Crystalline Silica Resource Page
AFS is committed to the elimination of the adverse health effects associated with the inhalation of respirable crystalline silica. To that end, AFS has developed over the years a number of guides and best practices documents such as the Control of Silica Exposure in Foundries and PPE Guide for Metalcasting Operations publications. In addition, the association holds an annual Environmental, Health & Safety Conference every August, along with safety seminars and webinars throughout the year.
OSHA’s Proposed Crystalline Silica Rulemaking: Final Rule Released March 24.
On August 23, 2013, the Occupational Safety and Health Administration (OSHA) released a proposal which considerably toughens its regulation of respirable crystalline silica by reducing the permissible exposure limit (PEL) to silica in half, from 100 µg (micrograms)/cu.m to 50 µg/cu.m. The rule was finalized March 24. AFS's Silica Task Force has been directing the industry’s comments and discussions with OSHA in response to the agency’s proposed silica standard. 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.
Scope: This is one of the most comprehensive rulemakings the agency has ever undertaken with significant economic consequences to major sectors of the economy, including foundries, steel, brick making, maritime, and construction. OSHA received more than 2,000 public comments, including significant input from the U.S. foundry industry.
Impact on metalcasters: The rule will force some foundries to close, shift production offshore, and impact the long-term productivity, profitability and competitive structure of the metalcasting industry. Simply put, OSHA’s proposal is not technologically or economically feasible for the foundry industry. OSHA’s proposal will ultimately cost the foundry industry more than $2.2 billion dollars annually.
- OSHA underestimates and/or omits the cost of equipment and processes.
- Foundries will have to exhaust all feasible engineering and work practice controls to meet the new PEL/Action Level. A one-size-fits-all solution does not work for this industry. Facilities may spend millions of dollars to implement engineering controls (through trial and error) and still not meet the new PEL.
- The rule drastically understates costs to comply and exceeds 9% of industry revenue.
- The rule prohibits work practices which contradict existing industry safe practices.
- Deficiencies in commercial lab analytical accuracy for silica air samples.
October 2013: AFS sends an industry survey to develop more detailed data on the effect of the proposed silica rule.
February 2014: AFS files its comments on the proposed rule. Click here to view the comments and appendices.
March 2014: Public hearings on the rule begin in Washington, D.C., and AFS and metalcasting industry representatives provided their testimony on March 28. You can read their testimony here. AFS continues reaching out to members of Congress and educating them and their staff about the devastating impact OSHA’s proposal will have on metalcasting facilities.
May 2014: AFS members highlight key concerns of OSHA’s crystalline silica rule in over 100 meetings with lawmakers on Capitol Hill during the industry Government Affairs Conference.
August 2014: AFS submits a post-hearing brief. This is the association’s final document which further substantiates the industry’s positions on the silica rulemaking.
March 2015: AFS member testifies on behalf of AFS in House Small Business Committee - Tangled in Red Tape: New Challenges for Small Manufacturers – on negative impact of OSHA’s crystalline silica rule on the foundry industry.
June 2015: AFS members highlight key concerns of OSHA’s crystalline silica rule in over 100 meetings with lawmakers on Capitol Hill during the industry Government Affairs Conference.
June 2015: The full Senate Appropriations Committee accepts by voice vote an amendment by Sen. John Hoeven (R-N.D.) which would require OSHA to conduct additional reviews and research before it could finalize the agency’s comprehensive silica rulemaking.
December 2015: OSHA sends crystalline silica rule to the White House Office of Management and Budget (OMB) for final review. The final rule is expected to be released in the spring.
February 2016: AFS and metalcasting representatives outline key concerns with OSHA’s crystalline silica rule in meeting with OMB and Office of Information and Regulatory Affairs (OIRA).
For further information, contact Stephanie Salmon, AFS Washington Office, 202-452-7135, firstname.lastname@example.org.
- AFS Critique of Interpretation of Foundry Silica Results Used by OSHA
- Impact of OSHA Silica Rule on U.S. Foundries
- Control of Silica Exposure in Foundries
- PPE Guide for Metalcasting Operations
Foundry Case Studies
- The C.A. Lawton Co. CASE STUDY: Reducing Silica Exposures Through Engineering Controls and Work Practices (2013, August)
- Clearing the Air at Acme Foundry: Integrated Engineering Design of a New Casting Cleaning and Finishing Facility (2010, February)
- Silica Dust Control Improvement: Grinding of Iron Castings with Portable Tools at Kennedy Valve Foundry in Elmira, New York (2009, June)
Listed below are links to OSHA’s proposed silica rule and accompanying documents and updates:
- Letter from Rep. Bill Huizenga (R-Mich.) to Stop Another OSHA Regulatory Overreach: Silica Dust
- December 2015 Modern Casting Article: OSHA Plans Release of Final Silica Rule in 2016
- AFS Testimony in Public Hearing March 28
- Texas Gover 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
- WSJ Runs Editorial Critical of OSHA Silica Proposal
- AFS Webinar on how the proposed silica rule impacts the metalcasting industry.
- OSHA Extends Comment Period to January 27, 2014
- August 23 Notice of Proposed Rulemaking
- OSHA’s health effects & risk assessment background documents
- OSHA’s preliminary economic analysis and employment analysis
- ACC's Estimated Costs and Adverse Economic Impacts (July 2011)
- AFS's report on costs to metalcasting facilities (2013)
- Silica Notice of Proposed Rulemaking in the Federal Register. The deadline for filing written comments and testimony is December 11, 2013.
- From The Hill's Regulation Blog: House chairman tells businesses to weigh in on silica rule.
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
AFS and its expert staff offer experience, professional services and in-plant assistance for crystalline silica-related matters. For information, contact Fred Kohloff, AFS Environmental, Health and Safety Department, 800/537-4237, email@example.com.