As part of the hazard assessment process, Responsible Individuals shall develop and maintain an inventory of beryllium, beryllium alloys, and beryllium compounds present in the facility. At the facility manager's discretion, UNCLASSIFIED (only) beryllium inventory information may be included in ChemTrack or obtained and tracked through some other means.

At a minimum, the inventory of beryllium, beryllium alloys, and beryllium compounds will be updated annually in each facility. In addition, whenever beryllium is brought into or taken out of a facility or removed from inventory because of use, workers shall notify their supervisors, who will then forward the inventory information to the Facility Manager. Individual inventories shall be provided to the facility manager, who prepares a consolidated inventory (in pounds) to the ChemTrack Operations Group in EPD for regulatory reporting purposes.

The inventory should have the following information (as appropriate):

* Product name, including form (e.g., beryllium foil)

* Manufacturer

* Building number

* Room number

* Sub-location (e.g., cabinet or other storage location)

* Quantity (i.e., weight of beryllium, beryllium alloy, or beryllium compound)

* Units

* Custodian's ID (i.e., employee number)

* Custodian's first and last name

* Custodian's telephone extension

* Container (if appropriate)

* Date

An inventory shall be sufficiently detailed to ensure the safety basis envelope of each facility where beryllium is used is not exceeded.

3.5.5 Exposure Monitoring

Initial Monitoring

In areas that may have airborne beryllium, initial personal breathing zone sampling shall be conducted to determine workers' 8-hour, time-weighted average exposure. Sufficient numbers of samples shall be taken to adequately characterize exposures. Work supervisors, workers, and the ES

Periodic Monitoring

When personal exposures equal or exceed the AL, sampling shall be performed periodically, i.e., at least quarterly for routine operations. Infrequent operations, i.e., operations that occur less than quarterly, shall be sampled each time they are performed.

Additional Monitoring

When work operations, maintenance, or procedures change, or when there is any reason to believe that such a change has occurred, additional monitoring shall be conducted.

3.5.6 Safety Documents

Before beginning any work involving beryllium, the work shall be authorized by an IWS. An activity's IWS shall be revised and reapproved if changes in operations increase the level of hazard or introduce new hazards.

In addition to an IWS, a safety plan is required for all beryllium operations that have the potential for producing airborne beryllium. A safety plan that is consistent with Document 2.2 shall provide specific controls to keep airborne beryllium at levels less than the AL and as low as practicable. A Hazard Assessment and Control (HAC) form is used to document the use of respirators and other PPE in accordance with the requirements of Document 11.1. A HAC form is used for work when a safety plan is not required.

3.5.7 Beryllium Work Areas and Regulated Beryllium Work Areas

A beryllium work area is any defined area (e.g., shop, laboratory, or other facility) that is subject to 10 CFR 850, i.e., that does not fall under the laboratory-use exemption (see Section 1.0), and where beryllium (other than beryllium articles) is handled, used, or worked. (Beryllium articles are those items meeting the OSHA definition of an article and whose surface contamination level is determined to be less than 0.2 µg Be/100 cm2.) Measured or potential airborne exposures are to be less than the AL of 0.2 µg Be/m3 as an 8-hour, time-weighted average. A beryllium work area may be either temporary or permanent, depending on the nature of the specific work. A beryllium work area shall be posted with the sign shown in Figure 1 in Section 3.5.8.

A regulated beryllium work area is any area (e.g., shop, laboratory, or other facility, including outdoor locations) that is subject to 10 CFR 850, i.e., that does not fall under the laboratory-use exemption, and where beryllium is handled, used, or worked and measured airborne exposures equal or exceed the AL. A regulated beryllium work area may be either temporary or permanent, depending on the nature of the specific task or effectiveness of controls. Significant requirements of a regulated beryllium work area are:

* A manner of demarcation from the rest of the workplace that adequately alerts workers to the boundaries. (See Figure 2 in Section 3.5.8.)

* Access that is limited to authorized persons.

