Operations Worker: Operations workers typically would be expected to have only limited exposures to fly ash in coal-fired power plants due to the nature of their work.  Four full-shift PBZ total beryllium exposure results reported for operations workers during a NIOSH HHE at the City of Ames, Iowa, municipal coal and RDF power plant (NIOSH, 1988) were nondetectable for beryllium.  Two of the samples were collected on the power plant auxiliary operator and two were collected on a fireworker (fireman).  The auxiliary operator assists the plant operator in the operation of power plant equipment; operates, lubricates, and inspects auxiliary power plant equipment; observes and records equipment operation parameters; tests various process water qualities; and operates the boiler bottom ash and fly ash removal equipment.  The power plant fireman operates control equipment in firing high pressure boilers; uses stoker and pulverized coal burning equipment and observes burning conditions of burners when firing coal, gas, oil, RDF, or combination fuels; operates soot blowers, fly ash removal equipment, boiler feed pumps, fans, pulverizers, and other boiler-related auxiliary equipment. During a NIOSH HHE conducted in 1991 at a coal-fired power plant in Healy, Alaska, beryllium was detected in two settled dust samples, but not in 15 full-shift air samples (12 area and 3 PBZ) collected and analyzed for elemental metals according to NIOSH Method 7300 (NIOSH, 1998).[,]  In a follow-up survey at this plant in 1993, 30 full-shift area samples were collected throughout all seven floors of the plant and analyzed for elemental compounds (NIOSH, 1998).  Results of that analysis indicated only trace quantities of metals present.  Area sampling locations included the control room, basement, coal pulverizer, burner deck, baghouse (various levels), turbine deck, coal tunnel (various levels), air intakes (various levels), boiler (various levels), and others.  These findings suggest that under routine operating conditions beryllium exposures for most power plant workers are low.
NIOSH investigators also noted that employees at the Healy power plant use compressed air and brooms to clean settled fly ash from plant surfaces (also called "blow down") and that the individuals doing the cleaning might expose themselves and other personnel throughout the plant to excessive dust.  Since there is the potential for exposure to arsenic, these procedures are prohibited unless other means have been tried and found not to be effective (29 CFR 1910.1018(k)(2)).  At least three operations jobs at the Healy plant have job duties that include some form of cleaning.  Relief control room engineers are responsible for general cleaning and assisting maintenance mechanics when not providing relief for other operators.  Auxiliary operators are responsible for monitoring equipment in the basement of the plant and operating the automatic ash removal equipment.  Other duties include cleanup of the first three floors and helping the assistant control room engineer during abnormal operating conditions.  The relief assistant's duties are the same as the relief control room engineer, except that this worker relieves the assistant and auxiliary positions only.  Since a total of 45 full-shift air samples collected throughout the Healy power plant were either nondetectable for beryllium or had trace levels, these findings suggest that elevated airborne dust levels associated with cleaning activities, some of which might be performed by operations workers, are not necessarily associated with elevated beryllium exposures.
Maintenance Worker: Maintenance workers have the highest potential exposure to fly ash and beryllium  (NIOSH, 1988, 1996, 1997).  The available exposure measurements for maintenance workers are summarized in Table IV.B-2.  The exposure profile is described by a median of 0.02 ug/m[3], a mean of 0.05 ug/m[3], and range from 0.01 to 0.39 ug/m[3].  These results are based on 96 full-shift PBZ total beryllium results for all workers classified in the maintenance category.  This category includes routine, emergency, and planned outage maintenance as well as other production-related work such as coal handling.  Job titles in this category for which exposure data are available include: maintenance worker, maintenance mechanic, electrical technician, boilermaker, laborer, and coal handler.  Although a majority of the data was obtained during scheduled outage maintenance activities, beryllium exposures associated with scheduled outage and other maintenance may be similar.  The operations manager at one coal-fired power plant reports that emergency tube leak repairs produce fly ash levels that are visually comparable to those of scheduled outage activities (Coal-Fired Power Plant A, 2006).
Routine Maintenance:  Ten of the sample results in the exposure profile were obtained on workers engaged in routine maintenance activities during a NIOSH HHE at the City of Ames, Iowa, municipal coal and refuse derived fuel power plant (NIOSH, 1988).  All 10 of the sample results for routine maintenance work are nondetectable for beryllium.  However, the LOD for beryllium was 0.5 micrograms at the time of the NIOSH survey.  Two of the routine maintenance samples were collected on an electrical technician, four of the samples were collected on maintenance mechanics, and the remaining four samples were obtained on maintenance workers.  The electrical technician installs, maintains, trouble shoots and tests a wide variety of electrical and electronic systems.  Maintenance mechanics perform skilled and difficult tasks involving the maintenance and repair of mechanical equipment.  This work includes machine work, steam fitting, plumbing, and welding; turbine, boiler, and auxiliary equipment repair; and inspection and repair of ash handling equipment.  Plant maintenance workers perform manual labor and semi-skilled work tasks.  These workers repack valves and assist with basic machine work, steam fitting, plumbing, cutting and welding; and turbine, boiler, and auxiliary equipment repair.
As noted, during subsequent HHEs at the Bruce Mansfield and Clinch River coal-fired power plants, the LOD for trace metals analysis was 0.02 micrograms per sample and the LOQ ranged from 0.06 to 0.12 micrograms per sample (NIOSH 1996, 1997).  If the nondetectable results for routine maintenance were based on the lower reporting limits, the results would be less 0.2 ug/m[3].
Scheduled Outage Maintenance: A majority (87 percent) of the sample results in the maintenance worker exposure profile were obtained while boilers were rebuilt during scheduled outages at the Bruce Mansfield and Clinch River coal-fired power plants (NIOSH, 1996, 1997).  Eighty-three full-shift PBZ samples were collected on plumbers, steamfitters, boilermakers, and laborers.  Fifty-one of the sample results were nondetectable for beryllium (0.02 ug/sample LOD), 28 samples had trace amounts of beryllium, and four samples had beryllium concentrations of 0.11 ug/m[3], 0.14 ug/m[3], 0.37 ug/m[3], and 0.39 ug/m[3].  To incorporate the trace results into the maintenance worker exposure profile, OSHA conservatively estimated the airborne concentrations of these samples by using the analytical limits of quantitation (0.06 ug/sample or 0.12 ug/sample) to quantify the trace airborne beryllium concentrations.  Although this approach might slightly overestimate the exposure profile for this job category, the resulting mean and median are less than the lowest PEL option (0.1 ug/m[3]) being considered by OSHA.
The four positive sample results that ranged from 0.11 ug/m[3] to 0.39 ug/m[3] were collected on workers that removed and replaced soot blowers (0.11 ug/m[3], 0.14 ug/m[3]) and boiler drains (0.39 ug/m[3]), and torch cut a rear exterior boiler wall casing (0.37 ug/m[3]).  During the boiler rebuilding activities, NIOSH investigators observed that workers were exposed to fly ash, metal fumes from hot work, and settled dust from fly ash and/or coal.  In some cases, the settled dust was five to six inches deep on work surfaces.  When workers removed boiler parts such as soot blowers and boiler drains, the settled dust became airborne.  NIOSH investigators also observed poor work practices, such as using compressed air to clean settled dust from surfaces, that created airborne dust (NIOSH, 1996, 1997).
One scheduled outage maintenance operation that is associated with higher beryllium exposures is maintenance of air pollution control equipment (Beaulieu et al., 2006; Beaulieu and Siert, 1997).  Beaulieu et al. (2006) conducted a 10-year exposure assessment of maintenance worker exposures to air contaminants (particulate matter, crystalline silica, and metals) at eight Colorado coal-fired power plants (four bituminous coal; four sub-bituminous coal).  Maintenance and cleaning of baghouse systems was evaluated at six of the plants and cleaning of electrostatic precipitators (ESPs) was evaluated at another plant with two ESP units.  For baghouse maintenance, worker exposures were evaluated during filter bag replacement and cleanup.  For ESP maintenance, worker exposures were assessed while shoveling fly ash from shelves for one type of ESP and erection of scaffolding and wash down for the other ESP.  Cleaning these air pollution control devices was reported to be extremely dusty.  The average respirable dust concentration measured during the baghouse cleaning was 9.5 mg/m[3] for the bituminous and 11.2 mg/m[3] for sub-bituminous coal, well above the OSHA PEL.  Beryllium exposures varied by the type of coal.  For baghouse bag changing in plants that burn bituminous coal, the mean of 15 full-shift PBZ samples was 0.2 ug/m[3] with a maximum of 1.2 ug/m[3].  Ninety-three percent of the results were less than or equal to 0.1 ug/m[3]; 7 percent of the results were greater than 0.1 ug/m[3] and less than 2.0 ug/m[3].  However, for bag changing in facilities that burn sub-bituminous coal, the concentration of beryllium was higher, with a mean of 14 full-shift PBZ samples of 2.4 ug/m[3] and a maximum of 13 ug/m[3].  Fifty percent of the beryllium results were less than or equal to 0.1 ug/m[3], 14 percent of the results were greater than 0.1 ug/m[3] and less than 2.0 ug/m[3], and 36 percent exceeded the current PEL of 2.0 ug/m[3].
To provide additional insight into the exposure profile for maintenance workers, OSHA also examined IMIS data for relevant supporting information.  For SIC groups 4911 and 4931, the IMIS data contains five PBZ entries with job descriptions representative of maintenance workers (see the beginning of this subsection on OSHA IMIS Data).  These job descriptions include mechanic welder (two samples collected in March 1994), pipe fitter (two samples collected in March 2002) and electrician (one sample collected in May 1987).  Both sample results for the mechanic welder are nondetectable (no volume-adjusted minimum detectable concentration available); the pipe fitter sample results are both 0.05 ug/m[3]; and the electrician sample result is 8.6 ug/m[3].  Although the IMIS data contain limited exposure information for maintenance workers, four out of the five sample results are nondetectable (< 0.05 ug/m[3] ) which indicates that typical beryllium exposures for maintenance workers are low. Thus, the baseline exposure level for maintenance workers is estimated to be less than 0.02 ug/m[3].  As previously discussed, during a HHE at the Healy coal-fired power plant in Healy, Alaska, 45 full-shift air area samples collected throughout the power plant were either nondetectable for beryllium or had trace levels, suggesting that beryllium exposures for most power plant workers are low at least under routine operating conditions (NIOSH, 1998).  Elevated exposures (exceeding the PEL) can occur for workers involved in air pollution equipment maintenance.
NIOSH investigators also noted that employees at the Healy plant use compressed air and brooms to clean settled fly ash from plant surfaces (also called blow down) and that these activities might expose the employees performing them, as well as other personnel throughout the plant, to excessive dust.  The clothing of maintenance workers becomes visibly soiled from cleaning settled dust or entering the baghouse to remove and/or clean filters.  These findings suggest that workers were exposed to excessive airborne dust levels due to maintenance activities which may be the root cause of the elevated beryllium exposures.  NIOSH investigators did not report PBZ total dust exposure levels for workers cleaning fly ash with compressed air and brooms during the Healy power plant health hazard evaluation.
Coal Handler: As shown in Table IV.B-2, the exposure data for coal handlers is based on three PBZ samples, each with results of 0.01 ug/m[3].  The published literature reviewed by OSHA contained no beryllium exposure data for coal handlers.  PBZ exposure data for air contaminants is available for coal handlers, but it is limited to respirable crystalline silica and coal dust results (NIOSH, 1981, 1984, 1988).  To estimate beryllium exposure for coal handling, OSHA used the only available PBZ exposure data -- three unpublished exposure results from the OSHA IMIS database.  These samples were obtained in February 1996 on workers with a job description of fuel handler at a coal-fired power plant.  Information pertaining to actual sample duration is not available; however, the sample results are listed as time-weighted averages and presumed to be representative of full-shift samples.
Description of Engineering Controls
Operations Worker: Operations workers are responsible for operating, controlling, and monitoring the routine production of electric power.  Most of the work shift may be spent inside an air-conditioned control room under positive pressure.  Several times a shift, operations workers conduct walk-through surveys of the entire facility to monitor and inspect the operation.  Potential exposure to beryllium can result when workers are outside the control room (e.g., when conducting walk-through surveys and inspecting equipment and processes) from worker movement or motion in areas where fly ash/coal dust has settled on exposed surfaces as well as airborne levels of fly ash/coal dust associated with boiler and process equipment leaks.  Other baseline conditions include some level of protective clothing and respiratory protection (depending on work activity or area) and routine housekeeping.  Some plants might use housekeeping techniques that generate considerable airborne dust such as dry sweeping and shoveling and the use of compressed air.
Operations workers have less exposure to fly ash and/or coal dust than maintenance workers and coal handlers.  The median exposure levels for scheduled outage maintenance and coal handling are both less than 0.1 ug/m[3], thus, the actual baseline exposure level for operations workers is also likely less than 0.1 ug/m[3].  Coal-fired power plants must ensure that they are in compliance with OSHA's arsenic standard which includes a provision on housekeeping.
Maintenance Worker: Potential maintenance worker exposure to beryllium is associated with worker movement or motion in areas where fly ash/coal dust has settled on exposed surfaces, as well as airborne levels of fly ash/coal dust associated with boiler and process equipment leaks.
Baseline conditions for maintenance include enclosed and ventilated boilers and process equipment.  During boiler rebuilding, exposure controls might include cleaning the interior surfaces of the boiler with high-pressure water; local exhaust ventilation (LEV); operating induced draft fans to ventilate the boiler (if available); and opening the stack dampers to create a natural draft.  Other baseline conditions include some level of protective clothing and respiratory protection (depending on work activity or area) and housekeeping (although housekeeping might include cleaning techniques that generate considerable airborne dust such as dry sweeping/shoveling and the use of compressed air).  Some plants might require good personal hygiene including the use of showers and on-site laundering of work clothes.
The median exposure level for all maintenance work is 0.02 ug/m[3].  Based on the available information, this value is also the best estimate of the typical exposure level for this job category.  Thus, the preliminary baseline exposure level for maintenance workers is estimated to be 0.02 ug/m[3].  Some maintenance tasks are associated with higher beryllium exposures.  To reduce these exposures, the following controls options could minimize the overall level of airborne dust:
Housekeeping procedures should be implemented and/or improved.  Fly ash/coal dust on working surfaces should be removed before work begins using wet methods and/or HEPA-filtered vacuums to minimize the suspension of settled dust.  Compressed air and the use of dry methods (such as sweeping and shoveling) should be prohibited.
Engineering controls such as LEV, operating induced draft fans and/or opening stack dampers should be used to reduce worker exposures to settled dust and fly ash during boiler rebuilding.
Good work practices to minimize exposure to dust should be implemented such as applying a water mist to exterior boiler panels and carefully placing them down after removal.
Boiler and process equipment leaks should be located and repaired to reduce in-plant airborne levels of fly ash/coal dust.
For workers involved in maintenance of baghouse systems, additional controls includeusing a pulley system to break up the ash cake and remove the bags, and inspecting the bags more frequently and promptly replacing them when leaks are detected (Beaulieu et al., 2006).  For ESP maintenance, additional exposure reductions can be achieved by increasing the cleaning frequency where possible during outages.
Fly ash contains other toxic metals, including arsenic and cadmium, for which OSHA has established substance specific standards.  Therefore, precautions to avoid exposure are routinely used during bag house maintenance and cleaning operations.
In sum, workers at coal-fired power plants can be exposed to beryllium due to trace amounts of beryllium in the fly ash in addition to other heavy metals.  The beryllium content of the fly ash is low (i.e., less than 0.01%), and exposures to beryllium during routine operations appear to be below 0.2 ug/m[3].  However, workers may be exposed to higher levels during very dusty maintenance operations such as cleaning the air pollution control devices.
References
Beaulieu, H.J., A.W. Siert, and S.C. Woods, 2006.  Exposures to Coal Fly Ash During Maintenance of Air Cleaning Devices in Power Plants.  Paper presented at the 2006 American Industrial Hygiene Conference and Exposition, May 13 - 18, Chicago, Illinois.
Beaulieu, H.J. and A. Siert, 1997.  Exposure Assessment of Maintenance Operations of Air Pollution Control Devices During "Outages" of Electric Power Generation Facilities: the Components of "Fly Ash" Dust.  [Abstract only]  Paper presented at the 1997 American Industrial Hygiene Conference and Exposition, May 17 - 23, Dallas, Texas.
Bird, M.J., D.L. MacIntosh, and P.L. Williams, 2004.  Occupational Exposures During Routine Activities in Coal-Fueled Power Plants.  Journal of Occupational and Environmental Hygiene, 1: 403 - 413.  June.
Clark, L.B. and L.L. Sloss, 1992.  Trace elements -- emissions from coal combustion and gasification.  IEACR/49, London, UK, International Energy Agency Coal Research, 111 pages (July 1992).  Cited in Trace Elements in Coal by Robert M. Davidson and Lee B. Clarke.  IEAPER/21, International Energy Agency Coal Research, London, UK.  January 1996.
Coal-Fired Power Plant A, 2006.  Telephone conversation between Eastern Research Group, Inc., Lexington, Massachusetts and the Operations Manager at Coal-Fired Power Plant A.  March 14, 2006.
EEI, 2010.  Edison Electric Institute website (Electricity Generation > Fuel Diversity > Coal). Accessed October 19, 2010 at http://www.eei.org/ourissues/ElectricityGeneration/FuelDiversity/Pages/Coal.aspx.
EPA, 1987.  Health assessment document for beryllium.  Prepared by Environmental Criteria and Assessment Office, Office of Health and Environmental Assessment, U.S. Environmental Protection Agency, Research Triangle Park, North Carolina, for the Office of Health and Environmental Assessment, Office of Research and Development, U.S. Environmental Protection Agency, Washington, DC.  EPA/600/8-84/026F.  Cited in Toxicological Profile For Beryllium, U.S. Department of Health and Human Services, Public Health Service, Agency for Toxic Substances and Disease Registry.  September 2002.
Kim, A.G. and G. Kazonich, 1999.  Mass Release of Trace Elements from Coal Combustion By-Products.  Paper #23 presented at the 1999 International Ash Utilization Symposium at the Center for Applied Energy Research, University of Kentucky, Lexington, Kentucky.  October 18 - 20.  Available online at http://www.flyash.info/1999/environ/kim2.pdf.
NIOSH, 1981.  Health Hazard Evaluation Report No. HETA 81-034, 035-934.  Colorado Springs Public Utilities, Colorado Springs, Colorado.  U.S. Department of Health and Human Services, Public Health Service, Centers for Disease Control, National Institute for Occupational Safety and Health, Hazard Evaluations and Technical Assistance Branch.  August.
NIOSH, 1984.  Health Hazard Evaluation Report No. HETA 81-119-1454.  James River Power Plant, City Utilities, Springfield, Missouri.  U.S. Department of Health and Human Services, Public Health Service, Centers for Disease Control, National Institute for Occupational Safety and Health, Hazard Evaluations and Technical Assistance Branch.  April.
NIOSH, 1988.  Health Hazard Evaluation Report No. HETA 86-422-1891.  City of Ames Municipal Power Plant, Ames, Iowa.  U.S. Department of Health and Human Services, Public Health Service, Centers for Disease Control, National Institute for Occupational Safety and Health, Hazard Evaluations and Technical Assistance Branch.  May.
NIOSH, 1996.  Health Hazard Evaluation Report No. 94-0273-2556.  Bruce Mansfield Power Station, Shippingport, Pennsylvania.  U.S. Department of Health and Human Services, Public Health Service, Centers for Disease Control, National Institute for Occupational Safety and Health, Hazard Evaluations and Technical Assistance Branch.  January.
NIOSH, 1996a.  Health Hazard Evaluation Report No. HETA 93-1062-2558.  Texas Utilities Company, Martin Lake Steam Electric Station, Tatum, Texas.  U.S. Department of Health and Human Services, Public Health Service, Centers for Disease Control, National Institute for Occupational Safety and Health, Hazard Evaluations and Technical Assistance Branch.  January.
NIOSH, 1997.  Health Hazard Evaluation Report No. 95-0393-2633.  Clinch River Power Plant, Cleveland, Virginia.  U.S. Department of Health and Human Services, Public Health Service, Centers for Disease Control, National Institute for Occupational Safety and Health, Hazard Evaluations and Technical Assistance Branch.  April.
NIOSH, 1998.  Health Hazard Evaluation Report No. HETA 91-0047-2672.  Golden Valley Electric Association, Healy Alaska.  U.S. Department of Health and Human Services, Public Health Service, Centers for Disease Control, National Institute for Occupational Safety and Health, Hazard Evaluations and Technical Assistance Branch.  February.
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]
Stadnichenko, T.M., P. Zubovic, and N.B. Sheffey, 1961.  Beryllium Content of American Coals.  U.S. Geological Survey Bulletin 1084-K: 253 - 295.  Cited in Toxicological Profile For Beryllium, U.S. Department of Health and Human Services, Public Health Service, Agency for Toxic Substances and Disease Registry.  September 2002.
Taylor, T.P., M. Ding, D.S. Ehler, T.M. Foreman, J.P. Kaszuba, and N.N. Sauer, 2003.  Beryllium in the Environment: A Review.  Journal of Environmental Science and Health.  Part A -- Toxic/Hazardous Substances and Environmental Engineering A38(2): 439 - 469.
U.S. Geological Survey, 2001.  Coal Combustion Products.  Minerals Yearbook: Volume I.  Metals and Minerals.  U.S. Department of the Interior, U.S. Geological Survey, Reston, Virginia.  Available online at http://minerals.usgs.gov/minerals/pubs/commodity/coal/coalmyb01.pdf.
WVGES, 2002.  Trace Elements in West Virginia Coals.  West Virginia Trace Element Summary Statistics.  West Virginia Geological and Economic Survey, Morgantown, West Virginia.  Website last revised: March 1, 2002.  http://www.wv.wvnet.edu/www/datastat/te/Statall.htm.  Website accessed on March 10, 2006.

