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Under 10 CFR 850.2 (Applicability), articles are exempt from the requirements of the rule. The term "article," as used in the exemption, has a meaning that is subject to specific criteria derived from the OSHA Hazard Communication Standard (i.e., 29 CFR 1910) and from interpretations in OSHA Compliance Instruction CPL 2-2.38D. An article is a manufactured item that:
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* Is formed to a specific shape or design during manufacture.
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* Has end-use functions that depend in whole or in part on its shape or design during end use.
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* Does not release beryllium or otherwise result in exposure to airborne concentrations of beryllium under normal conditions of use.
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The following three examples illustrate the differences between items that can be considered articles and items that cannot:
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1. Example of a nonexempt item. A piece of beryllium stock that is to be machined into a part is not an article because (1) it is not in its finished form, (2) its use is dependent on that form, and (3) machining the piece will produce beryllium particulates in potentially hazardous quantities.
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2. Example of a nonexempt item. A finished part that has gone through the final cleaning step of its manufacturing process is swiped and found to have a residual surface contamination of less than 0.2 µg Be/100 cm2. However, further handling or use (e.g., abrading the surface or exposing the object to an environment that results in removable oxidation, but not including operations that do not abrade the surface) results in removal beryllium surface contamination greater than 0.2 µg Be/100 cm2. The part is no longer an article and is subject to the rule. Beryllium metal or beryllium-copper alloy objects are expected to meet this criteria; beryllium oxide objects may not meet the criteria, although the determination depends on use.
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3. Example of an exempt item. A finished part that has gone through the final cleaning step of its manufacturing process is swiped and found to have residual surface contamination of less than 0.2 µg Be/100 cm2, and further handling will not abrade the part's surfaces, i.e., there will be no removal beryllium surface contamination exceeding 0.2 µg Be/100 cm2. This part is an article and is exempt from the rule.
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Before a beryllium item is considered an article, the following process shall be implemented:
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1. The item shall be assumed to be contaminated until surface contamination is determined.
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2. Swipes shall be taken by the ES
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3. If swipes reveal contamination that is less than 0.2 µg Be/100 cm2, the article or its container shall be labeled as an article with the date of the sampling and sample numbers (see Figure 5). If labeling of the article or its container would be inappropriate, then a record of the results of swiping shall be maintained with other documents for the work process.
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4. If swipes reveal contamination that is greater than 0.2 µg Be/100 cm2, the part may be recleaned and surface contamination reevaluated. If the results are less than 0.2 µg Be/100 cm2, the part shall be labeled as an article (see Figure 5).
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Equipment that is purchased for LLNL use and that has internal beryllium components does not require further evaluation. The components are assumed to be articles unless worked on by LLNL personnel, at which point the components are subject to the controls of this document.
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4.0 Responsibilities
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All workers and organizations responsible for the safe handling of beryllium and its compounds shall refer to Document 2.1, "Laboratory and ES
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4.1 Workers
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Workers involved in work with beryllium shall:
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* Take the appropriate courses specified in Table 3.
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* Comply with all requirements of an activity's IWS and safety plan.
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* Notify the Responsible Individual whenever beryllium or beryllium-containing items are brought into the work area so that appropriate evaluation can be conducted.
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* Follow the procedures specified in this document for all purchases of beryllium.
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* Wear the provided PPE.
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* Complete the Beryllium Occupational History Questionnaire. (The questionnaire is available from the Health Services Department and from the area ES
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4.2 Responsible Individuals and Work Supervisors
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Responsible Individuals, principal investigators, and work supervisors shall ensure that:
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* A complete ES
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* A safety plan is prepared for all uses of beryllium that may result in any airborne concentration of beryllium or for any operation indicated by an ES
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* Beryllium work areas and regulated beryllium work areas are established, as appropriate.
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* The ES
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* Workers take the courses specified in Table 3 before beginning beryllium work that could result in an airborne exposure. The courses are offered by the Hazards Control Department.
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* Workers comply with all requirements of an activity's IWS or safety plan and follow the controls specified in this document.
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* Access to beryllium work areas is limited to authorized workers and visitors essential to the mission; non-essential visitors should be discouraged.
