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Featured Perspective: Setting the Record Straight about OSHA’s Beryllium Rule

MONDAY, MARCH 5, 2018

By Mark Mummert, Mummert Environmental Consulting, Inc.


During the final days of the Obama presidency, OSHA attempted to implement a sweeping set of beryllium rules, including exposure limits and other regulations, that would have massive implications for the abrasive blasting industry. After hearing from members of our industry, however, OSHA has proposed to rework the beryllium rules to remove a number of requirements that would have increased the cost of abrasive blasting while providing no known health benefits to workers.

Whatever the specific scope of OSHA's final rule will be, it will establish exposure sampling requirements on abrasive blasting contractors. Some in the industry believe that these rules will only impact slag abrasives, but new research commissioned by the Abrasive Blasting Manufacturers Alliance (ABMA) finds that, no matter what blasting media are used, trace levels of beryllium are present at the work site. The trace levels are so low that any health risks are mitigated by personal protective equipment (PPE) and other worker safety rules, but compliance with the regulations will be triggered because of the extremely low action level set by OSHA. Some in our industry are seizing on confusion over the OSHA rule to claim it only affects certain materials. This is false. Abrasive blasters will all need to take the same steps to comply, whether they use slag, glass, garnet or any other blasting media.

Where the OSHA Beryllium Rules Stand Today

OSHA's rulemaking process for construction and shipyards is expected to conclude sometime this year. So what developments have been made since the original decision by the Trump administration to pause the rule? First, OSHA has agreed to both revoke and not enforce the ancillary provisions for construction and shipyards until further notice. Second, OSHA proposed lowering the beryllium permissible exposure limit (PEL) to a value of 0.2 μ/m3 and establishing a short-term exposure limit (STEL) of 2.0 μ/ m3 for the general industry, construction and shipyard sectors.

In the construction and shipyard sectors, this lowering of exposure limits is redundant. The current regulated levels are already sufficiently low to require use of PPE only. The more than two dozen PPE and other safety regulations mandated by OSHA protect all workers from airborne toxins, which is why there has not been a single documented instance of beryllium-related illness in the history of the abrasive blasting industry.

OSHA Rules Impact Expands with Glass Abrasive Study

Just recently, the ABMA released the results of an independent study assessing the beryllium content of nine samples of crushed glass abrasives from major manufacturers and distributors in the industry. The results show that all of the glass samples contained beryllium in concentrations that ranged between 0.270 and 0.757 mg/kg, in addition to arsenic, cadmium and lead. These findings suggest that, if implemented, glass abrasives will also be subject to the beryllium rules. The rules only exempt blasting where it can be shown that employee exposure to beryllium will be below the action level under any foreseeable conditions. This means that abrasive blasting contractors will have to conduct air sampling to test and document beryllium levels on nearly every blasting job, regardless of the blast media being used.

The current proposed OSHA standard is based on whether a blasting material contains less than 0.1 percent beryllium by weight.  Data: Exponent

Despite creative attempts made by advertisement campaigns to mislead the public about the supposed benefits of particular abrasive products, the science speaks for itself. While many in the industry might believe claims made by these advertisers and manufacturers — that their abrasives present "no hazard," that they are the "safe alternative" for blasting, and that they contain "no toxic metals such as beryllium, as found in slags" — such claims have been scientifically disproven. 

A Turning Point for the Abrasive Industry

Unfortunately, the recent government regulations affecting the abrasives industry have been quietly put forth with no relevant data to justify them. These beryllium rules are a solution in search of a problem, which will heap additional costs on abrasive blasters without providing any tangible benefits to employee safety and health. It is time that all users of abrasives — including glass, garnet, slag and sand — recognize that OSHA's beryllium rules will impact them equally and come together to champion sensible regulations that ensure worker health and environmental protection while preserving abrasive blasters' freedom to operate.

*Claims or positions expressed by sponsoring authors do not necessarily reflect the views of TPC, PaintSquare or its editors.

ABOUT THE AUTHOR
Mark Mummert, Mummert Environmental Consulting, Inc.

Mark C. Mummert, Ph.D., PE, CIH, is founder and owner of Mummert Environmental Consulting, Inc. He has 30 years of experience providing consulting services to the manufacturing and service industries.

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Tagged categories: Abrasive blasting; Abrasives; Beryllium; Health & Safety; Health and safety; OSHA; Regulations; Surface preparation

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