Under the new Occupational Safety and Health Administration’s (OSHA) Beryllium standard (29 CFR 1910.1024) the University is required to have a Beryllium Exposure Control Program (BECP). The purpose of the BECP is to provide the hazards associated with beryllium and outline the steps to take to ensure employees who work with, or around beryllium are not exposed to hazardous levels.
This program covers University employees and establishes the minimum requirements for working with beryllium, and applies to employees who are exposed to any airborne level or have a possibility of skin contact with beryllium.
Policy and Regulation
University of Iowa Operations Manual, Part III Human Resources, Division II Standards and Ethics, Chapter 16.4d Policy on Ethics and Responsibilities for University of Iowa Staff.
Roles and Responsibilities
EHS is responsible for:
- Establishing University expectations to meet regulatory requirements.
- Developing training related to beryllium.
- Conducting a yearly audit of each department’s program.
- Conducting qualitative assessments to determine the need for a BECP for the department
- Conducting exposure monitoring for beryllium exposure.
Departments are responsible for:
- Ensuring the BECP is available to all affected employees.
- Ensuring employees take required training.
- Conducting the annual review of the written exposure control plan (Appendix A)
- Providing needed PPE and exposure controls to employees.
- Paying for the cost of employee exposure monitoring.
Employees are responsible for:
- Complying with the requirements of this program and any further safety requirements set by supervisors.
Initial Exposure Assessment
Exposure monitoring will be conducted on any employee who is or may reasonably be expected to be exposed to any level of airborne beryllium. The monitoring will be done for both the PEL and the STEL.
Potential sources of beryllium at the University include coal fly ash, dental fillings, and metal alloys.
Periodic Exposure Assessment
If the most recent results are at or above the action level but are below the PEL, monitoring shall be repeated every 6 months.
If the most recent results are at or above the PEL or STEL, monitoring shall be repeated every 3 months.
Periodic exposure monitoring may be discontinued if results from two consecutive
sampling periods taken at least 7 days apart show that employee exposure is below
the action level or STEL.
Reassessment of Exposures
Whenever a change in the production, process, control equipment, personnel, or work practices may reasonably be expected to result in new or additional exposures at or above the action level, monitoring shall be conducted.
Within 15 workdays after the completion of the exposure assessment, employee(s) shall be notified in writing of the results of the assessment or the results will be posted in an appropriate location accessible to all affected employees.
If the result is above the PEL or STEL, the notification will include the means that are being taken to reduce the exposure to below the PEL or STEL.
Beryllium work areas must be established anywhere there is a potential for airborne beryllium exposure or dermal contact.
The work area must be demarcated from other work areas. This can be done with signs similar to those in Appendix B.
Regulated areas must be established in areas with an airborne exposure above the PEL or STEL.
Regulated areas must be demarcated from other work areas. This can be done with signs similar to those in Appendix C.
Access to the regulated area should be limited to employees who have work in the area. Employees entering the area are required to wear respirators and other appropriate PPE.
No eating, drinking, smoking, chewing gum, or applying cosmetics is allowed in the regulated area.
Written Exposure Control Plan
For each area that has potential exposure to beryllium, a written exposure control plan must be developed and made available to all employees who could work in the area. An outline of a written exposure control plan is in Appendix A. The exposure control plan includes a description of the task being done and all of the controls that are in place.
The plan must be reviewed at least annually, if a process change occurs, or if an employee shows symptoms of beryllium exposure during their medical evaluation.
Engineering and Work Practice Controls
Anywhere there is a potential exposure to airborne beryllium one of the following controls must be implemented: material substitution, isolation, local exhaust ventilation, or process controls.
Controls are not required if 2 air samples collected at least 7 days apart are below the action level.
Work rotation is not allowed as a means of lowering an employee’s exposure.
Respiratory Protection and PPE
Respiratory protection will be provided and used in accordance with the University’s respiratory program.
PPE will be provided as needed to protect workers from beryllium. The PPE for each process will be determined during the development of the BECP for each process.
The PPE must be removed when leaving the beryllium work area and disposed of in the appropriate manner.
Hygiene Areas and Practices
For each beryllium work area there must be a place for employees to be able to wash their hands, face, and neck. Employees should wash after completing the task that causes skin exposure, when leaving the beryllium work area, and prior to eating, drinking, smoking, chewing gum, or applying cosmetics.
Change rooms will be provided if the employee must change out of their own clothing prior to wearing PPE.
Showers will be provided to employees when the airborne exposure is above the PEL or STEL or skin contact could occur on parts of the body besides the hands, face, and neck. Employees who are provided showers are required to use them.
Eating and Drinking Areas
Cleaning procedures must be in place to ensure eating and drinking areas are as free as practicable of beryllium.
Employees cannot enter the eating and drinking area while wearing beryllium contaminated PPE.
Cleaning procedures must be in place to ensure surfaces in beryllium works areas are as free as practicable of beryllium. All spills must be cleaned up promptly.
Cleaning methods that are used must be designed to limit the likelihood of an airborne exposure. This includes vacuums with HEPA filters and wet cleaning methods.
Dry sweeping, non HEPA vacuums, and compressed air are only to be used if no other safer method is available. Respirators must be worn during cleaning with these methods. EHS must also be contacted to evaluate any additional hazards this will create.
Items that contain or are contaminated by beryllium must be disposed of in sealed, impermeable enclosures, such as bags or containers that are labeled with the following wording; Danger, Contains Beryllium, May Cause Cancer, Causes Damage To Lungs, Avoid Creating Dust, Do Not Get On Skin.
Any employee who is exposed above the action level for 30 or more days per year, shows signs or symptoms of CBD, or is exposed during an emergency will be provided medical surveillance at no cost. The medical surveillance is performed initially, at least every 2 years unless more frequently recommended by a PLHCP, and at termination of employment.
The medical examination will include medical and work history, a physical exam with emphasis on the respiratory system and skin rashes, pulmonary function test, BeLPT test, and any other test recommended by the PLHCP.
If CBD is suspected from the medical surveillance examination, the employee will go to a CBD diagnostic center for further evaluation.
The department will provide the following information to the PLHCP; the employee’s duties as they relate to beryllium exposure, results of air sampling, and the PPE that is used.
A written report on the results will be provided to the employee within 30 days.
Employees who have a confirmed positive finding for CBD or a written recommendation from a PLHCP and work in an area with airborne exposure above the action level are eligible for medical removal. If an employee is eligible for medical removal they can be removed according to the OSHA standard or continue to work but will be required to wear a respirator.
Beryllium must be included in the departments’ hazard communication program. This includes proper labeling and having a beryllium Safety Data Sheet (SDS).
Training (available soon)
Any employee that is exposed to any airborne level of beryllium or has the potential for skin contact is required to take the training on an annual basis.
University employees will complete the ICON course, W536OS Beryllium Safety, that provides general beryllium safety training, in addition, site-specific training provided by the department must also be completed.
The ICON training course will include the health hazards of beryllium and the contents of the OSHA beryllium standard (1910.1024). The site-specific training will cover the information in Appendix A of this program, including the specific task that lead to beryllium exposure and the specific methods being used to lower the exposure.
ICON Training records are maintained through the University’s Employee Self Service My Training site.
Each department shall review its BECP on an annual basis. The review shall consist of determining of the task and controls are still being used as described and if the plan is effective in reducing beryllium exposure.
EHS will audit each department with a BECP on a yearly basis. The audit will cover all aspects of the written program to ensure they are up to date and complete. The audit will also include a walkthrough of the area to check for appropriate labels, warning signs, and housekeeping.