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The Convincing Case Against OSHA's Silica Rule

A wise person once said that if the people writing federal regulations on businesses also had to bear the burden of complying with them, the rules would be written much differently. OSHA’s respirable crystalline silica rule, which was issued on March 24, 2016, is a case in point.

During the rulemaking process, AFS provided the agency with compelling analyses that demonstrated, beyond a shadow of a doubt, that the rule would be both technologically and economically infeasible for the foundry industry.

The agency ignored the strongest possible evidence, and produced a rule that OSHA is slated to begin enforcing in June of 2018. AFS immediately teamed up with the National Association of Manufacturers on a legal challenge. A subpanel of the U.S. Court of Appeals for the D.C. Circuit is slated to hear our arguments on the case in late September.

AFS supports worker protections that are based on sound science and are technologically and economically feasible. The OSHA rule fails that test. It is based on outdated, decades-old data. In fact, the last Small Business Regulatory Enforcement Fairness Act review on the issue was conducted in 2003.

Regulators vastly underestimated the annual cost of the rule, which can easily run over $1 million per metalcasting plant. The rule requires foundries to adopt extensive engineering and work-practice controls—an outdated approach—to limit silica exposures instead of other available technologies, such as personal protective equipment. Even with the massive outlays the rule will require, there is no guarantee of compliance.

Imagine a federal regulation that each year would cost 276% of the industry’s profits. That is exactly the scenario here.

Since the election, AFS has communicated to the new presidential administration our strong rulemaking record exposing the serious flaws in OSHA’s risk analyses and cost estimates. We continue to urge the Trump Administration to reopen the record on the rule. Numerous members of Congress have voiced identical requests.

If there is no regulatory relief by late September, the court case will proceed. It is unfortunate that U.S. manufacturers have to sue their own government, but AFS will continue to vigorously fight for the future of the metalcasting industry. We welcome your corporate membership investment as we wage this vital battle for the future of the foundry industry in the United States.

Click here to see this story as it appears in the August 2017 issue of Modern Casting


Continuous Energy Benchmarking for the Metalcasting Industry

Melting operations are the dominant uses of energy within metalcasting businesses. And many other plant processes depend on how efficient the melting production is. Detailed monitoring of furnace energy-usage can result in improvements in production throughput and reductions in energy costs.

AFS recently commissioned an energy efficiency R&D project at several metalcasting facilities (AFS Research Project 12-13#03), utilizing advanced sub-metering that was connected to major energy consumption devices. Sub-meters provide useful insights about how energy is used in a foundry. It’s easy to know how much energy is purchased every month but it is difficult to know each machine’s energy usage and the overall cost impact of energy usage by a particular machine or process. 

Furnace operations was a major focus area of the study but other machines can also consume significant amounts of energy. Different facilities and different processes have different sub-metering needs. Some frequently useful sub-metering measurements can be collected every two seconds and may include a range of metrics, including:
•    The rate in which electricity is consumed (kW).
•    Electric energy consumed for different time periods (kWh).
•    Compressed air and vacuum pressure.
•    Temperature, including melt temperature and equipment exterior surface temps.
•    Run-time.
•    Natural gas consumption rate and total consumption.
•    Oxygen or other gas consumption rate and totals.
•    Production units including pounds per melt (batch) and pounds per day (time unit).

Depending on the details of the foundry, this type of information can be collected with sub-meter measurements of energy-intensive equipment frequently used in foundries. Examples of the type of equipment that may be good candidates for sub-metering measurements include:
•    Furnaces.
•    Air compressors.
•    Hydraulic pumps.
•    Dust collectors.
•    HVAC.

AFS Research Study Results
During the AFS study, both production output and energy usage varied dramatically but not in tandem. Tap-to-tap furnace times, melt time per pound and other batch metrics all indicated large variations during most measurement periods from days to months. In many instances, the staff and management were unaware of the extent of these variations. Without detailed, time-resolved measurements, production metrics may not be apparent and so the root cause of monthly production variations is often unclear.

The AFS study highlighted the value of sub-meter measurements to glean useful insights into furnace operations. Assessments of furnace utilization can benefit from tracking furnace power-levels during daily operations.  By monitoring how long the furnace was using various power levels during each melt cycle and aggregating this information over a longer time period (day, week, or month) extremely useful insights can be created regarding furnace operations. Correlating tap-to-tap cycle time of the melt with common power level settings provided significant insight into the production variations.  For this study, four power levels were selected as common settings during operations including Off, Hold, Medium and Full power levels. Findings included longer than expected “Hold” times, inappropriate power settings during “Hold” periods and excessive use of “High” settings. This study also found that the furnace was “Off” at unusual times of the day. Recommendations to correct some of these findings can result in total potential savings that exceeded $1 million per year with no capital expense requirements.

