Our metal manufacturing shops are among the types of facilities eligible for the proposed one year extension.
EPA is currently proposing to: 

  • Extend the date by which the owners or operators of certain facilities must prepare or amend and implement an SPCC plan by one year to November 10, 2011;
    EPA HQ: 16,617,179 gallons of water used annually here.
  • Delay the compliance date for facilities with milk containers that are constructed according to the current applicable 3-A sanitary standards:
  • Maintain the current November 10, 2010 compliance date for drilling, production and workover facilities that are offshore or that have an offshore component, and for onshore facilities required to have and submit FRPs;
  • Reconcile the proposed compliance dates for new production facilities.

The proposed amendments do not remove the regulatory requirement for owners or operators of facilities in operation before August 16, 2002 (other than facilities with milk containers described above), to maintain and continue implementing an SPCC plan in accordance with the SPCC regulations then in effect. 
Our metal manufacturing shops are among the types of facilities eligible for the proposed one year extension.
EPA is seeking comment on whether a shorter extension period (6 to 9 months) is warranted for facilities rather than the proposed one year extension. In considering a shorter compliance extension period, we request comments on the criteria to consider, such as discharge history, size and type of facility, potential risk posed, and ability to come into compliance.
If you think that you will need more than 6 to 9 months to get your plan done and  signed by a Professional Engineer, we suggest that perhaps you might want to share your comment to that effect with EPA. 
To comment on the proposed amendments, go to  http://www.regulations.gov. Follow the online instructions to comment on Docket ID No. EPA-HQ-OPA-2009-0880. Any alternative dates presented must include appropriate rationale and supporting data for the Agency to be able to consider them for final action.
The public has the opportunity to comment on the proposed rule during a 15-day period following its publication in the Federal Register.
Clock starts ticking today.
More information on the proposed rule
Proposed dates pdf :
 Text of proposed amendments: (Please note: This is a prepublication version, this is scheduled to be published in the Federal Register today.)


"I have to get it right too?"

You wouldn’t use a gage that measures in 0.001″  increments for a requirement in 0.0001.” Why tolerate similar inaccuracies in your OSHA reporting work product?

Guest Post by James Pryor II, American Safety and Health Management Consultants, Inc.
Here are 5 tips to help keep your OSHA 300 up to requirements:

  1. Record ALL hours worked by ALL employees covered by the records – Hourly , Salary, Part Time, and Temporary
  2. If necessary, estimate  by multiplying the average number of workers by 2000 to obtain hours worked.
  3. Verify hours by  confirming against what amount was paid to unemployment insurance.
  4. If the hours  you report are too low (underestimated) the incidence rate will be too high.
  5. If the hours you report are too high (overestimated)  the incidence rate will be too low.

 Why is the incidence rate so important? It is the go / no go gage that will  determine whether or not your shop safety program gets a pass or a closer look. The DayAway and Restricted Time Report is a listing that is closely examined by OSHA. Too high an Incidence Rate will indicate a need for a review. Too low an incidence rate could give a false picture of your safety performance and lead to unintended consequences.
We don’t really have the technology to do a long form Gage R&R on your safety paperwork, but following these 5 tips will assure that your program “meets print.”
Use your passion for quality to assure high performance in all aspects of your shop’s safety program.The actionable information in your accurate OSHA 300 Log will help you continue to improve your shop’s safety performance.
Here is a link to our post on the 7 Indirect Costs of a Failed Safety Program.
Photo credit: Thanks Eighth Diary. Good luck with your work in the office!

Three points you should know about the EPA’s proposed TRI ‘Clarification’

  1. It underestimates industry burden. It would cost our Precision Machining Industry on the order of $3,534,104 in preparation,  collection of data, analysis and reporting costs.
  2. This impact falls mainly on our small businesses – 54 % of US Precision Machining shops employ less than 20 employees.
  3. The “Clarification” does not provide a positive impact on public health and safety, and it wil llikely foster over reporting, double counting of “releases” and otherwise mislead the public.