Chapter IV -- Appendix C: Abrasive Blasting
Introduction
Abrasive blasting involves the use of hand-held or automatic equipment to direct a stream of abrasive material at high speed against a surface to clean, abrade, etch or otherwise change the original appearance or condition of the surface (WorkSafe, 2000).   Surfaces commonly treated by abrasive blasting techniques include iron, steel, aluminum, brass, copper, glass, masonry (brick, concrete, stone, etc.), sand castings, plastic, and wood (NIOSH, 1976).  Abrasive blasting is used for a variety of purposes, including but not limited to:
Cleaning surfaces by removing unwanted paint, rust, scale, dirt, salts, grease, and flux in preparation for painting, anodizing, welding, or other processes requiring a clean surface.
Deburring, removing tooling marks, or otherwise finishing a crude product.
Producing a desired matte or decorative finish.
Cutting or inscribing of partially masked parts such as tombstones.
Removing "flashing" (excess material) from molded plastic or rubber.
Changing metallurgical properties or stress relieving parts by the peening action of multiple impactions.
A number of possible blasting media can be used depending on the application.  The blasting media used as well as the surface being blasted can contribute to potential beryllium exposures.  When beryllium is considered, several blasting media appear to be the most problematic, including coal slag and copper slag.  Coal slag is the processed residue produced by coal-burning electric power plants.  "Black Beauty," a trade name for a coal slag abrasive product, accounts for about two-thirds of the market for coal slag (Greskevitch, 2000).  A NIOSH sponsored study of alternative media for use in shipyard blasting operations found that the level of beryllium in coal slag varies from one product to another.  However, all nine bulk samples of coal slag products analyzed in the study contained detectable levels of beryllium at concentrations ranging from 0.28 to 6.3 micrograms per gram of sample (ug/gm), suggesting that coal slag typically contains beryllium.  Copper slag produced as by-product at copper smelters can also be used as an abrasive.  The bulk analysis of 10 copper slag samples showed beryllium concentrations from 0.448 to 1.45 μg/gm (NIOSH/KTA-Tator, 1999).
Abrasive blasting can generate large quantities of dust that can contain high levels of toxic air contaminants.  The source of the air contaminants includes the base material being blasted, the surface coating(s) being removed, the abrasive being used, and any abrasive contamination from previous blasting operations (Burgess, 1991).  This means workers can have exposures to multiple air contaminants from both the abrasive and the surface being blasted.  Potential air contaminants that might be associated with abrasive blasting and their sources are listed in Table IV.C-1.
Table IV.C-1 -- Potential Air Contaminants Associated with Abrasive Blasting
Source
Potential Air Contaminants
Base Material
(e.g., steel, aluminum, stainless steel, galvanized steel, copper-nickel and other copper alloys)
Aluminum, chromium, copper, iron, lead, manganese, nickel, and zinc
Surface Coatings
(e.g., pre-construction primers, anticorrosive and antifouling paints)
Copper, barium, cadmium, chromium, lead, tributyl tin compounds, zinc
Abrasive Blasting Media
(e.g., coal slag, copper slag, nickel slag, steel grit, garnet, silica sand)
Arsenic, beryllium, cadmium, chromium, cobalt, crystalline silica, lead, manganese, nickel, silver, titanium, and vanadium
Source: EPA, 1997b; EPA, 2000; NFESC, 1996; NIOSH/KTA-Tator, 1999

