In response to a call for comments, the American College of Occupational and Environmental Medicine (ACOEM) is strongly urging OSHA to retain those portions of the proposed rule on occupational exposure to beryllium that deal with medical surveillance, medical removal, and other ancillary standards for both construction and shipyard workers.

On June 27, 2017, OSHA issued a call for comments on its proposal to revoke the ancillary provisions of the beryllium rule for the construction and the shipyard sectors that OSHA adopted on January 9, 2017, but retain the new lower permissible exposure limit (PEL) and the short term exposure limit (STEL) for each sector.

ACOEM believes that the PEL/STEL alone is insufficient to protect workers in the construction and shipyard sections. “The unusual nature of the beryllium hazard that justifies the application of the ancillary standards in general industry applies by the same logic to construction and shipbuilding,” ACOEM noted in its comments to OSHA. “Given the extremely low levels at which beryllium can cause sensitization, extra measures to contain and minimize the hazard are warranted.”

ACOEM further pointed out that the ancillary provision for medical surveillance of exposed workers has been proven to be a ‘safety net’ for detecting beryllium sensitization and chronic beryllium disease (CBD) at early stages of illness. “Exposed workers deserve the opportunity to know, based on medical assessment, when they are at increased personal risk of CBD or have early signs of disease, ACOEM noted. “Without medical surveillance, at­risk workers may continue to be exposed and unknowingly increase their likelihood of serious, even fatal, disease.” ACOEM’s complete comments are available at

The National Council for Occupational Safety and Health and the United Steelworkers union have also announced their opposition to the revocation.

Dru Branche, director, environmental, health and safety for Newport News, Virginia-based Newport News Shipbuilding, submitted comments in support of revoking the ancillary requirements and proposed a one year delay a delay of the implementation date from the original January proposal "to allow shipyards to more adequately assess the potential for beryllium exposure to various blasting grits."