SOLUTIONS FOR MANUFACTURING
727-469-8773

OSHA Proposes Lowering Workplace Beryllium Levels

OSHA is proposing new standards on exposure to beryllium, an acknowledgement that many of its standards don’t adequately cover all workplace hazards. Beryllium is a metal widely used in the aircraft and aerospace industries because of its conductive and thermal properties when alloyed with other metals. Beryllium and its compounds are carcinogenic and toxic and when dust or fumes are inhaled can cause an incurable illness known as chronic beryllium disease or berylliosis. The Air Filtration and Indoor Air Quality experts at GulfTech Enterprises have significant experience in providing customer solutions to beryllium exposure. [1] They have installed air filtration systems to safely capture and contain the hazardous beryllium dust to OSHA standards.

OHSA’s proposal is historically significant because it represents a collaborative effort between industry and labor unions. The nation’s main manufacturer of beryllium products, Materion, and the United Steelworkers labor union, representing many of those who work with beryllium, recognized the need for a new standard. Together, they approached OSHA in 2012 to suggest a stronger standard.

“This collaboration of industry and labor presents a historic opportunity to protect the lives and lungs of thousands of beryllium-exposed workers,” said Assistant Secretary of Labor for Occupational Safety and Health Dr. David Michaels. “We hope other industries where workers are exposed to deadly substances join with unions and other organizations representing those workers to reduce exposures, prevent diseases and save lives.”[2]

There are an estimated 35,000 workers in the metalworking industry with potential exposure to beryllium that would be covered by OSHA’s rulemaking. Currently, OSHA’s eight-hour permissible exposure limit or PEL for beryllium is 2.0 micrograms per cubic meter of air. [3] That standard was adopted by OSHA in 1971 and has not changed since. OSHA’s proposed standard would reduce the eight-hour permissible exposure limit to 0.2 micrograms per cubic meter. Above that level, employers must take steps to reduce the airborne concentration of beryllium. Air Filtration and dust collection systems designed by experienced companies such as GulfTech, Inc.[4] can help employers meet that standard. The proposed rule would also require additional protections, including personal protective equipment, medical exams, other medical surveillance and training.

“This proposal will save lives and help thousands of workers stay healthy and be more productive on the job,” said U.S. Secretary of Labor Thomas E. Perez. “We’re pleased that industry has been such a strong voice in advocating for a more rigorous standard. The proposal is strong because of unprecedented partnership between manufacturers and the United Steelworkers.”[5]

While the exposure limits set back in 1971 had a significant effect in reducing fatalities due to acute beryllium disease, it has become clear in the 45 years since that exposure below 2.0 micrograms per cubic meter of air also had damaging long-term health effects. Although OSHA initially proposed to lower the permissible exposure limit for beryllium in 1975 it was not until industry and labor banded together that gave impetus to finally affect change.

OSHA estimates that the rule could prevent almost 100 deaths and 50 serious illnesses each year. Workers who inhale beryllium particles can develop a debilitating, incurable illness known as chronic beryllium disease, and are also at increased risk of lung cancer. Dangers arise when beryllium-containing materials are processed in a way that releases airborne beryllium dust, fume, mist or other forms.

The majority of current worker exposures to beryllium occur in operations such as foundry and smelting operations, machining, beryllium oxide ceramics and composites manufacturing and dental lab work.

The proposed rule was published in the Aug. 7, 2015 issue of the Federal Register. [1]

[1] OSHA proposal would lower beryllium levels, increase workplace protections, https://www.osha.gov/newsrelease/nat-20150806.html

[1] Installing Dust Collection System Helps Aerospace Company Safely Capture Hazardous Dust, https://www.gulftech.us/dust-collection-system-helps-aerospace-company-safely-capture-hazardous-dust/

[2] OSHA proposal would lower beryllium levels, increase workplace protections, https://www.osha.gov/newsrelease/nat-20150806.html

[3] OSHA Proposal (Same as Footnote 2)

[4] https://www.gulftech.us/

[5] OSHA proposal (See Footnote 2)

[1] OSHA proposal would lower beryllium levels, increase workplace protections, https://www.osha.gov/newsrelease/nat-20150806.html

Ron Beadenkopf is the Business Development Director and Technical Sales Manager at GulfTech Enterprises, Inc. located in Clearwater, FL

In-Door Air Filtration

GULFTECH is a full service provider of Dust Collectors, Air Cleaners, Vehicle Exhaust Removal Systems and Energy Controls for Ventilation
We offer wet (scrubber) and dry dust containment booths and downdraft tables, robotic welding hoods, ambient cleaning/collection systems for open areas and countless sizes and lengths of extraction arms.

