Table 2. OSHA Estimated Costs for Engineering Controls and Ancillary Development NAICS


Engineering Industry 331511 Iron foundries


331512 Steel investment foundries 331513 331524


Steel foundries (non-investment)


331525 331528 Various


Aluminum foundries Copper foundries


Other nonferrous foundries


Captive foundries Total


controls (includes abrasive blasting)


$11,372,127 $3,175,862


$3,403,790 $5,155,172


$1,187,578 $914,028


$6,993,368 $32,201,925


dent Obama has threatened to veto a budget bill that includes policy riders for any of its rulemakings. Although it has been an ardu-


ous process for OSHA to produce a final silica rule, the administration is adamant a final rule will be issued in 2016, before the current presidential term has ended. Te first step in this finalization process will be OSHA sending the final rule for review to the Office of Information and Regula- tory Affairs (OIRA) at the Office of Management & Budget. OIRA usually takes 90 days and sometimes more to review the rule. Te office can do one of three things: accept the rule, tell OSHA to go back and fix certain sections, or reject the rule. Interested stakeholders, such as metalcasting rep- resentatives, have the opportunity to meet with OIRA after OSHA sends the rule for review. Once the rule is finalized, affected


parties have 60 days to file petitions for judicial review in the U.S. Court of Appeals. Metalcasters also can anticipate lawmakers will introduce a


Respirators


$645,546 $179,639


$193,194 $291,571


$67,272 $51,701 n/a


$1,428,925


Exposure assessments


$2,612,775 $739,312


$794,973


$1,220,879 $309,403


$212,778 n/a


$5,890,120


Medical


surveillance $223,005


$62,324 $67,027 $101,588


$23,668 $17,937 n/a


$495,549


resolution of disapproval, known as the Congressional Review Act. If enacted, the bill would nullify the regulation. However, President Obama has issued a veto threat against the resolution. Once the final rule is published in


the Federal Register, 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. To comply with the new standard,


metalcasting facilities face two major challenges: economic impact and technical feasibility. While OSHA esti- mates the cost for additional controls for the metalcasting industry to comply with the lowered PEL to be $32 mil- lion a year, industry estimates are as high as $2.2 billion a year—more than 46 times OSHA’s estimate. In addition, OSHA’s ancillary cost estimation of $9 million a year is much lower than the industry’s estimate of more than $90 million a year (Tables 1-2). If the rule is finalized, metalcasters


Training


$216,228 $58,892


$65,679 $97,006


$23,448 $16,949 n/a


$478,202


Regulated areas


$241,133 $67,110


$72,174 $108,935


$25,095 $19,314 n/a


$533,761


Total


$15,310,814 $4,283,139


$4,596,837 $6,975,151


$1,636,464 $1,232,707 $6,993,368


$41,028,480


will have an uphill battle to achieve compliance. According to OSHA’s data, a large minority of the met- alcasting industry exhibits noncom- pliance with the current PEL (Table 3). More than 40% of facilities are noncompliant with the current 100 µg/cu.m limit in three job categories: cleaning/finishing operators, sand system operators and abrasive blast- ing operators. More than 30% are noncompliant in furnace, knockout, pouring and maintenance operation. Te lack of compliance stems largely from the lack of a ready, cost-effec- tive solution. OSHA’s cost analysis estimates include only the cost for those metalcasting facilities who already meet the standard and will be required to reduce PEL from 100 µg/ cu.m to less than 50 µg/cu.m. It does not include the costs for those above the current limit to progress to the new, more stringent limit after meet- ing the current standard.


For more information on the proposed crystalline silica rulemaking, visit www.afsinc.org/silica.


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


<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


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


December 2015 MODERN CASTING | 33


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