3.5.10 Medical Surveillance

All workers identified as beryllium-associated workers shall be offered beryllium medical surveillance in accordance with 10 CFR 850. The Health Services Department provides medical surveillance only for UC employees at no charge and at convenient times to accommodate their work schedules. All other workers are offered medical surveillance through their employers. Participation in the medical program is voluntary, i.e., subject to a worker's consent to specific medical tests.

The Responsible Individual shall identify beryllium workers on the IWS (see Section 3.5.3) and ensure that Hazards Control and Health Services Departments are on distribution. The payroll supervisor shall also ensure that medical surveillance is offered to beryllium-associated workers. These departments jointly develop and maintain a list of eligible beryllium-associated workers. The list is updated at regular intervals as new beryllium-associated workers are identified in the field and as others leave LLNL service. The Hazards Control Department and other LLNL departments, as necessary, provide the Health Services Department and employers of subcontract workers with information about exposure and industrial hygiene sampling as needed to direct and coordinate the Beryllium Medical Surveillance Program. Such information includes baseline inventories, hazard assessment and exposure monitoring data, and the identity and nature of activities covered under the CBDPP. The Health Services Department's ES

Medical evaluations are provided to beryllium-associated workers (who include beryllium workers). Beryllium workers are offered annual medical exams and testing. All other beryllium-associated workers are offered evaluations every 3 years. Medical evaluations include assessment of clinical history and exposure history, as well as an exam that emphasizes the respiratory system, skin, and eyes. Workers are offered the Be-LPT, spirometry test, and other tests. Examination and tests are offered with workers' consent, which is documented on the standardized DOE consent form. Information on the risk and benefits of any clinical tests is provided prior to those tests. The Health Services Department (in the case of UC employees) and employer-designated medical surveillance providers (in the case of nonUC employees) also provide clinical evaluation to any worker who may have been exposed to beryllium in an unplanned incident. Workers also receive a written summary of the clinical evaluation, as well as any recommendations, within 10 working days of receipt of the results by the Health Services Department.

LLNL employees may exercise the multiple-physician review option, which is specified in 10 CFR 850 and which can include review of initial medical findings by a second physician. Workers also receive a written summary of the clinical evaluation, as well as any recommendations, within 10 working days of receipt of the results by the Health Services Department.

If a worker is determined, by the Be-LPT, to be sensitized, then sensitization is reported through the standard OSHA injury reporting process. The medical removal option is discussed in detail in Appendix B.

Counseling is available through the Health Services Department (in the case of UC employees) and employer-designated medical surveillance providers (in the case of nonUC employees) for sensitized and CBD workers to assist those workers with concerns regarding their medical treatment, psychological concerns, workers' compensation, and the health risks of continued beryllium exposure. Sensitized workers are offered regular, comprehensive medical evaluations by a specialist to detect the early signs of CBD.

Records are maintained according to the standards specified in 10 CFR 850.39, and worker confidentiality is preserved to the extent afforded by law. The results of clinical evaluations of UC employees are stored in the Health Services Department's medical records. Records of subcontractor employees, including the results of analysis, shall be released to the Health Services Department for retention. All records are kept either for a minimum of 75 years or according to the LLNL record-retention schedule.

Worker exposure data and group sensitization data are regularly reviewed collaboratively by the Health Services and Hazards Control Departments and analyzed to establish a prevalence rate and thereby identify work groups who are at risk for sensitization. Health Services Department procedures are in place to protect the confidentiality of individual workers. The results of such analyses are also used to identify additional work groups who are in need of surveillance or exposure controls.

A worker who begins voluntary participation in the medical program is identified as a beryllium-associated worker and shall continue to be offered beryllium medical surveillance for the duration of his or her employment at LLNL.

3.5.11 Beryllium Registry

Under 10 CFR 850, DOE has established a registry of beryllium-associated workers and requires LLNL to transmit the following information semiannually for each beryllium-associated worker (including those who are subcontract workers) in the registry:

* A unique identifier

* Year of birth

* Gender

* Site identifier

* Job history

* Medical screening test results

* Exposure measurements

* Results of referral for specialized medical evaluations

Each record in the registry is identified by a unique identifier, which serves to link the record to a specific individual while maintaining confidentiality. The pairing of unique identifiers with specific workers is known only to the LLNL Medical Director and individuals designated by him or her as having a need to know such information.

In addition, see Appendix B for LLNL's medical protection requirements for current and prospective beryllium workers.

3.6 Personal Protective Equipment

The hazard assessment (see Section 3.5.3) shall determine and document the necessary PPE. The use of personal protective equipment protection is required when worker exposure equals or exceeds, or potentially equals or exceeds, the AL.

PPE shall be provided to any beryllium-associated worker, regardless of the level of exposure, whenever he or she requests it. Beryllium-contaminated PPE shall be handled in accordance with Document 11.1. Containers of contaminated PPE shall be labeled in accordance with Section 3.5.8 (Figure 3).

3.6.1 Respiratory Protection

For beryllium work that involves unknown exposures and that has a potential for airborne exposure, respiratory protection shall be used until at least one of the following conditions is satisfied:

* Personal samples have been taken, and exposures for worst case conditions are known to be less than the AL.

* The work has been evaluated and compared to other, similar work in which exposures are known to be less than the AL.

* The work has been evaluated, compared to other, related work (in which exposures are known to be less than the AL), and determined to have less exposure potential.

All workers requiring or wanting to use respiratory protection shall follow the requirements of Document 11.1. Respiratory protection shall be chosen by the ES

Table 4. Required respiratory protection.

