NGK Berylco

Workshop on Beryllium Applications and Health and Safety
June 28-30, 2017 – ITER Organization
Session 4 - Feedback Experience from Beryllium Users on
Beryllium Health and Safety Regulations
June 29, 2017
Ms. Angélique RENIER
Communication and Environment Manager
NGK BERYLCO France
Technical Adviser
Beryllium Science and Technology Association BeST
www.ngk-alloys.com
EN 9100 – ISO 14001
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Presentation outline:
 Slide 1: Reminder of the context (main Beryllium metal uses
outside the nuclear fusion)
 Slide 2: Presentation of the beryllium association BeST
 Slide 3: Current regulatory situation of Be in Europe (Main
regulations for Be Metal: CLP – REACH – RoHS & ELV – CMD)
 Slide 4: Recent and ongoing evolutions: RMOA (REACH), OEL
adopted by US OSHA, SCOEL & ACSH opinion
 Slide 5 & 6: BeST position, BeST recommended OEL
 Slides 7 to 9: Product Stewardship Program “Be Responsible”
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Reminder of the context - Beryllium Metal
 Beryllium is basically used as metal in copper alloys
(90% out of the 400 Mt produced /year)
 A low Beryllium content in copper substantially
increases the performances of alloys (best balance
between Mechanical Strength & Conductivity)
 Main use of Beryllium copper alloys : electrical and
electronic connectors (greater reliability and longer
product life, miniaturisation…)
 Main applications : Automotive, Aeronautic and
Aerospace, Telecommuication, Computers, Home
Appliances, Photovolatic, Oil & Gas, Medical, Defense…
 Beryllium copper alloys are not substituable in many
applications due to a unique properties combination
 Because of its non substituability and its strategic
applications, Beryllium is one of the 20 current Critical
Raw Materials designated by the European Commission
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Beryllium Association BeST
www.beryllium.eu
www.berylliumsafety.eu
 NGK, as BeCu alloys world producer (3 units : France - Japan – USA), is member of
the Beryllium Association BeST
 BeST is a non profit organization created in 2011, based in Brussels
 BeST represents the manufacturers, suppliers and users of Beryllium in the EU
market (Origin : REACH Consortium)
 4 Members : MATERION Corporation (USA), NGK BERYLCO (France), TROPAG
Oscar H. Ritter Nachf GmbH (Germany), SCHMELZMETALL AG (Swiss)
Our mission:
« To promote sound policies, regulations, science and actions related to the use
of beryllium and to serve as an expert resource for the international community
on the benefits and criticality of beryllium applications. To promote and
implement good practices on the workplace.»
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Current regulatory situation of Beryllium in Europe
 Beryllium is concerned only by health issues, not environmental to date. The
critical health effect of Beryllium is Chronic Beryllium Disease (CBD), lungs
pathology, in case of inhalation of fine particles by sensitised people (1% of the
general population, not occupationally exposed, sensitized without any health effect).
 CLP regulation (Classification, Labelling and Packaging): Beryllium metal and
soluble compounds are classified together in the same manner Carcinogen 1B.
BeST advocates a different classification for Beryllium soluble salts (anecdotal uses)
and insoluble metal forms, mainly used in Europe and not carcinogen.
 REACH regulation (Registration, Evaluation & Authorization of Chemicals):
Beryllium is not on the candidate list (Substances of Very High Concern: 173 to
date) and will be not included according to the RMOA (Risk Mangement Option
Analysis) conclusion document, published in november 2016.
 RoHS (Restriction of Hazardous Substances in Electrical & Electronic
Equipments) and ELV (End of Live Vehicles) directives: Beryllium is not in the list of
restricted substances (no project to include Be in the future).
 CMD (Carcinogen and Mutagen Directive): no European OEL (Occupational
Exposure Limit) for Beryllium to date. The most of Member States have their own
national OEL (e.g. France, UK & Sweden: 2 µg/m3 - Finland: 1 µg/m3 – Germany &
Netherlands: no OEL - Spain: 0,2 µg/m3 (Inhalable fractions 8 hours Time Weighted Average)).
