Guidance for the Identification and Control of Safety and Health Hazards in Metal Scrap Recycling - OSHA 3348-05 2008
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Guidance for the Identification and Control of Safety and Health Hazards in Metal Scrap Recycling OSHA 3348-05 2008
Employers are responsible for providing a safe and healthy workplace for their employees. OSHA’s role is to promote the safety and health of America’s working men and women by setting and enforcing standards; providing training, outreach and education; establishing partnerships; and encouraging continual improvement in workplace safety and health. This publication provides a general overview of a particular standards-related topic. This publication does not alter or determine compliance responsibili- ties which are set forth in OSHA standards, and the Occupational Safety and Health Act. Moreover, be- cause interpretations and enforcement policy may change over time, for additional guidance on OSHA compliance requirements, the reader should consult current administrative interpretations and decisions by the Occupational Safety and Health Review Com- mission and the courts. Material contained in this publication is in the public domain and may be reproduced, fully or partially, without permission. Source credit is requested but not required. This information will be made available to sensory impaired individuals upon request. Voice phone: (202) 693-1999; teletypewriter (TTY) number: 1-877-889- 5627. Edwin G. Foulke, Jr. Assistant Secretary of Labor for Occupational Safety and Health
Guidance for the Identification and Control of Safety and Health Hazards in Metal Scrap Recycling Occupational Safety and Health Administration U.S. Department of Labor OSHA 3348-05 2008
Contents Introduction 3 What You Need to Know about Mercury The Audience for This Guide 3 Exposure 22 Why This Guide Is Important 3 What You Need to Know about Exposure How This Guide Can Help 3 to Other Metals 24 What This Guide Covers 3 What You Need to Know about Radioactive Specific Standards and Requirements Scrap 26 Addressing Chemical and Physical What You Need to Know about Metalworking Hazards in Metal Recycling Operations 3 Fluids 27 Other Relevant Guidelines 4 What Other Hazards You Should Know About 27 Types of Hazards in Metal Scrap Recycling 4 How to Control Hazards 28 Engineering Controls and Work Commonly Recycled Metals and Practice Controls 28 Their Sources 5 Examples of Engineering and Work Practice Types of Metals Most Commonly Recycled 5 Control Techniques to Reduce Emissions 29 Common Sources of Recycled Metals 5 Personal Protective Equipment 30 What You Need to Know About Scrap The Need to Provide Hearing Protection 31 Quality and Contaminants 5 What You Need to Know about Hazard Communication 32 Common Recycling Processes, Hazards and Related Controls 7 References 34 Processes Commonly Used to Recycle Metal Scrap and Their Hazards 7 Appendix – Exposure Limits for Loading and Unloading 7 Selected Metals 38 Breaking and Separating Processes 9 Gas Torch Cutting 9 OSHA Assistance 41 Non-Gas Torch and Other Cutting 11 Baling, Compacting and Shredding 12 OSHA Regional Offices 44 Melting and Baking in Furnaces and Ovens 14 Applying Chemical Processes to Recycle Metals 15 Recognizing and Controlling Hazards 16 How to Determine the Hazard Levels of Various Processes 16 Metals that OSHA Regulates 16 What You Need to Know about Arsenic Exposure 17 What You Need to Know about Beryllium Exposure 18 What You Need to Know about Cadmium Exposure 19 What You Need to Know about Hexavalent Chromium Exposure 20 What You Need to Know about Lead Exposure 21 2 Occupational Safety and Health Administration
Introduction juries were sprains and strains; heat burns; and cuts, lacerations, and punctures. (BLS, 2003) The Audience for This Guide Anyone who works in the metal scrap recycling in- How This Guide Can Help dustry—employers, employees, safety profession- As an employer, this guide will help you protect als, and industrial hygienists—should read this your employees by helping you and your employ- publication. This guide can help you identify and ees recognize, manage, and control the potential manage the hazards associated with exposure to hazards associated with common metal scrap recy- various metals and processing chemicals and with cling processes. This guide will also assist safety related processes and equipment used in metal professionals and industrial hygienists in their ef- scrap recycling operations. forts to identify, evaluate, and develop appropriate controls for hazards related to metal scrap recycling Why This Guide Is Important processes. Metal scrap recycling, also called secondary metal processing, is a large industry that processes, in the What This Guide Covers U.S. alone, 56 million tons of scrap iron and steel This document will assist employers and employees (including 10 million tons of scrap automobiles), in recognizing and controlling typical health and 1.5 million tons of scrap copper, 2.5 million tons of safety hazards associated with various metal scrap scrap aluminum, 1.3 million tons of scrap lead, recycling operations and in selecting appropriate 300,000 tons of scrap zinc and 800,000 tons of scrap control methods. This document does not provide stainless steel, and smaller quantities of other met- an in-depth evaluation of every recycled material, or als, on a yearly basis. (ISRI NDa) of every associated process-related hazard; rather it gives an overview of processes and related hazards Scrap metals, in general, are divided into two basic common to a wide range of metal scrap recycling categories: ferrous and nonferrous. Ferrous scrap is operations. metal that contains iron, while nonferrous metals are metals that do not contain iron. These two basic Employers must evaluate their own operations, categories of metals are described in further detail in processes, and equipment to ensure that all hazards the section, “Types of Metals Most Commonly Recy- in their operations are identified and appropriately cled” in the “Commonly Recycled Metals and Their controlled. There are many relevant guidance doc- Sources” chapter of this guide. uments and standards related to exposure to haz- ardous substances (including metals), working in Many employees are employed by scrap metal recy- industrial environments, and working with specific cling industries. Private, nonferrous recycling indus- types of material handling and processing equip- tries in the U.S. employed approximately 16,000 ment that may be associated with recycling pro- employees in 2001.1 (Figures were not available for cesses. This guidance document includes references ferrous recycling industries.) In 2001, those nonfer- to these documents throughout the text, along with rous recycling industries reported approximately short summaries where appropriate. 