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SECTION III

SAFETY INFORMATION

Part A Notes on OSHA Standards


Introduction... 1. 2. 3. 4. 5. 6. 7. 8. 9. 10. 11. 12. 13. 14. 15. 16. 17. 18. 19. 20. 21. 22. 23. Bloodborne Pathogens... Cadmium... Chain and Web Slings and Hooks. Electrical Safety Emergency Evacuation and Fire Control.. Ergonomics .. Fire Extinguishers. First Aid .... Formaldehyde.... Grinding Wheels... Hazard Communication. Hazardous Waste Operations Hearing Conservation ... Lead... Lockout/Tagout. Machine Guarding. Medical Access. Overhead Cranes... Permit Required Confined Spaces. Personal Protective Equipment. Powered Industrial Trucks Process Safety Management.. Respiratory Protection... 36 37 38 39 44 45 48 52 54 58 58 60 63 64 72 76 77 78 78 83 86 87 88 89

SECTION III A SAFETY INFORMATION


INTRODUCTION Part A of this section entitled, Safety Information: is devoted to comments concerning most of the OSHA standards which apply to foundry operations. It covers those standards which require programs, that is, those where more than one step on your part is necessary. Those steps may be employee notification, specific employee training, preparing a written program, periodic inspections, certifications, recordkeeping, designating responsibilities, air sampling, medical testing, etc. Other standards, such as those covering walking and working surfaces and machine guarding, generally do not require interpretation and can be found in the index at the back of the OSHA Regulations Book, Part 1900 to 1910.999. A full list of foundry applicable standards is found in the Appendix. The discussions which follow are not full interpretations of the standards by any means so be sure you read each one thoroughly. Part B discusses other aspects of your safety program. PART A - NOTES ON OSHA STANDARDS 1. 2. 3. 4. 5. 6. 7. 8. 9. 10. 11. 12. 13. 14. 15. 16. 17. 18. 19. 20. 21. 22. 23. Bloodborne Pathogens Cadmium Chain and Web Slings & Hooks Electrical Safety Emergency Evacuation & Fire Control Ergonomics Fire Extinguishers First Aid Formaldehyde Grinding Wheels Hazard Communication Hazardous Waste Operations Hearing Conservation Lead Lockout/Tagout Machine Guarding Medical Access Overhead Cranes Permit Required Confined Spaces Personal Protective Equipment Powered Industrial Trucks Process, Safety Management Respiratory Protection

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PART A OSHA STANDARDS


1. BLOODBORNE PATHOGENS (1910.1030) This standard has been confusing because it applies to all occupational exposure to blood or other potentially infectious materials and to reasonably anticipated. contact with blood. It sounds as though it applies to people in the healthcare field. While it does, it can also apply to a foundry setting and here is why. The starting point in thinking about bloodborne pathogens is as follows. There are some microorganisms, Hepatitis B and the HIV virus being the best known ones, which can get into your bloodstream, cause illness and death. There are no cures for these two, although there is a series of vaccinations which can prevent one from getting Hepatitis B. There is no such vaccination against HIV. Statistically, only 3% of people who contact Hepatitis B die from the virus. To date, there is no cure if you have contracted the HIV virus which, through time will develop symptoms called AIDS. To date no one has outlived the HIV virus, so this is a very serious subject. The HIV virus has been found in body fluids other than blood, although to date there are no documented cases of transmission of the virus except through sexual contact or blood to blood contact. We use the expression Universal Precautions to be conservative, meaning not to let any bodily fluids of another come in contact with your bloodstream because medical science does not yet know everything about the HIV virus. What makes the subject all the more serious is that if someone carries one of these microorganisms in his or her bloodstream, he or she may not know it because it can take years before the symptoms surface. Further, if you are carrying the microorganism and you know it by test, you do not have to tell anyone! Well then, where does that leave all of us? It leaves us in the position of having to assume that anyone or everyone around us may carry and could transmit such a disease to us. Some companies take the position that only first aid trained people should handle first aid matters. But that may not be a practical policy when you find someone bleeding seriously and the first aid people are nowhere to be found. Therefore, we think that everyone needs to understand the basics of this potential health problem and get refresher training each year as required for first aid certified personnel. If you have first aid trained people, and you certainly should have 2 such trained people on each shift, they receive bloodborne pathogens training as part of their periodic retraining as first aiders. They should know: 1. The companys exposure control plan. 2. Which tasks are more likely to cause exposure to blood or other bodily fluids. 3. Methods to reduce exposure-use of protective clothing 4. How to handle blood or other body fluid contaminated materials clean up procedures and equipment the use of a biohazard cleanup kit which becomes part of your first aid kits. 5. The information on the Hepatitis B vaccination program a series of 3 shots over a period of six months made available to first aiders. Under normal conditions it is always advisable to have first aiders handle medical emergencies. However, every employee should be given the basics of bloodborne pathogen training because it is such a serious subject and the time may come when a first aider is not immediately available, to say nothing of the need to protect oneself in a private setting outside of the plant environment. Your health insurance premium could jump.

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WORKER TRAINING. Now suppose someone near you gets into trouble with a cutoff saw and severely cuts his/her hand or arm. Your instinct may very well be to rush to aid in providing comfort and to stop the bleeding a perfectly natural response because we all know that the name of the game is to keep the blood in the body. The theme is to keep on your dirty gloves if you come to someones aid. We can cure an infection if someone gets an infection from your dirty gloves but there is no cure for the HIV virus if someones blood containing that virus comes into contact with your bloodstream. But how could that happen? If you get someone elses blood on your hands, you might have an open cut, scratch a pimple, or, during especially cold winters, have deep juicy cracks in your fingers. A supervisor came to one of our training sessions and his shirtsleeve was soaked with blood but he didnt know it because he was distracted when he cut himself and did not feel the pain. Had he come to the aid of a fellow worker with his sleeves rolled up shortly after he cut himself, it is possible that there could have been blood-to-blood contact and the possible transmission of the virus! If you do get someone elses blood or any other body fluid on your skin, wash yourself thoroughly with soap and water. If you should be involved in a cleanup, the biohazard cleanup kit which should be stored with the first aid kits will have a chlorine solution or powder with which you make such a solution that will kill bloodborne pathogens. Put on the rubber gloves before using the absorbent materials to protect your skin which are then placed in the red biohazards bag for special disposal. 2. CADMIUM (1910.1027) This standard very closely parallels the Lead Standard with its air testing, and employee monitoring requirements. The

Cadmium Standard covers more than 100 pages including Appendices. It is your responsibility to test the foundry air for the presence of cadmium. Cadmium is, for our purposes, a tramp metal which can enter brass, bronze and aluminum foundries in your ingot and in purchased scrap steel. Do not rely on the MSDS your ingot supplier sends along. Some will indicate no cadmium, others report a trace and some give a range, although very small. We have found cadmium in a brass foundry where there was no indication that it would be present from the suppliers MSDS. Cadmium could be found in steel foundries if the foundry was using scrap containing cadmium plated bolts, for example. Cadmium is sometimes found in welding rods and in paints, although today it is not likely that you are using much painted scrap. Lead is more typically found in painted scrap such as cast heating system radiators and their brass fittings. While the Cadmium Standard is very similar to the Lead Standard, the PEL is only 5 micrograms per cubic meter of air, onetenth that of lead. The action level is 2.5 micrograms per cubic meter. However, unlike the Lead Standard, if any amount of cadmium is found, you must do annual employee training. That training must cover: 1. The contents of the Cadmium Standard 2. The results of your air monitoring. 3. An explanation of biological monitoring. 4. How cadmium enters the work area. 5. Symptoms of cadmium exposure kidney damage and lung cancer. 6. Procedures you need to take, if any, as directed by the company. If two air tests, taken at least one week apart, are below the action level, only employee training is required. Between the action level and the PEL, air sampling is required every six months. In addition, blood and urine testing is required as

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well as a medical and work history. Our experience has not found cadmium levels at or above the action level. 3. CHAIN AND WEB SLINGS AND HOOKS (1910.184) CHAIN SLINGS The only chain type allowable for lifting is grade 80 (high strength alloy), no longer the longstanding grade 63. A new grade 100 is emerging on the market and is lighter in weight. The OSHA Standard requires a visual inspection each day by the person first using a chain or chain sling. Additionally, from each week to once a month they should be given a more thorough inspection, typically by your maintenance department and a very thorough inspection annually, typically done by your chain supplier. We strongly recommend that you use an outside firm for the annual inspection. For example, the daily inspection should look for links that have lost their convexity and have parallel or concave sides. This indicates that the chain has been stretched and should be taken out of service. The maintenance department would go one step further by twisting the chain to see if it has stretched. Someone experienced with chains can tell if a chain has stretched beyond its maximum allowable length by how far it can be twisted. A stretched chain will not twist as far. At the annual inspection the chain supplier will lay out the chain sling and actually measure the length of each arm. Chains of different link sizes can grow by a very small maximum amount before they are considered unserviceable (3%). If a chain sling has one leg longer than the other, that sling has been stretched. Look at the loading capacity tag for the original length of the unit. Some show it and some dont. There is a difference between wear and stretch. Refer to the Campbell Chain Division procedure.

The photograph which follows shows examples of chain wear conditions which need to be looked for. The minimum allowable wear thickness of chain links for different chain sizes is given in a separate chart. Here are some conditions which indicate a worn chain: 1. links which have been worn from being dragged across the floor. They will have flat sides. 2. links which show gouges, perhaps from coming in contact with a grinding wheel or cutoff blade. 3. links which have been struck with an electric welder. 4. links which have been stretched. 5. links which have worn excessively from link to link contact. 6. links which are cracked, often at the interface of a factory weld. Chains cannot be repaired with homemade welds because the weld will not have been hardened. Chains should be stored off the floor when possible and kept free of oil and grease. Foundry hooks should be checked for wear at the throat. The chart attached gives the wear tolerances for those hooks. Hooks should also be removed from service if they have been bent side to side by more than 10 out of plane or opened by more than 15%. For example, a 2-inch hook opening can open to no more than 2.3 inches. Foundry chains are alloy chains, much stronger and tougher than chain you buy at the hardware store. After being completely assembled, the entire unit is heated up red hot and dashed through a stream of water or salt water or oil to flash chill it, rendering it through hardened and extremely tough. Alloy chains can typically withstand 600 F. on a continuous basis and up to 1000 F. for an instant! If you suspect exposure above those temperatures, remove the chain from service to have it proof loaded.

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Look at the chart showing the reduction in More than one chain sling has snapped, load capacity as the angle of the arms get killing a nearby worker. Even though chain smaller and smaller from the horizontal. At slings are proof tested at twice their rated 30 the strain on each arm has doubled capacity, they do get misused, overloaded and reducing the lifting capacity by ! The break. People have also been killed when solution to this problem, found when you are chain sling hooks were too casually placed handling a very long object, is simple. Use a around a casting and slipped, wrapping longer sling and get the angle back up to 60 around a worker like a snake. The worst or more. Chain sling load limit tags typically thing to do is to jerk or snap the load when rate the loading capacity at a 60 angle. Be lifting. sure your workers understand this clearly. Campbell Chain Division Extract from A Procedure for Chain Sling Inspection STRETCH OR WEAR? It is important that an inspector realize the difference between stretch and wear. A chain with long service and frequent use will increase in length even if not overloaded. This increased length caused by wear should not be confused with stretch. It is also possible to get increased length due to stretch with little or no wear. At times there will be a combination of both conditions. Remember that increased length due to wear is normal for a chain that has been in service for a long period of time. However, increased length due to stretch, with little or no wear, indicates a serious error in the lifting procedure. An accurate manner of checking stretch of elongation is to measure the inside length of the link(s). Deduct the wear (difference between original wire size and measured wire size) from the bearing points and divide this amount by the original length of the link. EXAMPLE: Alloy (when new) inside length 1.55 Measure link length 1-11/16 or 1.68 Measure bearing point wear 1/32 x 2 = 1/16 or .06 Deducted from measured link length and take results, 1.62 divided by 1.55 = 1.05 or approximately 5% stretch Although this method will provide you with the most accurate results, difficulties may be encountered because all manufacturers vary slightly in their link lengths. This method of computation should be followed only where the original link length is known. Therefore, when establishing your original inspection record cards, link lengths should be recorded after measurement for all new chains put into service. A similar procedure should be conducted on any chain added after it has been repaired.

Figure 7

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Recognize these seven sling danger signs?

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WEB SLINGS Web slings behave in exactly the same fashion as chain slings. Load capacity decreases as the angle gets smaller because in addition to the fixed vertical force, the horizontal force increases. In terms of wear, they may only have cuts or abrasion inward from the outer edge until the embedded colored strand shows. Then it must be discardedLook at the end of a web sling and you will see perhaps a red or a red and green strand. Sleeves are available to add life to otherwise delicate, lightweight, convenient to use web slings. TIPS FOR CHAIN USE 1. Avoid sudden jerks when lowering or lifting the load. That will stretch and possibly break the chain. 2. Balance the load before lifting so each arm has equal loading. 3. Never overload beyond the maximum allowable limit as determined by your chain manufacturer, which will be found on the metal identification tag attached to the master link 4. Do not use chains if they are twisted or knotted 5. Do not drop the load onto the floor on the chain. 6. Be sure the chain link is all the way in the crotch of the hook and not out on the tip. 7. When possible, use padding around sharp corners of the object being lifted. This will reduce point strain on the links. 8. Store chains off the floor so they stay safe, clean and dry. 9. Oil chains before prolonged storage. 10. Do not anneal chains yourself, as this may destroy the manufacturers hardening process if not done in exactly the same way.

