osha3348 metal scrap recycling

Guidance for theIdentification and Control of

Safety and Health Hazardsin Metal Scrap Recycling

OSHA 3348-05 2008

Employers are responsible for providing a safe andhealthy workplace for their employees. OSHA’s roleis to promote the safety and health of America’sworking men and women by setting and enforcingstandards; providing training, outreach and education;establishing partnerships; and encouraging continualimprovement in workplace safety and health.

This publication provides a general overview of aparticular standards-related topic. This publicationdoes not alter or determine compliance responsibili-ties which are set forth in OSHA standards, and theOccupational Safety and Health Act. Moreover, be-cause interpretations and enforcement policy maychange over time, for additional guidance on OSHAcompliance requirements, the reader should consultcurrent administrative interpretations and decisionsby the Occupational Safety and Health Review Com-mission and the courts.

Material contained in this publication is in the publicdomain and may be reproduced, fully or partially,without permission. Source credit is requested butnot required.

This information will be made available to sensoryimpaired individuals upon request. Voice phone: (202)693-1999; teletypewriter (TTY) number: 1-877-889-5627.

Edwin G. Foulke, Jr.Assistant Secretary of Labor forOccupational Safety and Health

Guidance for the Identification andControl of Safety and Health Hazards

in Metal Scrap Recycling

Occupational Safety and HealthAdministrationU.S. Department of Labor

OSHA 3348-052008

ContentsIntroduction 3

The Audience for This Guide 3

Why This Guide Is Important 3

How This Guide Can Help 3

What This Guide Covers 3

Specific Standards and Requirements

Addressing Chemical and Physical

Hazards in Metal Recycling Operations 3

Other Relevant Guidelines 4

Types of Hazards in Metal Scrap Recycling 4

Commonly Recycled Metals andTheir Sources 5

Types of Metals Most Commonly Recycled 5

Common Sources of Recycled Metals 5

What You Need to Know About Scrap

Quality and Contaminants 5

Common Recycling Processes,Hazards and Related Controls 7

Processes Commonly Used to Recycle

Metal Scrap and Their Hazards 7

Loading and Unloading 7

Breaking and Separating Processes 9

Gas Torch Cutting 9

Non-Gas Torch and Other Cutting 11

Baling, Compacting and Shredding 12

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

What You Need to Know about Mercury

Exposure 22

What You Need to Know about Exposure

to Other Metals 24

What You Need to Know about Radioactive

Scrap 26

What You Need to Know about Metalworking

Fluids 27

What Other HazardsYou Should Know About 27

How to Control Hazards 28

Engineering Controls and Work

Practice Controls 28

Examples of Engineering and Work Practice

Control Techniques to Reduce Emissions 29

Personal Protective Equipment 30

The Need to Provide Hearing Protection 31

What You Need to Know about Hazard

Communication 32

References 34

Appendix – Exposure Limits forSelected Metals 38

OSHA Assistance 41

OSHA Regional Offices 44

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Occupational Safety andHealth Administration

IntroductionThe Audience for This GuideAnyone who works in the metal scrap recycling in-dustry—employers, employees, safety profession-als, and industrial hygienists—should read thispublication. This guide can help you identify andmanage the hazards associated with exposure tovarious metals and processing chemicals and withrelated processes and equipment used in metalscrap recycling operations.

WhyThis Guide Is ImportantMetal scrap recycling, also called secondary metalprocessing, is a large industry that processes, in theU.S. alone, 56 million tons of scrap iron and steel(including 10 million tons of scrap automobiles),1.5 million tons of scrap copper, 2.5 million tons ofscrap aluminum, 1.3 million tons of scrap lead,300,000 tons of scrap zinc and 800,000 tons of scrapstainless steel, and smaller quantities of other met-als, on a yearly basis. (ISRI NDa)

Scrap metals, in general, are divided into two basiccategories: ferrous and nonferrous. Ferrous scrap ismetal that contains iron, while nonferrous metalsare metals that do not contain iron. These two basiccategories of metals are described in further detail inthe section, “Types of Metals Most Commonly Recy-cled” in the “Commonly Recycled Metals and TheirSources” chapter of this guide.

Many employees are employed by scrap metal recy-cling industries. Private, nonferrous recycling indus-tries in the U.S. employed approximately 16,000employees in 2001.1 (Figures were not available forferrous recycling industries.) In 2001, those nonfer-rous recycling industries reported approximately3,000 injuries and illnesses. The most commoncauses of illness were poisoning (e.g., lead or cad-mium poisoning), disorders associated with re-peated trauma, skin diseases or disorders, andrespiratory conditions due to inhalation of, or othercontact with, toxic agents. Of those injuries and ill-nesses, 701 cases involved days away from work.The most common events or exposures leading tothese cases were contact with an object or piece ofequipment; overextension; and exposure to a harm-ful substance. The most common types of these in-

juries were sprains and strains; heat burns; and cuts,lacerations, and punctures. (BLS, 2003)

HowThis Guide Can HelpAs an employer, this guide will help you protectyour employees by helping you and your employ-ees recognize, manage, and control the potentialhazards associated with common metal scrap recy-cling processes. This guide will also assist safetyprofessionals and industrial hygienists in their ef-forts to identify, evaluate, and develop appropriatecontrols for hazards related to metal scrap recyclingprocesses.

What This Guide CoversThis document will assist employers and employeesin recognizing and controlling typical health andsafety hazards associated with various metal scraprecycling operations and in selecting appropriatecontrol methods. This document does not providean in-depth evaluation of every recycled material, orof every associated process-related hazard; rather itgives an overview of processes and related hazardscommon to a wide range of metal scrap recyclingoperations.

Employers must evaluate their own operations,processes, and equipment to ensure that all hazardsin their operations are identified and appropriatelycontrolled. There are many relevant guidance doc-uments and standards related to exposure to haz-ardous substances (including metals), working inindustrial environments, and working with specifictypes of material handling and processing equip-ment that may be associated with recycling pro-cesses. This guidance document includes referencesto these documents throughout the text, along withshort summaries where appropriate.

Specific Standards and RequirementsAddressing Chemical and PhysicalHazards in Metal Recycling OperationsAlthough this guide recommends work practicesand engineering controls to decrease hazards to em-ployees, there are legal requirements in OSHA stan-dards that you need to know about and complywith. These include, for example, OSHA General In-dustry Standards, Title 29 of the Code of FederalRegulations (CFR), Part 1910 and the ConstructionIndustry Standards in 29 CFR 1926. Consult thesestandards directly to ensure full compliance with theprovisions. States with OSHA-approved plans havestandards which are at least as effective as, but maydiffer from, the Federal OSHA standards. These and

G U I D A N C E F O R T H E I D E N T I F I C A T I O N A N D C O N T R O L O FS A F E T Y A N D H E A L T H H A Z A R D S I N M E T A L S C R A P R E C Y C L I N G

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1After 2001, the data for private nonferrous recycling industrieswere no longer available due to a change in industry codes.However, the nonfatal injury incident rates in 2005 for codesthat encompass the nonferrous recycling industry range from7.8 to 11.2 per 100 employees (BLS, 2005).

with OSHA performance-based standards, such as29 CFR 1910.212, General Requirements for All Ma-chines. ANSI standards are sometimes incorporatedinto OSHA regulations, and in these cases, employ-ers are accountable for complying with the specificversions of the ANSI standard referenced. OSHAgenerally recommends, however, that employersuse the most recent versions of ANSI standards.

Types of Hazards in Metal Scrap RecyclingEmployees in facilities that recycle metal scrap areexposed to a range of safety hazards associatedwith material handling methods, hazards associatedwith the metals themselves (as dust or fumes), andwith the hazardous substances used to process orrecover these metals. These hazards, the processesand operations that present the hazards and the re-lated control measures are covered in this guide.

other OSHA standards and documents are availableonline at www.osha.gov.

Other federal agencies, including the Department ofTransportation (DOT), the Mine Safety and HealthAdministration (MSHA) within the Department ofLabor, the Environmental Protection Agency (EPA),the Nuclear Regulatory Commission (NRC), and theDepartment of Energy (DOE) may each have appli-cable standards regulating specific types of scrapmetals or specific aspects of related recycling pro-cesses. Employers should refer to these agencies forspecific information regarding standards that mayaffect their recycling operations.

Other Relevant GuidelinesThe American National Standards Institute (ANSI)publishes voluntary consensus standards on thesafe care and use of specific machinery. ANSI stan-dards also may give you guidance on complying

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• Brass from lock manufacturing.• Copper from tubing manufacturing.

Obsolete scrap, the other major source, may in-clude:• Copper cables.• Copper household products.• Copper and zinc pipes and radiators.• Zinc from die-cast alloys in cars.• Aluminum from used beverage cans.• Aluminum from building siding.• Platinum from automobile catalytic converters.• Gold from electronic applications.• Silver from used photographic film.• Nickel from stainless steel.• Lead from battery plates. (ISRI NDc; OECD 1995)

Nonferrous metals can also be recycled from cap-tured particle emissions from metal primary or sec-ondary production facilities.

Other exotic and precious metals come from a vari-ety of sources, such as:• Gallium from gallium arsenide (GaAs) used in

electronics.• Gold from precious metals manufacturing plants

and from discarded electronics and jewelry.• Platinum-group metals from catalysts (including

catalytic converters, which automobile recyclerssystematically collect).

• Used catalysts from industrial processes (mostlyfrom the chemical and pharmaceutical indus-tries).

• Old electronics equipment.• Other jewelry. (USGS 2001)

Radioactive metal scrap may come from military ap-plications (such as depleted uranium), discardedmedical equipment, building or storage materialfrom nuclear power plants (particularly nickel scrap)or trace amounts found elsewhere, such as Ameri-cium (Am-241), found in smoke detectors.

Additional information on sources of various metalsis provided in the “What You Need to Know aboutExposure to Other Metals” section at page 24.

WhatYou Need to Know about ScrapQuality and ContaminantsThe worldwide scrap metal recycling industry hasdeveloped sets of specifications and grading sys-tems to ensure consistent quality of source scrapmaterial for a given grade of metal scrap. The threemost widely-used specifications are the Scrap Spec-

Commonly Recycled Metalsand Their SourcesTypes of Metals Most Commonly RecycledThe scrap metal recycling industry encompasses awide range of metals. Some of the most commonly-recycled metals (by volume) are iron and scrap steel(ISS), copper, aluminum, lead, zinc, and stainlesssteel. (ISRI NDa)

Scrap metals, in general, are divided into two basiccategories: ferrous and nonferrous. Ferrous scrap ismetal that contains iron. Iron and steel (which con-tains iron) can be processed and remelted repeat-edly to form new objects. (ISRI NDb)

Common nonferrous metals are copper, brass, alu-minum, zinc, magnesium, tin, nickel, and lead. Non-ferrous metals also include precious and exoticmetals. Precious metals are metals with a high mar-ket value in any form, such as gold, silver, and plat-inum. Exotic metals contain rare elements such ascobalt, mercury, titanium, tungsten, arsenic, beryl-lium, bismuth, cerium, cadmium, niobium, indium,gallium, germanium, lithium, selenium, tantalum,tellurium, vanadium, and zirconium.

Some types of metals are radioactive. These may be“naturally-occurring” or may be formed as by-prod-ucts of nuclear reactions. Metals that have been ex-posed to radioactive sources may also becomeradioactive in settings such as medical environments,research laboratories, or nuclear power plants.

Common Sources of Recycled MetalsFerrous scrap comes from sources such as:• Mill scrap (from primary processing).• Used construction beams, plates, pipes, tubes,

wiring, and shot.• Old automobiles and other automotive scraps.• Boat scrap, railroad scrap, and railcar scrap.• Miscellaneous scrap metal.

Ferrous metals are magnetic and are often collectedin scrap yards by a large electromagnet attached toa crane, sweeping across piles of scrap to grab mag-netic objects.

Aluminum is the most widely-recycled nonferrousmetal. (ISRI NDc) The major sources of nonferrousscrap are industrial or new scrap, and obsoletescrap. Industrial or new scrap may include:• Aluminum left over when can lids are punched

out of sheets.


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Employers should be aware of the potential impuri-ties in their source scrap, and should be prepared tomonitor for hazardous levels of those metals andother chemicals in their work environments (OECD1995). Employers should also ensure that they re-ceive their scrap supply from reliable sources thatfollow the established guidelines and should obtainmaterial data safety sheets (MSDSs) and labels forthe scrap materials where available. If an MSDS isnot provided, the employer must request one fromtheir supplier. See the discussion on “What YouNeed to Know about Hazard Communication”at page 32 in the “Recognizing and ControllingHazards” section of this guide for more informationon employer obligations to obtain MSDSs andlabels for scrap materials.

ifications Circular (U.S. Institute of Scrap RecyclingIndustries, Inc.), the European Classification for Non-Ferrous Scrap Metals, and the Standard Classifica-tion for Non-Ferrous Scrap Metals (U.S. NationalAssociation of Secondary Materials Industries, Inc.).These specifications generally set minimum andmaximum content of certain metal impurities, andrestrict levels of certain hazardous metals and otherhazardous substances.

Employers should be aware that these criteria aredesigned to protect the end-user, or are for productquality purposes, and are not designed to protectemployees performing metal scrap recyclingprocesses. As a result, concentrations of certainmetals that are below these quality specification re-quirements, either as incoming raw scrap or asprocessed scrap (to be sent elsewhere), may stillpose hazards to employees handling metal scrap.

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metal scrap recycling, including (but not limitedto) the following standards• 29 CFR 1910.1000, Air Contaminants• 29 CFR 1910.212, General requirements for all

machines• 29 CFR 1910.219, Mechanical power-transmis-

sion apparatus• 29 CFR 1910.147, The control of hazardous en-

ergy (lockout/tagout)

Sources ofAdditional Information• OSHA 3170, Safeguarding Equipment and Pro-

tecting Employees from Amputations• OSHA 2254, Training Requirements in OSHA

Standards and Training Guidelines• OSHA Health and Safety Topics: Machine

Guarding, http://www.osha.gov/SLTC/machineguarding/index.html

• OSHA Lockout/Tagout eTool http://www.osha.gov/dts/osta/loto training/index.htm

• National Electrical Code 250-112

Loading and UnloadingThe first step in any metal scrap recycling operationis getting the metal scrap to the recycling operationand collecting or sorting materials to be processedin groups. This may involve light or heavy trucks,stationary or mobile cranes, conveyor belts, andother large and potentially hazardous equipment.Working with this equipment poses hazards typicalfor material handling equipment.

Employers must ensure that employees use the ap-propriate combination of personal protective equip-ment (PPE) such as hard hats, sturdy boots, gloves,thick clothing, and respirators (if the operation gen-erates hazardous dust) to be adequately protectedfrom safety and health hazards.

OSHA’s Personal Protective Equipment standards(29 CFR 1910 Subpart I) establish requirements foremployers to evaluate the workplace and identifyPPE needs based on actual workplace hazards(29 CFR 1910.132). These standards also establishcriteria for proper selection and use of specifictypes of PPE such as foot, eye, or head protection.See the “Applicable Standards” box on the nextpage for a list of OSHA PPE standards (not neces-sarily all-inclusive) that may apply to recyclingoperations.

Common RecyclingProcesses, Hazards andRelated Controls

Processes Commonly Used to RecycleMetal Scrap and Their HazardsMetal scrap recycling is a large and complex indus-try. The variety of metals involved and the widerange of sources of metal scrap require many pro-cessing techniques. These processing techniquespose a range of safety and health hazards to em-ployees in the industry. This section discusses a se-lection of those processes, the types of hazards thatthese processes may pose to employees, and con-trol measures employers and operators can imple-ment to control or eliminate these hazards. Thisdocument does not go into detail on every processor every hazard associated with every process, butrather it discusses the most common processes andprovides examples of hazards related to thoseprocesses.

Recycling is a multi-step process, starting with col-lection and transport of raw scrap, pretreatment,melting, refining, forming and finishing. The recy-cling processes discussed in this document fall intothese basic categories:• Loading and unloading.• Breaking and separating.• Gas torch cutting.• Non-gas torch cutting and other cutting.• Baling, compacting, and shredding.• Melting and baking in furnaces and ovens.• Applying chemical processes to recycle metals.

Each category is an individual component of the re-cycling process and may pose a wide range ofsafety hazards that are common to many industrialand material handling processes. Such hazards mayinclude flying pieces of material, exposed movingparts, fire hazards, and noise hazards.

Hazardous chemical exposures to employees aremost likely to result from hot processes that producefumes (such as torching and welding or melting in fur-naces) or processes that produce dust (such as break-ing, shredding, and cutting). Each of these processesis discussed in detail on the following pages.

Applicable Standards29 CFR 1910 General Industry - many standardsfor occupational safety and health may apply to


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Case History #3A 31-year-old male recycling plant foreman diedwhen he was run over and crushed by a front-endloader. The victim was struck by the loader whenits brakes failed as it backed down an incline afterdepositing cans into a hopper for processing.(NIOSH FACE, 95MA026)

Preventive/corrective measures: Operators mustexamine all powered material handling equip-ment at the beginning of each shift. All failingequipment must be tagged out of service and notused until repaired.

Case History #4A 24-year-old forklift truck operator died after thelift truck he was operating overturned. The victimwas operating the equipment in the storage yardof a wire mill. A length of wire became wrappedaround the front drive trans-axle, severing the hy-draulic brake line. As he was returning to theplant with two empty wire spools, the brakesfailed on the truck. He was traveling down an in-cline and turned abruptly to avoid striking storedmaterial. The sharp turn caused the truck to over-turn. The victim tried to jump free but was struckby the Roll Over Protective Structure (ROPS) ofthe truck. (NIOSH FACE, 96MO054)

Preventive/corrective measures: Employers mustkeep aisles and passages used by material han-dling vehicles clear of obstructions. Operatorsmust inspect all powered material handlingequipment at the beginning of each shift. All fail-ing equipment must be tagged out of service andnot used until repaired. Operators of sit-downtrucks need to be trained to remain in the opera-tor’s position in a tipover accident and to leanaway from the direction of fall to minimize thepotential for injury. When seat belts are installedon forklifts, employees are required to wearthem.

