doc_fn:    neword/440/g4401-7.html
ID:        DOE G 440.1-7
Title:     Interim Chronic Beryllium Disease Prevention Program
DocType:   ArcGuide
Summary:
Org:       EH
Date_Issue: 07/11/1997
Date_Close:
VdkVgwKey: neword-11
Directive: 440.1
Text:

						    DOE G 440.1-7
                                                          3-30-98
                                
                                
                                
                      IMPLEMENTATION GUIDE
                          for use with
                        DOE NOTICE 440.1
                                
                   INTERIM CHRONIC BERYLLIUM
                   DISEASE PREVENTION PROGRAM
                                
                                
                                
                                
                                
                                
                                
                                
                                
                                
                                
               OFFICE OF WORKER HEALTH AND SAFETY
                                
                          Disclaimer 
This Implementation Guide references specific sections of several available guides that are
not part of the DOE Directives System.  DOE endorses these specific sections but has made
no judgments about the usefulness of the other sections of these guides.                             FOREWORD

         1.       This Department of Energy (DOE) guide is approved by the Office of Environment, Safety
         and Health (EH) and is available for use by all DOE components and their contractors.
         
         2.       Beneficial comments (recommendations, additions, and deletions) and any pertinent data that
         may improve this document should be sent to the Director, DOE Office for Worker Health
         and Safety (EH-5), U.S. Department of Energy, Washington, D.C. 20585, by letter or by
         sending the self-addressed Standardization Document Improvement Proposal
         (DOE F 1300.3).
         
         3.       This guide is intended to identify acceptable methods for implementing the provisions of
         DOE Notice 440.1.                            ACRONYMS
                                
                   ABIH               American Board of Industrial Hygiene
ACGIH         American Conference of Governmental Industrial Hygienists
                   ACL                Administrative Control Level
                   AEC                Atomic Energy Commission
AIHA               American Industrial Hygiene Association
ANSI               American National Standards Institute
AWE                Atomic Weapons Establishment
                        Be                      Beryllium
                   BEI                Biological Exposure Indices
Be-LPT        Beryllium-Induced Lymphocyte Proliferation Test
BWI                Brush Wellman, Incorporated
CBD                Chronic Beryllium Disease 
CBDPP         Chronic Beryllium Disease Prevention Program
CFR                Code of Federal Regulations
CRD                Contractor Requirements Document
D&D                Deactivation and Decommissioning
DOE                Department of Energy
                   EH                 Office of Environment, Safety and Health
                   EH-5               DOE Office for Worker Health and Safety
              ELISA         Enzyme-Linked Immunosorbent Assay
EPA                Environmental Protection Agency
FEOSH         Federal Employee Occupational Safety and Health Program
                   FEV                Forced Expiratory Volume
                   FVC                Forced Vital Capacity
HEPA               High-Efficiency Particulate Air
                   IARC               International Agency for Research on Cancer
ICP                Inductively Coupled Plasma
ISM                Integrated Safety Management
LANL               Los Alamos National Laboratory
LIBS               Laser Induced Breakdown Spectroscopy
                   LTT                Lymphocyte Transformation Test
                   MSDS               Material Safety Data Sheet
NIOSH         National Institute for Occupational Safety & Health
NPE                Negative Pressure Enclosures
OEL                Occupational Exposure Limit
OSHA               Occupational Safety and Health Administration
PEL                Permissible Exposure Limit
                   PPE                Personal Protective Equipment
                   RCRA               Resource Conservation and Recovery Act
RFETS         Rocky Flats Environmental Technology Site
                   STEL               Short-term Exposure Limit
TLV                Threshold Limit Value
TRADE         Training Resources and Data Exchange
TWA                Time Weighted Average                            CONTENTS
                                
Paragraph                                                    Page

FOREWORD . . . . . . . . . . . . . . . . . . . . . . . . . . . .i

ACRONYMS . . . . . . . . . . . . . . . . . . . . . . . . . . . ii

I.       INTRODUCTION. . . . . . . . . . . . . . . . . . . . . .1

II.      APPLICATION . . . . . . . . . . . . . . . . . . . . . .2

         III.     GENERAL INFORMATION 

                       1.   PROGRAM ELEMENTS . . . . . . . . . . . . . . . . .7
         
                       2    STRATEGY FOR REDUCING AND MINIMIZING EXPOSURES . .7

                       3    MINIMIZING DISABILITY. . . . . . . . . . . . . . .7

                       4.   PROGRAMMATIC CONSIDERATIONS. . . . . . . . . . . .8
                                 4.1  Written Program . . . . . . . . . . . . . . .8
                                 4.2  Occupational Exposure Limits. . . . . . . . .9
                                 4.3  Program Integration . . . . . . . . . . . . 12
                                 4.4  Teaming . . . . . . . . . . . . . . . . . . 12
                                 4.5  Goals . . . . . . . . . . . . . . . . . . . 13
                                 4.5.1     Goals for Exposure Reduction and Minimization14
                                 4.6  Documentation . . . . . . . . . . . . . . . 16
                                 4.7  Labor Relations Requirements. . . . . . . . 17
                                 4.8  Qualified Personnel . . . . . . . . . . . . 17

                  References. . . . . . . . . . . . . . . . . . . . . . 19

         IV.      GUIDELINES
         
                  1.   BASELINE INVENTORY AND SAMPLING
                                 1.1  Baseline Inventory and Sampling Requirements21
                                 1.2  General Implementing Guidance for Baseline Inventory and Sampling21
                                 1.3  Specific Implementing Guidance for Baseline Inventory and Sampling22
                                                1.3.1     Inventory . . . . . . . . . . . . 22
                                                1.3.2     Sampling. . . . . . . . . . . . . 22

                  2.   HAZARD ASSESSMENT
                                 2.1  Hazard Assessment Requirements. . . . . . . 24
                                 2.2  General Implementing Guidance for Hazard Assessments24
                                 2.3  Specific Implementing Guidance for Hazard Assessments24

                  3.   EXPOSURE MONITORING
                                 3.1  Exposure Monitoring Requirements. . . . . . 26
                                 3.2  General Implementing Guidance for Exposure Monitoring27
                                 3.3  Specific Implementing Guidance for Beryllium Monitoring27
                                                3.3.1     Personal Air Monitoring . . . . . 30
                                                3.3.2     Area Air Monitoring . . . . . . . 34
                                                3.3.3     Surface Monitoring. . . . . . . . 36
                            References . . . . . . . . . . . . . . . . . . . 38

                  4.   EXPOSURE REDUCTION AND MINIMIZATION
                                 4.1  Exposure Reduction and Minimization Requirements39
                                 4.2  General Implementing Guidance for Exposure Reduction and Minimization39
                                 4.3  Specific Implementing Guidance for Exposure Reduction and Minimization39
                                                4.3.1     Goals, Plans, and Performance Measures41
                                                4.3.2     Administrative Action Levels. . . 42
                                                4.3.3     Exposure and Contamination Controls43
                                                          4.3.3.1   Engineering Controls . . . . 45
                                                          4.3.3.1.1  Ventilation. . . . . . 45
                                                          4.3.3.1.2  Glovebags and Negative Pressure Enclosures47
                                                          4.3.3.2   Administrative Controls. . . 47
                                                          4.3.3.2.1  Restricted-access Areas48
                                                          4.3.3.2.2  Decontamination Facilities50
                                                          4.3.3.2.3  Personal Hygiene . . . 51
                                                          4.3.3.2.4  Warning Signs and Labels52
                                                          4.3.3.2.5  Industrial Hygiene Procedures55
                                                          4.3.3.2.6  Work Practices . . . . 55
                                                          4.3.3.3   Personal Protective Equipment58
                                                          4.3.3.3.1  Protective Clothing. . 58
                                                          4.3.3.3.2  Respiratory Protection 59
                                                          4.3.3.4   Waste Management . . . . . . 60
                            References . . . . . . . . . . . . . . . . . . . 62
         
                  5.   MEDICAL SURVEILLANCE
                                 5.1  Occupational Medicine Requirements. . . . . 63
                                 5.2  General Implementing Guidance for Medical Surveillance63
                                 5.3  Specific Implementing Guidance for Occupational Medicine Monitoring66
                            References . . . . . . . . . . . . . . . . . . . 70

         6.   TRAINING
                                 6.1  Training Requirements . . . . . . . . . . . 71
                                 6.2  General Implementing Guidance for Training. 71
                                 6.3  Specific Implementing Guidance for Training 71
                            References . . . . . . . . . . . . . . . . . . . 73

         7.   RECORDKEEPING
                                 7.1  Recordkeeping Requirements. . . . . . . . . 74
                                 7.2  General Implementing Guidance for Recordkeeping74
                                 7.3  Specific Implementing Guidance for Recordkeeping75
                                                7.3.1     Program Records . . . . . . . . . 75
                                                7.3.2     Exposure and Medical Records. . . 75
                            
                       8.   PERFORMANCE FEEDBACK
                                 8.1  Performance Feedback Requirements . . . . . 78
                                 8.2  General Implementing Guidance for Performance Feedback78
                                 8.3  Specific Implementing Guidance for Performance Feedback80
                                                8.3.1     Outcome Measures. . . . . . . . . 80
                                                8.3.2     Output Measures . . . . . . . . . 80
                                                8.3.3     Surveillance. . . . . . . . . . . 81
                                                8.3.4     Teams To Identify Feedback Sources and Needs82

                  TABLE

         Table 1  Recommended Schedule of Medical Surveillance. . . . . 64

APPENDICES

              Appendix A    Basis for Departmental Action. . . . . . . . . .A-1
                                 Attachment A-1 Properties, Hazards, and Uses of BerylliumA-8
              Appendix B    Catalog of Chronic Beryllium Disease Prevention Program Examples and
              Descriptions . . . . . . . . . . . . . . . . . . . . . . . . .B-1
              Appendix C    Training Matrix. . . . . . . . . . . . . . . . .C-1
              Appendix D    Training Resource Materials. . . . . . . . . . .D-1
              Appendix E    DOE Directives Citations Relevant to the CBDPP .E-1I.       INTRODUCTION

DOE Notice 440.1 (DOE N 440.1) establishes a chronic beryllium disease prevention program
(CBDPP) that enhances, supplements, and is integrated into the worker protection program
requirements of DOE Order 440.1 (DOE O 440.1), "Worker Protection Management for DOE
Federal and Contractor Employees."  Appendix E contains specific citations from DOE O 440.1
that identify requirements that are relevant to a CBDPP.  This program is designed to reduce the
number of current workers exposed, minimize the levels of beryllium exposure and the potential
for exposure to beryllium, and establish medical surveillance protocols to ensure early detection
of disease.

DOE's CBDPP is part of the Department's efforts to establish the framework for an effective
worker protection program that will reduce or prevent accidental losses, injuries, and illnesses by
providing DOE Federal and contractor workers with a safe and healthful workplace.

DOE N 440.1 requires DOE elements and contractors to develop a specific CBDPP for their site.
This non-mandatory Implementation Guide (DOE G 440.1-7) for use with DOE N 440.1 was
developed to assist sites by describing DOE's expectations for these site-specific CBDPPs.

DOE G 440.1-7 presents suggestions and various approaches that DOE elements and contractors
may wish to consider for use in the risk-based implementation of DOE N 440.1 as an integral
part of their worker protection programs.  The goal of DOE G 440.1-7 is to make accessible to
the user a detailed presentation of how a site might wish to implement DOE N 440.1.  It
accomplishes this goal by providing information concerning lessons learned and best practices
for controlling beryllium exposure and disease as well as references to other sources of
information.II.      APPLICATION

DOE N 440.1 applies to all activities (including design, construction, operation, maintenance,
deactivation and decommissioning [D&D], research and development, and environmental
restoration activities) performed by DOE, its contractors, and their subcontractors.

Activities conducted under the authority of the Director, Naval Nuclear Propulsion Programs,
described in Public Law 98-525, are exempt from the provisions of DOE N 440.1.

DOE N 440.1 does not apply to DOE laboratory operations involving beryllium that are subject
to the requirements of 29 CFR (Code of Federal Regulations) 1910.1450, "Occupational
Exposure to Hazardous Chemicals in Laboratories."  The Occupational Safety and Health
Administration (OSHA) describes laboratory operations for the purposes of 29 CFR 1910.1450
(b) by the following definitions:

                  "Laboratory" means a facility where the "laboratory use of hazardous chemicals" occurs. 
         It is a workplace where relatively small quantities of hazardous chemicals are used on a
         non-production basis.

                  "Laboratory scale" means work with substances in which the containers used for
         reactions, transfers, and other handling of substances are designed to be easily and safely
         manipulated by one person.  Laboratory scale excludes those workplaces whose function
         is to produce commercial quantities of materials.

                  "Laboratory use of hazardous chemicals" means handling or use of such chemicals in
         which all of the following conditions are met:
                            Chemical manipulations are carried out on a "laboratory scale";
                            Multiple chemical procedures or chemicals are used;
                            The procedures involved are not part of a production process, nor in any way
              simulate a production process; and
                            "Protective laboratory practices and equipment" are available and in common use
              to minimize the potential for worker exposure to hazardous chemicals.

                  "Protective laboratory practices and equipment" means those laboratory procedures,
         practices, and equipment accepted by laboratory health and safety experts as effective, or
         that the employer can show to be effective, in minimizing the potential for worker
         exposure to hazardous chemicals.

                  Furthermore, 29 CFR 1910.1450 does not apply to quality control or quality assurance
         laboratories, or pilot plants, that support production processes.

Most of DOE's operations involving beryllium, including operations in DOE's national
laboratories, would not be considered laboratory operations by OSHA's definitions and therefore
would not be exempt from DOE N 440.1.

The CBDPP addresses current DOE and DOE contractor workers.  "Current workers" includes
presently employed workers who are, or potentially are, being exposed at DOE-owned or -leased
facilities at this time and presently employed workers who may have been exposed to beryllium
at DOE-owned or -leased facilities in the past.  Presently employed workers include workers who
left and returned to employment. Former DOE and DOE contractor workers who may have been
exposed to beryllium at DOE-owned or -leased facilities are not addressed in DOE N 440.1. (See
Appendix A, Section 1.7 for further discussion on former workers.)

The Contractor Requirements Document (CRD) (Attachment 2 to DOE N 440.1) delineates
requirements that are to be applied to contractors that have been awarded contracts for
performing work for DOE on DOE-owned or -leased facilities.  Contractor compliance with the
CRD will be required to the extent set forth in a contract.

DOE G 440.1-7 provides general information and methodologies that DOE finds acceptable in
meeting the Department's requirements defined in DOE N 440.1.  Other worker protection-
related Implementation Guides are:

                  G 440.1-3, "Occupational Exposure Assessment"

                  G 440.1-4, "Contractor Occupational Medical Program"

The Federal Employee Occupational Safety and Health (FEOSH) Program is established in
29 CFR 1960, "Basic Program Elements for Federal Employee Occupational Safety and Health
(FEOSH) Programs and Related Matters."  Requirements for FEOSH flow down into
DOE O 440.1 and are reflected in G 440.1-7.

In addition, other DOE Rules, Orders, and their Implementation Guides will have an impact on
the CBDPP.  Those documents contain requirements and non-mandatory guidance that must be
integrated with the CBDPP to be complete and effective.  The additional Orders and Rules
include but are not limited to:

                  DOE O 440.1, "Worker Protection Management for DOE Federal and Contractor
         Employees"

                  DOE O 210.1, "Performance Measures and Data Analysis"

                  DOE O 225.1, "Accident Investigation" 

         DOE O 231.1, "Safety and Health Reporting Requirements"

                  DOE O 232.1, "Occurrence Reporting"

                  DOE O 361.1, "Federal Employee Training"

                  DOE O 5480.29, "Employee Concerns" 

                  10 CFR 830.330, "Training and Qualification"

Additional non-mandatory guidance (Implementation Guides, technical standards, and
handbooks) is available to assist DOE elements and contractors in developing a successful site-
specific CBDPP.  This additional guidance includes but is not limited to:

                  DOE G 120.1-5, June 1996, Guidelines for Performance Measurement

                  Functional Area Qualification Standards for Defense Nuclear Facilities Technical
         Personnel

These additional non-mandatory guidance documents describe acceptable means of satisfying the
requirements established in DOE N 440.1.  DOE elements and contractors are free to use the
guidance provided in DOE G 440.1-7 and the additional non-mandatory guidance listed above, or
develop their own unique methods, provided that these alternative methods afford workers a
level of protection equal to or greater than that required by DOE N 440.1.

Additional guidance that was not published for DOE-wide use also has been used in DOE
G 440.1-7 and is referenced at its point of use in the text.  Disclaimer:  This Implementation
Guide references specific sections of several available guides that are not part of the DOE
Directives System.  DOE endorses these specific sections but has made no judgments about the
usefulness of the other sections of these guides.

         III.     GENERAL INFORMATION

         1.       PROGRAM ELEMENTS

The CBDPP elements consist of conducting a baseline inventory and sampling, conducting
hazard assessments, conducting exposure monitoring, reducing and minimizing exposures,
conducting medical surveillance, providing training, keeping records, and providing performance
feedback.  Detailed information about each of these subjects is provided in Section IV. 

2.       STRATEGY FOR REDUCING AND MINIMIZING EXPOSURES

Exposure reduction and minimization includes reducing airborne levels of beryllium as-low-as-
practical, minimizing the number of current workers exposed and potentially exposed to
beryllium, minimizing the number of opportunities to be exposed, and setting reasonable
exposure reduction and minimization goals using a risk-based (tailored) approach.  Section
IV.4.3.3 provides detailed information on actions that reduce and minimize exposures.  There is
not yet an accepted technical basis to define reduction and minimization in terms of an exposure
limit that would adequately prevent chronic beryllium disease (CBD) in DOE workers who are
predisposed to developing CBD (see Appendix A, Section 1.3, and Attachment A-1, Section 2). 
Each DOE site is expected to consider social, technical, economic, practical, and public policy
considerations in implementing exposure reduction and minimization that is appropriate for their
site.  Each DOE site is expected to apply a graded approach to minimizing beryllium exposures
based on the level of risk of incurring CBD.
         3.       MINIMIZING DISABILITY

The disability associated with CBD should be minimized by early detection of the disease. 
Current workers who are sensitized to beryllium or have CBD should be offered placement in
positions without beryllium exposure to maintain employment, and be assured of continued
medical screening.  Section IV.5 provides detailed information on early detection through
medical surveillance.  Although DOE currently funds medical surveillance programs, state
workers' compensation programs provide benefits to workers who need medical treatment as a
result of CBD.  It is important to involve Contractor Benefits Administrators and Loss Control
Managers in developing a CBDPP to assure that benefit programs address unique CBD issues.

The presentation and progression of CBD are highly variable.  A percentage of individuals with
positive results in their peripheral blood beryllium-induced lymphocyte proliferation tests (Be-
LPT) probably will require treatment for CBD symptoms even though those symptoms and other
signs of CBD may not be present at the time of the test.  Close medical monitoring of those
workers who are positive on the Be-LPT but are presently without loss of lung function or other
symptoms will allow for the consideration of early treatment options, if symptoms appear, that
may slow progression of the disease and reduce both morbidity and mortality (ref. III.3.1).

         4.       PROGRAMMATIC CONSIDERATIONS

The strategy of the DOE CBDPP is to "look" for beryllium in order to identify where it exists in
the work site; establish its hazard significance to set priorities for actions; minimize, within
reason, instances where exposure may occur and reduce exposure levels to as low as practical in
order to prevent disease from occurring; detect disease that has occurred at the earliest stages to
allow early treatment; and evaluate program effectiveness to promote its continuous
improvement.

4.1      Written Program

                  The site-specific CBDPP should be incorporated and integrated into a site's written
         worker protection program and should outline specific goals and objectives for the
         CBDPP (see Appendix E for relevant citations from DOE O 440.1).  The written program
         should describe, in detail, the responsibilities and accountability of program personnel
         and the specific procedures to be used to implement the required DOE CBDPP elements
         (see Section III.1).  The written program should address integrating line management,
         workers, maintenance, and worker protection and other support functions.

                  The written program also should reflect the nature of beryllium activities performed and
         the level of potential beryllium exposure at the site.  

         4.2      Occupational Exposure Limits

                  See Appendix E for citations in DOE directives relevant to occupational exposure limits
         (OEL).  See Appendix A, Section 1.3 for a discussion on the efficacy of the OELs.  Also
         in Appendix E are citations relevant to administrative action levels.  Section IV.4.3.2
         describes administrative action levels.

                  OSHA

                  29 CFR 1910.1000, the OSHA General Industry Standard, establishes the following
         permissible exposure limits (PEL) for beryllium:

                            8-Hour Time Weighted Average (TWA) - 2 micrograms/m3 (A worker's exposure
              to beryllium and its compounds in any 8-hour work shift of a 40-hour work week
              shall not exceed 2 micrograms/m3);

                            Acceptable Ceiling Concentration - 5 micrograms/m3 (A worker's exposure to
              beryllium and its compounds shall not exceed at any time during an 8-hour shift
              the 5 micrograms/m3 acceptable ceiling concentration limit);

                            Acceptable Maximum Peak Concentration -  25 micrograms/m3 (A worker's
              exposure to beryllium and its compounds shall not exceed 25 micrograms/m3, the
              acceptable maximum peak above the acceptable ceiling concentration, for a
              maximum duration of 30 minutes).

                  The 8-hour TWA exposure limit of 2 micrograms/m3 is repeated in 29 CFR 1926.55 for
         construction. Also, 29 CFR 1926.55 adopts the 1970 ACGIH TLVs for beryllium, and
         OSHA recommends using the latest version of a consensus standard which, in this case,
         are the ACGIH TLVs provided later on in this section.

                  OSHA has specific beryllium requirements for welding and cutting on beryllium-
         containing base or filler metals in 29 CFR 1910.252(c)(8):

                            Welding or cutting indoors, outdoors, or in confined spaces involving beryllium-
              containing base or filler metals shall be done using local exhaust ventilation and
              airline respirators unless atmospheric tests under the most adverse conditions have
              established that the workers' exposure is within the acceptable concentrations
              defined by 1910.1000.  In all cases, workers in the immediate vicinity of the
              welding or cutting operations shall be protected as necessary by local exhaust
              ventilation or airline respirators.

                  These above requirements are repeated in 29 CFR 1926 for construction.  In addition,
         OSHA Technical Manual - CPL 2-2.20B references beryllium in Chapter 1, "Personal
         Sampling for Air Contaminants," Appendix 1-E, "Sampling for Special Analyses," under
         "Samples Analyzed by Inductively Coupled Plasma (ICP)" and in Chapter 2, "Sampling
         for Surface Contamination," which suggests swipe sampling of surfaces since
         accumulated toxic materials such as beryllium "may become suspended in air, and may
         contribute to airborne exposures.  Bulk and wipe samples may aid in determining this
         possibility."  (ref. III.4.1)

                  NIOSH (National Institute for Occupational Safety & Health)

                  Recommended Exposure Level (Ceiling) - 0.5 microgram/m3

                  NIOSH also identifies beryllium as an occupational carcinogen.  In making the
         carcinogen determination, NIOSH uses the following definition:

                            Potential occupational carcinogen means any substance, or combination or
              mixture of substances, which causes an increased incidence of benign and/or
              malignant neoplasms, or a substantial decrease in the latency period between
              exposure and onset of neoplasms in humans or in one or more experimental
              mammalian species as the result of any oral, respiratory or dermal exposure, or
              any other exposure which results in the induction of tumors at a site other than the
              site of administration.  This definition also includes any substance which is
              metabolized into one or more potential occupational carcinogens by mammals. 
              (Section 3.1.2 of ref. III.4.1)

         American Conference of Governmental Industrial Hygienists (ACGIH)

                  The ACGIH has established the following Threshold Limit Value (TLV) for beryllium
         and beryllium compounds:

                            8-Hour TWA - 2 micrograms/m3;

                            Short-term Exposure Limit (STEL) - 10 micrograms/m3 (15-minute TWA
              exposure which should not be exceeded at any time during a workday even if the
              8-hour TWA is within the TLV TWA.)

                  The ACGIH lists beryllium and beryllium compounds as an A1 carcinogen, a known
         human carcinogen.  ACGIH explains this classification in their Documentation of TLVs
         by indicating that the weight of evidence supports the view that beryllium is a confirmed
         human carcinogen but is of such low potency that only persons exposed to airborne levels
         above 100 micrograms/m3 would be at significant risk of developing lung cancer (Section
         3.1.3 of ref. III.4.1).

4.3      Program Integration
                            
                  The DOE CBDPP is an integral part of  DOE's worker protection program and should be
         an integral part of the worker protection program at sites where beryllium exposure is
         reasonably possible. Sites with Integrated Safety Management (ISM) plans should include
         the CBDPP therein.  Sites with a Work Smart set of standards should consider DOE N
         440.1 requirements for relevance. Work that involves beryllium should be planned by
         interdisciplinary teams including workers assembled to perform enhanced work planning.
         The CBDPP should be integrated into all other current and future worker protection
         initiatives for which beryllium exposure is reasonably possible.
                            
         4.4      Teaming

                  The site-specific CBDPP should be implemented by interdisciplinary teams that integrate
         line management, workers, maintenance, and worker protection and other support
         functions.  Workers should be included when planning work, identifying hazards, or
         during other activities where the worker may provide valuable insights into local
         beryllium hazards and effective controls.  DOE O 440.1 requires that the written site
         worker protection program (which should include the CBDPP) outline a method for
         encouraging worker involvement in the development of program goals, objectives, and
         performance measures and in the identification and control of hazards in the workplace. 
         (See Appendix E for a citation on teaming.)

