OSHA Beryllium PEL Getting Lowered? Why That Makes Sense

So, like Beryllium, huh?

Yep, Beryllium.  You may not be familiar with it, but beryllium is pretty sweet.  And not just ‘cause it starts with ‘berry.’  It’s a naturally occurring, lightweight metal.  It has a high melting point, great strength-to-weight ratio, nice conductivity and excellent thermal stability.  Whew…I’m running out of adjectives, here.  As you can imagine, these physical properties make beryllium pretty darn attractive for aerospace, defense, medical, and nuclear industries.

Unfortunately, this metal isn’t all Sci-Fi.  It comes with a little hospital drama of its own.  Basically, beryllium is great for space shuttles, but bad for your lungs.  It is associated with beryllium sensitization, chronic beryllium disease, and lung cancer (just plain ole lung cancer, not beryllium lung cancer, if you were wondering).  Workers can be exposed to beryllium through inhalation in dust, mists and fumes or even through skin absorption.

Sounds pretty bad

Yep…pretty much.  That’s why OSHA released a ‘Notice of Proposed Rulemaking’ in August 2015 regarding beryllium.  (They also published a ‘Declaration of Randomly Capitalizing Letters to make Things sound more Official’ alongside it, but that’s for another discussion.)   Basically, OSHA wants to significantly lower the Permissible Exposure Limit (PEL) and add additional requirements.

In the proposal, OSHA outlines requirements for exposure monitoring, establishing specified work areas and regulated areas, implementing effective control methods, providing medical surveillance and removal protection, and training/recordkeeping similar to other OSHA health standards.  If you can honestly say you read this entire paragraph, then I applaud your dedication.  I couldn’t even do it, and I wrote it.

Anyway, PELs, STELs, and GELs

The current PEL for beryllium was set in 1971 at 2.0 µg/m³.  Believe it or not, a lot of studies about space metals have been done since then.  And they found…beryllium is bad.  (Seriously, if you’re surprised by this, I don’t think you read the section above.  Like, at all.)  It’s bad even when exposures are under the 2.0 µg/m³.  The ACGIH dropped their Threshold Limit Value (TLV) of 0.05 µg/m³ for beryllium in 2009.

So, empowered by this new knowledge, OSHA wants to drop the PEL to 0.2 µg/m³ while setting a STEL at 2.0 µg/m³.  There’s a couple of ‘Overly Wordy Clauses’ in the ‘Notice of Proposed Rulemaking’ that would raise or lower the PEL depending on some ‘Regulatory Factors determined in Regulation.’  This applies to general industry, but also can include construction and maritime, as well.

As far as the GELs, OSHA wants more, specifically in their shoes.  It hurts being on your feet all day.

Exposure monitoring – warning…numbers and boredom ahead

OSHA has proposed to monitor beryllium on an annual basis.  But as with everything involved in this, it could change.  (I mean, c’mon.  This is worse than trying to help my little sis get dressed.  What shirt do you want, Suzie?  Pink…I mean purple…pink…purple…BLUE!)

One change would require periodic monitoring every 180 days if beryllium levels are at or above the action level or greater than the STEL, and are at or below the TWA PEL.  Or if the exposure is greater than the STEL, and when the level is above the TWA PEL.  Or if it’s at or above the action level or greater than the STEL, and every 90 days where exposures are above the TWA PEL.

OSHA is allowing the employer flexibility in choosing the monitoring method as long as it meets certain set requirements. These requirements include a measurement of airborne concentrations to an accuracy of +/- 25 percent, as well as produce accurate measurements at a statistical confidence level of 95 percent. Some examples of acceptable monitoring methods are NIOSH 7704, ASTM D7202, ASTM D7439, OSHA 206, and OSHA 125G.

Now excuse me while I take off my monocle, rip these patches off the elbows of my brown suit jacket, and maybe put away my pipe.  Geez…I had high school history teachers more exciting than this.

Compliance and Homework

Under this new Notice, OSHA wants a written ‘Exposure Control Plan.’  (They did it again…my shift key is getting a work out on this one.)  You’ll have to provide info about jobs that put employees at risk for exposure, what you’re going to do about it, where beryllium is present below the ELs (Work Areas), and where beryllium is present over the ELs (Regulated Areas).  You’ll also have to proofread your work, cite your sources, and turn it in before the first bell on Monday.  Seriously…high school, again?

One more thing…

OSHA also expects medical examinations to be available at no cost for workers that meet certain criteria.  This includes (pound some coffee and take a deep breath, here we go): exposed to beryllium above the proposed PEL for 30 days or more in a 12 month period, exposed to beryllium during an emergency, or shown signs or symptoms of CBD. There are many regulator alternatives to the proposed regulation that could modify the employee’s eligibility for medical examinations, the type of medical exam offered and the frequency of periodic exams.

Whew.  I think we made it.  Wait.  Where’s Phil?  Phil!  HAS ANYONE SEEN PHIL?  I think we lost him…

In conclusion

OSHA’s planning on changing the beryllium regulation…by a lot.  If you’re worried about all the changes, you can look the whole thing up on the Federal Register.  Or you can call Safex, which is what I would do.  Less reading and more talking to an actual person.  Who probably won’t put you to sleep.  Probably.