C-17 Pollution Prevention Regulatory Outlook

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C-17 Pollution Prevention Regulatory Outlook
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Major ESOH Issues -

• Revised OSHA Hexavalent
• Chromium Standard
• Revised OSHA Crystalline Silica Standard
• Revised OSHA Beryllium Standard

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• Hexavalent Chromium (CrVI)
• Widely used for its corrosion inhibiting
  properties
• Used on many aerospace parts affecting product
  longevity and flight safety
• Used in aerospace primers, sealants, surface
  treatments and plating
• Manufacturing methods include primer
  application, sanding, chrome plating chromic
  acid anodizing
• Potential exposure operations
• spray coating, coating removal, scuff sanding,
  welding, electroplating, anodizing, surface
  preparation

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• Hexavalent Chromium (CrVI)
• Health concerns - human carcinogen dermatosis
• OSHA (under court order) proposed revised
  standard on 4 Oct 04 with final rule due by 18
  Jan 06
• Proposal would reduce PEL from 52 ?g/m3 to 1.0
  ?g/m3 (TWA)
• Action level proposed at 0.5 ?g/m3 requiring
  increased exposure monitoring and medical
  surveillance
• Employee awareness training required at any
  exposure

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• Hexavalent Chromium (CrVI)
• OSHA proposal would require -
• Record keeping
• Areas that exceed PEL would require
• warning signs
• engineering and work access controls
• employee washing facilities
• employee change rooms clothing storage

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• Hexavalent Chromium (CrVI)
• OSHA proposal would require
• Employees in areas exceeding PEL would require
• exposure monitoring every 3 months
• specific training (hazcom) to avoid exposure
• respiratory protection
• protective clothing eyewear
• medical surveillance

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• Hexavalent Chromium (CrVI) Timeline

2003
2004
2005
2006
2007
2008
Rule Development
Comments Public Hearings
Most Provisions
Change Rooms
Engineering Controls
Proposed Compliance Deadlines
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• Hexavalent Chromium (CrVI)
• CONCLUSION
• Enhanced and accelerated desire to qualify and
  approve non-chromated replacement materials and
  processes which would reduce exposures to
  employees and the environment as well as
  eliminate the higher costs of compliance required
  by a revised CrVI standard.

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• Crystalline Silica
• Widely used by many industries in many
  materials
• Used in some aircraft coatings as a flattening
  agent to provide better coverage during
  application
• Concentrations in coatings range from 5 to 30
• Potential aerospace exposure operations
• surface preparation, scuff sanding, drilling and
  de-painting operations
• Health concerns - silicosis lung cancer
  (generally due to long-term exposure of 10
  years)

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• Crystalline Silica
• OSHA considering rulemaking to revise standard
• Potential PEL decrease from formula based
  standard 10 mg/m3 (quartz2) to 50 ?g/m3
• OSHA scheduled to complete peer review of risk
  assessment in early 2005
• Proposed rule possible late 2005 or in 2006

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• Beryllium (Be)
• Alloys used in structural material for high
  performance aircraft, missiles, spacecraft
  and satellites found in aircraft landing gear
  assemblies and in some electrical connectors
• Desirable Chemical/Physical properties
• Strong, light-weight
• Heat dissipating
• Neutron absorption
• Health Concerns
• Acute Beryllium Disease - Pulmonary
  inflammation
• Beryllium Sensitization - Immune response to
  beryllium
• Chronic Beryllium Disease (CBD) - Progressive
  lung disease
• Lung Cancer
• Skin granuloma (inflamed tissues)

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• Beryllium (Be)
• Dust producing exposures through sanding,
  grinding, honing, abrasive sawing blasting and
  electro discharge machining
• OSHA petitioned by unions and public interest
  groups to lower PEL from 2 ?g/m3 to 0.2 ?g/m3
• OSHA collecting risk assessment information
• No timetable established for a proposed rule