Updated following OSHA issuing a new Direct Final Rule (DFR) on May 4.
As we head toward the enforcement date for OSHA’s new beryllium rule, we’ve heard many questions about compliance. One of the best ways companies can keep their workers safe is through diligent housekeeping using appropriate work practice controls.
The housekeeping section of the new standard for general industry is broken into three parts: general, cleaning methods, and disposal. Let’s take a quick look at each.
Housekeeping — General
(i) The employer must maintain all surfaces in beryllium work areas as free as practicable of beryllium and in accordance with the written exposure control plan required under paragraph (f)(1) and the cleaning methods required under paragraph (j)(2) of this standard; and
(ii) The employer must ensure that all spills and emergency releases of beryllium are cleaned up promptly and in accordance with the written exposure control plan required under paragraph (f)(1) and the cleaning methods required under paragraph (j)(2) of this standard.
First, what’s a beryllium work area?
OSHA defines a beryllium work area as “any work area: (1) containing a process or operation that can release beryllium and that involves materials that contain at least 0.1% beryllium by weight; and (2) 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.”
The rule requires employers to establish beryllium work areas in certain circumstances. This helps them keep airborne beryllium contained, rather than allowing it to disperse throughout the facility.
The standard also requires employers to maintain surfaces “as free as practicable” of beryllium. What does that mean?
According to the agency, whether a surface is “as free as practicable” of a contaminant depends on the employer’s housekeeping program. The goal is to minimize the possibility of exposure, and any method that achieves that goal is acceptable. In other words, this requirement is performance-based, giving employers the flexibility to adopt the methods best suited for their applications.
Updated: The May 4 DFR separated “beryllium work areas” from “regulated work areas.” Under the old definitions, all regulated areas where also beryllium work areas. Under the new definitions, it’s possible to have a regulated area that is not also a beryllium work area. For example, a process could involve materials that contain less than 0.1% beryllium by weight but still create exposure above the allowed levels. The DFR specifies that the housekeeping requirements apply to regulated areas, even if they aren’t beryllium work areas.
Housekeeping — Cleaning methods
(i) The employer must ensure that surfaces in beryllium work areas are regulated areas are cleaned by HEPA-filtered vacuuming or other methods that minimize the likelihood and level of airborne exposure.
(ii) The employer must not allow dry sweeping or brushing for cleaning surfaces in beryllium work areas or regulated areas unless HEPA-filtered vacuuming or other methods that minimize the likelihood and level of airborne exposure are not safe or effective.
(iii) The employer must not allow the use of compressed air for cleaning beryllium-contaminated surfaces unless the compressed air is used in conjunction with a ventilation system designed to capture the particulates made airborne by the use of compressed air.
(iv) Where employees use dry sweeping, brushing, or compressed air to clean beryllium-contaminated surfaces, the employer must provide, and ensure that each employee uses, respiratory protection and personal protective clothing and equipment in accordance with paragraphs (g) and (h) of this standard.
(v) The employer must ensure that cleaning equipment is handled and maintained in a manner that minimizes the likelihood and level of airborne exposure and the re-entrainment of airborne beryllium in the workplace.
The guidance here is clear — use a HEPA-filtered vacuum to clean surfaces in beryllium work areas. Dry sweeping and brushing should only be used if HEPA-filtered vacuuming isn’t safe or effective, and compressed air is a last resort that should only be used along with a ventilation system to capture airborne particles.
Housekeeping — Disposal
For materials that contain beryllium in concentrations of 0.1% by weight or more or are contaminated with beryllium, the employer must ensure that::
(i) Materials designated for disposal that contain or are contaminated with beryllium are disposed of in sealed, impermeable enclosures, such as bags or containers, that are labeled in accordance with paragraph (m)(3) of this standard; and
(ii) Materials designated for recycling that contain or are contaminated with beryllium are cleaned to be as free as practicable of surface beryllium contamination and labeled in accordance with paragraph (m)(3) of this standard, or placed in sealed, impermeable enclosures, such as bags or containers, that are labeled in accordance with paragraph (m)(3) of this standard.
The goal of this section is to ensure that once beryllium-contaminated materials are collected, they are disposed of safely. For example, a filter cleaning system and the proper collection option system on your HEPA-filtered vacuum cleaner will limit worker exposure during cleaning.
May 11 will be here before you know it! If you’re in one of the industries impacted by the beryllium rule, there’s no time to delay. If you have any questions about the housekeeping section or would like more information about HEPA-filtered vacuums, contact us today.