OSHA preliminarily estimates that each facility will need one enclosed, sealed leak-tight decontamination chamber.  The cabinet requires an additional 100 cfm of ventilation capacity. At $30 per cfm (including $5 per cfm for make-up air), the additional ventilation capacity is estimated to cost $3,000 (100 x $30).  From discussion with manufacturers, operating and maintenance costs are estimated to be 15 percent of the initial capital cost, for an annual operating and maintenance cost of $450 (0.15 x $3,000) resulting in a total annualized cost per facility of $802. Since there is only one facility in this application group and only one cabinet is needed to control exposures for decontamination workers, the above per-facility cost of $802 represents the total annualized engineering control costs for this process.
Mix/Makeup Workers
      Makeup workers prepare and charge (load) furnaces with alloy melting mixes.  This activity involves using material-handling equipment, such as industrial lift trucks, and transferring bulk material between charge tubs and furnaces.  Based on discussions with manufacturers, OSHA preliminarily estimates that each facility will need four enclosed cabs for industrial trucks located at that facility in order to isolate the workers from the source of possible beryllium exposures.  Based on manufacturer quotes, the capital cost per industrial truck enclosure is estimated to be $13,000, with an annualized cost of $1,524.  Operating and maintenance costs are estimated to be 15 percent of the initial capital cost, for an annual operating and maintenance cost of $1,950.  The total annualized cost per truck enclosure is therefore $3,474, yielding an annualized, per-facility cost of $13,896 (4 x $3,474).  Since there is only one facility in this application group, the above per-facility cost of $13,896 represents the total engineering control costs for this process.
Scrap Reclamation Workers
      Scrap reclamation workers receive high-beryllium-content scrap chips that are then degreased, magnetically screened to remove iron, sorted, inspected, and containerized for reuse internally.  Based on discussions with manufacturers, OSHA preliminarily estimates that each facility will need four enclosed cabs for industrial trucks located at that facility in order to isolate the workers from the source of possible beryllium exposures.  The total annualized cost of four enclosed cabs per facility is $13,896 (as explained above in the Mix/Makeup subsection).
      Based on the findings of the technological feasibility analysis, OSHA estimates that each facility will also need three automatic material samplers with glove boxes.  Automatic material samplers have a capital cost of $12,500 and require an additional 150 cfm of ventilation capacity (Werra, 2005).  At $30 per cfm (including $5 per cfm for make-up air), the additional ventilation capacity is estimated to cost $4,500 (150 x $30), resulting in a total capital cost per sampler of $17,000 ($12,500 + $4,500) and a per facility cost of $51,000 (3 x 17,000).  Operating and maintenance costs are estimated to be 15 percent of the initial capital cost for an annual per-facility cost of $7,650 (0.15 x $51,000).
      The cost of each enclosed glove box is $4,000 with a total capital cost per facility of $12,000 (3 x $4,000) (Werra, 2005). An additional 100 cfm of ventilation capacity per device is required at $30 per cfm (including $5 per cfm for make-up air) for a cost of $3,000 (100 x $30) and a per facility cost of $9,000 (3 x $3,000), resulting in total capital cost per facility of $21,000 ($12,000 + $9,000). Operating and maintenance costs per facility are estimated to be 15 percent for an annual cost of $3,150 (0.15 x $21,000).  The total per-facility capital costs of three solid material samplers with glove boxes is $72,000 ($21,000 + $51,000) and the total maintenance costs per facility is $10,800 ($7,650 + $3,150), resulting in an annualized per facility cost of $19,241.  The total annualized cost of the engineering controls for this process is $33,137.

Production Equipment, Furnace, and Tool Maintenance Workers
      The process of maintaining the furnace and associated tools requires engineering controls for jackhammers along with enhanced work practices and training.  Depending on the type and size of the furnace, the refractory lining may either be hydraulically extracted or removed using manual demolition methods (i.e., jackhammers).  For example, large induction furnace linings (that are about eight feet long and five feet in diameter) are removed by hydraulically extracting the lining using a "pusher."  The lining is then transferred to the furnace rebuild room where maintenance workers (furnace rebuilders) equipped with appropriate personal protective equipment and respirators use jackhammers to break the lining into smaller pieces.
      Making a jackhammer water-capable (equipping it with a controlled water spray at the chisel point) to wet down dust potentially containing beryllium, is estimated to cost $200 (NIOSH, 2003).  An industry source has estimated that the average facility will require five jackhammers (Corbett, 2005), for a total cost of $1,000 (5 x $200) and an annualized cost of $117. The O&M cost, estimated to be 15 percent of the initial cost, would be $150 (0.15 x $1,000) for the five jackhammers, for a total annualized cost of $267 ($117 + $150) per facility.  With one facility represented in this application group, the total annualized cost of $267 represents the total cost of engineering controls for this application-group process.

Machining Operations
      Machining at Materion in Elmore, Ohio involves the use of metal forming equipment to machine and/or fabricate low- and high-content beryllium-containing parts or shapes. The Agency has preliminarily estimated that controlling beryllium exposures for a machinist will require an additional 675 cfm of ventilation capacity. With a $30 cost per additional cfm of exhaust ventilation (including $5 per cfm for make-up air) the capital cost is $20,250 per machine (675 x $30).  OSHA preliminarily estimates that each machine will be used by two workers ((ERG, 2003a; ERG, 2004), resulting in a per-worker capital cost of $10,125 ($20,250/2) and an annualized cost of $1,187. The O&M cost per worker, estimated to be 15 percent of the initial cost, is $1,519 (0.15 x $10,125), resulting in a total per-worker annualized cost of $2,706.  With an estimated 95 workers in this application-group process, the total annualized cost of engineering controls is $257,042 (95 x $2,706).

Welders
      Welding is discussed in detail in the welding application group later in this cost chapter.  Engineering controls for welders at the Materion plant differ from the general welding application group so are separately broken out here.  The Agency has estimated, based on the findings in the Technological Feasibility chapter of this PEA, that welding operations in this application group will also require one chemical dip tank per facility.  Based on information received from Materion, OSHA estimates that a chemical dip tank costs $70,000 for an annualized, per-establishment cost of $8,206 (Kent, 2005).  The O&M cost per chemical dip tank, estimated to be 15 percent of the initial cost, is $10,500 (0.15 x $70,000), resulting in a total per-facility annualized cost of $18,706.  With only one facility represented in this application group, the per-establishment cost of $18,706 represents the total annualized engineering control costs for this application-group process.

Impact Grinders
      During impact grinding, vacuum-cast billets are prepared for machining, loaded into lathes, and milled into chips. The beryllium chips are vacuum-conveyed into collection containers and subsequently loaded into an impact-grinding (powder-generating) operation. During impact grinding, beryllium chips are injected into a high-speed air stream and sprayed against a beryllium target to generate beryllium powder.  Based on information provided by an industry consultant, OSHA has determined that impact grinding would require the installation of one additional pharmaceutical-quality high-containment isolator (Kent, 2005). The annualized cost per facility to install such a system is $123,292.  With only one facility represented in this application group, the per-establishment cost of $123,292 represents the total annualized engineering control costs for this application-group process.

Compact Loading and Cisterning
	During compact loading, workers load and cap vertically oriented cylindrical graphite dies with beryllium powder.  The dies are placed in a tall, fully enclosed loading hood equipped with back and side-draft exhaust ventilation, and are top-loaded with beryllium.  A worker will observe the loading process in an effort to prevent overloading of the die and a subsequent powder spill.  During loading, the beryllium powder is vibratorily packed (shaken and compacted as much as possible). The loaded die is capped with a graphite plug, removed from the loading hood, and transferred to a below-ground sintering furnace.
      	During the sintering process, the powder is consolidated into a billet in an inert environment using heat and pressure.  The finished billet is removed from the die (pushed out with a hydraulic ram) in a die-stripping hood that is equipped with back-draft exhaust ventilation.  Worker exposure is primarily associated with two activities --  installing and removing containers of powder from both the compact loading hood and the die loading area.  Based on the findings of the technological feasibility analysis, OSHA has determined that controlling worker exposure to beryllium during the compact loading and sintering process requires installation of a remote viewing system so that workers do not need to enter the die-loading hood. The closed-circuit remote TV installation is estimated to cost $2,000 with an annualized cost of $234 (Kent, 2005). The annual operating and maintenance costs are estimated to be 15 percent of the initial equipment cost, or $300 (0.15 x $2,000), for a total annualized cost of $534. Based on information from the same industry consultant, the Agency estimates that a facility would need to install one additional pharmaceutical-quality high-containment isolator with an annualized cost of $123,292 per facility (Kent, 2005).  With only one facility represented in this application group, the total annualized cost for engineering control for this application-group process is $123,826.

Near Net Shape (NNS) Fabrication
      NNS fabrication is a process of fabricating beryllium metal parts that minimizes the amount of beryllium scrap generated during this process.  Beryllium powder is loaded into dies and consolidated into preformed shapes with one or more techniques involving heat and/or pressure (cold and hot isostatic pressing).  After consolidation, the dies are unloaded using different techniques depending on the type of die (rubber, steel, or copper).  In order to protect workers performing NNS fabrication by reducing beryllium exposures to levels at or below the proposed PEL, the Agency estimates, based on information provided by an industry consultant, that a facility would need to install one additional pharmaceutical-quality high-containment isolator with an annualized cost of $123,292 per facility (Kent, 2005). With only one facility represented in this application group, the per-establishment cost of $123,292 represents the total annualized engineering control costs for this application-group process.

Beryllium Sulfate Salt Processing
      Beryllium sulfate salt processing is a process that produces high-purity beryllium sulfate salts by dissolving beryllium hydroxide in sulfuric acid, filtering the solution to remove insoluble materials/impurities, and then concentrating the resulting filtrate through evaporation/cooling.  This process is almost entirely enclosed and isolated from workers (i.e., chemical additions and mixing is automated and enclosed) except at the process entry and exit points.  Based on information from the Director of Environmental, Health and Safety at Brush Wellman Inc., OSHA estimates that Brush Wellman's facility (the only affected facility) would need to install one additional pharmaceutical-quality high-containment isolator in order to reduce beryllium exposures to workers performing beryllium sulfate salt processing activities to levels at or below the proposed PEL at an estimated annualized cost of $123,292 per facility (Kent, 2005).  With only one facility represented in this application group, the per-establishment cost of $123,292 represents the total annualized engineering control costs for this application-group process.

Alloy Arc Furnace Workers
      The alloy arc furnace operations produce an ingot of four percent copper-beryllium master alloy that is subsequently re-melted and diluted with other metals to form alloys with a reduced percentage of beryllium that are cast, hot rolled, and otherwise fabricated (NIOSH, 1972). Furnace operators weigh raw copper, transfer 55-gallon drums of beryllium hydroxide into the calciner (kiln burner) feed station, wash empty drums in the calciner feed station, charge and tap the furnace, remove and recycle dross (oxides and other contaminants that form a scum at the surface of the molten metal), add furnace electrodes, and cast ingots (Corbett, 2006; Kent et al., 2001).
      Based on the findings of the technological feasibility analysis, two enclosed sampling devices and enhanced work practices with better training and supervision are needed to reduce beryllium exposures to the proposed PEL for workers performing alloy arc furnace operations.  The capital cost of an enclosed sampling device is $16,500 (Werra, 2005) with a total per-facility cost of $33,000 for two devices (2 x $16,500).  Each enclosed sampling device requires an additional 100 cfm of local exhaust ventilation at a cost of $30 per additional cfm (including $5 per cfm for make-up air) of ventilation for a total of $3,000 (100 x $30) per device and $6,000 (2 x $3,000) per facility for a total capital cost of $39,000 ($33,000 + $6,000).  The annual operating and maintenance costs are estimated to be 15 percent of the initial equipment cost, or $5,850 (0.15 x $39,000), for a total annualized cost of $10,422. The cost of enhanced work practices -- estimated as time required for training -- is an annualized, per-worker cost of $190.  With one facility and an estimated 30 affected workers in this application-group process, the total annualized cost of engineering controls and enhanced work practices is $16,123.

Alloy Induction Furnace Workers
      The alloy induction furnace process produces beryllium alloys containing a concentration of beryllium of 0.1 percent to 2 percent.  Two workers operate each furnace: a deck worker and a floor worker.  Tasks conducted by the deck worker with potential exposure include charging, rubbing, skimming, degassing, and changing full dross barrels.  Tasks performed by the floor worker include setting up the mold; heating, placing, and cleaning the tundish (the reservoir in the top part of a mold into which molten metal is poured); and pouring the furnace (transferring the molten metal from the furnace into molds).
      Based on the findings of the technological feasibility analysis, OSHA has estimated that increased local exhaust ventilation (LEV) and enhanced work practices are necessary to reduce beryllium exposures at or below the proposed PEL.  The Agency has determined that four LEV units are needed per facility to control beryllium exposures to workers performing these types of operations. In order to meet the requirements of the proposed rule, ERG estimates that each LEV will need to supply 1,500 cfm of exhaust ventilation at a cost of $30 per additional cfm (including $5 per cfm for make-up air) for a total capital cost of $180,000 for four LEV units (1,500 x 4 x $30).  Operating and maintenance costs are estimated to be 15 percent of the initial equipment for an annual operating and maintenance cost of $27,000 (0.15 x $180,000) resulting in a total annualized cost of $48,101.  The Agency estimates that enhanced work practice control will cost $190 per worker.  With one facility and an estimated 13 affected workers in this application-group process, the total annualized cost of engineering controls is $50,572.