GULFTECH sells, services and installs dust collectors, air cleaners, and mist collectors along with cyclone separators and bag houses.
Contact us for filters, service and support for all brands and applications.

We represent the best companies and with over 25 years of experience we find the best product for your application.

Summary of NFPA 484 Standard for Combustible Metals 2009 edition

The following are items taken from the new NFPA 484 Standard to which I have received many questions.

The intent of this paper is to highlight the items that are most violated. This brief is not intended to replace the actual standard which has much more information on combustible metals.  By law, any company who processes these metals are required to have this manual on premises. To order go to http://catalog.nfpa.org

Chapter 3 Definitions

3.3.6* Combustible Metal Dust.  Any finely divided metal 425 microns (40 mesh or 0.0165”) or smaller.

3.3.8 Deflagration.   Propagation of a combustible zone at a velocity that is less than the speed of sound in the unreacted medium.

3.3.13 Fines

3.3.13.1 Aluminum fines.  The fraction of an aluminum powder that is 45 microns (325 mesh) or smaller in nominal diameter, either as a discrete particle or as an agglomerate of discrete particles.

3.3.13.2 Magnesium fines.  The fraction of an aluminum powder that is 44 microns (320 mesh) or smaller in nominal diameter, either as a discrete particle or as an agglomerate of discrete particles.

3.3.13.3 Tantalum fines.  The fraction of an aluminum powder that is 10 microns or smaller in nominal diameter, either as a discrete particle or as an agglomerate of discrete particles.

3.3.13.1 Titanium or Zirconium fines.  The fraction of an aluminum powder that is 44 microns (320 mesh) or smaller in nominal diameter, either as a discrete particle or as an agglomerate of discrete particles.

Chapter 6 Aluminum

6.1.9.10.1* Blades and housings of fans used to move air or inert gas in conveying ducts shall be constructed, non-sparking metal such as bronze, nonmagnetic stainless steel or aluminum.

6.3.2. Dust-producing operations

6.3.2.1 Machines that produce fine particles of aluminum shall be provided with hoods, capture devices, or enclosures that are connected to a dust collection system having suction and capture velocity to collect and transport all the dust produced.

6.3.2.4 Grinding operations shall not be served by the same dust collection system as buffing and polishing operations.

6.3.2.5 Dry-type dust collectors shall be located outside of buildings.

6.3.2.5.1 Individual machines with portable dust collection capability shall be permitted to be used when the object being processed or finished is incapable of being moved  to a properly arranged fixed hood or enclosure and shall incorporate the safeguards in 6.3.2.5.1 (A) through (D)

(A) The operation of portable dust collection devices shall be subject to a hazard analysis to ensure that the risk to personnel and operations from flash fire and shrapnel is minimized.

(B) Personnel protective clothing shall comply will 6.6.2

(C) The collector shall be designed to dissipate static electricity.

(D) Collector retention capacity shall be limited to 0.45 kg (1 lb.)

6.3.2.5.2 Dry type dust collectors shall be provided with barriers or other means for protection of personnel.

6.3.2.5.3 The area around the collector shall be posted with a sign that reads as follows:

CAUTION: This dust collector can contain explosive dust. 

Keep outside the marked area while equipment is running.

 

6.3.2.6 Dust collection systems shall be dedicated to the collection of aluminum and aluminum alloy dust only.

 

6.3.2.6.1 Grinders, buffers, and associated equipment with dust collectors utilized for processing aluminum shall be provided with a placard that reads as follows:

WARNING: Aluminum Metal Only – Fire or Explosion can result with other Metals

 

6.3.2.6.2  If the combustible aluminum dust collection system is to be used for other materials, the system shall be disassembled and thoroughly cleaned of all incompatible material prior to and after it uses.