We recently attended a meeting with the Office of Management and Budget (OMB) and Environmental Protection Agency (EPA) officials regarding EPA’s proposed “Clarification” of the Article exemption under TRI 313 Reporting. We were joined with representatives of roughly 14 other industry spokespeople at this meeting. 
Read our submission to OMB and EPA.
Many precision machining shops make use of the article exemption in some form, so any changes to the definition would require all  precision manufacturing companies to reassess  their need to report under the new clarification. In the US, that means 3,364 perecision machining establishments would need to spend, according to the EPA’s own estimates, 51.3 manhours to properly evaluate and report.
While the EPA’s federal register comments indicate that only the treated lumber industry would be affected,  representatives from a wide range of  industries were in attendance to show how the proposal would eliminate the Article Exemption for their products.
PMPA was there to show how, if the Article Exemption were lost, the reporting burden  for our industry would be orders of magnitude higher than the EPA’s estimate of $13,877.
That’s right. EPA thought that the TOTAL INDUSTRY Reporting Burden for this “Clarification’ would be no more than $13,877.
Using the 2007 Survey of Manufactures data from the U.S.Census, We were able to show that the cost of evaluating our new reporting status as an industry would be at least $3,534,104. That is just for Precision Machining Shops.
For Fabricated Metals, which includes Precision Machining, the burden jumps to $66,235, 899. And for the entire 33 NAICS code, including Precision Machining, Fabricated Metals, and Machinery Manufacture, the impact is over $209 Million Dollars.
EPA’s estimate of Reporting burden for NAICS 33XXXX underestimates by a multiple factor of 15108.83 times.
PMPA’s mission and vision charges us to provide resources that  “advance and sustain”  member companies within the Precision Machining Industry.
That’s why we went to Washington. To save you and 3,363 of your peers from a “clarification” that would have burdened the industry to the the tune of about $3,534,104.  Or US manufacturers in NAICS 33 about $209 million.
 EPA would better serve its mission by clearly defining what is a release, and exempting legitimately recycled materials such as scrap metals from TRI reporting.
That’s is a change we could support.
Read our submission to OMB and EPA.

Thanking the Buffalo Business  First  for their authoritative study on manufacturing jobs lost in the top 100 markets here in the U.S. over the past decade.
Using  latest Bureau of Labor Statistics figures, G. Scott Thomas documented  10,114,400 manufacturing jobs in the top 100 markets in May 2000.
In May 2010, the number of manufacturing jobs in those same 100 markets had fallen to 6,641,900.
That is a loss of 3,472,500 manufacturing jobs, a 34.33% decline.

Lots of manufacturing people in this situation.

Surprisingly El Paso, Texas  just edged out Detroit, Michigan  for highest percentage of manufacturing jobs lost at -55.44%.
Detroit lost – 55.41 % or 221,200 jobs gone.
The most surprising fact in the study?
Only 2 of the top 100 markets showed any growth in manufacturing jobs: Las Vegas,Nevada added 0.5% (100 jobs!) and Bakersfield, California added 16.36 % or about 1800 manufacturing jobs.
Only 4 markets’ manufacturing job losses were in the single digits.
98 out of 100 of the top U.S. markets posted declines in manufacturing jobs over the decade.
What do you think that we can do to turn this around?
What will you do to make a difference?

Repost from Change the Perception:

Today's manufacturing jobs are high skill-high thinking!

Often times when you read the headlines about manufacturing job loss, the type of job is not defined. The term manufacturing is very far reaching, it really has come to include anyone that is part of creating anything material. When you read a headline that says “5,000 Manufacturing Jobs Heading for Mexico”, chances are they’re not referring to what would be called “high-skill, high-education/training” type jobs.
This is an important point to understand. We’ve drawn attention to the skilled-labor shortage in the U.S. a number of times here on CTP, because it’s a fact. It’s happening currently and it will continue to get worse…but don’t get confused, the typical manufacturing jobs in the U.S. are no longer going to the production style jobs. Manufacturing jobs in the U.S. continue to evolve into high-skill, thinking type jobs. This article illustrates the requirements needed to be competitive in today’s manufacturing job market. Manufacturing is rich with opportunity for those that know how to learn, and have a mindset of continuous-learning. Now is a great time to direct young people into manufacturing, but set them on a path of education first!
Thanks again to Ryan at Change the Perception for championing the cause of skilled manufacturing here in the US.
Photo credit

Some things you want to have bubbles, some you don’t.

Usually, Bubbles are good.

In beermaking, yeast consumes the sugars in the wort and convert them into CO2 gas bubbles- carbonation.
In steel making the main reaction is the combination of Carbon in the melt with Oxygen to form a gas. At the high temperatures involved, this gas is very soluble in the molten bath.
If the Oxygen that is available for this chemical reaction isn’t completely removed before the steel is cast the gases will continue to be forced out of the melt during solidification, resulting in porosity in the steel.
Bubbles and where the gas goes can be important in your steel part.

In order to control the evolution of gas, chemicals called deoxidizers are added to the steel. These chemicals, Silicon or Aluminum, Vanadium, Columbium, Niobium scavenge the available oxygen in the molten steel, react chemically to form solid oxide particles dispersed throughout the steel, rather than bubbles of Carbon Dioxide.
The amount and type of deoxidizer added determines the type of steel. If sufficent deoxidizers are added, no gas is evolved from the solidifying steel, and the steel is said to be “killed.” The ingot drawing labelled number 1 shows a fully killed (deoxidized) steel showing only a shrinkage cavity, and no bubbles or porosity. ( This shrinkage cavity would be cropped off in normal rolling practice.)
Because gas is still evolving, this beer is NOT KILLED.

