Rod and wire production: point and chamfer (high-speed machining), wire annealing and pickling, wire drawing, wire rolling, straightening, die grinding, and rod and wire packing.

Strip metal production: strip annealing, strip rolling, slitting, strip pickling, inspection, degreasing, shipping and receiving, salt baths, cadmium plating, welding, and deburring.

Production support: maintenance mechanics, quality assurance (metallurgy lab), wastewater treatment.

Administration: plant and office.
For the period 1969 to 2000, the facility collected 650 personal (lapel), 4,524 general area, and 815 short-duration high-volume (SD-HV) breathing zone task samples. Median plantwide values for personal, general area, and SD-HV samples were 0.02 μg/m[3], 0.09 μg/m[3], and 0.44 μg/m[3], respectively. Ninety-nine percent of all personal samples were below 2 μg/m[3], and 93% were less than 0.2 μg/m[3]; 97% of the general area samples were below 0.5 μg/m[3]; 90% of the SD-HV task samples were less than 5 μg/m[3], and 97% were below 25 μg/m[3]. Wire annealing and pickling had the highest median (0.12 μg/m[3]) among personal samples and the highest arithmetic mean (2.77 μg/m[3]) among general area samples. Individual PBZ sample results not provided.
No systems in place to prevent migration of beryllium from production areas into support areas.

Respirator use primarily limited to intermittent tasks where high exposure had been found or could potentially occur.

After the completion of the Schuler et al. investigation, the wire annealing and pickling area was enclosed with walls and placed under negative pressure relative to adjacent areas. Access to the area was restricted, and protective work clothing (over garments), gloves, and powered air-purifying respirators were required for entry.
Day et al., 2007
Levels of beryllium in workplace air, on work surfaces, and on employees (hands, neck, and face) were evaluated after the 2002 implementation of an improved particulate-migration control program in a beryllium alloy facility, including dermal protection in production areas.**
Production, production support, and administration.

Production included 1) strip production (annealing, inspection, pickling, rolling, slitting, shipping/receiving) and 2) rod and wire processes (die grinding, point and chamfer, rod straightening, wire drawing, wire annealing, pickling).

Work in production support included maintenance (mechanics), quality assurance (metallurgical laboratory), and waste water treatment. Production support work required frequent entry into production areas.

Administration limited to front office area (human resources and accounting). Administration work rarely required entry into production areas.
Collected 10 general area samples; 252 wipes from routinely handled work surfaces; 113 thin cotton glove samples worn by employees, and 109 neck wipes and 109 face wipes from the same employees.

General area sample results: GM beryllium concentration among all general area samples was 0.003 ug/m[3] and ranged from 0.0007 ug/m[3] (administration) to 0.0238 ug/m[3] (wire annealing and pickling).

Surface wipe sample results: GM beryllium concentration was 0.77 ug/100 cm[2] and ranged from 0.05 ug/100 cm[2] in administration to 13.6 ug/100 cm[2] in wire annealing and pickling.

Cotton glove samples: GM beryllium mass on cotton glove samples was 13.4 ug and ranged from 0.007 ug for an administration worker to 2,534 ug for a worker in rod straightening.

Skin wipe samples: GM beryllium mass on neck wipe samples was 0.04 ug and ranged from less than the LOD in administration workers to 0.58 ug for a worker in rod straightening. GM of the face wipe samples was 0.04 ug and ranged from less than the LOD in administration workers to 1.44 ug for a worker in rod straightening.
Workers protected by comprehensive prevention program improved during 2000 and 2001. Program included improvements to existing ventilation and migration control strategies using isolation, engineering and administrative controls, and PPE, especially in work areas associated with elevated risk of beryllium sensitization. All workers wore single-use, disposable nitrile gloves and company-supplied long-sleeved work clothing; respirators with HEPA filters were worn when inhalation exposures were likely to exceed 0.2 ug/m[3] and during designated tasks.

Within wire annealing and pickling, controls were designed to minimize exposure and migration of contamination to other areas. Engineering controls included isolation from remainder of facility and increased ventilation, and tacky floor mats. Administrative controls included restricting access, minimizing number of employees in area, dedicating tools and equipment to area, and implementing specific protocols for entering/exiting area. Employees in area required to wear hooded PAPR respirators with HEPA filters, coveralls, rubber boots, and inner (nitrile) and outer (cotton, acid resistant or leather) gloves.
Thomas et al., 2009
NIOSH investigators assessed a multifaceted program to prevent beryllium sensitization among new employees at a copper-beryllium alloy processing facility (described also by Schuler et al. and Day et al.). As part of this assessment, NIOSH described the evolution of the preventive program and calculated mean airborne beryllium levels in the facility before and after the preventive program.
See Day et al. (2007) above.
Thomas et al. grouped and analyzed 2,394 full-shift PBZ lapel samples collected by the facility into three time periods -- 1995 to May 2000, June 2000 to December 2001, and January 2002 to July 2007 -- to reflect the workplace conditions experienced by employees during the evolution of the enhanced preventive program.

Descriptive statistics for the airborne beryllium concentrations are summarized in a detailed table by time period (1995 to 2007) and process group.
See Day et al. (2007) above.
*	Schuler et al. do not explicitly state that the copper-beryllium alloy plant is a Brush Wellman facility; however, Brush Wellman has acknowledged that the study facility is the Brush Wellman Reading, Pennsylvania, plant (Brush Wellman Reading, 2004).
**	Day et al. (2007) do not explicitly state that the copper-beryllium alloy facility described in their paper is the Brush Wellman Reading, Pennsylvania, facility. Information confirming the identity of the facility as the Brush Wellman Reading facility was obtained from NIOSH beryllium research updates (NIOSH Beryllium Research, 2005; Schuler, 2007).

CBD: chronic beryllium disease
2% Cu-Be alloy: 98% copper and 2% beryllium
1.8% Cu-Be alloy: 98.2% copper and 1.8% beryllium
GM: geometric mean
HEPA: high efficiency particulate air (filter)
PAPR: powered air-purifying respirator
TWA: time-weighted average
STEL: short-term exposure limit (15-minute TWA)
PBZ: personal breathing zone
PPE: personal protective equipment

SECTION 8 -- Copper Rolling, Drawing, and Extruding, Appendix 3 -- detailed personal exposure profile for the copper rolling, drawing, and extruding application group
Table IV-60 -- Personal Exposure Profile for the Copper Rolling, Drawing, and Extruding Application group
(NAICS 331421 and 331422)[a,b]
Job Category and Work Group
                                    No. of
                                    Samples
                               Range (μg/m[3])
                                     Mean
                                  (μg/m[3])
                                    Median
                                  (μg/m[3])
ADMINISTRATIVE
                                      68
                                 0.01 to 0.11
                                     0.022
                                     0.017
Engineering technician; expediter
                                      57
                                 0.01 to 0.11
                                     0.022
                                     0.017
Office
                                      11
                                 0.01 to 0.062
                                     0.021
                                     0.013
PRODUCTION SUPPORT
                                      52
                                 0.01 to 0.33
                                     0.04
                                     0.022
Wastewater treatment
                                       3
                                 0.077 to 0.33
                                     0.17
                                     0.11
Maintenance (plant and office)
                                      44
                                 0.014 to 0.1
                                     0.028
                                     0.02
Quality assurance (metallurgical lab)
                                       5
                                 0.01 to 0.13
                                     0.066
                                     0.061
PRODUCTION: Rod and Wire (bulk products)
                                      210
                                  0.01 to 7.8
                                     0.25
                                     0.055
Point and chamfer
                                      49
                                 0.01 to 1.58
                                     0.073
                                     0.028
Bulk pickling and annealing (same operator)
                                      78
                                  0.02 to 7.8
                                     0.57
                                     0.12
Wire drawing (swager pointer and bull blocks)
                                      30
                                 0.014 to 0.38
                                     0.076
                                     0.058
Rod and wire packing
                                      18
                                 0.016 to 0.17
                                     0.034
                                     0.025
Straightening
                                      34
                                 0.012 to 0.22
                                     0.048
                                     0.031
Die grinding
                                       1
                                0.018 to 0.018
                                     0.018
                                     0.018
PRODUCTION: Strip Metal
                                      320
                                 0.006 to 0.72
                                     0.041
                                     0.017
Strip annealing
                                      71
                                 0.006 to 0.72
                                     0.062
                                     0.026
Strip rolling (Z-mill)
                                      55
                                 0.01 to 0.31
                                     0.036
                                     0.017
Strip slitting
                                      33
                                 0.01 to 0.23
                                     0.043
                                     0.017
Strip pickling
                                      73
                                 0.011 to 0.28
                                     0.048
                                     0.033
Strip inspection
                                      30
                                 0.007 to 0.12
                                     0.021
                                     0.016
Shipping and receiving
                                      58
                                 0.011 to 0.12
                                     0.019
                                     0.017
TOTAL
                                      650
                                 0.006 to 7.8
                                     0.11
                                     0.024
[a]	Full-shift personal breathing zone (PBZ) results are based on the actual sample duration (400 minutes or longer). Nondetectable results are reported at one-half the analytical limit of detection (i.e., 0.05 micrograms beryllium per filter).
[b]	The exposure profile is a summary of full-shift PBZ total beryllium sample results for workers at the Brush Wellman Inc. Reading, Pennsylvania, alloy rolling and drawing mill from 1977 through 2000. Note that this facility does not conduct extruding.

Source: Brush Wellman Reading, 2004

TABLE IV-61 -- Distribution of Full-Shift PBZ Exposure Results for Total Beryllium in the Copper Rolling, Drawing, and Extruding Application group (NAICS 331421 and 331422)[a,b]
Job Category and Work Group
                     Number of Results in Range (ug/m[3])
                                     Total

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

ADMINISTRATIVE
                                      67
                                    (98.5%)
                                       1
                                    (1.5%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                      68
                                    (100%)
Engineering technician; expediter
                                      56
                                     (98%)
                                       1
                                     (2%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                      57
                                    (100%)
Office
                                      11
                                    (100%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                      11
                                    (100%)
PRODUCTION SUPPORT
                                      49
                                     (94%)
                                       2
                                     (4%)
                                       1
                                     (2%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                      52
                                    (100%)
Wastewater treatment
                                       1
                                    (33.3%)
                                       1
                                    (33.3%)
                                       1
                                    (33.3%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       3
                                    (100%)
Maintenance (plant and office)
                                      44
                                    (100%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                      44
                                    (100%)
Quality Assurance (metallurgical lab)
                                       4
                                     (80%)
                                       1
                                     (20%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       5
                                    (100%)
PRODUCTION: Rod and Wire (bulk products)
                                      147
                                     (70%)
                                      28
                                     (13%)
                                      22
                                     (11%)
                                       4
                                     (2%)
                                       4
                                     (2%)
                                       5
                                     (2%)
                                      210
                                    (100%)
Point and chamfer
                                      44
                                     (90%)
                                       3
                                     (6%)
                                       1
                                     (2%)
                                       0
                                     (0%)
                                       1
                                     (2%)
                                       0
                                     (0%)
                                      49
                                    (100%)
Bulk pickling and annealing (same operator)
                                      32
                                     (41%)
                                      16
                                     (21%)
                                      18
                                     (23%)
                                       4
                                     (5%)
                                       3
                                     (4%)
                                       5
                                     (6%)
                                      78
                                    (100%)
Wire drawing
(swager pointer and bull blocks)
                                      25
                                     (83%)
                                       3
                                     (10%)
                                       2
                                     (7%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                      30
                                    (100%)
Rod and wire packing
                                      17
                                     (94%)
                                       1
                                     (6%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                      18
                                    (100%)
Straightening
                                      28
                                     (82%)
                                       5
                                     (15%)
                                       1
                                     (3%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                      34
                                    (100%)
Die grinding
                                       1
                                    (100%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       1
                                    (100%)
PRODUCTION: Strip Metal
                                      297
                                     (93%)
                                      15
                                     (4%)
                                       6
                                     (2%)
                                       2
                                     (1%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                      320
                                    (100%)
Strip annealing
                                      62
                                     (87%)
                                       6
                                     (9%)
                                       1
                                     (1%)
                                       2
                                     (3%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                      71
                                    (100%)
Strip rolling (Z-mill)
                                      51
                                     (93%)
                                       3
                                     (5%)
                                       1
                                     (2%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                      55
                                    (100%)
Strip slitting
                                      30
                                     (91%)
                                       2
                                     (6%)
                                       1
                                     (3%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                      33
                                    (100%)
Strip pickling
                                      68
                                     (93%)
                                       2
                                     (3%)
                                       3
                                     (4%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                      73
                                    (100%)
Strip inspection
                                      29
                                     (97%)
                                       1
                                     (3%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                      30
                                    (100%)
Shipping and receiving
                                      57
                                     (98%)
                                       1
                                     (2%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                      58
                                    (100%)
TOTAL
                                      560
                                     (86%)
                                      46
                                     (7%)
                                      29
                                     (4%)
                                       6
                                     (1%)
                                       4
                                     (1%)
                                       5
                                     (1%)
                                      650
                                    (100%)
[a]	Full-shift personal breathing zone (PBZ) sample results are based on the actual sample duration (400 minutes or longer). Nondetectable results are reported at one-half the analytical limit of detection (i.e., 0.05 ug beryllium per filter).
[b]	The distribution represents full-shift PBZ total beryllium sample results for workers at the Brush Wellman Inc. Reading, Pennsylvania, alloy rolling and drawing mill from 1977 through 2000. Note that this facility does not conduct extruding.