4. ELECTRICAL SAFETY (1910.331-335) Electrical hazards need constant attention in foundries because of the large number of electrical controls normally found, the dusty conditions and the usual beating that electrical equipment takes in the rough and vibrating foundry environment. One condition often overlooked in foundries is keeping junction boxes closed. Electrical contact can be made from grinding room dust high in metal content slowly accumulating on energized electrical contacts. The magnetic halo around an energized electrical contact attracts metallic dust and can actually close a circuit and start up a piece of equipment or create an explosion. Both have happened, injuring employees. Here is a recent list of electrical hazard citations issued by OSHA arranged with number 1 reflecting the greatest number of citations written. 1. Guarding of live parts (1910.303.j 2) electrical boxes left open or knock-out holes unplugged. 2. Identification (.303 f) every switch box should be marked as to what it controls and its voltage. 3. Flexible cords (.305 g 1) substituting extension cord wiring where fixed wiring is possible, especially through walls, etc. 4. Pulled wiring at joints & terminals (.305 g 2) tension & abrasion from vibration at electrical boxes & power tool connection causing frayed cords exposing individual wires. 5. Splices in flexible cords (.303). 6. Grounding (.304) boxes, conduit and all equipment must be 3-prong. 7. Location of overcurrent devices (fuses or circuit breakers) (.304 e) must be within easy reach of the equipment it controls. 8. Working clearances (.303 g 1) adequate space between banks of

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electrical equipment for repairman to stand safely between units. 9. Marking (.303 e) manufacturers name & capacity on all equipment (e.g. 120 or 240 volts). The standard requires, in Section 1910.332, the training of all employees exposed to parts of electrical circuits operating above 50 volts in the basics of electrical safety. A very useful basic theme is to keep your left hand in your pocket when dealing with suspect electrical wiring and equipment. The electrical system in any foundry should be considered suspect because of the pounding it takes in the normal course of making castings. Since your heart is in the left center of your chest cavity, there is a greater chance of it being in the line of current coming to your body through your left hand seeking its way to ground than current coming through your right hand arm or shoulder. Keeping your left hand in your pocket also prevents current from going across your chest to take a shorter route than through your feet. 5. EMERGENCY PREPAREDNESS, MEANS OF EGRESS & FIRE PREVENTION PLANS (1910.35-38) The purpose of such a plan is to assign responsibilities and establish a course of action for the safe and orderly response to emergency situations. Those situations can include: # a chemical spill # civil disorder # entrapment # explosion # fire # bomb threat # flammable liquid or gas leaks # natural disaster, i.e., storms or lightening # power failure # serious injury # structural failure of the building

It is extremely important to address these circumstances which arise by surprise, with careful planning, assignment of duties and executing dry runs just as we did in grade school. There is a great tendency for us to overlook planning for the sudden emergency, in part, because we dont think it will ever happen to us. A. EMERGENCY PREPAREDNESS Different emergencies call for different procedures. If a fire develops on a foundry floor, your fire plan would go into effect. If a portion of the roof blows off, an emergency shut-down plan might go into effect. Or, if theres a serious injury or injuries, an ambulance and hospital call may be triggered. The starting point is to prepare a plan of your building and process layout. Your employees, rescue services and outside utility workers should be able to find power shutoffs, water lines, electrical breakers, gas lines, etc. and protective devices as quickly as possible during an emergency. The locations of hazardous and flammable materials need to be noted on a facility layout along with any other danger areas. An emergency coordinator and his alternates need to be designated to cover each shift. An emergency team should then be established with specific assignments for actions in an emergency. During most emergencies outside individuals and services need to be contacted, so list their names and phone numbers in your emergency plan. They might include a hazmat team, fire department, police department, company doctor, hospital, rescue services, a nearby clinic or infirmary, and the poison control center. Other contacts and phone numbers might be utility companies, your insurance company, the EPA and OSHA. There should be a contact person authorized to discuss the emergency with the media, the public or regulatory agencies. His or her home phone number and the names and phone numbers of

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emergency units, such as your doctor, hospital, police and/or fire department should be readily available in the plant. Your plants layout indicating the position of fire control equipment, extinguishers, and special handling areas, such as hazardous chemicals and flammables, should be posted in each department. Emergency preparedness training should be given to all employees. They should be instructed in how to respond to warning alarms, how to report an emergency, and be given a description of the responsibilities of the emergency team. Employees uninformed of such an action plan may become confused

and interfere with your plan when they are trying to be helpful. The three most likely emergency situations encountered in a foundry are medical emergencies and fires, and explosions usually followed by fires and utility failures. Below is an example of a very basic emergency evacuation plan developed by a foundry which covers the emergency shutdown of equipment. This is an example of the simplest possible evacuation plan. Be sure to read the OSHA standard for a more complete description of requirements which can become complex.

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USA FOUNDRY EMERGENCY EVACUATION PLAN Purpose: To assign responsibilities and courses of action for the safe and orderly evacuation of the plant in case of major fire or other emergency. Responsibility Evacuation decisions will be made by: a. Foundry Superintendent, or in his absence b. Cleaning Room Foreman or c. Maintenance Foreman Evacuation signal will consist of four long blasts on the time clock horn. Emergency Escape Procedures: 1. Building layout with all exits is posted in each department. 2. Employees should use exit closest to their work station, otherwise the alternative exit. 3. All employees must assemble in parking lot after leaving building for a head count. Procedures for Emergency Shutdown of Equipment According to Type of Emergency: 1. Cupola - Foundry Superintendent or acting supervisor will designate shut down procedure based on type of emergency. 2. Oxygen tank - Cupola leader will shut emergency valve at tank for all emergencies. 3. Air compressors - Maintenance Leader will shut down all air compressors. 4. Electrical service - Maintenance Foreman or Maintenance Leader will shut off all electrical service if required by type of emergency. 5. Gas service - Maintenance Foreman or Maintenance Leader will shut off gas service at inlet to building. Procedures to Account for all Employees: Headcounts will be taken by the following: Foundry personnel - Foundry Supervisor or acting supervisor. Cleaning, core room & shipping personnel - Cleaning & Core Room Foreman or Lead Inspector Shakeout personnel - Shakeout Leader or Foundry Superintendent Maintenance personnel Maintenance Foreman or Maintenance Leader Phone Numbers: Dr. Smith Hospital Ambulance Police Figure 11 Emergency Response EPA DEP County LERC -

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B. FIRE CONTROL Fire control consists of fire prevention and fire fighting. Foundry fires are most likely to take place in the: - melting area - pouring area - core machines and furnaces - welding and burning operations The diagram of the plant layout should include the location, type and size of fire extinguishers. All employees should be trained in handling a fire extinguisher and this training should be repeated annually. Fire extinguisher training is especially important because some employees unfamiliar with fire extinguishers may be frightened by pulling the pin, thinking it is timed like a hand grenade. We cannot emphasize enough that people unfamiliar with the use of fire extinguishers are reluctant to pull the pin. The pin is simply a mechanical barrier to depressing the handle which in turnlets out the powder stored under pressure. Extinguishers are classed as A, B, C, or D which means: A - for combustibles such as wood, paper and cardboard, B - for flammable liquids such as alcohol, gasoline and kerosene, C - for use against electrical fires such as energized wiring and drive motors, D - for use against flammable metals such as titanium, magnesium and aluminum. Extinguishers suitable against types A, C, and D fires should be placed no further than 75' from those types of fire hazards, according to OSHA regulations, but in reality, should be placed much closer to every foundry area than that. Type B extinguishers must be placed no more than 50', by OSHA regulation, from a potential electrical fire, because such fires reach their full intensity almost immediately, but you should certainly have them closer. If you have decided to attempt to extinguish fires with your own fire brigade, using large C02 cylinders or water tanks and fire hoses, that brigade must be put through specific annual training as listed in OSHA Standard

1910.156. If not, your plan should state that you will notify the fire department and evacuate the building immediately. We do not recommend that you institute a fire brigade because the requirements are quite complicated, unless, of course, you are a substantial distance from the local firehouse. Your fire safety prevention plan should include the following: 1. the placement of the correct fire extinguishers around the plant and clear markings of their locations high on the walls or beams. 2. well-developed and enforced safe work rules such as: a) no smoking in areas with flammable materials b) flammable materials stored in grounded or vented safety cabinets c) flammables transferred from one container to another using standard grounding techniques which eliminate electrostatic sparks d) clear labeling of flammables e) controlled use of open flame such as ladle heaters, burning off core washes and welding or burning operations 3. annual instruction in the hazards of different types of fires and the use of different fire extinguishers. 4. an adequate warning system if a fire develops. 6. ERGONOMICS (was 1910.900) Ergonomics is the study of a worker and his physical relationship to his job. It is the science of designing the work and the workstation so it most ideally suits the bodily motions of the worker keeping reach, load, bending, twisting and repetition within the reasonable limitations of the individual performing the work so as not to cause injury to ones muscles, joints, tendons, ligaments, blood vessels, nerves and discs. It is the attempt to reduce the number and severity of

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musculoskeletal injuries in the workplace caused by risk factors found in the foundry. There are five risk factors to be considered. They are REPETITION of the same bodily motion; FORCE, that is, lifting heavy loads and their repetition, pushing pulling, pinching an object to hold it and hand gripping; AWKWARD POSTURES such as working with your hands over your head, bending, kneeling, squatting or working with your back, neck or wrist twisted; CONTACT STRESS, using your hand, elbow, knee or foot to bang things like a hammer or pushing hard against something; and VIBRATION, using tools which vibrate or standing on a vibrating surface. Excessive heat or cold are additional considerations or risk factors that can add stress to the job and possibly overload your musculoskeletal system. One way of thinking about relieving the stress on the body is to think in terms of a weight moving a certain distance or foot pounds of energy expended. Any way you can find to reduce the overall foot-pounds of energy necessary to perform a task will reduce the likelihood of a muscular skeletal overload. Repetition is, naturally, equally important because excessive repetition of the same body parts can irritate, inflame and injure tendons, ligaments, muscles, joints and nerves, causing pain, burning and weakness, refered to as MSDs, musculoskeletal disorders. OSHA introduced an Ergonomics Standard on November 14, 2000. In March of 2001 Congress and the President rescinded the standard as being too overeaching, since any injury other than a slip and fall, a cut, a puncture or a broken bone qualified as a musculoskeletal injury and OSHA set exertion standards which could automatically make the injury job related! Additionally, no consideration was given to the fact that the aging process causes normal aches and pains, symptoms of musculoskeletal injuries. In any event, the attempt can serve as a guideline

which one can use in looking around the foundry for situations where workers may be overloading their bodies either by lifting very heavy items or repetative motion. At some point in the future OSHA will certainly come out with a revised standard or Recommended Practice. Doing ergonomic analyses can with certainty reduce the potential for workers compensation claims and pressure your valuable workforce. Ergonomics is a facinating, creative and very useful science and for that reason we have included comments on the OSHA standard as it came out, although it is no longer in effect. The preamble to the short-lived standard and its appendices make up a remarkable 1800 normal typed page resource on the subject for both plant and office workers and can serve as a guideline for your own ergonomics program. Also, see Section III, Part B, No. 1, Back Care, for more helpful information on the number one symptom of injury in the foundry and most industries. The standard first calls for you to inform your employees as to the following: EMPLOYEE INFORMATION 1. What are musculoskeletal disorders and their signs and symptoms e.g., excessive repetition of wrist motion can cause pain and weakness of grip which results form an inflammation of the tendons running through the carpal tunnel (the inside of your wrist), the disorder referred to as carpal tunnel syndrome (CTS). 2. The importance of reporting symptoms early and how not reporting them early can aggravate the symptoms and prolong the recovery. 3. How and where to report symptoms 4. The risk factors associated with the possibility of developing a disorder and work activities associated with MSDs.

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5. A description of the requirements of the OSHA Ergonomics Standard. All of this information must be written out and posted on bulletin boards. OSHA provided in this standard Appendices A and B which would fulfill these requirements. They are brief and well done. While the standard did not require it, we suggest that you cover these subjects in a training session to allow for questions and clear up misunderstandings. If employees tell you that they have the symptoms of what they believe is a work related musculoskeletal disorder (WMSD), you are to respond promptly to determine if the complaint is work-related and therefore requires medical treatment beyond first aid, restricted duty or days away from work. How do you determine if it is work-related? The standard has thresholds or trigger levels for each of the five risk factors. For example, the risk factor of FORCE has a trigger level of 75 lbs. for a single lift or 55 lbs. more than 10 times a day, or lifting more than 25 lbs. below the knees, above the shoulder or at arms length more than 25 times a day. If painful back symptoms develop as a result of one or more of these activities, on only one day of the week, the symptoms are presumed to be job-related! The other condition necessary to qualify symptoms to be work-related is if they persist and last for 7 consecutive days after reporting them. How do you determine if the reported symptoms require light duty, days away from work or medical treatment you can use a Health Care Professional (HCP) to help you make the decision. What is a Health Care Professional? That is anyone holding a license, certification or registration to medically manage a MSD, a very broad definition. You must provide the HCP with the job description, risk factors, the WMSD reported and a copy of the standard which of course is no longer in effect. The HCP must then issue a written opinion with

recommendations which you make available to the employee. The next question is what must you do at the work station after identifying the complaint as a WMSD (work-related musculoskeletal disorder). You must either develop a full ergonomics program or use a Quick Fix approach under a narrowly defined situation. That situation is if your employees have experienced no more than one WMSD in one particular job classification and these have been no more than 2 WMSDs anywhere in your operation over the last 18 months. In that case, the Quick Fix approach can apply. It includes executing the following: THE QUICK FIX 1. Provide medical management to the injured worker. That means providing access to an HCP. 2. Discuss with employees in that job category the specific tasks that may be causing the problem. 3. Observe their jobs to attempt to identify the risk factors involved. 4. Ask those employees for suggestions to reduce the risk. 5. Apply engineering, work practice or administrative (job rotation) controls to reduce the risk below the trigger levels, e.g., below 10 times in a day or less than 55 lbs., or comply with the recommendations offered in the references given in Appendix D for the particular risk involved. Those references are extensive studies collected from academia, insurance and governmental agencies. Whatever solution or solutions you apply must be accomplished within 90 days. It might, for example, be the design, fabrication and installation of an air operated mold weight unit which lifts and lowers weights onto moulds to replace weight shifting. It might be an