Process Description
Abrasive blasting systems generally include an abrasive container or blasting pot, a propelling device, and an abrasive blasting nozzle.  The three propelling methods include air pressure, water pressure, and centrifugal wheels.  Air blasting systems use compressed air to propel the abrasive, water blasting systems use either compressed air or high pressure water, and centrifugal wheel systems use centrifugal and inertial forces (EPA, 1997a).
Air blasting systems include compressed air suction, compressed air pressure, and wet abrasive blasting systems (EPA, 1997a).  In compressed air suction systems, hoses are connected to a blasting gun or nozzle from the bottom of the abrasive blasting pot and the compressed air supply.  The abrasive blasting gun consists of a jet of high velocity air that creates a partial vacuum as it expands inside a larger outer nozzle.  This suction draws the abrasive into the outer nozzle and expels it through the discharge opening of the gun (EPA, 1997a).  Compressed air pressure systems include a pressure tank or pot that contains the abrasive.  The compressed air supply is connected to the top and the bottom of the abrasive pot.  This configuration forces the abrasive through the blast hose without loss of pressure.
Wet blasting techniques include wet abrasive blasting, air and water abrasive blasting, high-pressure water blasting, and high-pressure water and abrasive blasting (EPA, 1997a).  Wet abrasive blasting systems use a specially designed pressure pot to propel the water and abrasive with compressed air.  An alternative system uses a pressure pot and an adapter nozzle on the blasting gun to convert the system from a dry blasting unit to a wet blasting unit (EPA, 1997a).
In air and water abrasive blasting systems, the use of air, water, and the abrasive are varied.  High-pressure water blasting systems include a high-pressure water pump and hose and a blasting nozzle.  To provide high-pressure water and abrasive blasting, abrasives are added to high-pressure water blasting systems.
Centrifugal blasters use high speed rotating blades (spinning wheel) to propel metallic shot or grit to the surface to be prepared and provide for easy recovery of abrasive materials for reuse and recycling (Burgess, 1991; EPA, 1997b; Queensland Government, 1999).  Centrifugal blasters are typically used for large, flat surfaces such as ship decks, hulls, and storage tanks.  Small hand-held units are available for use on bridges and similar structures (EPA, 1997a).
Abrasives:  The most commonly used abrasives in the construction industry (e.g., to etch the surfaces of outdoor structures, such as bridges, prior to painting) currently include coal slag and steel grit (Meeker et al., 2006).  Shipyards are large users of mineral slag abrasives.  In a recent survey conducted for the Navy, the use of coal slag abrasives accounted for 68 percent and copper slag accounted for 20 percent of abrasive media usage as reported by 26 U.S. shipyards and boatyards (NSRP, 1999).
Workers who blast with coal slag abrasives are potentially exposed to beryllium, according to a NIOSH-sponsored study of substitutes for silica sand in abrasive blasting (NIOSH/KTA-Tator, 1999).  In addition to coal slag abrasives, the use of copper slag abrasives may also produce beryllium exposures, and the NIOSH study also found significant airborne concentrations of beryllium when this material was used for abrasive blasting.  Coal slag, however, is more commonly used (Greskevitch, 2000).
The use of coal and copper slag abrasives has increased in recent years as industries have sought substitutes for silica sand blasting abrasives to avoid health risks associated with respirable crystalline silica.  There has been limited published information regarding the potential for and health risks of beryllium exposure associated with the use of coal slag for blasting.  The potential for beryllium exposure during abrasive blasting appears to be widespread.
Affected Job Categories
Abrasive blasting is used in general industry, construction and maritime operations by painting contractors, welders, shipyards, aircraft manufacturers, foundries, steel mills and fabrication plants, structural steel supply yards, memorial monument markers, plating and anodizing shops, special purpose job and machine shops, building cleaners, gas transmission stations, canneries, breweries, wineries, rubber and plastic manufacturers, electronic manufacturers, petrochemical companies, wood shops and furniture manufacturers, and many others (NIOSH, 1976).
In general industry, most abrasive blasting for the purposes of cleaning or finishing metal parts is typically conducted in blasting cabinets or similar enclosures.  Some open blasting is performed in the concrete products and cut stone industries, but no significant beryllium exposures have been documented for these operations.  Open blasting of large objects (e.g., airplanes) might also be performed in other industries, but, again, any resultant beryllium exposures have not been documented.  Abrasive blasting of copper-beryllium alloy castings is described in Section 5 of Chapter IV of this PEA, Nonferrous Foundries.
For construction applications, abrasive blasting is done in blasting yards or rooms, or inside temporary enclosures constructed on-site.  For maritime applications, abrasive blasting may be conducted within a blast house, a building dock, a floating dry dock, a building or sliding ways, on the ground, on board a vessel, and at berth (NSRP, 2000).  Open-area blasting of bridges, structures, and ship hulls, is conducted by construction industry contractors or by shipyard operators.  To estimate the number of workers engaged in open-air abrasive blasting work in construction, OSHA used estimates originally prepared as part of a regulatory impact assessment of OSHA's draft silica regulation (ERG, 2008).  OSHA estimated the number of construction blasting workers based on (1) disaggregated construction investment data in the 1997 Economic Census for painting and other contractors (i.e., contractors likely to perform abrasive blasting) and (2) the 2000 Bureau of Labor Statistics (BLS) Occupational Employment Survey which reports "construction and maintenance painters" (U.S. Census Bureau, 1997; BLS, 2001).  OSHA extrapolated these estimates to 2006 by multiplying by the overall rates of employment growth in the relevant construction industries.  Using this approach, OSHA estimated that 21,643 workers perform abrasive blasting in NAICS 238320 (Painting and Wall Covering Contractors) and 4,403 in NAICS 238990 (All Other Specialty Trade Contractors).  The total, 26,047, is assumed to include blasting helpers and cleanup workers.
In ship and boat building and repairing (NAICS 336611), the 2007 County Business Patterns reports 638 establishments and 94,876 employees (U.S. Census Bureau, 2007).  According to estimates from Maritime Standards about 1 percent of shipyard employees may be involved in abrasive blasting, painting and cleanup operations (Daddura, 2011).  Using this percentage, OSHA estimates that 949 (.01 x 94,876) employees work as painters in ship and boat yards and might perform abrasive blasting as part of their work.  This estimate also includes blasting helpers and cleanup workers.
No information is available regarding the number of abrasive blasting workers in the construction sector who use various blasting media, such as silica sand, coal slag, and copper slag abrasives.  OSHA based its exposure profile estimates on the presumption that one-quarter of abrasive blasting workers in the construction sector are potentially exposed to beryllium and estimated that approximately 6,500 (0.25 x 26,047) construction blasters are potentially exposed to beryllium.  This conclusion is consistent with the relatively low beryllium exposure levels found for workers engaged in construction industry blasting operations.
For ship and boat building and repair, OSHA relied on a U.S. Navy study that reported coal and copper slag account for 94 percent of the blast media used at Naval ship repair facilities (NSRP, 1999).  Since it is unlikely that some blasting workers use only one type of blast media, OSHA assumed that all 949 shipyard blasters are potentially exposed to beryllium.
The primary abrasive blasting job categories in the construction and maritime industries include the abrasive blasting operator (blaster) and the pot tender (blaster's helper or assistant).  Support personnel might also be employed to clean up (e.g., by vacuuming or sweeping) and recycle spent abrasive and to set up, dismantle, and move containment systems and supplies (NIOSH, 1995).
Abrasive Blasting Operator (blaster):  Abrasive blasting operators abrade the surfaces of metal or hard-composition products using abrasive blasting equipment.  The most common method of abrasive blasting is dry abrasive blasting or air nozzle blasting.  In dry abrasive blasting, compressed air is used to propel abrasive material (media) from a blast pot (container or pressure vessel to contain the abrasive), through a flexible hose to a nozzle, where the operator directs it to the work piece at high velocity.  Air pressure is typically high at 100 pounds per square inch, and nozzle velocities can approach 650-1700 feet per second (Brantley and Reist, 1994).
Abrasive blasting operators manually direct abrasive blasting nozzles over the surfaces of large parts in open-air, portable or fixed facilities, blast cleaning rooms or booths, or in other enclosures or environments.  Alternatively, these workers might operate automatic machines or hand-operated blasting cabinets.
Pot Tender/Helper (also called machine tender, blast pot equipment operator, abrasive blasting helper or assistant):  Pot tenders are responsible for maintaining the blasting machine and assisting the blasting operator (e.g., shutting off the blasting machine upon a signal from the operator or in the event of an emergency such as accidental dropping of the nozzle end of the hose).  These workers keep the blasting pot (or hoppers) filled with clean abrasive, ensure proper abrasive feed rate, move air hoses, and tend the air compressors supplying breathing air and the blasting hose.  Pot tenders may also be responsible for cleaning up the spent abrasive (e.g., by vacuuming or sweeping) at the end of the day's blasting.  If a temporary enclosure has been erected, pot tenders might watch for dust leaks in the containment (Meeker et al., 2005).
Abrasive Media Cleanup Workers: Laborers designated as cleanup or recovery workers are responsible for cleaning up spent abrasive (e.g., by vacuuming or sweeping) at the end of the day's blasting.
Exposure Profile
To estimate the exposure profile for abrasive blasters, pot tenders/helpers, and abrasive media cleanup workers, OSHA used the findings from two National Institute for Occupational Safety and Health (NIOSH) evaluations of beryllium exposure from abrasive blasting with coal slag, unpublished shipyard results (1995 to 2004) for abrasive blasting operations from four U.S. shipyards, and data submitted by the U.S. Navy (NIOSH, 1983b; NIOSH, 2007; OSHA, 2005; U.S. Navy, 2003).  The latter was provided in response to the OSHA request for information regarding occupational exposure to beryllium (Federal Register, 2002).  These samples represent the best available data to characterize beryllium exposures for abrasive blasters.  Although OSHA's Integrated Management Information System (IMIS) database also includes exposure monitoring results indicating beryllium exposures in abrasive blasting operations, the IMIS data are not sufficiently detailed to be included in the exposure profile.  However, the IMIS data are discussed in this analysis as supporting information for the exposure profile.  Additional technical literature was also examined.  In the general literature, most studies have focused on other health hazards, particularly silica and lead exposures.  Nevertheless, some of the technical literature includes useful data on beryllium and is discussed below to support this analysis.
Integrated Management Information System
OSHA reviewed unpublished exposure data from IMIS for beryllium for the time period June 1978 through September 2008 (OSHA, 2004 and 2009).  As shown in Table IV.C-2, the OSHA IMIS data indicates a possibility of elevated beryllium exposures for abrasive blasting activities.  The data show detectable beryllium exposures occur frequently among construction workers (SIC major groups 15 to 17) performing blasting.  Out of a total 182 construction industry samples, 110 (60 percent) show detectible levels of beryllium, with a median of 0.7 ug/m[3] (positive results).  Approximately 35 percent of the positive samples exceed 2.0 ug/m[3].  For shipyards (SIC group 373), 33 of the 57 samples are for shipyard blasters .  Of these, 14 are detectible for beryllium with a median of 4.3 ug/m[3] (positive results) and 50 percent greater than 2.0 ug/m[3].  For the fabricated metal products industry (SIC major group 34), 17 out of a total of 40 samples are positive for beryllium, with a median of 0.55 ug/m[3] (positive results) and 12 percent greater than 2.0 ug/m[3].  For this application group, most of the positive exposure results are associated with fabricated metal products and coating, engraving, and allied services.
The rest of the manufacturing industry (SIC goups 28-32, 33, 35, 36, and 38-39)   accounted for 47 samples, with 15 showing detectable beryllium levels.  The range, mean and median reported in Table IV.C-2 include only positive IMIS results because the volume-adjusted reporting limit concentrations for nondetectable samples are not available.  Since a significant number of the sample entries are nondetectable for all sectors evaluated (51 percent), the summary statistics based on the samples with detectable results are likely to overestimate the true exposure profile for abrasive blasters.  For the remaining industries (SIC groups 40-49, 70-89, and 91-99), the 14 abrasive blasting observations are concentrated among several four-digit industries.  Of the 6 positive samples for these groups, one (0.3 ug/m[3]) is accounted for by SIC 4231, Terminal and Joint Terminal Maintenance Facilities for Motor Freight Transportation.  Two of the positive samples (0.071 ug/m[3] and 47.0 ug/m[3]) are accounted for by SIC 7538, General Automotive Repair Shops.  The remaining three positive samples (0.18 ug/m[3], 0.44 ug/m[3], and 0.7 ug/m[3]) are accounted for by SIC 7699, Repair Shops and Related Services, Not Elsewhere Classified.
Table IV.C-2 includes three positive abrasive blasting results from OSHA consultation surveys; however, SIC codes for these establishments are not available.  The OSHA consultation results include the highest beryllium concentration in the IMIS database for a PBZ abrasive blasting sample (1,781 ug/m[3]).
The results from the IMIS database suggest that blasting in blast cabinets or similar enclosures does not result in elevated beryllium exposures.  Based on the job descriptions provided in the IMIS records, OSHA identified 18 samples of abrasive blasting that might reflect use of blast cabinets and enclosures (e.g., wheelabrator operator, rotoblast man, blaster-shothouse, or booth blaster).  Of these samples, seven showed detectible levels of beryllium, but only one exceeded 0.2 μg/m[3] (0.25 μg/m[3]).  The median (0.05 μg/m[3]) and the mean (0.084 μg/m[3]) of the detectible samples are both well below the lowest of the Permissible Exposure Limit (PEL) options.  The IMIS data do not, however, provide information about the conditions of blasting operations so little interpretation of the results is possible.  As noted, the IMIS data does not report the volume-adjusted nondetectable sample concentrations so some non-detectable samples might not have fallen below the lower PEL options.
For all SIC codes combined (including the OSHA consultation data), the IMIS database contains 343 entries with job descriptions representative of abrasive blasting operators.  Of these, 49% found detectable beryllium.  As noted, the volume-adjusted reporting limit concentrations for the nondetectable samples are not available.  The 169 positive results are described by a median of 0.56 ug/m[3], a mean of 34.95 ug/m[3], and a range from 0.02 ug/m[3] to 1,781 ug/m[3].  Since approximately 51 percent of the abrasive blaster results are nondetectable, the positive IMIS results for abrasive blasters likely overestimate the true median for this group of workers.
Table IV.C-2 -- OSHA IMIS PBZ Total Beryllium Air Sampling Results for Abrasive Blasting Workers[a]
                                      SIC
                                     Group
                                SIC Description
        No. PBZ Samples with Positive Results/Total No. PBZ Samples[b]
                               Job Descriptions
                       (as listed in the IMIS database)
                                   Range[c]
                                  (μg/m[3])
                                    Mean[c]
                                  (μg/m[3])
                                   Median[c]
                                  (μg/m[3])
15-17
Construction
                                    110/182
                                (60% positive)
Abrasive, abrasive blaster, abrasive blasters, abrasive blasting, blast oper, blaster, blaster 1, blaster helper, blaster/painter, blaster/painter-mix, blaster/shooter, blasting operator, grinder blaster, interior blaster, machine tender, painter blaster, painter/blaster, pot tender, sand blaster, sand blasters, sandblaster, sandblaster asst, sandblaster/assistant, sandblasters, sandblasting, shot blast assist, shot blaster, shot vacuum operator
                                 0.01-1,400.00
                                     35.12
                                     0.70
28-32
Manufacturing: Chemicals/allied products; petroleum refining/related industries; rubber/miscellaneous plastics products; leather/leather products; stone/clay/glass/concrete products
                                      5/5
                                (100% positive)
Painter/sandblaster, sandblaster
                                   0.10-2.90
                                     0.83
                                     0.10
33
Manufacturing: Primary metal industries
                                     6/21
                                (29% positive)
Abrasive blaster, abrasive blastings, abrasive cutting, balance blast operat, blast oper, blaster, blaster operator, roto blaster, rotoblast man, sand blaster, sand room, sandblast opr, sandblaster, shot blast oper, shot blast operator, wheelabrator, wheelabrator oper, wheelabrator operator
                                   0.02-0.10
                                     0.08
                                     0.10
34
Manufacturing: Fabricated metal products
                                     17/40
                                (43% positive)
Abras blaster, abrasive blast, abrasive blaster, abrasive blaster ope, abrasive blasting, blaster, blasting operator, paint and blast, painter/sandblaster, sand blaster, sandblaster, sandblaster/painter, sandblasting, shot dumper, wheelarator oper, wheelbrator/welder, yard man preblast
                                   0.02-3.50
                                     0.90
                                     0.55
35
Manufacturing: Industrial and commercial machinery and computer equipment
                                     1/13
                                 (8% positive)
Abrasive blaster, blaster-shot house #, sand blaster, sandblaster, sandblaster primer, sandblaster/painter, shot blaster, wheelabrator
                                   0.60-0.60
                                     0.60
                                     0.60
36
Manufacturing: Electronic and other electrical equipment/components
                                      3/5
                                (60% positive)
Abrasive blaster, sandblaster, sandblasting oper.
                                   0.05-0.06
                                     0.06
                                     0.06
37
Manufacturing: Transportation equipment
                                     18/57
                                (32% positive)
Abrasive, abrasive blast, abrasive blaster, abrasive blaster pai, beadblast, blast tender, blaster, blasting helper, booth 1 blaster, booth 2 blaster, grit blaster, painter sandblaster, sand blaster, sandblaster, shot blaster, wheelabrator
                                  0.03-22.00
                                     6.57
                                     1.30
38-39
Manufacturing: Instruments, photographic/medical/optical goods; watches/clocks and miscellaneous manufacturing industries
                                      0/3
                                 (0% positive)
Pot tender, wheelabrator oper
                                     None
                                     None
                                     None
40-49
Transportation, Communications, Electric, Gas, and Sanitary Services
                                      1/2
                                (50% positive)
Blaster, cylinder rotoblast
                                   0.30-0.30
                                     0.30
                                     0.30
70-89
Services
                                      5/9
                                (56% positive)
Abrasive blaster, abrasive blasting sw, blaster, blaster/painter, driver/sandblaster, sandblaster, spray painter/blaster
                                  0.07-47.00
                                     9.68
                                     0.44
91-99
Public Administration
                                      0/3
                                 (0% positive)
Blaster, sand blaster, sandblaster
                                     None
                                     None
                                     None
N/A
OSHA On-Site Consultation Services
                                      3/3
                                (100% positive)
Abrasive blast op, blaster, peterlangblast
                                 0.50-1,781.00
                                    618.50
                                     74.00
Total

