Surviving the OSHA lead standard: how three foundries are complying.

Five years ago, OSHA set the deadline for the 1996 Lead Standard. These three large foundries share their steps on the road to compliance.

The Occupational Safety and Health Administration's (OSHA) deadline for installing engineering controls to reduce employees' 8 hr time weighted average exposures to air borne lead was July 19, 1996. Nonferrous foundries with 20 or more employees are required to have installed all practical and feasible engineering controls and administrative controls in their plants to attempt to reduce exposures to 50 ug/[m.sup.3] or less. For firms with 20 or fewer employees the standard requires them to reduce exposures to 75 ug/[m.sup.3] or less.

The following three case studies presented at the 8th AFS Environmental, Health and Safety Conference in August outline what these foundries did at their facilities to come into compliance with OSHA's lead standard.

VERMONT FOUNDRY

Vermont Foundry Co., Vermont, Illinois, is a jobbing shop operation serving a customer base of about 120 companies. The foundry pours the entire realm of copper based alloys, with its primary end products used in the valving, electrical plumbing, lighting and gray water system industries. The foundry employs about 120 and uses one primary melting and pouring shift to consume about 3.5 million lb of metal per year.

In early 1994, with OSHA's 50 ug/[m.sup.3] lead standard looming on the horizon, Vermont Foundry began to assess what it would take to meet the standard. Air sample results showed that the melting and finishing departments would need further controls at most employee positions to obtain compliance. At that time, management's perspective was that most of those positions could be brought into compliance with further engineering controls.

The company designed an internal management program to remedy this situation. It was referred to as Vermont Foundry's Lead Abatement Program.

Phase I--The Melting Dept.

Vermont Foundry began its program in the melting department. After years of using overhead exhaust fans and a small baghouse, the firm decide it was time to invest in a dust collector of substantial size and capability. Members of the lead abatement team decided to purchase a 35,000 CFM dust collector hoping to bring the melting department into compliance with the 1996 standard. Suction was brought in from the new collector directly to the furnaces and capture hoods were installed in the skimming areas.

As a result, melting department employee exposure levels were immediately affected. Positions that were previously testing around the 200 ug/[m.sup.3] level dropped to about 50-100 ug/[m.sup.3]. These levels have remained somewhat consistent since the installation of the collector.

According to the company, further engineering controls in the melting department will probably be necessary to reach full compliance. Specifically, capture hoods for pouring ladles will need to be installed. The entire cost of Phase I of Vermont Foundry's Lead Abatement Program was about $250,000.

Phase II--The Finishing Dept.

Vermont's next goal was to bring its finishing department (grinding room) into compliance. The lead abatement team was especially concerned with the grinder, cutoff saw operator and deburring positions. Previous sampling of these employee positions ranged from 75-150 ug/[m.sup.3]. The department had been serviced by four small, inefficient dust collectors which weren't capable of meeting the 1996 lead standard.

In hopes of recovering some of the associated costs of regulatory compliance, the lead abatement team searched for a company who could engineer the second phase of the Lead Abatement Program while providing a plan to make castings flow through the department more efficiently. MetalCast Systems, Inc., Plymouth, Indiana, agreed to engineer the program and guaranteed to meet the lead standard at all finishing department employee positions. Through the firm, Vermont Foundry purchased a 48,500 CFM dust collector to service the finishing department. Furthermore, an ergonomically sound, efficient flow plan for the department was designed and incorporated into the Lead Abatement Program.

Use of conveyor belts, down draft booths and assembly of secondary work stations were some of the necessary adjustments made to the finishing department. The total cost of Phase II was about $450,000.

Today at Vermont Foundry

Upon completion of Phase 11 in June 1996, the foundry was ready to test plant-wide and see if its efforts paid off. Although the foundry has in-house air sampling pumps, company officials used a third party to ensure accuracy for these critical evaluations. The foundry is awaiting the results of the testing. With just a few more obstacles to overcome, the company states the efforts made by the Lead Abatement Program will eventually lead Vermont Foundry Co. into full compliance of the 1996 lead standard.

MATTHEWS INTERNATIONAL CORP.

To achieve compliance with OSHA's lead standard, Matthews International Corp., Pittsburgh, employed participative team management techniques. Lead teams were established for each of the company's four operating foundries consisting of engineering, environmental, maintenance, management and production personnel from each location. The teams met on a regular basis to define project goals and objectives, discuss project implementation, and follow up on a variety of project issues. Because of the group's diverse interests and experience, the team concept was a vital part of its success.

