OSHA recently announced that the compliance date for “specific ancillary requirements of the general industry beryllium standard” would be extended to December 12, 2018. At this time, OSHA is preparing a Notice of Proposed Rulemaking designed to clarify these provisions as well as addressing employers’ concerns with compliance.

Compliance Date Extended until December 12, 2018

The compliance date for the requirements listed below has been extended until December 12, 2018.

  • Provisions related to methods of compliance
  • Beryllium work areas
  • Regulated areas
  • Personal protective clothing and equipment
  • Hygiene areas and practices
  • Housekeeping
  • Communication of Hazards
  • Recordkeeping

NOT subject to the Compliance Extension

  • New Permissible Exposure Limits (PELs) for general industry, construction, and shipyards
  • General industry provisions enforceable as of May 11, 2018:
    • exposure assessment
    • respiratory protection
    • medical surveillance
    • medical removal
  • Provisions on change rooms and showers (March 11, 2019 compliance date)
  • Implementation of engineering controls (March 10, 2020 compliance date)

 

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Photo of Tressi L. Cordaro Tressi L. Cordaro

Tressi L. Cordaro is a Principal in the Washington, D.C. Region office of Jackson Lewis P.C. She is co-leader of the firm’s Workplace Safety and Health Practice Group. She advises and represents employers on occupational safety and health matters before federal and state…

Tressi L. Cordaro is a Principal in the Washington, D.C. Region office of Jackson Lewis P.C. She is co-leader of the firm’s Workplace Safety and Health Practice Group. She advises and represents employers on occupational safety and health matters before federal and state OSHA enforcement agencies.

Ms. Cordaro has advised employers faced with willful and serious citations as the result of catastrophic events and fatalities, including citations involving multi-million dollar penalties. Ms. Cordaro’s approach to representing an employer cited by OSHA is to seek an efficient resolution of contested citations, reserving litigation as the option if the client’s business objectives cannot otherwise be achieved. As a result, she has secured OSHA withdrawals of citations without the need for litigation.

Ms. Cordaro’s unique experience with government agencies involved in OSHA enforcement enables her to provide employers with especially insightful guidance as to how regulators view OSHA compliance obligations, and evaluate contested cases.

Ms. Cordaro served as the Presidentially-appointed Legal Counsel and Special Advisor to the past Chairman and Commissioner Horace A. Thompson, III at the U.S. Occupational Safety & Health Review Commission (OSHRC) in Washington, DC, the agency that adjudicates contested federal OSHA citations. As the Commissioner’s chief counsel, Ms. Cordaro analyzed all cases presented to the OSHRC and advocated the Commissioner’s position during decisional meetings.

In addition, Ms. Cordaro worked at the U.S. Department of Labor’s Occupational Safety & Health Administration developing OSHA standards, regulations and enforcement and compliance policies, with emphasis on the construction industry. She has in-depth experience on technical issues including, in particular, issues related to cranes and derricks in construction.

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