Wastewater Management – Metal Finishing

Rochester Institute of Technology

Industrial Wastewater Management

Metal Finishing

Ian Madison and Jacqueline Jordan

Industry Description

Industry Profile

The SIC code for metal finishing is 3471. There are many industries that use metal finishing in the process of creating their product. Metal finishing is an industry that has many divisions. The six main operations covered by metal finishing regulations are: electroplating, electroless plating, anodizing, coating (chromating, phosphating and coloring), chemical etching and milling, and printed circuit board manufacture. All of these processes create forms of pollution. There are reportedly 267 metal finishing shops in New York State (Sharon E. Rehder, 2000). Most of these shops in NYS are small businesses; almost half have less than 10 employees. Rehder reasons that most of the waste coming from metal finishing in NYS come from small businesses, possibly far more than reported; this is in contrast to most other industrial sectors which have a few large, well-known sources.

Water pollution is discussed in this paper. Many chemicals are used in the processes used to finish metal, whether it is plating, polishing, anodizing or coloring. One of the most disturbing reports regarding the businesses in NYS and the toxic chemicals they release is the Toxics Release Inventory (TRI). According to Rehder, only 29 of the 267 known metal finishers in the state have filed a TRI, and the amount reported to have been released is “315,156 pounds of hazardous substances to the environment”. There were no reports filed by the other 238 metal finishers, possibly due to being small enough of a business to not be required to report. However, collectively, the amount of toxic chemicals being released is significant.

Typical Processes and Products

There is a large variety of businesses that fall into the category of metal finishers. The products are diverse, widespread and used by everyone in some capacity or another. All the chrome on your vehicle starts out as either a dull metal or plastic piece. It gets coated with chromium to produce that shiny look that everyone is accustomed to seeing on their car or truck. Many other parts on autos have finished surfaces; the automotive industry is listed as the highest metal finishing industry, at 40% according to the Illinois Sustainable Technology Center. There are many types of finishing processes used: electroplating, electroless plating and immersion plating, chemical and electrochemical conversion, cladding, case hardening, dip/galvanized, electropolishing, vapor deposition, painting,  along with finishing  produced by machinery. A corporation that uses metal finishing on almost all its products is the Ingersoll Rand. The I-R has been a major supplier of power tools since 1871 (IR, 2012). Simon Ingersoll invented the first rock drill which was used in the building of the Hoover Dam and the sculpture of Mount Rushmore. Each individual metal part that went into the production of that rock drill and every power tool manufactured since has had its surface finished.  Metal water buckets are galvanized with a zinc process to prevent the water from rusting the bucket. Jewelry’s metallic surfaces, medical instruments, mechanical tools, electronics all have finished surfaces. If you think of the many metal surfaces in your home and office, they have all been finished in some manner to provide corrosion, wear, tarnish, chemical or electrical resistance; electrical conductivity or reflectivity and appearance.

Environmental Impacts

In addition to the effluent waste water flow, these metal finishing sources can have a negative impact on the environment through several different mediums. Electroplating can introduce Hexavalent chromium into the air which can have a delayed impact on employees, animals, and civilians who come in contact with this effluent flow. In addition to the air impacts, Hexavalent chromium can exist in the shallow soil long after metal finishing processes have ceased. This can be spread through ingestion of animals who have come in contact with the soil or direct contact. Hexavalent chromium is a well documented carcinogen and plays a vital role in proper planning for effluent flows in this industry. The presence of one or multiple RCRA 8 metals (Ag, Ba, Cd, Cr, As, Pb, Hg, Se) is also highly plausible in either a solid or airborne medium. All of these poisonous or carcinogenic metals can exist in the air or soil and can have chronic or acute effects on people that ingest, absorb, or inhale. These metals are frequently the focus of environmental investigations and can inflict high remediation costs due to their presence in air, soil, or groundwater.

Regulations

40 CFR Part 433 Subpart A (EPA, 1983) regulates effluent water from industries that use processes to finish metals. There are 119 toxic organics listed in §433.11(e) which are regulated in quantifiable sums > .01 mg/L. The discharger must test their effluent to determine if their processes create waste from any of these Total Toxic Organics (TTO). Best Practicable Control Technology (BPT) or Best Available Technology (BAT) must be utilized in regards to effluent limitations on up to twelve pollutants or pollutant properties (U.S., 2012). Cyanide is addressed as a separate pollutant altogether. Additionally, Pretreatment Standards for Existing Sources (PSES) apply for nine effluent pollutants. There are also standards that cover New Source Performance Standards (NSPS) as well as Pretreatment Standards for New Sources (PSNS). The common pollutants addressed in all effluent are Cadmium, Chromium, Copper, Lead, Nickel, Silver, Zinc, Cyanide and TTO. Three more considerations that need to be  addressed prior to discharge are Oil and Grease, TSS and pH. In NYS, the Department of Environmental Conservation has EPA approved programs that dischargers must follow (DEC, 2007).

Pretreatment Standards

Pretreatment of wastewater before discharging the water to a POTW is required. Because the water is treated prior, the industry user is considered an indirect discharger. This protects the POTW from wastes created by the industry that could cause damage or danger at the POTW. It also places the responsibility for the costs of treating the water onto the business creating the waste instead of the municipality that is operated on public tax money. Some pollutants could interfere with the operation of the POTW. Another potential problem is that the waste being discharged may not be a common pollutant that the POTW is set up to monitor for. Pretreatment also improves the POTW’s ability to recycle wastewater and sludge. The indirect discharger must abide by limits of pollutant levels set by both the federal, state and local governments as well as the POTW. Normally, the federal standards are the guidelines used by other agencies or municipalities. Title 40 Part 403 outlines the general pretreatment standards for existing and new sources of pollution.

Metal finishing facilities’ pretreatment standards are specifically controlled under 40 CFR Part 433. Some pollutants are prohibited; these are ones which could create an explosion, cause corrosive damage, obstruct flow, introduce excessive heat or release toxic gases. In lieu of testing for Total Toxic Organics, the owner or responsible person may sign a statement in the comments section of the discharge monitoring report (DMR) stating that to their knowledge, no concentrated dumping of toxic chemicals has occurred since the last DMR. Under this statement, when monitoring samples are needed to remain in compliance, only analysis for the pollutants that would be reasonably suspected need to be done. If certain pollutants are added to or are produced by the process of the individual business, they can be reasonably accurate in assuming what goes into the process must come out.

