NASF Public Policy Update – August 2021

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

OSHA Updates COVID Guidance for Non-Healthcare Workplaces — OSHA updated its primary COVID-19 guidance for non-healthcare employer. The guidance embraces CDC’s recent updated mask recommendations for vaccinated individuals.

Bipartisan Infrastructure Bill Passes the Senate — After months of negotiations, the Senate approved a $1 trillion bipartisan infrastructure deal. The legislative package includes nearly $550 billion in new spending and could mean new jobs over the next decade through federal investments in roads and bridges, broadband internet, public transit and electric utilities.

NASF Economic Impact and Market Trends Report to Be Presented at SUR/FIN — NASF has commissioned an economic impact and market trends study for the surface finishing industry. The analysis will include an assessment of the industry size, employment numbers, revenues, impact on GDP, profitability, and more. The team of economists has been reviewing data and interviewing industry leaders to gather this information.

Activist Group Analysis Identifies Metal Finishing, Electroplating and Nearly 30,000 “Suspected” Industrial PFAS Dischargers — The Environmental Working Group (EWG) projects that nearly 30,000 industrial sites may be using, making or releasing per- and polyfluoroalkyl substances (PFAS). EWG says that of the sites on its list, more than 4,700 use PFAS for electroplating and polishing. While the number of surface finishing facilities suspected of discharging PFAS is inaccurate and misleading, the net result is the EWG has clearly put surface finishing in the bull’s eye as a large source of PFAS discharges.

EPA and Army Corps of Engineers Announce Plans for Revising Major US Waters Rule — EPA and the Army Corps of Engineers announced a series of meetings, comment sessions and other outreach they say will fulfill their promise to craft a “reasonable” definition of waters of the United States (WOTUS) that reflects input from all stakeholders.

EPA Process for Designation New Hazardous Air Pollutants (HAPs) — EPA issued an advanced notice of proposed rulemaking (ANPRM) regarding the addition of 1-bromopropane (also known as n-propyl bromide) as a hazardous air pollutant. EPA asserted that the substantive decision to designate 1-bromopropane was made last year. EPA’s process may be problematic for several reasons – because of how the agency did this, additional listings of air pollutants could be on the horizon with little opposition.

Comment Deadline Extended for EPA Proposed Reporting Rule for PFAS Compounds — EPA proposed anew reporting rule for per- and polyfluoroalkyl substances (PFAS) under the Toxic Substances Control Act (TSCA). The proposed rule applies to manufacturers and importers of PFAS chemicals, including small manufactures and manufacturers who produce PFAS as a byproduct.

California Proposes Public Health Goals for PFOS and PFOA — The California Office of Environmental Health Hazard Assessment (OEHHA) released proposed Public Health Goals for PFOA at 0.007 parts per trillion (ppt) and for PFOS at 1 ppt. There are serious questions regarding the scientific justification for these goals and whether these levels can be measured.

California Platers Engage Regional Water Boards on PFAS Sampling Order — The California State Water Control Board and regional water boards are in the process of implementing 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. While many Work Plans based on the model template have been approved, facilities have received revised Work Plans from regional water boards that included extensive soil and groundwater sampling.

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