                                    169/343
                                (49% positive)

                                 0.01-1,781.0
                                     34.95
                                     0.56
[a]	Information regarding worker activities, the engineering controls in place, personal protective equipment worn during sampling, nondetectable sample concentrations, and sample duration is not available.
[b]	Includes all PBZ samples by SIC code.
[c]	The range, mean, and median results are based on positive sample results only.  All positive results are included.

PBZ: personal breathing zone
N/A: not available

Source: OSHA, 2009 (OSHA Integrated Management Information System (IMIS) Database, June 1978 through September 2008)

Exposure Profile Data
Table IV.C-3 shows the estimated exposure profile for abrasive blasting workers.  The exposure profile is also assumed to represent the baseline or typical exposure level for abrasive blasting workers.  These tables summarize the NIOSH, shipyard, and U.S. Navy full-shift personal breathing zone (PBZ) lapel-type total beryllium exposure data and report the distribution of the results in relation to PEL options.[,]   These data are 8-hour time-weighted average (TWA) samples that reflect 280 minutes or more of sampling time.  For this industry group, OSHA considered full-shift samples to be those with sampling durations of at least 280 minutes.  This minimum sample duration was selected in an effort to incorporate as much of the available data as possible into the exposure profile.  Industry contacts suggest this timeframe is a reasonable estimate of full-shift exposure because four to five hours of abrasive blasting typically would be a full-shift sample in a construction/shipyard environment.
Abrasive Blasters:  As shown in Table IV.C-3, the exposure profile for abrasive blasters is described by a median of 0.2 μg/m[3], a mean of 2.18 μg/m[3], and a range from 0.03 μg/m[3] to 66.5 μg/m[3].  These values represent 114 full-shift PBZ total beryllium sample results reported for U.S. Navy and shipyard workers (including shipyard workers from one NIOSH investigation) engaged in abrasive blasting.  About 16 percent of the values exceed the current PEL.  Nondetectable sample results (for NIOSH, 1983b and four U.S. shipyards) are incorporated into the exposure profile by assigning the detection limit value to each result reported as less than the sample limit of detection.  Of the 114 sample results included in the abrasive blaster exposure profile, 56 percent (64 samples) are nondetectable and range from less than 0.03 ug/m[3] to less than 55 ug/m[3].  Thus, the estimated exposure profile for abrasive blasters might overestimate the true median for this job category.  If the full-shift nondetectable results are eliminated from the abrasive blasters dataset, the remaining 50 samples are described by a median of 0.36 μg/m[3], a mean of 2.93 μg/m[3], and a range from 0.029 μg/m[3] to 66.5 μg/m[3].
Table IV-C.3 -- Personal Exposure Profile for Abrasive Blasting Workers[a]
                                 Job Category
                                   Number of
                                    Samples
                              Range (ug/m[3])[b]
                                    Mean[b]
                                  (ug/m[3])
                                   Median[b]
                                  (ug/m[3])
Abrasive Blasters[c]
                                      114
                                 0.03 to 66.5
                                     2.18
                                      0.2
Pot Tenders/Helpers
                                      14
                                 0.04 to 0.13
                                     0.08
                                     0.08
Abrasive Media Cleanup
                                      27
                                  0.01 to 7.4
                                     0.38
                                     0.06
Total
                                      155
                                 0.01 to 66.5
                                     1.68
                                      0.1
[a] 	Sample results are expressed as eight-hour time-weighted averages and include sampling durations of 280 minutes or longer.
[b]	Non-detected shipyard results are incorporated into the exposure profile by assigning the detection limit value to each result reported as less than the sample limit of detection.
[c] 	Excludes results where garnet was used as the abrasive due to high nondetectable reporting limits.

PBZ: personal breathing zone

Source: NIOSH, 1983b; OSHA, 2005; U.S. Navy, 2003

High reporting limits for some nondetectable samples may be due to several factors such as high analytical limits of detection, low sample volumes (sample air volumes less than the minimum volume required to meet the detection limit of the analytical method), and high iron content in the samples.  NIOSH reports that samples with high iron content must be diluted numerous times to eliminate spectral saturation interferences.  This action substantially increases (e.g., up to forty times) the analytical limits of detection and quantitation for the analytical method and produces insensitive and unreliable results (NIOSH, 1993a; NIOSH 1996b).  The highest volume-adjusted nondetectable sample concentrations in the exposure profile might be due to this phenomenon.  Such results make it impossible to determine if the nondetectable sample concentrations are below the PEL options or the current PEL of 2 ug/m[3].  For this reason, four full-shift sample results where garnet was used as the abrasive are not included in the exposure profile for abrasive blasters.  All four of these samples are nondetectable with high reporting limits ranging from less than 8 ug/m[3] to less than 35 ug/m[3] (< 8 ug/m[3], < 19 ug/m[3], < 19 ug/m[3], and < 35 ug/m[3]).
The entire database of PBZ abrasive blasting samples compiled from NIOSH, the U.S. Navy, and four shipyards includes 323 observations.  Of these samples, 118 have sample durations greater than or equal to 280 minutes (i.e., full-shift).  Of these, 114 are included in the abrasive blasting exposure profile and four were excluded because of high nondetectable reporting limits.  Two hundred and five of the abrasive blasting observations have sampling durations less than full-shift (less than 280 minutes) and are not included in the exposure profile.  Approximately 62 percent (128 samples) of these less than full-shift observations are non-detectable for beryllium and range from less than 0.01 ug/m[3] to less than 22 ug/m[3].  Seventy-seven (38 percent) of the less than full-shift observations are positive for beryllium with 8-hr TWA concentrations ranging from 0.029 ug/m[3] to 135 ug/m[3].  Of these, 38 (49 percent) have 8-hr TWA concentrations that exceed 2 ug/m[3] and sampling durations ranging from 104 minutes to 273 minutes.  This finding shows that less than full-shift abrasive blasting activities ranging in duration from about 2 to 4.5 hours can result in exposures that exceed the current PEL.
Pot Tenders/Helpers:  As shown in Table IV.C-3, the exposure profile for abrasive blasting pot tenders is described by a median of 0.08 ug/m[3], a mean of 0.08 ug/m[3], and a range from 0.04 to 0.13 ug/m[3].  All of the pot tender exposure results are less than or equal to 0.2 ug/m[3].  Of these, 64 percent (nine samples) are nondetectable for beryllium with volume-adjusted limit of detection concentrations ranging from less than 0.04 ug/m[3] to less than 0.12 ug/m[3].  If the full-shift non-detectable results are eliminated from the pot tenders dataset, the remaining five samples are described by a median of 0.1 μg/m[3], a mean of 0.1 μg/m[3], and a range from 0.09 μg/m[3] to 0.13 μg/m[3].
Abrasive Media Cleanup:  The estimated exposure profile for workers engaged in abrasive media cleanup is also shown in Table IV.C-3.  Eight-one percent (22 samples) of the abrasive media cleanup worker samples are nondetectable for beryllium with volume-adjusted limit of detection concentrations ranging from less than 0.02 ug/m[3] to less than 0.15 ug/m[3].  If the full-shift nondetectable results are eliminated from the abrasive media cleanup workers dataset, the remaining five samples are described by a median of 0.18 μg/m[3], a mean of 1.75 μg/m[3], and a range from 0.01 μg/m[3] to 7.4 μg/m[3].  One cleanup worker had a positive 8-hour TWA sample result of 1.1 ug/m[3]; however, blasting took place in the area during this worker's cleanup task (recovery of Black Beauty(TM) mineral grit) and it is likely that the nearby abrasive blasting contributed to the sample result.  Another cleanup worker had a positive sample result of 7.4 ug/m[3] (8-hour TWA).  This worker's exposure appears to be associated with the use of compressed air for cleaning (blowing down the area to remove dust) in conjunction with nearby abrasive blasting.
The available data suggest that most pot tenders and cleanup workers have low beryllium exposures.  The median exposure levels for both of these job categories are less than 0.1 ug/m[3] and nearly all results are less than or equal to 0.2 ug/m[3].  These findings are generally supported by relevant information for pot tenders and cleanup workers in the OSHA IMIS database.  The database contains 17 entries with job descriptions representative of pot tenders (e.g., blast tender, blaster helper, sandblaster assistant, and others) and one entry representative of cleanup workers (i.e., shot dumper).  Of the 18 entries, ten (56 percent) are nondetectable for beryllium including the sample entry for abrasive cleanup.  The volume-adjusted reporting limit concentrations for the ten nondetectable samples are not available.  The remaining eight positive results for pot tenders are described by a median of 0.14 ug/m[3], a mean of 0.18 ug/m[3], and a range from 0.01 ug/m[3] to 0.43 ug/m[3].
Beryllium Exposures by Type of Blast Media
OSHA also analyzed the abrasive blasting exposure profile data (full-shift PBZ 8-hour TWA total beryllium sample results) by the type of blasting media used.  These findings are summarized in Table IV.C-4.  In most cases, the composition of the base material blasted is not specified.  In the limited number of cases where it is (one shipyard and the U.S. Navy), the base material blasted includes steel, aluminum, and galvanized parts.  The highest sample results are associated with the use of mineral grit blasting media and are described by a median of 0.42 ug/m[3], a mean of 4.1 ug/m[3], and a range from 0.03 ug/m[3] to 66.5 ug/m[3].  Eighty-one percent (46 samples) of the mineral grit blasting samples are positive for beryllium and 16 (35 percent) of these exceed the current PEL.  According to a Navy source, coal, copper, and iron slags are the most commonly used types of mineral grit (Bishop, 2005).  In the construction industry, coal slag and steel grit are reported to be among the most commonly used abrasives (Meeker et al., 2006).
Nearly all of the available exposure results for workers using abrasive blasting cabinets or other types of enclosures are nondetectable for beryllium and below 0.1 ug/m[3].  This finding is consistent with the IMIS results for blasting cabinets discussed earlier.  All of the garnet samples are reported to be nondetectable, but the reporting limits are so high it is not possible to determine if the non-detectable results are below the PEL options or the current PEL.  For this reason the garnet results are not included in the exposure profile.  The four garnet samples came from one shipyard and it is possible that the high nondetectable reporting limits are due to the (high) iron content phenomenon discussed earlier.  Ten of the eleven glass bead samples are reported to be nondetectable with volume-adjusted limit of detection concentrations ranging from less than 0.03 ug/m[3] to less than 0.2 ug/m[3].  The only positive result for glass bead as the abrasive is 0.15 ug/m[3].  All seven of the organic media samples are reported as nondetectable with six of the volume-adjusted limit of detection concentrations ranging from less than 0.03 ug/m[3] to less than 0.08 ug/m[3].  One sample is reported as less than 0.37 ug/m[3] (390 minutes).  Twenty-six of the 28 samples where steel shot or grit was used as the abrasive are nondetectable with volume-adjusted reporting limits ranging from less than 0.03 ug/m[3] to less than 1 ug/m[3].  The two positive steel grit/shot samples have results of 0.2 ug/m[3] and 0.95 ug/m[3].  Two samples each for wet soda (< 0.04 ug/m[3] and < 0.04 ug/m[3]) and unspecified blast media (< 3 ug/m[3] and < 4 ug/m[3]) are nondetectable for beryllium; however, the reporting limits for the unspecified media are higher than the current PEL.
Table IV.C-4 -- Abrasive Blasting Exposure Profile by Type of Blasting Media[a][, b, c]
                           Media/Base Material Type
                             Total No. of Samples
                         No. of Non-Detectable Samples
                              Range (ug/m[3])[b]
                                    Mean[b]
                                  (ug/m[3])
                                   Median[b]
                                  (ug/m[3])
Abrasive Blasting Cabinet/Glove Box
(media not specified)
                                       7
                                       6
                                     (86%)
                                 0.07 to 0.08
                                     0.07
                                     0.07
Garnet[d]
                                       4
                                       4
                                    (100%)
                                    8 to 35
                                     20.2
                                      19
Glass Bead
                                      11
                                      10
                                     (91%)
                                  0.03 to 0.2
                                     0.10
                                     0.08
Mineral Grit
                                      57
                                      11
                                     (19%)
                                 0.03 to 66.5
                                      4.1
                                     0.42
Organic Media (not otherwise specified)
                                       7
                                       7
                                    (100%)
                                 0.03 to 0.37
                                     0.096
                                     0.04
Steel Grit/Steel Shot
                                      28
                                      26
                                     (93%)
                                   0.03 to 1
                                     0.22
                                      0.1
Wet Soda
                                       2
                                       2
                                    (100%)
                                 0.04 to 0.04
                                     0.04
                                     0.04
Unspecified Blast Media
                                       2
                                       2
                                    (100%)
                                    3 to 4
                                      3.5
                                      3.5
Total (excludes garnet, see footnote d)
                                      114
                                      64
                                     (56%)
                                 0.03 to 66.5
                                     2.18
                                      0.2
[a]	Full-shift personal breathing zone total beryllium sample results included in the abrasive blasting exposure profile by type of blasting media.  Sample results are expressed as eight-hour time-weighted averages and include a minimum of 280 minutes of sampling time.
[b]	Non-detected (NIOSH and shipyard) results are incorporated into the exposure profile by assigning the detection limit value to each result reported as less than the sample detection limit.
[c]	The composition of the base material blasted is generally not specified.  In the limited number of cases where it is specified (one shipyard and the U.S. Navy), the base material blasted includes steel, aluminum, and galvanized parts.
[d] 	All four of the samples where garnet was used as the abrasive are nondetectable.  However, due to the high reporting limits, these data are not included in the exposure profile.  The reporting limits may be due to high iron content in the samples requiring numerous dilutions to eliminate spectral saturation interferences.

