Discussion issues for SERs 

We would like to draw your attention to several discussion issues on
Beryllium.  You are welcome to comment on any issue you wish, of course,
and additional written comments may serve better in technical areas or
in the particulars of your specific line of business.

Processes

Could you please describe what processes you use that involve Beryllium
and the number of employees exposed?

Please describe or estimate your employees’ Beryllium exposure.

Do you use Beryllium routinely—daily, weekly, or occasionally?

What is unique about Beryllium in your product(s) and how is that
important in your business?

Are there substitutes available for Beryllium?

Controls

Do you utilize engineering controls to prevent or minimize employee
exposure?  Engineering controls could include: machinery or processes
that limit the creation of dust; enclosure or isolation of processes;
exhaust ventilation; local (added on) ventilation; and substitution of
materials.

Would a low permissible exposure limit  (PEL) cause you to substitute
other materials for Beryllium or to re-design a process to control the
generation of Beryllium dusts/particles?

Do any of your employees wear a respirator for work involving Beryllium?
 For which operations and why?

Compliance

Is the draft proposed standard clear and easy to understand?  Are there
any parts that are confusing?

After reviewing the draft proposed standard, what would be significant
issues for your business with respect to compliance?  

The current PEL is 2 micrograms (per cubic meter of air taken as an
8-hour time weighted average) and  OSHA is considering alternative PELs
down to 0.1. What actions would you need to take to reduce exposures to
the lower PELs?

Are OSHA’s estimates of time and unit costs reasonable?  (For example,
in the PIRFA Tables 13 and the Appendix.)

Regulatory alternatives

Of the regulatory alternatives identified in the Preliminary Initial
Regulatory Flexibility Analysis (PIRFA, pages 64 – 80), which would be
most effective in reducing impacts on your business?

Are there other alternatives that OSHA should consider? 

Several published studies suggest that Beryllium's health effects may be
due to the number or size of airborne particles rather than the
simpler mass measurement, or that the form of Beryllium (soluble versus
insoluble) could also be a factor.  How would these factors affect your
ability to comply with a standard?

Some studies suggest that employees may become sensitized by
"ultrafine" particles penetrating the skin.  Do your processes generate
such ultrafine particles or do you use Beryllium-containing powders as
raw materials?  How would protecting employees against this possible
hazard impact your operations?

Programs

Do you have a program for controlling employees’ exposure to
Beryllium?  This might include training in risks, exposure monitoring,
protective clothing to reduce skin exposure, housekeeping, medical
surveillance, etc.  

 you try to meet, such as the 0.2 μg/m3  Action Level in the Dept. of
Energy’s  regulation?

Do you perform personal exposure monitoring? How frequently and who does
the monitoring?  How much does it cost?

Do you isolate Beryllium exposure within separate work areas?  (OSHA
calls these “regulated areas.”)

Do you provide protective clothing and equipment for employees handling
Beryllium?  Is clothing disposable or laundered?

Do you have a housekeeping program for Beryllium?  What methods do you
use (e.g., dry sweeping, wet methods, HEPA vacuum)?  How frequently do
you use them?

Do you provide any of the following for employees:  showers, change
rooms, or separate lunch or break areas?

à

á

á



s

ñ

᠀otections?  Do you offer your employees the Beryllium lymphocyte
proliferation test (BeLPT)? Have any employees been sensitized or
developed chronic Beryllium disease (CBD)? 

