Beryllium scope and definitions

Under 1915.1024(a)(1) this beryllium standard applies to occupational exposure to beryllium in all forms, compounds, and mixtures in shipyards except as limited by the exceptions in paragraphs (a)(2) and (a)(3). See the Scope and application in 1915.1024(a).

• For practical use: treat any beryllium-containing material, process, or operation on a shipyard site as covered unless it clearly fits one of the two listed exceptions.

Under 1915.1024(a)(2) finished articles that contain beryllium are not covered by this standard when the employer does not process them and they meet the HCS definition of an "article." See 1915.1024(a)(2) and the Hazard Communication Standard definition at 1910.1200(c).

• In plain terms: if the employer only receives, stores, or ships intact manufactured articles that contain beryllium and does not process or alter them, the beryllium standard does not apply.

Under 1915.1024(a)(3) materials that contain less than 0.1% beryllium by weight can be excluded if the employer has objective data showing employee exposure will remain below the action level as an 8‑hour TWA under any foreseeable conditions. See 1915.1024(a)(3).

• "Objective data" must accurately reflect workplace conditions that are the same as or more conservative than the employer’s operations (see definition of objective data in the standard). If you rely on this exclusion, keep the objective data records to demonstrate compliance.

Under 1915.1024(b) the action level for beryllium is 0.1 micrograms per cubic meter (µg/m3), calculated as an 8‑hour time‑weighted average (TWA). See the definition of Action level in 1915.1024(b).

• Practically: if an 8‑hour TWA exposure meets or exceeds 0.1 µg/m3 you have reached the action level and must follow the monitoring and other requirements tied to that threshold.

Under 1915.1024(b) "airborne exposure" means the exposure to airborne beryllium that would occur if the employee were not using a respirator. See the definition in 1915.1024(b).

• Why it matters: monitoring and PEL compliance are based on unprotected exposures; respirator use does not reduce the measured airborne exposure for determining whether monitoring, regulated areas, or controls are needed.

Under 1915.1024(b) a BeLPT (Beryllium lymphocyte proliferation test) measures blood lymphocyte proliferation when challenged with a soluble beryllium salt, and a "confirmed positive" means the person has had two abnormal BeLPT results, an abnormal and a borderline, or three borderline results within a 3‑year period (or a more reliable test indicating sensitization). See the BeLPT and Confirmed positive definitions in 1915.1024(b).

• In practice: a confirmed positive indicates beryllium sensitization and triggers medical follow‑up under the standard.

Under 1915.1024(b) a CBD diagnostic center must have a pulmonologist or pulmonary specialist on staff and on‑site facilities to perform pulmonary function testing (per American Thoracic Society criteria), bronchoalveolar lavage (BAL), and transbronchial biopsy; it must also be able to transfer BAL samples to a laboratory for appropriate testing within 24 hours and interpret biopsy and BAL results. See the CBD diagnostic center definition in 1915.1024(b).

• For employers: referrals for suspected CBD should go to centers meeting these capabilities to ensure proper diagnostic evaluation.

Under 1915.1024(c)(1) the 8‑hour TWA PEL for beryllium is 0.2 µg/m3, and under 1915.1024(d) the 15‑minute short‑term exposure limit (STEL) is 2.0 µg/m3 measured over 15 minutes. See the TWA PEL in 1915.1024(c)(1) and the STEL requirement in 1915.1024(d).

• Actionable takeaway: ensure controls keep employee exposures below 0.2 µg/m3 over an 8‑hour shift and below 2.0 µg/m3 over any 15‑minute sampling period.

Under 1915.1024(d)(1) the employer must assess the airborne exposure of each employee who is or may reasonably be expected to be exposed to airborne beryllium using either the performance option in 1915.1024(d)(2) or the scheduled monitoring option in 1915.1024(d)(3). See 1915.1024(d)(1).

• The performance option lets you use a combination of air monitoring and objective data to accurately characterize exposure; the scheduled option requires initial and periodic personal sampling per job classification and shift.

