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SAFETY 2018

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22 SAFETY 2018 COATINGSPROMAG.COM By Stanford T. Liang, CIH, CSP, Senior Industrial Hygienist at Tetra Tech, Inc. Understanding the New Beryllium Standard A s of March 12, 2018, employers regulated under the Occupational Safety and Health Administration (OSH A) General Industr y Standards (29 CFR 1910) have been required to comply w ith the General Industr y Ber yllium Standard (29 CFR 1910.1024). Standard 29 CFR 1910.1024 does not apply to construction-related tasks, including alteration and repair. Ty pically, workers engaged in routine production or maintenance tasks, such as a steel fabrication shop, w ill fall under 29 CFR 1910. W here there is uncertainty as to which standard applies, OSH A's policy is to apply the more restric- tive of the Construction Industr y Standards: 29 CFR 1926 or 29 CFR 1910. OSHA announced that enforcement of 29 CFR 1910.1024 has been delayed to May 20, 2018, which permits OSHA to further review policy and law questions. OSHA has made it clear, though, that this does not affect the compliance dates. How might this affect the construction industry? What's Covered 29 CFR 1910.1024 requires that worker breathing zone exposures comply with an Action Level (AL) of 0.1 μg/m3 (0.003 μg/ft.3), a Permissible Exposure Limit (PEL) of 0.2 μg/ m3 (0.006 μg/ft.3), and a Short Term Exposure Limit (STEL) of 2 μg/m3 (0.06 μg/ft.3). e PEL and AL are based on an eight- hour time weighed average while the STEL is an exposure limit applicable to a fifteen-minute sampling period. If you have a facility that falls under 29 CFR 1910.1024, workers engaged in abrasive blasting have a potential exposure to beryllium as it is present in most common abrasive blasting agents. A study published by the National Institute of Occupational Safety and Health (NIOSH) in 1998 titled Evaluation of Substitute Materials for Silica Sand in Abrasive Blasting found beryllium in varying concentrations in common abrasives, such as coal and copper slag, crushed glass, garnet, nickel, olivine, specular hematite, staurolite, and steel grit, evaluated in both air and bulk samples. Employers must comply w ith this standard when using products w ith a ber yllium content exceeding 0.1 percent. If the concentration is less than 0.1 percent, then an employer is exempt only where the employer has objective data demonstrating that employee exposure to airborne ber yl- lium w ill remain below the action level under any foresee- able conditions. Objective data means information, such as air monitor- ing data from industry-wide surveys or calculations based on the composition of a substance, demonstrating airborne exposure to beryllium associated with a particular product or material or a specific process, task, or activity. e data must reflect workplace conditions closely resembling or with a higher airborne exposure potential than the processes, types of material, control methods, work practices, and environ- mental conditions in the employer's current operations. If beryllium is present in an abrasive material and objective data is not available, employers are obligated to obtain personal air samples to evaluate whether occupations performing tasks with potential exposure are in compliance with the AL, PEL, or STEL. Personal air sampling require- ments for beryllium are similar to other comprehensive health standards, such as for lead: • Personal air sampling can be discontinued if exposures are below the AL and STEL. Further monitoring would only be required if there is a change in production, process, control equipment, personnel, or work practices, which can reason- ably be expected to result in new or additional beryllium exposures. • Monitoring must be repeated every six months if exposures exceed the AL and every three months if exposures exceed Safety

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