NFFS and AFS Cooperate to Assist EPA with Area Source Rule


The U.S. Environmental Protection Agency (EPA) is under a court-mandated deadline to issue new area source rules for Hazardous Air Pollutant (HAP) emissions from 54 industry sectors.  The Non-Ferrous Founders’ Society (NFFS) and the American Foundry Society (AFS) have learned that a rule for Aluminum, Copper, and Other Nonferrous Foundries (non- diecasting) will be included in the final group to be issued in June 30, 2009.

To meet its deadline, the agency must have a draft Proposed Rule written by no later than January, 2009.  Before preparing the draft, however, the agency first needs to collect some production and HAP emissions data from the industry to support the rulemaking.  Complicating this effort, however, the EPA is limited in the number of data questionnaires it can actually send out to foundries without triggering the restrictions of the Paperwork Reduction Act.  In fact, the agency can only send nine questionnaires to each industry segment, to be answered on a completely voluntary basis, for a total of 27 potential industry responses.

To try to fill the information gap such a limited data collection creates, NFFS and AFS have agreed to cooperate in providing additional supplemental data on non-ferrous foundries to the EPA for its information and consideration.  The two metalcasting societies will be posting the industry’s own survey forms - one for aluminum foundries, a second for copper-alloy and other non-ferrous metals (including magnesium, titanium, zinc, lead, nickel-base and beryllium-base alloys) – on their respective websites for access by all non-ferrous foundries.

Our goal in doing this is two-fold.  First, we want to assure that any rule issued by the EPA is based upon a complete analysis of the HAP emissions emanating from nonferrous foundries.  Second, we hope to limit as much as possible the imposition of needless or contra-competitive costs and paperwork burdens on foundries by insuring that EPA’s new rule recognizes the practices and controls already in place and the positive effect those have had in reducing HAP emissions from the industry.

The societies will submit the information we obtain to EPA in the form of a composite report.  That report WILL NOT identify any facilities by name or location.  Moreover, as an industry-directed project, your participation is completely voluntary, and no monitoring or emissions testing is required to respond to this request.

While your response to this general information questionnaire is completely VOLUNTARY, NFFS and AFS strongly urge your cooperation so we can achieve our objectives of offering EPA a general assessment of the industry for their rulemaking effort, and effectively representing the concerns and interests of copper and other nonferrous foundries that may be covered by EPA’s proposed area source rule.

To access the Copper & Other Nonferrous Foundry Survey forms and instructions, CLICK HERE

To access the Aluminum Foundry Survey forms, CLICK HERE

Completed survey forms can be returned by mail or fax to either:

Non-Ferrous Founders’ Society
Attn: Area Source Rule Survey
1480 Renaissance Drive, Suite 310
Park Ridge, IL 60068, USA
Fax: 847/299-3598

or

American Foundry Society
Attn: Area Source Rule Survey
1695 Penny Lane
Schaumburg, IL 60173, USA
Fax: 847/824-7848

 


Report: Small Manufacturers More Affected by Global Competition

A report released by the Office of Advocacy of the U.S. Small Business Administration finds that currency exchange rate pressures lead to an increase in the exit rates very small manufacturers (fewer than 20 employees). According to the author of the paper, small manufacturers in high-tech industries are more insulated from international competitive pressures than those in other sectors.
 
The study, The Impact of International Competition on Small-Firm Exit in U.S. Manufacturing, focused on 1990 to 2004. The author noted little variation in the overall exit rate of small manufacturers over time, but a reasonable amount of variation across firm size and industry. Factors affecting exit across firm sizes included overall economic activity, labor costs, and whether the firm’s industry sector produced consumer goods. Changes in an industry’s import share produced mixed results across time periods and firm sizes.

For a complete copy of the new SBA report, click here.

OSHA Places New National Emphasis on Silica

WASHINGTON -- The U.S. Department of Labor's Occupational Safety and Health Administration (OSHA) has announced a new National Emphasis Program (NEP) to target worksites where employees are at risk for developing silicosis. Silicosis is a disabling, nonreversible and sometimes fatal lung disease caused by breathing in a large amount of crystalline silica. Visit www.osha.gov for more information on hazard recognition and possible solutions to silica exposure.

"Exposure to silica threatens nearly two million American employees annually," said Assistant Secretary of Labor for OSHA Edwin G. Foulke, Jr. "Under this program, OSHA will work diligently to maximize the protection of employees and eliminate workplace exposures to silica-related hazards."

The NEP compliance directive builds on policies and procedures instituted in the 1996 Special Emphasis Program and includes an updated list of industries commonly known to have overexposures to silica; detailed information on potential hazards linked to silica and about current research regarding silica exposure hazards; guidance on calculating the Permissible Exposure Limits (PELs) for dust containing respirable crystalline silica in the construction and maritime industries; and guidance on conducting silica-related inspections.