Under 1915.1024(d)(3)(i) and (ii) initial monitoring must use one or more personal breathing zone air samples that reflect exposure of employees on each shift, for each job classification, and in each work area for both 8‑hour TWA and 15‑minute short‑term exposures; and under 1915.1024(d)(3)(iii) you may sample a representative fraction of employees who perform the same tasks on the same shift in the same area. See 1915.1024(d)(3)(i)–(iii).

• Practical tip: sample those likely to have the highest exposures and ensure samples cover each shift and job classification until representative results are established.

Under 1915.1024(d)(3)(iv) you may discontinue monitoring for employees represented by initial sampling if results are below the action level and at or below the STEL. Under 1915.1024(d)(3)(v)–(viii), if monitoring shows exposures at/above the action level but at or below the TWA PEL you must repeat monitoring within six months; if above the TWA PEL repeat within three months; if below the action level you must repeat monitoring every six months until two consecutive measurements (≥7 days apart) are below the action level before discontinuing; and if above the STEL you must repeat short‑term monitoring within three months until two consecutive measurements (≥7 days apart) are below the STEL. See 1915.1024(d)(3)(iv)–(viii).

• Keep monitoring records and schedule repeat tests on time when any threshold is exceeded to remain compliant.

Under 1915.1024(d)(6)(i) employers must notify each affected employee of exposure assessment results within 15 working days after completing the assessment, either individually in writing or by posting the results where accessible to those employees. If the assessment shows exposure above the TWA PEL or STEL, the written notice must also describe corrective actions being taken, per 1915.1024(d)(6)(ii). See 1915.1024(d)(6)(i)–(ii).

• Action step: prepare a timely written notification (or post where employees can access it) and include planned corrective measures whenever limits are exceeded.

Under 1915.1024(d)(7)(i) employees whose exposures are measured (and their representatives) must be given the opportunity to observe any required exposure monitoring. If observation requires entry into an area where protective clothing or equipment is required, the employer must provide and ensure observers use appropriate protection at no cost under 1915.1024(d)(7)(ii) and ensure observers follow other safety procedures under 1915.1024(d)(7)(iii). See 1915.1024(d)(7)(i)–(iii).

• In practice: plan monitoring events so observers can attend safely, supply suitable PPE, and brief observers on site safety rules.

The standard requires that all air monitoring samples used to satisfy paragraph (d) be evaluated by a laboratory able to measure beryllium with an accuracy of ±25% at a 95% statistical confidence level for airborne concentrations at or above the action level. See the laboratory accuracy requirement described in 1915.1024(d)(6).

• Practical implication: choose an accredited analytical lab with documented performance at low µg/m3 levels to meet this accuracy standard.

Under 1915.1024(e)(1) the employer must establish and maintain a regulated area wherever employees are, or can reasonably be expected to be, exposed above the TWA PEL or STEL. Under 1915.1024(e)(3) access must be limited to authorized workers, employee representatives observing monitoring under 1915.1024(d)(7), and persons authorized by law. See 1915.1024(e)(1) and (3).

• Practically: post demarcation and restrict entry by signage, training, and access controls until exposures are reduced to acceptable levels.

Under 1915.1024(e)(4) the employer must provide and ensure that each employee entering a regulated area uses respiratory protection in accordance with paragraph (g) and personal protective clothing and equipment in accordance with paragraph (h) of the standard. See 1915.1024(e)(4)(i)–(ii).

• In short: in regulated areas employers must supply and enforce the use of required respirators and protective clothing as specified in the related paragraphs.

Under 1915.1024(f)(1)(i) the written exposure control plan must include: (A) a list of operations and job titles reasonably expected to involve beryllium exposure; (B) a list of engineering controls, work practices, and respiratory protection required by paragraph (f)(2); (C) a list of personal protective clothing and equipment required by paragraph (h); (D) procedures to ensure containment integrity; and (E) procedures for removing, cleaning, and maintaining protective clothing and equipment. See 1915.1024(f)(1)(i)(A)–(E).

• Quick checklist: job lists, control measures, PPE lists, containment procedures, and cleaning/maintenance protocols must all be written and available.

