Advocacy Comments on OSHA’s Proposed Occupational Exposure to Beryllium and Beryllium Compounds in Construction and Shipyard Sectors Rule
August 28, 2017
The U.S. Small Business Administration’s (SBA) Office of Advocacy (Advocacy) submits the following comments on the Occupational Safety and Health Administration’s (OSHA’s) Proposed Occupational Exposure to Beryllium and Beryllium Compounds in Construction and Shipyard Sectors Rule that was published on June 27, 2017. The proposed rule is a deregulatory action that would remove the ancillary provisions (e.g., exposure assessment, respiratory protection, personal protective equipment, hazard communication, recordkeeping, etc.) for construction and shipyards from the final OSHA beryllium rule that was issued on January 9, 2017. However, the proposed rule would retain the new lower permissible exposure limit (PEL) of 0.2 mg/m3 (measured as an eight-hour time-weighted average (TWA)) and the short term exposure limit (STEL) of 2.0 mg/m3 (over a 15-minute sampling period) for each sector. OSHA does not specifically state whether it is also proposing to remove the action level (AL) of 0.1 mg/m3 TWA that triggers the ancillary provisions.