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air operated adjustable height table to lower moulds onto the pouring line from the mould station. 6. Within 30 days of implementation, you must determine if you have lowered the risk below the trigger level and keep a record of what you did for 3 years. If, however, you have not been successful in getting below the trigger level, you then must put into place the full ergonomics program. The full ergonomics program is mandatory if you have reported more than the number of complaints which qualify for a QUICK FIX. The requirements of the full ergonomics program are given below. ELEMENTS OF A FULL ERGONOMICS PROGRAM 1. Provide the 5 items of employee information, recited previously. 2. Provide management leadership this means assigning responsibilities for setting up and managing the program and providing those individuals with the resources and authority to carry it out. 3. Include employees in the program by including them in the development, implementation and evaluation of your program. You might use your present safety committee, establish a subcommittee or start a separate one specifically for ergonomics. See the following Item 4. 4. Conduct a Job Hazard Analysis (JHA) you must include the affected employees in this analysis. Tools for performing this analysis can be the studies and recommendations given in Appendix D-1, the help of an individual trained in ergonomic analysis or any other reasonable method. If you find that there is a

substantial risk involved likely to cause further WMSDs the job is termed a problem job and you must take some steps to reduce the risk. You are to ask the affected employees for corrective recommendations. 5. Institute steps to reduce the WMSD risk using the Appendix D recomendations or in other ways to the extent which you can, but in that case, you must re-address the job tasks at least every 3 years. As described earlier, the steps you take can be engineering (the first preference according to OSHA), work practice, job rotation and personal protective equipment. While this standard attempted to standardize a subject which by definition of the word ergonomics means a custom fit, and should have first been introduced as a Recommended Practice, there are, nonetheless, lots of inexpensive and creative solutions to relaxing overloaded body parts. For example, to reduce body twisting, when a forklift brings a pallet of castings to a grinding station, a yellow line on the floor can designate just how close to the worker it can be placed not up close, so that the worker must step to the left to pick up the casting, thereby reducing the twisting with a load. Also, by nailing one pallet on top of another, the worker doesnt bend down as far in order to pick up the bottom layer of castings. Our experience is that ergonomic studies are far more useful when done by a team. All kinds of interesting, non-obvious solutions to problems surface when a group each with different perspectives look at the same problem. The solutions can be interesting, creative and sometimes exciting when a clever idea surfaces. Fortunately, the basic concepts of ergonomic analysis can be taught very quickly. We think that the subject of ergonomics is a very constructive approach to helping to reduce the overall musculoskeletal

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loading on foundry workers as well as all workers, including office workers. Under another Susan Harwood Grant, PFA has developed Train-the-Trainer ergonomics and worker training modules available on the PFA website at www.pfaweb.org. 7. FIRE EXTINGUISHERS (1910.157) Fire extinguishers require monthly and annual inspections. You should have a separate inspection sheet which lists each station, some people number each station, and the type and size of extinguisher which is assigned to that location. Inspections should be done as a separate monthly exercise, with each tag dated and initialed as to who performed the inspection. The annual inspection is better left to your servicing company, since they have the materials and equipment which it is unlikely you have. The monthly inspection should look to see that: 1. It is there 2. The correct size and type 3. Hung on the wall, not stored on the floor. 4. The seal is in place 5. The pin is in place 6. The gauge reads okay, if it has one Okay for the needle to be a bit above the full mark 7. The cylinder is not damaged 8. The hose is not clogged, e.g., chewing gum 9. The tag is there indicating when last serviced.

If the gauge is only slightly down or the seal is broken, or the pin has been removed or the tag missing, the unit has become unserviceable. Sprinkler systems require semi-annual inspection. How close to the fire should you get? Come up as close to the fire as you can until you can feel the heat on your face. Aim the stream at the base of the fire, moving the extinguisher back and forth. ABC dry powder extinguishers have a lot of thrust but empty in about 10 seconds. Type BC (CO2) extinguishers have extreme thrust so be careful not to literally blow the flames away and ignite nearby combustibles. They are identified by a long black tapered plastic nozzle and no gauge. They must be weighted to determine that they are full. The full weight is stamped on the cylinder. There is no gauge because it would not withstand the 600 lb. full pressure. Here is a chart prepared by NIOSH showing types of fires, extinguishers and extinguishments techniques.

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FIRE EXTINGUISHERS
WHERE TO USE
CLASS A TYPES OF FIRES
ORDINARY COMBUSTIBLES: wood, paper, cloth, trash and other ordinary materials.

TYPES OF EXTINGUISHERS

CLASS A

CLASS A:B CLASS B


FLAMMABLE LIQUIDS & GASES: gasoline, oils, paint lacquer and tar.

CLASS A:B:C

CLASS C

FIRES INVOLVING LIVE ELECTRICAL EQUIPMENT.

CLASS A:C

CLASS B:C
COMBUSTIBLE METALS OR COMBUSTIBLE METAL ALLOYS (NO picture symbol) FIRES IN COOKING APPLIANCES THAT INVOLVE COMBUSTIBLE COOKING MEDIA vegetable or animal oils and fats

CLASS D

CLASS D

CLASS K

CLASS K

HOW TO USE

Figure 12
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8. FIRST AID (1910.151) First aid is the immediate and temporary care given the victim of an accident or sudden illness until adequate medical care can be obtained. Having some knowledge of first aid can be life saving. While OSHA does not require first aid training if medical facilities are available nearby, every responsible employer will have at least two first aid trained individuals on each shift. While the OSHA standard is not specific, an interpretation of available nearby has been described as within four minutes of the site. That is a very short period of time andeven if you are just up the street from a hospital or clinic, you should have first aid trained personnel on site. Many non-occupational medical emergencies can develop as well. First aid treatment can be critical to the ultimate extent of an injury. First aid and CPR training is routinely given by the American National Red Cross, local Chambers, manufacturers associations, and many YMCA's offer first aid training. Certified first aid instructors can be hired to train your own people in-house. Be sure the Heimlich Maneuver is included in the training. It has cleared many windpipes and saved many lives, including the wife of the author. Here are some first aid tips and recommendations for first aid kits. FIRST AID TIPS Many injuries are minor, requiring nothing more than cleansing and a band-aid. More serious injuries may involve burns, severe bleeding, heart (cardiac), failure, breathing difficulties, choking, poisoning, head injuries or broken bones. First, stop the bleeding and determine whether artificial respiration is necessary. Then determine additional problems. Move injured persons as little as possible, only after you know what parts of the body have been injured. Always support injured parts when moving persons so as to avoid compounding the injury. To offset shock as much as possible, keep victim's body temperature from falling, preferably with blankets. Never heat the
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victim. Call a physician, local EMT or obtain medical advice on the phone as soon as possible. ADDITIONAL POINTERS 1. Identify the extent of all injuries, not just the most obvious one. 2. If victim is unconscious or partly conscious, do not attempt to rouse, or give fluids, or lift by the belt. 3. To allow good breathing if victim is unconscious and there is no apparent fracture, loosen clothing around the neck. Unless victim has suffered a head or neck injury, turn patient on his side and maintain this position by bending a leg. Place a pillow under head so secretions can drool from comer of mouth. Clear dentures, vomit or other materials out of mouth to allow air to move in. 4. With indoor accidents, dont open windows if weather is cold unless noxious gasses are present. 5. Leave diagnosing patient's condition to medically trained persons. 6. Reassure victim that help is on its way.

SUGGESTED SUPPLIES FOR CENTRAL FIRST AlD STATIONS (Post all emergency telephone numbers) # 1 pint of antiseptic # antiseptic applicators # 1" adhesive bandages ("Band-Aids") # 8 rolls 1" gauze bandages # rolls 2" gauze bandages # 2"x2" sterile gauze compresses # 8- 4"x4" sterile gauze compresses # 1 roll 2" adhesive tape # roll 1 " adhesive tape # 40" triangular bandage # bottle of boric acid solution (eye irrigation) # eye patches # bottle of eye drops # tourniquet # forceps # pair of scissors # set of splints # small tank of oxygen # 1 tube of burn dressing # blanket # ammonia inhalants & ampules # instruction book PORTABLE FIRST AID KITS # 1/4 pint of antiseptic # band aids # rolls I" gauze bandage # rolls 2" gauze bandage # 84" sterile gauze compresses # 1 roll I" adhesive tape # 1 tourniquet # instruction booklet

the skin reddens. In second degree burns, the skin blisters. In third degree burns, all layers of the skin are destroyed. Third degree burns are the most dangerous, leaving the body without a protective covering; bacteria and infections can enter and vital fluids escape. Treat first and second degree burns instantly with cold water, ice, then clean and keep clean. Keep third degree burns clean and covered until adequate medical care can be obtained. Chemical Burns Many chemicals, both acids and alkalis, can burn the skin. Dilute the chemical's potency by instantly flushing the burn with large amounts of water. Obtain medical treatment immediately. Electrocution Even an electrical shock of 0.2 amps can stop the heart from pumping! Electrical shock sends the heart into an out-of-sequence non-pumping pattern of electrical activity called fibrillation which can be fatal within four minutes. To treat an electrical shock, first make sure the victim is removed from the electrical tool or apparatus by unplugging the tool, or cutting off the electricity. If these aren't possible, attempt to knock or push the victim away from the current. Use only nonconducting instruments, such as a piece of wood. Otherwise, you may become part of the current and be electrocuted yourself. If victim stops breathing or lacks a heart beat, use cardiopulmonary resuscitation, but this must only be done by an individual trained in CPR. Shock Shock can be very serious. When in shock, the body is unable to maintain a proper metabolic balance. The condition is characterized by shallow breathing, weak pulse, pale complexion, cold and clammy skin, dilated pupils, nausea, and even

TREATMENT FOR SPECIFIC FIRST AID EMERGENCIES Burns Burns may be first, second, or third degree. In first degree burns such as sunburn,

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CPR IN THREE SIMPLE STEPS


(Please try to attend a CPR Training Course)

1. CALL
Check the victim for unresponsiveness. If there is no response, Call 911 and return to the victim. In most locations the emergency dispatcher can assist you with CPR instructions.

2. BLOW
Tilt the head back and listen for breathing. If not breathing normally, pinch nose and cover the mouth with yours and blow until you see the chest rise. Give 2 breaths. Each breath should take 2 seconds

3. PUMP
If the victim is still not breathing normally, coughing or moving, begin chest compressions. Push down on the chest 1-1/2 to 2 inches 15 times right between the nipples. Pump at a rate of 100/minute, faster than once per second.

CONTINUE WITH 2 BREATHS AND 15 PUMPS UNTIL HELP ARRIVES


NOTE: this ratio is the same for one-person and two-person CPR. In two person CPR Figure 13 the person pumping the chest stops while the other gives mouth-to-mouth breathing.
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vomiting. Persons suffering from shock may be conscious or unconscious. If not brought out of shock, the victim will likely die. Unless he has suffered a head injury, place shock victim on his back with legs elevated, cover with blanket to keep warm. If shock victim has also suffered a head injury, elevate the head and shoulders to prevent too much blood and pressure in the head. Head, Neck & Back Injuries If moved inexpertly, a person with a broken neck or back can become permanently paralyzed. Do not attempt to move the injured without instructions from someone trained in first aid. Fractured Bones Immobilize the broken bone, being careful not to injure the victim more by moving the broken area. Splints and belts can be used to immobilize legs. The body can be used as a splinting aid, for example by tying a broken wrist or forearm to the chest to prevent movement or by strapping a broken leg to the uninjured leg. Eye Injuries First aid for chemical burns of the eye should begin as quickly as possible by thoroughly washing eyelids, eye and face for at least five minutes. If the victim is lying down, turn head to side, hold the eyelids open and pour water from the inner corners of the eye outward. Make sure the chemical does not wash into the other eye. Where chemicals are in use, OSHA requires an eyewash station with the ability to provide 15 minutes of clean water flow to wash eyes and and other body parts. If particles are the only possible eye hazard, an eyewash is still required but it can be a self-contained unit without the 15-minute requirement.

Poisoning Call a doctor or your local poison information center immediately. It may be found in the front of your local telephone book. Unless poisoned by gasoline or similar petroleum products, or by caustic products, force the victim to vomit. Vomiting (as well as ingesting) petroleum products may cause victims to develop a type of pneumonia from inhaling vapors. If you cannot induce vomiting, give victim milk to reduce the poison's absorption by the stomach. Milk of Magnesia, tea and burned toast are no longer considered "universal antidotes." Do not force vomiting in unconscious or groggy persons. They may choke. Wounds & Bleeding Several problems can arise from scrapes, cuts and puncture wounds. Scrapes (abrasions) tend to be more painful than dangerous. Clean with soap and water. Cuts (lacerations) may have sharp, smooth edges caused by a knife or sharp instrument, or a ragged, rough appearance caused by crushing. Clean with soap and water, then join raw edges of the wound together with a band-aid for small cuts. Stitches may be required for more serious cuts. Avoid using strong antiseptics such as iodine. These substances tend to do more harm than good by destroying living cells. Leave that to the emergency room staff. To stop bleeding wounds, directly apply pressure with some sort of clean cloth or bandage. Do not use tourniquets. The only exception to this are severe injuries, such as major amputations where bleeding is profuse. In all first aid attempts where blood loss is a consideration, try in every way your can to keep the blood in the body.