Under 1915.1024(f)(1)(ii) the employer must review and evaluate the plan at least annually and update it when (A) changes could create new exposures, (B) an employee is eligible for medical removal, referred for CBD evaluation, or shows symptoms, or (C) the employer believes new exposures are occurring. Under 1915.1024(f)(1)(iii) the employer must make a copy accessible to each employee who is or can reasonably be expected to be exposed in accordance with the Access to Employee Exposure and Medical Records standard at 1910.1020(e). See 1915.1024(f)(1)(ii)–(iii).

• In practice: schedule annual reviews, revise the plan promptly when conditions change, and keep copies available per the records access rules.

Under 1915.1024(d)(3)(iv) employer must sample the employee(s) expected to have the highest airborne exposure when using representative sampling, and under 1915.1024(d)(3)(iii) you may sample a representative fraction of employees performing the same tasks. See 1915.1024(d)(3)(iv).

• Practical rule: start by sampling the workers most likely to have the highest exposures (worst‑case tasks/locations) to ensure representative coverage.

Under 1915.1024(b) "objective data" means information (for example, industry air monitoring data or calculations based on a substance composition) demonstrating airborne exposure to beryllium for a specific product, material, or process. Under the performance option in 1915.1024(d)(2) employers may use a combination of air monitoring data and objective data sufficient to accurately characterize airborne exposure, provided the objective data reflect workplace conditions that are the same as or more conservative than the employer’s operations. See the definition of objective data in 1915.1024(b) and the performance option in 1915.1024(d)(2).

• Use objective data only when it accurately represents your processes, controls, and conditions; document how the data applies to your workplace.

Under 1915.1024(d)(6)(ii) when an exposure assessment indicates airborne exposure is above the TWA PEL or STEL, the employer’s written notification must describe the corrective action being taken to reduce airborne exposure to or below the exceeded limit where feasible corrective action exists but had not been implemented when monitoring was conducted. See 1915.1024(d)(6)(ii).

• Practical note: include timelines, engineering or work practice changes, interim controls, and respirator use plans in the notice so affected employees know what actions are underway.

Under 1915.1024(e)(2) the employer must identify each regulated area in accordance with paragraph (m)(2) of the standard; that means follow the marking/demarcation requirements specified in [1915.1024(m)(2)]. See 1915.1024(e)(2) and consult 1915.1024(m) for the specific demarcation language.

• In short: regulated areas must be clearly identified per the standard’s marking rules so workers know where beryllium exposures exceed limits.

The employer must first use engineering and work practice controls to reduce and maintain airborne beryllium at or below the TWA PEL and STEL, and may use respiratory protection only when those controls are not feasible or do not reduce exposures to the PELs. See Requirement in 1915.1024(f).

• If engineering and work practice controls cannot bring exposures to or below the PELs, the employer must still implement those controls to reduce exposures to the lowest feasible level and supplement them with respirators as required by paragraph (g).
• Employers cannot rely on rotating employees to meet PELs; rotation is prohibited under 1915.1024(f)(3).

No; the employer must not rotate employees to different jobs to achieve compliance with the PELs. See the explicit prohibition in 1915.1024(f)(3).

• Rotation cannot be used as a substitute for engineering controls, work practice controls, or respiratory protection required by the standard.

The employer must ensure employees use respiratory protection whenever exposures exceed, or can reasonably be expected to exceed, the TWA PEL or STEL during specified situations: installation of controls, operations where controls are not feasible, operations where feasible controls are insufficient, and when an eligible employee chooses to remain in a job at or above the action level. See 1915.1024(g)(1)(i)-(iv).

• Examples include: while installing ventilation, during maintenance or non-routine tasks where controls can't be used, and where controls have been applied but exposures still exceed the PELs.
• The rule also requires employers to provide respirators at no cost to employees (see 1915.1024(g)(1)).

Respirator selection and use must follow OSHA's Respiratory Protection standard, meaning the employer must implement a written respiratory protection program consistent with [29 CFR 1910.134] (e.g., selection, fit testing, training, maintenance, and medical evaluation). See 1915.1024(g)(2) and 1910.134.

• The program must include medical evaluations, fit testing for tight-fitting respirators, user training, respirator inspection and maintenance, and procedures for cleaning, storage, and recordkeeping as required by 1910.134.
• Employers must provide respirators at no cost to employees as required by 1915.1024(g)(1).

