As of April 21, OSHA inspectors have new enforcement guidance when performing inspections involving employee exposure to beryllium dust. The guidance will be effective until a new beryllium compliance directive is issued for the 2020 beryllium standards.
Exposures and Assessments
For all three industries, one thing inspectors will obviously be checking on is whether beryllium exposure exceeds the permissible exposure limits (PEL) of the new standards, and if it does exceed the PEL it will result in a serious citation.
At the same time, they’ll also be checking for exposure to “any other air contaminants generated from the same process or operation” and they’ll be issuing a serious citation for each PEL violation they find. Inspectors will also be reviewing exposure assessments to see if employers performed new tests for beryllium exposure “whenever a change in the production, process, control equipment, personnel or work practices may have resulted in … additional exposures.”
If no assessment has been performed, then a citation will of course be issued, but inspectors will also be looking at assessments to ensure they are adequate in terms of sampling time, documentation, and analysis.
Exposure Control Plans
Each industry has its own requirements when it comes to written exposure control plans, but inspectors will be looking for similar things across all three.
The guidance tells inspectors to review the plan and interview managers and employees to determine what engineering and work practice controls were implemented and when.
Then they are to evaluate the effectiveness of the controls, the selected respiratory protection and any employer exemption claims along with the available sampling data.
