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.

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.