There are two types of technology-based limitations that are addressed in the regulations for metal finishers. The first one is Best Available-Based Limitations. These limits are used for businesses that may be older and not equipped with technology suited to pre-treat as well as newer facilities. Therefore, the economics of updating the facility are factored. The financial hardship of upgrading may be great enough to close the business. The goal of the regulations is to protect the environment and the POTW within reasonable efforts on the part of the businesses; it is the best equipment available to them. The second, is Best Practical Technology which is used for newer facilities that are utilizing the most recent equipment currently available. BPT has additional pollutants to test for that BAT does not; oil and grease, total suspended solids and pH. While this may not seem justified to allow older facilities to not take certain pollutants into consideration, these facilities may have larger maintenance on their equipment as the FOG and TSS not being considered in the beginning of the process. This will lead to the need to replace equipment sooner, at which time the newer technology will provide for the removal of these pollutants.

Another set of categories for dischargers is pre-treatment standards for new (PSNS) and existing (PSES) facilities.  Those effluent limits are the same as in Table 1 with the exception of the limits for Cadmium in new facilities has been decreased to 0.11 mg/L daily and 0.07 mg/L average monthly. The PSES also does not set limitations on FOG, for the same economical factors stated for BAT.

Table 1  BAT and BPT Discharge Limits

Title 40 Section 433.13 and 14
	BAT Discharge Limits		BPT Discharge Limits
Pollutant	Daily Max mg/L	Monthly Max Avg. mg/L	Daily Max mg/L	Monthly Max Avg. mg/L
Cadmium	0.69	0.26	0.69	0.26
Chromium   Total	2.77	1.71	2.77	1.71
Copper	3.38	2.07	3.38	2.07
Cyanide   A*	0.86	0.32	0.86	0.32
Lead	0.69	0.43	0.69	0.43
Nickel	3.98	2.38	3.98	2.38
Silver	0.43	0.24	0.43	0.24
Zinc	2.61	1.48	2.61	1.48
TTO	2.13		2.13
Oil   & Grease			52	26
TSS			60	31
pH			6.0 –   9.0	6.0 –   9.0
*   Amenable to alkaline chlorinization as opposed to Total Cyanide

Source: Title 40 Section 433.13 and 14

Sampling

Appendix E of Part 403 gives directions on two types of sampling procedures; composite and grab methods. Composite entails using samples taken over the course of a 24-hr span that will be mixed together in order to get a reading of the average pollutants. Grab samples are individual samples. Samples of both influent and effluent water should be taken. The influent samples allows the lab providing analysis for how much treatment additives and detention time may be necessary for the WWTP to successfully remove the various pollutants. The effluent samples determine if the water is under the limits allowed for water being discharged.

Application Process for SPDES Permit

Under the Clean Water Act, the federal government of the U.S. enacted the National Pollutant Discharge Elimination System. This set of regulations control all discharges of water, whether it be stormwater or discharges to municipal storm/sewer systems. New York State operates an EPA approved program, the State Pollution Discharge Elimination System (SPDES). There can be general permits, which cover stormwater or an industrial permit, which covers both stormwater and point source discharges. The metal finishing industry falls into Sector AA for Fabricated Metal Products. Part of the requirements for having a SPDES permit is the development of a Stormwater Pollution Prevention Plan (SWPPP). The SWPPP must have a site description that includes a site map, a section on spills and leaks and summary of potential pollutant sources. Areas for metal finisher businesses to consider when creating their SWPPP may include:

• Spills or leaks from containers of chromium, toluene, pickle liquor, sulfuric acid, zinc and other priority or hazardous chemicals
• Storage of raw materials, paints, empty containers, corn cob, chemicals, scrap metals, outdoor manufacturing, grinding, cutting, degreasing, buffing, brazing, spent solvents, sludge, shavings, ingots pieces, refuse and waste piles.

Stormwater controls such as good housekeeping, spill prevention and response procedures, inspections and comprehensive site compliance evaluations must be part of the SWPPP. While process wastewater is a major consideration, it is also critical to control pollutants that could be accidentally spilled or picked up by stormwater because this water may not be separated from piping that carries sewer water to the local POTW. Some areas of concern in the metal finishing industry are the following:

• Metal fabricating areas – kept clean and dry
• Storage areas for raw metal – measures to prevent spill or leakage of materials
• Receiving, unloading and storage areas – clean up procedures
• Storage of equipment – covers, storing indoors, clean up of pollutants if outdoors
• Metal working fluid storage areas – describe and implement measures for storage
• Cleaners and rinse water – control/cleanup (sandblasting, solvents, recyclable wastes)
• Lubricating oil and hydraulic fluid operations – leak detection, overflow, controls
• Chemical storage areas – prevent stormwater contamination, accidental spillage

The SPDES permit gives guidelines for which certain pollutant levels must be reported to the NYS DEC on an Annual Discharge Monitoring Report. Table 2 addresses these pollutants and their respective limits.

Table 2  Sector AA – Benchmark Monitoring Requirements

Sector AA – Benchmark Monitoring Requirements
Pollutant of Concern	Analytical Method	Benchmark Monitoring Cut-Off Concentration
Fabricated   Metal Products Except Coating (SIC 3411-3471, 3482-3499, 3911-3915)
Total   Nitrogen	EPA 350.1, 351.2, 353.2	6 mg/L
Total   Recoverable Aluminum	EPA 200.7	750 ug/L
Total   Recoverable Iron	EPA 200.7	1 mg/L
Total   Recoverable Zinc	EPA 200.7	120 ug/L

Source: NYS DEC SPDES Multi-Sector General Permit (GP-0-06-002) page VIII.AA – 3

These limits are not to be confused with the limits set forth for the pre-treatment limits for discharge to a POTW. These are separate guidelines and both set of limits must be followed. These requirements are  what the NYS DEC expects to be monitored prior to discharge to either a NYS body of water or to a stormwater/sewer system.

After the SWPPP has been developed, and before discharging, a Notice of Intent or Termination (NOIT) must be filed with the NYD DEC. This form contains information about the company. The NYS DEC can use this information to know what to expect from this particular site. They will in turn mail out forms needed to be returned to the DEC at various intervals depending on the individual business. One of the forms required to be returned is the Annual Discharge Monitoring Report (DMR). The above pollutants of concern will be listed on the DMR. Other factors may be mass loading, concentrations, sample type and frequency of sample. If there are concentrations above the limits, explanations are to be made in the Comments section.