Source: NIOSH, 1983b; OSHA, 2005; U.S. Navy, 2003

Focusing primarily on the blast media, a NIOSH sponsored study of shipyard abrasive blasting examined the apparent contributions to air contaminants of hazardous components of blast media, including the most common alternatives to silica sand, and coal and copper slag.  Overall, NIOSH comprehensively evaluated 40 abrasive blasting products, including nine different coal slag abrasive products.  Looking at the field simulation portion of that study, NIOSH found that blasting with coal slag abrasive resulted in airborne concentrations of beryllium that implied exposure levels well above the NIOSH recommended exposure limit (REL) of 0.5 ug/m[3] (NIOSH/KTA-Tator, 1999).  Of the alternative abrasives investigated, coal slag and copper slag both produced elevated beryllium levels in the operator's breathing zone.
Other studies also report elevated beryllium exposures with coal slag abrasives.  In a study of exposures among painters using three alternative blasting abrasives during a New Jersey highway footbridge repainting project, Meeker et al. (2005 and 2006) reported that coal slag was associated with higher beryllium exposures compared with both specular hematite and steel grit.  Beryllium was detected in all five personal breathing zone samples (obtained outside protective equipment) following abrasive blasting with coal slag with task-based (2 to 3 hours) concentrations ranging from 2.5 ug/m[3] to 9.5 ug/m[3] and a geometric mean of 5.0 ug/m[3].
In June 2004, NIOSH conducted a field study to investigate beryllium exposures during abrasive blasting operations with coal slag abrasive at the Annapolis Water Reclamation Facility in Annapolis, Maryland (NIOSH, 2007).  Abrasive blasting was conducted inside an empty open-top, in-ground circular vessel approximately 10 feet deep and 110 feet in diameter.  Personal breathing zone samples were obtained for both the abrasive blaster and the helper.  For the abrasive blaster, two eight-hour TWA PBZ beryllium sample results of 0.03 ug/m[3] and 2.1 ug/m[3] were reported for task-based sampling durations of 62 minutes and 189 minutes, respectively.  The blaster's helper, who worked outside a temporary containment enclosure erected over areas of the tank being blasted, had negligible sample results.  One 8-hour TWA sample result was nondetectable (less than 0.01 ug/m[3]) for beryllium (sampling duration of 75 minutes) and a second sample result was reported as 0.01 ug/m[3] (sampling duration of 196 minutes).
Table IV-C.5 -- NIOSH Comparative Field Simulation Study of Abrasive Blasting Media[a]
Short-Term (24 minutes) PBZ Total Beryllium Sample Results and Beryllium Content in Blasting Media
Abrasive Type
            Beryllium Concentration Operator's Breathing Zone[b]
                                  (ug/m[3])
                       Beryllium Content in Blast Media
                        Virgin Pre-Blast Bulk Analysis
                                   (ug/gm)
Coal slag
                                     4.83
                                     0.11
Nickel slag
                                     0.17
                                     0.04
Staurolite
                                     0.53
                                     0.005
Silica sand
                                     4.83
                                     0.05
Silica sand with dust suppressant
                                     0.14
                                     0.005
Copper slag
                                     1.24
                                     0.90
Garnet
                                     0.62
                                     0.02
Steel grit
                                ND (< 0.082)
                                     0.005
[a]	This field study (Phase 2 of the NIOSH study) was conducted at the Consolidated Coal Company Shipyard in Elizabeth, Pennsylvania.  One product from each of eight generic types of abrasives was tested.  Personal breathing zone sampling was conducted for a total of 24 minutes for each abrasive tested during open nozzle dry abrasive blast cleaning operations conducted on the exterior hull of a coal barge in temporary dry dock.  The hull was free of any coating and consisted of heavily rusted and pitted steel.  Throughout all abrasive tests, the same abrasive blast cleaning equipment and portable blast containment (16 ft. long by 8 ft wide by 8 ft high) were used.  The containment was equipped with a 5,000 cubic feet per minute capacity dust collector.  After each abrasive test, the containment was cleaned and moved to a new location on the barge to prevent cross-contamination between abrasives.
[b]	The personal air sampling pumps were programmed to initiate sampling 3 minutes after the abrasive trial began (to allow airborne concentrations of dust to equilibrate) and to stop sampling after a sampling duration of 24 minutes (to prevent overloading of the filter media).  Sample concentrations are based on the sampling period and have not been time-weighted for 8 hours.

PBZ: personal breathing zone
ND: nondetectable
<: less than

Source: NIOSH/KTA-Tator, 1998

Engineering Controls for Abrasive Blasting
Abrasive Blaster - Baseline Controls:  Baseline conditions reflect compliance with the elements of OSHA's standard covering abrasive blasting operations in 29 CFR 1910.94(a). Specifically, paragraph 1910.94(a)(5) requires operators to use abrasive blasting respirators when working inside of blast-cleaning rooms, when silica sand is used in manual blasting operations and the nozzle and blast are not physically separated from the operator in an exhaust ventilated enclosure, or where the concentrations of toxic contaminants exceed the limits set in 1910.1000 and a separate, ventilated blast enclosure is not used.  Similar requirements are specified by OSHA's standards addressing abrasive blasting operations in construction (29 CFR 1926.57) and shipyard (29 CFR 1915.34) environments.  Open-air blasting might be performed with coal or copper slag.  This is particularly true of shipyard blasting.  Other blast media such as aluminum oxide, glass beads, and steel shot or grit are more common when blast cabinets or similar enclosures are used.
Blast cleaning enclosures such as blasting rooms and cabinets and containment structures are typically ventilated to maintain operator visibility and/or limit the escape of dust emissions (Flynn and Susi, 2004; SBAR, 2008).  These baseline conditions are associated with a median beryllium exposure level of 0.2 ug/m[3] for workers engaged in abrasive blasting.
Abrasive Blaster - Other Control Options:  All blast-cleaning enclosures must be adequately ventilated, and increased or improved ventilation in blasting cabinets might reduce exposures.  Seals should be inspected and replaced, if necessary, to reduce leakage.  Abrasive blasting rooms, portable blast-cleaning equipment, and temporary containment structures must have sufficient exhaust ventilation to (1) prevent a build-up of dust-laden air and reduce the concentrations of hazardous air contaminants; (2) increase operator visibility; and (3) prevent any leakage of dust to the outside.  Exhaust ventilation systems for such enclosures must be constructed, installed, inspected, and maintained according to the Ventilation standard (29 CFR 1910.94).  The exhaust air from blast-cleaning equipment must be discharged through an appropriate dust collector to protect the workplace from hazardous air contaminants, and the dust collector must be set up so that the accumulated dust can be emptied and removed without contaminating work areas (29 CFR 1910.94(a)(4)(iii); NIOSH, 1992).
For transportable objects too large for blasting cabinets, employers could use a blasting room where one or more operators work inside the room.  Blasting rooms should have sufficient ventilation to (1) provide good operator visibility, (2) prevent dust from settling and accumulating in the room, (3) reduce dust concentrations so personal protective equipment (PPE) provides adequate protection, and (4) control the escape of contaminants into adjacent work areas or the environment.  Operators working inside abrasive blasting rooms must be protected by hoods and airline respirators, or by positive-pressure air helmets.
For large objects or structures that cannot be transported, or for fixed structures, temporary enclosures should be used.  Whenever possible, objects or structures should be fully enclosed.  When full enclosure is not possible, extend screening above the object or structure, and blast downwards.  Air monitoring should be used to ensure that workers and others outside the enclosure are not exposed to elevated levels of air contaminants.  If high levels of air contaminants are detected outside the enclosure, (1) workers should be excluded from these areas through the use of warnings signs and barricades or provided with appropriate PPE; and (2) all feasible control measures must be investigated and implemented when exposures exceed an OSHA PEL (see, e.g., 29 CFR 1910.1000(e)).
Substitution: The easiest way to eliminate hazardous air contaminants associated with abrasive media is to select a blasting agent that does not contain beryllium.  Meeker et al. (2005 and 2006) and the NIOSH/KTA-Tator (1999) study suggest that substitution of abrasive blasting agents is possible.  When selecting an alternative blasting abrasive, employers should consider that:
Depending on the abrasive, alternative media can result in elevated levels of other hazardous air contaminants.  These contaminants may be associated with virgin and recycled abrasives (i.e., contamination due to recycling activities) (NIOSH, 1994b).
The nature of the coating being removed and the underlying substrate also affect the toxicity of the dust generated.
Alternative media containing small amounts of crystalline silica (one percent or less) might result in elevated levels of airborne crystalline silica if used in confined or enclosed spaces (NIOSH, 1993b).
Supplemental use of respiratory protection may be needed depending on the abrasive and whether work is being performed inside enclosures.
Additional literature suggests various more benign abrasive media substitutes.  For example, Flynn and Susi (2004) report that dolomite (calcium magnesium carbonate) may be a good alternative to other problematic blasting media.  The authors also comment on the apparent potential for good results with crushed glass and with specular hematite (ferric oxide mineral).
Process or Equipment Change: Alternative techniques to dry abrasive blasting can be used to reduce or eliminate the amount of dust generated during surface preparation.  These techniques are summarized in Table IV.C-6 and include wet abrasive blasting, hydroblasting, centrifugal wheel blasting, vacuum blasting, and blasting with dry ice pellets.  Cleaning techniques that do not use abrasive blasting and are suitable for smaller jobs include thermal, chemical, and mechanical stripping methods (NIOSH 1994a, 1995, 1999b).  Other removal techniques that may reduce or eliminate toxic dust levels during surface preparation include blast cleaning with baking soda (sodium bicarbonate), reusable sponge abrasives, or plastic media (PMB); cryogenic stripping (immersing small parts into liquid nitrogen, followed by gentle abrasion or PMB); and laser paint stripping (generates no waste and uses a pulsed carbon dioxide laser as the stripping agent).
Other control options to reduce beryllium exposures associated with abrasive blasting include selecting a beryllium-free blasting agent, and alternative techniques to dry abrasive blasting that reduce or eliminate the amount of dust generated during surface preparation.  Where exposure is due to the blasting agent, substitution with a beryllium-free blasting agent should be considered but this should be done with caution to ensure that the alternative does not pose other health risks.
Table IV.C-6 -- Alternative Methods for Dry Abrasive Blasting
Name
Description/Comments
Wet Abrasive Blasting
Can be used in most instances where dry abrasive blasting is used.  Includes (1) compressed air blasting with the addition of water into the blast stream before the abrasive leaves the nozzle and (2) water jetting with the addition of abrasive into the water stream at the nozzle.  Additives and rust inhibitors may be used.
Hydroblasting
High Pressure Water Jetting:
Uses pressure pump, large volume of water, specialized lance and nozzle. Pressures range from 3,000 to 25,000 pounds per square inch (psi).  Can remove loose paint and rust; will not efficiently remove tight paint, tight rust, or mill scale.  Can be used in most instances where abrasive blasting is used.  Primary application is for an older surface rusted in a saline environment rather than new steel.  Rust inhibitors may be required to prevent flash rusting.

