NASF Public Policy Update – July 2021

The National Association for Surface Finishing has released its Public Policy Update for July 2021. Some of the highlights in the update are summarized below. You can access the July 2021 Public Policy Update here.

The Environmental Working Group Targets Finishing as Suspected PFAS Dischargers — The Environmental Working Group (EWG) released a new report that identifies 4700 finishing operations as “suspected PFAS dischargers.” EWG has also developed an interactive, searchable map to locate companies and view extensive permitting, compliance history, environmental justice and other detailed information by zip code, city, company name or census tract.

Surface Finishing Industry Could Get Nationwide Wastewater Discharge Limits for PFAS in Recently Passed House Infrastructure Bill — A new water and environment infrastructure bill, known as the INVEST in America Act (H.R. 3684), recently passed the House, and includes a provision that requires EPA to regulate PFAS under the Clean Water Act.

NASF/Department of Defense on Special Workshop at SUR/FIN on California’s Phase-Out of Hexavalent Chromium Processes and the Implications for the U.S. Defense Supply Chain –The California Air Resources Board (CARB) continues to advance a new rulemaking to transition hexavalent chromium plating to trivalent chromium for decorative chromium plating, functional chromium plating and chromic acid anodizing. In response to this rulemaking, NASF, in coordination with Department of Defense officials, has scheduled an NASF-DOD Workshop on at SUR/FIN in Detroit, Michigan.

NASF Webinar on OSHA Regulatory Outlook and Legal Guidance –NASF has scheduled a webinar on July 26, 2021 to help its members navigate the OSHA regulatory agenda and also the newly revised COVID guidelines.

Bipartisan PFAS Legislation Introduced in the House — Comprehensive PFAS legislation was introduced in the House. This bipartisan bill would require EPA to initiate several rulemakings to address PFAS.

EPA Proposes Reporting Rule for PFAS Compounds — EPA proposed a new reporting and recordkeeping rule for per- and polyfluoroalkyl substances (PFASThe proposed rule applies to manufacturers and importers of PFAS chemicals, including small manufactures and manufacturers who produce PFAS as a byproduct. In addition, the proposal would subject articles containing PFAS to reporting requirements.

Bipartisan Infrastructure Bill Would Reinstate Superfund Tax to Pay for Proposal — To help pay for proposed infrastructure bill, The Superfund Tax would reinstated. The proposal would place an excise tax on the manufacture, production or import of 42 chemicals (including organics and metals such as cadmium, chromium, cobalt, lead, nickel and zinc).

EPA Announces New Electronic Manifest User Fees — EPA announced new Electronic Manifest User Fees for fiscal years 2022 and 2023. EPA encourages the hazardous waste industry to adopt fully electronic manifesting as soon as possible, but acknowledges that it will take time for industry to fully transition to electronic manifests.

California Platers Begin Sampling of PFAS Pursuant to Water Board Orders — The California State Water Control Board issued an order to chromium platers in California to sample for PFAS compounds. NASF and its California Chapters negotiated a model Work Plan for facilities to use in conducting sampling. There has been inconsistent implementation of responses from regional water boards.

Posted in Government Relations, Law & Regulation