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Environmental: 'what's hot and what's not.' (environmental and occupational safety regulations covering foundries)

The weak economy and the upcoming presidential elections both will have major influences on what is passed by Congress and how quickly agencies such as OSHA and EPA advance their regulatory agendas. Even if Congress does not pass any new laws and OSHA and EPA stick with what's already on the books there are still many new obligations which begin this year.

Federal EPA

Toxic Reporting-responding to the obligations of the Pollution Prevention Act of 1990, EPA has significantly revised the SARA Section 313 Form R on Toxic Release Reporting. This is the report that companies (which use certain amounts of approximately 400 different chemicals) are required to submit by July I of every year. Many foundries have had to file these reports for chemicals such as lead, nickel, chromium and phenol.

Starting with the 1991 report, due July 1,1992, additional information on the quantity of the toxic chemical entering any waste stream prior to recycling, treatment or disposal and the amount of the toxic chemical that is recycled at the facility or elsewhere will have to be reported. Get out your crystal balls since a company will not only have to report on how these numbers have changed since the previous year's report but also speculate what these numbers may be for the next two years. A description of the recycling process also will have to be provided.

Source reduction is now the name of the game, so a company's source reduction practices for the reported toxic chemical and how source reduction opportunities are identified are to be included in the report. The new official Form R will not be available until at least March or April of 1992.

Storm Water-despite a credibility problem, EPA will be going forth with permitting for discharges of storm water. There have been many delays but it looks like individual permit applications will be due by October 1, 1992. Complying with EPA'S proposed General Permit conditions (which is meant to be the simple generic permit that most companies would apply for) could turn out to be so expensive that most companies will opt for their own individual permit to at least get a chance to negotiate specific conditions for their site. This will, most likely, overload the permitting system which could cause EPA and Congress to rethink the real need for storm water regulations. This issue will surface during debate on a new Clean Water Act in 1992.

Clean Air Act Implementation-by 1997 final Maximum Achievable Control Technology (MACT) regulations for the emissions of airtoxics from iron and steel foundries will be on the books. In January of this year the long process leading up to these regulations started with a meeting between EPA and representatives of the foundry industry.

While there will be no immediate action required by foundries, look for information requests from EPA contractors sometime during the year. At this point in time EPA wants this process to be a joint venture with the industry, recognizing that the impacts of these regulations will change the face of the foundry industry.

Federal OSHA

OSHA will continue its program of doing fewer inspections but each one will be more comprehensive than in the past. Financially this program has been a success. In 1985 OSHA proposed $7.7 million in fines for serious violations; in 1990, $27.3 million and in 1991,$46.1 million.

Ergonomics will continue to play a lead role in enforcement activity. While there is no specific standard for the agency to cite there is sufficient medical and technical information available for OSHA to cite violations of its General Duty Clause, 5(A) 1. Initially, companies in the food industry, particularly meat processing, were targeted for inspections; this initiative has now spread into the manufacturing industries. Foundries should start their own ergonomic programs recognizing that the best defense is a good offense.

Foundries that have in-house medical departments or even first aid facilities will have to comply with OSHA'S new Bloodborne Pathogens Standard (1910.1030). This standard was published December 6,1991 (FR vol 56#235, pages 64004-64182). The standard becomes effective on March 6,1992, with full compliance by July 6,1992. Provisions include an Exposure Control Plan, Information, Training, Recordkeeping, Engineering and Work Practice Controls, Personal Protective Equipment, Housekeeping, Hepatitis B Vaccinations, Post Exposure Evaluations and Follow up, and Labels and Signs.

Overall Trend

An obvious trend is emerging in the environmental and safety/health fields. These are Toxic Taxes (fees) and Super Lists of toxic chemicals.

Toxic Taxes-otherwise known as the concept of polluter pays," federal, state and local officials are increasing the fee that will have to be paid by companies wanting to do business in this country. Usually, the fees are tied directly into the amount of a particular chemical or class of chemicals that have been reported in some way, shape or form to these authorities under Right to Know regulations or emission permitting regulations. Since most levels of government are strapped for money, these types of fees are a convenient way for a governmental body to raise money without having to raise a citizen's taxes.

These fees will become even more important to states since federally mandated programs for environmental protection often are authorized without sufficient federal dollars to help the states carry them out. At some point in time all mandated environmental protection programs will be funded, almost totally, in this manner.

Super Lists of Toxic Chemicals-as new legislation is developed, superlists of toxic chemicals are being developed, not based on any scientific or technical data but on a chemicals presence on an already existing list. Ultimately, chemicals on these superlists will become increasingly regulated with many being banned. Overall, the concept of Toxic Use and Source Reduction will be developed to the point that the mere presence and use of a chemical will require tight control regardless of whether there is any harm to the environment or to public health.

Keeping Up

Future Conferences-"Safety in the Foundry IV," March 17-19,1992, will help foundries to comply with OSHA and worker compensation regulations.

An 'Ergonomics Conference,' June 24,1992 will address ergonomic issues.

The 5th Annual AFS Environmental Affairs Conference," August 17-18, 1992 will supply the latest environmental information. For more details call AFS.
COPYRIGHT 1992 American Foundry Society, Inc.
No portion of this article can be reproduced without the express written permission from the copyright holder.
Copyright 1992, Gale Group. All rights reserved. Gale Group is a Thomson Corporation Company.

Article Details
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Author:Mosher, Gary E.
Publication:Modern Casting
Date:Feb 1, 1992
Previous Article:AFS leading the way on RCRA reauthorization.
Next Article:Market drives automotive castings to aluminum.

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