Ultra High Pressure Water Jetting:
Similar to high pressure water blasting.  Uses pressurized water from 25,000 to 50,000 psi. Removes tight paint and rust, but not mill scale.
Centrifugal Wheel Blasting
Uses a rotating wheel assembly inside an enclosure equipped with a dust collector.  Abrasive is propelled outwards from the rotating wheel and removes rust, paint, and mill scale.  Abrasives are recycled and include steel shot, steel grit, cut wire, and chilled iron grit.  No contact with airborne dust or high velocity particles.
Vacuum Blasting
Uses standard blast nozzle inside a shroud (head) that forms a tight seal with the work surface. Vacuum is applied inside shroud during blasting to remove dust and debris.  Abrasives are recycled and include aluminum oxide, garnet, steel shot, steel grit, and chilled iron grit.  When used properly, cleans effectively with minimal dust.
Dry Ice Pellets
Dry ice blast cleaning with solid carbon dioxide.  Waste is minimized and includes paint chips and rust.  Storage and handling costs may be significant.
Thermal Stripping
Uses a flame or stream of superheated air to soften paint, allowing for easy removal.  Generates one waste stream; i.e., waste paint.  Effective for small parts; not suitable for heat-sensitive surfaces.  Very labor intensive.
Chemical Stripping
Uses hazardous chemical strippers such as methylene chloride-based or caustic solutions. Effective for small fiberglass, aluminum, and delicate steel parts.  Requires adequate ventilation and other safety measures.  Generates multiple waste streams; i.e., contaminated rinse water and waste strippers.
Mechanical Stripping
Involves chipping, grinding, sanding, or scraping the coating off small parts or surfaces through the use of needle guns, chipping hammers, sanders, and grinders.  Generates paint waste and airborne dust.  Some power tools may be equipped with dust collection systems.
Source:  EPA, 1991; Kura, B. et al. (undated); NIOSH, 1994a, 1995, 1999a, 1999b, 1999c

Pot Tender - Baseline Controls:  Pot tenders work within the immediate vicinity of the abrasive blasting equipment (air compressors, abrasive blast machine, media hopper).  As such, these workers may be located near the abrasive blasting operation or outside a temporary or permanent blast-cleaning enclosure.  Baseline controls for pot tenders include the controls in use for the abrasive blasting operation such as an enclosed and ventilated blasting room or containment structure.  In addition, these workers may wear particulate filter respirators for short, intermittent, or occasional dust exposures associated with media handling (receipt, cleanup/recovery, recycle, disposal).  These baseline conditions are associated with a median beryllium exposure level less than 0.1 μg/m[3] (0.08 μg/m[3]).
Pot Tender - Other Controls Options:  For abrasive blasting pot tenders, the median and baseline beryllium exposure level is below 0.1 μg/m[3].  A majority of these workers have low exposures and additional controls are not needed.  For those pot tenders that might experience higher exposure levels, implementing additional controls for abrasive blasters, as described above, will further reduce the exposures of these workers.
Abrasive Media Cleanup - Baseline Controls:  Abrasive media cleanup/recovery may be an automated or semi-automated process such as a blast room equipped with a full recovery system that automatically collects and separates reusable abrasive from dust and debris or a recovery system in which the abrasive blaster sweeps the spent media into a recovery hopper or floor trough.  Alternatively, the pot tender (or workers designated as media cleanup or recovery workers) may be engaged in spent media clean up.  These workers use various types of equipment to collect and load the spent abrasive into containers for recovery or disposal such as mechanical loaders (e.g., Bobcat skid steer), sweepers, brooms, and vacuum trucks or portable vacuum machines (some of which are HEPA-filtered) (SBAR, 2008; SCA, 2005).  Baseline controls for media cleanup/recovery also include any controls in use for abrasive blasting such as an enclosed and ventilated blasting room or containment structure.  These baseline conditions are associated with a median beryllium level less than 0.1 μg/m[3] (0.06 μg/m[3]).
Abrasive Media Cleanup - Other Control Options:  For cleanup workers recovering spent abrasive blasting media, the median and baseline beryllium exposure level is below 0.1 μg/m[3].  A majority of these workers have low exposures.  For those workers that might experience higher exposure levels, other options to further reduce exposures include (1) implementing additional controls for abrasive blasters, as described above (e.g., using a beryllium-free abrasive), (2) prohibiting the use of compressed air for cleaning, and (3) initiating recovery of spent media after the completion of the blasting process and airborne particulate has settled (NIOSH, 1993a and 1994b).
References
29 CFR 1910.94.  Ventilation standard for general industry.  Available on the OSHA Web site at http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=9734.
29 CFR 1915.34.  Abrasive blasting requirements for the shipyard industry (Surface Preparation and Preservation).  Available on the OSHA Web site at http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10226.
Bishop, J.E., 2005.  E-mail correspondence between John E. Bishop of the Navy Environmental Health Center, Norfolk, Virginia and Maureen Ruskin of the U.S. Occupational Safety and Health Administration, February 28.
Brantley, C.D., and P. C. Reist, 1994.  Abrasive Blasting with Quartz Sand: Factors Affecting the Potential for Incidental Exposure to Respirable Silica.  American Industrial Hygiene Association Journal, 55(10): 946-952.
Burgess, W.A., 1991.  Potential Exposures in the Manufacturing Industry -- Their Recognition and Control.  In Patty's Industrial Hygiene and Toxicology, 4[th] Edition, Volume I, Part A. G.D. Clayton and F.E. Clayton (editors).  New York: John Wiley and Sons.  Pages 595-598.
Daddura, J., 2011.  Telephone conversation between Joe Daddura, Maritime Standards, and Paul Bolan, U.S. Occupational Safety and Health Administration.  February 25.
[EPA] U.S. Environmental Protection Agency, 1991.  Guides to Pollution Prevention: The Marine Maintenance and Repair Industry. U.S. EPA, Office of Research and Development, Risk Reduction Engineering Laboratory and Center for Environmental Research Information.  EPA/625/7-91/015.  October.
[EPA] U.S. Environmental Protection Agency, 1997a.  Emission Factor Documentation for AP-42, Section 13.2.6, Abrasive Blasting.  Final Report.  U.S. EPA, Office of Air Quality Planning and Standards, Emission Factor and Inventory Group, Research Triangle Park, North Carolina.  September.
[EPA] U.S. Environmental Protection Agency, 1997b.  EPA Office of Compliance Sector Notebook Project: Profile of the Shipbuilding and Repair Industry.  U.S. EPA, Office of Compliance, Office of Enforcement and Compliance Assurance, Washington, D.C.  Document No. EPA/310-R-97-008.  November 1997.
[EPA] U.S. Environmental Protection Agency, 2000.  A Guide for Ship Scrappers -- Tips for Regulatory Compliance. U.S. EPA, Office of Enforcement and Compliance Assurance, Federal Facilities Enforcement Office.  EPA 315-B-00-001.  Summer 2000.
[ERG] Eastern Research Group, Inc., 2008.  Section 2.4 (Construction Industry Profile - Abrasive Blasting) in Technological Feasibility Study of Regulatory Alternatives for a Proposed Crystalline Silica Standard for Construction.  Version July 31, 2008.  Draft report submitted to OSHA.
Federal Register, 2002.  U.S. Occupational Safety and Health Administration, Department of Labor.  Occupational Exposure to Beryllium; Request for Information.  Federal Register 67(228): 70707-70712.  November 26, 2002.
Flynn, M. and P. Susi, 2004.  A Review of Engineering Control Technology for Exposures Generated During Abrasive Blasting Operations.  Journal of Occupational and Environmental Hygiene 1:680-687.  October.
Greskevitch, M., 2000.  Personal e-mail communication between Mark Greskevitch of the U.S. National Institute for Occupational Safety and Health (NIOSH) and Eastern Research Group, Inc., February 17.
Kura, B., S. Lacoste, and P.V. Patibanda, undated.  Multimedia Pollutant Emissions from the Shipbuilding Facilities.  <http://www.uno.edu/~bkura/PDF/UJNR_Paper1.pdf.>. Accessed March 2, 2004.
Meeker, J.D., P. Susi, and A. Pellegrino, 2005.  Case Study: Exposure to Silica and Metals Among Painters Using Specular Hematite Abrasive.  Journal of Occupational and Environmental Hygiene 2(8): D60-D64.
Meeker, J.D., P. Susi, and A. Pellegrino, 2006.  Case Study: Comparison of Occupational Exposures Among Painters Using Three Alternative Blasting Abrasives.  Journal of Occupational and Environmental Hygiene 3(9): D80-D84.
[NEHC] U.S. Navy Environmental Health Center, 1999.  Industrial Hygiene Field Operations Manual.  Chapter 4 -- Exposure Assessment Strategies.  Technical Manual NEHC-TM6290.91-2, Rev. B.  NEHC, Norfolk, Virginia.
[NFESC] Naval Facilities Engineering Service Center, 1996.  Recycling and Reuse Options for Spent Abrasive Blasting Media and Similar Wastes. NFESC, Port Hueneme, California. Technical Memorandum TM-2178-ENV, April.
[NIOSH] U.S. National Institute for Occupational Safety and Health, 1976.  Abrasive Blasting Operations: Engineering Control and Work Practices Manual.  NIOSH Publication No. 76-179.  March 1976.
[NIOSH]  U.S. National Institute for Occupational Safety and Health, 1983.  Health Hazard Evaluation Report HETA 78-135-1333.  International Brotherhood of Painters and Allied Trades.  Electric Boat Division of General Dynamics Corporation, Groton, Connecticut. U.S. Department of Health and Human Services, Public Health Service, Centers for Disease Control, NIOSH.  August.
[NIOSH] U.S. National Institute for Occupational Safety and Health, 1992.  Request for Assistance in Preventing Silicosis and Deaths from Sandblasting.  U.S. Department of Health and Human Services, Public Health Service, Centers for Disease Control, NIOSH.  DHHS (NIOSH) Publication No. 92-102.  August.
[NIOSH] U.S. National Institute for Occupational Safety and Health, 1993a.  In-Depth Survey Report: Control Technology for Removing Lead-Based Paint from Steel Structures: Abrasive Blasting Using Steel Grit with Recycling at I-75 Bridge (Project 255-92), Corcon, Inc., Dayton, Ohio.  Report No. ECTB 183-12a.  U.S. Department of Health and Human Services, Public Health Service, Centers for Disease Control and Prevention, NIOSH, Cincinnati, Ohio.  June.
[NIOSH] U.S. National Institute for Occupational Safety and Health, 1993b.  In-Depth Survey Report: Control Technology for Removing Lead-Based Paint from Steel Structures: Abrasive Blasting Using Staurite XL in Containment at BP Oil Corporation, Lima, Ohio.  Report No. ECTB 183-13a.  U.S. Department of Health and Human Services, Public Health Service, Centers for Disease Control and Prevention, NIOSH, Division of Physical Sciences and Engineering, Cincinnati, Ohio.  July.
[NIOSH] U.S. National Institute for Occupational Safety and Health, 1994a.  In-Depth Survey Report: Control Technology for Removing Lead-Based Paint from Steel Structures: Chemical Stripping Using Caustic (Peel Away ST-1) at Williams Pipeline Terminal and Station, Marshall, Minnesota.  Report No. ECTB 183-15a.  U.S. Department of Health and Human Services, Public Health Service, Centers for Disease Control and Prevention, NIOSH, Cincinnati, Ohio.  November 28.
[NIOSH] U.S. National Institute for Occupational Safety and Health, 1994b.  In-Depth Survey Report: Control Technology for Removing Lead-Based Paint from Steel Structures: Abrasive Blasting Inside Two Ventilated Containment Systems at Bridge Street and Shribner Street Overpass, Seaway Painting Company, Inc., Grand Rapids, Michigan.  Report No. ECTB 183-14a.  U.S. Department of Health and Human Services, Public Health Service, Centers for Disease Control and Prevention, NIOSH, Cincinnati, Ohio.  December.
[NIOSH] U.S. National Institute for Occupational Safety and Health, 1995.  In-Depth Survey Report: Control Technology for Removing Lead-Based Paint from Steel Structures: Power Tool Cleaning at Muskingum County, Ohio Bridge MUS-555-0567 and MUS-60-3360, Olympic Painting Company, Inc., Youngstown, Ohio.  Report No. ECTB 183-16a. U.S. Department of Health and Human Services, Public Health Service, Centers for Disease Control and Prevention, NIOSH, Cincinnati, Ohio.  November.
[NIOSH] U.S. National Institute for Occupational Safety and Health, 1996b.  Health Hazard Evaluation Report HETA 94-0122-2578.  Bath Iron Works Corporation, Bath, Maine.  N U.S. Department of Health and Human Services, Public Health Service, Centers for Disease Control and Prevention, NIOSH.  May.
[NIOSH] U.S. National Institute for Occupational Safety and Health, 1999a.  In-Depth Survey Report: Evaluation of an Automated Abrasive Blasting Machine at Marystown Shipyard, Marystown, Newfoundland, Canada.  Report No. ECTB 183-22.  U.S. Department of Health and Human Services, Public Health Service, Centers for Disease Control and Prevention, NIOSH, Division of Physical Sciences and Engineering, Engineering Control Technology Branch, Cincinnati, Ohio.  May 4.
[NIOSH] U.S. National Institute for Occupational Safety and Health, 1999b.  In-Depth Survey Report: Control Technology for Removing Lead-Based Paint from Steel Structures: Chemical Stripping at Columbus, Ohio Bridge Finishes, Inc., Columbus, Ohio.  Report No. ECTB 183-17a.  U.S. Department of Health and Human Services, Public Health Service, Centers for Disease Control and Prevention, NIOSH, Cincinnati, Ohio.  June.
[NIOSH] U.S. National Institute for Occupational Safety and Health, 1999c.  In-Depth Study Report: Control Technology for Crystalline Silica Exposures in Construction: Wet Abrasive Blasting at the Nokia Building Construction Site, Irving, Texas.  Report No. ECTB 247-11.  U.S. Department of Health and Human Services, Public Health Service, Centers for Disease Control and Prevention, NIOSH, Division of Physical Sciences and Engineering, Cincinnati, Ohio.  December.
[NIOSH] U.S. National Institute for Occupational Safety and Health, 2007.  Control Technology and Exposure Assessment for Occupational Exposure to Beryllium: Abrasive Blasting with Coal-Slag.  File No.: EPHB 263-13a, August 2007.  U.S. Department of Health and Human Services, Centers for Disease Control and Prevention, NIOSH, Division of Applied Research and Technology, Cincinnati, Ohio.
NIOSH/KTA-Tator, 1998.  Evaluation of Substitute Materials for Silica Sand in Abrasive Blasting.  Prepared for Department of Health and Human Services, Public Health Service, Centers for Disease Control and Prevention, National Institute for Occupational Safety and Health.  Prepared by KTA-Tator, Inc., Pittsburgh, Pennsylvania.  Phase 2 (Field Investigations), December 1998.
NIOSH/KTA-Tator, 1999.  Evaluation of Substitute Materials for Silica Sand in Abrasive Blasting.  Prepared for Department of Health and Human Services, Public Health Service, Centers for Disease Control and Prevention, National Institute for Occupational Safety and Health.  Prepared by KTA-Tator, Inc., Pittsburgh, Pennsylvania.  Phase 3 (Comparison of Lab and Field Investigations), March 1999.
[NSRP] The National Shipbuilding Research Program, 1999.  Feasibility and Economics Study of the Treatment, Recycling and Disposal of Spent Abrasives.  NSRP, U.S. Department of the Navy, Carderock Division, Naval Surface Warfare Center in cooperation with National Steel and Shipbuilding Company, San Diego, California.  NSRP 0529, N1-93-1.  April 9.
[NSRP] The National Shipbuilding Research Program, 2000.  Cost-Effective Clean Up of Spent Grit.  NSRP, U.S. Department of the Navy, Carderock Division, Naval Surface Warfare Center in cooperation with National Steel and Shipbuilding Company, San Diego, California.  NSRP 0570, N1-95-4.  December 15.
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] U.S. Occupational Safety and Health Administration, 2005.  Beryllium exposure data for hot work and abrasive blasting operations from four U.S. shipyards (sample years 1995 to 2004).  Data provided to Eastern Research Group, Inc. by the U.S. Department of Labor, OSHA.  March 2005.  [Unpublished]
[OSHA] U.S. Occupational Safety and Health Administration, 2009.  OSHA Integrated Management Information System.  Beryllium data provided by OSHA covering the period 2003 to 2008.  April 21, 2009.
[OSHA] U.S. Occupational Safety and Health Administration, H005C-2006-0870-0144.  Navy Response to Occupational Safety and Health Administration's Occupational Exposure to Beryllium: Request for Information.  U.S. Department of Labor, OSHA.  Beryllium Docket No.: OSHA-H005C-2006-0870.  Document ID No.: OSHA-H005C-2006-0870-0144.  Available at http://www.regulations.gov/search/Regs/home.html#docketDetail?R=OSHA-H005C-2006-0870.
[OSHA] U.S. Occupational Safety and Health Administration, 29 CFR 1926.57.  Abrasive blasting requirements for the construction industry (Ventilation).  Available on the OSHA Web site at http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10631.
Queensland Government, 1999.  Abrasive Blasting Industry Code of Practice.  Department of Employment, Training and Industrial Relations, Division of Workplace Health and Safety, Queensland Government, Australia.  June 22, 1999.  SBAR, 2008.  Report of the Small Business Advocacy Review (SBAR) Panel on the OSHA Draft Proposed Standard for Occupational Exposure to Beryllium.  Small Business Advisory Review Panel Report with Appendices A, B, C, and D.  Final version, January 15, 2008.  OSHA Beryllium Docket Document ID Number: OSHA-H005C-2006-0870-0345 and OSHA-H005C-2006-0870-0346.   Available at: http://www.regulations.gov/search/Regs/home.html#docketDetail?R=OSHA-H005C-2006-0870.
[SCA] Shipbuilders Council of America, 2005.  Shipyard Stormwater Best Management Practice #7: Abrasive Materials Management.  January 2005.  SCA, Washington, DC.
U.S. Census Bureau, 1997.  1997 Economic Census.
U.S. Census Bureau, 2007.  County Business Patterns, 2007.  Available online at http://www.census.gov/econ/cbp/.
U.S. Navy, 2003.  U.S. Navy Response to Occupational Safety and Health Administration, Beryllium Request for Information.  See OSHA Beryllium Docket H005C-2006-0870.  Document ID Numbers OSHA-H005C-2006-0870-0144 (Navy Response to Occupational Safety and Health Administration's Occupational Exposure to Beryllium; Request for Information) and OSHA-H005C-2006-0870-0145 (Attachment 1.  Navy Occupational Exposure Database (NOED) Query Report Personal Breathing Zone Air Sampling Results for Beryllium).
WorkSafe, 2000.  Code of Practice: Abrasive Blasting.  WorkSafe Western Australia Commission.  June.
.
CHAPTER V: COSTS OF COMPLIANCE

