GAO

United States General Accounting Office

Report to Congressional Requesters

May 2000 OCCUPATIONAL

SAFETY AND

HEALTH

Government

Responses to

Beryllium Uses and

Risks

GAO/OCG-00-6

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Contents

Letter 3

Appendixes Appendix I: Objectives, Scope, and Methodology 22

Appendix II: Comments From the Department of Energy 24

Appendix III: GAO Contacts and Staff Acknowledgments 25

Abbreviations

OSHA Occupational Safety and Health Administration
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United States General Accounting Office

Washington, D.C. 20548

National Security and

International Affairs Division

B-284882 Letr

May 19, 2000

Congressional Requesters

Over the last 50 years, federal policymakers and scientists have attempted

to both capitalize on the advantages of beryllium and address health and

environmental risks. Beryllium is a strong and lightweight metal that

generates and reflects neutrons, resists corrosion, is transparent to X-rays,

and conducts electricity. It is also a hazardous substance.

Among the organizations that have played key roles in responding to the

risks associated with beryllium are the Departments of Defense, Energy,

and Labor. The Departments of Defense and Energy are the federal

agencies that have most commonly used beryllium. Defense procures

components containing beryllium for a variety of weapon systems from

private contractors. Energy operates federal facilities (including nuclear

weapons production facilities) that use beryllium, and it has responsibility

for protecting federal and contract workers at these facilities. Energy has

identified at least 17 facilities that use or have used beryllium, and it

estimates that about 20,000 current and former workers at these facilities

were exposed or potentially exposed to beryllium from the 1940s to the

present. The Department of Labor’s Occupational Safety and Health

Administration has overall responsibility for protecting the health and

safety of workers in most workplaces throughout the United States,

including those that use beryllium.1

This report responds to your request for information on beryllium as a

hazardous material and on the health and safety controls over its use. As

agreed with your offices, this report (1) provides information on

beryllium’s uses and risks and (2) describes selected key events that

illustrate the evolution of the federal government’s response to risks posed

by beryllium. To respond to the second question, we identified and

summarized key events from the 1960s through the 1990s involving actions

by the Departments of Defense and Energy and the Occupational Safety

1 Defense uses of beryllium (primarily through its contractors) and Energy’s beryllium

vendors are subject to Occupational Safety and Health Administration (OSHA) standards.

Energy’s recent rule covering its facilities adopts OSHA’s permissible exposure limit.
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and Health Administration. Appendix I describes the objectives, scope, and

methodology for this review.

Results in Brief Lightness, strength, and other attributes have made beryllium useful in a

wide array of products, such as aircraft, spacecraft, X-ray equipment, and

nuclear weapons. However, beryllium is considered hazardous. Health

effects from high exposure to beryllium particles were first noted in the

early 20th century. Beginning in the 1940s, scientists linked exposure to

beryllium with an inflammatory lung condition now called chronic

beryllium disease, which can be debilitating and, in some cases, fatal.

Today, questions remain about the level of exposure that poses a risk and

exactly how chronic beryllium disease develops. In the 1950s, studies

showed that beryllium caused cancer in laboratory animals. National and

international organizations now consider beryllium a human carcinogen.

The magnitude of the risk from current occupational exposure levels is not

known, but may be minimal.

From the 1960s to the 1990s, Defense, Energy, and the Occupational Safety

and Health Administration took a number of actions to assess and to

respond to risks associated with exposure to beryllium. In reviewing

selected key events, we noted that the agencies took the following steps to

reduce risks from exposure to beryllium: discontinued testing of rocket

propellant containing beryllium, assessed beryllium exposure standards,

limited worker exposure to beryllium, established health surveillance

measures, and proposed compensation for workers who have chronic

beryllium disease. The key events are as follows:

• Defense discontinued testing beryllium in rocket fuel by 1970, due in

part to concerns about meeting air quality requirements.

• The Occupational Safety and Health Administration proposed a more

stringent worker exposure standard for beryllium in 1975 based on

evidence that it was carcinogenic in laboratory animals. The proposal

generated concerns about the technical feasibility of the proposal,

impact on national security, and the scientific evidence supporting the

proposed change. According to Occupational Safety and Health

Administration officials, the agency discontinued its work on the

proposal in the early 1980s in response to other regulatory priorities

such as lead, electrical hazards, and occupational noise. In 1998, the

agency announced that it would develop a comprehensive standard for

beryllium by 2001.
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• Energy improved working conditions at its facilities and implemented

medical testing for its current and former workers during the 1980s and

1990s after new cases of chronic beryllium disease were identified

during the 1980s. From 1984 through 1999, 149 Energy workers have

been diagnosed with definite or possible chronic beryllium disease.

• In 1999, Energy issued a rule that established new worker safety

controls, such as increased use of respirators and assessing hazards

associated with work tasks, for its facilities that use beryllium. Energy

also proposed a compensation program for Energy workers affected by

chronic beryllium disease, which has been introduced as legislation in

the Congress.