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9. FORMALDEHYDE (1910.1048) Formaldehyde is both a naturally occurring chemical and widely used in industry. In foundries, formaldehyde is present in some binders and can be a byproduct of shell core making operations. OSHA reduced the permissible exposure level (PEL) in 1992 from 1 PPM (part per million) to 0.75 PPM and introduced a training level at 0.1 PPM. As a result of OSHA lowering the PEL, our chemical suppliers greatly reduced and in some cases, eliminated formaldehyde from their binder systems. You should monitor the air for formaldehyde in the molding area and in any shell sand operations. Sampling can be done using a passive badge, a disc which hangs from the workers chest and passively collects molecules of formaldehyde through the course of the day unlike other air tests which required a vacuum pump. If the results show less than 0.1 PPM airborne formaldehyde, you only have to notify your employees of those results. If the air tests show between 0.1 PPM and 0.5 PPM (the action level), you must put those exposed employees through training. That training is to include: 1. The contents of the standard. 2. Health hazards of formaldehyde exposure. 3. Symptoms of exposure and how to report them 4. Safe work practices, including the use of respirators, where necessary. 5. Emergency procedures, including spill cleanup. 6. A description of labels and MSDSs If the air tests show a level between 0.5 PPM and the PEL 0.75 PPM you must label that work area with a sign which says Potential Cancer Hazard, retest the air every six months and make available which means if the employee wants to do it, a questionnaire to your exposed employees to be filled out before they start work in that area

and annually thereafter. The questionnaires will be used by a physician in conjunction with complaints and/or showing symptoms of overexposure to determine if a medical examination is necessary. If air testing results are over the PEL (0.75 PPM), in addition to the above, a respiratory program is necessary, access to the area is limited to trained employees and additional signage is required indicating Authorized Personnel Only. Of a group of 60 samples taken over the last 8 years by the Pennsylvania Foundry Association, 2/3 of the tests we ran were under the training level of 0.1 PPM and approximately 1/3 between the training level and the action level of 0.5 PPM. Only 3 were between the action level and the PEL of 0.75 PPM and none were overexposed to the PEL. 10. GRINDING WHEELS (1910.215) Small grinders, referred to as bench grinders because they sit on a bench, and larger grinders, referred to as stand grinders because they stand on the floor, are both dangerous and should be handled with great care. Each has a tool rest and by OSHA regulations it must be in place and adjusted to no more than 1/8 inch from the wheel at all times. This is to prevent your fingers from being drawn in between the rest and the wheel surface. OSHA permits operation of the wheel without the wheel only if it would not be possible to grind the surface of the metal casting with the rest in place. Bench grinders, and sometimes stand grinders, have a slotted vertical plate mounted at the top of the grinder housing referred to as a shatter or tongue guard which is adjusted always so it is always no more than inch from the wheel surface. Its purpose is to protect the operator from flying pieces of the grinding wheel should the wheel shatter. Rotation of the wheel will throw shattered pieces of the wheel forward and the shatter guard will cause the pieces to be thrown down

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toward the floor and not directly into the operator. More typical stand grinders guard the operator with a moveable top of the grinder casing rather than a vertical plate. Since use of the wheel reduces the diameter both the tool rest and top guard increase in clearance and need to be periodically adjusted back to less than those maximum settings. It is usually the first thing an OSHA inspector will find on his or her tour of your plant. The reason inspectors find those guards out of adjustment is usually because of a management problem. Whose job is it to keep those guards adjusted correctly? The operator, hes foreman of the maintenance department?. We have experienced, in visiting foundries, that the responsibility is unclear. We think that it belongs to the operator. It means, however, that he must have available to him the required tool with which to make that adjustment. Grinding wheels often are fitted with mounted glass shields. Do not confuse that eye protection for a tongue guard. It is not. Stand grinders have adjustable speed. Typically 3600 or 6000 RPM, they are designed to do their most effective metal removal at those speeds. As the wheel is used and its diameter grows smaller the surface speed falls, making for a less effective tool requiring more force against the wheel. Periodically the varidrive requires adjustment to bring the wheel back up to speed. In doing so, the top of the grinder moves back, reestablishing the tight gap with the wheel. There is a limit, of course, to how much the varidrive can be adjusted. If the wheel continues to be used beyond the final varidrive adjustment, the gap between the wheel surface and the top of the grinder will become greater than inch, which could allow pieces of the wheel to fly out and into the operator. Operators have been killed and, in 1999, a foundry grinder operator was so

severely injured in the thigh that his leg was amputated! What can cause a wheel to shatter? A fault in its manufacture, mishandling in storage at the plant creating a crack which is not noticeable or damage to the wheel when being mounted or misuse while in use. Also, forcing a wheel tightly can cause the metal collar to expand when the wheel heats up with outward force great enough to shatter the wheel. Before mounting, all wheels large and small, must be given a ring test, which will detect a crack or an out-of-balance condition from differential water absorption from improper storage. Stand large wheels on edge and tap the side of the wheel gently with a hammer at one to two inches from the outer surface toward the center and at four equidistant spots around the wheel. There will be a distinct dull sound if the wheel is cracked and a dull sounding spot if that spot has absorbed water. In either case, do not use the wheel. With bench grinder stones, use the same procedure while holding the wheel in the air by a wooden stick through the center hole. Wheels must be stored off the floor so they do not pick up water. Wheels can vibrate and then shatter if they pick up water only on one spot around their circumference or on one side. The wheel manufacturers industry recommendation for starting up grinding wheels states that one should wait a full minute after turning on a grinding wheel before putting it into use. Obviously, you are to stand beside the wheel and not in front of it because a wheel is most likely to shatter when it is winding up to its final RPM. The reason they recommend you wait a full minute is because after the wheel reaches full RPM, it may develop vibration which can get progressively greater and result in the wheel exploding.

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TIPS FOR GRINDING WHEEL OPERATION

1. Tool rest always no more than 1/8 inch from wheel surface. 2. Tongue guard always no more than inch from wheel surface an eye shield is not a tongue guard. 3. Wear safety glasses and face shields. 4. Wear strong leather gloves. 5. When starting up stand beside grinder, not in front and let run for a full minute. 6. No grinding on edge of wheel unless wheel is specifically made for that work 7. Turn wheel off if you leave for only a minute.

This means that a foundry may be both a seller of hazardous substances and, hence, the need to comply with a manufacturer's requirements, and also in the position of a user, therefore complying with the educational requirements. Heres why. The first question you have to ask yourself is, "Are the castings I sell a hazardous substance?" The answer to that question derives from the question, "Is it reasonable to assume that under normal conditions of use, my customers' people are exposed to a hazardous substance when they handle my castings?" What is a Hazardous Substance? There is no single definitive list of chemicals in the Hazard Communication Standard. It is up to the chemical supplier to determine if he is selling a hazardous chemical. This standard defines a product as a "hazardous substance" if your customers' employees may be exposed to any concentration of a hazardous substance. This is because it is an employee "Right to Know" Standard - the right to know about the presence of any substance in any amount in their workplace which might have an adverse effect on them physically or upon their health. So, "How can your customers' workers be exposed to a hazardous substance in handling your castings?" If their normal procedure is to weld your castings into a larger weldment, for example, metal fumes will be released from both the casting and the welding rod. In that instance, the worker may be exposed to metal fumes from your casting and metal fumes. Hazardous substances come primarily from OSHA's General Industry Standards section 1910.1000 table Z-3. There are other references including the American Conference of Governmental Industrial Hygienists, the National Toxicological Program, the International Research Agency for Cancer and the Registry for Toxic Effects of Chemicals. In addition, any chemical

CHANGING WHEELS STAND GRINDERS When wheels are changed follow these tips: 1. Use the oldest wheels from stock first. 2. Select the proper wheel for the grinding unit expressed in RPM or FPM (surface speed in feet per minute). 3. Perform ring or vibration test. 4. Use new paper blotters on each side every time you change a wheel (they provide uniform pressure around wheel). 5. Use metal flanges over blotters flanges must cover 1/3 of the wheel diameter. 6. Check torque when tightening nut. 7. Dont force wheel on shaft as shaft warms up and expands it can crack and shatter wheel. 8. Adjust wheel speed to correct RPM with tachometer before first use. 9. Recheck torque of nut.

11. HAZARD COMMUNICATION STANDARD (1910.1200) This standard requires manufacturers of hazardous substances to develop Material Safety Data Sheets (MSDSs) and to label containers of those substances which they believe may, under the wrong conditions, be hazardous to ones health. Employers who use those substances are to train their employees about those hazardous substances.

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found to have an adverse health effect on either humans or animals, and those which pose a physical hazard as defined in the standard are also defined as a hazardous substance. It includes familiar items such as silica dust, lead fumes, and carbon dioxide. In the case of brass castings, if a customer does grinding or cutting work, his employees may be exposed to lead dust in the same way that your employees could be when cutting gates or finish grinding. That means that you may have one customer to which you are selling a "hazardous substance" and other customers to whom you are not selling a hazardous substance, even though they are the very same casting. In the latter instance those castings are referred to as "articles" and are considered finished products. Assume for the moment that you have a customer who you believe welds your castings. You are, therefore, according to OSHA, a supplier of a hazardous substance and you have three obligations to fulfill: 1) supplying an MSDS to that customer once, 2) labeling the castings you ship and 3) notifying him with your first shipment each year if the chemical is on the EPAs SARA Title III Sec. 313 list. Notice that while the Hazard Communication Standard refers to section 1910.1000, entitled Air Contaminants with its list of chemicals showing permissible exposure limits, (PELs), the Hazard Communication Standard only refers to their existence. Whether a chemical requires an MSDS and a label is not related to the PEL for that chemical but simply its presence. Requirements for Manufacturers Material Safety Data Sheet - Since you are melting either scrap or ingot, the suppliers of that scrap and ingot must supply you with an MSDS because your workers may be exposed to molten metal fumes and/or dusts. It also applies to your alloying agent supplier. The MSDS you supply to your customer can be

the MSDS which your supplier gives you by changing his name to your name. If you are adding alloying agents to your metal, that information from their MSDS can be transferred to your own MSDS. You needn't list the exact percentages of ingredients but you can use a range. One MSDS can, therefore, apply to a number of alloys that you produce. You do, however, want to be sure that the MSDS which you receive from your suppliers have complete information. That information must include: 1) the material identification and CAS number, including the manufacturer's name, address and telephone, 2) the hazardous ingredients, 3) physical data about those individual ingredients, 4) fire and explosion data, 5) reactivity data, 6) health hazard data, 7) spill or leak procedures, and 8) special protection and precautions. Several of those sections do not apply to castings, such as numbers 4, 5, and 7 in which case "Not Applicable" (N/A) would suffice. There is no standard form; any format is acceptable. You need to send an MSDS only once to each customer and you may want to do so by certified mail so you have a record. If you change the information in any way from the MSDS you receive from your suppliers, be sure to keep their technical information, but if some of that information is in error OSHA looks to the original generator of that information. If an element is in your metal at less than a 1% concentration, it does not have to be included but if the element is a carcinogen or potential carcinogen, it must be listed unless it is less than 0.1 %. Labeling Your responsibility is to have labels on the products which you ship to a customer to which you have sent an MSDS. The label does not have to take the form of a sticker on every casting or be put on the side of each container, although they are good ideas. The purpose of the label is to warn the people who receive and handle your castings, since they

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may be other than the purchasing agent, general manager, etc. who receives your mailed MSDS. The label can be a piece of paper on which you have written a hazard warning and include it with the packing slip, or even a rubber stamp with the pertinent information which gets stamped on the packing slip. The label itself can take any form as long as it stands out from the other papers and catches the attention of the recipient. Your labels must, however, indicate the hazards and the specific organ or organs which may be affected by overexposure. Requirements for Employers All manufacturing employers must: a) Prepare an inventory of all hazardous substances in your workplace. b) Develop a written Hazard Communication program. c) Assemble MSDSs for each hazardous substance used in your workplace and have them easily available to your employees. d) See that workplace containers are labeled and traceable to an MSDS. e) Train your employees in how to take protective measures and inform them of the contents of the standard. MSDSs should be collected from your suppliers for every hazardous substance you purchase. If a supplier does not send you an MSDS and you believe it is a hazardous substance, document your attempts to get one. If OSHA inspects your plant and you do not have them all, OSHA will send the supplier a letter requiring him to submit one. The definition of "easily available to workers" is interpreted by OSHA to mean within one or two minutes of an individual's worksite. You might, for example, have them stored in each department office. The label on supplies you receive should be keyed to the MSDS, which is the reference for more complete information. Then, when your

employee receives something labeled "hazardous" he can, if he chooses, turn to the MSDS for that product and learn more about the substance than the label reveals. Not every employee needs to know about every MSDS but simply those that apply to his workplace. Since there is already a Medical Access Standard (1910.1020), it means that your MSDSs become part of the reference materials to workplace exposure and need to be kept according to the Medical Access Standard for 30 years after the last date of employment for each worker who was using those substances. The MSDSs contain some technical information which may not be very meaningful to your employees. The Standard is, however, a "Right-To-Know" standard whereby every employee has the right to know all the facts about the materials with which he works that can impact his body. He has the right to take home a copy and give it to a doctor. Workplace Labeling In theory the hazardous substances you buy will come in boxes, bags, bins, bulk or drums with labels attached. Those labels should stay affixed in your workplace to warn of potential exposure. They will take various forms so in reality you may want to unify the labeling system by using your own labels. They can be purchased or made up yourself. Good systems can be purchased from: 1) Label Master (800-621-5808), 2) NFPA (617770-3000), 3) ASTM(215-299-5400), and 4) ANSI (202-354-3300). As soon as possible you should rely upon the labels sent with your suppliers as labels become more uniform through the years. There are color, shape and numbering systems and wallet cards for reference to recommended protective equipment. If you use your own numerical labeling system, however, be sure you indicate the target organ effects on the label. If you are taking from a 55 gallon drum to a bucket, the bucket need not be labeled if it

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stays in control of the same employee who withdrew the chemical. Tanks, silos and material storage areas can have permanent signs attached or hanging nearby. Training and Information Training and informing your employees means informing all of your employees about the standard - its contents, and how it works. You must put your employees through a training program which covers the following areas: 1. identifying hazardous substances in their work areas - this does not necessarily mean all work areas. 2. how they can identify the presence of a hazardous substance in their work area, including symptoms such as odor, eye irritation, dizziness, and how to read labels and connect them with MSDSs. 3. how the hazards can affect them - how they can damage their body through lung disease or other organ damage, etc. 4. protective measures to take - such as goggles, rubber gloves, clothing. 5. location of & how to read MSDSs where they are located & what information they contain 6. the location & contents of your written program - (discussed below). 7. emergency response actions - what to do if a drum of resin or alcohol spills on the floor, for example, or the ventilation system stops. You should document the training given, including the date, material covered, attendance, etc. Employees need to be trained initially, for any new chemicals that come into the workplace and when an employee transferred from another area. While the standard does not require annual training, you should do this annually because of its importance. It is the opportune time to show them the results of your air sampling.