Applicable Standards• 29 CFR 1910.132, General requirements• 29 CFR 1910.132(h), Employer Payment for

Personal Protective Equipment• 29 CFR 1910.133, Eye and face protection• 29 CFR 1910.134, Respiratory protection

Forklift and crane operators must be properlytrained in the use of such equipment. Operatorsmust conduct pre- or post-shift vehicle inspectionsdepending on vehicle use. Employers must considerequipping vehicles with guarding to protect any vul-nerable brake lines from incidental damage duringoperation (NIOSH FACE; 29 CFR 1910.178). Ofcourse, any alterations/additions to powered indus-trial trucks would require written approval from themanufacturer.

Case History #1A 46-year-old laborer died from injuries sustainedwhen his left arm became caught between thebelt and pulley of a conveyor system at a Massa-chusetts scrapyard and recycling plant. The victimwas working alone removing fallen debris fromthe conveyor frame at the time of the incident.(NIOSH FACE, 94MA021)

Preventive/corrective measures: Material han-dling equipment must be equipped with propermachine guards to prevent employees from com-ing in contact with moving parts. Emergency stopdevices should be provided within easy reach ofall conveyor operator stations to allow operatorsto immediately stop conveyors in the event of anemergency. Machines must be locked or taggedout during cleaning, servicing or maintenance.Employees must be properly trained in all safetydevices.

Case History #2A 41-year-old tow truck operator was run over byhis tow truck while unloading a car at a scrapyard.The tow truck operator jerked the truck back andforth to release a car, and backed over the victim,who was working behind the truck. He then ranover him again as he moved forward, with thetruck coming to rest with the victim pinned underthe rear wheel. Scrapyard employees tried to res-cue the victim by lifting the truck with a grapplecrane but the grapple slipped and the truck fellback on him. (NIOSH FACE, 99NJ09101)

Preventive/corrective measures: Operatorsshould disengage the transmission of the towingvehicle when hooking or unhooking vehiclesfrom a tow. In addition, employees should neverwork behind the towed vehicle or between thevehicle and the tow truck during this process.

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sorted by hand. When sorting metal scrap by hand,employees must wear personal protective equip-ment such as gloves if there is a possibility of en-countering any metal or other substance for whichskin contact could result in adverse health effects.

Even for metals that do not irritate the skin, handlingsharp or pointed pieces of scrap metal poses cut orabrasion hazards to hands or bodies. Employers arerequired to ensure that employees wear proper per-sonal protective equipment such as gloves anddurable clothing to guard against cuts and scrapes.Employees also need to be aware of the proper firstaid, medical, and reporting procedures if they re-ceive a cut or scrape. Similar concerns apply toother scenarios where employees work with scrapby hand.

Once an employee has started feeding material intoa furnace, there is a risk of hazardous fumes fromcertain metals. Where exposures exceed OSHA Per-missible Exposure Limits (PELs), employers are re-quired to implement feasible engineering controls(e.g., furnace feeding operations can be set-up withlocal exhaust which can circulate and vent the airnear the furnaces to remove toxic fumes from theworkplace). If the exposures still exceed the PELs,employees will need to wear respiratory protectionto prevent inhalation of toxic fumes and dusts. Referto the section on Personal Protective Equipment inthe “Recognizing and Controlling Hazards” sectionof this guide for further information on this topic.

Applicable Standards• 29 CFR 1910.95, Occupational Noise Exposure• 29 CFR 1910.132, General requirements• 29 CFR 1910.133, Eye and face protection• 29 CFR 1910.134, Respiratory protection• 29 CFR 1910.135, Head protection• 29 CFR 1910.136, Occupational foot protection• 29 CFR 1910.137, Electrical protective devices• 29 CFR 1910.138, Hand protection• 29 CFR 1910.147, The control of hazardous en-

ergy (lockout/tagout)• 29 CFR 1910.212, General requirements for all


sion apparatus• 29 CFR 1910.1000, Air Contaminants

Gas Torch CuttingOne of the most common tools used to break apartlarge metal pieces is the gas cutting torch, often

• 29 CFR 1910.135, Head protection• 29 CFR 1910.136, Occupational foot protection• 29 CFR 1910.137, Electrical protective devices• 29 CFR 1910.138, Hand protection• 29 CFR 1910.147, The control of hazardous en-

ergy (lockout/tagout)• 29 CFR 1910.176, Handling materials - general• 29 CFR 1910.178, Powered industrial trucks• 29 CFR 1910.179, Overhead and gantry cranes• 29 CFR 1910.180, Crawler locomotive and truck

cranes• 29 CFR 1910.181, Derricks• 29 CFR 1910.184, Slings• 29 CFR 1910.212, General requirements for all


sion apparatus

Breaking and Separating ProcessesSize-reduction of metal scrap is a necessary compo-nent of some operations. Basic metal breakingprocesses often involve heavy manual labor tobreak up large or complex assemblies of scrapmetal, or to cut or break the pieces into sizes thatcan be fed into a furnace. Employees involved in ac-tivities of this type may be exposed to metal fumes,smoke, hot environments, and hot material whenworking near furnaces, and may come in contactwith metals that present hazards through both skincontact and inhalation.

Some recycling industries use drop-ball breaking (or‘tupping’) to break apart the largest solid pieces ofscrap metal, or to initiate breaking up large assem-blies. This process may create flying object hazardsas the material breaks apart from the impact of theball. Employers must ensure that employees areprotected from these hazards by either performingthe task remotely; placing a barrier or protectiveshield around the task; or using PPE such as faceand body protection. Breaking may also create anoise hazard, requiring the employer to implementfeasible engineering or administrative controls. Ifthese controls do not sufficiently reduce the noisehazard, employers must provide appropriate hear-ing protection such as earplugs, canal plugs, ear-muffs, or other protective devices as required byOSHA’s Occupational Noise Exposure standard,29 CFR 1910.95.

Sorting of scrap is now commonly done by auto-mated processes, though some metals must still be


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OSHA has established PELs for many hazardoussubstances. OSHA requires employers to provideengineering controls or work practices to the extentfeasible when employee exposure exceeds thesePELs for any metal or other hazardous substances.Appropriate engineering controls such as ventilationmay include a local exhaust hood or booth orportable local exhaust, such as a "snorkel" exhaustsystem. Where ventilation or other engineering so-lutions are not completely effective or are not feasi-ble, employees must wear PPE (e.g., respiratoryprotection) to reduce their exposures to below thePEL.

Eye protection, such as safety goggles or a welder'smask with appropriate shaded lenses must also beworn by employees that perform welding or cuttingactivities (see 29 CFR 1910.133 for a list of appropri-ate shade numbers for welding and cutting tasks).Employers should ensure that a competent personinspects all work areas where hot work will be doneand should also ensure that employees are capableof recognizing and avoiding hazardous situations.Note, a competent person is an individual whothrough training or experience is capable of recog-nizing hazards in the surroundings or working con-ditions and of identifying appropriate controls.

Case History #5A 29-year-old scrap metal cutter died from injuriessustained in an explosion. At the time of the inci-dent, the victim had been cutting a vehicle framefor salvage with a torch. He was working 8-to-10feet from a 1,500-gallon storage tank. Escapingvapors from the tank were ignited by spatter fromthe cutting activities, causing the tank to explode.The victim was engulfed in flames, igniting hisclothing and causing burns over 45% of his body.The coworker extinguished the victim’s burningclothing and helped him walk to the company’sshop building. (NIOSH FACE, 98AK021)

Preventive/corrective measures: A competent per-son should inspect all work areas where hot workwill be performed prior to the start of the opera-tions. All flammable and combustible materialsshould be removed from the area. If flammableor combustible materials cannot be removedfrom the area, employers must ensure thatproper steps are taken to isolate the flammable orcombustible material from the heat generated bythe torch.

used for cutting steel scrap. Classic cutting torchesuse gas, while other torches use plasma or powder,or even water (although water torches are rarelyused for metal scrap). Thermal (gas) torches exposeemployees to sprays of sparks and metal dust parti-cles, to high temperatures, to bright light that coulddamage eyes (light both inside and outside of thevisible spectrum), and to various gases. Old cuttingtorches used pure hydrogen and oxygen, whilenewer torches often use acetylene, propane, car-bide, gasoline-oxygen or other mixtures. (Nijkerk2001)

Compressed gases may be flammable and/or explo-sive or may present toxic or asphyxiant hazards ifleaks occur. Compressed gas cylinders can alsopresent explosion or missile hazards if exposed toexcessive heat or physical damage. OSHA stan-dards at 29 CFR 1910, Subpart H establish generaland selected substance-specific requirements forproper storage, handling, and use of compressedgasses. Additional requirements for compressedgasses used in certain types of welding and cuttingoperations are provided in 29 CFR 1910, Subpart Q.

The use of torches presents an obvious fire hazard.This hazard is of particular concern when workingon materials that have combustible or explosivecomponents such as motor vehicles with plasticsand fuel tanks, or objects with wooden interiors(Nijkerk 2001). Disc-cutting is sometimes used to cutscrap metal objects, particularly where the heat andhigh temperatures of a gas torch would pose in-creased fire safety hazards.

Gas torches also involve storage of flammable andexplosive gases on site. Employers must store thesegases in safe locations and ensure that all equip-ment is in good working condition (i.e., detached orpunctured hoses can create a safety hazard fornearby employees) (Nijkerk 2001). Employers mustensure that gas tanks are inspected, tested, and ap-propriately labeled while in storage and prior tomovement and use. (NIOSH FACE; 29 CFR 1910.253)

Employers must ensure that employees use appro-priate eye and face protection such as a welder’shelmet and heatproof and or aluminum lined cloth-ing to protect their bodies from the output of thesecutting operations, which have similar hazards towelding.

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torches are often used for superconductors of heator heat-resistant metals, such as alloy steels con-taining nickel and/or chromium (Nijkerk 2001).Plasma torches generate a large amount of smokeand noise, as well as ultraviolet (UV) and infrared(IR) light. Depending on the metal, this smoke couldcontain toxic fumes or dusts. A discussion on thepotential chemical hazards and controls to reduceexposures to these hazards can be found in the“Recognizing and Controlling Hazards” chapter atpage16. However, where exposures exceed OSHAPELs, employers must install feasible engineeringcontrols or work practices to reduce employee expo-sures such as providing well-ventilated areas forsuch operations. In addition, the employer shouldplace appropriate barriers around the process toprotect other nearby employees from exposure tothe UV and IR light. Employees performing thesetasks must use appropriate PPE such as respirators,goggles or face shields with appropriate shadedlenses, and hearing protection, to prevent exposureto smoke, fumes, light, and noise. See 29 CFR1910.134 for OSHA's standard on Respiratory Pro-tection, 29 CFR 1910.95 for OSHA's standard on Oc-cupational Noise Exposure, and 29 CFR 1910.133 forOSHA's standard on Eye and Face Protection. Note,a list of appropriate lens shade numbers for weldingand cutting tasks is also provided in 29 CFR1910.133.

Employees using torches often spend long periodsof time in awkward or hunched postures, which mayincrease the risk of bodily injuries such as strainsand sprains. Other hazards common to cutting oper-ations (as well as to welding and brazing) includeburns, fires, explosions, electric shock, and heatstress. Even chemicals that are generally not flam-mable may burn readily when vaporized. Largerscrap metal objects are often broken apart using sta-tionary shears, such as alligator shears used to cutapart short steel for foundries or to cut nonferrousmetals. These machines can send small pieces ofmetal flying. Such flying object hazards may be con-trolled through the use of shields set up around themachines to protect employees. Eye protection andother body protection such as metal lined abrasion-resistant protective clothing may also be needed insome cases.

A larger concern than flying objects, however, is thatthe operator often works quite close to the machineand is subject to amputation or crushing hazards. Inthe early days of using shears, it was not uncom-mon for an employee to lose a finger or a hand to

Applicable Standards• 29 CFR 1910.106, Flammable and combustible

liquids• 29 CFR 1910.132, General requirements• 29 CFR 1910.133, Eye and face protection• 29 CFR 1910.134, Respiratory protection• 29 CFR 1910.135, Head protection• 29 CFR 1910.136, Occupational foot protection• 29 CFR 1910.137, Electrical protective devices• 29 CFR 1910.138, Hand protection• 29 CFR 1910.147, The control of hazardous en-



sion apparatus• 29 CFR 1910.242, Hand and portable powered

tools and equipment (general)• 29 CFR 1910.243, Guarding of portable powered

tools• 29 CFR 1910.244, Other portable tools and

equipment• 29 CFR 1910.252, General requirements (Weld-

ing, Cutting, and Brazing)• 29 CFR 1910.253, Oxygen-fuel gas welding and

cutting• 29 CFR 1910.1000, Air Contaminants• 29 CFR 1910.1018, Arsenic• 29 CFR 1910.1025, Lead• 29 CFR 1910.1026 Hexavalent Chromium• 29 CFR 1910.1027, Cadmium

Sources ofAdditional Information• OSHA Safety and Health Topics: Welding, Cut-

ting, and Brazing,http://www.osha.gov/SLTC/weldingcuttingbrazing/index.html

• OSHA Construction Safety and Health OutreachProgram: Safety and Welding,http://www.osha.gov/doc/outreachtraining/htmlfiles/welding.html

Non-GasTorch and Other CuttingMaterials that require higher temperatures to cut,such as pig iron and heat-resistant alloyed scrap, ormaterials that conduct heat too well to be cut withthermal torches, such as copper and bronze, may becut with non-thermal methods such as plasmatorches or powder cutting torches. These tools mayalso be used where a gas torch could pose a safetyhazard, as discussed in the previous section. Plasma


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which was still under pressure, closed upward onthe victim. (NIOSH FACE, 02CA004)

Preventive/corrective measures: Employees mustfollow lockout/tagout procedures to de-energizeall equipment prior to cleaning or performingmaintenance.

Applicable Standards• 29 CFR 1910.147, The control of hazardous en-


machines• 29 CFR 1910.218, Forging• 29 CFR 1910.219, Mechanical power-transmis-

sion apparatus• 29 CFR 1910.242, Hand and portable powered

tools and equipment (general)• 29 CFR 1910.243, Guarding of portable powered

tools• 29 CFR 1910.244, Other portable tools and

equipment• 29 CFR 1910.252, General requirements (Weld-

ing, Cutting, and Brazing)• 29 CFR 1910.1000, Air Contaminants

Sources ofAdditional Information• OSHA Safety and Health Topics: Welding, Cut-

ting, and Brazing,http://www.osha.gov/SLTC/weldingcuttingbrazing/index.html


• OSHA 3170, Safeguarding Equipment and Pro-tecting Employees from Amputations

Baling, Compacting and ShreddingScrap metal is often compacted using balers to pro-mote efficient melting by allowing more metal into afurnace than would be possible for a random assort-ment of sheeting and other scrap objects. Balers usepowerful hydraulic systems to compact scrap metal.Moving parts of balers must be shielded to preventbody parts from coming in contact with the ma-chine. Car flatteners work on many of the same prin-ciples as balers and present similar hazards.

Balers are typically automated machines. This al-lows operators to stay a safe distance from the ma-

the shears, or to have a hand trapped betweenpieces of scrap that were fed into the shears. (Nijk-erk 2001)

Hydraulic shears can be stopped instantly to preventdamage to the machine or operator, whereas me-chanical shears transmit force from a flywheel to theshears and cannot be stopped quickly in an emer-gency. Hydraulic shears are, therefore, safer for theoperator. Both types of shears, however, are stillused in a variety of operations.

Modern alligator shears are often operated by a footpedal that stops the shear immediately if released(Nijkerk 2001). Employers can also use controls suchas wrist straps (attached to cables) to keep employ-ees’ limbs a safe distance from moving parts. Oneway to distance shears from the operator is to attachthe shears to a crane. In this setup, the operator sitsinside the cab of the crane and demolishes objectsor cuts pieces of scrap metal from a safe location. Ifthe metal scrap is being cut from a building or otherobject high off the ground, remote operation alsoeliminates the safety hazards associated with work-ing at heights.

Hydraulic guillotine shears work similarly to alligatorshears and pose similar hazards: employees mustremain at a safe distance from the point of operationso that no limbs or other body parts could contactthe cutting mechanism. Employers must installshields around stationary cutting areas to protectemployees from flying objects.

When a tough or complex piece of scrap damages amachine, that machine may be more likely to mal-function and to pose a hazard to the operator and toother nearby employees. As a result, machinesshould have periodic inspections and should bemaintained in proper working order. For all types ofshears, employees must follow the company’s es-tablished procedures for de-energizing energysources and for lockout/tagout when performingservicing or maintenance tasks (see the OSHA Lock-out/Tagout standard at 29 CFR 1910.147).

Case History #6A 52-year-old welder was crushed to death by ahydraulic door on a scrap metal shredder. The vic-tim was attempting to remove a jammed piece ofmetal from the hydraulic door when the incidentoccurred. Prior to removing the jam the victim didnot lockout or de-energize the system. When thepiece of metal was cut away, the hydraulic door,

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propriate guards must be installed to prevent em-ployees from coming into contact with hazardousmoving parts of the machinery. This applies to thealligator and guillotine shears discussed above, andalso to other similar machines such as rotary shearsand rotary shredders. For such equipment, employ-ees need to stay a safe distance away from workingmachinery and take adequate safety precautions tominimize risks. Employers must install shields toblock stray pieces of metal scraps from flying outfrom these machines and employees must betrained to know what materials can or cannot be fedinto the machine to prevent malfunctioning.

In addition to the physical hazards associated withbaling, compacting and shredding, these processesalso produce significant amounts of dusts. Thesedusts, if not controlled, can present both explosionhazards and inhalation hazards. Some ways to con-trol these hazards include:

• Installing proper air cleaning systems on shred-ding machines.