Source: Brush Wellman Reading, 2004

SECTION 9 -- FABRICATION OF BERYLLIUM ALLOY PRODUCTS
Industry Profile
Beryllium alloys (most typically copper-beryllium less than or equal to 2 percent beryllium) are used to make light-gauge springs, electronic connectors, and other stamped and formed metal products. The subsection on Light-Gauge Spring Manufacturing in this section on Fabrication of Beryllium Alloy Products shows the one NAICS classification associated with light-gauge spring manufacturing and the subsection on Electronic Connectors and Other Stamped and Formed Metal Products shows the three NAICS classifications associated with electronic connectors, and other stamped and formed metal products manufacturing.
Light-Gauge Spring Manufacturing
Beryllium alloy wire is commonly used to produce coil springs for electronic applications in automobile, aerospace, telecommunications, computers, and other sectors.  Information from industry contacts and literature discussed below suggest that copper-beryllium is used almost exclusively in the manufacture of light-gauge springs (NAICS 332612) and has little application in the manufacture of heavy-gauge springs (NAICS 332611).
Copper-beryllium alloys are used in the manufacture of most major types of light-gauge springs, including:
Coil springs:
Compression springs:  Coiled helical springs that resist compressive force applied axially (Acxess Spring, 2006; MW Industries, 2012).
Extension springs:  Springs wound with initial tension that holds the coils together and offers resistance to pulling. These springs have many different styles of hooked or looped ends (Acxess Spring, 2006; MW Industries, 2012).
Torsion springs:  Springs designed to offer resistance to applied torque. When deflected, they will reduce in coil diameter and extend in overall length (Acxess Spring, 2006; MW Industries, 2012).
Constant force springs:  Springs that consist of a rolled strip of metal, usually tightly wrapped on a drum.  These springs exert nearly constant restraining force to resist uncoiling (Spring-I-Pedia, 2011; Trakar, 2012).
Flat springs:  In its simplest form, a flat spring is made from a flat sheet, strip, or plate of metal that has been bent so that when pressure is applied to its outside ends, it flexes at the bend.  However, flat springs can have more complex designs that include multiple bends as well as cuts and holes.  A leaf spring is a type of narrow flat spring bent in an arch (Atlantic Precision Spring, 2012; JobShop.com, 2006, Rapid Sheet Metal, 2011).
According to industry contacts and product literature, the outer diameter of copper-beryllium coil springs ranges from 0.002 inches to 0.8 inches but does not usually exceed 0.125 inches (Witham, 2001; Wood, 2001).  Copper-beryllium alloys used in spring manufacturing range from 0.15 to 2.0 percent beryllium by weight (CDA, 1996; CDA, 1998; Brush Wellman MSDS No. A10, 2005; Acxess Spring, 2006).
Copper-beryllium alloys have several characteristics that make them good spring materials, including electrical and thermal conductivity, high strength and hardness, good corrosion and fatigue resistance, and non-magnetic properties (USGS, 2000).  These alloys can be used in a wide range of temperatures with little loss of mechanical property (NGK, 2012). Because of the high mechanical strength of copper-beryllium alloys, their use allows the production of smaller and lighter springs with the same spring pressure when compared with other materials, such as phosphor bronze (NGK, 2012).
Copper-beryllium springs are used primarily in electronic components and equipment but are also used as electrical conductors in high-temperature environments, where magnetic fields present a problem, where corrosion resistance is needed, and in applications where springs are exposed to sub-zero temperatures (Acxess Spring, 2006; Silberstein, 2007).
Number of Establishments and Employees
The 2010 County Business Patterns data show 323 establishments with 10,329 total employees for the light spring manufacturing industry (see Table IV-62).  Of these establishments, most (93.3 percent) employ fewer than 100 employees.  According to industry contacts and a review of spring manufacturer websites, most spring manufacturers potentially use copper-beryllium alloys, though copper-beryllium springs typically account for only a small percentage of their overall business.  All coil spring manufacturers contacted indicated that they use copper-beryllium (Bollinger, 2001; Briere, 2001; Germain, 2001; Leahy, 2001; Victorian, 2001; Witham, 2001).  However, three of the manufacturers indicated that copper-beryllium springs accounted for 3 percent or less of their business, and a fourth indicated that copper-beryllium springs accounted for a very small percentage (Bollinger, 2001; Germain, 2001; Leahy, 2001; Witham, 2001).  The remaining two contacts did not supply this information.
Table IV-62 -- Spring Manufacturing (2010)
                                NAICS Industry
                            Affected Establishments
                              Affected Employees
332612, Light Gauge Spring Manufacturing
                                      323
                                    10,329
Sources: U.S. Census Bureau, 2010; OSHA Office of Regulatory Analysis

