California’s EPA’s Office of Environmental Health Hazard Assessment (OEHHA) announced in February it will review several chemicals for possible listing under Proposition 65. These chemicals include: nickel and nickel compounds; perfluorooctanoic acid (PFOA) and its salts; perfluorooctane sulfonate acid (PFOS) and its salts; and n-hexane.
The state launched a preliminary review of the hazards for nickel and nickel compounds and identified them as possibly harmful to pregnant women and children, or as “developmental and reproductive toxicants.”
NASF and its strategic partner, the Nickel Institute, submitted comments in response and solicited support from other industry allies in October 2015 on whether the compounds should be elevated to priority status, and provided further information at a public meeting held by the agency’s scientific panel in November 2015. During that meeting, the panel informally identified nickel and nickel compounds as a medium priority reproductive toxicity hazard. The recent “data call in” asked for new scientific information on hazards of nickel compounds by April 4, which OEHHA will review as it considers a formal state listing under Proposition 65.
If OEHHA decides to list nickel and nickel compounds as a reproductive toxicant, the Proposition 65 labeling and notification requirements will be applicable to all products in California that contain nickel. The listing would also stigmatize nickelcontaining products for potential de-selection in California and elsewhere.
Even though the listing is a hazard identification and not a risk assessment, other jurisdictions may use it to impose unjustified risk-based restrictions and controls on the use of nickel and nickel compounds. NASF expects the next stage of the listing process to take several months. In the meantime, the association will be working closely with the Nickel Institute to prepare appropriate responses and comments on the potential reproductive toxicity of nickel and nickel compounds. If you have any questions or would like additional information on this issue, contact Christian Richter at crichter@thepolicygroup. com or Jeff Hannapel at firstname.lastname@example.org.
Posted in Law & Regulation |
The U.S. EPA proposed updated water quality criteria for cadmium that would relax the benchmark for protecting aquatic species from chronic exposures to cadmium in freshwater from 0.25 μg/L to 0.73 μg/L, and for acute exposure from 2.0 μg/L to 2.1 μg/L. EPA also proposed a more stringent cadmium standard for estuarine and marine waters with criteria to protect aquatic species from chronic exposure from 8.8 μg/L to 8.3 μg/L and for acute exposure from 40 μg/L to 35 μg/L. The proposal defines chronic risks as exposures of duration of four days or longer and acute risks as an exposure of one hour. Prior to the proposal, acute risks were considered exposures within a 24-hour period. When EPA last updated the cadmium water quality standard in 2001, it stated that stricter criteria were necessary because new data showed that exposure to cadmium over an extended period of time could have negative health impacts on aquatic life.
The 2001 cadmium water quality criteria lowered the chronic exposure limit by orders of magnitude, prompting sources in the wastewater industry at the time to claim that these criteria would be impossible to meet. While EPA’s risk-based criteria are not binding, states often use them to develop enforceable water quality standards. States can also revise EPA’s water quality criteria based on local concerns or develop their own, but EPA must approve alternate approaches. Other states and the industry-based Utility Water Act Group (UWAG) argue that the proposal is too stringent and have raised several questions about how the criteria were calculated. The industry group also challenged EPA’s decision to change the duration of acute exposure from 24 hours to one hour without sufficient evidence, as well as EPA’s more costly monitoring requirements. UWAG concluded that EPA appeared to be making a policy decision to revise the acute exposure without scientific evidence on cadmium toxicity to support it.
Illinois and Wisconsin also questioned EPA’s criteria claiming that the chronic exposure level was based on a flawed toxicity test that was published more than 15 years ago by the U.S. Geological Survey (USGS). According to the states, the USGS study should be retested, a position that it claims is supported by EPA’s Office of Science and Technology. EPA is in the process of reviewing public comments on the proposal. It is not clear if EPA intends to make any significant changes to the proposal.
The agency faces a March 30, 2016 courtordered deadline to issue the new criteria. If you have any questions or would like additional information on this issue, contact Jeff Hannapel with NASF at email@example.com.
Posted in Law & Regulation |
Designed for line operators and maintenance personnel
September 6 through 21
NASF’s training arm, the AESF Foundation, is announcing the expanded version of its popular SUR/FIN 2015 Boot Camp to help meet the need for training qualified workers. This course is written and provided in a non-technical fashion and assumes no formal math or technical knowledge. The training program consists of 9 lessons on the following subjects listed here.
Posted in Education
Registration Now Open
For nearly 100 years, SUR/FIN has covered industry’s most timely and critical issues for R&D, project systems, engineering, quality, and regulatory affairs from professionals within the surface finishing industry. Attendees can expect to come with their most pressing questions and leave with the information they need to improve their products, processes, and business.
Can attending SUR/FIN make a difference to your business…to the future of the industry? New and long-time attendees think so. The event has been the trusted resource for what’s next in surface finishing. Regardless of your particular objectives, SUR/FIN offers everything you need to build a more prosperous, efficient business and successful future.
Register today at NASFsurfin.com.
Show Floor Sold Out
The 2016 SUR/FIN trade show floor is already sold out, and an exhibit interest list is now forming for the 2017 SUR/FIN show in Atlanta, Georgia, June 19-21. If your company is interested in being added to the 2017 SUR/FIN waiting list, or to our mailing list for next year’s conference, please contact Cheryl Clark at 302-436-5616 or firstname.lastname@example.org
Posted in Events
This year’s election season is historic by any measure, as is this year’s Washington Forum which features a broader agenda than usual. Issues on the program for manufacturing and finishing range wide, including trade, tax and infrastructure policy, as well as environment, labor & workplace and emerging defense requirements. NASF is now working on several major actions in Congress and at the agencies that affect the industry.
Attendees at the April Washington Forum will hear updates and discuss issues, with an option to spend a day on Capitol Hill meeting face-to-face with Senators, Representatives, and congressional staff to discuss current industry challenges and shape issues affecting your business.
Register today at: WashingtonForum.NASF.org
Wednesday Luncheon Keynote
Founding Editor and Publisher of the Rothenberg & Gonzales Political Report, a political columnist for Roll Call and one of the nation’s most popular political analysts
Wednesday Capitol Hill Reception
REP. ADAM SCHIFF (D-CA 28th)
Ranking Member, Permanent Selection Committee on Intelligence, Member of the Benghazi Select Committee, and leader on national security and foreign policy.
Tuesday Forum Kickoff
Economist and Author; Professor at the Smith School of Business, University of Maryland and former Chief Economist, International Trade Commission.
Wednesday Headline Speaker
EDWIN FOULKE, JR.
Assistant Secretary of Labor for OSHA under President George W. Bush, now Partner of Fisher & Phillips, LLP, where he co-chairs the firm’s Workplace Safety group.
Wednesday Headline Speaker
Top tax policy expert and political analyst, founder of The Washington Update, former senior partner at Covington & Burling in Washington, D.C.
Posted in Events