Typical Wastes from Metal Finishing Processes

Each operation is unique in exactly what process they are performing and what the end product is. The system by which metal finishing follows has similar sequence. There are rinse tanks, ventilation systems, acid cleaners/acid etchers, and alkaline cleaners (Fister, 2010). One of the largest expenses comes from cleaning/rinse water. After each process, the metal is cleaned with water. Table 3 shows the amount of pollutants for common processes used in metal finishing (EPA, 1982). These pollutants end up in the wastewater.

Table 3 Typical Waste Characteristics of Metal Finishing Operations

Unit   Operation	Waste   Characteristics							Total #   of Pollutants	Total #   of In-organic Waste	Total #   of Organic Waste
	Inorganics					Organics
	Common   Metals	Precious   Metals	ComplexMetals	Cr6	Cyanide	Oils	Solvents
Cleaning	1	1	1	1	1	1	1	7	5	2
Heat   Treating	1				1	1	1	4	2	2
Electrochemical   Machining	1				1	1	1	4	2	2
Tumbling	1			1	1	1		4	3	1
Burnishing	1	1			1	1		4	3	1
Electroplating	1	1		1	1			4	4	0
Electroless   Plating	1	1	1		1			4	4	0
Conversion   Coating	1	1		1	1			4	4	0
Etching   (Chemical Milling)	1	1	1	1				4	4	0
Polishing	1	1				1		3	2	1
Machining	1					1		2	1	1
Grinding	1					1		2	1	1
Impact   Deformation	1					1		2	1	1
Pressure   Deformation	1					1		2	1	1
Shearing	1					1		2	1	1
Other   Abrasive Jet Machining	1					1		2	1	1
Electrodischarge   Machining	1					1		2	1	1
Anodizing	1			1				2	2	0

Source: National Service for Environmental Publications Table 4 – 2 pg. IV – 4 (EPA)

Wastewater Contaminated by Metal Finishing

Each site has unique properties which require analysis of the components in the process water that will be sent for treatment prior to discharge. Even within like industries or even industries that have the exact process and are owned by the same company will still have variations. Therefore one of the most important processes is the initial analysis, and careful monitoring thereafter. Depending on fluctuations in the process giving off waste water will dictate how often monitoring needs to be done. In an ideal situation, the WWTP will run almost at an automatic procedure, however it is wise to test the water periodically and record the results to ensure compliance with the limits.

Treatment Processes

Metals in wastewater stemming from metal finishing are most often soluble and or suspended in the water. In order to remove the metals that are basically floating in the water, the goal is to get the metals to become insoluble and then attract to each other so larger aggregated materials start to form. In order to turn the metals from soluble to soluble, a couple different directions can be taken. The solubility of metals are pH dependent. The first step is to use chemical precipitation. Metals can be precipitated out as hydroxides, carbonates or sulfides. Generally, hydroxide precipitation is the direction that most metals react best as. The metals in the water are atoms or groups of atoms that have electrical charges. These “ions” of metal can be cationic (positive), anionic (negative) or neutrally (nonionic) charged (EPA, 2000). Next, coagulation and flocculation is utilized. Polymers are often used to coagulate metals. The polymers act as bridges between the metal ions, grouping them together. Flocculation is a continuance of the coagulated materials into bigger clumps. The water then goes through clarification. Because the pH is adjusted greatly during the treatment process, the pH is balanced before discharge. Finally, the sludge is dewatered. The water from the sludge is sent back through the process due to the possibility of particles passing through at this stage. This is a very generic description of the process. Each wastewater from metal finishing is very unique.

Contaminants Other Than Metals

In the metal finishing industry, most often there is oil and grease involved in the wastewater. Generally, in many metal finishing processes, oil is used to keep the metal cool or lubricated to prevent wear and also to help machining to glide on the metal being worked on. On average, 10,000 to 20,000 mg/L can be in wastewater of some metal finishing industries (WEF, 2008). Individual pollutants and levels are site specific. Some general levels of in wastewater from a typical metal finishing business are as follow:

Table 4  Typical Wastewater Demands

Biochemical Oxygen Demand	Total Suspended Solids	Chemical Oxygen Demand	Total Organic Carbon	Total Kjeldahl Nitrogen
3,000 – 4,000 mg/L	2,000-3,000 mg/L	20,000 – 30,000 mg/L	7,500 – 10,000 mg/L	100 –   200 mg/L

Source: Industrial Wastewater Management, Treatment and Disposal, pg. 134 3rd Edition, WEF Press. 2008

Oils and greases are usually the first pollutant to be removed. They tend to cause maintenance problems with equipment down the line if allowed to stay. The treatment of oily wastes is first by means of segregation, then gravity separation followed by skimming. Emulsifying the oils helps float the oils to the surface.

Cyanide

While each site is different, there are known values for handling average concentrations of various metals. Whenever cyanide is in the mix, the water is always treated to eliminate the cyanide as the first metal to be removed (Holtzman, 1994). Ideally, if possible, cyanide streams should be kept separate from other waste streams. As a preliminary test, the lab at the wwtp should find out how much total cyanide and how much amenable cyanide is present in the water (WEF pg 385). It is done in a two step process called alkaline chlorination. The first process raises the pH to 9.5 to 11. Chlorine gas is often used, and another chemical used is sodium hypochlorite to change cyanide to cyanaogen chloride, then quickly to cyanate when it is amenable cyanide. Then the second step changes the cyanate into carbon dioxide and nitrogen gas the pH lowers to between 8.5 and 9. Cyanide is precipitated out using oxidation rather than later on with the other metals using hydroxides because many metals will create strong complexes with cyanide (Armenante). When the cyanide is not amenable, it is as a complex with another metal such as iron, chromium, or nickel.

Hexavalent Chromium

Another metal that needs to be treated in this fashion is Hexavalent Chromium. For this process, the pH is lowered to the acidic side of the pH scale to 2.5. This is done by adding Sulfur dioxide to the mix. This changes the +6 Cr to Trivalent Chromium, which can then continue on with the waste water and be treated with the other metals.