• Installing explosion sensors where appropriate toinject water to suppress explosions.

• Operating machinery at lower speeds to reducedust generation.

• Introducing an inert gas to rotary shears to re-duce the risk of explosion. (Nijkerk 2001)

• Providing supplemental ventilation whereneeded and perhaps respiratory protection toprotect employees from exposure to hazardousdusts.

• Using wet or semi-wet shredding processes.

Some scrap materials such as scrap vehicles or re-frigerators may contain fuels or other materials thatintroduce additional hazards to the process. Opera-tors must be sure to remove these materials beforeintroducing the scrap to process machinery. For ex-ample, gasoline must be removed from the gas tankof scrap automobiles before compacting or shred-ding the automobile. In addition, chloroflourocar-bons (CFCs) and ammonia must be removed fromair conditioning systems to prevent employee expo-sure to these irritants and to prevent the release ofthese gases to the atmosphere. Removal of CFCsalso applies to shredding of refrigerators.

Many of the processes above use large amounts ofelectricity to operate. Employees must be aware ofthe hazards of working in high-voltage environ-ments and should take appropriate precautions. Allequipment power systems must be covered with

chinery, however, employees must still exercise cau-tion when feeding raw material into a baler using ahopper or conveyor belt. Again, some sort of physi-cal restraint such as railings may be appropriate tokeep employees from falling onto these machines.

Some paper balers and shredders have sensors orheat detectors installed that react to human bodyheat and automatically stop all machine operations.For others, employees may wear magnetic or otherdevices on their belts that are linked to a safety in-terlock system (Nijkerk 2001). Systems such as thesecould be applied to some metal balers and shred-ders to provide additional protection to employees(both from metal and from contaminants in thescrap). Employees must be trained to understandthe functioning and safety procedures of their equip-ment, and must follow procedures for adequatecontrol of hazardous energy, particularly when per-forming maintenance procedures on equipment.(NIOSH FACE; 29 CFR 1910.147)

Case History #7A 34-year-old laborer died after falling into an op-erating paper baler. The victim and a coworkerwere loading scrap paper into an automaticallyoperated paper baler via a belt conveyor. The vic-tim ascended to a platform located between theconveyor discharge and the feed chute of thepaper baler to clear jammed material. Before as-cending, the victim had asked the coworker toshut down the conveyor so that he could clearthe jam. After shutting down the conveyor, thecoworker turned away to get more paper. Thevictim fell into the baling chamber and the balerram automatically activated. (NIOSH FACE, 9715)

Preventive/corrective measures: Employeesmust follow lockout/tagout procedures to de-energize all equipment prior to cleaning or per-forming maintenance. Employers must installguards on machinery to prevent any employeesfrom contacting moving parts.Where access toprocess machinery is necessary, employersshould consider installing standard railingsusing gates interlocked with the machine's con-trol system.When the gates are opened, the ma-chine will shut down.

For all equipment where pieces of scrap metal arefed into a machine directly, or using a hopper, oreven via conveyor belt, employees must be trainedin the proper use of the equipment. In addition, ap-


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oxides, and carbon monoxide and carbon dioxide.Organic compounds may be emitted as heating va-porizes oil and grease on scraps (EPA 2001). In addi-tion, heating or burning of certain plastics (such asplastic-coated wiring) may release phosgene orother hazardous substances. Emissions from fluxingtypically include chlorides and fluorides. The highestconcentrations of ‘fugitive’ emissions (i.e., gasesand vapors that escape from equipment) occurwhen the lids and doors of a furnace are openedduring charging, alloying, and other operations (EPA2001). Employers should ensure that workplaces arewell-ventilated, consider the use of local exhaustventilation during these operations, and that emis-sions from furnaces are filtered before the air is re-leased outside the facility.

Afterburners can be used to control organic com-pounds, carbon monoxide, chlorides, fluorides, andhydrochloric acid; fabric filters can be used to con-trol metal oxide dust, chlorides, fluorides, and hy-drochloric acid; wet scrubbers can be used tocontrol metal oxide dust, sulfur oxides and sulfuricacid mist; and electrostatic precipitators or fabric fil-ters can be used to control particulate or other mat-ter. These are used in different setups depending onthe specific recycling industry. EPA (2001) discussescontrol methods for some recycling industries. For afull listing of hazardous air pollutants associatedwith some metal recycling processes, such as alu-minum production, lead smelting, iron foundriesand steel foundries, see EPA’s Emission InventoryImprovement Program (EIIP), Vol. II, Table 9.2-1.(EPA 2001)

For information on ventilation, refer to the “Exam-ples of Engineering and Work Practice Control Tech-niques to Reduce Emissions” section at page 29.

Case History #8A 22-year-old male foundry laborer was electro-cuted when a piece of scrap metal he was loadinginto a damaged electric induction furnace becameenergized. The refractory had developed an un-usual degree of cracking, and molten metalseeped out of the refractory and solidified. Thismaterial was in contact with the frame, but notthe coil. Two employees lowered the scrap intothe furnace, which already contained moltensteel. The victim was resting his thighs on the topedge of the frame. The furnace was jarred, andpresumably more molten metal was releasedthrough the cracks, completing the circuit be-

non-conducting covers that require a tool to re-move. High-voltage areas must be protected to pre-vent access to unauthorized individuals. Employersmust create a lockout/tagout program and train em-ployees on proper implementation of these proce-dures.




sion apparatus• 29 CFR 1910.1000, Air Contaminants

Melting and Baking in Furnacesand OvensMany scrap metal recycling operations heat scrappieces to high temperatures to separate differentmetal components, increase the purity of scrap,bake out non-metal substances, burn off contami-nants, remove insulation from wire, or otherwiseprocess the metal scrap (EPA 2001). This may bedone using furnaces or ovens that use fuel or electri-cal heating sources.

Employees near operational furnaces are exposedto hazards even if they do not work directly with thefurnace. Heating scrap will generate metal fumes ifthe furnace temperature is above the melting pointof any of the metals in the furnace. In addition, hotpieces of metal could jump from the furnace, creatingfire or burn hazards to nearby locations or people.

Similar to many of the processes already discussed,electrical furnaces use large amounts of electricity athigh voltages to melt the metal scrap. Employeesnear these furnaces could face an electrocution haz-ard if they come into contact with a furnace in anunsafe manner. Employers must ensure that furnacerefractories are kept in good condition and that em-ployees follow electrical safety guidelines. Employ-ers should ensure that there is sufficient room foremployees to work safely in the vicinity of energizedfurnaces. For example, an employer may establish amaximum scrap metal size and weight for each type(and size) of furnace that they operate. (NIOSHFACE)

Furnaces generate smoke, dust, and metal fumes,depending on temperature and content. Combus-tion by-products may include sulfur and nitrogen

1 4


• The resulting forms of these materials followingany reaction.

• By-products.• Special cleaning agents.• The equipment used for the process.

As with every hazardous chemical introduced intothe workplace, all employees who are potentially ex-posed must be trained in the hazards associatedwith that chemical category. This requirement andother provisions of OSHA's Hazard Communicationstandard (29 CFR 1910.1200) are discussed in the“What You Need to Know about Hazard Communi-cation” section of the “Recognizing and ControllingHazards” chapter of this guide.

The most probable emissions from these processesinclude metal fumes and vapors, organic vapors,and acid gases. Other potential hazards may includehigh amounts of heat, splashing of caustic or other-wise hazardous chemicals, or combustion hazards.Employers should be knowledgeable about theprocesses that are used in their recycling operationsand should refer to MSDSs to obtain specific infor-mation regarding potential exposure to any othersubstances used in recycling processes. Employersmust comply with OSHA PELs. They may also wantto consider other recommended exposure limits(such as National Institute for Occupational Safetyand Health (NIOSH) Recommended Exposure Limits(RELs)) for the chemicals used or produced in theseprocesses.

One common process involves the use of aqua regiasolution to remove gold from gold-plated objects.Aqua regia is a mixture of two corrosive acids. Thisprocess emits acid fumes that are dangerous to in-hale. Employers using aqua regia or similar solu-tions (cyanide may also be used) must implementfeasible engineering controls, such as a fume hoodto remove fumes from the workspace. Employersmust also ensure that employees wear gloves andan apron to prevent skin or eye contact with theaqua regia solution. Not all glove and apron mate-rials protect from all corrosive substances, soemployers need to pay special attention to the capa-bilities of the PPE used. For additional informationon PPE, refer to the “Personal Protective Equip-ment” section in the “Recognizing and ControllingHazards” chapter of this guide.

After smelting or separation, metal may be refinedin an electrolytic process in which anodes from the

tween the coil and the contents of the refractory.Current passed through the piece of scrap, thevictim’s body, and to ground through the frame.(NIOSH FACE, 89OH43)

Preventive/corrective measures: Employersshould institute a regular inspection and mainte-nance program for all of their equipment.Whenproblems with equipment arise, the equipmentshould be tagged and removed from service untilit is repaired.




sion apparatus• 29 CFR 1910.1000, Air Contaminants• 29 CFR 1910.1018, Inorganic Arsenic• 29 CFR 1910.1025, Lead• 29 CFR 1910.1026, Hexavalent Chromium• 29 CFR 1910.1027, Cadmium

Sources ofAdditional Information• OSHA Construction Safety and Health Outreach

Program: Safety and Welding,http://www.osha.gov/doc/outreachtraining/htmlfiles/welding.html

• EPA (2001) Emission Inventory ImprovementProgram (EIIP), Vol. II, Table 9.2-1.

Applying Chemical Processes toRecycle MetalsChemical processes are also used in a wide range ofmetal scrap recycling industries as a means to sepa-rate scrap into its component metals, to clean scrapmetal prior to using physical processes, to removecontaminants (such as paint) from scrap material, orto extract selected metals from a batch of scrap con-taining many metal types. Chemical processes mayinclude high-temperature chlorination, electrorefining,plating, leaching, chemical separation, dissolution, re-duction, or galvanizing. Each of these processes maypresent specific safety and health hazards associatedwith how the process is carried out, as well as specificmaterial hazards associated with:• The starting reagents for the process.


1 5

Sources ofAdditional Information• OSHA Safety and Health Topics: Sampling and

Analysis, http://www.osha.gov/SLTC/samplinganalysis/index.html

• EPA Emission Inventory Improvement Program,Volume II, Chapter 9: Preferred and AlternativeMethods for Estimating Air Emissions fromSecondary Metal Processing. (EPA 2001)

Metals that OSHA RegulatesOSHA regulates the workplace exposure to manytoxic metals and their oxides. These metals arelisted in 29 CFR 1910.1000 along with employee ex-posure limits and include the following:

Table 1. OSHA-Regulated Toxic MetalsAluminum Hafnium SilverAntimony Iron TantalumArsenic Lead TelluriumBarium Magnesium ThalliumBeryllium Manganese TinBismuth Mercury TitaniumBoron Molybdenum UraniumCadmium Nickel VanadiumCalcium Osmium YttriumChromium Platinum ZincCobalt Rhodium ZirconiumCopper Selenium

OSHA also has comprehensive substance-specificstandards for hexavalent chromium (29 CFR1910.1026), arsenic (29 CFR 1910.1018), cadmium(29 CFR 1910.1027), and lead (29 CFR 1910.1025).Each of these standards establishes workplace PELsas well as specific requirements for personal moni-toring, medical surveillance, engineering controls,respiratory protection, and training.

Many of these metals do not pose any hazard topeople who handle objects containing the metal ineveryday use. In fact, low levels of many of these el-ements are needed for the human body to function.However, hazards exist when these metals areground, blasted, roasted, or melted and fumes ormetal dusts are produced and distributed in the air.Each of these metals may create health hazards toemployees recycling scrap that contains even traceamounts of that metal.

Employers can typically determine the level at whicha metal (or other hazardous chemical) poses a haz-

smelting process are placed in an electrolytic cellthat contains a cathode and an electrolyte such assulfuric acid; the metal is deposited on the cathode.In such operations, employees must be aware notonly of the hazards posed by the acid used as theelectrolyte and the metal involved but also of thehazards posed by the electrical system.




sion apparatus• 29 CFR 1910.1000, Air Contaminants• 29 CFR 1910.1200, Hazard Communication

Recognizing and ControllingHazards

How to Determine the Hazard Levels ofVarious ProcessesMetal scrap recycling operations present a wide va-riety of hazards, including health hazards associatedwith chemical exposures and safety hazards associ-ated with material processing operations and theequipment used in these tasks. This section dis-cusses the metals that may present hazards to em-ployees in recycling operations, the exposure routesthrough which employees may be exposed to thatmetal and the potential health effects from that ex-posure. This section also addresses other chemicalhazards of special note (e.g., metalworking fluidsand radioactive material), and discusses ways thatemployers and employees can identify and controlthese hazards. Finally, the section discusses someways that employers and employees can decreasethe risks of employee exposure to these hazards.There is little data available to describe the level ofair contaminants associated with specific metalscrap recycling operations. Employers and man-agers need to analyze the levels of various haz-ardous substances directly, using personal and areamonitoring devices to assess employee exposures.After doing this, employers must comply with allOSHA standards. Employers may also want to con-sider recommendations by NIOSH (i.e., RELs) to de-termine the need for additional controls (e.g.,engineering controls, PPE).

1 6


• OSHA Hazard Communication Web Pagehttp://www.osha.gov/SLTC/hazardcommunications/index.html

WhatYou Need to Know aboutArsenic ExposureThe United States has not produced primary arsenicsince 1985. All arsenic for domestic needs is im-ported, primarily from China (arsenic trioxide andarsenic metal) and Japan (arsenic metal). Histori-cally, approximately 90% of the domestic use of ar-senic was for chromated copper arsenate (CCA), awood preservative that is now being phased out forresidential uses due to concerns over toxicity. Somecoal is rich in arsenic and arsenic is sometimesfound in coal pollution. Arsenic compounds and ar-senic metal are also used in electronics, pigments,and metal alloys, and are sometimes used in glass-making. There is also limited demand for arsenicmetal to be alloyed with lead and antimony for am-munition, solders, and other applications. (USGS2001)

Arsenic may be found in contaminated workplaceair resulting from smelting operations, in recyclingfacilities that deal with various nonferrous metalalloys, or with electronic semiconductors. Arsenicexposure can occur in the workplace through inhala-tion, ingestion, or dermal contact.

Exposure to high concentrations of arsenic cancause sore throats or irritated lungs. Breathing inor-ganic arsenic over long periods of time can causedamage to blood vessels and nerves in the handsand feet. Redness or swelling may result from skincontact with inorganic arsenic (ATSDR 2000a). Occu-pational studies have found increased risk of lungcancer among employees exposed to inorganicarsenic for many years. IARC and NTP classify inor-ganic arsenic as a known human carcinogen. (IARC2006a; NTP 2004)

OSHA has a substance-specific standard regardingexposure to inorganic arsenic in general industry, 29CFR 1910.1018. This standard sets a PEL of 10 µg/m3

and outlines workplace requirements for the protec-tion of employees from arsenic exposure includingprovisions for exposure monitoring, preferred meth-ods for exposure control, written exposure controlprogram, respiratory protection, protective workclothing and equipment, medical surveillance, andemployee information and training.

ard to employees by referring to the OSHA PELslisted in 29 CFR 1910, Subpart Z, Toxic and Haz-ardous Substances. Employers can obtain additionalinformation on chemical hazards by referring to theNIOSH RELs listed in the NIOSH Pocket Guide toChemical Hazards. Information on exposures associ-ated with specific health effects of the OSHA-regu-lated toxic metals can be found in the referencescited in this guidance document.

In cases where employees could be exposed to mul-tiple hazardous metals or other hazardous sub-stances at the same time or during the sameworkday, employers must consider the combinedeffects of the exposure in determining safe exposurelevels. In such cases, employers must consultOSHA's standard, 29 CFR 1910.1000(d)(2), to deter-mine how to apply exposure limits to exposure situ-ations involving multiple hazardous substances.

Chemicals evaluated and found to be a suspected,anticipated, or known human carcinogen by authori-tative scientific organizations, such as the NationalToxicology Program (NTP) or the InternationalAgency for Research on Cancer (IARC) may warrantspecial consideration at any level of exposure.

Employers must also rely on chemical manufactur-ers' data (such as MSDSs) when determining thehazards of workplace chemicals.

The remainder of this section discusses the healtheffects of selected commonly recycled metals thatmay be encountered during recycling operations. Italso discusses where employees may encounterthese metals. This discussion begins with a detaileddescription of six metals for which OSHA has pro-vided comprehensive standards and/or guidance.

Applicable Standards• 29 CFR 1910.19, Special provisions for air con-

taminants• 29 CFR 1910.1000, Air Contaminants• 29 CFR 1910.1018, Inorganic Arsenic• 29 CFR 1910.1025, Lead• 29 CFR 1910.1026, Hexavalent Chromium• 29 CFR 1910.1027, Cadmium• 29 CFR 1910.1200, Hazard Communication

Sources ofAdditional Information• OSHA Safety and Health Topics: Toxic Metals,

http://www.osha.gov/SLTC/metalsheavy


1 7

lung. These immune system cells attack the beryl-lium particles, leading to damage that can result inscar tissue in the lungs. This prevents the affectedportion of the lung from functioning properly (Hath-away, Proctor, et al. 1991). There is no known curefor CBD (OSHA 1999b). Symptoms of CBD includepersistent coughing, difficulty breathing upon physi-cal exertion, fatigue, chest and joint pain, weightloss, and fevers. CBD only develops in employeessensitized to beryllium. A sensitized employee is anemployee who has developed an allergic reaction toberyllium. Exposure to beryllium, possibly evenbelow OSHA’s PEL, may sensitize an employee toberyllium, placing that employee at elevated risk ofCBD. (Bechtel 2001)

Many years ago, employees who breathed very highlevels (>100 µg/m3) of beryllium dust and fumes,even for a short period of time, developed acuteberyllium disease (ABD). This disease rarely occursin modern industry due to improved industrial pro-tective measures designed to reduce exposure lev-els. ABD is caused directly by inflammation of therespiratory tract from irritation due to tissue expo-sure to beryllium itself. Symptoms associated withABD include difficulty breathing, cough, and chestpain and occur much more rapidly than CBD symp-toms. (Lang 1994) ABD may lead to death or respira-tory illness similar to pneumonia.