 

6.3.3 Dust Collection Ducts and Ductwork

 

6.3.3.1 All ductwork to be installed per NFPA 91.

 

6.3.3.2 Ducts shall be designed for maintaining a velocity of not less than 4500 ft/min or (1364 m/min).

 

6.3.3.6 Duct systems, dust collectors and dust producing machinery shall be bonded and grounded to minimize static electrical charge.

 

6.3.4 Wet type dust collector

 

6.3.4.1 The exhaust vent shall terminate outside the building and be securely fastened.

 

6.3.4.1.1 The duct shall be as short and straight as possible and shall be designed to withstand the same explosion pressure as the wet-type dust collector.

 

6.3.4.1.2 The cleaned air shall be permitted to be returned to the work area where tests conducted by an approved testing organization prove that the collector’s efficiency is great enough to provide safety to both personnel and property with regards for particulate matter in the cleaned air stream and accumulations of particulate and hydrogen within the work area.

 

6.3.4.3 Location of dust collector

 

6.3.4.3.2 The blower shall be located on the clean air side of the collector

 

6.3.4.4 The dust collector shall be arranged so that the dust laden airstream is thoroughly scrubbed by the liquid to achieve the desired efficiency.  The use of additional dry filter medium either downstream or combined with the wet collector shall not be permitted.

 

6.3.4.6 Collector Sump Venting

 

6.3.4.6.1 The sump of water wet type dust collectors shall be ventilated at all times.

 

6.3.4.6.2 Vents shall remain open and unobstructed when the machine is shut down.

 

6.3.4.6.3 When the dust collector is not in operation, ventilation shall be permitted to be provided by an independent blower or by an unimpeded vent.

 

6.3.4.7 Power Supply

 

6.3.4.7.1 The power supply to the dust-producing equipment shall be interlocked with the airflow for the exhaust blower and the liquid level controller of the dust collector so that improper functioning of the dust collection system will shut down the equipment it serves.

6.3.4.7.2 A time delay switch or equivalent device shall be provided on the dust producing equipment to prevent the starting of the motor drive until the collector is in complete operation.

 

6.3.4.8 Disposal of Sludge

 

6.3.4.8.3 Sludge shall be permitted to be mixed with inert materials in a ratio of at least 5 parts inert material to one part sludge.

 

6.3.5 Dry type dust collectors

 

6.3.5.1 Electrostatic collectors shall not be used.

6.3.5.2 Dust collecting filter medium shall be designed to be conductive so as to dissipate static electrical charges.

 

6.3.5.3 Dry-dust collection systems shall be designed and maintained so that internal cleanliness is ensured. The accumulation of material inside any area of the collector other than in the discharge container designed for that purpose shall not be permitted.

 

6.3.5.5 Dust shall be removed from dry collectors at least once each day and at more frequent intervals if warranted.

 

6.3.5.5.1 Extreme care shall be taken in removing dust from the collectors, to avoid creating dust clouds.

 

6.3.5.5.3 Waste material shall be mixed with an inert material in a volume ration of five parts inert material to one part metal dust.

 

6.3.5.6 Dry collectors used for combustible aluminum dust shall be provided with deflagration vents.  The selection of the type and location of the vents or weak section of the collector shall be designed to minimize injury to personnel and to minimize blast and fire damage to nearby equipment or structures.

 

6.3.6 Recycling of exhaust air.  Recycling of air from a dry dust collector into a building shall be prohibited.

 

6.4.3 Vacuum Cleaning Systems

 

6.4.3.4 Portable vacuum cleaners shall be used only if listed and approved for use with combustible aluminum dust.

Chapter 10 Titanium

10.4 Machining, Fabrication and finishing of parts

10.4.1.2  Operations in which titanium is subjected to processing or finishing shall include and shall not be limited to grinding, buffing, polishing, sawing, and machining of solids.

10.4.4 Titanium, Dust Collection

10.4.4.1.2 The hoods or enclosures shall be connected to liquid precipitation separators (wet-type dust collectors) and the suction unit shall be installed so that the dust is converted to sludge without contact, in the dry state, with any high speed moving parts.