Two additional elements included in the directive are an evaluation procedure for recording reductions of employee exposures to silica, as well as information on outreach programs, partnerships and alliances with employers to share resources and training to reduce employee exposures.

Under the Occupational Safety and Health Act of 1970, employers are responsible for providing a safe and healthful workplace for their employees. OSHA's role is to assure the safety and health of America's working men and women by setting and enforcing standards; providing training, outreach, and education; establishing partnerships; and encouraging continual process improvement in workplace safety and health.

For a full copy of the OSHA Silica NEP release, click here

 

NFFS receives OSHA grant to provide 
Electrical Safety/NFPA 70E Arc Flash
training seminars to foundries

NFFS is pleased to announce that the Society has received its fourth Susan B. Harwood grant from OSHA.  The new grant will fund the development of bilingual (English and Spanish) training materials and provide for the conduct of Electrical Safety/Arc Flash training seminars for small business owners and their employees in the cast metals industry. The session is appropriate for ferrous and non-ferrous operations, including foundries, die casters, and secondary smelters. Students attending the training seminars will receive a CD-Rom of the bilingual materials and a written compliance materials. Additional information will be provided as it becomes available.

In 2006, NFFS receive and OSHA grant to provide training seminars addressing Workplace Emergency Planning topics. The seminars will be held in 2008 in conjunction with the Electrical Safety/Arc Flash training seminars.

In 2005, NFFS received an OSHA grant to develop a Lockout/Tagout Training Seminar series for foundries. This grant provided funding for the development of bilingual Lockout/Tagout training and compliance materials in addition to providing 9 regional training seminars. Although the seminars have been completed, the training materials and written compliance program are available at the NFFStar Lockout/Tagout Materials homepage.

In 2004, NFFS received an OSHA grant to develop and distribute a bi-lingual Lead Hazards Training program for foundries. As announced by NFFS in September, 2005, the project has been completed and is available for download or for delivery in printed format at the NFFStar Lead Hazards website.

 

NIOSH Offers Ergonomic Guidelines

The National Institute for Occupational Safety and Health (NIOSH) has issued a new publication called Ergonomic Guidelines for Manual Material Handling.  According to NIOSH, manual material handling (MMH) work contributes to a large percentage of the more than half million cases of musculoskeletal disorders reported annually in the U.S. Musculoskeletal disorders often involve strains and sprains to the lower back, shoulders and upper limbs. They can result in protracted pain, disability, medical treatment and financial stress for those afflicted with them, and employers often find themselves paying the bill, either directly or through workers' compensation insurance. At the same time, employers must cope with the loss of the full capacity of their workers.

 Though OSHA has yet to published an actual ergonomics standard, foundries may find the NIOSH booklet useful and relevant.  It offers suggestions to improve the handling of rectangular, square and cylindrical containers, sacks, and bags. Download a copy of the 68 page document.

 

NFFS receives OSHA grant to provide Workplace Emergency Planning training seminars to foundries

NFFS is pleased to announce that the Society has received its third Susan B. Harwood grant from OSHA.  The new grant will fund the development of bilingual (English and Spanish) training materials and provide for the conduct of Workplace Emergency Planning training seminars for small business owners and their employees in the cast metals industry. Students attending the training seminars will receive a CD-Rom of the bilingual materials and a written compliance materials. Additional information will be provided as it becomes available.

In 2005, NFFS received an OSHA grant to develop a Lockout/Tagout Training Seminar series for foundries. This grant provided funding for the development of bilingual Lockout/Tagout training and compliance materials in addition to providing 9 regional training seminars.

In 2004, NFFS received an OSHA grant to develop and distribute a bi-lingual Lead Hazards Training program for foundries.


  Metalworking associations form health insurance trust

Five metalworking trade associations have taken an unprecedented action by forming a joint Insurance Trust to offer a common health & dental employee benefits program exclusively to their collective memberships.  Partnering with Trustmark Affinity Markets (a leading insurance carrier), the associations will now be able to pool the claims experience of more than 1,600 member companies to better control the rise in insurance premiums for participating members over the life of the program.

 “Finding and keeping good employees can be difficult for any small business, but it can be an enormous problem for many manufacturers still operating in the U.S. today,” said Jim Mallory, Executive Director of the Non-Ferrous Founders’ Society.  “Paying competitive wages is just one part of an employee’s total compensation.  A recent study by the National Association of Manufacturers (NAM) concluded that the sharp rise in non-wage costs represents a significant and long-term problem for our nation’s manufacturers and America’s economy.  Chief among the increases that manufacturers have faced in recent years is the skyrocketing cost of healthcare.”