Written Program - The standard calls for a written hazard communication program. The idea is that if you are required to write out the elements of your program, it will help remind you of all the necessary details and to think through your plan of action. Your written program should cover the following six areas. 1. MSDSs - the person responsible for those which you prepare and send and also those you collect and keep on file, where they are kept, actions you've taken if MSDSs are not available from particular suppliers and your system for updating or getting new ones. 2. Labels - who is responsible, the labeling system you are going to use and your system for updating them as new materials are purchased. 3. Training Program who's responsible for it, how it's to be executed, what format you will use, elements of the program, and how follow-up training will be done for new materials or new employees. 4. Preparing a list of hazardous chemicals in your workplace - this is necessary to give to OSHA, your employees or their representatives at their request. 5. Written procedures for actions to take in non-routine situations - that might include entry into a silica sand silo or bucket elevator where the exposure may be extreme extreme and greater protection is needed. 6. On-site contractors - informing their people of your potentially hazardous chemicals and they informing you about those of their materials. 12. HAZARDOUS WASTE OPERATIONS (1910.120) This standard addresses the safe handling, storage and out-loading of hazardous wastes and the training requirements of individuals

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involved with any emergency situations where the hazardous waste may enter the air, water or soil. The standard has features which combine the EPA concern for the protection of the environmental and OSHA concerns for the protection of employees who may work with hazardous wastes and may be involved with a spill containment and cleanup. There are 5 classifications of hazardous waste workers: First Responder Awareness level one who is able to detect a hazardous waste spill or other release requires some generic training in recognizing a problem First Responder Operations level able to contain the release requires 8 hours of formal training. Hazardous materials technician qualified to stop the spill or release requires 24 hours of formal training and further sitespecific training. Hazardous Materials Specialist works with hazardous materials but who has received more chemical specific training and can serve as site liaison with governmental agencies requires 24 hours of formal training plus special training in selection of PPE and other skills. On-Scene Incident Commander one who can assume control of an incident scene requires 24 hours of formal training. All responders require annual retraining. It is not likely that all classifications of responders are necessary in a typical foundry hazardous dust, waste sand or sludge handling operating or spill. Since the standard addresses the day-today worker safety in the normal course of handling hazardous wastes, the individuals handling hazardous wastes in the process of collection, storage and outloading them to a final disposal site need training at one or more of the levels described above for emergency spill cleanup. For example, one which empties a dust collector into 55 gallon barrels and removes them to a staging-storage area

should have awareness or operations level training and his/her supervisor should have a higher level of training to safeguard the site and the community and be capable of dealing with the regulatory agencies, community representatives and the press, if necessary. 13. HEARING CONSERVATION (1910.95) Hearing conservation, conserving the ability to hear, means finding ways to reduce the noise in foundries by reducing the noise level generated and when that is not enough, which is almost universally true in the foundry industry, providing and insisting on the wearing of ear plugs, canal caps or muffs. How we hear is a complicated, fascinating and of extreme importance to foundries. For those reasons, here is a thorough analysis of the subject. The mechanism by which we hear includes in this order: the development of air pressure waves, followed by mechanical movement, then water waves, turned back to mechanical motion and finally the generation of electrical waves. We are talking about noise, which, by definition, is simply unwanted sound. When a casting is brought up to a spinning grinding wheel, vibration is set up, generating air pressure waves. Those waves have both amplitude and frequency. The air pressure waves enter your ear canal and make the ear drum oscillate. The eardrum resembles a musical drum on edge. Attached to the back side of the eardrum are three small bones suspended in air by ligaments, the hammer, attached to the drum, the anvil, attached to the hammer and the stirrup attached to both the anvil and the cochlea by two tiny feet in the shape of stirrups. The cochlea, shaped like a snail, is filled with fluid and lined with tiny hairs called cilia. When the stirrup oscillates the cochlea, it sets up water waves which in turn causes the cilia to move back and forth like sea grass. At the base of the cilia are neurons

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which send tiny electrical signals to the brain which say We hear noise or sound, as the case may be. The starting point for the protection of our hearing is that there is a limit to the amount of back and forth motion and the violence of that motion that the cilia can withstand. Too much over too long a time will cause them to die and fall out. Our ears were designed millions of years ago when we all lived out in the woods probably by a stream to get fish and water. All our ears likely heard were an occasional lightening storm, birds chirping, squirrels quarreling and the babbling sound of running water. Today, we are bombarded with noise of all kinds (frequencies) and in high volumes (amplitude). The result is that we are all losing our hearing a little bit each year. Everyone, not just foundry workers. But if you work in a foundry whereby the very nature of the work we do creates excessive noise, unless we wear ear protection where mandated, we will lose our hearing at a rate faster than the average person. Fortunately, ear protection works well and is easy to wear but it must be worn properly. The noise attenuation ability of an earplug is rated by OSHA to be of its laboratory tested (and advertized) attenuation ability since we know that earplugs are not usually placed in the ear in the ideal manner, fully in the ear canal. Earmuffs are rated at 90% and canal caps at 70% of their lab tested rating. It is important to remember that once we loose some of those hairs in our cochlea, they can never be re-grown, so you cannot take someone who has lost some hearing ability into a quiet environment and have them regain their hearing. You may have heard an older worker say that earplugs wont do him any good because he is deaf anyway. Just the opposite is true. That individual, all the more so, needs to save the hair he does have remaining so that he doesnt go completely deaf!

In reading the following summary of the Hearing Conservation Standard you will see that the standard makes hearing protection mandatory at 90dB or above, averaged over an 8-hour work shift, but optional at average noise levels between 85dB and 89dB. Some experts in the field state that as much as 25% of workers may lose their hearing at 90dB and 80% of workers may lose some hearing at an average level of 85dB! Employers should, therefore, make it absolutely mandatory that hearing protection be worn at an average level of 85dB, not beginning at 90dB. Not only will it better protect the hearing of your employees but it may also protect against a hearing loss claim which in some states is awarded for only the partial loss of hearing and may provide benefits for a lifetime. The OSHA Hearing Conservation Standard requires each employer to: 1. analyze all work areas for noise levels 2. give annual hearing tests to those exposed to 85dB or more 3. provide annual training in hearing 4. provide hearing protection 5. keep records of noise exposure for 2 years and audiometric tests for the duration of employment The following summary briefly discusses the required components of the hearing conservation program. Noise Monitoring The Hearing Conservation Standard requires employers to monitor noise exposure levels in a manner that will accurately identify employees who are exposed to noise at or above 85 decibels (dB) averaged over eight working hours, called an 8-hour timeweighted average (TWA). The exposure measurement must include all noise within an 80 dB to 130 dB range and must be taken during a typical work situation. This requirement is performance oriented since it allows employers to choose the monitoring

65

method that best suits each individual situation. Employees are entitled to observe monitoring procedures and they must be notified of the results of the exposure monitoring of their workplace. The method used to notify employees is left to the discretion of the employers. Instruments used for monitoring employee exposures must be carefully checked or calibrated to ensure that the measurements are accurate. Calibration procedures are unique to specific instruments. They should follow the manufacturer's instructions to determine when and how extensively to calibrate. Noise Abatement OSHA requires employers to first attempt to reduce the noise generated before turning to ear protection. Wood or plastic for example, can sometimes replace metal surfaces. Lining metal surfaces with wood or plastic can absorb some of the noise generated. Isolating a noisy machine in its own room is ideal and creating soundbarriers lined with dampening material such as styrofoam, fiberglass or rubber will absorb and dampen sound which would otherwise reverberate and increase sound levels. The chart entitled Adding Noise Levels shows the additve effect of two noise sources near each other. Two machines side-by-side will create a noise level greater than either operating alone as one might suspect. The closer they are in sound generating level, the greater will be the additive effect of both of them operating together. A frequency band analyser, though expensive, can help identify the sources of additive noise by identifying the frequency finger print of individual machines. By moving machines away from each other, the noise level in an area can be reduced.

Adding Noise Levels


Add to Higher Level (dBA) 3

0
2 4 6 8 12 10 14

Difference in Noise Levels Between Two Sources (dBA)

Figure 14 Audiometric Testing Audiometric testing not only monitors the sharpness or acuity of an employee's hearing over time, but also provides an opportunity for employers to educate employees about their hearing and the need to protect that delicate mechanism. The important elements of an audiometric testing program include baseline audiograms, annual audiograms, training, and follow-up procedures where problems exist. Audiometric testing must be made available to all employees who have average exposure levels over an 8-hour period of 85 dB or more. The audiometric testing program each year should indicate whether hearing loss is being prevented by the employer's hearing conservation program. A professional audiologist (specialist dealing with individuals having impaired hearing), an otolaryngologist (physician specializing in the diagnosis and treatment of disorders of the ear, nose, and throat), or a physician must be responsible for the program. Both professionals and trained technicians may conduct audiometric testing. The professional does not have to be present when a qualified technician is conducting testing, however. The professional responsibilities include overseeing the program and the work of the technicians, reviewing problem audiograms,
66

and determining whether referral for medical diagnosis is necessary. There are two types of audiograms required in the hearing conservation program: baseline and annual audiograms. Baseline Audiograms The baseline audiogram is the reference audiogram against which future audiograms are compared. Baseline audiograms must be provided within 6 months of an employee's first exposure at or above an 8-hour time weighted average, TWA, of 85 dB. Where employers are using mobile test vans to obtain audiograms, baseline audiograms must be completed within one year after an employee's first exposure to workplace noise at or above a TWA of 85 dB. Where mobile vans are used and employers are allowed to delay baseline testing for up to a year, after 6 months their employees exposed at or above 85 dB must be issued and fitted with hearing protectors to be worn until the baseline audiogram is obtained. You, of course, would not wait one day. b. Annual Audiograms The annual audiograms must be conducted within one year of the baseline. It is important to test hearing on an annual basis in order to identify changes in hearing ability so that protective follow-up measures can be initiated before hearing loss progresses. That might include tighter enforcement of use of ear protectors or a switch to ear muffs. Annual audiograms must be routinely compared to baseline audiograms to determine whether the audiogram is accurate and to determine whether the employee has lost hearing ability (that is, if a standard threshold shift (STS) has occurred). STS is defined as an average shift in either ear of 10 dB or more at 2000, 3000, and 4000 Hz (hertz or cycles per second).

Audiogram Evaluation If an STS is identified, employees must be fitted or refitted with adequate hearing protectors, shown how to use them, and required to wear them. Employees must be notified within 21 days from the time the determination is made that their audiometric test results showed an STS. Some employees with an STS may need to be referred to further testing if the professional determines that their test results are questionable or if they have an ear problem of a medical nature which is thought to be caused or aggravated by wearing hearing protectors. If the suspected medical problem is not thought to be related to wearing protectors, employees must be informed that they should see a physician. If subsequent audiometric tests show that the STS identified on a previous audiogram is not persistent, employees whose exposure to noise is less than a TWA of 90 dB may discontinue the wearing of hearing protectors, although we definitely do not recommend this unless the average exposure is less than 85 dB. A subsequent audiogram may be substituted for the original baseline audiogram if the professional supervising the program determines that the employee's STS is persistent. This substitution will ensure that the same shift is not repeatedly identified. The professional may also decide to revise the baseline audiogram if an improvement in hearing has occurred. This will ensure that the baseline reflects actual hearing thresholds to the extent possible. It is common to have employees showing hearing loss that results from colds, and certain medications. All indicated hearing loss should be retested one week to one month later. Audiologists distinguish occupationally induced hearing loss from other types of loss by reading an audiogram. Occupationally induced loss will show the greatest loss at 4000 hertz and extend to either side toward 3000 and 5000 hertz, even though the

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frequencies entering the ear cover a much broader range of cycles per second, typically 500 to 16,000 hertz. It is the constant intensity of the water waves hitting the cilia in that area (4000 hertz) which damages them and gives the characteristic chart even though the loudest foundry frequencies are in the 1500 to 2500 hertz range. Hearing Protectors Hearing protectors must be available to all workers exposed to 8-hour time-weighted average noise levels of 85 dB or above. This requirement will ensure that employees have access to protectors before they experience a loss in hearing. You must offer two or morre types of hearing protectors because not everyone is comfortable with the same protector. Hearing protectors must be worn by: 1) employees for any period exceeding 7 months from the time they are first exposed to 8-hour average noise levels of 85 dB or above until they receive their baseline audiograms in situations where baseline audiograms are delayed because it is inconvenient for mobile test vans to visit the workplace more than once a year; 2) employees who have incurred standard threshold shifts, since these workers have demonstrated that they are susceptible to hearing loss; and 3) employees exposed over the permissible exposure level, an 8-hour timeweighted average of 90 dB or above. Employees should decide, with the help of a person who is trained in fitting hearing protectors, which size and type protector is most suitable for their working environment. The protector selected should be comfortable to wear and offer sufficient attenuation to prevent hearing loss. Hearing protectors must adequately reduce the severity of the noise level for each employee's work environment. The employer must reevaluate the suitability of the employee's present protector whenever there is a change in working conditions that may cause the hearing protector being used to be

inadequate. If workplace noise levels increase, employees must be given more effective protectors. The protector must reduce employee exposures to at least 90 dB and to 85 dB when a standard threshold shift has already occurred in the worker's hearing. We, however, advise protection at least down to 85dB. Employees must be shown how to use and care for their protectors and must be supervised on the job to ensure that they continue to wear them correctly. Training Employee training is very important. When workers understand the reasons for the hearing conservation program's requirements and the need to protect their hearing, they will be better motivated to participate actively in the program and to cooperate by wearing their protectors and taking audiometric tests. Employees exposed to TWA's of 85 dB and above must be trained at least annually in the effects of noise, the purpose, advantages and disadvantages of various types of hearing protectors; the selection, fitting and care of protectors; and the purpose and procedures of audiometric testing. The training program may be structured in any format, different parts being conducted by different individuals and at different times as long as the required topics are covered. Recordkeeping Noise exposure measurement records must be kept for 2 years. Records of audiometric test results must be maintained for the duration of employment of the affected employee. Audiometric test records must include the name and job classification of the employee, the date, the examiner's name, the date of acoustic or exhaustive calibration, measurements of the background sound pressure levels in audiometric test rooms, and the employees most recent noise exposure measurement.

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EXAMPLES OF FOUNDRY NOISE CONTROL Before-after db(A) reduction which in some circumstances has been achieved 107 to 85 102 to 84 90 to 85 110 to 92

Noise Source Exhaust from Molding Machine Squeeze Cylinder Portable Air Grinders Pencil Air Grinder Impact Noise from Falling Parts

Controls Remote Exhaust by piping Switch to Electric Hose Muffler

Dampening Material Wooden and Rubber Linings Reduce Falling Distances Cover Bench Surface with Wood and Blocks and Rubber and Plywood Covering Line with Rubber Belting Switch to Rubber Heavy Rubber Liners Enclosure Switch to Scarfing (Use Torch to Clean Casting) Partial Enclosure Rubber Bumpers Partial Enclosure 6600 cfm Isolation by Walling and Enclosure

Castings on Metal Work Benches Loading Castings into Barrels or Tool Boxes Noisy Steel Wheel Carts Tumblers Chipping Shakeout Noise Radial Saw Cupola Blower with 150 h.p. Motor

95 to 83 -

100 to 80 110 to 88 110 to 90 102 to 94 115 to 108 92 to 84 102 to 83 (at distance at 14 ft.)

Figure 15

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Following is employee information which meets the Hearing Conservation Standard requirements for employee notification.

