The American Foundry Society (AFS) and five other trade associations sent a letter to the Secretary of Labor strongly urging the re-opening of the rulemaking record on the Occupational Safety and Health Administration’s (OSHA) final rule on Occupational Exposure to Respirable Crystalline Silica.

In the letter to Secretary of Labor Alexander Acosta, the six associations said if the rule is not changed, the economic impact will include the closure of many small and mid-size foundries in numerous states. Enforcement of the rule is slated to begin in June 2018, and that would lead to many larger foundries closing their U.S. plants and moving those operations to Asia, Europe, and other parts of the world.

As the letter points out, “Foundries are predominately small businesses, as 80 percent of domestic metalcasters have fewer than 100 employees. Many are family-owned. Our industry employs nearly 200,000 men and women directly and supports thousands of other jobs indirectly. Imported castings now comprise 20 percent of the market, mostly from China.”  

During the rulemaking process, as well as in a Aug. 23, 2017 meeting with OSHA staff, AFS outlined the following points: 

• The rule is technologically and economically infeasible for the foundry industry.
• OSHA drastically understated the compliance costs.
• The engineering and work-practice controls mandated by the rule represent a less-than-optimal regulatory approach.
• New, highly relevant data has become available since the rule was issued that casts further doubt on the feasibility of the rule.

Along with AFS, the five organizations signing the letter were the Casting Industry Suppliers Association, Ductile Iron Society, Iron Casting Research Institute, Non-Ferrous Founders’ Society, and the Steel Founders Society of America. AFS and the other associations support worker protections that are based on sound science and that are technologically and economically feasible. The OSHA crystalline silica rule does not meet that test.

According to the letter, OSHA did not take the economic devastation of the rule into account: “Imagine a federal regulation that each year would cost 276 percent of the industry’s profits,” the letter says. “That is the scenario here. OSHA has vastly underestimated the annual cost of the rule. Our smaller and medium-sized foundries are working with outside consultants and are now receiving cost estimates for the installation of engineering controls for well over $1 million, without assurances of meeting the new PEL (permissible exposure level).”

The American Foundry Society is a not-for-profit organization formed in 1896. With its headquarters in Schaumburg, Illinois, AFS provides members and consumers with information and services to promote and strengthen the $30.3 billion metalcasting industry.

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