Ensure that Members of the Workforce complete the training identified in ESH100.2.IH.24 prior to performing the indicated work activity or fulfilling the indicated role.

Note: See Sandia corporate procedure HR100.2.1, Identify and Complete Sandia Required Training for all Members of the Workforce.

Identify, Evaluate, and Control Beryllium

Managers

Ensure that:

• Potential hazards associated with beryllium and known or potential beryllium contamination are identified, evaluated, and controlled.
• The division ES&H team industrial hygienist is contacted for an exposure assessment of potential hazards, as well as to determine whether a beryllium operational area or beryllium activity exists.
• Any control measures specified as a result of the industrial hygiene exposure assessment are implemented and maintained.
• The division ES&H team industrial hygienist is contacted to re-evaluate potential hazards associated with beryllium or beryllium contamination when a change in workplace conditions indicates a new or increased hazard exists.
• When feasible, engineering or administrative controls are used to mitigate or abate beryllium exposures to below the occupational exposure limit.

Identify, Evaluate, and Control Beryllium

Members of the Workforce

Use safe work practices, applicable control measures and personal protective equipment to mitigate and abate exposures to beryllium and to control the spread of beryllium contamination.

Ensure that:

• The number of Members of the Workforce and the number of opportunities for Members of the Workforce to be exposed to airborne beryllium when planning new work is minimized.
• A site-specific Chronic Beryllium Disease Prevention Program Implementation Plan (CBDPP-IP) is developed and implemented for beryllium operational areas and beryllium activities.
• CBDPP-IPs address all of the applicable requirements in this section.
• The CBDPP-IP is provided to the Beryllium Program subject matter expert to approve, when it is initially developed or significantly changed subsequent to initial approval.
• The CBDPP-IP is written in accordance with the requirements found in ESH100.2.GEN.3, Develop and Use Technical Work Documents).

Ensure that:

• Members of the Workforce are provided with personal protective clothing and equipment and that it is appropriately used and maintained, where dispersible forms of beryllium may contact skin, enter openings in skin, or contact eyes, including where:
  • Exposure monitoring has established that airborne concentrations of beryllium are at or above the action level (regulated area).
  • Measured or presumed removable surface contamination levels are above 3 µg Be/100 cm² in a beryllium operational area.
  • Any beryllium-associated worker requests the use of personal protective clothing and equipment (including respiratory protection) for protection against airborne beryllium, regardless of measured exposure levels.
  • The division ES&H team industrial hygienist specifies protective clothing and equipment for Members of the Workforce in areas shown to have removable contamination above 0.2 µg Be/100 cm².
• Procedures for donning, doffing, handling, and storing protective clothing and equipment are established that address the following, as applicable:
  • Instructs beryllium workers not to exit beryllium operational areas with contamination on their bodies or their personal clothing.
  • Instructs beryllium workers not to exchange their personal clothing for full-body protective clothing and footwear before they begin work in regulated areas.
  • Instructs beryllium workers to remove beryllium-contaminated protective clothing and equipment from areas that contain beryllium, unless authorized by management through the use of the Chronic Beryllium Disease Prevention Program-Implementation Plan (CBDPP-IP), to launder, clean, maintain, or dispose of the clothing and equipment.
  • Instructs beryllium workers not to remove beryllium from protective clothing and equipment by blowing, shaking, or other means that may disperse beryllium into the air.
  • Requires cleaning, laundering, repair, or replacement of protective clothing and equipment as needed to maintain effectiveness.
  • Requires placing beryllium-contaminated protective clothing and equipment, when removed for laundering, cleaning, maintenance, or disposal, in containers that prevent the dispersion of beryllium dust. These containers must be labeled in accordance with the requirements under the Warning Signs and Labels section.
• Organizations that launder or clean beryllium contaminated protective clothing or equipment are informed in writing that exposure to beryllium is potentially harmful, and they are informed in writing of the manner in which clothing and equipment should be laundered or cleaned to prevent the release of airborne beryllium.

Ensure that:

• Surfaces contaminated with beryllium dusts and waste are maintained below a removable contamination level of 3 µg Be/100 cm² during non-operational periods. Non-operational periods are post-shift or at the logical end of an activity involving the release of airborne beryllium particulates.
• Floors and surfaces in areas where beryllium is present are cleaned using a wet method, high-efficiency particulate air (HEPA) vacuum, or sticky tack cloths that avoid the production of airborne dust.
• Compressed air or dry methods are not used for such cleaning.
• Only HEPA filtered portable or mobile vacuum units are used to clean beryllium-contaminated areas.
• Cleaning equipment, such as a HEPA vacuum, used to clean beryllium-contaminated surfaces, is labeled as not to be used for non-hazardous materials.

