OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

July 17, 1991

ATTENTION:     ASSISTANT REGIONAL ADMINISTRATORS
              FOR TECHNICAL SUPPORT

FROM:          THOMAS J. SHEPICH Director
              Directorate of Technical Support

SUBJECT:       Process Modification - Thermoset Resin Technology Replacement
              for Lead in Drop Hammer Punches

Akemi Plastics in Eaton Rapids, Michigan brought to our attention a system which uses a thermoset plastic resin as a replacement for lead in drop hammers. Other lead containing metal alloys used in drop hammer applications, such as kirksite, can also be eliminated. This system is according to the company making an impact in the aircraft/aerospace industry by providing companies with an alternative to lead.

We have not performed any study on the technology to identify potential safety or health hazards. However, according to Akemi Plastics this technology reduces the dependency on lead smelting needed to manufacture drop hammer punches. When this technology is used it eliminates workers' exposure to lead.

For further information please contact Ira Wainless on (FTS) 523- 7056.

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