Memorandum

TO:	Pete Andrews, Tiffany DeFoe, and David Valiente (OSHA)

FROM: 	Patricia Engel and John Wilhelmi (ERG) 

SUBJECT:	Abrasive Blasting with Coal Slag or Copper Slag Media 

DATE:	November 20, 2015 

This memo presents a brief review of the use of coal slag and copper
slag in abrasive blasting operations. The first three sections of this
memo—use of coal and copper slag in abrasive blasting, coal and copper
slag abrasive blast products, and exposures and current safety
practices—are based on information readily available from online
searches. The final section of the memo identifies and very briefly
summarizes all public comments that OSHA recently received that address
the use of coal slags or copper slags in abrasive blasting operations.
If requested by OSHA, ERG will conduct further research into any of
these topics. 

Use of Coal and Copper Slag in Abrasive Blasting

 

Abrasive blasting is generally conducted to clean and prepare surfaces
for painting. Typical surfaces where blasting occurs include those found
on vessels, bridges, water towers, tanks, pipelines, and farm equipment.
Abrasive blasting occurs in many industries, including shipbuilding,
construction, and automotive. 

The preferred blasting media for a given task depends on many factors.
These include regional differences, environmental conditions (e.g.,
temperature, moisture), project size, surface composition, environmental
concerns, price, contract specifications, employer size, and operator
preference. For many years, silica sand was the most common blasting
media used, due to its performance and low cost. However, silica sand
produces large amounts of hazardous dust, and recent silica regulatory
activity has shifted industry favor to other media that produce less
toxic dust. Two non-silica media used for abrasive blasting in recent
years are coal slag and copper slag. During an interview with ERG in
2011, an industry contact reported that these materials cost
approximately $145 per ton and $180 per ton, respectively (ERG, 2011).
Coal slag and copper slag are reportedly not suitable for blasting
“softer” surfaces (e.g., wood) which account for approximately 15
percent of blasting operations (ERG, 2014a). However, these slags are
widely used for blasting more durable surfaces (e.g., stone, metal)
which account for the majority of blasting projects. 

Table 1 (at the end of this section) summarizes how the profile of
blasting media used by industry changed between 1991 and 2006. During
this 15-year time frame, the use of both silica sand and copper slag as
blast material decreased while the use of coal slag roughly doubled.
These general trends likely continued from 2006 to the present, due to
toxicity and regulatory concerns regarding silica sand and the
diminishing national reserves of copper slag; but ERG did not identify
more recent abrasive blasting media usage data to support this
inference. 

For a sense of scale, in 1991, the industry as a whole used 4.5 million
tons of abrasive blast material (EPA, 1997). A more recent estimate from
2014 suggests that the industry uses “over 2 million tons” of
abrasive blast material annually (Novetas, 2014). Relative usage of
slags varies regionally, with copper slag predominantly used in western
states and coal slag used predominantly in eastern states. Industry
interviews indicate that approximately 80 to 90 percent of companies
that perform abrasive blasting use either coal slag or copper slag on at
least some of their projects; and approximately 50 to 90 percent of
these companies’ projects involve use of coal slag or copper slag as
blasting media (ERG, 2014b).

Table 1. Nationwide Profile of Abrasive Blasting Media, 1991 and
2005-2006

Year	Silica Sand	Coal Slag	Copper Slag	Other

1991	56%	22%	11%	11%

2005/2006	47%	42%	3%	7%

Sources: 	EPA, 1997; Novetas, 2014.

Note: 	One source (Novetas, 2014) suggests a far greater drop in silica
sand usage than indicated in the table. That source notes that silica
sand usage between 1996 and 2007 decreased by a factor of two-thirds;
however, further documentation of that estimated drop in usage was not
available. 

Coal and Copper Slag Abrasive Blast Products

Several manufacturers produce and distribute coal slag and copper slag
for abrasive blasting, and the products come in various grain sizes. The
largest manufacturer of both coal slag and copper slag is Harsco
Corporation (formerly Reed Minerals), which produces the well-known
“Black Beauty” product. Table 2 lists several coal slag and copper
slag products that ERG identified during a few hours of online searches.
The table only includes products for which beryllium content was
identified during our research. 

