The Agency developed exposure profiles for these jobs based on air-sampling data from three sources: 1) samples taken between 1994 and 2003 at a large beryllium oxide ceramics facility, 2) air-sampling data obtained during a site visit to a primary beryllium oxide ceramics producer, 3) a published report that provides information on beryllium oxide ceramics product manufacturing for a slightly earlier time period, and 4) exposure data from OSHA's Integrated Management Information System (IMIS) (OSHA, 2009).  The exposure profile indicates that the three job groups with mostly indirect exposure (production support work, metallization, and administrative work) already achieve the proposed PEL of 0.2 μg/m[3].  Median exposure sample values for these job groups did not exceed 0.06 μg/m[3].
The four job groups with direct exposure had higher exposures.  In forming operations and machining operations, the median exposure levels are slightly below the proposed PEL (0.18 and 0.15 ug/m[3], respectively), while the median exposure levels for material preparation and kiln operations exceed the proposed PEL (0.41 μg/m[3] and 0.25 μg/m[3], respectively).
OSHA preliminarily concludes that the profile for the directly exposed jobs may overestimate exposures due to the preponderance of data from the mid-1990s, a time period prior to the implementation of a variety of exposure control measures introduced after 2000.  In forming operations, 44% of sample values in the exposure profile exceeded 0.2 ug/m[3].  However, the median exposure levels for some tasks, such as small-press and large-press operation, based on sampling conducted in 2003 were below 0.1 ug/m[3].  The exposure profile for kiln operation was based on three samples taken from a single facility in 1995, all above 0.2 ug/m[3].  Since then, exposures at the facility may have declined due to changes in operations that reduced the amount of time kiln operators spend in the immediate vicinity of the kilns, and the discontinuation of a nearby high-exposure process.  More recent information communicated to OSHA suggests that current exposures for kiln operators at the facility are currently below 0.1 ug/m[3], as discussed in the Exposure Profile for the Nonferrous Foundries section of this PEA (OSHA, 2014).   Exposures in machining operations, most of which were already below 0.2 ug/m[3] during the 1990s, may have been further reduced since then through improved work practices and exposure controls (PEA Chapter IV Section 7 -- Precision Turned Products). For forming, kiln, and machining operations, OSHA preliminarily concludes that the installation of additional controls such as machine interlocks (for forming) and improved enclosures and ventilation will reduce exposures to or below the proposed PEL most of the time.  OSHA requests information on recent exposure levels and controls in beryllium oxide forming and kiln operations to help the Agency evaluate the effectiveness of available exposure controls for this application group.
In the exposure profile for material preparation, 73% of sample values exceeded 0.2 ug/m[3].   As with other parts of the exposure profile, exposure values from the mid-1990s may overestimate airborne beryllium levels for current operations.  During most material preparation tasks, such as material loading, transfer, and spray drying, OSHA preliminarily concludes that exposures can be reduced to or below 0.2 ug/m[3] with process enclosures, ventilation hoods, and improved housekeeping procedures.  However, OSHA acknowledges that peak exposures from some short term tasks such as maintenance of the spray chamber might continue to drive the TWA exposures above 0.2 ug/m[3] on shifts when this task is performed, and that respirators may be needed to protect workers from exposures above the proposed PEL during this task.  OSHA notes that material preparation for production of beryllium oxide ceramics currently takes place at only two facilities in the United States.
References
ABI, 2006. American Beryllia Incorporated, Haskell, New Jersey. www.americanberyllia.com/pages/manufact.html. Accessed October 2.
ASME, 2002. The Beryllium Oxide Manufacturing Process. Technical Peer Review Report -- Report of the Review Panel. CRTD-Vol.69. Prepared by the American Society of Mechanical Engineers (ASME) Center for Research and Technology Development and the Institute for Regulatory Science for the Office of Science and Technology Development of the U.S. Department of Energy.
Berakis, M., 2009. Case Study: Working Safely with Beryllium Oxide. Occupational Health and Safety 5: 34 - 41.
Brush Ceramic Products, 2006. Beryllia Ceramic Material Safety Data Sheet - No. C10. Brush Ceramic Products Incorporated, Tucson, Arizona. January 12.
Brush Wellman Tucson, 2004. Individual full-shift personal breathing zone (lapel-type) exposure results for the Brush Ceramics Products facility in Tucson, Arizona. Samples collected between 1994 and 2003. Data provided to Eastern Research Group, Inc., Lexington, Massachusetts, on August 23, 2004. [Unpublished]
Cunningham, L.D., 2004. Beryllium Recycling in the United States in 2000. U.S. Geological Survey Circular 1196-P. October 14.
ERG Beryllium Site 3, 2003. Site visit to a beryllium oxide fabrication facility. Eastern Research Group, Inc., Lexington, Massachusetts. Recorded as a supporting document at www.regulations.gov, under Document ID number OSHA-H005C-2006-0870-0341. January 16 - 17.
ERG Beryllium Site 9, 2004. Site re-visit to a beryllium and aluminum-beryllium alloy machining and fabrication facility. Eastern Research Group, Inc. Lexington, Massachusetts. Recorded as a supporting document at www.regulations.gov under Document ID number OSHA-H005C-2006-0870-0341. February 3 - 5.
ERG Beryllium Site 10, 2006. ERG walkthrough survey of a beryllium oxide fabrication facility. Eastern Research Group, Inc., Lexington, Massachusetts. August 16.
Facility A-1, 2000. Telephone conversation between Facility A-1 and Eastern Research Group, Inc. January 23.
Facility B-1, 2000. Telephone conversation between Facility B-1 and Eastern Research Group, Inc. February 8.
Facility C-1, 2000. Telephone conversation between Facility C-1 and Eastern Research Group, Inc. February 8.
Facility D-1, 2000. Telephone conversation between Facility D-1 and Eastern Research Group, Inc. January 27.
Facility E-1, 2000. Telephone conversation between Facility E-1 and Eastern Research Group, Inc. February 15.
Facility G-1, 2000. Telephone conversation between Facility G-1 and Eastern Research Group, Inc. February 8.
Facility H-1, 2000. Telephone conversations between Facility H-1 and Eastern Research Group, Inc. January 26 and February 14.
Facility I-1, 2000. Telephone conversations between Facility I-1 and Eastern Research Group, Inc. January 26 and 28.
Facility J-1, 2000. Telephone conversation between Facility J-1 and Eastern Research Group, Inc. January 27.
Facility K-1, 2000. Telephone conversation between Facility K-1 and Eastern Research Group, Inc. January 27.
Facility L-1, 2000. Telephone conversation between Facility L-1 and Eastern Research Group, Inc. January 28.
Facility M-1, 2000. Telephone conversation between Facility M-1 and Eastern Research Group, Inc. January 26.
Facility N-1, 2000. Telephone conversation between Facility N-1 and Eastern Research Group, Inc. February 8.
Facility O-1, 2000. Telephone conversation between Facility O-1 and Eastern Research Group, Inc. February 8.
Frigon, T., 2004. Telephone conversation between Eastern Research Group, Inc.; Marc Corbett, consultant to Eastern Research Group, Inc.; and Tom Frigon, Environmental, Health and Safety Manager, Brush Ceramic Products, Tucson, Arizona. December 6.
Frigon, T., 2005. Telephone conversation between Eastern Research Group, Inc. and Tom Frigon, Environmental, Health and Safety Manager, Brush Ceramic Products, Tucson, Arizona. February 7.
Hosokawa Micron Group, 2005. Telephone conversation between Eastern Research Group, Inc. and a technical representative from Hosokawa Micron Powder Systems, Summit, New Jersey. January 13. Product information available at http://www.hosokawa.com/web/Stott/ and http://www.hosokawa.com.
Johnson, P.K., 2000. Powder Metallurgy. In Kirk-Othmer Encyclopedia of Chemical Technology. John Wiley and Sons, Inc., December 4.
Kent, M.S., 2005. Personal communications between Eastern Research Group, Inc. and Michael S. Kent, Director, Environmental, Health and Safety, Brush Wellman Inc., Elmore, Ohio. January and February.
Kolanz, M.E., 2001. Brush Wellman Customer Data Summary. OSHA Presentation, Washington, D.C. Marc E. Kolanz, CIH, Vice President, Environmental Health and Safety, Brush Wellman Inc., Cleveland, Ohio. Recorded as a supporting document at www.regulations.gov, under Document ID number OSHA-H005C-2006-0870-0091. July 2.
Kreiss, K., M.M. Mroz, L.S. Newman, J. Martyny, and B. Zhen, 1996. Machining Risk of Beryllium Disease and Sensitization with Median Exposures Below 2 ug/m[3]. American Journal of Industrial Medicine 30:16 - 25.
Materion, 2011. Product information for iso-pressed beryllium oxide ceramics and beryllium-containing metal matrix composites (AM 162H, AM 162 Extrusions, Electronic Materials E-20, E-40, and E-60). Materion Corporation, Mayfield Heights, Ohio. Product information available at http://materion.com/Products.aspx. Materion Corporation Product Groups: Beryllium Oxide Ceramics and Metal Matrix Composites (beryllium-containing). Accessed December 6, 2011.
NIOSH Beryllium Research, 2005. Beryllium Research Highlights, Issue 2. NIOSH Beryllium Research Program. U.S. Department of Health and Human Services, Centers for Disease Control and Prevention, National Institute for Occupational Safety and Health. Available at http://www.cdc.gov/niosh/topics/beryllium/pdfs/beryllium-issue2.pdf. July 2005.
NIOSH NOES, 1989. National Occupational Exposure Survey (1981 - 1983). Estimated Numbers of Employees Potentially Exposed to Specific Agents by 2-Digit Standard Industrial Classification (SIC). Agent Name: Beryllium Oxide (Agent Code X3577). U.S. Department of Health and Human Services, Public Health Service, Centers for Disease Control and Prevention, National Institute for Occupational Safety and Health. Cincinnati, Ohio. Available at http://www.cdc.gov/noes/noes1/x3577sic.html.
OSHA, 2009.  Integrated Management Information System (IMIS).  Beryllium exposure data, updated April 21, 2009, covering the period 1978 through September 2008.  Data provided to Eastern Research Group, Inc. by the U.S. Department of Labor, Occupational Safety and Health Administration, Washington, DC.  [Unpublished, electronic files]
OSHA-H005C-2006-0870-0094. U.S. Department of Labor, Occupational Safety and Health Administration. OSHA Beryllium Docket No. OSHA-H005C-2006-0870. Document ID No. OSHA-H005C-2006-0870-0094. Attachment 2.4. Beryllium Oxide Ceramic Production and Processing Facility. Comments Submitted by Brush Wellman, Inc. in response to Federal Register of November 26, 2002. February 21, 2003.
Parsonage, T., 2011. System Performance of a Lightweight Beryllium Composite Heat Sink for Advanced Electronic Packaging. Materion Brush Beryllium and Composites, Elmore, Ohio. Available at http://materion.com/~/media/Files/PDFs/Beryllium/ApplicationsElectrical-MAE/MAE-004SysPerfofaLtweightBeCompHeatSinkforAdvElecPkg.pdf. Accessed November 8, 2011.
Pekrul, E., 2004. Telephone conversation between Eastern Research Group, Inc. and Elissa Pekrul, contractor to Communications and Power Industries. December 2.
U.S. Census Bureau -Porcelain, 2002.  2002 Economic Census for Porcelian Electrical Supply Manufacturing, Document Number EC02-31I-327113 (RV). Available on the U.S. Census Bureau website at https://www.census.gov/prod/ec02/ec0231i327113.pdf.
U.S. Census Bureau, 2007. 2007 Economic Census. Available at http://www.census.gov/econ/census07/.
U.S. Census Bureau, 2010. County Business Patterns: 2010. Available at http://www.census.gov/econ/cbp/index.html.
Wikipedia, 2006. Sintering. Wikipedia, The Free Encyclopedia. Available at http://en.wikipedia.org/wiki/Sintering. Accessed October 2.

