**Final Number range CHAPTERSite Visit Report:**

**Beryllium Site 8**

**Submitted to:**

**Office of Regulatory Analysis**

**Directorate for Evaluation and Analysis**

**Occupational Safety and Health Administration**

**Submitted as partial fulfillment of**

**requirements for Task Order 41**

**Contract No. J-9-F-9-0010**

**Submitted by:**

**Eastern Research Group, Inc.**

**110 Hartwell Ave.**

**Lexington, MA 02421**

# TABLE OF CONTENTS

**Introduction........................................................................
2**

**Facility and Process
Description.......................................... 4**

**Exposure
Assessment....................................................... 7**

**Exposure Controls in
Place................................................ 15**

**General
Recommendations................................................ 16**

**Specific
Recommendations................................................ 19**

# References........................................................................ 21 

# Introduction

On December 2 and 3, 2003, a non-ferrous forging and machining facility
was visited. During this visit measurements were made to characterize
worker exposure to airborne and surface levels of beryllium and gather
data to assist in the development of some industry guidance criteria.

Copper beryllium (CuBe) alloys have unique characteristics that make it
a superior material for certain specialized applications. Copper
beryllium's physical and mechanical properties differ considerably from
those of other copper alloys because of the nature and action of the
alloying element beryllium. Varying the beryllium content from about
0.15 to 2.0 percent by weight produces a variety of alloys with
differing physical properties, including strength, and thermal and
electrical conductivity. Heat-treating and hot working (e.g. forging)
CuBe alloys produces an oxide film on the surface. This surface oxide is
a mixture of beryllium oxide (BeO) and copper oxides. The composition
and thickness of the oxidation is dependent on temperature, time, and
atmosphere in the furnace. Beryllium has a great affinity for oxygen and
since beryllium oxide is not reduced by hydrogen, there is no
heat-treating atmosphere that will provide a surface free of beryllium
oxide. It is important to understand the fate of these surface oxides in
any CuBe working manufacturing environment as uncontrolled generation,
accumulation, and distribution can lead to subsequent worker exposure.

Exposure to beryllium compounds is associated with a chronic
debilitating lung disease\--chronic beryllium disease (CBD)\--that is
the result of a beryllium-specific, T lymphocyte-mediated
hypersensitivity. Symptoms of the disease are exertional dyspnea and
cough, followed by weight loss, chest pain, arthralgias, and fatigue.
Progression of the disease may lead to heart failure as a result of
chronic respiratory insufficiency.

# Objectives

The objective of this work is to develop guidance material that would
help business to reduce worker exposure during the processing of
beryllium from the best practices currently found in industry. These
practices are for all users of beryllium regardless of the form the
beryllium is in; metal, oxide or alloy.

The amount or length of exposure to beryllium necessary to cause a
specific individual to develop CBD is not known, but recent information
suggests that even short exposures to levels of beryllium below OSHA's
Permissible Exposure Limit (PEL) of 2 µg/m^3^ averaged over an 8-hour
day may lead to CBD in some workers. CBD may develop within months after
initial exposure to beryllium or may have a very slow onset and not
develop for 25 years or more and may even develop after exposure has
ceased. The prevalence of CBD among beryllium-exposed workers has been
reported to range from an average of about 2% to a high of approximately
15% for workers involved in machining operations in the manufacturing of
beryllium products.

Measurement of exposure to total airborne beryllium dust may not be the
best predictor of CBD. Particle size, surface area, number of particles,
solubility, and the chemical form of beryllium involved may all be
relevant to the development of disease. It has also been suggested that
beryllium can enter through either intact skin or breaks in the skin to
initiate sensitization. Recent studies have shown that particles less
than 1 μm in diameter can penetrate intact skin that has been flexed.
Therefore, it is essential that all possible pathways of exposure be
considered when assessing a work site for potential exposure to
beryllium.

# Facility and Process Description

The company, located in the Midwest, was originally founded in 1946
providing services to copper users around the world. The company is a
manufacturer and distributor of forged copper: beryllium copper, chrome
copper and aluminum bronze in plate, block, bar, rings; and, other
copper alloy forgings for plastic mold tooling, resistance welding
applications, metal melting liners and end caps, and bearing components.
Metal conversion services are also provided to customers who supply
their own metal materials.  Services include recommendation of alloys,
properties and design for tooling applications, concurrent design,
fabrication, heat treating to meet various temper and grain size
requirements, near net shape processing, rough or finish machining,
testing and technical certifications.

The company has over 50,000 square feet of manufacturing space (see
Figure 1). It currently operates a single, 10-hour shift, 4-days per
week work schedule with 40 total workers employed. At the time of this
survey 25 employees worked in the production shop, with 5 having direct
involvement with CuBe alloys. The production capacity of this facility
is approximately 6 million pounds/year. During the time of this visit
the company was operating at an estimated 33% of capacity, 5 -- 10 % of
which involves processing of CuBe alloys.

![](media/image1.wmf){width="6.313888888888889in" height="7.75in"}

##  

## Job Descriptions

The company offers a variety of manufacturing and metal conversion
capabilities designed to meet a number of applications involving
nonferrous alloys. These capabilities encompass a variety of process
steps including material preparation, open die press forging, hammer
forging, and machining to suite customer requirements. Different alloys
follow specific process flows, as required by the material or customer.
Copper beryllium alloys generally require material preparation involving
a series of operations prior to forging. Copper beryllium alloy are
generally received in bulk billet forms (e.g. plates and rounds), some
alloy specifications require a 24 hour homogenization step at 1450 ^ο^F
in a gas fired furnace; billets are cut to a predetermined size on a
metal band saw under flood coolant; cut pieces are loaded into a gas
fired preheat furnace for 12 hours prior to forging; depending on size,
the parts are removed from the preheat furnace by hand or forklift and
held in place under the forging press or hammer mills with mechanical
assist devices; the alloy cools as it is forged and generally has to be
placed back into the furnace to bring up the temperature in between
forging cycles; once forging is completed, CuBe alloys are then annealed
in a furnace where the temperature is brought up to 1325 ^ο^F; the parts
are removed from the furnace and immediately quenched in a water bath;
ends and sides are trimmed on a metal band saw; some CuBe alloys require
an age hardening step where the alloy is held at 600 ^ο^F for 4 hours in
a gas fired furnace; alloys are removed and air cooled; and final
machining of the surfaces to remove oxidation prior to shipment to the
customer.