The employer must provide a powered air-purifying respirator (PAPR) instead of a negative-pressure respirator when respiratory protection is required, the employee requests a PAPR, and the PAPR provides adequate protection under the respiratory protection program. See 1915.1024(g)(3)(i)-(iii).

• The PAPR must be provided at no cost to the employee when these conditions are met.
• Adequacy is determined under the employer’s respiratory protection program consistent with 1915.1024(g)(2).

The employer must provide appropriate personal protective clothing and equipment at no cost when airborne exposures exceed or can reasonably be expected to exceed the TWA PEL or STEL, ensure employees remove required PPE at shift end or task completion, prevent removal methods that disperse beryllium, and ensure reusable PPE is properly cleaned, laundered, repaired, and replaced. See 1915.1024(h) and its subsections 1915.1024(h)(2) and 1915.1024(h)(3)(i)-(ii).

• PPE must not be removed in a way that disperses beryllium (no blowing or shaking) and employees with expected exposures above the PEL/STEL may not remove PPE from the workplace unless it has been cleaned per 1915.1024(h)(3)(ii).
• Reusable PPE must be maintained to preserve its effectiveness (1915.1024(h)(3)(i)).

The employer must use cleaning methods that minimize airborne exposure when cleaning beryllium dust; dry sweeping, brushing, and compressed air are prohibited where they cause or can reasonably be expected to cause airborne exposures above the TWA PEL or STEL, and if such methods are used, the employer must provide respirators and PPE. See 1915.1024(j)(1)-(5).

• Use methods such as HEPA-filtered vacuuming or wet cleaning to minimize dust re-entrainment where feasible.
• If dry sweeping, brushing, or compressed air are used only because safer methods are not effective or safe, the employer must provide respiratory protection and required PPE in accordance with 1915.1024(g) and 1915.1024(h).

The employer must make medical surveillance available at no cost and at a reasonable time and place to employees who are or are reasonably expected to be exposed at or above the action level more than 30 days per year, employees who show signs or symptoms of CBD or other beryllium-related effects, and employees whose PLHCP recommended periodic surveillance. See 1915.1024(k)(1)(i)(A)-(C).

• The surveillance must be performed by or under the direction of a licensed physician per 1915.1024(k)(1)(ii).

The employer must provide a medical exam within 30 days after determining an employee meets the surveillance criteria (unless examined within the last two years), at least every two years for continuing eligible employees, and at termination if the employee meets the criteria at termination unless an exam was provided within the prior six months. See 1915.1024(k)(2)(i)-(iii).

• Keep track of exam dates to meet the two-year periodic requirement and the termination timing described in the standard.

The employer must ensure the PLHCP offers a medical and work history (including smoking), a physical exam focusing on the respiratory system, a skin exam, pulmonary function tests (FVC and FEV1) per American Thoracic Society guidelines, and a standardized BeLPT (or equivalent) at the first exam and at least every two years unless the employee is confirmed positive. See 1915.1024(k)(3)(ii)(A)-(E).

• Pulmonary function testing must follow ATS guidelines as specified in 1915.1024(k)(3)(ii)(D).
• The BeLPT cadence is described in 1915.1024(k)(3)(ii)(E).

A low-dose CT scan should be offered when the PLHCP recommends it after considering the employee’s beryllium exposure history and other risk factors such as smoking, family history, sex, age, and existing lung disease. See 1915.1024(k)(3)(ii)(F).

• The decision is individualized and made by the PLHCP as part of the medical surveillance process.

If a BeLPT result is other than normal, the employer must offer a follow-up BeLPT within 30 days (unless the employee is already confirmed positive), and ensure the sample is analyzed by a laboratory certified under the College of American Pathologists/CLIA guidelines to perform the BeLPT. See 1915.1024(k)(3)(ii)(E) and the standard text regarding follow-up and laboratory certification requirements.

• Timely follow-up testing and use of a certified lab are required to confirm sensitization findings and guide further medical actions.