Vacuum Casting
      Vacuum casting is a furnace operation designed to produce feedstock (vacuum-cast billets) for powder-making operations (NMAB, 1989).  Beryllium feed material (e.g., reclaimed chips and scrap) is vacuum-melted inside a tilt-pour induction furnace and poured into graphite molds to produce round billets that are approximately three to four feet in length.  The billets are manually cleaned (pressure washed) and prepared inside an exhaust hood and then transferred to the powder-making operation.
      There are two engineering controls needed for the vacuum casting process based on the findings of the technological feasibility analysis: redesigning the charge make-up (filling and weighing) process and performing a task analysis.  Redesigning the charge make-up process has a capital cost of $117,500 and an integration cost of $100,000, for a total annualized cost of $25,498 (Bernero, 2005). Redesigning the charge make-up process also has an annual 15 percent operating and maintenance cost, for an annual cost of $17,625 (0.15 x $117,500), resulting in a total annualized cost of $43,123 ($25,498 + $17,625).
      The task analysis is intended to identify work methods associated with the vacuum casting process (e.g., filling, weighing, and rubbing/skimming) that contribute most to worker exposure, and result in the implementation of work-practice improvements to further reduce worker exposure.  OSHA preliminarily estimates that improved work practices will not affect worker productivity and will not require additional time to complete tasks relative to the current work practices.  The task analysis study requires labor from three individuals: 8 hours by a certified industrial hygienist at $125 dollars an hour or $1,000 (8 x $125), 24 hours by a ventilation engineer at $125 an hour for a total of $3,000 (24 x $125), and four hours of a supervisor's time at $30 an hour for a total of  $120 (4 x $30) -- yielding an estimated total cost of $4,120 ($1,000 + $3,000 + $120), and an annualized cost of $483.  With one affected establishment in this application group, the total engineering control costs for this application-group process are $43,606.

Atomization
      Atomization is a furnace process where the final product is aluminum-beryllium or beryllium powder.  For the reasons explained in the technological feasibility analysis, this process requires two types of engineering controls to limit beryllium exposure: a one-time task analysis and a pharmaceutical-quality high containment isolator.  The task analysis is intended to identify work methods associated with atomization (e.g., charge make-up, rubbing/skimming, and make/break connections) that contribute most to worker exposure and result in the implementation of work-practice improvements to further reduce worker exposure.  OSHA preliminarily estimates that improved work practices will not affect worker productivity and will not require additional time to complete tasks relative to the current work practices.  Task analysis costs are the same as in vacuum casting and explained in the subsection above, and have an estimated annualized per-facility cost of $483.  OSHA has estimated that a facility will need to install one additional pharmaceutical-quality high-containment isolator in order to reduce worker exposures to levels at or below the PEL and that the isolator has a per-facility annualized cost of $123,292.  With one affected establishment in this application group, the total annualized engineering control costs for this application-group process are $123,775.

Beryllium Oxide Furnace Workers
      In this process, wet-screened beryllium sulfate salt is calcined in hearth furnaces to produce beryllium oxide powders.  The furnaces have top-ventilated, full enclosures at the loading/unloading point that consist of removable metal wall panels.  To load the furnaces, operators remove one of the front wall panels from the enclosure, empty drums of wet beryllium sulfate salt into large rectangular refractory containers with a lift truck equipped with a barrel grabber, and then load the refractory containers into the furnace chamber. The beryllium sulfate salt gets fired in the furnace for several days and is transformed into a fluidized bed of beryllium oxide powder.
      OSHA has estimated that, as discussed in the technological feasibility analysis, the engineering controls required for beryllium oxide furnaces in order to reduce worker exposures to beryllium to levels at or below the proposed PEL are a task analysis, enhanced LEV, and the installation of one additional pharmaceutical-quality high containment isolator (Bernero, 2005). As discussed above in the vacuum casting section, the task analysis, which is intended to identify work methods associated with beryllium oxide furnace processes that contribute most to worker exposure and result in the implementation of work-practice improvements to reduce worker exposure, has an annual cost of $4,120 and an annualized cost of $483.  As with the vacuum casting task analysis, OSHA preliminarily estimates that improved work practices will not affect worker productivity or require additional time to complete tasks relative to the current work practices.
      Based on discussions with industry experts, enhanced LEV requires 1,500 cfm of additional exhaust ventilation capacity at a cost of $30 per additional cfm (including $5 per cfm for make-up air) for a capital cost of $45,000 (1,500 x $30).  With an operating and maintenance cost of 15 percent of capital costs, annual operating and maintenance cost would be $6,750 (.15 x $45,000).  The annualized total cost for these items is $12,025 per facility.  Based on information provided by an industry consultant, OSHA has estimated that a facility will need to install one additional pharmaceutical-quality high-containment isolator in order to reduce worker exposures to levels below the PEL and that this isolator has a per-facility annualized cost of $123,292 (Kent, 2005).  With one affected establishment in this application group, the total annualized engineering control costs for this application-group process are $135,800.

      Table V-2 below summarizes the unit capital costs and operating and maintenance costs for each affected process in beryllium production.  For the one firm engaged in beryllium manufacturing in NAICS 331419: Primary Smelting and Refining of Nonferrous Metals, the entire annualized cost of complying with engineering controls for each of the above processes is estimated to be $1,188,758.

Beryllium Oxide, Ceramics & Composites

	Beryllium oxide ceramics and beryllium oxide-metal matrix composites are used to manufacture materials with unique physical, thermal, and electrical properties for use in electronic equipment in the aerospace and other industries (Parsonage, 2011).  In examining engineering control costs for this application group, the Agency notes that not all jobs occur at all establishments covered in every six-digit NAICS industry.  In particular, only a small number of facilities that work with beryllium oxide perform powder-handling operations or operate kilns. Additionally, a number of beryllium oxide-using establishments are not assigned any control costs because they are estimated to perform only operations where workers are assembling finished parts made of materials that contain beryllium but are not machining parts or performing any other operations that would produce beryllium-containing dust and thus.
      According to the technological feasibility report and analysis presented in Chapter IV: Technological Feasibility in this PEA, a variety of engineering, ventilation, and work practice adjustments are needed to control beryllium exposures and ensure that workers are not exposed to beryllium at levels above the proposed PEL for the following processes:
      Material Preparation
      Forming Press Operations
      Forming-Extruding Operations
      Kiln Operations

      Machine Operations
      Metallization

Material Preparation
      In the material preparation process, beryllium oxide powder is refined through a series of dry and wet processing steps in order to create materials with the properties necessary for subsequent forming/shaping operations.  The material preparation operator receives bulk beryllium oxide powder in drums and transfers the material -- automatically or manually -- to mixing equipment where an aqueous suspension of beryllium oxide, binder additives, and water is prepared.  Next, the operator uses mixing equipment to blend the ingredients to create a homogeneous slurry.  The beryllium oxide material is shaped using a pressed-powder process; the material preparation operator then finishes by pumping slurry to a spray dryer that disperses the material under a high pressure stream of air for rapid drying inside an enclosed chamber. Based on the findings of the technological feasibility analysis, OSHA estimates that, in order to reduce worker's beryllium exposures to levels at or below the proposed PEL, facilities engaged in the material preparation process require review and enhancement of operating and cleaning procedures along with installation of one additional pharmaceutical-quality high-containment isolator per facility.
      Review and enhancement of operating and cleaning procedures require a one-time investment of 40 hours by an engineer with a wage rate of $54.70 an hour (Industrial Engineers, SOC: 17-2112), for a total cost of $2,188 (40 x $54.70), and an annualized cost of $256.  Annual training in these revised procedures requires four hours of training at $22.16 an hour (Production Occupations, SOC: 51-0000) for two workers per facility, resulting in an annual cost of $177 (2 x 4 x $22.16).  The final annualized cost per facility is $434 ($256 + $177), and with an estimated 2 facilities, this results in a total cost of $868.
      The installation of one pharmaceutical-quality high-containment isolator per facility is needed for multiple process steps  This capital cost is made up of a filling and weighing system ($117,500), a powder transfer system ($20,000), and an integration cost for new technology ($100,000) for a total capital cost of $237,500 (Bernero, 2005).  This total, annualized over a ten-year period at a three percent discount rate, is $27,842. The Agency also applied an annual operating and maintenance cost of 15 percent (the same as for beryllium production O&M) for the filling and weighing system and the powder transfer system, resulting in $20,625 (0.15 x $137,500) for annual operating and maintenance costs.  The total per-unit annualized cost is then $48,467 ($27,842 + $20,625).  With an estimated 2 facilities needing these controls, the total annualized cost for installing these isolators is $96,934, resulting in a total annualized engineering control cost for this application-group process of $97,802.

Forming - Pressing
	Prepared beryllium oxide materials are used in forming operations to shape a variety of small specialty ceramics products (ranging in size from a few millimeters to several inches).  The forming processes include a variety of techniques common to the ceramics industry.  For example, forming operators typically mold beryllium oxide using one of the following processes:
1. Dry (powder) pressing: a process in which forming operators oversee equipment that compresses spray dried, low-moisture beryllium oxide powder material into a die with a ram.
2. Isostatic pressing: an advanced powder compaction process in which hydrostatic forming equipment applies even pressure on all sides of a liquid-tight rubber die containing beryllium oxide powder.
3. Hot pressing: a process whereby beryllium oxide powder is simultaneously subjected to high temperature and high pressure in heated dies.
4. Extrusion: a conventional mechanical process in which moist, paste-like beryllium oxide material is forced through a shaped orifice or die.
5. Tape casting: a technique in which the beryllium oxide paste is extruded into a long bendable strip that can then be rolled up for further processing.

   The Agency has estimated, based on the findings of the technological feasibility analysis, that forming press operations require engineering controls both to modify presses in order to reduce the dust released and to enclose presses.  Two presses per establishment are estimated to need modification in order to reduce dust and therefore beryllium exposures.  ERG estimates that the cost per establishment for modifying a press includes 150 hours of an industrial engineer's time at an hourly wage of $54.70 (Production Occupations, SOC: 51-0000) for a total cost of $8,205 (150 x $54.70) per press.  This gives a total cost for two presses of $16,409 (2 x $8,205).  The total cost, annualized over ten years at a three percent discount rate, is estimated to be $1,924 per facility. With one facility estimated to have workers performing this process who are at risk of beryllium exposures above the PEL, the total annualized cost of these controls is $1,924.
      OSHA determined that three presses per establishment require an enclosure.  Each press requires a capital investment of $12,500 for enclosures. This results in a cost per facility for enclosing three presses of $37,500 (3 x $12,500), or an annualized cost of $4,396 (Frigon, 2005).  Each enclosure is also estimated to require an additional 200 cfm in ventilation capacity, which ERG estimated at $13.18 per additional cfm (ERG, 2013).  This yields a total cost per facility of $7,908 (200 x 3 x $13.18), or an annualized cost of $927.  O&M expenses for the new ventilation system are the standard $3.92 per additional cfm.  The total O&M cost for the additional ventilation capacity is therefore $2,350 (200 x 3 x $3.92).  The total annualized cost per facility for the three enclosures is $7,673 ($4,396 + $927 + $2,350).  OSHA estimates that one facility in the application-group process will need these controls for this process, resulting in a total annualized cost for these enclosures of $7,673.  The total of all controls for this application group process is $9,597.

Forming - Extruding
	In this process, workers force beryllium oxide material that is of a paste-like consistency through a die in order to form the product.  The operator manually cuts and removes the product from the press as it is being extruded and places it on a product transfer cart for subsequent firing or other processing.
      Based on exposures for extruders described in Chapter IV of this PEA, OSHA has estimated that the forming-extruding process requires engineering controls for ventilation enhancements and ventilation enclosure in order to reduce worker's exposure to beryllium to levels at or below the proposed PEL.  While industry representatives did not specify the cost of a ventilation enclosure, ERG's industry experts estimate that a typical enclosure would cost $5,000 and that the enhanced LEV would require an additional 500 cfm of ventilation capacity at $13.18 per cfm for a capital cost of $6,588 (500 x $13.18) -- yielding a total capital cost of $11,588 ($5,000 + $6,588) and an annualized cost of $1,359.  There is an O&M cost of $3.92 per additional cfm for the ventilation, for a total O&M cost of $1,958 (500 x $3.92).  The total annualized cost is $3,317 per facility.  With one facility estimated to have workers performing this process who are at risk of exposure to beryllium at levels above the PEL, the total cost for this application-group process is $3,317.