The following operations were available for observation and sampling
during this evaluation.

*Hammer Mill Forging Operator*

Pre-heated alloys are removed from the furnace, either by hand or
forklift; the parts are held under the hammer mill with the assistance
of the forklift or by one or two operators with the assistance of metal
tongs; the mill is repetitively cycled by the mill operator as the alloy
is rotated and flipped on the hammer mill die. Visible oxidation that
builds up on the alloy is intermittently removed by impaction and
scraping with a steel bar. Parts are reheated in the furnace and forged
as necessary. The hammer mill cycle times observed during this
evaluation were between 8 to 10 minutes. The parts are allowed to air
cool sitting on the lip of the furnace on a ramp leading to the furnace.
A forklift then places the large parts into the annealing furnace.
Smaller parts are manually shoved into the furnace with a steel rod
where they are brought up to 1325 ^ο^F. Parts are removed in the same
manner, either with a forklift or tongs, and subsequently quenched in a
water bath. General exhaust ventilation exists in the forging shop
through a series of wall fans located at the ceiling of the building.
There are no local exhaust ventilation systems in place and no
housekeeping efforts were observed on the date of this survey.

*Open Die Press Forge Operator*

Large alloy billets are removed from gas fired furnaces by a forklift
equipped with a manipulator that allows for handling and rotation of the
billets. The forklift operator positions the billet in the open die
forge; the press operator, stationed inside a control booth,
repetitively cycles the press as the forklift operator rotates and
indexes the billet within the operating envelope of the die; billets are
reheated in the furnace and forged as necessary; after forming is
complete the billets are placed on the floor to air cool. The open die,
press forge cycle times observed during this evaluation were between 5
to 10 minutes. Small sections of the surface of the forged plate
(2/plate) are ground with a pneumatic disk grinder to remove oxidation
and expose the base metal for metallurgical quality testing. General
exhaust ventilation exists in the forging shop through a series of wall
fans located at the ceiling of the building. There are no local exhaust
ventilation systems in place and no housekeeping efforts were observed
on the date of this survey.

*Machining Operator*

The operator receives forged plates from the forging shop; using a
forklift the operator loads the plate onto a table saw, clamps it into
position on the saw table and the edges are trimmed with a circular
blade cutting saw under flood coolant; the plates are removed from the
saw table with a forklift and set aside for milling on the planner mill;
the operator loads the plate onto the planner mill table with a forklift
and clamps it into position. The table of the mill indexes the plate
under a rotating mill head equipped with multiple cutting blades
removing surface oxides and flattening out the surface. The cutting head
is cooled with a spray mist coolant. A number of planner mill passes are
required for each plate surface due to varying degrees of plate
distortion. The plate is turned over and the process is repeated for the
opposite side. It can take up to 120 minutes to completely mill both
sides of the plate. After milling the operator deburrs the edges with a
high-speed pneumatic grinder, blows off the surface with a compressed
air line, and wipes the plate down. Both the table saw and the planner
mill produce considerable volumes of metal chips and the operator
frequently blows chips off machine surfaces and shovels chips from the
floor into scrap collection containers. General exhaust ventilation
exists in the machine shop through an oil mist collection system. There
are no local exhaust ventilation systems in place.

# Exposure Assessment

Sampling was conducted to determine the beryllium air and surface
contamination to which workers are potentially exposed and to derive
some simple measure of dose for these workers. The first day of the site
visit was spent meeting with company personnel (company management and
employees) to arrange sampling on the subsequent day, and to walk
through the plant to begin the industrial hygiene assessment of exposure
and control technology. Employees with the highest potential beryllium
exposures in each process area or operation were the major focus of the
sampling. Workers selected for sampling were briefed on the sampling
procedures to be conducted. Because the goal of this study is to assess
the effects of engineering controls and work practices on beryllium
exposures, samplers were placed outside of any respiratory protective
equipment worn by the worker. Two days of sampling were then conducted
on the only three employees present who worked with beryllium alloy.

## [Sampling Methods]{.underline}

Beryllium-related disease is assumed to be related to the number of
deposited beryllium particles and perhaps the available surface area of
those particles in the lung. Thus, parameters of interest include
surface contamination, skin exposure, airborne particle number
concentration (for particles of a size that deposits in lung), and the
surface area distribution of the beryllium particles, in addition to the
total gravimetric concentration of beryllium in air. The methods used to
assess these parameters are listed below and briefly described in this
section.

+------------------------+---------------------------------------------+
| **Parameter**          | **Sampling Method \[unit of measure\]**     |
+------------------------+---------------------------------------------+
| Surface contamination  | NIOSH Method 9100, surface wipe samples     |
|                        | \[μg/100 cm^2^\]                            |
+------------------------+---------------------------------------------+
| Skin exposure          | Hand wipe samples \[μg/100 cm^2^\]          |
+------------------------+---------------------------------------------+
| Total airborne         | Traditional air sampling for total dust     |
| beryllium              | \[μg/m^3^\]                                 |
| concentration          |                                             |
+------------------------+---------------------------------------------+
| Airborne deposited     | Condensation particle counter (CPC)         |
| particle number        | measuring airborne concentration of         |
| concentration          | particles proportional to that which would  |
|                        | deposit in the lung \[number of particles   |
|                        | between 0.01 and 1 μm per cm^3^ of air\]    |
+------------------------+---------------------------------------------+
|                        |                                             |
+------------------------+---------------------------------------------+
|                        | # Laboratory Analysis                       |
+------------------------+---------------------------------------------+
| Total mass             | Gravimetric analysis \[μg/sample\]          |
+------------------------+---------------------------------------------+
| Beryllium mass (in     | OSHA Method 125-G, graphite furnace atomic  |
| wipe and air samples)  | absorption \[μg beryllium/sample\]          |
+------------------------+---------------------------------------------+