         4.5      Goals

                  The DOE CBDPP includes setting reasonable goals using a risk-based (tailored) approach
         that reflects the level of risk of incurring CBD.  Goals that reflect expectations for each of
         the CBDPP program elements (see Section III.1) would be useful tools for improving
         program performance.  In general, goals are targets, or achievements that one works
         toward accomplishing.  Goals define what is important, provide focus, establish direction,
         and provide a basis for measuring performance.  Examples of site-specific CBDPP goals
         include:

                            Complete the sitewide baseline inventory and sampling by the end of FYXX.

                            Complete hazard assessments for all known beryllium activities/processes by the
              end of FYXX.

                            Enroll all workers who are exposed or potentially exposed to airborne or
              potentially airborne beryllium in a medical surveillance program by the end of
              FYXX.

                            Review job and exposure history of all beryllium sensitized workers by FYXX.

                            Provide beryllium hazard communication training to all workers who are exposed
              or potentially exposed to beryllium by the end of FYXX, and general employee
              awareness training on beryllium to all other workers by the end of FYXX.

                            Provide performance feedback reports on a quarterly basis beginning in FYXX.

                            4.5.1     Goals for Exposure Reduction and Minimization

                  Exposure reduction and minimization goals are essential and are explicitly required by
         DOE N 440.1 (see Appendix E).  Goals for exposure reduction and minimization should
         be established and reestablished periodically using a risk-based approach.  Reestablishing
         goals does not require a continuous reduction in exposures, but instead ensures that goals
         are current with the site's mission and management is actively engaged in the
         implementation and continuous improvement of the site's CBDPP.  In some cases, goals
         may be modified to allow higher exposures consistent with mission changes requiring
         increased workloads or activities that emit greater amounts of airborne beryllium so long
         as these goals never exceed OELs.  For sites conducting extensive nonroutine activities,
         such as D&D, goals reflecting the intrinsically higher level of risk and limited availability
         of engineering controls may be appropriate.  When establishing exposure reduction and
         minimization goals, the following factors should be considered:

                            Existing exposure levels,

                            Reductions in exposures needed to reach an OEL or administrative action level,

                            Impact on workers,

                            Effectiveness of control options,

                            Impact on operations, and

                            Social, technical, economic, practical, and public policy considerations in
              determining the practicability of various control options for reducing and
              minimizing worker exposure to beryllium.

                  Examples of goals reflecting exposure reduction and minimization efforts include:

                            No more than xx (determined by site management) percent of all measured
              exposures for FYXX will exceed the site's administrative action level.

                            No measured exposures for FYXX will exceed the 8-hour TWA PEL at work sites
              where engineering and administrative controls are available to maintain exposures
              below that level.  It is recognized that a small percentage of exposure values are
              likely to exceed the PEL.  Site management should consider those exceedences to
              be violations of the DOE Order that adopted the OSHA standard and a failure to
              achieve this goal.

                            There will be no incidents of uncontrolled exposures during FYXX.  It is
              recognized that incidents of uncontrolled exposures may occur.  Site management
              should consider those incidents to be a failure to achieve this goal.

                            The total number of beryllium-exposed workers for FYXX will decrease by xx
              (determined by site management) percent of the current number of beryllium-
              exposed workers after normalizing for any change in the potential for beryllium
              exposure that is expected due to changes in mission work with beryllium and the
              scope of work to be performed.

                            The total number of workers entering restricted-access areas for FYXX will
              decrease by xx (determined by site management) percent from the current number
              of workers entering restricted-access areas after normalizing for any change to the
              amount of work taking place in these areas that is expected due to changes in
              mission work with beryllium and the scope of work to be performed.

                  Additional information specific to exposure reduction and minimization goals and
         performance measures is provided in Section IV.4.3.1  Additional information provided
         by DOE's Training Resources and Data Exchange (TRADE) organization on goals and
         performance measures in general can be found in ref. III.4.2.  A source of information for
         specific safety and health performance measures that could be modified for the site-
         specific CBDPP is Kodak's "Safety Performance Indexing:  Metrics for Safety
         Performance Improvement Projects" (ref. III.4.3).

         4.6      Documentation

                  Two types of documentation are essential to the DOE CBDPP.  One type are the records
         that provide sufficient information about the site's exposure and health conditions to
         understand the causes of any CBD that occurs.    Documenting and posting the locations
         where beryllium hazards exist fall into this category.  The other type of documentation
         provides a description of the site-specific CBDPP, including the goals that are set and the
         site's performance against those goals.  This programmatic documentation is critically
         important because the DOE CBDPP uses the performance-based strategy of requiring
         performance toward reducing and minimizing exposures rather than selecting DOE-wide
         OELs.  Documentation of site-specific CBDPP rationales, plans, and performance is an
         important factor in demonstrating adherence to the requirements of DOE N 440.1.  See
         Section IV.7 for more details about documentation and recordkeeping.

         4.7      Labor Relations Requirements

                  An application of reduction and minimization principles with regard to the protection of
         workers from the hazards of exposure to beryllium at DOE work sites constitutes a
         mandatory subject of bargaining under Section 8(a)(5) of the National Labor Relations
         Act.  Where workers are represented for purposes of collective bargaining, in the absence
         of a waiver of the union's rights, an employer violates that duty to bargain by either
         (1) unilaterally changing conditions pertaining to workplace exposure to beryllium
         without notice and bargaining to a good-faith impasse with the collective-bargaining
         representative of its workers or (2) substantially and materially modifying any collective-
         bargaining agreement regarding workplace beryllium practices without the agreement of
         the labor organization.  Therefore, DOE N 440.1 provides for an exception consistent
         with the requirements of the National Labor Relations Act.  See Appendix E for the
         relevant citation in DOE N 440.1.

                  Sites should include the collective bargaining representatives of workers in the
         development of a site CBDPP to help ensure that labor relations issues are resolved
         before the plan is submitted to DOE for approval.

         4.8      Qualified Personnel

                  DOE N 440.1, 3.a. calls for the use of qualified personnel (see Appendix E for the
         citation).  Worker protection personnel who are responsible for implementing a site-
         specific CBDPP should be qualified in their discipline and specifically qualified in the
         subject of beryllium within their discipline.

                  An effective worker protection program must have access to competent industrial
         hygienists. Management should ensure that its industrial hygiene staff:

                            Is adequately trained in the anticipation, recognition, evaluation, and control of
              hazardous and potentially hazardous occupational exposures, and

                            Has the support necessary to maintain and enhance the staff's proficiency in
              industrial hygiene through continued training, professional education, and
              professional activities (e.g., the professional certification process).

                                      Because industrial hygienists have widely varying backgrounds,
                   experience, talent, and education, their development programs should be
                   individualized.  Within the worker protection field, opportunities exist for
                   cross-training among the various disciplines.  For example, an industrial
                   hygienist may benefit from cross-training in health physics, environmental
                   protection, occupational safety, and waste management, as well as from
                   management training in administration, budgeting, and strategic planning.

                  The industrial hygiene aspects of the worker protection program should be directed by a
         senior industrial hygienist with appropriate experience, who should report directly to a
         senior member of management.  A senior industrial hygienist is a person who is certified
         in the practice of industrial hygiene or who meets the American Board of Industrial
         Hygiene's (ABIH) requirements for certification.  At a minimum, such individuals must
         have a college or university degree in industrial hygiene or a related scientific,
         engineering, or technical degree; special studies and training; and 5 years of full-time
         employment in the professional practice of industrial hygiene.  An industrial hygiene
         technician should have, at a minimum, a high school diploma, special studies and training
         in the field of industrial hygiene, and five years of experience under a senior industrial
         hygienist.  Appropriate introductory-level college courses can serve as the equivalent of
         one year of experience, and an appropriate associate's degree can serve as the equivalent
         of two years of experience. [See the ABIH Bulletin (ref. III.4.4) for detailed requirements
         for certification or eligibility for certification.]

                  DOE G 440.1-4 describes professional qualifications for medical staff (see Appendix E
         for relevant citations).  In addition, the DOE Department-wide Functional Area
         Qualification Standard:  Industrial Hygiene Qualification Standard can be used to
         establish the qualifications of industrial hygienists and the Office Specific Standards
         called for in the Department-wide Technical Qualifications Program can be used to
         address specific knowledge, skills, and abilities concerning beryllium.  A directory of
         DOE Qualification Standards is available on the World Wide Web at
         http://cted.inel.gov/cted/qualstd/ and the industrial hygiene standard is at
         http://cted.inel.gov/cted/qualstd/ih.html.
                         III.  References

              III.3.1       Rossman, M.D., et al., Beryllium: Biomedical and Environmental Aspects. 
              Williams & Wilkins, Baltimore, MD, 1990

              III.4.1       Defense Programs Beryllium Good Practice Guide, University of California
              Publication Number UCRL-ID-127871, July 1997

              III.4.2       Training Resources and Data Exchange (TRADE).  How To Measure
              Performance:  A Handbook of Techniques and Tools, October 1995

              III.4.3       Kodak Corporate Safety, Eastman Kodak Company (716-722-6955):  Safety
              Performance Indexing:  Metrics for Safety Performance Improvement
              Projects, 1994

              III.4.4       American Board of Industrial Hygiene, Bulletin, April 13, 1997

         IV.      GUIDELINES

         1.       BASELINE INVENTORY AND SAMPLING

         1.1      Baseline Inventory and Sampling Requirements

                  See Appendix E for the requirements to characterize the workplace and identify activities
         that may contribute to potential workplace exposures.  
                  
         1.2      General Implementing Guidance for Baseline Inventory and Sampling

                  Baseline inventory and sampling are the first steps in determining potential beryllium
         exposures.  The desired outcome is a complete inventory of available information on
         workers, tasks, materials, and locations that can be reviewed to identify the potential
         beryllium hazards.  The baseline inventory and sampling should provide an inventory of
         activities that may generate hazardous exposures and a list of the potentially exposed
         workers, preliminary exposure monitoring data, and preliminary exposure profiles of each
         similarly exposed group of workers.  Included in the inventory is a comprehensive listing
         of locations where beryllium is located or suspected.  This information is vital in
         determining locations for posting areas, establishing beryllium restricted areas, and in the
         conduct of work planning that results in adequate and appropriate worker protection from
         beryllium hazards. Appendix E identifies DOE's Exposure Assessment Implementation
         Guide, (DOE G 440.1-3), which provides information on initial hazard identification and
         conducting qualitative exposure monitoring, including development of exposure profiles,
         identification of exposure groups, and use of administrative controls limits.

         1.3      Specific Implementing Guidance for Baseline Inventory and Sampling

                            1.3.1     Inventory

                  All sources of information about the current and former presence and use of beryllium on
         site should be considered for review to ascertain the locations of beryllium and the
         potential for beryllium exposures.  Sites should use a risk-based approach to determine
         which of these sources to review. See Appendix E for requirements to conduct an
         inventory of beryllium hazards and DOE G 440.1-3, Section 4.4.1, for a list of sources of
         information to review in conducting a hazard inventory.

                  1.3.2     Sampling

                  Once the potential presence of beryllium is established, sampling should be conducted to
         verify the locations and actual and potential exposure levels.  (See Appendix E for the
         DOE N 440.1 requirement for sampling.)  DOE N 440.1 does not intend that sites sample
         locations that are not likely to present a reasonable risk of beryllium exposure based on
         the inventory.  Standard survey sampling techniques for air sampling (breathing zone and
         fixed location or "area") and available survey sampling techniques for surface sampling
         should be used to determine the extent of possible contamination and exposure.  A site's
         beryllium sampling strategy should use a combination of sampling techniques that are
         appropriate to the site's conditions and should document the controls, including personal
         protective equipment (PPE) in use, and the amount and form of beryllium used in the area
         for the period for which the sampling results are representative.  (See Section IV.3.3 for
         details on sampling.)

                  Appendix B, Numbers 1 and 2 provides specific examples of sampling plans and hazard
         assessments conducted at facilities at Los Alamos National Laboratory (LANL) and
         Rocky Flats Environmental Technology Site (RFETS) that had potential beryllium
         hazards.  Appendix B, Number 3, provides examples of typical sampling field data and
         results.

         2.       HAZARD ASSESSMENT

         2.1      Hazard Assessment Requirements

                  See Appendix E for requirements when conducting hazard assessments.

         2.2      General Implementing Guidance for Hazard Assessments

                  Hazard assessment is the activity of determining and documenting the likelihood that
         individuals will contract CBD from exposure to beryllium that has been identified in the
         results of the baseline inventory and sampling.  

         2.3      Specific Implementing Guidance for Hazard Assessments

                  The higher the toxicity (different forms of beryllium have different levels of toxicity) and
         the greater the frequency and magnitude of beryllium exposure, the greater the hazard. 
         Other determinants of hazards are the physical and chemical form of the beryllium; the
         likelihood that the beryllium will become airborne; the frequency, magnitude, and
         variability of exposure; and the routes of exposure.  The hazard assessment should also
         consider the adequacy and potential for failure of engineering and work practice controls.
         Sections IV.1 and IV.3 provide information about characterizing workers' exposures. 
         Section III.4.2 and Appendix A, Attachment A-1, Section 2, provide information about
         beryllium OELs and other measures of toxicity.  The hazard assessment should be based
         on this exposure and toxicity information and be performed as a collaboration among line
         management, workers, maintenance, and worker protection and other support functions.

                  Early integration of exposure assessment with work planning activities ensures that
         assessments of potential exposures during the work are addressed in the work plan.  The
         use of a work planning team will help facilitate this integration.  A multidisciplinary
         team, convened at the earliest stage of a job or project, can help plan the work and include
         the hazard characterization and exposure assessment as part of the job.  Team members
         may include planners, engineers, managers, health and safety professionals, professionals
         from other technical disciplines, technicians, and representative workers.
         3.       EXPOSURE MONITORING

         3.1      Exposure Monitoring Requirements

                  See Appendix E for exposure monitoring requirements.

                  DOE N 440.1 requires the exposure monitoring of workers in beryllium areas or engaged
         in beryllium operations in order to collect accurate exposure data on individual workers.
         DOE N 440.1 also allows a subset of workers to be monitored as long as the rationale for
         using a subset is provided. Situations for which monitoring a subset of workers is allowed
         are further described in section IV.3.3 below.

                  The terms "assessment" and "monitoring" often are used to convey the same general
         meaning.  The Environmental Protection Agency (EPA) and the American Industrial
         Hygiene Association (AIHA) both provide the following definition of exposure
         assessment:

                            Exposure Assessment is the determination or estimation (qualitative or
              quantitative) of the magnitude, frequency, duration, and route of exposure
              (ref. IV.3.1, EPA "Guidelines for Exposure Assessment; Notice," May 29, 1992;
              ref. IV.3.2, AIHA "A Strategy for Occupational Exposure Assessment," 1991).

                  Exposure monitoring for DOE G 440.1-7 more narrowly refers only to the ongoing
         determination or estimation (quantitative) of the magnitude, frequency, duration, and
         route of actual beryllium exposure to workers.  

         3.2      General Implementing Guidance for Exposure Monitoring

                  For operations having potential beryllium exposure, surveys should include:

                            Personal monitoring for airborne contaminants using breathing zone samples that
              reflect the 8-hour TWA exposures, TWA excursions, short-term exposures, or
              ceiling exposure of the worker, as indicated by the appropriate occupational
              exposure limit. Area monitoring results should not be used for estimating
              personnel exposures.

                            Sampling and analysis, using methods specified by OSHA or NIOSH or by other
              methods documented to be at least as accurate as the OSHA or NIOSH methods.

                            Interpretation of personal monitoring results by industrial hygienist(s) in a manner
              that is consistent with procedures in OSHA's Field Inspection Reference Manual
              (ref. IV.3.5) and Technical Manual (ref. IV.3.6).

         3.3      Specific Implementing Guidance for Beryllium Monitoring

                  Much of the following information is based on the Defense Programs Beryllium Good
         Practice Guide (ref. IV.3.3).  Other good practices can be found in the procedures of the
         Brush Wellman Company, Inc. (BWI), (Appendix B, Number 4), and the Atomic
         Weapons Establishment (AWE), Cardiff Facility (Appendix B, Numbers 5-8).

                  A beryllium exposure assessment plan should be developed for activities with beryllium
         exposure or potential for exposure.  Ref. IV.3.3 provides additional guidance on
         developing such a plan.  Appendix B, Numbers 1 and 2, identify examples of plans.  The
         suggested plan would be a component of the written worker protection program
         addressed in Section III.4.1.  The relevant elements of the suggested plan are the
         following:

                            identifying all potential exposures to beryllium;

                            ranking exposure hazard potential;

                            identifying potentially exposed workers;

                            monitoring to characterize exposures;

                            documenting, communicating, and keeping records of monitoring results;

                            determining the frequency of monitoring; and

                            developing and establishing mechanisms to initiate additional monitoring
              following changes in processes, production, materials, controls, work practices, or
              personnel (ref. IV.3.3, Section 4).

                  A useful tool for communicating ranking of exposure potential is to develop an exposure
         matrix for all beryllium activities and different forms of beryllium in use at the site that is
         similar to Table 2 in DOE G 440.1-3 (see Appendix E).

                  The suggested plan would be updated along with the written worker protection program
         that addresses beryllium (covered in Section III.4.1) periodically and when significant
         operation, process, or procedure changes are made.

                  An effective exposure assessment plan uses statistical principles to determine the most
         meaningful monitoring to conduct and the most meaningful presentation of the
         monitoring results.  Presentation of results should use statistical tools to describe the
         uncertainty, variability, and level of confidence of the results to avoid misunderstandings
         and inappropriate actions in response to the results. The NIOSH Occupational Exposure
         Sampling Strategy Manual (ref. IV.3.4) is a good reference to consult to obtain techniques
         for applying statistical principles to monitoring beryllium at a site.  DOE's Exposure
         Assessment Implementation Guide, DOE G 440.1-3 (see Appendix E) describes exposure
         assessment in terms of the three types of monitoring relevant to the workplace:

                            personal air monitoring;

                            area air monitoring; and

                            surface monitoring.  

                  Monitoring serves one or both of the following two fundamental purposes: 

                            determining personal exposure, and 

                            diagnosing the sources of exposure.

                  Appendix B, Numbers 1 and 2, are examples of actual sampling plans for personal air,
         area air, and surface sampling.  Appendix B, Number 3, provides examples of typical
         sampling field data and results.  

                            3.3.1     Personal Air Monitoring

                  Personal air monitoring is used primarily to estimate or measure individual worker
         exposure.  The major personal air monitoring issues that must be addressed in the
         exposure assessment plan are whom, when, and how often to monitor, what to measure,
         and by what methods.

                  Breathing zone is recommended for personal monitoring because samples of breathing
         zone air provide the best estimate of worker exposure.  Breathing zone samples should be
         obtained for every worker for every shift until sufficient data are collected that
         demonstrate that worker exposures are fully characterized and uniformly low.  Breathing
         zone samples are the only samples that can be used to represent personal exposure. 
         Breathing zone sample results should not be reported as adjusted by protection factors for
         samples taken while the worker was using respiratory protection.  This approach of
         reporting unadjusted breathing zone sample results is required by OSHA to demonstrate
         compliance and allows worker protection professionals to compare and aggregate
         different sets of breathing zone results.  The type of respiratory protection and its
         protection factor should be noted with the sample results.  Results both unadjusted and
         adjusted by protection factors should be provided to the monitored workers with an
         explanation of the meaning of these results.  Sampling results should include the actual
         concentration and sampling time in addition to any TWAs that may be calculated.

                  Monitoring every worker for every shift is recommended but less monitoring may be
         appropriate under limited circumstances.  Both representative monitoring and reduced
         frequency of monitoring for specific operations may be appropriate once the operations
         and their controls are stable and monitoring data demonstrate that exposure levels are
         stable and consistently below an administrative action level.  No, or occasional,
         monitoring may be appropriate for highly controlled operations, e.g., operations
         conducted in fully enclosed systems.  

                  Groups that are selected to be characterized by representative monitoring should be
         selected based on actual tasks performed and their individual histories of exposures, not
         on job title.  For a given representative group, the individuals with the highest expected
         exposure should be monitored.  Ref. IV.3.3, Section 4.2.1 recommends the minimum
         percentage of workers in each representative group that should be monitored and provides
         a table, (Table 4-1), that recommends the frequency of personal air monitoring needed as
         a function of the reasonable potential level of beryllium exposure.  Ref. IV.3.3  further
         suggests that sometimes an increase in sampling frequency helps to make positive
         changes to local culture, e.g., by providing performance measures that motivate workers
         to actively trend and reduce their own exposures.  The representative and reduced
         frequency monitoring still should allow continued demonstration that workers' exposures
         are adequately characterized and consistently below an administrative action level. The
         exposure matrix shown as Table 2 in DOE G 440.1-3 can be a convenient tool for linking
         the individuals or groups to tasks and the exposures anticipated from those tasks.   

                  Additional recommendations for personal air monitoring include the following:

                            Characterization of all operations and job tasks for both full shift and potential
              peak exposures.  New operations, or those recently modified or previously
              uncharacterized, require the most intensive initial exposure evaluation.  Personal
              monitoring and sample analysis should be conducted in accordance with
              procedures in the OSHA Technical Manual (ref. IV.3.6) and NIOSH methods
              7102 (ref. IV.3.7) and 7300 (ref. IV.3.8) or equivalent. Comparability of
              equivalent methods should be documented.

                            In operations where it can be reasonably expected that brief high concentrations of
              beryllium may be possible, the initial monitoring should include short-term 
              breathing zone samples.  These exposure samples should be taken during those
              portions of operations expected to produce high-level exposures.  Such sampling
              would be taken in addition to full shift monitoring.

                            Rapid analysis and feedback.  Rapid analysis and feedback of worker exposure
              data allows early identification of problems.  Analysis of samples at the end of
              each shift would provide the opportunity to correct problems before work
              continued.  Also, this would allow validation of individual worker's clean work
              practices.

                            Frequent monitoring.  For example, in the United Kingdom, the AWE has
              successfully monitored every beryllium worker during every shift (ref. IV.3.3,
              Section 4.2.1).  The AWE Cardiff facility monitored every worker (approximately
              300) for every shift for 37 years of operation (see Appendix B, Numbers 5 and 8).

                  Frequent personal monitoring allows the site to validate its specific CBDPP.  Section
         4.2.1 of ref. IV.3.3 provides the following additional reasons for frequent personal air
         monitoring:

                            It provides greater assurance that workers are not overexposed.

                            The variability of exposures in the workplace can be characterized.

                            Individual work practices contributing to high exposures can be identified.

                            It acts as a continuing check on the efficacy of workplace controls.

                  The added value of frequent monitoring should be considered when developing an
         exposure assessment plan.  The cost of frequent monitoring may be relatively small
         compared to that of a worker over-exposure or the shutdown of an operation due to
         control failure (ref. IV.3.3, Section 4.2.1).

                  Non-routine operations such as maintenance, repair, cleaning, D&D, and special projects
         have some of the highest potential exposures to beryllium (ref. IV.3.3., Section 4.2.1).

                  Personal air monitoring should be conducted where respirators are used to confirm that
         the level of respiratory protection is adequate (see Section IV.4.3.3.3.2.for more
         information about respiratory protection).

                  D&D operations at former beryllium facilities may result in unexpected exposures to
         beryllium.  Monitoring every worker for every shift is recommended but less monitoring
         may be appropriate under limited circumstances.  Both representative monitoring and
         reduced frequency of monitoring for specific operations may be appropriate once the
         operations and their controls are stable, and monitoring data demonstrate that exposure
         levels are stable and consistently below the OELs set by the site for these activities.  D&D
         operations tend to be highly variable so attaining consistently stable operations and
         controls may be rare.  As a minimum for each task or work group, daily personal air
         monitoring should be conducted where respirators are used to confirm that the level of
         respiratory protection is adequate.

                  Periodic personal air monitoring still may be necessary to validate that conditions have
         not changed even in situations where a beryllium hazard is present but there is no
         reasonable potential for beryllium exposure.  The exposure assessment plan should
         document how it was determined that there is no reasonable potential for exposure with
         that specific operation or process, and the rationale for the monitoring schedule that
         validates the presumption of no beryllium exposure.

                            3.3.2     Area Air Monitoring

                  Area air monitoring is used primarily as a diagnostic tool in characterizing sources of
         beryllium exposure, checking the effectiveness of beryllium control systems, making an
         initial determination of the level of respiratory protection needed,  and confirming
         acceptable air quality in general work areas.

                  Sample analysis should be conducted according to procedures in the NIOSH Methods
         7102 and 7300 (refs. IV.3.7 and IV.3.8) or equivalent. Comparability of equivalent
         methods should be documented.

                  Routine area air monitoring should be conducted at locations of all potential sources of
         airborne beryllium and in all areas that have the potential for containing airborne
         beryllium.

                  It is encouraged that area air monitoring be used periodically as a general beryllium air
         quality measure in both beryllium operations areas and in adjacent non-beryllium
         operations areas.  This type of monitoring may require high flow rates and/or long
         sampling times to achieve the sensitivity required.  Frequency and location of such air
         quality measurements should be identified in the facility's beryllium exposure assessment
         plan.