SECTION 4 -- BERYLLIUM OXIDE CERAMICS AND COMPOSITES, APPENDIX 1 -- PERSONAL EXPOSURE DETAILS
Table IV-21 -- Details of Personal Exposure in the Beryllium Oxide Ceramics Industry (1994 - 2003)
                               Job Category and
                                  Work Group
                             No. of Full-Shift PBZ
                                  Samples a
                                     Range
                                  (μg/m[3])
                                     Mean
                                  (μg/m[3])
                                    Median
                                  (μg/m[3])
Material Preparation Operator
                                      77
                                 0.02 to 10.6
                                     1.01
                                     0.41
Forming Operator
                                      408
                                 0.02 to 53.2
                                     0.48
                                     0.18
Tape casting [b]
                                      28
                                  0.03 to 5.6
                                     0.62
                                     0.14
Extrusion
                                      65
                                 0.04 to 0.88
                                     0.23
                                     0.17
Small press
                                      190
                                 0.02 to 53.2
                                     0.62
                                     0.18
Press setup
                                       3
                                 0.15 to 0.25
                                     0.20
                                     0.20
Large press
                                      115
                                  0.02 to 6.3
                                     0.36
                                     0.20
Isopress
                                       7
                                  0.06 to 1.0
                                     0.59
                                     0.83
Kiln Operator
                                       3
                                 0.22 to 0.36
                                     0.28
                                     0.25
Machining Operator
                                      355
                                  0.01 to 5.0
                                     0.32
                                     0.15
Ignition module machining
                                      35
                                  0.03 to 1.8
                                     0.22
                                     0.10
Surface grinding
                                       2
                                 0.03 to 0.05
                                     0.04
                                     0.04
Laser scribing
                                      27
                                 0.02 to 0.51
                                     0.12
                                     0.09
Complex machining
                                      80
                                  0.02 to 4.9
                                     0.22
                                     0.10
Drilling
                                       2
                                 0.18 to 0.20
                                     0.19
                                     0.19
Machining resistor cores
                                       3
                                 0.20 to 0.44
                                     0.28
                                     0.20
Lapping/Plate polishing
                                      60
                                  0.02 to 3.4
                                     0.58
                                     0.29
Dry (green) machining
                                      180
                                 0.01 to 4.99
                                     0.32
                                     0.16
Dicing
                                       1
                                     0.36
                                     0.36
                                     0.36
Metallization Worker
                                      36
                                 0.02 to 0.62
                                     0.15
                                     0.06
Production Support Worker
                                      119
                                  0.02 to 7.7
                                     0.21
                                     0.05
Packaging operator
                                      37
                                 0.020 to 0.50
                                     0.09
                                     0.05
Maintenance
                                      81
                                 0.02 to 7.70
                                     0.26
                                     0.05
Janitor
                                       1
                                     0.80
                                     0.80
                                     0.80
Administrative Staff
                                      185
                                  0.02 to 1.2
                                     0.06
                                     0.05
Office
                                      172
                                  0.02 to 1.2
                                     0.06
                                     0.05
Engineering and R&D
                                      13
                                 0.03 to 0.06
                                     0.05
                                     0.06
Total
                                     1,218
                                 0.01 to 53.2
                                     0.36
                                     0.11
[a]	The exposure profile is based on full-shift PBZ (lapel) total beryllium sample results. Full-shift sample results represent a sampling duration of 360 minutes or longer and have not been time-weighted for 8 hours (i.e., full-shift sample results are based on the actual sampling duration). Most samples (1,214 samples) were analyzed by NIOSH Method 7102 (Beryllium and compounds, as Be) or 7300 (Elements by ICP), and the analytical LOD was reported to be 0.1 ug beryllium per filter. For sample results below the analytical LOD, a sample weight of 0.05 ug (one-half the analytical LOD) was used to calculate the volume-adjusted nondetectable sample concentration. Four samples were analyzed using OSHA Method 125G, with a reporting limit of 0.02 ug per filter. Results reported as less than 0.02 ug are incorporated into the exposure profile as volume-adjusted reporting limit concentrations.
[b]	The 28 samples (7 percent of all forming operator samples) associated with tape casting are included, although tape casting is not currently performed.

Sources: Brush Wellman Tucson, 2004 (presenting data for ERG Beryllium Site 10); ERG Beryllium Site 3, 2003.

Table IV-22 -- Details Regarding Distribution of Full-Shift PBZ Exposure Results for Total
Beryllium in the Beryllium Oxide Ceramics Industry (1994 - 2003)
                               Job Category and
                                  Work Group
             Number of Full-Shift PBZ Sample Results in Range [a]
                                  (μg/m[3])
                                     Total
                                    No. of
                                    Samples

                                   < 0.1
                                  >= 0.1 to
                                    <= 0.2
                                  > 0.2 to
                                    <= 0.5
                                  > 0.5 to
                                    <= 1.0
                                  > 1.0 to
                                    <= 2.0
                                   > 2.0

Material Preparation Operator
                                      10
                                     (13%)
                                      12
                                     (14%)
                                      24
                                     (33%)
                                      15
                                     (20%)
                                       8
                                     (10%
                                       8
                                     (10%)
                                      77
                                    (100%)
Forming Operator
                                      110
                                     (27%)
                                      118
                                     (29%)
                                      115
                                     (28%)
                                      43
                                     (11%)
                                      15
                                     (4%)
                                       6
                                     (1%)
                                      408
                                    (100%)
Tape casting [b]
                                      11
                                     (39%)
                                       6
                                     (21%)
                                       6
                                     (22%)
                                       0
                                     (0%)
                                       2
                                     (7%)
                                       3
                                     (11%)
                                      28
                                    (100%)
Extrusion
                                      17
                                     (26%)
                                      23
                                     (36%)
                                      19
                                     (29%)
                                       6
                                     (9%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                      65
                                    (100%)
Small press
                                      56
                                     (30%)
                                      51
                                     (27%)
                                      53
                                     (28%)
                                      21
                                     (11%)
                                       6
                                     (3%)
                                       3
                                     (1%)
                                      190
                                    (100%)
Press setup
                                       0
                                     (0%)
                                       2
                                     (67%)
                                       1
                                     (33%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       3
                                    (100%)
Large press
                                      25
                                     (22%)
                                      35
                                     (30%)
                                      35
                                     (31%)
                                      12
                                     (10%)
                                       7
                                     (6%)
                                       1
                                     (1%)
                                      115
                                    (100%)
Isopress
                                       1
                                     (14%)
                                       1
                                     (14%)
                                       1
                                     (14%)
                                       4
                                     (58%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       7
                                    (100%)
Kiln Operator
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       3
                                    (100%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       3
                                    (100%)
Machining Operator
                                      142
                                     (37%)
                                      102
                                     (26%)
                                      87
                                     (22%)
                                      40
                                     (10%)
                                      11
                                     (3%)
                                       8
                                     (2%)
                                      390
                                    (100%)
Ignition module machining
                                      17
                                     (48%)
                                       8
                                     (23%)
                                       6
                                     (17%)
                                       3
                                     (9%)
                                       1
                                     (3%)
                                       0
                                     (0%)
                                      35
                                    (100%)
Surface grinding
                                       2
                                    (100%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       2
                                    (100%)
Laser scribing
                                      15
                                     (55%)
                                       7
                                     (26%)
                                       4
                                     (15%)
                                       1
                                     (4%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                      27
                                    (100%)
Complex machining
                                      36
                                     (45%)
                                      25
                                     (31%)
                                      15
                                     (19%)
                                       3
                                     (4%)
                                       0
                                     (0%)
                                       1
                                     (1%)
                                      80
                                    (100%)
Drilling
                                       0
                                     (0%)
                                       2
                                    (100%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       2
                                    (100%)
Machining resistor cores
                                       0
                                     (0%)
                                       2
                                     (67%)
                                       1
                                     (33%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       3
                                    (100%)
Lapping/Plate polishing
                                      15
                                     (25%)
                                       9
                                     (15%)
                                      15
                                     (25%)
                                      11
                                     (18%)
                                       6
                                     (10%)
                                       4
                                     (7%)
                                      60
                                    (100%)
Dry (green) machining
                                      57
                                     (32%)
                                      49
                                     (37%)
                                      45
                                     (25%)
                                      22
                                     (12%)
                                       4
                                     (2%)
                                       3
                                     (2%)
                                      180
                                    (100%)
Dicing
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       1
                                    (100%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       1
                                    (100%)
Metallization Operator
                                      20
                                     (55%)
                                       5
                                     (14%)
                                      10
                                     (28%)
                                       1
                                     (3%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                      36
                                    (100%)
Production Support Worker
                                      81
                                     (68%)
                                      24
                                     (20%)
                                       8
                                     (7%)
                                       3
                                     (2%)
                                       1
                                     (1%)
                                       2
                                     (2%)
                                      119
                                    (100%)
Packaging operator
                                      27
                                     (73%)
                                       8
                                     (22%)
                                       2
                                     (5%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                      37
                                    (100%)
Maintenance
                                      54
                                     (67%)
                                      16
                                     (20%)
                                       6
                                     (8%)
                                       2
                                     (2%)
                                       1
                                     (1%)
                                       2
                                     (2%)
                                      81
                                    (100%)
Janitor
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       1
                                    (100%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       1
                                    (100%)
Administrative Staff
                                      172
                                     (93%)
                                       9
                                     (5%)
                                       2
                                     (1%)
                                       1
                                    (0.5%)
                                       1
                                    (0.5%)
                                       0
                                     (0%)
                                      185
                                    (100%)
Office
                                      159
                                     (93%)
                                       9
                                     (5%)
                                       2
                                     (1%)
                                       1
                                    (0.5%)
                                       1
                                    (0.5%)
                                       0
                                     (0%)
                                      172
                                    (100%)
Engineering and R&D
                                      13
                                    (100%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                      13
                                    (100%)
Total
                                      574
                                     (47%)
                                      231
                                     (19%)
                                      249
                                     (20%)
                                      103
                                     (9%)
                                      36
                                     (3%)
                                      25
                                     (2%)
                                     1,218
                                    (100%)
[a]	The exposure profile is based on full-shift PBZ (lapel) total beryllium sample results. Full-shift sample results represent a sampling duration of 360 minutes or longer and have not been time-weighted for 8 hours (i.e., full-shift sample results are based on the actual sampling duration). Most samples (1,214 samples) were analyzed by NIOSH Method 7102 (Beryllium and compounds, as Be) or 7300 (Elements by ICP), and the analytical LOD was reported to be 0.1 ug beryllium per filter. For sample results below the analytical LOD, a sample weight of 0.05 ug (one-half the analytical LOD) was used to calculate the volume-adjusted nondetectable sample concentration. Four samples were analyzed using OSHA Method 125G, with a reporting limit of 0.02 ug per filter. Results reported as less than 0.02 ug are incorporated into the exposure profile as volume-adjusted reporting limit concentrations.
[b] 	The 28 samples (7 percent of all forming operator samples) associated with tape casting are included, although tape casting is not currently performed.

Sources: Brush Wellman Tucson, 2004 (presenting data for ERG Beryllium Site 10); ERG Beryllium Site 3, 2003.