Other Metals

Most metals become insoluble at higher, more alkaline pH. At lower pH, metals are soluble. To get them to precipitate and settle, they need to be put into solid form. To aid this process, coagulants are added. These additives get the metals to attract to each other, which helps to get the metals to settle. In this first part of the process of treating the metals in group-like manner, the pH is raised back up to 6 to 6.5. Polyaluminum is a common metal reducer used to coagulate the metals. The water is then brought up to a pH of 7.5 to 8 by the addition of Sodium hydroxide. Finally, the last tank the pH is raised to 9, although there are cases that need the pH to be raised as high as 11 at this point. Flocculants are added, which allow some of the wastes to float, where they will be skimmed off. The remaining metals settle and are removed to a sludge tank. The sludge gets thickened and then is transferred to another piece of equipment that will dewater it. Depending on the type of metals removed, the sludge disposal may need to be transported to a hazardous waste disposal site.

The water that has been through all the precipitating, settling and flocculation processes then goes through a filter. The filter is usually either sand or carbon, and sometimes both are used. When the sensors pick up on either low head pressure or that particles are passing through the filter, the filter is then backwashed. The backwash water goes back to the beginning, as some metals may be contained in the backwash. After the water clearly goes through the sand/carbon filter(s), it goes to a tank where the pH is adjusted. At this point, it is ready to be discharged.

Table 5  Typical Concentration Ranges of Metals in Metal Finishing Wastewater

Typical Initial Ranges of Metals and the pH or Ion that will   Precipitate the Metals
Pollutant	pH that will Promote Precipitation	Typical Range of Mean Concentrations mg/L	Concentration of Metal Ion
			Hydroxide mg/L	Sulfide mg/L
Cadmium	9.0 – 11.0	0.28	2.3 x 10-5	6.7x 10-10
Copper	7.0 – 8.0	12.6	2.2 x 10-2	5.8 x 10-18
Lead	8.5 -9.0	0.33	2.1	3.8 x 10-9
Nickel	9.0 – 11.0	15.5	6.9 x 10-3	6.9 x 10-8
Silver	9.0 – 12.0	Trace	13.3	7.4 x 10-12
Zinc	8.0 – 8.5	12.5	1.1	2.3 x 10-7

Sludge

During the wastewater treatment process, a contaminated sludge is generated which can contain FOGs, metals and other compounds. This sludge must be removed from the facility, typically through a third party, for final disposal. To start off the disposal process, the sludge must first be sampled for basic waste parameters such as ignitability and corrosivity. In addition to these waste parameters, the EHS team must also collect and submit Toxicity Characteristic Leaching Procedure (TCLP) samples. The waste parameters are used to monitor the effect of storing the soil in a landfarming environment to ensure safe, permanent disposal. The TCLP sample replicates rain water of an average pH percolating through the surface soil and contaminated sludge in an effort to study the potential effects of water movement versus contaminant mobility. If the TCLP samples come back under the action level that is specified by the state, meaning that the samples did not “leach” a sufficient amount of materials (metals in this case), then there is no additional stabilization requirements. If the samples come back showing that the sludge would leach contamination to down-gradient locations due to naturally occurring rainwater, then additional stabilization is required. Stabilization methods include mixing Portland cement, lime, bentonite, or a combination of the 3 with the contaminated sludge. Disposal facilities, such as the one in Robstown, TX, may also choose to use a proprietary blend of stabilization material such as “Enviroblend”. Once the sludge has been classified as either hazardous or non-hazardous waste, the process can begin of transporting it. If the sludge has been deemed non-hazardous it can typically be disposed of at a number of landfills. If the sludge has been deemed hazardous or needs stabilization, the choices are limited on where you can dispose of it. Typical treatment fees for a chromium contaminated sludge can range from 200-250 dollars per ton. This fee includes the cost of stabilization. If the concentrations are extremely high, it is possible that additional measures will have to be taken to stabilize the sludge. Additional stabilization can incur longer transportation fees and higher rates per ton of material. In the end, the sludge will be removed from the wastewater treatment facility for disposal. The path that the sludge takes towards final disposal will vary from facility to facility

Wastewater Management Strategy

Wastewater Reuse

Designing processes that can reuse water within the facility is an efficient way to save time and money. A great example would be to clean up process water to a level that would be considered satisfactory to use for rinsing. This quality could be achieved by a number of processes such as Koch Membrane System’s tubular, ultrafiltration membranes (Koch). These membranes can remove FOG and heavy metals so that the effluent flow may be safely utilized in other facility processes. This process works by first establishing cleanup criteria for your effluent flow. By establishing a internal system of standards to which wastewater can be cleaned up, an EHS manager can determine what operations can use the water based on the standard.

A small process, or group of processes can be implemented to assist with the wastewater reuse. These processes would operate upstream of the treatment plant and would cycle the majority of wastewater back into the facility as treated water to be used in select operations. These processes may remove a particular contaminant or group of contaminants to make the wastewater stream acceptable for the appropriate internal function. These processes can cycle back a large amount of water, but still produce some wastewater to be sent to the treatment facility. Addition of these systems also brings about additional maintenance costs and monitoring for the equipment. Consideration must be taken to weight the costs benefits over time of installing a wastewater recycling system versus the upkeep and construction of the system.

Another example of a water reuse process would be capturing storm-water from the throughout the facility boundaries. LEED architecture designs incorporate storm-water collection into structures and utilize this resource when there are no strict restrictions on water parameters. Collecting storm water to use in rinsing processes and sanitary facilities takes advantage of an existing resource and reuses it within the operating processes. Designs can also be incorporated into existing facilities which can affect permitting and reduce operational costs. Organizations such as the National Onsite Wastewater Recycling Association (NOWRA)provide knowledge to companies that are wanting to make best advantage of their wastewater (NOWRA). For a large metalworking facility that requires multiple rinse stations, this is a great opportunity for wastewater reuse.

Reducing Operational Costs

There are various ways in which a metal finishing organization can reduce operational costs. One of the first ways to optimize many processes within an facility is to look carefully at the use of water. Reductions to water intake and minimization of wastewater production is of course the most obvious methods. Identifying ways to reuse fresh water or slightly used water can also present a great opportunity to drive down costs. Reductions to wastewater output will affect the overall design of a wastewater system a lot of designs are based off influent flow volumes and the area required to lower concentrations of contaminants. The intelligent use of water in a closed system will provide the greatest cost reductions over time. Researching alternative chemicals to use within the metal finishing process is another method to reducing operational costs over time. Although this process requires investment on the front end, finding a chemical that more effectively reduces contaminants in your wastewater treatment facility or can eliminate a contaminant completely can have enormous financial benefits on the back end. Increased efficiency of contaminant removal can have positive effects on applicable permits and regulations, sampling methodology for monitoring, agency involvement in business affairs, potential legal/liability issues, and exposure concerns to workers. All of these processes incur a cost to the organization and any reduction can be seen as a great benefit over time. Normalizing the waste stream can also have a beneficial impact on costs. By reducing the amount of variability in the wastewater, we can eliminate the need for equalization tanks and additional steps in the treatment process. Modification of the order of events within the operational process can produced this desired effect if possible.