Beryllium has been classified as a known humancarcinogen by NTP and IARC (NTP 2004; IARC2006a). Occupational studies reported excess lungcancer mortality among employees engaged inberyllium production and processing during the1930s to 1960s. Exposure to large amounts of beryl-lium metal and beryllium compounds in the lungs ofexperimental animals has led to increased lung can-cer. (ATSDR 2002)

As noted in the 1999 OSHA Hazard Information Bul-letin, the current eight-hour time-weighted average(TWA) permissible exposure limit (PEL) of 2 µg/m3

may not adequately prevent CBD among exposedemployees (OSHA 1999c). Control of dusts or fumesis the main preventative measure. Industries thatwork with beryllium should consider their ventila-tion systems, employee PPE, and workplace moni-toring for hazardous levels of beryllium. Foradditional control information, refer to the “How toControl Hazards” section of this guide.

Beryllium sensitization can be detected through theuse of a blood test called the BeLPT, which stands

Applicable Standards• 29 CFR 1910.19, Special provisions for air con-

taminants• 29 CFR 1910.1018, Inorganic Arsenic


http://www.osha.gov/SLTC/metalsheavy/index.html

• ATSDR Toxicology Frequently Asked Questions(ToxFAQs), http://www.atsdr.cdc.gov/toxfaq.html

WhatYou Need to Know aboutBeryllium ExposureBeryllium is used in alloy forms, as a metal, and asberyllium oxide. Beryllium is mined from two miner-als, beryl and bertrandite. The United States is oneof three countries that process beryllium ores. Mostof the beryllium is sold to the domestic market, insectors such as communications and computers,automotive electronics, industrial components, andoptical media. (USGS 2001)

The most likely place for employees to encounterberyllium is the processing of alloy metals contain-ing beryllium (http://www.osha.gov/SLTC/metalsheavy; http://www.osha.gov/SLTC/beryllium/index.html). Beryllium is often used as a metal in aero-space and defense applications, or as berylliumoxide in high-density electronics circuits (USGS2001). Both of these sources may be recycled atsome recycling plants. Beryllium is also used in cop-per and aluminum alloys and in sporting equipmentsuch as golf clubs. Beryllium copper (a type of scrapmetal that may contain high levels of beryllium) isprocessed by melting it in a furnace. Employees lo-cated near those furnaces may be exposed to beryl-lium fumes. Beryllium copper scrap is sometimesprocessed by other methods, such as chemical andelectrolytic separation; thermal reduction and burn-ing; melting and pyro-metallurgical separation; andmilling (IPMI 2001). The melting process used forsome other scrap metals may also generate fumesthat can contain beryllium. (IPMI 2001)

Employees who breathe relatively low levels ofberyllium dust and fumes may develop the lung ail-ment, chronic beryllium disease (CBD). CBD can de-velop over a few months or can take many years todevelop. The disease occurs as a result of a person'simmune system attacking beryllium present in the

1 8


Cadmium is a toxic metal commonly found in smelt-ing operations. Cadmium hazards exist for recyclingemployees cutting apart pieces of metal scrap withgas torches, and employees near furnaces that meltsuch alloys. Overexposure to cadmium may occureven in situations where only trace quantities ofcadmium are found in the raw material or in smelterdust or fumes.

Nickel-cadmium (NiCad) batteries are one of themain sources of scrap cadmium (USGS 2003). Recy-cling of large NiCad batteries, usually weighing over2 kg, typically involves emptying the electrolytesfrom the battery and dismantling the battery (cuttingoff the tops). The cadmium plates are detached,washed, dried and then sent to a recycling facilitywhere the cadmium would be loaded into the fur-nace. Cadmium in smaller batteries is typically re-covered by burning off the castings and separatorsin a furnace. Exposures to cadmium in NiCad recy-cling operations typically are associated with worknear the recycling furnaces.

Historically, cadmium was also used as a pigmentin industrial paints and may present a hazard toemployees when welding, cutting, or shreddingscrap coated with cadmium-containing paints.

Cadmium emits a characteristic brown fume (CdO)upon heating, which is relatively non-irritating. Sev-eral deaths from acute exposure occurred in welderswho welded on cadmium-containing alloys or workedwith silver solder.

Short-term exposure to high concentrations of air-borne cadmium may lead to metal fume fever withflu-like symptoms such as weakness, fever,headache, chills, sweating and muscle pain. Acutepulmonary edema (excess fluid in the lungs) usu-ally develops within 24 hours, reaching a maxi-mum in three days: if death due to asphyxiationdoes not occur, then symptoms may resolvewithin a week (http://www.osha.gov/SLTC/metalsheavy; http://www.osha.gov/SLTC/cadmium/index.html).

Longer-term exposure to lower levels of cadmiummay cause lung or prostate cancer, kidney dam-age, and hypertension. Cadmium is also believedto cause pulmonary emphysema, bone disease,and possibly anemia, teeth discoloration and lossof smell (http://www.osha.gov/SLTC/metalsheavy;ATSDR, 1999a). Cadmium is classified as a knownhuman carcinogen by IARC and NTP (IARC 2006a;

for beryllium lymphocyte proliferation test. This testmeasures how specific white blood cells called lym-phocytes react to beryllium. A confirmed positivetest result means that an employee is sensitized(OSHA l999c). While it is not known whether every-one who is sensitized will develop CBD, many ex-posed employees who were confirmed positive withthe BeLPT already had CBD or were diagnosed withthe disease at a later time.

All employees who could potentially be exposed toberyllium in the workplace should be taught to rec-ognize the following symptoms as possible signs ofCBD: unexplained cough; shortness of breath; fa-tigue; weight loss or loss of appetite; fevers; and/orskin rash. These employees should also be encour-aged to talk to their doctor or other health profes-sional about CBD and getting a BeLPT blood testregardless of symptoms. (OSHA 1999c)

Applicable Standards• 29 CFR 1910.1000, Air Contaminants• 29 CFR 1910.134, Respiratory Protection

Sources ofAdditional Information• OSHA Safety and Health Topics: Toxic Metals:

Beryllium http://www.osha.gov/SLTC/beryllium/index.html

• 10 CFR Part 850, Chronic Beryllium Disease Pre-vention Program, Final Rule. (Department of En-ergy, 9 Feb. 2006)

• OSHA. Preventing Adverse Health Effects fromExposure to Beryllium,http://www.osha.gov/dts/hib/hib_data/hib19990902.html.

• IARC 1997, Beryllium and beryllium com-pounds,http://www.inchem.org/documents/iarc/vol58/mono58-1.html

• EPA 1998, Beryllium and compounds,http://www.epa.gov/iris/subst/0012.htm

WhatYou Need to Know aboutCadmium ExposureThe worldwide production of cadmium was approx-imately 19,400 tons/year in 2005. In the U.S., onlythree companies produced cadmium in 2006: oneproduced cadmium as a by-product of the smeltingand refining of zinc while the other produced cad-mium from scrap, primarily nickel-cadmium (NiCd)batteries. (USGS 2007)


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His condition continued to worsen; he was hos-pitalized two days later and died three weekslater. (OSHA IMIS)

Preventive/corrective measures: Employers arerequired to monitor employees’ exposure tocadmium in all situations where employeesmay be exposed. If the monitoring indicates ex-posure to cadmium above the PEL, employersmust implement a full cadmium complianceprogram including provisions for engineeringcontrols, warning signs, emergency plans, andPPE, among others.

For additional details on control measures, refer tothe “How to Control Hazards” section of this guide,at page 28 or to the OSHA website section on ToxicMetals.

Applicable Standards• 29 CFR 1910.1027, Cadmium• 29 CFR 1910.19, Special provisions for air con-

taminants

Sources ofAdditional Information• OSHA 3136, Cadmium http://www.osha.gov/

Publications/osha 3136.pdf• OSHA Safety and Health Topics: Toxic Metals,


WhatYou Need to Know about HexavalentChromium ExposureChromium exists in several physical states; the mostcommon states are chromium metal (Cr0), trivalentchromium (CrIII) and hexavalent chromium (CrVI).Chromium (in its various states) has a wide rangeof uses in metals, chemicals, and refractories.Chromium metal is principally used to producestainless steel, alloy steels, and other nonferrous al-loys to improve structural and anticorrosive proper-ties. (USGS 2005)

Hexavalent chromium and trivalent chromium com-pounds are often used in electroplating of metalsand plastic substrates to improve corrosion resist-ance. Chromates (CrVI) are also used as pigmentsin paints, plastics, dyes and inks to impart corrosionresistance, heat stability, color and other qualities.Other major industrial uses of hexavalent chromium

NTP 2004). Additional information is available inCadmium, OSHA Publication 3136.

OSHA has a substance-specific standard regardingexposure to cadmium in general industry, 29 CFR1910.1027, that establishes a PEL of 5 µg/m3. Thisstandard also contains additional requirements forthe protection of employees from cadmium expo-sure such as provisions for exposure monitoring,preferred methods for exposure control (includingthe use of separate engineering control limits (orSECALS) in selected operations), written exposurecontrol plans, respiratory protection, protective workclothing and equipment, medical surveillance, andemployee information and training. OSHA Publica-tion 3136 provides additional details on these re-quirements.

Case History #9A 36-year-old man was poisoned with cadmiumfumes after smelting lead. Cadmium exposurescan occur during lead processing since lead con-centrates contain small amounts of cadmiumwhich exist naturally in the environment. The pa-tient developed pulmonary edema and died onthe fifth day after exposure. (PIM 1990)

Preventive/corrective measures: All employerswho use cadmium must monitor employeesfor exposure. In cases where employees areexposed above the PEL, employers must imple-ment a full cadmium compliance program in-cluding provisions for engineering controls,warning signs, emergency plans, and PPE,among others.

Case History #10An employee used an oxyacetylene torch to per-form demolition work on a bridge whichspanned a creek. He was assigned to salvageguardrails on the bridge and to also salvage agauge shelter which was mounted on a platformnext to the bridge. While wearing no respiratoryprotection, he spent the morning cutting anchorposts and bolts to remove the bridge rails; thesewere later found to be cadmium-coated. Afterlunch, he worked to remove the gauge shelterwhich was anchored to the platform on both anexterior and interior flange. Wearing no respira-tor, the employee entered the shelter and cut thebolts with the torch; these were galvanized. Theemployee felt ill after coming out of the shelter.

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and for corrosion resistance and color characteris-tics (as pigments) in paints.

Lead is the most recycled metal, when compared topercentage output (ISRI NDc) with the U.S. as theworld’s largest recycler of lead scrap. Most recycledlead comes from batteries where the primaryprocess involves breaking and smelting used bat-teries. (EPA 1995)

The lead in used batteries is often in the form of leadoxide, which easily forms inhalable particles. Whenworking with old batteries, employees should alsobe aware of the corrosive acid contaminated withlead (Washington 2002). Lead-acid batteries areprocessed by:• Draining the acid.• Dismantling the battery using hammer mill and

grinding.• Washing and tumbling.• Treating individual components by desulfuriza-

tion.• Feeding this to a blast furnace or electric reduc-

tion furnace to recover raw lead. (USGS 1999)

OSHA has developed the Secondary Lead SmeltereTool (http://www.osha.gov/SLTC/etools/leadsmelter) to describe ways to reduce lead exposureto employees in lead smelting plants, with sectionsthat focus on Raw Materials Processing, Smelting,Refining and Casting, Environmental Controls, andMaintenance. Many of the discussions that thiseTool provides on smelting and processing of leadshould give insights into hazards that may be en-countered by employees that deal with lead scraprecycling.

Secondary processing of lead battery scrap andother materials recycled with that scrap typicallyproduce air emissions containing other hazards in-cluding sulfur dioxide and particulate matter con-taining lead and cadmium (EPA 1995). For furtherinformation on the potential hazards from exposureto cadmium, refer to the “What You Need to Knowabout Cadmium Exposure” section of this guide.

Recyclers may also encounter lead when workingwith scraps coated with paints containing lead (es-pecially scraps originating from bridge dismantlingand rehabilitation and shipyards). Lead dust can becreated by grinding, cutting, drilling, sanding, scrap-ing or blasting surfaces coated with lead paints.Lead fumes can be created by using heat guns orother heating techniques to remove paint from sur-

containing compounds are in catalysts, as a woodpreservative, and as a chemical intermediate to pro-duce chemicals for leather tanning. (OSHA 2006)

Employees in the metal recycling industry can be ex-posed to hexavalent chromium when chromium-con-taining materials are heated such as during melting orwelding of chromium alloys such as stainless steel ora substrate with chromium protective coating.

The major illnesses associated with occupationalexposure to hexavalent chromium are lung cancer,nasal septum ulcerations and perforations, asthma,skin ulcerations and allergic and irritant contact der-matitis (OSHA 2006). Hexavalent chromium is classi-fied as a known human carcinogen by IARC andNTP. (IARC, 2006a; NTP 2004)

OSHA has a substance-specific standard regardingexposure to hexavalent chromium in general indus-try, 29 CFR 1910.1026, that establishes a PEL of 5µg/m3. The standard also includes provisions foremployee protection such as preferred methods forexposure control, respiratory protection, protectivework clothing and equipment, housekeeping, med-ical surveillance and communication of hazards.

Applicable Standards• 29 CFR 1910.1026, Hexavalent Chromium

Sources ofAdditional Information• OSHA Safety and Health Topics: Hexavalent

Chromium http://www.osha.gov/SLTC/hexavalent chromium/index.html

• OSHA 3320, Small Entity Compliance Guide forthe Hexavalent Chromium Standardshttp://www.osha.gov/Publications/OSHA_small_entity_comp.pdf

• ATSDR Toxicology Frequently Asked Questions(ToxFAQs),http://www.atsdr.cdc.gov/toxfaq.html

WhatYou Need to Know aboutLead ExposureThe United States is the world’s third-largest pri-mary producer of lead. Eighty percent of the leadore mined domestically comes from Missouri. In1993, the lead industry employed 600 employees inprimary smelting and 1,700 employees in secondarysmelting and refining.

Lead is used primarily in batteries. Other uses in-clude ammunition, sheathing on electrical cables,


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Lead poisoning is a topic of extreme concern in themedical community. Employees that encounter leadat work must take precautions so that they do notaccidentally take lead dust into their homes throughcontaminated workplace shoes or clothes. For ex-ample, employees must not be allowed to leave thefacility wearing the clothes that they wore duringtheir work shift, which may be contaminated withlead dust.

Applicable Standards• 29 CFR 1910.1025, Lead• 29 CFR 1910.19, Special provisions for air con-

taminants

Sources ofAdditional Information• OSHA, Lead: Secondary Smelter eTool,

http://www.osha.gov/SLTC/etools/leadsmelter/index.html

• OSHA Safety and Health Topics: Toxic Metals,http://www.osha.gov/SLTC/metalsheavy/index.html

WhatYou Need to Know aboutMercury ExposureThe United States relies on recycled material andimports to meet its mercury needs; no U.S. minehas recovered mercury as its main product in over adecade. Some domestic companies recover mer-cury as a by-product of other metals. Several com-panies recover and refine mercury; the largest enduses for this mercury are the production of chlorineand of caustic soda. (USGS 2002)

Mercury is typically used in electrical applicationssuch as thermometers and other gauges, valves,switches, batteries, and high-intensity dischargelights; it is used in amalgams for dentistry, in preser-vatives, in pigments, catalysts, and lubricating oils,and in heat transfer technology. The most commonenvironments where exposure is likely to occur areduring production and transportation of mercury,and mining and refining of gold and silver ores(http://www.osha.gov/SLTC/metalsheavy/index.html). Mercury and its compounds exist in threegeneral forms; elemental (metallic) mercury, inor-ganic mercury, and organic mercury.

Mercury may be present in any industry that workswith mercury or with materials that contain traceamounts of mercury. Recycling of mercury lamps is

faces, or by using heated cutting tools to cutthrough painted metal. (NYSDOH 2001)

Lead is also recycled from solder, cable covering,building construction materials, and residues anddrosses from smelter-refinery operations (USGS2001). Employees may be exposed to lead duringany of these processes.

Overexposure to lead is one of the most common-place overexposures in industry. OSHA has estab-lished the reduction of lead exposure as a highstrategic priority. Lead is a systemic poison andoverexposure to lead can damage blood-forming,nervous, urinary, cardiovascular and reproductivesystems and may cause cancer (ATSDR 1999b,Navas-Acien 2007). Lead accumulates in the bodyover time and remains in the blood for a month, inorgans for several months, and in bones for years(NYSDOH 2001). Lead affects:• the brain and nervous systems• reproductive capabilities• kidneys• cardiovascular system• the digestive system• the ability to make bloodInorganic lead is classified as a reasonably antici-pated human carcinogen by NTP and as a probablehuman carcinogen by IARC. (NTP 2004; IARC 2006b)

Early signs of lead poisoning include:• tiredness• headache• metallic taste in the mouth• poor appetite

Later signs include aches or pains in the stomach,constipation, muscle and joint pains, and memoryproblems. (NYSDOH 2001)

Employees who may have been exposed to leadshould talk to a doctor or other health professional.Your doctor may order a blood lead test which willmeasure the body’s lead levels.

OSHA has a substance-specific standard regardingexposure to lead in general industry, 29 CFR1910.1025. This standard establishes a PEL of 50µg/m3 and includes additional employee protectionprovisions such as preferred methods of control,protective work clothing and equipment, house-keeping, hygiene facilities and practices, medicalsurveillance and employee training.

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was absorbed into the professor’s body was esti-mated to be less than one-tenth of a milliliter (ap-proximately 300 mg), or the equivalent of a singlesmall droplet.