10.4.4.2.2. Ducts shall be fabricated and installed in accordance with NFPA 91.

10.4.4.4  If the combustible titanium dust collection system is to be used for other materials, the system shall be disassembled and thoroughly cleaned of all incompatible material prior to and after it uses.

 

10.4.4.5  Grinders, buffers and associated equipment with dust collectors utilized for processing titanium shall be provided with a placard that reads as follows:

Caution

Current Use: Titanium Metal – Fire or Explosion can result with other Metals 

10.4.6.2 Ducts shall be designed to maintain a velocity of not less than 4500 ft/min or (1364 m/min).

10.4.4.6 Power Supply

10.4.4.6.1 The power supply to the dust-producing equipment shall be interlocked with the airflow for the exhaust blower and the liquid level controller of the dust collector so that improper functioning of the dust collection system will shut down the equipment it serves.

10.4.4.6.2 A time delay switch or equivalent device shall be provided on the dust producing equipment to prevent the starting of the motor drive until the collector is in complete operation.

10.4.7 Wet type dust collector

 

10.4.7.1 The exhaust vent shall terminate outside the building and be securely fastened.

 

10.4.7.1.1 The duct shall be as short and straight as possible and shall be designed to within stand the same explosion pressure as the wet-type dust collector.

 

10.4.7.1.2 The cleaned air shall be permitted to be returned to the work area where tests conducted by an approved testing organization prove that the collector’s efficiency is great enough to provide safety to both personnel and property with regards for particulate matter in the cleaned air stream and accumulations of particulate and hydrogen within the work area.

10.4.7.2 The exhaust vent shall be inspected and cleaned frequently to prevent the build-up of highly combustible deposits on the interior of the duct.

10.4.7.3 The dust collector shall be arranged so that the dust laden airstream is thoroughly scrubbed by the liquid to achieve the desired efficiency.  The use of additional dry filter medium either downstream or combined with the wet collector shall not be permitted.

10.4.7.4 The blower shall be located on the clean air side of the collector

10.4.7.5 The dust collector shall be arranged so that the dust laden airstream is thoroughly scrubbed by the liquid to achieve maximum efficiency.

10.4.7.6 Collector Sump Venting

 

10.4.7.6.1 The sump of water wet type dust collectors shall be ventilated at all times.

 

10.4.7.6.2 Vents shall remain open and unobstructed when the machine is shut down.

 

10.4.7.6.3 When the dust collector is not in operation, ventilation shall be permitted to be provided by an independent blower or by an unimpeded vent.

10.4.8 Dry type dust collector

10.4.8.1 Electrostatic collectors shall not be used.

10.4.8.2 Dry-type cyclone shall be located outside of buildings

10.4.8.3 Dry dust collection systems shall be designed and maintained so that the internal cleanliness is assured.

10.4.8.4 The accumulation of material inside any area of the collector other than in discharge containers designed for that purpose shall not be permitted.

10.4.8.6 Dust shall be removed from dry collectors at least once each day and at more frequent intervals if warranted.

10.4.8.6.1 Extreme care shall take in removing dust from the collectors, to avoid creating dust clouds.

10.4.8.6.2 The dust shall be discharged into properly bonded and grounded metal containers that shall be covered promptly to avoid the creation of airborne fugitive dust.

10.4.8.6.3 Dry collectors shall be emptied before or when 100% of the storage capacity is attained.

10.4.8.6.4 The maximum volume of titanium fines collected before emptying shall not exceed 19 l or 5 gallons.

10.4.8.7 The cyclone dust collector shall be of conductive metal construction suitable for the service intended.

10.4.8.7.1 The cyclone dust collector shall be solid weld and with ground smooth internal seams.

10.4.8.7.2 The equipment shall be provided with a spark-proof airlock on the hopper discharge and connected to a covered metal container.