Exposurea

Required Respirator

<0.2 µg Be/m3

None

<2.0 µg Be/m3 (<10 x AL)

Half-mask, negative-pressure respirator with P100 filter

<10 µg Be/m3 (<50 x AL)

Full-face, negative-pressure respirator with P100 filter or half-mask PAPRb with P100 filter

<20 µg Be/m3 (<100 x AL)

Full-face PAPR with P100 filter

<200 µg Be/m3 (<1000 x AL)

Supplied-air, full-face respirator operated in pressure demand mode

>200 µg Be/m3, unknown concentration, or firefighting

Full-face SCBA in positive pressure mode

a "Exposure" means measured exposure or potential for exposure at the indicated level.

b Powered, air-purifying respirator.

3.6.2 Other Personal Protective Equipment

The use of other PPE (e. g., gloves, lab coats, or coveralls), as determined by the ES

* Airborne exposures to beryllium equal or exceed the AL.

* Surface contamination exceeds, or is presumed to exceed, the housekeeping standard (i.e., 3 µg Be/100 cm2).

All workers required or wanting to use PPE shall follow the requirements of Document 11.1, which requires that the selection of PPE be documented. The processes of Document 2.2 shall also be followed.

3.7 Facilities and Equipment

Facilities used for beryllium work should be designed to minimize the spread of beryllium aerosols and to minimize beryllium contamination and opportunities for beryllium exposure. Therefore, such facilities have the following features:

* Beryllium work areas that are at negative pressure relative to non-beryllium work areas (e.g., beryllium machine shops).

* Building components (e.g., floors and walls) that are nonporous (for ease of decontamination), to the extent feasible.

* A facility layout that enables non-beryllium workers to enter and pass between non-beryllium work areas in the facility without entering a beryllium work area.

* Eyewashes and safety showers shall be provided where operations are done routinely in which eye or skin contact with dust or splinters is possible. Requirements for training the users of eyewashes/safety showers are found in Section 3.1.3 of Document 10.2 (for non-laboratory situations), and Section 3.2.6 of Document 14.2 (for laboratory situations). Requirements for testing safety showers/eyewashes are specified in Appendix B of Document 14.1. Engineering specifications are found in LLNL Facility Standard PEL-M-11610, "Emergency Eyewash and Shower Units."

When a regulated beryllium work area needs to be established (see Section 3.5.7), the change room and showers should be located as close as possible, and preferably adjacent, to the regulated area or located in such a manner that beryllium contamination is not spread throughout the facility or to other workers. The ES

3.8 Housekeeping

Beryllium work areas shall be kept as clean as the nature of the work allows during operational periods. The work area shall be cleaned at the conclusion of work. [The interior of a system (e.g., enclosure, glove box, chamber, or ventilation system) designed to contain beryllium contamination is not subject to this cleaning and sampling requirement.] Cleaning shall use techniques (e.g., wet methods or HEPA vacuuming) that do not produce airborne dust. Equipment used for cleaning beryllium-contaminated areas shall not be used for nonhazardous materials. Such equipment shall be labeled as beryllium contaminated using the label shown in Figure 3.

During nonoperational periods, beryllium work areas shall have residual surface contamination verified to be less than 3 µg Be/100 cm2 based on a routine sampling protocol that meets Appendix C guidelines. Sampling shall be conducted as often as necessary to ensure 95% confidence in meeting the housekeeping standard.

A nonoperational period is defined, based on the nature of the work, as the period commencing at either of the following:

o For ongoing, routine operations (i.e., production-type activities)--The end of the work shift or shifts, if work extends over one more consecutive shifts.

o For specific jobs (i.e., non-production or isolated activities)--The conclusion of the work, even if the work extends over 2 or more days. For long-term operations, the first definition applies.

3.9 Shipment and Receipt of Potentially Beryllium-contaminated Items

Operations involving shipment or transfer of potentially beryllium-contaminated items are subject to all the controls established in this document to minimize worker exposure to beryllium and to minimize the opportunities for exposure.

Classified beryllium parts shall be handled in accordance with this section when there is a potential for exposure to beryllium. See MDD Procedures Manual, Section 302.17, "Beryllium," UCRL-MA-124100 (UCNI), Materials Management Material Control and Accountability Manual, Volume A, "Material Control and Accountability Plan;" and Safeguards and Security Program Guide for specific requirements for classified parts.

Prior to shipment or transfer, potentially beryllium-contaminated items shall be cleaned to the extent practical taking into consideration the nature of the item and its subsequent use. Shipment and receipt of an item that is potentially contaminated with beryllium, or that has uncharacterized beryllium contamination, shall be handled to minimize the potential for exposure to airborne beryllium. The surface criteria standards listed in Table 2 in Section 3.3 of this document shall apply, except when:

* The item is too fragile to be swiped.

* Swiping of the item's surface would render the item unsuitable for experimental or investigative work.

* The item is composed of beryllium that may be released when handled or manipulated.

Transfer (i.e., movement of an item within the geographically contiguous property owned by, or under the control of, LLNL) shall comply with Document 21.2.

Shipment (i.e., movement of beryllium on public roads) shall comply with 49 CFR 100-199, "Research and Special Programs Administration, Department of Transportation." Assistance is available from the Hazardous Material Packaging and Transportation and Safety Office. The following beryllium-specific controls apply to preparation for shipment, actual shipment, and receipt of a potentially beryllium-contaminated item:

Preparation for Shipment

The Responsible Individual shall

* Document the shipment, including swipe results, if done, on the Equipment/Property Release Form as required by Document 21.5, "Requirements for Transfer of Equipment and Property for Repair, Reuse, Maintenance, Storage, Excess, or Scrap," in the ES

* Verify whether swiping the surface would render the item unsuitable for its intended purpose or investigation. (This fact shall be included with the shipping documents.)

* Ensure that swipes are taken to determine the level of contamination. If the item is not to be swiped, the item shall be assumed to be contaminated.