There are many ways to reduce costs associated with wastewater treatment. Optimization of processes, selection of chemicals, treatment facility design, and resource usage all intertwine and add to the total cost of wastewater handling at a facility. The proper management of these details can create huge saving to the facility owner as well as increased sustainability and profitability in the future. Sustainability and profitability is marketable to consumers, shareholders, and prospective employees as selling points for interest in the company. As EHS becomes more integrated into companies, more focus will be placed on details such as these as a way to increase the bottom line.

Conclusion

The metal finishing industry deals with a variety of complex issues from a wastewater standpoint. The contaminants associated with the industry and the concentrations in which they are emitted to the environment can create complicated problems that must be solved by skilled EHS professionals. Careful consideration must be taken for the health and environmental effects for present exposure and also potential future exposure pathways. Source reduction, cost reduction, and water recycling have proven to be successful foundations for wastewater management in this industry. A thorough understanding of the best practices, regulations, and efficient technologies mentioned above will provide a manager with an excellent foundation with which to begin solving these issues.

Works Cited

Armenante, P. M. (n.d.). Precipitation of Heavy Metals. Retrieved February 12, 2012, from http://cpe.njit.edu/dlnotes/CHE685/Cls06-2.pdf

DEC, N. (2007, March 28). SPDES Permit. Retrieved February 24, 2012, from New York State Department of Environmental Conservation: http://www.dec.ny.gov/docs/water_pdf/gp0601.pdf

EPA. (1982, August). Development Document for Effluent Limitations Guideline and Standards for the Metal Finishing. Retrieved February 4, 2012, from 2007_10_22_guide_metalfinishing_tdd-proposed.pdf

EPA. (1983, July 15). Environmental Protection Agency Code of Federal Regulations. Retrieved February 4, 2012, from Part Subpart A – Metal Finishing Point Source Category (48 FR 32485): http://edocket.access.gpo.gov/cfr_2010/julqtr/pdf/40cfr433.10.pdf

EPA. (2000, September). Wastewater Technology Fact Sheet – Chemical Precipitation.

Federation, W. E. (2008). Industrial Wastewater Management, Treatment, and Disposal. Alexandria, VA: WEF Press.

Fister, D. (2010, June 23). Metal Finishing – Reducing Operational Costs, Environmental Impact via Rigorous Plating/Finishing Analysis. Retrieved February 4, 2012, from MetalFinishing.com: http://www.metalfinishing.com/view/10486/reducing-operational-costs-environmental-impact-via-rigorous-platingfinishing-analysis/

Holtzman, S. A. (1994). Advanced Chemical Technology, Inc. Retrieved February 12, 2012, from Advanced Chemical Technology, Inc.: http://www.actglobal.net/products_wastewater_heavy_metals.htm

Illinois, U. o. (n.d.). Overview of Metal Finishing Industry – Metal Finishing Industry. Retrieved February 4, 2012, from Illinois Sustainable Technology Center: http://www.istc.illinois.edu/info/library_docs/manuals/finishing/overview.htm

IR. (2012). Construction Tools. Retrieved February 24, 2012, from Ingersoll Rand: http://www.ingersollrandproducts.com/IS/Category.aspx-am_en-394

Koch, M. (n.d.). Retrieved February 2012, from http://www.kochmembrane.com/Water-Wastewater/Metal-Finishing/Water-Reuse.aspx

NOWRA. (n.d.). National Onsite Wastewater Recycling Association. Retrieved February 2012, from http://www.nowra.org/program_svc.html

Sharon E. Rehder, P. (2000, Winter Vol. 30, No. 4). Clearwaters. Retrieved February 4, 2012, from NYWEA.org: https://nywea.org/clearwaters/pre02fall/304090.html

U.S. (2012, February 22). Electronic Code of Federal Regulations. Retrieved February 24, 2012, from GPO Access: http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&tpl=/ecfrbrowse/Title40/40cfr403_main_02.tpl

The Changing Role of Safety Professionals

The Changing Role of Safety Professionals

American Society of Safety Engineers

Central New York Chapter

January 2012 Meeting

Speaker: Jackie Jordan

I hope this topic is informative and motivating for you . This is an overview of where Safety Professionals came from, where we have been, and the plan for the future. The job description of Safety Professional was invented over 100 years ago. Since then we have reinvented our strategies of preventing workplace injuries, illnesses and fatalities several times. Each time we measure our progress through charting successes and failures. The mission of developing management skills is always evolving. By continuing to monitor safety statistics both nationwide and within our own companies we can see trends that help us determine where to focus and how to properly manage our employees and clients. The following information is intended to aid in filling in some of the gaps of today’s presentation. One hundred years cannot be covered in a half hour or even in this handout; therefore it is not intended as an exhaustive resource of the history of Safety Professionals. Please sit back and enjoy today’s topic. I thank you for coming today.

~ Jackie Jordan, Safety Manager for Burns Bros Contractors

History of Safety in the Workplace

Safety in the U.S. Workplace

• 1910 – The first comprehensive look at workplace accidents
• Work Accidents and the Law was written by Crystal Eastman.

–       Ms. Eastman investigated and studied the following:

1. 1.      The causes or workplace accidents
2. 2.      The economic cost of accidents
3. 3.      The extent to which employers should be held liable

–       Her theory was “Employers would be more willing to invest in safety if the cost of injury was ultimately on them”.

Eastman’s Findings & Conclusions

1/3 of accidents were unavoidable

1/3 of accidents were caused by human weakness

1/3 of accidents were caused by insufficient provisions for safety

Remember, this was in 1910.

In order to make changes, there were 3 Requirements:

1. Every       serious accident must have a certain & considerable expense to the       employer.
2. Shift       a considerable share of the burden from each accident from the family of       the injured to the business; Thus to the whole body of consumers.
3. Must       reduce to a minimum the possibilities of dispute between the parties.

