensure the use of showers if employees are or can reasonably be expected to be exposed above the TWA, PEL or STEL AND If beryllium could reasonably be expected to contaminate the employees’ body parts other than hands, face, and neck.
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53. j) Housekeeping – General Industry
INTRODUCTION TO OSHA Lesson
j) Housekeeping – General Industry
Requires employers to maintain all surfaces in beryllium work areas as free as practicable of beryllium; promptly clean spills and emergency releases of beryllium; use appropriate cleaning methods; and properly dispose of materials containing or contaminated with beryllium.
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54. j) Housekeeping – Construction Industry
INTRODUCTION TO OSHA Lesson
j) Housekeeping – Construction Industry
Requires employers to follow the written exposure control plan. Spills and emergency releases are cleaned up promptly.
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55. k) Medical Surveillance
INTRODUCTION TO OSHA Lesson
k) Medical Surveillance
Specifies which employees must be offered medical surveillance, as well as the frequency and content of medical examinations.
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56. k) Medical Surveillance
INTRODUCTION TO OSHA Lesson
k) Medical Surveillance
The purposes of medical surveillance:
(1) To identify beryllium-related adverse health effects so that appropriate intervention
measures can be taken;
(2) to determine if an employee has any condition that might make him or her more sensitive to beryllium exposure; and
(3) To determine the employee’s fitness to use
personal protective equipment such as respirators.
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57. k) Medical Surveillance
INTRODUCTION TO OSHA Lesson
k) Medical Surveillance
Exposed AL or above for > 30 days per year Exposed to beryllium during an emergency Based on recent medical opinion
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58. INTRODUCTION TO OSHA Lesson
l) Medical Removal
Under the standard employees may be eligible for medical removal. Example would be a written medical report indicating a confirmed positive finding or CBD diagnosis Chronic beryllium disease (CBD)
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59. INTRODUCTION TO OSHA Lesson
l) Medical Removal
Employers must provide eligible employees with a choice of removal from exposure at or above the action level or remaining in their job with airborne exposure at or at or above the action level and wearing a respirator.
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60. INTRODUCTION TO OSHA Lesson
l) Medical Removal
If the employee chooses removal, the employer is required to remove the employee to comparable work in a work environment where the airborne exposure is below the action level, if such work is available. If comparable work is not available, the employer must maintain the employee’s base earnings, seniority, and other rights and benefits that existed at the time of removal for six months or until such time that comparable work becomes available.
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61. m) Communication of Hazards
INTRODUCTION TO OSHA Lesson
m) Communication of Hazards
Requires employers to include beryllium in the hazard communication program. Must provide initial training to each employee by the time of initial assignment; and Training must be repeated annually.
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62. m) Communication of Hazards
INTRODUCTION TO OSHA Lesson
m) Communication of Hazards
Employees to demonstrate knowledge and understanding of the following: The health hazards associated with airborne exposure to and contact with beryllium; The written exposure control plan, with emphasis on the location(s) of beryllium work areas, including any regulated areas, and the specific nature of operations that could result in airborne exposure, especially airborne exposure above the TWA PEL or STEL
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63. m) Communication of Hazards – General Industry
INTRODUCTION TO OSHA Lesson
m) Communication of Hazards – General Industry
Requires employers to provide and display warning signs at each approach to a regulated area so that each employee is able to read and understand the signs and take necessary protective steps before entering the area. Regulated Area – An area where an employee’s airborne exposure exceeds either the PEL or STEL
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64. m) Communication of Hazards – General Industry
INTRODUCTION TO OSHA Lesson
m) Communication of Hazards – General Industry
Warning Signs Must Bear: DANGER BERYLLIUM MAY CAUSE CANCER CAUSES DAMAGE TO LUNGS AUTHORIZED PERSONNEL ONLY WEAR RESPIRATORY PROTECTION AND PROTECTIVE CLOTHING AND EQUIPMENT IN THIS AREA
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65. m) Communication of Hazards
INTRODUCTION TO OSHA Lesson
m) Communication of Hazards
Requires employers to label each bag and container of clothing, equipment, and materials contaminated with beryllium.
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66. m) Communication of Hazards – General Industry
INTRODUCTION TO OSHA Lesson
m) Communication of Hazards – General Industry
At a minimum the label must include the following: DANGER CONTAINS BERYLLIUM MAY CAUSE CANCER CAUSES DAMAGE TO LUNGS AVOID CREATING DUST DO NOT GET ON SKIN
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67. m) Communication of Hazards – General Industry
INTRODUCTION TO OSHA Lesson
m) Communication of Hazards – General Industry
For each employee who has, or can reasonably be expected to have, airborne exposure to or dermal contact with beryllium: Must provide information and training in accordance with the HCS; Must provide initial training to each employee by the time of initial assignment; and Must repeat the training annually for each employee.
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68. INTRODUCTION TO OSHA Lesson
n) Recordkeeping
Sets forth the employer’s obligation to comply with requirements to maintain records of air monitoring data, objective data, medical surveillance, training, and transfer of records.
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69. INTRODUCTION TO OSHA Lesson
n) Recordkeeping
The employer must make and maintain a record of all exposure measurements taken to assess airborne exposure.
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70. Appendix A – General Industry
INTRODUCTION TO OSHA Lesson
Appendix A – General Industry
Control Strategies To Minimize Beryllium Exposure Provides information to employers on control options that employers could use. The construction standards do not contain Appendix A.
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71. INTRODUCTION TO OSHA Lesson
Compliance Schedule
Employers must comply with most elements of the rule starting March 12, Employers have an additional year - until March 11, to provide required change rooms and showers Employers have an additional two years – until March 10, to implement engineering controls.
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72. INTRODUCTION TO OSHA Lesson
Compliance Schedule
Obligations contained in paragraphs: (c) Permissible Exposure Limits (d) Exposure Assessment (g) Respiratory Protection (k) Medical Surveillance (l) Medical Removal March 12, 2018
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73. INTRODUCTION TO OSHA Lesson
Compliance Schedule
All other obligations December 12, 2018
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74. Enforcement General Industry
INTRODUCTION TO OSHA Lesson
Enforcement General Industry
General industry PEL
§ (c);
General industry exposure assessment at § (d);
General industry respiratory protection § (g);
General industry medical surveillance § (k); and
General industry medical removal at § (l).
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75. INTRODUCTION TO OSHA Lesson
Federal Register
DEPARTMENT OF LABOR
Occupational Safety and Health
Administration
29 CFR Parts 1910, 1915, and 1926
[Docket No. OSHA–H005C–2006–0870]
RIN 1218–AB76
Occupational Exposure to Beryllium
AGENCY: Occupational Safety and Health
Administration (OSHA), Department of
Labor.
ACTION: Final rule.
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76. Frequently Asked Questions
INTRODUCTION TO OSHA Lesson
Frequently Asked Questions
Frequently Asked Questions Beryllium and Beryllium Compounds
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77. Noel Buitrago Assistant Area Director
INTRODUCTION TO OSHA Lesson
Noel Buitrago Assistant Area Director
Thank You!
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