OSHA’s National Emphasis Program for the Primary Metal Industry
In May, 2011 OSHA issued a directive to “identify and reduce or eliminate worker exposures to harmful chemical and physical health hazards in facilities in the Primary Metal Industries”. This comprehensive nationwide emphasis program was developed to address the many health and safety hazards in this industry group. The goal of the NEP is to reduce or eliminate exposures to chemical and physical hazards including the reduction of skin and eye injuries, hearing loss and lung disease and other illnesses. OSHA also hopes that the NEP will improve industry awareness and control of hazards.
Which Industries are Covered?
The Primary Metal Industries (PMI) melt, refine and produce products from ferrous and nonferrous metals. Processes can include ore, pig, and scrap refining and rolling, drawing, casting, and alloying metals. Products manufactured include castings, nails, spikes, wire and cables, piping, sheets and bars, copper and aluminum products, and coke. The following SICs/NAICSs are covered in this NEP:
- 3312 – Steel Works, Blast Furnaces (including Coke Ovens), and Rolling Mills (NAICS 324199, 331111, 331221)
- 3313 – Electrometallurgical Products Except Steel (NAICS 331112)
- 3316 - Cold-Rolled Steel Sheet, Strip and Bars (NAICS 331221)
- 3317 - Steel Pipe and Tubes (NAICS 331210)
- 3321 - Gray and Ductile Iron Foundries (NAICS 331511)
- 3322 – Malleable Iron Foundries (NAICS 331511)
- 3325 – Steel Foundries, Not Elsewhere Classified (NAICS 331513)
- 3331 – Primary Smelting and Refining of Copper (NAICS 331411)
- 3334 – Primary Production of Aluminum (NAICS 331312)
- 3339 – Primary Smelting and Refining of Nonferrous Metals, Except Copper and Aluminum (NAICS 331419)
- 3341 – Secondary Smelting and Refining of Nonferrous Metals (NAICS 331314, 331423, 331492)
- 3351 – Rolling, Drawing and Extruding of Copper (NAICS 331421)
- 3354 – Aluminum Extruded Products (NAICS 331316)
- 3366 – Copper Foundries (NAICS 331525)
- 3365 – Aluminum Foundries (NAICS 331524)
- 3369 – Nonferrous Foundries Except Aluminum and Copper (NAICS 331528)
What Will OSHA Do In an NEP Inspection?
Compliance officers will look at:
- Personal Protective Equipment (PPE) Program. OSHA's PPE Standard (1910.132) requires employers to identify hazards and determine what PPE is necessary to protect eyes, face, hands, torso and feet. The PPE is expected to be properly selected, used, and maintained.
- Respiratory Protection Program: OSHA's Respiratory Protection Standard (1910.134) requires that employers must assess the nature and magnitude of the hazard in both normal operating conditions and reasonably foreseeable emergencies. OSHA will determine if respirators are necessary and are properly selected and used.
- Hazard Communication Program: MSDSs for the chemicals used in the facility will be reviewed to determine what hazards are present.
- Injury/Illness Records. Records will be reviewed to identify any workers with recorded illnesses or symptoms associated with exposure to chemical or physical hazards investigating log entries for any type of respiratory issues, hearing loss, or other evidence of adverse health effects, and skin or eye injuries involving chemicals.
- Production Process Evaluation. Production and processing records will be reviewed with a focus on the types and quantities of chemicals used. Engineering controls, work practices and PPE usage will be evaluated.
- Personal Air and Noise Monitoring Records: Industrial hygiene surveys conducted by the employer will be evaluated.
- Access to Employee Exposure and Medical Records Procedures: Workers will be interviewed to determine whether they were informed of their right to review their medical and exposure records annually and understand their rights regarding the confidentiality of such records. The recordkeeping program will be reviewed to determine if the required information is being collected and reported and if there are adequate methods for ensuring the confidentiality of worker medical records.
- Heat Stress Program: Engineering, administrative and work practice controls will be evaluated in areas where there is a potential for heat stress and/or when cases of heat stress are recorded on the OSHA 300.
The compliance officer may conduct air monitoring if exposures are identified. If the employer has conducted representative sampling in the previous six months, which shows no overexposures for all processes that have a potential for worker exposures, and any changes in the process are not likely to have increased exposures, only screening sampling may be done. Employer sampling records will look at whether the sampling has been done for all job functions and the heaviest production shifts.
OSHA has a list of potential chemical exposure in the Primary Metal Industries in Appendix A of the directive. Examples include carbon monoxide, silica, metal dusts and fumes, asbestos, solvents, isocyanates, formaldehyde, amines, benzene, coal tar pitch volatile, polycyclic aromatic hydrocarbons, acids, sulfur dioxide and ammonia.
What Types of Citations Could be Issued?
Following inspections, citations may be issued if:
- feasible engineering, work practice and administrative controls have not be implemented when exposures exceed the PEL(s)
- there has not been an initial evaluation of the respiratory hazards
- the requirements of the respiratory protection standard have not been followed
- there is no hazard assessment to determine if PPE is necessary and/or there is no written certification that the assessment was conducted.
- PPE is not being used or is inadequate when there is potential chemical exposure to eyes and/or skin. The expectation is that chemical goggles or other appropriate eye protection is used when there is a potential for splash or vapor exposure to substances likely to cause eye or skin injury and that chemical-resistant gloves, or sleeves or other appropriate protection for exposed skin are used when handling liquid, paste, or powdered substances that could cause dermal injury.