### 

### Surface Samples

Surface contamination evaluation followed the well-established protocol
for lead surface contamination measurements, as did skin sampling.
Surface sampling was done by marking off a 100 cm^2^ area using a
plastic template, with a square hole 10 cm on a side, which was placed
on the surface and the corners marked with the moistened towelette. The
template was then removed and the perimeter lined out with the same
moistened towel. The inside of the square was then wiped according to
NIOSH Method 9100 and the towel placed in a screw-top glass vial for
analysis. The template was cleaned before reuse.

### Skin Samples

Hand wipe samples were obtained by asking study participants to wipe
their hands before the end of their shift or during the shift, at least
two hours after their last hand washing. They were instructed to lift a
fresh wet-wipe from its opened container and to thoroughly wipe both
hands (including the front and back, up to the wrists, and each finger),
removing as much visible dirt as possible. The wipe was then placed in a
labeled screw-top glass vial. The hand wiping exercise was supervised
and timed for 30 seconds by the investigators to ensure consistency from
subject to subject. A tracing of both hands of each participant was
taken to estimate the total surface area of the participants' hands. The
concentration of beryllium on the workers' hands is reported in
micrograms of beryllium per 100 cm^2^.

# *Personal Air Sampling* (Airborne deposited particle number concentration and Total airborne beryllium)

Each full-shift air-sampling subject wore a backpack containing a
condensation particle counter (CPC) \[make, model, calibration date\]
and two personal air-sampling pumps \[make, model\].One of the air
sampling pumps \[nominal air flow rate\] was attached to an Anderson
personal impactor \[model, 8^th^ and final stages only\] clipped outside
the backpack at the worker's lapel. While stage 8 of the impactor
screened larger particles, a triple layer of polycarbonate filters in
the impactor base captured particles 0.01 to 1.0 μm, the size range that
would deposit in the lung. A battery-operated valve allowed the CPC to
alternately measure the concentration of particles in two air
streams: 1) air drawn through the polycarbonate filters and 2) ambient
air from a tube also attached at the workers lapel. By comparing the
particle concentration values recorded by the CPC for the filtered and
unfiltered air-streams, it was possible to estimate the concentration of
particles removed by the layered polycarbonate filters, which represents
the deposited submicrometer particle concentration (DSP).

The second personal air-sampling pump in the worker's backpack was used
for collecting the "total" airborne beryllium sample. This pump was
connected to a 37 mm cassette containing pre-weighed PVC filters,
clipped outside the backpack at the worker's lapel.

When short-term samples were collected during specific tasks, the second
personal air-sampling pump was eliminated and instead a high-flow pump
(Gast, Model, 25 LPM) was connected to the 37 mm cassette assembly on
the workers lapel. The higher flow rate was required to ensure an
adequate volume of air was collected during the shorter sampling period.
A member of the investigative team held the pump and followed the worker
around to assure the tether did not interfere with the worker's
activities. The sampling pumps were calibrated both before and after the
shift using a Bios Dry-Cal meter. Pumps were set within one percent of
the target flow rate.

The PVC filters were analyzed to obtain the total mass and beryllium
mass, from which the fractional beryllium content (% beryllium) was
determined. This percentage was applied to the DSP number concentration
obtained from CPC results, to estimate the percent of that concentration
that was beryllium (Be DSP). This final value, Be DSP, represents the
airborne concentration of beryllium particles that are of a size that
would deposit in the lung and is reported as particles per cubic
centimeter of air (p/cc).

# *[Laboratory Analysis]{.underline}*

OSHA's Salt Lake City Laboratory performed the laboratory analysis.
Gravimetric results were reported to the nearest microgram. Beryllium
mass was determined for surface wipes, hand wipes, and air samples using
OSHA method 125-G, graphite furnace atomic absorption spectrophotometry.
Field blanks made up 10 percent of the samples analyzed and another five
percent were media blanks.

