New Silica Dust Proposal Would Have Big Impact on Foundries, Other Manufacturers

The Fabricator
October 2013

The Occupational Safety and Health Administration (OSHA) could impose new costs on metal casters and other manufacturers if it moves forward with new workplace exposure rules for crystalline silica, which gets into the air, in the case of foundries, when silica sand molds are broken in order to remove the  cast metal part. The OSHA lists foundry workers as numbering the highest among any general industry category for being exposed to levels of crystalline silica above the current permissible exposure limit (PEL). And only the concrete products sector has more total workers exposed to crystalline silica.

The proposed rule would replace a 40-year-old PEL of 100 micrograms with one set at 50 micrograms and an action level of 25 micrograms. The action level is the standard’s trigger for increased industrial hygiene monitoring and initiation of worker medical surveillance.

Groups such as the National Association of Manufacturers say no new standard is needed because there has been a 93 percent reduction in silicosis mortality from 1968 to 2002, according to the Centers for Disease Control and Prevention. Silicosis, an incurable sometimes fatal lung disease, is the major health effect caused by crystalline silica exposure.

The costs for all companies subject to the new standard, even those with admirably low current exposure limits, might be substantial given the exposure monitoring, medical monitoring and training costs. The OSHA estimates those to be $630 million for all sectors, total, on an annual, recurring basis. Amanda Wood, Director, Labor and Employment Policy, NAM, says industry estimates are $5 billion. Given the costs of compliance that all companies would face, Wood says the OSHA ought to focus on companies violating the current standard. 

The yawning difference between the OSHA and industry cost estimates may be because the OSHA says the  provisions of the proposed rule "are similar to industry consensus standards that many responsible employers have been using for years, and the technology to better protect workers is already widely available."

DOE Takes Next Step on Energy Efficiency Standards for Industrial Pumps

Green Manufacturer
September/October 2013 - for the online version go HERE.

The Department of Energy (DOE) has taken the next step in establishing first-time energy efficiency standards for industrial and commercial pumps. The agency is in the process of putting together what is called a negotiated rulemaking committee composed of users, manufacturers, and environmentalists who ostensibly hammer out a standard which then flies through the rulemaking process, without any objections.

The DOE previously released a request for information in 2011 and then a framework document last February providing some direction on where it expects to go, in terms of the categories of pumps covered and the kind of metrics that could be used to set new efficiency standards. The pump manufacturers, represented by the Hydraulic Institute, are pressing for "an extended product approach" using an energy efficiency index (EEI) which would take into account the pump, motor, variable speed drive and control and feedback systems. The HI has been working with environmental groups such as the American Council for an Energy-Efficient Economy (ACEEE), the Alliance to Save Energy, and the Natural Resources Defense Council (NRDC) on consensus standards with those efforts focusing on clean water commodity-type pumps. 

However, environmentalists want to expand the types of clean water pumps to include double-suction and circulator pumps. The EU already has a Directive (547, 2012) on efficiency standards  for clean water pumps, and the DOE generally intends to follow it. Charles Llenza, project manager for the rulemaking, says, "We have sort of borrowed from their playbook a little until we get our footing with this rulemaking and  the stakeholders input in the U.S. industry."

The DOE estimates clean water pumps represents about 70 percent of sales by value and 90 percent of  pump energy use. Those pumps can be used for chemicals and other liquids, and the DOE is considering roping "chemical" pumps--to the extent any are used primarily for that end use--into the new standard. But wastewater, slurry, API 610 pumps are outside the purview of this rulemaking.

A major issue will be whether to include variable speed drives (VSDs) in the standard. Greg Towsley, Director, Regulatory and Technical Affairs, Grundfos Pumps Corporation, the Danish concern which claims to be the world's largest pump manufacturer, wants VSDs to be included.  

But Steve Rosenstock, Senior Manager, Energy Solutions, the Edison Electric Institute, which represents investor-owned utilities, says, "EEI does not support establishing standards or test procedures based on pump performance with a variable speed drive controller. Pumps are used in a variety of applications and not all are a good fit for VSD."

EPA Balks at Updating Aftermarket Catalytic Converter Standard

Aftermarket Business World
Thursday, August 22, 2013 - for the online version go HERE.

The decision of a House Appropriations Subcommittee in late July to prevent the EPA from moving forward with its Tier III tailpipe emission standards moves the agency's proposed rule on that subject to the Capital's front burner.

In one sense, whether the proposal becomes final is a non-issue for the aftermarket since its sulfur-in-gasoline limit will not affect sales of aftermarket gasoline additives, at least as the proposal is currently written. When used at the maximum recommended treatment rate, aftermarket gasoline additives contribute less than the proposed limit of 3 parts per million sulfur to the finished gasoline.

But the proposal does raise some other aftermarket concerns. It does not modernize the EPA's dusty aftermarket catalytic converter standard, which differs from California's.

The whole point of the Tier III proposal is to bring EPA standards for reducing carbon monoxide, nitrogen oxide and hydrocarbon air pollution across the country to levels promoted by the California Air Resource Board (CARB) LEV III program, which goes into effect in 2015.

However, the Tier III proposal omits any mention of the EPA's aftermarket catalytic converter policy. It was adopted in 1986, and has never been altered. It is inferior to the requirements adopted by CARB in 2009 which requires catalytic converters to meet a 50,000 mile/5 year warranty and relies on a mass based standard (i.e. grams of pollution/mile). The EPA requirement is 25,000 miles/ 5 years. Instead of a "mass-based" standard, the EPA uses a 70 percent hydrocarbon, 70 percent carbon monoxide, and 30 percent NOx emission reduction-based standard.

What this means, if the House subcommittee cancellation of Tier III does not stand, is that there will not be one, aligned federal aftermarket catalytic converter policy. California and states that follow the CARB standard will have a stricter standard than the states that adhere to the EPA standard.

This doesn't sit well with some major national clean air organizations. One of the major proponents of an updated aftermarket catalytic converter policy is the Ozone Transport Commission (OTC), a group of Eastern states with among the biggest air pollution problems. In comments to the EPA, the OTC said, "Without updating its policy, EPA would be allowing use of replacement converters that will not guarantee emission reductions as long as the original converters. To ensure emission reductions occur when catalysts fall outside of the warranty period, the final Tier 3 regulation should include a more stringent aftermarket catalytic converter policy as recommended previously by OTC."

The OTC has adopted numerous resolutions over the past few years pleading with the EPA to bring its aftermarket catalytic converter policy into line with California's. It did so again at its 2013 annual meeting. However, the OTC recommendation differs in one aspect from CARB's: CARB would not allow used original engine manufacturer (OEM) converters to be certified and sold. The reuse of reconditioned converters is OK by the OTC.

Mary Nichols, the chairman of the CARB, calls the EPA Tier III proposal a "noteworthy strengthening" of Tier II standards. However, California did not ask the EPA to update its 1986 aftermarket catalytic converter policy when it submitted comments on the Tier III proposal. John Swanton, a CARB spokesman, says that was because "we limited our remarks to the specific issues included in the EPA proposal."

Asked about the omission, an EPA spokeswoman says, "EPA is aware of Ozone Transport Commission’s interest in an aftermarket catalytic converter regulation and OTC’s concerns regarding the proposed Tier 3 rule.  Currently, EPA is in the process of reviewing stakeholder comments received during the comment period, which was extended to July 1, 2013. EPA will take all comments received under consideration as we work to complete the final rule."

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