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Re: Elimination of Lead

At 11:44 AM 9/29/97 -0500,   Ric wrote:
>    All,
>    A manufacturer of gas meters makes some small parts out of a 
>    generic "white metal" containing about 30 percent lead.  All 
>    in-process metal wastes are recycled in-house.  All out-of-service 
>    meters are either repaired or recycled.  The manufacturer would 
>    like to eliminate the use of the high lead white metal for a 
>    tin-based replacement.  The problem is finding a pressing reason 
>    to change current operations and eliminate the lead.
>    ******************************************************************
>    Is anyone aware of any pressing regulatory demands for elimination 
>    of the lead?  (like by the year 2000? or similar stuff)
>    Any pressing OSHA requirements which may make worker exposure 
>    levels more of a concern? (currently not an issue at the facility)
>    Any regulations which may make the leaded metal hard to come by 
>    for production thereby forcing a change??
>    Is anyone aware of any web sites that discuss lead and may address 
>    reasons to eliminate lead (other than from paints or in 
>    construction)?
>    ******************************************************************
>    The only positive aspects I can point to is liability reduction 
>    and another feather in the facility's cap relative to overall 
>    facility P2 improvements (reduction in toxicity) and possibly 
>    grounds for an Environmental Award.
>    Your help is always appreciated,
>    Ric
>    illig.richard@a1.dep.state.pa.us
Lead is worth getting rid of because of its high priority in EPA's policy
and enforcement activities.  Using it draws unwanted attention and is
unnecessary.  It may soon get more attention from OSHA as well.

There is little reason to continue using lead if an alternative can be
found.  It is difficult to handle lead with no environmental or
occupational exposure, and any exposure should be avoided.


Ralph E. Cooper, Ph.D.
CWRU School of Law
(216) 991-6837 (Thursdays and Fridays only)