SECTION 5 -- NONFERROUS FOUNDRIES
Industry Profile
Aluminum and copper foundries produce a variety of cast products using alloyed and unalloyed copper, aluminum, and other metals that at some foundries include castings of copper-beryllium and, to a lesser extent, aluminum-beryllium. Aluminum and copper foundries that produce or process beryllium alloys are classified in the following industries as defined by 2007 NAICS:
Aluminum foundries (except die-casting) (NAICS 331524 [SIC 3365]).
Copper foundries (except die-casting) (NAICS 331525 [SIC 3366]).
Other foundries perform die-casting of aluminum, copper, and other nonferrous alloys:
Aluminum die-casting foundries (NAICS 331521 [SIC 3363]).
Nonferrous (except aluminum) die-casting foundries (NAICS 331522 [SIC 3364]).
Copper beryllium alloys average about 70 percent of U.S. annual consumption of beryllium, most which contain approximately 2% beryllium.  Aluminum-beryllium alloys which contain 30% to 68% are used primarily in aerospace applications and account for less than 5% of annual consumption (Cunningham, 2004).  Table IV-23 shows U.S. Census Bureau data describing the copper and aluminum foundry industries.  At some of these establishments, pure beryllium is cast for specialized aerospace applications, however, the vast majority of beryllium is alloyed with other metals. Most beryllium alloys contain 5 percent or less of beryllium. Products produced by casting beryllium alloys include alloy ingots; non-sparking hand tools; welding electrodes and other parts of the welding electrode assembly, such as holders and shanks; and specialized parts for the electronics and aerospace industries.
OSHA has limited information on the number of foundries that cast beryllium and beryllium alloys. Based on discussions with representatives of the American Foundry Society and the Non-Ferrous Founders' Society, the number is likely to be small (Robinson, 2001; NFFS, 2002). Other industry sources, including representatives from copper and aluminum foundries, a resistance welding electrode manufacturer, and a brass and copper rolling mill, also indicated that few foundries cast beryllium and beryllium alloys, although they could not estimate the number (Barbetti, 2002; Capozzi, 2002; Erickson, 2002; Specialloy, 2002).
Table IV-23 -- Copper and Aluminum Foundries, 2010

              NAICS 331525, copper foundries (except die-casting)
             NAICS 331524, aluminum foundries (except die-casting)
                 NAICS 331521, aluminum die-casting foundries
       NAICS 331522, nonferrous (except aluminum) die-casting foundries
No. of Establishments
                                      208
                                      394
                                      254
                                      140
Total Employees
                                     5,123
                                    15,178
                                    18,017
                                     6,362
Source: U.S. Census Bureau, 2007; U.S. Census Bureau, 2010.

Copper Foundries
An analysis of sampling information from OSHA's Integrated Management Information System (IMIS) found that beryllium was detected in 20 percent of the 110 copper foundries where samples were taken during the period 1978 through 2008 (OSHA, 2009). An extrapolation of this percentage to the population of copper foundries (208) classified in NAICS 331525 suggests that about 42 such foundries work with copper-beryllium alloys. Industry contacts suggest that the number of foundries casting beryllium alloys has declined in recent years. Of seven foundries contacted that have used copper-beryllium, two have stopped using the material in recent years, therefore the current number is likely to be less than 42.  (Dollard, 2002; Enviro, 2001; Johnson, 2002; Specialloy, 2002; Taylor, 2001; Tricast, 2001; Worldcast, 2001).
Table IV-24 shows data from the U.S. Census Bureau (2002) describing the number of copper foundries with shipments in categories that include copper-beryllium, specifically high-copper alloys. The table shows that 25 firms produced copper and high-copper sand castings (NAICS<PHONE_NUMBER>), and 25 firms also produced investment castings out of high-copper alloys (NAICS<PHONE_NUMBER>0. Fewer foundries produced high-copper mold, centrifugal, and other types of castings. These categories are not exclusive, however, and firms might be listed more than once, and therefore, the number of foundries using high-copper alloys is less than the total shown in the table (89). If the number of unique foundries represented in Table IV-24 is one-half the aggregate, then the Census data suggest that about 45 copper foundries might potentially work with beryllium alloys. This estimate is consistent with the findings from OSHA's IMIS database, given the decline in copper-beryllium use in the foundry industry in the last decade.
Table IV-24 -- Number of Foundries Producing High-Copper Alloy Castings by NAICS, 2002
                    NAICS, Foundry Type, and Casting Method
                                 No. Foundries
All Copper Foundries (331525)
                                      208
33152504: Tin, bronze, copper, and high-copper alloy sand castings

3315250416: Copper and high-copper sand castings (except bearings and bushings)
                                      25

33152505: Other copper and copper-base alloy castings

3315250531: Permanent and semi-permanent mold castings
                                      12

3315250536: Centrifugal castings
                                      13

3315250541: Investments castings
                                      25

3315250546: Other castings
                                      10

 33152506: Copper-base alloy bearings and bushings, nonmachined*
                                       4

Total Firms Producing High-Copper Alloy Castings
                                      89
*	Includes high-copper as well as other types of copper alloys.

Source: U.S. Census Bureau, 2002: number of firms with $100,000 or more in shipments.

Aluminum Foundries
OSHA found little information on which to estimate the number of foundries in the United States that cast aluminum-beryllium alloys. The use of aluminum-beryllium alloys is much less common than the use of copper-beryllium. (Cunningham, 2004).  Copper-beryllium alloys are used in a variety of applications, including electronic and computer products, whereas aluminum-beryllium alloys are used primarily in specialized applications, such as the aerospace industry. In addition, a representative of an aluminum foundry indicated an apparent trend away from the use of beryllium alloys in aluminum foundries (Barbetti, 2002).
Based on information from the U.S. Census Bureau and industry sources, OSHA  estimates that 14 foundry companies cast aluminum-beryllium alloys (Kosto, 2002). Of these foundries, at least 12 are estimated to use aluminum-beryllium master alloys (Kosto, 2002). The remaining two foundries cast both pure beryllium and beryllium composite or hybrid products. These foundries make parts for specialized aerospace applications (MDA, 2011; Fedvendor.com, 2004-2005). For the purposes of this analysis, OSHA divided these establishments and assigned one half of the total, or seven establishments, to each of the two aluminum foundry industries (NAICS 331521 and 331524).
Nonferrous Die-casting Foundries (Except Aluminum)
OSHA found no information about beryllium alloy use among establishments classified in NAICS 331522 as nonferrous (non-aluminum) die-casting foundries. The U.S. Census Bureau, however, reported that 38 firms classified in this industry produce copper or copper-base alloy die-castings, including bearings and bushings (U.S. Census Bureau, 2002). Because these are the products most likely to contain beryllium, OSHA used this as an upper estimate of the number of such establishments that might work with copper-beryllium alloys.
Table IV-25 summarizes OSHA's estimates of the number of foundries that produce casts made from beryllium alloy metals. The number of employees are estimated based on the average employment sizes for the respective industries. OSHA, thus, estimates a total of 97 foundries with 3,601 employees.
Table IV-25 -- Foundries Casting Beryllium and Beryllium Alloys
                                   Industry
                                Establishments
                                Total Employees
NAICS 331521, Aluminum die-casting foundries
                                       7
                                      497
NAICS 331522, Nonferrous (except aluminum) die-casting foundries
                                      38
                                     1,727
NAICS 331524, Aluminum foundries (except die-casting)
                                       7
                                      270
NAICS 331525, Copper foundries (except die-casting)
                                      45
                                     1,108
Total
                                      97
                                     3,601
Source: ERG estimates; see text (Industry Profile for Aluminum and Copper Foundries).

Affected Job Categories
The metal casting industry uses many different casting processes for a wide variety of applications. The production of castings using beryllium alloys includes the following basic process steps: 1) preparing a mold into which the molten metal is poured, 2) melting and pouring the molten metal, and 3) cleaning the cooled metal casting to remove molding and extraneous metal (NIOSH 85-116). The primary job categories with potential for beryllium exposure in foundries are as follows:
Molder (including sand mold-maker and permanent mold maintenance).
Material handler.
Furnace operator (also melt operator).
Pouring operator.
Shakeout operator (only in foundries using sand molds or cores).
Abrasive blasting (shotblast) operator.
Grinding/finishing operator.
Maintenance operator (including furnace/ladle and ventilation system maintenance, housekeeping).
Furnace operators, pourers, and foundry supervisors are present in the foundry areas of the facility during the entire work shift (NIOSH EPHB 326-16a). The other job categories spend some portion of the shift in the production areas.
The volume, size, and type of castings produced vary widely from one foundry to another, ranging from a few large specialized castings to thousands of small castings per shift. Depending on the size of the foundry, each task may be performed by a separate operator or one operator may be responsible for several tasks. In high-production foundries, workers are likely to be responsible for a single task (e.g., molder, pouring operator, or furnace operator); in small or highly automated shops, a single worker may be assigned to several operations, such as combined responsibilities for furnace operation and pouring (NIOSH 79-114).
In addition to the categories listed above, other operations may occur in foundries, including pattern making, core making, welding, and X-ray inspection of castings. Welding is the subject of a specific section of this analysis and is not further addressed here (see Section 10 -- Welding). Inspection and radiography/X-ray processes are not normally associated with exposure to airborne beryllium at concentrations greater than the proposed permissible exposure limit (PEL) of 0.2 micrograms per cubic meter (ug/m[3]) (Interactive Guide Casting Alloys, 2012). Pattern and core making are precision processes typically involving new, uncontaminated non-metal materials (e.g., wood, sand, clay, plastic, Styrofoam, chemical agents) and are often performed in a separate foundry area, away from mold making and casting areas, with little potential for exposure.  OSHA assumes these activities are not associated with significant exposure.  And therefore, pattern making, core making and inspection of castings are not discussed further in this report.
Table IV-26 summarizes the major activities of workers potentially exposed to beryllium in foundries. Figure IV-1 illustrates a typical plant layout with two foundries: an aluminum-beryllium and copper-beryllium ingot foundry, and a green sand foundry that primarily manufactures copper-beryllium hand tools (NIOSH EPHB 326-16a).
Table IV-26 -- Job Categories and Major Activities of Workers Potentially
Exposed to Beryllium in Foundries
Job Category
Major Activities
Molder
(mold maintenance, mold formation, sand systems operation)
Maintains molds, removes metal deposits, and cleans molds in foundries with reusable molds. Monitors sand systems and molding machine operation in sand casting foundries. Applies mold parting/coating/release compounds.
Material handler
(forklift operator, crane operator)
Operates a front-end loader, forklift, crane, or other material-moving equipment to transport metal, castings, or other materials. Assists other workers with manual handling activities (such as furnace charging).
Furnace operator
(melt operator)
Controls and monitors furnaces used to produce molten metal. Loads metal into furnaces and skims dross from molten metal.
Pouring operator
(ladle operator, casting operator)
Transfers molten metal into ladle or holding furnace, and then into molds, typically via equipment supported by a cart, crane, or rail configuration.
Shakeout operator
In foundries using sand molds or cores, oversees operation of shakeout and knockout equipment to separate castings from molds. Contact with equipment and castings will depend on the degree of automation.
Abrasive blasting operator (includes wheelabrator operator, rotoblast operator)
Typically operates shotblasting cabinet; if very large casting, may blast on open floor or use compressed air to clean castings.
Grinding/finishing operator (includes saw operator and sanding operator)
Uses portable or bench tools such as chippers, grinders, and polishers or buffers to remove defects and adhered molding material from castings.
Maintenance operator
Repairs and maintains foundry and furnace equipment including repair and maintenance of ventilation system air cleaning devices and refractory lining on furnace, ladle, and tundish. Activities may also include housekeeping such as dry sweeping, vacuuming, and shoveling chips and metal splatter from floors and equipment.