## Sampling Results

*Surface Samples*

**Table I. Results of Surface Samples**

+-----------------------------------+-------+-----------+--------------+
| **Machining**                     | **    | **Surface | **Be         |
|                                   | Total | Area      | Con          |
|                                   | Be**  | (cm2)**   | centration** |
|                                   |       |           |              |
|                                   | **(   |           | **(ug/100    |
|                                   | ug)** |           | cm2)**       |
+-----------------------------------+-------+-----------+--------------+
| Floor next to planner mill (chips | 2     | 100       | 297.50       |
| in sample)                        | 97.71 |           |              |
+-----------------------------------+-------+-----------+--------------+
| Top of fan next to planner        | 4.39  | 100       | 4.18         |
+-----------------------------------+-------+-----------+--------------+
| Side of planner control panel     | 4.08  | 100       | 3.87         |
+-----------------------------------+-------+-----------+--------------+
| Top of planner table (chips in    | 47    | 100       | 4724.29      |
| sample)                           | 24.50 |           |              |
+-----------------------------------+-------+-----------+--------------+
| Top of floor scrubber             | 64.95 | 100       | 64.74        |
+-----------------------------------+-------+-----------+--------------+
| Top of coolant drum               | 24.59 | 100       | 24.38        |
+-----------------------------------+-------+-----------+--------------+
| Top of work table at King mill    | 2     | 100       | 223.05       |
| (chips in sample)                 | 23.26 |           |              |
+-----------------------------------+-------+-----------+--------------+
| Shipping -- top of work table     | 1.92  | 100       | 1.71         |
+-----------------------------------+-------+-----------+--------------+
| Inspection -- Floor leading to    | 1.86  | 100       | 1.65         |
| Admin. Offices                    |       |           |              |
+-----------------------------------+-------+-----------+--------------+
| Floor in material storage area    | 4.30  | 100       | 4.09         |
+-----------------------------------+-------+-----------+--------------+
|                                   |       |           |              |
+-----------------------------------+-------+-----------+--------------+
| **Hammer Forging**                | **    | **Surface | **Be         |
|                                   | Total | Area      | Con          |
|                                   | Be**  | (cm2)**   | centration** |
|                                   |       |           |              |
|                                   | **(   |           | **(ug/100    |
|                                   | ug)** |           | cm2)**       |
+-----------------------------------+-------+-----------+--------------+
| Floor next to press forge         | 46.11 | 100       | 45.90        |
+-----------------------------------+-------+-----------+--------------+
| Work table top in press forge     | 19.94 | 100       | 19.73        |
| area                              |       |           |              |
+-----------------------------------+-------+-----------+--------------+
| Floor just outside office         | 4.88  | 100       | 4.67         |
+-----------------------------------+-------+-----------+--------------+
| Work table top in press forge     | 6.35  | 100       | 6.14         |
| area                              |       |           |              |
+-----------------------------------+-------+-----------+--------------+
| Surface under cutting saw         | 3     | 100       | 331.35       |
|                                   | 31.56 |           |              |
+-----------------------------------+-------+-----------+--------------+
| Floor in corner of building       | 25.70 | 100       | 25.59        |
+-----------------------------------+-------+-----------+--------------+
| Top of hammer forging machine     | 2     | 100       | 261.64       |
|                                   | 61.85 |           |              |
+-----------------------------------+-------+-----------+--------------+
| Fork lift dashboard               | 11.72 | 100       | 11.51        |
+-----------------------------------+-------+-----------+--------------+
| Door of break room                | 0.35  | 100       | 0.14         |
+-----------------------------------+-------+-----------+--------------+
| Break room floor (just inside     | 4.07  | 100       | 3.86         |
| door)                             |       |           |              |
+-----------------------------------+-------+-----------+--------------+
| Break room top of refrigerator    | 2.35  | 100       | 2.14         |
+-----------------------------------+-------+-----------+--------------+
|                                   |       |           |              |
+-----------------------------------+-------+-----------+--------------+
| **Administrative Areas**          | **    | **Surface | **Be         |
|                                   | Total | Area      | Con          |
|                                   | Be**  | (cm2)**   | centration** |
|                                   |       |           |              |
|                                   | **(   |           | **(ug/100    |
|                                   | ug)** |           | cm2)**       |
+-----------------------------------+-------+-----------+--------------+
| Top of paper shredder             | 0.08  | 100       | \< 0.04      |
+-----------------------------------+-------+-----------+--------------+
| Floor in kitchen                  | 0.68  | 100       | 0.47         |
+-----------------------------------+-------+-----------+--------------+
| Lunch room -- next to vending     | 0.20  | 100       | \< 0.04      |
| machine                           |       |           |              |
+-----------------------------------+-------+-----------+--------------+
| Lunch room floor at exit          | 1.20  | 100       | 0.99         |
+-----------------------------------+-------+-----------+--------------+
|                                   |       |           |              |
+-----------------------------------+-------+-----------+--------------+

It is apparent that beryllium is being transferred from work processes
and materials to adjacent production area walking and working surfaces.
This was true of all production areas sampled. Beryllium is also being
transferred out of the production area and into the adjacent
administrative office and support areas. While not as high, on average,
as the production areas the support areas had detectable levels of
beryllium on the surfaces that were sampled.

*Hand Samples*

**Table II. Wipe Samples Obtained from Both Hands Together**

+----------------------------------+-------+--------------+------------+
| **Bare-Hand Samples**            | **    | **Surface    | **Be       |
|                                  | Total | Area (cm2)** | Conce      |
|                                  | Be**  |              | ntration** |
|                                  |       |              |            |
|                                  | **(   |              | **(ug/100  |
|                                  | ug)** |              | cm2)**     |
+----------------------------------+-------+--------------+------------+
| Hammer Mill Forging Op.          | 0.66  | 692          | 0.10       |
| (12/02/03 @ 05:58)               |       |              |            |
+----------------------------------+-------+--------------+------------+
| Hammer Mill Forging Op.          | 2.46  | 692          | 0.36       |
| (12/02/03 @ 07:55)               |       |              |            |
+----------------------------------+-------+--------------+------------+
| Hammer Mill Forging Op.          | 1.18  | 692          | 0.17       |
| (12/02/03 @ 07:57)               |       |              |            |
+----------------------------------+-------+--------------+------------+
| Hammer Mill Forging Op.          | 3.20  | 692          | 0.46       |
| (12/02/03 @ 09:45)               |       |              |            |
+----------------------------------+-------+--------------+------------+
| Hammer Mill Forging Op.          | 3.45  | 692          | 0.50       |
| (12/02/03 @ 12:25)               |       |              |            |
+----------------------------------+-------+--------------+------------+
| Hammer Mill Forging Op.          | 3.04  | 772          | 0.39       |
| (12/03/03 @ 09:55)               |       |              |            |
+----------------------------------+-------+--------------+------------+
| Hammer Mill Forging Op.          | 1.73  | 772          | 0.22       |
| (12/03/03 @ 12:15)               |       |              |            |
+----------------------------------+-------+--------------+------------+
| Forging Mill Fork Lift Op.       | 3.18  | 904          | 0.35       |
| (12/02/03 @ 07:55)               |       |              |            |
+----------------------------------+-------+--------------+------------+
| Forging Mill Fork Lift Op.       | 2.40  | 904          | 0.27       |
| (12/02/03 @ 07:57)               |       |              |            |
+----------------------------------+-------+--------------+------------+
| Forging Mill Fork Lift Op.       | 0.87  | 904          | 0.10       |
| (12/02/03 @ 09:45)               |       |              |            |
+----------------------------------+-------+--------------+------------+
| Forging Mill Fork Lift Op.       | 0.94  | 904          | 0.10       |
| (12/02/03 @ 12:21)               |       |              |            |
+----------------------------------+-------+--------------+------------+
| Planner Mill Machining Op.       | 22.50 | 728          | 3.09       |
| (12/02/03@ 06:30)                |       |              |            |
+----------------------------------+-------+--------------+------------+
| Planner Mill Machining Op.       | 14.72 | 728          | 2.02       |
| (12/02/03@ 06:32)                |       |              |            |
+----------------------------------+-------+--------------+------------+
| Planner Mill Machining Op.       | 41.34 | 728          | 5.68       |
| (12/02/03@ 09:05)                |       |              |            |
+----------------------------------+-------+--------------+------------+
| Planner Mill Machining Op.       | 46.39 | 728          | 6.37       |
| (12/02/03@ 09:07)                |       |              |            |
+----------------------------------+-------+--------------+------------+
| Planner Mill Machining Op.       | 45.83 | 728          | 6.30       |
| (12/02/03@ 13:09)                |       |              |            |
+----------------------------------+-------+--------------+------------+
| Planner Mill Machining Op.       | 43.64 | 728          | 5.99       |
| (12/03/03@ 07:25)                |       |              |            |
+----------------------------------+-------+--------------+------------+
| Planner Mill Machining Op.       | 38.14 | 728          | 5.24       |
| (12/03/03@ 10:40)                |       |              |            |
+----------------------------------+-------+--------------+------------+
| Planner Mill Machining Op.       | 1     | 728          | 19.32      |
| (12/03/03@ 13:00)                | 40.66 |              |            |
+----------------------------------+-------+--------------+------------+
|                                  |       |              |            |
+----------------------------------+-------+--------------+------------+