3,000 injuries and illnesses. The most common causes of illness were poisoning (e.g., lead or cad- Specific Standards and Requirements mium poisoning), disorders associated with re- Addressing Chemical and Physical peated trauma, skin diseases or disorders, and Hazards in Metal Recycling Operations respiratory conditions due to inhalation of, or other Although this guide recommends work practices contact with, toxic agents. Of those injuries and ill- and engineering controls to decrease hazards to em- nesses, 701 cases involved days away from work. ployees, there are legal requirements in OSHA stan- The most common events or exposures leading to dards that you need to know about and comply these cases were contact with an object or piece of with. These include, for example, OSHA General In- equipment; overextension; and exposure to a harm- dustry Standards, Title 29 of the Code of Federal ful substance. The most common types of these in- Regulations (CFR), Part 1910 and the Construction Industry Standards in 29 CFR 1926. Consult these standards directly to ensure full compliance with the 1After 2001, the data for private nonferrous recycling industries provisions. States with OSHA-approved plans have were no longer available due to a change in industry codes. standards which are at least as effective as, but may However, the nonfatal injury incident rates in 2005 for codes that encompass the nonferrous recycling industry range from differ from, the Federal OSHA standards. These and 7.8 to 11.2 per 100 employees (BLS, 2005). G U I DA N C E F O R T H E I D E N T I F I C AT I O N A N D C O N T R O L O F 3 S A F E TY A N D H E A LT H H A Z A R D S I N M E TA L S C R A P R E CYC L I N G
other OSHA standards and documents are available with OSHA performance-based standards, such as online at www.osha.gov. 29 CFR 1910.212, General Requirements for All Ma- chines. ANSI standards are sometimes incorporated Other federal agencies, including the Department of into OSHA regulations, and in these cases, employ- Transportation (DOT), the Mine Safety and Health ers are accountable for complying with the specific Administration (MSHA) within the Department of versions of the ANSI standard referenced. OSHA Labor, the Environmental Protection Agency (EPA), generally recommends, however, that employers the Nuclear Regulatory Commission (NRC), and the use the most recent versions of ANSI standards. Department of Energy (DOE) may each have appli- cable standards regulating specific types of scrap Types of Hazards in Metal Scrap Recycling metals or specific aspects of related recycling pro- Employees in facilities that recycle metal scrap are cesses. Employers should refer to these agencies for exposed to a range of safety hazards associated specific information regarding standards that may with material handling methods, hazards associated affect their recycling operations. with the metals themselves (as dust or fumes), and with the hazardous substances used to process or Other Relevant Guidelines recover these metals. These hazards, the processes The American National Standards Institute (ANSI) and operations that present the hazards and the re- publishes voluntary consensus standards on the lated control measures are covered in this guide. safe care and use of specific machinery. ANSI stan- dards also may give you guidance on complying 4 Occupational Safety and Health Administration
Commonly Recycled Metals • Brass from lock manufacturing. • Copper from tubing manufacturing. and Their Sources Types of Metals Most Commonly Recycled Obsolete scrap, the other major source, may in- The scrap metal recycling industry encompasses a clude: wide range of metals. Some of the most commonly- • Copper cables. recycled metals (by volume) are iron and scrap steel • Copper household products. (ISS), copper, aluminum, lead, zinc, and stainless • Copper and zinc pipes and radiators. steel. (ISRI NDa) • Zinc from die-cast alloys in cars. • Aluminum from used beverage cans. Scrap metals, in general, are divided into two basic • Aluminum from building siding. categories: ferrous and nonferrous. Ferrous scrap is • Platinum from automobile catalytic converters. metal that contains iron. Iron and steel (which con- • Gold from electronic applications. tains iron) can be processed and remelted repeat- • Silver from used photographic film. edly to form new objects. (ISRI NDb) • Nickel from stainless steel. • Lead from battery plates. (ISRI NDc; OECD 1995) Common nonferrous metals are copper, brass, alu- minum, zinc, magnesium, tin, nickel, and lead. Non- Nonferrous metals can also be recycled from cap- ferrous metals also include precious and exotic tured particle emissions from metal primary or sec- metals. Precious metals are metals with a high mar- ondary production facilities. ket value in any form, such as gold, silver, and plat- inum. Exotic metals contain rare elements such as Other exotic and precious metals come from a vari- cobalt, mercury, titanium, tungsten, arsenic, beryl- ety of sources, such as: lium, bismuth, cerium, cadmium, niobium, indium, • Gallium from gallium arsenide (GaAs) used in gallium, germanium, lithium, selenium, tantalum, electronics. tellurium, vanadium, and zirconium. • Gold from precious metals manufacturing plants and from discarded electronics and jewelry. Some types of metals are radioactive. These may be • Platinum-group metals from catalysts (including “naturally-occurring” or may be formed as by-prod- catalytic converters, which automobile recyclers ucts of nuclear reactions. Metals that have been ex- systematically collect). posed to radioactive sources may also become • Used catalysts from industrial processes (mostly radioactive in settings such as medical environments, from the chemical and pharmaceutical indus- research laboratories, or nuclear power plants. tries). • Old electronics equipment. Common Sources of Recycled Metals • Other jewelry. (USGS 2001) Ferrous scrap comes from sources such as: • Mill scrap (from primary processing). Radioactive metal scrap may come from military ap- • Used construction beams, plates, pipes, tubes, plications (such as depleted uranium), discarded wiring, and shot. medical equipment, building or storage material • Old automobiles and other automotive scraps. from nuclear power plants (particularly nickel scrap) • Boat scrap, railroad scrap, and railcar scrap. or trace amounts found elsewhere, such as Ameri- • Miscellaneous scrap metal. cium (Am-241), found in smoke detectors. Ferrous metals are magnetic and are often collected Additional information on sources of various metals in scrap yards by a large electromagnet attached to is provided in the “What You Need to Know about a crane, sweeping across piles of scrap to grab mag- Exposure to Other Metals” section at page 24. netic objects. What You Need to Know about Scrap Aluminum is the most widely-recycled nonferrous Quality and Contaminants metal. (ISRI NDc) The major sources of nonferrous The worldwide scrap metal recycling industry has scrap are industrial or new scrap, and obsolete developed sets of specifications and grading sys- scrap. Industrial or new scrap may include: tems to ensure consistent quality of source scrap • Aluminum left over when can lids are punched material for a given grade of metal scrap. The three out of sheets. most widely-used specifications are the Scrap Spec- G U I DA N C E F O R T H E I D E N T I F I C AT I O N A N D C O N T R O L O F 5 S A F E TY A N D H E A LT H H A Z A R D S I N M E TA L S C R A P R E CYC L I N G