The Departments of Defense, Energy, and Labor provided written or oral

comments on our report and generally concurred with the information

presented. They suggested technical changes, and Labor officials also

emphasized that the hazard information bulletin on beryllium cited in the

body of this report was a significant effort to protect worker health.2

Beryllium Uses and

Risks

In the 1920s and 1930s, beryllium was used for a variety of purposes,

including as an additive for alloying with copper and other metals in

manufacturing, as an ingredient in fluorescent lamps, and for other

purposes. Today, beryllium is used in nuclear reactor and weapons parts;

aircraft, spacecraft, and missile structures and parts; military vehicle

structures and parts; electronics; auto parts; lasers; X-ray equipment;

dental prosthetics; and other consumer products. In some of these

products, substitutes for beryllium can be used (e.g., titanium, stainless

steel, and some forms of bronze and aluminum). However, Energy and

Defense officials state there is no substitute for beryllium in key nuclear

components or in weapons for which lightweight and strength are critical.

According to U.S. Public Health Service reports, people are exposed to

extremely low levels of naturally occurring beryllium in the air, in many

foods, in water, and in soil. The highest exposures to beryllium tend to

occur in the workplace. Occupational exposure to beryllium occurs when it

is extracted from ore; when the ore is processed into beryllium metal; and

2 An OSHA bulletin titled Preventing Adverse Health Effects from Exposure to Beryllium on

the Job was issued in September 1999. The bulletin cautioned that the current permissible

exposure limit may not be adequate to prevent the incidence of disease, and it

recommended measures to reduce exposures.
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when this metal is made into parts (e.g., machined, welded, cut, or ground).

Today, beryllium is used in many applications outside of the Defense and

Energy industries.

Health effects from high exposure to beryllium particles were first noted in

the early 20th century. Beginning in the 1940s, scientists linked exposure to

beryllium with an inflammatory lung condition now called chronic

beryllium disease, which is often debilitating and, in some cases, fatal.

Research on the biomedical and environmental aspects of beryllium is

extensive.3 According to the National Jewish Medical and Research Center

(a nonprofit institution devoted to respiratory, allergic, and immune system

diseases), beryllium primarily affects the lungs. The disease occurs when

people inhale beryllium dust, and it can develop even after workers have

been out of the beryllium industry for many years. There are three main

types of adverse health effects associated with beryllium exposure:

• Chronic beryllium disease is caused by an allergic-like reaction to

beryllium. Even brief exposure to very low levels can lead to this

disease, which often has a slow onset and involves changes to lung

tissue that reduce lung function. The first evidence of what was to be

called chronic beryllium disease was identified in 1946. More recent

studies indicate that reaction to beryllium depends on the type of

beryllium and the work task.4 According to the National Jewish Medical

and Research Center, the disease occurs in 1 to 16 percent of exposed

people, with the level of exposure that poses risk and the precise

mechanisms of disease not yet well characterized.

• Acute beryllium disease (symptoms lasting less than 1 year) results from

relatively high exposure to soluble beryllium compounds (i.e.,

compounds that can be at least partially dissolved). This disease usually

has a quick onset and resembles pneumonia or bronchitis. High

exposures may also cause skin lesions. The earliest cases of this disease

involved severe overexposure to beryllium that affected the lungs and

3 A database sponsored by Energy contains over 2,500 citations (dating up to 1994) on

biomedical and environmental aspects of beryllium, and more studies exist. For example,

although Energy’s database contains only 20 citations identified as relating to beryllium use

in propellants or rocket fuel, databases maintained by Defense and the National Aeronautics

and Space Administration contain more than 350 additional studies on rocket fuel issues

alone.

4 For example, the size of beryllium particles has been identified as a possible factor in

toxicity, and machining tasks have been associated with higher rates of disease.
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skin of fluorescent light workers in the 1930s. It is now rare due to

improved industrial protective measures designed to reduce exposure

levels.

• National and international organizations have identified beryllium metal

and compounds as carcinogenic to humans. Studies involving workers

in plants with high exposures during the 1940s showed subsequent

increases in mortality. The magnitude of the risk from current

occupational exposure levels is not known, but may be minimal.

Key Events in the

Federal Response to

Beryllium Risks

The following illustrative key events involving Defense, Energy, and the

Occupational Safety and Health Administration (OSHA) document

concerns and actions taken regarding beryllium exposure risks. The events

include (1) Defense’s decision to discontinue testing beryllium in rocket

fuel by 1970, (2) OSHA’s efforts in the 1970s and since 1998 to lower the

exposure limits, (3) Energy’s steps to improve working conditions and

medical screening in the 1980s and 1990s, and (4) Energy’s 1999 rule on

beryllium worker safety.

Defense Discontinued

Testing of Beryllium Rocket

Propellant

Defense discontinued testing of rocket propellant containing beryllium by

1970 due to the potential risk of public exposure to hazardous levels of

beryllium particles released in rocket exhaust. According to an August 1969

Air Force report,5 the Air Force and the Advanced Research Projects

Agency began development of beryllium rocket propellant in 1959.