The employer must ensure the PLHCP has a copy of the standard and, if known, provide a description of the employee’s former and current job duties related to beryllium exposure, the employee’s former and current airborne exposure levels, a description of PPE and respirator use (including durations), and any relevant previous employment-related medical exam records with the employee’s written consent. See 1915.1024(k)(4)(i)-(iv).

• Supplying this information helps the PLHCP make informed medical judgments about surveillance and any needed follow-up.

The employee must receive a written medical report within 45 days that explains the results and any detected conditions, recommendations (including respirator or exposure limitations), referrals to a CBD diagnostic center if confirmed positive or diagnosed, and recommendations for surveillance or medical removal as appropriate. The employer must receive a written medical opinion within 45 days that documents the exam date, compliance with the standard’s examination requirements, any recommended respirator limitations, and confirmation that the PLHCP explained results to the employee; additional recommendations regarding exposure limits or referrals require the employee’s written authorization. See 1915.1024(k)(5) and 1915.1024(k)(6).

• Both reports must be provided within 45 days of the examination (including any required follow-up BeLPT).
• The employer must give the employee a copy of the PLHCP’s written opinion within 45 days as well (1915.1024(k)(6)(vi)).

If a PLHCP recommends referral or the employee presents a physician’s report confirming positive or CBD diagnosis, the employer must provide a CBD diagnostic center evaluation at no cost that is mutually agreed upon and must schedule the evaluation within 30 days of receiving the referral recommendation or the employee’s report. See 1915.1024(k)(7)(i)-(ii).

• The employer must also ensure the CBD center offers tests the physician deems appropriate (e.g., pulmonary function, BAL, transbronchial biopsy) as part of the evaluation (1915.1024(k)(7)(ii)).

Yes; an employee eligible for medical removal may choose to remain in the job with airborne exposure at or above the action level, but if they do so the employer must ensure respiratory protection is provided and used in accordance with the standard. See 1915.1024(g)(1)(iv) and 1915.1024(l)(2)(ii).

• The decision to remain must still meet the respiratory protection and exposure-control requirements of the standard and the employer’s written exposure control plan.

No; employees who have reasonably expected exposures above the TWA PEL or STEL may not remove required personal protective clothing and equipment from the workplace unless it has been cleaned in accordance with the standard. See 1915.1024(h)(2)(iii) and the cleaning restrictions in 1915.1024(h)(3)(ii).

• Employers must provide facilities or procedures to clean PPE so it can be removed without dispersing beryllium into the workplace or beyond.

Cleaning equipment must be handled and maintained in a manner that minimizes airborne exposure and prevents re-entrainment of beryllium back into the workplace. See 1915.1024(j)(5).

• Examples include using HEPA-filtered vacuums, maintaining filters and collection bags, using wet methods where appropriate, and following procedures that prevent shaking or other actions that re-suspend dust.

Yes; the PLHCP must advise the employee of the risks and benefits of participating in the medical surveillance program and inform the employee of their right to opt out of any or all parts of the medical examination. See 1915.1024(k)(3)(i).

• Employers must still make the full set of required examinations available at no cost to eligible employees per 1915.1024(k)(1)(i).

Recommendations about limitations on the employee's airborne exposure, referrals to a CBD diagnostic center, continued periodic medical surveillance, and recommendations for medical removal when the employee is confirmed positive or diagnosed with CBD may be included in the PLHCP’s written opinion to the employer only if the employee provides written authorization. See 1915.1024(k)(6)(ii)-(v).

• The written opinion the employer does receive without employee authorization must still state the exam date, that the exam met the standard’s requirements, any respirator limitations, and that the PLHCP explained results to the employee (1915.1024(k)(6)(i)).

The employer must provide a medical examination within 30 days after determining the employee meets the action-level exposure criterion, unless the employee has received an exam under this standard within the last two years. See 1915.1024(k)(2)(i)(A).

• If the employee previously had an exam under the standard within two years, the 30-day requirement does not apply for that subsequent determination.

Respiratory protection must be used during maintenance and repair or non-routine tasks when engineering and work practice controls are not feasible and airborne exposure exceeds or can reasonably be expected to exceed the PELs, and during operations where all feasible controls are implemented but still do not reduce exposures to or below the PELs. See 1915.1024(g)(1)(ii)-(iii).

