Table 1. Estimated Costs for the Metalcasting Industry to Comply with Proposed Silica Ancillary Requirements According to Environomics Report
PEL=100 AL=50
Exposure assessment
Health screening/surveillance Regulated areas
Respiratory protection
Hazard communication/training Recordkeeping
Competent person Total
the rule. Te agency has changed pro- posed rules in the past after receiving feedback from stakeholders. Once OSHA has completed the
evaluation and made changes to the text of the proposal, it will be reviewed by the solicitor’s office within the agency before the final draft is sent to the U.S. Office of Management & Budget (OMB) for final review before publication. Tis document is not shared with the public. At a future date (likely in 2015), AFS plans to meet with the OMB’s Office of Information and Regulatory Analysis to
12.3 13.2 10.8 8.1 4.8 0.6 3.1
PEL=50 AL=50
11.4 8.8
13.8 20.6 3.7 0.8 3.1
PEL=50 AL=25
$18.1 million $28.7 million $13.8 million $20.6 million $8.1 million $1.4 million $3.1 million $93.8 million
discuss the impact of the OSHA silica rulemaking on the metalcasting industry and focus on the economic and techno- logical flaws of OSHA’s analysis of the metalcasting industry. After the White House signs off on
the rule, it is published in the Federal Register as a final rule, likely sometime in 2015 or 2016. Any group that believes it is adversely affected by the rule may request a judicial review within 60 days of the final rule’s publication. It is likely a ruling will come before the 2016 election. A court challenge from the metalcasting industry may
be necessary to address the major dis- crepancies that will critically affect the industry’s future sustainability. Once the final rule is published, the standard will become effective after 60 days. All obligations set in the rule are required to commence 180 days after the effective date, except for engineering controls and laboratory requirements, which are required after a full year.
Economic and Technological Feasibility
OSHA’s rule applies to respirable
crystalline silica, with “respirable” defined as having particles less than 5 microns in diameter. Human hair is 80 microns in diameter. Te agency estimates 2.2 million workers will be affected by the proposed rule, which applies to all of general industry, includ- ing metalcasting. Metalcasting stands to be one of the most affected sectors. Te current PEL of 100 µg/cu.m of respirable crystalline silica was adopted
24 | MODERN CASTING June 2014
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