Kiln Operations
      The kiln operator ensures that the kiln is working properly and that material is fired properly.  These employees load firing carts containing beryllium oxide ceramic parts into the kilns and remove the carts once the firing process is complete.  OSHA has estimated, based on the findings of the technological feasibility analysis, that kiln operations will require both increased ventilation controls and HEPA vacuums for cleaning in order to reduce worker exposures to beryllium to levels below the proposed PEL.
       OSHA estimates that these facilities have, on average, three kilns.  Industry experts indicated that a custom design will need to be developed for the LEV in this setting and that costs for this study are $30,000.  In addition, installation of the ventilation enhancement requires 1,500 cfm of additional ventilation capacity per kiln at $13.18 per cfm for a cost of $19,765 per kiln and $59,294 (3 x $19,765) per facility, resulting in a total capital cost of approximately $89,294 ($30,000 + $59,294).  OSHA includes an annual operating and maintenance cost of $3.92 per additional cfm of ventilation, for a total annual operating and maintenance cost of $5,875 (1,500 x $3.92) per kiln, and approximately $17,624 (3 x $5,875) per facility.  The total annualized cost per facility is $28,092.  The Agency preliminarily estimates that there are two facilities where workers are engaged in this process and where beryllium exposures are above the PEL.  Therefore, the total annualized cost for kiln LEV is $56,185.
      OSHA has preliminarily estimated that an additional one percent of a kiln operator's time will be spent operating HEPA vacuums to clean contaminated saggers and reduce worker exposures to beryllium. Based on a kiln operator wage rate of $21.61 per hour (Production Occupations, SOC: 51-9051), total labor costs for this activity as a result of the requirements of the proposed rule are $432 per worker annually (2,000 hours annually x 0.01 x $21.61). With an estimated 20 workers at risk of exposure to beryllium, the total cost for additional time spent cleaning is $8,646.  For the two establishments and 20 workers affected, the total cost of engineering controls for this application-group process is $64,830.

Machining Operations
      Machining operators receive sintered beryllium oxide shapes in the form of blocks that must be shaped to size.  For larger-scale machining jobs, machining operators might oversee automated electrostatic discharge machines. These enclosed machines use jigs that operate under water to convert large ceramic blocks into finished shapes.  In other cases, machining operators receive the ceramics in "near-net-shapes" that require only small-scale machining to meet final product specifications.  Such machining processes include grinding, lapping, drilling, laser cutting/scribing, trimming, diamond dicing, water cutting, sanding, abrasive cutting, polishing, chemical etching, and other surface abrasion techniques.
      Based on the technological feasibility analysis in Chapter IV: Section 4 of this PEA, many machining facilities have controls currently installed but may need to improve the efficiency of these controls.  OSHA has estimated that these machining operations will require improved enclosures, including additional LEV capacity, for three units per establishment, on average.  The Agency estimates that each enclosure modification will take 24 hours of a senior engineer's time at an hourly rate of $54.70 (Industrial Engineers, SOC: 17-2112, in NAICS industries: 327100, 334200, 334300, 334400, 334500, and 336300), for a cost of $1,313 (24 x $54.70).  Each modification will also need an additional $1,000 for materials.  Finally, enhanced LEV per unit is estimated to require an additional 788 cfm of ventilation capacity, at a cost of $13.18 per cfm, for a capital cost of $10,386 (788 x $13.18) -- yielding a total capital cost per enclosure for improvements and additional LEV capacity of $12,689 ($1,000+ $1,313 + $10,386).  An annual operating and maintenance cost of $3.92 per additional cfm of ventilation capacity is calculated to add an annual cost of $9,253 per facility (788 x 3 x $3.92), resulting in a total annualized cost of $13,715 per facility.  OSHA's exposure profile in Chapter IV indicates that exposure levels of 37.44 percent of machining operators are above the PEL.  OSHA preliminarily estimates that this exposure profile is distributed uniformly throughout the establishments in this process group such that 34 (Table V-3 shows just 33 due to rounding) facilities of the 90 establishments will need to improve their enclosures to protect machining operators, resulting in a total annualized cost of $462,105 for machining operations.  Machining operators, as well as metallization operators below, work in several NAICS industries within this application group.  Total costs were allocated across these different NAICS industries by their share of establishments within this application group, and are so presented in Table V-3 below.

Metallization workers
      Some beryllium oxide ceramics are metallized, which involves plating or brazing with metal to permit the joining of the ceramic part to other pieces of equipment.  OSHA has estimated that each facility where metallization processes are performed will require a one-time review of ventilation controls by an industrial engineer to ensure that controls are working properly in order to achieve the proposed PEL.  OSHA estimated that the review requires eight hours of an industrial engineer's time at an hourly wage rate of $54.70 (Industrial Engineers, SOC: 17-2112, in NAICS industries: 327100, 334200, 334300, 334400, 334500, 336300), for a cost per facility of $438 (8 x $54.70), and an annualized cost of $51.30.  With 28 establishments estimated to have workers performing this process with risk of exposure above the proposed PEL, the total annualized cost for this application-group process is $1,411.  Similar to machining operators discussed above, metallization operators work in several NAICS industries within this application group.  Total costs are allocated across these different NAICS industries by their share of establishments within this application group, and are so presented in Table V-3 below.

      The total control costs for the beryllium oxide, ceramics & composites application group is $639,061.  The cost by NAICS is presented in Table V-3, below.

Nonferrous Foundries
      Nonferrous foundries produce a variety of cast products using alloyed and unalloyed copper, aluminum, and other metals that at some foundries include castings of copper-beryllium and, to a lesser extent, aluminum-beryllium.  Employees can have exposures above the proposed PEL while performing several job tasks in foundries.  The job categories with potential for beryllium exposure in foundries are as follows:
         Molder
         Material handler
         Furnace operator
         Pouring operator
         Shakeout operator
         Grinding and finishing operator
         Abrasive blasting operator
         Maintenance operator
      Several of the controls are specific to workers in sand-casting foundries while others apply only to non-sand-casting operations (e.g., permanent mold casting).  OSHA preliminarily estimates that no foundries specialize in casting alloys containing beryllium, meaning that the controls -- mainly improved local exhaust ventilation -- necessary to reduce worker exposures to beryllium to levels at or below the proposed PEL would not need to be used one hundred percent of the time.  Facilities in this application group that are affected by the proposed rulemaking would only need to operate the additional LEV while processing beryllium.  ERG's industry expert determined that the foundries in question commonly cast a number of other non-beryllium alloys (e.g., bronze), and estimated that work involving beryllium will be performed 20 percent of the time.  This estimate is also reflected in the control costs through lower operating and maintenance costs for additional ventilation capacity and in the number of hours workers are estimated to be working with beryllium.  For example, in other application groups, OSHA estimated that operating and maintenance costs would normally be $3.92 per cfm of additional ventilation capacity.  For foundries, operating and maintenance costs are estimated to be 20 percent of that amount, or $0.78 (0.20 x $3.92) per cfm of additional ventilation capacity.  Where the cost estimates associated with processes in this application group use a percentage of work hours needed to complete the task involving beryllium, the Agency has estimated that the typical worker, working an estimated 2,000 hours per year, would only spend 400 hours (20 percent of 2,000 hours) a year performing beryllium-related work.
      Several job categories within this application group work in different NAICS industries.  Total costs for each job category were allocated across these different NAICS industries by their share of establishments within this application group, and are so presented in Table V-4 below.

Molder
      There are two processes for molding: sand casting and non-sand casting.  Some engineering controls needed for these two processes differ due to the nature of the respective processes.  In sand-casting foundries where non-permanent molds are used, molders typically prepare molds by shaping granular media (sand or similar substances) and a binder into shapes that will form molten metal but will disintegrate to the original granular structure when casting is complete.  In some facilities, that media is a beryllium-containing sand.  Reducing beryllium exposures associated with sand cast molding can be accomplished by installing covered or enclosed systems for transporting sand through or near the molding area.  In sand-casting foundries, this would take the form of conveyor belt enclosures.
      The Agency's technical feasibility analysis indicates that a conveyor enclosure would enclose and maintain sand-mixing or recycling equipment under exhaust ventilation.  An ERG industry expert examined a previous ERG  study (ERG 2013) and determined that a conveyer enclosure requires 1,225 cfm of exhaust ventilation at $13.18 per cfm, for an initial capital investment of $16,141 (1,225 x $13.18).  The associated annual maintenance cost is $0.78 per cfm, for a total annual operating and maintenance cost of $956 (1,225 x $0.78).  The total annualized cost is $2,852.  OSHA estimates that each machine for molding processes that is improved as a result of the proposed rulemaking is used by four employees, which results in an annualized cost of $713 ($2,852/4) per worker.  OSHA preliminarily estimates that there are 128 workers performing molding activities who may be exposed to beryllium at levels at or above the PEL.  Therefore, the total annualized cost for enclosing conveyors in sand-casting foundries is $91,323.
      The non-sand-casting foundries use permanent (reusable) molds or dies, requiring little daily preparation other than assembly and cleaning (brushing, sweeping, scraping, minor grinding, and applying mold release agents).  Beryllium-containing residue (in the form of oxides and base metal) can build up on the molds during the casting process, and molders may be exposed to beryllium as they remove this material.  Non-sand-casting foundries need the following additional controls in order to reduce beryllium exposure: wet wiping of molds and working surfaces, use of HEPA vacuums to clean molds, and additional LEV with movable exhaust hoods.  For the first type of controls for non-sand-casting foundries, ERG has estimated that wet wiping would take two percent, or 8 hours, of a worker's time spent working with beryllium-containing materials each year.  The hourly wage for foundry mold and core makers is $20.66 (Foundry Mold and Coremakers, SOC: 51-4071).  As a result, the annual cost per worker for wet wiping is estimated to be $165.28 (8 x $20.66).  OSHA estimates that there are 369 affected workers in this application-group process, resulting in a total annual cost for wet wiping of $60,974.
      The second category of new controls (and costs) for non-sand-casting foundries is use of HEPA vacuums.  The housekeeping provisions for this standard (under ancillary provisions) will require such vacuums, and the purchase of this equipment is costed there. Therefore, for this engineering control, there are no purchase costs reported in this section.  Additional vacuuming is estimated to take one percent of a worker's time each year.  Using the estimated hourly wage presented above and total hours worked per year, the resulting annual cost per worker of additional vacuuming is $83 (400 x 0.01 x $20.70).  Using the above estimate of 369 affected workers, the total annual cost for additional vacuuming is $30,487.
      The third category of engineering controls for non-sand-casting foundries is increased LEV for their existing movable exhaust hoods.  Each hood requires an additional 600 cfm of ventilation capacity (ACGIH, 2001) with a cost of $13.18 per cfm, resulting in a capital cost per hood of $7,906 (600 x $13.18).  The operating and maintenance costs are $0.78 per cfm, for an annual cost per hood of $468 (600 x $0.78).  The total annualized cost per establishment is $1,397.  OSHA estimates that each movable exhaust hood is used by two employees, resulting in a per-worker annualized cost of $698.  With 369 affected workers, the total annualized cost for increased ventilation capacity for movable exhaust hoods is $257,642.
      The final engineering control cost for molders is the same for both types of foundries.  OSHA estimates that both sand and non-sand-casting foundries will need to increase general ventilation primarily to protect molders. This general ventilation upgrade is needed to reduce possible cross contamination from other workers.  An upgrade will be needed for an average area of 10,000 square feet per establishment.  ERG's industry experts estimate a cost of $5.00 per square foot to improve general ventilation (often through the introduction of make-up air). The cost per establishment is then $50,000 (10,000 x $5), which, when annualized at 3 percent over 10 years, gives an annual per-establishment cost of $5,862.  With an estimated 97 sand and non-sand foundry establishments that will need to perform general ventilation upgrades, the total annualized cost is $568,568.  The total annualized cost of the controls identified in this section for this application-group process, for both sand-casting and non-sand-casting foundries, is $1,008,995 ($91,323 + $60,974 + $30,487 + $257,642 + $568,568).