Dimethyl-mercury is absorbed through the skinand is potentially lethal in small doses. Exposureappeared to have occurred through the em-ployee’s gloves. This death by organic mercurypoisoning was directly attributable to use of thewrong type of glove material for the chemical in-volved. (OSHA IMIS)

Preventive/corrective measures: Employees mustbe trained in proper selection and use of PPE (inthis case, the correct type of gloves) and must berequired to use this PPE when handling haz-ardous substances. Employees that believe theyhave been exposed to any level of hazardous ma-terials should report the suspected exposure totheir employer and seek medical attentionpromptly.

Case History #12An employee was told to clean up some mercurythat had spilled out of a device. Three days laterhe went to an emergency room for neurologicalproblems. After two more days, he was moved toanother medical facility for further treatment.(OSHA IMIS)

Preventive/corrective measures: Employees mustbe trained in proper spill cleanup procedures, in-cluding proper selection and use of PPE whenhandling hazardous substances. If regular em-ployees are unable to effectively and safely man-age potential spills, the employer must eitherevacuate the area or have an emergency re-sponse plan in place to manage uncontrolledspills or other releases. Employees who believethat they have been exposed to hazardous sub-stances should inform their employer andpromptly seek medical attention.

Applicable Standards• 29 CFR 1910.132, Personal Protective Equip-

ment, General Requirements• 29 CFR 1910.134, Respiratory Protection• 29 CFR 1910.1000, Air Contaminants

one industry that is at risk for exposure to mercury.Emissions testing in 1999 showed that facilities thatprocess steel scrap could be a large source of mer-cury emissions (Sastry et al. ND). Other sources in-clude electronic devices such as rectifiers, switches,thermostats, relays; thermometers; dental amal-gams; and catalysts used in the production of chlo-rine and caustic soda (USGS 2001). Employees maybe exposed to mercury when smelting metals thatcontain trace levels of mercury, or when smelting in-volving processes that use mercury. Employeescould also be exposed to mercury when collectingor otherwise processing gauges containing mercury.

Exposure to high levels of metallic, inorganic, or or-ganic mercury can permanently damage the brain,kidneys, and developing fetus. Mercury’s effects onbrain functionality may result in changes in mood orpersonality (such as irritability or shyness), tremors,changes in vision or hearing, and memory prob-lems. Short-term exposure to high levels of metallicmercury vapor may cause adverse effects includinglung damage, nausea, vomiting, diarrhea, increasesin blood pressure or heart rate, skin rashes, and eyeirritation. (ATSDR 1999d)

In addition to the OSHA PEL for mercury (29 CFR1910.1000, Table Z-2), OSHA has published guide-lines in CPL 02-02-006, Inorganic Mercury and itsCompounds, for protecting employees from occupa-tional exposure to inorganic mercury. These guide-lines provide suggestions for exposure monitoring,medical surveillance, training, PPE, housekeeping,and personal hygiene facilities and practices. (OSHA1978, 1985)

Case History #11A college chemistry professor spilled a few dropsof dimethyl-mercury on the back of her glovedhand while the chemical was being transferredbetween containers. She promptly cleaned upand did not think any more about it. This was theonly time the material was handled outside of aclosed container.

The first symptoms did not occur until twomonths later, and they were ascribed to gastroen-teritis. Neurological symptoms appeared after anadditional two months, and she died five monthslater of organic mercury poisoning.

A lapse time between exposure and the appear-ance of symptoms is characteristic of alkyl mer-cury poisoning. The amount of the chemical that


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cause skeletal problems in those with poor kidneyfunction. High levels of aluminum were found inpeople with Alzheimer’s disease, but it is not knownwhether the aluminum is a cause of this disease.(ATSDR 1999c)

Antimony is derived primarily from the recycling oflead-acid batteries (USGS 2002). It may be found inthe air near industries that process or release it, in-cluding smelters, coal-fired power plants, and refuseincinerators. Occupational overexposure to anti-mony has been reported to result in eye and respira-tory tract irritation, chronic lung disease, andpossibly cardiovascular and gastrointestinal effects.(ATSDR 1992a)

Cobalt exposure may be a problem for employeeswho make or use grinding or cutting tools, or thatrefine or process cobalt metals, or that use cobalt orproduce cobalt alloys. Cobalt is typically processedin an electric arc furnace operating under reducingconditions to adjust cobalt’s chemical composition,or by roasting of spent catalysts, chlorination orleach milling, or by other chemical processes(USGS 1999; Jones 1998). Most recycled cobaltcomes from used catalysts from the petroleum andchemical industries, cemented carbides used in cut-ting and wear-resistant applications, rechargeablebatteries, superalloys, magnetic- and wear-resistantalloys, and tool steel (USGS 2001). Occupationaloverexposure to cobalt can result in respiratory irri-tation, chronic lung inflammation and pulmonary fi-brosis. Possible cardiac and neurological effectshave also been reported. Skin contact can cause anallergic contact dermatitis (ATSDR 2004a). IARC hasclassified metallic cobalt containing tungsten car-bide as probably carcinogenic to humans and othercobaolt compounds as possibly carcinogenic to hu-mans. (IARC 2006c)

Copper may be present in dust in industries thatgrind or weld copper metal. Direct metal scrap (pri-marily alloy scrap) is the main source of copperscrap, with other copper scrap coming from coppersmelters and refiners, brass mills, brass and bronzeingot makers, aluminum and steel alloy producers,foundries, and chemical plants (USGS 2001). Em-ployees might breathe, or have skin contact withthis dust. Occupational overexposure to copper dustcan irritate the eyes, nose and lungs and possiblylead to gastrointestinal disturbance. (ATSDR 2004b)

Iron and steel are used in construction and industrialuses including vehicles, bridges, machinery, tools,



• OSHA Safety and Health Topics: EmergencyPreparedness and Response,http://www.osha.gov/SLTC/emergency pre-paredness/index.html


• OSHA (1978) CPL 02-02-006 Inorganic Mercuryand its Compounds

• OSHA (1985) CPL 02-02-006 CH-1 Removal ofObsolete Sections

WhatYou Need to Know about Exposureto Other MetalsOSHA has published extensive information on ar-senic, beryllium, cadmium, hexavalent chromium,lead, and mercury. In addition to these metals, em-ployers should also limit employee exposure to allother hazardous metals handled or processed inmetal scrap recycling operations. This section of theguide discusses additional metals for which OSHAand other agencies have collected health informa-tion. The section also notes some of the commonprocessing techniques for those metals, where infor-mation was available.

The current PELs for each of the metals discussed inthis section can be found in 29 CFR 1910.1000, TableZ-1 or Z-2. NIOSH has recommended exposure lim-its for a number of these metals. The NIOSH RELscan be found in the NIOSH Pocket Guide availableonline at http://www.cdc.gov/niosh/npg/default.html.These exposure limits are summarized in AppendixA of this guide.

Aluminum is one of the most commonly recycledmetals and can be hazardous to employees in recy-cling operations. Scrap aluminum mostly comesfrom recycled used beverage cans (UBCs), which ac-count for over half of the recycled aluminum supply.The other main source is diecasts, which are mostlyfrom the automobile industry (USGS 2001). Employ-ees who process aluminum scrap might be exposedto high levels of aluminum dust in workplace airduring pre-processing steps that involve crushingand/or shredding and drying. Aluminum may causerespiratory problems, including coughing and possi-bly asthma from breathing dust, and it may also

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Nickel may be present as fumes or as dust in in-dustries that process nickel scrap. Nickel is used instainless steel, copper-nickel alloys, aluminum al-loys, and nickel-based alloy, and is used in electro-plating and welding products. Employees may beexposed to nickel by breathing fumes, by ingestingdust, or via skin contact. Other sources includeemission control dusts, swarf, grindings, millwaste, and waste from the stainless steel industry(USGS 2001). Skin exposure to nickel dust cancause an allergic contact dermatitis, often at theskin site where the contact occurred. Some occu-pational studies of employees exposed to nickelcompounds have found increased risk of lung andnasal cancer among employees (ATSDR 2005a).Most nickel compounds are classified as knownhuman carcinogens by IARC and NTP (IARC 2006a;NTP 2004). Employees who inhale large amountsof nickel may suffer from inflammation of the res-piratory tract, chronic bronchitis or reduced lungfunction. (ATSDR 2005a)

Selenium may be present in the air at some metalprocessing facilities typically as elemental seleniumor selenium dioxide. Selenium uses are: as a substi-tute for lead in plumbing when alloyed with bismuthand in electronics including rectifier and photo-electric applications (USGS 2001). Occupationaloverexposure to selenium may lead to eye, skin,respiratory tract irritation, bronchitis, and breathingdifficulties. (ATSDR 2003)

Silver is used in solder, which may be found withmany types of scrap metal. Silver is found in photo-graphic plates and solutions, and in silver recoverycartridges (VADEQ 2001). Other large sources ofscrap silver include jewelers’ sweepings, catalysts,electronic scrap, and other metal materials (USGS2001). Exposure to high levels of silver for a long pe-riod of time may result in argyria, which is a blue-gray discoloration of skin and other body tissue.Argyria is permanent but it does not have anyknown health effects. Lower levels of silver expo-sure can also cause silver deposition in areas of thebody. A study found that 21% and 25% of silverreclamation employees exhibited conjunctival andcorneal argyrosis, respectively, and that 74% of thesubjects exhibited some degree of internal nasal-septal pigmentation. The route of exposure mayhave been direct absorption by the eyes. No associ-ation was observed between these depositions anddecreased visual ability (ATSDR 1990). Exposure tohigh levels of silver can also cause breathing prob-lems, lung and throat irritation, and stomach pain. In

buildings, containers, highways, and appliances.The primary source of obsolete steel is automobiles(USGS 2001). Steel is often coated with aluminum,chromium, lead-tin alloy, tin, or zinc (refer to the sec-tions on those metals for information on their haz-ards). Steel mills melt scrap in electric arc furnacesor basic oxygen furnaces, or in blast furnaces(USGS 1999). Iron oxide is a red-brown fume with ametallic taste that can affect the respiratory systemand damage the lungs after breathing high concen-trations over many years. (http://www.osha.gov/SLTC/metalsheavy). Exposure to iron pentacarbonylis acutely toxic and can cause acute lung damage(http://www.osha.gov/dts/chemicalsampling/data/CH_247500.html), however, this form of iron may notbe commonly encountered in recycling operationssince it is used as a chemical intermediate or cata-lyst and, therefore, is not in the final products. (ISP,ND)

Manganese is ubiquitous throughout the variousgrades of steel (averaging 0.7% manganese), andcan also be found as a component in certain alu-minum alloys. The main material recycled for itsmanganese content is high-manganese (Hadfield)steel, otherwise manganese is mostly recycled inci-dentally when recycling steel and aluminum (USGS2001). Manganese exposures can occur during oper-ations at steel and aluminum recycling facilitieswhich consist of segregating scrap by content andcutting up bulky pieces as well as the melt and refin-ing processes (USGS 1999). Short-term exposure tohigh levels of manganese can result in respiratorytract irritation and inflammation of the lungs. Man-ganese exposure, at high levels over a longer periodof time, can cause manganism, a set of Parkinson-like symptoms that include mental and emotionaldisturbances, difficulty walking, and slow andclumsy body movements. Long-term exposure tomanganese at lower levels may cause deteriorationof certain motor skills (such as holding hands steadyor performing fast movements) and balance.(ATSDR 2000c)

Molybdenum is mostly recycled from catalysts.Molybdenum is also found in alloy iron and steelscrap, where it is recycled to produce steel products(USGS 2001). Employees can be exposed to molyb-denum dust during the processing of scrap whichinvolves cutting, cleaning, and baling, and possiblycalcining, drying, leaching, precipitation, and sepa-ration. Roasting, crushing, and abrading may beused in preparation for melting (USGS 1999)(http://www.osha.gov/SLTC/metalsheavy).


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WhatYou Need to Know aboutRadioactive ScrapScrap recycling industries may encounter radioac-tive metal scrap (Nijkerk 2001). This scrap could con-sist of scrap from decommissioned nuclear powerplants (steel, galvanized iron, copper, Inconel, lead,bronze, aluminum, brass, nickel, precious metals),industrial and research irradiator activities, telether-apy, industrial radiography, medical equipment,gauges, logging, and pipes from the potash industry(Legare ND), or from other sources.

Radioactive materials may pose adverse health ef-fects to employees, including cancer. Employeescould be exposed to radioactive material or dustwhen contaminated materials are crushed orground. If radioactive materials or objects aresmelted, sealed sources of radioactivity may ruptureand release their radioactive contents. Radioactivescrap in an uncontrolled setting in a processing fa-cility may cause problems with the machinery, andrequire an extensive cleanup effort and possibletemporary shutdown of the facility.

To detect radioactive material when it enters the re-cycling facility, employers can install a radiationmonitoring system to detect gamma radiation emit-ting from source materials. These systems are ex-pensive to purchase and expensive to calibrate andmaintain. It is also possible to monitor incomingmaterial with hand-held radiation detection deviceswhich can monitor for alpha, beta, and gamma radi-ation, but these devices may be less sensitive andthey require more operator skill. (Smith ND)

Fixed radiation-monitoring systems are generally in-stalled at the loading area of a scrap facility, typicallyat the weigh bridge. Factors such as the type of radi-ation emitted, the distance from monitors, shielding,and background radiation may affect the ability ofthe monitoring systems to register all radioactivity. Itmay be necessary to install multiple fixed radiation-monitoring systems to monitor the same batch ofscrap metal; common locations to install such sys-

some people, skin contact with silver can cause al-lergic reactions such as rashes, swelling, and inflam-mation.

Tin is recycled from can-making facilities, brass andbronze plants, and soldering operations (USGS2001). De-tinning involves removal of tin from newor old tinplate scrap by immersion in a heatedsodium hydroxide solution, a batch process that re-verses the tin electroplating process (USGS 1999).Employees could potentially have airborne expo-sures from fumes and dermal exposures from mate-rial handling. Inorganic tin compounds typicallyenter and leave the body rapidly and they do notusually cause harmful effects. Overexposure to or-ganic tin compounds can cause respiratory, eye, andskin irritation and interfere with the normal opera-tion of the nervous, endocrine, and reproductivesystems. (ATSDR 2005b)

Vanadium may be present as a vapor or particulatein air at facilities that work with scrap metal contain-ing vanadium. Vanadium is primarily an alloying el-ement generally less than 1%; the main supply ofvanadium scrap for recycling comes from used cat-alysts (USGS 2001). Overexposure to vanadium cancause harmful health effects to the respiratory tract(such as lung irritation, inflammation, and bronchi-tis), and can irritate the eyes (ATSDR 1992b). Van-adium pentoxide is classified as a possible humancarcinogen by IARC. (IARC 2006c)

Zinc is found as dust or fumes in air at manufactur-ing sites, and at recycling sites. The chief sources ofzinc scrap are brass, die casting scrap, flue dust,zinc sheet, galvanizing residues, and zinc die casts(USGS 2001). Zinc is processed by boiling second-ary zinc alloys and then capturing the purified zinc ina distillation column, or by casting galvanizedresidues into slabs, melting the slabs in furnacesand then condensing the zinc fumes. A more recentprocess involves dissolving the zinc coating fromscrap in a hot caustic solution and then recoveringthe zinc from the solution using an electrolyteprocess (USGS 1999). Some zinc is needed forproper body function, but high levels may be haz-ardous. Breathing large amounts of zinc can causemetal fume fever, which is thought to be an immuneresponse that affects the lungs and body tempera-ture. (ATSDR 2005c)

Applicable Standards• 29 CFR 1910.1000, Air Contaminants

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What Other HazardsYou ShouldKnowAboutIn addition to the toxicological hazards discussed inthe preceding sections, employees may face haz-ards from trace metals mixed into the scrap, or frommaterials and chemicals associated with the scrapsuch as gasoline in old cars, flammable and haz-ardous plastics surrounding cables, paint on usedbeverage cans, or from metalworking fluids used toprocess metals. Some metals are processed by oxi-dation/reduction or other chemical processes whichmay release harmful gases or harmful gaseousforms of the metal being processed.

The equipment used to process scrap metal may in-clude physical processes that cut, slice, compact,shred, or perform other operations. These pose haz-ards to machine operators and those who work inclose proximity to machine points of operation.

In addition, employers must also consider:• Fire hazards from flammable metals or other

substances.• Explosion hazards from gas canisters, tanks, or

cylinders, or from particles in the air.• Injury from falling objects.• Burns and scalding from hot air or hot materials.• Other process-specific safety hazards such as

amputation, acid burns, electrical hazards, con-fined spaces, etc.

Employers need to evaluate their metal scrap recy-cling operations to identify hazards present in theirprocesses and to develop control measures. Em-ployers should evaluate each piece of equipment toidentify related hazards and to determine the bestways to control or eliminate hazards.

OSHA has guidance documents to assist you in con-sidering many of these hazards.

Case History #13An employee mixed sodium nitrate and alu-minum out of sequence in a secondary leadsmelter factory. As a result, the pot of lead ex-ploded, burning and scalding 12 employees withmolten lead. Five employees were hospitalized formore than one week. One employee died approxi-mately 35 days after the accident as a result of theinjuries he sustained. (OSHA IMIS)

Preventive/corrective measures: Employeesshould pay close attention to sequence when

tems are at the shredder or furnace entry, or at aconveyor or sorting station. (Legare ND)

Employers should work with their suppliers to en-sure that no radioactive materials are delivered andshould also install radiation detectors as appropriate.Working with radioactive materials can cause varioustypes of cancer. There are no early warning signs forcancer. Exposure to large doses of radiation couldalso lead to acute radiation syndrome which includesnausea, vomiting, diarrhea, bleeding, coma, and evendeath. Employers must communicate the hazards ofradioactive materials to employees and should setclear instructions on how to remove any radioactivematerials that are discovered.