Table 2. Selected Coal Slag and Copper Slag Abrasive Blasting Media
Products

Manufacturer/Supplier	Product	Beryllium Content	Reference

Selected coal slag products

Abrasives, Inc.	Black Magic	“0.00063%”	Abrasives, 2015

Abrasive Technologies, Inc.	Black Diamond	“0.00036%”	ATI, 2012

American Ind. Minerals, LLC	Black-Max Coal Slag	“<0.00005%”	AIM,
2012

Ensio Resources, Inc.	Patriot-Blast	“0.0002%”	Ensio, 2015

Harsco Corporation	Black Beauty Original	“0-0.001%”	BBA, 2012a

Mobile Abrasives	Black Blast	“0-0.0003%”	MA, 2015

Opta Minerals, Inc.	Black Blast	“<0.001%”	Opta, not dated (a)

U.S. Minerals	Black Magnum	“0-0.00005%”	US Minerals, 2015

Selected copper slag products

Harsco Corporation	Black Beauty Iron	“0-0.001%”	BBA, 2012b

Opta Minerals, Inc.	Ebony Grit	“<0.001%”	Opta, not dated (b)



ERG was able to identify numerous manufacturers and suppliers of coal
slag, presumably due to this material’s more widespread use in
abrasive blasting operations (see Table 1). Some accounts suggest that
these companies previously did not disclose beryllium content in coal
slags in product Material Safety Data Sheets, but disclosures became
more commonplace after a public interest group informed OSHA failure to
disclose beryllium in this material likely violated the Hazard
Communication Standard (Public Citizen, 2012). 

Information on beryllium content in copper slag products appears to be
more limited. Table 2 presents information for two products for which
manufacturers or suppliers disclosed beryllium content in copper slag.
ERG identified other copper slag products from online searches, but
these products’ Safety Data Sheets and technical specifications
present no information on beryllium. Examples of such products include:
Kleen Blast copper slag distributed by the Kleen Blast Division;
Andrablast distributed by Saucon Resources, LLC; and various products
manufactured or distributed by foreign suppliers. 

Beryllium Exposures and Safety Practices

A complete review of beryllium exposure studies among abrasive blasting
workers was beyond the scope of this initial review. However, ERG
accessed two key studies conducted or funded by the National Institute
for Occupational Safety and Health (NIOSH). We summarize them here: 

In the late 1990s, a NIOSH-funded study examined worker exposure to
beryllium during abrasive blasting (KTA, 1998). The study evaluated air
concentrations that occurred during use of 13 different blast media,
which included silica sand, coal slag, copper slag, and several other
materials. Air samples were analyzed for more than ten different
substances. For beryllium, the highest air concentrations occurred
during blasting with coal slag, followed by blasting with copper slag,
and then followed by, in descending order: nickel, garnet, silica sand,
crushed glass, specular hematite, staurolite, steel grit, and olivine.
For a sense of magnitude, air concentrations observed during abrasive
blasting with two types of coal slag (with and without dust suppressant)
ranged from 0.19 µg/m3 to 25.0 µg/m3. For multiple copper slag
products, air concentrations observed during blasting ranged from
non-detectable to 6.41 µg/m3. A synthesis of the 1998 study published
by other authors (Public Citizen, 2012) reports that personal sampling
results for beryllium exposures during coal slag blasting reached 5.87
µg/m3—higher than OSHA’s current and proposed permissible exposure
limits. ERG could not verify the personal sampling results, because they
do not appear in the version of the study currently posted on the NIOSH
website (KTA, 1998). 

 

In 2004, NIOSH measured personal exposures to beryllium among workers
conducting abrasive blasting operations with coal slag (NIOSH, 2007).
This study involved personal exposure sampling over a 2-day period among
two employees: a blaster and an assistant. The highest 8-hour
time-weighted average personal breathing zone exposure level reported in
the study was 2.1 µg/m3—higher than OSHA’s current and proposed
permissible exposure limits. Additionally, the highest 3-hour average
time-weighted average exposure was 5.3 µg/m3.

These two NIOSH studies demonstrate the potential for abrasive blasting
workers to be exposed to elevated levels of beryllium when using coal
slag as a blasting material. If requested, ERG can provide a more
detailed literature review of this topic. (Note: Some public comments
reviewed in the next section of this memo refer to additional literature
documenting beryllium exposures during coal slag abrasive blasting
operations.)

Current safety practices for abrasive blasting include use of
respirators, isolation and containment structures, and ventilation.
Blasters generally use supplied air respirators during this activity.
After blast operations are completed and workers move outside the
containment environment, they typically use half-mask and full facepiece
air purifying respirators. In some cases, helpers or assistants may only
use cloth dust masks. Painters or inspectors typically do not work on
the site until well after blasting is completed, at which point
blasting-related dust levels would likely have subsided. 

Overview of Public Comments Regarding Uses of Coal and Copper Slag

Of the public comments that OSHA received to date on the proposed
beryllium rulemaking, ERG identified 13 that specifically mentioned
either “coal slag” or “copper slag” in the context of abrasive
blasting. This section lists and very briefly summarizes the content for
these comments, first for comments that appear to support including
abrasive blasting operations in the current rulemaking and second for
comments that do not support this. 

