Metalcaster speaks against OSHA's possible reduction of the Silica PEL.In light of OSHA's proposed draft-rule to lower the permissible exposure limit The Permissible Exposure Limit (PEL or OSHA PEL) is a legal limit in the United States for exposure of an employee to a substance, usually expressed in parts per million (ppm), or sometimes in milligrams per cubic metre (mg/m3). (PEL) of crystalline silica, I was asked to participate in a Small Business Regulatory Enforcement Act (SBREFA SBREFA Small Business Regulatory Enforcement Fairness Act ) process to review the plan. This panel was sponsored by the Small Business Advocacy Review (SBAR SBAR Situation, Background, Assessment, Recommendation (clinical care; aka situational briefing model) SBAR State Bank Advance Rate (prime lending rate of State Bank of India) ). Several points of concern for the metalcasting industry were developed and addressed during a conference call held Nov. 12, 2003 for the SBREFA panel. The following is a summary of my verbal comments during the call: At Kansas Castings, we believe in protecting our employees and are constantly striving to create a safe working environment. Statistics show a drop in silicosis related deaths over the last 20 years of nearly 80%. I believe the current PEL is doing the job. In March of 1999, Marthe Kent, OHSA OHSA Occupational Health and Safety Act (various countries) OHSA Occupational Health and Safety Agency (Health Canada) , stated that 30% of operations are not in compliance. I believe that OSHA OSHA n. Occupational Safety and Health Administration, a branch of the US Department of Labor responsible for establishing and enforcing safety and health standards in the workplace. should devote time and effort on education and consultation with these operations. An example might be that if the speed limit is 60 mph and 70% of the traffic obeys this law, you don't lower the speed limit to 30 mph to compensate for the 30% who don't obey. Logically, you just enforce the 60 mph limit. Yes, 30 mph might save lives but at what cost to the majority? If it were possible to engineer a ventilation system ventilation system Public health An air system designed to maintain negative pressure and exhaust air properly, to minimize the spread of TB and other respiratory pathogens in a health care facility to comply with the 0.5 or the 0.75 PEL, it would require many more parts to be installed. Start up costs to engineer, purchase and install the equipment would be approximately $117,450. Even if tax credits were made available, with 38% of the foundries nationwide losing an average of 6.39%, a tax credit would have no value. The new monitoring standards also would require us to purchase new monitoring equipment, re-train employees and provide maintenance for this equipment at a projected cost of $16,000 per year. Taking into consideration that silica is an inhalation hazard not an ingestive hazard, the need for changing rooms
This experience made me appreciate what governmental affairs means to our industry. I encourage all metalcasters, regardless of their position, to get involved in government affairs. Together, we can make a difference. Ron Pomeroy President Kansas Castings Inc. Belle Plaine Belle Plaine may refer to:
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