The hand wipes results follow a similar type trend as those described
for the surface wipes, only in this case representing a measured
exposure to the skin. The planner mill machining operator hand wipe
results were consistently higher than the results for operators in the
forging shop.

*Air Samples*

Table III. Personal Samples -- Total Beryllium

  ---------- ------------- ------------ --------------- ----------- ------------ ------------- ------------- ------------- -----------------
  **Sample   **Subject**   **Date**     **Sample        **Flow      **Sample     **Mass        **Beryllium   **Beryllium   **Beryllium
  Number**                              Duration**      Rate**      Volume**     Collected**   Collected**   Fraction**    Concentration**

                                        **(minutes)**   **(lpm)**   **(m^3^)**   **(μg)**      **(μg)**      **(%)**       **(μg/m^3^)**

  5941       1             12/02/2003   442             2.00        0.884        303           51.80         17.10         58.6

  6099       2             12/02/2003   452             1.98        0.895        242           81.80         33.80         91.4

  6065       3             12/02/2003   445             1.99        0.886        652           1.42          0.22          1.6

  5943       4             12/03/2003   397             1.99        0.790        259           0.24          0.09          0.3

  6112       5             12/03/2003   451             1.92        0.866        959           0.17          0.02          0.2

                                                                                                                           
  ---------- ------------- ------------ --------------- ----------- ------------ ------------- ------------- ------------- -----------------

Subject 1 represents the personal full shift, time weighted average
exposure (58.6 μg/m^3^) to the Hammer Mill operator on 12/02/2003. This
particular operator was responsible for loading and unloading preheat
furnaces and positioning of the alloys on the mill during processing.
Dry grinding of copper beryllium alloys occurred frequently during this
shift primarily as a function of the open die forging activity.

Subject 2 approximates the personal full shift, time weighted average
exposure (91.4 μg/m^3^) to the open die forging forklift operator on
12/02/2003. Due to difficulties in wearing the backpack sampling device
and operating the forklift for a full shift the backpack was strapped to
the forklift as close the operator's breathing zone as possible. The
backpack was removed from the forklift and placed in the break room
during times the operator went on breaks and lunch. The forklift
operator would occasionally exit the forklift during the shift and
during such times the backpack remained on forklift, consequently this
result only represents an approximation of his exposure for the sampled
time period. Technical difficulties with the equipment prevented the
particle count information from being obtained for this job. Dry
grinding of copper beryllium alloys occurred frequently during this
shift primarily as a function of the open die forging activity.

Subject 3 represents the personal full shift, time weighted average
exposure (1.6 μg/m^3^) to the planner mill operator, on 12/02/2003. The
operator's use of compressed air for cleaning and the high speed
pneumatic grinder for deburring are potential contributors to airborne
particulate generation at this operation.

Subject 4 represents the second personal full shift, time weighted
average exposure (0.3 μg/m^3^) to the hammer forging mill operator, this
time on 12/03/2003. This particular operator was responsible for
operation and cycling of the hammer mill. He did not participate in
loading/unloading of the preheat furnaces or positioning of the alloys
on the mill during processing. It is interesting to note that the open
die press forge did not process CuBe alloys on 12/03/2003 and no dry
grinding of plate was observed during the sample period on this date.

Subject 5 represents the second personal full shift, time weighted
average exposure (0.2 μg/m^3^) to the planner mill operator, this time
on 12/03/2003.

The current OSHA Permissible Exposure Limit (PEL) for beryllium in air
is 2.0 μg/m^3^. OSHA considers this level to be insufficient to protect
all workers^1^ and new level has not been established. In the interim
OSHA advises that levels be maintained to the lowest level feasible.

