Invest and participate in the NASF Government Affairs program. This highly effective public policy effort directly impacts decisions affecting finishing; it also produces direct savings to your company as a result of its education outreach at the state and national levels, and internationally.

Your membership generates a solid return on investment and supports essential programs to advance surface technology, nationally and worldwide.

The leaders in our industry understand the advantage of aligning themselves with NASF, which connects them to the people and information needed to leverage their resources to greatest advantage.

Discover the opportunities for involvement and engagement in the National Association for Surface Finishing! Whether you’re a chemical supplier … equipment vendor … job shop … captive finisher … academic, or consultant, there’s a membership type that perfectly meets your needs: Visit our Membership Types

NASF and U.S. EPA Region 5 Partnership to Reduce Halogenated Solvents

POSTED: November 18, 2018

The U.S. Environmental Protection Agency’s (EPA) Region 5’s office has initiated a voluntary air toxic reduction effort with regulated industry sectors in 6 states: Illinois, Indiana, Michigan, Minnesota, Ohio and Wisconsin.

Facilities covered by the Degreasing Organic Cleaners Halogenated Solvent Cleaners standard (40 CFR Part 63, Subpart T) may receive a letter from EPA Region 5 requesting their participation to help reduce or eliminate the use of the regulated solvents.

Halogenated solvents include:

  • Trichloroethylene (TCE)
  • Methyl chloroform (TCA, 111- trichloroethane)
  • Dichloromethane (DCM, methylene chloride)
  • Perchloroethylene (PERC)
  • Carbon Tetrachloride (CTC)

The National Association for Surface Finishing (NASF) and the surface finishing industry have made significant progress in reducing the use of halogenated solvents and air emissions from these solvents. Historically, these solvents have been used to clean parts prior to finishing, and halogenated solvents are still in use for applications where substitute solvents are not feasible. Where halogenated solvents continue to be used, facilities implement a variety of control technologies to minimize air emissions.

Even with the success in reducing emissions of halogenated solvents from the surface finishing industry, NASF is partnering with EPA to help members identify additional options for product substitution and improved control technologies to reduce or eliminate air emissions from halogenated solvents. Solvent substitution may allow the facility to reduce or eliminate permit or other compliance requirements under the federal standard, protect worker health and reduce costs. More information on alternative solvents can be found on EPA’s website.

More information on the regulatory benefits of safer solvents can be found here.

NASF and EPA will soon develop a webinar to provide more details on this initiative. For more information regarding the NASF/EPA partnership on this initiative, please contact Jeff Hannapel with NASF at jhannapel@thepolicygroup.com.



CATEGORIES: Law & Regulation


Are Prop 65 Warnings Required for Your Metal-Plated Materials/Products?

POSTED: October 5, 2018

California’s Safe Drinking Water and Toxic Enforcement Act of 1986 (Proposition 65) is a complex regulation for which it is difficult to find determinative answers. California’s Office of Environmental Health Hazard Assessment (OEHHA) recently updated its warning regulations that apply to products manufactured after August 30, 2018. As a result, many NASF members have received letters from customers that sell or distribute products in California asking if the products need Prop 65 warnings and labels.

Even if a part is plated outside California, but is sold or distributed in California, warning labels may be required. NASF is providing 3 documents that can help in determining whether warning labels are required for products that are sold or distributed in California.

Download Proposition 65 Documents



CATEGORIES: Law & Regulation


Form 300A must be submitted electronically by July 1, 2018

POSTED: June 29, 2018

Washington, DC – The National Association for Surface Finishing sends this reminder: submit your 2017 injury and illness summary report electronically to OSHA today, before Sunday’s deadline.

OSHA estimates that 450,000+ US companies must submit 2017 Form 300A data under the agency’s tracking system – the Injury Tracking Application (ITA). Companies are required to submit Form 300A if they meet these criteria:

  • Large Companies – If you have 250 or more employees and are currently required to keep OSHA injury and illness records.
  • Small and Medium-Size Companies – If you have 20-249 employees and are classified in certain industries with historically high rates of occupational injuries and illnesses. This category includes most manufacturing operations, including companies in the surface finishing industry.

More information on this reporting requirement is available on the OSHA website at https://www.osha.gov/injuryreporting/index.html.

For further information, please contact Jeff Hannapel with NASF at jhannapel@thepolicygroup.com



CATEGORIES: Law & Regulation


Valuable Technical Resource at Your Fingertips: Explore STERC.org

POSTED: May 22, 2017

Did you know, as an active member of the National Association for Surface Finishing (NASF), you have access to one of the most comprehensive online tools for surface finishing?