Figure IV-1. Plant layout of a facility with two foundries: an aluminum-beryllium and copper-beryllium ingot foundry and a green sand foundry that manufactures a variety of copper-beryllium hand tools (Source: NIOSH EPHB 326-16a).
OSHA used BLS Occupational Employment Statistics Survey data to estimate the percentages of foundry workers in each of these job classifications (BLS, 2008). The percentages were adjusted to account for occupations specific to sand casting foundries (shakeout operator) and to ensure a minimum number of employees per establishment (at least one) in each job classification. The resultant percentages were then applied to the employment totals to estimate the number of employees by job category in the affected establishments. These estimates are shown in Table IV-27.
Table IV-27 -- Distribution of Beryllium Alloy Foundry Employment by Affected Job Category
                                 Job Category
                           Percentage of Employment
                              Number of Employees
Molder
                                    13.80%
                                      497
Material handler
                                     2.20%
                                      79
Furnace operator
                                     2.60%
                                      94
Pouring operator
                                     4.20%
                                      151
Shakeout operator
                                     1.14%
                                      41
Abrasive blasting operator
                                     2.40%
                                      86
Grinding/finishing operator
                                     7.20%
                                      259
Maintenance operator
                                     5.50%
                                      198
Total-affected job categories
                                    39.04%
                                     1,406
Other, non-affected occupations
                                    60.96%
                                     2,195
Total
                                    100.0%
                                     3,601
Sources: BLS, 2008; Table IV-25; and ERG estimates. See text (Affected Job Categories subsection in this  on Aluminum and Copper Foundries).

