Coming clean on chemicals: recent legislation requires metalcasters to report to the government on the chemicals in their plants

Modern Casting, March, 2008 by Shea Gibbs

It was about four weeks before Halloween in 2006 when the use of a single word removed a disguise that lay over many of the nation's chemical-holding facilities. Before the word was invoked, manufacturers were able to keep the chemcicals in their plants hidden and undisclosed to authorities.

On Oct. 4 that year, the Bush administration signed into law the Department of Homeland Security Appropriations Act of 2007. Lawmakers wrote in Section 550 of the bill that it would establish "risk-based performance standards for security of chemical facilities."

Security. Past laws had spoken about the regulation of chemical facilities by the government. But here, for the first time, the administration was taking upon itself the responsibility of assuring chemical-holding facilities remain secure.

Now, in the face of international terrorism, metalcasting facilities have been unmasked as potential national security threats. The industry must come under compliance by reporting certain chemicals that are present in its facilities at a given level to the U.S. Department of Homeland Security (DHS). Otherwise, it could face as yet undetermined penalties.

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Reconnaissance and Reporting

Metalcasters must become chemically unmasked immediately. The deadline to comply with the new reporting requirements passed on Jan. 22.

But this is no reason to go into hiding if you haven't already come forward. Companies that contain a chemical deemed to be hazardous in amounts greater than the minimum allowed still can report without repercussions. The project will be ongoing, according to environmental consulting firm Keramida Inc., Indianapolis. Failing to report, however, could be met with an unexpected audit, which could in turn lead to penalties.

The first step for any company that handles chemicals--this tends to include most metalcasters, particularly those that employ chemical binders and resins in their sand system--is to determine whether it might fall under the jurisdiction of the law. The facilities must look over a list of cited substances and compare it with the contents of their plant. If any chemical listed is also found in a certain quantity in the building, the company must complete what is known as a top screen.

"We followed the DHS guidelines for completing that process, which we found to be pretty straightforward, and provided the data requested by the deadline," said Mark Remlinger, manager of environmental safety and health, Matthews International, Pittsburgh. "Now, we're going to wait for input and at that point determine if we would be considered a high risk facility."

After a metalcasting facility has completed a top screen, the ball is in DHS's court. The department will rank all of the facilities that report according to a tiered system, going from tier 1 to 4. High risk facilities will be assigned to the bottom of the scale, and lower risk plants will be at the top. Only time will tell what the requirements for high risk will be. The more difficult part of the process, though, will be determining whether your facility should complete a top screen in the first place. The list of chemicals (available online) is nearly seven pages long.

Matthews, for example, is unlike most metalcasters. The company operates more than 20 manufacturing facilities, only one of which casts metal. In its various industries, the company uses more than its share of potentially volatile chemicals. The need for a top screen was a no-brainer. But its metalcasting facility, which produces bronze castings in green sand, turned up no red flags. On its own, it would not have had to submit a top screen. So where does that leave your average, stand-alone metal pourer?

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Disaster in Your Plant?

In defense of the new regulations, Congress harkens back to a 1984 chemical disaster in India in which 3,800 were killed. The offending chemical in that case was isocyanate gas. While a metalcaster will have a hard time relating to this incident, that doesn't let them off the hook.

To determine whether a top screen is necessary, consider the chemicals common to a metalcasting facility that are in the government appendix, as well as those that have escaped attention.

"Two of the big hitters that are not on the list, which is fortunate, are [triethylamine] and [dimethylethylamine]," said Kristen Belcredi, senior vice president, sustainability services for Keramida. "But the ones that we are running into that have made some facilities reportable are propane and the chemicals contained in some of the resins and binders. That can be a lot of different chemicals, so I've just been advising clients to look at their resins and binders. Formaldehyde has come up a lot."

List notables nitrocellulose, hydrogen peroxide, acetaldehyde, aluminum powder, dimethylamine and potassium nitrate all are common in metalcasting facilities, appearing in paints, resins, coatings, pigments, oxidation systems and risers. Belcredi also suggests you look at the chemicals in your wastewater treatment system, such as sulfur dioxide.