(This week we would like to share the metalcasting foundry environmental resources available from the American Foundry Society (AFS) to help you be in compliance with governmental regulations from OSHA and EPA.)
The American Foundry Society (AFS) has the technical personnel to help you be in compliance with governmental regulations from OSHA and EPA. The society offers confidentiality, experience, professional services and in-plant environmental assistance whether you need an on-site consultation or just some answers. AFS fosters environmental protection through industry participation in its Environmental, Health and Safety Division 10 Committees.
Division 10 Environmental Health & Safety
This division contains three standing committees plus an exec/programming group. The committees meet independently, but all EHS meetings take place during the same few days and there is considerable overlap in committee personnel.
Executive/Program Group
Organizes, administers and implements the necessary committees with the technical and scientific disciplines required to advance responsible health, safety and environmental control programs and standards in the foundry industry. Responsible for the preparation of the technical program of the EHS division for the annual meeting of the Society. Secures papers and speakers with the responsibility for review and acceptance.
Air Quality Committee 10-E
Compiles and develops technical data for the most efficient methods of controlling air contaminant emissions from within the workplace and ambient air from the plant. Reviews the new issues and regulations as they affect air quality emissions in the metal-casting industry. Recommends and supervises research projects. Issues technical information and advisories on air quality matters.
Water Quality & Waste Disposal Committee 10-F
Studies proposed and current laws, rules and regulations affecting effluent water quality, waste management and the most cost-effective means of compliance. Guides research in solid waste management. Interprets guidelines for foundry operators in disposing of their solid wastes in an environmentally sound manner. Compiles and disseminates technical and regulatory information to members.
Safety & Health Committee 10-Q
Develops standards of practice. Reviews and conducts research on new and existing operations/processes to improve foundry employee safety and health protection. Assists foundries in meeting their obligation to provide a workplace free of recognized safety and health hazards. Represents the foundry industry in regulatory proceedings to develop safety and health standards.
Click below for more compliance and regulatory information on individual environmental topics.
Air
AFS is committed to providing the metalcasting industry with the latest information and rules affecting air emissions in metalcasting facilities. For more information on EPA regulations for air, visit the U.S. EPA's Office of Air & Radiation Website.
Casting Emission Reduction Program
Environmental Protection Agency
Iron & Steel Area Source Standards: On January 2, 2008, EPA published the final iron and steel foundry area source rule in the Federal Register. EPA issued the standard based on generally available control technology (GACT) for the control of the following urban hazardous air pollutants (HAPs): chromium, lead, manganese and nickel. The final rule sets emission limits for large area source foundries and requires both large and small area source foundries to comply with pollution prevention management practices and notification and record keeping requirements.
Nonferrous Area Source Rule: The U.S. Environmental Protection Agency (EPA) has issued a final regulation to reduce hazardous air pollutants (HAPs) from aluminum, copper and other nonferrous metalcasting area sources. Area sources are those facilities that emit small amounts of HAPs.
Iron & Steel MACT: Read updates on the Iron and Steel MACT rule and how they affect the casting industry.
Urban Air Toxics Strategy: The air toxics strategy from EPA is a framework for addressing air toxics emissions in urban areas.
Form R: Reporting of Binder Chemicals Used in Foundries - 4th Edition: This document, written and compiled by AFS is provided to help foundries more accurately report on the uses and releases of binder chemical systems.
Organic HAP Emission Factors 2007: This document prepared by the AFS Air Quality Committee (10-E) provides iron foundries with guidance on the selection of organic HAP emissions factors for pouring, cooling and shakeout operations and to a limited extent for nobake molding operations.
SARA Title III [Toxic Release Inventory (TRI) Program]: View various resources for maintaining a TRI program.
AFS Comments on Mandatory Reporting of GHGs for Landfills Subpart TT: This document includes the comments from August 2011 submitted by AFS to the EPA.
Crystalline Silica Resource Page
OSHA's new crystalline silica rule was finalized March 24. It reduced the permissible exposure limit (PEL) to silica in half, from 100 µg (micrograms)/cu.m to 50 µg/cu.m. Here is what you need to know about the rule. AFS is committed to a silica regulatory policy based on sound science that protects its workers, is technologically and economically feasible, and does not impose compliance costs that far exceed its expected benefits.
Brief Rundown of the Final Rule Provisions
Watch the AFS Webinar on OSHA's Final Rule and its Impact on Metalcasters (Download the PDF of the webinar here.)
As the new silica rule imposes a significant reduction in the PEL and requires metalcasting facilities to adopt extensive engineering and work practice controls to limit silica exposures over other available technology, compliance with the new rule will require substantial investment per plant without a guarantee that your facility can actually comply with the new requirements.
AFS and the National Association of Manufacturers asked the U.S. Court of Appeals for the 5th Circuit Court to review the silica rule. The request was filed through AFS’ affiliated Texas Chapter. After all petitioners have filed, the court that ultimately hears the case will set a briefing schedule. Should we prevail at the Circuit Court, OSHA would likely appeal to the U.S. Supreme Court or come to a settlement agreement with all of the parties who litigate this rulemaking.
To support AFS's legal challenge to the silica rule, please click here.
Contributions, gifts or payments to American Foundry Society are not tax deductible as charitable contributions for Federal income tax purposes. American Foundry Society does not provide tax advice regarding the deductibility of such payments under other provisions of the Federal tax laws. You should discuss with your tax advisors whether the payments are deductible under other provisions of the Federal tax laws.