Experiments in the 1960s showed that rocket payloads could be increased

10 to 30 percent by using beryllium powder in propellant. Research and

development efforts later expanded to include other Defense agencies and

the National Aeronautics and Space Administration.

As military and civilian agencies experimented with beryllium in rocket

fuel, they also pursued concerns about beryllium’s potential risks. For

example, an August 1962 manufacturer’s internal memorandum stated that

officials planned a visit from the Navy propellant plant at Indian Head,

Maryland, to discuss health and safety concerns in handling beryllium

powders at a test facility for solid fuel propellants. When testing began to

involve firing large rocket motors that would release potentially hazardous

5 Review of Toxicity Aspects of Beryllium Propellant, The Aerospace Corporation (San

Bernardino, California: Aug. 8, 1969).
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levels of beryllium particles into the air, concerns expanded to include the

general population in the vicinity of test facilities.

In 1966, the U.S. Public Health Service6 requested the National Academy of

Sciences-National Research Council7 to study the toxicity and hazards of

beryllium propellant and its compounds and to recommend air quality

criteria. The resulting March 1966 council report8 recommended a range of

less stringent limits for atmospheric contamination.9 The U.S. Public Health

Service concluded that releases of any form of beryllium above 75

micrograms per cubic meter of air could be hazardous, and it did not adopt

the council’s recommendation to change the release limit.

According to a 1985 Air Force report,10 as a result of the U.S. Public Health

Service decision, all beryllium propellant and motor testing has been

discontinued since 1970.11 Following the U.S. Public Health Service

decision, Defense issued a directive in 1967 that in effect curtailed open-air

6 The U.S. Public Health Service is part of the Department of Health and Human Services,

the major health agency of the federal government. During the time of the request, the

Service was part of the Department of Health, Education, and Welfare. Part of its mission is

to control and prevent disease and conduct and fund biomedical research.

7 The National Academy of Sciences, a private and nonprofit organization composed of

scholars, is engaged in scientific and engineering research for the purpose of furthering

knowledge and advising the federal government. The National Research Council, the

principal operating agency for the National Academy of Sciences, provides services to the

government, the public, and the scientific and engineering community.

8 Air Quality Criteria for Beryllium and Its Compounds, Committee on Toxicology and the

Advisory Center on Toxicology, National Academy of Sciences-National Research Council

(Washington, D.C.: Mar. 1, 1966).

9 At that time, the U.S. Public Health Service was responsible for such standards. The 1966

Academy report stated that, for intermittent rocket firings totaling up to 1 hour during any

2 weeks, releases of forms of beryllium oxide believed less toxic could total as much as

1,500 micrograms per cubic meter. Forms believed more toxic were limited to a peak of 75

micrograms per cubic meter in such circumstances.

10Beryllium Propellant Feasibility Study (Revised), Jet Propulsion Laboratory (Pasadena,

California: Jan. 1985), p. 4.

11According to an August 1969 Air Force Systems Command report, a key document in the

decision to discontinue testing was “Control of Air Pollution Associated with Beryllium

Enriched Propellants,” a memorandum from the Director for Defense Research and

Engineering to the Assistant Secretary of the Air Force (Research and Development) dated

November 20, 1967. It directed that all open-air rocket firings be within the lowest proposed

limits or that firings be made within protected facilities or outside the continental United

States.
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firing of beryllium-fueled rocket motors. The directive required that the

release of beryllium in all open-air firings fall within the 75 microgram

contamination limit, that exhaust from rocket motors be filtered to meet

the 75 microgram limit, or that firings be conducted outside the continental

limits of the United States. According to the August 1969 Air Force report,

this directive severely limited development of beryllium-fueled rocket

motors. The report also indicated that the 75 microgram contamination

limit could not be met, the equipment needed to filter exhaust to meet the

75 microgram limit was not available, and firing at remote locations was

expensive. The Environmental Protection Agency, which is today

responsible for air quality standards, continues to limit such releases to the

75 microgram level.

OSHA Actions to Revise

Exposure Standards

In 1971, OSHA adopted a beryllium standard developed by the American

National Standards Institute to control exposure to beryllium in the

workplace.12 OSHA subsequently began efforts to determine whether this

standard should be revised. Officials at OSHA believed a change in the

standard was warranted because of research conducted by the National

Institute for Occupational Safety and Health, a component of the Center for

Disease Control under the Department of Health, Education, and Welfare at

the time.13 This research concluded that beryllium exposure caused cancer

in animals and likely posed a similar risk to humans. OSHA policy at the

time required that once a toxic material was confirmed as carcinogenic in

animals, it should be treated as posing a carcinogenic risk to humans and

employee exposure should be reduced to the lowest level feasible. OSHA’s

proposal would have cut the permissible exposure limit in half.14

12The American National Standards Institute is a private organization that facilitates the

development of voluntary standards by consensus. The standard for industrial exposure set

a permissible exposure limit of 2 micrograms per cubic meter of air based on an 8-hour time

weighted average, with a ceiling concentration of 5 micrograms per cubic meter for

30 minutes.

