DRAFT
Contents
Approved by Rob Connelly
Revised 11/21
38.1 Policy
38.2 Scope
38.3 Applicability
38.4 Exceptions
38.5 Roles and Responsibilities
38.6 Definitions
38.7 Required Work Processes
- Work Process A. General Requirements
- Work Process B. Procurement of Beryllium or Beryllium-Containing Materials
- Work Process C. Authorization to Work with Beryllium or Beryllium-Containing Materials
- Work Process D. Qualification and Training (Does Not Include Subcontractors)
- Work Process E. Beryllium Hazard Assessment
- Work Process F. Labeling and Disposal
38.8 Source Requirements
38.9 Reference Documents
Note:
đźš©đźš© Denotes a new section
đźš© Denotes the beginning of changed text within a section
🛑 Denotes the end of changed text within a section
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38.1 Policy
The Beryllium Safety Program at Lawrence Berkeley National Laboratory (Berkeley Lab) ensures exposures are minimized through limiting work with beryllium and through medical surveillance, exposure assessment, and controls.
38.2 Scope
The majority of Berkeley Lab work involving beryllium is nondestructive in nature. Beryllium is primarily part of an alloy found in everyday pieces of equipment such as chamber windows, targets, springs, foils, pins, connectors, and tools. These components are often handled by Laboratory personnel when installing or replacing them. Berkeley Lab does not routinely perform destructive operations such as milling, grinding, and other machining.
38.3 Applicability
The Beryllium Safety Program applies to Berkeley Lab employees, affiliates, and subcontractors who could be performing work that may include beryllium.
38.4 Exceptions
None
38.5 Roles and Responsibilities
Role |
Responsibility |
Environment, Health & Safety (EHS) Division |
|
Beryllium Safety Program Manager |
|
Line Management |
Ensures that personnel performing work with beryllium are properly trained and aware of beryllium-related safety issues |
Employees and Affiliates |
Follow all safety requirements when working with beryllium |
Subcontractors |
Conform to the requirements of applicable regulations and this EHS program |
38.6 Definitions
None
38.7 Required Work Processes
Work Process A. General Requirements
![](https://ehs.lbl.gov/wp-content/uploads/sites/2/2023/12/image-34.png)
Work Process B. Procurement of Beryllium or Beryllium-Containing Materials
Beryllium is on the Berkeley Lab Restricted Items list. If beryllium-containing material is ordered through the Laboratory’s procurement system, the Beryllium Safety Program Manager will receive notification from procurement seeking approval for the purchase. The Beryllium Safety Program Manager will contact the prospective buyer and ascertain the nature of the work to be accomplished with the material.
Work Process C. Authorization to Work with Beryllium or Beryllium-Containing Materials
Before personnel procure beryllium-containing materials, they must contact the Beryllium Safety Program Manager to obtain procurement approval and to determine if a hazard assessment is necessary before use. An authorization such as a reviewed and approved Work Planning and Control (WPC) Activity is required before work with beryllium-containing materials may begin.
Work Process D. Qualification and Training
Berkeley Lab’s WPC database Activity Manager includes beryllium hazards that an employee can add to an Activity, thus identifying if he or she works with beryllium in a destructive nature (fabricating, milling, grinding, etc.) or in a nondestructive nature (replacing beryllium-containing components in equipment, using targets, coated windows, tools, etc.). If the work involves destructive processes with beryllium, the employee must take the online Beryllium Hazard Communication course (EHS0342). If the work is nondestructive, the training is recommended.
Work Process E. Beryllium Hazard Assessment
If it has been determined that a hazard assessment is necessary for work involving beryllium, the Beryllium Safety Program Manager will perform a field assessment, document and communicate the appropriate exposure controls, and perform any necessary exposure monitoring.
Work Process F. Labeling and Disposal
Per 10 CFR Part 850, beryllium-contaminated or abated/cleaned items that meet the DOE release criteria for the general public, as demonstrated through wipe sampling, must still be labeled with beryllium labels that state: “Danger, Contaminated With Beryllium. Do Not Remove Dust By Blowing Or Shaking. Cancer and Lung Disease Hazard”. Per 10 CFR Part 850, the labels must be placed in a conspicuous place on the item. If items were to be labeled as such and then placed in metal recycling bins or regular trash dumpsters, this could present public relations concerns for the Lab and other problematic downstream issues. For this reason, the Lab is taking a conservative approach to managing beryllium-contaminated or abated/cleaned items that are no longer needed by disposing of these items as beryllium hazardous waste even though the items meet release criteria for the general public. The individual items will be handled during the removal, cleaning, or abatement process using IH prescribed controls and PPE including labeling of individual components along with the hazardous waste container(s). Additional hazardous waste management requirements are addressed in the ES&H Manual, Chapter 20.
38.8 Source Requirements
10 CFR 850, Chronic Beryllium Disease Prevention Program; Final Rule
DOE-STD-1187-2005, Beryllium-Associated Worker Registry Data Collection and Management Guidance
38.9 Reference Documents
LBNLChronic Beryllium Disease Prevention Program (CBDPP) Plan
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