OSHA Issues Final Rule for Beryllium – Part II.
This is the second post in a three-part series reviewing OSHA’s final rule for beryllium. In the first part of this series, we covered the exposure assessment, work areas, and written exposure control requirements. This post covers the respiratory protection and personal protective clothing requirements as well as hygiene practices.
The employer must provide respiratory protection during operations, maintenance activities, and non-routine tasks where engineering controls are not feasible and airborne exposures of beryllium are expected to exceed OSHA’s short term exposure limit (STEL) and/or permissible exposure limit (PEL). Employers are required to provide a powered air purifying respirator (PAPR) instead of a negative pressure respirator where respiratory protection is required by the standard and an employee requests the PAPR, provided the PAPR provides adequate protection.
Personal Protective Clothing and Equipment
The final rule requires use of protective clothing and equipment where employee exposure exceeds, or can reasonably be expected to exceed the PEL or STEL, or where there is a reasonable expectation of dermal contact with beryllium. The employer must also:
- Ensure that each employee removes the protective clothing at the end of the work shift or when it becomes visibly contaminated with beryllium (following the procedures specified in the written exposure control plan as outlined in part one of this series).
- Contaminated clothing or equipment removed from the facility should be transported in labeled sealed bags or other impermeable containers.
- The employer also must ensure that all reusable clothing and equipment required by the standard is cleaned, laundered, repaired, and replaced as needed.
- When using other companies to clean or repair the protective clothing or equipment, the employer must inform them in writing about the potential harmful effects of airborne exposure to and dermal contact with beryllium, and the contents should be handled in accordance with the standard.
For each employee working in a beryllium work area, employers must provide:
- Accessible washing facilities and ensure that employees who have dermal contact with beryllium wash any exposed skin at the end of the activity, process or work shift before eating, drinking, smoking, chewing tobacco, applying cosmetics, or using the toilet.
- Change rooms should be provided if employees are required to remove their personal clothing.
- The employer must provide showers where airborne exposure exceeds OSHA’s regulatory limits or where beryllium can reasonably be expected to contaminate employee’s hair or body parts other than hands, face, and neck.
- Where showers are provided, the employer must ensure that each employee showers at the end of the work shift or work activity.
- If employees are allowed to consume food or beverage at the worksite where beryllium is present, the employer must ensure that surfaces in eating/drinking areas are free of beryllium and employees should not enter the eating/drinking areas with protective clothing unless the beryllium has been removed from the clothing.
The employer must maintain all surfaces in beryllium work areas as free of beryllium as practicable as stated in the company’s written exposure control plan. HEPA filtered vacuuming or other methods that minimize the likelihood and level of airborne exposure should be used. Dry sweeping or brushing should not be allowed. Compressed air should also not be allowed unless it is used in conjunction with a ventilation system designed to capture the particles made airborne by the compressed air. If dry sweeping, brushing, or compressed air is used, the employee should be protected with a respirator and protective clothing.
Next week, in part three of this series we will cover medical surveillance, training, and effective dates of this final rule.