Killed steel has more uniform chemical composition and properties than rimmed, semi-killed, or non-killed steels, and generally less segregation. The uniformity of killed steel and and its freedom from porosity makes these steels more suitable for critical components and for applications involving heat treatment.
Killed steels generally contain 0.15-.35 weight percent Silicon as a deoxidizer, and may contain  some of the other elements as mentioned above. These other elements may be used as deoxidizers or as grain refiners.
Steel grades with a Carbon maximum of 0.30 weight % and above, and all alloy steels are typically provided as “killed steels.”
Free machining steels such as 12L14, 1215, and some 11XX series steels are not “killed” with Silicon, Aluminum, etc., due to their deleterious effects on tool life and machinability. The high amounts of Manganese  in these steels form Manganese Sulfides to promote machinability, and also the Manganese scavenges excess Oxygen, preventing  evolution of CO2.
Killed steel is specified so your critical parts won't have bubbles in them.

Killed steel- for critical parts. Non-killed beer for critical  after work down time.
Beer Bubbles Photo Credit
Ingot scan from a handout in my files originally after Making Shaping and Treating of Steel.
 Beer Head Photo Credit
Bread with Holes

w00t! w00t! 1st place solar car and PMPA shop part of it!

PMPA member Wolverine Machine Products Company in Holly, Michigan knows a little bit about Precision Machining.
With their new Wardjet waterjet cutting table, they had exactly the capability that the University of Michigan Solar Car Race team needed.
A new view of Precision Machining.

They used their new waterjet capability to fabricate fixtures to help the U of M team lay-up the carbon fiber parts.
They used more traditional precision machining technologies to help the team make parts out of aluminum for wheels, suspensions, and other important systems.
Blaine Walker, Wolverine Machine’s Special Projects Manager had this to say about their role in the U of M project, “Working with the University of Michigan students gave us a great opportunity to explain tolerances, stackups and other  critical pieces of manufacturing knowledge. That they came in first place is a sign that they were listening.”
And Blaine,  that first place finish also  tells me that Wolverine Machine makes quality parts!
Here’s one other lesson for the precision machining industry:
The waterjet parts were cut out of plate material. The rest of the precision machined parts were aluminum.  Lightness and strength were critical in this solar car’s performance, and automotive jobs in the future will likely be non-traditional materials compared to todays specifications.
What do precision machining, Wolverine Machine, and Solar Cars have in common? All three of these are pointing the way to a brighter future for high skill high technology manufacturing right here at home. 
Thanks for taking on the special project, Wolverine.
And congratulations to the University of Michigan Solar Car Race team!

University of Michigan Solar Car Team

Temper colors of 0.95% carbon steel at temperatures indicated.

In steels, tempering is reheating hardened steel to some temperature below the lower critical temperature for the purpose of decreasing hardness and increasing toughness.
(The lower critical temperature is the temperature of the austenite-to-pearlite eutectoid transformation in steels- below this temperature austenite does not exist.)
Tempering is also sometimes applied to normalized steels. For the same reasons- decrease hardness and improve toughness.
The chart above shows the colors that are elicited by tempering a 0.95% carbon content steel at the temperatures shown. (Think drill rod.)
I saved this chart back in my youth from a Bethlehem Steel Handbook.
This is what we here at PMPA call “Knowledge Retention” and “Tools You Can Use.”

Poorly served by our Executive Branch!

After postponements and a head fake by the Chinese, the US Department of the Treasury has once again failed to name China as a currency manipulator.
You can read the Treasury Department  Report to Congress here.
Here’s what Treasury Tim Geithner had to say:
“What matters is how far and how fast the renminbi appreciates…We will closely and regularly monitor the appreciation of the renminbi and will continue to work towards expanded U.S. export opportunities in China that support employment in the United States, in close consultation with Congress.”
Hey Tim,  how many more years do you guys think you’ll need to closely and regularly monitor this?

 Chinese Yuans to 1 USD (invert,data) 

Chart courtesy xrates.com  

When do you guys think it will be time for action? This is the same old do nothing approach we suffered through from the last administration. (PMPA has been active on this issue since 2004 when we joined the China Currency Coalition)
When was that “Change”you guys campaigned about  supposed to arrive? 
On the China Currency Issue, NOTHING HAS CHANGED
We mentioned this before here, here and here.
So what can you do? Help us get Congress to do what the Administration can’t won’t.
National Currency Call-in  DayInstructions. Today!
Manufacturers from all across the United States will be contacting their legislators asking them to support Senate Bill 3134 and co-sponsor House Bill 2378. 
Congress needs to hear from manufacturers on this important issue, so they’ll move on legislation to provide the Administration with additional tools to prosecute illegal currency manipulators. Clearly, the Executive Branch can’t get it done. 
The time to act is now.
Photo credit: Poster, Yuan

Was held up the other day while the authorities cleaned up a bit of a mess. Fortunately, it wasn’t my mess.

What is so important that you have to text it while driving?

Delaware has become the 30th state to ban cell phone use while driving.
30 states now ban cell phone use while driving.
What about your state?
What about your community?
What about your company?
Do you have a policy regarding distracted driving?
Should you?
30 state legislatures and governors seem to think so.
 Here’s a list.
Still need a compelling business reason?
How about occupational fatality statistics for sales and managerial workers?
I’ll always take your call, but if I’m driving, it will go into voice mail.