Launched in early 2017, NASF, in partnership with the National Center for Manufacturing Sciences (NCMS) and continued grant funding through the U.S. Environmental Protection Agency (EPA), launched the Surface Technology Environmental Resource Center (STERC.org).

STERC offers a fresh new look with additional menu options, an expanded library, combined training and education products from the AESF Foundation and NCMS, highlights of pending new rules and compliance deadlines, and other planned features. The STERC library is now home to thousands of searchable technical articles and papers from Plating and Surface Finishing (P&SF) magazine to SUR/FIN conference papers, as well as articles and papers from many other sources. Under the new partnership, the content of the library is included in your NASF membership.

STERC is a valuable one-stop resource for the latest compliance information and best practices for reducing pollution for the surface fishing industry. Like the old National Metal Finishing Resource Center (NMFRC), STERC will continue to include:

  • Easy-to-follow regulatory overviews
  • Tips on how to comply
  • Best-practice solutions that can help the environment while saving companies money
  • Industry calculators
  • Links to other useful resources

For more information on STERC, contact Jeff Hannapel at jhannapel@thepolicygroup.com or Matt Martz at mmartz@nasf.org.



CATEGORIES: Business, Education, Government Relations, Law & Regulation, Research


NASF Finalizing Metals Discharge Study: Presentation to EPA at April Washington Forum

POSTED: March 30, 2017

The NASF through its Government Advisory Committee is nearing completion of a milestone review and case study of the industry’s progress in reducing wastewater discharges throughout a nearly 30-year period. The study compares metals discharged by permitted finishing operations in Milwaukee from 1989 to 2016. It evaluates total metals reductions from companies to the municipal treatment plant, average reductions on a per facility basis, and the relative contribution of the finishing industry versus the larger universe of industrial dischargers in the community.

The draft version is under review by the committee this month and, as anticipated, preliminary findings show the industry’s reductions to be significant. The results of the study will be presented at the NASF Washington Forum in a discussion led by GAC Committee Member John Lindstedt, Advanced Plating Technology. Committee representatives will also present the study’s findings to the U.S. Environmental Protection Agency during the April meetings. The findings will substantiate the association’s position that protecting the nation’s waterways has been an overwhelming success, and that future, more stringent discharge standards are unnecessary.

Further details will be available shortly after the committee’s review and the report is finalized.



CATEGORIES: Government Relations, Law & Regulation, NASF Members, Other Publications, Research


Regulatory Alert: California Targeting Finishing Air Emissions Below Nanogram Levels

POSTED: March 30, 2017

Prompted by concerns over elevated air monitoring levels of hexavalent chromium in a southern California neighborhood, the South Coast Air Quality Management District (SCAQMD) is expected to propose revisions to its Rule 1469 – Hexavalent Chromium Emissions from Chrome Plating and Chromic Acid Anodizing Operations and Rule 1426 – Emissions from Metal Finishing Operations.

Local air officials have indicated that hexavalent chromium levels of more than 0.2 nanograms per cubic meter would pose unacceptable risks to human health. AQMD has already required one metal finishing shop to cease operations for exceeding 1 nanogram of hexavalent chromium per cubic meter at air monitors at the property boundary.

Focus is on Fugitive Emissions

The AQMD staff stated that they are concerned primarily about fugitive emissions from plating operations, rather than emissions from stacks, scrubbers and other control devices. To address the fugitive emissions from plating shops, AQMD may add the requirements below to the current rules for chromic anodizing and chrome plating operations.

  • Monitoring on the premises using multiple monitors ($5000 each) with immediate abatement when levels exceed acceptable risk thresholds
  • Total enclosures for plating and anodizing operations
  • Buildings with negative air pressure
  • Controls and/or covers on all tanks that are heated or agitated and may contain hexavalent chromium, including sealer and rinse tanks
  • More stringent controls on abrasive blast cabinets and grinding operations
  • New housekeeping requirements, including:
    • Daily vacuuming of floors with a HEPA vacuum that is emptied in a clean room environment
    • Daily cleaning of flat surfaces and wall
    • Cleaning of roofs two times per month

Expansion to Other Metals

AQMD is also considering applying similar requirements for metal finishing operations pursuant to Rule 1426 to control fugitive emissions of other metals such as cadmium, lead, nickel, zinc and tin.

