NASF Comments Point to Major Flaws, Bad Precedent in EPA Chromium Air Rule

NASF industry has submitted a 100-page package of comments to EPA in response to the agency’s proposed rule for chromium finishing operations.

In it, the association questions the agency’s decision to tighten tough regulations even further when the industry has reduced emissions by 99.9 percent since 1995.

EPA Used Data from “Phantom Facilities”

The comments also point to major flaws in EPA data and analysis and raise concerns over EPA’s approach to the rule that, if left unchallenged, will pose problems for the broader finishing indusutry in the future.

“Unfortunately, EPA’s analysis has dramatically overestimated both emissions and potential risks from the industry,” said Jeff Hannapel, NASF Government Affairs.

“This is not a favorable precedent – the actual data we’ve received from NASF members across the U.S. show that EPA counted emissions incorrectly – a majority of companies shown as emitters on the agency’s list either don’t exist, don’t do chromium or have actual emissions far below EPA’s “models” driving the new regulation,” said Hannapel.

See the executive summary below. NASF’s complete set of comments are available at

Data Call from Chromium Finishing Operations

NASF Government Affairs is still collecting company emissions data, and needs your help to present a complete picture to the agency and the White House on U.S. chromium finishing emissions.

Is your company’s chromium emissions profile accurately represented in EPA’s database? Please contact Government Affairs at or

Rule To Be Discussed at NASF Washington Forum

Join your colleagues at the Washington Forum, April 24-26, and strengthen the industry’s advocacy efforts on this and other major challenges facing U.S. finishing and manufacturing. Register today for the 2012 Washington Forum or contact Cheryl Clark at

Join the NASF and Support Industry Advocacy through the NASF1000!

NASF is the voice of surface technology. We have an impact on decisions that affect the industry’s future with committed members who support a strong advocacy program.

For more information on NASF membership, click here or contact Phil Assante at

Support NASF advocacy efforts by being a contributing member of the NASF1000 today! Contact Jeff Hannapel at for more information.

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