Regulations

The Regulatory Case for Clean Air

Workplace air quality is regulated by a number of standards. Manufacturers understand that they must keep up with these regulations—which are ever-changing—and comply with them to the best of their ability. Maintaining clean air isn't just an ethical and functional necessity, it's the law.

Failure to comply with air quality regulations opens your business to multiple liabilities. Regulatory agencies can levy serious fines if they find your facility is out of compliance. Lawsuits stemming from health-related problems are worsened in the case of noncompliance, as well. Fortunately, there are comprehensive ways to improve your air quality. RoboVent engineers understand air quality regulations and how to meet them. For more information on regulations, explore the following:

  • OSHA
  • ACGIH
  • Environmental Regulations
  • Staying Ahead of Regulations

Clean Air and Compliance

Regulating harmful dusts, weld fumes and other airborne particulates in the workplace is the job of the Occupational Safety and Health Administration (OSHA). This agency began its work in 1971 with a mission to “assure safe and healthful working conditions for working men and women by setting and enforcing standards and by providing training, outreach, education and assistance.” Today, OSHA is the primary agency regulating air quality in manufacturing facilities.

OSHA's authority comes out of its “General Duty Clause.” It reads: “Each employer shall furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees.” The legal code is long (and ever growing) and includes many specific standards for air quality, most of which are contained in Standard 29 CFR Part 1910 Subpart Z.

OSHA sets “permissible exposure limits” (PEL's) for workers in facilities where airborne contaminants are a concern. These limits set an amount of a substance a worker can be exposed to over the course of an 8-hour shift (a time-weighted average, or TAV). For example, here is a list of a few PEL's:

  • Cadmium: 0.005 mg/m3
  • Hexavalent chromium: 0.005 mg/m3
  • Lead: 0.05 mg/m3
  • Nickel: 1.0 mg/m3
  • Manganese: 5.0 mg/m3

If a manufacturer needs to improve its air quality to meet a specific OSHA regulation, there are several steps available. First, you would study your engineering processes to see if you might remove an obvious source of the contaminant. This would be considered the “low-hanging fruit.” For example, a residue on weld surfaces contributes greatly to weld fumes and can often be easily removed.

Another way to improve air quality in order to meet OSHA regulations is to implement a dust or weld capture solution. Most of this equipment is categorized in two ways: source capture and ambient capture. Source capture allows you to control localized fume and dusts and includes equipment such as fume arms, hoods and fume guns. Ambient capture equipment is installed throughout your building and filters or exhausts air from the entire facility. These are ducted systems or large, standalone pieces of equipment that, optimally, create a flow within a building to filter the air as efficiently as possible.

Because OSHA standards are statutory regulations, maintaining clean air is mandatory. Failure to comply with these regulations can lead to serious fines. For example, in 2014, a manufacturer was forced to pay a $342,000 fine for 38 violations that exposed workers to hexavalent chromium. Fortunately, there are many other good reasons to improve air quality beyond OSHA compliance.

acgih-regulations

Scientific Standards for Clean Air

Not to be confused with OSHA but very important in its own right is the American Conference of Governmental Industrial Hygienists (ACGIH). This organization is a group of industry professionals that maintains its own list of air quality standards. These standards are based on rigorous science and industry expertise. In general, ACGIH standards are more stringent than OSHA standards. In many ways, the ACGIH plays a leadership role in the air quality field; OSHA often changes its standards to match those of the ACGIH, though often after a long period of deliberation.

Canadian regulatory agencies tend to follow ACGIH standards for clean air. Canada lacks a national regulatory body that is the equivalent of OSHA. Instead, they set their regulations at the provincial level. About half of Canadian provinces officially base their regulations on ACGIH exposure limits.

An example of the ACGIH's leadership in air quality standards is its recent announcement regarding exposure limits for manganese. Until recently, the ACGIH's limit for manganese was 0.2 mg/m3. Recall that the U.S. limit (listed above) is currently 5.0 mg/m3—25 times the ACGIH level. In early 2016, however, the ACGIH announced a new limit for manganese of 0.02 mg/m3. This constitutes an exposure level ten times stricter than before and 250 times stricter than the current OSHA level.

While the ACGIH has no legal authority, manufacturers are watching this change. Since OSHA often follows the ACGIH's scientific findings, many in industry are assuming that OSHA will eventually tighten its manganese regulations. As soon as OSHA changes its rule, many manufacturers will have to reevaluate their air quality.

Some manufacturers follow ACGIH standards for clean air. These include leading companies such as Volvo and Honda. They do this not only because it creates a cleaner, more productive work environment, but also because it ensures they don't get taken by surprise by changes in regulations.

The EPA and Your Clean Air

In addition to OSHA's long list of air quality regulations, the Environmental Protection Agency (EPA) enforces a set of regulations, as well. Most of these rules are the result of the Clean Air Act. While this act was passed in 1963, it has been amended several times, expanding the list of regulated substances and the purview of their enforcement.

One of the EPA's sets of rules particularly relevant to manufacturing is the National Emission Standards for Hazardous Air Pollutants (NESHAP). These rules establish nine metal fabrication and finishing “source categories.” These include operations such as “Electrical and Electronics Equipment Finishing Operations” and “Iron and Steel Forging.” The EPA's purpose for this list was to reduce “Metal Fabrication Hazardous Air Pollutants (MFHAP) of compounds of metals such as Cadmium, Chromium, Lead, Manganese and Nickel.” The EPA has laid out the requirements and methods of compliance, much like OSHA has. EPA regulations also limit how much contaminated air a facility can exhaust to the outside.

As with OSHA regulations, compliance with these EPA rules is critically important for manufacturers. Noncompliance can carry serious fines, hassles and reputational harm.

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Strategizing with Clean Air

Keeping up with changing air quality regulations has become a major responsibility for manufacturers. While plant managers usually understand the dangers of airborne contaminants, translating that shop-floor knowledge into a strategy for legal compliance is something different. And when those legal rules change, the challenge can become particularly acute.

An important step in staying ahead of regulations is to establish a baseline of your air quality. This is done through an air quality audit, preferably conducted by a certified industrial hygienist. These professionals set up monitors throughout your facility to measure air quality. Using their report, you can then develop a strategy for meeting or surpassing the current regulations. Most likely, of course, you will already be complying with many or all OSHA regulations. Even a fully compliant facility, however, could benefit from an air quality audit. Besides serving as a third-party documentation of your air quality, the audit presents the opportunity to plan for the future—a future in which regulations could change.

There are many examples of air quality regulations changing and of manufacturers being caught by surprise. A recent rule change from OSHA involving silica dust is expected to force many manufacturers to take new actions to ensure compliance. The new silica rules are significantly more stringent than previous regulations. Mounting scientific evidence had shown that the previous limits on silica dust were not keeping workers safe. OSHA estimates that the new rule could prevent 600 deaths and 900 new cases of silicosis each year. The new rule forces manufacturers to cut PEL's by half. In addition, the rule lists requirements for assessing and monitoring exposure, protecting employees, mitigating dust, keeping records and communicating with employees. Many manufacturers are scrambling to adapt.

To avoid being caught in such a situation, manufacturers can take action today to improve their air quality. By implementing a comprehensive dust or weld fume collection system, they can meet or surpass today's standards. If exposure limits become more strict in the future, they will either already be in compliance or will be much better prepared to marginally improve their air quality to come into compliance.