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Editor's Note: In late summer and throughout the fall of 2002, FRONTLINE, The New York Times, and the CBC made repeated requests to McWane for an on-the-record interview, with or without cameras. Although the company would not agree to a face-to-face interview, nor allow any of their plant managers to speak with us, we provided the company with a long list of items that we were investigating, and they did address some of them in a long exchange of letters and e-mails.

In the broadcast, we drew from these letters and included portions of them at key moments. Carefully crafted letters that cannot be followed up with questions are a poor substitute for on-the-record interviews. However, we are publishing below longer verbatim excerpts from a letter sent by McWane Inc. President G. Ruffner Page on Oct. 17, 2002 that articulates the company's defense of its corporate safety and environmental policies. We have included sections related to plants owned by McWane and Ransom Industries LP, (a wholly owned subsidiary of McWane, Inc.) reported on in FRONTLINE's broadcast, "A Dangerous Business." We are doing so to demonstrate our continuing efforts to fairly reflect the company's views. Nothing in the letter causes us to doubt the accuracy of our reporting.

A. Safety Programs at McWane and Ransom.

Many years ago McWane developed and published a comprehensive model safety program based upon OSHA guidelines. This model program was distributed to the general managers of each of its plants, who are responsible for tailoring it to the specific needs and circumstances of their plants and for implementation. The program includes 37 separate sections dealing with all aspects of plant safety. When Ransom was formed in 1995, it used the McWane program as the foundation for its own program. These programs, coupled with additional safety management practices adopted at each plant, form the bedrock of McWane's effort to safely operate its facilities. Some of the elements of this program include:

  • Oversight at the corporate level. Staffing for safety at McWane and Ransom includes a vice president charged with overall supervision of their safety efforts and two full time safety coordinators who support the safety directors at each of our plants. Staffing at several facilities, including Tyler Pipe, has been substantially increased in recent years.

  • Supervisory and employee safety training procedures. The day-to-day responsibility for training falls on supervisors, the plant safety director, and his staff. Under this program, employees receive monthly training (while still on the clock) on a variety of important safety subjects throughout the year.

  • Safety committees comprised of both management and hourly employees. The hourly representatives to this committee are chosen by their union leadership to ensure an independent voice brings safety issues to management's attention. The safety committee, along with management, is required to 'guide, assist, train, and consult with the line managers in carrying out the safety program.'

  • Written safety inspection programs designed to detect and correct hazards before an accident occurs. These programs include regular safety inspections by the plant supervisors and by the plant safety director. At least annually the safety directors train the supervisors on how to conduct thorough safety inspections of their plant departments. In turn, each supervisor trains his or her employees on recognizing unsafe conditions, acts, or work methods. All employees have a responsibility to report unsafe conditions, unsafe acts, or unsafe work methods.

  • Comprehensive outside safety audits. Under this program, each plant at both companies undergoes a thorough audit by a team of 2-3 safety professionals from their respective sister facilities and frequently with an outside consultant. Each plant at both companies is audited at least once every two years, and typically every year. During 2001, I required that every plant be audited by a team of external, independent safety engineers to ensure that we were getting effective action at the plant level.

  • An annual joint safety conference including all safety personnel for additional safety training and to discuss safety management techniques. Guest speakers at these meetings include nationally recognized experts in occupational safety. For example, in 2002, Jack Schuldt, an author of several ANSI safety standards, made a presentation on machine guarding and hazard assessments.

  • Return to work programs. Workers' compensation programs are administered in tandem with return to work programs to rehabilitate injured workers as soon as possible, in accordance with any restrictions imposed by the treating physician, and in the most appropriate setting. Although bringing a recovering worker back to work in a limited duty assignment is more expensive to the company because we pay the restricted duty worker full wages instead of the limited workers' compensation benefits, our companies nevertheless adopted this practice because it is considered a 'best practice' among those with expertise in this area. For example, such programs are recommended by the American Academy of Orthopedic Surgeons, the American Association of Orthopedic Surgeons, and OSHA. The Texas Workers' Compensation Commission has also noted: 'Injured workers [in return to work programs] are able to take an active role in their recovery, resulting in less disruption to their personal and vocational lives. They heal better and faster than injured workers who remain off work.' ...