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* The storage, handling, and disposal of beryllium meet the requirements of this document and other requirements in the ES
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* Shipping or transfer of beryllium meet the requirements of this document and any other applicable document in the ES
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* A beryllium inventory is conducted, kept current, and provided to the facility manager.
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* Inform the technical release representative of all purchases involving beryllium and of the presence of beryllium in items.
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* All engineering controls (i.e., ventilation and HEPA filtration) function properly.
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* PPE is provided to workers who may be potentially exposed to levels of beryllium equaling or exceeding the AL or who may be involved in work with uncharacterized exposures.
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* Workers fill out the Beryllium Occupational History Questionnaire. (A new questionnaire shall be completed each time work assignments change.)
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* A formal exposure reduction and minimization program is developed by the impacted program with the assistance of the Hazards Control and Health Services Departments in the event that exposures equal or exceed the AL.
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* Beryllium workers and beryllium-associated workers are identified and reported to the payroll supervisor, to the Chemical and Biological Safety Section of the Hazards Control Department, and to the Health Services Department at least annually.
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* The presence of visitors and other ancillary personnel in beryllium work areas is approved.
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* Approved visitors and other ancillary personnel are briefed on hazards and controls in beryllium work areas.
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* Payroll supervisors are notified of training and medical surveillance for assigned workers.
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* Control of SRD beryllium parts meets the requirements of the Materials Management classified parts procedures.
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* Ensure that beryllium processing and control equipment is properly maintained.
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* Replace beryllium warning signs that have been removed or defaced.
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4.3 Payroll Supervisors
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Payroll supervisors are responsible for ensuring that:
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* Beryllium medical surveillance is offered to identified workers. This may be accomplished by contacting either the Health Services Department point of contact for beryllium surveillance or the Health Services Department clinician assigned to the supervisor's ES
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* Workers take the appropriate courses specified in Table 3.
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* The payroll organization is responsible for ensuring its assigned responsibilities in Appendix B are followed.
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4.4 Hazards Control Department
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The Hazards Control Department shall:
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* Review beryllium IWSs and safety plans.
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* Analyze the hazards of all beryllium operations, evaluate the hazards to workers, and document hazard assessments.
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* Evaluate new beryllium work against the CBDPP and initiate DOE review, if needed.
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* Conduct initial and periodic monitoring (i.e., personal air sampling) of beryllium operations when required.
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* Perform periodic sampling of surface contamination in beryllium work areas.
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* Maintain the industrial hygiene portion of LLNL's entries in the DOE beryllium registry.
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* Provide training identified in Table 3.
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* Assist an impacted program in development of a formal (i.e., written) exposure reduction and minimization program when measured exposures equal or exceed the AL.
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* Provide timely personnel exposure monitoring data to the Health Services Department and to employers of subcontract workers.
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* Work closely with the Health Services Department to review group exposure and group sensitization data.
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* Review all subcontractor contracts for compliance with 10 CFR 850.
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* Take swipe samples on equipment to determine the level of surface contamination.
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* Inform the authorizing organization and facility management of the need to establish beryllium work areas or regulated beryllium work areas.
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4.5 Health Services Department
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The Health Services Department shall:
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* Offer baseline and periodic medical surveillance examinations for beryllium workers and beryllium-associated workers who are UC employees.
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* Recommend temporary or permanent removal from beryllium work (if needed), including medical restrictions, and advise management of medical removal issues.
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* Provide counseling for UC employees who are diagnosed as being sensitized to beryllium or having CBD.
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* Provide training in the medical issues of beryllium sensitization and disease, the potential consequences of beryllium sensitization, and medical removal.
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* Maintain the medical portion of LLNL's and subcontractors' entries in the DOE beryllium registry.
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* Assist in development of a formal (i.e., written) exposure reduction and minimization program when exposures equal or exceed the AL.
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* Work closely with the Hazards Control Department to analyze group exposure and sensitization data.
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* Perform group analyses of beryllium medical surveillance data.
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4.6 Environmental Protection Department
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The Environmental Protection Department shall:
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