                  New, recently modified, or previously uncharacterized operations initially will require the
         most frequent area air monitoring.  Non-routine operations such as maintenance, repair,
         cleaning, reconfiguration, special projects, and D&D operations often require frequent
         area monitoring for the duration of the activity.  As a minimum for each task or work
         group, representative area air monitoring should be conducted to fully characterize
         potential sources of worker exposures.

                  Routine area air monitoring should focus on reducing exposure.  AWE, Cardiff, obtained
         area air samples at potential beryllium emission points and in general room air every
         shift.  They analyzed the samples and posted the results daily.  They discontinued
         operations and investigated the cause any time elevated levels were measured.  In
         addition, they identified a number of "core" samples taken at operations that were the
         most difficult to control.  AWE, Cardiff, collected and analyzed the core samples at the
         middle and end of each shift so that they could stop personal exposures from occurring
         within a few hours of when a release began.  (Consult Numbers 4, 6, and 9 of Appendix
         B for additional examples of area air monitoring frequency.)

                  DOE has developed Laser Induced Breakdown Spectroscopy (LIBS) as a new technology
         that will greatly enhance the ability to diagnose emissions from beryllium operations. 
         LIBS will provide results within minutes of when the sample was taken, which will allow
         pinpointing the specific tasks and locations that are responsible for the release of
         beryllium.  DOE plans to have LIBS commercially available.

                  Area air monitoring may be useful in conjunction with personal air monitoring when
         characterizing potential worker exposures.  When used to characterize potential worker
         exposures, area monitors should be placed along the expected path of the exposure where
         the beryllium concentration is expected to be equal to or greater than the worker's
         potential exposure.  When interpreting area air monitoring results, keep in mind the
         difficulty of anticipating the actual path of exposure and that area air monitoring may help
         to understand the source of potential exposures, but is not a substitute for personal air
         monitoring to determine actual exposures. 

                            3.3.3     Surface Monitoring

                  Surface monitoring is most often used to monitor the effectiveness of housekeeping
         efforts in a workplace and to help diagnose the sources of beryllium contamination.  The
         location and pattern of surface levels can help to pinpoint the source of airborne
         beryllium.  Beryllium contamination on surfaces may become resuspended and contribute
         to airborne levels if aggressively agitated.  

                  Facilities should strive to keep surfaces in the workplace at or below the levels of
         accumulations of beryllium dust that could become airborne that have been established in
         the site's CBDPP.  The appropriate use of surface monitoring should be covered in the
         beryllium exposure assessment plan.  The frequency of monitoring should be determined
         using a risk-based approach and can vary from occasional to every shift. Occasional
         monitoring may be adequate for activities that are not likely to increase surface
         contamination levels. Examples include activities conducted in administrative areas that
         are adjacent to, but not within, an active beryllium work area and small scale tasks that
         are conducted in ventilated enclosures. On the other hand, frequent monitoring may be
         appropriate for activities that have a high potential for increasing surface contamination
         levels. For example, both the AWE at Cardiff (Appendix B, Number 8) and the LANL
         Beryllium Technology Facility (Appendix B, Number 9) procedures call for surface
         monitoring every shift. Surface monitoring should be conducted according to procedures
         in the OSHA Technical Manual (ref. IV.3.6) or equivalent.  Appendix B, Numbers 4 and
         7 provide specific examples of surface monitoring methods.  Comparability of equivalent
         methods should be documented.

                  Sites should establish surface contamination administrative action levels that trigger
         control actions that get more aggressive as the levels increase.  See Section IV.4.3.2 for a
         discussion of administrative action levels.

                  Surface wipes are a useful tool for monitoring the effectiveness of housekeeping efforts
         or to help identify the presence of potential beryllium hazards, but they should not be
         used in an attempt to measure worker exposure or demonstrate regulatory compliance.

                  Surface wipes will not detect beryllium that is difficult to remove, sealed beneath paint,
         or imbedded in building materials.  Such beryllium that is not detectable by surface wipes
         could potentially become airborne during D&D or remodeling operations.  Methods
         suitable for difficult to remove beryllium should be used in addition to surface wipes
         when identifying potential beryllium hazards for operations that will involve demolition,
         resurfacing, remodeling, or other procedures that will significantly disturb structures or
         building materials.  Section 4.4.1 of DOE G 440.1-3 provides guidance in using other
         sources of information (such as worker interviews and records reviews) to identify
         locations where beryllium may be present on surfaces from prior beryllium activities.                        IV.3.  References

              IV.3.1        Environmental Protection Agency, "Guidelines for Exposure Assessment;
              Notice," Federal Register Vol. 57, No. 104, May 29, 1992

              IV.3.2        American Industrial Hygiene Association, "A Strategy for Occupational Exposure
              Assessment," 1991

              IV.3.3        Defense Programs Beryllium Good Practice Guide, University of California
              Publication Number UCRL-ID-127871, July 1997

              IV.3.4        NIOSH, Occupational Exposure Sampling Strategy Manual, DHEW (NIOSH)
              Publication Number 77-173, 1977

              IV.3.5        U.S. Department of Labor.  OSHA Field Inspection Reference Manual

              IV.3.6        U.S. Department of Labor. OSHA Technical Manual, Fourth Edition. 
              Washington, DC: Government Institutes, Inc. 1996

              IV.3.7        National Institute for Occupational Safety and Health.  NIOSH Manual of
              Analytical Methods.  Method 7102, "Beryllium and compounds, as Be," U.S
              Department of Health and Human Services/National Institute for Occupational
              Safety and Health.  Cincinnati, OH: 1987

              IV.3.8        National Institute for Occupational Safety and Health.  NIOSH Manual of
              Analytical Methods.  Method 7300, "Elements by ICP," U.S Department of
              Health and Human Services/ National Institute for Occupational Safety and
              Health.  Cincinnati, OH: 19874.       EXPOSURE REDUCTION AND MINIMIZATION

4.1      Exposure Reduction and Minimization Requirements

                  Appendix E contains specific citations from DOE O 440.1 and DOE N 440.1 that address
         implementation of a hazard prevention and abatement process to ensure that all identified
         hazards are managed through abatement or control.

4.2      General Implementing Guidance for Exposure Reduction and Minimization

                  Appendix E contains specific citations from guides and standards in the DOE directives
         system that address minimizing and reducing exposures.

4.3      Specific Implementing Guidance for Exposure Reduction and Minimization

                  Although OELs for chemicals in general are airborne concentrations to which nearly all
         workers may be repeatedly exposed without adverse effect, some workers will still
         experience discomfort or disease at airborne concentrations below these limits because of
         variations in individual susceptibility.  Some of these individuals may be
         hypersusceptible or unusually responsive for various reasons, such as genetic factors, age,
         and personal habits.  Consequently, OELs should be viewed as guidelines for good
         practice, and controls should be implemented to maintain airborne concentrations as low
         as practical.   This approach is recommended by the ACGIH, 1996 TLVs and Biological
         Exposure Indicies (ref. IV.4.10) and is the approach recommended for controlling
         beryllium exposures within DOE.  

                  Because information is not available to determine if individuals with positive Be-LPT
         results or CBD were exposed above the OEL or are hypersusceptible, it is prudent to
         control beryllium exposures at DOE sites to as low as practical using strategies of
         exposure reduction and minimization.  The objectives of an exposure control program
         based on exposure reduction and minimization are (see Appendix E for relevant
         citations):

                            reduce airborne levels of beryllium to levels that are as-low-as-practical,

                            minimize the number of current workers exposed and potentially exposed to
              beryllium,

                            minimize the number of opportunities to be exposed, and 

                            set reasonable exposure reduction and minimization goals using a risk-based
              (tailored) approach.

                  Sites can determine their reduction and minimization strategies to control their beryllium
         hazards after they have characterized their beryllium by conducting baseline inventory
         and sampling (Section IV.1), hazard assessment (Section IV.2), and exposure monitoring
         (Section IV.3).  Sites may wish to evaluate control strategies used for other hazards (e.g.,
         radiation and asbestos) for application to beryllium.  Also, sites may wish to determine
         the value of consolidating beryllium operations as much as possible.  Activities that are
         limited in number and not expected to generate airborne beryllium may be adequately
         addressed by implementing a few simple controls aimed at contamination control.  These
         controls, even if basic, should be formally adopted to ensure that the beryllium does not
         inadvertently become a more significant hazard at a later time.  Sources that may generate
         airborne beryllium sufficient to impact workers' health should be fully evaluated from a
         reduction/minimization standpoint to identify appropriate control strategies for preventing
         beryllium exposure.

                  Appendix B, Numbers 9, 13, and 14 provide examples of exposure reduction and
         minimization procedures used by LANL, RFETS, and AWE, Cardiff, U.K.

                  4.3.1     Goals, Plans, and Performance Measures

                  Goals should be established that represent a reasonable and practical effort to achieve
         exposure reduction and minimization.  Because exposure reduction and minimization
         strategies focus on reducing exposure levels, minimizing the number of exposures per
         worker, and minimizing the total number of exposed workers, it may be appropriate to
         establish goals based on these control strategies.  Goals may focus on each control
         strategy, or just one, depending on the types of activities and the current exposure levels. 
         For example, new facilities offer the opportunity to include cost-effective engineering
         controls that can achieve aggressive goals for the reduction or prevention of routine
         exposures.  For facilities or operations involving small or localized beryllium sources,
         goals for exposure minimization, rather than exposure reduction via engineering controls,
         would be graded to fit those unique circumstances.  Also, if exposure levels are below the
         site's administrative action level, further reduction may not be needed, and emphasis
         would be placed on minimization strategies.  Exposure reduction and minimization
         performance measures corresponding to the above goals should be established.  See
         Section III.4.5.1 for suggestions for exposure reduction and minimization goals and
         performance measures.

                  Once goals and performance measures have been established, it is important to follow
         through with an implementation plan that identifies the necessary steps in achieving the
         goals.  The implementation plan should establish accountability by identifying
         responsible organizations and setting due dates for completing actions.  Adherence to the
         plan should be monitored by management.

                  4.3.2     Administrative Action Levels

                  Administrative action levels are established as the levels at which controls are
         implemented or actions taken to prevent the occurrence of exposures above the OEL that
         has been established by the site.  For many substance-specific OSHA standards, the
         administrative action level is one-half the PEL.  Applying this approach to beryllium, the
         administrative action level would be 1 microgram/m3.  However, it is also possible and
         sometimes practical to set administrative action levels at exposures less than half of the
         PEL.  Many sites already have actions levels less than half the PEL.  For example,
         RFETS subcontractors follow administrative action levels of 0.2 and 0.5 microgram/m3 to
         initiate wearing respiratory protection.  These levels are below half of the PEL and reflect
         the risk-resource balance that they have determined for their different tasks.
         Administrative action levels may differ for differing conditions but the rationales used to
         determine these levels should be consistent and documented. DOE G 440.1-3, Section
         4.4.6.2, describes an approach for setting administrative action levels (called
         administrative control limits in DOE G 440.1-3).

                  Administrative action levels may also differ depending on the control strategy.  For
         example, one administrative action level may be used to initiate establishing a restricted-
         access area, while another may be used to initiate using PPE.  An administrative action
         level may also be used to trigger cleanup of surface contamination.  Sites should establish
         surface contamination levels that trigger control actions that get more aggressive as the
         levels increase.  These levels should be facility and operation specific and kept as low as
         is reasonable and practical.  At some sites, a surface contamination of 25 micrograms/ft2
         will initiate cleanup; other sites use 10 micrograms/ft2.  Reference IV.4.1 and Appendix
         B, Numbers 4, 7, 10 and 11, provide examples of recommended actions to take at various
         levels of surface contamination.  It is important to keep in mind when setting
         administrative action levels and interpreting the results of surface sampling that the
         sampling techniques (often referred to as surface wipes or swipes) are not standardized
         and are subject to a number of hard-to-control variables that could affect the results. 
         Although it is not possible to relate specific surface contamination levels to specific
         airborne levels, it is possible for surface contamination to become airborne if sufficiently
         agitated and result in exposures.  Establishing housekeeping administrative action levels
         will help control and minimize potential exposure to airborne beryllium that may be
         resuspended from surface contamination.  (See Section IV.3.3.3 for information on
         surface sampling.)

                  Administrative action levels should be selected to provide confidence that exposures are
         below the site's OEL and will meet site exposure reduction and minimization goals.  The
         rationales for selecting administrative action levels should be documented in the site-
         specific CBDPP.

                  4.3.3     Exposure and Contamination Controls

                  To determine appropriate controls for exposure reduction and minimization, a
         multidisciplinary team including line management, workers, maintenance, and worker
         protection and other support functions, who are familiar with beryllium operations,
         hazards, and control methods, should review existing engineering and administrative
         controls and PPE.  A typical review may include, but not be limited to, the following:

                            The general configuration of the facility and impacts of beryllium control
              strategies on operations; including traffic patterns, location of beryllium sources,
              need for changerooms, personnel, decontamination facilities, personnel
              monitoring, adequacy of space for proposed modifications, and the impact on
              maintenance, production, research, and decommissioning activities;

                            Verification that the design criteria are consistent with applicable regulations and
              reduction and minimization goals;

                            Verification that beryllium controls provide the required level of protection from
              airborne beryllium.  Any releases of beryllium to the workplace atmosphere
              should be avoided under normal operating conditions and inhalation by workers
              should be avoided to the greatest extent practical;

                            Evaluation and confirmation of the adequacy of specific control devices for
              reducing the opportunity for worker exposures, including local ventilation,
              containment systems, and PPE;

                            Verification that the facility design is able to maintain personnel entry control for
              each beryllium restricted-access area to prevent the spread of contamination, and
              that the design is commensurate with the existing or potential beryllium hazard
              within the restricted-access area; and

                            Assessment of the adequacy of the monitoring planned for activities and spaces
              that involve potential beryllium exposure to characterize worker exposures,
              provide measurements needed to implement the reduction and minimization
              control strategies, and identify elevated or unplanned beryllium exposures.

                  Planning efforts should incorporate exposure reduction and minimization strategies.  To
         ensure appropriate control strategies are selected for the planned activities, fundamental
         principles of enhanced work planning, or other similar collaborative planning process,
         should be followed.  At the completion of short-term beryllium activities such as
         maintenance, post-job reviews should be conducted to identify lessons learned and best
         practices to control beryllium exposures during future work.  Conduct of operations
         reviews that are conducted of long-term operations should include reviews of beryllium
         activities.

                  Much of the following information on controls has been obtained from the Defense
         Programs Beryllium Good Practice Guide (ref. IV.4.1).  Additional design specifications
         for controls at the LANL Beryllium Technology Facility are provided in Appendix B,
         Number 9.

                            4.3.3.1   Engineering Controls

                  Primary reliance should be placed on engineering controls for maintaining airborne
         concentrations below the administrative action level established in the site-specific
         CBDPP.  Engineering controls normally include local exhaust ventilation, gloveboxes,
         and other enclosures.  For non-routine operations, temporary enclosures such as
         glovebags or negative pressure enclosures (NPEs) can be used to control exposures and
         contamination.  Engineering controls also include wet methods for cutting, grinding,
         machining, sanding, or processing of solid beryllium.  Caution still must be exercised
         since any airborne contaminated liquid that is generated would be a potential source of
         exposure.

                            4.3.3.1.1 Ventilation

                  The design and air-flow specifications of local ventilation systems should be reviewed to
         ensure they at least meet the design criteria of the ACGIH's current "Industrial
         Ventilation, A Manual for Recommended Practice" (ref. IV.4.2).  Section 10.40 (Low-
         Volume/High Velocity Exhaust Systems) of this manual includes applications for
         beryllium operations.  Even better control of airborne beryllium can be obtained by using
         state-of-the-art ventilation systems such as the High-Volume/High Velocity Exhaust
         System and other systems that LANL will use for their new beryllium facility (see
         Appendix B, Number 9). Hood configuration and air-low rates are critical design features
         for adequate face or capture velocity.  Insufficient face velocity allows toxic materials to
         remain airborne around the hood and to be potentially drawn into the breathing zones of
         workers.  Hood designs need to be specific to the actual operation.  Exhaust from routine
         beryllium-processing operations that could produce airborne particulates should be vented
         to the environment through an approved high-efficiency particulate air (HEPA) filter. 
         Where air is removed from an area, make-up air must be supplied.  Make-up air systems
         should be constructed so they do not draw in contaminated exhaust air, create turbulence
         that disperses beryllium contamination, and do not contaminate the workspace with toxic
         or irritating materials originating from some other location. 

                  Ventilation systems should be evaluated periodically under actual operating conditions to
         ensure continued operation at design specifications.  For work areas that routinely process
         beryllium (i.e., at least monthly), visual indicators, audible alarms, telltale power lights,
         or flow indicators should be installed at appropriate work stations to show that the
         ventilation is operating properly.  Workers should perform daily operational checks of
         their engineering controls before beginning work.  These are initial tests to ensure that the
         systems are on and that air is circulating through them.  Ventilation systems should be
         scheduled for preventive maintenance. 

                  Engineering controls should also be checked after any change in work operations or
         equipment that might affect the controls to ensure that changes do not impair or
         overwhelm the system's efficacy and that all design specifications continue to be met. 
         Normal beryllium operations should not be resumed until the system is shown to be
         operating properly.

                  4.3.3.1.2 Glovebags and Negative Pressure Enclosures

                  For non-routine operations such as maintenance or D&D activities, temporary enclosures
         provide an adequate approach to controlling exposures and contamination.  Because
         exposure levels may be difficult to predict for non-routine activities, it is recommended
         that temporary enclosures be used when practical to keep exposures below the site-
         specific administrative action level.  Glovebags can provide a flexible, easily installed,
         and quickly removed temporary work enclosure ideal for small-scale maintenance or
         D&D activities.  When properly installed and used, glovebags permit workers to remain
         completely isolated from beryllium dust.  Glovebags with support frames can be used as
         NPEs when connected to a HEPA-filtered vacuum system.  Additional information on the
         use of glovebags can be found in 29 CFR 1926.1101 (ref. IV.4.3 ).  Although this
         standard is concerned with controlling exposures to asbestos, much of the information
         provided is directly applicable to controlling exposures to beryllium dust.

                  For larger scale maintenance and D&D activities, NPEs may be an appropriate control
         method for preventing contamination outside the enclosure.  This control method does
         not necessarily reduce exposures of workers within the NPE but exposures can be
         minimized within the enclosure by directing air movement away from the workers and
         toward a HEPA filtration system.  NPEs usually are constructed of 6-mil plastic and
         maintained under a negative pressure of at least 0.02 inch of water pressure differential,
         relative to outside pressure.  Additional information on NPEs can be found in 29 CFR
         1926.1101 (ref. IV.4.3 ).

                  4.3.3.2   Administrative Controls

                  Administrative controls can be an effective means for reducing and minimizing worker
         exposures to below the site-specific administrative action level.  Administrative controls
         involve changing work conditions or operations to lower exposure.  Examples of
         appropriate administrative controls include:

                            Establishing restricted-access areas;

                            Scheduling maintenance activities that generate airborne beryllium during times
              when most workers are elsewhere;

                            Arranging operations, schedules, or equipment such that fewer persons are
              potentially exposed, or persons are exposed for shorter periods or to lower
              concentrations of beryllium; 

                            Developing site-specific exposure reduction and minimization procedures; and

                            Posting warning signs.

                  Administrative control through worker rotation is not recommended because this practice
         does not minimize the number of workers exposed to beryllium.  Additionally, tours
         should not be permitted in areas where there is a potential for beryllium exposure above
         the site-specific administrative action levels.  Instead, alternative methods of viewing the
         activities and processes, such as closed-circuit TV, videotapes, or adjacent viewing rooms
         with windows, should be used. 

                            4.3.3.2.1 Restricted-access Areas

                  Beryllium restricted-access areas should be established for any location where there is
         airborne beryllium, a potential for airborne beryllium, or when there is a concern for the
         spread of beryllium contamination.  Restricted-access areas are established to limit the
         number of individuals exposed and potentially exposed, to provide formality of
         operations for personnel who enter the location, and to limit the spread of contamination
         to uncontrolled areas.

                  Because operations and activities with beryllium exposures vary throughout the complex,
         as well as at an individual site, a single type of restricted-access area would not be
         appropriate for all possible situations.  Restricted-access areas may vary from a simple
         barricade around the designated area with a small contamination reduction zone for
         doffing of contaminated PPE, to a facility where access is gained only through a change
         room.  An industrial hygienist should play a major role in determining whether an area
         needs to be classified as a restricted-access area, and the type of restricted-access area
         should be based on risk for exposure.

                  The controls necessary for a restricted-access area vary to reflect the actual or potential
         level of airborne concentration or surface contamination.  The basic restricted-access area
         should be demarcated from the rest of the workplace by appropriate physical barriers and
         signs.  There should be storage outside the area for clean PPE.  A contamination
         reduction zone should be established that has containers for booties, outer garments,
         respirators, and other equipment.  Temporary restricted-access areas are needed to cover
         maintenance, intermittent operations, or unforeseen situations.  For permanent activities
         where site-specific administrative action levels are likely to be exceeded, restricted-access
         areas should be wholly separate rooms maintained at a negative pressure with respect to
         adjacent areas to prevent the migration of contamination.  All potential sources of
         contamination need to be identified to ensure the integrity of the restricted-access area
         when moving people and items out of restricted-access areas. For example, it may be
         appropriate to assume that papers inside the beryllium area are contaminated. The AWE
         at Cardiff (Appendix B, Number 8), under this assumption, photocopied all papers on a
         machine at the area barrier. The copies came out of the clean side of the barrier, and the
         originals were retained in the beryllium area until disposed as beryllium waste. 
         Additional information on configurations of restricted-access areas can be found in 29
         CFR 1926.1101 (ref. IV.4.3).

                  A record of all individuals who enter restricted-access areas should be kept since entry
         indicates potential exposure.  (See Section IV.7.3.2 for more information about exposure
         control records).  Such a record ensures that employers are knowledgeable about all
         individuals who work in a restricted-access area and, in addition, serves to relate any
         health events to possible exposures.  Access records are particularly important when
         exposure monitoring results indicate an unforeseen elevated exposure had occurred.  The
         record might include the following information: 

                            Date and time that the restricted area was entered and left;

                            Location of the restricted area;

                            Names of workers;

                            PPE worn; and

                            Type of activity performed.  

                  4.3.3.2.2 Decontamination Facilities

                  For workers who work in restricted-access areas, provision of  decontamination facilities
         consisting of a change room where contaminated clothing is removed, a shower, and a
         clean room where workers may store and don street clothing is important.  The proximity
         of the decontamination facility to the restricted-access area depends on the beryllium
         hazards and local conditions.  The change room and clean room should be separate, and
         the change room should be maintained at negative pressure to the clean room.  If
         circumstances require, the restricted-access area or parts thereof may be used as the
         change room if it meets all the criteria in this section.

                  Workers should be required to shower after leaving a restricted-access area, but the
         location of the change room and shower, and how soon a shower is taken after leaving a
         restricted-access area depend on local conditions.  For example, change rooms may not
         necessarily be located adjacent to restricted-access areas.  Where operations are changing,
         of short-term duration, or of small scale and low hazard (site-specific administrative
         action level not likely to be exceeded), it is often impractical to have change rooms and
         showers adjacent to the operations.  However, it is important that soiled work clothing be
         removed in a change room that is separate from the room where street clothing is stored,
         and that this change room be maintained under negative pressure to all adjacent rooms
         outside the restricted-access areas.  In some cases, soiled overclothes and equipment may
         be removed in the restricted-access area, thus combining the change and restricted-access
         area if the restricted-access area meets the requirements of negative pressure with respect
         to surrounding areas and can be physically separated (i.e., enclosed with a door, etc.)  
         Conversely, where high-hazard (site-specific administrative action level likely to be
         exceeded) operations are involved, a contiguous decontamination facility is
         recommended.

         4.3.3.2.3 Personal Hygiene 

                  Although ingestion is not the primary occupational hazard of beryllium, good personal
         hygiene, including frequent hand washing, is necessary to control the spread of
         contamination and to control personal exposure to airborne beryllium.  Some restricted-
         access areas do not require personal hygiene facilities, whereas other areas will have the
         need for full showers, lockers for street clothing, and handwashing facilities.  The need is
         based on risk.  While personal exposure does have some role in the decision, in general
         the spread of contamination should be the basic factor for deciding when to require this
         type of rigor.  For instance, if one is concerned that personnel may take contamination
         home through contaminated hair, shoes, or undergarments, then shower facilities should
         be required.

                  Smoking, drinking, or eating should not be allowed in a beryllium restricted-access area. 
         Storing tobacco, beverages, and food in beryllium restricted-access areas should also be
         prohibited.