Applicable Standards• 29 CFR 1910.1096, Ionizing radiation

WhatYou Need to Know aboutMetalworking FluidsMetalworking fluids (MWFs), or sometimes calledmachining fluids, are “fluids used during machiningand grinding to prolong the life of the tool, carryaway debris, and protect the surfaces of workpieces.These fluids reduce friction between the cutting tooland the work surface, reduce wear and galling, pro-tect surface characteristics, reduce surface adhesionor welding and carry away generated heat.” (NIOSH98-116). Employees are unlikely to encounter MWFin conjunction with the scrap metal they process,however, they may encounter MWF in the course ofusing various heavy machinery (such as hydraulicshears) to cut apart pieces of scrap metal. MWFsmay contain toxic substances; skin exposure toMWF in liquid forms, or breathing in vapors/mistsfrom MWF, can cause dermatitis, acute and chronicrespiratory disease, skin cancer and other cancers(OSHA 1999a). Precautions for working with MWFinclude ventilation, PPE, and training for relevantprocedures. Similar precautions apply to solventsused for cleaning metal scrap prior to processing.

Applicable Standards• 29 CFR 1910.1000, Air Contaminants

Sources ofAdditional Information• OSHA Safety and Health Topics: Metalworking

Fluids, http://www.osha.gov/SLTC/metalworkingfluids/

• NIOSH 98-116, What You Need to Know AboutOccupational Exposure to Metalworking Fluids


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In all cases, employers must ensure that operatorsare fully trained to use their industrial equipment orvehicle and use caution during operation. Employersmust ensure that defective equipment is removedfrom service until it has been repaired. Only trainedemployees should operate industrial equipment andvehicles.

Employers may need to design, develop and imple-ment a comprehensive safety plan that includes, butis not limited to, analysis and control of vehicle- andmachine-related hazards through use of a dailychecklist. Equipment must be de-energized whenemployees are attempting to clean out fallen orjammed material. Employers must make sure that allelectrically powered equipment complies with appli-cable electrical standards (29 CFR 1910 Subpart S).

Applicable Standards• 29 CFR 1910 Subpart S Electrical• 29 CFR 1910.1000 Air Contaminants

Sources ofAdditional Information• OSHA 3162, Screening and Surveillance: A

Guide to OSHA Standards• OSHA 3170, Safeguarding Equipment and Pro-

tecting Employees from Amputations• OSHA 2254, Training Requirements in OSHA

Standards and Training Guidelines• OSHA Safety and Health Topics: Machine

Guarding, http://www.osha.gov/SLTC/machineguarding/index.html

• OSHA Lockout/Tagout eTool, http://www.osha.gov/dts/osta/lototraining/index.htm

Engineering Controls andWork Practice Controls

Engineering controls and work practice controls arethe primary means by which an employer can at-tempt to reduce employee exposure to the hazardsof toxic metal scraps and the equipment used toprocess those scraps.

Examples of engineering and work practice controlsinclude:• Enclosing processes where employees do not

constantly need direct access to the machinery.• Using product substitution to eliminate harmful

substances.• Installing an exhaust system to capture the air-

borne hazardous metal at the source.

mixing certain groups of chemicals. Employersshould provide written procedures for conductinghazardous processes.Where possible, theseprocesses should be conducted in isolated areasof the facility.

Applicable Standards• 29 CFR Subpart L, Fire protection• 29 CFR 1910.106, Flammable and combustible

liquids

How to Control HazardsThere are many ways to reduce the hazards themetal scrap recycling industry poses to employees.Engineering controls (for example, adding machineguards or barriers or installing ventilation, etc.) orwork practice controls (such as establishing stan-dard operating procedures or requiring the use ofPPE) can place a safer distance between an em-ployee and a potentially dangerous material orprocess. Employees must be protected (using engi-neering and work practice controls) from potentiallyharmful materials, and from the dust and fumesgenerated by these materials and the recyclingprocesses. Workplaces should be well ventilated toremove dust and fumes from the air employeesbreathe. Employers must fully communicate thehazards of their operations to employees in such away as to reduce those hazards.

Additionally, employers may need to conduct med-ical testing or medical surveillance to determinewhether the exposure levels of certain metals andother substances have placed employees at risk.Medical surveillance is an important hazard preven-tion tool that can help employers detect and elimi-nate hazardous exposures that may be affectingemployee health. Periodic medical testing is alsoimportant to help ensure prompt diagnosis andtreatment of employees suffering adverse health af-fects related to exposures (http://www.osha.gov/SLTC/medicalsurveillance). Further information onmedical screening and medical surveillance is avail-able in OSHA 3162, Screening and Surveillance: AGuide to OSHA Standards.

The following sections outline some safety recom-mendations that are specific to certain operations, butmany recommendations are common to a range ofphysical operations. Employers should become fa-miliar with available resources on safety standardsand safe work practices.

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Examples of Engineering andWork Practice ControlTechniques to Reduce Emissions

Some common engineering control techniques toreduce emissions to the atmosphere include:• Wet scrubbers for dust (particulate matter) and

acid gases. Scrubbers work by passing the mate-rial through a liquid that absorbs the dust. Liq-uids are selected based on their ability tomaximize pollutant removal.

• Thermal and catalytic incineration for organiccompounds. Incineration uses burners andchambers to ignite fuel and to allow oxidation tooccur.

• Cyclones, electrostatic precipitators (ESPs), andfabric filters, for filterable dust (EPA 2001). Cy-clones work like centrifuges, spiraling incominggases to cause heavier particulate matter to dropout of the air to a surface to be collected. Electro-static precipitators use electrical static forces tocollect particles out of a gas stream and ontocollection plates. Fabric filters (baghouses) passa gas stream through a porous fabric: the parti-cles form a layer of dust that can be removed.

Other examples of common engineering controls:• Adding machine guards or barriers.• Local exhaust ventilation, which includes both

portable ventilation systems and stationaryhoods, is generally the preferred method to con-trol emissions in the workplace. For example,cutters with local exhaust ventilation.

Employers should ensure that employees avoid pro-longed skin contact with hazardous metals andother hazardous substances either through control-ling fugitive emissions or providing appropriatePPE. In most cases, employers must not use com-pressed air to clean working surfaces or body parts.Ventilation is one of the main engineering controlsused to control exposure to chemical hazards in theworkplace. There are two basic types of ventilationsystems used for this purpose: general exhaust ven-tilation which provides ventilation for an entire roomor area and local exhaust ventilation which provideslocal exhaust at a specific work area or process.

General exhaust ventilation (i.e., dilution, ventila-tion) allows materials to be released into the generalatmosphere of the workplace and then introducesuncontaminated air to reduce concentrations of dustor vapor to acceptable levels. General exhaust ven-tilation may be appropriate where:

• Installing guard devices at nip points where em-ployees could come into contact with movingparts of machinery.

• Equipping all machinery with prominently-dis-played and properly-functioning stop buttons, ora stop cable running the length of a conveyorbelt or other equipment.

• Using explosion-proof electrical systems to re-duce hazards associated with flammable materi-als or other combustibles.

Employers should also consider the use of alternateprocesses as a way to reduce hazards. For example,in some situations, employees can use other meth-ods to cut scrap such as shears or power saws thatmay lower employee exposure to some toxic metals(e.g., hexavalent chromium) when compared totorch cutting. However, alternative methods such assaws and shears can still produce dust and noiseand create certain safety hazards.

Work practice controls involve changing employeeprocedures and practices to reduce exposure tosome substances. For example, employers may notallow employees to eat, drink, smoke, chew tobaccoor gum in areas where hazardous chemicals areused or present. Both the lead and cadmium stan-dards forbid eating or storage of food, consumptionof tobacco products and application of cosmetics inregulated areas or areas where exposures havebeen measured above the PEL.

In addition to engineering and work practice con-trols, employers can implement administrative con-trols. For example, to reduce the number ofemployees at risk during a hazardous operation, anemployer may consider performing the hazardoustask during times when fewer individuals are pres-ent in the work area.

OSHA substance-specific standards for arsenic, cad-mium, hexavalent chromium and lead contain provi-sions for change rooms and hygiene facilities suchas showers and handwashing and luncheon facili-ties. Employers must also follow other requirementsregarding clean surfaces; cleanup of spills and re-leases; and cleaning methods that minimize the riskof dispersing hazardous dust into the air. Refer tothe specific OSHA standards for these metals forfurther information on these topics. Employers canalso apply these controls for recycling operationsthat involve other metals to help minimize the pos-sibility of spreading contamination beyond workareas.


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hazards cannot be eliminated through the use of en-gineering, work practice, or administrative controls.

A PPE program must identify and evaluate potentialhazards in the workplace and indicate whether theuse of PPE is an appropriate control measure. If PPEis required, the program must address selection,use, and maintenance procedures, as well as em-ployee training and periodic reviews to evaluate itseffectiveness in preventing employee injury or ill-ness.

OSHA Publication 3151, Personal Protective Equip-ment, discusses PPE and the ways that employersand employees can identify hazards requiring PPE.For example, employees exposed to various safetyhazards from operating heavy equipment may re-quire adequate body protection including head andfoot protection, gloves, durable clothing, hearingprotection and safety glasses. Hazards from skincontact with materials can be addressed through theuse of gloves and other protective clothing. A widevariety of chemical protective suits are available,and if such protection is needed employers must en-sure that the suits used are appropriate for the ma-terials of concern.

Some of the most significant hazards are associatedwith employee exposure to metal dust or fumes, sorespiratory protection is a very important considera-tion. Respirators are required when exposures ex-ceed the PEL and engineering and work practicecontrols are infeasible or insufficient. They may alsobe required in an emergency or in a designated reg-ulated area.

Employers must provide respirators at no cost toemployees, and ensure that respirators are used incompliance with applicable standards (29 CFR1910.134). Respirators can be broken down into twogeneral types, air purifying and supplied air. Air pu-rifying respirators are typically tight fitting respira-tors that use replaceable filters to clean the airlocally before the person breathes that air. They canhave a facepiece that covers the whole face or onethat just covers the mouth and nose. Supplied airrespirators can be broken down into two categories,air-line respirators and self-contained breathing ap-paratus (SCBA). Air-line respirators connect thewearer’s facepiece to a remote source of air either ina bottle or an air compressor. SCBA units supply airto users through an air tank worn on the user’s back.Additional information on respirators is available inOSHA’s Small Entity Compliance Guide for the Re-

• The contaminants released into the air constitutea low hazard.

• The contaminants are unlikely to settle.• Emission is widely dispersed or uniform.

Local exhaust ventilation is designed to capture andremove hazardous dusts, vapors, or fumes at theirsource before they can enter the general workspace. Local exhaust ventilation (such as chemicalhoods) may be appropriate where the materials re-leased pose a high hazard or are highly localized;where air does not already circulate adequately toeliminate the hazard; or where employees work inclose proximity to the emission source.

Applicable Standards• 29 CFR 1910.94, Ventilation• 29 CFR 1910.1000, Air Contaminants• 29 CFR 1910.1018, Arsenic• 29 CFR 1910.1026, Hexavalent Chromium• 29 CFR 1910.1025, Lead• 29 CFR 1910.1027, Cadmium

Sources ofAdditional Information• OSHA Safety and Health Topics: Ventilation,

http://www.osha.gov/SLTC/ventilation/

Personal Protective Equipment

While engineering controls and work practice con-trols are the primary means of reducing exposure tohazardous chemicals and processes, they are not al-ways completely effective. In such cases, PPE maybe used to reduce employee exposure. OSHA re-quires the use of PPE to reduce employees’ expo-sures to hazards when engineering and admin-istrative controls are not feasible or effective in re-ducing these exposures to acceptable levels (29 CFR1910, Subpart I). PPE may include respirators, cover-alls or other full-body clothing, gloves, head cover-ings, boots, face shields, earplugs and ventedgoggles.

Employers are required to determine all exposuresto hazards in their workplace, and to determine ifPPE should be used to protect employees. Employ-ers must provide PPE for their employees if the workenvironment or processes present a hazard or arelikely to present a hazard to any part of an em-ployee’s body; or if an employee might come intocontact with hazardous chemicals, radiation, or me-chanical irritants; and potential exposure to these

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The Need to Provide Hearing Protection

Noise is a pervasive occupational health problem.According to NIOSH, 30 million employees are occu-pationally exposed to hazardous noise, and aboutone-third of these people have noise-induced hear-ing loss, nearly all caused by occupational exposureto hazardous noise levels. (NSC 2000)

OSHA requires employers to make hearing protec-tors and audiometric testing available to all employ-ees exposed to 8-hour TWA noise levels of 85 dB orabove. Employees must wear hearing protection ifexposures to noise levels are 90 dB or above (8-hourTWA) or above 85 dB (8-hr. TWA) for employeeswho have experienced a standard threshold shift.These requirements are set to ensure that employ-ees have access to protectors before they experi-ence significant hearing loss. (29 CFR 1910.95)

Employees that work with or near heavy machineryincluding melting furnaces, or material handlingequipment may need hearing protection for protec-tion from noise hazards. The incidence of noise-induced hearing loss can be reduced, or ofteneliminated, through the successful application ofengineering controls and hearing conservation pro-grams. For example, employers can install sound-proofing to enclose loud processes or equipment tostop loud noises from traveling to all work areas. Ifengineering controls are not adequate to eliminateproblematic workplace noise, employees can usehearing protection devices such as earplugs, canalcaps, or earmuffs.

For additional information regarding OSHA require-ments and guidance on hearing protection, refer toOSHA 3074, Hearing Conservation. To ensure com-pliance, employers should also refer directly to theOSHA standards in 29 CFR 1910.95.

Applicable Standards• 29 CFR 1910.95, Occupational Noise Exposure

Sources ofAdditional Information• OSHA 3074, Hearing Conservation• OSHA Safety and Health Topics: Noise and

Hearing Conservation,http://www.osha.gov/SLTC/noisehearingconservation/

• National Safety Council, Safeworker,http://www.nsc.org/pubs/sw.htm

vised Respiratory Protection Standard, Publication9071, available online at http://www.osha. gov/Publi-cations/SECG_ RPS/secg_rps.html orhttp://www.osha.gov/Publications/secgrev-current.pdf

Employees using metalworking fluids or chemicalbaths to dissolve or clean metal scrap may be atadded risk of hazardous chemicals spraying ontotheir bodies or heads and would need appropriateprotection. Employees that use high-temperaturegas torches need eye protection for flying pieces ofscrap and for different types and intensities of lightand possibly full-body protection from the extremeheat generated by some gas torches. Employeeswho weld or torchcut stainless steel must be in-formed of the hazards of hexavalent chromium thatis generated in the process and can be inhaled withthe fumes.

Employers must dispose of and/or properly clean,launder, repair, and replace PPE. Employees shouldnot be allowed to take work clothing or equipmenthome or off the work site, and are prohibited fromdoing so under OSHA’s Cadmium standard, 29 CFR1910.1027, and Hexavalent Chromium standard, 29CFR 1910.1026. Employers subject to OSHA’s Ar-senic and Lead standards (29 CFR 1910.1018 and1910.1025, respectively) must train their employeeson the hazards related to exposure to contaminatedclothing. Employers should provide clearly-markedcontainers for PPE and maintain separate storageareas for work clothes and street clothes. FurtherPPE suggestions are discussed along with eachprocess, earlier in this document.

Applicable Standards• 29 CFR 1910.132, General requirements• 29 CFR 1910.133, Eye and face protection• 29 CFR 1910.134, Respiratory protection• 29 CFR 1910.135, Head protection• 29 CFR 1910.136, Occupational foot protection• 29 CFR 1910.137, Electrical protective devices• 29 CFR 1910.138, Hand protection• 29 CFR 1910.1018, Arsenic• 29 CFR 1910.1025, Lead• 29 CFR 1910.1026, Hexavalent Chromium• 29 CFR 1910.1027, Cadmium

Sources ofAdditional Information• OSHA Safety and Health Topics: Ventilation,

http://www.osha.gov/SLTC/ventilation/


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The HCS provides employees the right to know thehazards and identities of the chemicals they are ex-posed to in the workplace. When employees havethis information, they can effectively participate intheir employers’ programs and take steps to protectthemselves.

Specifically, employees need to know about:• The requirements of the HCS.• Any operation in their work area where haz-

ardous chemicals are present and the nature ofthe operations that could result in exposure tothese substances.

• The physical and health hazards of chemicals inthe work area.

• Work practices and other measures employeescan take to protect themselves from potentialhazards such as emergency procedures and per-sonal protective equipment needed.

• The location and availability of the written hazardcommunication program.

• The content of applicable OSHA standards.

OSHA Publication 3111, Hazard CommunicationGuidelines for Compliance, and OSHA Publication3084, Chemical Hazard Communication, discuss therequirements of the HCS in more detail. These docu-ments discuss labeling, MSDS procedures, andother hazard communication requirements. Employ-ers must consider special communication needs toensure comprehension of the contents of the train-ing program.

The substance-specific standards for Arsenic (29CFR 1910.1018), Lead (29 CFR 1910.1025), Hexava-lent Chromium (29 CFR 1910.1026), and Cadmium(29 CFR 1910.1027) also establish requirements (e.g.,employee training, labeling, and posting of warningsigns) for communicating the hazards associatedwith these metals to potentially exposed employees.Employers must refer to these standards for specificinformation on related hazard communication re-quirements.

Applicable Standards• 29 CFR 1910.1200, Hazard Communication• 29 CFR 1910.1018, Arsenic• 29 CFR 1910.1025, Lead• 29 CFR 1910.1026, Hexavalent Chromium• 29 CFR 1910.1027, Cadmium

WhatYou Need to Know about HazardCommunicationEmployees in the recycling industry may come incontact with a wide range of hazardous materials intheir workplace. These materials may include themetals and scrap materials themselves as well asany chemicals used or produced in the recyclingprocesses. Employers must ensure that employeesare trained on the hazards of the metals and othersubstances that are in their recycling plants. In addi-tion, employers must ensure that employees aretrained on emergency procedures and that employ-ees can obtain the required information immediatelyin the event of an emergency. Employees must betrained to wear appropriate PPE and to recognize sit-uations where PPE is needed.