Road to Compliance

The first step the Matthews lead teams took toward achieving compliance with the 50 ug/[m.sup.3] lead standard was to identify the scope of the project. This was done by conducting three rounds of comprehensive employee exposure monitoring at each plant. This included all representative occupational positions and all shifts.

The company purchased new monitoring and calibration equipment to upgrade facility lead in air exposure monitoring capabilities. In addition, specialized training was provided to employees who conduct lead in air testing.

In addition to conducting the exposure monitoring testing, monitoring personnel also identified work practices that may exacerbate lead exposure. Employees were informed of these findings, and an additional round of testing was done to confirm lead exposure.

Based on the results of the lead exposure monitoring testing, Matthews classified various foundry positions into one of three general categories (Table 1.)

Table 1. Airbone Lead Exposure Categories

Exposure Category

A    Lead in Air Concentration (8-hour time
B    weighted average--TWA)
C    < 30 ug/[m.sup.3]
       30 ug/[m.sup.3]-50 [m.sup.3]
       50 [m.sup.3] >

These levels were selected because they correlate with specific requirements contained in the OSHA Lead Standard. The "action level" as defined by OSHA is 30 ug/[m.sup.3], the PEL as defined in the standard is 50 ug/[m.sup.3].

Category A employees exposed below the action level must be given a copy of appendices A and B of the lead standard annually if their job involves any exposure to lead.

Category B employees are exposed to lead at or above the action level and must receive annual lead standard training, be monitored every six months to determine airborne lead exposure, and must have a blood lead and zinc protoporphyrin (ZPP) test at least every six months.

Category C employees are covered by the full provisions of the OSHA lead standard and are the key positions that must be in a program to reduce 8 hr time weighted average exposures below 50 ug/[m.sup.3].

Based on the results of Matthews' initial exposure monitoring program, the scope of the engineering control project was identified for each of its four large nonferrous foundries.

Compliance Alternatives

After defining the project scope, Matthews evaluated two compliance alternatives that could potentially be employed to achieve the standard. These included substituting low lead alloys for production purposes and using administrative controls such as job rotation to the meet the standard.

Because of the intense administrative burden and the amount of cross training required for employees, administrative controls were dismissed as an impractical option for compliance at each of Matthews foundries.

Low lead alloys (bismuth) may be used for some nonferrous casting operations, however, foundries must evaluate the physical and chemical characteristics of the alloy to determine its ability to substitute for leaded brass and bronze alloys. In addition, testing of alternative alloys must be conducted to determine key casting characteristics such as shrinkage and machinability. Only after such an analysis is completed should low lead alloys be considered as a compliance alternative to the engineering control provisions of the lead standard. Matthews determined after extensive testing that this alternative would not work for their production.

Existing Engineering Controls

Once Matthews ruled out the compliance alternatives, the lead teams focused on implementing engineering controls to achieve the 50 ug/[m.sup.3] limits.

The first step in this effort was to identify and evaluate existing engineering controls used at each of its facilities. This included plant mechanical exhaust systems, air pollution control devices (baghouses) serving ventilation systems, and plant makeup air and general ventilation systems (louvers, passive vents, etc.).

This information was compiled for each facility and used to prepare a bid package for each of Matthews' foundries. This allowed consultants bidding on the project to have access to the same information when preparing offers to enhance engineering controls used at each of the foundries.

Competitive Bidding

Next, Matthews sought competitive bids to achieve compliance with the standard. Bid packages were distributed to a minimum of three ventilation design engineering firms with expertise in the foundry industry. A comprehensive scope of work was included with the bid package.

The bids were evaluated by the lead teams and input was sought from each member to ensure that all aspects of each proposal were evaluated. A bid evaluation matrix was prepared by engineering and environmental personnel to provide team members with a comparative tool for decision making.

Bid Selection/Scheduling/Contract Preparation

Following a thorough analysis of each bid, the lead teams reached a decision and began to develop a schedule for project implementation with Perri Environmental Services, Racine, Wisconsin.

One key scheduling component that shouldn't be overlooked by nonferrous foundries is the time required by regulatory agencies to approve air permit application for construction or modification of air pollution control devices. Foundries may experience delays of up to four to six months to obtain permits to construct at some facilities. Foundries should also ensure that the contractor selected to complete the work has adequately accounted for any delays that may be experienced in equipment delivery and duct work construction.

Contractual agreements were developed by Matthews and executed by the vendor selected for the lead in air engineering control work completed at each plant. Foundries should ensure that each party has a clear understanding of what tasks will be completed by the contractor and what tasks are the foundry's responsibility. In addition, a clear understanding of performance requirements should be contained in any contract covering lead engineering control work.