                  4.3.3.2.4 Warning Signs and Labels

                  Proper exposure control of beryllium requires that its presence be clearly identified to all
         who might possibly be exposed.  The purpose of the warning label is to ensure that all
         affected individuals, not only those previously identified as potentially exposed to
         beryllium, are appraised of the potential hazards of beryllium exposures.  The posting of
         signs serves as a warning to workers who may otherwise not know they are entering a
         restricted-access area where beryllium exposure may occur.  Restricted-access areas, as
         discussed above, may often exist on a temporary basis such as during maintenance, D&D
         operations, or in emergency situations.  The use of warning signs under these
         circumstances is of particular importance because a maintenance or D&D operation, or an
         emergency may present new or unexpected potential for exposure to workers who are
         regularly expected to conduct work unrelated to beryllium at these sites.  Distinctive
         warning signs for restricted-access areas where only authorized personnel are allowed
         access are recommended.  All restricted-access areas should be clearly identified with
         warning signs containing the following information:                              DANGER

                    BERYLLIUM DUST (or FUMES)

    Inhalation of Dust or Fumes May Cause Serious Chronic Lung
                              Disease

                     Potential Cancer Hazard

Contact                                               Prior To Entry

                   Authorized Personnel Only 
                                
                                
                                
                                
                                
                                
                                
                                
                                
     All containers of beryllium, beryllium compounds, beryllium parts, or beryllium-
contaminated clothing, waste, scrap, or debris should have a prominent warning label. 
These provisions should conform to OSHA's Hazard Communication Standard
(29 CFR 1910.1200) (ref. IV.4.4).  The warning may convey the following information:
                                
                           BERYLLIUM
                       (Name of Compound)
                                
                             DANGER
                                
             Inhalation of Dust or Fumes May Cause
                  Serious Chronic Lung Disease
                                
                    Potential Cancer Hazard
                                
 Use Only with Adequate Local Exhaust Ventilation or approved 
          Respiratory and Personal Protective Devices
                                
                May Cause Ulcers on Open Wounds
                                
                 Wash Thoroughly After Handling
                                  Equipment with beryllium contamination or potential contamination should also be
labeled.  All equipment inside a permanent beryllium restricted area may not need to be
labeled until the item is removed from the area.  Examples of labels include:
                                
                                
                            CAUTION
                                
                    Beryllium Contamination
                                
             Inhalation of Dust or Fumes May Cause 
                  Serious Chronic Lung Disease
                                
    This equipment was known to have been used for beryllium operations, and may
  be internally contaminated.  If the internal compartments of this equipment are
  breached, workers must be protected in accordance with applicable OSHA
  standards.  Surveys were performed to determine levels of external surface
  contamination.  Survey results are packaged with the equipment.

                                
                            CAUTION
                                
                Possible Beryllium Contamination
                                
             Inhalation of Dust or Fumes May Cause 
                  Serious Chronic Lung Disease
                                
    This equipment was in a building where beryllium manufacturing operations were
  performed.  This equipment was not used in beryllium operations but may be
  internally contaminated.  If the internal compartments of this equipment are
  breached, workers must be protected in accordance with applicable OSHA
  standards.  Surveys were performed to determine the presence of external surface
  contamination.  Survey results are packaged with the equipment.
              Detailed specifications for warning signs and labels, such as size, color, or other physical
  attributes, should conform to the requirements of 29 CFR 1910.145 (ref. IV.4.5).  It is the
  responsibility of the contractor to design, produce, and use signs and labels of appropriate
  size, color, contrast, and the like, so that warning signs are easily visible to the workers. 
  Emphasis is on visibility and effectiveness in informing workers of beryllium's potential
  to cause serious disease.

  4.3.3.2.5 Industrial Hygiene Procedures

    Site-specific industrial hygiene procedures are another example of an administrative
  control for the protection of workers from the hazards of beryllium.  All beryllium
  processes and activities that are capable of generating airborne beryllium should have a
  site-specific industrial hygiene procedure to address the hazards and identify appropriate
  controls.  Examples of such processes are cutting, machining, welding, maintenance, and
  D&D activities.  For non-routine work, an industrial hygienist familiar with beryllium
  controls should participate in the planning phase and review all work control documents
  to ensure minimization of exposure levels.

  4.3.3.2.6 Work Practices

    Procedures should ensure housekeeping practices are performed regularly and thoroughly
  to reduce beryllium contamination to the extent practical.  All surfaces should be
  maintained at or below the site-specific administrative action levels that have been
  established for accumulations of beryllium dust that could become airborne.  Following
  this practice will minimize the amount of beryllium dust that may be entrained into the air
  (and the worker's breathing zone) from contaminated surfaces such as floors, work
  surfaces, ventilation system components, equipment and furnishings, windows and
  window sills, doors and door frames, rafters, and other supporting structures.  

    Cleaning methods should minimize the generation of airborne beryllium dust.  In contrast
  to dry cleaning methods such as dusting and dry sweeping, wet cleaning methods are
  likely to capture and retain beryllium particles before they can be dispersed into the air
  from dusty surfaces.  Floors and other surfaces should be cleaned using HEPA vacuum
  cleaning, wet cleaning, or both.  Acceptable methods of wet cleaning include the use of
  low-pressure water mists (rather than high-pressure streams that will disperse beryllium
  particles), mobile wet scrubber units, wet floor mops, and wet wipes, sponges, and cloths. 

    Beryllium-contaminated dust and debris collected by portable or mobile vacuum systems
  should not be released into the workplace atmosphere.  Either dedicated central vacuum
  cleaners or HEPA-type portable vacuum cleaners should be the only types used in the
  cleanup of beryllium.  The same dedicated system may be used for beryllium and other
  toxic contaminants as long as all hazards are considered in the maintenance of the system
  and disposal of contaminated filters.  Vacuuming systems should be equipped with HEPA
  filters because these filters have a high degree of capture efficiency for particulates. 
  Periodic monitoring should be conducted to demonstrate the efficacy of the filters. 
  Dedicated central vacuuming systems that discharge outside after filtration will normally
  be permitted by the local authority for enforcement of the Clean Air Act.  The filtration
  system and maintenance schedule may be specified by the local authority in the permit.

    Filter maintenance is critical for vacuum systems.  Partially or completely blocked filters
  can substantially compromise system function.  HEPA filters on portable or mobile
  vacuum units should be changed as often as necessary to maintain the design flow rate. 
  To ensure this, periodic maintenance of portable HEPA filter vacuum cleaners should be
  required.  It is recommended that such maintenance be conducted on fixed systems as
  well.  Such maintenance normally includes pressure drop testing to determine when a
  filter is clogged and needs to be cleaned or replaced, and aerosol penetration testing to
  determine that no leaks have developed in the HEPA filters.  Aerosol penetration testing
  of HEPA filters is also normally done when a new filter is installed to ensure that the unit
  is correctly positioned and dust is not leaking around the filter.  Filter testing and
  maintenance personnel should be considered for inclusion in the CBDPP.

    Mobile or portable vacuum units used in beryllium work areas should not be used in
  workplace areas that are not identified as potentially contaminated with toxic material. 
  Cleaning equipment used in restricted-access areas should not be used in non-restricted
  areas.  This prevents equipment such as vacuum cleaners from being emptied or handled
  outside of beryllium restricted-access areas; such equipment is often a major source of
  beryllium-contaminated dust and debris.  Adequate facilities should be available to
  prevent personnel exposure and dust dispersion during emptying of vacuum cleaners and
  changing of HEPA filters.  Mobile or portable vacuum cleaners used in a beryllium
  operation should be labeled accordingly.  The maintenance personnel should be included
  in the CBDPP.

    Dry methods of cleaning should be prohibited; these methods entrain previously settled
  dust into the workplace air, where it may subsequently enter the workers' breathing
  zones.  Examples of prohibited dry cleaning methods include shoveling, sweeping, or
  brushing.  The use of these methods is acceptable only in completely closed systems such
  as a glovebox.  Another prohibited work practice includes the use of compressed air to
  remove dust containing particles of beryllium unless the compressed air is used in
  conjunction with an enclosed ventilation system designed to capture the disturbed dust.

    When a spill has occurred and it is possible to transport the beryllium-contaminated item,
  it is best to determine if it would be preferable to conduct the cleanup where the spill has
  occurred, or to isolate and transport the item to another site for decontamination.  Reasons
  to transport the item may include lower risk to workers performing the cleanup or better
  technology resulting in a more effective cleanup process.

    4.3.3.3 Personal Protective Equipment

    4.3.3.3.1 Protective Clothing

    The use of protective clothing for beryllium operations should be specified in the site-
  specific CBDPP and industrial hygiene procedures.  Employers should provide protective
  clothing for all workers working in areas where they may be exposed to airborne
  beryllium and who enter areas where there is a potential of surface contamination.  The
  type and variety of protective clothing (e.g., coveralls, lab coats, or shoe covers) should
  be based on the work conditions and expected contamination levels.  Typically, a lab
  coat, gloves, and booties are the minimum protection needed.  Gloves should be worn by
  workers who may get high levels of contamination on their hands so that the gloves can
  be removed close to the point of use rather than allowing the hands to spread
  contamination.  Open wounds must be sealed because beryllium contamination causes
  ulcers which seriously aggravate the wound (see Appendix B, Number 8 for information
  about a beryllium contaminated wound that occurred at the U.K. Cardiff facility). 
  Impermeable gloves should be worn when working with soluble forms of beryllium to
  avoid skin contamination.  Upon leaving the restricted-access area, workers should
  remove protective clothing and discard it as hazardous waste or segregate it with other
  beryllium-contaminated clothing.  Workers should carefully remove and place soiled
  clothing in laundry containers to avoid generating airborne beryllium and unnecessarily
  contaminating the change room with the beryllium-bearing dust on the clothing. 
  Beryllium-contaminated clothing should be appropriately labeled.

    Clean protective clothing should be provided at least daily.  Employers may choose 
  reusable or disposable clothing.  Each choice has its benefits and drawbacks.  Reusable
  clothing is more comfortable to wear but presents the problem of potential exposure of
  laundry personnel. Laundry containers should have lids that automatically close behind
  the deposited clothing.  Additional protective equipment (face-shields, goggles, gloves,
  etc.) may be required when the danger of skin or eye exposure to soluble forms of
  beryllium exists. Laundry bags are available that dissolve during the washing process so
  that laundry workers can avoid the potential exposure that could result from opening the
  bags and handling the contaminated clothing. Laundry operation workers should be
  included in the CBDPP. Contractors who provide laundry services should be notified of
  the beryllium contamination, the hazards associated with the contamination, and
  appropriate protective measures related to beryllium exposure.

    4.3.3.3.2 Respiratory Protection

    When employers have implemented all practical engineering and administrative controls
  and the site-specific administrative action level continues to be exceeded, the employer
  must implement a respiratory protection program in accordance with DOE O 440.1,
  which references OSHA's respirator standards, 29 CFR 1910.134 (ref. IV.4.6) and 29
  CFR 1926.103 (ref. IV.4.7), as well as ANSI Z88.2, Practices for Respiratory Protection
  (ref. IV.4.8).  Contractors may elect to use more stringent requirements when
  implementing a respiratory protection program.  Additional information on respiratory
  protection can be obtained from the AIHA Manual, Respiratory Protection: A Manual and
  Guideline (ref. IV.4.9).

    ANSI Z88.2, Practices for Respiratory Protection (ref. IV.4.8) provides protection
  factors in section 4.5.4 (Table 1 - Assigned Protection Factors).  The actual protection
  provided by respirators may vary from this table for individuals depending on the fit of
  the respirator and the conditions of use. Respirators accepted for use at higher
  concentrations may be used at lower concentrations; respirators must not, however, be
  used at concentrations higher then those for which they are approved.  Full-facepiece
  respirators should be worn during the operations where airborne soluble forms of
  beryllium have the potential to cause irritation to eyes or skin. 

    Respirator protection factor technology and standards are undergoing major changes at
  this time.  NIOSH, in 1995, replaced the Mine Safety and Health Administration
  regulations at 30 CFR 11 with NIOSH regulations at 42 CFR 84.  This action included a
  revision to their respirator certification standards.  NIOSH's significant revisions were for
  their non-powered particulate filter standards and the designations of these filters.  For
  example, filters formally designated as High Efficiency Particulate Air filters now are
  designated as N-100, R-100, or P-100 (N = not resistant to degradation by oil, R =
  resistant to degradation by oil, and P = most resistant to degradation by oil).  See web site
  http://www.cdc.gov/niosh/pt84abs2.html for a summary or 42 CFR 84 for details.  OSHA,
  on January 8, 1998, promulgated a revised respiratory protection standard.  OSHA
  reserved section 29 CFR 1910.134(d)(3)(A) for assignment of protection factors. 
  OSHA's new protection factors may supercede the factors in the ANSI Z88.2 table.  Site
  CBDPPs regularly should be updated to reflect these changes in respirator protection
  factor technology and standards.

            4.3.3.4 Waste Management

    A waste management program designed to minimize the generation of beryllium waste
  should be implemented.  Because beryllium waste may or may not be interpreted to be a
  hazardous waste under the Resource Conservation and Recovery Act (RCRA), and
  discharges to air and water may require permits, each site should involve environmental
  personnel who are familiar with applicable regulations in establishing the beryllium waste
  management program.  Certainly it is necessary to dispose of beryllium-contaminated
  waste in such a manner as to ensure both that workers are not additionally exposed to
  airborne beryllium generated by the handling of such wastes, and that downstream
  handlers of waste are also protected.  The activities of containment and labeling of
  beryllium waste should be considered a beryllium activity and included in the CBDPP.

    In some situations, disposing of beryllium-contaminated items may be more protective of
  workers than performing cleanup operations prior to disposal.  In such a situation, worker
  protection should have a higher priority than waste minimization programs. 

    Release or disposal of equipment or materials used for beryllium operations or used in
  beryllium areas needs to be reviewed with regard to the intended end use to minimize
  exposure and potential exposure to beryllium by the subsequent users.

    Documents transferring ownership of items with actual or potential beryllium
  contamination should inform the new owner or user of the contamination, steps taken or
  not taken to clean both internal and external surfaces, surface contamination levels,
  hazards associated with beryllium exposure, and appropriate protective measures related
  to beryllium exposure.  

    The AWE at Cardiff  (Appendix B, Number 8) has established three release criteria,
  depending on the end use.  For items that will be disposed of in a landfill, the accessible
  surfaces are cleaned before disposal.  For items released to the Aldermaston facility,
  accessible surfaces were cleaned to 5 micrograms/ft2.  For items released for other uses
  within the Cardiff facility, accessible surfaces are cleaned to 1 microgram/ft2.
                          IV.4.  References

          IV.4.1    Defense Programs Beryllium Good Practice Guide, University of California
          Publication Number UCRL-ID-127871, July 1997 

          IV.4.2    American Conference of Governmental Industrial Hygienists.  Industrial
          Ventilation, A Manual for Recommended Practice, 22nd  Edition, 1995

          IV.4.3    Title 29 CFR Part 1926.1101 (Asbestos), October 11, 1994

          IV.4.4    Title 29 CFR Part 1910.1200 (Hazard Communication), March 11, 1994

          IV.4.5    Title 29 CFR Part 1910.145 (Specifications for Accident Prevention Signs and
          Tags), September 19, 1986

          IV.4.6    Title 29 CFR Part 1910.134 (Respiratory Protection), latest revision

          IV.4.7    Title 29 CFR Part 1926.103 (Respiratory Protection), March 7, 1996

          IV.4.8    American National Standard Institute.  American National Standard Practices for
          Respiratory Protection, Z88.2

          IV.4.9    American Industrial Hygiene Association.  Respiratory Protection: A Manual and
          Guideline, 2nd Edition, 1991

          IV.4.10   American Conference of Governmental Industrial Hygienists.  Threshold Limit
          Values for Chemical Substances and Physical Agents Biological Exposure
          Indices, latest edition5.   MEDICAL SURVEILLANCE

5.1  Occupational Medicine Requirements

    See Appendix E for medical surveillance requirements and additional information on
  medical surveillance and coordination with industrial hygiene that is relevant to the
  CBDPP.

5.2  General Implementing Guidance for Medical Surveillance

    Medical surveillance should be offered to all current workers at risk for CBD due to
  either current or past exposures (see Appendix A, Section 2.3 for a discussion of
  beryllium exposure groups).  Table 1 provides a recommended schedule of medical
  surveillance.  At most sites, records identify some workers known to have been exposed
  to beryllium.  In the past, however, incidentally exposed workers were often not
  considered to be at risk for CBD and were not included.  If records are known to be
  incomplete, workers should be given an opportunity to self-identify as having been
  exposed to beryllium in the past.  At some sites, beryllium projects had a limited duration,
  and when asked, some workers may recall that they worked on those projects rather than
  that they worked with beryllium.

     Table 1.  Recommended Schedule of Medical Surveillance
                                
                                
                            Complete
                          Medical and
                          Occupational
                            History
                            Physical
                          Examination
                            Chest x-
                              ray
                           (Postero-
                            anterior
                             view)
                           Spirometry
                           Blood Be-
                              LPT
                                
                                
                          Preplacement
                              ND1
Include
emphasis on
prior
respiratory
disease
                               ND
                                D2
Offered if
spirometry
and history
warrant
                               ND
                                D
Offered if
history of 
exposure to
Be

Periodic
(1-3 yrs)
                                ND
Updated
                                ND
Directed
(Lungs and
Skin)
                                D
Offered
only if
medically
indicated
                               ND
                                D
Offered as
voluntary

Termination
or
Transfer
                                ND
Updated
                                ND
Directed
(Lungs and
Skin)
                                D
Offered
only if
medically
indicated
                               ND
                               D
                           Offered as
                           voluntary
                                

  1 ND = Non-discretionary component of surveillance.
  2 D = Discretionary component of surveillance to allow individual decisions on the risk versus benefits and
  because surveillance can be conducted without this procedure.

    Medical surveillance using traditional screening tests has proven ineffective in detecting
  CBD in its early stages.  The Be-LPT demonstrates immune system sensitivity to
  beryllium, which is usually a pre-indicator of CBD.  Many sensitized individuals, as
  identified by positive results on the Be-LPT, have developed CBD at a future date.

    Participants should be offered other screening tests considered appropriate by a qualified
  occupational medicine physician.  Spirometry and respiratory medical histories are
  recommended as part of preplacement examination to rule out other lung diseases and to
  establish a baseline.  If the result of spirometry and the medical history justifies the
  provision of a chest x-ray, it should be offered by the physician on a voluntary basis.  A
  standardized questionnaire is often used as part of periodic examinations to elicit signs or
  symptoms of respiratory disease.  

    Workers with signs or symptoms of CBD are usually referred to an occupational
  medicine or pulmonary medicine clinic familiar with CBD and the protocols for
  establishing a diagnosis.  The reports on diagnoses provide health effects information. 
  The medical surveillance program should include periodic and systematic review and
  analysis of beryllium worker health and exposure data, with the aim of providing early
  recognition of work-related health effects.  The program should periodically present
  summary data on the incidence of CBD and sensitization by risk factor (such as tasks and
  location where exposure occurred, job title, and exposure level).  The goal is to provide
  workers and managers a better understanding of the risks associated with beryllium
  operations so that they can take actions to improve health protection programs when
  needed.

    All beryllium workers and employees who have been exposed to beryllium incidentally in
  the past (incidentally exposed workers) should be included in the occupational medicine
  surveillance program.  (See Appendix A, Section 2.3, for a discussion of exposed and
  incidentally exposed workers.)

5.3  Specific Implementing Guidance for Occupational Medicine Monitoring

    The disability associated with CBD should be minimized through early detection of the
  disease.  Current workers sensitized to beryllium or diagnosed with CBD should be
  offered placement to maintain employment, and be assured of continued screening.  DOE
  G 440.1-7 further on in this section provides information on various screening tests to
  assist in the diagnosis of CBD, including the Be-LPT, and spirometry. Although DOE
  currently funds medical surveillance programs, state workers' compensation programs
  provide benefits to workers who need medical treatment as a result of CBD. It is
  important to involve Contractor Benefits Administrators and Loss Control Managers in
  developing a CBDPP to assure that benefit programs address unique CBD issues.

    Much of the following information has been adapted from the Defense Programs
  Beryllium Good Practice Guide (ref. IV.5.1).  Also, the BWI Medical Surveillance
  Program (Appendix B, Number 12) provides useful information on specific tests and
  procedures to follow on current workers who work, or have worked, in facilities where
  the potential exists for exposure to environments with air levels of beryllium greater than
  0.1 microgram/m3.  BWI also provides specific medical protocols to follow for former
  employees who think they may have CBD as well as employees and former employees
  who have sub-clinical and clinical CBD.

    Medical surveillance should be conducted on a periodic basis of at least 1 to 3 years, with
  a preplacement and a termination or transfer examination.  Medical evaluations are
  recommended a minimum of every 3 years because of the delay between first exposure
  and first indication of disease.  Frequent medical examinations ensure less concern about
  false negatives, particularly when diagnosing CBD in the very early stages.  Medical
  surveillance should be offered to persons who have had only brief exposure to beryllium
  levels that were presumed minimal because there is insufficient information to know for
  certain that these individuals did not have a brief high-level exposure that went
  undetected, and the possibility exists that some of these individuals are highly sensitive to
  beryllium and may develop CBD.  An exposed worker with any pulmonary symptoms
  should be evaluated immediately.  Termination or transfer examinations will document
  the occupational health status of workers, and should be used to remind them of signs and
  symptoms that they and their private physician should look for that warrant future
  medical evaluation for CBD.

    Medical examinations should include:

          complete medical and occupational history with special focus on history of
     respiratory disease;

          physical examination;

          spirometry;

          Chest x-ray may be offered if medically justified and approved by the
     occupational medicine physician on review of lung function tests or relevant
     medical history.  Chest x-rays also are useful in documenting the absence of other
     diseases.  

          The pulmonary function testing should include, as a minimum, the forced vital
     capacity (FVC) and the forced expiratory volume (FEV) at one second.  These
     tests can show other pulmonary disease and, along with a chest x-ray, are
     important as a baseline.

          Be-LPT.

              Be-LPT should be offered to known or self-identified current beryllium
       workers and incidentally exposed workers (see Appendix A, Section 2.3
       for a description of these workers).

              The Be-LPT is being used as a diagnostic test, as a screening test, and as a
       surveillance tool.  The in vitro proliferation of beryllium-exposed
       lymphocytes has been shown to be an indicator of CBD.  A positive Be-
       LPT in lung lymphocytes combined with granuloma is considered to
       provide definitive support for a diagnosis of CBD (see Appendix A,
       Section 2.2 for CBD diagnostic criteria).  A positive Be-LPT in peripheral
       blood lymphocytes indicates sensitization and may be an early sign of
       CBD.  The incidence of positive peripheral blood Be-LPT results in
       exposed workers is considered to be an indicator of the occupational
       health impacts of beryllium operations and a method for identifying
       populations at risk for CBD.  

              Individuals' participation in Be-LPT screening for CBD should be
       voluntary.  In addition, workers should understand that the Be-LPT can
       produce false positive and false negative results.  Occupational medicine
       physicians are encouraged to make recommendations on participation
       within the context of the individual's overall health, employment, and life
       situation after discussing all these issues with the worker.  Be-LPT
       screening should be offered every 1-3 years to those workers who choose
       to participate.                       IV.5.  References 

          IV.5.1    Defense Programs Beryllium Good Practice Guide, University of California
          Publication Number UCRL-ID-127871, July 1997.
     6.   TRAINING

6.1  Training Requirements

    Appendix E contains specific citations from DOE O 440.1 and DOE N 440.1 that address
  training requirements.

6.2  General Implementing Guidance for Training

    Appendix E contains a specific citation from DOE G 440.1-1 pertaining to training. 

     6.3  Specific Implementing Guidance for Training

    Personnel who work directly with beryllium need to receive training specific to beryllium
  and the activities they perform.  In addition to these workers, others who require training
  specific to their duties and risks for beryllium exposure include workers working in areas
  adjacent to beryllium restricted-access areas, maintenance and waste workers, laundry
  staff, emergency responders, procurement staff, planners, industrial hygiene and medical
  personal, visitors, line supervisors, and management.  For sites with widespread beryllium
  activities, it may be appropriate to provide training to all workers.  Industrial hygienists
  with key CBDPP responsibilities should be qualified as described in section III.4.8.
          
    Because not all of the above groups require the same level of training, a graded approach
  should be implemented.  The highest level of training would be provided to workers with
  beryllium exposures and potential exposures, including maintenance workers, waste
  workers, laundry staff, and industrial hygienists.  The lowest level of training would be
  provided to site workers not involved in beryllium activities.  For these workers, a brief
  discussion during General Employee Training (awareness training) of basic information
  about beryllium, the beryllium activities performed at the site, and familiarization with
  warning signs may be sufficient.  A training matrix with suggested topics for the various
  groups is provided in Appendix C.  All training should meet the requirements of 29 CFR
  1910.1200 (ref. IV.6.1) and be presented by trainers who are technically qualified.  A list
  of training resource materials is included in Appendix D. 
          
    Workers with actual and potential beryllium exposures should receive periodic training.
  A mentor program would be beneficial in the training of new workers who have actual
  and potential beryllium exposures. This training should provide information pertinent to
  the potential for beryllium exposure of their positions, and focus on lessons learned at the
  site to help reduce and minimize exposures.  The periodic training should provide new
  information, trends, recent events, etc., and not be merely a repeat of the initial training. 
  How often training is provided should be determined using a risk-based approach. 
  Examples of when more frequent training would be required include when the risk for
  exceeding an administrative action level is high, the effectiveness of exposure reduction
  and minimization strategies is marginal or not proven, and activities and processes are
  highly variable.
                         IV.6  References

          IV.6.1    Title 29 CFR Part 1910.1200 (Hazard Communication), March 11, 1994.     7.   RECORDKEEPING

     7.1  Recordkeeping Requirements

    See Appendix E for recordkeeping requirements relevant to the CBDPP.