13 Currently the National Institute for Occupational Safety and Health is part of the Centers

for Disease Control and Prevention under the Department of Health and Human Services.

14 In addition to reducing the permissible exposure limit from 2 to 1 micrograms per cubic

meter, OSHA proposed reducing a ceiling concentration of 5 micrograms per cubic meter

from 30 to 15 minutes and added requirements such as employee exposure measurements,

medical surveillance, compliance procedures, and protective equipment.
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In a 1975 Federal Register notice outlining its proposal, OSHA cited several

issues raised by the revised standard, including OSHA’s decision to treat

beryllium as a substance that posed a carcinogenic risk to humans based

on laboratory animal data, the technical feasibility of achieving the

proposed exposure limits, and the method of monitoring airborne

concentrations of beryllium. It solicited comments from the public and

received about 150 written comments and 40 requests for a public hearing.

As a result, from August through September 1977, OSHA held an informal

rulemaking hearing and heard testimony from 46 individuals representing

business, government, labor, and academia. Some commenters questioned

whether there was sufficient scientific evidence to support a revision,

whether employers (particularly beryllium producers) could comply with

lower exposure limits with existing technology, and whether the cost of

complying with the proposed standard was excessive.

In 1978, while government panels15 were considering the sufficiency of

scientific evidence, the Secretaries of Energy and Defense questioned the

impact of the proposed standard on the continued production of beryllium,

which was important for national defense. August 30, 1978, letters from the

Secretary of Energy to the Secretary of Labor and the Secretary of Health,

Education, and Welfare noted that the proposed standard would place a

heavy burden on the two primary beryllium producers in the United States,

who might stop producing beryllium. Specifically, the letter stated that

“Clearly, cessation of beryllium metal and/or beryllium oxide production is

unacceptable and would significantly degrade our national defense effort.”

The Secretary agreed that workers’ health was paramount, but believed

that the scientific questions warranted an independent peer review. The

Secretary of Defense—in November 1978 letters to the Secretary of Labor

and the Secretary of Health, Education, and Welfare—echoed the Energy

Secretary’s concerns about national security and the scientific evidence.

The first government panel reviewed human cancer studies, but documents

did not show whether or how the panel’s review was concluded. The

Secretary of Health, Education, and Welfare formed a second panel in 1978

to address three questions. The questions were as follows: (1) Are the

15 The first panel (generally called the Beryllium Review Panel) included six members from

Department of Health, Education, and Welfare’s National Institute for Occupational Safety

and Health, and its Center for Disease Control. The panel was active from March to

September 1978. The second panel (generally called the Health, Education, and Welfare

Beryllium Review Panel) met during early October 1978 and included seven members from

five academic and two government institutions.
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animal studies credible in showing beryllium carcinogenicity in at least two

species? (2) Is beryllium-copper alloy a carcinogen? (3) Is there evidence

indicating that beryllium is a carcinogen in man?

The second panel’s consultants generally agreed that (1) beryllium was an

animal carcinogen, (2) no good information existed on cancer involving

beryllium-copper alloy, and (3) epidemiological evidence was suggestive of

an association between beryllium exposure in the workplace and human

lung cancer (however, the data were only suggestive because of alternative

explanations for this association). In a 1978 report to the Secretary of

Health, Education, and Welfare, the U.S. Surgeon General and the Assistant

Surgeon General, who oversaw the panel and reviewed the scientific

evidence, stated that the conclusion that beryllium was an animal

carcinogen required the Department of Health, Education, and Welfare to

recommend standard setting and that more definitive answers were needed

regarding the last two questions.

Representatives from Defense, Energy, and OSHA met to discuss the

proposed OSHA standard in 1979. Concerns included national security,

technical feasibility, and the scientific evidence. OSHA continued its efforts

to finalize the standard and prepare a draft rule at least through July 1980.

According to OSHA officials, work was discontinued in the early 1980s

because of other regulatory priorities such as lead, electrical hazards, and

occupational noise.

In 1998, OSHA announced that it was developing a comprehensive standard

on occupational exposure to beryllium. In its announcement, the agency

cited evidence of chronic beryllium disease associated with beryllium

exposure below the 2 microgram limit, a new beryllium sensitivity16 test,

and conclusions that beryllium is a human carcinogen. Officials from OSHA

expect to propose a standard in 2001.

To develop information for this standard, OSHA contracted with a private

firm and has obtained preliminary data on industries that use beryllium. It

also issued a hazard information bulletin17 on beryllium exposure in

September 1999 to alert employers and employees about the potential

16 In this report, sensitivity and sensitization have the same meaning.

17 OSHA issues hazard information bulletins to provide information and guidance to affected

workers on new or misunderstood health and safety hazards when they arise.
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hazards of beryllium and to provide guidance on work practices needed to

control exposure.

