Federal Industry Issues

OCMA and Casting Industry
Federal Industry Issues

Speaker of the House, Ohio OCMA Trustee and HR Committee Chairman John Lalley, Globe Metallurgical Inc., warns the OCMA members about the potential impact of the controversial OSHA ergronomics standard.

In the waning days of the Clinton Administration, the Occupational Safety and Health Administration (OSHA) adopted the Final Rule version of its "Ergonomics Program Standard". This standard which became effective January 16, 2001, would have placed an onerous financial and administrative burden upon Ohio metal casters and suppliers. Estimates of the cost of the new standard ranged from an OSHA estimate of nearly $5 billion to the National Association of Manufacturers (NAM) estimate of $18 billion, to an estimate by the National Coalition on Ergonomics of more than $90 billion a year!

According to OSHA estimates, the average foundry would have incurred over $25,000 in costs to comply with the standard. The American Foundry Society (AFS) estimated it would have cost in excess of $40,000 just to set up an ergonomics program. Either of these estimates would have represented a severe financial burden for Ohio's small and medium-sized foundries.

Fortunately for manufacturing businesses throughout the U.S., on March 6 & 7, 2001 Congress under the Congressional Review Act (CRA) voted to repeal the Ergonomics Standard. President George W. Bush signed the measure on March 20, 2001 and this particular standard is now history.

Environmental

Tightening of Air Pollution Standards without Congressional Action

OCMA was actively opposed to the proposals to significantly tighten the standards for ozone and particulate matter (PM). OCMA recruited the Chairman of the Clean Air Scientific Advisory Committee (CASAC) George Wolff to address the OCMA membership in January 1997. Mr. Wolff's committee was responsible for providing recommendations to the USEPA concerning changes in the ozone/PM standards. The USEPA virtually ignored their recommendations. OCMA arranged to have Mr. Wolff meet with members of the Voinovich Administration including the director of Ohio EPA, the head of the Departments of Health and Economic Development, and representatives of the Governor's office. The information gleaned from that meeting assisted the administration in their efforts to oppose the proposed standards.

New interpretations of the Clean Air Act by Administrator Browner's staff have led the USEPA to develop additional regulations that will have a tremendous impact upon manufacturers in Ohio, specifically metal casters. The Any Credible Evidence (ACE) rule changed years of interpretation of the CAA and threatens to subject metal casters to frivolous, resource consuming lawsuits by environmental bounty hunters. The Compliance Assurance Monitoring (CAM) rule relegates environmental engineers to paper pushing versus serious efforts to reduce air emissions.

OCMA Vice President for Environmental Affairs, Kurt Braun, Ford Motor Company, provides the environmental update at the June annual meeting.

Global Warming Treaty

The metal casting process is a highly energy-intensive process. Efforts to reduce carbon emissions especially by levying a tax on carbon would have a devastating impact on our industry. Major international competitors Brazil, China, and India are excluded from the Kyoto Treaty.

Other Key Issues

OSHA Silica Standard

Under the Bush Administration and new head of OSHA, it is too early to determine whether the proposed tightening of the silica standard will move forward. Efforts are under way to convene a conference to discuss the technical difficulties of measuring silica exposure at reduced levels. Importantly, Ohio metal casters should not let down their guard. This issue is not going away so we must remain prepared.

Russ Murray and Silica Panel OCMA Executive Director, Russ Murray (second from left) joins a panel of experts discussing the proposed OSHA Silica Standard at the AFS Government Affairs Conference, May 2000.

The inaugural meeting of the AFS-led Silica Alliance was held on Monday, December 6, 1999, at AFS headquarters in Des Plaines. More than forty industry representatives attended the meeting and Ohio OCMA members were prominent. Steering Committee members Mike Hamilton, GM-Powertrain, Defiance Plant and Bob Huston, Xenia Foundry & Machine Company were joined by Kim Myers, Buckeye Steel Castings Company, Mark Armstrong & Jill Longendelpher, Flowserve Corporation, Batuk Modi, Ford Motor Company, Ken Kasprzak, Globe Metallurgical Inc., Gary Follmer, Hill & Griffith Company, Mike Lenahan, Kurtz Brothers, Inc., Kevin Sedensky, Morris Bean & Company, Craig Schmeisser, RMT, Inc., Kip Reiher, St. Marys Foundry, Inc., Roy Euvrard, Safety & Environmental Staff and Russ Murray, OCMA.

Two Working Groups were established; Economic & Technical Feasibility (ETF) and Communications. The ETF Working Group focused upon the need for reliable industry data to formulate a defense against enactment of the more restrictive OSHA standard. The ETF will be reviewing data from AFS lab tests in an effort to demonstrate that industry efforts to improve working conditions have been successful. The Communications Working Group is responsible for alerting metal casters to the devastating impact a reduced standard could have upon our industry. Craig Schmeisser is Co-chair of the ETF Working Group with Joy Cole, EBBA Iron. Russ Murray is Chairman of the Communications Working Group and Mike Lenahan is Secretary.

On December 7th, the AFS Government Affairs Committee approved a motion requesting that the AFS Executive Committee provide $50,000 for activities of the Silica Alliance. OCMA members participating on the Government Affairs Committee include, Bill Tordoff, AMSI, Inc., C. Frank DeMeo, General Casting Company, Mike Hamilton, and Jeet Radia, RMT, Inc. Although tight finances prevented full funding of the request, $10,000 in "seed" money was approved.

On January 19, 2000, Marthe Kent, Director of Health Standards, OSHA, announced that the silica standard had been moved from a 2000 priority to a 2001 priority. In September 2000, OSHA postponed indefinitely the stakeholders meetings and put on hold a small business review or SEBREFA panel.

In December 2001, OSHA removed crystalline silica from their regulatory priority list and indicated it would not proceed on the formal rulemaking track. Marthe Kent is no longer employed at OSHA. A consensus standard is now a possibility.

OSHA Reform

OCMA continues to support changes in the federal OSHA program that would transform OSHA from a confrontational, penalty-driven agency into one that assists employers with compliance and offers incentives to achieve real improvements in workplace safety and health

Regulatory Reform

OCMA supports the use of cost-benefit analysis for new regulations. Additional oversight is needed to assure that regulatory agencies such as the USEPA do not reinterpret legislation to change the intent of Congress. A system similar to that used in Ohio with the JACARR process would work wonders. Despite promises, congressional action has led to very little real relief for small businesses.

SIC Code Composition of OCMA Foundries

Gray and Ductile Iron Foundries	3321
Steel Foundries	3325
Malleable Iron Foundries	3322
Aluminum Foundries	3365

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