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USA Today recently published a series of articles focusing on air quality issues for America’s children and schools. The coverage used scores and rankings to highlight concerns about potential childhood health hazards from various sources, including manufacturing facilities.
State Environmental Agencies and scientific experts have raised concerns about the limitations of USA Today’s analysis and how the study should be interpreted. The American Foundry Society and it’s members share the same concerns. While that scientific discussion continues, it is important to point out the progress that key sectors in American manufacturing, including the metalcasting industry, are making when it comes to the commitment to environmental protection.
Metalcasting…An Environmental Success Story
The American Foundry Society, the nation’s leading trade association representing the metalcasting industry, can point with confidence to our industry’s success in minimizing the impacts of our operations to air, water and land.
Part of our mission is to help our member companies achieve superior environmental performance. We’ve invested heavily to educate, inform and guide U.S. foundries on industry best practices to minimize human health risks, promote a safe workplace and reduce our environmental footprint.
The U.S. EPA’s recent report on the metal casting industry demonstrates that our strong commitment to environmental and economic sustainability has yielded meaningful results.
Measurable Gains
The impressive record of the metal casting industry is confirmed by the U.S. EPA’s 2008 Sector Performance Report, which reviewed the environmental performance of key U.S. industries. The report shows that just since 1996, we’ve achieved measurable gains in minimizing the industry’s impacts to the nation’s air and water as well as reducing our waste. Here are a few examples where we’ve made a difference:
Cleaner Air
- 63% Air Emission Reductions – U.S. metal casters reduced their air emissions of all reportable chemicals and metals by 63% under EPA’s Toxics Release Inventory.
- 82% Decline in Our Toxicity Score – EPA estimates that the industry’s overall "toxicity score" for air emissions has declined dramatically – by over 80%.
Cleaner Water
- 52% Drop in Regulated Wastewater Discharges of Chemicals – All metal casting companies with process wastewater operate under strict discharge limits, and reported discharges for the industry have dropped by 52%.
Less Waste
- 34% Less Waste Being Managed – The industry generates 34% less metal waste to be managed via treatment, disposal or recycling.
Reuse and Recycling
- Beneficial and Safe Reuse of 2.6 million tons of casting sand a year – Currently, the industry beneficially reuses 2.6 million tons of sand per year, or 28% of the total casting sand available for reuse. The industry is now pursuing a sand reuse goal of 50% by 2015.
- Why Sand Use is Important – Metal casting operations use millions of tons of sand each year to cast millions of different parts and components from sand molds – parts that are vital to everyday life.
- Safe and Clean – Most of our sand is safe and clean and can be beneficially reused in numerous ways, from being a key ingredient in soil mix for rain gardens to filter storm water to essential fill material for roads and bridges.
- Reaching out to Regulators and Users – The industry is now collaborating with the EPA, USDA, the Federal Highway Administration and states to maximize beneficial reuse of sand across the nation.
To learn more about our commitment to protecting the environment, contact the American Foundry Society, at www.afsnic.org or 800/537-4237.
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In November, the study Raw Deal: How Governmental Trade Barriers and Subsidies Are Distorting Global Trade in Raw Materials was released, concluding that governments around the world are enacting a variety of trade restrictive measures to gain an unfair advantage in the race for raw materials. The report documents how China, Russia, Ukraine, India and other governments are increasingly participating in the race for raw materials and are intervening in commodity markets in order to protect their domestic industries and sustain economic growth.
The study, written by Wiley Rein LLP and sponsored by the American Scrap Coalition (ASC), details the rise of trade-restrictive measures designed to secure supplies of low-cost raw materials and benefit domestic industrial giants. "These barriers are being used by certain U.S. trading partners to game the system to their advantage while prejudicing those countries that are playing by the rules," said Alan Price, Wiley Rein LLP, Washington D.C., legal representation for the ASC and one of the study's authors.
The ASC is calling for immediate action to address these trade-distorting practices on scrap and all raw materials, and will continue to work with the U.S. Trade Representative's Office, the Commerce Department, U.S. Congress and the new Administration to reach a long-term solution to these problems.
For more information on this study or AFS' involvement with the ASC, contact Stephanie Salmon, AFS Washington Office, at 202/842-4864 or
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On Oct. 30, EPA issued a new regulation to revise the definition of solid waste to encourage the recycling of more hazardous secondary materials. 73 Fed. Reg. 64668 (2008). The changes to the definition are in response to several court decisions that held EPA’s regulatory definition was overly broad and did not clearly delineate when a material is discarded. Hazardous secondary materials that are legitimately reclaimed are eligible to be exempt from regulation as a hazardous waste under the new rule.