Energy Improved Working

Conditions and Medical

Screening Following New

Disease Cases in the 1980s

Two Energy facilities that have large numbers of beryllium-related workers

are the Rocky Flats Environmental Technology Site in Golden, Colorado,

and the Oak Ridge Y-12 Plant in Oak Ridge, Tennessee. Rocky Flats

produced beryllium metal parts for nuclear weapons from 1958 through

1989, but no longer has any production role and is expected to be closed.

Some workers at Rocky Flats may encounter beryllium during the

environmental cleanup process at the facility. The Y-12 Plant produces

nuclear weapons parts from beryllium powder and has other roles in the

nuclear weapons program that may expose workers to beryllium. Overall,

as of March 2000, Energy had identified at least 17 facilities that use or have

used beryllium. Energy’s preliminary estimate is that about 20,000 current

and former workers at its facilities were exposed or potentially exposed to

beryllium.18

According to Energy documents, from the 1970s through 1984, the

incidence of chronic beryllium disease appeared to significantly decline at

Energy facilities. This apparent reduction, along with the long latency

period for the disease, led Energy to assume that chronic beryllium disease

was occurring only among workers who had been exposed to high levels of

beryllium decades earlier, such as in the 1940s. However, in 1984 a new

case of chronic beryllium disease was diagnosed in a worker employed in

1970 at Energy’s Rocky Flats facility. Several additional cases were

diagnosed among Rocky Flats workers in the following years, raising

questions about the adequacy of worker protection measures. In response,

Energy investigated the working conditions at Rocky Flats and made

improvements to ventilation in 1986 and also improved working practices.

Energy also instituted medical screening programs for beryllium workers

at risk of developing chronic beryllium disease, making use of new medical

18 Los Alamos National Laboratory in New Mexico is now responsible for producing a small

number of the beryllium metal parts that Rocky Flats used to produce. Energy workers were

exposed to beryllium at several additional facilities where nuclear weapons research and

development, production, maintenance, or testing occurred. In addition, Energy conducts

many scientific research activities, such as investigation of the basic nature of matter and

atoms. Some Energy research laboratories use beryllium or beryllium parts. For example,

several nuclear reactors that are used for scientific research contain beryllium parts called

reflectors. Workers at Energy facilities may also be exposed to beryllium during

environmental cleanup and decontamination of buildings.
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advances such as a new blood test. In addition, Energy improved its

practices for monitoring worker exposure.

Energy’s Actions at Rocky Flats After the new case of chronic beryllium disease was diagnosed in June

1984, Energy’s Albuquerque Operations Office, which oversaw Rocky Flats,

conducted an investigation of working conditions at the plant’s beryllium

machine shop to identify factors contributing to the disease case. The

investigation, reported in October 1984, identified ventilation problems in

the beryllium machine shop and hazards from performing certain

operations outside of ventilation hoods, which are designed to collect and

filter out airborne beryllium particles. The investigation also found that the

affected worker had repeatedly been exposed to beryllium at levels greater

than the permissible exposure limit of 2 micrograms per cubic meter of air

(averaged over an 8-hour period).

During the 1984 investigation, the Rocky Flats facility began taking air

samples from workers’ “breathing zones” for the first time, using sampling

devices placed on workers’ shirts or lapels. Previously, the facility had used

“area monitoring,” in which sampling devices were placed on beryllium

machines or other fixed locations in the work area. Exposure levels

measured by personal breathing zone sampling were generally found to be

higher than those measured by area samplers. Several reasons could

account for the differing monitoring results, according to a 1996 research

study and Energy officials. Fixed area monitors were not always

well-placed to represent workers’ breathing zones.19 Also, fixed area

monitors placed on or near machines may not capture exposures resulting

from the use of hand-held tools or poor work practices, such as shaking out

cloths used to clean machines.

Following the investigation, Rocky Flats remodeled the ventilation system,

eliminated most operations outside ventilation hoods, improved

procedures for cleaning tools and work areas, increased respirator use, and

improved worker safety training. For example, starting in 1984, respirators

were required to be worn in the Rocky Flats beryllium machine shop.

According to officials, workers exposed above the permissible exposure

limit during the 1984 through 1989 era would have been protected by

respirators. Energy officials indicated that this was an especially important

19Anthony E. Barnard, Janet Torma-Krajewski, and Susan M. Viet, “Retrospective Beryllium

Exposure Assessment at the Rocky Flats Environmental Technology Site,” American

Industrial Hygiene Association Journal (Sept. 1996).
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interim corrective measure prior to completion of the remodeling project in

September 1986. In addition, Rocky Flats hired a health and safety

consulting firm to test the effectiveness of its remodeling by conducting

“before-and-after” personal breathing zone monitoring. According to the

consultant’s study, samples taken in September and October 1986 (after the

ventilation remodeling) showed lower average exposure levels and fewer

samples were over exposure limits than was the case before the

remodeling.