Descriptions of Affected Job Categories
Molder
Molders prepare, clean, and maintain permanent and non-permanent molds. Permanent (reusable) molds, or dies, require little daily preparation other than assembly and cleaning (brushing out old mold release agent, sweeping, scraping, and minor grinding). Beryllium-containing residue (in the form of oxides and base metal) can build up on the molds during the casting process, and molders may be exposed to beryllium as they remove this material along with the residual mold release agents. When molds will be reused immediately, workers perform these tasks in the pouring area (in foundries with a small workforce, molder and pouring operator tasks may be performed by one worker). Molds can also be transported to other areas for maintenance.
In facilities that use non-permanent molds (e.g., sand casting foundries), molders typically prepare molds by shaping granular media (sand or similar substances) and a binder into shapes that will form molten metal, but will disintegrate to the original granular structure when casting is complete. Sand casting methods do little to minimize oxide formation, and sand castings may be covered with beryllium oxide (Corbett, 2004). As a result, reclaimed molding sand may become contaminated with oxide and beryllium alloy dislodged from the casting during shakeout activities. This process creates a source of beryllium exposure for workers handling the sand and preparing molds in foundries that cast beryllium alloys.
Sand molders usually work in an area of the foundry that is functionally separate from other foundry activities; however, air monitoring of other toxic metals, such as lead and cadmium, in copper and bronze sand casting foundries indicates that molders can experience secondary metal fumes and dust exposures when poorly balanced ventilation systems allow contaminated air to flow from melting and pouring spaces to the molding area (CCMA, 2000). Results from OSHA's IMIS database indicate that molders can also be exposed to beryllium (OSHA, 2009). However, job descriptions in the IMIS database generally do not permit differentiation between workers handling reusable molds and those working with expendable or sand molds. For example, out of 85 job descriptions associated with molding, only five indicated the nature of the molds handled (one green sand mold and four permanent mold operators). Additional process and exposure information is required to determine the extent to which workers performing these tasks should be differentiated in the future.
Material Handler (Heavy Equipment Operator, Crane Operator, Forklift Operator)
Material handlers transport materials and castings between workstations. For these workers, the primary sources of beryllium exposure include ineffectively controlled processes associated with other job categories that the material handler must pass by or work near, spilled and settled dusts disturbed by the transport equipment they operate (e.g., forklifts), dust and fumes released directly from loads being transported by the material handler (e.g., fuming ladles, open barrels of excess metal trimmed from casting), and beryllium fumes and dust that cause cross-contamination in areas frequented by material handlers. Forklift operators who charge furnaces and who move receptacles containing dross (a scum at the surface of the molten metal formed by oxides and other contaminants) and scrap can experience airborne beryllium exposure from these sources. Forklift and crane operators who move new castings may encounter beryllium oxide dust from these items or be exposed to fumes as they pass near active melting and pouring operations. As other studies have shown, forklift drivers' exposure often is related to areas they enter where other workers' activities generate elevated airborne concentrations of contaminants (ERG Silica_GenInd1v.2, 2008).
Furnace Operator (Melt Operator, Furnace Assistant)
Furnace operators charge furnaces with new and/or reused metal (foundry scrap returns), supervise the melting process, sparge molten metal in the furnace (i.e., adding a gas-generating substance to promote mixing), and skim dross using a scoop or wand. The tasks associated with managing dross are reportedly among those that generate the highest and most frequent potential beryllium exposures in foundries (Corbett, 2004).
Furnace operators spend the majority of their time melting metal. For more automated processes, the furnace operators frequently spend a substantial amount of their shift in an office or control booth, monitoring the melting process remotely and through periodic checks. Certain tasks, however, must be performed for each melt. For example, furnace charges (raw materials in the form of ingot or foundry returns) must be prepared (weighed) to create the desired mix, pre-heated, and placed in the furnace (more than one charge may be required per melt). Heating the charge usually occurs in a large specialized bucket placed in a separate furnace. In addition to dust that might be released during the transfer process, preheating can cause air currents that disturb beryllium-containing dust, particularly on foundry scrap returned to the furnace for melting (the previous melting/casting cycle may have caused beryllium oxides to form). Transfer of the charge to the furnace may be manual or automated, depending on the size of the furnace and level of foundry automation. Furnace operators often transfer the raw materials (brought by a material handler to the furnace area) from a transport container to the special bucket used for preheating the charge or making additions to the furnace.
Once the raw material is loaded into the furnace, the operator initiates the melting process.  This involves several repetitive steps centered around the furnace. Induction furnaces, typically cylindrical without a refractory lid (open top), have been growing in popularity for a number of years and now are the most common type of equipment controlled by furnace operators. A furnace typically includes a small platform at the top for the operator. Some foundry designs also include a separate observation/control platform removed from the furnace or an enclosed control room.
Regardless of the furnace type or foundry design, most of the melting steps are similar. In one step, the furnace operator monitors the extent to which impurities in the metal and oxygen (from air at the molten metal surface) create dross. Furnace operators must remove this dross at regular intervals to improve the purity of the molten metal and prevent the newly forming oxides from becoming incorporated into the melt when it is stirred.
To skim the dross, the furnace operator typically uses a scoop on a long handle and reaches into the furnace to scoop the impurities from the surface. After emptying the scoop into a receptacle, typically a bucket, the operator repeats the process as many times as necessary. Extra beryllium may be added to the mix to compensate for beryllium lost as oxide and to ensure the final casting contains the correct percentage. Furnace operators are exposed to beryllium when they manipulate molten metal in the furnace (fumes rising off molten metal), when they bring dross off the surface and move the scoop outside the furnace, and when they knock the dross from the scoop into the receptacle. They can also be exposed when they handle the dross receptacle to transport it or empty it into a larger storage container. In addition to the beryllium hazard, this work is physically demanding and hot.
Other activities associated with the melting process include sparging the molten metal to stir it (adding a gas-generating substance on a wand or using an automated process), collecting samples for analysis (again manipulating molten metal in the furnace), and cleaning the melt deck. Operators also visually check the melt frequently to determine whether other actions are needed. Once the metal is properly formulated, melted, drossed, and sparged, the furnace operator adjusts the furnace for tapping (transferring molten metal out of the furnace for pouring). For example, in a typical operation, the furnace will be tipped to pour metal into a tundish (a refractory-lined vessel with one or more openings at the bottom for controlling metal flow into the molds) or a ladle (a container used to transport molten metal to another area where it will be poured). This point marks the beginning of activities in the pouring operator job category.
In smaller or more automated foundries, the same person will often do a number of jobs; for example, furnace operators can control both the furnace and the pouring operations (ERG Beryllium Site 7, 2003). These jobs are generally separate in larger foundries, so exposures and controls relating to pouring activities are addressed under the pouring operator job category. Some furnace operators also maintain furnace refractory linings, which are contaminated with beryllium/oxide from contact with molten metal that impregnates the semi-porous refractory surface. This task, often performed by maintenance staff, is addressed under the maintenance operator (furnace maintenance) category. Additionally, furnace equipment (e.g., dross handling equipment, furnace hoods/enclosures, and furnace tools) can become contaminated with beryllium. Furnace operators can be exposed during cleaning and service activities associated with contaminated equipment.
Furnace operators frequently receive help from designated furnace operation assistants and employees who normally work in other job categories (e.g., material handlers), but are appointed as helpers during the melt process (ERG Beryllium Site 7, 2003). OSHA has considered these helpers to be doing work associated with the furnace operator job category during their time working in the furnace area.
Pouring Operator
Pouring operators supervise the transfer of molten metal from the furnace (and any intermediary ladles) into molds. Depending on the type of casting performed by the foundry, these workers oversee a wide range of common molding equipment. Examples include sand molds, permanent molds such as dies, vacuum molding equipment (pulls molten metal into the mold using vacuum pressure), centrifugal molds (spins molten metal to force it out into a mold or to coat the inside of a spinning cylinder -- such as for manufacturing pipes), and water-chilled molds that quickly cool casting surfaces (Schleg and Kanicki, 2000). Depending on mold type, foundry staffing, and casting size, some or all duties may be shared by the furnace operator, the pouring operator, the molder, and/or the shakeout operator. One worker may perform all these jobs (ERG Beryllium Site 7, 2003).
Beryllium fumes can enter pouring operators' breathing zones as the fumes rise off molten metal in open ladles, tundishes, and molds. The American Foundry Society (AFS), in its Foundry Ventilation Manual (1985), notes: "Normally, copper and its alloying agents due to greater toxicity have lower allowable exposure levels (threshold limit values or permissible exposure levels) than ferrous metals and their alloying agents." Additionally, "copper-based alloys have a lower vapor pressure than ferrous metals. In the molten state, they produce more metallic fumes. Since the main reservoir for the molten metal is the ladle(s), the majority of emissions from these pouring operations emanates from that source, rather than the mold itself. Once copper-based alloys solidify, the emission of air contaminants drops to a very low level."
Fume escaping from any source into the work area contributes to background exposure levels in the pouring area and other areas where air currents transport the fumes. Other sources of beryllium exposure in the pouring area include any beryllium metal or oxide residue left on the molds (see molder job category) and refurbishing of the tundish and ladles (see maintenance operator job category). Adjacent operations can also influence employee exposure in the pouring area. For practical reasons, the pouring area is nearly always next to the furnace area, with minimal barriers between the two spaces. Beryllium fumes and dust released from the furnace area can be a substantial source of exposure for pouring operators. Shakeout areas, where new castings are separated from molds (particularly sand molds and cores), can also be adjacent to the molding area for convenience.
Exhaust ventilation systems are available for numerous types of equipment used in the pouring area; however, this equipment is not consistently installed in foundries. Additionally, some ventilation systems require special work practices and may be used improperly, which decreases their effectiveness.
Shakeout Operator
Shakeout operators separate molds from castings. If sand molds or sand cores are used in the casting process, shakeout operators use vibrating equipment to dislodge granular media ("sand"). This process is generally termed "shakeout." Under some casting conditions, beryllium oxide can form on the casting surface. In these cases, sand can be contaminated with residual beryllium oxide from contact with the cast metal surface.
Shakeout operators monitor equipment that separates castings from mold materials by mechanically vibrating or tumbling the casting. The castings, along with large lumps of molding sand and excess metal, remain on top, while fine materials (primarily molding sand) fall through grates. Sand separated during shakeout is transported away on a portion of the sand transport system and is frequently reused (overseen by another group of workers, molders). When melting and casting in the presence of oxygen in air, beryllium oxide typically forms on the casting surface. In these cases, sand can be contaminated with residual beryllium oxide from contact with the cast metal surface. Shakeout operators may tend automated equipment or perform manual operations, primarily loading and unloading the vibrating equipment. Additionally, in the case of large, heavy castings, a material handler (e.g., crane operator) may work in the shakeout area, hoisting the flask that contains the mold and then dumping it on a vibrating table. During this operation, a second operator may be responsible for re-hooking the cast metal piece onto the crane for transfer to the finishing area (NIOSH 79-114, 1978). Shakeout operations vary from manually handling and turning over the mold to systems that are fully automated (AFS, 1985).
A National Institute for Occupational Safety and Health (NIOSH) study described a manual shakeout operation at a copper-base casting operation. At this facility, an oscillating shakeout was mobilized on a set of tracks for shakeout at the end of the five mold conveyor lines. Three workers operated the shakeout, two to dump the molds from the pouring conveyor and simultaneously retrieve the bottom board, and the other worker to hook the casting off the conveyor (NIOSH 79-114, 1978). Workers may also use sledgehammers and compressed air to move excess sand from castings (NIOSH HETA 92-090-2296). These high-energy processes release substantial dust. If the molding materials are contaminated with beryllium, then beryllium dust could be released (Corbett, 2004).
Shakeout operators' duties frequently overlap with those of pouring operators and material handlers. For some casting methods that do not use granular media for molds or cores (e.g., extruded casting processes, or casting solid objects in permanent molds), the shakeout operator job category may be completely eliminated.
Abrasive Blasting Operator
Abrasive blasting operators clean castings to remove residual molding material (e.g., sand) and surface oxides, and to prepare the metal surface for additional treatment (e.g., painting). For the surface cleaning and preparation activities, these workers use abrasive media, usually steel shot or steel grit for the hardest alloys, or for softer alloys, a range of other organic and inorganic media (Belair, no date; Kramer, 2012). For smaller castings, abrasive blasting operators typically operate automated blasting machines (such as those made by Wheelabrator) or related equipment such as tumbling media mills or vibratory mills that perform a similar function in cleaning and preparing the casting surface. Large castings are abrasively blasted in booths, although castings too large to fit in a booth are typically blasted in large open areas with respiratory protection.  However, very few foundries produce beryllium alloy castings this large. Some abrasives can themselves be a source of additional beryllium exposure due to beryllium content of the abrasive media, or contain other toxic substances such as crystalline silica, other metals (KTA-Tater-Phase-I, 1998).
Grinding/Finishing Operator -- Description
Grinding/finishing operators perform any steps needed to finish castings.  They can use saws to remove gates, sprues, and risers or trim the casting to specification. These workers also perform grinding to remove minor casting surface defects. They finish castings by polishing, buffing, sanding, or grinding pieces to customer specifications. Grinding/finishing operators can use abrasive cut-off saws, stationary or hand-held grinding equipment, sanding equipment, and machine tools (precision machining activities are also grouped with this category). All of these items remove metal from the casting and create beryllium metal dust. Some grinding and sanding is performed to remove beryllium-containing oxide that forms on the product during the casting process. This work can be performed using wet methods in aluminum and copper foundries to reduce the amount of dust (ERG Beryllium Site 7, 2003). Additionally, some abrasive media can themselves be a source of additional beryllium exposure (due to beryllium content of the abrasive media).
Maintenance Operator
Maintenance operators repair equipment throughout the facility. These workers can be exposed to beryllium when they service foundry ventilation systems, repair production equipment, and maintain refractory materials.
Maintenance operators encounter beryllium while adjusting and repairing industrial ventilation system components such as bag houses and filters, or when emptying portable vacuum cleaners used to capture dust that contains beryllium. For example, maintenance operators must periodically change the filter bags in bag houses and filters in other air cleaning devices. This process can be dusty, particularly during upset conditions when a bag has deteriorated to the point that it has begun leaking dust. NIOSH reported on maintenance operators who inspected vacuum cleaners and cleared cyclone dust separators at a facility that cast beryllium alloy (in this case not classified as a foundry, but performing some of the same activities) (NIOSH HHE 78-17-567, 1979).
Maintenance operators also encounter beryllium when they chip and scrape refractory ceramic linings that have been in contact with beryllium alloys (e.g., in a furnace, ladle, or tundish). Although new refractory ceramic material (usually a cementitious mineral product) does not contain appreciable beryllium, molten metal and metal oxides coat (and in some cases impregnate) the semi-porous refractory surface upon use (Corbett, 2004). Oxides of beryllium can contain appreciably higher beryllium content than the original alloy. The oxide that accumulates on furnace, ladle, and tundish walls can have a beryllium content that is several percent higher than the beryllium alloy itself. Because refractory ceramic linings can be damaged by the heating and cooling cycles to which they are subjected, maintenance operators in some foundries must repair cracks and thin spots on a daily basis. Furnace maintenance workers may use a hammer and chisel, or scraping tools, or use power equipment (pneumatic chipping tools) to chip away damaged/cracked refractory lining before patching (Refractory Services Provider A, 2003; ERG Silica_GenInd1v.2, 2008). In some foundries, furnace operators and pouring operators also perform this task. At an ERG foundry site visit, tundish maintenance was performed immediately after the metal was poured, while the metal on the tundish was still hot. Debris was removed from one or more square feet of surface area and placed in a ventilated receiving container. The furnace operator then patched and painted the tundish with a coating similar to a mold-release agent. During this process, the furnace operator was exposed to fumes as he moved in and out of the effective range of the exhaust ventilation in the pouring area (Corbett, 2005).
Some maintenance workers may perform housekeeping tasks. Sources of exposure include beryllium-containing dust disturbed during housekeeping, such as handling contaminated equipment, dry sweeping, dry wiping, moving dusty items, and chipping splattered metal. At one beryllium alloy facility with both ingot and green sand foundries, production workers clean and maintain their work stations throughout the day and at the end of the work shift (NIOSH EPHB 326-16a). High-efficiency particulate air (HEPA) filter vacuums are used to clean equipment and work surfaces. A centralized (stationary) HEPA vacuum system is used in the ingot foundry, while portable HEPA vacuums are used in the green sand foundry and in the cutting and grinding shop.
Exposure Profile
Data Sources
For aluminum and copper foundries, OSHA examined the affected job categories, including mold maker, material handler, furnace operator, pouring operator, shakeout operator, abrasive blasting operator, grinding/finishing operator, and maintenance worker.
Limited information is available regarding worker exposure to beryllium in copper and aluminum foundries. The available sources of exposure information include:
Eight reports containing individual exposure results.
Surrogate exposure information from a primary beryllium producer.
IMIS sampling results.
Individual Exposure Results
OSHA identified eight sources of individually reported exposure results:
A 2003 ERG site visit conducted at a beryllium alloy casting facility hereafter referred to as ERG Beryllium Site 7 (ERG Beryllium Site 7, 2003). This facility uses direct chill casting methods to manufacture beryllium alloy casting and master alloy ingot (copper-beryllium, nickel-beryllium, and aluminum-beryllium). The beryllium content of the products range from 0.25 percent to 10.5 percent in the master alloys. A total of four personal breathing zone (PBZ) beryllium samples were obtained for three workers (furnace operator, furnace helper, and forklift operator) over two days. Casting was done during the night shift with only one casting done on a typical night. Because the workers were permitted to end the shift after they melted and poured one batch of alloy, the sampling periods for three of the four samples were less than 5 hours (i.e., 252 to 267 minutes), encompassing the employees' total exposure for a typical day. All four PBZ samples were positive for beryllium, with results ranging from 1.92 ug/m3 to 14.08 ug/m[3]. The air sampling rate was 2 liters per minute (lpm) and the samples were analyzed using OSHA Method 125G (Inductively Coupled Argon Plasma -- Atomic Emission Spectroscopy (ICAP-AES)). The analytical limit of detection was reported to be 0.02 ug beryllium per sample.
A 2007 NIOSH industrial hygiene evaluation conducted at a copper-beryllium foundry and machine shop that manufactures products for the metal die casting industry (NIOSH EPHB 326-11a). This foundry uses both sand mold and permanent mold systems in two different furnace operations and the products contain from 0.45 percent to 2.15 percent beryllium. Twenty-four PBZ and three general area air samples for beryllium were obtained over two consecutive days during normal plant operations. Most samples were more than 8 hours in duration due to the plant's 10-hour work shift. Beryllium was detected in all samples collected with PBZ concentrations ranging from 0.13 ug/m3 to 5.52 ug/m[3]. The three area samples were all obtained in the machine shop and ranged from 0.06 ug/m3 to 0.08 ug/m[3]. Sixteen of the 24 samples exceeded the NIOSH Recommended Exposure Limit (REL) of 0.5 ug/m[3] and seven indicated airborne beryllium concentrations greater than the current PEL of 2 ug/m[3]. The highest PBZ concentrations were associated with melting and casting, mold cleanout, sawing and grinding, and the machine shop. PBZ and general area samples were collected at a flow rate of 3 lpm and analyzed according to NIOSH Method 7300 (inductively coupled plasma spectroscopy).
Another 2007 NIOSH industrial hygiene evaluation conducted at a facility with both an ingot foundry and a green sand foundry (NIOSH EPHB 326-16a). The ingot foundry manufactures aluminum-beryllium and copper-beryllium ingots containing 1 percent to 5 percent beryllium. The green sand foundry manufactures a variety of copper-beryllium products (including non-sparking hand tools) that contain a maximum of 4 percent beryllium. A total of 23 full-shift air samples were collected on two consecutive workdays for beryllium and other metals (17 PBZ and six general area air samples) during normal plant operations. PBZ concentrations ranged from less than 0.03 ug/m3 to 1.07 ug/m[3] and general area samples ranged from 0.03 ug/m3 to 0.15 ug/m[3]. Three of the samples exceeded 0.5 ug/m[3] and none exceeded the current PEL of 2 ug/m[3]. The highest PBZ concentrations were associated with the grinding room, the foundry supervisor, and the aluminum-beryllium ingot furnace operator. PBZ and general area samples were collected at a flow rate of 3 lpm and analyzed according to NIOSH Method 7300 (inductively coupled plasma spectroscopy).
A site visit (Case History D) conducted in 1999 at a ferrous/non-ferrous centrifugal casting foundry by the California Cast Metals Association (CCMA, 2000). The case history includes a brief description of the pouring area and 10 PBZ air sampling results for beryllium for various job categories (such as melting and casting, abrasive blasting, machining, grinding, and others) obtained over several days. Most samples were at least 7 hours in duration. One beryllium result (2.2 ug/m[3]) during casting exceeded OSHA's current PEL for beryllium (2 ug/m[3]), while all other results were well below the PELs for the metals evaluated (many of these results were also below the limits of detection). Information regarding sampling and analytical procedures was not provided.
A 1983 NIOSH Health Hazard Evaluation (HHE) at a light-alloy foundry that manufactures aluminum and magnesium castings for the aircraft, missile, and aerospace industries (NIOSH HETA 83-015-1809). NIOSH investigators evaluated worker exposures to various chemical substances including beryllium in the foundry and welding areas of the facility. A chest X-ray obtained in 1982 of one beryllium-exposed employee showed findings consistent with sarcoidosis, a disease that can be difficult to differentiate from chronic beryllium disease. A total of 20 full-shift PBZ samples were obtained for beryllium. Thirteen of the samples were collected on furnace tenders (operators), five samples were collected on welders, and two samples were obtained on weld cleaners (removing unsightly burns, bluing, scale, discoloration and rust from welds). The metals were collected at a sampling flow rate of 2.0 lpm and analyzed by inductively coupled plasma-atomic emission spectroscopy. The analytical detection limit was 1 ug beryllium per sample. Although none of the samples contained detectable amounts of beryllium, NIOSH investigators reported that the sampling limit of detection (1 ug/m[3]) was not low enough to adequately evaluate the presence of airborne beryllium (NIOSH HETA 83-015-1809). Further, it was not known whether beryllium-containing castings were being processed at the time of the NIOSH evaluation. A description of the facility's engineering controls was limited to the pouring and cooling areas of the foundry. NIOSH noted the use of general dilution ventilation in these areas and a lack of LEV. Previous sampling conducted by a consultant to the company showed airborne concentrations of 0.2 ug/m[3] in the breathing zone of a pouring operator and concentrations of 1.1 ug/m3 to 1.4 ug/m[3] in the breathing zone of a weld cleaner working on a casting containing 0.03 percent beryllium (by weight). No other information was reported.
Two NIOSH HHEs conducted in 1975 and 1978 at a large beryllium extraction and manufacturing facility in Reading, Pennsylvania, that produced pure beryllium metal, beryllium oxide, and beryllium alloys (copper, nickel, and aluminum). The principal product produced, however, was copper-beryllium alloys (master alloy containing 4 percent beryllium and other forms containing 2 percent or less beryllium) including tools, wire, rod, tubing, strip, and sheet (NIOSH HHE 75-87-280; NIOSH HHE 78-17-567; Kriebel et al., 1988). Site processes included a foundry where alloys were cast into billets and sold as is or used to cast other alloys. The alloys were rolled or drawn to the proper dimensions and then tempered. During the 1975 evaluation, NIOSH investigators obtained 17 PBZ samples for beryllium in the foundry and melting and casting areas (NIOSH HHE 75-087-280). Sampling durations ranged from 306 minutes to 428 minutes and the air sampling rate was approximately 1.5 lpm. The samples were analyzed for beryllium using NIOSH Method P & CAM 121 with a beryllium limit of detection (LOD) of 1 ug per sample (NIOSH HHE 75-87-280; NIOSH HHE 78-17-567). In addition to air monitoring for beryllium and other metals throughout the facility, NIOSH conducted a review of randomly selected employee medical records, which indicated that one employee experienced beryllium dermatitis, one employee had acute beryllium pneumonitis, and nine employees had chronic beryllium disease.
During the 1978 evaluation at the Reading facility (NIOSH HHE 78-17-567), NIOSH investigated the beryllium exposure of maintenance employees (called Hygiene Assistants) whose activities included emptying the waste material collected in central cyclone floor vacuums and local exhaust ventilation (LEV) systems (i.e., releasing and bagging wastes from the vacuum system and dust collectors), periodic servicing of bag houses (e.g., inspection, rebagging, and cleaning), cleaning up spills (e.g., beryllium hydroxide), and decontaminating and vacuum cleaning work areas. During the evaluation, NIOSH investigators obtained two full-shift PBZ samples with results of 29.5 ug/m[3] and 31 ug/m[3] for maintenance workers dumping LEV cyclone collectors and inspecting and cleaning floor vacuums. The air sampling rate was 1.5 lpm and the samples were analyzed using both atomic absorption spectrophotometry (NIOSH Method P & CAM 121, LOD 1.0 ug per sample) and the graphite furnace technique (LOD 0.1 ug per sample).
In addition, NIOSH investigators obtained the results of the facility's quarterly OSHA abatement reports on beryllium exposures for several activities including melting and casting and ventilation system maintenance. In all, 50 positive full-shift PBZ sample results for five quarters (first quarter 1977 through first quarter 1978) were provided to NIOSH. These exposure results reflected ongoing abatement activities associated with OSHA citations.
A 1971 NIOSH air sampling survey conducted at a Hazelton, Pennsylvania, facility that converted beryl ore to beryllium metal, alloys, and compounds (NIOSH IWS-37-13; Bureau of Mines, 1971). Copper-beryllium master alloy was prepared by calcining beryllium hydroxide into beryllium oxide and then melting the beryllium oxide with copper and carbon powder in an electric arc furnace. The resulting copper-beryllium master alloy was cast into ingots containing about 4 percent beryllium. Copper-beryllium alloy containing about 2 percent beryllium was formed by melting the master alloy with copper in an induction furnace (EPA APTD-1508). During this survey, NIOSH investigators obtained 118 PBZ total beryllium samples throughout the facility. All samples were positive for beryllium and presumed to be full-shift. Most of the sample results are not applicable to the facility's foundry operations. Two relevant job categories for which PBZ data were obtained include furnace repair worker (1.90 ug/m[3], 3.76 ug/m[3], and 3.80 ug/m[3]) and maintenance mechanic (4.45 ug/m[3], 5.71 ug/m[3], 17.49 ug/m[3], and 35.97 ug/m[3]). These samples could reflect maintenance activities associated with the foundry operations. However, OSHA cannot be certain because the NIOSH report does not elaborate further and the facility's operations included other activities involving furnaces such as beryllium extraction from beryl ore.
Surrogate Data
OSHA obtained exposure data for melting and casting operations from a primary beryllium producer that operates copper-beryllium foundry facilities (Kent et al., 2001). Air sampling results and production process information was provided for alloy furnace operations.  Primary beryllium alloy operations occur in two different buildings and include master alloy production and beryllium alloy melting and casting. A Whiting four-electrode arc furnace is used for master alloy production and produces 4 percent copper-beryllium ingots. Feed material for the master alloy consists of copper and beryllium oxide pellets. Beryllium oxide is produced onsite by drying and rotary calcining beryllium hydroxide. The pellets are prepared by combining the resulting beryllium oxide with carbon and ventilation fines. Copper-beryllium alloys with a beryllium content of 2 percent or less are produced by coreless induction furnaces. Products include alloy ingots, rounds, and slabs (Kent et al., 2001).
Air sampling results from a 1999 baseline exposure assessment were provided for tasks associated with its master alloy and beryllium alloy melting and casting operations. These results are presented in Section 3 -- Beryllium Production of this report (subsections on Exposure Profiles and Technological Feasibility Analysis) and are used in this analysis as supporting information when appropriate. Samples were analyzed by NIOSH Methods 7102 or 7300 and the analytical limit of detection was reported to be 0.1 ug per sample. For results less than the limit of detection, a value of one-half the limit of detection was used to calculate the sampling limit of detection (Kent, 2005).
IMIS
IMIS entries for the years 1978 to 2008 also contain beryllium personal air sampling results associated with aluminum and copper foundries (SICs 3363 [NAICS331521], 3364 [NAICS 331522], 3365 [NAICS 331524], and 3366 [NAICS 331525]). These results are summarized by industry in Table IV-28 and include a total of 891 PBZ samples of which 183 (21 percent) measured detectable levels of beryllium. The means, medians, and distribution of positive-value IMIS results aggregated by relevant job categories are also shown in Table IV-28. Only IMIS results above the limit of detection are used to calculate the summary statistics. As noted in Section 2 -- Methodology of Chapter IV (Technological Feasibility) of the Preliminary Economic Analysis (PEA), IMIS data can be difficult to interpret because the database does not capture information pertaining to worker activities, workplace conditions, engineering controls, use of personal protective equipment (PPE), sampling time, and sampling limits of detection. Thus, when evaluating job descriptions in the IMIS database with potential beryllium exposure, it is not possible to determine whether beryllium was included in the sample analysis because there was potential workplace exposure to beryllium, or because it was analyzed as part of a routine metal screening. IMIS data are therefore used in this analysis in a supporting role to provide additional insight into the exposure profile of each affected job category.