ifications Circular (U.S. Institute of Scrap Recycling Employers should be aware of the potential impuri- Industries, Inc.), the European Classification for Non- ties in their source scrap, and should be prepared to Ferrous Scrap Metals, and the Standard Classifica- monitor for hazardous levels of those metals and tion for Non-Ferrous Scrap Metals (U.S. National other chemicals in their work environments (OECD Association of Secondary Materials Industries, Inc.). 1995). Employers should also ensure that they re- These specifications generally set minimum and ceive their scrap supply from reliable sources that maximum content of certain metal impurities, and follow the established guidelines and should obtain restrict levels of certain hazardous metals and other material data safety sheets (MSDSs) and labels for hazardous substances. the scrap materials where available. If an MSDS is not provided, the employer must request one from Employers should be aware that these criteria are their supplier. See the discussion on “What You designed to protect the end-user, or are for product Need to Know about Hazard Communication” quality purposes, and are not designed to protect at page 32 in the “Recognizing and Controlling employees performing metal scrap recycling Hazards” section of this guide for more information processes. As a result, concentrations of certain on employer obligations to obtain MSDSs and metals that are below these quality specification re- labels for scrap materials. quirements, either as incoming raw scrap or as processed scrap (to be sent elsewhere), may still pose hazards to employees handling metal scrap. 6 Occupational Safety and Health Administration
Common Recycling metal scrap recycling, including (but not limited Processes, Hazards and to) the following standards Related Controls • 29 CFR 1910.1000, Air Contaminants • 29 CFR 1910.212, General requirements for all Processes Commonly Used to Recycle machines Metal Scrap and Their Hazards • 29 CFR 1910.219, Mechanical power-transmis- Metal scrap recycling is a large and complex indus- sion apparatus try. The variety of metals involved and the wide • 29 CFR 1910.147, The control of hazardous en- range of sources of metal scrap require many pro- ergy (lockout/tagout) cessing techniques. These processing techniques pose a range of safety and health hazards to em- ployees in the industry. This section discusses a se- Sources of Additional Information lection of those processes, the types of hazards that • OSHA 3170, Safeguarding Equipment and Pro- these processes may pose to employees, and con- tecting Employees from Amputations trol measures employers and operators can imple- • OSHA 2254, Training Requirements in OSHA ment to control or eliminate these hazards. This Standards and Training Guidelines document does not go into detail on every process • OSHA Health and Safety Topics: Machine or every hazard associated with every process, but Guarding, http://www.osha.gov/SLTC/machine rather it discusses the most common processes and guarding/index.html provides examples of hazards related to those • OSHA Lockout/Tagout eTool http://www. processes. osha.gov/dts/osta/loto training/index.htm • National Electrical Code 250-112 Recycling is a multi-step process, starting with col- lection and transport of raw scrap, pretreatment, melting, refining, forming and finishing. The recy- Loading and Unloading cling processes discussed in this document fall into The first step in any metal scrap recycling operation these basic categories: is getting the metal scrap to the recycling operation • Loading and unloading. and collecting or sorting materials to be processed • Breaking and separating. in groups. This may involve light or heavy trucks, • Gas torch cutting. stationary or mobile cranes, conveyor belts, and • Non-gas torch cutting and other cutting. other large and potentially hazardous equipment. • Baling, compacting, and shredding. Working with this equipment poses hazards typical • Melting and baking in furnaces and ovens. for material handling equipment. • Applying chemical processes to recycle metals. Employers must ensure that employees use the ap- Each category is an individual component of the re- propriate combination of personal protective equip- cycling process and may pose a wide range of ment (PPE) such as hard hats, sturdy boots, gloves, safety hazards that are common to many industrial thick clothing, and respirators (if the operation gen- and material handling processes. Such hazards may erates hazardous dust) to be adequately protected include flying pieces of material, exposed moving from safety and health hazards. parts, fire hazards, and noise hazards. OSHA’s Personal Protective Equipment standards Hazardous chemical exposures to employees are (29 CFR 1910 Subpart I) establish requirements for most likely to result from hot processes that produce employers to evaluate the workplace and identify fumes (such as torching and welding or melting in fur- PPE needs based on actual workplace hazards naces) or processes that produce dust (such as break- (29 CFR 1910.132). These standards also establish ing, shredding, and cutting). Each of these processes criteria for proper selection and use of specific is discussed in detail on the following pages. types of PPE such as foot, eye, or head protection. See the “Applicable Standards” box on the next Applicable Standards page for a list of OSHA PPE standards (not neces- 29 CFR 1910 General Industry - many standards sarily all-inclusive) that may apply to recycling for occupational safety and health may apply to operations. G U I DA N C E F O R T H E I D E N T I F I C AT I O N A N D C O N T R O L O F 7 S A F E TY A N D H E A LT H H A Z A R D S I N M E TA L S C R A P R E CYC L I N G
Forklift and crane operators must be properly trained in the use of such equipment. Operators Case History #3 must conduct pre- or post-shift vehicle inspections A 31-year-old male recycling plant foreman died depending on vehicle use. Employers must consider when he was run over and crushed by a front-end equipping vehicles with guarding to protect any vul- loader. The victim was struck by the loader when nerable brake lines from incidental damage during its brakes failed as it backed down an incline after operation (NIOSH FACE; 29 CFR 1910.178). Of depositing cans into a hopper for processing. course, any alterations/additions to powered indus- (NIOSH FACE, 95MA026) trial trucks would require written approval from the manufacturer. Preventive/corrective measures: Operators must examine all powered material handling equip- Case History #1 ment at the beginning of each shift. All failing A 46-year-old laborer died from injuries sustained equipment must be tagged out of service and not when his left arm became caught between the used until repaired. belt and pulley of a conveyor system at a Massa- chusetts scrapyard and recycling plant. The victim was working alone removing fallen debris from Case History #4 the conveyor frame at the time of the incident. A 24-year-old forklift truck operator died after the (NIOSH FACE, 94MA021) lift truck he was operating overturned. The victim was operating the equipment in the storage yard Preventive/corrective measures: Material han- of a wire mill. A length of wire became wrapped dling equipment must be equipped with proper around the front drive trans-axle, severing the hy- machine guards to prevent employees from com- draulic brake line. As he was returning to the ing in contact with moving parts. Emergency stop plant with two empty wire spools, the brakes devices should be provided within easy reach of failed on the truck. He was traveling down an in- all conveyor operator stations to allow operators cline and turned abruptly to avoid striking stored to immediately