OSHA Beryllium Enforcement Deadline Is Coming Soon: Are You Ready?
On March 11 2019, OSHA will begin enforcing two provisions of its beryllium standard for general industry, with additional enforcement measures currently scheduled to begin next year.
If you have beryllium exposure risks in your workplace, now is a good time to take a closer look at OSHA’s beryllium requirements, and make sure you’re prepared for compliance.
What’s Happening Now?
OSHA is following its phased-in compliance timeline for its 2017 final rule on beryllium. They’ll begin enforcing requirements for change rooms and showers for general industry on March 11, 2019.
These requirements, listed in paragraphs (i)(2) and (i)(3) in the general industry standard, state that employers must:
- Provide employees who work in a beryllium work area with a designated change room where employees are required to remove their personal clothing.
- Provide showers when airborne exposure exceeds, or can reasonably be expected to exceed, the TWA PEL or STEL, or when employee hair or body parts other than hands, face and neck can reasonably be expected to become contaminated with beryllium
Additional compliance obligations are coming next year. OSHA will begin enforcing general industry requirements for engineering controls to limit beryllium dust exposures next year, on March 10, 2020.
There are fewer current compliance obligations outside of general industry. OSHA is presently enforcing only the new PEL requirement at construction and shipyard workplaces, and began enforcement at those workplaces in May 2018.
This compliance deadline is the latest chapter in OSHA’s efforts to protect workers from beryllium exposures. The agency’s 2017 final rule had separate standards for general industry, shipyards and construction.
Most notably, the 2017 rule established a new permissible exposure limit (PEL) of 0.2 micrograms of beryllium per cubic meter of air (µg/m3), measured as an 8-hour time-weighted average (TWA) concentration. The rule also established an Action Level (AL) of 0.1 µg/m3and a short-term exposure limit (STEL) of 2.0 µg/m3as measured over a 15-minute sampling period. The rule mandates that employers must use engineering and work practice controls to reduce airborne concentrations of beryllium to levels below the PEL and STEL.
Ancillary requirements for general industry including methods of compliance, work areas, regulated areas, personal protective equipment (PPE), hygiene facilities and practices, housekeeping, hazard communication and recordkeeping, became effective in December 2018. At that time, OSHA also issued a proposed rule to amend selected paragraphs of the standard, including “Definitions,” “Methods of Compliance,” “Personal Protective Clothing and Equipment,” “Hygiene Areas and Practices,” “Housekeeping,” “Medical Surveillance,” “Hazard Communication and Recordkeeping.” It would also add new terms to the “definitions” section of the standard, and would remove the existing Appendix A, which lists suggested controls, and replace it with a new Appendix A called “Operations for Establishing Beryllium Work Areas.”
The comment period for this proposed rule ended on February 9, 2019. OSHA has stated that while the rulemaking is pending, they will evaluate facilities for compliance based on requirements as modified by the proposed rule.
So what should you do during this period of changing beryllium requirements? Prioritize compliance with those requirements of the general industry beryllium standard that have been in effect since December 2018, as well as the change room and shower requirements going into effect on March 11. It would also be wise to familiarize yourself with the provisions of the proposed rule, since OSHA will be evaluating compliance based on its provisions.
Getting a handle on your chemical inventory is a great place to start, because unless you know exactly where beryllium is being used in your workplace, you’ll have difficulty meeting OSHA’s beryllium requirements. Revisit your chemical and SDS management practices, and make sure they’re giving you the visibility you need.
Let VelocityEHS Help!
MSDSonline chemical management solutions from VelocityEHS can help you meet the Hazard Communication requirements of OSHA’s beryllium standard by ensuring your employees have quick, easy access to GHS-formatted SDSs and labels, along with On-Demand training to help them better understand the risks of exposure to beryllium and beryllium compounds present in your workplace.
Our award-winning MSDSonline HQ and HQ RegXR Accounts provide 24/7 mobile-enabled, employee right-to-know access to the industry’s leading database of SDSs, and feature built-in GHS workplace labeling capabilities. Available ingredient indexing features mean you’ll be able to identify all products containing beryllium in your inventory, and be well-prepared to begin assessing employee exposure levels as required under the beryllium standard.
In addition, the VelocityEHS Risk Analysis solution can help streamline the identification of areas where exposure to beryllium may occur, as well as the assignment and tracking of follow-up actions.
If you’re looking for an easier way to manage the inspections needed to comply with the housekeeping requirements of the beryllium rule, our Audit & Inspections solution and VelocityEHS mobile app provide a powerful, yet easy-to-use system that simplifies every aspect of inspection program management — from planning and scheduling, to evaluation, corrective actions and reporting.
With the right tools, you’ll be prepared for compliance with OSHA’s beryllium standard, and ready to take your workplace safety performance to the next level. Request a Demo of our award-winning solutions today, and see why more than 14,000 businesses and 8 million users worldwide trust VelocityEHS to help meet their EHS management needs and build a safer, more sustainable workplace.