WASHINGTON ALERT
Stephanie Salmon, AFS Washington Office; Jeff Hannapel & Christian Richter, The Policy Group, Washington, D.C. Proposed Lowered Silica PEL Released
METALCASTING INDUSTRY ADVOCATES WORKING ON COMMENTS IN RESPONSE. Te Occupational Safety and Health
Administration (OSHA) formally issued a draft of comprehensive rules for controlling exposure to crystal- line silica on August 23. Te proposal would significantly tighten the current permissible exposure limit (PEL) of 100 micrograms of respirable crystalline silica per cubic meter of air (µg/cu.m) to 50 µg/cu.m, with an action level of 25 µg/m3. Te proposed lower PEL would apply to all general industry, including metalcasting facilities. Provisions of the standard include: • Measuring the amount of silica that workers are exposed to above an action level of 25 µg/cu.m;
• Protecting workers from respirable crystalline silica exposures above the PEL of 50 µg/cu.m, on aver- age, over an 8-hour day;
• Limiting workers’ access to areas where they may be exposed above the PEL;
• Using dust controls to protect workers from silica exposures above the PEL;
• Providing respirators to workers ON THE HILL
Revisions Proposed to Emissions Reporting Requirements
In September, the U.S. Environ- mental Protection Agency (EPA) published proposed revisions to greenhouse gas emissions report- ing requirements for 24 industries, including stationary fuel combustion sources at metalcasting facilities and industrial waste landfills. The proposed action addresses concerns regarding the potential release of certain data as inputs to greenhouse gas emissions equations while al- lowing EPA to verify emissions and ensure compliance with the reporting requirements. This data may include confidential business information. The comment deadline for the proposed revisions is November 12. A public hearing may be held, if specifical-
18 | MODERN CASTING October 2013
ly requested. A copy of the proposed rule is available at
http://www.gpo.gov/fdsys/ pkg/FR-2013-09-11/pdf/2013-21773.pdf. The proposed rule would require companies reporting annual green- house gas emissions to use an EPA electronic verification tool for calculat- ing process and production data. This would include data facilities may regard as confidential business information such as product composition, raw mate- rials used, fuel types and quantities, and production volumes.
In July 2010, as part of its green- house gas emissions reporting rules, EPA proposed that inputs to the emissions equations are classified as emissions data. Pursuant to the Clean Air Act, emissions data could not be protected as confidential business information. At that time, numerous
stakeholders expressed concerns regarding the potential release of the data, so EPA deferred the reporting deadline for the inputs to emission equations until March 31, 2015. Pursuant to the new proposed revisions, the designated inputs to the emissions equations would be entered into the electronic tool. The tool would calculate the greenhouse gas emissions and conduct an electronic verification. The inputs or data entered into the tool would not be retained, as the tool would conduct checks at the time of data entry and generate a verification summary. This verification summary would be available to EPA when the facility submitted its an- nual greenhouse gas report.
For additional information, contact Stephanie Salmon, AFS Washington Off ice,
202/842-4864,
ssalmon@afsinc.org.
when dust controls cannot limit exposures to the PEL;
• Offering medical exams, including chest X-rays and lung function tests, every three years for workers exposed above the PEL for 30 or more days each year;
• Keeping records of workers’ silica exposure and medical exams. OSHA will provide 90 days for
comments on the draft regulations. Te agency plans to hold public hearings beginning March 2014 in Washington D.C. Te American Foundry Society
(AFS) has formed a working group to prepare formal comments in response to the proposed rule and will actively be involved in the public hearings. AFS also will review the more than 700 pages of the proposed rule and provide an in-depth overview. In 2011, a report from a working
group created by the American Chem- istry Council (ACC) estimated the overall economic impact of new silica standards to be close to $5.5 billion for general industry and construction. It was estimated that such a rule would cost the metalcasting industry $1-2 billion annually. Additional information on the
proposed rule, including procedures for submitting comments and information on the public hearings, can be found at
www.osha.gov/silica. Information on handling crystalline silica in metalcasting can be found at
www.afsinc.org/silica. If you have any questions regarding
the proposed silica rule, contact Stepha- nie Salmon, AFS Washington Office,
ssalmon@afsinc.org, or Fred Kohloff, AFS headquarters,
fhk@afsinc.org.
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