Steel Founders Society of America Silica Study

Transcription

1 Steel Founders Society of America Silica Study 1) Identify potential areas/occupations/operations in the steel foundry where operator exposures may be at or above the OSHA PEL of 50 µg/m 3 of respirable silica. 2) Identify potential areas/occupations/operations in the steel foundry where operator exposures may be at or above the OSHA Action Level of 25 µg/m3 of respirable silica. 3) Determine control or exposure areas (the physical space surrounding these over exposure occupations/operations that will require inclusion in the Silica Program for these identified areas of potential overexposure) 4) Determine potential sources of silica that contribute to over exposure at these occupations/operations 5) Determine feasible means of control of potential sources of silica overexposure in steel foundries with consideration of the range of sizes, configurations, production methods. 6) Establish standard of care for the industry to assist foundries in determining feasibility of compliance with the OSHA Silica Standard

2 Respirable crystalline silica (a) Scope and application. (1) This section applies to all occupational exposures to respirable crystalline silica, except: (2) This section does not apply where the employer has objective data demonstrating that employee exposure to respirable crystalline silica will remain below 25 micrograms per cubic meter of air (25 μg/m3) as an 8-hour time-weighted average (TWA) under any foreseeable conditions Engineering and work practice controls. The employer shall use engineering and work practice controls to reduce and maintain employee exposure to respirable crystalline silica to or below the PEL (50 μg/m3), unless the employer can demonstrate that such controls are not feasible. Wherever such feasible engineering and work practice controls are not sufficient to reduce employee exposure to or below the PEL, the employer shall nonetheless use them to reduce employee exposure to the lowest feasible level and shall supplement them with the use of respiratory protection that complies with the requirements of paragraph (g) of this section. METHODS of Control The Respirable Crystalline Silica standard lists ENGINEERING and WORK PRACTICES as methods of control However, other means of compliance may include SUBSTITUTION OF MATERIALS THAT CONTAIN THE TOXIC SUBSTANCE. CHANGES IN PRODUCTION OR PROCESS METHODS CHANGES IN PLANT LAYOUT THAT MAY INCLUDE ISOLATION ELIMINATION OF WORKERS OR CONTROL OF WORKERS IMMEDIATE ENVIRONMENT Which of these are FEASIBLE for Steel Foundries? In American Textile Manufacturers Institute, Inc. v. Donovan (Cotton Dust), the Supreme Court held that feasible in section 6(b)(5) of the OSH Act means capable of being done. The the Court determined the OSH Act did not mandate cost-benefit analysis because Congress itself defined the basic relationship between costs and benefits, by placing the benefit of worker health above all other considerations save those making attainment of this benefit unachievable. However, lower courts have divided feasibility into two components: technological feasibility and economic feasibility. The courts have required OSHA to demonstrate that the technology could meet a standard specified in United Steelworkers v. Marshall either already in use or has been conceived and is reasonably capable of experimental refinement and distribution within the standard s deadlines. Court decisions also determined that OSHA is require[d]... to establish [a] standard s economic feasibility in a particular way, OSHA must construct a reasonable estimate of compliance costs and demonstrate a reasonable likelihood that these costs will not threaten the existence or competitive structure of an industry, even if it does portend disaster for some marginal firms.

3 Operations/Occupations with Potential Silica exposure in the Steel Foundry 1) Charge preparation 2) Charging furnace 3) Furnace and Ladle relining (including heat treat furnace) 4) Sand Mixer (chemically bonded sand) 5) Sand Mullors (clay bonded sand) 6) Workers near sand conveyance, handling, screening, cooling, reclamation 7) Core Makers 8) Core finishing 9) Shake out 10) De spruing 11) Shot blast a) Tumblast b) Table Blast c) Cabinet Blast d) Rotary Blast 12) Sand blast 13) Grinders a) Pedestal Grinder b) Hand Held Grinder 14) Chippers 15) Burners 16) Utility (clean up) 17) Dust Control Maintenance 18) Non Routine tasks

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