• In short: respirators are required for short-term tasks where controls can't be used and for any work where even the best feasible controls are insufficient.

Yes. Tests that the examining physician deems appropriate may be performed at another location if the employer and the employee mutually agree to that arrangement. See 1915.1024(k)(7)(iii).

• Make the agreement in writing when possible so there is a clear record of the alternate location and who pays for it.
• Ensure the alternate facility can provide the specific tests required by the PLHCP and that results are shared with the CBD diagnostic center and the employee as required by the standard.

The employee must receive a written medical report from the CBD diagnostic center containing the items described in paragraphs (k)(5)(i), (k)(5)(ii), (k)(5)(iv), and (k)(5)(v), and the PLHCP must explain the examination results to the employee within 30 days of the examination. See 1915.1024(k)(7)(iv).

• Employers should confirm the CBD diagnostic center provides the required written report and that the PLHCP meets the 30-day explanation requirement.
• If the employee does not receive the report or explanation within 30 days, the employer should follow up with the CBD diagnostic center to obtain and deliver the information promptly.

Yes. The written medical opinion from the CBD diagnostic center may include additional items (for example, those listed in (k)(6)(ii), (k)(6)(iv), and (k)(6)(v)) if the employee provides written authorization to release that extra information. See 1915.1024(k)(7)(v).

• Employers must obtain and retain the employee’s written authorization before sharing any medical information beyond the baseline opinion allowed by (k)(6)(i).
• The written medical opinion provided without the employee’s authorization must contain only the information specified in 1915.1024(k)(6)(i).

An employee is eligible for medical removal if they work in a job with airborne exposure at or above the action level and either (a) provide a written medical report showing a confirmed positive CBD finding or recommending removal, or (b) the employer receives a written medical opinion recommending removal. See 1915.1024(l)(1).

If eligible, the employer must offer the employee a choice between:

• removal as described in 1915.1024(l)(3); or

• remaining in the job with exposures at or above the action level provided the employer supplies and ensures the employee uses respirators that comply with 1915.1024(g).

• Employers should document the employee’s choice in writing and follow the medical recommendations that triggered eligibility (see 1915.1024(l)(1)(i)–(ii)).

If an employee chooses removal and a comparable job with airborne exposures below the action level is available (and the employee is qualified or can be trained within one month), the employer must move the employee to that job; if comparable work is not available, the employer must maintain the employee's base earnings, seniority, and other rights and benefits for six months or until comparable work becomes available, whichever occurs first. See 1915.1024(l)(3)(i)–(ii).

The employer's obligation to provide medical removal protection benefits is reduced to the extent the employee receives compensation for lost earnings from publicly or employer-funded programs or income from another employer made possible by the removal, per 1915.1024(l)(4).

• Keep clear records of comparable positions, training offers, pay and benefits maintained, and any outside compensation to document how any reductions were calculated.

The employer must post legible, readily visible warning signs at each approach to a regulated area using the exact legend specified in the standard, and must include beryllium in the hazard communication program and provide initial and annual training that meets HCS requirements. See 1915.1024(m)(2)(ii) for sign text and 1915.1024(m)(3) and 29 CFR 1910.1200(h) for training details.

Key points:

• Signs must be legible, visible, and contain the legend: "DANGER REGULATED AREA BERYLLIUM MAY CAUSE CANCER CAUSES DAMAGE TO LUNGS AUTHORIZED PERSONNEL ONLY WEAR RESPIRATORY PROTECTION AND PERSONAL PROTECTIVE CLOTHING AND EQUIPMENT IN THIS AREA" (1915.1024(m)(2)(ii)(B)).
• Employers must include beryllium in the hazard communication program and provide the HCS-required information and training 1915.1024(m)(1)(i)–(ii).
• Training must be provided at initial assignment and repeated annually, and must cover the health hazards (including CBD symptoms), exposure control plan locations, PPE selection and use, medical surveillance and removal protection, contents of the standard, and records access rights (1915.1024(m)(3)(i)–(ii)).