Material Handler
      Material handlers transport materials and castings between workstations.  These employees need sealed cabs on machinery in order to reduce beryllium exposures to meet the proposed PEL.  Based on discussions with vendors, the initial capital cost of sealing a cab is $13,000, including the installation of retrofitted cabs with filtered ventilation systems (ERG, 2004).  OSHA estimates that the annual operating and maintenance costs are 15 percent of the initial non-annualized capital costs, or $1,950 (0.15 x $13,000).  Total annualized cost per cab is $3,474, which, based on the Agency's estimate that each machine is used by two workers, gives a per-worker annualized cost of $1,737 ($3,474/2).
      Using a sealed cab will slow the material handling process.  OSHA preliminarily estimates that using a sealed cab will require additional time equal to 2.5 percent of a worker's total hours as a material handler.  Given an average work year of 400 hours as a material handler and an average wage of $20.93 (Production Occupations, SOC: 53-7051), the productivity cost per worker incurred as a result of using sealed machine cabs is $209 (400 hours x 0.025 x $20.93).  The total annualized cost per employee for a sealed cab is $1,946 ($1,737 + $209).  OSHA preliminarily estimates that each of the 97 facilities projected to be affected by the proposed rule in this application group employs one material handler, resulting in a total annualized cost of engineering controls of $188,794.

Furnace Operation
      Furnace operators charge (load) furnaces with new and/or reused metal (foundry scrap returns), supervise the melting process, sparge molten metal in the furnace (i.e., bubble gas through molten metal to promote mixing), and skim dross (use a scoop/wand to remove oxides and other contaminants that form a scum at the surface of the molten metal).  OSHA has preliminarily estimated that these employees require enhanced furnace ventilation in order to be adequately protected against beryllium exposures above the proposed PEL.  The Agency estimates that one furnace per facility will require 1,750 cfm of additional ventilation (ACGIH, 2001). At a cost of $13.18 per cfm of additional ventilation capacity, the initial capital cost is $23,059 per furnace (1,750 x $13.18). The annual operating and maintenance cost is $0.78 per cfm of additional ventilation capacity (20 percent of the usual $3.92 O&M cost) for a total cost of $1,371 (1,750 x $0.78).  Total annualized cost per facility is $4,074.  With 79 affected facilities, this results in a total cost of $321,846.
      As described in Chapter IV of this PEA, local exhaust ventilation is needed for dross receptacles and furnace tools.  A ventilated dross collection tray integrates fume control with furnace-mounted slot hood exhaust ventilation.  The dross receptacle requires 1,600 cfm of additional ventilation capacity. With an initial cost of $16.47 (1.25 x $13.18) per cfm (including a 25 percent premium for needed custom design), the capital cost for ventilating dross receptacles is $26,353 (1,600 x $16.47).  Operating costs are estimated to be $0.78 per cfm of additional ventilation capacity for a total annual operating and maintenance cost of $1,253 (1,600 x $0.78).  With one dross receptacle per facility, the total annualized cost per facility is $4,343, and with 79 affected facilities, the total annualized cost is $343,097.
      The proposed rulemaking will also require furnace operators to vacuum the work area using HEPA filtration vacuums.  OSHA has estimated that facilities already have the necessary equipment but that employing this equipment will require additional time for vacuuming equal to one percent of a worker's time.  With an hourly wage of $23.16 (Production Occupations, SOC: 51-4051) and an estimated 400 hours spent working with beryllium-containing materials per year, the annual cost per worker for additional time spent vacuuming is $93 (0.01 x 400 x $23.16).  With an estimated 94 affected workers, the total annual cost is $8,742 (94 x $93).
      In order to reduce beryllium exposures to below the proposed PEL, furnace operators are also estimated to need pressurized air supplied to the operator booths, which requires additional ventilation capacity.  The operator booth requires 1,500 cfm (ERG, 2004) of additional ventilation at a cost of $13.18 per cfm, for a capital cost of $19,765 per unit (1,500 x $13.18).  The annual operating and maintenance cost is estimated to be $0.78 per cfm of additional ventilation capacity for a total of $1,175 per unit (1,500 x $0.78).  OSHA estimates that facilities have, on average, one operator booth, which results in a per-facility annualized cost of $3,492.  OSHA estimates that there are 79 affected facilities, yielding a total annualized cost of $275,868 (79 x $3,492).  Combining the costs of these required engineering controls results in a total annualized cost for furnace operations in this application group of $952,459.

Pouring Operator
      Pouring operators supervise the transfer of molten metal from the furnace (and any intermediary ladles) into molds. Beryllium fumes can enter a pouring operator's breathing zone as the fumes rise off molten metal in open ladles, tundishes, and molds. Beryllium fumes and dust released from the furnace area can be a substantial source of exposure for pouring operators.	LEV is the primary control measure for pouring that involves toxic metals, such as beryllium (and lead), and exhaust ventilation systems are available in the market for numerous types of equipment used in the pouring area.  However, this equipment is currently not consistently used properly in foundries.  Special mobile ventilation hoods that pouring operators can attach to ladles or crucibles are needed to achieve the PEL. These hoods connect to flexible ducts extending from overhead trunks and are used to remove fumes during transport and pouring.  OSHA preliminarily estimates that facilities have these ventilation hoods but that they currently are not providing ventilation adequate to protect workers.
      The ventilation for pouring operators requires 350 cfm of additional ventilation capacity (CCMA, 2000) at a cost of $13.18 per cfm, resulting in an initial capital cost of $4,612 (350 x $13.18). The operating and maintenance cost for the additional ventilation capacity is estimated to be $0.78 per cfm for a total annual operating and maintenance cost of $274 (350 x $0.78).  With one pouring operator per facility, total annualized cost of ventilation to reduce beryllium exposure for these workers to levels at or below the proposed PEL is $815 per establishment.  With an estimated 58 affected facilities, the total annualized cost for pouring operators is $47,421 (58 x $815).

Shakeout Operator
      Shakeout operators separate molds from castings.  If sand molds or sand cores are used in the casting process, these operators use vibrating equipment to dislodge the sand from around the formed metal pieces.  Under some casting conditions, beryllium oxide can form on the casting surface.  In these cases, sand can be contaminated with residual beryllium oxide from contact with the cast metal surface.  OSHA preliminarily estimates that shakeout operators need improved LEV in order to reduce beryllium exposures to levels at or below the proposed PEL.  The Agency estimates that firms will need 1,013 cfm of additional ventilation capacity in order to adequately protect these workers.  At a cost of $13.18 per cfm the total capital cost is $13,348 per unit (1,013 x $13.18). Operating and maintenance costs are $0.78 per cfm for a total O&M annual cost of $793 (1,013 x $0.78). The Agency estimates an average of one shakeout operator per facility, which results in a total annualized cost per facility of $2,358.  With an estimated 25 affected establishments, the total annualized engineering control costs for this application-group process are $58,956 (25 x $2,358).

Grinding and Finishing Operator
      Grinding/finishing operators perform any required steps needed to finish castings (except cleaning steps performed by shakeout operators and abrasive blasting operators).  They may use saws to remove imperfections left from the casting process or to trim the casting to specification. These workers also perform grinding to remove minor casting surface defects. They finish castings by polishing, sanding, or grinding pieces to customer specifications.  Based on the findings of the technological feasibility analysis in Chapter IV of this PEA, OSHA estimates that facilities with grinding and finishing operations will need to improve ventilation enclosures in order to meet the proposed beryllium PEL.
      The Agency estimates that, on average, a facility will have one ventilation enclosure and that four workers will use the enclosure.  Each enclosure requires an estimated 525 cfm of additional ventilation capacity at a cost of $13.18 per cfm, for a capital cost of $6,918 (525 x $13.18).  Operating and maintenance costs are estimated to be $0.78 per cfm of additional ventilation capacity, for a total annual cost of $411 (525 x $0.78).  Total annualized cost per unit, including operating and maintenance, is $1,224, and the per-worker annualized cost is $306 ($1,224/4).  OSHA preliminarily estimates that there are 120 affected workers in this application-group process, resulting in a total annualized cost for engineering controls of $36,713 (120 x $306).

Abrasive blasting operator
      Abrasive blasting operators in foundries typically use enclosed and ventilated blasting units that are partially or fully automated.  Based on the findings of the technological feasibility analysis, the Agency has preliminarily concluded that blasters in this application group are not using beryllium-containing blasting media in any operations where the blasters are within an enclosure or performing open blasting, and hence this analysis estimates no cost for this operation.

Maintenance operator
      Maintenance operators repair equipment throughout the facility.  Maintenance operators are exposed to beryllium when they disturb equipment and work surfaces that are contaminated with beryllium. When working on ventilated equipment, such as furnaces, the process exhaust ventilation system may offer some degree of exposure control for the maintenance operator, but is unlikely to be designed to provide optimal control of maintenance activities.  Maintenance workers may be required to clean and maintain their work stations throughout the day and at the end of the work shift.  Maintenance workers may disturb dust containing beryllium when handling contaminated equipment, dry sweeping, dry wiping, moving dusty items, and chipping splattered metal, leading to worker exposures to a level of beryllium in excess of the proposed PEL.
      To reduce exposure to beryllium during these activities in accordance with the recommendations of the technological feasibility analysis, maintenance workers would perform additional vacuuming of their work areas (beyond the vacuuming required for normal housekeeping) using the vacuums purchased to comply with the housekeeping provision, which is discussed as part of the ancillary provisions cost estimates presented later in this chapter.  OSHA preliminarily estimates that vacuuming would require an additional 30 minutes of time per worker per day, which is ERG's estimate of the time needed based on the amount of time required to comply with similar types of cleaning provisions in other OSHA standards.  With 50 working days per year -- a full working year has 250 days and, as previously noted, OSHA estimates that 20 percent of a worker's time in this application group would be spent working with beryllium-containing materials, so, 0.2 x 250 -- and an hourly wage of $21.91 (Production Occupation, SOC: 51-0000), the vacuuming labor costs would be $548 per worker per year (50 days x 0.5 hours x $21.91).  OSHA preliminarily estimates that there are 99 affected employees who will need to perform this additional vacuuming, resulting in a total annual cost of $54,225 (99 x $548).
      In addition to the vacuuming requirements, OSHA estimates that workers would also need to wet wipe their work area.  Wet wiping would require an additional 30 minutes of time per worker per day.  Applying a 50-day work year working with beryllium-containing materials, as previously explained, and the $21.91 hourly wage (Production Occupation, SOC: 51-0000), the time cost would be $548 per worker per year (50 hours x 0.5 x $21.91).  With 99 affected employees, the total annual labor cost for wet wiping is $54,225 (99 x $548).
       For most maintenance workers or maintenance activities, the Agency estimates, based on the findings of the technological feasibility analysis, that controls will include portable LEV systems.  In a portable LEV system, an enclosure or booth is placed around the work area, or the work is placed inside an enclosure that the operator reaches into.  Openings in the enclosure, such as access hatches and gas vents, are used to maintain favorable circulation (Refractory, 2003).  OSHA estimates that two employees will share one portable LEV system and that each system will require 800 cfm of additional ventilation capacity (ACGIH, 2001) at a cost of $13.18 per cfm, for a total capital cost per LEV system of $10,541 (800 x $13.18).  Operating and maintenance costs are estimated to be $0.78 per additional cfm of ventilation capacity, for a total annual cost of $627 (800 x $0.78).  Total annualized cost, including O&M, is $1,862 per unit, or $931 ($1,862/2) per employee.  With an estimated 99 affected employees, the cost of a portable LEV system for maintenance operators in this application group is $92,188 (99 x $931).
      Based on the demonstrated benefits of tool-mounted exhaust systems for controlling hazardous dusts (such as crystalline silica) in other industries, OSHA preliminarily estimates that facilities in this application group will need to employ these exhaust systems in order to protect maintenance operators from exposures to beryllium-containing dust above the proposed PEL.  Dust shroud adapters cost $100 per unit with a one year life span (Contractors Direct, 2009; Berland, 2009; Dust-Buddy, 2009; Martin, 2008), and the Agency estimates that each unit with such an adapter will be shared by two employees.  This results in an annual cost per worker of $50. This control also requires a large capacity vacuum that costs $1,552 (based on the average of estimates from Nikro Industries, 2012, and Nilfisk, 2012a) with an average life span of two years.  OSHA estimates that the operating and maintenance costs are 15 percent of the annual cost of the high capacity vacuum, for an annual per-worker cost of $116.  The total annualized cost for the large capacity vacuum is $522 per worker, resulting in a total annualized cost for the entire tool-mounted exhaust system -- dust shroud adapter and large capacity vacuum -- of $572 ($50 + $522) per employee.  With an estimated 99 affected workers in this application-group process, the total cost for this exhaust system is $56,623 (99 x $572).  The total control costs to protect maintenance operators in the nonferrous foundries application group is $2,563,348. The total cost for the application group by NAICS industry is represented in Table V-4 below.

Secondary Smelting, Refining and Alloying

      This section focuses on one job category -- Furnace Operators -- where exposures are estimated to be greater than 0.2 μg/m[3] in industries where smelting, refining, and alloying activities are performed.