A representative of the Spring Manufacturers Institute (SMI) also indicated that copper-beryllium springs account for only a small part of the overall coil spring market.  However, any spring manufacturer could produce them because no special equipment is required.  According to the SMI representative, the spring business is based almost entirely on custom orders, with manufacturers producing springs to customer specifications (Wood, 2001).  Therefore, virtually any spring manufacturer could receive an order for copper-beryllium springs.  Based on information from manufacturers, the SMI, and spring manufacturer websites, OSHA estimates that all light-gauge spring manufacturers are manufacturing copper-beryllium springs, at least on an occasional basis.
Overview of Spring Manufacturing Technology
The processes used in manufacturing springs depend on the type of spring being produced.  The process for steel alloy coiled springs is described below and includes coiling, hardening or heat treating, and finishing (Madehow.com, 2009).  The process for copper-beryllium springs is similar.  One spring manufacturer reports that after copper-beryllium springs are manufactured, they are heat treated to reduce distortion, re-inspected to ensure dimensional accuracy, and then finished by plating (Atlantic Precision Spring, 2012).
Coiling: Coil springs are manufactured by winding wire around a rod called an arbor or mandrel (Silberstein, 2007).  Alternatively, the wire may be coiled without a mandrel using production machinery, such as a central navigation computer machine (Madehow.com, 2009). Automatic coiling machinery is typically used to manufacture large batch quantities of springs. For smaller quantities, springs can be produced manually using semi-automatic equipment, such as a lathe (an arbor is secured in the chuck of the lathe and the spring wire is coiled around the arbor).  Copper-beryllium and other types of wire used in spring manufacturing are purchased from suppliers.  Refer to Preliminary Economic Analysis, Section 8 -- Rolling, Drawing, and Extruding, for information on the firms that produce copper alloy wires.
Cold coiling of wire up to 0.75 inches in diameter consists of winding wire at room temperature around an arbor or mandrel.  Winding is done on a dedicated, automatic spring-winding machine; a lathe; an electric hand drill with the mandrel secured in the chuck; a hand-cranked winding machine; or a computer numerically controlled machine (Madehow.com, 2009).
Hot coiling is done when thicker wire or bar stock is used for springs.  The steel is heated to make it flexible and then wound around a mandrel while red hot.  Standard industrial coiling machines are used for bar stock up to 3 inches in diameter.  After coiling, the steel is removed from the coiling machine and immersed into oil to cool and harden it.
Hardening (heat treating): Coiling creates stress that must be relieved for the steel to maintain its resilience (Madehow.com, 2009).  To relieve this stress, the spring must be tempered after coiling by heat treating it in an oven at the appropriate temperature for a predetermined time and then allowing it to cool slowly.  Heat treating is required for all steel springs regardless of whether the steel has been coiled hot or cold.
An SMI representative stated that coil spring manufacturing typically does not require any machining, grinding, heat treating, or annealing; just cold forming (Wood, 2001).  The available information suggests, however, that the manufacture of some coil springs can involve both heat treating and grinding.  For example, steel alloy coiled springs may be coiled at room temperature (cold winding) or by heating the metal to make it flexible (hot winding).  Whether the steel has been coiled hot or cold, the process creates stress within the material that must be relieved by heat treating (Madehow.com, 2009).  For example, the guidelines for stress relief of copper-beryllium springs call for heating the springs at 600[o]F for 90 minutes.  Heat can cause compression springs to shorten; compression springs for high-temperature applications are heat-set so that shortening will not occur while the spring is in use (Silberstein, 2007).  One-third of the spring manufacturers contacted for this study reported heat treating copper-beryllium springs (Briere, 2001; Germain, 2001).
Finishing: Finishing steps include grinding (if specified by design), shot peening, setting, coating (electroplating or mechanical coating), and packaging.  Shot peening (hammering the entire surface of the spring with tiny steel balls) strengthens the steel to resist metal fatigue and cracking during its lifetime of repeated flexings.  Setting (fully compressing the spring so all the coils touch each other) permanently fixes the desired length and pitch of the spring.  Coatings protect the surface of the spring from corrosion and include painting, dipping the spring in liquid rubber, electroplating with another metal such as chromium or zinc, and mechanical plating (tumbling with metallic powder, water, accelerant chemicals, and tiny glass beads that pound the powder onto the spring surface).  When carbon steel springs are electroplated, they must be baked for several hours (at 325°F to 375°F) soon after plating to counteract embrittlement, which results from the plating process.  Completed springs are individually bagged, enclosed in tubes, affixed to sticky paper, strung onto wires, or bulk-packaged in plastic bags or boxes (Madehow.com, 2009).
Grinding of copper-beryllium springs also occurs but, according to manufacturers' representatives, is limited.  Only one of the six spring manufacturers contacted for this study reported grinding copper-beryllium springs, and this manufacturer indicated that his facility only performs grinding on about 10 percent of the copper-beryllium springs produced (Bollinger, 2001).  A coil spring manufacturing manual indicates that grinding can occur during the manufacture of compression springs.  For some applications, each end of the spring has to be ground square with respect to the body of the spring (Silberstein, 2007).  If the design calls for flat ends, the ends are ground during the finishing steps.  For coiled springs, the spring is mounted in a jig and held against a rotating abrasive wheel.  Alternatively, if highly automated equipment is used, the spring is held in a sleeve while both ends are ground simultaneously. Grinding may be performed with water or an oil-based substance to cool the spring, carry away particles, and lubricate the grinding wheel (Madehow.com, 2009).
A review of the websites of several manufacturers of copper-beryllium springs indicates that some manufacturers perform grinding (and other machining) and heat treating in-house (MW Industries, 2012).  Others perform machining-related activities in-house and utilize a network of approved vendors for surface modification and physical property alteration such as plating and heat treating (Atlantic Precision Spring, 2012; Dudek and Bock, 2012).
For all springs, the waste wire at the ends of the springs must be cut away.  When highly automated spring manufacturing machines are used, the machine does the cutting.  For small-scale production operations (fewer than 50 springs), springs may be cut with wire cutters, a cutoff wheel, or an acetylene torch (Silberstein, 2007).
Electronic Connectors and Other Stamped and Formed Metal Products
Beryllium alloys (typically copper-beryllium alloy) are stamped and formed to make a variety of parts, especially for electronic applications.  These applications include connectors, terminals, switches, spring contacts, and electromagnetic interference (EMI) shielding gaskets (Battey, 2002; Page, 2002; Tech-Etch, 2006).  Stamped alloy is also used to make a wide range of clips and card guides used to secure parts in electronic assemblies.  Copper-beryllium clips are used to secure components, such as resisters, capacitors, fuses, relays, transistors, and other small cylindrical parts in electronic assemblies (Atlee Clips, 2012).  Copper-beryllium card guides are used to hold printed circuit boards in place (Atlee Card Guides, 2012).  Manufacturers also stamp copper-beryllium to produce parts for mechanical applications, including spring washers and retaining rings (Small Parts, 2006; Rotor Clip, 2008).
Electronic connectors are devices for mating and de-mating electrical power connections or communications media (NTIA, 1996).  Copper-beryllium alloys are used in the manufacture of a variety of electronic connector components, including flat and leaf springs, pins, jacks, and bus bars.  These components find use in computers, telecommunication equipment, audio and video components, medical monitors, and a range of other electronic equipment.
Number of Establishments and Employees
Establishments producing connectors or other stamped and formed metal products are classified in three NAICS industries.  Facilities specializing in the production of electronic connectors and components are classified in NAICS 334417, Electronic Connector Manufacturing.  Other establishments in the NAICS classification NAICS 332116, Metal Stamping, might produce stamped and formed products for use in the connector and electronics industries.  Manufacturers producing electrical or electronic-related automotive parts might also directly use copper-beryllium alloys in the production of electronic equipment.  These producers are included in the NAICS classification 336322, Other Motor Vehicle Electrical and Electronic Equipment Manufacturing.
Manufacturers of Stamped Products (NAICS 332116) Using Beryllium Alloys: Facilities in this industry produce stamped products for a range of applications, using a variety of metals.  Based on information from industry representatives, copper-beryllium is used, at least occasionally, by most stampers that supply the electronics industry (Page, 2002; Tschool, 2002). Many such stampers produce parts to order and will use copper-beryllium alloys if called for in the customer's specifications (Battey, 2002; Becker, 2002; Tschool, 2002).
Copper-beryllium alloy stampings are believed to account for only a small percentage of the industry's total output, however.  Though two stampers contacted said that copper-beryllium alloy stampings account for a substantial portion of their business (Laird, 2001; Yarborough, 2002), most industry sources stated that the alloy represented only a small percent of their overall output (Battey, 2002; Becker, 2002; Tschool, 2002; Volkert, 2001).  One source estimated that no more than 5 percent of stamped parts intended for the electronics market are made of copper-beryllium alloys (Page, 2002).
Based on data from the 2007 Economic Census Product Summary, it is possible to identify the subset of companies that are likely to be stamping copper-beryllium parts for the electronics industry.  These are the four product codes that OSHA has preliminarily determined comprise all copper-beryllium electronics applications in this NAICS industry code: NAICS<PHONE_NUMBER>: Radio and Phonographs; NAICS<PHONE_NUMBER>: Televisions; NAICS<PHONE_NUMBER>: Computers; and NAICS<PHONE_NUMBER>: Office Machines.
The 2007 Economic Census reports a total of 97 companies in these product classes. More recent information from the U.S. Census Bureau is not available to determine the number of affected establishments and employees. In order to estimate the number of affected establishments and employees, OSHA used historical information from the U.S Census Bureau. OSHA's arrival at an estimate of affected establishments is discussed below.
The 2002 Economic Census reports a total of 1,698 companies with 1,787 establishments in this NAICS code (with only a portion that manufacture products for the electronics industry). These numbers yield and average of 1.05 establishments per company.  Thus, OSHA estimated a total number of establishments that manufacture products for the electronics industry by multiplying the 2007 Census number of companies likely to be producing stamped products for the electronics industry (97) by the 2002 Census total ratio of establishments per company in this NAICS code (1.05).  This yields an estimate of 102 establishments.  In order to obtain an estimate that reflect more recent data, OSHA multiplied this estimate by a ratio of 2010 Census total number of establishments to 2007 Census total number of establishments (102 * (1484/1528)).  This results in a 2010 estimate of 99 establishments.  Based on information from industry representatives, OSHA estimates that approximately 75 percent of these 99 stampers that produce parts for the electronics industry work with copper-beryllium alloys.  OSHA's current estimate of affected establishments is 74 establishments.
OSHA has assumed that the number of employees per establishment in affected establishments is the same as that for all establishments in the NAICS group.  Table IV-63 summarizes the number of affected establishments and employees in NAICS industry 332116.
Electronic Connector Manufacturers (NAICS 334417) Using Beryllium Alloys: According to the 2010 County Business Patterns, electronic connector industries (NAICS 334417) comprise 231 establishments.  No data exist regarding the number of electronic connector manufacturers that use copper-beryllium alloys, nor could any of the industry sources contacted provide an estimate of the share of connector manufacturers that use such alloys. Because of copper-beryllium's cost, however, most sources believe that the number of copper-beryllium users is limited.  This assumption is supported by an overall review of information on connector manufacturers in Thomas Register and on the Web (Thomas Register, 2002; Thomas Net, 2006).  Based on these sources, OSHA estimates that 20 percent or fewer of electronic connector manufacturers likely use copper-beryllium alloys.  Applying this percentage to the 231 establishments, OSHA estimates that 46 establishments (0.2 x 231) in this industry use copper-beryllium alloys.  OSHA has assumed that the number of employees per establishment in affected establishments is the same as that for all establishments in the NAICS group. Table IV-63 summarizes the number of affected establishments and employees in NAICS industry 334417.
Automotive Parts Manufacturers (NAICS 336322) Using Copper-Beryllium Alloys: According to the 2010 County Business Patterns, 636 establishments produce automotive electrical and electronic equipment (NAICS 336322).  Data describing the number of automotive parts manufacturers using copper-beryllium alloys are not available.  Based on an earlier analysis of data from the 2002 Economic Census and the Brush Wellman customer database, OSHA estimated that about 25 percent of automotive parts manufacturers perform copper-beryllium alloy stamping, primarily for electronic applications (Kolanz, 2001).  Applying this percentage to the establishment figures from the 2010 County Business Patterns, the Agency estimates that 159 establishments (636 x .25) in this industry use beryllium alloys.  OSHA has assumed that the number of employees per establishment in affected establishments is the same as that for all establishments in the NAICS group.  Table IV-63 summarizes the number of affected establishments and employees in NAICS industry 336322.
Table IV-63 -- Electronic Connector Manufacturing and Metal Stamping (2010)
                                NAICS Industry
                            Affected Establishments
                              Affected Employees
332116, Metal Stamping
                                      74
                                     2,436
334417, Electronic Connector Manufacturing
                                      46
                                     3,908
336322, Other Motor Vehicle Electronic and Electronic Equipment
                                      159
                                     9,619
Source: U.S. Census Bureau, 2002 ; U.S. Census Bureau 2010 ; OSHA Office of Regulatory Analysis

Overview of Stamping Process Technology
Large and medium-size stamping operations are primarily automated and enclosed. Smaller shops still use manually operated presses, however, and larger shops may maintain manually operated equipment for smaller jobs.  Stamping is often performed under a light flood coolant (Page, 2002).  Copper-beryllium scrap resulting from stamping is generally returned to the supplier (Yarborough, 2002).  According to industry representatives, limited grinding or other machining is performed on parts after stamping (Battey, 2002; Downing, 2002; Gabriel, 2002; Kramer, 2002; Laird, 2001; Mil-Max, 2001; Omastiak, 2002; Page, 2002; Trico, 2001; Yarborough, 2002).  After stamping, parts may be degreased and, in some cases, heat treated (Yarborough, 2002).  Stamped copper-beryllium parts are usually plated.  Connectors typically receive a full plating of nickel and a selective plating of tin or gold (Downing, 2002).  Several stampers reported that they send parts to an outside contractor for plating (Battey, 2002; Yarborough, 2002).
Stamping facilities are described as large, open spaces with very high ceilings and machinery spaced throughout.  Work with copper-beryllium alloy may be performed on different automated stamping machines throughout the plant floor (OSHA-H005C-2006-0870-0345).
Connector manufacturers may either stamp copper-beryllium components in-house or purchase these components from a stamper.  Industry representatives report that virtually no grinding or other machining of copper-beryllium occurs during connector manufacture. Connector assembly is reported to be largely automated.  For example, Meiyu Automation Corporation manufactures automated systems that assemble and package connectors (Downing, 2002).  Soldering of copper-beryllium components can occur during connector assembly, though one source reports the use of conductive adhesives instead (Richter, 2002).
Affected Job Categories
The primary job categories with potential for beryllium exposure in the beryllium alloy products fabrication application group are summarized in Table IV-64.  Other production jobs in this application group were found to have very low exposures (i.e., below an alternative PEL of 0.1 ug/m[3]).  The primary job categories with potential for beryllium exposure include machine operators, tool makers, welding operators, heat-treating operators, inspectors, and packers/shippers.
Table IV-64 -- Job Categories and Major Activities of Workers Potentially Exposed to
Beryllium in the Fabrication Industry
                                 Job Category
                               Major Activities
Chemical Processing Operators
Operate and maintain one or more chemical cleaning and processing operations, such as pickling/cleaning, etching, and plating. Also includes wastewater treatment operators.
Deburring Operators
Set up and operate deburring, shot peening, or other mechanical/abrasive tumbling/grinding/finishing equipment used to clean (i.e., remove residue and imperfections) and increase the product life of fabricated parts.
Assembly Operators
Mechanically assemble finished product components when required, including operation of automated assembly lines. Assembly operations may include riveting, hardware insertion, tapping, threading, brazing, soldering, welding, and other operations.

