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Animal studies have demonstrated a consistent scenario of beryllium exposure resulting in chronic pulmonary inflammation and tumor formation at levels below overload conditions (Groth et al., 1980, Document ID 1316; Finch et al., 1998 ; Nickel-Brady et al., 1994 ). The animal studies support the human epidemiological evidence and contributed to the findings of the NTP, IARC, and others that beryllium and beryllium-containing material should be regarded as known human carcinogens. The beryllium compounds found to be carcinogenic in animals include both soluble beryllium compounds, such as beryllium how to make cbd isolate gummies sulfate and beryllium hydroxide, as well as poorly soluble beryllium compounds, such as beryllium oxide and beryllium metal. The doses that produce tumors in experimental animal are fairly large and also lead to chronic pulmonary inflammation. The exact tumorigenic mechanism for beryllium is unclear and a number of mechanisms are likely involved, including chronic inflammation, genotoxicity, mitogenicity, oxidative stress, and epigenetic changes. A study by Boffetta et al. and an abstract by Boffetta et al., were submitted by Materion for Agency consideration (Document ID 1661, p. 3).

ORCHSE argued that for the protection of municipal and commercial disposal workers, materials discarded from beryllium work areas should be in bags or other containers (Document ID 1691, p. 5). NFFS asserted that “visibly contaminated,” “cleaned to remove visible particulate,” and “sealed, impermeable enclosures” are vague terms (Document ID 1678, p. 5). Paragraph of the proposed rule would have required the employer to ensure that waste, debris, and materials visibly contaminated with beryllium and consigned for disposal were disposed of in sealed, impermeable enclosures, such as bags or containers. Paragraph would have further required such bags or containers to be labeled in accordance with paragraph of the proposed rule. Sample reveals a toxic substance on a surface, and the employer has not taken practicable measures to keep the surface clean, the employer has not kept the surface as free as practicable of the toxic substance pickleball and cbd.

Materion separately commented that monitoring on all three shifts is not warranted, would be burdensome to small businesses, and does not align well with other standards (Document ID 1661, p. 14 ). In an individual submission, the USW also stated that three-shift monitoring would add unnecessary compliance costs. Additionally, it commented that if the operations are identical, the shift chosen will not matter, while if they are not identical, then monitoring on the highest exposed shift will overestimate exposures on the other shifts (Document ID 1681, Attachment 1, p. 8). During the hearings, Dr. Virji from NIOSH testified that because exposure is variable and “different things happen at different shifts,” including maintenance activities, “it is hard to . Which shift the highest exposure,” so “it is important that multiple shifts get representative sampling” (Document ID 1755, Tr. 50-51). Paragraph requires employers to train employees on the written exposure control plan required by paragraph , including the location of regulated areas and the specific nature of operations that could result in airborne exposure.

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The requirement is restricted to body parts other than the hands, face, and neck because if employees have dermal contact with beryllium on their hands, faces, or necks, they must use the washing facilities required by paragraph . This language is intended to convey that showers must be used immediately after work activities involving beryllium exposure have been completed for the day. If, however, employees are performing tasks involving exposure intermittently throughout the day, this provision is intended to require them to shower after the last task involving exposure, not after the completion of each such task. Most commenters agreed with the need for hygiene areas and practices to protect workers from airborne exposure to and dermal contact with beryllium (Document ID 1664, p. 7; 1665, pp. 10-11; 1667, pp. 5-6; 1675, p. 13; 1679, p. 9; 1680, p, 5; 1689, p. 12).

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Also, beryllium can contaminate employees’ clothing, shoes, skin, and hair, prolonging workers’ beryllium exposure and exposing others such as family members if proper hygiene practices are not observed. A study by Sanderson et al. measured the levels of beryllium on workers’ skin and vehicle surfaces at a machining plant. The study showed beryllium was present on workers’ skin and in their vehicles, demonstrating that workers carried residual beryllium on their hands when leaving work (Sanderson et al., 1999, Document ID 0474).

However, these properties have not been consistently characterized in most studies. These factors may be responsible, at least in part, for the process by which beryllium sensitization progresses to CBD in exposed workers. Other factors influencing beryllium-induced toxicity include the surface area of beryllium particles and their persistence in the lung. With respect to dermal contact or exposure, the physical characteristics of the particle are also important since they can influence skin absorption and bioavailability. This section addresses certain physical characteristics (i.e., solubility, particle size, particle surface area) that influence the toxicity of beryllium materials in occupational settings. The purpose of the Occupational Safety and Health Act (29 U.S.C. 651 et seq.) (“the Act” or “the OSH Act”), is “to assure so far as possible every working man and woman in the Nation safe and healthful working conditions and to preserve our human resources” (29 U.S.C. 651).

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In addition to the comments above and those noted throughout this Health Effects section, Materion submitted their correspondence to the National Academies regarding the company’s assessment of the NAS beryllium studies and their correspondence to NIOSH regarding the Cummings 2009 study to OSHA. For the NAS study, Materion included a series of comments regarding studies included in the NAS report. OSHA has reviewed these comments and found that the comments submitted to the NAS critiquing their review of the health effects of beryllium were considered and incorporated where appropriate. For the NIOSH study Materion included comments regarding 2 cases of acute beryllium disease evaluated in a study published by Cummings et al., 2009.

The RFA states that whenever an agency promulgates a final rule that is required to conform to the notice-and-comment rulemaking requirements of section 553 of the Administrative Procedure Act , the agency shall prepare a final regulatory flexibility analysis . In contrast, the record evidence does not show that it is feasible for most operations in all affected industries and application groups to achieve the alternative PEL of 0.1 μg/m3 most of the time. As discussed below, although a number of operations can achieve this level, they may be interspersed with operations that cannot, and OSHA sees value in having a uniform PEL that can be enforced consistently for all operations, rather than enforcing different PELs for the same contaminant in different operations. Dr. Newman described one example of a patient who developed CBD from his occupational beryllium exposure and “who went on to die prematurely with a great deal of suffering along the way due to the condition chronic beryllium disease” (Document ID 1756, Tr. 80). Criteria to determine “significant” exposure, and the criteria appeared to vary considerably (Taiwo et al., 2010); thus, it is difficult to compare rates of sensitization across companies in this study.

In light of this evidence, OSHA finds the comments opposing the cancer warning language on signs unpersuasive. However, with regard to Materion’s suggested language, OSHA agrees that a warning that beryllium can cause damage to lungs is appropriate and retains that language, as proposed, in the final standards for general industry and shipyards. Finally, the triggers for a medical removal recommendation in paragraph reflect the triggers under paragraph and are discussed in more detail in the summary and explanation for final paragraph , medical removal protection.

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Proposed paragraphs and made clear that this definition included both the proposed 8-hour TWA PEL and the proposed STEL. Because the revised trigger in final paragraph focuses on the action level, rather than working in a regulated area, it does not directly require medical surveillance for employees who are exposed above the STEL, provided their airborne exposure levels do not exceed the action level for more than 30 days per year. OSHA intends these beryllium work area provisions to apply to the area surrounding the process, operation, or task where airborne beryllium is released or the potential for dermal contact is created.