OSHA Publishes Beryllium Compliance Guidance

by Mike DeBlasi | July 12, 2021 10:20 am

OSHA has just released new resources to help businesses act in accordance with beryllium compliance — and employers are advised to take notice.

Poised for action

With the final rule[1] revising the Beryllium Standard for General Industry published last summer — and the release of updated enforcement guidance [2]for regional offices in April — OSHA is now poised for taking action.

To facilitate implementation and compliance, OSHA has just released a small entity compliance guide[3]. Concurrently, the agency published guidance about the medical surveillance [4]of beryllium-exposed workers, including updated information and resources for employees about the beryllium lymphocyte proliferation test (BeLPT).[5]

New rules

The final rule for occupational exposures to beryllium is described in three separate standards, 29 CFR 1910.1024[6] for general industry, 29 CFR 1926.1124[7] for construction, and 29 CFR 1915.1024 [8]for shipyards.

The big change is the rule’s permissible exposure limit (PEL) of 0.2 micrograms of beryllium per cubic meter of air (µg/m3), measured as an 8-hour time-weighted average (TWA) concentration. The previous limit had been 2.0 micrograms. The new rule also establishes an Action Level (AL) of 0.1 µg/m3 and a short-term exposure limit (STEL) of 2.0 µg/m3, measured over a 15-minute sampling period. The rule mandates that employers use “engineering and work practice controls” to reduce airborne concentrations of beryllium to levels below the PEL and STEL.

Review and prepare

Employers in impacted industries should be taking steps now to review their assessment, engineering controls, respiratory protection, personal protective equipment, training, and recordkeeping procedures to make sure they are compliant.

Should you have questions or concerns about your compliance with the new beryllium standard— or if you have received a citation for any reason — feel free to contact me to discuss options.

About the Author: James Laboe[9]

 

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Endnotes:
  1. final rule: https://www.osha.gov/sites/default/files/laws-regs/federalregister/2020-07-14_2.pdf
  2. updated enforcement guidance : https://www.osha.gov/laws-regs/standardinterpretations/2021-04-21
  3. small entity compliance guide: https://www.osha.gov/beryllium/small-entity-guide
  4. medical surveillance : https://www.osha.gov/sites/default/files/publications/OSHA4116.pdf
  5. beryllium lymphocyte proliferation test (BeLPT).: https://www.energy.gov/ehss/beryllium-testing
  6. 29 CFR 1910.1024: https://ecfr.federalregister.gov/current/title-29/subtitle-B/chapter-XVII/part-1910/subpart-Z/section-1910.1024
  7. 29 CFR 1926.1124: https://ecfr.federalregister.gov/current/title-29/subtitle-B/chapter-XVII/part-1926/subpart-Z/section-1926.1124
  8. 29 CFR 1915.1024 : https://ecfr.federalregister.gov/current/title-29/subtitle-B/chapter-XVII/part-1915/subpart-Z/section-1915.1024
  9. James Laboe: https://orr-reno.com/our-people/james-f-laboe/

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