Exposure Profile
To estimate the exposure profile for workers fabricating beryllium alloy products (i.e., springs, stampings, and connectors), OSHA used exposure information on stamping from five sources: a Brush Wellman case study conducted at four precision stamping companies; a National Institute for Occupational Safety and Health (NIOSH) report on a Michigan spring and stamping company; an Eastern Research Group (ERG) site visit to a precision stamping, forming, and plating establishment; and two presentations, one by Corbett and one by Miller, from the 2007 American Industrial Hygiene Conference and Exposition on follow-up exposure monitoring at one of the stamping facilities in the Brush Wellman case study (Brush Wellman Stamping, 2004; Corbett, 2007; ERG Beryllium Site 6, 2003; Miller, 2007; NIOSH EPHB 263-12a, 2004).  These data are discussed in the subsection on Data Sources for this Fabrication of Beryllium Alloy Products section and represent the best available information for characterizing beryllium exposure in this application group.  No data are available for spring manufacturing.
OSHA also reviewed unpublished exposure data from OSHA's Integrated Management Information System (IMIS) for beryllium.  As noted in earlier sections of this report, IMIS data can be difficult to interpret because the database is not designed to capture information pertaining to worker activities, workplace conditions, engineering controls, personal protective equipment (PPE), and sampling limit of detection (LOD) values (for nondetectable samples). Additionally, information on sampling durations was not available, and when evaluating job descriptions with potential beryllium exposure, it generally was not possible to determine whether beryllium was included in the sample analysis request because of potential workplace exposure to beryllium or because it was part of a routine metal screening.  For these reasons, IMIS information was used as ancillary data in developing the exposure profile for beryllium alloy fabricators.
Data Sources
Brush Wellman -- Precision Stamping Case Study
The Brush Wellman data are part of a case study that was conducted in 2000 at four precision stamping companies that use copper-beryllium alloy (2 percent beryllium).  Exposure results for this study are summarized in the OSHA beryllium docket as Attachment 2.6 - Stamping Facilities Processing Copper Beryllium (OSHA-H005C-2006-0870-0096).  OSHA received the individual exposure results for this study from Brush Wellman and supplemented these data with information provided by industry consultants (Brush Wellman Stamping, 2004; Corbett, 2007; Miller, 2007).  The individual total beryllium exposure results include 183 full-shift personal breathing zone (PBZ) samples collected on workers engaged in various fabrication jobs, including press operation, tool making and repair, chemical processing (e.g., parts washing, bright cleaning, photoetching, racking, plating, wastewater treatment), deburring, heat treating, welding, mechanical assembly, inspection, and packaging and shipping. Samples were analyzed by NIOSH Methods 7102 (Beryllium and Compounds, as Be) or 7300 (Elements by ICP).  The limit of quantitation ranged from 0.02 to 0.005 micrograms (ug) per sample, depending on the laboratory that performed the analysis. Seventy-four percent of the results (136 samples of a total of 183 samples) were nondetectable for beryllium, with sampling LOD concentrations ranging from 0.004 ug/m[3] to 0.02 ug/m[3].  A majority (35 of 47) of the positive results were obtained at one facility (Site 4) (Brush Wellman Stamping, 2004).
Fifty-two PBZ samples were obtained at Site 1, including 10 samples (19 percent) that were positive for beryllium (Brush Wellman Stamping, 2004). Results at Site 1 ranged from 0.0049 ug/m[3] to 0.024 ug/m[3].  At Site 2, 43 PBZ samples were collected on fabrication workers and all the samples were nondetectable.  Sampling LOD concentrations ranged from 0.005 ug/m[3] to 0.019 ug/m[3].  Two of the 33 samples from Site 3 were positive for beryllium, with results of 0.0068 ug/m[3] and 0.014 ug/m[3].  At Site 4, 55 PBZ samples were obtained.  Thirty-five of these were positive for beryllium, with results ranging from 0.0058 ug/m[3] to 0.42 ug/m[3].  Chemical handling and housekeeping practices were in need of significant improvement at this facility.
Although a survey report was not available for the Brush Wellman case study (Brush Wellman Stamping, 2004), OSHA obtained the following information on the stamping facilities through discussions with a beryllium industry consultant involved with the case study (Corbett, 2004):
Site 1 has state-of-the-art processes.  Operations at Sites 1 and 4 include stamping, heat treating, and plating.  No plating is conducted at Sites 2 and 3.  At Site 1, copper, nickel, and gold plating is conducted with an automatic mass plating system.
None of the facilities has beryllium intentional controls (i.e., there are no special work practices, engineering controls, or PPE specifically for beryllium).  Investigators observed the use of compressed air for cleaning at all of these facilities, and advised against it.
Assembly operations can vary by plant and may include soldering and welding.  At Site 1, the parts are tiny ((1/8) inch to (1/4) inch) and assembly is automated.  At Site 4, the parts are 25 to 500 feet long and assembly includes a coil-winding operation.  A small metal roller guide is used to apply tension to the strip parts during coil winding. Investigators noted a visible metallic deposition on the equipment work surface and recommended that the metal roller guide be replaced with a nylon tension roller.
Site 4 is the only facility with detectable beryllium levels in the plating area. Investigators observed the use of local exhaust ventilation (LEV) to control corrosive misting at pickling/cleaning, plating, and photoetching tanks and reported that containment, chemical handling, and housekeeping practices were poor and in need of improvement (Corbett, 2004 and 2007).  Substantial quantities of crystalline materials (chemical residue) were observed on the floor and equipment due to spills and drag-out.  Investigators recommended the following: 1) a thorough wall-to-wall cleaning; 2) a ventilation survey to determine the effectiveness of the exhaust ventilation and the need for modifications/enhancements; 3) no use of compressed air for cleaning; and 4) a re-evaluation of airborne beryllium levels after the first three recommendations have been completed.
Corbett Presentation -- Follow-up Exposure Assessment at Site 4 of the Brush Wellman Case Study
The Corbett presentation reported on follow-up exposure data obtained in 2006 and 2007 during plating and associated support operations at one of the facilities included in Brush Wellman's case study of four precision stamping companies (Site 4) (Corbett, 2007).  After the baseline exposure assessment in 2000, Site 4 made significant improvements in work practices and housekeeping.  Follow-up PBZ samples were obtained in 2006 for pickling/cleaning (nine samples), photoetching (18 samples), plating (21 samples, tank and selective plating), racking (12 samples), deburring (five samples), and wastewater treatment operations (18 samples). Individual sample results were not provided.  The 2006 results indicated that the existing LEV with improved work practices and housekeeping were not sufficient to control beryllium exposures below the California OSHA (Cal/OSHA) permissible exposure limit (PEL) of 0.2 ug/m[3] for pickling/cleaning, photoetching, selective plating, and deburring.  Tank plating, racking, and wastewater treatment were determined to be controlled, with nearly all sample results less than 0.10 ug/m[3].  An engineering control evaluation and follow-up sampling were conducted in 2007.  A series of LEV improvements were made, including the addition of enclosures and improved ductwork and hood designs, and system maintenance. PBZ results in 2007 showed that pickling/cleaning, photoetching, and selective plating were controlled, with all sampling results below 0.1 ug/m[3].  Two deburring PBZ results of 0.29 ug/m[3] and 0.41 ug/m[3] exceeded the Cal/OSHA PEL and were attributed to corn cob deburring (i.e., polishing with dried, granulated corn cob finishing media).  Corbett reported that corn cob deburring needed LEV during the six-hour cycle time and subsequent screening activities.
All of the follow-up samples were analyzed using NIOSH Method 7300 by a laboratory accredited by the American Industrial Hygiene Association (AIHA).  The analytical reporting limit was not reported; however, Method 7300 lists the estimated analytical LOD as 0.005 ug per  filter.  Individual results were provided for the 2007 deburring samples only and ranged from 0.02 ug/m[3] to 0.41 ug/m[3].
Miller Presentation -- Mechanical and Material Handling at the Four Plants in the Brush Wellman Case Study
The Miller presentation described the Brush Wellman case study of four precision stamping companies (Miller, 2007).  Miller provided photographs of some of the manufacturing equipment and products at the stamping facilities and summarized the exposure results for press operators, tool makers, assembly operators, inspectors, and shipping technicians.  As noted, these data were provided to OSHA by Brush Wellman and are incorporated into Attachment 2.6−Stamping Facilities Processing Copper Beryllium in the OSHA Beryllium Docket (OSHA-H005C-2006-0870-0096).
NIOSH -- Strip Stamping Operation (Michigan Spring and Stamping)
The NIOSH data are from an August 21 - 22, 2003, study conducted at Michigan Spring and Stamping in Muskegon, Michigan (NIOSH EPHB 263-12a, 2004). NIOSH researchers collected two PBZ and 10 general area air samples for a copper-beryllium alloy (2 percent beryllium) strip stamping operation.  The air samples were analyzed in accordance with NIOSH Method 7300 (Elements by ICP) modified for hot-block digestion.  The analytical LOD and limits of quantitation were reported to be 0.004 g and 0.01 g of beryllium per sample, respectively.
The PBZ samples included one full-shift sample (450 minutes) with results of 0.021 ug/m[3] and one partial-shift (231 minutes) sample with results of 0.006 ug/m[3].  OSHA used only the full-shift result in the exposure profile for this industry sector.  The general area samples were collected in a variety of locations on and around the stamping machine with results ranging from 0.003 ug/m[3]to 0.058 ug/m[3].
A Finzer - U.S. Baird stamping machine was used to stamp clips for a headlight assembly. Coiled 0.0150-inch thick by 0.3125-inch wide copper-beryllium strips were fed from a spool into the stamping machine at a rate of 10 feet per minute.  The stamping machine cut, perforated, folded, and ejected each finished clip into a cardboard box using compressed air.  A rag suspended by the machine operator across the inside of the collection box was used to catch small chips; process scrap dropped down a chute to another collection box on the floor.  The finished clips were dumped into metal trays.  When three trays were full, the machine operator transported the clips to a heat-treating oven where they were heated at 600°F for one hour.  After the clips cooled, they were dumped into boxes, weighed, packaged, and shipped.  The weighing operation was adjacent to the stamping machine.
At the time of the NIOSH survey, the headlight assembly clips were the only beryllium-containing part produced at Michigan Spring and Stamping, and only one stamping machine was used to produce these parts.  No engineering controls were used with this process.  During cold weather, tempered air is supplied to the area through a cloth duct suspended from the ceiling.  In the summer months, the facility doors and windows are opened.  Pedestal fans were observed in the production area, but the fan nearest the stamping machine was not operating during the NIOSH survey.
The machine operator is responsible for four other machine tools and spends only a portion of the workday at the stamping machine.  The operator also has a desk in the production area where he completes administrative work.
ERG Beryllium Site 6 -- Copper-Beryllium Stamping, Forming, and Plating Facility
The ERG data are from an August 26 - 28, 2003, visit to a copper-beryllium stamping, forming, and plating facility (ERG Beryllium Site 6, 2003).  ERG investigators collected five full-shift PBZ samples for beryllium, all with nondetectable results and sampling LOD concentrations ranging from 0.021 ug/m[3] to 0.024 ug/m[3].  The air samples were analyzed by OSHA Method ID-125G (Metal and Metalloid Particulates in Workplace Atmospheres) using inductively coupled argon plasma-atomic emission spectroscopy (ICAP-AES); the laboratory analytical LOD was 0.02 ug per sample.
ERG Beryllium Site 6 operates one nine-hour shift per day, four and one-half days per week.  The workforce at the site consists of 22 employees, of whom 20 are regarded by the facility as beryllium exposed.  Exact production figures on the number of parts produced are not available because the work is piecework and changes continually; however, the company estimated that it was operating at 60 percent of maximum capacity at the time of the visit. Copper-beryllium parts are not produced on a daily basis for any given machine and might only be produced for a portion of a work shift (ERG Beryllium Site 6, 2003).
Raw materials are typically received as strips or plates of copper-beryllium and stored on site until needed.  Machine operators retrieve the appropriate raw material from storage and load it into the stamping machines.  The operations most commonly associated with stamping are performed with dedicated tooling known as hard tooling and include blanking, drawing, forming, and piercing.  Hard tooling is used to make high-volume parts of a specific configuration.  During production, a die is selected and, depending on the pattern required, may be placed into either the stamping machine or the forming machine, or both.  The stamping machine is used to cut out patterns, whereas the forming machine is used to make bends and depressions in the stamped parts.  Workers manually control the process and place the parts into containers as they are produced.  These parts may then be heat-treated, cleaned, dried, and plated.  Other steps that may be performed include assembly and quality control.  Finished parts are packaged and shipped to customers.  Maintenance of machine tools and dies is also performed on site, but these activities were not observed during the site survey (ERG Beryllium Site 6, 2003).
ERG investigators reported three operations at the site with potential beryllium exposure, including stamping, forming/assembly, and plating.  During the site visit, the stamping operator was observed making 5-centimeter (cm) diameter spring rings at a rate of 80 per minute.  The operator loaded a coil of copper-beryllium strip (1 millimeter thick and 5 cm wide) into the stamping machine and manually activated the stamp with a foot pedal.  As the strip of copper-beryllium was fed into the machine a cutting die was pneumatically activated, causing the die to cut the material.  Stamped parts dropped into a basket underneath the die and were subsequently dumped into a larger container as the basket filled up.  About every 15 minutes the operator reached into the container with his hand and stirred the parts to keep the material level.  During the site visit, only one worker was observed stamping parts, and he remained at the machine for the entire operation.  Copper-beryllium parts were stamped for about two hours, and brass parts were stamped for the remainder of the work shift.  No engineering controls (e.g., LEV) were associated with the stamping machine (ERG Beryllium Site 6, 2003).
Approximately five employees work as forming/assembly operators at ERG Beryllium Site 6.  Parts for forming may be stamped on site from a coil of strip material or obtained from other sources.  Forming/assembly operators obtain the appropriate parts, remove the parts individually from a container and place them into a die fixture, manually activate the press with a foot pedal, remove the parts from the die, check the clearance with a thumbnail, and place the formed parts into a cardboard box. ERG investigators generally observed careful and deliberate work practices and noted frequent hand washing by one worker.  The forming/assembly operation is adjacent to the tooling operation, and compressed air was used for cleaning equipment, parts, and work surfaces (ERG Beryllium Site 6, 2003).
Electroplating takes place in a separate building from stamping and forming (see Figure IV-3).  Beryllium exposure during the chemical processing, including electroplating, of small copper-beryllium parts is associated with 1) beryllium-containing aerosols that may be released from corrosive chemical solutions during processing and 2) beryllium-containing residue (from chemical solutions that have splashed outside process containers) that has dried and subsequently become airborne (Materion SF 104, 2011).
During the site survey, two employees were observed working in the plating area. Copper-beryllium parts produced in the stamping and forming operations are placed in a basket and lowered into a cadmium or nickel plating solution.  When plating is complete, the basket is removed and placed in a spin dryer where the parts are rinsed and spun dry.  The parts are removed from the basket, inspected, packaged, and then transferred to the stamping building for subsequent boxing and shipping.  A complete cycle takes less than 30 minutes.  The plating operator prepares the chemical plating solutions and was observed wearing nitrile gloves, protective outer garments, and work boots.  Workers remained in the plating area for the majority of the work shift, except for the brief amount of time it took to move materials back and forth between buildings.
During the site visit, ERG investigators noted the following regarding baseline conditions (Corbett, 2004; ERG Beryllium Site 6, 2003):
Production workers enter the facility at the start of the shift through a side entrance. Office workers enter through a front entrance that is also open to the public.  No special precautions are used to enter production areas from the offices and vice versa (e.g., production workers entering the offices are not required to wear shoe covers while in the area).
Respiratory protection is not worn in the plant and gloves are not required. Some workers (e.g., the plating workers) were observed using gloves during certain operations, but gloves generally are not worn in the plant.  Plating operators wear protective outer garments to protect against chemical splashes.  Workers do not shower or change clothes at the end of the shift on company premises.
LEV is used at the metal plating tanks and by the machinists that maintain the tools and dies.  The plating tanks are exhausted by slot-type hoods located at the rear of the tanks.  The machinists have moveable LEV ducts at their workstations and are responsible for properly positioning them during tool and die maintenance.
With one notable exception, the facility's general appearance is that of a clean and well cared for operation.  There was no apparent dust accumulation on work surfaces and no visible mist in the air from machining fluids.  There was, however, room for improvement as small metallic chips were visible on the floor and some dry sweeping was observed during the survey.  As the notable exception, plating area housekeeping was poor and in need of improvement; chemical residue was detected on the floor, process equipment, and supplies.