EPA estimates that approximately 5,600 facilities will be impacted by this rule, and it will include 30,000 tons of new recycled materials annually. The rule will provide a cost savings to U.S. facilities of approximately 95 million dollars, and the savings could be even higher if more states adopt the new regulations. A copy of the final rule is available on EPA’s website. To view the final rule, click here.
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Union organizations are pushing hard to make the Employee Free Choice Act (EFCA) the top priority issue when the 111th Congress convenes in January. Their efforts, if proven successful, would make it easier for workers to form unions by essentially eliminating a requirement that unions be launched via a secret ballot vote.
Specifically, it would give union organizers free rein to pressure workers into signing authorization cards. Once enough workers are persuaded to sign, the union would automatically be certified, and it would be illegal for workers to have a secret ballot election. Then the bill would implement a compressed schedule for employers to bargain with their new union.
If an agreement isn't reached within 120 days, a government-mandated arbitrator would dictate the terms and conditions of employment (ultimately deciding a business’s profit margin) and hand the employer a contract. This contract would remain in place for two years.
Unions have spent over $300 million in lobbying and campaign contributions in this year’s election to congressional supporters this year; partly to support members of Congress that favor EFCA.
AFS opposes the EFCA and has joined forces with an alliance of pro-business groups - the Coalition for a Democratic Workplace (CDW). The CDW is spending millions of dollars to build grassroots opposition to labor’s advocacy efforts, and is targeting donations in a few key Senate races. The CDW has also released numerous television ads in battleground states like Colorado, Minnesota, and Maine stressing the importance of the election and how its outcome will dramatically affect the formation of unions.
To help stop the agenda, visit CDW website and sign the petition against card check at www.myprivateballot.com. The CDW website also contains background materials on the EFCA and its implications for the business community. For more information, contact Alicia Oman, AFS Washington Office at
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or 202/842-4864.
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In 2008, over twelve metalcasting facilities have been fined so far this year for over $100,000 in safety and health citations. Some of the facilities that were cited are located in the state of Ohio and were chosen for inspection as part of a local emphasis program (LEP) concentrating on the primary metal industry.
Following a series of fatalities and serious injuries in the metals industry, the state of Ohio has developed a comprehensive inspection program. The following types of metacasting facilities are part of the Ohio LEP primary inspection list: grey & ductile iron (3321), malleable iron (3322), steel (3325) and aluminum (3365). Copper facilities (3366) and non-ferrous facilities (3369) except aluminum are placed on the secondary inspection list.
According to Ohio OSHA, manufacturing fatalities accounted for 32 percent of all fatalities in that state. The program is intended to address hazards or industries that pose a particular risk to workers. The inspections will address at a minimum the following safety and health issues:
- Material handling and storage, including but not limited to cranes, forklifts and rail yards;
- Control of hazardous energy (such as lockout/tagout);
- Machine guarding;
- Hazard assessments, including use of PPE, fire explosion hazards associated with molten metal and emergency action plans;
- Air Contaminants (41);
- Review of all safety and health programs;
- Ergonomic hazards.
Metalcasting Facilities also have been cited with large fines in New York, Illinois and Texas. Here is a sample of some of the serious violations and repeat violations that foundries are being cited for:
- Lead and silica over-exposures;
- High-level noise exposure;
- Electrical hazards;
- Training deficiencies (including respiratory protection training);
- Lack of personal protective equipment for employees.
Federal OSHA is in the process of developing a National Emphasis Program (NEP) for primary metal, which would include metalcasting facilities. The NEP for primary metal will be released in 2009 during a new Administration.
Again, whether your metalcasting facility is small or large, it is critically important to be in compliance with current OSHA federal standards and regulations. Fore more information concerning safety and health compliance issues, contact Fred Kohloff, AFS Director of Environmental, Health & Safety at 800/537-4237.
In addition, OSHA offers free and confidential advice to small and medium-sized businesses in all states across the country through its On-Site Consultation Service, with priority given to high-hazard worksites. Consultation services are totally separate from enforcement and do not result in penalties or citations. If you have any questions regarding the LEP or NEP, contact Stephanie Salmon, AFS Washington Office at 202/842-4864 or
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