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OSHA 1910.1024AppA

Beryllium work area operations

Subpart Z

19 Questions & Answers
10 Interpretations

Questions & Answers

Under 1910.1024(b) and Appendix A, what is a "beryllium work area"?

A beryllium work area is any work area where materials that contain at least 0.1 percent beryllium by weight are processed during one of the operations listed in Appendix A, or where employees are, or can reasonably be expected to be, exposed to airborne beryllium at or above the action level. See paragraph (b) of 1910.1024 and Appendix A to 1910.1024 for the regulatory text and the trigger table (Table A.1).

Under Appendix A to 1910.1024, when does processing of a material create a beryllium work area because of beryllium content?

If the material contains at least 0.1 percent beryllium by weight and the employer performs one of the operations listed in Table A.1 under the appropriate material column, that processing creates a beryllium work area. Appendix A explicitly ties the 0.1% weight threshold and the listed operations to the requirement to establish a work area; see Appendix A to 1910.1024 and 1910.1024(b).

If a material contains less than 0.1% beryllium by weight, does Appendix A automatically require a beryllium work area when listed operations are performed?

No — Appendix A’s listed operations do not automatically create a beryllium work area for materials containing less than 0.1% beryllium by weight. Appendix A applies to materials that contain at least 0.1 percent beryllium by weight; however, a beryllium work area may still be required if employees are, or can reasonably be expected to be, exposed to airborne beryllium at or above the action level. See Appendix A to 1910.1024 and 1910.1024.

Under Appendix A, does abrasive blasting trigger the requirement to establish a beryllium work area?

Yes — abrasive blasting is a listed operation that triggers a beryllium work area when performed on materials that contain at least 0.1% beryllium by weight. Abrasive blasting appears in Table A.1 in the columns covering beryllium metal alloy, beryllium composite/metal operations, and beryllium oxide operations. See Table A.1 in Appendix A to 1910.1024.

Under 1910.1024 App A, does welding of beryllium-containing materials require establishing a beryllium work area?

Yes — welding is listed in Appendix A and requires a beryllium work area when welding is performed on materials that contain at least 0.1% beryllium by weight. Check Appendix A to 1910.1024 for the table entries and 1910.1024 for the statutory definition of a beryllium work area.

Does common machining (for example, CNC machining, milling, or turning) trigger a beryllium work area under Appendix A?

Yes — many machining operations such as CNC machining, milling, turning, and similar machining processes are listed in Table A.1 and will establish a beryllium work area when performed on materials containing at least 0.1% beryllium by weight. See Appendix A (Table A.1) to 1910.1024 and 1910.1024.

Under Appendix A, does powder handling or powder processing always create a beryllium work area?

Powder handling and related powder operations are listed in Table A.1 for some material columns (for example, beryllium composite and beryllium oxide operations) and will create a beryllium work area when performed on materials with at least 0.1% beryllium by weight. However, powder handling is not listed under every column (for example, it is not listed in the beryllium metal alloy column), so you must consult the appropriate column for the material type. See Appendix A to 1910.1024 (Table A.1) and 1910.1024.

Appendix A lists certain temperature qualifiers (for example, brazing or firing >1,100 °C). Do those temperature limits matter for triggering a beryllium work area?

Yes — when Appendix A specifies a temperature qualifier (for example, brazing or firing above 1,100 °C), the operation triggers a beryllium work area only when performed under the described temperature condition. Follow the exact operation descriptions in Table A.1 of Appendix A to 1910.1024 and the definition in 1910.1024.

If an operation is not listed in Table A.1 of Appendix A, can an employer still be required to establish a beryllium work area?

Yes — even if an operation is not listed in Appendix A’s table, an employer must establish a beryllium work area when employees are, or can reasonably be expected to be, exposed to airborne beryllium at or above the action level. Appendix A lists common triggering operations, but the exposure-based criterion in 1910.1024 also requires a work area when exposures meet or exceed the action level. See Appendix A to 1910.1024 and 1910.1024.