25 priority substances to regulate in 3 waves, including beryllium & compounds in the
third wave, final OEL expected for 2019 (Final step: vote at European parliament)
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Recent and ongoing evolutions, stakes
 November 2016: Beryllium not on the Reach Candidate List: The BAuA (German Federal Institute
for Occupational Health and Safety) has officially published its decision (RMOA conclusion) not to
identify Beryllium as SVHC (Substance of Very High Concern) = not to place any authorization or
restriction on the uses of beryllium in the future. Instead, Harmonized EU Wide OEL to be developed by
the European Commission.
 January 2017: US OSHA decision: US OSHA has adopted 0.2 µg/m3 CFC= 0.6 µg/m3 inhalable 8h
TWA. According to health data from Member States, Be users surveys and last scientific studies and
data, BeST recommends the same value in Europe, both protective and feasible.
 February 2017: SCOEL recommendation (Scientific Committee for Occupational Exposure Limits):
Despite BeST inputs to provide the last scientific evidence that CBD – and not sentitization - is the critical
health effect, SCOEL has maintained its extremely low scientific recommendation based on
immunological sensitization: 0.02 µg/m3. While this is not feasible for the industry and while Beryllium is
not classified as respiratory sensitizer (in the CLP regulation).
 May 2017: ACSH opinion (Advisory Committee on Safety and Health at work): this tripartite
committee mandated by the European commission (member states, employers and employees) has
published its official opinion, by taken into account health and safety but also socio-economic aspects,
and technical feasibility. BeST recommendation has been strenghtened: 0.2 µg/m3 with a value of 0.6
µg/m3 during a transitionnal period of 5 years (inhalable - 8h TWA)
 Next step: a new SEA (Socio Economic Assessment) including Beryllium amoung 6 substances
should be conducted by the European Commission in order to analyse the impacts of different OELs. A
very low OEL would cause costly equipments & measurements, beyond the beryllium industry  loss of
activities and employments, loss of performance, loss of innovation and sustainability in Europe. A first
SEA has been completed (end of 2016) but not published so far. Then, the European Commission should
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propose a final value to be voted by the parliament (likely in 2019).
BeST position
 Our position : we ask agreement and
support for the OEL recently accepted by
the social partners of 600 ng/m3 (0.6
µg/m3) Inhalable 8h TWA
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Product Stewardship Program
In order to help beryllium users to protect workers and to
comply with future regulations, BeST has developed a
Product Stewardship Program, based on its OEL
recommendation of 0.6 µg/m3
 Culmination of decades of practice and research
 Key points: personal hygiene, personal protective
equipment, engineering and work practice controls,
migration controls, worker education
 Support and cooperation of industry affiliations, unions,
and authorities (BAuA)
 Monitoring further to the ongoing implementation
Kit of 12 brochures: General Health & Safety,
Exposure Assessement, Personal Protective
Equipment, and 9 for the most frequent
operations (stamping, welding, grinding, forging,
CNC machining etc..)
Public Web Site on line
with videos
www.berylliumsafety.eu
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Good Practices Guide – www.berylliumsafety.eu
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Good Practices Guide – www.berylliumsafety.eu
NGK BERYLCO France feedback :
 By implementing those key principles
of our Product Stewardship Program,
as beryllium copper alloys processer,
we respect an OEL of 0.6 µg/m3
(BeST recommendation) and a
surface contamination of 0.3 mg/m2
(indicative current limit in France).
 No specific medical surveillance
according to the French legislation,
no case of CBD or any suspect
pulmonary troubles for more than 45
years of activity (1970). A recent
ANSES report (France) confirms that
available biological indicators (Urine,
blood (BeLPT) and exhaled air
condensate) don’t enable to establish
a reliable biomonitoting related to the
airborne exposures to date.
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Thanks for your attention and let’s
!!!
Access &
Engineering
Controls
(exhaust ventilation,
wet process etc..)
Controlling Dust Emission
& Dispersion
Exposure
Assessment
& PPE on the
workplace
Appropriate Housekeeping
and Hygiene Measures
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