     7.2  General Implementing Guidance for Recordkeeping

    Accurate and retrievable records are essential to the assessment of the adequacy of 
  worker protection programs. All information that supports assessments of the compliance
  with OELs, the acceptability of exposures, the adequacy of exposure controls, and health
  effects due to exposure should be kept. Sites should link exposure data to the identity of
  exposed individuals to support communication of exposure information to workers and
  creation of an historical record that can be combined with medical surveillance data for
  epidemiologic analysis.  Records of beryllium inventory, hazard assessment, medical
  surveillance, and exposure monitoring provide the basis for decisions on the
  implementation of an effective and efficient CBDPP. 

    Sites should take advantage of existing records systems for use by the site-specific
  CBDPP.  Records kept for personnel, work control, and cost accounting often contain
  information relevant to a site's CBDPP.  Multidisciplinary teams representing line
  management, workers, maintenance, and worker protection and other support functions
  such as personnel and accounting, should collaborate on the content and format of the
  records that each function needs and can provide.  The ultimate objective is an efficient
  sitewide system, or linked systems, that minimize the resources needed for upkeep and
  maximize the ease of entry to, access to, and usefulness of the records.

     7.3  Specific Implementing Guidance for Recordkeeping

            7.3.1   Program Records

    Records of all aspects of the site-specific CBDPP addressed in Sections III.1, III.4.1,
  III.4.2, and III.4.5 should be documented.  Reduction and minimization documents: 
  CBDPP policies, goals, implementation strategies, plans and schedules; job-specific
  plans; beryllium specific training; OELs and administrative action levels; lessons learned;
  and good practices are particularly important records to maintain.

            7.3.2   Exposure and Medical Records

    The data needed to answer frequently asked questions should be kept in an electronic
  format for easy retrieval.  These should include:

          Baseline hazard information: beryllium and beryllium contamination inventory,
     facility and process descriptions including diagrams, cost codes that link workers
     to tasks that involve beryllium, and building and room numbers identified as
     having the presence or potential presence of beryllium.  Include the strategy used
     in determining that the baseline is comprehensive and explanations of why the
     spaces and processes not shown in the baseline are unlikely to contain beryllium
     hazards. 

          Exposure group information: personal identifiers, job, task, and location, whether
     the worker is current or former, whether the worker has had known exposures or
     potential incidental exposures, and other information that can be used to link
     beryllium exposure information to individuals and medical records.

          Records of individuals who enter restricted-access areas, since entry indicates
     potential exposure and can link workers to unexpected elevated exposures that are
     identified later when routine monitoring results are available.  Records should
     include name, date, time entered and left, location, activities performed in the area
     location, and PPE worn.

          Hazard assessment and industrial hygiene reports:  methods, assumptions,
     conclusions, and recommendations.

          Medical records:  diagnoses and clinical results linked to exposure and work
     history data and exposure groups. 

          Exposure monitoring:  dates, locations, and chemical and physical characteristics
     of beryllium contaminants; methods; results; the type of respiratory protective
     equipment worn; the identity of workers monitored; and links to exposure groups,
     if appropriate.  Records should indicate whether the purpose of the sample was to
     characterize personal exposure or characterize a process.

          Types of control methods in use including design and measured levels of control.

          Investigative reports of significant accidental releases. 

          Worker concerns and occurrence reports that indicate breaches in the worker
     protection program.

    The physician responsible for medical services should outline procedures for the creation
  and maintenance of a medical record for each worker who is identified as exposed or 
  potentially exposed to airborne beryllium.  These medical records should be easily
  retrievable and protected against loss or destruction.  

    Employers are required to maintain medical monitoring records for all workers who are
  subject to the beryllium medical surveillance program (see Appendix E).  Medical
  surveillance records should be retained permanently.  Medical records should include the
  following:

          copies of the attending physician's written reports;

          a copy of the worker's occupational medicine history;

          results of all medical tests including additional tests recommended by the
     physician;

          a description of any worker medical complaints which may be related to beryllium
     exposure; and 

          original x-ray films.

    Cases of CBD are required to be investigated and reported in accordance with
  DOE O 231.1.  One goal of this investigation report is to create CBD case descriptions
  that can be grouped for analysis.  The narrative portion of the investigation reports should
  include:  (1) a work history collected through a review of personnel records and an
  interview; (2) a summary of exposure records, which should include descriptive statistics
  such as range, mean, standard deviation, or alternatively, percent exceedance of detection
  limits and OELs; and (3) a characterization of the clinical stage of the disease such as
  alveolitus, granuloma, or fibrosis and whether treatment has been prescribed.       8.   PERFORMANCE FEEDBACK

     8.1  Performance Feedback Requirements

    See Appendix E for performance feedback requirements relevant to the CBDPP.

     8.2  General Implementing Guidance for Performance Feedback

    Performance measurement to provide feedback is important to the management of safety
  and health risks.  One of the principles stated in the DOE ISM guide is  "Responsibility
  and accountability are demonstrated through performance measures and indicators
  specified in contracts."  Feedback is one of ISM's five core safety functions.

    Performance measures can be selected to determine progress toward achieving the site-
  specific CBDPP goals discussed in Section III.4.5.  Performance measures provide
  information that helps with understanding, managing, and improving program
  implementation as well as demonstrating performance to external customers and
  stakeholders.  A performance measure is a quantitative or qualitative characteristic of
  performance, usually consisting of a number, a unit of measure, and a time period. 

    DOE has published DOE O 210.1, "Performance Indicators and Analysis of Operations
  Information," and G 120.1-5, "Guidelines for Performance Measurement," which indicate
  the following reasons for measuring performance:

          Performance measurement improves the management and delivery of products
     and services;

          Performance measurement improves communications internally among workers,
     as well as externally between the organization and its customers and stakeholders;

          Performance measurement helps justify programs and their costs;

          Performance measurement demonstrates the accountability of Federal stewardship
     of taxpayer resources; and

          Performance measurement is mandated by the Government Performance and
     Results Act of 1993 and is central to other legislation and administration
     initiatives.

    Examples of uses of performance measures that provide management with mechanisms
  by which to proactively manage and continually improve their site-specific CBDPP are:

          Targeting activities and processes requiring additional control strategies,

          Identifying activities and processes with higher risk for causing CBD,

          Identifying workers actually or potentially exposed to beryllium who require
     medical surveillance,

          Evaluating the effectiveness of job-specific training programs, and 

          Determining the need for additional monitoring.
    

    
     8.3  Specific Implementing Guidance for Performance Feedback

    8.3.1   Outcome Measures

    Outcome measures are an assessment of the results of a program activity or effort
  compared to its intended purpose. Possible outcome measures include:

          Exposure level measures such as arithmetic means or percent exceeding OELs,
     administrative action limits, or detection limits,

          Incidence of CBD and beryllium sensitization,

          Number of workers potentially exposed,

          Percent of surface wipe samples exceeding administrative action limits, and

          Results of analyses of occurrence reports.

    8.3.2   Output Measures 

    Output measures are the tabulation, calculation, or recording of an activity or effort and
  can be expressed in a quantitative or qualitative manner. Output measures that are
  potentially useful in managing the implementation of a site-specific CBDPP include: 

          Percent of hazard assessments completed per month,

          Percent of beryllium workers participating in scheduled medical surveillance per
     month,

          Percent of beryllium workers completing scheduled hazard communication
     training per month,

          Percent of site workers completing scheduled general employee beryllium
     awareness training per month,

              Percent of the site's facilities that have completed baseline inventories and
       sampling per month, and 

              Percent of beryllium workers who received personal monitoring that were targeted
       for this monitoring in the site's CBDPP.

              8.3.3     Surveillance 

    Surveillance is closely related to performance measurement but includes analyses with
  the goal of identifying potential problems where intervention can improve performance. 
  The following definition is from the Council of State and Territorial Epidemiologists. 

              "Surveillance is the ongoing, systematic collection, analysis, and interpretation of
       health data essential to the planning, implementation, and evaluation of public
       health practice, closely integrated with the timely dissemination of these data to
       those who need to know. The final link in the surveillance chain is the application
       of these data to prevention and control."

    Medical surveillance analyzes health and clinical data for higher than expected incidence
  or sentinel events, such as CBD diagnoses or beryllium sensitization, to determine if
  corrective actions can prevent a recurrence.  The physicians providing medical
  surveillance should be familiar with working conditions, have access to exposure
  information, have the authority to report findings and make recommendations directly to
  line management, and deliver summaries and impacts of medical surveillance results to
  the multidisciplinary teams (see Section IV.8.3.4).  Beryllium training should include this
  medical surveillance information.

    Similarly, exposure surveillance includes the routine analysis of exposure data with the
  aim of identifying occupational exposures that require additional control.  Exposures that
  are out of compliance with the site's OELs should be investigated to determine their cause
  and to determine corrective actions that can prevent a recurrence.  Control charts of
  beryllium exposure levels and other analytical tools can be used to identify working
  conditions that require further investigation.  

              8.3.4     Teams To Identify Feedback Sources and Needs 

    Active performance feedback mechanisms are essential for day-to-day implementation
  and continual improvement of each element of site-specific CBDPPs and the DOE-wide
  program.  (See Section III.1, Program Elements.)  Active feedback can best be
  approached by having a multidisciplinary team representing line management, workers,
  maintenance, and worker protection and support functions collaborate on the content and
  format of the information that each function needs and can provide.  Also, the team
  should use computerized information systems to manage and transfer the information. 
  The amount of information and need for timely and easy input and access to the
  information can only be satisfied by computerized information systems.

    Optimal performance measurement feedback to the various organizations and workers is
  facilitated by thoroughly integrating the staffs of the relevant functions, including
  workers, in monitoring performance.  Performance feedback occurs naturally as a
  consequence of team activities in addition to the preparation and distribution of
  performance reports.  The mechanisms used for providing feedback to the various
  organizations and workers should be addressed in the written program.                                
                                
                                
                                
                                
                           APPENDIX A
                                
                                
                                
                                
                                
                 BASIS FOR DEPARTMENTAL ACTION


                            CONTENTS

                                                             Page
       1.     Basis for Departmental Action                             
         1.1  Unacceptable Prevalence . . . . . . . . . . . . . . . .A-1
         1.2  Recent Studies. . . . . . . . . . . . . . . . . . . . .A-1
         1.3  Elusive Exposure Threshold for Disease. . . . . . . . .A-2
         1.4  Individual Susceptibility May Influence Who Gets CBD. .A-2
         1.5  Increasing Numbers of Beryllium Workers . . . . . . . .A-2
         1.6  Public Trust. . . . . . . . . . . . . . . . . . . . . .A-3
         1.7  Former Workers. . . . . . . . . . . . . . . . . . . . .A-3

       2.     Technical Information
         2.1  Beryllium Containing Materials. . . . . . . . . . . . .A-4
         2.2  Definition of and Diagnostic Criteria for CBD . . . . .A-4
         2.3  Beryllium Worker Exposure Groups. . . . . . . . . . . .A-5
         2.4  Properties, Hazards, and Uses of Beryllium. . . . . . .A-6

References . . . . . . . . . . . . . . . . . . . . . . . . . .A-7

                 Attachment A-1   Properties, Hazards, and Uses of Beryllium. .A-8
                               APPENDIX A

                 BASIS FOR DEPARTMENTAL ACTION

1.     BASIS FOR DEPARTMENTAL ACTION

       1.1    Unacceptable Prevalence

    The Department is establishing a Chronic Beryllium Disease Prevention Program
  (CBDPP) in response to the unacceptably high current prevalence of approximately 1%
  confirmed cases among DOE workers who have been included in a worker health
  surveillance program for Chronic Beryllium Disease (CBD).  CBD is a chronic,
  irreversible, and sometimes fatal lung disease. See Section 2 of this Appendix for a
  discussion of beryllium exposure groups and more information about CBD.
  
       1.2    Recent Studies

    Recent studies demonstrate that CBD continues to be identified in DOE workers.  Worker
  health surveillance programs for CBD initiated in 1991 at DOE's Rocky Flats
  Environmental Technology Site (Rocky Flats) and the Oak Ridge Y-12 Plant provide
  screening to current and former beryllium workers and employees who may have received
  incidental exposures.  Data from these programs confirm that CBD remains an ongoing
  problem.  Through December 1996, 93 cases of CBD have been diagnosed among 9053
  workers screened (1.0% prevalence).

1.3    Elusive Exposure Threshold for Disease

    The occupational health community does not have sufficient exposure and health
  outcome data to satisfy the majority of occupational health practitioners in either
  confirming that the current limit is adequate or establishing a lower limit.  Peer-evaluated
  journal articles (refs. 1, 2, and 3) indicate a high prevalence of CBD where average
  exposures were reported to be below the 2 micrograms/m3 limit, but the reported
  exposure data has been challenged as not representing the true exposures that the CBD
  cases received.  Adding to the uncertainty are unpublished data from the United Kingdom
  Atomic Weapons Establishment Cardiff  Facility that suggest that controlling their
  facility to 2 micrograms/m3 resulted in no cases of CBD among their workers (ref. 7). 
  DOE is not considering a change to the exposure limit given this level of uncertainty. 

       1.4    Individual Susceptibility May Influence Who Gets CBD

    Though workers having the highest levels of exposure are at greatest risk for CBD,
  individual susceptibility may play a role in who does or does not develop CBD.   It has
  long been suspected that genetics plays a role in determining who will become ill, and
  recent research suggests that a genetic predisposition may play some role in determining
  who develops CBD (ref. 4).  Currently, however,  there is no reliable genetic test that
  identifies highly susceptible individuals.

       1.5    Increasing Numbers of Beryllium Workers

    DOE anticipates a large increase in workers who will be potentially exposed to beryllium
  during the deactivation and decommissioning of former nuclear weapons production
  sites.  Beryllium parts for nuclear weapons were produced in DOE sites.  See Attachment
  A-1, Section 2 for additional information on uses of beryllium in DOE sites.

       1.6    Public Trust

    The Department's handling of the beryllium issue is attracting public attention and is one
  of the many activities that affect the public's trust in DOE's ethics and competence.  The
  Department's responsible actions to minimize future cases of CBD will maintain the
  public's trust.

       1.7    Former Workers

    Former workers are outside the scope of DOE N 440.1 and its Implementation Guide.
  DOE G 440.1-7 uses the term "former worker" to refer to workers who no longer work
  for DOE. The term "current worker" refers to current DOE workers who are potentially
  exposed as well as those no longer potentially exposed. All current workers who have
  current or past potential exposure are covered by DOE N 440.1.  The Office of
  Occupational Medicine and Medical Surveillance (EH-61), however, is operating a
  Beryllium Worker Medical Surveillance Program that contacts and offers CBD screening
  examinations to former workers. The program is currently operating at the Rocky Flats
  Environmental Technology Site, the Oak Ridge Y-12 Plant, and the Mound Facility. 
  (The Los Alamos National Laboratory is conducting a beryllium medical surveillance
  research project but only for current workers.).   It is expected that a DOE-wide program
  will be established in response to a legislative mandate to offer medical examinations to
  former employees at risk for occupational diseases (refer to 42 USC Section 7274i.
  "Program to Monitor Department of Energy Workers Exposed to Hazardous and
  Radioactive Substances".)

       2.     TECHNICAL INFORMATION

       2.1    Beryllium-Containing Materials

    DOE N 440.1 applies to elemental beryllium and any insoluble beryllium compound or
  alloy containing 0.15 percent beryllium or greater that may be released as an airborne
  particulate.  The soluble forms of beryllium are not covered because these forms of
  beryllium apparently do not cause CBD (see Attachment A-1).  The 0.15 percent
  beryllium was chosen because beryllium copper alloys are the most widely produced form
  of low-concentration beryllium and these alloys contain from less than 0.15 percent to
  approximately 2 percent (ref. 6).  Omitting materials containing less than 0.15 percent
  beryllium is not likely to miss beryllium that would pose a significant health risk in DOE
  work sites.  Also, DOE N 440.1 does not intend the CBDPP to cover copper that contains
  the trace amounts of beryllium that are likely to be found in non-beryllium copper
  products as a result of the common practice of recycling beryllium copper alloys along
  with waste copper.  Covering materials that contain trace amounts of beryllium would be
  of inconsequential value in preventing CBD.

       2.2    Definition of and Diagnostic Criteria for CBD

    CBD is a granulomatous, interstitial inflammation affecting primarily the lungs.  The
  most common manifestation is chronic interstitial pneumonitis.  The interstitial
  pnemonitis is usually associated with noncaseating granulomas.  See ref. 8 and
  Attachment A-1for more information.

    Different occupational medicine physicians use different diagnostic criteria for CBD but
  most use a definition similar to the following taken from ref. 9:

    PROPOSED DIAGNOSTIC CRITERIA FOR BERYLLIUM LUNG DISEASE,
  SUBCLINICAL BERYLLIUM LUNG DISEASE, AND BERYLLIUM
  SENSITIZATION*

         1.   History of exposure to beryllium
         2.   Beryllium-specific immune response
               positive peripheral blood LTT** and/or 
               positive bronchoalveolar lavage LTT
         3.   Histopathology on lung biopsy compatible with beryllium disease
               noncaseating granulomas or
               mononuclear cell infiltrates
         4.   Constellation of clinical findings that may include any of the following:
               respiratory symptoms; 
               reticulonodular infiltrates on chest radiograph or other imaging technique;
               altered pulmonary physiology with restrictive and/or obstructive physiology,
       decreased diffusing capacity for carbon monoxide, ventilatory impairment, or
       altered gas exchange on exercise testing
         *    Diagnosis of:
               "beryllium disease" requires all four criteria.
               "subclinical beryllium disease" requires Criteria 1 through 3.
               "beryllium sensitization" requires Criteria 1 and 2.  The meaning of a positive
       peripheral blood lymphocyte transformation testing (LTT) in the absence of a
       positive lavage LTT requires further study.
         **   LTT is equivalent to the "Be-LPT" term used in G 440.1-7.

       2.3    Beryllium Worker Exposure Groups

    It can be useful to place individuals into groups based on their potential beryllium
  exposure.  Beryllium workers are workers who are, or have been, potentially exposed to
  beryllium at or above the administrative action level that the site has established for
  personal air exposure.  (DOE N 440.1, Attachment 1, 4.b, and Contractor Requirements
  Document, 7.d.(2) requires establishing administrative action levels.)  Incidentally
  exposed workers are individuals who are, or have been, potentially exposed to beryllium
  at concentrations above naturally occurring background levels and below the
  administrative action level that the site has established for personal air exposure.  This
  group includes individuals who tour beryllium areas unless personal air monitoring
  confirms no exposure above natural background levels during the tour.  Site CBDPP
  managers should recognize that non exposed workers, who have no known prior, or
  anticipated potential future, exposure to beryllium above natural background air levels,
  also are addressed since DOE N 440.1, Attachment 1, 4, and Contractor Requirements
  Document, Section 7.d, requires minimizing the number of individuals who become
  incidentally exposed or beryllium workers.  This group includes individuals who tour
  beryllium areas and have personal air monitoring results confirming no exposure above
  natural background levels during the tour.  Site CBDPP managers should determine the
  exposure group that individuals belong to based on the information obtained from
  baseline inventory and sampling (see Section IV.1), hazard assessment (see Section IV.2),
  exposure monitoring (see Section IV.3), and medical surveillance (see Section IV.5) and
  maintain records that are relevant to the CBDPP for these individuals (see Section IV.7).

       2.4    Properties, Hazards, and Uses of Beryllium

    See Attachment A-1 for information about the properties, hazards, and uses of beryllium.

                      Appendix A References

  1 Kreiss, K., et al., "Machining Risk of Beryllium Disease and Sensitization with Median
  Exposures Below 2 g/m3, "American Journal of Industrial Medicine, 30:16-25 (1996).

       2.     Stange, A.W., et al., "Possible Health Risks from Low Level Exposure to Beryllium,"
       Toxicology,  III: 213-224 (1996).

       3.     Barnard, A.E., et al., "Retrospective Beryllium Exposure Assessment at the Rocky Flats
       Environmental Technology Site," American Industrial Hygiene Association Journal,
       57:804-808 (1996).

       4.     Richeldi, L., et al., "HLA-DPB1 Glutamate 69: A Genetic Marker of Beryllium Disease,"
       Science, 262:242-244 (1993).

  5 Pappas, G.P., et al., "Early Pulmonary Physiologic Abnormalities in Beryllium Disease,"
  American Review of Respiratory Disease, 148:661-666 (1993).

       6.     Rossman, M.D., et al., Beryllium:  Biomedical and Environmental Aspects.  Williams &
       Wilkins, Baltimore, MD, 1990.

       7.     Atomic Weapons Establishment, Cardiff, U.K., U.S. Department of Energy, EH-5,
       Beryllium Control Model, June 25, 1997.

       8.     Green, D.M., et al., "Beryllium Toxicity," Case Studies in Environmental Medicine,
       Agency for Toxic Substances and Disease Registry, July 1992

       9.     Newman, L.S., et al., "Pathologic and Immunologic Alterations in Early Stages of
       Beryllium Disease," American Review of Respiratory Disease, 139:1479-1486                          Attachment A-1

           Properties, Hazards, and Uses of Beryllium

This attachment is taken from the July 3, 1997 draft of the Defense Programs Beryllium Good
Practice Guide.  The Defense Programs Good Practice Guide paragraph numbering was retained.

1.2  Properties and Use

Beryllium is a silver-gray metal that has a low density, moderately high melting point, good
stability, and good mechanical properties particularly specific stiffness, which is six times
greater than steel (see Table 1-1). Beryllium is a natural occurring mineral estimated to be
present in the earth's surface in concentrations of 1 to 6 ppm. There are approximately 45
beryllium-containing minerals. The commercially important minerals include beryl,
3BeOAl2O3.6SiO2, phenakite, 2BeO.SiO2; bertrandite, 4BeO.2SiO2H2O; and chrysoberyl,
BeOAl2O3. Beryl has been known since ancient times as the gemstones emerald (green),
aquamarine (light blue), and beryl (yellow). Today, the primary forms of beryllium used are pure
metal, metal alloys, and beryllium oxide.

Beryllium is an essential material used in many applications within the Department of Energy
(DOE), Department of Defense, and in private industry. It is used in a number of aerospace
applications, including major components on satellites and spacecraft. The pure metal is used in
high-strength, non-sparking copper alloy tools; as moderators and neutron reflectors in nuclear
reactors; as components in nuclear weapons; in light-weight, high-performance aircraft brakes;
and in mirrors in satellite optical systems. Because beryllium transmits x-rays 17 times greater
than aluminum, it is also used extensively in making windows for x-ray tubes. The high-fired
oxide (see Table 1-2) is used as a ceramic in electronic applications and in lasers.

Table 1-1. Physical properties of beryllium.

Atomic number
4

Atomic weight
9.0122

Density
1.8477 g/cm3

Melting point
1287C

Boiling point
2472C

Table 1-2. Physical properties of beryllium oxide.

Formula
BeO

Molecular weight
25.01

Density
3.01 g/cm3

Melting point
ca 2530C

Boiling point
ca 3900C

Beryllium alloyed with copper, aluminum, and other metals is a popular engineering material in
the electronics, automotive, defense, and aerospace industries. Beryllium oxide powder formed
into shapes by processes such as dry pressing and extruding and subsequent firing produces a
ceramic with an exceptional combination of high thermal conductivity, high electrical resistivity,
and excellent dielectric properties. The ceramic is used in a number of electronics, laser,
automotive, and defense applications.

While a number of DOE facilities have used beryllium over the years, a few still use it today in
operations such as

         1.   Fabrication of beryllium metal components for nuclear weapons. These operations
       consist principally of machining beryllium metal pieces purchased from a vendor.
       The finished pieces are handled by workers involved in quality assurance and
       assembly activities.
         2.   Fabrication of beryllium oxide ceramic components for nuclear weapons. The
       principal operation consists of diamond grinding, high-precision machining of
       ceramic pieces that are primarily purchased from a vendor. 
         3.   Ceramic hot press where beryllium oxide powder is mixed with other compounds,
       pressed into the desired shape, and fired in a kiln. 
         4.   Destructive testing operations associated with development of new devices in
       which beryllium components are included in a non-nuclear package that is
       destroyed using high explosives.
         5.   Weapons assembly and disassembly, where workers receive, handle, and store
       beryllium parts.
         6.   Beryllium alloy and process development.

2.  Toxicology and Biological Effects of Beryllium

The toxicity of beryllium became apparent in the 1930s, but has only been generally recognized
since the 1940s. This section provides a general review of the toxicity of beryllium to humans
and experimental animals, and describes the characteristics of beryllium-related diseases and
current issues. A more thorough review of the toxicology of beryllium can be found in several
recent reviews (Meyer 1994; IARC 1993; Rossman, Preuss, and Powers 1991; Kriebel 1988;
USEPA 1987; WHO 1990; ATSDR 1993; HSE 1992).

2.1  Extent of Exposure

The principal concern of beryllium exposure to humans is in occupational settings. The potential
for such exposure by inhalation exist in the basic production industry, beryllium alloy casting
operations, ceramic beryllium-oxide parts manufacturing, and beryllium metal and alloy
fabrication (Preuss, 1991). It is estimated that workers potentially exposed to beryllium range
from 30,000 (NIOSH 1972) to 800,000 (NIOSH 1978), although the latter estimate has been
challenged as an overestimate (Preuss 1991).

To provide for review and ongoing evaluation of the acute and chronic forms of beryllium-
induced disease, a Beryllium Case Registry was established in 1952. However, this Registry has
not been maintained actively or uniformly in recent decades.