Early Developments in Safety

• March 24^th, 1911 New York denies compulsory worker’s compensation into law, viewed it as unconstitutional.
• March 25^th, 1911, the Triangle Shirtwaist Factory Fire occurred, killing 146 workers. This fire marks a turning point in how the public viewed workplace safety and what would not be acceptable in the future.
• Oct. 14, 1911 United Casualty Investigators was formed

62 Members. Later, in 1914 UCI changed their name to the American Society of Safety Engineers.

“The Great Tradeoff” – Worker’s compensation was known as due to employers agreed to pay medical bills and lost work time in exchange for employees not being able to sue their employers.

Initially, safety professionals started as a group of people who investigated why workers died in workplace incidents. The Triangle Shirtwaist Factory fire had fire exit doors locked; doors that were not locked opened inward; fire escapes lead nowhere and collapsed when used; firefighter ladders were too short to rescue people who were working as high as the 9^th floor, and water hoses could not reach the fire. Workers were stranded and some jumped to the concrete below, over 100 ft below.

Many people watched in horror as the fire consumed people. Frances Perkins was one of those people; she became the first female Secretary of Labor, and was committed to workplace safety & health after the tragic fire.

The owners of the sewing factory were tried for manslaughter and acquitted. A civil suit against the owners netted each of 23 families $75 in damages (The Columbia Electronic Encyclopedia)

May 1911 Wisconsin became 1^st state to pass WC law. By end of 1911, nine more states passed WC laws.

American Society of Safety Engineers

–       Safety Professional was defined as

“An individual, qualified by education, training and experience, who in working with and through others, and following a Code of Professional Conduct, helps to identify hazards and develop appropriate controls for these hazards, that when effectively implemented, prevent occupational injury, illness and property damage”.

The Change in Roles

• In just 3 years, 1911 to 1914…

–       Safety Professionals went from being reactive to being proactive

–       Finding ways to prevent accidents that lead to deaths and serious injuries.

–       Identify hazards

–       Develop controls for hazards

The first decade in 1900 impacted safety culture that continues even today.

Decrease in Fatalities, But not Drastic                         

Source of data: National Safety Council – Injury Facts 2008 Edition

Having safety managers in the work place made a difference but it wasn’t huge. Companies resented them for slowing production and workers resented them because they looked at them as big brother for the company heads. Safety managers were being fought from both ends.

It must be remembered that at this point in time, the corrective measures in safety were made from within companies by their choice. Obviously by safety professionals working hard and some companies being progressive and seeing the light, differences were made. However, going from 20,000 fatalities to 14,300 over the course of more than 40 yrs. was not enough if you were the family members of one of the workers killed.

Management Styles

1950’s

Taylor’s Scientific Management

Observation, measurement and experimental comparison. “If you can’t measure it, you can’t control it”.

1960’s

Theory X and Theory Y

This theory is pre-industrial revolution. However, McGregor brought it to the surface in his book “The Human Side of Enterprise” in 1960. “Managers who make Theory X assumptions believe that employees dislike and attempt to avoid worked, need direction, avoid responsibility, and lack ambition”. “Managers who follow Theory Y assume that employees do not dislike work, they have self-control and direction, and they seek responsibility”. These concepts were not new; they can be traced back to 1690. Many people theorized about the concepts of Theory X & Y but McGregor articulated it best. Theory Y says that if “employees were treated well at work, and were given responsibility, they responded positively and the opposite was Theory X”. McGregor preferred Theory Y. He believed that the reason why Theory X looked true was not because people had those negative traits but rather that a “repressive organizational climate” trains people into having self-defeating behavior. Both theories are used as foundations for more refined methods of management today.

1970’s

Command & Control

This form of management says the boss knows the best way to do the job, and the workers are to not think for themselves, just do as they are told. Boss = brains and Workers= Non-thinking labor. Command and Control is a spin-off of the military, who had already been using this style of management for a very long time. Often this method  has been used in manufacturing plants.

1928 to 1969 Chart Revisited

Remember…by 1969 we were still at 15,000 workplace fatalities per year, so while the presence of safety professionals was making a dent, perhaps more progress could be made.

OSHA was Born in 1970

In 1970, President Nixon approved the Occupational Safety & Health Act.

OSHA did not make a large initial impact in the first two decades of its existence beyond what Safety Professional’s had already been doing to decrease fatalities.

The First Decade of OSHA

• • Assembled a staff
• • Created regulations
• • Developed enforcement strategies
• Voluntary compliance
• A “get tough” stance

• • Focused 95% of inspections on industries with serious problems.

They weren’t very friendly!!!

Focusing on the bad companies left no room to praise the good companies and foster growth in a positive relationship between companies and OSHA. It was all negative and that did little for the reputation of OSHA.

Based on how OSHA came out of the gate, companies viewed OSHA as an intruder that they needed to battle.

• When people feel intimidated or threatened, they become defensive.
• The result is not a positive relationship of working towards a common goal.

The Second Decade of OSHA

As with anything, trial and error is often the way to success.  OSHA is no different, it is run by people just like you and me.

The negative connotations of OSHA from strict policing of regulations may not have been the optimal use of resources.

A new goal was set:

“to provide a balanced mix of enforcement, education and training, standard setting, and consultation activities”

The Voluntary Protection Program (VPP) began in the 80’s.

OSHA changed and created a better balance between reprimanding those who need it, helping those who ask for help, and congratulating those who have done well in developing good safety programs.

A Funny Thing Happened with the New Approach…

There was a steady decrease in workplace fatalities since 1930 until 1992.

       For the first time in recorded history in the U.S., a sharp decrease in fatalities .

 Then a sharp decline in fatalities occurred.

Measureable results showed success.

Harsh penalties for businesses not protecting workers and helping those who wanted to do the right thing was paying off.

It was a good blend of combining Command & Control with Behavior Based Management. For those who needed to be policed, OSHA was able to penalize. For those who wanted to voluntarily comply by providing training with safety programs, self-enforce compliance, and engineer out hazards, OSHA developed a mutual relationship where the employees were the winners by being kept safe. The results show the success of using the combined methods.

It took the efforts of over 80 years to steadily decrease work place fatalities and serious injuries.

The sharp decrease seen in 1990 can only refer to the previous decade of accumulative methods tried and finally finding what works.

Time is money. Companies need to take a look at what worked to make the 1990’s successful and apply the same principals within

Tug of War Between Safety and Workers

Just like OSHA has been perceived as policing agency out there to write citations for things that often do not make sense to companies, Safety Managers are seen as babysitters by workers.