Table IV-28 -- Summary of OSHA IMIS PBZ Beryllium Air Sampling Results for Aluminum and Copper Foundries
(SICs 3363, 3364, 3365, and 3366)[a]
                                      SIC
                                     Code
                                SIC Description
        No. PBZ Samples with Positive Results/Total No. PBZ Samples[b]
                              Job Descriptions[c]
                            (Positive Results Only)
                                   Range[d]
                                  (μg/m[3])
                                    Mean[d]
                                  (μg/m[3])
                                   Median[d]
                                  (μg/m[3])
                                     3363
Aluminum die-casting foundries
                                     3/38
                                     (8%)
Laborer
                                  0.17 to 0.2
                                     0.19
                                      0.2
                                     3364
Non-ferrous die casting foundries (except aluminum)
                                     17/76
                                     (22%)
Grinder; furnace operator; furnace tender; spinner operator
                                  0.01 to 13
                                     1.54
                                     0.05
                                     3365
Aluminum foundries
                                    68/199
                                     (34%)
Caster/casting; grinder; floor trimmer; foundry worker; furnace operator; furnace tender; inspection finisher; machine operator/machinist; mold maker/assembler; pourer/pouring operator; sander; sandblaster; sawyer; welder
                                 0.031 to 8.8
                                     1.22
                                     0.51
                                     3366
Copper foundries
                                    95/578
                                     (16%)
Caster/pourer; casting cleaner; castings finisher; foreman; furnace tender; grinder; grinding finisher; melter/caster; melter/pourer; metal chaser/chasing; molder/mold maker; patina; permanent mold; pourer/pouring; pouring supervisor; production worker; sandblaster, sanding; saw operator; shakeout operator; shifter/shakeout; smelter; welder, wheelabrator operator
                                  0.016 to 19
                                      0.2
                                     0.17
                                     Total
All aluminum and copper foundries
                                    183/891
                                     (21%)

                                  0.01 to 19
                                     0.11
                                      0.2
[a]	Information regarding worker activities, engineering controls in place, personal protective equipment worn, sampling duration, and sampling limits of detection is not available in the database reviewed by OSHA.
[b]	Includes all positive PBZ samples by SIC code regardless of the job description. Note that, for each SIC code, other types of samples (in addition to PBZ samples) may have been obtained such as area, screening, bulk, or wipe samples.
[c]	Not inclusive. Includes major job descriptions associated with positive PBZ results.
[d]	The range, mean, and median results are based on positive sample results only. All positive results are included.

PBZ: personal breathing zone

Source: OSHA, 2009 (OSHA IMIS database, June 1978 to September 2008).

Exposure Profiles for Affected Job Categories
The exposure profile for copper and aluminum foundries is summarized in Tables IV-29 and IV-30. For each job category, OSHA reviewed the available exposure information, as discussed above, and selected the best available data for the foundry exposure profile. For one job category, maintenance operators, OSHA was not able to identify exposure information specific to the foundry industry. For this group of workers, OSHA has relied on PBZ results from a primary beryllium producer, which uses some of the same processes encountered in foundries. The exposure profile for each job category is discussed below.
Table IV-29 -- Personal Exposure Profile by Job Category for Workers in Aluminum and Copper Foundries
(NAICS 331521, 331522, 331524, 331525)
                                Job Categories
                             Total Number Samples*
      Range
      (μg/m[3])
                                     Mean
                                  (μg/m[3])
                                    Median
                                  (μg/m[3])
Molder
                                       8
                                 0.24 to 2.29
                                     0.67
                                     0.45
Material handler
(crane/forklift operator)
                                       1
                                     0.93
                                     0.93
                                     0.93
Furnace operator
(melt/heating operator and assistants)
                                      11
                                 0.2 to 19.76
                                     4.41
                                     1.14
Pouring operator
                                       5
                                  0.2 to 2.2
                                     1.21
                                      1.4
Shakeout operator
                                       1
                                      1.3
                                      1.3
                                      1.3
Abrasive blasting operator
                                       5
                                 0.05 to 0.15
                                     0.11
                                     0.12
Grinding/finishing operator
                                      56
                                 0.01 to 4.79
                                     0.31
                                     0.05
Maintenance operator
(furnace/ventilation, housekeeping)
                                      78
                                 0.05 to 22.71
                                     0.87
                                     0.21
      All Job Categories
                                      165
                                 0.01 to 22.71
                                      0.9
                                      0.2
*	The exposure profile includes one or more non-detectable (ND) results as follows: furnace operator, two ND results; pouring operator, two ND results; and grinding/finishing operator, three ND results. Non-detectable results are reported as sampling limit of detection concentrations: in each case these were 0.2 μg/m[3] or less.

Source: CCMA, 2000; ERG Beryllium Site 7, 2003; NIOSH HHE 75-87-280; NIOSH EPHB 326-11a; NIOSH EPHB 326-16a; Brush Wellman Elmore, 2004; MC Pkg I-D, 2010.

