The American Foundry Society (AFS) hosted Environmental, Health and Safety professionals from the metalcasting industry recently in St. Louis to discuss a variety of EPA- and OSHA-related topics. The venue was just a short walk from the Gateway Arch, which is the tallest national monument in the U.S. (630 feet) and was built with more stainless steel than any other structure in history (900 tons stainless out of 17,200 tons total weight).

AFS hosts several meetings each year to promote the interchange of information among members. This column covers the Health & Safety portion of the August 2008 meeting. Environmental was covered in last month’s column. Many AFS members are also Industrial Heating subscribers, and many issues relevant to metalcasters are also important to other heating equipment users and makers. IH readers seeking to stay abreast of EH&S issues should consider attending this conference in 2009.

Health & Safety Issues

On the OSHA front, AFS staffers reported that several new standards and “emphasis” programs are on the verge of being implemented and that Congress is also considering new legislation that can affect foundries and others in the primary metals manufacturing industry.

Combustible Dust– The U.S. Chemical Safety and Hazard Investigation Board (CSB) issued a report in 2006 that identified 281 fires and explosions involving combustible dust between 1980 and 2005, in which 119 workers were killed and 718 injured. Fatal dust explosions at foundries were cited as occurring in 1999 (Massachusetts) and 2003 (Indiana). Collectively, these incidents helped trigger Congress to introduce HR 5522 “The Combustible Dust Explosion and Fire Protection Act of 2008.” If enacted, this legislation will require employers to conduct dust hazard assessments and establish inspection, housekeeping and ignition-prevention programs. It will also require manufacturers of combustible dusts to improve hazard communications (e.g., MSDS) for their products.

Criminal Penalties –Also pending in Congress is an amendment to the Occupational Health and Safety Act of 1970 called “Protecting America’s Workers Act” (HR 2049, S 1244). The bill would provide additional safeguards for whistle-blowers and possible felony charges for employers who repeatedly or willfully violate OSHA regulations, especially when such violations result in death or serious injury to workers.

Mining PELs –The Supplemental Miner Act (HR 2768) would amend the Federal Mine Safety and Health Act of 1977 in a number of areas. AFS staffers identified one aspect of this legislation that could set a precedent for many industries beyond mining. This is the automatic adoption of “recommended exposure limits” (RELs), as published by the National Institute of Occupational Safety and Health (NIOSH), to become the new “permissible exposure limits” (PELs), which are mandatory airborne contaminant levels regulated by OSHA. While acknowledging that many PELs are out of date and need to be revised, AFS liaisons expressed concern that a process of automatic adoption without Congressional hearings or debate is undesirable.

Silica –Earlier this year, OSHA expanded a 1996 “special emphasis program” to become a new National Emphasis Program (NEP) in crystalline silica. The goal of the program is to identify and reduce health hazards associated with workplace exposure to silica. One provision of this new program requires that a minimum of 2% of routine OSHA inspections be focused on silica. Inspectors will be looking for compliance with workplace controls such as local exhaust ventilation, worker isolation, use of HEPA vacuums, wet cutting methods and respiratory protection. Sand casting and sand blasting will be among processes targeted for inspection, and companies with a record of worker compensation claims for silicosis will be among those randomly chosen, irrespective of number of employees. Employers that participate in the Voluntary Protections Program (VPP) will be exempt from the random inspections.

Internal Audit –One presenter discussed the basic steps of performing internal audits for compliance with environmental and/or safety regulations. Also discussed was how commercial software packages can help facilitate both the audit and the required follow-up. IH

Part 1 of this column can be found in October 2008's archive.