EDITORIAL
You Can Make a Difference I
f your metalcasting facility uses silica sand in its manufacturing process, then you have heard about the Occupational Safety & Heath
Administration’s (OSHA) proposed rule for a comprehensive oc- cupational health standard for crystalline silica that was released in September. Te proposed reduction of the permissible exposure limit (PEL) for silica from 100 µg/cu. m to 50 µg/cu. m (with an action level of 25 µg/ cu. m) while also setting in place a number of ancil- lary provisions is anticipated to cost the industry more than $1.5 billion annually, or 4% of our industry’s sales in 2013. Wow, that is a startling figure even if you have been immersed in this rule’s development for the last decade. One of the reasons this proposed rule is such
“Your facility, regardless of size,
can be a critical part of this outreach effort because you support jobs in your Congressional district.”
ers feel. Te entire regulatory rulemaking process (and the government law writing process, for that matter) is confusing, and it all seems to happen in some far-away place behind closed doors. Unless you have been intimately involved with your elected officials back home or worked with regulatory officials or your Members of Con- gress in Wash- ington D.C., it is an intimidating situation to try to immerse yourself in. But, if there ever was a time for you to push through those fears, it is now. In the first part of 2014, AFS is
launching an outreach campaign to speak to the U.S. Congress about the impact this rulemak- ing will have on the metalcasting
a challenge to metalcasters is it mandates the use of engineering controls, ventilation and a host of administrative controls to try to meet the reduced silica PEL prior to the use of personal protective equipment. So, your facility must spend money on equipment and controls to try to reach the reduced PEL even if it is known the equipment has minimal chance to achieve the required PEL. Only then does personal protective equipment for your facility’s workers become an option. For more details on this segment of the rule (or the rule as a whole), review the Silica Resource Page on the American Foundry Society (AFS) website at
www.afsinc.org/silica. On recent visits to several metalcasters in Michi-
gan, the same question was posed to me by two different industry veterans: “What can we possibly do about the proposed rule?” Te context of the questions was similar in that these metalcasters both felt they were too small and insignificant to make a difference. Tey basically felt helpless. Everyone understands how these two metalcast-
industry. You will be armed with information and talking points on the proposed rule. Te goal is to help your members of Congress understand the harm and potential loss of jobs associated with this proposed rule. Tese members then can help our industry reach out to OSHA to communicate a reasonable set of changes to the proposed rule that will allow our industry to continue to move forward while also protecting our workers. Your facility, regardless of size, can be a critical
part of this outreach effort because you support jobs in your Congressional district. Tat is meaningful to the Member of Congress that represents you. Te truth is the metalcasting industry must move together in force and push out our message about this proposed rule before it is too late.
Alfred T. Spada, Publisher/Editor-in-Chief
If you have any comments about this editorial or any other item that appears in Modern Casting, email me at
aspada@afsinc.org.
January 2014 MODERN CASTING | 9
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