stop conveyors in the event of an material. The sharp turn caused the truck to over- emergency. Machines must be locked or tagged turn. The victim tried to jump free but was struck out during cleaning, servicing or maintenance. by the Roll Over Protective Structure (ROPS) of Employees must be properly trained in all safety the truck. (NIOSH FACE, 96MO054) devices. Preventive/corrective measures: Employers must keep aisles and passages used by material han- Case History #2 dling vehicles clear of obstructions. Operators A 41-year-old tow truck operator was run over by must inspect all powered material handling his tow truck while unloading a car at a scrapyard. equipment at the beginning of each shift. All fail- The tow truck operator jerked the truck back and ing equipment must be tagged out of service and forth to release a car, and backed over the victim, not used until repaired. Operators of sit-down who was working behind the truck. He then ran trucks need to be trained to remain in the opera- over him again as he moved forward, with the tor’s position in a tipover accident and to lean truck coming to rest with the victim pinned under away from the direction of fall to minimize the the rear wheel. Scrapyard employees tried to res- potential for injury. When seat belts are installed cue the victim by lifting the truck with a grapple on forklifts, employees are required to wear crane but the grapple slipped and the truck fell them. back on him. (NIOSH FACE, 99NJ09101) Preventive/corrective measures: Operators Applicable Standards should disengage the transmission of the towing • 29 CFR 1910.132, General requirements vehicle when hooking or unhooking vehicles • 29 CFR 1910.132(h), Employer Payment for from a tow. In addition, employees should never Personal Protective Equipment work behind the towed vehicle or between the • 29 CFR 1910.133, Eye and face protection vehicle and the tow truck during this process. • 29 CFR 1910.134, Respiratory protection 8 Occupational Safety and Health Administration
sorted by hand. When sorting metal scrap by hand, • 29 CFR 1910.135, Head protection employees must wear personal protective equip- • 29 CFR 1910.136, Occupational foot protection ment such as gloves if there is a possibility of en- • 29 CFR 1910.137, Electrical protective devices countering any metal or other substance for which • 29 CFR 1910.138, Hand protection skin contact could result in adverse health effects. • 29 CFR 1910.147, The control of hazardous en- ergy (lockout/tagout) Even for metals that do not irritate the skin, handling • 29 CFR 1910.176, Handling materials - general sharp or pointed pieces of scrap metal poses cut or • 29 CFR 1910.178, Powered industrial trucks abrasion hazards to hands or bodies. Employers are • 29 CFR 1910.179, Overhead and gantry cranes required to ensure that employees wear proper per- • 29 CFR 1910.180, Crawler locomotive and truck sonal protective equipment such as gloves and cranes durable clothing to guard against cuts and scrapes. • 29 CFR 1910.181, Derricks Employees also need to be aware of the proper first • 29 CFR 1910.184, Slings aid, medical, and reporting procedures if they re- • 29 CFR 1910.212, General requirements for all ceive a cut or scrape. Similar concerns apply to machines other scenarios where employees work with scrap • 29 CFR 1910.219, Mechanical power-transmis- by hand. sion apparatus Once an employee has started feeding material into a furnace, there is a risk of hazardous fumes from Breaking and Separating Processes certain metals. Where exposures exceed OSHA Per- Size-reduction of metal scrap is a necessary compo- missible Exposure Limits (PELs), employers are re- nent of some operations. Basic metal breaking quired to implement feasible engineering controls processes often involve heavy manual labor to (e.g., furnace feeding operations can be set-up with break up large or complex assemblies of scrap local exhaust which can circulate and vent the air metal, or to cut or break the pieces into sizes that near the furnaces to remove toxic fumes from the can be fed into a furnace. Employees involved in ac- workplace). If the exposures still exceed the PELs, tivities of this type may be exposed to metal fumes, employees will need to wear respiratory protection smoke, hot environments, and hot material when to prevent inhalation of toxic fumes and dusts. Refer working near furnaces, and may come in contact to the section on Personal Protective Equipment in with metals that present hazards through both skin the “Recognizing and Controlling Hazards” section contact and inhalation. of this guide for further information on this topic. Some recycling industries use drop-ball breaking (or Applicable Standards ‘tupping’) to break apart the largest solid pieces of • 29 CFR 1910.95, Occupational Noise Exposure scrap metal, or to initiate breaking up large assem- • 29 CFR 1910.132, General requirements blies. This process may create flying object hazards • 29 CFR 1910.133, Eye and face protection as the material breaks apart from the impact of the • 29 CFR 1910.134, Respiratory protection ball. Employers must ensure that employees are • 29 CFR 1910.135, Head protection protected from these hazards by either performing • 29 CFR 1910.136, Occupational foot protection the task remotely; placing a barrier or protective • 29 CFR 1910.137, Electrical protective devices shield around the task; or using PPE such as face • 29 CFR 1910.138, Hand protection and body protection. Breaking may also create a • 29 CFR 1910.147, The control of hazardous en- noise hazard, requiring the employer to implement ergy (lockout/tagout) feasible engineering or administrative controls. If • 29 CFR 1910.212, General requirements for all these controls do not sufficiently reduce the noise machines hazard, employers must provide appropriate hear- • 29 CFR 1910.219, Mechanical power-transmis- ing protection such as earplugs, canal plugs, ear- sion apparatus muffs, or other protective devices as required by • 29 CFR 1910.1000, Air Contaminants OSHA’s Occupational Noise Exposure standard, 29 CFR 1910.95. Gas Torch Cutting Sorting of scrap is now commonly done by auto- One of the most common tools used to break apart mated processes, though some metals must still be large metal pieces is the gas cutting torch, often G U I DA N C E F O R T H E I D E N T I F I C AT I O N A N D C O N T R O L O F 9 S A F E TY A N D H E A LT H H A Z A R D S I N M E TA L S C R A P R E CYC L I N G
