January 25, 2011
On the wings of the Occupational Safety and Health Administration’s (OSHA) efforts to control the permissible exposure limit (PEL) of hexavalent chromium, the Environmental Protection Agency (EPA) has gone one step further. By July 25, 2011, the agency requires that metal fabricators comply with a new air quality regulation for processes that contain cadmium, chromium, lead, manganese, and nickel.
The regulation applies to facilities that are “primarily engaged” in one of nine source categories: electrical and electronic equipment finishing; fabricated metal products; fabricated plate work (including boiler shops); fabricated structural metal manufacturing; heating equipment (not including electric); industrial machinery and equipment finishing (including construction machinery manufacturing, oil and gas field machinery manufacturing, and pumps and pumping equipment manufacturing); iron and steel forging; primary metal products manufacturing; and valves and pipe fittings.
Pat Gilmour, business development director for RoboVent, Sterling Heights, Mich., breaks down for PWT the motivation behind the EPA’s new upcoming regulation and explains how this regulation differs from OSHA’s.
For starters, we need to clarify the difference between the two agencies’ focus. While OSHA is concerned about the impact of industrial practices on the health and safety of personnel, the EPA is concerned about the impact of industrial practices on the environment.
OSHA’s standards apply to an individual’s exposure, whether it be to hexavalent chromium, manganese, or lead, and are expressed as a PEL. This new regulation from the EPA (40 CFR Part 63) includes cadmium, chromium, lead, manganese, and nickel and applies to exhausted air from manufacturing facilities that will have an impact on the surrounding environment, including humans.
EPA’s regulation takes the nine source categories listed previously and applies five primary industrial processes that are common to those industries. The five processes are dry abrasive blasting, dry grinding and dry polishing with machines, dry machining, spray painting, and welding
If 50 percent of your operation involves these processes, then this regulation applies to you. Additionally, if you consume more than 2,000 lbs. of welding wire per year, then you are subject to this regulation.
To get a little perspective, these two entities—OSHA and the EPA—are totally different. Citing the most recent data from 2008, OSHA had 2,186 employees with an operational budget of $490.3 million, while the EPA had 17,324 employees and a budget of $7.2 billion. Statistically speaking, the EPA is eight times larger with a budget 14 times greater than that of OSHA.
Additionally, in 2008 the EPA concluded civil and criminal enforcement actions requiring regulated entities to spend an estimated $11.8 billion on pollution controls, cleanup, and environmental projects. No data was available for OSHA compliance efforts.
Good question. I will give two examples that may make this easier to understand.
A manufacturing facility has installed source-capture devices (i.e., fume arms or hoods) and is processing the fume through a dust collector. Under these conditions, as long as the employee exposure level to hexavalent chromium is less than 5 micrograms per cubic meter, then the facility will not have a problem.
Now let’s say the same manufacturing facility chooses to blow the fume outside instead of filtering the fume. Even though the employee exposure level meets OSHA’s PEL requirements, that facility still could be in violation of EPA’s regulations because it’s discharging this particulate into the atmosphere.
The EPA estimates that this regulation will affect approximately 5,800 metal fabrication and finishing facilities.
Any solution must satisfy both OSHA and the EPA at this point. To satisfy OSHA, don’t exceed the PEL. For the EPA, don’t blow the pollution outside.
OSHA has established PELs at the following levels:
Cadmium and chromium are incredibly restrictive and must be addressed at the source of origin to protect employees fully. Cadmium can be found in plated metals, zinc alloys, and flux-cored electrodes. Chromium is generally associated with processing of stainless steels and high-alloy metals.
Lead is another tightly regulated element that needs to be caught at the source. Lead is common in solder, brass, and bronze alloys.
Nickel, usually present along with chromium, is common in stainless steel, INCONEL®, MONEL®, and other high-alloy metals and welding rods.
Manganese has the highest PEL and is common to virtually all welding, either as a base metal or filler wire. A disorder known as manganism has been the basis for many lawsuits recently and has clearly moved to the top of concerns along with chromium.
Modern dust collectors use cylindrical, self-cleaning cartridge filters that have efficiencies of 99.9 percent at a particle size of 0.5 micron. To put this into perspective, a human hair is roughly 100 microns in size.
Other types of dust collectors include electrostatic precipitators and “throwaway” filter boxes. Electrostatic devices are inefficient and their maintenance intensive. It is the oldest technology out there and is rarely applied to welding anymore. Units that use throwaway filters are not nearly as efficient as cartridges and lack the ability to self-clean, which becomes costly in a very short period of time.
Most people want to know if the regulation applies to them. The definition states that “primarily engaged” means the manufacturing, fabricating, or forging of one or more products listed in one of the nine metal fabrication and finishing source category descriptions (see Question 1 for a complete list) where this production represents at least 50 percent of the production at the facility, and where production quantities are established by the volume, linear foot, or other value suited to the specific industry. The period used to determine production should be the previous 12 months of operation.
I usually tell folks that if they are a painting and a welding shop this regulation applies to them if 50 percent or more of their process is welding.
The one thing that’s got a lot of people concerned is manganese exposure, and a reduction in manganese PELs could be next.
I say this because a couple of years ago the American Conference of Governmental Industrial Hygienists® (ACGIH) put in a Notice for Intended Change (NIC) that it wanted to reduce manganese exposure to 20 micrograms. To put that into perspective, the OSHA PEL for manganese is 5 milligrams per cubic meter, so 20 micrograms is 250 times lower than that.
Manganese is very common to the metalworking industry. It’s in base metals and a lot of welding wire that’s out there. Reducing the PEL to 20 micrograms would mean everyone would have to address the fumes being produced with some sort of extraction system.
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