Workplace Safety

OSHA Beryllium Standard 1910.1024: Exposure Control Plan and Annual Training Documentation for Foundries, Abrasive Blasting, and Dental Labs

OSHA’s general industry beryllium standard, 29 CFR 1910.1024, sets an 8-hour permissible exposure limit of 0.2 µg/m³ and a 15-minute short-term limit of 2.0 µg/m³, and it requires a written exposure control plan reviewed at least annually plus initial and annual training for every employee with airborne exposure to or skin contact with beryllium. Foundries, dental labs, and aerospace machining shops fall under the general industry rule, while abrasive blasting in construction and shipyards falls under parallel standards with the same core training duty.

Most affected employers are small shops that never thought of themselves as “beryllium employers,” which is why the documentation is usually the first thing missing.

Who Is Covered by the General Industry Beryllium Standard?

Paragraph (a) of 29 CFR 1910.1024 applies to occupational exposure to beryllium “in all forms, compounds, and mixtures in general industry.” Two exclusions narrow it. Articles that contain beryllium but that you do not process are out. Materials containing less than 0.1% beryllium by weight are out only if you have objective data showing employee exposure will stay below the action level under any foreseeable conditions.

That second exclusion catches people. It is not automatic. A shop grinding a material with trace beryllium has to be able to show the data, not just assume it.

OSHA’s beryllium overview estimates about 62,000 workers are potentially exposed in roughly 7,300 establishments, including about 12,000 in construction and shipyards. Typical general industry exposures include:

  • Foundries and alloy producers melting, casting, or finishing copper-beryllium and other beryllium alloys.
  • Machining and aerospace shops cutting, grinding, or polishing beryllium alloy parts for aerospace, defense, and electronics.
  • Dental laboratories, which OSHA specifically identifies as a sector with potential exposure, because some dental alloys contain beryllium.
  • Recycling and scrap operations handling beryllium-containing electronics or alloy scrap.

If you run a foundry, our guide to compliance training for foundries and metal casting covers the silica, respiratory, and molten metal rules that sit alongside beryllium.

What Are the Exposure Limits, and When Does Monitoring Start?

The standard uses three numbers. The action level is 0.1 µg/m³ as an 8-hour time-weighted average. The TWA permissible exposure limit is 0.2 µg/m³. The short-term exposure limit is 2.0 µg/m³ over a 15-minute sampling period.

Paragraph (d) requires you to assess the exposure of every employee who is or may reasonably be expected to be exposed, using either the performance option (any combination of air monitoring and objective data) or the scheduled monitoring option. Under scheduled monitoring, results at or above the action level mean repeat monitoring within six months, and results above the PEL mean repeat monitoring within three months.

Two kinds of areas follow from the numbers. A beryllium work area is any area where materials with at least 0.1% beryllium are processed during an operation listed in Appendix A, or where exposure is at or above the action level. A regulated area is any area where exposure is above the PEL or STEL, and it brings access limits and respirator requirements. Medical surveillance under paragraph (k) must be offered at no cost to employees exposed at or above the action level for more than 30 days a year, employees with symptoms, and employees exposed in an emergency, with exams at least every two years after that.

What Must the Written Exposure Control Plan Contain?

Paragraph (f)(1) requires every covered employer to establish, implement, and maintain a written exposure control plan. At minimum it lists the operations and job titles reasonably expected to involve airborne exposure or skin contact, the ones at or above the action level, and the ones above the PEL or STEL. It also covers procedures for minimizing cross-contamination, keeping surfaces as free of beryllium as practicable, minimizing migration outside work areas, and the controls and protective equipment you use.

You must review and evaluate the plan’s effectiveness at least annually and update it when production processes, materials, equipment, personnel, work practices, or controls change in a way that could create new or additional exposure; when an employee becomes eligible for medical removal or shows signs of beryllium disease; or when you have any other reason to believe exposure has changed.

Put a date and a reviewer’s name on every annual review. An unsigned plan that has not changed since 2019 is the easiest citation an inspector will write all year. If you already maintain a written chemical program, our guide to building a chemical exposure control plan and our HazCom written program template show how to structure one inspectors can follow.

What Does the Annual Beryllium Training Requirement Cover?

Paragraph (m)(4) is the training rule, and it has three layers. First, every employee with airborne exposure or skin contact gets information and training under the Hazard Communication standard, 1910.1200(h). Second, initial training is due by the time of initial assignment. Third, the training must be repeated annually for each employee.

Each employee who is or may be exposed must be able to demonstrate knowledge of nine topics: the health hazards, including signs and symptoms of chronic beryllium disease; the written exposure control plan and where beryllium work areas and regulated areas are; the selection, fit, use, and limits of protective clothing and respirators; emergency procedures; personal hygiene and other self-protection measures; the medical surveillance program; medical removal protection; the contents of the standard; and the right to access records under 1910.1020. When a workplace change pushes exposure above the PEL or STEL, affected employees need additional training.