Furnace Operations
	 The term "furnace operations" is here used broadly to include activities performed by melting and casting operators and helpers, as well as operation of furnaces and incinerators.  The melting process separates the metals of interest from their metallic compounds, removes contaminants remaining after the pretreatment process, and allows operators to make alloys and castings from the liquid metal.  After the metal is melted and refined, it may be formed into bars and ingots, or a final product.  OSHA has estimated that two engineering controls are necessary in order to reduce exposure to beryllium among workers performing furnace operations to levels at or below the proposed PEL.  These controls are: additional furnace ventilation and additional ventilation for dross removal.
	The Agency has estimated, that each facility in the secondary smelting, refining, and alloying application group would require 1,800 cfm of additional ventilation for one furnace per facility at an estimated cost of $13.18 per cfm, resulting in a capital cost of $23,718 (1,800 x $13.18).  Operating and maintenance costs are estimated to be $3.92 per cfm of additional ventilation capacity, for an annual operating and maintenance cost of $7,050 (1,800 x $3.92). Total annualized costs per facility, including operating and maintenance, is $9,830.  With 20 estimated affected establishments, the total annualized cost for additional furnace ventilation is $196,600 (20 x $9,830).
       OSHA has estimated that each facility would also require one additional custom- designed ventilation system for areas where dross removal and furnace "plugging" occur (see Chapter IV: Technological Feasibility Analysis, Section 5, of this PEA).  The Agency estimates that this additional ventilation system would need to provide an additional 1,600 cfm of ventilation capacity per facility.  At a cost of $16.47 per cfm of additional ventilation capacity, the capital costs are estimated to be $26,353 (1,600 x $16.47) per facility.  Operating and maintenance costs are estimated to be $3.92 per cfm, for an annual operating and maintenance cost of $6,266 (1,600 x $3.92). The total annualized cost per facility for this custom ventilation, including operating and maintenance, is $9,356; with 20 affected establishments, the total annualized cost is $187,120.
      The total annualized control costs for the secondary smelting, refining, and alloying application group is $383,719.  Several job categories within this application group, such as "furnace operator," appear in several different NAICS industries.  Total costs for each job category were therefore allocated across these different NAICS industries by their share of establishments within this application group, and are so presented in Table V-5 below.

Precision Turned Products
      The precision turned product manufacturing industry includes companies that produce metal products by a combination of machining processes, including, but not limited to, turning, milling, tapping, drilling, sawing, and grinding.  Beryllium-containing materials that might be used for these products include beryllium metal and beryllium alloyed with other metals, including copper, nickel, aluminum, magnesium, gold, and zinc.
      OSHA has determined that ventilated enclosures for machining equipment are an effective strategy for reducing a machining equipment operator's exposure to beryllium to levels at or below the proposed PEL.
      Installing ventilated enclosures would first require a machine-specific engineering and industrial hygiene study to determine the design parameters of the ventilation equipment.  The Agency has estimated that this study would take eight hours for a consulting industrial hygienist to complete -- at a wage rate of $150 per hour, for a cost of $1,200 (8 x $150) -- plus 16 hours for a ventilation mechanical engineer -- at a wage rate of $48.83 per hour (Mechanical Engineer, SOC: 17-2141), for a cost of $781 (16 x $48.83).  Four hours of a machinist's time is also required to explain the workings of the machine in question (to assist the engineer and industrial hygienist in determining the best way to design the enclosure) -- at a wage rate of $25.00 per hour (Machinists, SOC: 51-4041), for a cost of $100 (4 x $25).  The total initial cost to complete the industrial hygiene study is $2,081 per machine ($1,200 + $781 + $100).  OSHA estimates that each machine that is subject to one of these studies will be used by four machinists, which results in a total initial cost of $520 per worker ($2,081/4), and a total annualized cost of $61 per worker.  OSHA preliminarily estimates that there are 697 workers at risk and in need of controls, resulting in a total annualized cost of $42,511 (697 x $61) for the studies.
      The Agency estimated the cost of a standard hood based on the exhaust requirements of a "high toxicity materials milling machine hood" shown in the ACGIH ventilation manual (ACGIH, 2001).  OSHA believes this type of hood will be representative of the type of hood that industrial hygienists will recommend in most cases for facilities in this application group to comply with the requirements of the proposed rule.  OSHA estimates that this type of enclosure will require 675 cfm of additional exhaust ventilation capacity. Based on these specifications, total capital costs for the ventilation enclosure, using a per-cfm cost of $13.18, is $8,894 (675 x $13.18). Additional annual operating and maintenance costs, estimated to be $3.92 per cfm of additional ventilation capacity, are $2,644 (675 x $3.92).  The total annualized cost per machine is $3,686. Given the previous estimate of four workers per machine, the cost per worker is $922 ($3,686/4).  With 697 affected employees in this application-group process, the resulting total annualized cost is $642,285 (697 x $922) for the ventilation enclosure and additional ventilation.
      The precision machining application group must incur additional costs for engineering  controls or work practices to comply with paragraph (f)(2) of the proposed standard, which requires employers to protect employees with exposures at or above the proposed action level and at or below the proposed PEL.  Machinists working with low content beryllium require enhanced LEV for employees exposed at or above the proposed action level but at or below the proposed PEL.  OSHA estimates that LEV for these machinists would be similar to that used in high-content beryllium machining operations with four workers per machine.  Adding 675 cfm of additional ventilation capacity at a cost of $13.18 per cfm has a capital cost of $8,894 (675 x $13.18), or $2,224 ($8,894/4) per worker. Operating and maintenance costs are estimated at $3.92 per cfm of additional ventilation capacity and therefore total $2,644 (675 x $3.92), or $661 ($2,644/4) per worker, annually.  Total annualized costs, including O&M, are $3,686, or $922 (($3,686/4) per worker.  OSHA has estimated that approximately 11.3 percent of machinists working with low content beryllium, or 398 machinists, have exposures at or above the proposed action level and at or below the proposed PEL.  The total cost of implementing engineering controls to comply with paragraph (f)(2) for this application group is therefore $366,444 ($922 x 398).
      The total control costs for the machining application group is $1,051,240.  Several job categories within this application group work in different NAICS industries.  Total costs for each job category were allocated across these different NAICS industries by their share of establishments within this application group, and are so presented in Table V-6 below.

Copper Rolling, Drawing, and Extruding
      Copper rolling, drawing, and extruding mills produce copper and copper alloy rod, bar, sheet, strip, plate, pipe, tube, and wire. The metal-forming processes used to produce copper-beryllium alloy products (which typically contain 2 percent or less beryllium) are common to other metals and, depending on the product, may include rolling, extrusion, pickling, annealing, and hot or cold drawing.  OSHA has determined that employees in only a few operations in this application group are currently exposed above the PEL.  These include rod and wire production workers and strip metal production workers (both of whom are exposed to high levels of beryllium mainly during bulk pickling and annealing) and wastewater treatment workers.
      The costs for this application group, presented by NAICS industry, are shown in Table V-7 at the end of this application group section.

Wastewater Treatment Operators
      Industrial wastewater treatment facilities at copper rolling, drawing, and extruding facilities process wastewater containing dilute acids and caustics.  Sludge from the clarified wastewater is dewatered in a filter press, collected in a container, and removed from the facility by a licensed contractor for landfill disposal.  Worker activities where beryllium exposures occur include handling both universal and process-related waste and maintaining the industrial wastewater treatment facility.
      Based on materials presented in the technology feasibility analysis describing a housekeeping program implemented by Materion, the Agency estimates that affected workers would each need to devote an additional 10 minutes per day to clean their work area in order to reduce beryllium exposures to levels at or below the proposed PEL.  Based on a 250 day work-year and an hourly wage rate of $29.62 (Water and Liquid Waste Treatment Plant Operators: SOC 51-8031), this requirement would result in a yearly cost of $1,234 per worker ((10/60) x 250 x $29.62).  With an estimated 26 affected workers needing controls to reduce beryllium exposures, the total annual cost of cleaning is $31,544.

Rod and Wire Production Workers
      Rod and wire production workers perform the following job tasks: wire annealing and pickling; wire drawing; straightening; point and chamfer; rod and wire packaging; and die grinding.  All of these processes are equipped with LEV except for rod and wire packaging and the rod/tube straightening process, where finished product is cut to length prior to packaging and shipping.
      Within this job category, bulk pickling and annealing operations have the highest beryllium exposures (see Table 8-4 in Chapter IV: Section 8 of this PEA).  In one facility, these higher exposures are likely caused in part by a bulk pickling tank equipped with an ineffective push-pull LEV system (Kent, 2004), which results in workers being exposed to beryllium at levels above the proposed PEL.  OSHA therefore expects that at that facility and all other similar facilities in the application group, additional controls are necessary.  In order to reduce beryllium exposures to levels at or below the proposed PEL, the Agency has estimated that these firms will need to use an interim restricted access zone to enclose the bulk pickling and annealing operations with floor-to-ceiling walls that contain two rapid-access doors to isolate these activities from the rest of the facility.
      Based on an ERG site visit to a copper-beryllium alloy facility, OSHA estimates that the average plant area devoted to pickling and annealing is 1,250 square feet (ERG, 2004b).  Based on industry data, OSHA estimates that it would cost $15.00 per square foot of area to enclose the activity (RS Means, 2005), so the initial capital cost to erect an interim restricted access zone is $18,750 (1,250 x $15), and the annualized cost is $2,198.
      This enclosure will also require enhanced ventilation equal to a 25 percent increase in ventilation capacity, which OSHA has estimated, for the baseline, to be 225,000 cubic feet per hour, or 3,750 cfm (225,000/ 60) per minute. The extra ventilation capacity required is estimated to be 938 (0.25 x 3,750) cfm in order to provide adequate ventilation to meet the proposed PEL.  At a cost of $13.18 per cfm, this results in a total capital cost of $12,353 (938 x $13.18).  OSHA estimates that the operating and maintenance cost is $3.92 per cfm of additional ventilation capacity, for a total annual operating and maintenance cost of $3,672 (938 x $3.92).  The annualized capital cost for enhanced ventilation is $1,448, and the total annualized cost, including operating and maintenance, is $5,120 per facility.
      The total annualized cost per facility for enclosures of the rod and wire production areas and to provide ventilation enhancements is $7,318 ($2,198 + $5,120) per facility. With an estimated 10 facilities engaged in these activities --  all in NAICS 331422 Copper wire (except mechanical) drawing --  the total annualized engineering control costs are $71,960.

Strip Metal Production Worker
      The strip metal production processes at copper-beryllium rolling and drawing facilities include strip rolling, annealing, pickling, slitting, inspection, and shipping and receiving.
      The Agency estimates that three ventilation controls would be needed per facility to meet the proposed PEL.  ERG estimates that each ventilation control requires 1,000 cfm at $13.18 per cfm, for a total capital cost of $39,529 (1,000 x 3 x $13.18).  Operating and maintenance costs are $3.92 per cfm, for a total annual operating and maintenance cost of $11,750 (1,000 x 3 x $3.92).  The total annualized cost, including maintenance, is $16,384 per facility. With one affected facility in NAICS 331421a: Copper rolling, drawing, and extruding, the total annualized cost for these ventilation controls is $16,384.
       OSHA estimates that the total annualized engineering controls for the copper rolling and drawing application group are $119,887.  Several job categories within this application group fall into different NAICS industries.  Total costs for each job category were allocated across these different NAICS industries according to the percentage of establishments by NAICS industry within this application group, and are so presented in Table V-7 below.

Fabrication of Beryllium Alloy Products

      Copper-beryllium alloys (less than or equal to 2 percent beryllium) are used to make a variety of products for electrical applications.  Copper wire and flat copper plate are used to make light-gauge springs, electronic connectors, and other stamped and formed metal products.  Large and medium-size stamping operations, involving procedures such as punching, bending, and other metal forming activities, are primarily automated and enclosed, meaning that the potential for beryllium exposures is low.  In addition, stamped copper-beryllium parts are usually plated -- typically with nickel, tin, or gold (Downing, 2002) -- and this plating serves to further protect workers from beryllium exposures since the beryllium metals are covered with another, non-toxic metal.  Electronic connector manufacturers may either stamp copper-beryllium components in-house or purchase these components from a stamper.  There is a potential for workers to be exposed to beryllium if stamping is done in-house.  Most workers in the stamping, spring, and connector manufacture application group have low beryllium exposures, although the potential for higher exposures exists for chemical process operators and deburring operators.  Exposures can be reduced to or below the proposed PEL through enhanced LEV for these operations.