used for cutting steel scrap. Classic cutting torches OSHA has established PELs for many hazardous use gas, while other torches use plasma or powder, substances. OSHA requires employers to provide or even water (although water torches are rarely engineering controls or work practices to the extent used for metal scrap). Thermal (gas) torches expose feasible when employee exposure exceeds these employees to sprays of sparks and metal dust parti- PELs for any metal or other hazardous substances. cles, to high temperatures, to bright light that could Appropriate engineering controls such as ventilation damage eyes (light both inside and outside of the may include a local exhaust hood or booth or visible spectrum), and to various gases. Old cutting portable local exhaust, such as a "snorkel" exhaust torches used pure hydrogen and oxygen, while system. Where ventilation or other engineering so- newer torches often use acetylene, propane, car- lutions are not completely effective or are not feasi- bide, gasoline-oxygen or other mixtures. (Nijkerk ble, employees must wear PPE (e.g., respiratory 2001) protection) to reduce their exposures to below the PEL. Compressed gases may be flammable and/or explo- sive or may present toxic or asphyxiant hazards if Eye protection, such as safety goggles or a welder's leaks occur. Compressed gas cylinders can also mask with appropriate shaded lenses must also be present explosion or missile hazards if exposed to worn by employees that perform welding or cutting excessive heat or physical damage. OSHA stan- activities (see 29 CFR 1910.133 for a list of appropri- dards at 29 CFR 1910, Subpart H establish general ate shade numbers for welding and cutting tasks). and selected substance-specific requirements for Employers should ensure that a competent person proper storage, handling, and use of compressed inspects all work areas where hot work will be done gasses. Additional requirements for compressed and should also ensure that employees are capable gasses used in certain types of welding and cutting of recognizing and avoiding hazardous situations. operations are provided in 29 CFR 1910, Subpart Q. Note, a competent person is an individual who through training or experience is capable of recog- The use of torches presents an obvious fire hazard. nizing hazards in the surroundings or working con- This hazard is of particular concern when working ditions and of identifying appropriate controls. on materials that have combustible or explosive components such as motor vehicles with plastics Case History #5 and fuel tanks, or objects with wooden interiors A 29-year-old scrap metal cutter died from injuries (Nijkerk 2001). Disc-cutting is sometimes used to cut sustained in an explosion. At the time of the inci- scrap metal objects, particularly where the heat and dent, the victim had been cutting a vehicle frame high temperatures of a gas torch would pose in- for salvage with a torch. He was working 8-to-10 creased fire safety hazards. feet from a 1,500-gallon storage tank. Escaping vapors from the tank were ignited by spatter from Gas torches also involve storage of flammable and the cutting activities, causing the tank to explode. explosive gases on site. Employers must store these The victim was engulfed in flames, igniting his gases in safe locations and ensure that all equip- clothing and causing burns over 45% of his body. ment is in good working condition (i.e., detached or The coworker extinguished the victim’s burning punctured hoses can create a safety hazard for clothing and helped him walk to the company’s nearby employees) (Nijkerk 2001). Employers must shop building. (NIOSH FACE, 98AK021) ensure that gas tanks are inspected, tested, and ap- propriately labeled while in storage and prior to Preventive/corrective measures: A competent per- movement and use. (NIOSH FACE; 29 CFR 1910.253) son should inspect all work areas where hot work will be performed prior to the start of the opera- Employers must ensure that employees use appro- tions. All flammable and combustible materials priate eye and face protection such as a welder’s should be removed from the area. If flammable helmet and heatproof and or aluminum lined cloth- or combustible materials cannot be removed ing to protect their bodies from the output of these from the area, employers must ensure that cutting operations, which have similar hazards to proper steps are taken to isolate the flammable or welding. combustible material from the heat generated by the torch. 10 Occupational Safety and Health Administration
torches are often used for superconductors of heat Applicable Standards or heat-resistant metals, such as alloy steels con- • 29 CFR 1910.106, Flammable and combustible taining nickel and/or chromium (Nijkerk 2001). liquids Plasma torches generate a large amount of smoke • 29 CFR 1910.132, General requirements and noise, as well as ultraviolet (UV) and infrared • 29 CFR 1910.133, Eye and face protection (IR) light. Depending on the metal, this smoke could • 29 CFR 1910.134, Respiratory protection contain toxic fumes or dusts. A discussion on the • 29 CFR 1910.135, Head protection potential chemical hazards and controls to reduce • 29 CFR 1910.136, Occupational foot protection exposures to these hazards can be found in the • 29 CFR 1910.137, Electrical protective devices “Recognizing and Controlling Hazards” chapter at • 29 CFR 1910.138, Hand protection page 16. However, where exposures exceed OSHA • 29 CFR 1910.147, The control of hazardous en- PELs, employers must install feasible engineering ergy (lockout/tagout) controls or work practices to reduce employee expo- • 29 CFR 1910.212, General requirements for all sures such as providing well-ventilated areas for machines such operations. In addition, the employer should • 29 CFR 1910.219, Mechanical power-transmis- place appropriate barriers around the process to sion apparatus protect other nearby employees from exposure to • 29 CFR 1910.242, Hand and portable powered the UV and IR light. Employees performing these tools and equipment (general) tasks must use appropriate PPE such as respirators, • 29 CFR 1910.243, Guarding of portable powered goggles or face shields with appropriate shaded tools lenses, and hearing protection, to prevent exposure • 29 CFR 1910.244, Other portable tools and to smoke, fumes, light, and noise. See 29 CFR equipment 1910.134 for OSHA's standard on Respiratory Pro- • 29 CFR 1910.252, General requirements (Weld- tection, 29 CFR 1910.95 for OSHA's standard on Oc- ing, Cutting, and Brazing) cupational Noise Exposure, and 29 CFR 1910.133 for • 29 CFR 1910.253, Oxygen-fuel gas welding and OSHA's standard on Eye and Face Protection. Note, cutting a list of appropriate lens shade numbers for welding • 29 CFR 1910.1000, Air Contaminants and cutting tasks is also provided in 29 CFR • 29 CFR 1910.1018, Arsenic 1910.133. • 29 CFR 1910.1025, Lead • 29 CFR 1910.1026 Hexavalent Chromium Employees using torches often spend long periods • 29 CFR 1910.1027, Cadmium of time in awkward or hunched postures, which may increase the risk of bodily injuries such as strains and sprains. Other hazards common to cutting oper- Sources of Additional Information ations (as well as to welding and brazing) include • OSHA Safety and Health Topics: Welding, Cut- burns, fires, explosions, electric shock, and heat ting, and Brazing, stress. Even chemicals that are generally not flam- http://www.osha.gov/SLTC/weldingcut mable may burn readily when vaporized. Larger tingbrazing/index.html scrap metal objects are often broken apart using sta- • OSHA Construction Safety and Health Outreach tionary shears, such as alligator shears used to cut Program: Safety and Welding, apart short steel for foundries or to cut nonferrous http://www.osha.gov/doc/outreachtrain metals. These machines can send small pieces of ing/htmlfiles/welding.html metal flying. Such flying object hazards may be con- trolled through the use of shields set up around the machines to protect employees. Eye protection and Non-Gas Torch and Other Cutting other body protection such as metal lined abrasion- Materials that require higher temperatures to cut, resistant protective clothing may also be needed in such as pig iron and heat-resistant alloyed scrap, or some cases. materials that conduct heat too well to be cut with thermal torches, such as copper and bronze, may be A larger concern than flying objects, however, is that cut with non-thermal methods such as plasma the operator often works quite close to the machine torches or powder cutting torches. These tools may and is subject to amputation or crushing hazards. In also be used where a gas torch could pose a safety the early days of using shears, it was not uncom- hazard, as discussed in the previous section. Plasma mon for an employee to lose a finger or a hand to G U I DA N C E F O R T H E I D E N T I F I C AT I O N A N D C O N T R O L O F 11 S A F E TY A N D H E A LT H H A Z A R D S I N M E TA L S C R A P R E CYC L I N G
