
                                  Memorandum

To: Robert Stone, Bryan Lincoln, OSHA
From: Chet Fenton, ERG
Date: April 12, 2016
Subject: Benefit estimates for Alternative 1B of the proposed OSHA beryllium rule

Under Alternative 1B of OSHA's proposed beryllium rule, facilities in General Industry who do not meet the 0.1% threshold for beryllium content but would be in-scope under Alternative 1A but would be exempted from the rule if they can provide objective data showing that none of their workers are exposed to beryllium at levels exceeding the action level of 0.1 ug/m[3]. This alternative concerns establishments engaged in primary aluminum smelting and those operating coal-fired power plants, all of whom are in-scope under Alternative 1A. Profile and exposure estimates for these groups are provided below.
Industry Profile and At-Risk Estimates
Coal-Fired Power Plants
Because beryllium occurs as a trace element in coal, workers in coal-fired power plants are at risk of beryllium exposure. Based on data collected by the Department of Energy, Energy Information Administration, ERG estimates that currently 562 such facilities are in operation under OSHA's purview (DOE, 2013). These include 433 operated by utilities and 129 operated by establishments in other industries. Census data indicate that employment for utility facilities averages 52 workers per establishment (US Census Bureau, 2012). Applying this number to the entire set of coal-fired power plants suggests a total employment of 29,417. While reliable exposure information is not available for this sector, ERG believes that potential beryllium exposures are limited to workers engaged in production occupations. Based on data from the BLS Occupational Employment Statistics Survey, ERG estimates that 50.5% of the workers at coal-fired power plant facilities fall into this category (BLS, 2012). These estimates are shown in following table.
                                       
                     Employment at Coal-Fired Power Plants

                                     Total
                             Average Per Facility
Total Employment
                                    29,417
                                     52.3
Non Production Occupations
                                    14,558
                                     25.9
All Production Workers
                                    14,859
                                     26.4

Construction and Extraction Occupations
                                     1,108
                                      2.0

Installation, Maintenance, and Repair Occupations
                                     8,864
                                     15.8

Production Occupations  -  Operators
                                     4,405
                                      7.8

Transportation and Material Moving Occupations
                                      482
                                      0.9

Data on the distribution of production workers by beryllium exposure are not available. Exposure to arsenic, which is also a trace contaminant in coal ash, is concomitant with beryllium exposure. OSHA believes that compliance with the arsenic standard ensures that worker beryllium exposures will be below the proposed PEL. For this reason, and given the available evidence, ERG believes the exposure profile shown below best characterizes the beryllium exposures of the affected production workers.

  Estimated Beryllium Exposure Profile for Coal Fired Power Plant Facilities
                              Job Classification
                                       
                                     Total
                              Beryllium Exposure


<0.1μg/m[3]
0.1 to 0.2μg/m[3]
>0.2 μg/m[3]
Construction and Extraction Occupations
                                     1,108
                                      831
                                      277
                                       0

                                    100.0%
                                     75.0%
                                     25.0%
                                     0.0%
Installation, Maintenance, and Repair Occupations
                                     8,864
                                     6,648
                                     2,216
                                       0

                                    100.0%
                                     75.0%
                                     25.0%
                                     0.0%
Production Occupations  -  Operators
                                     4,405
                                     3,304
                                     1,101
                                       0

                                    100.0%
                                     75.0%
                                     25.0%
                                     0.0%
Transportation and Material Moving Occupations
                                      482
                                      361
                                      120
                                       0

                                    100.0%
                                     75.0%
                                     25.0%
                                     0.0%

                                       
                                       
                                       
                                       
All production workers
                                    14,859
                                    11,144
                                     3,715
                                       0

                                    100.0%
                                     75.0%
                                     25.0%
                                     0.0%

Primary Aluminum Smelters
Based on a review of the primary aluminum smelting industry, ERG found that 10 such smelters are currently operating in the United States, employing 8,750 workers. Of these employees, an estimated 6,956 employees work in production occupations. While comprehensive exposure data are not available, the evidence suggests that some workers in pot room-related jobs are currently exposed to beryllium (from trace amounts in bauxite ore), with some at levels exceeding the proposed PEL. These jobs include pot room workers, pot repair workers, and other maintenance workers involved in cleaning operations in the pot room. Based on data from the BLS Occupational Employment Statistics survey, ERG estimated the numbers of such workers as shown below:
Pot room workers: 805
Pot room maintenance workers: 270
Pot repair workers: 260
Total affected workers: 1,335

