The rollout of OSHA’s new beryllium standard has been rocky, to say the least. There have been numerous delays and adjustments, but some parts of the standard are already in enforcement, and the others will follow, even if they’re delayed.
To learn more about the beryllium standard and clear up any misconceptions on the part of employers, we spoke with Tom Anthos, the president of TriMedia Environmental & Engineering, a professional services firm that offers industrial hygiene, safety, and environmental consulting, as well as surveying, GIS, and drone services. Anthos has been an industrial hygienist for more than 20 years and TriMedia’s president for the last 10.
Why we need a beryllium standard
Beryllium has been used in manufacturing for decades. So, why is OSHA just issuing a standard now? According to Anthos, it’s because of what industry looks like today.
“Beryllium and beryllium compounds have become more prevalent because the industries in which they’re used, like aerospace, electronics, energy, and telecommunications, have become more prominent in our lives,” he explains. “Historically, we didn’t understand that it was going to be a problem. Now, we see the canary in the coal mine.” The increase in the manufacturing of tech products has led to more people being exposed, and we’ve started to see the health effects [i.e., lung cancer and other pulmonary disease].”
Like with silica dust, there has been a permissible exposure limit (PEL) for beryllium for decades. But that level was still too high to keep workers safe. “Even at levels below the old PEL, people were experiencing health effects,” Anthos said. “So OSHA did additional studies, and based on what they saw in the field they developed a new standard that pushed the PEL significantly lower than it was in the past.”
Where beryllium needs to be controlled
Anthos notes that there are two main components of beryllium control and a complete control plan needs to incorporate both:
- Controlling the fumes. When beryllium is heated, it creates fumes composed of very small particulate. This requires point-source control (i.e., control at the point of fume generation), such as local exhaust ventilation (LEV).
- Controlling the dusts. When those fumes cool, the particulate settles into dust. This requires housekeeping equipment designed to pick up and trap beryllium-containing dust. Specifically, it requires a HEPA vacuum.
Misconceptions and mistakes
The various delays and changes to the rule have led to confusion about when enforcement will actually start. According to an OSHA memo dated May 9, 2018, these are the only parts of the standards that went into effect as of May 11:
- General industry: PEL, exposure assessment, respiratory protection, medical surveillance, and medical removal
- Construction: PEL only
- Shipyard: PEL only
OSHA said in the memo that it wouldn’t enforce any other provisions of the general industry standard until June 25, 2018. Then, on June 1, the agency proposed a 9-month extension (to December 12, 2018) of the compliance date for certain ancillary requirements.
For the construction and shipyard standards, OSHA won’t enforce any other provisions until it provides notice.
Compliance dates aside, there are several other areas where Anthos sees confusion and misconceptions about the standard and mistakes in complying with it. Here are the three big ones.
Assuming NFPA 484 compliance is sufficient
NFPA 484 is the National Fire Protection Association’s Standard for Combustible Metals. Beryllium dust is an explosion hazard and NFPA certainly applies to facilities where it’s present. But compliance with NFPA 484 alone won’t be sufficient when OSHA inspectors arrive.
“People think that if they comply with NFPA 484, then they’re automatically in compliance with the beryllium standard,” Anthos says. “But that’s not true. They need to understand whether they have beryllium dust within their operations, identify the potential sources of worker exposure, and have a plan for control and compliance.”
Failing to assess exposure during one-offs and special projects
Even companies that have assessed their beryllium exposure risk for their main operations may be missing hazards present in one-off jobs and special projects.
Anthos gives the example of a construction company that demolishes buildings. This might not usually lead to an exposure risk, but now imagine that company gets a contract to demolish several buildings on an Air Force base, including an old telecommunications building. Demolition workers often use saw and torches to cut buildings into smaller pieces that can be easily hauled away. But in a telecommunications building, the materials they’re cutting likely have electronic components that contain beryllium. In this case, the workers could be at risk.
“Even if you don’t typically manufacture or deal with components that contain beryllium, you still need to look at potential exposures during all of your operations,” Anthos advises.
Not following up to ensure controls are working
Finally, Anthos notes that companies that do implement controls often fail to do follow-up monitoring to understand if those controls actually work. “You can spend a lot of money on engineering controls and not be able to prove that they work,” he warns.
He says that companies often do area sampling, “but for OSHA the only monitoring that counts is monitoring your workers. Personal exposure monitoring during activities that are controlled under your plan will identify whether the engineering controls and work practices you have in place are working. Exposure assessment is what will help both you and your employees.”
In addition, follow-up monitoring will be essential when inspectors arrive. “You need to be able to say to them, ‘Here’s our point source, here are our controls, and here’s the documentation that shows the controls work,’” Anthos says.
A path to compliance
Hopefully, you’ve already started your compliance journey. But, if not, Anthos offers a 3-step plan:
- Perform a risk assessment. “If you’re not sure whether you have beryllium in your operations, contact someone to help you. You can even get an over-the-phone assessment of the potential for beryllium in your space.”
- Identify the point source and exposure groups. “Once you’ve determined you have beryllium, you need to look deeper to identify the point source and which employees may be exposed.”
- Make a control plan. “Only when you know where the beryllium is, who’s exposed, and why, can you start your administrative control planning.”
It may sound like a large undertaking, but Anthos says it doesn’t have to be, at least not the getting started part. “A planning assessment to identify if the standard applies to you and develop a next steps program is fairly inexpensive — $500 to $1500 depending on your operations and what you already have in place.” Even if you have to purchase new equipment, the cost will still be significantly less than the OSHA fine you’d get from not being in compliance.
To learn more about risk assessments and other services TriMedia provides, visit their website. For information on HEPA vacuums and other equipment that will help you meet compliance requirements, contact us.