Figure IV-3. ERG Beryllium Site 6 plant layout. Note that the plating operation
for this facility is located in a separate building.
IMIS Data
The IMIS database contains a total of 102 PBZ beryllium samples from June 1978 through September 2008 in the matching standard industrial classification (SIC) codes 3469 (Metal Stamping [NAICS 332116]), 3495 (Light Gauge Springs [NAICS 332612]), and 3678 (Electronic Connector Manufacturing [NAICS 334417]).  These findings are summarized in Table IV-65 and include only two positive results for beryllium (i.e., 2 percent of the sample results are positive).  The two positive results are both in SIC code 3469 and include values of 3.9 ug/m[3] for a painter in December 1995 and 0.01 ug/m[3] for a welder in July 2008.  The available information suggests that the potential for higher exposure levels exists at some facilities, but most establishments fabricating beryllium alloy products have low beryllium exposures.

Table IV-65 -- OSHA IMIS PBZ Total Beryllium Air Sampling Results for Industries Fabricating Beryllium Alloy Products (SIC Codes 3469, 3495 and 3678)
                                      SIC
                                     Code
                                SIC Description
                    No. PBZ Samples with Positive Results/
                           Total No. PBZ Samples[a]
                               Job Descriptions
                       (as listed in the IMIS database)
                                   Range[b]
                                  (μg/m[3])
                                    Mean[b]
                                  (μg/m[3])
                                   Median[b]
                                  (μg/m[3])
                                     3469
Metal Stamping
                                     2/72
                                 (3% positive)
Assembler; Be-Cu line operator; brazing operator; grinder; melter mixed ingots; milling metal; molding machine operator; operator; packer; painter[c]; press operator; production; robot welder; shipping manager; supervisor; team leader; welder; welder and machine operator; welder-foreman; welder-union rep; welding[c]; and nine sample entries with no job descriptions.
                                  0.01 - 3.9
                                     1.96
                                     1.96
                                     3495
Light Gauge Springs
                                     0/10
                                 (0% positive)
Extruder operator; general labor; grinder; press operator; ram operator; and one sample entry with no job description.
                                     None
                                     None
                                     None
                                     3678
Electronic Connector Manufacturing
                                     0/20
                                 (0% positive)
Abrasive blaster; air arcing welder; assistant lead hard solder; band saw grinder; car body sander; CNC machine operator; finisher; grinder; machine operator; machine shop operator; melter/pourer; plate; pour; pourer/melter; spray painter; stocker/checker; supervisor; utility tool worker; W-G operator.
                                     None
                                     None
                                     None
                                     Total

                                     2/102
                                 (2% positive)

                                  0.01 - 3.9
                                     1.96
                                     1.96
[a]	Includes all positive PBZ samples by SIC code, regardless of the job description. Note that for each SIC code, other types of samples (in addition to PBZ samples) may have been obtained, such as area, screening, bulk, or wipe samples.
[b]	The range, mean, and median results are based on positive sample results only. All positive results are included. Sampling limit of detection (LOD) concentrations for nondetectable samples are not available in the IMIS database.
[c]	The positive PBZ beryllium air sampling results in the metal stamping industry include two workers with painter and welding job descriptions.

PBZ: personal breathing zone.

Source: OSHA, 2009

Exposure Profile
OSHA produced an exposure profile for the establishments fabricating beryllium alloy products (i.e., springs, stampings, and connectors) based on full-shift PBZ total beryllium exposure samples available for workers in this industry.  Tables IV-70 through IV-72 in Fabrication of Beryllium Alloy Products Appendix 1 show the exposure profile for all 201 samples and the breakdown of the nondetectable samples by job category and work group.  Seventy percent of the exposure results are nondetectable for beryllium, and 90% are less than 0.1 ug/m[3], indicating that most workers in the beryllium alloy product fabrication industry have low exposures.  OSHA evaluated the exposure data associated with the nine job categories for this industry.  For six of the nine job categories (i.e., machine operators, tool makers, welders, heat treating operators, inspectors, and packers/shippers), all full-shift PBZ exposure results are less than the alternative PEL of 0.1 ug/m3 for beryllium.  Because their exposure levels are consistently low, OSHA anticipates that in the fabrication industry, the exposure levels of the vast majority of workers in these six job categories will not exceed the proposed PEL of 0.2 ug/m[3] or the alternative PEL of 0.1 ug/m[3].
There are 71 samples associated with three job categories that have a higher potential for beryllium exposure: chemical processing operators (primarily plating and bright cleaning), workers deburring fabricated parts (in this case, dry tumbling the parts with corn cob tumbling media), and assembly operators.  The exposure profile for each of these job categories is summarized in Tables IV-66 and IV-67 and discussed below.  These tables summarize the best available full-shift PBZ exposure results for the affected job categories in this industry sector (as discussed in the subsection on Data Sources, within this section on the Fabrication of Beryllium Alloy Products) and report the distribution of the results in relation to the proposed and current PELs for beryllium.  Table IV-72 provides a breakdown of the nondetectable samples by affected job category.
Table IV-66 -- Personal Exposure Profile for Affected Job Categories in the Beryllium Alloy Products Fabrication Industry (NAICS 332612, 332116, 334417)[a,b]
                                 Job Category
                                    No. of
                                    Samples
                            No. of Samples <LOD
                                     Range
                                  (μg/m[3])
                                     Mean
                                  (μg/m[3])
                                    Median
                                  (μg/m[3])
Chemical Processing Operators
                                      43
                                      14
                                 0.004 to 0.42
                                     0.059
                                     0.025
Deburring Operators
                                      14
                                       0
                                 0.02 to 0.41
                                     0.095
                                     0.064
Assembly Operators
                                      14
                                      12
                                 0.005 to 0.12
                                     0.015
                                     0.006
TOTAL
                                      71
                                      26
                                 0.004 to 0.42
                                     0.056
                                     0.025
[a]	Full-shift personal breathing zone (PBZ) lapel-type sample results are based on the actual sample duration. Full-shift means a sampling duration of 360 minutes or longer.
[b]	Nondetectable results are reported as sampling limit of detection (LOD) concentrations.

Source: Brush Wellman Stamping, 2004; Corbett, 2007; ERG Beryllium Site 6, 2003; NIOSH EPHB 263-12a, 2004

Table IV-67 -- Distribution of Full-Shift PBZ Exposure Results for Total Beryllium in the Beryllium Alloy Products Fabrication Industry (NAICS 332612, 332116, 334417)[a,b]
                                 Job Category
                     Number of Results in Range (ug/m[3])
                                     Total

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

Chemical Processing Operators
                                      35
                                     (81%)
                                       6
                                     (14%)
                                       2
                                     (5%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                      43
                                    (100%)
Deburring Operators
                                      11
                                     (79%)
                                       1
                                     (7%)
                                       2
                                     (14%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                      14
                                    (100%)
Assembly Operators
                                      13
                                     (93%)
                                       1
                                     (7%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                      14
                                    (100%)
TOTAL
                                      59
                                     (83%)
                                       8
                                     (11%)
                                       4
                                     (6%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                       0
                                     (0%)
                                      71
                                    (100%)
[a] 	Full-shift personal breathing zone (PBZ) lapel-type sample results are based on the actual sample duration. Full-shift means a sampling duration of 360 minutes or longer.
[b] 	Nondetectable results are reported as sampling limit of detection (LOD) concentrations.