Existing exposure data for aluminum smelter workers are only available on an aggregated basis and are not disaggregated by specific job task. ERG, however, believes that the following profile provides a likely approximation of the distribution of beryllium exposures for each of the affected job categories listed above.
                                       
                  Primary Aluminum Smelting Exposure Profile
                                 Affected Job
                                     Total
                              Beryllium Exposure


<0.1μg/m[3]
0.1 to 0.2μg/m[3]
>0.2 μg/m[3]
Pot room workers
                                      805
                                      322
                                      241
                                      241

                                    100.0%
                                     40.0%
                                     30.0%
                                     30.0%
Maintenance cleaning workers
                                      270
                                      108
                                      81
                                      81

                                    100.0%
                                     40.0%
                                     30.0%
                                     30.0%
Pot repair workers
                                      260
                                      104
                                      78
                                      78

                                    100.0%
                                     40.0%
                                     30.0%
                                     30.0%

Alternative 1B Assumptions
For the purposes of estimating the costs and benefits associated with this alternative, ERG used estimates of the share of aluminum smelters and coal-fired power plants that would be exempt by use of objective data and reduced the number of affected in-scope facilities and employees accordingly Given the small number of smelters (10) and the complexity of smelter operations, ERG set the smelter share at zero. Because of the relatively low levels of beryllium exposures at coal-fired power plants, ERG set the share of facilities using objective data for this sector at 50%. Thus, the number of affected employees with exposures below the action level and thereby exempted from the rule would equal 50% of the total, or 7,430 employees. Based on these estimates the resultant exposure profile for the remaining at-risk workers is shown below.


           Alternative 1B  -  Additional In-Scope At-Risk Employees
                                    Sector
                                     Total
                              Beryllium Exposure


<0.1μg/m[3]
0.1 to 0.2μg/m[3]
>0.2 μg/m[3]
Primary Aluminum Smelting
                                     1.335
                                      934
                                      133
                                      268

                                    100.0%
                                     70.0%
                                     10.0%
                                     20.0%
Coal-Fired Power plants
                                     7,430
                                     3,715
                                     3,715
                                       0

                                     100.%
                                     50.0%
                                     50.0%
                                     0.0%
Total
                                     8,765
                                     4,649
                                     3,848
                                      268

                                    100.0%
                                     53.0%
                                     43.9%
                                     3.1%

Benefit Estimates
When these at-risk employees are combined with the in-scope at-risk employees for the baseline version of the proposed rule, the following benefit estimates are obtained.

                     Estimated Benefits for Alternative 1B
 
                             Airborne Factor Only
                         Non-Airborne Factor Included
                                   Midpoint
Annual Cases Avoided
                                       
                                       
                                       
Mortality
                                       
                                       
                                       
Lung Cancer
                                      4.1
                                      4.1
                                      4.1
CBD-related
                                     92.1
                                     109.5
                                     100.8
Total mortality
                                     96.3
                                     113.6
                                     104.9

                                       
                                       
                                       
Morbidity
                                     49.6
                                     59.0
                                     54.3
 
                                       
                                       
                                       
Monetized Benefits
                                       
                                       
                                       
3% discount rate
                                 $578,011,421
                                 $680,969,358
                                 $629,490,389
 
                                       
                                       
                                       
7% discount rate
                                 $256,326,075
                                 $301,952,089
                                 $279,139,082

Compared to Alternative 1A, the benefits for Alternative 1B are identical when only the airborne factor is considered. This result is due to the fact that all workers exempt from the standard under 1B are assumed to have exposures below the proposed PEL and therefore enjoyed no benefit from the reduced PEL when they were in-scope under Alternative 1A. When the non-airborne factor is included. the benefits under Alternative 1B are larger, but smaller than the comparable values for Alternative 1A. This difference is due to the fact that the exempted employees under 1B still are at risk of CBD-related mortality and morbidity, despite their relatively low exposures. If exempted, these employees would not benefit from the effect of the standard's ancillary provision in preventing such cases irrespective of employee's exposure level.
References: 
BLS, 2012. Occupational Employment Statistics Survey, U.S. Bureau of Labor Statistics. 2012.
DOE, 2013. U.S. Department of Energy, Energy Information Administration. Form EIA-860, Annual Electric Generator Report, 2013. 
 US Census Bureau, 2012. County Business Patterns, US. Census Bureau, 2012.