Ensure that the following actions are taken for a regulated area:

• The regulated area:
  • Is demarcated from the rest of the workplace in a manner to adequately alert Members of the Workforce to the boundaries of such areas;
  • Has limited access to authorized persons; and
  • Has a documented record of all individuals who enter (these records must include the name, date, time in/out, and work activity).
• Food, beverages, and tobacco products are not used, nor are cosmetics applied in regulated areas.
• Members of the Workforce are prevented from exiting regulated areas with contamination on their bodies or their personal clothing.
• Separate facilities free of beryllium contamination are provided where Members of the Workforce change into and/or store personal clothing and clean protective clothing and equipment in order to prevent cross-contamination.
• Change rooms or areas that are used to remove beryllium-contaminated clothing and protective equipment are kept under negative pressure or are located in such a way as to minimize dispersion of beryllium from the regulated area into clean work areas.
• Hand washing and shower facilities are provided for Members of the Workforce (beryllium workers) who work in regulated areas.
• Members of the Workforce (beryllium workers) who work in regulated areas shower at the end of each work shift.
• Lunchroom facilities are provided that are readily accessible to beryllium workers; tables for eating are free of beryllium; and no Member of the Workforce in a lunchroom facility is exposed at anytime to beryllium at or above the action level.
• Beryllium workers do not enter lunchroom facilities wearing or carrying personal protective equipment, unless surface beryllium has been removed from clothing and equipment by high-efficiency particulate air (HEPA) vacuum or other methods that remove beryllium without dispersing it.
• Change room areas, shower, and hand washing facilities, and lunchroom facilities comply with 29 Code of Federal Regulations (CFR) 1910.141, Sanitation.

Managers and Space Owners

Ensure that contaminated buildings and areas have a Chronic Beryllium Disease Prevention Program-Implementation Plan (CBDPP-IP) and are managed using one of the following methods:

• Mothballing the building or area, includes securing access through locks and postings.
  • Areas in a building can only be mothballed if they can be completely isolated, for instance by isolated ventilation systems, floor to ceiling walls, and lockable doors.
• Decontaminating the building or area to meet industrial hygiene post-decontamination verification requirements.
• Continuing work in the building or area as a beryllium operational area.

Ensure that:

• Equipment release procedures and practices to minimize the potential for the inadvertent transport of beryllium contamination to uncontrolled areas (non-beryllium areas) are addressed in a Chronic Beryllium Disease Prevention Program-Implementation Plan (CBDPP-IP). Address, at a minimum:
  • Decontamination of equipment and other items; confirmation of decontamination is obtained through wipe surface sampling (performed by/or at the direction of the division ES&H team industrial hygienist ).
  • Labeling of released equipment and other items.
  • Release letter notification (beryllium equipment release letter) and letters of recipient's commitment.
  • Containerization and containment.
  • Beryllium risk assessments.
• A log, database, or other means of tracking items for release from operational areas and regulated areas is established.
• A beryllium equipment release letter is used to notify the recipient of the following:
  • Contamination control requirements.
  • An explanation of where the contamination exists.
  • An explanation of the hazards associated with beryllium and the controls required.
  • The requirement of a recipient’s commitment to accept the item or equipment.
• Table 1 and the non-beryllium area logic flow diagram are used to determine release requirements.

• For releases to a non-beryllium area or the general public, contact the appropriate division ES&H team industrial hygienist.
• Decontaminate the equipment externally and to the extent feasible internally, so that the removable beryllium surface contamination has been determined to not exceed 0.2 µg Be/100 cm² as established through representative wipe sampling.
• The equipment or item is labeled in accordance with the Warning Signs and Labels section.
• A beryllium equipment release letter is sent and a corresponding written recipient's commitment is received prior to release of the equipment or other item.
• The equipment release letter is used in its entirety and is prepared on Sandia National Laboratories letterhead. Any modifications to this release letter, other than those noted in the template, must be approved by the Beryllium Program subject matter expert or designee.
• All correspondence regarding released equipment and other items is archived by the organization releasing the equipment and made available for review upon request.