Source: Brush Wellman Stamping, 2004; Corbett, 2007; ERG Beryllium Site 6, 2003; NIOSH EPHB 263-12a, 2004

Chemical Processing Operator
Table IV-66 shows that the exposure profile for chemical processing operators ranges from 0.004 ug/m[3] to 0.42 ug/m[3], with a mean of 0.059 ug/m[3] and a median of 0.025 ug/m[3].  These values are based on 43 full-shift PBZ samples obtained on chemical processing operators at three precision stamping facilities.
Most worker exposures at these three facilities are well below 0.1 ug/m[3]; however, exposures exceeding the proposed PEL (0.2 ug/m[3]) can occur.  Thirty-three percent of the results (14 of 43 PBZ samples) are nondetectable for beryllium, with sampling LOD concentrations ranging from 0.004 ug/m3 to 0.024 ug/m[3].  As shown in Table IV-67, 81 percent of the results (35 samples) are less than 0.1 ug/m[3].  The remainder (14 percent of the results, or six samples) range from 0.1 ug/m[3] to 0.42 ug/m[3]; these results were obtained on chemical processing workers with job descriptions of plating operator and bright cleaning operator at one stamping facility (Site 4) (Brush Wellman Stamping, 2004).
Chemical processing of beryllium alloy parts does not occur at all fabrication facilities. Three of the six establishments (50 percent) for which exposure data are available have chemical processing operations (Brush Wellman Stamping, 2004; ERG Beryllium Site 6, 2003).  One of the establishments (Site 1) electrochemically plates very small parts using a completely enclosed and automated plating system (Brush Wellman Stamping, 2004).  Worker exposures associated with this technology are nondetectable, with sampling LOD concentrations of approximately 0.005 ug/m[3] (0.0048 ug/m[3] to 0.0054 ug/m[3]).  At the other two establishments (Site 4 and ERG Beryllium Site 6) chemical processing takes place in classic open surface tanks equipped with LEV (Brush Wellman Stamping, 2004; ERG Beryllium Site 6, 2003).  For both of these facilities, compressed air was used for cleaning, and poor housekeeping was observed in the chemical processing areas.  At precision stamping Site 4, investigators observed significant amounts of crystallized material (dried chemical residue) on the floor and process equipment. Recommendations were made to 1) conduct a thorough wall-to-wall cleaning of the area; 2) eliminate the use of compressed air; 3) perform a ventilation survey to determine the effectiveness of the LEV, and enhance/modify as necessary; and 4) re-evaluate airborne beryllium levels after the first three recommendations have been completed.
To provide additional insight into the exposure profile for this job category, OSHA also reviewed the IMIS database for exposure information pertaining to the beryllium alloy fabricating industry.  However, the review identified only one entry with a job description representative of chemical processing.  This sample was obtained in October 1985 on a plater at an electronic connector establishment (SIC 3678) and was nondetectable for beryllium.  Although limited, this finding supports the exposure profile, which shows that most chemical processing operators experience minimal beryllium exposure, although exposures can occur at levels up to 0.42 ug/m[3].
Based on the conditions described for this job category in the data sources, OSHA has preliminarily determined that the range of exposures for chemical processing operators in the beryllium alloy products fabrication industry is represented by the range of results summarized in Tables IV-68 and IV-69 (the exposure profile).  The median exposure level for this job category is 0.025 ug/m[3].
Deburring Operator
The deburring exposure profile, summarized in Tables IV-68 and IV-69, is based on 14 PBZ beryllium sample results reported for deburring operators at one precision stamping facility (Site 4) -- the only source of full-shift exposure data available for this job category (Brush Wellman Stamping, 2004).  As shown in Table IV-69, deburring is characterized by a median exposure level of 0.064 ug/m[3], a mean of 0.095 ug/m[3], and a range from 0.02 ug/m[3] to 0.41 ug/m[3].  All of the results for deburring are positive for beryllium (see Table IV-72).  Seventy-nine percent of the exposure results are less than 0.1 ug/m[3] (see Table IV-67).  Seven percent (one result) are equal to 0.1 ug/m[3].  Fourteen percent (two results) of the results fall between 0.2 ug/m[3] and 0.5 ug/m[3] and include values of 0.29 ug/m[3] and 0.41 ug/m[3].  These two highest results are associated with follow-up exposure sampling conducted in 2007 after ventilation improvements were made in nearby wet chemical operations that were thought to be impacting deburring (i.e., a co-location exposure issue).  The follow-up sampling showed that elevated deburring exposures were due to corn cob deburring (in an open tumbling mill) and not to co-location issues associated with the chemical operations.  Industrial hygiene investigators concluded that corn cob deburring required work practice improvements and LEV to reduce exposures to below 0.2 ug/m[3] during the six-hour processing cycle and subsequent screening activities (Corbett, 2007).  Other details are not available.
OSHA also examined the IMIS database for deburring exposure information in SIC codes 3469, 3495, and 3678.  No entries with a job description of deburring were identified.  However, since many techniques are used for deburring including blasting techniques and grinding machines, OSHA also reviewed the database for these job descriptions.  For SIC code 3469, the database includes six PBZ results for workers with a job description of grinder.  These samples were obtained at two establishments (May 1991 and February 2001) and are all nondetectable for beryllium.  For SIC code 3495, there are three nondetectable results for grinders from three establishments (December 1984, October 1985, and June 1990).  And for SIC code 3678, the database includes four nondetectable results for three grinders and one abrasive blasting operator from two establishments (August 1984 and November 1999).  Together, these IMIS findings offer further evidence that exposures for deburring operators are typically low, supporting the exposure levels presented in the exposure profile for this job category.
Based on the descriptive information contained in the data sources, OSHA finds that the results presented in Table IV-67 offer the best available profile of deburring operator exposures in the beryllium alloy products fabrication industry.  The median exposure level for this job category is 0.064 ug/m[3].
Assembly Operator
The exposure profile for assembly operators is summarized in Tables IV-68 and IV-69 and represents the best available exposure data for this job category.  As shown in Table IV-69, the exposure levels for assembly operators range from 0.005 ug/m[3] to 0.12 ug/m[3], with a mean of 0.015 ug/m[3] and a median of 0.006 ug/m[3].  These values represent 14 PBZ total beryllium results for assembly operators at two precision stamping facilities in the Brush Wellman case study (12 results from Site 1 and two results from Site 4) (Brush Wellman Stamping, 2004). Eighty-six percent of the results are nondetectable for beryllium (see Table IV-67), with sampling LOD concentrations ranging from 0.005 ug/m[3] to 0.02 ug/m[3].  Only two of the 14 results are positive for beryllium, and of those, one result slightly exceeds 0.1 ug/m[3] (an assembly operator at precision stamping Site 4 had an exposure result of 0.12 ug/m[3]).  Assembly operations vary depending on the establishment and can include welding and soldering activities.  At stamping Site 4, the assembly operations also include coil winding (i.e., running beryllium alloy strips across a steel roller to apply tension to the strips during winding).  During coil winding, visible metallic dust was generated.  The 0.12 ug/m[3] exposure level reported for an assembly operator at this site is likely associated with the coil-winding activity because investigators made a recommendation to substitute a less mechanically abrasive nylon roller for the steel roller (Corbett, 2004).
To provide additional insight into the exposure profile for this job category, OSHA also examined the IMIS database for relevant exposure information in SIC codes 3469, 3495, and 3678.  From June 1978 to September 2008, the IMIS database contains a total of seven PBZ results for workers with a job description of assembler in the beryllium alloy product fabrication industry (SIC 3469 only).  All the samples are nondetectable for beryllium and were obtained in April 1997 at a manufacturer of shielding equipment for electromagnetic (EMI) and radiofrequency interference (RFI).  Because assembly operations can also include soldering and welding, OSHA reviewed the IMIS database for these job descriptions as well.  For SIC 3469, the database contains 31 results (April 1987 to July 2008) from 16 different establishments. Relevant job descriptions include welder, welding, robot welder, and brazing operator.  Ninety-seven percent of the sampling results for welding are nondetectable for beryllium; one welding sample was positive for beryllium, with a result of 0.01 ug/m[3].  For SIC code 3678, the database contains two nondetectable welding results (August 1984 and June 1991) from two establishments.  The job descriptions for these results are air arcing welder and assistant lead hard solder operator.  No results with relevant welding job descriptions were identified for SIC 3495.  These IMIS findings suggest that exposures for assembly operators are low and lend support to the exposure profile for this job category.
Based on the available information in the data sources, and supported by the IMIS findings from 19 additional facilities, OSHA assumes that the sample results provided by these sources reflect the experience of assembly operators throughout this industry. That is, the exposure profile for assembly operators is representative of assembly operator exposures in the beryllium alloy product fabrication industry.  The median exposure level for this job category is 0.006 ug/m[3].
Technological Feasibility
Most workers in the beryllium alloy product fabrication industry have low beryllium exposures, although the potential for occasional higher exposures exists for chemical processing, deburring, and assembly operators.  These jobs are discussed in greater detail below.  For all other fabrication workers, exposures are less than 0.1 ug/m[3] and additional exposure controls are not required to achieve exposures at or below the proposed PEL of 0.2 ug/m[3] or an alternative PEL of 0.1 ug/m[3].
Chemical Processing Operator
Chemical Processing Operator -- Baseline Controls
Based on the information contained in the data sources described in the subsection on Data Sources for this section on Fabrication of Beryllium Alloy Products, OSHA finds that establishments fabricating beryllium alloy products typically do so without any exposure controls specific for beryllium.  Most establishments do not isolate or segregate beryllium operations (OSHA-H005C-2006-0870-0345); no precautions are taken to enter or leave process areas of the facility; and no special work practice controls are in place.  Workers also do not shower or change clothes on the company premises at the end of their shifts.
Housekeeping programs are in place, but production areas may not be cleaned on a daily basis and housekeeping in plating areas may be poor (Corbett, 2004; OSHA-H005C-2006-0870-0345).  Compressed air and dry sweeping are used for cleaning in some establishments.  In other establishments, employees use vacuums to clean machines at the end of the day or after a production run (OSHA-H005C-2006-0870-0345).  Respiratory protection or Tyvek coveralls might be worn during cleaning activities (OSHA-H005C-2006-0870-0345).
The data source documents indicate that chemical processing areas are typically fitted with LEV, although this ventilation is likely designed to capture other chemical processing hazards (e.g., electroplating and wastewater contaminants rather than beryllium) and may not be well maintained (Brush Wellman Stamping, 2004; Corbett, 2007; Miller, 2007).  Chemical processing operations (such as plating) described by Corbett (2007) use open chemical baths that are likely to have some form of LEV to control corrosive vapors and mists.  The ventilation systems might not be effective, however, and could need improved ductwork and hood designs, as well as enhanced maintenance programs.  This baseline condition was also found in the chromium plating and anodizing industries (analogous operations) where LEV was reported to be the primary exposure control in use for chemical process tanks.  Upon investigation, however, most ventilation systems were found to be in need of repair, increased exhaust rates, enhanced maintenance programs, and other system improvements (OSHA-H054A-2006-0064-2527).
In addition to LEV, employees working with chemical processing operations are likely to wear PPE such as gloves, aprons, and safety glasses to protect against chemical contact and splashing.  Although one facility (Site 1) has a state of the art automatic mass plating system, OSHA does not believe that the majority of establishments use this technology (Brush Wellman Stamping, 2004).
Chemical Processing Operator -- Additional Controls
The exposure profile for chemical processing operators is representative of the beryllium alloy products fabrication industry.  The median exposure level associated with this job category is 0.025 ug/m[3].  Based on the exposure profile, 95 percent of the exposure results for these workers are less than 0.2 ug/m[3], and 80 percent are less than 0.1 ug/m[3].  The  5 percent of chemical processing operators have exposures that exceed 0.2 ug/m[3] will require additional controls to further reduce exposures.  These controls primarily include improvements in LEV, work practices, and housekeeping.  An alternative to these controls, where possible, includes the use of automated self-contained chemical processing systems.  Key benefits of this technology include reduced airborne contaminants and a clean working environment (no dripping and spillage) due to the self-contained design.  One of the precision stamping establishments (Site 1) plated very small parts using a completely enclosed and automated plating system (Brush Wellman Stamping, 2004).  Worker exposures associated with this technology were all nondetectable for beryllium, with a sampling LOD concentration of approximately 0.005 ug/m[3].
At sites without automated self-contained systems, chemical processing operators can be exposed to beryllium when drips and spills dry and leave dust, which is then disturbed.  Control methods that minimize this source will reduce exposures originating from that dust because less dust will be available to become airborne.  This point is demonstrated by a series of air samples obtained at Site 4 of the Brush Wellman case study series.  At this precision stamping facility, compressed air was used for cleaning, and very poor housekeeping was observed in the chemical processing areas.  Specifically, significant amounts of dried chemical residue were observed on the floor and process equipment surfaces.  For several of the chemical processing operations at this facility (e.g., pickling/cleaning, photoetching, plating), workers experienced exposure levels greater than 0.1 ug/m[3].  For pickling/cleaning, some PBZ exposures also exceeded 0.2 ug/m[3].
Follow-up PBZ sampling was conducted twice at stamping facility Site 4.  The first follow-up sampling occurred in 2006 after the plant made significant work practice and housekeeping improvements (not otherwise specified) (Corbett, 2007).  Three of nine follow-up PBZ results for pickling/cleaning were between 0.1 ug/m[3] and 0.2 ug/m[3], while four results exceeded 0.2 ug/m[3].  Among 18 samples for photoetching,  two of the results exceeded 0.2 ug/m[3].  Maximum exposure levels of approximately 0.3 ug/m[3] and 0.4 ug/m[3] were obtained for photoetching and pickling/cleaning operations, respectively.  Furthermore, in the "selective" plating area (not otherwise described), two of the sample results approaching 0.5 ug/m[3] (Corbett, 2007).
Based on the findings of the first (2006) follow-up sampling at stamping facility Site 4, investigators concluded that improved work practices and housekeeping in conjunction with the existing LEV were not sufficient to control exposures below 0.2 ug/m[3], and that exhaust ventilation improvements would also be required.  After the facility implemented LEV improvements (consisting of improved ductwork and hood design/enclosures, additional exhaust airflow, system maintenance and filter change), additional air sampling was performed in 2007. During this second round of follow-up sampling the results were less than 0.1 ug/m[3] for all PBZ samples associated with chemical processing operators (Corbett, 2007).  Table IV-68 summarizes the baseline exposure levels in 2000 (before controls) and the second follow-up air sampling results obtained in 2007 after housekeeping, work practice, and LEV controls were added at precision stamping Site 4 (individual exposure results for chemical processing are not available).
Table IV-68 -- Precision Stamping Facility Site 4 Follow-Up PBZ Total Beryllium Results for Select Chemical Processing Operations after Work Practice, Housekeeping, and Ventilation Improvements
Exposure Group
                          BEFORE
(baseline exposures)
                          AFTER
(additional controls)