Table IV-30 -- Distribution of PBZ Exposure Results for Total Beryllium in Aluminum and Copper Foundries (NAICS 331521, 331522, 331524, 331525)
                                Job Categories*
                     Number of Results in Range (ug/m[3])
                                     Total

< 0.1
>= 0.1 to <= 0.2
> 0.2 to <= 0.5
> 0.5 to <= 1.0
> 1.0 to <= 2.0
> 2.0

Molder
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       5
                                    (62.5%)
                                       2
                                     (25%)
                                       0
                                     (0%)
                                       1
                                    (12.5%)
                                       8
                                    (100%)
Material handler
(crane/forklift operator)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       1
                                    (100%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       1
                                    (100%)
Furnace operator
(melt/heating operator and assistants)
                                    0
(0%)
                                  2
(18.2%)
                                   1
(9.1%)
                                  2
(18.2%)
                                  2
(18.2%)
                                  4
(36.4%)
                                  11
(100%)
Pouring operator
                                       0
                                     (0%)
                                       2
                                     (40%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       1
                                     (20%)
                                       2
                                     (40%)
                                       5
                                    (100%)
Shakeout operator
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       1
                                    (100%)
                                       0
                                     (0%)
                                       1
                                    (100%)
Abrasive blasting operator
                                   2
(40%)
                                   3
(60%)
                                    0
(0%)
                                    0
(0%)
                                    0
(0%)
                                    0
(0%)
                                   5
(100%)
Grinding/finishing operator
                                  33
(58.9%)
                                  8
(14.3%)
                                  8
(14.3%)
                                   3
(5.4%)
                                   1
(1.8%)
                                   3
(5.4%)
                                  56
(100%)
Maintenance operator
(furnace/ventilation, housekeeping)
                                  12
(15.4%)
                                  27
(34.6%)
                                  18
(23.1%)
                                  11
(14.1%)
                                    7
(9%)
                                   3
(3.8%)
                                  78
(100%)
All Job Categories
                                  47
(28.5%)
                                  42
(25.5%)
                                  32
(19.4%)
                                  19
(11.5%)
                                  12
(7.3%)
                                  13
(7.9%)
                                  165
(100%)
*	The exposure profile includes one or more non-detectable (ND) results as follows: furnace operator, two non-detectable results; pouring operator, two ND results; and grinding/finishing operator, three ND results. Non-detectable results are reported as sampling limit of detection concentrations: in each case these were 0.2 μg/m[3] or less.

Source: See Table IV-29.