Note: 	Two additional public comments refer to slag from power plants,
but not in the context of abrasive blasting; those two comments are not
summarized here. Additionally, one
comment—OSHA-H005C-2006-0870-1679—is only available in the Federal
Docket Management System (FDMS). ERG cannot view that comment until OSHA
provides our designated user access to the FDMS docket. Therefore, it is
possible that one additional comment (beyond those listed below)
addresses coal and copper slag in abrasive blasting. 

Comments that Support Including Slag Abrasive Blasting Operations in the
Rulemaking 

OSHA-H005C-2006-0870-1625, Julie Tremblay, 3M. Concludes that regulatory
alternative #2a offers greater worker protection against beryllium
exposures. Acknowledges that use of beryllium-containing slags as
abrasive blast material can lead to potentially hazardous airborne
beryllium levels. 

OSHA-H005C-2006-0870-1635, Jennifer Reeves, Exxon Mobil employee.
Supports expanding applicability to include abrasive blasting operations
with coal slag. Notes that existing controls (i.e., tarp enclosures)
used at her worksite are not effective at containing dusts. Submitted an
attachment with a quote from OSHA (Tiffany DeFoe) about potential
beryllium exposures from abrasive blasting with coal and copper slag. 

OSHA-H005C-2006-0870-1658, Evan Shoemaker, general public. Mentions that
use of coal and copper slag for abrasive blasting would likely lead to
elevated exposure concentrations. 

OSHA-H005C-2006-0870-1664, Lisa Maier et al., National Jewish Health.
Citing NIOSH exposure data (which are reviewed earlier in this memo),
supports expanding applicability to include abrasive blasting operations
in the maritime industry and abrasive blasting operations using coal
slag. 

OSHA-H005C-2006-0870-1670, Sammy Almashat et al., Public Citizen.
Supports expanding applicability to abrasive blasting that occurs in
maritime and construction industries, in part due to concerns regarding
exposures during blasting operations using coal slag. 

OSHA-H005C-2006-0870-1671, NIOSH: Supports expanding applicability to
include all operations where beryllium is found as a trace contaminant,
which would include coal and copper slag. Cites results from a Center
for Construction Research and Training study as evidence of elevated
beryllium exposure potential among abrasive blasting workers. See page 5
in comment file (Attachment 1 of the NIOSH submissions). 

OSHA-H005C-2006-0870-1672, Robert Scott, U.S. Congressman, House of
Representatives Committee on Education and the Workforce: Supports
expanding scope to include abrasive blasting with coal slags and copper
slags in the maritime sector; and cites exposure data from multiple
studies (including OSHA publications) as evidence for elevated worker
exposures among those who conduct abrasive blasting. (Note: The comment
refers to an attached white paper that is not included on the
regulations.gov website.) 

OSHA-H005C-2006-0870-1681, Ashlee Fitch et al., United Steelworkers:
Argues that maritime workers and construction workers should not be
excluded from the benefits of the proposed beryllium rulemaking; cites
additional data not included this memo regarding beryllium content in
coal slag; and presents proposed regulatory text for revising the
standard to include this activity. 

Comments that Do Not Support Including Slag Abrasive Blasting Operations
in the Rulemaking 

OSHA-H005C-2006-0870-1582, Kellie Allen, Jack Allen, Inc. Does not
support extending applicability to include abrasive blasting operations,
arguing that existing work practices and engineering controls
satisfactorily mitigate exposures. 

OSHA-H005C-2006-0870-1618, Matthew Paxton, Shipbuilders Council of
America. Does not support extending applicability of abrasive blasting
requirements to shipyards, noting (among other arguments) that
compliance with the Abrasive Blasting standard already sufficiently
protects workers from unhealthy beryllium exposures. 

OSHA-H005C-2006-0870-1657, Dru Branche, Newport News Shipbuilding.
Argues that it is “unnecessary and burdensome” to extend certain
proposed requirements to shipyards. Notes that designating beryllium
work areas for abrasive blasting is impractical, and indicates that
existing medical monitoring requirements for shipyard blasting personnel
need not be expanded.  

OSHA-H005C-2006-0870-1673, Jeffrey Tannenbaum, Nixon Peabody, LLP. A
25-page comment submitted on behalf of the Abrasive Blasting Materials
Alliance that generally does not support further regulation on abrasive
blasting. The term slag appears throughout the first 17 pages of the
comment, in various contexts. 

OSHA-H005C-2006-0870-1684, Maureen Sullivan, Department of Defense.
Comment does not explicitly make a statement about whether regulation
should address blasting in shipyards, but notes that blasting personnel
at shipyards are already using all feasible engineering controls, safe
work practices, and personal protective equipment. 