- employees are not trained on when PPE is needed and how to use it
- a hearing conservation program is not complete or effective.
- employees are not required to use hearing protection when noise levels exceed 90 dBA as a TWA or if workers have a standard threshold shift (STS) and noise exposures are at or above 85 dBA as a TWA.
- a variety of hearing protectors are not available and/or not offered at no cost to the employees
- violations to OSHA’s expanded standards (i.e. lead, cadmium hexavalent chromium, formaldehyde) exist.
- workers exposed to chemicals are not trained on the hazards of the chemicals in the workplace including knowing the signs and symptoms of any respiratory, skin or eye exposure.
- all MSDSs are not readily accessible to employees
- containers are not labeled with appropriate hazard warnings.
Compliance officers will also look at housekeeping and hygiene practices to determine whether these practices may contribute to overexposure.
How Can Industrial Hygiene Sciences, LLC Help You ?
Industrial Hygiene Sciences, LLC has conducted many industrial hygiene assessments in the primary metals industry, especially in foundries, and has the experience you need to identify and manage your exposures to hazardous substances and noise. Industrial Hygiene Sciences, LLC can
- review your exposures, programs (Hazard Communication, Respiratory Protection, chemical PPE, hearing conservation) and past monitoring records
- prepare a sampling strategy to assess your exposures
- collect air samples and interpret the results
- help you select appropriate protective equipment
- help you identify potential exposure reduction/control methods.
Contact Industrial Hygiene Sciences, LLC for more information.
Hexavalent Chromium Standard Updates (November 2010)
The May 31, 2010 deadline for implementing feasible engineering and work practice controls when exposures exceed the PEL has come and gone and OSHA has recently issued substantial penalties against several employers for violations of the Standard. Exposures over the PEL are common in the following operations:
- Welding with stainless steel or other high chromium content consumables using Shielded Metal Arc (stick) Gas Metal Arc (MIG) and Flux Core welding processes
- Manual plasma cutting or arc gouging on stainless steel or other high chromium content metals
- Manual hard surfacing using high chromium content alloys
- Thermal spraying with chromium materials
- Producing or using dry pigments containing hexavalent chromium
- Spray finishing with hexavalent chromium containing coatings
- Removal of hexavalent containing coatings from surfaces
Conducting baseline monitoring using methods equivalent to OSHA 215ID is essential to determine what requirements of the Standard apply to your facility.
Here are some suggestions for evaluating your program:
- review your past documents and procedures to ensure that you are complying with the various aspects of the Standard.
- if you have had or currently have overexposures, review your controls and work practices to ensure the controls are properly functioning and that work practices are being properly used
- if you have exposures that exceed the PEL, it is very important to implement exposure controls as soon as possible. While respirators may be needed to protect employees in the interim, they are not considered a control by OSHA. If you believe you have attempted feasible controls or if feasible controls are not possible, you should document the reasons for this and what options you explored in making this decision. The burden of proof that a control is not feasible is on the employer.
- if exposures exceeded the Action Level, make sure you are following the monitoring and medical surveillance requirements of the Standard and that all affected employees on all shifts are included in your program.
- if your processes have changed since you last had monitoring performed, monitoring should be repeated to assess current exposures
- if you did not have exposures that exceeded the Action Level but had exposures that exceeded 0.5 µg/m3 as a TWA, the main compliance requirement is to ensure you are informing employees about hexavalent chromium hazards through your Hazard Communication program and notifying employees about the existence of the Standard
- if you had exposures below 0.5 µg/m3 as a TWA, then you need to maintain your exposure monitoring records.
OSHA issued a Directive for a National Emphasis Program for Hexavalent Chromium on February 23, 2010. The Directive provides guidance for OSHA inspectors on targeting industries that have potential exposures to hexavalent chromium for inspection. It also references a previous Directive that specifies how the agency will enforce the provisions of the Standards.
OSHA has issued a booklet on the Hexavalent Chromium. It provides a good summary of what the standard requires. Also, there is an archived article on Hexavalent chromium
OSHA also has published a Final Rule to Protect Workers from Exposure to Hexavalent Chromium. In the original Hexavalent Chromium Standards, OSHA only required employees to be notified of the results of monitoring if their exposures exceeded the PEL. This is not consistent with other OSHA standards on hazardous substances such as lead, arsenic, cadmium and formaldehyde that require employee notification of monitoring results regardless whether or not they exceed the Action Limit or PEL. The rule was published on May 15, 2010 and takes effect June 15, 2010.
If you need assistance with complying with the Hexavalent Chromium Standard, please contact Industrial Hygiene Sciences, LLC. IHS has extensive experience helping employers comply with the Standard. You can also find another article on the Standard on the IHS Archives page.
NIOSH Hearing Loss Training Tool
NIOSH recently published a short document highlighting their Hearing Loss Simulator Tool. Noise exposure is found in many workplaces; NIOSH estimates that 1 in 4 employees occupationally exposed to excessive noise or other toxicants will develop permanent hearing loss but these losses are preventable! Motivating employees to consistently wear and properly use hearing protection is a challenge for many employers. Health promotion research indicates that people will take actions to prevent adverse health effects when they believe they are susceptible to the effect and that there is a threat to them. The Hearing Loss Simulator Tool allows employees experience the effect of a hearing loss without actually having one bringing what can be an abstract concept down to earth.
The software, available free from the NIOSH website, can also be personalized for employees by entering information about their current hearing loss. The instruction and training guide for the tool can also be downloaded at the NIOSH website.
Updated June 18, 2011