the shears, or to have a hand trapped between pieces of scrap that were fed into the shears. (Nijk- which was still under pressure, closed upward on erk 2001) the victim. (NIOSH FACE, 02CA004) Hydraulic shears can be stopped instantly to prevent Preventive/corrective measures: Employees must damage to the machine or operator, whereas me- follow lockout/tagout procedures to de-energize chanical shears transmit force from a flywheel to the all equipment prior to cleaning or performing shears and cannot be stopped quickly in an emer- maintenance. gency. Hydraulic shears are, therefore, safer for the operator. Both types of shears, however, are still used in a variety of operations. Applicable Standards • 29 CFR 1910.147, The control of hazardous en- Modern alligator shears are often operated by a foot ergy (lockout/tagout) pedal that stops the shear immediately if released • 29 CFR 1910.212, General requirements for all (Nijkerk 2001). Employers can also use controls such machines as wrist straps (attached to cables) to keep employ- • 29 CFR 1910.218, Forging ees’ limbs a safe distance from moving parts. One • 29 CFR 1910.219, Mechanical power-transmis- way to distance shears from the operator is to attach sion apparatus the shears to a crane. In this setup, the operator sits • 29 CFR 1910.242, Hand and portable powered inside the cab of the crane and demolishes objects tools and equipment (general) or cuts pieces of scrap metal from a safe location. If • 29 CFR 1910.243, Guarding of portable powered the metal scrap is being cut from a building or other tools object high off the ground, remote operation also • 29 CFR 1910.244, Other portable tools and eliminates the safety hazards associated with work- equipment ing at heights. • 29 CFR 1910.252, General requirements (Weld- ing, Cutting, and Brazing) Hydraulic guillotine shears work similarly to alligator • 29 CFR 1910.1000, Air Contaminants shears and pose similar hazards: employees must remain at a safe distance from the point of operation so that no limbs or other body parts could contact Sources of Additional Information the cutting mechanism. Employers must install • OSHA Safety and Health Topics: Welding, Cut- shields around stationary cutting areas to protect ting, and Brazing, employees from flying objects. http://www.osha.gov/SLTC/weldingcut tingbrazing/index.html When a tough or complex piece of scrap damages a • OSHA Construction Safety and Health Outreach machine, that machine may be more likely to mal- Program: Safety and Welding, function and to pose a hazard to the operator and to http://www.osha.gov/doc/outreachtrain other nearby employees. As a result, machines ing/htmlfiles/welding.html should have periodic inspections and should be • OSHA 3170, Safeguarding Equipment and Pro- maintained in proper working order. For all types of tecting Employees from Amputations shears, employees must follow the company’s es- tablished procedures for de-energizing energy Baling, Compacting and Shredding sources and for lockout/tagout when performing Scrap metal is often compacted using balers to pro- servicing or maintenance tasks (see the OSHA Lock- mote efficient melting by allowing more metal into a out/Tagout standard at 29 CFR 1910.147). furnace than would be possible for a random assort- ment of sheeting and other scrap objects. Balers use Case History #6 powerful hydraulic systems to compact scrap metal. A 52-year-old welder was crushed to death by a Moving parts of balers must be shielded to prevent hydraulic door on a scrap metal shredder. The vic- body parts from coming in contact with the ma- tim was attempting to remove a jammed piece of chine. Car flatteners work on many of the same prin- metal from the hydraulic door when the incident ciples as balers and present similar hazards. occurred. Prior to removing the jam the victim did not lockout or de-energize the system. When the Balers are typically automated machines. This al- piece of metal was cut away, the hydraulic door, lows operators to stay a safe distance from the ma- 12 Occupational Safety and Health Administration
chinery, however, employees must still exercise cau- propriate guards must be installed to prevent em- tion when feeding raw material into a baler using a ployees from coming into contact with hazardous hopper or conveyor belt. Again, some sort of physi- moving parts of the machinery. This applies to the cal restraint such as railings may be appropriate to alligator and guillotine shears discussed above, and keep employees from falling onto these machines. also to other similar machines such as rotary shears and rotary shredders. For such equipment, employ- Some paper balers and shredders have sensors or ees need to stay a safe distance away from working heat detectors installed that react to human body machinery and take adequate safety precautions to heat and automatically stop all machine operations. minimize risks. Employers must install shields to For others, employees may wear magnetic or other block stray pieces of metal scraps from flying out devices on their belts that are linked to a safety in- from these machines and employees must be terlock system (Nijkerk 2001). Systems such as these trained to know what materials can or cannot be fed could be applied to some metal balers and shred- into the machine to prevent malfunctioning. ders to provide additional protection to employees (both from metal and from contaminants in the In addition to the physical hazards associated with scrap). Employees must be trained to understand baling, compacting and shredding, these processes the functioning and safety procedures of their equip- also produce significant amounts of dusts. These ment, and must follow procedures for adequate dusts, if not controlled, can present both explosion control of hazardous energy, particularly when per- hazards and inhalation hazards. Some ways to con- forming maintenance procedures on equipment. trol these hazards include: (NIOSH FACE; 29 CFR 1910.147) • Installing proper air cleaning systems on shred- Case History #7 ding machines. A 34-year-old laborer died after falling into an op- • Installing explosion sensors where appropriate to erating paper baler. The victim and a coworker inject water to suppress explosions. were loading scrap paper into an automatically • Operating machinery at lower speeds to reduce operated paper baler via a belt conveyor. The vic- dust generation. tim ascended to a platform located between the • Introducing an inert gas to rotary shears to re- conveyor discharge and the feed chute of the duce the risk of explosion. (Nijkerk 2001) paper baler to clear jammed material. Before as- • Providing supplemental ventilation where cending, the victim had asked