References

Abrasives, 2015. Safety Data Sheet for Black Magic. Abrasives, Inc.
June, 2015.   HYPERLINK
"http://www.abrasivesinc.com/docs/Black-Magic-SDS.pdf" 
http://www.abrasivesinc.com/docs/Black-Magic-SDS.pdf 

AIM, 2012. Material Safety Data Sheet for Black-Max Coal Slag. American
Industrial Minerals, LLC. April 15, 2012.
http://www.americanindminerals.com/msds/blackmax.pdf

ATI, 2012. Material Safety Data Sheet for Black Diamond Granules.
Abrasive Technologies, Inc. February 22, 2012.
http://www.ati-blackdiamond.com/media/docs/msds/msds-4B5219.pdf

BBA, 2012a. Material Safety Data Sheet for The Original Black Beauty.
Black Beauty Abrasives (BBA). November 30, 2012.   HYPERLINK
"http://www.blackbeautyabrasives.com/admin/resources/cph-msds-na-black-b
eautyr-.pdf" 
http://www.blackbeautyabrasives.com/admin/resources/cph-msds-na-black-be
autyr-.pdf 

BBA, 2012b. Material Safety Data Sheet for Black Beauty Iron. Black
Beauty Abrasives (BBA). November 30, 2012.   HYPERLINK
"http://www.blackbeautyabrasives.com/admin/resources/cph-msds-na-black-b
eautyr-iron.pdf" 
http://www.blackbeautyabrasives.com/admin/resources/cph-msds-na-black-be
autyr-iron.pdf 

Ensio, 2015. Material Safety Data Sheet for Patriot - Blast. Ensio
Resources, Inc. June, 2015.
http://www.ensioresources.com/forms/SDS_PATRIOT-BLAST_Coal_Slag_Abrasive
s_June_2015.pdf

EPA, 1997. AP-42: Compilation of Air Pollutant Emission Factors: Chapter
13.2.6, Abrasive Blasting. U.S. Environmental Protection Agency.
September, 1997.   HYPERLINK
"http://www3.epa.gov/ttn/chief/ap42/ch13/final/c13s02-6.pdf" 
http://www3.epa.gov/ttn/chief/ap42/ch13/final/c13s02-6.pdf 

ERG, 2011. Personal communication between ERG and Respondent A,
September 23, 2011.

ERG, 2014a. Personal communication between ERG and Respondent A,
September 18, 2014.

ERG, 2014b. Personal communication between ERG and Respondent B,
September 19, 2014.

MA, 2015. Safety Data Sheet for Black Blast. Mobile Abrasives. June 1,
2015. Available from:   HYPERLINK "http://mobileabrasives.com/products" 
http://mobileabrasives.com/products . 

KTA, 1998. Evaluation of Substitute Materials for Silica Sand in
Abrasive Blasting. KTA-Tator, Inc. Prepared for the National Institute
for Occupational Safety and Health.
http://www.cdc.gov/niosh/topics/silica/pdfs/ab_p1rep.pdf

Novetas, 2014. Presentation to OSHA concerning the new Proposed Silica
Rule exposure changes with focus on the Abrasive Blasting/Sand Blasting
Industry. Novetas Solutions, LLC. April 3, 2014.   HYPERLINK
"http://www.newageblastmedia.com/Novetas%20Solutions%20Presentation%20to
%20OSHA%20on%20Silica%20Rule%20April%203%202014%20final%20%282%29.pdf" 
http://www.newageblastmedia.com/Novetas%20Solutions%20Presentation%20to%
20OSHA%20on%20Silica%20Rule%20April%203%202014%20final%20%282%29.pdf 

Opta, not dated (a). Material Safety Data Sheet for Black Blast. Opta
Minerals, Inc. June, 2014.   HYPERLINK
"http://www.rodeco.com/wp-content/uploads/2014/06/Black-Blast-VMI-413-1.
pdf" 
http://www.rodeco.com/wp-content/uploads/2014/06/Black-Blast-VMI-413-1.p
df  

Opta, not dated (b). Material Safety Data Sheet for Black Blast. Opta
Minerals, Inc. June, 2014.   HYPERLINK
"http://www.rodeco.com/wp-content/uploads/2014/06/Black-Blast-VMI-413-1.
pdf" 
http://www.rodeco.com/wp-content/uploads/2014/06/Black-Blast-VMI-413-1.p
df 

Public Citizen, 2012. Enforcement of Hazard Communications Standard.
Letter from Justin Feldman (Public Citizen) to Thomas Galassi (OSHA).
January 19, 2012.
http://www.citizen.org/documents/Coal-Slag-HazCom-Memo.pdf

U.S. Minerals, 2015. Material Safety Data Sheet for Black Magnum.
January 14, 2015.
http://www.us-minerals.com/wp-content/uploads/2015/03/Coal-Slag-SDS-2.4-
2015.pdf

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