+----------------------------+---+-------+---+------+------+---------+
| **HAMMER MILL 12/02/2003** |   |       |   |      |      |         |
+----------------------------+---+-------+---+------+------+---------+
| ** **                      | * | ###   |   |      | ##   |         |
|                            | * | ## To |   |      | ## B |         |
|                            |   | tal D |   |      | e DS |         |
|                            | * | SP^1^ |   |      | P^2^ |         |
|                            | * |       |   |      |      |         |
+----------------------------+---+-------+---+------+------+---------+
| **Average**                |   | 22140 |   | p/cc | 3786 | p/cc    |
+----------------------------+---+-------+---+------+------+---------+
| **Median**                 |   | 22032 |   | p/cc | 3767 | p/cc    |
+----------------------------+---+-------+---+------+------+---------+
| **standard deviation**     |   | 15609 |   |      |      |         |
+----------------------------+---+-------+---+------+------+---------+
| **number of measurements** |   | 26    |   |      |      |         |
+----------------------------+---+-------+---+------+------+---------+
| **%Beryllium**             | * | 17.1% |   |      |      |         |
|                            | * |       |   |      |      |         |
|                            |   |       |   |      |      |         |
|                            | * |       |   |      |      |         |
|                            | * |       |   |      |      |         |
+----------------------------+---+-------+---+------+------+---------+

+----------------------------+---+-------+---+------+------+---------+
| **PLANNER MILL             |   |       |   |      |      |         |
| 12/02/2003**               |   |       |   |      |      |         |
+----------------------------+---+-------+---+------+------+---------+
|                            | * | ###   |   |      | ##   |         |
|                            | * | ## To |   |      | ## B |         |
|                            |   | tal D |   |      | e DS |         |
|                            | * | SP^1^ |   |      | P^2^ |         |
|                            | * |       |   |      |      |         |
+----------------------------+---+-------+---+------+------+---------+
| **Average**                |   | 1     |   | p/cc | 345  | p/cc    |
|                            |   | 56753 |   |      |      |         |
+----------------------------+---+-------+---+------+------+---------+
| **Median**                 |   | 1     |   | p/cc | 359  | p/cc    |
|                            |   | 63042 |   |      |      |         |
+----------------------------+---+-------+---+------+------+---------+
| **standard deviation**     |   | 48910 |   |      |      |         |
+----------------------------+---+-------+---+------+------+---------+
| **number of measurements** |   | 51    |   |      |      |         |
+----------------------------+---+-------+---+------+------+---------+
| **%Beryllium**             | * | 0.22% |   |      |      |         |
|                            | * |       |   |      |      |         |
|                            |   |       |   |      |      |         |
|                            | * |       |   |      |      |         |
|                            | * |       |   |      |      |         |
+----------------------------+---+-------+---+------+------+---------+

+---------------------------+---+------+---+------+--------+--------+
| **HAMMER MILL             |   |      |   |      |        |        |
| 12/03/2003**              |   |      |   |      |        |        |
+---------------------------+---+------+---+------+--------+--------+
| ** **                     | * | ##   |   |      | ##     |        |
|                           | * | ###  |   |      | ## Be  |        |
|                           |   | Tota |   |      | DSP^2^ |        |
|                           | * | l DS |   |      |        |        |
|                           | * | P^1^ |   |      |        |        |
+---------------------------+---+------+---+------+--------+--------+
| **Average**               |   | 3    |   | p/cc | 28.5   | p/cc   |
|                           |   | 1643 |   |      |        |        |
+---------------------------+---+------+---+------+--------+--------+
| **Median**                |   | 3    |   | p/cc | 27.3   | p/cc   |
|                           |   | 0372 |   |      |        |        |
+---------------------------+---+------+---+------+--------+--------+
| **standard deviation**    |   | 1    |   |      |        |        |
|                           |   | 3243 |   |      |        |        |
+---------------------------+---+------+---+------+--------+--------+
| **number of               |   | 36   |   |      |        |        |
| measurements**            |   |      |   |      |        |        |
+---------------------------+---+------+---+------+--------+--------+
| **%Beryllium**            | * | 0    |   |      |        |        |
|                           | * | .09% |   |      |        |        |
|                           |   |      |   |      |        |        |
|                           | * |      |   |      |        |        |
|                           | * |      |   |      |        |        |
+---------------------------+---+------+---+------+--------+--------+

+--------------------------+---+------+---+-----+----------+--------+
| **PLANNER MILL           |   |      |   |     |          |        |
| 12/03/2003**             |   |      |   |     |          |        |
+--------------------------+---+------+---+-----+----------+--------+
|                          | * | ##   |   |     | #### B   |        |
|                          | * | ###  |   |     | e DSP^2^ |        |
|                          |   | Tota |   |     |          |        |
|                          | * | l DS |   |     |          |        |
|                          | * | P^1^ |   |     |          |        |
+--------------------------+---+------+---+-----+----------+--------+
| **Average**              |   | 9    |   | p   | 18.7     | P/cc   |
|                          |   | 3557 |   | /cc |          |        |
+--------------------------+---+------+---+-----+----------+--------+
| **Median**               |   | 10   |   | p   | 20.5     | P/cc   |
|                          |   | 2569 |   | /cc |          |        |
+--------------------------+---+------+---+-----+----------+--------+
| **standard deviation**   |   | 7    |   |     |          |        |
|                          |   | 9432 |   |     |          |        |
+--------------------------+---+------+---+-----+----------+--------+
| **number of              |   | 37   |   |     |          |        |
| measurements**           |   |      |   |     |          |        |
+--------------------------+---+------+---+-----+----------+--------+
| **%Beryllium**           | * | 0    |   |     |          |        |
|                          | * | .02% |   |     |          |        |
|                          |   |      |   |     |          |        |
|                          | * |      |   |     |          |        |
|                          | * |      |   |     |          |        |
+--------------------------+---+------+---+-----+----------+--------+

The Hammer Mill Be DSP concentration on 12/02/03, for Subject 1 in Table
III, is the highest level that has so far been found among numerous
operations in a variety of facilities sampled under this Contract. Had
there not been a problem with the particle counting equipment on Subject
2 it is possible that exposure would have been the highest level. In
either case, the airborne beryllium concentration for those two subjects
in Table III substantially exceeds the OSHA Permissible Exposure Limit.

