NASF Public Policy Update – September 2021

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

President Biden Announces New COVID-19 Vaccine Requirements, OSHA to Initiate New Standard and Enforcement — President Biden announced broad COVID-19 vaccine requirements that will impact approximately 100 million Americans.

EPA to Set New Federal Wastewater Discharge Standards for PFAS in Surface Finishing Operations —The U.S. Environmental Protection Agency (EPA) announced that it will commence a rulemaking process to set first-time ever wastewater discharges for PFAS from chromium plating and related processes in the surface finishing industry as well as certain chemical manufacturers and formulators of PFAS. The announcement follows extensive discussions between NASF and senior EPA officials since the Trump administration released its PFAS Action Plan in 2019.

EPA Moves to Repeal More Flexible Trump-Era Waters of the U.S.” Rule after Court Ruling — A federal district judge tossed out the Trump administration’s April 2020 Navigable Waters Protection Rule (NWPR). The decision creates major uncertainty for a wide array of industries and landowners. EPA and the Corps will continue to advance the rulemaking process to formulate yet another WOTUS definition that the agencies note will be “informed by diverse perspectives and based on an inclusive foundation.”

Michigan PFAS Action: Detroit POTW Considering Pretreatment Limits for PFAS
The Great Lakes Water Authority (GLWA) recommended adoption of new local pollutant discharge limitations for PFOS (64 parts per trillion (ppt)) and total PFAS compounds (7,000 ppt). If these local limits are enacted, chromium plating operations may have to install treatment technology such as granular activated carbon (GAC) units to treat wastewater prior to discharge to the POTW.

California Efforts Continue to Ban Hexavalent Chromium Plating — 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. CARB is considering extending the dates for phasing out hexavalent chromium to ten years and beyond and contemplating other possible options to address their concerns about hexavalent chromium emissions form surface finishing operations in California.

NASF 1000 — The NASF 1000 program was established to ensure that the surface finishing industry would have resources to effectively address regulatory, legislative and legal actions impacting the industry, NASF members and their workplaces. The commitment to this program is one of the most vital contributions made in support of surface finishing and directly shapes the future of the industry. Please consider supporting the NASF 1000 program.

Posted in Law & Regulation