Lanterna Rally

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Published: 2007

Total Pages: 1

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On December 8, 1999, the Department of Energy (DOE) published Title 10 CFR 850 (hereafter referred to as the Rule) to establish a chronic beryllium disease prevention program (CBDPP) to: (1) reduce the number of workers currently exposed to beryllium in the course of their work at DOE facilities managed by DOE or its contractors; (2) minimize the levels of, and potential for, exposure to beryllium; and (3) establish medical surveillance requirements to ensure early detection of the disease. On January 4, 2001, DOE issued DOE G 440.1-7A, Implementation Guide for use with 10 CFR 850, Chronic Beryllium Disease Prevention Program, to assist line managers in meeting their responsibilities for implementing the CBDPP. That guide describes methods and techniques that DOE considers acceptable in complying with the Rule. In 2005 a draft DOE Technical Standard ''Management of Items and Areas Containing Low Levels of Beryllium'' (SAFT 0103; hereafter referred to as the ''TS'') was circulated for comment (http://www.hss.energy.gov/NuclearSafety/techstds/tsdrafts/saft-0103.pdf). DOE technical standards are voluntary consensus standards developed when industry standards do not exist (see http://www.hss.energy.gov/NuclearSafety/techstds/index.html for more information). DOE does not require its field elements to implement DOE technical standards, but field elements may choose to adopt these standards to meet specific needs. This beryllium TS is intended to provide best practices and lessons learned for manageing items and areas that contain low levels of beryllium, which has been a costly and technically challenging component of CBDPPs. The TS is also intended to provide guidance for determining if the Rule's housekeeping and release criteria are met. On challenge the TS addressed was the statistical interpretation of data sets with non-detected results, a topic for which no strong consensus exists. Among the many comments on the draft TS was a suggestion that certain of the statistical comparisons described in the TS could be better implemented if analytical results, even when below a reporting limit, were to be reported by analytical laboratories. See Appendix 1 for a review of terminology related to reporting limits. The Beryllium Health and Safety Committee (BHSC) formed a Sampling and Analysis Subcommittee (SAS) in 2003. The SAS established a working group on accreditation and reporting limits. By 2006 it had become evident that the issues extended to data reporting as a whole. The SAS proposed to the BHSC the formation of a Data Reporting Task Force (DRTF) to consider issues related to data reporting. The BHSC Board agreed, and requested that the DRTF generate a white paper, to be offered by the BHSC to potential interested parties such as the DOE policy office that is responsible for beryllium health and safety policy. It was noted that additional products could include detailed guidance and potentially a journal article in the future. The SAS proposed that DRTF membership represent the affected disciplines (chemists, industrial hygiene professionals and statisticians, and the DOE office that is responsible for beryllium health and safety policy). The BHSC Board decided that DRTF membership should come from DOE sites, since the focus would be on reporting in the context of the TS and the Rule. The DRTF came into existence in late 2006. The DRTF membership includes industrial hygienists, analytical chemists and laboratory managers, members of the regulatory and oversight community, and environmental statisticians. A first White Paper, ''Summary of Issues and Path Forward'', was reviewed by the BHSC in March 2007 and issued by the DRTF in June 2007. It describes the charter of the DRTF, introduces some basic terminology (reproduced here in Appendix 1), lays out the issues the DRTF is expected to address, and describes a path forward for the DRTF's work. This first White Paper is available through the BHSC web site. This White Paper presents recommendations developed by the DRTF following the process laid out in that first White Paper.