# Exposure Controls in Place

## Access Control

Access to the production area is not rigidly controlled for
office/administrative personnel. Administrative personnel enter the
production areas of the facility in street clothes and shoes without any
special precautions. Workers are permitted in the office environment and
enter on a daily basis. Company supplied uniforms are provided for use
on a voluntary basis. Workers are not required to wear the uniforms.
However, most employees do wear them and most change out at work. The
locker rooms where workers can change from work clothes to street
clothes are not designed to prevent personal/work clothing
cross-contamination. Showers are available for workers to use, however,
their use is not mandatory.

## Personal Protective Equipment (PPE)

Standard industrial safety glasses and work shoes are required in the
manufacturing area. There is no routine or constant use of respiratory
protection equipment. Workers wear standard cotton/leather work gloves
as the work tasks require for abrasion/cut protection. No use of
impermeable gloves by operators was observed. Overall, there is no
strategy for keeping beryllium off the skin.

## Work Practice Controls

The site reportedly conducts CuBe operations with the expectation that
all processes capable of producing airborne particulate (e.g. machining
and grinding) be conducted under wet conditions. Management expectations
regarding beryllium health and safety are verbally communicated,
however, do not appear to be clear, certain, and well defined in
documentation, training or ongoing program audits. Worker compliance
with company established work practices and procedures is suspect; as an
example management has communicated that grinding of CuBe alloys is
never to be performed dry and is only permitted under wet conditions.
This expectation had not been well transferred into practice, as dry
grinding of CuBe alloys was observed on both days of this evaluation.

## Housekeeping

Housekeeping in all zones of the facility is not well-organized.
Operators are responsible for keeping their work areas free of bulk
accumulations of chips and debris, however, little attention is given to
beryllium specific cleanliness. Of particular note is the forging shop
where visible dust accumulations are apparent on virtually all walking
and working surfaces. Compressed air and dry sweeping of equipment and
walking and working surfaces is readily used as a local cleaning
technique and was observed on both days of this evaluation.

## Local Exhaust Ventilation Controls

There were no local exhaust ventilation controls in place at this
facility during the dates of this evaluation. General ventilation is
provided in the forging and machining shop as previously described.

# Discussion

####### Specific Recommendations

This site visit was not intended to serve as a comprehensive industrial
hygiene review. Thus, investigators did not evaluate all possible
hazards at this facility. To optimize migration control, the design
layout and sequence of work practices are important during transitions
from controlled plant areas to designated offices or administrative
areas outside the control zone. The following considerations should be
incorporated into current or future re-designs:

-   Dry grinding and dry deburring of CuBe alloys need to be strictly
    prohibited. This expectation needs to be clearly defined in written
    procedures and documentation. Management audits should be performed
    to ensure work practices are consistent with procedural
    expectations.

-   A respiratory protection program needs to be implemented at the
    facility. Respiratory protection needs to be worn by forging and
    machining operators, until engineering and work practice controls
    are implemented and worker exposures are consistently maintained
    well below the current OSHA standard.

-   The use of wet methods alone, for controlling particles generated
    from a high speed grinding or deburring process is often not
    sufficient. Local exhaust ventilation should be designed and
    installed for controlling airborne particles during grinding and
    deburring of CuBe materials.

-   The use of flood coolant, rather than spray mist cooling, at the
    planner mill should be investigated, in an effort to provide
    additional suppression of alloy particulate and reduce the overall
    concentration of oil mist generation. If flood coolant is not
    practical or feasible, local exhaust ventilation should be designed
    and installed to reduce overall particulate escape from the process.

-   Workers entering a beryllium work area should change out of personal
    clothing and shoes into company supplied work uniforms and shoes.
    Work clothing and shoes should remain at the plant site at the end
    of the shift.

-   Showers should be taken by all beryllium workers at the end of the
    work shift.

-   Housekeeping requirements specific to controlling beryllium
    accumulation need to be developed, documented, observed, and
    audited. Procedures for cleaning the open die forge, hammer mills
    and, planner after a beryllium alloy run need to be developed and
    observed. Compressed air and dry sweeping in beryllium work areas
    should be strictly prohibited. Vacuuming and wet cleaning are the
    preferred techniques for cleaning beryllium contaminated work
    surfaces.

-   Ideally, there should only be one designated/routine entry into
    controlled work areas where PPE is required.

-   A transition zone should be established between the controlled work
    area and non-controlled area (administrative offices, break areas,
    etc.)

-   The transition zone should be designed and constructed to facilitate
    the use of tack mats, donning and doffing respirators, gloves, and
    coveralls, dirty PPE disposal, seating, and clean PPE storage.

-   Tack mat floor covering should be designed for 3-foot falls per foot
    to increase effectiveness of particle removal from work shoes at the
    transition area.

-   Disposable protective gloves should be on before handling any
    potentially contaminated articles or work surfaces.

-   Disposable gloves should be on at all times inside the transition
    room and the plant area. Gloves should only be removed just before
    exiting the transition room into an adjacent office/support area.

-   Work shoes should be covered, removed, or otherwise cleaned prior to
    leaving the transition room into an adjacent office or support area.

-   Foot cross over designs and techniques should be considered in the
    transition area to control transfer of shoe contamination from the
    work area to the office area.

-   All reusable PPE should be placed in covered storage containers.

-   Glove disposal containers should be located at any transition point.

-   Containers of clean disposable gloves should be available at the
    entrance into the plant area and at operator workstations.

-   Hand wipes should be available wherever clean gloves are stored to
    facilitate hand washing prior to donning clean gloves.

-   Beryllium contaminated waste containers should have lids with foot
    pedals. This will alleviate the temptation of workers to throw
    potentially contaminated trash from any distance and will also make
    it unnecessary to touch the lid to open it.