2.2  Effects on Humans

2.2.1  Acute Beryllium Disease

Acute beryllium-induced pulmonary disease, which is characterized by acute nasopharyngitis,
tracheobronchitis, and chemical pneumonitis, results from exposure to relatively high levels of
airborne beryllium (reviewed by Ridenour and Preuss 1991; Kreibel 1988). For the last 40 years,
acute beryllium disease has been associated solely with the extraction of beryllium from ore.
However, the potential for contracting the disease only exists in operations that involve handling
or extraction of soluble forms of beryllium (e.g., beryllium fluoride and beryllium chloride). It
has been noted that virtually all workers exposed to concentrations above 1,000 micrograms/m3
contracted acute beryllium disease, but there has been no reported cases among workers who
were exposed to less than 100 micrograms/m3. When removed from exposure, employees who
contracted acute beryllium disease gradually improved over a period of several weeks to a few
months. The last confirmed case of acute beryllium disease in the United States was in 1967.

2.2.2  Chronic Beryllium Disease

Chronic beryllium disease (CBD) was first described by Hardy and Tabershaw (1946) as a
chronic, delayed-type chemical pneumonitis. It is characterized clinically by pulmonary
symptoms that include dyspnea, nonproductive cough, and detriments in lung function, although
symptoms can also include progressive weakness and fatigue, pain, and anorexia. Histologically,
features of CBD include the presence of progressive, noncaseating granulomas, mononuclear cell
infiltrates, and calcific inclusions (Freiman and Hardy, 1970). Recently, several authors reviewed
the clinical features, pathology, diagnosis, and treatment of CBD (Rossman 1996; Meyer 1994;
Rossman Pruess, and Powers 1991; Kriebel 1988). The disease results from the inhalation of
airborne beryllium, and is most closely associated with the relatively insoluble forms (Eisenbud
and Lisson 1983). The mean latency period for CBD may range from 1 to 40 years, with an
incidence in exposed populations from 1 to 10%. This latter feature led Sterner and Eisenbud
(1951) to suggest an immunologically mediated basis for the disease and the possibility that
genetic susceptibilities may exist. Dermal effects may also exist in response to skin contact with
soluble salts or beryllium slivers, and these effects may range from contact dermatitis to dermal
granulomas.

2.2.3  Lung Cancer

There has been considerable debate on the extent to which beryllium and its compounds should
be regarded as a human lung carcinogen. Several groups have undertaken epidemiological
research on beryllium workers from two general populations: all identifiable beryllium workers,
and workers listed in the Beryllium Case Registry. Throughout the 1970s, the former group of
workers formed the basis of reports by Wagoner et al. (1980) and by Mancuso (1980), whereas
the second group was examined by Infante et al. (1980). These studies have been extensively
reviewed and critiqued (USEPA 1987; ATSDR 1993; IARC 1993). The general tone of these
reviews is that serious methodological problems with the studies prevented definitive
conclusions to be drawn. For this reason, but in consideration of the demonstrable
carcinogenicity of beryllium in certain animal models (see Section 2.4), beryllium was classified
in the early 1990s as a demonstrated animal carcinogen and a suspect human carcinogen.

More recently, these same two cohorts were reanalyzed. Steenland and Ward (1991) described a
small, yet statistically significant increase in lung cancer for cases listed in the Beryllium Case
Registry versus the United States population. Interestingly, the mortality rate for lung cancer was
greater among individuals with acute beryllium disease (possibly because of greater beryllium
exposure) compared with those having CBD. Ward et al. (1992) examined 9225 beryllium
workers from 7 beryllium plants and also noted a small, yet significant increase in the mortality
rate for lung cancer from some, but not all of the plants. Presumably on the basis of these studies,
the IARC (1993) voted to classify beryllium as a demonstrated lung carcinogen in humans. In
spite of these findings, however, beryllium is still classified as a suspected human lung
carcinogen in the United States.

2.3  Historical Aspects

2.3.1  Acute Beryllium Disease

Acute beryllium disease was first reported in the United States by Van Ordstrand (1943) and
Kolanz (1997). This disease is a chemical pneumonia, which for the last 40 years, has been solely
associated with the extraction of beryllium from ore. Prior to 1950, acute beryllium disease was
associated with the manufacture and usage of low-fired beryllium oxide in the fluorescent lamp
industry. However, high-fired oxide used in the same application did not result in the disease.
Hall et al. (1950) found that the low-fired oxide powder was actually an agglomeration of smaller
particles, while the high-fired oxide was made up of larger particles. Also, low-fired oxide was
much more soluble than high-fired oxide. 

Today, the potential for contracting acute beryllium disease only exists in facilities that handle or
extract soluble forms of beryllium (e.g., beryllium fluoride and beryllium chloride). The last
confirmed case of acute beryllium disease in 1967 was caused by welding on ventilation duct
work containing beryllium fluoride residue. Thus, it appears that acute beryllium disease does not
occur in operations involving insoluble forms of beryllium (such as metallic beryllium powder or
dust, high-fired beryllium oxide powder or dust, or fumes or dust from alloys containing
beryllium).

2.3.2  Chronic Beryllium Disease

As previously noted, CBD was first identified in 1946. In subsequent years, several hundred
cases were identified and entered into the Beryllium Case Registry. Eisenbud and Lisson (1983)
found a significant reduction in CBD among workers first exposed after 1950. Associated with
the decreased incidence of CBD, in spite of increased beryllium use in the 1950s and 1960s,
Eisenbud found a decrease in the latency period (Eisenbud, 1990). For various plants and
beryllium-working operations, the estimated level of exposure did not correlate well with the
incidence of CBD. The role of beryllium-specific sensitization was confirmed in both laboratory
and clinical studies.

The identification of a CBD case in a DOE facility in 1984 resulted in increased scrutiny of both
industrial hygiene practices and individuals working with beryllium. The lymphocyte
proliferation test (LPT), combined with more definitive medical examinations, is now being used
in large-scale programs to screen patients' blood or lung lymphocytes. The test involves placing
the lymphocytes in cell culture with a soluble form of beryllium and measuring proliferation of
the cells (see Section 2.5.2). To date, over 100 new cases of beryllium sensitization and/or CBD
have been identified.

2.3.3  Neighborhood Cases

A curious feature of the early literature was the occurrence of several cases of CBD in people
residing in the vicinity of beryllium plants. Although it was not possible to always estimate
airborne beryllium concentrations near these plants, it was clear that air concentrations could not
have been as large as within the plants. However, investigations concluded that insufficient
personnel hygiene practices of plant workers, largely from laundering contaminated work clothes
in the home, was responsible (Eisenbud 1982, 1990). These investigations also lead to the
adoption in 1950 by the AEC of the 0.01 micrograms/m3 concentration standard for air in the
vicinity of beryllium plants.

2.4  Animal Models

2.4.1  Biokinetics

Most of our knowledge on the excretion biokinetics of beryllium in humans comes from
experimental studies in laboratory animals. Limited information that exists on the topic has been
recently summarized in various works (USEPA 1987; Reeves 1991a; ATSDR 1993; IARC 1993;
Finch et al. 1996). 

Systemic absorption of beryllium through the skin after dermal exposure or through the
gastrointestinal tract after oral ingestion is low. Retention in the lung, distribution to other tissues
and organs, and excretion is largely due to the physicochemical form of the beryllium inhaled.
More soluble beryllium is cleared relatively quickly from the lungs, but can be retained longer,
presumably due to precipitation into relatively insoluble forms. Forms of lower solubility, such
as the metal or oxide, can be cleared following conventional lung kinetics of clearance of
relatively insoluble particles, although toxicity induces delayed clearance (Finch et al. 1996), or
by dissolution. Systemically distributed beryllium is retained predominantly in bone, but has
been noted in other compartments. Excretion in feces is largely due to unabsorbed beryllium
passing from the respiratory to gastrointestinal tract; urinary excretion is more important for
systemically distributed beryllium (Reeves 1991b).

2.4.2  Toxic and Immunological Effects

Non-cancer toxic and immunological effects of beryllium compounds have been observed in
systems ranging from cultured cells to intact animals (EPA 1987; WHO 1990; Reeves 1991b;
ATSDR 1993; IARC 1993; Finch et al. 1996). At sufficiently high exposure levels, beryllium
compounds can cause death in periods ranging from minutes to weeks. Beryllium is cytotoxic
and can also induce severe, chronic inflammatory pulmonary responses even from single
inhalation exposures to the metal.

Animal models have been useful in demonstrating the immunological nature of responses to
beryllium. Barna et al. (1984) have demonstrated differential sensitivity of two strains of guinea
pigs, suggesting a genetic component of response. Most of the components of human CBD have
been demonstrated in either mice (Huang et al. 1992; Finch et al., 1996), rats (Votto et al. 1987),
dogs, or monkeys (Finch et al. 1996). Unfortunately, an animal model that incorporates all the
significant features of human CBD (including the progressive nature of the disease) has not yet
been identified despite efforts by numerous investigators. The development of such a model
would allow for investigation of many of the current uncertainties regarding responses to
beryllium (see Section 2.5).

2.4.3  Cancer

Recent reviews of the carcinogenicity of beryllium compounds in various tissues of several
species of laboratory animals can be found in various works (EPA 1987; WHO 1990; Reeves
1991b; ATSDR 1993; IARC 1993). Most notable have been bone cancer induced by various
routes of exposure and, more pertinent to humans, lung cancer induced by inhalation or
intratracheal instillation of several different beryllium-containing materials. Marked species
differences in pulmonary carcinogenic responses to inhaled beryllium metal between rats
(relatively susceptible) and mice (relatively resistant) have been observed (Finch et al. 1996).
Experimental data are sufficient to permit both the EPA (600/8-84/026F, 1987) and IARC (1993)
to conclude that beryllium and its compounds are demonstrated carcinogens in animals.

2.5  Current Issues

2.5.1  Relationship Between Sensitization and Disease

Because of the development and widespread use of the blood LPT within only the last decade,
the relationship between Be-sensitization and the development of clinical CBD is not clear.
While it is generally accepted that CBD cases were preceded by detectable sensitization, the
extent to which sensitization, as measured by the LPT, predestines an individual to contract the
clinical disease is not known. Some investigators have provided a few instances where this
progression has occurred (Kreiss 1993a), but a definitive answer to the question must await
follow up of individuals who have recently been identified as sensitized, but who are clinically
free of any signs of CBD.

2.5.2  Current Large-scale Screening Programs

Efforts are currently under way at two DOE sites (Rocky Flats and the Y-12 plant at Oak Ridge)
and in the private sector to test current and former beryllium workers for Be-specific sensitization
using the blood LPT. The largest effort is at Rocky Flats, where 4,268 workers have been tested
(Stange et al. 1996). About 1,000 workers at Oak Ridge have been or will be tested.

Large-scale screening programs include an initial blood LPT test, follow-up tests if the initial test
is positive, medical counseling, and possible removal from beryllium work. Follow-up tests may
include a lung LPT and collection of a transbronchial biopsy sample for analysis of possible lung
granulomas. Medical removal from Be-related work is problematic in the private sector where
beryllium work may be the only business. It is anticipated that prospective follow up of
sensitized, asymptomatic individuals will provide important information on the relationship
between beryllium-specific sensitization and the development of clinical CBD.

An enzyme-linked immunosorbent assay (ELISA) (a beryllium antibody test) was developed to
screen individual employees for possible exposure to beryllium in the workplace (Clarke 1991).
This exceptionally sensitive assay has been used to assess beryllium exposures in a variety of
jobs (i.e., engineers, maintenance staff, filter replacement technicians, and laboratory workers),
and has identified beryllium exposures within weeks at concentrations as low as 0.08
micrograms/m3 (Clarke 1993). It has also been shown to be effective at detecting antibodies in
laboratory mice following inhalation exposures. 

2.5.3  Effect of Physicochemical Form and Frequency of Exposure

Despite a 50-year relationship between beryllium exposure and CBD, industrial hygiene
assessments have not definitively identified the relationship among specific forms of beryllium,
the frequency of exposure (single acute, chronic, or multiple episodic exposure), and the disease.
It has been apparent for some time, however, that exposure to the less soluble forms of beryllium
(e.g., beryllium metal or beryllium oxide), compared to more soluble forms, are more likely to be
associated with CBD cases. Eisenbud and Lisson (1983) showed that machinists working with
beryllium metal had the greatest risk of contracting CBD although recent data indicate that
exposure to beryllium oxide, even when fired at relatively high temperatures, may be the more
hazardous exposure (Kreiss 1996). Cases attributable to exposures to beryllium-containing alloys
also exist, although these are apparently more rare (Levin 1991).

There is considerable uncertainty regarding the role of beryllium exposure frequency. CBD cases
attributable to a single or only a few exposures are rare, but do exist (see, for example, Newman
and Kreiss 1992). As for the relative importance of low-level, chronic exposure, versus periodic
"spikes" of exposure, neither industrial hygiene data on human exposures nor data from
experimentation on animals permit this question to be adequately answered.

2.5.4  Human Carcinogenicity

Beryllium and its compounds was classified as a demonstrated human carcinogen by the IARC
(1993) based on cohort epidemiology studies conducted by Ward et al. (1992) and Steenland and
Ward (1991). The interpretation of the findings of these studies is controversial, and factors other
than beryllium exposure might explain the results (MacMahon 1994; Vainio and Rice 1997;
BISEC 1997). Some agencies in the United States classify beryllium as a suspect human
carcinogen (USEPA 1987; ATSDR 1993). Thus, an unresolved dichotomy exists between
Europe and the United States regarding the regulatory classification of beryllium as a human
carcinogen.
             Appendix A, Attachment A-1 References
                                
  ACGIH, American Conference of Governmental Industrial Hygienists.  Industrial Ventilation: A
  Manual of Recommended Practice.  22nd Edition.  Cincinnati, OH: ACGIH; 1995.
  ACGIH, American Conference of Governmental Industrial Hygienists.  1996 TLVs and BEIs
  Threshold Limit Values for Chemical Substances and Physical Agents and Biological
  Exposure Indices.  Cincinnati, OH: ACGIH; 1996a.
  ACGIH, American Conference of Governmental Industrial Hygienists.  Documentation of the
  Threshold Limit Values and Biological Exposure Indices.  Sixth Edition.  Cincinnati, OH:
  ACGIH; 1996b. 
  ANSI, American National Standards Institute.  Acceptable concentrations of beryllium and
  beryllium compounds.  New York: ANSI; ANSI  Z37.29; 1970.
  ANSI, American National Standards Institute.  American National Standard Practices for
  Respiratory Protection.  New York: ANSI; ANSI Z88.2-1991; 1991.  
  ATSDR, Agency for Toxic Substances and Disease Registry, Public Health Service.  Toxicological
  Profile for Beryllium.  Washington, DC: U.S. Department of Health and Human Services;
  ATSDR/TP-92/04; 1993.  
  Barna, B. P.; Deodhar, S. D.; Chiang, T.; Gautam, S.; Edinger, M.  Experimental Beryllium-Induced
  Lung Disease.  Differences in Immunologic Responses to Beryllium Compounds in Strains
  2 and 13 Guinea Pigs.  Int. Archs. Allergy Appl. Immunol. 73:42 48; 1984.  
  BISAC, Beryllium Industry Scientific Advisory Committee.  Is Beryllium Carcinogenic in Humans?
  J. Occup. Env. Med. 39(3):205 208; 1997.  
  Caplan, K.J.  The Significance of Wipe Samples.  Am. Ind. Hyg. Assoc. J.  54:70 75; 1993.
  CFRa, Code of Federal Regulations.  DOE National Environmental Policy Act Implementing
  Procedures.  Washington, DC: U.S. Government Printing Office; Title 10, Part 1021. 
  CFRb, Code of Federal Regulations.  OSHA Hazardous Waste Operations and Emergency
  Response.  Washington, DC: U.S. Government Printing Office; Title 29, Part 1910.120. 
  Clarke, S. M.  A Novel Enzyme-Linked-Immunosorbent-Assay (ELISA) for the Detection of
  Beryllium Antibodies.  J. Immunol. Methods.  137:65 72; 1991.
  Clarke, S. M.; Thurlow, S. M.; Hilmas, D. E.  Occupational Beryllium Exposure/Recovery
  Monitored by Beryllium Antibody Assay: Six Year Case Study.  The Toxicologist. 
  13:440(Abstract); 1993.  
  Colton, C. E.; Birkner, L. R.; Brosseau, L. M., eds.  Respiratory Protection: A Manual and
  Guideline.  Second Edition.  Akron, OH: American Industrial Hygiene Association;
  1991.  
  Deodhar, S. D.; Barna, B. P.  Immune Mechanisms in Beryllium Lung Disease.  Cleve. Clin. J. Med. 
  58:157 160; 1991.  
  Eisenbud, M.  Origins of the Standards for Control of Beryllium Disease (1947-1949).  Environ.
  Res.  27:79 88; 1982.  
  Eisenbud, M.; Lisson, J.  Epidemiological Aspects of Beryllium-Induced Nonmalignant Lung
  Disease: A 30-Year Update.  J. Occup. Med.  25:196 202; 1983.  
  Eisenbud, M.  Health Problems in the Beryllium Industry.  An Environmental Odyssey: People,
  Pollution, Politics in the Life of a Practical Scientist.  Seattle, WA: University of Washington
  Press; 1990:48 54.  
  Epstein, W. L.  Cutaneous Effects of Beryllium.  Rossman, M. D.; Preuss, O. P.; Powers, M.
  B. Beryllium, Biomedical and Environmental Aspects.  Baltimore, MD: Williams
  and Wilkins; 1991:113 119.
  Finch, G. L.; Hoover, M. D.; Hahn, F. F.; Nikula, K. J.; Belinsky, S. A.; Haley, P. J.; Griffith, W.
  C.  Animal Models of Beryllium-Induced Lung Disease.  Environ. Hlth. Perspect. 104(Suppl.
  5):973 979; 1996.  
  Freiman, D. G.; Hardy, H. L.  Beryllium Disease: The Relation of Pulmonary Pathology to Clinical
  Course and Prognosis Based on a Study of 130 Cases from the U.S. Beryllium Case Registry. 
  Hum. Pathol.  1:25 44; 1970.  
  Hall, R. H.; Scott, J. K.; Laskin, S.; Stroud, C. A.; Stokinger, H. E.  Acute Toxicity of Inhaled
  Beryllium.  Observations Correlating Toxicity with the Physicochemical Properties of
  Beryllium Oxide Dust.  Arch. Ind. Hyg. Occup. Med.  2:25 48; 1950. 
  Hardy, H. L.; Tabershaw, I. R.  Delayed Chemical Pneumonitis Occurring in Workers Exposed to
  Beryllium Compounds.  J. Ind. Hyg. Toxicol.  28:197 211; 1946.  
  Hawkins, N. C., Norwood, S. K.; Rock, J. C.  A Strategy for Occupational Exposure Assessment. 
  Fairfax, VA: American Industrial Hygiene Association; 1991.  
  HSE, Toxicity Review 27: Triglycidyl isocyanurate, Beryllium and beryllium compounds.  Health
  and Safety Executive.  Sheffield, United Kingdom: 1992.
  Huang, H.; Meyer, K. C.; Kubai, L.; Auerbach, R.  An Immune Model of Beryllium-Induced
  Pulmonary Granulomata in Mice: Histopathology, Immune Reactivity, and Flow-Cytometric
  Analysis of Bronchoalveolar Lavage-Derived Cells.  Lab Invest.  67:138 146; 1992.  
  IARC, International Agency for Research on Cancer.  Monographs on the Evaluation of
  Carcinogenic Risks to Humans: Vol 58. Beryllium, Cadmium, Mercury, and Exposures in
  the Glass Manufacturing Industry.  Lyon, France: World Health Organization; 1993.
  ILO, International Labor Organization.  Guidelines for the use of ILO international classification of
  radiographs of pneumoconioses.  Geneva, Switzerland: ILO; Occupational Safety and Health
  Series No. 22 (Rev):1980. 
  Infante, P. F.; Wagoner, J. K.; Sprince, N. L.  Mortality Patterns from Lung Cancer and Non-
  neoplastic Respiratory Disease among White Males in the Beryllium Case Registry. 
  Environ. Res.  21:35 43; 1980.  
  Klingner, T.D.; McCorkle, T.  The Application and Significance of Wipe Samples.  Am. Ind. Hyg.
  Assoc. J.  55:251 254; 1994.
  Kolanz, M. E.  Sample "Request for Quotation" for cleaning and decontamination of a beryllium
  facility, Brush Wellman Inc., Cleveland, OH, February, 7, 1996.
  Kolanz, M. E.  Comments of Brush Wellman, Inc. on the Department of Energy's Notice Requesting
  Information Relative to Control of Occupational Exposure to Beryllium in DOE Facilities. 
  Cleveland, OH: Brush Wellman, Inc.; 1997.  
  Kreiss, K.; Newman, L. S.; Mroz, M. M.; Campbell, P. A.  Screening Blood Test Identifies
  Subclinical Beryllium Disease.  J. Occup. Med.  31:603 608; 1989.  
  Kreiss, K.; Mroz, M. M.; Zhen, B.; Martyny, J. W; Newman, L. S.  Epidemiology of Beryllium
  Sensitization and Disease in Nuclear Workers.  Am. Rev. Resp. Dis.  148:985 991; 1993a. 
  Kreiss, K.; Wasserman, S.; Mroz, M. M.; Newman, L. S.  Beryllium Disease Screening in the
  Ceramics Industry: Blood Lymphocyte Performance and Exposure-disease relations.  J.
  Occup. Med.; 35:267 274; 1993b.
  Kreiss, K.; Mroz, M. M.; Newman, L. S.; Martyny, J.; Zhen, B. Matching Risk of Beryllium Disease
  and Sensitization with Median Exposures Below 2 micrograms/m3.  Am. J. Ind. Med.
  30:16 25; 1996.
  Kriebel, D.; Brain, J. D.; Sprince, N. L.; Kazemi, H.  The Pulmonary Toxicity of Beryllium.  Am.
  Rev. Respir. Dis.  137:464 473; 1988.  
  Levin, L. Letter to the Editor (in response to Hoover, M. D.; Finch, G. L.  Release of Aerosols
  during Milling of Metal and Beryllium Alloys.) Appl. Occup. Environ. Hyg.  6:567; 1991.
  Lichtenwalner, C.P.  Evaluation of Wipe Sampling Procedures and Elemental Surface
  Contamination.  Am. Ind. Hyg. Assoc. J.  53:657 659; 1992.
  MacMahon, B.  The Epidemiological Evidence on the Carcinogenicity of Beryllium in Humans.  J.
  Occup. Med.  36(1):15 24; 1994.
  Mancuso, T.  Mortality Study of Beryllium Industry Workers' Occupational Lung Cancer.  Environ.
  Res.  21:48 55; 1980.  
  Markham, T. N.  Medical examination programs.  Rossman, M. D.; Preuss, O. P.; Powers, M. B.,
  eds.  Beryllium: Biomedical and Environmental Aspects.  Baltimore, MD: Williams &
  Wilkins; 1991:185 192.
  Meyer, K. C.  Beryllium and Lung Disease.  Chest.  106:942 946; 1994.  
  Mitchell, R.N.; Eutsler, B. C.  A Study of Beryllium Surface Contamination and Resuspension.  B.R.
  Fish, Editor, Symposium on Surface Contamination Gatlinburg, TN, June 1964.  Elmsford,
  NY: Pergamon Press; 1966:349 352. 
  Newman, L. S.; Kreiss, K.; King, T. E., Jr.; Seay, S.: Campbell, P. A.  Pathologic and Immunologic
  Alterations in Early Stages of Beryllium Disease.  Am. Rev. Respir. Dis.; 139:1479 1486;
  1989.  
  Newman, L. S.; Kreiss, K.  Nonoccupational Beryllium Disease Masquerading as Sarcoidosis:
  Identification by Blood Lymphocyte Proliferative Response to Beryllium.  Am. Rev. Respir.
  Dis.  145:1212 1214; 1992.
  NIOSH, National Institute for Occupational Safety and Health.  Occupational Exposure to Beryllium
  (Criteria for a Recommended Standard).  Rockville, MD: U.S. Department of Health,
  Education, and Welfare; NIOSH-TR-003-72; PB 210-806; 1972.  
  NIOSH, National Institute of Occupational Safety and Health.  Public Hearing on the Occupational
  Standard for Beryllium.  Cincinnatti, OH: U.S. Department of Health, Education, and
  Welfare; NIOSH PB83-182378; 1977.
  NIOSH, National Institute of Occupational Safety and Health.  Health Hazard Evaluation
  Determination.  Report No. 78-028-480.  Persolite Products Inc.: Florence, Colorado. 
  Cincinnati, OH: U.S. Department of Health, Education and Welfare;
  NIOSH-TR-HHE-78-028-480; 1978.  
  NIOSH, National Institute for Occupational Safety and Health.  NIOSH Manual of Analytical
  Methods.  Method 7102: Beryllium and compounds, as Be.  Cincinnati, OH: U.S Department
  of Health and Human Services; 1987. 
  Preuss, O. P.  Assessment of Risk Potential.  Rossman, M. D.; Preuss, O. P.; Powers, M. B., eds. 
  Beryllium: Biomedical and Environmental Aspects.  Baltimore, MD: Williams and Wilkins;
  1991:263 273.  
  Preuss, O. P.; Rossman, M. D.  Clinical Picture and Nonimmunological Laboratory Findings in
  Chronic Beryllium Disease.  Rossman, M. D.; Preuss, O. P.; Powers, M. B., eds.  Beryllium:
  Biomedical and Environmental Aspects.  Baltimore, MD: Williams & Wilkins,
  1991:133 140.  
  Reeves, A. L.  Toxicodynamics.  Rossman, M. D.; Preuss, O. P.; Powers, M. B., eds.  Beryllium:
  Biomedical and Environmental Aspects.  Baltimore, MD: Williams & Wilkins; 1991a:87 93. 
  