Under Appendix A, how do I know which column of Table A.1 applies to my material—metal alloy, composite, or oxide?

Use the material category column label that matches the form and composition of your material: the table is divided into columns for "beryllium metal alloy operations (generally <10% beryllium by weight)," "beryllium composite operations (generally >10% beryllium by weight) and beryllium metal operations," and "beryllium oxide operations." Choose the column that best matches your material’s type and compare your operation to the listed operations in that column. See Table A.1 in Appendix A to 1910.1024 and 1910.1024 for the appendix structure and definitions.

Under 1910.1024 App A, does laser cutting or laser machining of beryllium-containing materials require establishing a beryllium work area?

Yes — laser cutting, laser machining, and related laser operations are listed in Table A.1 and will require a beryllium work area when performed on materials containing at least 0.1% beryllium by weight. See Appendix A (Table A.1) to 1910.1024 and 1910.1024.

How should an employer use Appendix A to decide whether to designate a beryllium work area?

First identify whether the material contains at least 0.1% beryllium by weight; second, determine which material column (metal alloy, composite, oxide) fits the material; third, check if the specific operation appears in Table A.1 of Appendix A to 1910.1024. If the operation is listed for that material type, designate a beryllium work area. Even if the operation is not listed, designate a work area whenever employees are, or can reasonably be expected to be, exposed to airborne beryllium at or above the action level per 1910.1024.

Does abrasive sawing or sawing with a tooth blade trigger a beryllium work area under Appendix A?

Yes — sawing operations are listed in Table A.1 (including "abrasive sawing" and "sawing (tooth blade)" in the appropriate columns) and will establish a beryllium work area when performed on materials that contain at least 0.1% beryllium by weight. See Appendix A to 1910.1024 (Table A.1) and 1910.1024.

Are manual tasks such as filing by hand or hand brushing included in Appendix A triggers for beryllium work areas?

Yes — certain hand operations like "filing by hand" and "brushing" are listed in Table A.1 in the columns for beryllium composite and beryllium oxide operations; when performed on materials with at least 0.1% beryllium by weight, they establish a beryllium work area. Consult Appendix A (Table A.1) and 1910.1024 for details.

Does torch cutting (oxy-acetylene) of beryllium-containing materials require a beryllium work area under Appendix A?

Yes — torch cutting (i.e., oxy-acetylene) is listed in Table A.1 and will trigger a beryllium work area when performed on materials that contain at least 0.1% beryllium by weight. See Appendix A to 1910.1024 (Table A.1) and 1910.1024.

Do mixing, pressing, or tape casting operations trigger beryllium work areas under Appendix A?

Yes — operations such as mixing, powder pressing, and tape casting appear in Table A.1 for the appropriate material columns (notably beryllium composite and beryllium oxide operations) and will require a beryllium work area when applied to materials with at least 0.1% beryllium by weight. See Appendix A (Table A.1) to 1910.1024 and 1910.1024.

If a process includes several steps, and at least one step is listed in Appendix A for my material type, do I have to designate the whole area as a beryllium work area?

Yes — if any operation performed on materials that contain at least 0.1% beryllium by weight matches a listed operation in the applicable column of Table A.1, the employer must establish a beryllium work area for the workplace where that processing occurs. See Appendix A to 1910.1024 (Table A.1) and 1910.1024.

Does simple storage of parts or finished articles that contain ≥0.1% beryllium automatically create a beryllium work area under Appendix A?

No — simple storage or presence of beryllium-containing parts does not automatically create a beryllium work area under Appendix A, because Appendix A’s trigger is processing during the listed operations or employee exposure at/above the action level. However, if storage activities (for example, handling that generates dust or on-site movement) lead to airborne beryllium exposures at or above the action level, a beryllium work area must be established per 1910.1024 and Appendix A.

Where can I find the official list of operations that trigger the requirement to establish beryllium work areas?

The official list is Table A.1 in Appendix A to 1910.1024. The main beryllium standard and definitions are in 1910.1024. Check both the standard and Appendix A when making your compliance determination.