Deburring Operator
      Deburring operators in this application group use the same range of deburring equipment as other metal product fabrication industries, including manual filing, brushing with wire or other stiff bristles brushes, abrasive action, and media barrel finishing (Corbett, 2007).  This same reference and a standard industrial hygienist design manual (Corbett, 2007; ACGIH, 2010) suggest that in beryllium handling facilities this equipment is usually attached to exhaust ventilation trunks, but air flow rates might not meet the levels necessary to adequately protect workers from beryllium exposures.
       Based on ACGIH (2010), OSHA has preliminarily estimated that each enhanced ventilation control will require an additional 1,750 cfm of ventilation capacity in order to reduce worker exposures to beryllium to levels at or below the proposed PEL.  With a cost of $13.18 per cfm of additional ventilation capacity, the initial capital cost is estimated to be $23,059 (1,750 x $13.18).  Operating and maintenance costs are $3.92 per cfm of additional ventilation capacity, for an annual operating and maintenance cost of $6,854 (1,750 x $3.92).  The total annualized cost for enhanced ventilation is $9,557 per facility.  OSHA preliminarily estimates that there are 86 facilities engaged in deburring that would need engineering controls in order to reduce exposures to beryllium to the proposed PEL.  This results in a total annualized cost for this application-group process of $822,183.

Chemical Process Operator
      Based on the technological feasibility assessment in Chapter IV, Section 9: Fabrication of Beryllium Alloy Products, in this PEA, OSHA has determined that firms in this application group will need enhanced LEV for chemical processing tanks in order to reduce worker exposures to beryllium, since the LEV currently in use does not meet the established performance criteria.  The Agency has estimated that there are two tanks per facility that will each require 600 cfm of additional ventilation capacity in order to meet the requirements of this rulemaking.  At a cost of $13.18 per cfm, this results in a capital cost of $7,906 per tank (600 x $13.18). The operating and maintenance cost is $3.92 per cfm of additional ventilation capacity, for an annual operating and maintenance cost of $2,350 per tank (600 x $3.92).  The total annualized cost per tank, including operating and maintenance costs, is $3,277, or $6,553 (2 x $3,277) per facility. OSHA preliminarily estimates that there are 28 (Table V-8 only shows 27 due to rounding) facilities that will need enhanced LEV in this application-group process, resulting in a total annualized cost of $183,557.
      Chemical process operators are one of the two job categories that would require engineering controls under paragraph (f)(2) of the proposed rule, which requires employers to take certain actions if their employees are exposed to beryllium in the range above the proposed action level (0.1) but at or below the proposed PEL (0.2) (if the exposure is above the PEL, then additional controls are required).  Based on the technological feasibility analysis in Chapter IV of this PEA, the Agency has determined that chemical processing requires enhanced maintenance of local exhaust ventilation.  OSHA has estimated that enhanced maintenance of LEV would require a five percent increase, per establishment per year, in the amount of labor provided by a maintenance worker.  Using a wage rate of $22.16 (Production Occupations, SOC:  51-0000), 250 work days per year, and eight hour shifts, a five percent increase in labor results in 100 additional hours annually (0.05 x 250 x 8) necessary to maintain LEV at a cost of  $2,216 (100 x $22.16) per establishment annually.  Approximately 6.8 percent of spring manufacturers, or 19 establishments, have exposures at or above the proposed action level and at or below the proposed PEL, resulting in a total annual cost of $42,106 (19 x $2,216).  Approximately 7.0 percent of stamping manufacturers, or 22 establishments, have exposures at or above the proposed action level and at or below the proposed PEL, resulting in a total annual cost of $48,754 (22 x $2,216).  The total cost of implementing engineering controls and work practices to comply with paragraph (f)(2) for this application-group process is therefore $90,860 ($42,106 + $48,754).
      The total control costs for the stamping, spring, and connection manufacturing application group is $1,096,600.  Several job categories within this application group fall into different NAICS industries.  Total costs for each job category were allocated across these different NAICS industries by their share of establishments within this application group, and are so presented in Table V-8 below.

Welding
      Beryllium-containing materials are welded using mainly two techniques:  arc welding and resistance welding.  Fumes are generated in welding operations when metals and oxides vaporize in the arc area, and rapid condensation (of the vapors) occurs to form particles.
      All arc welding processes create an electric arc (current) between the welding electrode (stick, rod, or wire filler metals) and the surface of the work piece.  The heat of the arc melts the electrode (or filler metal if a non-consumable electrode is used) and the work pieces to be joined. Both metal inert gas (MIG) and tungsten inert gas (TIG) welding are well suited for welding copper-beryllium. When copper-beryllium is welded to itself or to other metals, a copper-beryllium rod is typically used as the filler metal. Aluminum-bronze filler can also be used for welding copper-beryllium to steel.
      The second type of welding is resistance welding, which refers to a group of welding processes that apply electric current and mechanical pressure to create a weld between two pieces of metal.  Resistance welding electrodes can include beryllium material (see Chapter IV of this PEA).  Resistance welding is frequently used to attach electrical contacts to copper-beryllium flat springs. Exposure data for resistance welding used in the exposure profile (from the Welding section of Chapter IV of this PEA, Tables 10-1, 10-2) are all below the action level.  Hence there are no control costs estimated for resistance welders.
      Control options for this application group include taking steps to enhance exhaust ventilation and/or minimize the presence and release of beryllium oxide, which can flake off the surface of the metal work piece when the welder handles it (applicable only to facilities and operations where beryllium alloy has not been treated to prevent loose oxide from forming).

Reducing surface oxidation
      The presence and release of flaking beryllium oxide on the surface of pieces that welders are handling may account for as much as ninety percent of the beryllium exposure experienced by a welder, and has been implicated in the high exposure levels recorded among welders at the Materion Elmore facility (Corbett, 2006; Kent, 2005). Reducing the flaking surface oxide as a source of contamination could have a dramatic effect on lowering these exposure levels.  OSHA has determined that facilities would be able to eliminate the release of loosely adhered beryllium oxide by chemically stripping and pickling the beryllium alloy work piece prior to welding.  These procedures remove the loose surface oxides and stabilize the surface to prevent additional loosely adhered beryllium oxides from forming (Materion Information Meeting, 2012).  Although no formal studies have been conducted examining the efficacy of this method, safety and health professionals at Materion's Elmore facility report that the beryllium exposure of welders on their strip welding line decreased substantially when welding was performed only on pre-cleaned, pickled alloy strip (Kent 2012).  The costs for this method, involving a chemical dip tank, were already accounted for in the earlier estimation of welding costs during beryllium production.

Local Exhaust Ventilation Hoods
      Where welding fumes are the primary source of beryllium exposure, LEV would be needed as a control measure. When existing LEV is not adequate to reduce exposures to levels at or below the PEL, employers must improve the quality of the enclosed hood control or the placement of the exhaust pickup or hood relative to the work piece in order to optimize the capabilities of the hood and to reduce exposures to the maximum amount possible.
      For temporary or mobile operations, OSHA has estimated that a firm will employ movable LEV systems and that two welders will be able to utilize each enclosed hood control. The Agency estimates that a movable LEV system requires an estimated 800 cfm (ACGIH, 2001, p. 10-150) of additional ventilation capacity at a cost of $13.18 per cfm.  This results in a capital cost of $10,541 per hood (800 x $13.18). The operating and maintenance cost is estimated to be $3.92 per cfm of additional ventilation capacity, for an annual O&M cost of $3,133 (800 x $3.92).  The total annualized cost, including operating and maintenance, for an enclosed hood control is $4,369, or $2,184 ($4,369/2) per employee.  With an estimated 586 workers at risk of exposure to beryllium in this application-group process, the total annualized cost is $1,279,161.
        Correct use of portable ventilation systems can greatly improve system effectiveness, and OSHA has determined that workers are currently lacking in training on how to correctly use these systems. The Agency has judged that employers in this application group will need to provide additional training in order for their workplaces to be able to meet the proposed PEL.  ERG has estimated that annual training on the correct use of portable LEV will take four hours and will be provided by a single instructor to an average class size of six.  At a production worker wage rate of $22.16 an hour, an employer will incur a cost of $88.64 (Production Occupation, SOC: 51-0000) for the worker's time to receive this training (4 x $22.16).  The instructor's wage rate is $37.39 an hour (Training and Development Specialist, SOC 13-1151), and the total cost for the instructor for four hours, $149.55 (4 x $37.39), will be spread across the class size of six, resulting in a per worker annual cost for the instructor of $24.92 ($149.55/6). This results in an annual labor cost per worker of $114 ($88.64 + $24.92) to receive training on the correct use of portable LEV systems.  In addition to the time necessary for training to be provided, OSHA has estimated that an employer will make training materials available, which are estimated to cost $2.00 per employee.  The total annual cost to receive training on the correct use of portable LEV systems is then $116 ($114 + $2) per worker.  OSHA preliminarily estimates that there are 586 workers who will need training, resulting in a total annual cost of $67,674.  The total control costs for this application group is $1,346,835.
      The welding application group encompasses numerous NAICS industries.  Total costs are allocated across these different NAICS industries by their share of establishments within this application group, and are so presented in Table V-9 below.

Dental Laboratories
      Some dental laboratories use beryllium alloys in the oral appliances they manufacture.  Some of the manufacturing processes -- including grinding, polishing, abrasive blasting, and melting metal beryllium alloys --  may generate significant exposures among technicians.  For those employers currently using beryllium alloys, two options are available to comply with the requirements of the proposed standard.  Employers can either substitute a product which does not contain beryllium, or they can continue to work with beryllium alloys and comply with the proposed standard's provisions.
      During the Small Business Advocacy Review panel, Small Entity Representatives (SERs) informed OSHA that dental labs using beryllium typically use ventilation controls for processes that can result in workers being exposed to beryllium.  However, SERs reported that these controls may not be HEPA-filtered or vented to the outside, which the Agency has concluded is necessary to control exposure.  OSHA believes it is reasonable to estimate that the dental laboratories most likely to opt for substitution are those with the highest exposures and that those laboratories with exposures below the proposed PEL have already invested in the necessary engineering controls.  However, the Agency acknowledges the possibility that, for some dental labs (for example, those processing the highest volume of beryllium-containing alloys per technician), it might be less expensive to institute LEV and comply with the ancillary provisions than to substitute materials.  OSHA invites comment on this point, and has provided a sensitivity analysis in Chapter VII addressing a scenario if controls are used instead of substitution.
      Based on the technological feasibility analysis, the Agency has estimated that all dental laboratories with exposure above 0.1 μg/m[3] and an additional 5.3 percent of laboratories exposed below 0.1 μg/m[3] would substitute to beryllium-free alloys, so that after the beryllium rule took effect, 75 percent of dental labs would not be working with beryllium. Of the 25 percent of dental labs continuing to use beryllium, the Agency estimates that these laboratories will have low levels of beryllium exposures due to the engineering controls they have already implemented.  Because of this, OSHA estimates that no dental laboratories would require additional engineering controls, although the laboratories that continue to work with beryllium-containing alloys would incur costs, as discussed later in this chapter, to come into compliance with the ancillary provisions.
      OSHA estimates that the cost to substitute to beryllium-free alloys consists of the price differential between beryllium-free alloys and alloys that contain beryllium, plus additional training needed to teach dental technicians how to cast the beryllium-free alloys.  As indicated in Chapter III: Industry Profile of this PEA, ERG interviewed consultants in the dental laboratory market industry who estimated that roughly 60 percent of dental prosthetics are made from metals and 40 percent are made from ceramics (Cascone, 2012).  The consultants estimated that half of the dental laboratory market for metals is precious metals (gold, etc.), while the other half is base metals (nickel, chromium, etc.).  Of the share of the market that is base metals, 90 percent is estimated to contain beryllium (Cascone, 2012). Based on these estimates, OSHA has calculated that beryllium-containing metals account for 27 percent (0.6 x 0.5 x 0.9) of the materials purchased by makers of dental appliances.  In order to simplify the remaining calculations, that estimate has been rounded down to 25 percent.
      The same industry consultants indicated that Ni-Cr-Be alloys are most frequently used to manufacture crowns and multi-unit crowns or bridges (Cascone, 2012; O'Brien, 2002).  ERG interviewed suppliers of dental alloys and found that they frequently offer a beryllium-free Ni-Cr alloy for a slightly higher price (Cascone, 2012; Nowak, 2012; CMP, 2013).  Alloy manufacturers noted that the prices of these two groups of alloys have remained fairly stable since 2010 and that they expect this trend to continue (Cascone, 2013; CMP, 2013).  Neither consultants nor literature indicated a significant difference in performance of beryllium-free Ni-Cr alloys and Ni-Cr-Be alloys. The only significant difference is that beryllium-free alloys are somewhat more difficult to cast (Cascone, 2013; Wassell, et al., 2010; Wataha, 2002; Bezzon, et al., 1998; Leinfelder, 1997).
      OSHA determined from discussions with an industry consultant that two hours was an adequate amount of time to train dental technicians to work with beryllium-free alloys (Cascone, 2013b).  Based on the large share of dental laboratories with fewer than 20 employees and evidence both from the American Dental Association (ADA, 2011) and an industry consultant (Cascone, 2013a) that most dental laboratories using beryllium are small entities, the Agency estimated that only two dental technicians would be trained in each training session.  The wage for a dental technician is $24.91 per hour (Dental Laboratory Technician, SOC: 51-9081), while the trainer's wage is $37.11 per hour (First-Line Supervisors of Production and Operating Workers, SOC: 51-1011).  The total cost for training two dental technicians per facility is then $173.86 ((2 x 2 x $24.91) + (2 x $37.11)), or $86.93 per dental technician ($173.86/2). Annualized over ten years, this cost per worker is $10.19 per year.
      To determine the difference in total cost between using beryllium-free alloys and those with beryllium, OSHA examined both the quantities used and the difference in cost.  Consultants estimated that approximately 16 million crown units are made from base metal alloys each year and that one ounce of base metal yields 20 crowns (Cascone, 2012). Based on these estimates, OSHA calculates that 800,000 (16,000,000/20) ounces of base metal alloys are sold to dental appliance makers in a given year. Using the prior estimate that 90 percent of base metal alloys sold contain beryllium, this means that 720,000 (0.9 x 800,000) ounces of beryllium-containing base-metal alloys are sold to dental appliance manufacturers each year.  An ounce of beryllium-free Ni-Cr costs $20.50 and an ounce of Ni-Cr-Be costs $18.50, resulting in a $2.00 price differential between beryllium-free Ni-Cr and Ni-Cr-Be alloys (Cascone, 2004).  At $2.00 an ounce, the aggregate cost of purchasing beryllium-free alloys instead of beryllium-containing alloys is $1,440,000 (720,000 x $2) each year.
       OSHA estimated that 75 percent of dental laboratories would substitute away from beryllium-containing alloys due to the combined cost of installing engineering controls and complying with the ancillary provisions of the proposed standard.  With this substitution rate, the aggregate cost to purchase beryllium-free alloys, instead of beryllium-containing alloys, would be reduced  to $1,080,000 (0.75 x $1,440,000) per year.  From Chapter III: Industry Profile of this PEA, there are 9,255 dental technicians with beryllium exposure, and with a proportional allocation, 6,941 technicians will substitute to beryllium-free alloys (.75 x 9,255).  This gives a per-technician substitution cost of $155.59 (1,080,000/6,941) per year.  Including training costs, the total annual per technician cost of substitution is $165.78 ($155.59 + $10.19).  This yields a total annualized cost for dental laboratories of $1,150,739.  Job categories within this application group work in different NAICS industries.  Total costs for each job category were allocated across these different NAICS industries by their share of establishments within this application group, and are so presented in Table V-10 below.