  Reeves, A. L.  Toxicokinetics.  Rossman, M. D.; Preuss, O. P.; Powers, M. B., eds.  Beryllium:
  Biomedical and Environmental Aspects.  Baltimore, MD: Williams & Wilkins; 1991b:77-86. 
  Richeldi, L.; Sorrentino, R.; Saltini, C.  HLA-DPB1 Glutamate 69: A Genetic Marker of
  Beryllium Disease.  Science.  262:242-244; 1993.
  Ridenour, P. K.; Preuss, O. P.  Acute Pulmonary Beryllium Disease.  Rossman, M. D.; Preuss, O.
  P.; Powers, M. B., eds.  Beryllium: Biomedical and Environmental Aspects.  Baltimore,
  MD: Williams & Wilkins; 1991:103 112.  
  Rossman, M. D.; Kern, J. A.; Elias, J. A. et al.  Proliferative response of bronchoalveolar
  lymphocytes to beryllium: a test for chronic beryllium disease.  Ann. Intern. Med.
  108:687 693; 1988.
  Rossman, M. D.; Preuss, O. P.; Powers, M.B., eds.  Beryllium: Biomedical and Environmental
  Aspects.  Baltimore, MD: Williams & Wilkins; 1991. 
  Rossman, M. D.; Jones-Williams, M.  Immunopathogenesis of Chronic Beryllium
  Disease.  Rossman, M. D.; Preuss, O. P.; Powers, M. B.  Beryllium, Biomedical
  and Environmental Aspects.  Baltimore, MD: Williams and Wilkins;
  1991:121 132.  
  Rossman, M.D.  Chronic Beryllium Disease Diagnosis and Management.  Environmental Health
  Perspectives.  104(S5):945 947; 1996.
  Stange, A. W.; Hilmas, D. E.; Furman, F. J.  Possible Health Risks from Low Level Exposure to
  Beryllium.  Toxicology.  111:213 224; 1996.
  Steenland, K.; Ward, E.  Lung Cancer Incidence Among Patients With Beryllium Disease: A
  Cohort Mortality Study.  J. Natl. Cancer Inst.  83:1380 1385; 1991.  
  Sterner, J. H.; Eisenbud, M.  Epidemiology of Beryllium Intoxication.  Arch. Ind. Hyg. Occup.
  Med.  4:123 151; 1951.  
  Stokes, R. F.; Rossman, M. D.  Blood cell proliferation response to beryllium: analysis by
  receiver-operating characteristics.  J. Occup. Med.  33:23-28; 1991.
  USDOE, U.S. Department of Energy.  Comprehensive Environmental Response, Compensation,
  and Liability Act (CERCLA) Requirements.  Washington, DC: DOE; DOE Order 5400.4. 
  1989.
  USDOE, U.S. Department of Energy.  Decommissioning Handbook.  Washington, DC: DOE;
  DOE/EM-0412; March 1992.
  USDOE, U.S. Department of Energy.  Decommissioning Manual.  Washington, DC: DOE;
  DOE/EM-0246; August 1995.
  USDOE, U.S. Department of Energy.  Environmental Restoration Program Decommissioning
  Implementation Guide.  Washington, DC: DOE; DOE/EM;  May 22, 1995.
  USDOL, U.S. Department of Labor.  OSHA Technical Manual, Fourth Edition.  Washington,
  DC: Government Institutes, Inc.  1996.  
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  Washington, DC: EPA; EPA/600/8-84/ 026F; 1987.  
  Vainio, H.; Rice, J. M.  Editorial: Beryllium Revisited.  J. Occup. Env. Med.  39(3):203; 1997.
  Van Ordstrand, H. S.; Hughes, R.; Carmody, M. G.  Chemical Pneumonia in Workers Extracting
  Beryllium Oxide: Report of Three Cases.  Cleve. Clin. J. Med.  10:10 18; 1943.  
  Votto, J. J.; Barton, R. W.; Gionfriddo, M. A.; Cole, S. R.; McCormick, J. R.; Thrall, R. S.  A
  Model of Pulmonary Granulomata Induced by Beryllium Sulfate in the Rat.  Sarcoidosis. 
  4:71 76; 1987.  
  Wagoner, J. K.; Infante, P. F.; Bayliss, D. L.  Beryllium: An Etiologic Agent in the Induction of
  Lung Cancer, Non-neoplastic Respiratory Disease, and Heart Disease Among Industrially
  Exposed Workers.  Environ. Res.  21:15-34; 1980.  
  Ward, E.; Okun, A.; Ruder, A.; Fingerhut, M.; Steenland, K.  A Mortality Study of Workers at
  Seven Beryllium Processing Plants.  Am. J. Ind. Med.  22:885 904; 1992.  
  WHO, World Health Organization.  Environmental Health Criteria 106: Beryllium.  Geneva,
  Switzerland: WHO; 1990.                           APPENDIX B

                                
                          CATALOG OF 
                                
          CHRONIC BERYLLIUM DISEASE PREVENTION PROGRAM
                                
                   EXAMPLES AND DESCRIPTIONS
The following are examples and descriptions of chronic beryllium disease prevention programs and tools that various organizations have developed and used. 
These materials have not been reviewed for accuracy or regulatory compliance, and are not endorsed by DOE, unless otherwise indicated in DOE G 440.1-7. 
Copies of the material are available on the DOE EH Chronic Beryllium Disease Prevention Program Web Site at http://tis-nt.eh.doe.gov/be/.

No.
Title
Description

1
Rocky Flats Environmental Technology Site (RFETS)
Site Beryllium Characterization Sampling and Analysis
Plan
The plan that was used by RFETS to characterize the site for beryllium.  Includes personal
air, area air, and surface sampling; statistical treatment of sample selection and sample
results; sampling, analysis, chain of custody and quality assurance procedures, decision rules
to adjust sampling as results become available, and the development of a database for the
results.

2
Los Alamos National Laboratory Site Characterization
for TA-3-141, Sampling and Testing Plan,
December 15, 1995
The plan that was used by LANL to characterize the facility that formerly was used for
beryllium and will be renovated into their state-of-the-art beryllium facility.  Includes
personal air, area air, and surface sampling; statistical treatment of sample selection and
sample results; sampling, analysis, chain of custody and quality assurance procedures, and
decision rules to adjust sampling as results become available.

3
Los Alamos National Laboratory Site Characterization
for TA-3-141, Volume 1-Summary of Site
Characterization Results, Volume 2-Detailed Analysis
of Site Characterization Results (abbreviated)
Results of a detailed survey for beryllium (and other toxic materials) in a facility that had
been used for beryllium activities.  Includes typical sample collection and hazard assessment
forms that were completed in the field.

4
Brush Wellman Company, Inc., Beryllium Air
Sampling Procedure, CLGREG01 Doc: 194776_1,
Beryllium Surface Sampling Procedure, CLGREG01
Doc: 194777_1
Brush Wellman, Inc.'s procedures for sampling air and surfaces for beryllium.

5
Atomic  Weapons Establishment, Cardiff Facility,
AWE Cardiff, U.K., Health Physics Process Instruction
Number 13, Personal Air Sampling Project Be Area,
November 1993
Cardiff's procedure for personal air sampling for beryllium.

6
Atomic  Weapons Establishment, Cardiff Facility,
AWE Cardiff, U.K., Health Physics Process Instruction
Number 14, Static Air Sampling Project Be Area,
November 1993
Cardiff's procedure for sampling area air for beryllium.

7
Atomic Weapons Establishment, Cardiff Facility,
AWE Cardiff Health Physics Process Instruction
Number 15, Smear Samples Project Be, February 1994
Cardiff's procedure for sampling surfaces for beryllium.

8
Atomic Weapons Establishment (AWE) Cardiff, U.K.,
Beryllium Control Model description prepared by
AWE and EH-5
Summary of Cardiff's beryllium control practices and results over their 37 years of
operation.

9
Los Alamos National Laboratory Beryllium
Technology Facility Auditable Safety Analysis 
Descriptions of the state-of-the-art Los Alamos National Laboratory  beryllium facility.  The
descriptions include engineering, work practice, and administrative controls, and how these
controls work together.  The descriptions also describe industrial hygiene support and
emissions and waste controls.

10
Rocky Flats Plant Procedure 1-15310-HSP-13.04,
Beryllium Protection, Revision 0, September 27, 1992
Rocky Flats Environmental Technology Site resposibilities and requirements for working 
with and monitoring beryllium.

11
Los Alamos National Laboratory Administrative
Requirements, AR Section 6:  Hazardous Materials,
Beryllium, AR 6-7, August 16, 1991
Provides Los Alamos National Laboratory requirements for air quality, surface swipes, and
other general requirements for beryllium operations.

12
Brush Wellman Medical Surveillance Program, 2/7/96
Describes beryllium exposure groups, medical survaillance procedures, and diagnostic
criteria for CBD.

13
Rocky Flats Industrial Hygiene Procedure Manual, 4-
15310-IHPM-5.2, Beryllium Control Program, March
27, 1992
Rocky Flats Environmental Technology Site worker protection personnel resposibilities,
exposure monitoring procedures, and exposure reduction and minimization procedures for
working with  beryllium.

14
Atomic Weapons Establishment (AWE), Cardiff, U.K.,
Beryllium Facility (Project "Be") Building Regulations
Cardiff's administrative, work practice, and personal protective equipment controls.

                                            
                                       APPENDIX C
                                            
                                            
                                            
                                EXAMPLE TRAINING MATRICES
                                            
                                            
                                            
                                            
                                            
                                            
                                            
                                       APPENDIX C

                                EXAMPLE TRAINING MATRICES

Two matrices are provided as examples for consideration by sites.  The first matrix defines training needs by position.  The second
matrix offers a simplified version with four training levels and suggests positions to be included at each level.  The training needs
indicated in site specific CBDPPs should reflect that site's beryllium hazards.
                               TRAINING MATRIX BY POSITION

POSITION

*TOPIC
A
B
C
D
E
F
G
H
I
J
K

CBDPP
x
x
x
x
x
x
x
x
x
x
x

Goals
x
x
x
x
x

x

Performance Measures
x
x
x
x
x

x

Health Effects
x
x
x
x
x
x
x
x
x
x
x

Physical Properties
x
x

x

x
x
x
x

x

MSDS
x
x

x

x
x
x
x

x

Methods to detect the presence
or release
x
x

x

x
x

x

Exposure
Reduction/Minimization
x
x
x
x
x

x

x

x

Labeling/Warnings Signs
x
x

x

x
x

x
x
x

Exposure Monitoring
x
x

x
x

x

Standards
x
x
x
x
x

x

x

Use & Limitations of PPE
x
x

x
x

x

x

x

Medical Surveillance
x
x
x
x
x

x

Hazard Assessments
x
x

x

Analytical Techniques

x

Assessment of Risk

x
x

Activity/Process Descriptions
x
x
x
x
x

Activity/Process Locations
x
x
x
x
x

x
x
x

Waste Management
x
x
x
x

x

Lessons Learned
x
x

x
x

______________________________________________________________________________
     A    Beryllium exposed and potentially exposed workers (includes employees working directly with beryllium, maintenance workers, waste
     workers, laundry staff, etc.)      
     B    Line Supervisors                                  
     C    Management                                   
     D    Industrial Hygiene Staff
     E    Medical Personnel
     F    Workers in areas adjacent to beryllium restricted-access areas
G    Emergency Responders 
H    Procurement Staff 
I    Planners
J    General Site Personnel
K    Visitors

*The content of each topic could vary depending on the group receiving the training.                                TRAINING MATRIX BY LEVEL

LEVEL

*TOPIC
I
II
III
IV

CBDPP
x
x
x
x

Goals
x

x

Performance Measures
x

x

Health Effects
x
x
x
x

Physical Properties
x
x

MSDS
x
x

Methods to detect the presence or release
x
x

Exposure Reduction/Minimization
x
x
x

Labeling/Warnings Signs
x
x

x

Exposure Monitoring
x

Standards
x
x
x

Use & Limitations of PPE
x
x

Medical Surveillance
x

x

Hazard Assessments
x

Analytical Techniques
x

Assessment of Risk
x

x

Activity/Process Descriptions
x

x

Activity/Process Locations
x
x
x
x

Waste Management
x

x

Lessons Learned
x

____________________________________________________________________________________
     I    Beryllium exposed and potentially exposed workers                
                                                                           (includes employees working directly with beryllium,             
          maintenance workers, waste workers, laundry staff, etc.)         
          Line Supervisors                                  
          Industrial Hygiene Staff                     
          Medical Personnel
          Planners
     II   Workers in areas adjacent to beryllium restricted-access areas 
     Emergency Responders
     Procurement Staff
     Visitors
III  Management
IV   General Site Personnel                                
                                
                                
                                
                           APPENDIX D
                                
                  TRAINING RESOURCE MATERIALS

                           APPENDIX D

                  TRAINING RESOURCE MATERIALS

As of the publication date of this guide, DOE's Training Resources and Data Exchange
(TRADE) is developing a Beryllium Health Risk Communication Prototype specifically to assist
in implementing CBDPPs.

The following two videos are endorsed by DOE's Office of Worker Health and Safety:
       1. Beryllium Disease, EG&G, Inc., Rocky Flats Plant, September, 1993
       2. Beryllium, Course No. HPH107, DOE Environment Safety and Health, May 28, 1997
The following list of items was submitted by Brush Wellman Inc. in response to the Department
of Energy's request for information relevant to a DOE beryllium standard.  The list includes
items that would be useful as training materials.  These materials have not been reviewed for
accuracy or regulatory compliance, and their inclusion should not be considered an endorsement
by DOE.  All of these items are Brush Wellman Inc. products unless otherwise noted.  Brush
Wellman makes the following disclaimer:  "Brush Wellman, Inc. (BWI) materials and
information are specific to Brush Wellman's operations and products.  This information should
only be used as a reference in developing other materials.  In providing this information, BWI is
not undertaking any responsibility for Department of Energy (DOE) facilities or employees, or its
industrial hygiene, safety or work practices and expressly disclaims any responsibility.  It remains
DOE's sole responsibility and obligation to take those actions necessary to protect its employees
from exposures to airborne beryllium particulate."

  1. Video:  Beryllium Alloys Safe Handling
  2. Video:  Beryllium Metals Safe Handling
  3. Video:  Beryllia Ceramics Safe Handling
  4. Video:  Working Safely with Beryllium
  5. Material Safety Data Sheets
  6. Flash Cards:  Copper Beryllium Machining Operations
  7. Beryllium Surface Sampling Procedure
  8. Guide to Beryllium Copper
  9. Machining Beryllium Copper
10.  Beryllium Copper Casting and Master Alloys
11.  MoldmaxR /ProthermR Health and Safety Hints
     12.  Potential Beryllium Exposure While Processing Beryllium Ceramics for Electronic
     Applications
13.  Hazard Materials Minimization Program in Government Electronic Ceramics
     14.  Editorial:  Re:  The Epidemiological Evidence on the Carcinogenicity of Beryllium by
     MacMahon
     15.  Federal Register:  EPA National Emission Standards for Hazardous Air Pollutants: 
     Asbestos, Beryllium and Mercury
16.  Health, Safety and Environmental Policy
17.  ES&H News:  Special Edition
18.  High Velocity - Low Volume Ventilation System
19.  Medical Facts:  Beryllium Disease by National Jewish Center
20.  Beryllium - Its Industrial Hygiene Aspects
     21.  Health Protection in Beryllium Facilities - Summary of Ten Years of Experience by
     USAEC Health and Safety Laboratory
22.  Wipe Test of Surface Dust on Beryllium Shapes or Containers
23.  Safety Facts:  Thin Film Processing
24.  Safety Facts:  Destructive Testing
25.  Safety Facts:  Machining
26.  Safety Facts:  Laser Operations
27.  Safety Facts:  Regulatory
28.  Safety Facts:  Disposal
29.  Safety Facts:  Thick Film Processing
30.  Safety Facts:  Safety Practices for Welding Beryllium Copper
31.  Safety Facts:  Safety Practices for Handling AlBeMETR Products
32.  Safety Facts:  Safety Practices of Sanding and Grinding Beryllium Copper Parts
33.  Safety Facts:  Safety Practices for Buffing and Polishing Beryllium Copper Parts
34.  Safety Facts:  Safety Practices for Electrical Discharge Machining Beryllium Copper
35.  Safety Facts:  Safety Practices for Heat Treating Beryllium Copper Parts
36.  Safety Facts:  Respiratory Protection for Processing Beryllium-containing Materials
37.  Safety Facts:  Airborne Beryllium Exposure Standards
38.  Safety Facts:  Ventilation of Beryllium Dust Generating Operations
39.  Safety Facts:  Safety Practices for Stamping and Plating Beryllium Copper
     40.  Safety Facts:  Safety Practices for Machining Beryllium Copper (Drilling, Boring,
     Milling, Turning, Tapping, Reaming and Sawing)
41.  Safety Facts:  Beryllium Copper Foundry Safety Practices
42.  Safety Facts:  Health Effects Related to Beryllium Exposure
     43.  Safety Facts:  Safety Practices for Handling and Disposal of Electronic Components
     Containing Beryllium Copper
44.  EH&S Corporate Standard:  Respiratory Protection
45.  Safe Practice Procedure: Maintenance Work on Be-contaminated Equipment
46.  Safe Practice Procedure:  Plant Housekeeping Program
47.  Safe Practice Procedure:  New and Transferred Employee Safety Training Program
48.  Safe Practice Procedure:  Welding and Burning Permit System
     49.  Safe Practice Procedure:  Procedure for Managing Solid Wastes Contaminated with
     Metallic Beryllium and Beryllium Compounds
     50.  Safe Practice Procedure:  Transportation Accidents Involving Powdered Beryllium
     Products
51.  Safe Practice Procedure:  Visitors and Contractors 
     52.  Safe Practice Procedure:  Air Cleaning Equipment Operations, Inspection and
     Maintenance
53.  Safe Practice Procedure:  Supervisor's Investigation of High Air Count Values
54.  Safe Practice Procedure:  Serious Air Contamination
55.  Industrial Hygiene Procedure:  Control Areas
56.  Industrial Hygiene Procedure:  Control of Contaminated Equipment Leaving Plant Site
57.  Plant Housekeeping
58.  Customer Form Letter #30:  Building/Equipment Decontamination 
59.  Memo:  Supplement to Safety Practice Procedure 8.6 Entitled, Visitors and Contractors
60.  Memo:  3000# Arc Furnace Bay Entry and Work Practices
     61.  Memo:  Whiting Furnace and Ladle Bay Entry and Decontamination Practices for
     Maintenance and Production Activities
62.  Memo: Re-drumming Beryllium-containing By-Products or Wastes
     63.  Memo:  Revised - Air Cleaning/Product Collecting Equipment Bat/Cartridge Changes
     and System Maintenance
64.  Memo:  Work Practice Clarification for Working Near Ceiling Structures
65.  Janitorial Maintenance Guidelines
66.  Respirator Use/Facial Hair Limitations Policy
67.  Memo:  MSA Spectacle Kits
68.  Employee Guideline for Using Airline Respiratory Protection Equipment
69.  Air Sampling Philosophy
70.  Guiding Principles
71.  Air Sampling Trains
72.  Face Velocities
73.  Sampling Rates vs Face Velocity
74.  Air Sampler Calibration Procedure
75.  Characterization of Potential PO15 Wastes
76.  Customer Letter on Copper Beryllium as Hazardous Waste
77.  Designing with Beryllium
78.  Producing Defect-free Beryllium and Beryllium Oxide                                
                                
                                
                                
                                
                                
                                
                                
                           APPENDIX E
                                
         DOE DIRECTIVES CITATIONS RELEVANT TO THE CBDPP
                                
             CROSSWALK TO APPLICABLE DOE DIRECTIVES
                           APPENDIX E

         DOE DIRECTIVES CITATIONS RELEVANT TO THE CBDPP

             CROSSWALK TO APPLICABLE DOE DIRECTIVES

The following matrix provides a crosswalk of the guidance provided in G 440.1-7 to those DOE
Directives (Orders, Notices, and Guides) and DOE Technical Standards relating to the CBDPP.

DOE G 440.1-7 
Paragraph No.

DOE *

Requirement and Associated Guidance

III.4.1
Written Program
O 440.1
4.a. and Attachment 2, 1:  Implement a written worker protection program that:..provides a
place of employment free from recognized hazards that are causing or are likely to cause
death or serious physical harm to their employees; and...integrates all requirements
contained in paragraphs 4a through 4l of this Order; program requirements, contained in
Title 29 Code of Federal Regulations (CFR) Part 1960, "Basic Program Elements for
Federal Employee Occupational Safety and Health Programs and Related Matters";
applicable functional area requirements contained in Attachment 1; and other related site-
specific worker protection activities.

4.b and Attachment 1, 2:  Establish written policy, goals, and objectives for the worker
protection program.

Attachment 2, 18.a.(2):  A formal, written contractor occupational medical program
detailing the methods and procedures used to implement the occupational medical
requirements necessary for worker protection and the promotion of a healthful work
environment shall be established, maintained, reviewed, and updated.

N 440.1
4.b.:  Include in the CBDPP written plans, schedules, and other measures for achieving the
objectives and requirements of this Notice.  The program shall address, at a minimum, the
following elements:  baseline inventory and sampling, hazard assessment,  medical
surveillance, exposure monitoring, training, exposure reduction and minimization,
recordkeeping, and performance feedback.

Attachment 1, 4.a. and Attachment 2, 6.d.(1):  Developing a documented program that
includes exposure reduction and minimization goals using a risk-based (tailored) approach,
a plan for meeting goals, measures that will be used to assess status of attaining goals, and
the rationale for determining reduced and minimized exposures.

Attachment 1, 4.e.:  Documenting the rationale used for determining reduced and
minimized exposures.

Attachment 2, 4.:  Include in the CBDPP written plans, schedules, and other measures for
achieving the objectives of DOE Notice 440.1 and requirements of this CRD.  The program
shall address at a minimum, the following:  baseline inventory and sampling, hazard
assessment, exposure monitoring, medical surveillance, training, exposure reduction and
minimization, recordkeeping, and performance feedback.  The CBDPP shall be approved
by the contractor's site senior health and safety executive and the Head of the DOE Field
Organization.

III.4.2
Occupational
Exposure Limits
O 440.1
4.l(1):  Comply with the following worker protection requirements:  American Conference
of Governmental Industrial Hygienists (ACGIH), "Threshold Limit Values for Chemical
Substances and Physical Agents and Biological Exposure Indices" (most recent edition),
when ACGIH Threshold Limit Values (TLVs) are lower (more protective) than
Occupational Safety and Health Administration (OSHA) Permissible Exposure Limits. 
[When ACGIH TLVs are used as exposure limits, DOE operations shall nonetheless
comply with the other provisions of any applicable OSHA-expanded health standard.]  The
TLVs for exposures to laser emissions in the ACGIH Indices are excluded from this
requirement.

Attachment 2, 12.a,e:  Comply with the following worker protection requirements: a. Title
29 of the Code of Federal Regulations (CFR), Part 1910, "Occupational Safety and Health
Standards,"  . . . e. Title 29 CFR, Part 1926, "Safety and Health Regulations for
Construction." 

N 440.1
Attachment 1, 4.b. and Attachment 2, d.(2).:  Using administrative action levels that trigger
actions to reduce or minimize worker exposure and the potential for exposures.

G 440.1-3
4.4.6.2:  The Administrative Control Limit is a useful statistical tool for providing
confidence that exposures are acceptable.  Usually, an initial ACL set at 10% to 25% of the
OEL is used until sufficient data are obtained to generate a statistically valid exposure
profile.  (See the AIHA Exposure Assessment Strategy document for a discussion of
"trigger points" and details on obtaining statistically significant sampling.)  If the ACL is
not exceeded, then it can be reasonably assumed that the actual exposures are acceptable
with respect to the OEL and additional exposure monitoring may not be needed

III.4.4
Teaming
O 440.1
4.e.:  Encourage the involvement of employees in the development of program goals,
objectives, and performance measures and in the identification and control of hazards in the
workplace.

Attachment 2, 17.g.:  Coordination with cognizant occupational medical, environmental,
health physics, and work planning professionals.

Attachment 2, 18.a.(4):  To carry out this goal, the contractor occupational medical
professional staff shall participate as members of a worker protection team.

III.4.5.1
Goals for Exposure
Reduction and
Minimization
N 440.1
Attachment 1, 4:  Exposure Reduction and Minimization.  Manage and control exposures
to beryllium by: reducing airborne levels of beryllium as-low-as-practical, minimizing the
number of current workers exposed and potentially exposed to beryllium, minimizing the
number of opportunities to be exposed, and setting reasonable exposure reduction and
minimization goals using a risk-based (tailored) approach.

Attachment 1, 4.a:  Developing a documented program that includes exposure reduction
and minimization goals using a risk-based (tailored) approach, a plan for meeting goals,
measures that will be used to assess status of attaining goals, and the rationale for
determining reduced and minimized exposures. 