10.4.9 Recycling of Exhaust Air. Recycling of air from dry dust collection into buildings shall be prohibited.

 

12.4.3 Vacuum Cleaning Systems

 

12.4.3.4 Portable vacuum cleaners shall be used only if listed and approved for use with combustible aluminum dust.

ANNEX A EXPLANATORY MATERIAL

A.3.2.2 AUTHORITY Having Jurisdiction (AHJ) The phrase “authority having jurisdiction” or its acronym AHJ is used in NFPA documents in a broad manner since jurisdiction and approval agencies as do their responsibilities. Where public safety is primary, the authority having jurisdiction may be a federal, state, local, or other regional departmental or individual such as a fire chief, fire marshal, chief of a fire prevention bureau, labor department, or health department; building official; electrical inspector; or others having statute authority.  For insurance purposes, an insurance inspection department, rating bureau, or other insurance company representative may be the authority having jurisdiction.  In many circumstances, the property owner or his or her designated agent assumes the role of the authority having jurisdiction; at government installations, the commanding officer or departmental official may be the authority having jurisdiction.

A.6.1.9.10.1 information on spark resistant fans and blowers can be found in AMCA standard no. 99-0401-86, “Classification for Spark Resistant Construction.”

A.6.1.9.10.4 Ultimately, all fans and blowers in dust collection systems accumulate sufficient powder to become a potential explosion hazard.

A.6.1.10.1 (selected excerpts)

………………………………………………..

Industry experience has clearly demonstrated that an eventual explosion can be expected where a bag or media type (cartridge) collector is used to collect aluminum fines.  Seldom if ever can the exact source of ignition be positively identified.  In those unusual instances when it becomes necessary to collect very small fines for a commercial product, it is customary for the producer to employ a bag or media (cartridge) type collector. With the knowledge that strong explosive potential is present, the producer will locate the bag or media (cartridge) type collector a safe distance from buildings and personnel.  ……………………………………………………………….This type of collector will be located at least 50 feet from any other building or operations.  …………………..Explosion venting must adhere to NFPA 68, Standard on Explosion Protection by Deflagration Venting.

A.6.5.2.4 Experience has shown that dry sodium Chloride is one of the most effective chemicals for containing fires involving aluminum.

A.6.5.2.6.3 Class B extinguishing agents usually will greatly accelerate combustible aluminum dust fires and can cause burning metal to explode.

A.7.3.2.4.2 See “Industrial Ventilation: A Manual of Recommended Practice,” figure 4 14, the range of particle size, Concentration, and Collector performance.  One pound is equivalent to 7000 grains.

 

BRIEF OVERVIEW OF IMPORTANT ITEMS FROM THE NEW NFPA 68 Standard on Explosion Protection by Deflagration Venting

OSHA Issues New Combustible Dust Instruction

  1. Prior to this NFPA 68 was a guideline and now it is a standard.  Therefore insurance companies and local fire codes will accept this as its legal code unless the AHJ (AUTHORITY Having Jurisdiction) specifies another safety approach such as Factory Mutual guidelines.  OSHA will enforce the NFPA standard EN14491 as it mandatory code. 
  2. The AHJ (AUTHORITY Having Jurisdiction) is anyone where public safety is a concern.  This can be the fire marshal, labor department head, health department, safety inspector and etc. or just about anyone who has authority to make policy.  However and change from the stated conditions would require a waiver from the company stating the dust is not explosive or that they want us to comply with Factory Mutual.
  3. Chapter 1 Administration 1.3, unless the customer can prove in writing their dust is not explosive, all dust collectors will have explosion vents.
  4. Under Chapter 4.2.3.1 Hazard analysis will require a company keeping records of whether their dust in explosive or not.  In other words, the end user must submit his dust to an independent lab for analysis.
  5. Chapter 5 stated if you can prove another method is acceptable to protect the device from explosions that is acceptable to the AHJ, you can use that method.
  6. Chapter 6 states the end user must know the Kst value for his dustIt must be tested and certified unless it is a know substance where the Kst is a published value.

These are just a few of the highlights.

One of the best solutions for combustible metals applications is a wet dust collector.  Click the link below to learn more about GulfTech’s Product Offerings for wet dust collectors:

Wet Dust Collectors

Please obtain the actual standard at http://www.osha.gov/OshDoc/Directive_pdf/CPL_03-00-006.pdf.

Sites to visit

http://www.osha.gov/dts/shib/shib073105.html

http://www.osha.gov

www.nfpa.org

4/5/10