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NFFS regulatory consultants, Guimond & Associates, are available to assist members with specific regulatory questions or problems via phone or fax. A special member telephone Hotline has been established especially for use by NFFS Members. |
NFFS Safety & Environmental Office |
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Reducing the burden that newly-enacted or expanded laws and regulations place upon foundries is the primary goal of many of the NFFS programs and services for metalcasters. Small foundries in particular often do not have the financial and/or personnel resources required to stay abreast of changing internal safety, environmental or industrial hygiene requirements. Several examples of NFFS-developed compliance assistance programs include: EPA Storm Water Permitting NFFS organized a Group Storm Water Permit application as an affordable means for non-ferrous foundries to comply with this regulatory requirement. More than 100 metalcasters nationwide enrolled in the permit application, and NFFS coordinated the collection and submission of storm water run-off samples at sample foundries for submission to EPA. As a result of the data submitted, the regulatory requirements for non-ferrous foundries in EPA's final Multi-Sector General Permit implemented in 1995 were far less costly and restrictive than those in the agency's Baseline General Permit enacted several years earlier. The Society has also developed a generic Storm Water Pollution Prevention Plan (SWPPP) to give foundries general framework to follow in implementing this requirement of state and federal storm water permits. OSHA's Airborne Lead Standard Largely because of the Society's comments and opposition to OSHA's proposed reduction in the airborne lead exposure limits, non-ferrous foundries were given five years (until July, 1996) to bring their work practices and engineering controls into compliance with the standard's requirements. During that time, the Society has offered a continuing series of training workshops for foundries describing the new standard's requirement and what non-ferrous foundries would have to do in order to comply. Aluminum Dross Shipping Regulations Responding to a federal register notice concerning new shipping regulations established by the Department of Transportation affecting certain foundry byproducts including aluminum dross and skims, NFFS applied for and was granted an exemption from certain DoT requirements on behalf of all of its members that cast aluminum. First proposed in 1994, this regulation applied to the shipper rather than to the company that receives it. Under the regulation, aluminum dross is treated as a hazardous material. The NFFS exemption waives the place carding and labeling requirements of the regulation, but not the applicable shipping requirements. Subject materials must still be shipped in sift-proof containers that are covered to prevent the material from getting wet. Accompanying shipping papers must describe the contents as "Aluminum processing by-products, 4.3 Dangerous when wet, " and include a 24-hour emergency response phone number and specific certification language. A copy of the NFFS exemption papers must also accompany the shipping papers. |
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