EXECUTIVE SUMMARY

COMPLIANCE COSTS FOR 

OSHA’S DRAFT BERYLLIUM STANDARD

μg/m3) and includes several program requirements for establishments
where beryllium is used or workers are otherwise exposed to airborne or
surface beryllium contamination. These program elements include
requirements for exposure assessment, hazard control plans, respiratory
protection, regulated areas, protective clothing and equipment, hygiene
areas and practices, housekeeping, medical surveillance, and hazard
communication.

Based on the companion technological feasibility analysis, Eastern
Research Group (ERG) identified ten sectors where beryllium exposures
might occur:

Beryllium Production

Beryllium Oxide

Copper and Aluminum Foundries

Copper and Aluminum Smelting, Refining, and Alloying

Precision Machining

Copper Rolling and Drawing 

Stamping and Spring and Connector Manufacturing 

Dental Laboratories 

Welding

Abrasive Blasting .

For each sector, ERG first established a profile of establishments and
employees were beryllium exposures might occur. Based on the
technological feasibility analysis, ERG then estimated the numbers of
workers employed in each of the affected job categories identified in
the feasibility  analysis. Next, for each job, ERG estimated the costs
of engineering and other controls necessary to achieve the PEL option
levels specified in the draft standard. Finally, ERG estimated the costs
of complying with the standard’s program requirements. Table ES-1
shows the number of beryllium establishments and associated employment
levels by sector.

Table ES-1. Profile of Beryllium Establishments, by Sector



Sector	Number of Establishments	Total Employment	Production Employment

Beryllium Production	1	824	NA

Beryllium Oxide	102	8,552	5.736

Copper and Aluminum Foundries	97	4,547	3,694

Copper and Aluminum Smelting, Refining, and Alloying	48	2,239	1,321

Precision Machining	289	7,739	6,016

Copper Rolling and Drawing	74	8,147	5,959

Stamping and Spring and Connector Manufacturing	885	57,488	44,943

Dental Laboratories	4,020	NA	19,375 [a]

Welding	500	NA	2,000 [b]

Abrasive Blasting	NA	NA	29,101 [c]

Source: See text.

[a] Dental laboratory technicians.

[b] Welders.

[c] Abrasive blasters.



	Employers are required to implement engineering or work practice
controls whenever exposures exceed OSHA’s PEL. ERG estimated the costs
of such controls for each affected job category whose median exposure
level, as reported in the technological feasibility analysis, exceeded
the PEL option under consideration,. Table ES-2 shows the estimated
median exposures and associated exposure profile used in this costs
analysis. Table ES-3 shows the estimated control costs, by sector, to
achieve compliance with each of the PEL options contained in the draft
standard, while Table ES-4 show the costs for compliance with the
program requirements. Total compliance costs are shown in Table ES-5.

	At the most stringent PEL option (0.1μg/m3), costs for engineering
costs total $85.9 million, while program costs are estimated at $58.3
million. At the least stringent PEL option (1.0μg/m3), estimated
compliance costs for engineering controls and program requirements are
$59.0 and $53.4 million, respectively. The abrasive blasting and foundry
sectors account for the largest share of compliance costs.

Table ES-6 shows compliance costs disaggregated by the standard’s
provisions for each PEL option. Among program costs, requirements for
housekeeping and employee showering account for about half of the total.



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