Methods of Compliance
Written exposure control plan
The employer must establish, implement, and maintain a written exposure control plan, which must contain:
- A list of operations and job titles reasonably expected to involve airborne exposure to or dermal contact with beryllium;
- A list of operations and job titles reasonably expected to involve airborne exposure at or above the action level;
- A list of operations and job titles reasonably expected to involve airborne exposure above the TWA PEL or STEL;
- Procedures for minimizing cross-contamination, including the transfer of beryllium between surfaces, equipment, clothing, materials, and articles within beryllium work areas;
Procedures for keeping surfaces as free as practicable of beryllium;
NOTE: Under the beryllium standards, the employer is required to keep surfaces in beryllium work areas, materials designated for recycling in general industry, eating and drinking areas as free as practicable of beryllium. As OSHA explained in a 2014 letter of interpretation concerning the meaning of "as free as practicable" in the hexavalent chromium standard, OSHA evaluates whether a surface is "as free as practicable" of a contaminant by the efficacy of the employer's program to keep surfaces clean. A sufficient housekeeping program for beryllium may include a routine cleaning schedule and the use of effective cleaning methods to minimize exposure from accumulation of beryllium on surfaces. The intent of the "as-free-as-practicable" requirement is to ensure that accumulations of beryllium dust do not become sources of employee beryllium exposures. Therefore, any method that achieves this end is acceptable. OSHA further intends for this term to be broad and performance-oriented, so as to allow employers in a variety of industries flexibility to decide what type of control methods and procedures are best suited to their beryllium operations, and OSHA’s beryllium standard does not specify quantitative limits for the amount of beryllium on surfaces. OSHA intends to evaluate compliance based on employer efforts under the circumstances present at each facility. For example, eating and drinking areas may need more frequent cleaning than regulated areas where workers wear PPE. Or work areas may need more frequent cleaning during periods of higher production volume. Where appropriate, based on the beryllium content of the material, employees and employers may be able to assess whether surfaces are visibly clean as a practical guide to determine the effectiveness of a housekeeping program. For example, in industries working with materials that contain more than 0.1% beryllium by weight, visible cleanliness may be a helpful indicator of whether a surface is as free as practicable. However, depending on the operations involved, visible cleanliness may not be necessary or appropriate as a barometer of compliance in industries that work with materials that contain less than 0.1% beryllium by weight. If an employer maintains a reasonable, comprehensive written exposure control plan and follows the plan, the employer would likely be considered to be in compliance with the “as-free-as-practicable” requirement. (Source OSHA FAQ) Cleaning frequencies should be defined by area on a daily, weekly, and monthly basis. Examples of practicable cleaning methods include HEPA vacuuming, mechanical wet floor scrubbing, and wet mopping, washing, and wiping.
- Procedures for minimizing the migration of beryllium from beryllium work areas to other locations within or outside the workplace;
- A list of engineering controls, work practices, and respiratory protection required by paragraph (f)(2) of this standard;
- A list of personal protective clothing and equipment required by paragraph (h) of this standard; and
- Procedures for removing, laundering, storing, cleaning, repairing, and disposing of beryllium-contaminated personal protective clothing and equipment, including respirators.
The employer must review and evaluate the effectiveness of each written exposure control plan at least annually and update it, as necessary, when:
- Any change in production processes, materials, equipment, personnel, work practices, or control methods results, or can reasonably be expected to result, in new or additional airborne exposure to beryllium;
- The employer is notified that an employee is eligible for medical removal in accordance with paragraph (l)(1) of this standard, referred for evaluation at a CBD diagnostic center, or shows signs or symptoms associated with exposure to beryllium; or
- The employer has any reason to believe that new or additional airborne exposure is occurring or will occur.
- The employer must make a copy of the written exposure control plan accessible to each employee who is, or can reasonably be expected to be, exposed to airborne beryllium in accordance with OSHA’s Access to Employee Exposure and Medical Records (Records Access) standard (§ 1910.1020(e)).
The following templates are available for your consideration and use in fulfilling this compliance obligation:
Written Exposure Control Plan - Template
Written Exposure Control Plan – Inventory Table Template
- The employer must establish, implement, and maintain a written exposure control plan, which must contain:
Engineering and work practice controls
- The employer must use engineering and work practice controls to reduce and maintain employee airborne exposure to beryllium to or below the PEL and STEL, unless the employer can demonstrate that such controls are not feasible. Wherever the employer demonstrates that it is not feasible to reduce airborne exposure to or below the PELs with engineering and work practice controls, the employer must implement and maintain engineering and work practice controls to reduce airborne exposure to the lowest levels feasible and supplement these controls by using respiratory protection in accordance with paragraph (g) of this standard.
For each operation in a beryllium work area that releases airborne beryllium, the employer must ensure that at least one of the following is in place to reduce airborne exposure:
- Material and/or process substitution;
- Isolation, such as ventilated partial or full enclosures;
- Local exhaust ventilation, such as at the points of operation, material handling, and transfer; or
- Process control, such as wet methods and automation
An employer is exempt from using the controls listed in paragraph
(f)(2)(i) of this standard to the extent that:
- The employer can establish that such controls are not feasible; or
- The employer can demonstrate that airborne exposure is below the action level, using no fewer than two representative personal breathing zone samples taken at least 7 days apart, for each affected operation.
- Prohibition of rotation. The employer must not rotate employees to different jobs to achieve compliance with the PELs.