of critical cast metal components. As proposed, OSHA’s new regu-
lation likely will force some facilities to close, shift production offshore and impact the long-term produc- tivity, profitability and competi- tive structure of the metalcasting industry. OSHA expects the pro- posed crystalline silica standard to be finalized in 2016. The American Foundry Soci-
ety has been communicating with OSHA and lawmakers regarding its concerns about the proposal, asking for the rule to be withdrawn until a technologically and economically feasible rule can be established. Key concerns with the proposed rule- making include: • It prohibits certain work practices that contradict existing industry safety practices. For example, OSHA bans dry sweeping, compressed air and employee rotation as control methods, but
for many metalcasting facili- ties, compressed air is the only feasible method to clean complex castings. Wet vacuuming can damage equipment and create a significant explosion risk.
• It underestimates and/or com- pletely omits the cost of equip- ment and processes. Metalcasting facilities will have to exhaust all feasible engineering and work practice controls to meet the new PEL. New dust collectors, which can cost more than $1 million to install, were not accounted for by OSHA. Professional clean- ing services would cost $1 per sq. ft. of facility, plus $400 million annually for downtime.
• It conflicts with EPA regulations, as some metalcasting plants will be forced to redesign ventilation systems and in some cases, make changes to their air permits, which can take at least a year to obtain.
OSHA’s estimated cost of the
silica proposal for the metalcastsing industry is $43 million; however, economic analysts projected the cost to be more than $2.2 billion annu- ally. This represents 9.9% of the metalcasting industry’s revenue and 276% of its profits. The economic impact will disproportionately affect small businesses. Employers are expected to
achieve complete compliance within one year of the effective date. AFS is asking Congress members
to contact the chairs of the Senate and House Appropriations Labor/ HHS Subcommittees urging support of language in the FY 2016 Labor/ HHS Appropriations bill prevent- ing OSHA from receiving funds to work on the agency’s proposed silica rule. AFS is also asking the Sen- ate subcommittee to require OSHA to undertake a new Small Business Panel Review (SBREFA).
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June 2015 MODERN CASTING | 23
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