Respiratory Protection Costs

      Based on the findings of the technological feasibility analysis, a small subset of employees working with a few processes in a handful of application groups will need to use respirators, in addition to required engineering controls and improved work practices, to reduce employee exposures to meet the proposed PEL.  Specifically, furnace operators -- both in non-ferrous foundries (both sand and non-sand) and in secondary smelting, refining, and alloying -- as well as welders in a few other processes, will need to wear half-mask respirators.  In beryllium production, workers who rebuild or otherwise maintain furnaces and furnace tools will need to wear full-face powered air-purifying respirators.  Finally, the Agency recognizes the possibility that, after all feasible engineering and other controls are in place, there may still be a residual group with potential exposure above the proposed PEL and/or STEL. To account for these residual cases, OSHA estimates that 10 percent of the workers, across all application groups and job categories, who are above the proposed PEL before the beryllium proposed standard is in place (according to the baseline exposure profile presented in Chapter III of this PEA), would still be above the PEL after all feasible controls are implemented and, hence, would need to use half-mask respirators to achieve compliance with the proposed PEL.
      There are five primary costs for respiratory protection.  First, there is a cost per establishment to set up a written respirator program in accordance with the respiratory protection standard (29 CFR 1910.134).  The respiratory protection standard requires written procedures for the proper selection, use, cleaning, storage, and maintenance of respirators.  OSHA estimates that these procedures will take a human resources manager 8 hours to develop, at an hourly wage of $70.44 (Human Resources Managers, SOC: 11-3121), for an initial cost of $564 (8 x $70.44).  Every year thereafter, OSHA estimates that the same employee will take 2 hours to update the respirator program, for an annual cost of $141 (2 x $70.44).  OSHA annualized the initial program cost over 10 years, yielding an annualized per-establishment cost for a written respirator program of $207.
      ERG's research indicates that, for reasons unrelated to the proposed standard, certain establishments will already have a respirator program in place.  Based on this research, table V-11 below presents OSHA's estimates, by application group, of current levels of compliance with the respirator program provision of the proposed rule.

      The four other major costs of respiratory protection are the per-employee costs for all aspects of respirator use: equipment, training, fit-testing, and cleaning.  Table V-12 breaks out OSHA's estimate of the unit costs for the two types of respirators needed:  a half-mask respirator and a full-face powered air-purifying respirator.  These unit costs are further described below in the text.
      A half-mask respirator is estimated to cost $29.32  and to have a service life of two years, yielding an estimated annualized cost of $15.32.  OSHA estimates that 100 disposable filters would be needed each year at a cost of $183.20.  Therefore, total annualized half-mask equipment costs (for respirator and filters) are $198.53 ($15.32 + $183.20).  Annual training for respirator use is estimated to be done for a class size of 4, where each trainee's hourly wage is $22.16 (Production Occupations, SOC:  51-0000) and the trainer's wage is $37.11 (First-Line Supervisors of Production and Operating Workers, SOC:  51-1011). This results in a per-employee hourly training cost of $31.44 ($22.16 + ($37.11/4)).  Half-mask respirator training is estimated to last 2 hours, so the per-employee annual training cost is estimated to be $62.88 (2 x $31.44).  Fit-testing will need to be done annually and is estimated to have the same parameters as for training: it will be done in groups of four, and wage rates will be the same.  Fit testing, however, is estimated to take only one hour, so the annual cost would be $31.44 per worker.  The final half-mask respirator cost is periodic cleaning, which is estimated to be needed every two days, or 125 times annually (250/2). Each cleaning is estimated to take 5 minutes, or 0.08 (5/60) hours, and the wage cost per hour is $22.16 ((Production Occupations, SOC:  51-0000).  Multiplied together, this gives an annual respirator cleaning cost of $230.85 (125 x 0.08 x $22.16).  Summing these various respirator costs together yields an annualized per-employee cost for a half-mask respirator of $523.69 ($198.53 + $62.88 + $31.44 + $230.85).
	A full-face powered air-purifying respirator (PAPR) is estimated to cost $848.50 and to have a service life of three years, yielding an annualized cost of $298.91.  The annual cost for a cartridge, a breathing tube, and replacement parts is $510.46, for a total annualized equipment cost of $809.37 ($298.91 + $510.46).  Class size and wage costs are the same as for the half-mask respirator (see above), so the per-employee hourly training cost is $31.44.  But the increased complexity of the full-mask respirator means that four hours of training are needed; therefore the per-employee annual training cost is $125.76 (4 x 31.44).  Two hours are estimated to be needed for fit testing, which will be done in groups of two (with all else the same as for half-mask respirators).  Therefore, the per-employee annual fit-testing cost is $81.43 (2 x ($22.16 + ($37.11/2)).  Because PAPRs are expected to be assigned to individual workers, no respirator cleaning is required.  Summing these costs together, the total annualized per-employee cost for a full-face powered air-purifying respirator is $1,016.56 ($809.37 + $125.76 + $81.43).
      Table V-13 presents the number of additional employees by application group and NAICS industry that will need to wear respirators to comply with the proposed standard and the cost to industry to supply those respirators and to comply with the other respirator protection provisions in the proposed rule. OSHA estimates that only the workers in Beryllium Production work with processes that would require a full-face respirator would need additional respiratory protection and that there are 23 of those workers.  Three hundred and eighteen workers in other assorted application groups are estimated to need half-mask respirators. A total of 341 (23 + 318) employees will need to wear some type of respirator, resulting in a total annualized cost of $249,684 for affected industries to comply with the respiratory protection requirements of the proposed standard.

Annualized Cost of Complying with the Proposed PEL/STEL

      Table V-14 presents a summary of the total annualized costs for affected firms to meet the proposed beryllium PEL/STEL.  As shown, these costs are disaggregated by engineering controls and work practices and by respiratory protection, as well as by application group and six-digit NAICS industry.

PROGRAM COSTS AND DEFINITIONS OF AFFECTED WORKER POPULATIONS
      This section presents OSHA's estimated costs for ancillary beryllium control programs required under the proposed rule.  Based on the program requirements contained in the proposed standard, OSHA considered nine potential cost elements in the following employer duties: (1) assess employees' exposure to airborne beryllium, (2) establish regulated areas, (3) develop a written exposure control plan, (4) provide protective work clothing, (5) establish hygiene areas and practices, (6) implement housekeeping measures, (7) provide medical surveillance, (8) provide medical removal for employees who have developed CBD or been confirmed positive for beryllium sensitization, and (9) provide appropriate training.
      The worker population affected by each program element varies by several criteria discussed in detail in each subsection below.  In general, some elements would apply to all workers exposed to beryllium at or above the action level.  Other elements would apply to a smaller set of workers who are exposed above the PEL.  The training requirements would apply to all employees who work in a beryllium work area (e.g., an area with any level of exposure to airborne beryllium).  The regulated area program elements triggered by the proposed PEL of 0.2 μg/m[3] would apply to those workers for whom feasible controls are not adequate.  In the earlier discussion of respiratory protection, OSHA estimated that 10 percent of all affected workers with current exposures above the proposed PEL would fall in this category.
      Costs for each program requirement are aggregated by employment and by industry.  For the most part, unit costs do not vary by industry, and any variations are specifically noted.
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Current Compliance Rates
      The current levels of baseline compliance rates for each provision were estimated based on site visits, industry contacts, published literature, and the Final Report of the Small Business Advocacy Review (SBAR) Panel (SBAR 2008).  As part of the SBAR Panel, small entity representatives (SERs) reported current compliance measures present in their respective industries.  Based on information provided by ERG experts, the Agency believes the application groups copper rolling, drawing & extruding; precision turned products; and beryllium oxide ceramics & composites are currently undertaking some of the required actions with respect to three of the ancillary provisions: exposure assessment, regulated areas, and medical surveillance.  SERs who make products from materials with high beryllium content as an important part of their business, as well as a SER from a precious metal recovery and recycling employer, indicated that they performed considerable air sampling for exposure monitoring purposes (SBAR, 2008, p. 9).
      OSHA estimates that at least some percentage of firms affected by the proposed rulemaking are currently complying with the training and housekeeping requirements in the majority of application groups.  The estimated compliance rate for each provision of the proposed standard by application group, based on information provided by ERG, is presented in Table V-15, below.

Exposure Assessment

      Most establishments wishing to perform exposure monitoring would require the assistance of an outside consulting industrial hygienist (IH) to obtain accurate results.  While some firms might already employ or train qualified staff, OSHA judged that the testing protocols are fairly challenging and that few firms have sufficiently skilled staff to eliminate the need for outside consultants (ERG, 2007b).
      The proposed standard requires that, after receiving the results of any exposure monitoring where exposures exceed the TWA PEL or STEL, the employer notify each such affected employee in writing of suspected or known sources of exposure, and the corrective action(s) being taken to reduce exposure to or below the PELs. Those workers exposed at or above the action level and at or below the PEL must have their exposure levels monitored annually.
      For costing purposes, based on ERG (2007b), OSHA estimates that, on average, there are four workers per work area.  OSHA interpreted the initial exposure assessment as requiring first-year testing of at least one worker in each distinct job classification and work area who is, or may reasonably be expected to be, exposed to airborne concentrations of beryllium at or above the action level.
      The proposed standard requires that whenever there is a change in the production, process, control equipment, personnel, or work practices that may result in new or additional exposures, or when the employer has any reason to suspect that a change may result in new or additional exposures, the employer must conduct additional monitoring.  The Agency has estimated that this provision would require an annual sampling of 10 percent of the affected workers.
      OSHA estimates that an industrial hygienist (IH) would spend one day each year -- at a cost of $513.43, based on the professional judgment of an IH (ERG, 2007b), brought forward to 2010 dollars -- to sample 2 workers, for a per worker IH fee of $257 ($513/2).  This exposure monitoring requires that three samples be taken per worker: one TWA and two STEL for an annual IH fee per sample of $85.57 ($257/3).  Based on the 2000 EMSL Laboratory Testing Catalog (ERG, 2007b), OSHA estimated that analysis of each sample would cost $137 in lab fees. When combined with the IH fee, OSHA estimated the annual cost to obtain a TWA sample to be $222.53 ($137 + $85.57) per sampled worker and the annual cost to obtain the two STEL samples to be $445.07 (2 x ($137 + $85.57)) per sampled worker.  The direct exposure monitoring unit costs are summarized in Table V-16 below.