                                  No. Samples
                               Range (ug/m[3] )
                                  No. Samples
                               Range (ug/m[3] )
Pickling/Cleaning
                                       5
                                  0.1 to 0.42
                                      14
                                 0.02 to 0.05
Photoetching
                                       5
                                  0.02 to 0.1
                                      15
                                 0.01 to 0.08
Plating
                                       5
                                 0.03 to 0.18
                                      23
                                 0.01 to 0.05
Source: Brush Wellman Stamping, 2004; Corbett, 2007

Based on the follow-up work conducted at Site 4, OSHA finds that exposure levels of less than 0.1 ug/m[3] can be achieved by 1) eliminating work practices that can generate airborne beryllium; 2) improving the frequency and quality of housekeeping (e.g., removing dried beryllium-containing chemical residue that can become airborne from work surfaces); and 3) enhancing existing LEV systems.
When consulting with facilities that use beryllium-containing materials, researchers from the National Jewish Health Division of Environmental and Occupational Health Sciences request that all compressed air lines be removed and that no dry sweeping be conducted in beryllium areas because both of these activities can result in significant worker exposure.  In some cases, a worker's primary exposure to beryllium is due to cleaning his/her work clothes with compressed air.  National Jewish researchers specify that only wet methods and HEPA filter vacuums should be used for cleaning in beryllium work areas (OSHA-H005C-2006-0870-0155).
OSHA consistently requires that compressed air not be used for cleaning work surfaces contaminated with hazardous metals (e.g., Lead, 29 CFR 1910.1025(h)(2)(i), Inorganic arsenic, 29 CFR 1910.1018(k)(2)) because it can disperse these materials into the workplace.  In some cases, the use of compressed air for cleaning is allowed only when used in conjunction with a ventilation system designed to capture the dust cloud created by the compressed air (e.g., Cadmium, 29 CFR 1910.1027(k)(6), Hexavalent chromium, 29 CFR 1910.1026(j)(2)(iii)).
Yoshida et al. (1997) reported that workplace cleaning and ventilation improvements contributed to a significant reduction in general area beryllium levels in a copper-beryllium rolling and drawing establishment.  Like beryllium alloy product fabrication plants, rolling and drawing operations typically include chemical processing such as pickling.  Airborne beryllium levels decreased 84 percent, from a geometric mean of 0.19 ug/m[3] to a geometric mean of 0.03 ug/m[3], through a combination of improved LEV and workplace cleaning to remove settled/deposited particulate matter.
A primary beryllium producer has developed recommended work practices and control measures for the chemical processing of small copper-beryllium alloy parts (Materion SF 104, 2011).  These recommendations are summarized in Table IV-69 and include effective LEV, workplace cleanliness, safe work practices for servicing and maintaining LEV systems, and employee training and exposure monitoring.
Table IV-69 -- Safety Practices for Chemical Processing of Small Copper-Beryllium Parts
Install effective LEV to minimize the escape of mists and vapors associated with corrosive processes using acids and bases.
Do not discharge the exhaust air from a recirculating air cleaning device into the workplace due to the potential for exposure if there is a failure of the filtration system.
Contain chemical solutions used in the cleaning and processing of copper-beryllium to prevent splashing onto floor areas, external structures, and operators' clothing.
Clean up chemical solutions that splash outside process containers as soon as possible and do not allow these solutions to dry, because they may carry beryllium-containing particulate that can later become airborne or attach to clothing or shoes.
Thoroughly clean contaminated equipment prior to performing service and maintenance. Beryllium-containing residue can settle on the internal surfaces of ventilation enclosures and equipment structures and must be removed, kept wet, or otherwise be controlled during service and maintenance activities to minimize the generation of airborne particles.
Develop detailed procedures for safely maintaining ventilation systems and process equipment. These procedures should provide detailed information regarding the use of wet methods, vacuuming, ventilation, and appropriate PPE to prevent exposure to beryllium.
Train all process operators and maintenance personnel in the established procedures prior to performing service or maintenance activities.
Characterize worker exposure, including the use of air monitoring, for those operations where a potential for beryllium exposure exists.
Source: Materion SF 104, 2011