A second evaluation at Rocky Flats was conducted by the National Institute

for Occupational Safety and Health, at the request of a union’s local

chapter. This evaluation, which was completed in May 1986 before the

ventilation remodeling was completed, concluded that a health hazard

existed from overexposure to beryllium in the beryllium machine shop. The

Institute recommended that Rocky Flats routinely use personal breathing

zone sampling, conduct all beryllium machining under exhaust ventilation,

and conduct medical monitoring of beryllium-exposed workers.

Improved Medical Testing During the late 1980s, medical advances allowed for earlier and easier

detection of chronic beryllium disease and sensitivity to beryllium.

Beryllium sensitivity is an immune system reaction, similar to an allergic

reaction, which can occur in some persons exposed to beryllium and that

indicates an increased risk of developing chronic beryllium disease. A

blood test for sensitivity, known as the beryllium lymphocyte proliferation

test, was refined during the late 1980s. Another new diagnostic device, the

flexible bronchoscope (a tubular lighted device), provided a less invasive

means for examining the lungs for signs of chronic beryllium disease.

Energy and the National Jewish Medical and Research Center first began

using the newly developed blood test on a trial basis to identify workers’

sensitivity to beryllium at Rocky Flats in 1987. Beginning in 1991, Energy

established medical screening programs for many additional current and

former Energy employees, using this blood test. For those identified as

having sensitivity to beryllium, Energy offered follow-up medical exams to

determine whether chronic beryllium disease was present. Medical testing

was provided in phases, due to the funding levels available, according to an

official in Energy’s Office of Occupational Medicine and Medical

Surveillance. Specifically, blood testing for current and former Rocky Flats

workers began on a routine basis in 1991, for current Oak Ridge workers in

1991, for former Oak Ridge workers in 1993, and for former workers at

several other facilities where workers could have been exposed to

beryllium in 1996 and 1997.
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From 1984 through December 31, 1999, a total of 13,770 current and former

workers (or about 69 percent of the estimated 20,000 workers who may

have been exposed to beryllium) had been screened for definite or possible

chronic beryllium disease. Through this testing, 149 Energy workers have

been diagnosed with chronic beryllium disease. The Assistant Secretary for

Environment, Safety, and Health states that of the 149 workers, 89 have

been diagnosed with chronic beryllium disease and another 60 have clinical

findings presumed to be due to chronic beryllium disease. An additional

299 workers were identified as having sensitivity to beryllium; 219 of these

workers do not have chronic beryllium disease; and 80 workers had yet to

complete clinical evaluations to determine whether or not they have the

disease. Energy plans to continue offering testing to additional former

workers.

Improved Exposure Monitoring During the 1990s, Energy also expanded the use of personal breathing zone

monitoring at its facilities. For instance, the Y-12 Plant at Oak Ridge took

only 148 personal breathing zone samples prior to 1990, but took 1,448

personal breathing zone samples from 1990 through 1996. According to

plant officials, beginning in January 1998 and continuing through fiscal

year 1999, the Y-12 Plant sampled every beryllium worker on every shift and

reported the results back to the workers the following day. More than 7,900

personal breathing zone samples were collected during this period,

according to the plant’s Industrial Hygiene Manager. The purposes of this

monitoring effort were to make workers more aware of safety practices

through immediate feedback, to identify any practices needing

improvement, and to address the monitoring requirements stated in a 1997

Energy notice on chronic beryllium disease prevention (described below).

The Industrial Hygiene Manager for the Y-12 Plant told us that the plant

plans to continue using personal breathing zone sampling routinely,

sampling every worker in some locations and using a statistically based

sampling approach in locations where more extensive data have already

been gathered.
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Energy Established a Rule

on Beryllium Worker Safety

in 1999 and Proposed a

Beryllium Worker

Compensation Program

Energy issued a rule in December 1999 establishing regulations to reduce

beryllium exposure levels among its workforce, to reduce the number of

workers exposed to beryllium, and to provide medical testing for exposed

and potentially exposed workers.20 This rule on chronic beryllium disease

prevention applies to federal, contractor, and subcontractor employees at

Energy facilities where there is actual or potential exposure to beryllium.21

Energy has identified 17 facilities affected by the rule. These facilities have

a total of about 8,100 workers who currently are associated with beryllium

activities. According to officials in Energy’s Office of Environment, Safety,

and Health, each Energy facility is currently evaluating how it is affected by

the new requirements in the rule. This review may result in identifying

additional facilities that are affected by the rule. Several actions by Energy,

such as a survey of its facilities to identify those with beryllium uses,

preceded development of the final rule. In addition, in November 1999, the

Secretary of Energy announced a legislative proposal to provide

compensation for Energy workers who have contracted chronic beryllium

disease or beryllium sensitivity.

Steps Preceding Issuance of

Energy’s Rule

In 1996, Energy surveyed the contractors that manage and operate its

facilities concerning the extent of beryllium usage and the estimated

numbers of workers exposed to beryllium. Following the survey, in July

1997, Energy issued a notice to its offices requiring the development and

implementation of programs to minimize workers’ exposure to beryllium

and to minimize the incidence of chronic beryllium disease. The Secretary

of Energy stated that the programs were to be followed until an Energy rule

on beryllium could be promulgated. The notice required that the programs

include measures to monitor and reduce workers’ exposures to beryllium.

