Table 3. Percent Distribution of OSHA Samples in Foundries Meeting Current PEL (100 µg/cu.m) OSHA Sampling Data Job Category
Cleaning/finishing operator Sand system operator
Abrasive blasting operator Furnace operator Knockout operator Pouring operator
Maintenance operator Shakeout operator
Housekeeping worker Material handler Molder
Coremaker
50 µg/cu.m and not the costs for those already above the current limit to prog- ress to the new, more stringent limit. Te disparity in costs goes hand in hand with the disparity in feasibil- ity assumptions. OSHA’s numbers assume a few examples of workable methods in a handful of metalcasting facilities can be applied broadly across the entire industry with the same suc- cess. AFS and the industry contend this one-size-fits-all approach will not work, as dust sources are not the
<25 15.5 17.2 6.6
37.5 10.8 25
16.7 14.4 14.3 28.1 26.3 25.5
25-50 21.6 15.5 24.6 25
36.1 25 25
25.8 14.3 18.8 24.3 32.1
Silica Exposure Range (µg/cu.m) 50-100 19.2 25.9 27.9 0
18.9 16.7 25
29.9 42.9 31.3 28.9 29.2
same at every facility. A significant portion of costs for compliance will go into iterative (trial-and-error) studies to find a workable solution at individual plants. Other costs not included in OSHA’s economic analy- sis include permit applications, design engineering, makeup air, baghouse installation, and maintenance and downtime for installation. For the costs included in OSHA’s
analysis, such as equipment and engineering controls, AFS and the
100-250 21.1 27.6 27.9 12.5 24.3 28.2 12.5 17.5 14.3 21.9 19.1 9.4
>250 22.5 13.8 13.1 25
10.8 4.2
20.8 12.4 14.3 0
1.3 3.8
total >100 43.6 41.4 41
37.5 35.1 33.4 33.3 29.9 28.6 21.9 20.4 13.2
industry contend the agency has underestimated the equipment needed to comply with the lowered PEL. For instance, where OSHA’s cost analysis assumed foundries could use a $5,000, 15-gallon HEPA vacuum in place of sweeping, an economic study performed by consulting firm Environomics Inc. figured $45,000 for a 2-cu.yd., 40-horsepower vacuum system with HEPA filter would be needed to achieve compliance in a comparable plant.
26 | MODERN CASTING June 2014
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