Both OSHA and the U.S. Environmental Protection Agency (EPA) recognize the importance of maintaining ventilation systems for plating operations.  Poor maintenance can greatly diminish the effectiveness of the ventilation such that it operates at a fraction of its design specifications (OSHA-H054A-2006-0064-2527).  Other factors for effective ventilation of plating operations include (OSHA-H054A-2006-0064-1364):
Doubling the exhaust flow rate if the bath temperature is increased by 15° to 20°C.
Limiting the height of the exhaust over the surface of the bath to 30 percent of the distance to the cathode rod.
Using a lid that encompasses the bath and the exhaust to create a shorter distance between the source and the exhaust at a constant bath width.
Isolating plating operations from door openings and transport paths where drafts can arise.
Lifting and lowering product slowly through the exhaust zone.
Additionally, in a study of control technology for plating and cleaning operations in the metal plating industry, NIOSH concluded that covers are effective in limiting emissions from plating tanks (NIOSH 85-102, 1984).  For example, around one tank normally uncovered and located in a region of strong cross-drafts, the average tank concentration of hexavalent chromium was substantially reduced (20-fold drop) when a cover was placed over the tank.  For operations involving smaller tanks and pieces, the use of partial covers can increase the effectiveness of the exhaust ventilation while allowing viewing of and access to the pieces being plated (NIOSH 85-102, 1984).
Chemical Processing Operator -- Conclusion
Based on the best available data described in the exposure profile, the median exposure level associated with this job category is 0.025 ug/m[3], and beryllium exposure levels of 0.2 ug/m[3] or less have already been achieved for the vast majority (95 percent) of the chemical processing operators in this industry.  This control level has been achieved through the use of LEV, work procedures that minimize spillage, and housekeeping methods that minimize the opportunity for beryllium dust to become airborne.  OSHA estimates that the remaining workers in this job category (the 5 percent that are not already protected by these methods) will require additional controls to reach this level.  Additional controls could include upgrading or installing and maintaining ventilation systems, eliminating the use of compressed air, and improving housekeeping.
These additional controls have proven effective in the past.  A 2007 follow-up industrial hygiene study at a precision stamping facility showed that the beryllium exposure of chemical processing operators was reduced to less than 0.1 ug/m[3] by the combined use of several control measures (Corbett, 2007).  These measures included improved work practices (such as eliminating the use of compressed air), thorough and frequent housekeeping, and enhanced LEV for chemical processing tanks (those that initially did not meet the established performance criteria specified for the operation).  Previously, in 2000, before the control measures were put in place, chemical processing operators performing the same jobs experienced beryllium exposure levels up to 0.42 ug/m[3].
In the event that further control measures are required, employers can protect chemical processing operators by installing completely enclosed and automated chemical processing systems (such as for plating), which will also reduce operator exposures.  At one precision stamping facility (Site 1), workers plating copper-beryllium parts with an automated mass plating system had nondetectable beryllium exposures, with sampling LOD concentrations of approximately 0.005 ug/m[3] (Brush Wellman Stamping, 2004).  Based on the available information, OSHA preliminarily concludes that an alternative PEL of 0.1 ug/m[3] and proposed PEL of 0.2 ug/m[3] are feasible for chemical processing operators.
Deburring Operator
Deburring Operator -- Baseline Controls
Deburring operators in this industry use the same range of deburring processes for product finishing tasks used by other metal product fabrication industries, including manual filing, brushing with wire or other stiff material, abrasive action, and vibratory and media barrel finishing (Corbett, 2007; Fennel et al., 2006).  Data source documents suggest that these processes are ventilated with LEV, but air flow rates might not meet ACGIH recommendations (ACGIH, 2010; Corbett, 2007).
Deburring Operator -- Additional Controls
The exposure profile for deburring operators is based on 14 full-shift PBZ samples obtained at one precision stamping facility (Site 4) (Brush Wellman Stamping, 2004).  The median exposure level for this job category is 0.064 ug/m[3].  Based on the exposure profile presented in Tables IV-68 and IV-69, 86 percent of the samples are less than 0.2 ug/m[3], and 79 percent are below the alternative PEL of 0.1 ug/m[3].  The 14 percent of deburring operator exposures (2 samples) that exceed 0.2 ug/m[3] would require additional controls to further reduce exposures.  In the exposure profile, the elevated exposures for this job category (0.29 ug/m[3] and 0.41 ug/m[3]) are associated with a precision stamping facility (Site 4) deburring operation, which involves dry tumbling small copper-beryllium alloy products with corn cob media in an small open tumbling mill (less than 24-inch diameter barrel) (Corbett, 2007).  During a follow-up industrial hygiene survey at Site 4, the investigators, who were highly experienced with beryllium process controls, concluded that to reduce exposures, this deburring operation required 1) work practice improvements and 2) the addition of LEV during both the six-hour cycle time and subsequent screening activities.  The case study does not include an update on this operation, however, and OSHA does not have access to exposure data to support the effectiveness of these recommended additional controls for deburring.
In the absence of additional information on the effectiveness of the recommended controls, OSHA considered evidence that well-designed and properly maintained LEV can control exposures of other mechanical surface finishing operations to levels of less than 0.1 ug/m[3].  OSHA also considered options for using more fully enclosed or wet deburring process equipment as well as reducing the need for deburring (Dayton Progress Corporation, 2003; Hedrick, 2004).  For the former (LEV), OSHA reviewed the exposure reduction associated with LEV improvements for a related finishing operation (buffing) at the same facility (Site 4), where mechanical buffing is one of the steps in the selective plating operation (Brush Wellman Stamping, 2004; Corbett, 2007).
Buffing and deburring are two forms of mechanical surface finishing work (Fennell et al., 2006).  Both are capable of removing oxides and small imperfections from metal alloy products through mild abrasion or friction applied to the product surface.  Although not identical processes, both buffing (at Site 4, a bench-mounted electric buffing machine with buffing/polishing wheels) and deburring (in a small, open tumbling mill with plant-based media such as corn husks) involve gentle, moderate-to-high-energy action on the product surfaces; therefore, for both processes, the source and nature of the beryllium particles is also similar. Additionally, at Site 4, before exposure control upgrades, both buffing and deburring were associated with similar levels of worker exposure (0.5 ug/m[3] in the buffing area, compared to up to 0.41 ug/m3 for deburring, as noted above) (Corbett, 2007).  Both buffing machines and small tumbling mills (up to 24 inches in diameter) have recommended ventilation design specifications provided by ACGIH (2010).
Initially, investigators conducting an industrial hygiene survey in the Site 4 selective plating/buffing area determined that elevated PBZ sampling results of approximately 0.5 ug/m[3] were associated with the operation.  Further investigation led them to focus their attention specifically on buffing as a source of exposure requiring control.  Improved ductwork and hood designs were implemented following the ACGIH industrial ventilation manual guidelines for buffing and polishing operations (ACGIH, 2010 [Figure VS-80-30]).  Design improvements coupled with ventilation filter changes and LEV system maintenance increased the exhaust flow rate by 31 percent, from 633 cubic feet per minute (cfm) to 830 cfm.  After the improvements were implemented, seven follow-up PBZ samples for beryllium were all less than 0.10 ug/m[3] (Corbett, 2007).  This case demonstrates that a well-maintained exhaust ventilation system designed to ACGIH's recommended specifications can effectively control beryllium exposure during mechanical surface finishing.
ACGIH (2010) provides air exhaust specifications for nine different sizes in each of two tumbling mill shape configurations.  OSHA preliminarily finds that, because tumbling/vibrating media mills are typically more automated (largely an unattended process) and can be more fully enclosed (Royson, 2011; Vibra Finish, 2011; ACGIH, 2010 [Figure VS-80-03]) than manual buffing wheels, the ACGIH ventilation design guidelines for tumbling mills will be at least as effective (and likely more so) for preventing the release of beryllium particles as the ventilation design for the buffing ventilation system. In some cases (e.g., low speed, low-energy tumbling), shop-built housing connected to an appropriate ventilation system will be sufficient.
The tumbling equipment used at Site 4 was uncontrolled and involved a final screening step (Corbett, 2007).  Tumbling equipment is commercially available with various levels of control options (Gibson, 2011; Royson, 2011; Vibra Finish, 2011).  The more aggressive the anticipated media, the more tightly enclosed the tumbler and its housing must be to achieve good exposure control.  Some tumbling mills (e.g., those that incorporate an abrasive blast feature) are already designed with sealed external housing, pneumatic locking doors, and exhaust ventilation (Gibson, 2011).  These principles of enclosure design can be applied to any tumbling mill. OSHA believes well-designed housing and exhaust ventilation that meet ACGIH specifications will substantially reduce exposures compared to the open unventilated process.
Some deburring operators perform a final screening step, which involves dumping batches of beryllium alloy shapes into receptacles and separating items from particulate matter. This final screening step generates airborne dust (Kent, 2012; Russell Finex, 2009).  Where beryllium alloy workers also perform sieving to separate alloy product from tumbler media, the ventilated housing will need to enclose the sieving screen(s) as well, or the screening process will require separate ventilation. Housing fitted for exhaust ventilation is commercially available for media mills and associated separating/drying equipment (Royson, 2011) and for tumble blasting equipment with media-separating capability (Gibson, 2011).  Additionally, the pharmaceutical industry uses screening equipment and certain commercially available, enclosed, ventilated pharmaceutical screening equipment (e.g., designed for separating pills from extremely high-potency dust) that has been proven to limit dust concentrations to less than 1 ug/m[3] (Russell Finex, 2009).  At Site 4, screen separation of beryllium alloy product from tumbling media occurs for just a moment or two at the end of a six-hour cycle (360 minutes). Using such equipment, even if the screening process were performed for a full five minutes during each 360-minute tumbling cycle, the time-weighted average dust emission from the screening process would be less than 0.014 ug/m[3] over the cycle.
Tumbling mills designed to be watertight for wet deburring processes are also a commercially available option (Royson, 2011).  In this case, media is separated from the product by rinsing, and dust release is prevented by work practices that minimize splashing and dripping of dust-laden process water and that require spills to be cleaned up immediately while still wet.
Another option involves minimizing the need for deburring processes by adjusting stamping machinery to optimize punch-to-die clearance to decrease burr height while increasing tool life (Dayton Progress Corporation, 2003; Hedrick, 2004).
Deburring Operator -- Conclusion
The median exposure level for deburring operators is 0.064 ug/m[3].  Based on the exposure profile for this group of workers, exposure levels at or below the proposed PEL of 0.2 ug/m[3] have already been achieved for 86 percent of the deburring operators (79 percent are also already below the alternative PEL of 0.1 ug/m[3]).  For those workers who experience higher exposures (14 percent), additional controls include work practice and LEV improvements (Corbett, 2007).  For a related mechanical surface finishing operation at Site 4 (manual buffing), initial exposure levels of 0.5 ug/m[3] were reduced to less than 0.1 ug/m[3] after the LEV system was upgraded to meet ACGIH recommendations.  OSHA observes that the deburring operation, which is an automated activity in open equipment with exposure levels up to 0.41 ug/m[3], will be at least as effectively controlled by LEV that meets the ACGIH recommendations for tumbling mills (ACGIH, 2010 [Figure VS-80-03]).  Using these methods, OSHA preliminarily concludes that the exposure of all deburring operators can be reduced to levels of less than or equal to the proposed PEL of 0.2 ug/m[3] and also less than an alternative PEL of 0.1 ug/m[3].  In the event that deburring operator exposures continue to exceed the proposed PEL of 0.2 ug/m[3], enclosed and ventilated deburring equipment, fully enclosed screening equipment, and wet process deburring equipment are also available.  OSHA therefore preliminarily concludes that an alternative PEL of 0.1 ug/m[3] and the proposed PEL of 0.2 ug/m[3] are feasible for this job category.
Assembly Operator
Assembly Operator -- Baseline Controls
Assembly operators perform a wide range of activities, including soldering and welding, forming equipment, manual processes, and automated processes (Brush Wellman Stamping, 2004; Corbett, 2007; Miller, 2007).  Little evidence suggests that these activities contribute to the beryllium exposure of assembly operators. Although exposures exceeding 0.1 ug/m[3] can occur where the process abrades the beryllium alloy (Corbett, 2004), 13 of the 14 samples for this job category were lower than 0.1 ug/m[3], indicating that this is not a typical concern.  Compressed air is used for clearing work pieces and work areas (ERG Beryllium Site 6, 2003; Corbett, 2004).
Assembly Operator -- Additional Controls
Fourteen PBZ samples were obtained for assembly operators at two precision stamping facilities (12 at Site 1 and two at Site 4) (Brush Wellman Stamping, 2004).  Of these, none exceeded 0.2 ug/m[3] and only one sample (7 percent) resulted in an exposure that was 0.1 ug/m[3] or greater (an assembly operator at precision stamping facility Site 4 experienced an exposure level of 0.12 ug/m[3]).
Assembly operations vary depending on the establishment and can include welding and soldering activities.  At stamping facility Site 4, the assembly operations also include coil winding (i.e., running beryllium alloy strips across a steel roller to apply tension to the strips during winding).  During coil winding, friction is generated from the metal strip sliding over the roller.  This activity results in the generation of a small amount of metallic dust that gets deposited on the equipment surface.  The 0.12 ug/m[3] exposure level reported for an assembly operator at this site is likely associated with the coil-winding activity.  As a result of this observation, investigators made a recommendation to substitute a less mechanically abrasive nylon roller for the steel roller (i.e., to eliminate the metal-to-metal abrasion from occurring). OSHA does not have access to exposure data to support the effectiveness of this additional control.  OSHA estimates that exposure levels of less than 0.1 ug/m[3] can be achieved by an engineering change to the coil-winding activity if the change reduces the generation of visible metallic dust.  Therefore, OSHA concurs with the investigators' determination that this source of exposure will be eliminated by switching to a nylon roller.  Nylon is softer than beryllium alloy and will not abrade the alloy metal.  Additionally, although the number of variables involved with resuspension of dust is large (Caplan, 1993), routine cleaning of equipment surfaces (with wet methods or vacuums equipped with HEPA filtration) to remove deposited dust may help to further reduce worker exposures, because deposited dust can be a secondary source of worker exposure if it gets resuspended in the air.  Variables that affect dust resuspension include the dust and surface properties and the resuspension action, such as air velocity, vibration, foot traffic, and powered and nonpowered wheel traffic (Caplan, 1993).
Yoshida et al. (1997) reported that workplace cleaning to remove settled dust, in conjunction with LEV improvements (not otherwise specified), reduced ambient (general area) levels of beryllium by 84 percent in a copper-beryllium rolling and drawing facility, reducing the total beryllium geometric mean from 0.19 ug/m[3] to 0.03 ug/m[3].  These data show that improved engineering controls and a thorough cleaning contribute to reduced ambient levels of beryllium in a manufacturing environment.  Although this establishment is not a fabrication facility, the sources of beryllium dust were similar to those associated with a fabrication facility (i.e., both use mechanical processes to shape beryllium alloys).  Similarly, at a primary beryllium production plant, ambient air samples collected in an area noted to be "very dirty" were reduced by 93 and 89 percent, respectively, after the areas were cleaned (Couch, 2006).  Prior to cleaning, the results of two general area samples obtained in the powder ball mill area of the plant were 12.7 ug/m[3] and 14 ug/m[3]. After cleaning, two follow-up ambient air samples from the same areas were 0.9 ug/m[3] and 1.5 ug/m[3], respectively.  Although some source(s) of exposure remained, this study demonstrates the extent to which poor versus improved housekeeping can influence worker exposure.  Depending on the plant area, primary beryllium production can involve materials containing 2 to 50 times more beryllium in the metal than is present in the beryllium alloys used in fabricating plants.  The dust generated (and exposure levels created by this dust) would be correspondingly lower in a fabrication facility.  If poor housekeeping contributed to assembly operator exposure results, even a modest 20-percent reduction in exposure due to improved housekeeping would bring the highest assembly operator exposure level (0.12 ug/m[3]) down to a level less than 0.1 ug/m[3] (0.096 ug/m[3]).
Assembly Operator -- Conclusion
The median exposure level for this job category is 0.006 ug/m[3].  No results exceeded 0.2 ug/m[3] and OSHA preliminarily concludes that no additional controls are required to achieve the proposed PEL of 0.2 ug/m3 for assembly operators.  This conclusion is supported by the exposure profile for this job category, which shows that 93 percent of the measurements on assembly operators are less than 0.1 ug/m[3].  The remaining workers in this job category (7 percent) can experience exposure levels between 0.1 ug/m[3] and 0.2 ug/m[3].
In the event that elevated exposures do arise, additional controls are available.  For example, at precision stamping Site 4, a simple, straightforward engineering modification to an assembly coil-winding operation (i.e., substituting a steel roller with a nylon roller that will not abrade the beryllium alloy) will eliminate the source of exposure.  Furthermore, routine cleaning of equipment surfaces to remove deposited dust (i.e., housekeeping) will help to further reduce worker exposures, because deposited dust can be a secondary source of worker exposure if it gets resuspended in the air.  Any required engineering modifications together with routine cleaning are estimated to reduce the exposures of all assembly operators to below 0.1 ug/m[3].
The available exposure data show that all assembly operators are exposed below the proposed PEL of 0.2 ug/m[3], with the highest exposure being slightly above 0.1 ug/m[3].  This information suggests that implementation of additional controls can reduce exposures below 0.1 ug/m[3].  Therefore, OSHA preliminarily concludes that an alternative PEL of 0.1 ug/m[3] and the proposed PEL of 0.2 ug/m3 are feasible for assembly operators.
References
ACGIH, 2010. Sections 6.2 (Enclosing Hoods -- Introduction) and 6.3 (Totally Enclosing Hoods), Chapter 5 (Design Issues -- Systems), Chapter 13 (Specific Operations), and Section 8.9 (Selection of Air Filtration Equipment), Industrial Ventilation: A Manual of Recommended Practice for Design, 27th Edition. American Conference of Governmental Industrial Hygienists. Cincinnati, Ohio.
Acxess Spring, 2006. Properties of Common Spring Materials and Compression, Extension, and Torsion Spring Design Information. Acxess Spring. Riverside, California. Available online at: http://www.acxesspring.com/main.html. Accessed December 04, 2006.