In addition, for the AFS study, special reports were developed to summarize how long the furnace was operated at each power-level setting (Off, Hold, Medium and Full power) and a scatter-gram plot showing hundreds of furnace cycles to help understand the overall statistical variations in furnace processes. Management could now monitor the relative efficiency of the melting operations in near real time and be alerted when anomalies occurred. Summary reports by hour, day, week, month, were also created to easily review relative variations in furnace operations over time. With this type of measurement and data presentation, unexpected variations could be identified and measurements can be further analyzed during the relevant time period. This can result in more consistent operations, increased throughput and lower energy costs. Such automated analysis and reporting represents an advanced form of benchmarking that is unique to the metalcasting industry.

Another option is to develop manual data collection at your plant. Simple charts recording the start times of important parts of the cycle may help you identify developing issues or provide opportunities to improve operations. Automated data collection can include things like burner natural gas-usage rates, door open times, and casting times. For instance, these measurements may highlight that burner high fire and low-fire settings differ between similar furnaces. Other findings from simple charting efforts can assist staff in understanding variations in charge time and can help optimize processes.   

You can contact Brian Reinke (AFS Energy Program Manager) at breinke@tdi-energysolutions.com for more information on this study. Some of the sensors and equipment used in the AFS research project are available to AFS corporate members for studies at their plants.

Click here to see this story as it appears in the August 2017 issue of Modern Casting


A Mind for Numbers

If you make the effort to learn how your brain works, you might also discover that you have much greater capacities for mastering those mystifying subjects that stumped you in school. In “A Mind for Numbers,” Barbara Oakley tells her story of conversion from mathphobe to professor of engineering.

The book does more than tell you how your thinking organ behaves—and some of that will surprise you—it inspires you to learn more. More about what really happens when you think, and more about which ideas you’d like to have more clarity about.

First, let’s stipulate that although the book is subtitled “How to Excel at Math and Science (Even if you Flunked Algebra),” it’s a book about learning and learning how to learn. Yes, it does explain how to improve performance in math and science. That’s because the book applies to every kind of learning. Oakley hated math and science growing up. I mean hated. When she describes her excruciatingly painful experiences in math classes, we know how she feels. Many of us have felt the same in those classes.

Young Barbara was stumped by clocks. Why does the long hand not mean hours instead of minutes? The way she tells it, she flunked so many math and science classes, she gave up. Her self-talk seems to have been all about her own stupidity. In retrospect, that’s hard to believe.

She joined the Army and learned Russian, so stupidity was clearly not the problem. Using the GI Bill to fund the effort, Oakley decided to retrain her brain. What did she discover on this path of self-discovery?

The brain switches between highly attentive states (focused thinking) and resting states (diffuse thinking). Focused thinking is well, focused on subject matter in a way that allows you to process ideas into familiar patterns. These familiar patterns can be so potent that the best answers to thorny problems in any discipline remain unsolvable.

Oakley’s approach asks you to learn, consciously, how to toggle between focused thinking and diffuse thinking. You need focused thinking to concentrate and understand the material to an extent. But diffuse thinking will lead to that flash of insight that solves the problem when you’re not (focused) thinking about the issue.

We’ve all had this experience. We just didn’t know what was happening in our brains. You’re driving down the highway, and a solution springs full blown from you mind, like some Greek deity from the head of Zeus.

No matter the learning task, consciously exploiting your toggle switch between modes is helpful, and not just because you think it’s nap time. However, math and science are harder to learn than other topics because they have an extra layer of abstraction or to use Oakley’s word, “encryptedness.”  Meaning, you can easily and concretely associate a C-O-W with Bessie in the pasture, but you have no correlation to a (+) in the world. The plus sign is abstract, but the cow is concrete.

Thanks to Oakley’s book, you know how that happens. Better yet, you can coach yourself to attain these epiphanies. Focus, diffuse, answer, move on. It’s not that simple, but those are the dance steps. If you’ve ever gone to sleep thinking about an issue to have the answer right there in the morning? That’s your diffuse mind taking over. However, you don’t have to enter the dream world to gain the benefits of diffuse thinking. You can talk a walk, go for a drive, or just stare out the window. Let the diffuse thinking begin!  

Click here to see this story as it appears in the August 2017 issue of Modern Casting

 

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