If you need assistance in compliance with the OSHA final rule on Beryllium worker exposure discussed in this article, call us at 973-366-4660 or email us at info@atlenv.com for details and a free estimate.

Written By: Robert E. Sheriff, MS, CIH, CSP, President
February 19, 2020

Final Rule to Lower Beryllium Worker Exposure Levels and Increase Worksite Compliance Requirements

OSHA extended the Beryllium compliance date from March 22, 2018, to May 20, 2018, which means it is now in effect and enforceable by OSHA field personnel. This was the result of the White House Memorandum from President Trump titled “Regulatory Freeze Pending Review.”

On January 6, 2017, OSHA issued its long-awaited—and expected—regulation on Beryllium but delayed implementation until 2018.

In summary: The 8-hour PEL for Beryllium was reduced to 0.2 micrograms per cubic meter (0.2 ug/M³) of Beryllium from 2 ug/M³. It also established a 15-minute STEL (Short Term Exposure Limit) of 2.0 ug/M³ and an Action Level of 0.1 ug/M³.

The Beryllium regulations are as follows:

General Industry         29CFR1910.1024 – Beryllium Regulation

Construction                 29CFR1926.1124 – Beryllium Regulation

Shipyards                        29CFR1915.1024 – Beryllium Regulation

These regulations went into effect on March 20, 2018:

1. EXCEPTION NO. 1 – CHANGE ROOM AND SHOWERS—2 YEARS—THUS MAY 20, 2020. The deadline is coming soon!
2. EXCEPTION NO. 2 – ENGINEERING CONTROLS—3 YEARS—THUS MAY 20, 2021.

You can go to the January 9, 2017, Federal Register to obtain a full copy of the complete justification and implementation details and the Beryllium Standard itself which is 942 pages long. The actual Beryllium Standard starts on page 856—thus a mere 86 pages long. You can also go to OSHA’s website at www.osha.gov under NEWS or just go to www.osha.gov/regulations/lawandregulations/General Industry and scroll down to 1910.1024 or select Construction or Maritime as necessary.

The initial and periodic monitoring requirements are similar to those of other regulations such as the lead standard 29CFR1910.1025 including:

1. Sequence of follow-up monitoring if STEL or PEL is exceeded. If PEL is exceeded, 2 consecutive samplings with exposure levels below the Action Level within 3 months. If the Action Level is exceeded, two consecutive samplings within 6 months below the Action Level.
2. Full containment and protective clothing and showers for a regulated area where exposure levels exceed the PEL.
3. Initial monitoring of each work task on each shift.
4. A Written Beryllium Exposure Control Plan.
5. Medical Surveillance if potential exposure at or above the action level for 30 days per year.
6. Hazard Communication Training—initially and annually.
7. Labeling.
8. Recordkeeping.

Many of the provisions have already been implemented by organizations working with Beryllium. We can assist in developing acceptable programs, program audits, and sampling compliance for Beryllium at info@atlenv.com, call: 973-366-4660 or fill out our online contact form.

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