      The cost of the sample also incorporates a productivity loss due to the additional time for the worker to participate in the sampling (30 minutes per worker sampled) as well as for the associated recordkeeping time incurred by a manager (15 minutes per worker sampled).  The STEL samples are assumed to be taken along with the TWA sample and, thus, labor costs were not added to both unit costs.  Including the costs related to lost productivity, OSHA estimates the total annual cost of a TWA sample to be $251.22 ($222.53 + $11.08 + $17.61), and 2 STEL samples, $445.07.  The total annual cost per worker for all sampling taken is then $696.29 ($251.22 + $445.07).  OSHA estimates the total annualized cost of this provision to be $2,208,950 for all affected industries.  The annualized cost of this provision for each affected NAICS industry is shown in Table V-19 at the end of this section.

Beryllium Work Areas and Regulated Areas

      The proposed beryllium standard requires the employer to establish and maintain a regulated area wherever employees are, or can reasonably expected to be, exposed to airborne beryllium at levels above the TWA PEL or STEL.  Regulated areas require specific provisions that both limit employee exposure within its boundaries and curb the migration of beryllium outside the area. The Agency judged, based on the preliminary findings of the technological feasibility analysis, that companies can reduce establishment-wide exposure by ensuring that only authorized employees wearing proper protective equipment have access to areas of the establishment where such higher concentrations of beryllium exist, or can be reasonably expected to exist. Workers in other parts of the establishment are also likely to see a reduction in beryllium exposures due to these measures since fewer employees would be traveling through regulated areas and subsequently carrying beryllium residue to other work areas on their clothes and shoes.
      Requirements in the proposed rule for a regulated area include: demarcating the boundaries of the regulated area as separate from the rest of the workplace, limiting access to the regulated area, providing an appropriate respirator to each person entering the regulated area and other protective clothing and equipment as required by paragraph (g) and paragraph (h), respectively.  OSHA estimated costs for establishing and maintaining regulated areas to comply with these requirements.
      OSHA estimated that one regulated area would be established for every 4 employees exposed above the TWA PEL or STEL. The initial set up time by a supervisor is estimated to require eight hours at an hourly wage of $37.11 (First-Line Supervisors of Production and Operating Workers, SOC 51-1011) for a total of $296.88 (8 x $37.11).  The annualized cost would be $34.81. Demarcating the regulated area was estimated to require 300 feet of hazard tape at a cost of $25.83 -- $15.50 per 180 feet (Grainger, 2012a) -- so that the total cost is ($15.50 x (300/180)). Demarcation will also need six 6 x 24 inch warning signs, with a per-sign cost of $21.87 (Grainger, 2012b), and hence a total cost of $131.22 (6 x $21.87).  The hazard tape will need to be replaced yearly while the signs are estimated to last 10 years.  Together these materials have an annualized cost of $41.22. The total annualized cost for setting up a regulated area including labor and supplies is $76.02 ($34.81 + $41.22).
      The Agency has estimated an annual cost of $1,767.50 for two disposable respirators per day to be used by authorized persons (other than those who regularly work in the regulated area) who might need to enter the area in the course of their job duties.  In addition, for costing purposes, OSHA estimated that in response to the protective work clothing and equipment requirements in regulated areas, employees (other than those who regularly work in the regulated area and would otherwise be covered under the requirements for protective clothing) would, collectively, on average wear two suits of disposable protective clothing daily at $9.00 per suit, with 250 work days per year, this gives an annual cost of $4,500 (2 x 250 x $9.00).  Total annualized cost per regulated area including set up costs, respirators and protective clothing is $6,343.52 ($76.02 + $1,767.50 + $4,500).
      When establishments are in full compliance with the standard, regulated areas would be required only for those workers for whom controls could not feasibly reduce their exposures to or below the 0.2 μg/m3 TWA PEL and the 2 μg/m3 STEL.  Based on the findings of the technological feasibility analysis, OSHA estimated that 10 percent of the affected workers would be exposed above the TWA PEL or STEL after implementation of engineering controls and thus would require regulated areas (with one regulated area, on average, for every four workers exposed above the proposed TWA PEL or STEL).
      The proposed standard requires that all beryllium work areas are adequately established and demarcated.  ERG estimated that one work area would need to be established for every 12 at-risk workers.  The initial set up time by a supervisor is estimated to require four hours at an hourly wage of $37.11 (First-Line Supervisors of Production and Operating Workers, SOC 51-1011) for a total of $148.45 (4 x $37.11).  As with regulated areas, six signs would be needed to demarcate each work area, with the same type and costs as for regulated areas (see above).  The annualized cost (over 10 years, the life span of the signs) is $32.79 per work area.
      OSHA estimates the total annualized cost of the regulated areas and work areas is $629,031 for all affected industries.  The cost for each affected NAICS industry is shown in Table V-19 at the end of this section.

Written Exposure Control Plan

	The proposed standard requires that employers must establish and maintain a written exposure control plan for beryllium work areas.  The written program must contain:
      1. An inventory of operations and job titles reasonably expected to have exposure.
      2. An inventory of operations and job titles reasonably expected to have exposure at or above the action level.
      3. An inventory of operations and job titles reasonably expected to have exposure above the TWA PEL or STEL.
      4. Procedures for minimizing cross-contamination, including but not limited to preventing the transfer of beryllium between surfaces, equipment, clothing, materials and articles within beryllium work areas.
      5. Procedures for keeping surfaces in the beryllium work area free as practicable of beryllium.
      6. Procedures for minimizing the migration of beryllium from beryllium work areas to other locations within or outside the workplace.
      7. An inventory of engineering and work practice controls required by paragraph (f)(2) of this standard.
      8. Procedures for removal, laundering, storage, cleaning, repairing, and disposal of beryllium-contaminated personal protective clothing and equipment, including respirators.

      The unit cost estimates below take into account the judgment that (1) most establishments have an awareness of beryllium risks and, thus, should be able to develop or modify existing safeguards in an expeditious fashion, and (2) many operations have limited beryllium activities and these establishments need to make only modest changes in procedures to create the necessary exposure control plan.  The unit costs presented include estimates by ERG's experts that managers, earning an hourly wage of $70.44 (Human Resources Managers, SOC: 11-3121), would spend eight hours per establishment to develop and implement such a written exposure control plan.  The total cost per establishment to develop and implement the written control plan is then $563.53 ($70.44 x 8), for an annualized cost of $66.  In addition, because larger firms with more affected workers will need to develop more complicated written control plans, the development of a plan would require an extra thirty minutes of a manager's time per affected employee, for a cost of $35.22 (0.5 x $70.44) per affected employee and an annualized cost of $4.13 per employee.  There are various triggers under which the employer must update the plan and the Agency estimates that, on average, this will occur annually.  The agency invites comment on whether this frequency is correct.  Managers would also need 12 minutes (0.2 hours) per affected employee per quarter, or 48 minutes (4 x 12), (0.8 hours) per affected employee per year to review and update the plan, for a recurring cost of $56.35 (0.8 x $70.44) per affected employee per year to maintain and update the plan.  Five minutes of clerical time would also be needed per employee for providing each employee with a copy of the written exposure control plan.   With a clerical wage of $19.97 (File Clerks SOC 43-4071) this is a per employee cost of $1.66.  The total annual per-employee cost for development, implementation, review, and update of a written exposure control plan is then $62.14 ($4.13 + $56.35 + $1.66).  The Agency estimates the total annualized cost of this provision to be $1,769,506 for all affected establishments.  The breakdown of these costs by NAICS code is presented in Table V-19 at the end of this program cost section.

Personal Protective Clothing and Equipment

      The proposed standard requires personal protective clothing and equipment for workers:
      1. Whose exposure can reasonably be expected to exceed the TWA PEL or STEL.
      2. When work clothing or skin may become visibly contaminated with beryllium, including during maintenance and repair activities or during non-routine tasks.
      3.  Where employees' skin can reasonably be expected to be exposed to soluble beryllium compounds.
	 OSHA has determined that it would be necessary for employers to provide reusable overalls and/or lab coats at a cost of $283.92 and $86.06, respectively (from Crown Uniform, 2012; Dempsey Uniform, 2012), for operations in the following application groups:
      Beryllium Production
      Beryllium Oxide, Ceramics & Composites
      Nonferrous Foundries
      Fabrication of Beryllium Alloy Products
      Copper Rolling, Drawing & Extruding
      Secondary Smelting, Refining and Alloying
      Precision Turned Products
      Dental Laboratories
      Chemical process operators in the spring and stamping application group would require chemical resistant protective clothing at an annual cost of $848.66 (Grainger, 2012c).  Gloves and/or shoe covers would be required when performing operations in several different application groups, depending on the process being performed, at an annual cost of $50 (OSHA estimate) and $78 (Grainger 2012c), respectively.
      The proposed standard requires that all reusable protective clothing and equipment be cleaned, laundered, repaired, and replaced as needed to maintain their effectiveness. This includes such safeguards as transporting contaminated clothing in sealed and labeled impermeable bags and informing any third party businesses coming in contact with such materials of the risks associated with beryllium exposure.  OSHA estimates that the lowest cost alternative to satisfy this provision is for an employer to rent and launder reusable protective clothing -- at an estimated annual cost per employee of $48.62.  Ten minutes of clerical time would also be needed per establishment with laundry needs to notify the cleaners in writing of the potentially harmful effects of beryllium exposure and how the protective clothing and equipment must be handled in accordance with this standard.  With.a wage of $19.97 (File Clerks SOC 43-4071) this per establishment cost is $3.33.
      The Agency estimates the total annualized cost of this provision to be $1,407,365 for all affected establishments.  The breakdown of these costs by NAICS code is shown in Table V-19 at the end of this program cost section.

Hygiene Areas and Practices

	The proposed standard requires employers to provide readily accessible washing facilities to remove beryllium from the hands, face, and neck of each employee working in a beryllium work area and also to provide a designated change room in workplaces where employees would have to remove their personal clothing and don the employer-provided protective clothing.  The proposed standard also requires that employees shower at the end of the work shift or work activity if the employee reasonably could have been exposed to beryllium at levels above the PEL or STEL, and if those exposures could reasonably be expected to have caused contamination of the employee's hair or body parts other than hands, face, and neck.
      In addition to other forms of PPE costed previously, for processes where hair may become contaminated, head coverings can be purchased at an annual cost of $28.37 per employee (Grainger, 2013a).  This could satisfy the requirement to avoid contaminated hair. If workers are covered by protective clothing such that no body parts (including their hair where necessary, but not including their hands, face, and neck) could reasonably be expected to have been contaminated by beryllium, and they could not reasonably be expected to be exposed to beryllium while removing their protective clothing, they would not need to shower at the end of a work shift or work activity.  OSHA notes that some facilities already have showers, and the Agency judges that all employers either already have showers where needed or will have sufficient measures in place to ensure that employees could not reasonably be expected to be exposed to beryllium while removing protective clothing.  Therefore, OSHA has preliminarily determined that employers will not need to provide any new shower facilities to comply with the standard.
       The Agency estimated the costs for the addition of a change room and segregated lockers based on the costs for acquisition of portable structures. The change room is presumed to be used in providing a transition zone from general working areas into beryllium-using regulated areas.  OSHA estimated that portable structures, adequate for 10 workers per establishment can be rented annually for $3,251 (Lerch, 2003), and that lockers could be procured for a capital cost of $407 -- or $48 annualized -- per establishment (Lab Safety, 2004).  This results in an annualized cost of $3,299 ($3,251 + $48) per facility to rent a portable change room with lockers.  OSHA estimates that the 10 percent of affected establishments unable to meet the proposed TWA PEL would require change rooms.  The Agency expects that, in many cases, a worker would simply be adding and later removing a layer of clothing (such as a lab coat, coverall, or shoe covers) at work, which might involve no more than a couple of minutes a day.  However, in other cases, a worker may need a full clothing change.  Taking all these factors into account, OSHA estimates that a worker using a change room would need 5 minutes per day to change clothes.  OSHA welcomes comment on this time estimate. At a production worker wage rate of $22.16 an hour (Production Occupation, SOC: 51-0000) and for 2 minutes (2/60 of an hour) per day for 250 days per year, this annual time cost to changing clothes is $184.68 per employee ((2/60) X 250 X $22.16).
      The Agency estimates the total annualized cost of the provision on hygiene areas and practices to be $389,241 for all affected establishments.  The breakdown of these costs by NAICS code can be seen in Table V-19 at the end of this program cost section.

Housekeeping

      The proposed rule specifies requirements for cleaning and disposing of beryllium-contaminated wastes.  The employer shall maintain all surfaces in beryllium work areas as free as practicable of accumulations of beryllium and shall ensure that all spills and emergency releases of beryllium are cleaned up promptly, in accordance with the employer's written exposure control plan and using a HEPA-filtered vacuum or other methods that minimize the likelihood and level of exposure.  The employer shall not allow dry sweeping or brushing for cleaning surfaces in beryllium work areas unless HEPA-filtered vacuuming or other methods that minimize the likelihood and level of exposure have been tried and were not effective.