Silica Threatens Your Existence.

"We won't survive the silica issue with a wait and see attitude. At best, the expense to reach a lower permissible exposure limit (PEL) is going to place a majority of foundries further into a noncompetitive situation on pricing. At worst, the shakeout forecasts as bad as the early 80s, as many foundries will be forced to close their doors."

These words aren't mine. They are those of your fellow foundrymen. They are voiced as a warning to all the foundries that haven't taken notice of the new comprehensive crystalline silica standard OSHA is developing for a proposed rulemaking in early 2001. They are voiced as a call to arms.

Four years ago, OSHA announced that crystalline silica was designated for comprehensive rulemaking. This was due, it said, to the more than 2 million U.S. workers at risk to silica exposure and the more than 250 workers that die each year due to silica-related diseases. According to OSHA, significant progress in prevention will not be achieved without a comprehensive standard (which includes a reduced exposure limit, dust monitoring, medical surveillance, worker training, engineering controls, respirators and record keeping) because exposure at the current PEL poses a "significant risk" for silicosis and lung cancer. Although the extent of the proposed exposure limit reduction still is unknown (OSHA is considering up to four different concentrations), the National Institute for Occupational Safety and Health 

(NIOSH) has recommended a 50% reduction from 0.1 mg/cu m to 0.05. (However, some reports say this figure could be lowered up to another 50%.) This new rule would affect the 67% of our foundries that use one or more of the various sand casting processes (according to the Casting Source Directory).

What would a 50% reduction mean to your foundry?

According to a 120-employee gray and ductile iron nobake foundry with annual shipments of 3700 tons, the cost to comply with a 0.5 PEL is $850,000 for a brand new air exhaust system with no guarantee of meeting a 50% reduction. Its current exposure levels range from 0.061 in the coreroom to 0.89 at shakeout. One interesting fact for this foundry--it has been in operation since 1917 without a single reported case of silicosis.

Another 250-employee green sand iron foundry just spent $480,000 to achieve compliance with the current PEL and states, "I am not sure how our plant complies with a lower PEL even with more exhaust. How much does OSHA expect us to spend per employee to achieve a reduced PEL?"

No one argues about worker protection. The argument is that if OSHA just would enforce the current 0.1 PEL, the threat of silica-related diseases would disappear.

According to OSHA's own data from silica samples taken from 1980-1992, 48% of the companies tested had exposure limits exceeding 0.1. Yet, according to NIOSH, deaths related to silicosis declined 78% from 1968-1992. This reduction can be attributed to industries beginning to understand the silica problem in the 1930s and adopting measures to eliminate it.

This reduction can be substantiated by Dr. William Graham, a pulmonary physician at the Univ. of Vermont who has studied silica-related diseases in granite workers for more than 20 years. His state's granite industry has enforced the equivalent of OSHA's PEL since 1940 and has seen the reduction in disease. Based on his studies, Graham believes silica-related problems would be eliminated if the current PEL were "strictly enforced."

The foundation for OSHA's case for a lower PEL and comprehensive standard is scaring the public and Congress by linking lung cancer and silica exposure. As reported in The Wall Street Journal, this link was made from a NIOSH study of 3246 quarry and mine workers that had 52 deaths due to lung cancer and a 1996 statement from the International Agency for Research on Cancer that classified crystalline silica as "carcinogenic to humans." The problem scientists see with this study and statement is that they don't account for smoking and other factors that might contribute to cancer. In fact, NIOSH researchers examined the smoking histories of 30 of those workers who died and found that 93% had been smokers. That information, however, was dropped from the final study along with the conclusion that the excess lung cancer cases in the workers "can be largely attributed to cigarette smoking."

OSHA is holding another stakeholder meeting on crystalline silica at the end of this summer, and is expected to issue a draft of the new silica regulation at that time. While the AFS Silica Alliance and the Silica Coalition (made up of trade associations and companies in the construction, maritime, mining and metalcasting industries) maintain a presence in front of OSHA to fight the unsubstantiated health risk claims, foundries first must meet the current standard. Then, it is your duty to determine the economic impact a comprehensive silica rule with a lower PEL would have on your plant, participate in the studies being used to support the foundry industry's position against a lower PEL, and voice these results to the policy-makers in OSHA and Congress. They need to hear it from you to understand that this new rule potentially could destroy an industry so vital to our nation's economy. If you don't, our industry could be entering an era that may cause many foundries to recall the 80s as the good old days.

Alfred T. Spada

Managing Editor