the coworker to needed and perhaps respiratory protection to shut down the conveyor so that he could clear protect employees from exposure to hazardous the jam. After shutting down the conveyor, the dusts. coworker turned away to get more paper. The • Using wet or semi-wet shredding processes. victim fell into the baling chamber and the baler ram automatically activated. (NIOSH FACE, 9715) Some scrap materials such as scrap vehicles or re- frigerators may contain fuels or other materials that Preventive/corrective measures: Employees introduce additional hazards to the process. Opera- must follow lockout/tagout procedures to de- tors must be sure to remove these materials before energize all equipment prior to cleaning or per- introducing the scrap to process machinery. For ex- forming maintenance. Employers must install ample, gasoline must be removed from the gas tank guards on machinery to prevent any employees of scrap automobiles before compacting or shred- from contacting moving parts. Where access to ding the automobile. In addition, chloroflourocar- process machinery is necessary, employers bons (CFCs) and ammonia must be removed from should consider installing standard railings air conditioning systems to prevent employee expo- using gates interlocked with the machine's con- sure to these irritants and to prevent the release of trol system. When the gates are opened, the ma- these gases to the atmosphere. Removal of CFCs chine will shut down. also applies to shredding of refrigerators. Many of the processes above use large amounts of For all equipment where pieces of scrap metal are electricity to operate. Employees must be aware of fed into a machine directly, or using a hopper, or the hazards of working in high-voltage environ- even via conveyor belt, employees must be trained ments and should take appropriate precautions. All in the proper use of the equipment. In addition, ap- equipment power systems must be covered with G U I DA N C E F O R T H E I D E N T I F I C AT I O N A N D C O N T R O L O F 13 S A F E TY A N D H E A LT H H A Z A R D S I N M E TA L S C R A P R E CYC L I N G
non-conducting covers that require a tool to re- oxides, and carbon monoxide and carbon dioxide. move. High-voltage areas must be protected to pre- Organic compounds may be emitted as heating va- vent access to unauthorized individuals. Employers porizes oil and grease on scraps (EPA 2001). In addi- must create a lockout/tagout program and train em- tion, heating or burning of certain plastics (such as ployees on proper implementation of these proce- plastic-coated wiring) may release phosgene or dures. other hazardous substances. Emissions from fluxing typically include chlorides and fluorides. The highest Applicable Standards concentrations of ‘fugitive’ emissions (i.e., gases • 29 CFR 1910.147, The control of hazardous en- and vapors that escape from equipment) occur ergy (lockout/tagout) when the lids and doors of a furnace are opened • 29 CFR 1910.212, General requirements for all during charging, alloying, and other operations (EPA machines 2001). Employers should ensure that workplaces are • 29 CFR 1910.219, Mechanical power-transmis- well-ventilated, consider the use of local exhaust sion apparatus ventilation during these operations, and that emis- • 29 CFR 1910.1000, Air Contaminants sions from furnaces are filtered before the air is re- leased outside the facility. Melting and Baking in Furnaces Afterburners can be used to control organic com- and Ovens pounds, carbon monoxide, chlorides, fluorides, and Many scrap metal recycling operations heat scrap hydrochloric acid; fabric filters can be used to con- pieces to high temperatures to separate different trol metal oxide dust, chlorides, fluorides, and hy- metal components, increase the purity of scrap, drochloric acid; wet scrubbers can be used to bake out non-metal substances, burn off contami- control metal oxide dust, sulfur oxides and sulfuric nants, remove insulation from wire, or otherwise acid mist; and electrostatic precipitators or fabric fil- process the metal scrap (EPA 2001). This may be ters can be used to control particulate or other mat- done using furnaces or ovens that use fuel or electri- ter. These are used in different setups depending on cal heating sources. the specific recycling industry. EPA (2001) discusses control methods for some recycling industries. For a Employees near operational furnaces are exposed full listing of hazardous air pollutants associated to hazards even if they do not work directly with the with some metal recycling processes, such as alu- furnace. Heating scrap will generate metal fumes if minum production, lead smelting, iron foundries the furnace temperature is above the melting point and steel foundries, see EPA’s Emission Inventory of any of the metals in the furnace. In addition, hot Improvement Program (EIIP), Vol. II, Table 9.2-1. pieces of metal could jump from the furnace, creating (EPA 2001) fire or burn hazards to nearby locations or people. For information on ventilation, refer to the “Exam- Similar to many of the processes already discussed, ples of Engineering and Work Practice Control Tech- electrical furnaces use large amounts of electricity at niques to Reduce Emissions” section at page 29. high voltages to melt the metal scrap. Employees near these furnaces could face an electrocution haz- ard if they come into contact with a furnace in an Case History #8 unsafe manner. Employers must ensure that furnace A 22-year-old male foundry laborer was electro- refractories are kept in good condition and that em- cuted when a piece of scrap metal he was loading ployees follow electrical safety guidelines. Employ- into a damaged electric induction furnace became ers should ensure that there is sufficient room for energized. The refractory had developed an un- employees to work safely in the vicinity of energized usual degree of cracking, and molten metal furnaces. For example, an employer may establish a seeped out of the refractory and solidified. This maximum scrap metal size and weight for each type material was in contact with the frame, but not (and size) of furnace that they operate. (NIOSH the coil. Two employees lowered the scrap into FACE) the furnace, which already contained molten steel. The victim was resting his thighs on the top Furnaces generate smoke, dust, and metal fumes, edge of the frame. The furnace was jarred, and depending on temperature and content. Combus- presumably more molten metal was released tion by-products may include sulfur and nitrogen through the cracks, completing the circuit be- 14 Occupational Safety and Health Administration