Detailed Information on the Rule
- Final OSHA Silica Rule (March 2016)
- Key Provisions of Final OSHA Silica Rule (March 2016)
- AFS Webinar on OSHA Rule and Impact on Metalcasters
- AFS' Filed Comments on Proposed Silica Rule
- Metalcasting Industry Testimony in Public Hearings on Rule
- AFS Critique of Interpretation of Foundry Silica Results Used by OSHA
- Impact of OSHA Silica Rule on U.S. Foundries (April 12 Webinar Power Point PDF)
- AFS Webinar on how the silica rule impacts the metalcasting industry.
- Environomics report on costs to metalcasting facilities (2013)
- OSHA’s health effects & risk assessment background documents
- OSHA’s preliminary economic analysis and employment analysis
For further information, contact Stephanie Salmon, AFS Washington Office, 202-452-7135, ssalmon@afsinc.org.
Support From Elected Officials
- Letter from Rep. Bill Huizenga (R-Mich.) to Stop Another OSHA Regulatory Overreach: Silica Dust
- Texas Governor Files Letter Against OSHA's Silica Proposal Rule
- Iowa Governor Writes Letter Asking OSHA to Withdraw Proposed Silica Rule
- 55 Members of Congress Sign Letter Concerning Silica Rulemaking
OSHA Silica Resource Pages
- Crystalline Silica
- OSHA Crystalline Silica Rule Fact Sheet
- Crystalline Silica: OSHA’s web-based training tool to help companies comply with OSHA’s standard on crystalline silica rule.
- National Emphasis Program on Crystalline Silica
- National Emphasis Program - Primary Metal Industries
Silica Control Resources
- Control of Silica Exposure in Foundries
- PPE Guide for Metalcasting Operations
- The C.A. Lawton Co. CASE STUDY: Reducing Silica Exposures Through Engineering Controls and Work Practices
- Clearing the Air at Acme Foundry: Integrated Engineering Design of a New Casting Cleaning and Finishing Facility
- Silica Dust Control Improvement: Grinding of Iron Castings with Portable Tools at Kennedy Valve Foundry in Elmira, New York
Water
Visit the U.S. EPA's Water site.
NPDES Permits
Stormwater Permits
Groundwater
Industrial Pretreatment Program Permits
Waste & Recycling
AFS works with its members, staff and committees to maintain compliance with waste and recycling. For further information, visit the U.S. EPA's Office of Solid Waste & Emergency Response site and the U.S. EPA's Resource Conservation and Recovery Act (RCRA) site.
Redefinition of Solid Waste Rule Summary: This report prepared by AFS provides an overview of the new Solid Waster Rule and how it affects the metalcasting industry. You can download the whole rule in completion through the links below:
- Redefinition of Solid Waste Rule Part 1
- Redefinition of Solid Waste Rule Part 2
- Redefinition of Solid Waste Rule Part 3
Foundry Sand Multi-Stakeholder Action Plan (MAP): AFS has participated in a comprehensive process to increase the beneficial use of foundry sand with a broad group of stakeholders, including EPA, state regulators, potential end-users of foundry sand, and representatives of the metal casting industry.
AFS Foundry Industry Recycling Starts Today (AFS-FIRST): AFS-FIRST is an independent non-profit association that exists to educate foundries, end users, government agencies and other stakeholders about the benefits of using foundry byproducts.
EPA Risk Assessment Says Use of Spent Foundry Sands Safe in Soil-Related Applications
AFS Comments on Mandatory Reporting of GHGs for Landfills Subpart TT: This document includes the comments from August 2011 submitted by AFS to the EPA.
Scrap Management Plan for Iron and Steel Area Source Foundries
Climate Change
Climate change legislation and greenhouse gas regulatory requirements that could impact the metalcasting industry are receiving increased attention and focus in Washington, DC. Below is information that can help your facility with climate change issues.
Greenhouse Gas Emissions Calculator
The AFS Committee for Air Quality (10-E) Greenhouse Gas Emissions Working Group has prepared a tool for metalcasting facilities to calculate their direct greenhouse gas emissions from fuel consumption.
The primary purpose of this tool is to generate a preliminary estimate of greenhouse gas (GHG) emissions from a metalcasting facility. It is not intended to be a substitute for a detailed GHG inventory or to meet the reporting and other requirements of any current or future local, state, or federal laws or regulations. The GHG estimate can, however, help a metalcasting facility determine how Climate Change legislation and GHG emissions regulations may impact their business.
Download the tool by clicking on the appropriate link(s) below:
AFS Greenhouse Gas Calculation Tool (.xls format)
For more information, contact Jeff Hannapel, AFS Washington Office at jhannapel@thepolicygroup.com.
“Theoretical/Best Practice Energy Use in Metalcasting Operations,” Jim Schifo and Jeet Radia, May 2004.
Section 3 includes subsections 3.4.3.5, 3.4.3.6, & 3.4.3.7 on EAF direct GHG emissions calculations Additionally, section 3.4.3.5 alone could be used to estimate EIF direct emissions.
Greenhouse Gas Monitoring Plan Template
Download the model Greenhouse Gas Monitoring Plan Template, which has been provided as a courtesy from McWane, Inc. This is intended bo be used as a guide. Be sure to consult the final Greenhouse Gas Emissions Reporting Rule to ensure that your facility addresses all requirements applicable to your facility's operations.
Hill and Griffith Customer Service
The Hill and Griffith Company's green sand metalcasting foundry supplies help achieve the EPA's M.A.C.T. standards and reduce Benzene emissions. Our variety of environmentally sound release agents, coatings, partings, lubricants, core oils and specialty products will help you meet your metal casting's needs. We're known for our hands on approach. Let us visit your plant and recommend products that suit your needs.
Product Samples
We are pleased to provide samples in quantities large enough to allow you to "try before you buy."
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Technical Services & Support
On-site casting defect investigations, product testing, machine start-ups and much more. Also, lab facilities are available to provide testing upon request.
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