For example, Energy facilities were to assess the hazards associated with

each beryllium-related task. The contractors at these facilities were also

required to offer voluntary medical testing for beryllium sensitivity to their

current workers. Seventeen Energy facilities developed chronic beryllium

disease prevention programs in response to the notice.

Energy’s Rule on Chronic

Beryllium Disease Prevention

Energy’s December 1999 rule on chronic beryllium disease prevention

includes a number of provisions designed to reduce beryllium exposure

20 64 Fed. Reg. 68854 (Dec. 8, 1999).

21 The rule does not apply to Energy’s beryllium vendors, which are regulated by OSHA. It

also does not apply to certain Energy laboratory operations that are regulated under an

OSHA rule for laboratories.
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Page 17 GAO/OCG-00-6 Beryllium Uses and Risks

among its workers. First, the rule adopts OSHA’s permissible exposure limit

(currently 2 micrograms per cubic meter averaged over an 8-hour period)

or a more stringent limit that may be promulgated by OSHA in the future.

Second, the rule establishes an action level that is one-tenth of the

permissible exposure limit,22 at which level certain controls must be

implemented. Controls required when exposure reaches the action level

include using respirators and protective clothing, periodically monitoring

beryllium levels, setting annual goals for exposure reduction, and limiting

work area access to authorized personnel. The rule requires that periodic

monitoring occur at least quarterly and that facilities use personal

breathing zone monitoring. In addition, some controls are required for any

beryllium work, regardless of the exposure level. These include assessing

hazards before beginning work tasks involving beryllium, providing safety

training to workers, and providing respirators to any beryllium worker who

requests one.

Energy’s rule includes two other types of beryllium limits. First, the rule

establishes limits for beryllium particles on surfaces such as floors, tables,

and the exterior of machinery. Surface sampling must be conducted

routinely, and specified housekeeping methods must be used to keep

beryllium dust below the limits. Second, the rule sets limits called release

criteria for beryllium-contaminated equipment or items. One limit is set for

releasing equipment and items to other facilities that perform beryllium

work. A second, more stringent level is set for releasing equipment and

items for reuse outside of Energy facilities or in non-beryllium areas of

Energy facilities.

Energy’s rule requires that medical surveillance be provided, on a voluntary

basis, to all current workers with known or potential exposure to

beryllium. Beryllium workers’ annual health evaluations are to include

blood tests for beryllium sensitivity and a physical examination

emphasizing the respiratory system. These health evaluations are to be

provided at no cost to workers. If medical opinions so indicate, employers

at Energy facilities must offer to remove workers from beryllium work and

exposure. Individuals removed from beryllium work must be provided the

opportunity to transfer to other work for which they are qualified or can be

trained in a short period. If a position is not available, employers must

provide such workers with their normal earnings, benefits, and seniority

for up to 2 years.

22 The action level is 0.2 micrograms per cubic meter averaged over an 8-hour period.
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Page 18 GAO/OCG-00-6 Beryllium Uses and Risks

Worker Compensation Proposal In November 1999, the Administration transmitted a legislative proposal to

the Congress to provide compensation for current and former Energy

workers with chronic beryllium disease.23 The proposal covers employees

of Energy and its predecessor agencies, Energy contractors and

subcontractors, and beryllium vendors who sold beryllium to Energy.

According to Energy officials who helped develop the proposal, employees

of beryllium vendors were included because (1) Energy’s contracts with

vendors through the early 1960s generally required them to apply the same

worker safety provisions that Energy used in its own facilities and (2) the

vendors manufactured beryllium parts to government specifications and

for the sole use of the government. Affected workers would be eligible to

receive reimbursement for medical costs, assistance for impairment or

vocational rehabilitation, and compensation for lost wages. Workers with

sensitivity to beryllium could also be reimbursed for medical costs involved

in tracking their condition. In an announcement regarding this proposal,

the Secretary of Energy noted that the proposal would reverse Energy’s

past practice of opposing and litigating most worker health compensation

claims. The Administration’s proposed legislation was introduced in the

House and the Senate in November 1999. Two other bills concerning

compensation for beryllium workers have also been introduced in the

House and are pending.

Agency Comments and

Our Evaluation

We provided the Departments of Energy, Labor, and Defense with a draft of

this report for their review and comment. They generally agreed with the

information in the report and provided technical changes, which we

incorporated as appropriate. Energy’s written comments are in appendix II.

An official of the Office of the Deputy Under Secretary of Defense for

Environmental Security orally concurred with the information in our report

and suggested changes to clarify data on air monitoring and medical

testing. An official of Labor’s Occupational Safety and Health

Administration orally concurred with the information in our report and

suggested changes to clarify terminology and to expand data on beryllium

as a human carcinogen.