* A log of all entrants that shows each entrant's name, employee number, date, time in, time out, and work activity.

* Dedicated change rooms for workers to change into and store personal clothing and clean protective clothing and equipment.

* Dedicated showers and handwashing areas. (Workers are required to shower at the end of the shift.)

Additional requirements for regulated areas are specified by 10 CFR 850 and are addressed in the following sections of this document:

* Section 3.2, "Exposure Reduction and Minimization Program."

* Section 3.5.5, "Exposure Monitoring."

* Section 3.5.8, "Labeling and Posting."

* Section 3.6.1, "Respiratory Protection."

* Section 3.6.2, "Other Protective Equipment."

A regulated beryllium work area reverts to a beryllium work area when personal air samples determine that exposures are less than the AL.

3.5.8 Labeling and Posting

All access points to a beryllium work area shall be demarcated with a sign having, as a minimum, the wording shown in Figure 1. Earlier versions of such signs having the same wording may be used if legible.

Figure 1. Access posting for entrance to beryllium work areas.

All access points to a regulated beryllium work area shall be demarcated, as required by 10 CFR 850, with a sign having, as a minimum, the wording shown in Figure 2.

Figure 2. Access sign for regulated beryllium work areas.

All containers of beryllium, beryllium compounds, or beryllium-contaminated clothing, equipment, waste, scrap, or debris shall be labeled, as required by 10 CFR 850, with a sign having, as a minimum, the wording shown in Figure 3. In addition, labeling shall also conform to the requirements of the LLNL Health Hazard Communication Program, as specified in Document 10.2.

Figure 3. Label for containers of beryllium or items contaminated with beryllium.

Items made of beryllium, beryllium alloys, or beryllium compounds that do not meet the definition of beryllium articles shall be labeled as indicated in Figure 4. When such a label affects the performance of the item or interferes with a process (e.g. machining or cleaning), the label shall be positioned so that the information is readily apparent to the user or shall be included in the work documentation.

Figure 4. Label for beryllium items.

Beryllium articles, although exempt from the requirements of 10 CFR 850, should be labeled, when feasible, to alert users to the presence of beryllium. Labels may be affixed to storage containers or enclosures for parts. The label shown in Figure 5 may be used for this purpose.

Figure 5. Label for beryllium articles.

Areas where beryllium metal, alloys, or compounds are stored shall be posted prominently with the sign shown in Figure 6:

Figure 6. Beryllium storage area sign.

3.5.9 Training

All persons working at LLNL (e.g., UC/LLNL employees, subcontract workers and assigned to LLNL) shall be trained in the hazards of, and controls for, working with beryllium. The level of training is dependent on a worker's exposure potential. Details are listed in Table 3.

Table 3. Required training.

Course

Target Audience

Repeat Frequency

HS4258-W, "Beryllium Awareness"

Required for all workers at LLNL, except beryllium workers or beryllium-associated workers

One time only

HS4258-RW, "Beryllium Awareness-Refresher" Required for all workers at LLNL, except beryllium workers or beryllium-associated workers

Every 2 years following HS4258

HS4257-W, "Beryllium Safety Training" Required for beryllium-associated workers, except beryllium workers

Every 2 years

HS4256, "Beryllium Worker Training"

Required for beryllium workers

HS4610-CBT, "Basic Air Purifying Respirator Training"

Persons required or choosing to use air purifying respirators

Annually

HS4620-CBT, "Basic Air-Supplied Respirator Training"

Persons required to use air supplied respirators

HS4630-S, "SCBA - Interspiro/Spiromatic-Specific"a

Persons required to use SCBAs

a Self-contained breathing apparatus.

Visitors and other ancillary personnel in beryllium work areas shall be briefed on area specific hazards, including beryllium, and controls by the Responsible Individual or designee.

Retraining for beryllium workers and beryllium-associated workers is required every 2 years or sooner if a worker's performance in work involving beryllium indicates that he or she has not retained the required proficiency.

When respirators or other PPE is required, training shall be conducted as required by Document 11.1.