• The resulting forms of these materials following tween the coil and the contents of the refractory. any reaction. Current passed through the piece of scrap, the • By-products. victim’s body, and to ground through the frame. • Special cleaning agents. (NIOSH FACE, 89OH43) • The equipment used for the process. Preventive/corrective measures: Employers As with every hazardous chemical introduced into should institute a regular inspection and mainte- the workplace, all employees who are potentially ex- nance program for all of their equipment. When posed must be trained in the hazards associated problems with equipment arise, the equipment with that chemical category. This requirement and should be tagged and removed from service until other provisions of OSHA's Hazard Communication it is repaired. standard (29 CFR 1910.1200) are discussed in the “What You Need to Know about Hazard Communi- cation” section of the “Recognizing and Controlling Applicable Standards Hazards” chapter of this guide. • 29 CFR 1910.147, The control of hazardous en- ergy (lockout/tagout) The most probable emissions from these processes • 29 CFR 1910.212, General requirements for all include metal fumes and vapors, organic vapors, machines and acid gases. Other potential hazards may include • 29 CFR 1910.219, Mechanical power-transmis- high amounts of heat, splashing of caustic or other- sion apparatus wise hazardous chemicals, or combustion hazards. • 29 CFR 1910.1000, Air Contaminants Employers should be knowledgeable about the • 29 CFR 1910.1018, Inorganic Arsenic processes that are used in their recycling operations • 29 CFR 1910.1025, Lead and should refer to MSDSs to obtain specific infor- • 29 CFR 1910.1026, Hexavalent Chromium mation regarding potential exposure to any other • 29 CFR 1910.1027, Cadmium substances used in recycling processes. Employers must comply with OSHA PELs. They may also want to consider other recommended exposure limits Sources of Additional Information (such as National Institute for Occupational Safety • OSHA Construction Safety and Health Outreach and Health (NIOSH) Recommended Exposure Limits Program: Safety and Welding, (RELs)) for the chemicals used or produced in these http://www.osha.gov/doc/outreachtrain processes. ing/htmlfiles/welding.html • EPA (2001) Emission Inventory Improvement One common process involves the use of aqua regia Program (EIIP), Vol. II, Table 9.2-1. solution to remove gold from gold-plated objects. Aqua regia is a mixture of two corrosive acids. This process emits acid fumes that are dangerous to in- Applying Chemical Processes to hale. Employers using aqua regia or similar solu- Recycle Metals tions (cyanide may also be used) must implement Chemical processes are also used in a wide range of feasible engineering controls, such as a fume hood metal scrap recycling industries as a means to sepa- to remove fumes from the workspace. Employers rate scrap into its component metals, to clean scrap must also ensure that employees wear gloves and metal prior to using physical processes, to remove an apron to prevent skin or eye contact with the contaminants (such as paint) from scrap material, or aqua regia solution. Not all glove and apron mate- to extract selected metals from a batch of scrap con- rials protect from all corrosive substances, so taining many metal types. Chemical processes may employers need to pay special attention to the capa- include high-temperature chlorination, electrorefining, bilities of the PPE used. For additional information plating, leaching, chemical separation, dissolution, re- on PPE, refer to the “Personal Protective Equip- duction, or galvanizing. Each of these processes may ment” section in the “Recognizing and Controlling present specific safety and health hazards associated Hazards” chapter of this guide. with how the process is carried out, as well as specific material hazards associated with: After smelting or separation, metal may be refined • The starting reagents for the process. in an electrolytic process in which anodes from the G U I DA N C E F O R T H E I D E N T I F I C AT I O N A N D C O N T R O L O F 15 S A F E TY A N D H E A LT H H A Z A R D S I N M E TA L S C R A P R E CYC L I N G
smelting process are placed in an electrolytic cell that contains a cathode and an electrolyte such as Sources of Additional Information sulfuric acid; the metal is deposited on the cathode. • OSHA Safety and Health Topics: Sampling and In such operations, employees must be aware not Analysis, http://www.osha.gov/SLTC/sampling only of the hazards posed by the acid used as the analysis/index.html electrolyte and the metal involved but also of the • EPA Emission Inventory Improvement Program, hazards posed by the electrical system. Volume II, Chapter 9: Preferred and Alternative Methods for Estimating Air Emissions from Secondary Metal Processing. (EPA 2001) Applicable Standards • 29 CFR 1910.147, The control of hazardous en- ergy (lockout/tagout) Metals that OSHA Regulates • 29 CFR 1910.212, General requirements for all OSHA regulates the workplace exposure to many machines toxic metals and their oxides. These metals are • 29 CFR 1910.219, Mechanical power-transmis- listed in 29 CFR 1910.1000 along with employee ex- sion apparatus posure limits and include the following: • 29 CFR 1910.1000, Air Contaminants • 29 CFR 1910.1200, Hazard Communication Table 1. OSHA-Regulated Toxic Metals Aluminum Hafnium Silver Antimony Iron Tantalum Recognizing and Controlling Arsenic Lead Tellurium Barium Magnesium Thallium Hazards Beryllium Manganese Tin Bismuth Mercury Titanium How to Determine the Hazard Levels of Boron Molybdenum Uranium Various Processes Cadmium Nickel Vanadium Metal scrap recycling operations present a wide va- Calcium Osmium Yttrium riety of hazards, including health hazards associated Chromium Platinum Zinc with chemical exposures and safety hazards associ- Cobalt Rhodium Zirconium ated with material processing operations and the Copper Selenium equipment used in these tasks. This section dis- cusses the metals that may present hazards to em- OSHA also has comprehensive substance-specific ployees in recycling operations, the exposure routes standards for hexavalent chromium (29 CFR through which employees may be exposed to that 1910.1026), arsenic (29 CFR 1910.1018), cadmium metal and the potential health effects from that ex- (29 CFR 1910.1027), and lead (29 CFR 1910.1025). posure. This section also addresses other chemical Each of these standards establishes workplace PELs hazards of special note (e.g., metalworking fluids as well as specific requirements for personal moni- and radioactive material), and discusses ways that toring, medical surveillance, engineering controls, employers and employees can identify and control respiratory protection, and training. these hazards. Finally, the section discusses some ways that employers and employees can decrease Many of these metals do not pose any hazard to the risks of employee exposure to these hazards. people who handle objects containing the metal in There is little data available to describe the level of everyday use. In fact, low levels of many of these el- air contaminants associated with specific metal ements are needed for the human body to function. scrap recycling operations. Employers and man- However, hazards exist when these metals are agers need to analyze the levels of various haz- ground, blasted, roasted, or melted and fumes or ardous substances directly, using personal and area metal dusts are produced and distributed in the air. monitoring devices to assess employee exposures. Each of these metals may create health hazards to After doing this, employers must comply with all employees recycling scrap that contains even trace OSHA standards. Employers may also want to con- amounts of that metal. sider recommendations by NIOSH (i.e., RELs) to de- termine the need for additional controls (e.g., Employers can typically determine the level at which engineering controls, PPE). a metal (or other hazardous chemical) poses a haz- 16 Occupational Safety and Health Administration
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