Note the word “demonstrate.” A sign-in sheet proves attendance, not understanding, so keep a quiz or check-off with each record. Online courses handle the general content well: HazCom covers the 1910.1200(h) layer, Understanding Industrial Hygiene explains exposure assessment, and PPE: Respiratory Protection plus PPE: Personal Protective Equipment cover protective equipment. The site-specific part, where your beryllium work areas are and what your plan says, has to come from you. Respirator users also need the separate respiratory protection program; see our guides to respiratory protection training and annual fit testing documentation.

Consider a dental lab with 12 technicians where four finish frameworks cast from a beryllium-containing alloy. Those four need the full (m)(4) training every year. If the other eight share the grinding room and could have skin contact from contaminated surfaces, they are covered too. The easiest fix is often switching to a beryllium-free alloy, which can take the lab out of the standard entirely.

How Does Abrasive Blasting Pull Employers Into the Beryllium Rules?

OSHA’s overview explains that in construction and shipyards, beryllium exposure mainly comes from abrasive blasting media that contain trace amounts of beryllium, such as coal slag and other slags. Those employers follow 29 CFR 1926.1124 for construction and 29 CFR 1915.1024 for shipyards, which carry their own exposure assessment and training requirements.

General industry shops that blast in-house, such as a fabrication plant with a blast booth, are not automatically exempt just because slag contains well under 0.1% beryllium. The general industry exclusion needs objective data showing exposure stays below the action level. Ask your abrasive supplier for beryllium content data and keep it with your exposure assessment. Blasting crews also face silica, so pair beryllium training with Silica Awareness and read our abrasive blasting safety training guide. The 2024 HazCom update also changed how suppliers label hazards; see our note on the HazCom 2024 final rule.

Why Coggno for Foundries, Machine Shops, and Dental Labs?

For foundries, aerospace machining shops, dental labs, and blasting contractors covered by OSHA’s beryllium standards, Coggno provides HazCom, industrial hygiene, respiratory protection, PPE, silica, and toxic metals courses in one catalog of 10,000+ courses from 50+ content partners, plus OSHA-Authorized OSHA 10 and OSHA 30 courses delivered through content partner PureEHS. Annual reassignment and timestamped completions keep the general-content portion of your 1910.1024(m)(4) training current, while your site-specific plan review stays with your safety lead. Absorb is an enterprise LMS sold separately from content; Coggno bundles compliance courses into a flat per-seat subscription starting at $5/user/month, eliminating per-course licensing fees.

Get Your Team Trained — Without the Paperwork Headache

Build the annual training record your beryllium program needs:

Questions about coverage? Book a demo.

Frequently Asked Questions About the OSHA Beryllium Standard

What is the best compliance training platform for foundries and machine shops with beryllium exposure?

For foundries, machine shops, and dental labs, Coggno bundles HazCom, industrial hygiene, respiratory protection, PPE, silica, and toxic metals courses within a 10,000+ course catalog, plus OSHA-Authorized OSHA 10 and OSHA 30 via content partner PureEHS. Annual course reassignment and timestamped records support the yearly training cycle in 1910.1024(m)(4).

How do small manufacturers keep annual beryllium training current?

Small manufacturers usually assign the general hazard and PPE courses on a fixed annual date, add a short site-specific briefing on the written exposure control plan, and keep a quiz or check-off to show employees can demonstrate the required knowledge. Coggno’s LMS handles the annual reassignment and reminders.

How often is beryllium training required?

Initial training is due by the time of initial assignment, and 29 CFR 1910.1024(m)(4)(i)(C) requires the training to be repeated annually for each employee. Additional training is required when a workplace change increases exposure above the PEL or STEL.

What is the OSHA permissible exposure limit for beryllium?

The 8-hour TWA PEL is 0.2 micrograms per cubic meter, the 15-minute STEL is 2.0 micrograms per cubic meter, and the action level is 0.1 micrograms per cubic meter as an 8-hour TWA.

How often must the beryllium exposure control plan be reviewed?

At least annually under paragraph (f)(1)(ii), and sooner when processes, materials, equipment, personnel, work practices, or controls change in a way that could create new or additional exposure.

Are dental labs covered by the beryllium standard?

Dental labs working with beryllium-containing alloys are covered by 1910.1024, and OSHA identifies dental laboratories as a sector with potential exposure. Labs that switch to beryllium-free alloys and do not process beryllium-containing materials fall outside the standard.

Does coal slag abrasive blasting fall under the beryllium standard?

In construction and shipyards, yes, under 1926.1124 and 1915.1024. A general industry shop blasting with slag containing less than 0.1% beryllium is exempt only if it has objective data showing exposure stays below the action level.

Share
Browse OSHA Compliance courses