23 The proposal also addressed compensation for several other groups of Energy workers.
B-284882

Page 19 GAO/OCG-00-6 Beryllium Uses and Risks

We are sending copies of this report to the Honorable William S. Cohen,

Secretary of Defense; the Honorable Bill Richardson, the Secretary of

Energy; the Honorable Alexis Herman, the Secretary of Labor; and other

interested parties.

If you have any questions about this report, please call the contacts listed in

appendix III.

David R. Warren, Director

Defense Management Issues
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Page 20 GAO/OCG-00-6 Beryllium Uses and Risks

List of Congressional Requesters

The Honorable Robert F. Bennett

The Honorable Mike DeWine

The Honorable John McCain

United States Senate

The Honorable Christopher Shays

Chairman, Subcommittee on National Security,

Veterans’ Affairs, and International Relations

Committee on Government Reform

The Honorable Tim Holden

The Honorable Paul E. Kanjorski

The Honorable Marcy Kaptur

The Honorable Jim Kolbe

House of Representatives
Page 21 GAO/OCG-00-6 Beryllium Uses and Risks
Page 22 GAO/OCG-00-6 Beryllium Uses and Risks

Appendix I

Objectives, Scope, and Methodology ApApenednxidexiIs

Our objectives were (1) to provide information on beryllium uses and risks

and (2) to describe selected key events that illustrate the evolution of

federal government responses to risks. More specifically, we were asked to

examine key events at the Departments of Energy and Defense and at

Labor’s Occupational Safety and Health Administration.

To obtain information on beryllium uses and risks, we reviewed

documentation such as agency studies and reports and interviewed

officials at Energy, Defense, Labor, and the Occupational Safety and Health

Administration headquarters. We reviewed current and archived data and

reports from the U.S. Public Health Service; the National Jewish Medical

and Research Center, Denver, Colorado; Brush Wellman, Inc. (one of two

producers of beryllium in the United States) headquartered in Cleveland,

Ohio; and the Lovelace Respiratory Research Institute, Albuquerque, New

Mexico.

We selected key events during the 1960s through 1990s involving Energy,

Defense, and Labor to illustrate agency responses to beryllium uses and

risks. For each event, we screened current and archived records for

documentation such as agency hearing records, studies, correspondence,

and reports; we interviewed agency officials to identify agency positions;

and we followed up on agency officials’ interviews with other parties, to

ensure the accuracy of our report.

• For Energy, we contacted headquarters staff in the Offices of

Environment, Safety, and Health; the General Counsel; Defense

Programs; Science; and Nuclear Energy, Science, and Technology; and

field staff from Defense facilities, including Rocky Flats, Colorado; Oak

Ridge Y-12 Plant, Tennessee; Los Alamos National Laboratory, New

Mexico; and Lawrence Livermore National Laboratory, California. We

obtained data on exposure sampling; working conditions; medical

screening efforts; workplace controls; policy, practices, and procedures;

and the rule, proposed legislation, and associated history.

• For Defense overview information, we contacted staff from the Deputy

Under Secretary of Defense for Environmental Security; the military

service headquarters; the U.S. Army Center for Health Promotion and

Preventive Medicine, Aberdeen Proving Ground, Maryland; the Navy

Environmental Health Center, Norfolk, Virginia; the Air Force Institute

for Environment, Safety, and Occupational Health Risk Analysis, Brooks

Air Force Base, Texas; and selected subordinate commands. Regarding

beryllium rocket fuel, we also visited the Air Force Research Laboratory,

Edwards Air Force Base, California. We obtained background
Appendix I

Objectives, Scope, and Methodology

Page 23 GAO/OCG-00-6 Beryllium Uses and Risks

information from the headquarters of the National Aeronautics and

Space Administration, its Langley Research Center, and the Chemical

Propulsion Information Agency, Columbia, Maryland.

• For Labor, we interviewed current and former staff from the

Department of Labor’s Occupational Safety and Health Administration

and the Department of Health and Human Services’ National Institute

for Occupational Safety and Health. We obtained and examined the

complete transcript of the August-September 1977 informal hearing on

beryllium, as well as key documents available from hearing records and

related archive files.

This report was reviewed for classification by an authorized derivative

classifier at Energy and was determined to be unclassified. We conducted

our review from June 1999 through April 2000 in accordance with generally

accepted government auditing standards.
Page 24 GAO/OCG-00-6 Beryllium Uses and Risks

Appendix II

Comments From the Department of Energy ApendxiI
Page 25 GAO/OCG-00-6 Beryllium Uses and Risks

Appendix III

GAO Contacts and Staff Acknowledgments ApendxiI

GAO Contacts Charles Patton, Jr., (202) 512-8412

Uldis Adamsons, (202) 512-4289

Acknowledgments In addition to those named above, Bruce Brown, Rachel Hesselink, Arturo

Holguin, Robert Kigerl, Lori Rectanus, Ronni Schwartz, George Shelton,

and Glen Trochelman made key contributions to this report.

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