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/m3 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

§1910.1053 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.”

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