HEARING CONSERVATION FACTS FOR EMPLOYEES


A bulletin prepared by the Pennsylvania Foundry Association (This or similar information is required to be given to each employee exposed to 85dB TWA or above.) 1. Effects of Noise on Your Hearing Being exposed to too much noise can temporarily affect your hearing, and exposure to too much noise over an extended period of time can result in permane nt hearing loss and even complete deafness. Studies show that there is only an 8 % risk of us having any permanent hearing loss if we protect our ears from an average noise level (volume) of 85 decibels (dB) or greater each day while on the job and at home. 2. Noise Measurement Noise is easily measured with a hand-held sound level meter or by wearing a dosimeter which averages noise levels throughout the day. 3. Hearing Protection Fortunately, our ears are easily protected to 85dB or below with either earplugs or ear muffs or canal caps (ear plugs which just seal off the canal), but they must be worn all the time if you are in a noisy area. Our plant has areas which are considered noisy and where ear protectors must be worn without fail. As an example, an average noise level while you are chipping may be 115dB, grinding 105dB and shakeout and squeeze-jolt molding 100dB. Other activities are quieter. Normal quiet conversation is 65dB. Good plugs or muffs will reduce the noise level entering your ear by about 15dB. Read the fitting instructions on the ear protector package or your supervisor will show you how to wear and maintain them. They will not work if they are not correctly worn in your ear canal. 4. Audiometric Tests Hearing tests, called audiometric tests, measure the volume level at which you can first detect a sound. To take the test you wear earphones in a quiet room and signal the operator when you first hear the sound through the earphones. The test is repeated to see if you can hear high notes as well as low notes. You will be given an audiometric test each year to see if your hearing ability has changed from last year. This way we can tell if there is a problem with your hearing beyond the normal loss of hearing we all experience as we grow older. BE SURE YOU ALWAYS WEAR HEARING PROTECTORS IF YOUR JOB REQUIRES THEM! Figure 16

70

PERMISSIBLE NOISE EXPOSURES


INDICATORS OF LEVEL (EFFORT REQUIRED BETWEEN SPEAKING PERSONS AT VARIOUS DISTANCES)

NOISE SOURCES

SOUND LEVEL dBA

MAXIMUM SINGLE EXPOSURE PER DAY* dBA


!"

AIR BLOW-OFF PNEUMATIC CHIPPER (AT 5 FT.) CASTING SHAKEOUT AREA CAR STEREO W. LARGE WOOFERS GRINDING CASTINGS PNEUMATIC AIR HOIST ELECTRIC FURNACE

115

15 MIN.

NEARLY IMPOSSIBLE TO COMMUNICATE BY VOICE VERY DIFFICULT TO COMMUNICATE BY VOICE SHOUT W. HANDS CUPPED BETWEEN MOUTH AND OTHER PERSONS EAR

110

!"

30 MIN.

105 102

!" !" !" !" !" !" !"

1 HOUR 1.5 HOURS 2 HOURS 3 HOURS 4 HOURS 6 HOURS 8 HOURS

SQUEEZE JOLT MACHINE

100 97

SHOUT AT FOOT

POWER LAWN MOWER

95 92

SHOUT AT 1 FOOT

VANEAXIAL FAN (1500 CFM) BOILER ROOM MANCOOLER FANS DIESEL TRUCK (40MPH AT 50 FT.) MILLING MACHINE (AT 4 FT.)

90

85

!"

16 HOURS

80

!"

INDEFINITE

VACUUM CLEANER (AT FT.)

75

!! !" ""

INDEFINITE

NORMAL VOICE AT 1/2 FOOT RAISED VOICE AT 1 FOOT SHOUT AT 2 FEET NORMAL VOICE AT 1 FOOT RAISED VOICE AT 2 FEET SHOUT AT 4 FEET NORMAL VOICE AT 1.5 FEET RAISED VOICE AT 3 FEET SHOUT AT 6 FEET TELEPHONE USE IMPOSSIBLE NORMAL VOICE AT 2 FEET RAISED VOICE AT 4 FEET SHOUT AT 8 FEET

*EXPOSURE FOR REMAINDER OF DAY MUST BE LESS THAN 90 dBA

Figure 17

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14. LEAD STANDARD (1910.1025) Lead fumes and dust are found in brass and bronze foundries melting leaded alloys and also to a much lesser degree in some iron foundries. Overexposure has been found in some iron foundries as a result of lead-bearing scrap, oily scrap, lead bearing painted scrap, tramp brass or lead wheel balancing weights. The Lead Standard requires that you monitor your workplace to determine the concentrations of airborne lead dust. It also calls for the use of respirators, personal hygiene requirements such as showers, clothing changes, not eating, drinking, smoking or wearing cosmetics in the workplace, and housekeeping. Also, engineering and/or administrative controls, employee education, and biological monitoring and medical removal if airborne concentrations are above a certain level. The Lead Standard is complicated but following your reading of the flow diagrams, one for air sampling and one for medical monitoring, the requirements should make sense. You will refer to them frequently. Airborne Lead Exposure There are two important levels to remember when dealing with airborne exposure to lead. The. first is the permissible exposure level (PEL) of 50 micrograms per cubic meter of air - ug/m3, and the second is the action level (AL) of 30ug/m3. If the airborne lead level in your plant as a result of air sampling is: At or Above The Action Level (AL) (30ug/m3) These are the requirements: 1. Take representative air samples of exposure for each employee 2. Do this air monitoring at least every 6 months 3. If exposure to lead is above the AL for more than 30 days a year, provide a medical surveillance program

which includes a medical exam and blood lead level testing 4. Provide a training program At or Above The Permissible Exposure Level (50ug/m3) These are the requirements: 1. Sample the air every 3 months 2. Provide high efficiency type respirators (100N) 3. Provide clean work clothes weekly, if airborne level is +200ug/m3, clothes cleaned daily. 4. Prohibit eating, smoking, drinking, or applying cosmetics in areas where concentrations are 50ug/m3 or more 5. Employees to wash hands & face prior to eating, drinking or smoking 6. Provide separate change rooms (one for dirty clothes, one for clean) 7. Provide lunchrooms under positive air pressure 8. Provide shower facilities Blood Testing 1. Blood testing for blood lead and zinc protoporphyrin (ZPP) must be given every 6 months if you are exposed above the action level for more than 30 days per year. 2. If the level is at or greater than 40ug lead/100g blood: a) Test every 2 months b) Notify employees in writing of results of test c) Notify employees that the standard has a medical removal section d) Medical exam yearly 3. Medical removal protection - based on blood lead level - when average level of the last 3 tests (or all tests in the last 6 months, whichever is longer) exceeds 50ug/100g. Remove employees from lead-bearing environment. 5. Return to job after medical removal when 2 tests are at 40ug lead/100g blood or below.

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Zinc Protoporphyrin (ZPP) & Blood Lead Testing 1. ZPP testing is required in addition to blood lead. See 1910.1025(j)(2) & (3). 2. ZPP testing is an indicator of the total loading on your body. Lead will bioaccumulate in our bones if we take in too much and ZPP testing reflects reflects bone accumulation. 3. ZPP tests indicate lead that is stored in red blood cells (Heme substitute), which live for about 120 days. 4. A normal ZPP level is less than 100 ug/100g while blood. 5. Expect to see a sharp rise in ZPP when blood lead exceeds 40 ug/100g whole blood. 6. The blood lead level may drop off drastically in a short period but ZPP levels change slowly.

LEAD AND YOUR HEALTH


A bulletin prepared for you and your supervisor by the Pennsylvania Foundry Association

Lead is found in brass and bronze foundries. To a lesser degree, lead is sometimes found in the air around melting operations in iron and steel foundries. It can become airborne as a fume from the melting process and as a dust from cutting and grinding operations. Like most materials, lead can be a poison if you get too much in your body. There are safe levels of exposure, but beyond that point it can endanger your health. Lead can get into your body through your nose and mouth, reach your lungs and stomach and eventually get into your blood stream. Your body gets rid of lead through the feces and urine. That's normal and happens to everybody all the time because lead is also sometimes found in the food and drink we consume each day and lead-bearing paint dust at home. We all have some lead in our bodies. But too much lead can cause illness. Ventilation cannot always get all the lead out of the air. That's why it is so important that you cooperate with the specific safety regulations of your plant, including biological testing when necessary. Here are precautions that everyone should take who works in a brass or bronze foundry, and, if required, in iron foundries. 1. Always wear your respirator when required by company regulations. 2. Never eat, drink, smoke or apply cosmetics in the plant area. Always use the lunchroom or other assigned areas. 3. Always wash your hands before eating or smoking. 4. Keep your work clothes and your work area clean. A vacuum is best. Dont blow yourself off with an air hose. 5. leave your work clothes and shoes at the plant. Don't wear them home. Handle and wash them separately.

OBEY YOUR PLANT SAFETY RULES It is your health we all want to protect! IF YOU WANT FURTHER FACTS, ASK YOUR SUPERVISOR

Figures 18 and 19

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Start: Yes End.* Any lead in the workplace? (d)(2) No

OSHA LE AD ST AN D AR D SU MMAR Y 2 9 C F R 19 1 0 .1 0 2 5

Conduct full-shift air monitoring for a representative number of jobs. (d)(1)(2)(3) Is lead exposure from 30 g/m3 to <50 g/m3? the Action Level No Yes Lead exposure is above 50 g/m3, the PEL. **

See 1910.1025 for details (d)(5) refers to section of 1910.1025

No

Is lead exposure <30 g/m3? Notify employees of their results in writing within 5 days. (d)(8) Notify employees of their results in writing within 5 days and the corrective action being taken to reduce their exposures. (d)(8)(ii)

*Whenever there has been a production, process or control change which may result in new or additional lead exposure, additional monitoring shall be done. (d)(7)

Yes

74 Provide training program on hazards of lead. (l)(1)(ii). (End here if exposure is for less than 30 days per year)* Is exposure greater than the PEL (**) for more than 30 days per year? Yes Provide medical surveillance program for all employees exposed above 30 g/m3. (j)(1)(i). Make available blood lead and ZPP sampling at least every 6 months. (j)(2)(i)(A) See Medical Surveillance flow chart. Use engineering and work practice controls to reduce exposures below PEL. if controls are insufficient, supplement w. respiratory protection (as per section f) to reduce exposures to at least 50 g/m3. (e)(l)(i) Repeat air monitoring quarterly. (d)(6)(iii) 74 Figure 20 Repeat air monitoring semiannually. (d)(6)(ii)

Notify employees of their results in writing within 5 days. (d)(8). Document as per (d)(5), (3). Inform employees of Appendices A & B. (l)(1)(i)

Exposure is for less than 30 days per year. Implement engineering controls to reduce exposures to at most 200 g/m3. Thereafter use any combination of engineering, work practice & respiratory programs to maintain exposure below 50 ug/m3. (e)(l)(ii)

**the PEL for lead is 50 g/m3 except for nonferrous foundries with less than 20 employees, the PEL is 75 ug/m3. (c)(1), Table 1 No Provide these programs: If employee is exposed for more than 8 hrs/day, the PEL is calculated by: 400/hrs worked in the day. (c)(2) 50 g/m3=0.050 mg/m3 g/m3 micrograms per cubic meter of air mg - milligrams Action Level =30 g/m3 Document all activities regarding your lead program! 1997 Pa. Foundry Assoc. Compliance methods (e) Respiratory protection (f) Work clothing & equip. (g) Housekeeping (h) Hygiene facilities (i) Medical surveillance (j) Med. Removal Protection (k) Employee info/training (l) Signs (m) Recordkeeping (n) Employee observation of monitoring (o) Exposure monitoring (d)

End. (d)(6)(i)*

If 2 consecutive results taken at least 7 days apart are below 30 g/m3, monitoring may be discontinued. (d)(6)(ii)*

OSHA LE AD ST AN DAR D ME DICAL S U R VE ILANCE SUMMAR Y 2 9 C F R 19 1 0 .1 0 2 5


Start: No Is airborne lead exposure greater than 30 g/m3 for more than 30 days per year? Institute a medical surveillance program. (j)(l)(i), (ii) & (iii). Yes See 1910.1025 for details. (d)(5) refers to section of 1910.1025

Notify employees of their results in writing within 5 days. (d)(8). Document as per (d)(5), (3). Inform employees of Appendices A & B. (l)(1)(i) Make available blood lead and ZPP tests at least every 6 months. (j)(2)(1)(A)

Blood lead result is <40g/100g whole blood. No Blood lead result is between 40 & 60g /100g whole blood. No Temporary medical removal from job is required. See medical removal protection benefits. (k)(2) Blood lead result is 60 g/100g or greater, or, last 3 results (or avg. of all tests of last 6 months whichever is longer) show blood lead is equal to or >50g/100g. (k)(1)(I)(B) Yes Yes

*Whenever there has been a production, process or control change that may result in new or additional lead exposure, additional monitoring shall be done. (d)(7)

End. (d)(6)(i)*

75 Test again within 2 weeks, (j)(2)(C)(ii), & then monthly, (j)(2)(i)((C). Make available medical exams at least annually. (j)(3)(i)(A) Return employee to work when 2 consecutive results are at or below 40g/100g. (k)(1)(iii)(A)(3). Go back to Start above. Figure 21

**See (j)(2)&(3) for details of medical surveillance requirements. See (j)(3)(B) for other situations that call for medical exams and consultations. ZPP: Zinc Protoporphyrin. Normal level is <100 g/100g whole blood. ZPP is an indicator of lead stored in red blood cells. Blood lead may drop quickly but ZPP level changes slowly. Expect to see a sharp rise in ZPP when blood lead is >40g/100g whole blood.

Make available blood lead and ZPP tests every 2 months. (j)(3)(i)(B). make available medical exams & consultations at least annually. (j)(3)(i)(A) No Are 2 consecutive blood lead test results less than 40g/100g? Yes

All medical exams shall be done by or under the supervision of a licensed physician. (j)(1)(ii). Employees may have multiple physician review as per (j)(3)(iii). 1997 Pa. Foundry Assoc.