The five associations are:  the Industrial Fasteners Institute; the Forging Industry Association; the Non-Ferrous Founders’ Society; the Precision Metalforming Association; and the Spring Manufacturers’ Institute.  Trustmark Affinity Markets is part of Trustmark Companies, with nearly 100 years in the insurance industry and more than 50 years as a leader in servicing associations and other affiliated organizations.  Together, they have formed the Metalworking Manufacturing Coalition (MMC) Trust.

The MMC Health & Life Trust Plan offers a range of choices for participating member firms, their employees and families.  Some of the coverage options the plan offers include:

PPO Plan – Trustmark’s PPO offers flexible options to choose different deductible and coinsurance levels.  Employees can choose any caregiver or facility, but typically pay less when services are rendered inside the extensive PPO Network.

Health Savings Accounts (HSA) – HSAs offer an innovative marketplace solution to the problem of rising healthcare costs by placing the insured employee more closely in charge of healthcare spending.

Prescription Drug Benefit – Trustmark’s selected pharmacy management partner has more than 57,000 network pharmacies nationwide, including both national chain stores and independent pharmacies.  In addition, PrecisionRx mail service pharmacy delivers medication to over 1 million patients nationwide.

Extra Benefits – Dental is one of the most frequently requested member benefits and can easily be added to a company’s coverage plan.  Trustmark’s plan offers the cost advantages of a PPO with the freedom to choose any dentist.  Life and Accidental Death & Dismemberment coverages are also available to complement medical coverage.

Membership in good standing in one of the five associations is required in order for a metalworking company to participate in the MMC Insurance Plan.  Additional information on the coverage options is available by contacting George Michelic at Trustmark Affinity Markets.  Information on their respective membership eligibility requirements, costs, and benefits can be obtained from each of the associations.

For additional information, contact:

TRUSTMARK AFFINITY MARKETS

Attn: George Michelic
400 Field Drive
Lake Forest
, IL  60045
Phone:  847-283-2041
Fax:  847-615-3898
E-mail:  gm2@trustmarklife.com

Download Program Brochure

Manufacturers' Non-Production Costs Escalate

In December of 2003, the National Association of Manufacturers and the Manufacturing Institute released the results of a study showing that external, non-production costs added approximately 22 percent to unit labor costs for U.S. manufacturers. “The Non-Ferrous Founders’ Society and other manufacturing associations have deliberately and repeatedly cited that study in communications with the government, from the Commerce Department’s Manufacturing Initiative to the ITC’s 2005 Section 332 report on the Competitive Conditions in the U.S. Market for Foundry Products,” said NFFS Executive Director Jim Mallory, “but we have recently learned that the percentage we’ve been citing with such vigor and volume is, in fact, wrong.”


NAM, the Manufacturing Institute, and the Manufacturing Alliance/MAPI have now updated the study. The original document reported on costs up until 2003. The new study reexamines those costs and concludes that the trends are headed in the wrong direction. Using 2005 figures, the report now suggests that the same external costs add 31.7% to a U.S. manufacturer’s production costs.

“This increase from just three years ago is astonishing,” said Jeremy Leonard, the economist who authored the MAPI study. “Because of these escalating costs, fewer new manufacturing jobs have been created and less funding has been available to invest in research and development and worker training.”

According to the study, by standing still, the United States has fallen further behind. Pollution abatement costs alone have increased by 11.5% since 2000, to an estimated $77 billion in 2004, raising the U.S. excess cost burden by 1.7 percentage points relative to its major trading partners. “Much of this burden is simply not recognized by the EPA when it prepares its estimates of the benefits and costs of its regulations,” Mallory noted, “and the result is that benefits-to-cost ratios of proposed new rules are often grossly overstated.”

Escalating Costs Study


DHL Preferred Pricing for NFFS Members

NFFS would like to announce a new partnership with the world’s largest and international air express network, DHL. Members have the opportunity to streamline costs with this new membership benefit. 

These specially negotiated parcel discounts are based on overall expedited usage and projected total monthly participation, rather than package size and shipping frequencies (there is no volume requirement to participate in this program).

NFFS members can save up to 25% on the following:

• Next day delivered by 10:30 AM, & by noon,
• Next day delivered by 3:00 PM,
• 2nd day deliveries,
• Ground deliveries, and
• Worldwide document, parcel express, and import express.

 It’s easy for members to open their DHL account.  Members will be able to sign up for the program by contacting us using any of these convenient methods:

 Call: 800-647-3061 ext. 6560     Fax: 913-982-5923          Online