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 EN 9100 – ISO 14001 www.ngk-alloys.com

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”

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

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.»

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)

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 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

Product Stewardship Program 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..) 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 Public Web Site on line with videos www.berylliumsafety.eu

Good Practices Guide – www.berylliumsafety.eu

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.

Controlling Dust Emission Thanks for your attention and let’s !!! Controlling Dust Emission & Dispersion Access & Engineering Controls (exhaust ventilation, wet process etc..) Appropriate Housekeeping and Hygiene Measures Exposure Assessment & PPE on the workplace