OSHA and EPA frontline updates
The Non-Ferrous Founders' Society recently learned of several important developments affecting non-ferrous foundries that are worth sharing with our industry and our membership.
The Occupational Safety and Health Administration (OSHA) in Region 3 is actively inspecting foundries regarding a wide variety of general industry safety regulations. We have had reports of a significant number of aluminum-base, copper-base and steel foundries being subject to inspections by region 3 OSHA in recent weeks. While we have not yet heard of any iron foundry inspections, given the number and range of foundries that have been inspected, it is anticipated that ferrous foundries will soon see increased enforcement activity as well. If your foundry is in Region 3, it may be time to once again review your occupational safety and health (OSH) systems and documentation ahead of a possible inspection by representatives from OSHA. Ensure your organizational entry policy is updated and that your written procedures and training records have been reviewed and are up to date! As always, contact NFFS if you have any question regarding your OSH programs. We are here to help!
The Environmental Protection Agency (EPA) has been active in recent weeks as well. Region 6 EPA inspectors are actively investigating the amount of lead, nickel, chromium and other trace metals in aluminum alloys 319, 356 and 380, and the link to the required reporting of these (and other) substances on the foundry Tier II (R Form) report. At question is whether the concentration percentage identified on the Safety Data Sheets (SDS) for these trace metals can be or should be used in the calculation to determine whether a foundry has exceeded reporting thresholds based upon the quantity of aluminum alloys processed.
NFFS is asking its members to let the Society know if you are in Region 3 and receive a notice of inspection from OSHA, a surprise enforcement visit by OSHA representatives, or if you receive any communication from Federal EPA regarding R Form filings for aluminum foundries with respect to Lead, Nickel, Chromium or other trace contaminants.