INTRODUCTION
      In this chapter, OSHA assesses the costs to establishments in all affected application groups of reducing worker exposures to beryllium to an eight-hour time-weighted average (TWA) permissible exposure limit (PEL) of 0.2 μg/m[3] and to the proposed short-term exposure limit (STEL) of 2.0 μg/m[3], as well as of complying with the proposed standard's ancillary provisions.  These ancillary provisions encompass the following requirements:  exposure monitoring, regulated areas, a written exposure control plan, protective work clothing, hygiene areas and practices, housekeeping, medical surveillance, medical removal, and worker training.  This preliminary cost assessment is based in part on OSHA's technological feasibility analysis presented in Chapter IV of this PEA; analyses of the costs of the proposed standard conducted by OSHA's contractor, Eastern Research Group (ERG); and the comments submitted to the docket in response to the request for information (RFI) and as part of the SBREFA process.  Where costs are presented with no explicit source they come either from industry experts at ERG or industry experts contacted by ERG.
      OSHA estimates that the proposed standard would have an annualized cost of $37.8 million.  All costs in this chapter are expressed in 2010 dollars and were annualized using a discount rate of 3 percent, which -- along with 7 percent -- is one of the discount rates recommended by OMB.  Annualization periods for expenditures on equipment are based on equipment life, and one-time costs are annualized over a 10-year period.
      OSHA used its typical time horizon for analysis for the proposed rule, 60 years, which reflects the typical time needed to recognize the full benefits of a rule with cancer-avoiding benefits (45-year working life + 15-year gestation period for cancer) and reach steady-state values.  Therefore, the benefits of the proposed standard, discussed in Chapter VII of this PEA, were annualized over that 60-year period.  Note that, over this time horizon, employment and production in affected industries are being held constant for purposes of the analysis.  All non-annual costs are estimated to repeat over the 60-year time horizon, including one-time costs that recur because of changes in operations over time or because of new entrants that must comply with the proposed standard.  OSHA welcomes comment on the choice of time horizons for the purpose of this analysis, recognizing the uncertainties of long-term forecasts and the need for long-term forecasts to capture the full effects of the standard on benefits.
      Table V-1 shows, by affected application group and six-digit NAICS code, annualized compliance costs for all establishments, for all small entities (as defined by the Small Business Act and the Small Business Administration's -- SBA's -- implementing regulations; see 15 U.S.C. 632 and 13 CFR 121.201), and for all very small entities (as defined by OSHA, those with fewer than 20 employees).

      OSHA's exposure profile, presented in Chapter III of this PEA, represents the Agency's best estimate of current exposures (i.e., baseline exposures).  OSHA did not attempt to determine the extent to which current exposures in compliance with the current beryllium PEL and STEL are the result of baseline engineering controls or the result of circumstances leading to low exposures.  If exposures were above the proposed PEL for worker in a given occupation and sector, then OSHA assumed that all engineering controls would be needed to bring those exposures for that occupation and sector into compliance. If exposures were at or below the proposed PEL, OSHA estimated costs only for those establishments that had no controls at all and would be required by paragraph (f)(2)(i) of the proposed standard to use one or more of the specified engineering or work practice controls where exposures equal or exceed the action level
      The estimated costs for the proposed beryllium rule represent the additional costs necessary for employers to achieve full compliance. They do not include costs associated with current compliance that may already have been achieved with regard to existing beryllium requirements.  The cost of complying with the proposed standard's program requirements depends on the extent to which employers in affected application groups are already undertaking some of the required actions. For example, regulated areas would be required where employee exposures cannot be reduced below the proposed PEL by using engineering and work practice controls.  If all employers in an industry have already provided regulated areas, perhaps by physically isolating high exposure processes and restricting access, then the industry's compliance rate for that requirement would be 100 percent, and that industry would incur no new costs for this provision under the proposed standard.
      Throughout this chapter, OSHA presents cost formulas in the text, usually in parentheses, to help explain the derivation of cost estimates for individual provisions.  Because the values used in the formulas shown in the text are shown only to the second decimal place, while the actual spreadsheet formulas used to create final costs are not limited to two decimal places, the calculation using the presented formula will sometimes differ slightly from the presented total in the text, which is the actual and mathematically correct total as shown in the tables.
      The remainder of this chapter is organized as follows.  First, OSHA explains how estimates of the costs of meeting the proposed PEL and STEL were developed.  Then, OSHA describes how estimates of the costs of the ancillary (or program) provisions of the proposed standard were developed.  The chapter concludes with a summary of the estimated costs of the proposed rule for all affected application groups and NAICS codes.
COMPLIANCE WITH THE PROPOSED PEL/STEL
      In this section, OSHA estimates the costs for affected employers to comply with the proposed PEL of 0.2 μg/m[3] and the proposed STEL of 2.0 μg/m[3].  The cost estimation consists of two parts.  First, costs are estimated for the engineering controls, additional studies, and custom design requirements to implement those controls, work practices, and specific training required for those work practices (as opposed to general training in compliance with the rule) needed for affected employers to meet the proposed PEL and STEL, as well as the opportunity costs (lost productivity) that may result from working with some of the new controls.    OSHA judged that the two-year lead-in time to comply with the proposed PEL would be sufficiently long that, in general, employers would be able to schedule the installation of any needed compliance equipment during periodic maintenance shifts or other planned production downtime with no, or de minimus, production disruptions. The Agency invites comment on this issue.
      Second, for employers unable to meet the proposed PEL and STEL using engineering controls and work practices alone, costs are estimated for respiratory protection sufficient to reduce worker exposure to the proposed PEL and STEL or below.
      In the technological feasibility analysis presented in Chapter IV of this PEA, OSHA concluded that implementing all engineering controls and work practices necessary to reach the proposed PEL will, except for a small residual group (accounting for about 6 percent of all exposures above the STEL), also reduce exposures below the STEL.  However, based on the nature of the processes this residual group is likely to be engaged in, the Agency expects that employees would already be using respirators to comply with the PEL under the proposed standard.  Therefore, with the proposed STEL set at ten times the proposed PEL, the Agency has preliminarily determined that engineering controls, work practices, and (when needed) respiratory protection sufficient to meet the proposed PEL are also sufficient to meet the proposed STEL.  For that reason, OSHA has estimated no additional costs in this chapter for affected employers to meet the proposed STEL.  The Agency invites comment and requests that the public provide data on this issue.