The magnitude of our efforts at McWane and Ransom is partially reflected by their costs. Expenditures on safety related projects have increased significantly over the past five years, increasing to 16% of all capital expenditures through mid-2002, while total capital expenditures have increased at an annual rate of 22% per year since 1997. In addition, both companies spend millions of dollars each year on safety related matters as a part of normal operating expenses. Although the dividends from these investments often take time to appear, they have already had an impact on the companies' safety records...

B. Environmental Programs at McWane and Ransom

The primary raw material used in the production of our product line is recycled iron and steel from junk cars, discarded appliances, engine blocks and other sources. The melting and molding processes in our facilities are similar to those used by other foundries. Like many heavy industries, the foundry industry is subject to a number of complex regulations that have been phased in over the past few decades. On occasion however, our plants have fallen short in their efforts to meet all of these requirements, as have many other companies faced with similar challenges. These instances of noncompliance have resulted from different causes that sometimes resulted in notices of noncompliance or other enforcement efforts by the regulatory authorities. Each instance, however, was resolved with the appropriate environmental agency.

McWane and Ransom employ a vice president in charge of environmental compliance who was formerly a government regulator. At the plant level McWane and Ransom together have 38 other full-time safety and environmental professionals who administer environmental and safety programs specific to the processes at their facilities. To provide overall program coordination, McWane hosts an annual environmental conference at which all of our environmental professionals from McWane and Ransom meet to participate in continuing education, to discuss the latest developments in environmental management, control technology, and compliance, and to share experiences that help other plants improve their management practices. ...

To maximize the effectiveness of our efforts, environmental training is a key part of our programs. At each facility, both supervisory and hourly employees participate in 26 bi-weekly safety and environmental training sessions. Environmental topics common to all training programs include:

  • Company Environmental Policy and Commitment

  • Water Pollution Requirements

  • Air Pollution Requirements

  • Hazardous Waste Generator Requirements

  • Spill and Emergency Response

  • Basic Environmental Rules

Each facility also conducts regular and frequent self-inspections in a pre-emptive effort to identify and address potential compliance issues. Several years ago McWane and Ransom began implementing a practice of internal audits by a team drawn from other sister plants to supplement internal efforts, and both companies periodically have environmental audits performed at each plant by independent, third party consultants. Most recently, at my instruction, outside audits of every facility of both companies were completed in 2001. ...

In addition to ongoing maintenance and compliance activities, we have undertaken the following major initiatives that in most cases improve the plants' performance beyond regulatory requirements:

a. McWane, Inc.

  • Atlantic States has significantly improved its air pollution control system within the last two (2) years at a cost in excess of $3.5 million. Atlantic States has also dramatically improved its stormwater management program, including the design and installation of an advanced, facility-wide system for over $2.1 million with a storage capacity in excess of 2.2 million gallons.

  • In 2002 McWane Pipe in Birmingham brought a new air pollution control system on line, that had been approved in 2001, to replace its existing system at a cost in excess of $5.2 million. Additional air pollution control initiatives include a separate baghouse for ductile treatment emissions and improved ductwork and hooding. Within the last two (2) years, McWane Pipe also installed a 400,000-gallon aboveground storage tank to collect and store stormwater and excess process water for reuse. ...

  • Kennedy Valve also substantially replaced its air pollution control system between 1999 and the present, with new state-of-the-art baghouse systems. Kennedy has also upgraded, replaced, or added air pollution control equipment on the shakeout systems, shotblast units, grinding stations and iron melting operations. Total project costs have exceeded $2 million.

b. Ransom Industries, LP

  • Tyler has committed to upgrade projects for its North and South Plants, and is currently in the permitting stage with the Texas Department of Natural Resources. This project is estimated to involve expenditures of several million dollars over the next five years. Tyler has also undertaken several other projects, including upgrading its wastewater treatment plant, further reducing fugitive emissions within the plant and increasing fugitive emission control outside the plant.

  • Union Foundry has redesigned and replaced its air pollution control system. This project included installation of a cupola stack collection system, a dust collection system for the inoculation process, and a new dust collection system on its newest molding line. Since 2001, Union has spent $5.3 million on these projects. ...

Conclusion

The United States domestic foundry industry faces a number of challenges to its very survival. In particular, foreign manufacturers in China and Latin America who have little or no regard for the safety of their workers or concern about polluting the environment have made progress in capturing more of the U.S. market. Our company has dramatically improved its safety and environmental record at significant expense while continuing to provide thousands of jobs to United States workers and manufacture products important to our economy. ...

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