If you need testing/sampling and analysis for beryllium and assistance in OSHA Compliance discussed in this article call us at 1-800-344-4414 or email us at firstname.lastname@example.org for details and a free estimate.
Written by Robert E. Sheriff, MS, CIH, CSP, President
April 3, 2018
OSHA has issued the a new Permissible Exposure Level (PEL) for Beryllium. The new PEL will reduce the 8-hour time weighted average exposure from 2 micrograms per cubic meter of air (2 ug/m3) to 0.2 ug/m3—a ten-fold reduction! and an action level of 0.1 ug/m3. A 15 minute STEL is proposed at 2 ug/m3. Further, OSHA intends to develop a complete standard for Beryllium identified as 29 CFR 1910.1024. (Formerly it was just exposure limits in 1910.1000 Table Z2). Originally the New Beryllium Regulation was to go into effect on March 12, 2018 but was extended to May 20, 2018.
Testing/sampling to satisfy OSHA’s requirements involves use of a small, battery powered, portable air sampler with a sampling/testing hose connected to a filter and clipped to the worker’s collar—referred to as a breathing zone sample. The sampler is small enough to be clipped to the worker’s belt or put in a pocket.
The collection filter clipped to the worker’s collar is a MCE (mixed cellulose ester) filter that can be sent to a laboratory for analysis. (It is strongly recommended that the laboratory be accredited by the American Industrial Hygiene Association [AIHA] as a means of ensuring quality control). Analysis for Beryllium (BE) is normally by Inductively Coupled Plasma (ICP for short!) and is generally included in most standard analytical methods such as Solder Metals, Priority Pollutant Metals, Welding Fume Metals, CAM 17 Metals, EPA DW Primary List Metals, and Appendix IX Metals.
A method also exists for obtaining surface samples for Beryllium but OSHA has not proposed a surface contamination limit. Although not a regulatory requirement, it is generally accepted that Beryllium should not be detected above background levels in areas outside the work area—including break areas and lunchrooms. It is possible that OSHA may address surface contamination under the General Duty Clause or under Sanitation.
A variety of organizations—including government entities—have set internal standards for surface contamination. These levels vary from about 3 ug/100 cm2 to 0.1 ug/100 cm2 while others have set a limit of no detectable Beryllium above background levels—noticing that Beryllium is often present in soils. (The 3 ug/100 cm2 is the limit set by DOE).
Complete details of the proposed Beryllium Standard 29 CFR 1910.1024 can be found at: Federal Register, Volume 80, Number 152, (Friday, August 7, 2015), pages 47565-47828 or at www.osha.gov/publications/osha3821.pdf. The final rule was ultimately issued in January 2017 with a compliance date of March 12, 2018 which has been extended to May 20, 2018.
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