OSHA’s Hazard Communication standard (HCS) (29CFR 1910.1200) describes how employers are toidentify and convey information about various work-place chemical hazards. The HCS requires chemicalmanufacturers and importers to evaluate the haz-ards of the chemicals they produce or import andprovide information about these hazards and associ-ated protective measures to downstream usersthrough container labels and material safety datasheets (MSDSs). All employers with hazardouschemicals in their workplaces must develop and im-plement a written hazard communication programthat includes provisions for container labeling, em-ployee access to MSDSs and training for all poten-tially exposed employees.

Manufacturers and importers are required to pro-vide information on the scrap metal they sell to re-cyclers. Manufacturers are also required to pass onany information they have regarding known con-taminants of the scrap, as would be the case if cut-ting fluids were present. This information must, inturn, be given to the downstream users by the scraprecycler. However, the HCS does not require em-ployers to create labels and MSDSs when they scrapmanufactured articles, such as equipment, piping,radiators and furniture, when the employer scrap-ping the item did not manufacture it and does not,in fact, possess an MSDS for the item. Regardless,employers should check with their scrap supplier todetermine if MSDSs and labels or other hazard in-formation are available. If a scrap supplier obtainsan MSDS from a manufacturer or distributor, thescrap supplier must make that MSDS available toany downstream user upon request.

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Sources ofAdditional Information• OSHA 2254, Training Requirements in OSHA

Standards and Training Guidelines• OSHA 3084, Chemical Hazard Communication• OSHA 3111, Hazard Communication Guidelines

for Compliance• OSHA Hazard Communication

http://www.osha.gov/SLTC/hazardcommunications/index.html

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National Institute for Occupational Safety andHealth (NIOSH)• NIOSH. FACE. NIOSH Fatality Assessment and

Control Evaluation (FACE) Program. Onlinedatabase. http://www.cdc.gov/ niosh/face

• NIOSH 98-116. What You Need to Know AboutOccupational Exposure to Metalworking Fluids.

• NIOSH, 2005 NIOSH Pocket Guide to ChemicalHazards.

Occupational Safety and Health Administration(OSHA) Standards• 29 CFR 1910.19 – Special provisions for air con-

taminants• 29 CFR 1910.94 – Ventilation• 29 CFR 1910.95 – Occupational Noise Exposure• 29 CFR 1910.106 – Flammable and combustible

liquids• 29 CFR 1910.119 – Process safety management

of highly hazardous chemicals• 29 CFR 1910.132 – General requirements• 29 CFR 1910.133 – Eye and face protection• 29 CFR 1910.134 – Respiratory protection• 29 CFR 1910.135 – Head protection• 29 CFR 1910.136 – Occupational foot protection• 29 CFR 1910.137 – Electrical protective devices• 29 CFR 1910.138 – Hand protection• 29 CFR 1910.147 – The control of hazardous en-

ergy (lockout/tagout)• 29 CFR 1910.176 – Handling materials – gen-

eral.• 29 CFR 1910.178 – Powered industrial trucks• 29 CFR 1910.179 – Overhead and gantry cranes• 29 CFR 1910.180 – Crawler locomotive and

truck cranes• 29 CFR 1910.181 – Derricks• 29 CFR 1910.184 – Slings• 29 CFR 1910.212 – General requirements for all

machines• 29 CFR 1910.219 – Mechanical power-transmis-

sion apparatus.• 29 CFR 1910.242 – Hand and portable powered

tools and equipment (general)• 29 CFR 1910.243 – Guarding of portable pow-

ered tools• 29 CFR 1910.244 – Other portable tools and

equipment• 29 CFR 1910.252 – General requirements (Weld-

ing, Cutting, and Brazing)• 29 CFR 1910.253 – Oxygen-fuel gas welding

and cutting• 29 CFR 1910.1000 – Air Contaminants• 29 CFR 1910.1000, Table Z-1 – Limits for Air

Contaminants

References

American National Standards Institute (ANSI)• ANSI Z87.1-2003, Occupational and Educational

Eye and Face Protection Devices• BSR Z89.1-1997, Industrial Head Protection• ANSI Z9.1, Open SurfaceTanks Operation• ANSI Z9.2, Fundamentals Covering the Design

and Operation of Local Exhaust Systems• ANSI Z9.3, Design, Construction, and Ventila-

tion of Spray Finishing Operations• ANSI Z9.4, Ventilation and Safe Practice of

Abrasive Blasting Operations• ANSI Z9.5, Laboratory Ventilation

Agency for Toxic Substances and Disease Registry(ATSDR)• ATSDR. 1990. Toxicological Profile for

Silver.• ATSDR. 1992a. Toxicological Profile for

Antimony.• ATSDR. 1992b. Toxicological Profile for Vana-

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(Update).• ATSDR. 1999c. Toxicological Profile for Alu-

minum. (Update).• ATSDR. 1999d. Toxicological Profile for Mer-

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(Update).• ATSDR. 2000b. Toxicological Profile for

Chromium (Update).• ATSDR. 2000c. Toxicological Profile for Man-

ganese.• ATSDR. 2002. Toxicological Profile for Beryl-

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(Update).• ATSDR. 2004b. Toxicological Profile for Copper.

(Update).• ATSDR. 2005a. Toxicological Profile for Nickel.

(Update).• ATSDR. 2005b. Toxicological Profile forTin.• ATSDR. 2005c. Toxicological Profile for Zinc.

(Update).• ATSDR. ND Toxicology Frequently Asked Ques-

tions (ToxFAQs), http://www.atsdr.cdc. gov/tox-faq.html


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Guide to OSHA Standards• OSHA 3170, Safeguarding Equipment and Pro-

tecting Employees from Amputations• OSHA 3320, Small Entity Compliance Guide for

the Hexavalent Chromium Standards

Occupational Safety and Health Administration(OSHA) Releases• OSHA. 1999a. Summary of Final Report of the

OSHA Metalworking Fluids Standards AdvisoryCommittee. July 1999.http://www.osha.gov/dhs/reports/metalworking/MWFSAC-FinalReportSummary.html

• OSHA. 1999b. OSHA Alerts Workers to Beryl-lium Exposure, Trade News Release, 9/17/99.http://www.osha.gov/pls/oshaweb. show_document?p_table=New_Release& p-id=283

• OSHA. 1999c. Preventing Adverse Health Ef-fects from Exposure to Beryllium.http://www.osha.gov/dts/hib/hib_data/hib19990902.html

• OSHA 2001. OSHA Launches National Empha-sis Program to Reduce Lead Exposure, OSHATrade News Release, July 20, 2001.

• OSHA. 1978. Directive 02-02-006 Inorganic Mer-cury and its Compounds.

• OSHA. 1985. Directive 02-02-006 CH-1 Removalof Obsolete Sections

Other ReferencesACGIH. 2004. Industrial Ventilation: A Manual ofRecommended Practice, 25th Edition. 2004.

Bechtel. 2001. Hanford Site Contractor ChronicBeryllium Disease Prevention Program, BechtelHanford, Inc., Hanford Environmental Health Foun-dation, Fluor Hanford, Pacific Northwest NationalLaboratory, CH2M Hill Hanford Group, Inc. Rev. 2,April 26, 2001.

BLS. 2003. Occupational Injuries and Illnesses inthe United States, Profiles Data 1992-2001, Version9.0. Bureau of Labor Statistics. Department ofLabor.

DOE. 2006. 10 CFR part 850, Chronic Beryllium Dis-ease Program, Final Rule (Department of Energy, 9Feb. 2006).

EPA. 1995. EPA Office of Compliance Sector Note-book Project. Profile of the Nonferrous Metals In-dustry. Sept. 1995.http://www.epa.gov/Compliance/resources/publications/assistance/sectors/notebooks/nfmetlsn.pdf

• 29 CFR 1910.1000, Table Z-2• 29 CFR 1910.1018 – Arsenic• 29 CFR 1910.1025 – Lead• 29 CFR 1910.1026 – Hexavalent Chromium• 29 CFR 1910.1027 – Cadmium• 29 CFR 1910.1096 – Ionizing radiation• 29 CFR 1910.1200 – Hazard Communication• 29 CFR 1910 Subpart H – Hazardous Materials• 29 CFR 1910 Subpart I – Personal Protective

Equipment• 29 CFR 1910 Subpart L – Fire protection• 29 CFR 1910 Subpart Q – Welding, Cutting and

Brazing• 29 CFR 1910 Subpart S – Electrical• 29 CFR 1926.62 – Lead in Construction• 29 CFR 1926.55 – App. A, Gases, fumes, vapors,

dusts, and musts

Occupational Safety and Health Administration(OSHA) Databases andWeb Pages• OSHA IMIS. OSHA Form 170 Reports, Integrated

Management Information System (IMIS).• OSHA eTool. OSHA, Lead Secondary Smelter

eTool, http://www.osha.gov/SLTC/etools/leadsmelter/

• OSHA eTool. Lockout/Tagout eToolhttp://www.osha.gov/dts/osta/lototraining/index.htm

• OSHA Safety and Health Topics: Main Pagehttp://www.osha.gov/SLTC/index.html


• OSHA Hazard Communication Web Page: Foun-dation of Workplace Chemical Safety Programs,http://www.osha.gov/SLTC/hazardcommunica-tions/index.html

Occupational Safety and Health Administration(OSHA) Publications• OSHA 1620, Occupational Exposure to Beryl-

lium (not yet released)• OSHA 2254, Training Requirements in OSHA

Standards and Training Guidelines• OSHA 3074, Hearing Conservation• OSHA 3084, Chemical Hazard Communication• OSHA 3111, Hazard Communication Guidelines

for Compliance• OSHA 3136, Cadmium• OSHA 3139, Occupational Exposure to Cad-

mium in the Construction Industry• OSHA 3151, Personal Protective Equipment• OSHA 3162, Screening and Surveillance: A

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ISRI. NDb. Recycling Scrap Iron and Steel. Nodate. Online at http://www.isri.org/isridownloads/ironq.pdf.

ISRI. NDc. Recycling Nonferrous Scrap Metals. Nodate. Online at http://www.isri.org/isri-downloads/nonferq.pdf.

Jones, R.T., 1998 Using a Direct-Current Arc Fur-nace to Recover Cobalt from Slags. JOM, 57 1998October.

Lang, 1994. Beryllium: a chronic problem. LeslieLang. Environmental Health Perspectives, 102(6-7),June-July 1994.

Legare, J-M, PhD, ND. Detection of RadioactiveSources in Scrap Metal. Commercial RadiationProtection Services. No date. Online athttp://www.sftext.com/radioprotection/ cuba_de-tection_radio.html.

Navas-Acien, A., Guallar, E., Silbergeld, E.K., andRothenberg, S.J. 2007. Lead Exposure and Cardio-vascular Disease – a Systematic Review. Environ-mental Health Perspectives, 115(3), March 2007.

Nijkerk, A.A. and Dalmijn, W.L. 2001. Handbook ofRecycling Techniques. The Hague: Nijkerk Consul-tancy. Fifth, revised and expanded edition, Febru-ary 2001.

NSC. ND. Accident Prevention Manual for Indus-trial Operations: Engineering and Technology. 10thEd. Itasca, IL: National Safety Council. No date.

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NTP. 2004. Eleventh Report on Carcinogens, Na-tional Toxicology Program.

NYSDOH. 2001. Lead on the Job: A Guide forWorkers, New York State Department of Health,January 2001. http://www.health.state.ny.us/nysdoh/lead/worker.htm.

OECD. 1995. Recycling of Copper, Lead, and Zinc-Bearing Wastes. Environmental Monographs No.109. Organization for Economic Cooperation andDevelopment (OECD), Paris, 1995. http://www.cpplatform.ch/technology/pdf_ docs/1114b.pdf.

EPA. 1998. Beryllium and Beryllium Compounds.http://www.epa.gov/IRIS/subst/0012.htm

EPA. 2001. Emission Inventory Improvement Pro-gram. U.S. Environmental Protection Program.2001. http://www.epa.gov/ttn/chief/eiip/

Hathaway GJ, Proctor NH, Hughes JP, and Fis-chman ML [1991]. Proctor and Hughes' chemicalhazards of the workplace. 3rd edition. New York,NY: Van Nostrand Reinhold.

IARC 1997. IARC Monographs on the Evaluation ofCarcinogenic Risks to Humans. Volume 58, Beryl-lium, Cadmium, Mercury, and Exposures in theGlass Manufacturing Industry.

IARC 2006a. List of Agents Evaluated and TheirClassifications as Evaluated in IARC MonographsVolumes 1-85. http://monographs.iarc.fr/ENG/Classification/index.php

IARC 2006b. IARC Monographs on the Evaluationof Carcinogenic Risks to Humans. Volume 87, Inor-ganic and Organic Lead Compounds.

IARC 2006c. IARC Monographs on the Evaluationof Carcinogenic Risks to Humans. Volume 86,Cobalt in Hard Metals and Cobalt Sulfate, GalliumArsenide, Indium Phosphide, and Vanadium Pen-toxide.

IPCS. 2000. International Chemical Safety Card,Beryllium. NIOSH, CEC, and IPCS.http://www.cdc.gov/niosh/ipcsneng/neng0226.html.

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ISP ND International Specialty Products IndustrialReference Guide Performance-Enhancing Productsfor Industrial Markets. No date. Online at:http://www.ispcorp.com/products/biocides/content/brochure/ind_ref.html

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USGS. 2001. U.S. Geological Survey MineralsYearbook.


USGS, 2003 Cadmium Recycling in the UnitedStates in 2000.


VADEQ. 2001. Precious Metal Recovery: Photo-graphic Silver. Virginia Department of Environ-mental Quality, Waste Management. Revision6/12/01. http://www.deq.state.va.us/waste/haz-ardous3.html.

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SUBSTA

NCE

Alu

min

um

Met

al(a

sA

l)pyr

opow

der

san

dw

eldin

gfu

mes

solu

ble

salts

and

alky

lsA

ntim

ony

and

com

pounds

exce

ptS

tibin

e(a

sS

b)

Ars

enic

,inorg

anic

com

pounds

(as

As)

;A

rsen

ic,o

rgan

icco

mpounds

(as

As)

Ars

ine

Bar

ium

,solu

ble

com

pounds,

exce

pt

Bar

ium

Sulfat

e(a

sB

a)B

ariu

msu

lfat

eB

eryl

lium

and

com

pounds

(as

Be)

Bis

muth

tellu

ride,

Undoped

Bis

muth

tellu

ride,

Se-

doped

Cad

miu

man

dco

mpounds

(as

Cd)

Chro

miu

m(V

I)co

mpounds

Chro

mic

acid

and

chro

mat

esC

hro

miu

m(II)

com

pounds

(as

Cr)

Chro

miu

m(III)

com

pounds

(as

Cr)

Chro

miu

mm

etal

(as

Cr)

Chro

miu

min

solu

ble

salts

(as

Cr)

Cobal

tm

etal

,dust

,and

fum

e(a

sC

o)

Cobal

tca

rbonyl

Cobal

thyd

roca

rbonyl

Copper

,fum

e(a

sC

u)

Copper

,dust

and

mis

t(a

sC

u)

Haf

niu

man

dco

mpounds

(as

Hf)

Hyd

rogen

sele

nid

e(a

sS

e)Ir

on

oxi

de

Iron

salts,

solu

ble

asFe

Lead

inorg

anic

(as

Pb)

Lead

Chro

mat

e

Mag

nes

ium

oxi

de

fum

e

NIOSH

REL

10m

g/m

3(tota

ldust

)5

mg/m

3(r

esp)

5m

g/m

3

2m

g/m

3

0.5

mg/m

3

Ca

C0.

002

mg/m

3[1

5-m

inute

]none

Ca

C0.

002

mg/m

3[1

5-m

inute

]0.

5m

g/m

3

10m

g/m

3(tota

ldust

)5

mg/m

3(r

esp)

Ca

Notto

exce

ed0.

0005

mg/m

3

10m

g/m

3(tota

l)5

mg/m

3(r

esp)

5m

g/m

3

Ca

(as

Cr)

Ca

0.00

1m

g/m

3

0.5

mg/m

3

0.5

mg/m

3

0.5

mg/m

3

0.5

mg/m

3

0.05

mg/m

3

0.1

mg/m

3

0.1

mg/m

3

0.1

mg/m

3

1m

g/m

3

0.5

mg/m

3

0.05

ppm

(0.2

mg/m

3 )5

mg/m

3dust

and

fum

e1

mg/m

3

0.05

0m

g/m

3

See

“Lea

din

org

anic

”an

d“C

hro

mic

acid

&ch

rom

ates

”

OSHA

PEL

15m

g/m

3as

Al(

tota

l)5

mg/m

3(r

esp)

0.5

mg/m

3

0.01

0m

g/m

3se

e19

10.1

018

0.5

mg/m

3

0.05

ppm

(0.2

mg/m

3 )0.

5m

g/m

3

15m

g/m

3(tota

l)5

mg/m

3(r

esp)

0.00

2m

g/m

3C

0.00

5m

g/m

30.

025

mg/m

3

[30-

min

ute

max

imum

pea

k]15

mg/m

3(tota

l)5

mg/m

3(r

esp)

0.00

5m

g/m

3se

e19

10.1

027

(as

Cr)

C0.