• An approved Chronic Beryllium Disease Prevention Program-Implementation Plan (CBDPP-IP) is in place prior to release of equipment to another operational area or regulated area within SNL-controlled premises:
  • The equipment or item is labeled and placed in sealed, impermeable bags or containers to prevent the release of beryllium dust during handling and transportation. Label the bags, container, and enclosures that are used. If plastic bags are used, double-bag the equipment or item.

• An approved Chronic Beryllium Disease Prevention Program Implementation Plan (CBDPP-IP) is in place prior to the release of equipment to operational areas outside of SNL-controlled premises at other DOE facilities.
• The equipment or item is decontaminated so that the removable contamination levels do not exceed 3 µg/100 cm² as established through representative wipe sampling performed by, or at the direction of, the division ES&H team industrial hygienist.  
• The equipment or item is labeled and placed in sealed, impermeable bags or containers to prevent the release of beryllium dust during handling and transportation. Label the bags, container, and enclosures that are used. If plastic bags are used, double-bag the equipment or item.
• Prior to releasing the equipment or other items, obtain a written notification from the receiving DOE facility stating that it is operating under a DOE-approved CBDPP. The notification includes the following:
  • Site name and address.
  • A point of contact and telephone number.
  • The title of the CBDPP operating under.
  • A statement that it has been approved by the appropriate DOE Field Element.
• Provide copies of the notification to the Beryllium Program subject matter expert.

Ensure that waste disposal procedures are established in a Chronic Beryllium Disease Prevention Program-Implementation Plan (CBDPP-IP) that address the following:

• Waste minimization principles are applied to the generation of beryllium-containing and beryllium-contaminated waste.
• The release of beryllium dust is controlled by placing beryllium-containing and beryllium-contaminated wastes in sealed, impermeable bags or containers during handling and transportation. Label the bags, container, and enclosures that are used for disposal of beryllium waste. If plastic bags are used, double bag the equipment or item. A recipient's commitment, decontamination, and wipe sampling are not required. Refer to ESH100.2.ENV.26, Manage Other Waste at SNL, for additional waste disposal requirements.
• Beryllium-containing equipment and other items, including beryllium articles (beryllium-containing non-sparking tools, excess beryllium alloy metal stock) are not re-applied or recycled unless the appropriate division ES&H team industrial hygienist has performed an exposure assessment and determined that it may be treated as an uncontrolled release.

Ensure that:

• Beryllium workers are enrolled and removed from the Beryllium Medical Surveillance Program as specified in HR100.4.7, Participate in Medical Monitoring/Surveillance.
• Members of the Workforce who believe they meet the definition of a beryllium-associated worker understand that they may self-identify as a participant and request an evaluation.

Note: Participation, as well as inclusion, in the Beryllium Medical Surveillance Program (HR100.4.7) is voluntary. 

Managers

Ensure that procedures that address sign and labeling requirements are established in a Chronic Beryllium Disease Prevention Program-Implementation Plan (CBDPP-IP) to include the following:

• Warning signs are posted at each access point to a regulated area (see SF 2001-BHR, Sign for Beryllium Hazard Regulated Area [Word file/Acrobat file]).
• Warning labels are affixed to all containers of beryllium, beryllium compounds, or beryllium-contaminated clothing equipment, waste, scrap, or debris (see SF 2001-BER, Label for Beryllium Containers, Beryllium Compounds, or Beryllium-Contaminated Clothing, Equipment, Waste, Scrap, or Debris [Word file/Acrobat file]).
• Warning signs are posted at each access point to unregulated areas where beryllium activities are conducted (see SF 2001-LUN, Sign for Unregulated Areas Where Beryllium Activities Are Conducted [Word file/Acrobat file]).
• Caution signs are posted at each access point to contaminated buildings and areas and operational areas (see SF 2001-BCB, Sign for Beryllium-Contaminated Buildings and Operational Areas [Word file/Acrobat file]).
• Caution labels are affixed to equipment such as high-efficiency particulate air (HEPA) vacuums used to clean beryllium-contaminated surfaces (see SF 2001-CBS, Label for Equipment Used To Clean Beryllium [Word file/Acrobat file]).

Sandia Delegated Representative (SDR)

Ensure that all personal monitoring data collected by contractors is provided to the Beryllium Program subject matter expert in a timely manner after monitoring is complete.