15. LOCKOUT/TAGOUT (1910.147) The expression to lockout equipment literally means putting a lock on something. It is generally assumed to be the electrical switch, using your own lock so that someone else cannot come along and start the equipment while it is undergoing a maintenance check or repair. But equipment also has other energy sources such as compressed air, hydraulic pressure, springs, gravity or even chemical reactions which can release energy and cause an accident. So, the definition of lockout really means a zero mechanical state. It means that before repairs or maintenance servicing is done, all sources of energy are brought to a zero state. OSHA adopted the zero state concept developed and copyrighted by the foundry industry prior to the standard being issued. Injuries are sustained when equipment is not brought to a zero mechanical state and it cannot be stressed enough how important it is to have strictly enforced lockout procedures in your foundry. The most common source of injuries from lockout failure in foundries involve muller/mixers and conveyor systems. There has been confusion as to under what conditions one can by-pass the lockout procedure because of the note under 1910.147 (a)(2)(ii)(B) which allows an alternate to a standard lockout procedure if the minor adjustment or lubrication are routine and repetative. It does not mean that you can reach in for just a second to make an adjustment or oil a moving part. You still cannot by-pass a guard or safety switch or bring any part of your body into a danger zone. An alternate procedure, without without shutting down the machine, might be to make an oiling device which is operated remotely, keeping yourself out of the danger zone. The point is that you must invent an approach which will do the job without risking the operators safety, if only for a second.

There may be a situation where it is literally impossible to physically apply a lock, though in our industry it is most unlikely. In that case, a tag is appropriate but OSHA expects you to retrofit switches to accommodate a lock and there are a variety of devices available to enable you to lock out soft wiring plugs, swinging valves, water valves, etc. if only a tag is used, a fuse must be pulled, a switch blocked or some means must be used to prevent energizing the system. Also available on the market is a set of locks, each a different color, stored on a metal wall unit. We have seen a number of foundry settings where this unit is hung on the wall for anyone to use, with keys hanging out of the locks. OSHA, naturally, will disagree with this because it destroys one of the basic concepts of the standard that of one manone lock, with no one else having the opportunity to have access to the key, so the individual who climbs into machinery has absolute confidence that no other person has had the opportunity to have access to the key and to have made a copy of it for whatever reason. It has happened numerous times. Therefore, a set of such locks and their keys should not be out in the open. The maintenance department might use the wall unit to store locks, but the keys cannot be there in open view. Each individual keeps the key to his lock on his body or hidden somewhere. We have seen the lock and key to the muller mixer hanging in the open by the mixer. Ouch! The standard says that if an individual has a unit apart and sources of energy locked out, goes home and does not return the next day, those who want to continue the repair must attempt to contact him before they turn to the reserve key or cut the lock so as to give him the opportunity to explain, for example, that he temporarily has a heavy air cylinder hanging underneath by a piece of wire or that he has electrical wiring incorrectly tied

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together just to get the wiring out of the way, so to watch out for things which may not be obvious but are potentially hazardous conditions. The standard also says that someone must think through and write down the steps in sequence that you go through in order to bring all sources of energy down to a zero state. Then the steps which are required in sequence to re-energize the unit are thought out and written out. It is a strong recommendation that those typed steps be placed in a protective clear sleeve and stationed by each unit requiring lockout. Even the most experienced of us forget, get distracted or rush. Turning off the air line is not enough. The stored air pressure must also be bled off. Lockout Procedure for Electrically Operated Equipment Each individual who may work on the equipment has his own lock with its own key. No one else has that same key. A duplicate key is stored in a remote location such as the maintenance office or safe, not available to other employees. Another approach is to destroy the second key. Then when the electrical energy to the equipment is turned off by the operator or the maintenance man, that switch is mechanically locked out with that man's lock. He can safely work on the equipment knowing that only he can unlock the electrical switch. The office key would only be used in an emergency such as if the lock owner was out on the day the equipment repair was to be finished or it is perfectly clear that the key is lost. If two or more operators or maintenance people work on the equipment, a lockout hasp is used. It has provisions for several locks to be attached. Each person adds his own lock to this hasp. This way he is assured that the equipment cannot be started until he has removed his key. Only thoroughly trained qualified by OSHA definition, individuals may work on

electrically operated equipment. Unqualified persons must still, however, be trained in the dangers of electrical safety. The lockout procedure must be made available to your employees. As mentioned earlier, having those steps available near each machine is a good idea. NEV ER EVER SHARE LOC KS! 16. MACHINE GUARDING (1910.211.222) We find many guards on the floor and not in place. In some cases, guards which have come with new equipment are attached with so many nuts and lock washers that by the time the maintenance man has removed them and fixed the machine, he has lost some of them in the floor sand or they have been kicked or dropped to a level below. By that time he wants to get onto the next project and replaces those he can easily find or perhaps leaves the guard on the floor, especially if the unit is in some out of the way area. Eventually, after a number of repairs, the guard is hanging on by one or two nuts, which in time loosen up, and the guard flops and makes irritating noise. Ultimately, an operator may just rip the thing off. Do not assume that even a brand new machine is adequately guarded to yours and OSHAs standard. Look for points of operation such as ingoing nip points, rotating parts and flying chips and sparks. Do not forget rollers on conveyors. It sometimes takes imagination to retrofit an older unit which was never fitted with guards. Whenever and wherever you can, try to find ways to hang a guard over revolving parts (this means anything less than 7 feet above the floor or accessible by a stairway or ladder). This way the maintenance man will be more inclined to replace the guard. Sometimes alternate guarding can be created with a plywood barrier on feet which can be easily moved. This, however, takes second

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preference to a guard permanently affixed to the machine. There are OSHA prescribed guard hole sizes, created for visibility, related to how far the revolving shape, or whatever the moving item maybe, is to the guard itself. The following chart is provided by Rockford Systems, Rockford, Illinois (1-800-922-7533) who also sells a folding aluminum Guard Opening Scale useful for establishing the maximum allowable hole size in the guard.
POINT OF OPERATION GUARD OPENING REQUIREMENTS

Openings in the guard or between the guard and moving surface shall not be greater than the following:
DISTANCE OF OPENING FROM POINT OF OPERATION HAZARD MAXIMUM WIDTH OF OPENING

to 1 inches 1 to 2 2 to 3 3 to 5 5 to 6 6 to 7 7 to 12 12 to 15 15 to 17 17 to 31 Over 31 Figure 22

inch 1 1 1 2 6

17. MEDICAL ACCESS (1910.1020) This standard, actually called Access to Employee Exposure and Medical Records gives your employees, their union representatives and OSHA representatives the right to see and make copies of all occupational environmental testing and biological testing that you have done. It includes the results of any air sampling that you have done on your own or that OSHA may have done as a result of their inspections. It includes the results of any biological monitoring such as hearing tests or

blood or urine tests performed for compliance under a standard such as the Lead or Cadmium Standard; not just the actual test results themselves but any reports with analyses and recommendations as well. Also, employees have the right not only to see but to copy and take home any MSDSs (Material Safety Data Sheets). The basic theme here is that employees have the right to know just as much as you do about their work environment and what they are exposed to and to what degree. Good employers should welcome such inquiries because keeping employees informed serves to keep false notions from developing and creating suspicion that you are covering up something. Our experience has been that keeping employees informed and explaining to them why they have to wear a respirator and that you are working on a problem or that there is nothing more you can do about it short of building a new foundry helps with the enforcement of wearing personal protective equipment and reduces the chances of poor morale. The best opportunity to explain testing results and how you actually perform air sampling is when you do Hazard Communication training. It goes a long way in helping your employees understand plant conditions and why they are what they are. It helps both the quiet worker who may be afraid to ask questions and the noisy worker who may be looking for ways to be critical. While not mandated by the standard, Hazard Communication should be included in your annual employee training and should include the results of all recent air sampling. 18. OVERHEAD CRANES (1910.179) Only designated personnel should operate overhead cranes and they should be thoroughly instructed in their operation. Operators should have vision of at least 20/30 in one eye and 20/50 in the other with or without corrective lenses. They should, of course, also have normal depth perception and

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color distinction. Their hearing should be adequate for audible instructions and they should not have a history of seizures, dizziness, or emotional instability which could create a hazard. OSHA does not require crane operators to be certified according to any specific set of requirements. The crane operator who operates the crane from the cab should be given an annual examination to check the condition of his heart to reduce the likelihood of a heart attack. There have been accidents where the operator suffered a heart attack, fell over the controls and caused the hoist to move in an unpredictable manner! OSHA does require, however, that cranes be inspected for certain items on a daily, weeklyto monthly, and from one-to-12 month intervals depending upon the activity and severity of service. One individual is to be designated to perform these inspections and be made familiar with the many details of safe crane operation and mechanical conditions. Those inspection items are listed below, along with illustrations of the standard crane signals universally used. Also, a monthly inspection with signed report made out for items C.4 through 9. ot the Inspection Checklist.

Pendant Cranes Pendant cranes are any cranes operated by an operator on the floor moving the crane using controls hanging down from the motors above. It may also be a control box held by the floor operator which sends radio signals to the controls above. The added concern is that the operator must walk along as he is moving the object and does not have the advantage of seeing everything from above. Many large and potentially dangerous overhead cranes have been retrofitted to be operated from the floor as a personnel cost savings and this new arrangement requires great care initially.

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Pendant Crane Safety Rules 1. Be sure all control buttons are readable (We often find them unreadable) 2. Be sure that the control buttons function properly 3. Control boxes should not be turned upside down before operating since the equipment could be moved in the wrong direction. 4. Do not allow pendant control boxes to swing free for any distance because of the possibility of striking an employee or a stationary object and being damaged. 5. Aisleways should be kept clear so the operator can move freely back and forth with the overhead load. 6. If necessary to walk around equipment or material, stop the crane, walk around the equipment and then continue with the operation. 7. The safe load limit of each crane must be visible and observed. 8. Centering the crane hook over the load is required on all lifts for balance. 9. Be sure to keep a firm grip on controls.

SAFE CRANE OPERATION Avoid moving crane loads over people whenever possible Do not allow anyone to ride the hook or the load Sound a warning when traveling with a load Always land the load before leaving the crane cab Always insist on the use of standard crane signals and they should be taken only from the person directly responsible for the move 6. Do not make the lift or move, regardless of signals, if someone is in a position to be injured or the load is unsafe 7. Avoid dragging slings and chains along the floor 8. Take the twist out of blocks before hoisting to prevent the fouling of cables 9. When handling hot metal or unusually heavy loads, brakes should first be tested 10. Do not use the upper limit switch for normal stopping of the hook block 11. If power goes off, immediately throw all controllers to "off' position 12. If controller sticks, pull out main power 13. If leaving crane cab to go on top of crane, place controllers in "off' position. Open and lock the main power. Use the same sequence when leaving the crane for the day. 1. 2. 3. 4. 5.

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OSHA REQUIRED OVERHEAD & GANTRY CRANE INSPECTION CHECKLIST A. Daily visual inspection by the "designated" person. 1. All functional operating mechanisms for maladjustment interfering with proper operation. 2. All limit switches checked, without a load on the hook, at the beginning of each work shift. Check operations of limit switch by inching the block into the switch, or run it at slow speed. 3. Leakage in lines, tanks, valves, pumps & other parts of air or hydraulic systems. 4. Deformed or cracked hooks - visual inspection. B. Weekly to monthly visual inspections, depending on activity & severity of service. 1. Hoist ropes, including tightness of end clamps & rope clips. 2. Hoist, load or magnet chains, including end connections, for wear, twist, distorted links interfering with proper function, or stretch beyond manufacturer's recommendations. 3. Rope slings, including end connections, for wear, broken wires, stretch, kinking or twisting. 4. Rope reeving for noncompliance with crane manufacturer's recommendations. 5. Condition of hoisting sheaves. C. One to 12 month visual inspections, depending on the activity & severity of service. Any deficiencies shall be carefully examined & a determination made as to whether they constitute a hazard. We strongly recommend that this inspection be accomplished by an outside crane inspection company, for fresh eyes and their experience. 1. Deformed, cracked or corroded structural members. 2. Loose bolts or rivets. 3. Cracked or worn sheaves & drums. 4. Worn, cracked or distorted parts such as pins, bearings, shafts gears, rollers, locking & clamping devices. 5. Excessive wear on brake system parts, linings, pawls and ratchets. 6. Load and other indicators over their full range for any significant inaccuracies. 7. Gasoline, diesel, electric or other power plants for improper performance or noncompliance with other applicable standards. 8. Excessive wear of chain drive sprockets & excessive chain stretch. 9. Electrical apparatus for signs of any deterioration of controllers, master switches, contacts, limit switches & push-button stations, but not limited to these items.

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19. PERMIT REQUIRED CONFINED SPACES (1910.146) Confined spaces, by definition, have 3 qualities. They (1) have restricted means of entry, but big enough to enter (2) are not entered on a regular basis and (3) are not designed for continuous occupancy. The starting point is to ask yourself, Could I easily get out of the space. Think in terms of running out through a door or up a stairway, or up a ladder. There are some confined spaces which have hazards or potential hazards so that careful planning is needed before one makes entry. In this case a permit is required. There are four such conditions, the presence of any one triggering the need for a permit. They are (1) the existence of or the potential for an unsafe atmosphere, such as a lack of oxygen, a toxic gas, or the possibility of an explosion from a flammable gas, (2) the possibility of being engulfed, such as in a silo containing sand or clay. If you should fall into the sand you might be engulfed and not be able to get yourself out, (3) the possibility of becoming entrapped, such as falling down into the conical shaped bottom of an empty silo, and (4) if a serious safety or health exposure or potential exposure was present. Serious means immediately dangerous to your safety or health. An example might be walking into a dark electrical control room containing exposed high voltage contacts. Other considerations could be extreme heat or cold, excessive noise, vibration, moving parts or inadequate footing or lighting. Considering such possibilities, those areas or units require careful planning before someone enters. A permit is written out and signed off by a supervisor. The permit requires answers to questions such as: 1. the reason for the entry 2. the precise space to be entered 3. when and for what duration 4. the name of designated entrant(s), attendee(s) and entry supervisor

5. the hazard or hazards of the space to be entered 6. how the space will be isolated so others cannot interfere 7. the acceptable entry conditions how the hazard or hazards will be overcome or accommodated 8. the results of any air testing and by whom and when 9. the name of rescue service and phone no it may be your own or an outside service 10. how entrant will communicate with attendee(s) voice, phone, signals with tugs on a rope, light signals. 11. the equipment which will be used for entry and for rescue if necessary 12. any special considerations 13. the entry supervisors signature Below is an example of an entry permit. Also below is a decision tree prepared by OSHA to help you determine if the space to be entered requires a permit or not. Determining the need for a permit is not easy in every circumstance. For example, suppose there is a bad atmosphere either by smell or as a result of using a gas analyzer. You could ventilate the chamber from outside the space with a fan and eliminate the bad atmosphere. But does that get your out from under a permit? It depends. The source of the bad atmosphere would have to be completely eliminated before you could reclassify the space as not having a hazardous atmosphere. After eliminating and locking out a potential source of a hazardous atmosphere, you could ventilate the space and measure its quality with a gas analyzer and, if shown to be safe, you could reclassify the space as non-hazardous. Suppose you suspect that a hazardous atmosphere could exist. An example is a cupola. The atmosphere immediately after dropping bottom is certainly high in carbon monoxide. When, then, is the atmosphere safe for entry? By measuring the space inside