Molder -- Exposure Profile
The molder exposure profile is summarized in Tables IV-29 and IV-30. All eight samples included in the profile had detectable levels of beryllium, ranging range from 0.24 ug/m3 to 2.29 ug/m[3], with a mean of 0.67 ug/m3 and median of 0.45 ug/m[3]. Five of the eight results are between 0.2 ug/m[3] and 0.5 ug/m[3], while two additional values are greater than 0.5 ug/m[3] and less than or equal to 1.0 ug/m[3]. A single exposure level for a molder is notably higher, at 2.29 ug/m[3].
This exposure profile relies on full-shift PBZ samples obtained by NIOSH during an industrial hygiene evaluation at a copper-beryllium foundry in 2007 (NIOSH EPHB 326-11a). These samples represent the best available information for the molder job category because they were collected on the sand molding line at a foundry that performed both sand casting and permanent mold casting. Additionally, the samples were obtained relatively recently and are well characterized, in that information regarding sampling duration and work conditions and controls is available. OSHA acknowledges that these data were obtained from a single facility; however, information from other sources support this profile.
The highest value in the molder exposure profile (2.29 ug/m[3]) is associated with "mold cleanout" in the sand casting portion of the facility (NIOSH EPHB 326-11a). Information contained in the report is insufficient to explain why this result was markedly higher than the other molder results, but worker exposures of this magnitude were not uncommon at this foundry. During NIOSH's visit, exposures exceeding the current OSHA PEL of 2.0 mg/m[3] were widespread.
It is possible that lack of a dedicated ventilation system, work practices, and/or co-location exposures contributed to these results. Although the survey report does not specifically discuss work practices, NIOSH investigators made a general recommendation that HEPA-filtered vacuums should be used in beryllium work areas to remove dust from floors and work surfaces and that dry sweeping should be discontinued.  After the completion of the survey, the facility initiated a comprehensive upgrade of the entire ventilation system in the foundry areas. Molders might also have used compressed air to clean mold and core surfaces as this practice is common in some foundries (NIOSH HETA 91-0093-2126; NIOSH HETA 92-092-2333; NIOSH HETA 92-157-2304). High dust exposure can occur when brooms (dry sweeping) or compressed air are used for cleaning, and these practices must be prohibited as part of an effective beryllium control program (Materion SF 201, 2011).
An additional molder result (below the analytical limit of detection and reported as "ND") was obtained when NIOSH investigators conducted a health hazard evaluation at a beryllium alloy (copper and aluminum) casting facility in 1975 (NIOSH HHE 75-87-280). The full-shift PBZ sample was collected on a molder in the facility's alloy foundry area. However, OSHA did not include the result in the molder exposure profile because the beryllium analytical limit of detection was significantly higher in the 1970s than in more recent years.
OSHA also examined the IMIS results for molders in aluminum and copper foundries (SICs 3363, 3364, 3365, and 3366). As with all IMIS sample results, no information is available regarding the working conditions associated with these measurements. The IMIS database contains 88 PBZ results with mold and core making job descriptions (e.g., molder, mold maker, core maker, mold assembler, sand molder, automatic molder, permanent mold operator). Of these, 13 samples (15 percent) are positive for beryllium with a range from 0.02 ug/m3 to 5 ug/m[3], a mean of 1.48 ug/m[3] and a median of 0.9 ug/m[3]. The 13 positive results came from three different facilities (9 results for mold assemblers at a California establishment; 1 result for a molder in a Pennsylvania facility, and three results for permanent molders at an Ohio facility). The three highest results (1.98 ug/m[3], 4.67 ug/m[3], and 5 ug/m[3]) were obtained on permanent molders during a November 2007 inspection at the Ohio facility -- a copper-beryllium foundry with approximately 38 employees. This finding provides evidence of recent exposures to elevated levels of beryllium for molders in nonferrous foundries foundries. Eleven other samples are associated with molding and a second activity such as melting, pouring, or finishing. Each of these results is nondetectable for beryllium.
Although the range of NIOSH values (0.24 ug/m3 to 2.29 ug/m[3]) used in the molder exposure profile is within the range of positive IMIS data (0.02 ug/m3 to 5 ug/m[3]), the IMIS range is wider than the range of NIOSH values, and the mean and median values are approximately two times greater than the corresponding values in the exposure profile.  While this difference between the two sets of samples indicates that the molder exposure profile may be underestimating the median exposure for this group of workers, additional information for the alloy melting and casting operations at a primary beryllium producer signals otherwise. Fifteen full-shift PBZ samples obtained for workers maintaining permanent molds in the beryllium producer's copper-beryllium (containing 2 percent beryllium) melting and casting operations ranged from 0.09 ug/m3 to 2.88 ug/m[3], with a mean of 0.36 ug/m[3] and a median of 0.16 ug/m[3] (Brush Wellman Elmore, 2004). This range of values is similar to the NIOSH results used in the exposure profile and suggests that exposures for molders in nonferrous foundries may be similar regardless of whether they prepare sand molds and cores or maintain permanent molds. The mean and median values for the molders at the primary beryllium producer's facility are slightly lower than the corresponding values in the exposure profile. This difference in exposure could be attributable to the controls used by the molders at the beryllium producer's facility which include HEPA-filtered vacuum cleaners, down-draft tables and hoods and exhaust ventilated hose drops. Thus, based on the available information, OSHA assumes that the molder exposure profile is representative of the nonferrous foundry industry.
Material Handler -- Exposure Profile
Results for material handlers in beryllium alloy casting foundries are extremely limited. NIOSH reported a single positive full-shift (424 minutes) PBZ result of 0.93 ug/m[3] for a crane operator at the beryllium alloy (copper and aluminum) casting facility visited in 1975 (NIOSH HHE 75-87-280). At this site, alloys were cast into billets and sold as is or used to cast other alloys. This facility processed master alloy containing 4 percent beryllium, in addition to other forms containing 2 percent or less beryllium (NIOSH HHE 75-87-280; NIOSH HHE 78-17-567; Kriebel et al., 1988).
An additional less-than-full-shift sample result is also available, but not included in the exposure profile because in addition to typical material handler duties, the worker performed several tasks that are addressed under the furnace operator and grinding/finishing operator job categories (ERG Beryllium Site 7, 2003).
OSHA also reviewed the IMIS database for results applicable to material handling. For the years 1978 to 2008, the database contains only three results for material handlers in this industry. Each result was obtained at a different establishment (one result is for a forklift operator in Mississippi, one result is for a crane operator in Illinois, and one result is for a material handler in New York) and all three results are non-detectable for beryllium. Without knowledge of the limit of detection for these samples, of each facility's operations, and of whether beryllium alloy castings are produced, the non-detectable IMIS results do not provide additional insight into material handler exposure in aluminum and copper foundries.
In the absence of other results, OSHA has relied upon the single full-shift PBZ result of 0.93 ug/m[3] for the material handler exposure profile. OSHA acknowledges that a single data point may not be representative of furnace operator exposure in this industry. However, it is the only well characterized full-shift sample result available for this job category. Additional information is needed to increase the accuracy and reliability of the profile, particularly since there is some evidence that the single value might underestimate exposure for this job category. OSHA requests additional information to determine whether the material handler exposure profile is representative of the nonferrous foundry industry.
 Furnace Operator -- Exposure Profile
Workers in the furnace operator job category have the highest potential and most consistently elevated beryllium exposure of any job category in foundries. The elevated exposure is primarily related to handling of beryllium-containing dross, work practices that place the furnace operator's breathing zone in the path of fumes rising off the furnace, and inadequate design, operation, and maintenance of ventilation systems.
The exposure profile for furnace operators is summarized in Tables IV-29 and IV-30 and is based on 11 full-shift results obtained from five different beryllium alloy foundry operations (CCMA, 2000; ERG Beryllium Site 7, 2003; NIOSH HHE 75-87-280; NIOSH EPHB 326-11a; NIOSH EPHB 326-16a). These results are well characterized and represent the best available exposure data for furnace operators in nonferrous foundries (e.g., information on the sampling time, general working conditions and the nature of the operations at each foundry is available). Nine of the furnace operator results are positive for beryllium and two are non-detectable (both less than 0.2 ug/m[3]).
As shown in Tables IV-29 and IV-30, the 11 results range from 0.2 ug/m3 to 19.76 ug/m[3], with a mean of 4.41 ug/m[3] and a median of 1.14 ug/m[3]. More than one-third of the 11 results (four values, or 37 percent) are above the current PEL of 2.0 ug/m[3] and nearly three-quarters of the results (8 values, or 73 percent) exceed 0.5 ug/m[3].  Two of the sample results are less than 0.2 ug/m[3]. Among the results for which control information is available, OSHA notes a trend toward higher exposure levels in cases where ventilation systems were deemed inadequate or poorly designed for worker protection. The highest exposure (19.76 ug/m[3]) is associated with a furnace operator in a facility where LEV was provided at all operations where dust and fumes were generated; however, NIOSH investigators deemed most engineering controls inadequate and in need of re-evaluation (NIOSH HHE 75-87-280). The second highest result (14.08 ug/m[3]) is based on a sample obtained on a furnace operator in a facility that produces copper-, nickel-, and aluminum-beryllium casting and master alloy ingot. The elevated exposure may have been due to the design of the furnace canopy hood, which captured fumes from the melt but also covered the work area for the furnace operator, such that the furnace operator stood in the exhaust stream of contaminants from the furnace (ERG Beryllium Site 7, 2003). Other elevated exposures (such as 1.14 ug/m[3], 1.16 ug/m[3], 4.72 ug/m[3], and 5.52 ug/m[3]) were obtained relatively recently on furnace operators in a die casting foundry (NIOSH EPHB 326-11a). Although LEV systems were in place in the furnace areas, NIOSH investigators noted that the existing systems were either not always adequate to capture the emissions or were used incorrectly.
OSHA also reviewed the available IMIS data for information pertaining to furnace operators. OSHA identified 171 samples with job descriptions representative of furnace operators (such as furnace operator, furnace tender, furnace helper, melter, and others). Twenty-two of the job descriptions include a second work activity, primarily pouring (i.e., melting and pouring). Thirty-one (18 percent) of the 171 samples are positive for beryllium and were obtained from 12 establishments in 10 states. These results range from 0.01 ug/m3 to 45.7 ug/m[3], with a mean of 5.15 ug/m[3] and a median of 0.77 ug/m[3].  Forty eight percent of the samples are less than or equal to 0.2 ug/m[3] and 45 percent are greater than 2 ug/m[3]. The bimodal distribution of the positive IMIS results suggests substantial differences in work practices and engineering controls within the inspected facilities.
The IMIS results support the range of the data that make up the furnace operator exposure profile. However, the profile could be underestimating the exposure of this group of workers because the range of positive IMIS results (0.01 ug/m3 to 45.7 ug/m[3]) is significantly wider than the full-shift values used in the furnace operator exposure profile (0.2 ug/m3 to 19.76 ug/m[3]). The positive IMIS results also capture a larger segment of the nonferrous foundry industry (i.e., 12 facilities). Four of the highest IMIS results (6.2 ug/m[3], 14.3 ug/m[3], 39.2 ug/m[3], and 45.7 ug/m[3]) were obtained in 2007 at a copper-beryllium foundry in the Midwest. This demonstrates recent high beryllium exposures in aluminum and copper foundries, despite the increasing awareness over the past decade of the hazards of beryllium.
The full-shift PBZ results from the alloy furnace operations at a primary beryllium production facility (summarized in Section 3 -- Beryllium Production Exposure Profile and Technological Feasibility Analysis) also support the trend described by the positive IMIS results for foundry furnace operators. The beryllium producer reported 97 results for beryllium alloy operations involving induction furnaces, which range from 0.06 ug/m3 to 48.07 ug/m[3] (median 0.50 ug/m[3]; mean 1.46 ug/m[3]). At the same company, alloy melting using another type of furnace follows the same general trend; 38 results for workers involved with arc furnace operations ranged from 0.15 ug/m[3] to 9.37 ug/m[3] (median 0.95 ug/m[3]; mean 1.95 ug/m[3]). These data, together with the positive IMIS results, suggest that the exposure profile may be underestimating the maximum exposure for furnace operators in aluminum and copper foundries. The exposure profile is based on the best available data, however, and therefore OSHA assumes these data provide a reasonable representation of the distribution of exposures for this job category in the nonferrous foundry industry.
Pouring Operator -- Exposure Profile
The exposure profile for pouring operators includes five results from two sources of information: a NIOSH exposure assessment of mold pourers and other workers in a copper-beryllium foundry and a California Cast Metals Association case study that reports individual beryllium results for foundry workers in the pouring area (CCMA, 2000; NIOSH EPHB 326-11a). These are the only well-characterized exposure data available for pouring operators in the nonferrous foundry industry.
As shown in Tables IV-29 and IV-30, the five pouring operator results range from 0.2 ug/m3 to 2.2 ug/m[3], with a mean of 1.21 ug/m[3] and a median of 1.4 ug/m[3]. Three of the results, which include two values less than the sampling limit of detection (0.2 ug/m[3]) and a single value of 2.2 ug/m[3], were obtained on the same date during CCMA's site visit to a centrifugal casting foundry (CCMA, 2000). These results are associated with pouring/casting-area workers performing various tasks, including pouring metal. The pouring area was fitted with engineering controls such as mobile ladle exhaust hoods, fixed exhaust at the centrifugal mold pour spout, and a tight-fitting furnace-mounted exhaust hood on the adjacent furnace. The available supporting information does not indicate why this sample result is 10 times higher than the other two also obtained in the pouring area at the same foundry.
The two remaining individual full-shift PBZ samples include results of 1.4 ug/m[3] and 2.04 ug/m[3] (NIOSH EPHB 326-11a). NIOSH investigators obtained these samples on two workers who used a permanent mold system to produce copper-beryllium parts. The trough that funneled molten metal to the mold was equipped with a slotted hood attached to a LEV system. However, workers usually placed a cover over the mold and ventilation duct, a practice that reduced exhaust air flow and hampered emissions capture. NIOSH noted that process thermodynamics might also have been a factor in significant emissions.
OSHA also reviewed the IMIS database and identified 153 results applicable to pouring operators. The job descriptions associated with these samples include caster, casting, caster/pourer, cast helper, casting deck operator, cast machine operator, furnace deck pourer, ladle leader, pourer, pouring molds, pouring supervisor, and other related terms. Forty-five (29 percent) of the 153 IMIS samples are positive for beryllium and were obtained from 17 facilities in eight states. The positive IMIS values range from 0.016 ug/m3 to 8.8 ug/m[3], with a mean of 0.97 ug/m[3] and a median of 0.13 ug/m[3]. This median is one-tenth of the exposure profile median for this job category, suggesting that the exposure profile might overestimate pouring operator exposure levels. In addition to representing more facilities (17 compared to two), the larger IMIS dataset also is distributed more widely across all the ranges of interest, with a markedly larger percent exhibiting low exposure levels: 16 IMIS results (35.5 percent) are less than 0.1 ug/m[3], and 62 percent are less than or equal to 0.2 ug/m[3]. Both IMIS and the exposure profile include a substantial percent (in the case of IMIS, 16 percent) that exceed the current PEL of 2.0 ug/m[3]. OSHA also identified 33 IMIS results for workers performing metal pouring in conjunction with a second activity, such as melting, molding, grinding, mixing, or shakeout. Six of these results are positive for beryllium and range from 0.02 ug/m3 to 6.1 ug/m[3] (OSHA, 2009).
An additional sample result of 0.2 ug/m[3], reported for a metal pourer at the aluminum-magnesium foundry visited by NIOSH (NIOSH HETA 83-015-1809), was not used in the pouring operator exposure profile because no information is available about the sampling duration. This value does, however, further suggest that the exposure profile overestimates actual pouring operator exposures.
Based on the available information, OSHA finds that the beryllium exposure profile for pouring operators is representative of the nonferrous foundry industry, but acknowledges that the profile might overestimate the exposure experienced by these workers.
Shakeout Operator -- Exposure Profile
OSHA based the exposure profile for shakeout operators on one full-shift PBZ result from a recent NIOSH exposure assessment at a copper-beryllium die-casting foundry (NIOSH EPHB 326-11a). This is the only result available for the shakeout operator job category. The 587-minute PBZ sample was obtained on a "mold remover" in the foundry's shakeout operation and resulted in a concentration of 1.3 ug/m[3]. The greater than 8-hour sampling duration was due to the facility's 10-hour work shift. No specific information is provided to account for the shakeout operator's exposure. NIOSH investigators did note that the foundry shakeout area was equipped with in-wall fans, but that air flow was less than 50 feet per minute (fpm) at distances 15 feet to 20 feet from the fans. Although most of this foundry's operations were equipped with some type of LEV (not necessarily functioning optimally), NIOSH provided no details about LEV for the shakeout operation. Beryllium exposure was widespread at this facility, and the shakeout area was not the greatest source of exposure: overall, two-thirds of the samples collected at this facility exceeded 0.5 ug/m[3], and nearly one-third exceeded the current PEL of 2 ug/m[3] (the highest was 5.52 ug/m[3]) (NIOSH EPHB 326-11a).
OSHA also reviewed the IMIS database for supporting information. For the years 1978 to 2008, OSHA identified 27 results for shakeout operators. Job descriptions associated with this activity include mold breaker, power shakeout, shakeout operator, shake-up operator, and others. Two of the IMIS sample results are associated with multiple activities, e.g., shakeout and pouring, and shakeout and sand mixing . Six of the 27 results are positive for beryllium and were obtained from two different foundries. The positive results range from 0.05 ug/m3 to 0.5 ug/m[3], with a mean of 0.22 ug/m[3] and a median of 0.11 ug/m[3]. In this case, the positive IMIS results are all lower than the single value used for the shakeout operator exposure profile and suggest that shakeout operator exposures can be substantially lower than suggested by the exposure profile summarized in Tables IV-29 and IV-30. Like the NIOSH data, these concentrations indicate that the highest  beryllium exposures for shakeout operators tend to be lower than the highest exposures reported for other job categories in this industry (please refer to Table IV-30). This is in contrast to another air contaminant often released by shakeout operations: crystalline silica ("silica"). Worker silica levels for shakeout operators are routinely among the most elevated for foundry workers (ERG Silica_GenInd1v.2, 2008).
OSHA acknowledges that a single data point may not be representative of shakeout operator exposure in this industry. However, it is the only well-characterized sample result available for this job category. Additional information is needed to increase the accuracy and reliability of the profile. Pending such information, OSHA is assuming that the shakeout operator exposure profile is representative of the nonferrous foundry industry.
Abrasive Blasting Operator -- Exposure Profile
OSHA based the exposure profile for abrasive blasting operators on five sample results obtained during a series of industrial hygiene surveys conducted by the primary beryllium producer. The four employees used ventilated blasting cabinets (glove box type) to conduct abrasive blasting of beryllium alloy objects (previously cast in a foundry) at a facility where the castings are periodically abrasively blasted with aluminum oxide or steel shot during repair (MC Pkg I-D, 2010). Two of the exposure results (0.09 ug/m[3] and 0.14 ug/m[3]) are associated with a ventilation system that averaged 75 cubic feet per minute (CFM) per blast cabinet. Another two results (0.12 ug/m[3] and 0.15 ug/m[3]) were obtained at the same facility after system modifications to improve transport velocity, minimize unnecessary ductwork, and modestly increase air flow (114 CFM). A fifth result from the same (post modifications) time period in this series (0.05 ug/m[3], the lowest in this exposure profile) was also included in this group because a brief period of abrasive blasting and associated work cleaning out the blasting cabinet were this employee's primary potential sources of exposure for the day (MC Pkg I-D, 2010; OSHA, 2009). The investigator recommended additional changes intended to further decrease employee exposure (the report does not indicate whether those were implemented or provide follow-up monitoring). Together, these five full-shift samples for abrasive blasting operators in the exposure profile range from 0.05 ug/m3 to 0.15 ug/m[3], with a mean of 0.11 ug/m[3] and a median of 0.12 ug/m[3].
OSHA also identified a single short-duration (112 minutes) sample result with a sampling limit of detection of 0.7 ug/m[3] (i.e., the sample result was reported as less than 0.7 ug/m[3]) for an abrasive blasting booth worker (CCMA, 2000). The worker used a "blast booth" in a ferrous/non-ferrous foundry where exposure levels for several metals were all well below the respective PELs and usually below the limits of detection (CCMA, 2000). Assuming no additional exposure for the day, OSHA converted the sampling limit of detection to an 8-hour TWA (less than 0.16 ug/m[3]), which appears to support the sample results used in the exposure profile.
The IMIS data for this industry include 13 results for abrasive blasting. Job titles associated with the results include abrasive blasting, sandblaster, sandblast operator, wheelabrator operator, and others. Six of the results are associated with tasks in addition to abrasive blasting, such as cutting, cutting and grinding, and grinding and machining. Three of the abrasive blasting results are positive for beryllium and include the minimum value of 0.02 ug/m[3] and two results of 0.101 ug/m[3]. The positive results are associated with abrasive blasting (exclusive of any other tasks) and were obtained from three different establishments (OSHA, 2009).