Stephanie Salmon, Artemis Strategies; Jeff Hannapel & Christian Richter, The Policy Group, Washington, D.C. WASHINGTON ALERT
New OSHA Program Targets Metalcasting I
n June, the U.S. Occupational Safety and Health Administra- tion (OSHA) formally posted a
new nationwide inspection program for primary metals industries, which impacts industries that fall under SIC Code 33, including all metalcasting facilities. Te directive establishes a new national emphasis program (NEP) to identify and reduce or elimi- nate worker exposures to dangerous conditions. Te wall-to-wall inspec- tion program incorporates all existing NEP programs and targets specific health and safety hazards found in metalcasting facilities. A Bureau of Labor Statistics (BLS)
report shows that five of the top 20 industries with non-fatal occupational injuries and illness cases were within this SIC code. Furthermore, OSHA inspection history indicates individuals employed in the primary metals indus- tries are exposed to serious safety and health hazards daily. Previous inspec-
ON THE HILL
Incinerator Standards Imposed on Thermal Sand Reclamation Units
In the Identification of Non-Hazardous Secondary Materials as Solid Waste rule that was announced on March 21, the U.S. Environmental Protection Agency (EPA) indicated for the first time that foundry sand processed in thermal sand reclamation units should be classified as solid waste, and as of May 20, the units are subject to commercial and solid waste incinerator standards (CISWI). Facilities operating thermal sand recla- mation units face regulatory uncertainty regarding these units. For temporary regulatory relief, metalcasting facilities may argue the imposition of incinerator standards are unreasonable because EPA never intended to subject these units to the 2000 CISWI standards and provid- ed no time for the newly regulated units to comply with the standards. Facilities
with existing state or federal air permits that address these units also may be able to argue these permits should continue to apply and shield the facility from enforce- ment for a reasonable period to allow the facility to modify the permit status of the units and meet any new emission limits or operating requirements. Companies should consult their legal counsel regarding the applicability of these arguments to their thermal sand reclamation units.
OSHA Silica Rulemaking Under Review
The U.S. Occupational Safety and Health Administration (OSHA) is a step closer to publishing a proposed rule regulating crystalline silica exposure for general industry, including metalcasting. The proposal is in its final internal review, and OSHA expects to release it later this summer. The proposed rule likely will lower the permissible exposure limit of
crystalline silica and include ancillary provisions, such as medical surveil- lance requirements, engineering controls, housekeeping requirements and regulated areas.
Critical Minerals Bill Introduced
U.S. Sen. Lisa Murkowski (R-Alaska) introduced the Critical Minerals Policy Act of 2011 to jump-start federal policy and research related to the availability of rare earth elements and minerals critical to U.S. manufacturing, economic com- petitiveness and security. The legislation specifically recognizes the importance of critical materials for many sectors the metalcasting industry supplies. A similar bill was introduced in the U.S. House of Representatives by Rep. Doug Lamborn (R-Colo.). Both the Senate and House have held a series of hearings on critical minerals in recent weeks.
July 2011 MODERN CASTING | 17
tions of primary metal establishments have resulted in citations for overexpo- sure to a wide variety of health hazards, including dangerous chemicals and physical stressors like noise and heat. Chemical exposures found in these facilities include carbon monoxide, lead, silica, metal dusts, fumes and other substances. Tis list is similar to the one
A NATIONAL EMPHASIS PROGRAM FOR THE PRIMARY METALS INDUSTRIES WILL USE MORE INSPECTIONS TO REDUCE WORKER EXPOSURE TO HAZARDOUS CHEMICALS AND PHYSICAL STRESSORS.
used in the local emphasis program in Ohio, Wisconsin and OSHA Region I (covering Connecticut, Massachusetts, Maine, New Hampshire, Rhode Island and New York). Te Office of Statistical Analy-
sis will provide each state a list of establishments to be inspected, and facilities with past inspection histories and higher incidence rates likely will be inspected first. Te NEP contem- plates at least three inspections per year per state or field office. In Ohio, more than three primary metals in- spections have taken place annually for metalcasting facilities, with monetary penalties reaching six digits. OSHA is encouraging each area of-
fice or region to develop outreach pro- grams that will support enforcement efforts, such as letters and news releases to the impacted industries.
Te NEP for primary metals industries can be found at
www.osha.gov/OshDoc/Directive_pdf/ CPL_03-00-013.pdf.
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