Beryllium Rule Amended

The August 9, 2018 Federal Register provided OSHA’s latest amendments of the Beryllium rule (29 CFR 1910.1024) and delayed certain compliance deadlines.  We think its helpful for the compliance deadlines to be outlined in chronological order.  So we made a list for you. 
 
Below are the compliance dates (bolded) for the OSHA rule.  If the MIOSHA dates are the same or different, it is noted.  Listed below the compliance dates are the various paragraphs of 1910.1024 that are affected by the bolded compliance dates: 
 
March 12, 2018 – same for MIOSHA
This is the compliance date for obligations contained in paragraphs (c), (d), (g), (k), and (l) of this standard. 

• (c) – Permissible Exposure Limits
• (d) – Exposure Assessment
• (g) – Respiratory Protection
• (k) – Medical Surveillance
• (l) – Medical Removal

 
December 12, 2018 – MIOSHA Part 340 is March 12, 2018.
The amended rule sets this date as the compliance date for “all other obligations” of this standard such as:

• Scope & Application
• Definitions
• (e)  Beryllium Areas and Regulated Areas
• (h)  Personal Protective Clothing and Equipment
• (j)  General
• (m)  Communication of Hazards
• (n)  Recordkeeping & Training

 
March 11, 2019 – same for MIOSHA
For paragraph (i) Hygiene Areas and Practices, the following requirements have been postponed until this new compliance date: 

• (i)(2) Change Rooms
• (i)(3) Showers

 
March 10, 2020 – same for MIOSHA
For Engineering Controls required by paragraph (f) this is the new compliance date.  However, It is believed that the intent here is for companies to comply with the non-engineering control portions of this section such as:

• Preparing an Exposure Control Plan,
• Prepare a list of operations and job titles where exposures to beryllium are expected
• Prepare a list of work practices and PPE required in section (f)(2)

 
We’ll keep you updated on more OSHA and MIOSHA updates of this and other standards in future issues.   
 

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