Upper Management and Safety Costs

Upper Management

Expect limited or lower:

• Experience Modification Rate
• Worker’s Comp Insurance Rates
• Safety Equipment Costs
• Training Costs
• Safety Professional Costs

 

Safety Professionals

Expected to:

• Decrease EMR and WC Rates instantly
• Spend minimal $$ for equipment and training
• Control workers using harsh enforcement

 When a company suffers enough accidents, their EMR goes up, which is the numeric judgment given to a company based on the past three years of activity of accidents and events in which the insurance carrier paid out claims for injured or killed workers. Safety may otherwise go unnoticed by upper management if it weren’t for insurance premiums rising along with the EMR. Nothing gets more attention than money being paid out.

When the premiums continue to rise, safety professionals are expected to bring the EMR down instantly. While it took three years of accidents to create the higher EMR, it also will take about four years to decrease it. This still does not alleviate the sense of urgency to which management wants to lower the EMR. In the meantime, this raised EMR can cost companies jobs, since doing business with a company with a high EMR can mean the company is not being managed effectively.

The role of a safety professional has at times turned into one of a babysitter. Management wants the SP to go out like a soldier and crack the whip to enforce ultra strict safety habits that magically cast a spell on the workers to mindlessly put their safety glasses and hard hats on, follow fall protection, lockout tagout, confined space protocol and follow every rule in the book.

We have a lot on our plates

It’s Our Turn to Change

OSHA has shown it can be done. Unfortunately, OSHA may have taken it as far as they can from the outside.

The flat line from 1992 forward shows that the progress has stalled. Compared to 1930, it is a miracle.

But if you are a family member of one of the 5,000 workers killed annually, it is still too many.

Change now has to come from within companies. OSHA will still be there doing their job, but now we have to figure out how to get that decline started again and keep fatalities and serious injury rates going down.

Don’t Reinvent the Wheel!

Learn from history.

The paths of what works is right under our noses.

Various Management Methods

There have been many models of safety management over

the past few years.

• Command & Control – Managers do all the thinking and workers do the work.
• Behavior-based – Change the behavior of “at-risk” employees to “safe” behaviors.
  • Safety Training – Developing manuals, procedures, training and disciplinary systems.
  • Compliance Strategy – Inspections & audits
  • Technical Strategy – Ergonomics, tool design, guards
  • Leading by example –
    • Values & Leadership – Executives
    • Systems & Structures – Managers
    • Management practices & motivation

Everyone has theories on what the best management method is. If we didn’t have theories, we wouldn’t be thinking. At some point, we have to look at our progress of success and if the numbers are not going down, try a different method.

What Else Works?

Looking at Quality Control Management, they have figured out how to be successful at “lowering defects, mistakes, scrap and rework caused by the way they manage the work system”.

Accidents are caused by how we manage the work site

Follow A Good Idea

It takes all the worker’s input to create a safe work site. Teams of people can look at the situation and see better ways to do the job than just one person.

Creativity, ingenuity, and motivation happens when everyone uses their minds to think through a problem instead being told each step of the way on how to perform a task.

People who do the job are the experts of the job. They know the hazards better than anyone.

  Company        Safety Manager         Workers

The role of a Safety Manager is changing.

• We should be spending our time facilitating a system in which their teamwork can be applied to their work environment.
• Safety managers now work WITH workers
• Workers understand safety managers are a resource of knowledge to help them plan their tasks.

Safety Managers are part of the team.

Total Quality Management

Why reinvent the wheel? It works for quality control, why not try it for safety?

Quality Control

Do you think anyone can step in and do your job and do it well? Can you be an expert at everything? The answer to both those questions is no. No one person can have the skill and knowledge to think of all that goes into a process. Sometimes it takes the money people, the experts at the jobs, and the safety professionals to all work together to make the right decisions.

QA/QC

Quality control management allows people to feel that they are an important part of the whole picture. When they feel they have a voice in a situation, you will get the best work from them because they know that if the project fails, they also have a stake in the failure. Not just the supervisor gets the blame.

Team Studies

Study the operation and figure out ways to do the job better, before an accident occurs. Look for the hazards beforehand. One person may not see them all or even know some of the hazards without actually doing the job themselves. When you build a team, the problem gets looked at from more than one angle. Everyone brings something different to the table.

When people feel they have a voice that is being heard, they believe that whether the operation is a success or failure reflects back on them also, not just the boss. They have a stake in it.

Teams will figure out better ways to avoid waste, scrap or mistakes (or accidents!) before they happen.

Safety can successfully mimic quality control management to lower accident risks.

If a worker does not feel they have a say in how things are done, they have no sense of pride in how successful a project is. They also have no blame in failing.

Goal

To get control of the system.

You don’t get control by controlling the system. Control is the EFFECT of good management.

Your Unique Method

Everyone’s situation is different.

Find what works for you.

Challenge yourself to be creative, try new methods

Get your people involved, motivate them.

Don’t settle for mundane methods that are tired.

Make a difference in someone’s life.

Sources:

The New York Times. “Work-Accidents and The Law” Striking Facts and Figures…Aug. 6, 1910.

Happy 100th Birthday Workers’ Compensation: The Great Tradeoff!http://www.insurancejournal.com/news/national/2011/03/23/191291.htm# 8/16/11

A Brief History of The American Society of Safety Engineers’ A Century of Safety’ .8/15/11 http://www.asse.org/about/history.php  

Walsh-Healy Public Contracts Act. http://en.wikipedia.org/wiki/Walsh%E2%80%93Healey_Public_Contracts_Act 8/16/11

40 USC CHAPTER 37 – CONTRACT WORK HOURS AND SAFETY STANDARDS

www.OSHA.gov 8/16/11

The Architecture of Excellence. Hansen,  L. May 2000. Professional Safety

What Safety Excellence Managers Do. Hansen, L. May 2006. Occupational Hazards

What’s Wrong with Behavior-Based Safety? Smith, Thomas A.. Sept. 1999 . Professional Safety.

A Historical View of Douglas McGregor’s Theory Y. Carson, Charles M. Emerald Management Decision Vol. 43 No. 3, 2005.

Voluntary Environmental Management: The Inevitable Future. Morelli, John. Chapter Three – Defining Management.

