Indoor Air Quality: Know Your Data, Demonstrate Action, And Don’t Set Your Money on Fire
Take a breath. Air is so simple, so necessary, yet deeply complex for the metalcasting industry as it strives to achieve high indoor air quality for its workforce in an enclosed atmosphere potentially rife with contaminant build-up. The struggle for smaller operations can be particularly acute in the battle against respirable crystalline silica, as well as contaminants like carbon monoxide, formaldehyde and other organic and metal compounds inside the plant.
Uniquely individual like humans, foundries have identities, too, defined by attributes such as size of operation, part types and casting processes, yet like people, one and all must play by the same set of rules––especially in the context of environment, health and safety (EHS), however uneven the playing field may feel. Without doubt, small foundries, while nimble and competitive in their niches, approach the compliance arena with some distinct disadvantages.
First, fewer people obviously work at a small foundry, and they tend to wear multiple hats––it’s not uncommon for employees to be cross-trained in a variety of jobs, so pinpointing exposures to individuals can be tricky as they move about the facility through the day. But fewer people on the team has another drawback: With everyone, including management, so busy every day, the question of who’s going to own the oversight of workspace air quality may itself be a conundrum.
“Many don’t have a dedicated person whose only job is to deal with safety and OSHA-related issues,” said Kay Rowntree, owner of Industrial Hygiene Sciences and a member of AFS, who works with foundries. “In a small operation, the person who’s been given that responsibility is trying to do a whole bunch of other tasks, and it’s really hard for them to allocate the time to bring their program not only into compliance, but thinking beyond compliance about how they can make this even better. They’re just trying to get parts out the door. It’s a real challenge to keep all those balls in the air.
“And for many small operations, the OSHA regulations can be very intimidating,” she added.
A small foundry located in a rural geography may have the added difficulty of finding technical talent to manage EHS, so inexperienced personnel could be over their heads when it comes to maintaining indoor air quality standards for their company.
Another divot in the compliance playing field is the lower square footage of a small foundry’s facility––less free flow of air in an indoor space can mean particulates and gases can become more concentrated; also, more employees may have exposure to airborne contaminants, even those whose jobs don’t involve direct contact with typical exposure-prone tasks.
And if these obstacles were not problematic enough, a small foundry may lack expendable capital to devote to exposure controls, ultimately leaving management with a sense of overwhelm.
Impediments aside, to get out of neutral and accelerate toward solutions, the small foundry’s management must truthfully reckon with: (1) Am I only interested in checking compliance boxes to avert citations? Or (2), am I genuinely interested in protecting people?
“We all use this slogan, that our workers our most valuable asset,” said Jeet Radia, senior vice president of EHS and HR at AFS Corporate Member McWane Inc. “I think small foundries and large businesses, everyone needs to put their money where their mouth is, because protecting our team members has got to be the highest priority. And there are so many different ways of doing it. So my advice is, don’t run away from it because you think it’s going to be very expensive.”
Addressing air contaminant exposures is not only the right thing to do, sources agree, it’s an important dimension to the small foundry’s reputation. The company’s stance and actions on employee health and safety matters to customers who want to do business with ethical casting suppliers; demonstrating care to employees also matters to prospective hires and should be used as a recruitment tool in the present dearth of skilled talent.
In the end, however, fear of OSHA is what keeps the industry on its toes and the agency has a National Emphasis Program to identify and reduce or eliminate worker exposures to respirable crystalline silica; simply put, metalcasting is among a list of industries the agency is prioritizing for inspections and enforcement. Considering that most OSHA citations for compliance violations result in a fine, an uptick in inspector visits isn’t welcome news.
Small foundries are not without sobering incentives to discover and then mitigate all their airborne exposures on an ongoing basis. But if a company’s written EHS plan has been sitting in the file cabinet for a few years, all is not lost. However, correcting problems will take unwavering commitment from management.
It will also require a system, according to Radia.
“There’s a lot of different moving parts, and if we don’t take a systems approach to it, you will be forever firefighting,” he said. “That’s what happens to a lot of foundries big and small, but particularly small, because people are trying to do a lot of things, wearing different hats.
“The way you start building an environmental health and safety system, is, first of all, you understand the operation itself, what its needs are, where the shortcomings are––in other words, you do a gap analysis based on globally recognized standards like ISO 14000 and OSHA’s 45001.
“Then you set up goals and objectives, what you want to achieve. And then you develop processes and protocols; then you make sure there’s auditing. A system adds discipline so you know where you’ve been and where you’re going. For compliance purposes, documentation is obviously key because if regulators come in, and you say you did something, they’re going to ask you to prove it with documentation.”