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the cupola at different time periods after dropping bottom and repeating the process over a period of time, you could establish that the atmosphere is safe after so many hours and, therefore, needs no ventilation. A quirk of the standard is that if you have two conditions, a hazardous atmosphere and another safety or health hazard, say machinery which requires locking out, you cannot get out from the need for a permit by locking out the machinery and then locking out the cause of the bad atmosphere and thoroughly ventilating the space. Apparently OSHA felt that allowing more than one hazard to be eliminated might lead to people taking shortcuts. It is important to be very suspect of confined spaces with little or no air circulation. Pits, tunnels, sumps, ductwork and a silo containing a greensand mixture can become oxygen deficient from the development of methane, using up oxygen. Even extensive rusting can consume enough oxygen to become dangerous if in a confined setting. Water main pits are an example. In helping foundries determine what locations within their operations should be Permit Required often we have come down on the side of not requiring a permit. That is to say, many foundrymen have designated certain confined spaces as requiring a permit when one is not necessary. However, the standard fairly screams to us to be sure that you have your lockout program working without fail every day. Most really serious potential mechanical hazards can be blocked out by faithfully locking out that machinery. Audit that program frequently. There are other settings which do not require a permit but require your serious attention. Suppose someone climbs to the top of a flat topped baghouse to check the hatch seal. Suppose he or she goes unconscious or sprains an ankle while standing on the roof of the baghouse. How do you get him or her down off that roof safely? None of the 4

reasons to require a permit apply here because it is not a confined space. You could be in a fix! Thinking through the requirements of a permit in this instance may be a good idea anyway, even though it is just the reverse of a confined space. Another consideration which surfaces as you inventory your confined spaces is the need for a buddy system. Suppose you send someone down to shovel spilled sand back onto an underfloor return sand conveyor. With the overall noise level in the average foundry, he might injure himself, call out and no one hear him. He may also have control of the conveyor system switch in order to bump it to get sand piled on the conveyor out of the way. He may get caught in the system and you may not know about the problem. You need a buddy system here. Whenever anyone goes into a confined space out of sight, someone else should know about it and be assigned to keep an eye on the situation. A buddy needs to be assigned to keep an eye on the situation. Confined spaces, themselves, have no governing standard except for a few industry-specific ones but none which refer to the foundry industry.

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20. PERSONAL PROTECTIVE EQUIPMENT (1910.132-138) This standard refers to the respirators, faceshields, safety glasses, gloves, leggings, safety shoes and other items worn to protect our bodies from injury or illness while doing foundry work. The standard requires you to go through the foundry, identifying each job type with a form which lists the basic hazard catagories which follow and then determine if the worker has exposure to any of them and then write down the protective equipment necessary to be worn to fully protect the individual from that exposure, all on the same form. It forces you to think through each real or potential exposure to be sure you have thought through each possible situation. HAZARD CATAGORIES 1. Impact 2. Penetration (puncture) 3. Compression (crushing) 4. Chemical attack 5. Heat and cold 6. Dust and particle 7. Light radiation (welding) 8. Non-light band radiation (x-ray) We have frequently found that some foundries still have not responded to the possibility of castings falling on the metatarsal, or upper foot, bones which can be protected by metatarsal guards. Additionally, the standard requires you to sit your employees down and go over each piece of personal protective equipment he or she is to wear, explaining what it is used for, when it must be worn, how to put it on, adjust it and its limitations of protective use. You, naturally, should indicate the disiplinary action if it is not worn all the time that it is required. Relatively unique to the foundry industry is the handling of molten metal. Different clothing materials react differently

to contact with molten metal. Cotton is still the most satisfactory protective clothing and especially cotton treated for fire retardancy. They are available as pants and jackets, referred to as greens, though not always green in color. The weight of the material naturally plays an important role in the degree of protection provided. Silver heat reflecting and flame resistant jackets and pants made of the synthetic material aramid, (a trade name is Nomex) are stiff and therefore somewhat uncomfortable, although effective protection for higher temperature steel foundries. Also, these suits do not breathe like cotton and therefore can be hot. Synthetic material made from petroleum such as nylon and polyester will melt and exacerbate a burn. They should be outlawed completely, including use as underwear and socks. The American Foundry Society committee on safety has issued a comprehensive listing of recommended protective clothing materials for use with different metals. Their phone number is 800537-4237. When wearing spats to cover the laces and eyelets of shoes, be sure the spats are worn under the pants. Even when wearing slip-on shoes, spats can protect from having molten metal lodge in the sewn welt around the sole. When wearing a spat-legging combination, the legging should either go under the pant-leg (not always possible) or have the pant-leg bloused over the top of the legging the way a marine blouses his pants over his boots. Leather aprons also protect. Molders boots, designed specifically for foundrymen, are steel tipped, have no laces but have elasticized side sections so they can be kicked off in a second should molten metal get down inside. Gauntlet gloves should not be used with molten metal because of the longer dwell time of the metal should it run down into the glove. Safety glasses with wire mesh or plastic sideshields are universally worn in foundries and, where prescribed, faceshields

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should be worn in addition to safety glasses and sideshields, not in place of safety glasses. Hot working conditions can be helped with the aid of a neckerchief which contains a gel that absorbs water, cooling your neck as the water evaporates. Since our heads release by far the greatest amount of heat from our bodies, where practical, do not have workers wear a hat. Some foundries require everyone to wear safety hats for uniformity of enforcement but some workers may be able to function safely without them. Cooling jackets can be purchased which use ice or even a water cooling unit but great care must be taken around molten metal splashes. 21. POWERED INDUSTRIAL TRUCKS (1910.178) Forklifts, front end loaders (bobcats) and other motorized mobile equipment are jointly referred to as powered industrial trucks. Only designated people who have been trained in the safe operation of powered industrial equipment are permitted to operate them. They must be given both classroom and "at the wheel" training. At the beginning of each shift the operator should inspect the equipment for the condition of the following: 1. the braking system for leaks 2. horn operation 3. headlights and warning lights 4. back up warning bell if fitted 5. fuel system for leaks 6. hydraulic lines for leaks 7. muffler 8. proper functioning of all controls 9. engine coolant level 10. condition of mirrors 11. condition of seatbelt, if so fitted A 1998 ammendent to the Powered Industrial Trucks Standard requires specific items to be covered in the classroom training.

They cover: Classroom Instruction A. Truck Related Topics 1. Complete operating instructions for the particular truck to be operated 2. The differences between the truck and an automobile 3. Maneuvering the truck. 4. Visibility 5. Fork use 6. Truck capacity 7. Truck stability 8. Inspection requirements 9. Refueling/recharging requirements B. Workplace Topics 1. The surface conditions where trucks will be operated. 2. Types of loads. 3. How to stack and handle the loads. 4. Cautions with pedestrian traffic. 5. Handling narrow and other difficult aisleways and other hazardous settings. 6. Handling slopes. 7. Close environments where exhaust may be a consideration. In addition, an actual operational test, which is more than just a driving test, is to be given by someone who will be designated as a qualified trainer. The test must include doing the kind of work the employee will be required to perform. There are no specific criteria as to becoming certified. You could send an employee to a class given by equipment suppliers or other educational services considered by experience to be qualified in this field. There is no federal OSHA certification for trainers. OSHA relies on the professionalism of training organizations. Your trained employee could then instruct your people and evaluate their driving tests. Everyone certified by your instructor or that from an outside firm must be reviewed at least every 3 years or sooner if they appear from their driving performance to be in need of further training. Motorized

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industrial equipment is, indeed, potentially very dangerous, both to the driver and those around him. The following are some rules for safe operation: SAFETY RULES FOR POWERED INDUSTRIAL TRUCKS 1. Forks and buckets should be carried as low as possible, when loaded or empty- no more than 4 off the floor when possible. 2. Operator should not place any part of his body outside the running lines of the truck. 3. Operators of forklifts should never place any part of their body between the mast uprights or other parts of the truck where shear or crushing hazards exist. 4. When climbing or descending a grade in excess of 10, loaded trucks should always be driven with the load upgrade. 5. On downgrades of more than 10, the load engaging means should be tilted backwards. 6. No riders should ever be permitted on vehicles or to ride on the forks or in the bucket. 7. When vehicle is left unattended, power should be shut off, keys removed, brakes set, the mast brought to the vertical position and forks and buckets fully lowered. A powered industrial truck is considered unattended when the operator is 25' or more away or the vehicle is not in his view. 8. Two vehicles moving in the same direction should keep three vehicle lengths between them. No passing. 9. Operators should sound their horn when approaching a blind comer. 10. Railroad tracks should be crossed diagonally and vehicles parked no closer than 6' from either rail of the railroad track. 11. When stopping on a loading dock, the vehicle should be parked no closer than 1 tire width from the edge of the dock.

22. PROCESS SAFETY MANAGEMENT (1910.19) This standard addresses the prevention or minimization of a catastrophic release of certain toxic and reactive, flammable or explosive chemicals. There are minimum quantities established for each chemical below which the standard does not apply. If you have more than that threshold quantity on-site at any one time, you must analyze the operation which uses those chemicals, determine the potential hazards of a release, explosion or fire, and institute a program which will prevent such an occurrence from taking place. There is a list of specific chemicals and their threshold planning quantities which is given in an Appendix to the standard and in addition, reference is made to the Hazard Communication Standard (1910.1200) which does not include a specific list but refers to any MSDS showing a reactive or flammable chemical under its Section II, called hazardous ingredients. If a chemical listed in Section II is flammable, reactive or explosive and you have 10,000 lbs. or more on-site at any moment, it falls under this standard. While very few foundries fall under the requirements of the standard, some chemicals which might cause you to comply are propane (10,000 lbs.), oxygen (10,000 lbs.) chlorine (1,500 lbs.), hydrofluoric acid (1,000 lbs.) liquid sulfur dioxide (1,000 lbs.) and methylisocyanate (250 lbs.). The standard calls for a process hazard analysis, thought through and written out and then done again every 5 years at a minimum, safety training of the employees and retraining at least every 3 years, and performance of an audit of safe operating techniques and a compliance audit again at least every 3 years. This standard is a cross between an EPA community protection standard and an OSHA worker protection standard, like the Hazardous Waste Operations Standard (1910.120).

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23. RESPIRATORY PROGRAM (1910.134) This OSHA standard requires that all employers have a respiratory program in effect where the use of respirators is necessary. It's called a "program" because it requires more than simply providing respirators. It includes air sampling, a medical qualification test for wearing respirators, an annual respirator fit test (sometimes semi-annual) and annual employee education. OSHA's requirements for a minimal respirator program are as follows: 1. Written standard operating procedures governing the selection and use of respirators shall be established. 2. Respirators shall be selected on the basis of the hazards to which the worker is exposed. 3. Only approved respirators shall be used (approved by NIOSH). 4. The user shall be instructed and trained in the proper use of respirators and their limitations. This means education as to: a) type of respirator and its uses b) when to wear a respirator c) how to test a respirator before each use d) how to maintain a reusable respirator 5. Employees shall be given a qualitative or quantitative fit test before first wearing a respirator and at least annually thereafter, although certain chemical specific standards call for more frequent fit tests such as the Lead Standard. 6. Persons should not be assigned to tasks requiring the use of respirators unless it has been determined that they are physically able to perform the work and can safely wear a respirator. The health care professional shall determine what health and physical

conditions are pertinent. A comprehensive health questionnaire must be completed by the employee and taken to the health care professional at the time the individual is tested for suitability to wear a negative pressure respirator. The employer is not permitted to see the completed questionnaire until the examination has been made. The questionnaire must then be placed in the file of the employee. We ecommend that you keep separate files for occupational exposure and for other personnel matters since OSHA and union representatives have the right to see occupational exposure results. 7. Where practicable, reusable respirators should be assigned to individual workers for their exclusive use. 8. Reusable respirators shall be regularly cleaned and disinfected. Those issued for the exclusive use of one worker should be cleaned after each day's use or more often, if necessary. Those used by more than one worker shall be thoroughly cleaned and disinfected after each use. 9. Disposable respirators should never be shared. 10. Respirators shall be stored in convenient, clean and sanitary locations. Reusable respirators used routinely shall be inspected during cleaning and deteriorated parts replaced. 11. Appropriate surveillance of work area conditions and degree of employee exposure or stress shall be maintained. 12. There shall be regular inspections and evaluation to determine the continued effectiveness of the program, as least annually. Be sure that your employees who wear disposable respirators to protect themselves

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against silica dust are wearing respirators with the designated N95 or an N100 against lead or cadmium fume and dust. Older respirators do not have these designations and should no longer be used, although according to the Respiratory Standard, they can be used until those in stock are used up. N95 and N100 respirators are more efficient than those made prior to their existence. While the new N95 respirator is suitable protection against silica and other dusts up to 10 times the PEL, and N100 respirators are suitable to protect against lead and cadmium fume and dust, the uses of a reusable respirator is necessary for protection against organic vapors because of the need to provide an activated charcoal surface on which to collect the molecules of the organic vapor. There is a disposable organic vapor respirator available but its useful life is very limited. Disposable respirators can be used not 1 hour, 1 day or 3 days, but as long as the inside of the respirator does not get so dirty that one begins breathing dust from the inside of the unit. In fact, the dirtier the outside becomes, the more efficiently it works, going from 95% efficient to 96%, 97%, etc. Disposable respirators with

designations R or P are specialized for use in atmospheres where there is oil mist, a condition we do not find in foundry settings. In 1998, when OSHA revised the Respiratory Protection Standard, it clarified the need for fit testing disposable respirators where the employee is wearing one voluntarily not because air testing determined that he/she must wear a respirator because the airborne concentration may be above the PEL. An employee who wears a dust mask voluntarily does not become part of the respiratory protection program and, therefore does not have to be given a respirator fit test. Such employees only have to be given Appendix D of the standard. Appendix D cautions that wearers should heed the respirator manufacturers instructions and to be sure to wear the proper type. The exemption from a respiratory program does not apply to the use of disposable respirators only dust masks.

Section II
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Section III - Part B

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