Post Engineering Control Installation Actions

Following installation of the engineering control systems at Matthews' facilities, two major tasks were completed. First, mechanical exhaust systems were tested and balanced and the results of the testing were compared against performance standards contained in the contract between the foundry and the contractor.

Second, post control exposure monitoring was completed to determine post control exposure levels. The results of this testing are being used to reclassify various positions into the category of occupational lead exposure shown in Table 1. The foundry then revised its written lead programs to reflect post engineering control conditions.

Matthews recorded all actions taken in this matter and compiled the information into a comprehensive notebook. The company has also conducted extensive employee training on the operation and maintenance of all ventilation systems.

Using this systematic approach Matthews International Corp. proved that compliance with OSHA's 50 ug/[m.sup.3] limit for airborne lead levels can be achieved by nonferrous foundries where such action is technically feasible and practical.

SLOAN VALVE

Sloan Valve operates a brass foundry in Augusta, Arkansas. Serving mainly the plumbing industry, the foundry pours thousands of pounds of metal every week. In its initial efforts to come into compliance with the 1996 lead standard the foundry made changes to the ventilation system on the melt deck, but found it was unsuccessful.

The company then hired a professional to reevaluate the existing ventilation systems and the written management plan. Production and maintenance staff were involved in the process every step of the way to develop a strategy and recommendation for achieving compliance using feasible engineering controls.

A thorough review revealed that the foundry had adequate ventilation equipment in place, but the melt deck hoods were incapable of efficient capture. The study showed that the foundry could double or even triple the air flow on the melt deck, yet all that would do is exacerbate the thermal rise. In addition the melt deck tenders' work practices contributed to their exposure.

An Action Plan

Following the review, Sloan Valve's first step was to conduct air sampling across the foundry. Then several duct changes in areas like the melting, pouring and cleaning rooms were made.

Because the melt deck area exhibited the most exposure, something had to be done. A melt deck furnace hood was designed and fabricated for one of the furnaces and put in place for testing. In addition, the company retrained melt deck operators and changed specific work practices that were contributing to the problem.

The trial of the initial furnace hood seemed to alleviate the problem on the melt deck, so Sloan Valve committed to new hoods for the additional two furnaces.

Results

Upon final hood installation, which was done on weekends to prevent production interruption, Sloan conducted a full round of employee and area air sampling.

This second round of tests in area air sampling locations verified a reduction in lead from greater than 100 ug/[m.sup.3] to less than 30 ug/[m.sup.3]. Furnace tenders were tested between 50-100 ug/[m.sup.3], and it was confirmed that they were still crossing the clean air line and entering the hood during the testing.

General foundry samples were less than 80 ug/[m.sup.3] and the cleaning room was less than 50 ug/[m.sup.3], with the exception of the large grinding stations.

A final look at the results of this testing showed that the average lead and cadmium levels were reduced by 78% on the melt deck and 45% in the cleaning room. Compliance was achieved with good engineering controls and a sound engineering approach to solving the problem. Also in Sloan Valve's case, compliance was achieved without a major capital investment for new control equipment.

Proceedings of the 8th AFS Environmental, Health and Safety Conference will be available in 1997. For more information, contact the AFS Environmental Affairs Dept. at 800/537-4237.

RELATED ARTICLE: Steps to Compliance

Although the deadline for OSHA's Lead Standard was July 19, 1996, if your foundry is running behind, these steps outlined by J.A. and Martha Guimond, Joseph A. Guimond & Assoc., Inc., in The Crucible, will help your foundry come into compliance.

STEP 1

Establish exposure levels for all occupations in your operation. Based on test results, identify all occupations or operations that have lead exposure and know each employee's TWA exposure.

STEP 2

Establish what engineering controls are in use at your facility. This includes replacing older methods and equipment with new methods and equipment that don't create as much airborne lead exposure; providing mechanical exhaust to an air pollution control device, providing make up air and sufficient ventilation; or changing the facility layout.

STEP 3

Establish what administrative controls are in use in your facility. These include employee rotation or eliminating all leaded alloys.

STEP 4

Determine what steps can be taken in your foundry to reduce employee exposure to airborne lead. You must do everything that is practical and feasible to reduce employee exposures, even if they aren't reduced to below the Permissible Exposure Limit.

STEP 5

Write a compliance program complete with a compliance schedule. Once the steps to reduce employee exposure levels are established they must be written into a program outlining the actions the foundry is going to take and a schedule of the time required to implement your program.