005

mg/m

3se

e19

10.1

026

0.5

mg/m

3

0.5

mg/m

3

1m

g/m

3

1m

g/m

3

0.1

mg/m

3

0.1

mg/m

3

1m

g/m

3

0.5

mg/m

3

0.05

ppm

(0.2

mg/m

3 )10

mg/m

3fu

me

0.05

0m

g/m

3se

e19

10.1

025

See

“Lea

din

org

anic

”an

d“C

hro

mic

acid

&ch

rom

ates

”15

mg/m

3

Appendix: Exposure Limits for Selected Metals

3 9

SUBSTA

NCE

Man

gan

ese

com

pounds

(as

Mn)

Man

gan

ese

fum

e(a

sM

n)

Mer

cury

(org

ano)al

kylc

om

pounds

(as

Hg)

Mer

cury

(Ele

men

tala

nd

Inorg

anic

form

)M

ercu

ryva

por

Moly

bden

um

inso

luble

com

pounds

(as

Mo)

Moly

bden

um

solu

ble

com

pounds

Nic

kelc

arbonyl

(as

Ni)

Nic

kel,

met

al(a

sN

i)N

icke

l,in

solu

ble

com

pounds

(as

Ni)

Nic

kel,

solu

ble

com

pounds

(as

Ni)

Osm

ium

tetr

oxi

de

(as

Os)

Pla

tinum

,met

alPla

tinum

,solu

ble

salts

(as

Pt)

Rho

dium

(as

Rh)

,met

alfu

me

and

inso

lubl

eco

mpo

unds

Rhodiu

m(a

sR

h),

solu

ble

com

pounds

Sel

eniu

man

dco

mpounds

(as

Se)

Sel

eniu

mhex

aflu

ori

de

(as

Se)

Silv

er,m

etal

(as

Ag)

Silv

er,s

olu

ble

com

pounds

(as

Ag)

Stibin

e(A

ntim

ony

hyd

ride)

Tanta

lum

,met

alan

doxi

de

dust

Tellu

rium

and

com

pounds

(as

Te)

Tellu

rium

hex

aflu

ori

de

(as

Te)

Tetr

aeth

ylle

ad(a

sPb)

Tetr

amet

hyl

lead

(as

Pb)

Thal

lium

,solu

ble

com

pounds

(as

Tl)

Tin,i

norg

anic

com

pounds

(exc

eptoxi

des

)(a

sS

n)

Tin,o

rgan

icco

mpounds

(as

Sn)

Tin(II)

oxi

de

Tin(IV

)oxi

de

Tita

niu

mdio

xide

Ura

niu

m,s

olu

ble

com

pounds

NIOSH

REL

1m

g/m

3S

T3

mg/m

3

1m

g/m

3S

T3

mg/m

3

0.01

mg/m

3S

T0.

03m

g/m

3[s

kin]

C0.

1m

g/m

3[s

kin]

0.05

mg/m

3[s

kin]

Ca

0.00

1ppm

(0.0

07m

g/m

3 )C

a0.

015

mg/m

3

Ca

0.01

5m

g/m

3

Ca

0.01

5m

g/m

3

0.00

2m

g/m

3(0

.000

2ppm

)S

T0.

006

mg/m

3(0

.000

6ppm

)1

mg/m

3

0.00

2m

g/m

3

0.1

mg/m

3

0.00

1m

g/m

3

0.2

mg/m

3

0.05

ppm

0.01

mg/m

3

0.01

mg/m

3

0.1

ppm

(0.5

mg/m

3 )5

mg/m

3S

T10

mg/m

3

0.1

mg/m

3

0.02

ppm

(0.2

mg/m

3 )0.

075

mg/m

3[s

kin]

0.07

5m

g/m

3[s

kin]

0.1

mg/m

3[s

kin]

2m

g/m

3

0.1

mg/m

3[s

kin]

2m

g/m

3

2m

g/m

3

Ca

Ca

0.05

mg/m

3

OSHA

PEL

C5

mg/m

3

C5

mg/m

3

0.01

mg/m

3C

0.04

mg/m

3

C0.

1m

g/m

3

C0.

1m

g/m

3

15m

g/m

3

5m

g/m

3

0.00

1ppm

(0.0

07m

g/m

3 )1

mg/m

3

1m

g/m

3

1m

g/m

3

0.00

2m

g/m

3

none

0.00

2m

g/m

3

0.1

mg/m

3

0.00

1m

g/m

3

0.2

mg/m

3

0.05

ppm

(0.4

mg/m

3 )0.

01m

g/m

3

0.01

mg/m

3

0.1

ppm

(0.5

mg/m

3 )5

mg/m

3

0.1

mg/m

3

0.02

ppm

(0.2

mg/m

3 )0.

075

mg/m

3[s

kin]

0.07

5m

g/m

3[s

kin]

0.1

mg/m

3[s

kin]

2m

g/m

3

0.1

mg/m

3

15m

g/m

3

0.05

mg/m

3

4 0

SUBSTA

NCE

Ura

niu

m,i

nso

luble

com

pounds

Vanad

ium

,dust

Vanad

ium

,fum

esY

ttrium

and

com

pounds

(as

Y)

Zin

cch

loride

fum

eZin

coxi

de

fum

eZin

coxi

de

dust

Zin

cst

eara

teZirco

niu

mco

mpounds

(as

Zr)

NIOSH

REL

Ca

0.2

mg/m

3S

T0.

6m

g/m

3

C0.

05m

g/m

3[1

5-m

inute

](a

sV

)C

0.05

mg/m

3[1

5-m

inute

](a

sV

)1

mg/m

3

1m

g/m

3S

T2

mg/m

3

5m

g/m

3S

T10

mg/m

3

5m

g/m

3C

15m

g/m

3

10m

g/m

3(tota

l)5

mg/m

3(r

esp)

5m

g/m

3S

T10

mg/m

3(a

sZr)

(exc

ept

Zir

coniu

mte

trac

hlo

ride.

)

OSHA

PEL

0.25

mg/m

3

C0.

05m

g/m

3(a

sV

2O5)

(res

p)

C0.

1m

g/m

3(a

sV

2O5)

1m

g/m

3

1m

g/m

3

5m

g/m

3

15m

g/m

3(tota

l)5

mg/m

3(r

esp)

5m

g/m

3

Sourc

es:2

9C

FR19

10.1

000

Table

Z-1

;29

CFR

1910

.100

0Ta

ble

Z-2

;Nat

ional

Inst

itute

for

Occ

upat

ional

Saf

ety

and

Hea

lth

(NIO

SH

)Pock

etG

uid

e,Public

atio

n97

-140

,Feb

ruar

y20

04.

LegendofA

cronymsandNotationsforA

ppendixA

Gen

eral

mg/m

3m

illig

ram

sper

cubic

met

erppm

par

tsper

mill

ion

resp

resp

irab

lefr

action

ofth

eai

rborn

epar

ticu

late

skin

indic

ates

the

pote

ntial

for

der

mal

abso

rption

tota

lto

tala

irborn

epar

ticu

late

Cce

iling

NIOSH

Ca

carc

inogen

REL

reco

mm

ended

exposu

relim

itS

TS

hort

term

exposu

relim

it

OSHA

PEL

per

mis

sible

exposu

relim

itsk

inin

dic

ates

the

pote

ntial

for

der

mal

abso

rption

Substan

ces

AA

lum

inum

Ag

Silv

erA

sA

rsen

icB

aB

ariu

mB

eB

eryl

lium

Cd

Cad

miu

mC

oC

obal

tC

rC

hro

miu

mC

rO3

Chro

miu

mO

xide

Cu

Copper

FeIr

on

Hf

Haf

niu

mH

gM

ercu

ryM

nM

angan

ese

Mo

Moly

bden

um

Ni

Nic

kel

Os

Osm

ium

Pb

Lead

Pb

3(A

sO4)

2Le

adA

rsen

ate

Pt

Pla

tinum

Rh

Rhodiu

mS

bA

ntim

ony

Se

Sel

eniu

mS

nTi

nTe

Tellu

rium

Tl

Thal

lium

VVa

nad

ium

V2O

5Va

nad

ium

Pen

toxi

de

YY

ttri

um

Zr

Zir

coniu

m


4 1

pational safety and health plans must adopt stan-dards identical to, or at least as effective as, the Fed-eral OSHA standards.

Consultation ServicesConsultation assistance is available on request toemployers who want help in establishing andmaintaining a safe and healthful workplace.Largely funded by OSHA, the service is providedat no cost to the employer. Primarily developed forsmaller employers with more hazardous opera-tions, the consultation service is delivered by stategovernments employing professional safety andhealth consultants. Comprehensive assistance in-cludes an appraisal of all mechanical systems,work practices, and occupational safety and healthhazards of the workplace and all aspects of theemployer’s present job safety and health program.In addition, the service offers assistance to em-ployers in developing and implementing an effec-tive safety and health program. No penalties areproposed or citations issued for hazards identifiedby the consultant. OSHA provides consultation as-sistance to the employer with the assurance thathis or her name and firm and any informationabout the workplace will not be routinely reportedto OSHA enforcement staff.

Under the consultation program, certain exem-plary employers may request participation in OSHA’sSafety and Health Achievement Recognition Program(SHARP). Eligibility for participation in SHARP in-cludes receiving a comprehensive consultation visit,demonstrating exemplary achievements in work-place safety and health by abating all identified haz-ards, and developing an excellent safety and healthprogram.

Employers accepted into SHARP may receivean exemption from programmed inspections (notcomplaint or accident investigation inspections)for a period of 1 year. For more information con-cerning consultation assistance, see OSHA’s web-site at www.osha.gov.

Voluntary Protection Programs (VPP)Voluntary Protection Programs and on-site consulta-tion services, when coupled with an effective en-forcement program, expand employee protection tohelp meet the goals of the OSH Act. The VPPs moti-vate others to achieve excellent safety and health re-sults in the same outstanding way as they establisha cooperative relationship between employers, em-ployees, and OSHA.

OSHA Assistance

OSHA can provide extensive help through a varietyof programs, including technical assistance abouteffective safety and health programs, state plans,workplace consultations, voluntary protection pro-grams, strategic partnerships, training and educa-tion, and more. An overall commitment toworkplace safety and health can add value to yourbusiness, to your workplace, and to your life.

Safety and Health ProgramManagement GuidelinesEffective management of employee safety andhealth protection is a decisive factor in reducing theextent and severity of work-related injuries and ill-nesses and their related costs. In fact, an effectivesafety and health program forms the basis of goodemployee protection and can save time and money(about $4 for every dollar spent) and increase pro-ductivity and reduce employee injuries, illnesses,and related workers’ compensation costs.

To assist employers and employees in develop-ing effective safety and health programs, OSHApublished recommended Safety and Health Pro-gram Management Guidelines (54 Federal Register(16): 3904-3916, January 26, 1989). These voluntaryguidelines can be applied to all places of employ-ment covered by OSHA.

The guidelines identify four general elementscritical to the development of a successful safetyand health management system:• Management leadership and employee involve-

ment,• Worksite analysis,• Hazard prevention and control, and• Safety and health training.

The guidelines recommend specific actions,under each of these general elements, to achievean effective safety and health program. The FederalRegister notice is available online at www.osha.gov.

State ProgramsThe Occupational Safety and Health Act of 1970(OSH Act) encourages states to develop and oper-ate their own job safety and health plans. OSHA ap-proves and monitors these plans. Twenty-fourstates, Puerto Rico, and the Virgin Islands currentlyoperate approved state plans: 22 cover both privateand public (state and local government) employ-ment; Connecticut, New Jersey, New York, and theVirgin Islands cover the public sector only. Statesand territories with their own OSHA-approved occu-

4 2


OSHATraining and EducationOSHA area offices offer a variety of informationservices, such as compliance assistance, technicaladvice, publications, audiovisual aids, and speakersfor special engagements. OSHA’s Training Institutein Arlington Heights, IL, provides basic and ad-vanced courses in safety and health for Federal andstate compliance officers, state consultants, Federalagency personnel, and private sector employers,employees, and their representatives.

The OSHA Training Institute also has establishedOSHA Training Institute Education Centers to ad-dress the increased demand for its courses from theprivate sector and from other federal agencies.These centers include colleges, universities, andnonprofit training organizations that have been se-lected after a competition for participation in theprogram.

OSHA also provides funds to nonprofit organiza-tions, through grants, to conduct workplace trainingand education in subjects where OSHA believesthere is a lack of workplace training. Grants areawarded annually. Grant recipients are expected tocontribute 20 percent of the total grant cost.

For more information on training and education,contact the OSHA Training Institute, Directorate ofTraining and Education, 2020 South ArlingtonHeights Road, Arlington Heights, IL, 60005, (847)297-4810, or see Training on OSHA’s website atwww.osha.gov. For further information on anyOSHA program, contact your nearest OSHA regionaloffice listed at the end of this publication.

InformationAvailable ElectronicallyOSHA has a variety of materials and tools availableon its website at www.osha.gov. These include elec-tronic compliance assistance tools, such as Safetyand HealthTopics Pages, eTools, Expert Advisors;regulations, directives, publications and videos; andother information for employers and employees.OSHA’s software programs and compliance assis-tance tools walk you through challenging safety andhealth issues and common problems to find thebest solutions for your workplace.

A wide variety of OSHA materials, including stan-dards, interpretations, directives, and more can bepurchased on CD-ROM from the U.S. GovernmentPrinting Office, Superintendent of Documents, toll-free phone (866) 512-1800.

For additional information on VPP and how toapply, contact the OSHA regional offices listed at theend of this publication.

Strategic Partnership ProgramOSHA’s Strategic Partnership Program, the newestmember of OSHA’s cooperative programs, helpsencourage, assist, and recognize the efforts ofpartners to eliminate serious workplace hazardsand achieve a high level of employee safety andhealth. Whereas OSHA’s Consultation Programand VPP entail one-on-one relationships betweenOSHA and individual worksites, most strategicpartnerships seek to have a broader impact bybuilding cooperative relationships with groups ofemployers and employees. These partnerships arevoluntary, cooperative relationships betweenOSHA, employers, employee representatives, andothers (e.g., trade unions, trade and professionalassociations, universities, and other governmentagencies).

For more information on this and other coopera-tive programs, contact your nearest OSHA office, orvisit OSHA’s website at www.osha.gov.

Alliance ProgramThrough the Alliance Program, OSHA works withgroups committed to safety and health, includingbusinesses, trade or professional organizations,unions and educational institutions, to leverageresources and expertise to develop complianceassistance tools and resources and share informationwith employers and employees to help preventinjuries, illnesses and fatalities in the workplace.

Alliance program agreements have been estab-lished with a wide variety of industries includingmeat, apparel, poultry, steel, plastics, maritime,printing, chemical, construction, paper and telecom-munications. These agreements are addressingmany safety and health hazards and at-risk audi-ences, including silica, fall protection, amputations,immigrant workers, youth and small businesses. Bymeeting the goals of the Alliance Program agree-ments (training and education, outreach and com-munication, and promoting the national dialogue onworkplace safety and health), OSHA and the AllianceProgram participants are developing and dissemi-nating compliance assistance information and re-sources for employers and employees such aselectronic assistance tools, fact sheets, toolbox talks,and training programs.

4 3G U I D A N C E F O R T H E I D E N T I F I C A T I O N A N D C O N T R O L O FS A F E T Y A N D H E A L T H H A Z A R D S I N M E T A L S C R A P R E C Y C L I N G

OSHA PublicationsOSHA has an extensive publications program. For alisting of free or sales items, visit OSHA’s websiteat www.osha.gov or contact the OSHA PublicationsOffice, U.S. Department of Labor, 200 ConstitutionAvenue, NW, N-3101, Washington, DC 20210: Tele-phone (202) 693-1888 or fax to (202) 693-2498.

Contacting OSHATo report an emergency, file a complaint, or seekOSHA advice, assistance, or products, call (800) 321-OSHA or contact your nearest OSHA Regional officelisted at the end of this publication. The teletype-writer (TTY) number is (877) 889-5627.

Written correspondence can be mailed to thenearest OSHA Regional or Area Office listed at theend of this publication or to OSHA’s national officeat: U.S. Department of Labor, Occupational Safetyand Health Administration, 200 Constitution Avenue,N.W., Washington, DC 20210.

By visiting OSHA’s website at www.osha.gov,you can also:• File a complaint online,• Submit general inquiries about workplace safety

and health electronically, and• Find more information about OSHA and occupa-

tional safety and health.

4 4


RegionVI(AR, LA, NM,* OK, TX)525 Griffin Street, Room 602Dallas, TX 75202(972) 850-4145

RegionVII(IA,* KS, MO, NE)Two Pershing Square2300 Main Street, Suite 1010Kansas City, MO 64108-2416(816) 283-8745

RegionVIII(CO, MT, NO, SO, UT,* WY*)1999 Broadway, Suite 1690PO Box 46550Denver, CO 80202-5716(720) 264-6550

Region IX(American Samoa, AZ,* CA,* HI,* NV,* GM,Northern Mariana Islands)90 7th Street, Suite 18-100San Francisco, CA 94103(415) 625-2547

Region X(AK,* ID, OR,* WA*)1111 Third Avenue, Suite 715Seattle, WA 98101-3212(206) 553-5930

Region I(CT,* ME, MA, NH, RI, VT*)JFK Federal Building, Room E340Boston, MA 02203(617) 565-9860

Region II(NJ,* NY,* PR,* VI*)201 Varick Street, Room 670New York, NY 10014(212) 337-2378

Region III(DE, DC, MD,* PA, VA,* WV)The Curtis Center170 S. Independence Mall WestSuite 740 WestPhiladelphia, PA 19106-3309(215) 861-4900

Region IV(AL, FL, GA, KY,* MS, NC,* SC,* TN*)61 Forsyth Street, SW, Room 6T50Atlanta, GA 30303(404) 562-2300

RegionV(lL, IN,* MI,* MN,* OH, WI)230 South Dearborn StreetRoom 3244Chicago, IL 60604(312) 353-2220

* These states and territories operate their own OSHA-approved job safety and health programs and cover state andlocal government employees as well as private sector employees. The Connecticut, New Jersey, New York and Virgin Is-lands plans cover public employees only. States with approved programs must have standards that are identical to, orat least as effective as, the Federal standards.

Note: To get contact information for OSHA Area Offices, OSHA-approved State Plans and OSHA Consultation Proj-ects, please visit us online at www.osha.gov or call us at 1-800-321-0SHA.

OSHA Regional Offices

osha3348 metal scrap recycling

Documents

workplace safety

theoccupational safety

types of metals

health act

types of hazards

common recycling processes

separating processes

metal recycling operations