Fatality at Hydro Plant Incident in Baldwinsville, NY

On Monday, August 8^th, Jon C. Stranburg age 60 of Allegany, co-owner of the Wave Hydroelectric facility on the Seneca River in Baldwinsville died while trying to make a repair to the flood gate(s). This is a privately owned facility located on Lock 24, near Paper Mill Island.

The second owner, Neil Collins was also involved in the incident[1]. He was conscience but in pain as he was taken by ambulance to Crouse Hospital with non-life threatening injuries.

According to Syracuse.Com[2], “The New York State Canal Corp. announced on July 19 that the lower-than-normal water levels upstream of Erie Canal Lock # 24 in Baldwinsville was due to inoperable gates at the Wave Hydro Hydroelectric facility. The Canal Corp. said in a news release that the Wave Hydro facility was unable to close its gates”.

Stranburg was apparently working on the 10’ diameter turbine around noon, when he slipped and fell into the turbine. Because the flood gates were inoperable, the turbine had water flow going through it. Without being able to shut down the source of water, there is no way to stop the turbine blades from turning. The force of hydraulic energy created a strong current. The turbine pit was a confined space that was not well lit[3]. Baldwinsville Police Chief Michael Lefancheck said “Apparently he fell down into the turbine and was unable to withstand the strong currents and undertow, and he was pulled under the water”. He also said the water conditions and dark confined space made rescue attempts very difficult. By 2:00 pm, it was announced Stranburg was dead; his body was recovered shortly before 4:00pm.

In the Comments section of Syracuse.com, one author wrote about earlier reports giving information on Stranburg wearing a harness with a rope attached. This report also said “…the fall arrest rope was too long to be effective, ie; stop him from falling into the swiftly moving water, and it seems he didn’t consider the force which would be applied against his body by the flowing water that made it impossible for his partner to pull him out without the aid of a mechanical retrieval device”.

OSHA regulations have several sections that state the minimum standards by which people should operate in hazardous situations in order to remain safe. While OSHA is set up as regulations for employers to keep their employees safe, they can and should be adhered to by anyone at a risky job site.

Many lessons can and should be learned by anyone who has ever or will ever work in a similar situation.

Confined Space §1910.146. The first question you would ask yourself is “is this a confined space”? There always seems to be someone who wants to argue the point of this simple definition, but here it is:

Confined Space means a space that:

1. Is large enough and so configured that an employee can bodily enter and perform assigned work; and
2. Has limited or restricted means for entry or exit (for example, tanks, vessels, silos, storage bins, hoppers, vaults, and pits are spaces that may have limited means of entry.); and
3. Is not designed for continuous employee occupancy.

Much of what Mr. Stranburg and Mr. Collins did or did not recognize concerning the potential hazards that existed within the confined space of the turbine pit would be speculative at this point. We also do not know many facts about how they organized their plan or if there was a plan that took into consideration the “what if” events that could occur. However, some of the hazards that may have existed and should have some form of mitigation planned out prior to entry are as follow:

• Atmospheric testing for dangerous gasses
• Ventilation
• PPE such as:

                   i.      Harness;

                   ii.      Life line that is the proper length that includes the person’s body length from the harness clip on the person’s back to the feet and also the length from the tie off point to the lanyard.

• Lighting equipment
• Communications equipment
• Assigning tasks to individuals such as authorized entrant, authorized attendant and who and how the attendant will call for help if needed.
• Providing barriers to keep pedestrians out of the area.
• Equipment such as ladders for safe ingress and egress.
• Rescue equipment such as a mechanical tripod or hoist.

Since this was a permanent structure that needed periodic maintenance, the local fire department could have been called ahead of time to plan a practice rescue. This could have better prepared the rescuers for what equipment they might need and how to best set it up in order to reach the person in distress.

Lockout/Tagout § 1910.147. It appears that the whole reason for going into the confined space was to fix the gates that would hold back the water. The hydraulic energy is the main contributor to this fatality. Hydraulic energy is one form of energy that falls under lockout/tagout regulations. Without seeing the whole set up, it is difficult to come up with a plan that would control the energy of the water, since the flood gates were not working. In making the initial assessment, it is quite possible that a much more elaborate and expensive system may have been needed in order to provide temporary control of the hydraulic force if indeed there was no other way to lockout the energy. An engineer may have been needed for consultation of the project. When looking at the cost of a project as enormous as that would have been, it also must be considered that a life was lost and how do you value one against the other? Naturally this is hindsight, but going forward, it is truly necessary to look at this situation and apply the risk to similar future projects.

Working over or near Water § 1926.106 Where danger of drowning exists, employees must have U.S. Coastguard approved life jacket or buoyant vests. This regulation in itself probably would not apply in this case. With what has been written so far on this accident, it might be assumed that the force of the water was great enough to hold the man under even if he was wearing a life preserver. There are a couple other stipulations that also may not have helped in this case. However, when there is a regulation, look at the title and then think of the General Duty Clause.

General Duty Clause

(a)                   Each employer —

(1) 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 following is a description of what an OSHA inspector uses as criteria for issuing a citation involving the General Duty Clause[4]

1) That a hazard exists;

2) That employees are exposed to the hazard;

3) That the employer knew, or should have know with the exercise of reasonable diligence, of conditions that exposed the employees to the hazard (referred to as employer knowledge);

4) That a feasible means of abatement exists to protect employees.

Even though the water standard did not completely apply in this particular incident that caused a fatality and it may not apply, nor may other regulations apply exactly…the point is that if there is a hazard that a person is exposed to, and the employer knows about it or should have known, then it is the duty of the employer to remove the hazard.

OSHA is currently investigating this incident. Having access to the scene, interviewing witnesses and time to spend on this case solely until the completion of the investigation, the report should be thorough.

They aren’t the only ones with their eyes on it. Already as of today, Texas attorney E. Michael Grossman has it listed in his Accident Blog where he posts construction fatalities and injuries and shares his opinions and “raises awareness to rather serious safety concerns”. He also recommends anyone who is considering legal counsel to contact their family attorney. I have yet to see in one of his blogs any kind of productive advice that may stop a future accident unless you consider punishing companies, employers and anyone involved with lawsuits, punitive damages, etc. a form of solving safety issues.

J Jordan

8/9/2011

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[1] www.9wsyr.com 8/9/11

[2] Syracuse.com 8/9/2011

[3] www.buffalonews.com 8/9/11

[4] http://oshaaboveground.blogspot.com/2009/06/general-duty-clause-citations.html 8/9/11

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