A system will also help owners plot out a doable investment plan of action, spreading the costs of controls and abatement across five years, for example, to make the outlay more manageable. OSHA tends to be “more sympathetic,” said Radia, to those who are making good-faith efforts to follow a documented timetable. The key is, begin.
Radia contends the biggest challenge for the small foundry is knowing where they stand––which is why, if capital is tight, the best place to target any expenditure is data collection, and preferably real-time data, according to Eric Pylkas, a small-foundry expert and AFS member with Insight Industrial Hygiene Consulting Solutions.
Baseline exposure data is Step 1, but it’s not a one-and-done event; in fact, he recommends foundries perform air sampling quarterly. Without this regular influx of facts, a foundry is only guessing about its exposures and possibly throwing money in the wrong direction.
“There’s nothing worse than seeing a small foundry put in a $100,000 ventilation system that doesn’t fix the problem,” Pylkas said. “You’ve essentially just set that money on fire. It’s okay to have the ventilation, which may help you in the eyes of OSHA more than not having it ... But just like with anything, it makes so much sense to be educated on it; be knowledgeable that you’re putting in a system that’s going to help you and not spend money on something that won’t result in a significant improvement to worker exposures.”
The value of continuous data collection can be evident in the northern half of the U.S. where the seasons create very different air environments inside the small foundry.
“If I went into a typical small Midwest foundry in the middle of August, I bet you every single overhead door and every service door in that entire facility is going to be wide open,” said Pylkas. “The exhaust fans are operating, and with those overhead doors, you’re getting a lot of fresh air into the facility, which is ultra-helpful for controlling your exposures.
“But if we fast forward to January and it’s negative 15 degrees outside, none of those doors are open. And it’s quite likely that a lot of those roof exhaust fans aren’t necessarily on either, because once the doors are closed, those fans don’t function efficiently ... [at the same time], tempered make-up air systems are expensive and most small foundries won’t have them. So, it’s two different seasons in the foundry world, and collecting data during summer season is going to yield you completely different results than in the winter.”
Pylkas said even day to day, foundries can experience “wildly different exposures,” depending on the parts employees are working on. Abundant, real-time data is worth the expense, he said.
“I’ve seen foundries put in controls in areas where it’s like, ‘Why did you put it there? That’s not even the problem area.’ If you don’t have data that’s driving it, then you have much less confidence it’s going to fix the problem.”
When the at-risk people and places within the foundry have been correctly identified, acceptable action must follow a hierarchy of controls set by OSHA. The first thing inspectors want to see is elimination of the exposure––an example, according to Rowntree, would be switching to non-silica sand to address excessive respirable crystalline silica conditions. If elimination is unfeasible, OSHA will want the operation to implement engineering controls, such as ventilation/exhaust systems. Enclosing and ventilating sand-handling systems, which are a leading source of silica dust as well as noise, is another example of an engineering control to protect workers.
A range of respirators is available in the marketplace, from disposable styles to more sophisticated, powered air purifying respirators that provide that provide filtered air to the wearer. The problem is, OSHA doesn’t accept personal protective equipment alone as the only means to address overexposures. Rowntree said she doesn’t see the agency moving off that position any time soon.
“One could argue the benefits of [the PPE] approach as well as the negatives, but there’s a lot of things happening in the world of respirators,” said Rowntree. “If you’re looking at it purely from an employee protection standpoint, there are a lot of things about powered air purifying respirators and air supplied respirators that make them very attractive to protect people ... they’re getting better, lighter and a little bit easier to maintain. I just wish OSHA would at least consider that these things have merit as a long-term employee protection measure.
“From my standpoint, I want to protect employees,” she added. “I want employees to go home safe and not have some disease 20 years from now. And that’s all about keeping flying particles like silica or lead out of the employees’ breathing zone. The issue will be convincing OSHA that it’s the most feasible method of protecting employees.”
Experts agree that now’s the time to dust off the written plan every foundry most likely crafted to comply with the 2018 silica rule. Resuscitate it and apply it as a living document to govern how employees will be protected. And if their wellbeing isn’t enough to incentivize change, a knock on the door from either a federal or state OSHA inspector will surely help management see the light. A small foundry producing nearly 100% lead castings had that kind of wake-up call and brought Rowntree in for guidance to turn around their dismal situation.
“They had let their lead program fall through the cracks, and after some management changes in the operation, they just didn’t continue to do what they needed to do to comply,” she said. “OSHA came in, and they ended up with just a boatload of citations. But as part of that process, they got some newer management who were much more concerned about it and said, ‘We need to do something different here.’
“They basically fired the plant manager who was part of the problem, they buckled down and put in some engineering controls. They put everybody in respirators, they improved work practices, and they worked on their housekeeping. And over about 10 years, they now have their lead exposures extremely well controlled ... What they’re doing is working, and I couldn’t be more proud of how they’re handling that.”