-   All porous surfaces should be eliminated to the extent feasible,
    unless they are disposable and are disposed of regularly, in that
    they may accumulate beryllium dust. This especially includes
    fabric-covered chairs in the work area.

-   Workers and management should closely study the work practice
    sequences at transition and locker room areas. Identify all articles
    having a potential for contamination and develop work practice
    sequences that minimize migration of beryllium particles from the
    plant into the office or locker room areas.

# General Recommendations

OSHA has developed the following general recommendations for all
beryllium workplaces:

*[Engineering Controls]{.underline}*\
\
Employers should use appropriate engineering controls and work practices
to ensure that worker exposures to beryllium are maintained below the
current OSHA PELs to the extent feasible. The following engineering
controls and practices should be used by employers:

-   enclose processes;

-   design and install appropriate local exhaust ventilation;

-   use vacuum systems in machining operations;

-   use pellets instead of powders wherever possible;

-   use product substitution where possible;

-   minimize the number of workers who have access to areas where there
    is a potential for beryllium exposure;

-   monitor employee exposures to airborne beryllium dust and fume,
    using personal sampling techniques, on a regular basis to ensure
    that exposures are below the PELs and that proper respiratory
    protection is being used where necessary.

*[Work Practices to Reduce Beryllium Exposure\
]{.underline}*Employers should ensure that employees use the following
safe practices to reduce their exposure to beryllium:

-   use high-efficiency particulate air (HEPA) vacuums to clean
    equipment and the floor around their work areas;

-   do not leave a film of dust on the floor after the water dries if a
    wet mop is used to clean;

-   do not use long vacuum hoses and do not loop the hoses that are
    used;

-   do not disconnect or disable the vacuum system during any machining
    operation;

-   never use compressed air to clean parts or working surfaces;

-   avoid prolonged skin contact with beryllium particulate; and

-   do not allow workers to eat, drink, smoke, or apply cosmetics at
    their work stations.

*[Hygiene and Personal Protective Clothing\
]{.underline}*\
OSHA is aware of CBD cases that have occurred among family members of
beryllium-exposed workers. To reduce \"carry-home\" exposures, employers
should provide showers, clean work clothes, and clean areas for storing
street clothes**.** Protective clothing should be provided to employees
who work in areas where beryllium-containing powders are used and where
there is a potential for spills. In addition, employers should ensure
that employees:

-   change into work uniforms before entering their work area;

-   place their uniforms in a labeled bin with a cover at the end of the
    work shift;

-   shower and change into street clothes prior to leaving the facility;

-   wash their face, hands, and forearms before eating, smoking, or
    applying cosmetics;

-   keep their work clothes as clean as possible during the workshift;

-   wipe off their shoes before leaving the work area; and

-   do not wear their work uniform (including their work shoes) outside
    of the facility.

*[Respiratory Protection]{.underline}*\
\
Recent data suggest that exposures to beryllium even at levels below the
2 micrograms/m^3^ PEL may have caused CBD in some workers. Therefore,
employers should consider providing their beryllium-exposed workers with
air-purifying respirators equipped with 100-series filters (either N-,
P-, or R-type) or, where appropriate, powered air-purifying respirators
equipped with HEPA filters, particularly in areas where material
containing beryllium can become airborne.\
\
*[Training\
]{.underline}*\
Employers should give employees exposed to beryllium training and
information about the following items:

-   material safety data sheets (MSDSs) for beryllium;

-   the fatal lung disease that may occur as a result of exposure;

-   the availability of the BeLPT blood test to determine whether an
    exposed worker has become sensitized to beryllium;

-   the potential for developing lung cancer as a result of exposure;

-   the importance of avoiding skin contact;

-   the engineering controls the employer is using to reduce worker
    exposures to beryllium;

-   specific work practices that can be used to reduce exposure to
    beryllium;

-   the use of appropriate protective equipment, including the use of
    respirators;

-   the results of any industrial hygiene sampling for levels of
    beryllium in the workplace; and

-   a copy of all pertinent Hazard Information Bulletins from OSHA.

*[Health Screening Methods for Beryllium sensitization and Chronic
Beryllium Disease]{.underline}*\
\
Employers should consider sending beryllium-exposed employees to a
physician or other licensed health care professional to be evaluated for
beryllium sensitization or the presence of CBD. The screening
examination for CBD usually begins with a chest x-ray and a blood test
for beryllium sensitization, namely, the BeLPT, plus any further
evaluation considered appropriate by the health care professional. The
blood test can detect an adverse health response to beryllium exposure
earlier than breathing tests or chest x-rays can. The BeLPT is not
routinely done in most medical laboratories; however, the health care
professional may order this test from any laboratory that has overnight
courier service to one of the Medical Research Centers listed below. If
a worker is sent to a health care professional for health screening, a
copy of OSHA's Hazard Information Bulletin 19990902, *Preventing Adverse
Health Effects From Exposure to Beryllium on the Job* should accompany
the employee.

Employees who work in a place where beryllium is used and have developed
any of the symptoms listed below, should inform their health care
professional of their past beryllium exposure, or seek information from
a health care professional who specializes in occupational lung diseases
to determine whether they may have developed CBD:

-   unexplained cough,

-   shortness of breath,

-   fatigue,

-   weight loss or loss of appetite,

-   fevers, and/or

-   skin rash.

If they do not have any of the above symptoms but are concerned that
they may have become sensitized to beryllium, they should inform their
health care professional that they would like to be tested with the
blood BeLPT. They should also take a copy of the above-mentioned Hazard
Information Bulletin with them.

# References

1.  Occupational Safety and Health Administration (OSHA) - Health
    Intelligence Bulletin. *Preventing Adverse Health Effects From
    Exposure to Beryllium on the Job.* September 2, 1999.

2.  McCawley, M.A., M.S. Kent and M.T. Berakis. Ultrafine beryllium
    number concentration as a possible metric for chronic beryllium
    disease risk. Appl. Occupational and Environ. Hyg. 16(5): 631-638
    (2001)