The Senate Environment and Public Works Committee passed legislation this summer that would authorize the U.S. Environmental Protection Agency (EPA) to develop an electronic system to track hazardous waste. Entitled the Hazardous Waste Electronic Manifest Establishment Act (S. 3109), the bill would permit EPA to select a contractor to develop an electronic manifest system and would authorize the collection of fees from the industry to fund the effort. 

The Resource Conservation and Recovery Act (RCRA) requires companies to track their shipments of hazardous waste through maintaining records of shipments and the filing of paper manifests with the government after the shipment. The electronic system is purported to permit a more complete and accurate tracking of the wastes. Although awaiting authorization from Congress to establish a funding mechanism, EPA has already begun a rulemaking process, issuing a request for comments from the industry last February on the benefits and costs of establishing an e-manifest system.

In August, the U.S. Department of Labor’s Occupational Safety and Health Administration (OSHA) issued a directive that implements a revised National Emphasis Program (NEP) to reduce occupational exposures to lead. This document supersedes the 2001 OSHA National Emphasis Program on Lead (CPL 02-00-130). The new NEP directive contains a list of industries included to assist OSHA’s field offices in determining industries for targeting.  The list includes copper and non-ferrous metalcasting facilities (other than aluminum).  Based on OSHA inspection data for the past year, there have been approximately ten inspections for non-ferrous foundries using lead and thirteen for copper-based metalcasting facilities. 

Under the NEP, OSHA will direct resources towards inspections of industries in which lead exposures occur. Subsequent to an initial inspection, follow-up site visits will be conducted in all establishments where exposures were measured at or above the permissible exposure limit (PEL) or above the action level where the employer has not taken preventive/corrective action (as required by the standard).

Employee exposure to airborne lead will be sampled, whenever possible, during both the initial and follow-up inspection. Medical surveillance records will be reviewed by Compliance Officers during NEP lead inspections.

In addition, during both the initial and follow-up inspections, Compliance Officers will evaluate training, use of personal protective equipment, surface concentrations of lead and the availability of hygiene facilities, work practices, and engineering controls.

The Regional and Area Offices can delete any establishment from the list that has had an inspection where exposures to lead have been evaluated within the current year or previous three fiscal years.  In addition, these metalcasting facilities were found to have no serious violations cited for lead, or a subsequent inspection documented employer efforts to abate all serious hazards, or no cases of increased blood lead levels were identified. 

For further information, contact Stephanie Salmon, AFS Washington Office, at This e-mail address is being protected from spam bots, you need JavaScript enabled to view it or 202/842-4864 or Fred Kohloff, AFS director of Environmental, Health & Safety, at This e-mail address is being protected from spam bots, you need JavaScript enabled to view it or 800/537-4237.