Control Costs:  Methodological Considerations

      For this preliminary cost analysis, OSHA estimated the necessary engineering controls and work practices for each affected application group according to the exposure profile of current exposures by occupation presented in Chapter III of this PEA.  Under the requirements of the proposed standard, employers would be required to implement engineering or work practice controls whenever beryllium exposures exceed the proposed PEL of 0.2 μg/m[3] or the proposed STEL of 2.0 μg/m[3].
      In addition, even if employees are not exposed above the proposed PEL or proposed STEL, paragraph (f)(2) of the proposed standard would require employers at or above the action level to use at least one engineering or work practice control to minimize worker exposure.  Based on the technological feasibility analysis presented in Chapter IV of this PEA, OSHA has determined that, for only two job categories in two application groups -- chemical process operators in the Stamping, Spring and Connection Manufacture application group and machinists in the Machining application group -- do the majority of facilities at or above the proposed action level, but below the proposed PEL, lack the baseline engineering or work controls required by paragraph (f)(2).  Therefore, OSHA has estimated costs, where appropriate, for employers in these two application groups to comply with paragraph (f)(2).
      By assigning controls based on application group, the Agency is best able to identify those workers with exposures above the proposed PEL and to design a control strategy for, and attribute costs specifically to, these groups of workers.  By using this approach, controls are targeting those specific processes, emission points, or procedures that create beryllium exposures.  Moreover, this approach allows OSHA to assign costs for technologies that are demonstrated to be the most effective in reducing exposures resulting from a particular process.
      The engineering controls necessary to comply with the proposed standard, which form the basis for estimating these compliance costs, are identified for each affected application group in Chapter IV of this PEA.  Engineering costs estimated in this section are based on reports and analyses prepared by OSHA's contractor, ERG, and can be found in the docket for the Small Business Advocacy Review (SBAR) Panel (SBAR, 2008).  All proposed requirements for specific control devices and practices, including necessary increases in ventilation, are based on OSHA's technological feasibility analysis in Chapter IV of this PEA.  In some instances, additional measures are necessary for the engineering controls to be installed and used effectively, such as additional special equipment-specific training, or additional assessment and design by an industrial hygienist.  These additional measures are also based on OSHA's technological feasibility analysis and explained in Chapter IV.
      In developing cost estimates, OSHA took into account the wide variation in the size or scope of the engineering or work practice changes necessary to minimize beryllium exposures based on technical literature, judgments of knowledgeable consultants, industry observers, and other sources. The resulting cost estimates reflect the representative conditions for the affected workers in each application group and across all work settings.  In all but a handful of cases (with the exceptions noted in the text), all wage costs come from the 2010 Occupational Employment Statistics (OES) of the Bureau of Labor Statistics (BLS, 2010a) and utilize the median wage for the appropriate occupation.  OSHA provides in the text for each wage rate the Standard Occupational Classification (SOC) code for the specific occupation.  The wages used include a 30.35 percent markup for fringe benefits as a percentage of total compensation, which is the average percentage markup for fringe benefits for all civilian workers from the 2010 Employer Costs for Employee Compensation of the BLS (BLS, 2010b).  All descriptions of production processes are drawn from the relevant sections of Chapter IV: Technical Feasibility in this PEA.
      The specific engineering costs for each of the applications groups, and the NAICS industries that contain those application groups, are discussed in the following section of this cost chapter.  Like the industry profile and technological feasibility analysis presented in earlier chapters in this document, this section of the cost chapter will present engineering control costs for the following application groups:
      Beryllium Production
      Beryllium Oxide, Ceramics & Composites Production
      Nonferrous Foundries
      Stamping, Spring and Connection Manufacture
      Secondary Smelting, Refining, and Alloying
      Copper Rolling, Drawing, and Extruding
      Secondary Smelting, Refining, and Alloying
      Precision Machining
      Welding
      Dental Laboratories
      The costs within these application groups are estimated by occupation and/or operation.  One application group could have multiple occupations, operations, or activities where workers are exposed to levels of beryllium above the proposed PEL, and each will need its own set of controls.  Capital costs and annual operation and maintenance (O&M) costs, as well as any other annual costs, are estimated for the set of engineering controls estimated to be necessary for limiting beryllium exposures for each occupation or operation within each application group.
Unit Costs Per Worker and Per Establishment
      Some engineering control costs are estimated on a per-worker basis and then multiplied by the estimated number of affected workers -- as identified in Chapter III: Profile of Affected Industries in this PEA -- to arrive at a total cost for a particular control within a particular application group.  This worker-based method is necessary because -- even though OSHA has data on the number of firms in each affected industry, the occupations and industrial activities that result in worker exposure to beryllium, and the exposure profile of at-risk occupations -- the Agency does not have a way to match up these data at the firm level.  Nor does the Agency have establishment-specific data on worker exposure to beryllium for all establishments, or even establishment-specific data on the level of activity involving worker exposure to beryllium.  Thus, OSHA could not always directly estimate per-affected-establishment costs, but instead first had to estimate aggregate compliance costs (using an estimated per-worker cost multiplied by the number of affected workers) and then calculate the average per-affected-establishment costs by dividing those aggregate costs by the number of affected establishments. This method, while correct on average, may under- or over-state costs for certain firms. For other controls that are implemented on a fixed-cost basis per establishment (e.g., creating a training program, writing a control program), the costs are estimated on an establishment basis, and these costs were multiplied by the number of affected establishments in the given application group to obtain total control costs.
      In developing cost estimates, the Agency sometimes had to make case-specific judgments about the number of workers affected by each engineering control.  Because work environments vary within occupations and across establishments, there are no definitive data on how many workers are likely to have their exposures reduced by a given set of controls. In the smallest establishments, especially those that might operate only one shift per day, some controls would limit exposures for only a single worker in one specific affected occupation.  More commonly, however, several workers are likely to benefit from each enhanced engineering control.  Many controls were judged to reduce exposure for employees in multi-shift work or where workstations are used by more than one worker per shift.
      In general, improving work practices involves operator training, actual work practice modifications, and better enforcement or supervision to minimize potential exposures.  The costs of these process improvements consist of the supervisor and worker time involved and would include the time spent by supervisors to develop a training program.
Estimating Current Compliance
      In general, OSHA viewed the extent to which exposure controls are already in place to be reflected in the distribution of exposures at levels above the proposed PEL among affected workers. Thus, for example, if 50 percent of workers in a given occupation are found to be exposed to beryllium at levels above the proposed PEL, OSHA judged this equivalent to 50 percent of facilities lacking adequate exposure controls.  OSHA has provided a sensitivity analysis of this judgment in Chapter VII of this PEA.
      As noted above, OSHA also judged that if an exposure is over the proposed PEL, all necessary controls would be needed.  OSHA believes that the combination of these two judgments is more likely to result in an overestimate of costs than an underestimate.  On the one hand, it possible that every facility has at least one person above the PEL and thus all would need to incur expenditures on controls, resulting in possible underestimates of costs. However, this possibility seems unlikely. A more likely scenario is that many facilities would not need any or all controls, either because baseline conditions produce exposures below the proposed PEL or because these facilities have already installed some controls.  The facilities may, for example, have the correct equipment installed but without adequate ventilation to provide protection to workers exposed to beryllium.  In this example, the Agency would expect that the remaining 50 percent of facilities to either have installed the relevant controls to reduce beryllium exposures below the PEL or that they engage in activities that do not require that the exposure controls be in place (for example, they do not perform any work with beryllium-containing materials). To estimate the need for incremental controls on a per-worker basis, OSHA used the exposure profile information as the best available data.
      OSHA recognizes that a very small percentage of facilities might have all the relevant controls in place but are still unable, for whatever reason, to achieve the proposed PEL through controls alone.  ERG's review of the industrial hygiene literature and other source materials (ERG, 2007b), however, suggest that the large majority of workplaces where workers are exposed to high levels of beryllium lack at least some of the relevant controls. Thus, in estimating the costs associated with the proposed standard, OSHA has generally assumed that high levels of exposure to beryllium occur due to the absence of suitable controls.  This assumption likely results in an overestimate of costs since, in some cases, employers may not need to install and maintain new controls in order to meet the proposed PEL but merely need to upgrade or better maintain existing controls, or to improve work practices.
Control Costs for Individual Application Groups
Beryllium Production
      Materion Corporation's Elmore, Ohio, plant is the only facility in the United States that currently produces beryllium metal.[,]  In addition to producing pure beryllium, beryllium oxide, and beryllium oxide products, a large part of the facility's operations are devoted to manufacturing a range of beryllium alloy products.  This facility is primarily in NAICS 331419: Primary smelting and refining of nonferrous metal (except copper and aluminum), but it also performs processes found in many of the other application groups affected by the proposed rule.  As a result, some of the engineering controls for the beryllium production application group will be the same as those in other application groups discussed later in this section.  Many of the activities undertaken by Materion in its processing of beryllium metal require ventilation enhancements and the installation of pharmaceutical-quality high containment isolators to comply with the proposed standard.  Because these items are included in multiple places throughout the remainder of this section, and to avoid repeating this detailed discussion of these costs, OSHA is presenting the estimates for these two cost items before the discussion of the individual activities where these controls are necessary.
      OSHA applied a standard cost for ventilation enhancements of $25 per cubic foot per minute (cfm) for additional exhaust capacity in this application group, along with $5 per cfm for make-up air (air introduced into the environment to replace air that is displaced through the suction of the additional exhaust ventilation).  These ventilation cost estimates are based on ERG research identifying an average cost across different facilities, recognizing that the actual capacity of the equipment is likely to vary by facility, and factoring in the cost of ductwork.  The $30 ($25 + $5) per cfm figure is higher than that estimated in other application groups and is based on Materion's estimates of representative costs for ventilation enhancements it has made in several plant renovations. These higher costs appear to be related to exceptional costs for filtering of exhaust air.
      For all other application groups the cost per cfm of ventilator enhancements is $13.18, which is based on ERG's research (ERG, 2013).  Also, O&M expenses for such enhancements are estimated to be $3.92 per additional cfm, which ERG based on its research of energy costs incurred in the operation of an LEV system, averaged across a number of representative cities, plus an estimated annual maintenance cost amounting to 10 percent of capital investment (10 percent of the $13.18 per cfm) (ERG, 2013).
      The installation of pharmaceutical-quality high containment isolators is needed for several processes: impact grinding, compact loading/sintering, near net shape fabrication, beryllium sulfate salt processing, and atomization.  The containment isolators have a total capital cost of $517,500.  This capital cost is made up of a filling and weighing system ($117,500), a drum unload/cleaning system ($300,000), and a cost for integrating new technology with existing systems ($100,000) (Bernero, 2005).  The total cost, annualized over a ten year period at a three percent discount rate, is $60,667.  There is an additional annual operating and maintenance cost for filling and weighing and drum unload/cleaning systems, estimated to be 15 percent of the total non-annualized capital cost for these systems, or $62,625 (0.15 x $417,500).  The total annualized per-unit cost for a pharmaceutical-quality high containment isolator is $123,292 ($60,667 + $62,625).
      The remainder of this section presents detailed estimates either by type of worker who may be exposed to beryllium or by type of activity that may result in beryllium exposures.  Each subsection presents the categories of controls that the Agency has estimated are necessary to reduce beryllium exposures to limits at or below the proposed PEL for each type of worker or type of activity.  For this application group, OSHA has estimated the following types of workers or activities will need additional engineering controls:
	Wastewater Treatment Workers
	Decontamination Workers
	Mix/Makeup Workers
	Scrap Recycling/Reclamation Workers
	Production Equipment, Furnace, and Tool Maintenance Workers
	Machining Operations
	Welders
	Impact Grinders
	Compact Loading and Cisterning
	Near Net Shape Fabrication
	Beryllium Sulfate Salt Processing
	Alloy Induction and Alloy Arc Furnace Workers
	Vacuum Casting
	Atomization
	Beryllium Oxide Furnace Workers
The total costs for this application group are presented in Table V-2 at the end of this section.

Wastewater Treatment Workers
      Wastewater treatment worker exposures to high levels of beryllium result from beryllium contamination in the treatment plant water, and are estimated to be associated primarily with sludge cake operation (operating and cleaning the filter presses and monitoring bag filling).  Once sludge contaminated with beryllium has been allowed to dry, the resulting dust can become easily airborne and is a potential source of beryllium exposure.  High exposures for wastewater treatment workers are reportedly a result of poor work practices and inadequate housekeeping (Kent, 2005).
      The Agency has estimated costs for enhanced work practices through operator training, work practice modification, and better supervision that will minimize exposures associated with the sludge cake operation.  For example, wastewater treatment operators need to limit the number of times the sludge cake is pressed to avoid making it too dry.  A dry cake can increase the amount of dust generated during sludge bag filling and directly affect worker exposure and contaminate the work environment.
      OSHA estimates that, in the first year that the proposed standard is in effect, a supervisor, with an hourly wage of $37.11 (First-Line Supervisors of Production and Operating Workers, SOC: 51-1011), will initially spend eight hours per worker developing a training program, resulting in a cost of $297 (8 x $37.11) per worker.  The supervisor will then provide an eight-hour training-course to the workers. Assuming that, on average, the class contains 4 employees, the supervisor time per employee will be 2 hours, at a cost of $74 (2 x $37.11).  Each worker, with a wage of $22.16 (Production Occupations, SOC: 51-0000), will spend eight hours in the training session, for a total of $177 (8 x $22.16), resulting in a per-employee cost of $548 ($297 + $74 + $177).  After the first year, annual training is estimated to require four hours of training per worker, with the supervisor spending one hour per worker (4 supervisor hours of training/4 workers) for an annual cost of $126 ($37.11 + (4 x $22.16)).  The total annualized cost per wastewater treatment worker is $190.  OSHA preliminarily estimates that there are seven affected wastewater treatment workers in this application group, resulting in a total cost of $1,330 to control beryllium exposures for these workers.

Decontamination Workers
       Decontamination workers perform large-scale surface cleaning in places that do not get cleaned frequently.  Entire areas are shut down based on a predetermined work schedule.  Small equipment (not currently installed) can be decontaminated in enclosed/sealed cleaning cabinets (NIOSH, 1977).  Using such equipment, decontamination workers' exposures would be greatly reduced.  An industry consultant suggests that perhaps 20 percent of the equipment that is decontaminated (e.g., engines) could be cleaned in a leak-tight decontamination chamber (Corbett, 2004).