a metalcasting facility would likely need at least a 2-cu.yard 40 horsepower vacuum system with a HEPA filter at an initial cost of $60,000. OSHA’s solution for environmental controls in abrasive blast cleaning is a $8,000 glove box. Industry estimates for a new pro- duction blasting machine are greater than $100,000. Te rule underesti- mates or completely omits the cost of equipment and practices, such as new dust collectors, which can cost more than $1 million to install. In addition, some metalcasting plants will be forced to redesign ventilation systems and make changes to air permits from EPA, which can take at least a year to obtain.
Legal Challenge In the two years since the for-
mal silica proposal was released, the metalcasting industry has voiced its concerns regarding the regulation in numerous ways. In April, AFS and the National Association of Manufacturers (NAM), numerous industry trade groups, and labor unions, filed legal challenges to the rule’s validity in several circuit courts across the country. Te peti- tions have now been consolidated into the U.S. Court of Appeals for the D.C. Circuit (Docket No. 16-1105).
Rep. Bill Huizenga A petition filed by a labor coali-
tion contended OSHA did not go far enough. Te United Auto Workers (UAW), one of the petitioners, said the PEL should be set at 25 µg/m3
or
lower where feasible. Te labor group was joined by the United Steelwork- ers and the AFL-CIO. Separately, North America’s Building Trades Unions argued that the medical testing provisions can be improved in their
Rep. John Hoeven
petition. AFS/NAM also will be chal- lenging these petitions. In June, the court likely will issue
briefing notices, at which point the petitioners will have the opportunity to file briefs. OSHA will be repre- sented by attorneys from the U.S. Department of Labor and will have an opportunity to file one brief. Oral arguments will be heard most likely later this year. A court decision could
Under OSHA’s estimates, the above $8,000 glove box (above) is given as a compliant alternative to abrasive blast cleaning. The equipment on the right is more typical of what a metalcasting facility would use in production for controlled blast cleaning, at a cost of more than $100,000.
June 2016 MODERN CASTING | 31
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