III.4.7
Labor Relations
Requirements
N 440.1
5.f:  Modify the requirements of this Notice for a contractor or subcontractor when
necessary to accommodate the obligations of a contractor whose employees are represented
for collective bargaining purposes by a labor organization consistent with the requirements
of the National Labor Relations Act.

III.4.8
Qualified Personnel
O 440.1
4.c:  Use qualified worker protection staff to direct and manage the worker protection
program.

Attachment 2, 17.k:  Professionally and technically qualified industrial hygienists to
manage and implement the industrial hygiene program.

Attachment 2, 18.i.(1):  The physician responsible for the delivery of medical services shall
be a graduate of a school of medicine or osteopathy who meets the licensing requirements
applicable to the location in which the physician works.

Attachment 2, 18.i.(2):  Occupational medical physicians, occupational health nurses,
physician's assistants, nurse practitioners, psychologists, and other occupational health
personnel shall be graduates of accredited schools and shall be licensed, registered, or
certified as required by Federal or State law where employed.

N 440.1
3.a: Conduct comprehensive inventory and hazard assessments for beryllium by qualified
professional industrial hygienists to ensure that current workers not involved with beryllium
activities or processes and the public are not exposed to beryllium.

Attachment 2, 6: Ensure all aspects of the CBDPP are managed and implemented by
professionally and technically qualified industrial hygienists and medical personnel.

G 440.1-4
4.8.1:  Physicians who are providing occupational medical services to contractor
employees need to have a degree from an accredited school of medicine or osteopathy and
meet the licensing requirements applicable to the locations in which they work.  Board
certification in occupational medicine is preferred.  It is desirable that the responsible
physician report to the contractor site manager, appropriate laboratory director, or another
management level with sufficient authority to participate in health and environmental issues
at policy-making levels to ensure program effectiveness.  They should be afforded
opportunities for continuing education, including attendance at professional meetings.

4.8.2:  It is recommended that occupational health nurses, physician's assistants, nurse
practitioners, and other occupational health personnel be graduates of accredited schools,
licensed, registered, or certified, and legally qualified to practice by Federal or State law
where employed.  They should be afforded opportunities for continuing education,
including attendance at professional meetings.

IV.1.3.1
Baseline Inventory
O 440.1
4.i:  Identify existing and potential workplace hazards and evaluate the risk of associated
worker injury or illness.

Attachment 1, 5.a:  Initial or baseline surveys of all work areas or operations to identify and
evaluate potential worker health risks.

N 440.1
Attachment 1,1:  Develop a baseline inventory of beryllium locations and operations;
identify exposed and potentially exposed workers by location; and conduct sampling.

G 440.1-3
4.4.1:  (The section provides guidance about initial hazard identification as the first step in
determining potential worker exposures.) 

IV.1.3.2
Sampling
O 440.1
4.i.2-3:  Assess worker exposure to chemical, physical, biological, or ergonomic hazards
through appropriate workplace monitoring (including personal, area, wipe, and bulk
sampling), biological monitoring, and observation.  Monitoring results shall be recorded. 
Documentation shall describe the tasks and locations where monitoring occurred, identify
workers monitored or represented by the monitoring, and identify the sampling methods
and durations, control measures in place during monitoring (including the use of personal
protective equipment), and any other factors that may have affected sampling results.
Evaluate workplaces and activities accomplished routinely by workers, supervisors, and
managers and periodically by qualified worker protection professionals.

Attachment 1, 5.a,c and d:  Initial or baseline surveys of all work areas or operations to
identify and evaluate potential worker health risks.  Periodic resurveys and/or exposure
monitoring as appropriate.  Documented exposure assessment for chemical, physical, and
biological agents and ergonomic stressors using recognized exposure assessment
methodologies and use of accredited industrial hygiene laboratories.

N 440.1
Attachment 1, 1:  Develop a baseline inventory of beryllium locations and operations;
identify exposed and potentially exposed workers by location; and conduct sampling.

G 440.1-3
4.4.6:  (The section provides guidance about conducting qualitative exposure monitoring,
including development of exposure profiles, identification of exposure groups, and use of
administrative control limits.)

IV.2
Hazard Assessment
O 440.1
4.i.(1):  Analyze or review: (a) designs for new facilities and modifications to existing
facilities and equipment; (b) operations and procedures; and (c) equipment, product, and
service needs.

4.i.(3):  Evaluate workplaces and activities accomplished routinely by workers, supervisors,
and managers and periodically by qualified worker protection professionals.

4.i.(4):  Report and investigate accidents, injuries, and illnesses (reference DOE O 231.1,
232.1, and 225.1) and analyze related data for trends and lessons learned (reference DOE
O 210.1).

N 440.1
Attachment 1, 2a.-c.:  a.  Conduct a beryllium hazard assessment and determine whether in-
depth analysis is warranted... b.  Conduct in-depth analysis, where appropriate, to ascertain
the nature of the exposure risk to beryllium...  c.  Include in the beryllium hazard
assessment an analysis of existing conditions, exposure data, medical surveillance trends,
and the exposure potential of planned activities.

G 440.1-1
4.3.1:  (This section discusses the types of analyses and reviews that can be useful in
identifying and evaluating hazards.)

4.3.3:  (This section gives guidance on effective approaches to routine evaluation of
workplaces and activities.)

G 440.1-3
4.4.6:  (The section provides guidance about conducting qualitative exposure monitoring,
including development of exposure profiles, identification of exposure groups, and use of
administrative control limits.)

IV.3
Exposure Monitoring
O 440.1
4.i.(2):  Assess worker exposure to chemical, physical, biological, or ergonomic hazards
through appropriate workplace monitoring (including personal, area, wipe, and bulk
sampling), biological monitoring, and observation.  Monitoring results shall be recorded. 
Documentation shall describe the tasks and locations where monitoring occurred, identify
workers monitored or represented by the monitoring, and identify the sampling methods
and durations, control measures in place during monitoring (including the use of personal
protective equipment), and any other factors that may have affected sampling results.

Attachment 1, 5c:  Periodic resurveys and/or exposure monitoring as appropriate.

N 440.1
Attachment 1, 3.a-f and Attachment 2, 7.c.(1)-(6):  (1):  Identify the operations and areas in
which workers must be monitored...Conduct personal breathing zone sampling for all
workers exposed and potentially exposed to beryllium, or provide the rationale for
monitoring a limited subset of workers...Conduct area sampling where appropriate to
determine operational control...Conduct surface sampling to determine housekeeping
conditions and to identify contamination that has the potential to become
airborne...Establish the required frequency of monitoring by using a risk-based (tailored)
approach...Require additional monitoring when warranted due to changes in operations or
procedures, or as necessary to ensure that exposure reduction and minimization goals are
met.

G 440.1-3
4.2-4.5:  (These sections contain guidance about exposure assessment approaches,
conducting qualitative exposure assessments, and conducting quantitative exposure
assessments.)

IV.3.3.1
Personal Air
Monitoring
N 440.1
Attachment 1,3.b., f. and Attachment 2, 7.c.(2), (6):  Conduct personal breathing zone
sampling for all workers exposed and potentially exposed to beryllium, or provide the
rationale for monitoring a limited subset of workers...Require additional monitoring when
warranted due to changes in operations or procedures, or as necessary to ensure that
exposure reduction and minimization goals are met.

IV.3.3.2
Area Air Monitoring
N 440.1
Attachment 1,3.c. and Attahcment 2, 7.c.(3):  Conduct area sampling where appropriate to
determine operational control.
IV.3.3.3
Surface Monitoring
N 440.1
Attachment 1, 3.d and Attachment 2, 7.c.(4):  Conduct surface sampling to determine
housekeeping conditions and to identify contamination that has the potential to become
airborne.

IV.4
Exposure Reduction
and Minimization
O 440.1
4.j:  Implement a hazard prevention/abatement process to ensure that all identified hazards
are managed through final abatement or control.

4.j(1):  For hazards identified either in the facility design or during the development of
procedures, controls are incorporated in the appropriate facility design or procedure.

4.j(2):  For existing hazards identified in the workplace, abatement actions prioritized
according to risk to the worker are promptly implemented, interim protective measures are
implemented pending final abatement, and workers are protected immediately from
imminent danger conditions.

4.j(3):  Hazards are addressed when selecting or purchasing equipment, products, and
services.

4.j(4):  Hazard control methods are selected based on the following hierarchy: (a)
Engineering controls. (b) Work practices and administrative controls that limit worker
exposures. (c) Personal protective equipment.

4.l(1):  Comply with the following worker protection requirements:  American Conference
of Governmental Industrial Hygienists (ACGIH), "Threshold Limit Values for Chemical
Substances and Physical Agents and Biological Exposure Indices" (most recent edition),
when ACGIH Threshold Limit Values (TLVs) are lower (more protective) than
Occupational Safety and Health Administration (OSHA) Permissible Exposure Limits. 
[When ACGIH TLVs are used as exposure limits, DOE operations shall nonetheless
comply with the other provisions of any applicable OSHA-expanded health standard.]  The
TLVs for exposures to laser emissions in the ACGIH Indices are excluded from this
requirement.

Attachment 1, 5.b:  . . . Industrial hygiene programs shall include . . . coordination with
planning and design personnel to anticipate and control health hazards that proposed
facilities and operations would introduce.

Attachment 1, 5.e:  Specification of appropriate engineering, administrative, work practice,
and/or personal protective control methods to limit hazardous exposures to acceptable levels. 

Attachment 2, 12.a,e:  Comply with the following worker protection requirements: a. Title 29
of the Code of Federal Regulations (CFR), Part 1910, "Occupational Safety and Health
Standards,"  . . . e. Title 29 CFR, Part 1926, "Safety and Health Regulations for Construction."

IV.4
Exposure Reduction
and Minimization
(cont.)
N 440.1
Attachment 1,4.a-e and Attachment 2, 7. d. (1)-(5):  Elements of reduction and
minimization strategies include:  Developing a documented program that includes exposure
reduction and minimization goals using a risk-based (tailored) approach, a plan for meeting
goals, measures that will be used to assess status of attaining goals, and the rationale for
determining reduced and minimized exposures...Using administrative action levels that
trigger actions to reduce or minimize worker exposure and the potential for
exposures...Establishing contamination control to preclude exposures to the extent
practical...Implementing work control strategies to reduce exposures to as low as practical
using the established hierarchy of industrial hygiene controls (i.e., engineering and
administrative controls, and personal protective equipment) to reduce the potential for
worker exposure...Documenting the rationale used for determining reduced and minimized
exposures.

G 440.1-1
4.4:  (This section contains guidance for implementing a hazard prevention/abatement
process to ensure that all identified hazards are managed through final abatement or
control.)

G 440.1-3
4.6.1.2:  (This section explains how exposure reduction goals for individuals and groups
should be established and tracked for each significant risk group to help reduce exposures.
It gives some suggested questions that should be considered in measuring management's
performance in conducting exposure assessment.)

IV.4.3.1
Goals, Plans, and
Performance
Measures
O 440.1
4.b:  Establish written policy, goals, and objectives for the worker protection program.

N 440.1
Attachment 1, 4 and Attachment 2, 7.d.:  Exposure Reduction and Minimization.  Manage
and control exposures to beryllium by: reducing airborne levels of beryllium as-low-as
practical, minimizing the number of current workers exposed and potentially exposed to
beryllium, minimizing the number of opportunities to be exposed, and setting reasonable
exposure reduction and minimization goals using a risk-based (tailored) approach.

Attachment 1, 4.a and Attachment 2, 7.d.(1):  Developing a documented program that
includes exposure reduction and minimization goals using a risk-based (tailored) approach,
a plan for meeting goals, measures that will be used to assess status of attaining goals, and
the rationale for determining reduced and minimized exposures. 

G 440.1-3
4.6.1.2:  (This section explains how exposure reduction goals for individuals and groups
should be established and tracked for each significant risk group to help reduce exposures.
It gives some suggested questions that should be considered in measuring management's
performance in conducting exposure assessment.)

IV.4.3.2
Administrative
Action Levels
N 440.1
Attachment 1, 4.b and Attachment 2, 7.d.(2):  Using administrative action levels that trigger
actions to reduce or minimize worker exposure and the potential for exposures.

G 440.1-3
4.4.6.2:  (This section explains the concept of administrative control limits.)

IV.4.3.3.1
Engineering Controls
O 440.1
4.j(4)(a):  Hazard control methods are selected based on the following hierarchy:
Engineering controls, . . . 

N 440.1
Attachment 1, 4.d and Attachment 2, 7.d.(4):  Implementing work control strategies to
reduce exposures to as low as practical using the established hierarchy of industrial hygiene
controls (i.e., engineering and administrative controls, and personal protective equipment)
to reduce the potential for worker exposure.

IV.4.3.3.1
Engineering Controls
(cont.)
G 440.1-1
4.4.4.1:  Where controls are necessary to reduce worker risk from exposure to workplace
hazards, engineering controls should be implemented to the extent feasible.  Principal
engineering controls include: substituting a less hazardous substance or process, enclosing
a hazard, locating hazardous operations or equipment in remote and/or unoccupied areas,
establishing physical barriers and guards, and using local and general exhaust ventilation.

G 440.1-3
4.6.3:  (This section discusses the role of exposure assessment in exposure prevention and 
hazard control.)

IV.4.3.3.2
Administrative
Controls
O 440.1
4.j(4)(b):  Work practices and administrative controls that limit worker exposures.

N 440.1
Attachment 1, 4.d and Attachment 2, 7.d.(4):  Implementing work control strategies to
reduce exposures to as low as practical using the established hierarchy of industrial hygiene
controls (i.e., engineering and administrative controls, and personal protective equipment)
to reduce the potential for worker exposure.

G 440.1-1
4.4.4.2:  The effectiveness of work practice and administrative controls depends on the
ability of line management to make employees aware of established work practices and
procedures, to reinforce them, and to provide consistent and reasonable enforcement. 
Administrative controls include: written operating procedures, safety work practices, and
work permits; exposure time limitations; limits on the use of hazardous materials and
monitoring of such operations; health and safety plans; altered work schedules, such as
working in the early morning or evening to reduce the potential for heat stress; and training
employees in methods of reducing exposure.

G 440.1-3
4.6.3:   (This section discusses the role of exposure assessment in exposure prevention and 
hazard control.)

IV.4.3.3.3
Personal Protective
Equipment
O 440.1
4.j(4)(c):  Personal protective equipment.

4.l(3): Comply with . . . American National Standards Institute Z88.2, "Practices for
Respiratory Protection."

N 440.1
Attachment 1, 4.d and Attachment 2, 7.d.(4):  Implementing work control strategies to
reduce exposures to as low as practical using the established hierarchy of industrial hygiene
controls (i.e., engineering and administrative controls, and personal protective equipment)
to reduce the potential for worker exposure.

IV.4.3.3.3
Personal Protective
Equipment
(cont.)
G 440.1-1
4.4.4.3:  When engineering and/or administrative controls have been considered and
implemented and are not sufficient to fully protect the worker from a recognized hazard,
personal protective equipment can be used to supplement these other controls as
appropriate.  PPE is acceptable as a control method: to supplement engineering, work
practice, or administrative controls when such controls are not feasible or do not adequately
reduce the hazard; as an interim measure while engineering controls are being developed
and implemented; during emergencies when engineering controls may not be feasible; and
during maintenance and other non-routine activities where other controls are not feasible. 
The use of PPE can itself create significant worker hazards, such as heat stress, physical
and psychological stress, and impaired vision, mobility, and communication.  An example
would be a worker wearing several layers of clothing (for warmth and anti-contamination),
a respirator, gloves, and a helmet while welding or cutting.  This arrangement of PPE could
prevent the worker from being aware of the environment in the event of a fire or other
emergency.  Research has also confirmed that fabric assemblies with high percentages of
cotton fiber in their outer wear and/or underwear layers and no air space between layers
yielded the highest maximum heat transfer rate and total heat transfer.  These assemblies
have more burn potential than assemblies containing higher amounts of polyester and more
space between layers.  In these situations, engineering and/or administrative controls (e.g.,
a fire watch to ensure the safety of the worker as well as the property) should be
implemented to supplement PPE.  Equipment and clothing should be selected that provide
an adequate level of protection.  The selection process should involve representatives of the
affected safety disciplines (e.g., health physicist, industrial hygienist, fire protection staff,
etc.) working in concert.  Two basic objectives of any PPE practice should be to protect the
wearer from safety and health hazards, and to prevent injury to the wearer from incorrect
use and/or malfunction of the PPE.  To accomplish these objectives, a comprehensive PPE
practice should include hazard identification (hazards that PPE will protect against and
hazards caused by the use of PPE), medical monitoring, environmental surveillance,
selection, use, maintenance, and decontamination of PPE and its associated training.

G 440.1-3
4.6.3:   (This section discusses the role of exposure assessment in exposure prevention and 
hazard control.)

IV.5
Medical Surveillance
O 440.1
Attachment 2, 18.c(1)(c)-(e):  Occupational medical physicians and selected medical staff
shall: . . .   perform targeted examinations based on an up-to-date knowledge of work site
risk,. . . (d) identify potential or actual health effects resulting from work site exposures,
and (e) communicate the results of health evaluations to management and to those
responsible for mitigating work site hazards.

Attachment 2, 18.d(1):  Health examinations shall be conducted by an occupational health
examiner under the direction of a licensed physician in accordance with current sound and
acceptable medical practices.

Attachment 2, 18.d(2):  The content of health examinations shall be the responsibility of
the physician responsible for delivery of medical services.

Attachment 2, 18.d(3)(d):  The following classes of examinations are required . . . medical
surveillance and health monitoring.

Attachment 2, 18.d(4):  The occupational medical department shall be informed of all job
transfers and shall determine whether a medical evaluation is necessary.

Attachment 2, 18.e(1):  The occupational medical program shall be responsible for the
review of all monitored care of ill and injured employees to maximize their recovery and
safe return to work, and to minimize lost time and its associated costs.

Attachment 2, 18.g(1)-(3):  An employee medical record shall be developed and
maintained for each employee for which medical services are provided.  The confidentiality
of all employee medical records shall be observed.  Employee medical records shall be
adequately protected and stored permanently.

N 440.1
Attachment 1, 5.a.-d. and Attachment 2, 7.e.(1)-(4):  Offer to enroll in a medical
surveillance program all workers at risk for chronic beryllium disease (CBD) due to
exposure or potential exposure to beryllium...Maintain an updated roster of workers at risk
for CBD...Conduct pulmonary medical histories and lung function tests as part of the 
preplacement examination for workers to be assigned to beryllium areas.  If the
occupational medicine physician concludes that the medical history and the lung function
test results warrant a chest x-ray, it must be offered to the worker...Provide on a voluntary
basis, beryllium-specific peripheral blood lymphocyte proliferation testing, or other
available preferred beryllium-specific tests considered appropriate by an occupational
medicine physician, to screen for beryllium sensitization and provide early detection of
CBD.  Physicians must notify workers of the procedures and associated risks of the
tests...Workers' occupational histories and clinical stages of the disease must be included in
investigation reports of recordable beryllium disease (see DOE Order 231.1).  Contact
DOE (EH-6) for guidance on the content of the reports.  Send copies of reports to DOE
(EH-6).

G 440.1-3
4.6.2:  (This section discusses the role of exposure assessment in occupational medicine
and medical monitoring.)

IV.5
Medical Surveillance
(cont.)
G 440.1-4
4:  (This section contains guidelines for an occupational medical program, including
implementation of an onsite program, maintenance of a healthful work environment,
employee health evaluations, diagnosis and treatment of injury or disease, medical records,
organization, staffing, facilities, and equipment.)

4.3.2:  The medical professional responsible for the occupational medical program should
have responsibility for health evaluation content.  Initial or baseline evaluations should be
comprehensive, and follow-up evaluations should be additionally targeted as determined by
employee exposure data, job task and hazard analysis information, or other occupationally
related factors.  Minimum elements of a comprehensive evaluation are:
medical/occupational history, physical examination, laboratory studies, and review and
evaluation of findings.  The protocols for x-ray examinations should follow the
recommendations and guidance contained in 43 FR 4377, dated 2-1-78.  All radiographs
should be interpreted by a qualified radiologist or as specified by OSHA/DOE.

4.3.3.2:  Standards and requirements for special health evaluations and health monitoring
of employees who work in jobs involving specific physical, chemical, or biological hazards
should be in accordance with applicable OSHA/DOE standards.  When employees are
exposed to potential hazards not covered by regulations, appropriate special evaluations
may be required as determined by the physician responsible for medical services and
approved by the DOE Director, Office of Occupational Medicine and Medical
Surveillance.

4.3.3.5:  All employees with occupationally related injuries or illnesses should be evaluated
before returning to work.  The scope and content of this evaluation should be determined
by the OHE, based upon the nature and extent of the injury or disease, and should be
sufficient to ensure that the employee may return to work without undue health risk to self
or others.  The employee should obtain written clearance from the occupational medical
department before returning to work.

4.4.1:  The management of occupational injury or disease should be in accordance with the
laws and regulations of the state in which the facility is located.  Diagnosis and treatment of
occupational injury or disease should be prompt, with emphasis placed on rehabilitation
and
return to work at the earliest time compatible with job safety and employee health.  Contractor
management has the responsibility to establish procedures to ensure that all employees with
occupational injuries or illnesses receive medical clearance before returning to work.  The
responsible first-line management and health and safety groups (health physics, industrial
hygiene, or safety) should be notified of unhealthy work situations detected by the
occupational medical staff.

IV.6
Training
O 440.1
4.k: Provide workers, supervisors, managers, visitors, and worker protection professionals
with worker protection training.

Attachment 1, 5.f:  Industrial hygiene programs shall include the following elements: . . .
Worker education, training, and involvement.

IV.6
Training
(cont.)
N 440.1
Attachment 1, 6 and Attachment 2, 7.f.:  Implement a training program that provides
workers exposed and potentially exposed to beryllium, and supervisors, managers, medical
personnel, industrial hygienists, and others involved in beryllium activities and processes,
with information concerning the proper handling and control of beryllium, hazards of
exposure to beryllium, controls (e.g., engineering, administrative, and personal protective
equipment) and work practices of the job assignment, minimization of worker exposure, the
purpose and use of personal protective equipment, medical monitoring, and waste
management and decontamination procedures. 

G 440.1-1
4.5:  (This section contains guidance on providing worker protection training and refers to
other training requirements in DOE O 360.1 and 29 CFR 1960, Subpart H.)

IV.7
Recordkeeping

O 440.1
4.i(4):  Report and investigate accidents, injuries, and illnesses (reference DOE O 231.1,
232.1, and 225.1) and analyze related data for trends and lessons learned (reference DOE
O 210.1).

N 440.1
Attachment 1, 7 and Attachment 2, 7.g.:  Maintain records of all beryllium inventory
information, hazard assessments, exposure measurements, controls, and medical
surveillance pursuant to DOE Order 440.1, paragraph 4.i.(2), to demonstrate program
effectiveness...  Maintain the records in an electronic, easily retrievable manner for
transmittal to DOE Headquarters on request...  Create links between data sets on working
conditions and health outcomes to serve as a basis for understanding the beryllium health
risk.

G 440.1-1
4.3.4:  (This section contains guidance on recordkeeping, reporting, and data analysis for
accidents, injuries, and illnesses.) 

IV.8
Performance
Feedback
O 440.1
4.I(4):  Report and investigate accidents, injuries, and illnesses (reference DOE O 231.1,
232.1, and 225.1) and analyze related data for trends and lessons learned (reference DOE
O 210.1).

Attachment 1, 5.g:  Industrial hygiene programs shall include . . . coordination with
cognizant occupational medical, environmental, health physics, and work planning
professionals.

Attachment 2, 18.c(1)(a),(e):  Occupational medical physicians and selected medical staff
shall: (a) coordinate with other safety and health professionals (industrial hygienists, health
physicists, safety specialists/managers) to identify work-related or work site hazards and
their possible health risks to employees, . . . (e) communicate the results of health
evaluations to management and to those responsible for mitigating work site hazards.

Attachment 2, 18.c(2)(a)-(c):  Contractor management shall provide to the physician
responsible for delivery of medical services: (a) employee job task and hazard analysis
information; (b) summaries of potential work site exposures of employees prior to
mandatory health examinations; and (c) the opportunity to participate in worker protection
team meetings and committees.

N 440.1
Attachment 1, 8 and Attachment 2, 7.h.:  Conduct periodic analysis and assessment of
monitoring results, hazards identified, medical surveillance results, attainment of exposure
reduction and minimization goals, and occurrence reporting data...Feed back results to line
managers, planners, worker protection staff, workers, medical staff, and others to ensure
that needed information is available to improve all elements of the CBDPP continuously.

IV.8
Performance
Feedback
(cont.)
G 440.1-1
4.3.4:  (This section contains guidance on recordkeeping, reporting, and data analysis for
accidents, injuries, and illnesses.) 

                    * DOE O 440.1       Worker Protection Management for DOE Federal and Contractor Employees
                      DOE N 440.1       Interim Chronic Beryllium Disease Prevention Program
                           DOE G 440.1-1          Worker Protection Management for DOE Federal and Contractor Employees Guide 
                           DOE G 440.1-3          Occupational Exposure Assessment 
                           DOE G 440.1-4          Occupational Medical Program

<<EOD>>                                                    DOE G 440.1-7