AQMD has indicated that it expects to issue the proposed rule by July 2017 and finalize it by the end of 2017. The industry is concerned that it may not be technologically or economically feasible to meet the proposed revisions. California state industry leaders and NASF representatives have met with AQMD officials this month. The industry is now in the process of evaluating options to address this significant and precedent-setting challenge to finishing operations in the region and beyond.

To view a summary of the pending regulatory actions from South Coast air regulatory officials, please click here.



CATEGORIES: Government Relations, Law & Regulation, NASF Chapters, NASF National


Outlook on the Federal Regulatory Agenda: A Tectonic Shift in Washington

POSTED: January 23, 2017

The Trump Administration and Republican leaders in Congress have launched 2017 with several early actions on an agenda that, if implemented, would represent a tectonic shift in the U.S. regulatory landscape, particularly in the areas of environment, labor, health and safety.

Nominees and Advisors

The president’s nominees to head key agencies – Oklahoma Attorney General Scott Pruitt for the Environmental Protection Agency and burger chain executive Andy Puzder for Department of Labor – are widely known critics of the federal bureaucracy and government overreach. Pruitt led states’ efforts in recent years in major lawsuits against EPA. Puzder, who battled regulation in California, has warned that overly strict labor laws will lead employers to replacing workers with machines. Both nominees are now awaiting Senate confirmation.

The president also recently named activist investor and billionaire Carl Icahn as his special advisor on regulatory overhaul. He promised a regulatory moratorium and a rollback of key Obama Administration executive orders and memos on a host of topics. That’s exactly what’s transpired since Trump took office.

The President’s EPA transition team chief, libertarian think-tank advocate Myron Ebell, recently called the environment movement “the greatest threat to freedom.” He suggested last week that EPA’s budget should be cut by two-thirds, from 15,000 to 5,000 employees.

Executive Orders and a Regulatory Freeze

The President just this week signed an executive order promising that going forward for each new regulation issued, two old regulations would have to be eliminated. In announcing the policy, he noted “we’re cutting regulations massively for small business – and for large business” and that the annual impact on the economy of government rules would be “no greater than zero.”

The order follows an Inauguration Day memo from the President’s Chief of Staff Reince Priebus to all departments and agencies. The directive would freeze a number of recently finalized regulations for a 60-day review period. It also instructed agency heads to also consider delaying effective dates for regulations beyond the 60-day time period. The temporary moratorium on regulations is not uncommon for incoming presidents.

Indeed, several major rules that the Obama administration was speeding to the finishing line will be held up. Among them is the Department of Labor’s controversial overtime rule to boost worker pay, along with several EPA regulations.  Another on the slate is a rule to make hardrock mining operations show the financial ability to pay for contamination clean-up if closed. This is the first in a series of rules that EPA has anticipated would affect a range of industries in the future, including surface finishing.

Regulatory Reform Legislation on Capitol Hill

On Capitol Hill, Republicans with control of both legislative chambers on Capitol Hill have moved swiftly in the first few weeks of the new Congress to reshape the future of regulation. In its first week back in Washington, the House began action on and approved several regulatory relief bills, including:

  • the REINS Act (Regulations from the Executive in Need of Scrutiny) – requires Congress to approve any agency rule estimated to have more than a $100 million cost on the U.S. economy;
  • the Regulatory Accountability Act – requires agencies to complete a number of steps on a proposed rule, including weighing the direct and indirect costs and benefits of their rules on jobs and economic growth; and
  • the Midnight Rule Relief Act – allows Congress to repeal in a single vote any rule finalized in the last 60 legislative days of the Obama administration.

Since passage in the House, the Senate is now reviewing these measures, but Democrats have promised opposition there. The bills were passed by the House in earlier Congresses but were never previously acted on by the Senate.

In addition, House leaders have assembled a first short list of major Obama-era rules for repeal in the coming days. Republican leaders have promised to use their legal authority to scuttle the regulations under a rarely used legislative tool, the Congressional Review Act. The law, enacted in 1996, has been successfully invoked by Congress only once. In 2001, Republicans used it as President George W. Bush took office to overturn a major OSHA workplace ergonomics standard from the Clinton Administration.

EPA – Selected Regulatory Targets

Several major environmental regulations that the Trump administration has targeted for elimination, reform or delay include EPA’s Clean Power Plan to set carbon emission limits on power plants, the agency’s revised ozone standard and EPA’s controversial Clean Water Rule, which would determine which rivers, lakes, streams and ponds are subject to federal jurisdiction. The U.S. Supreme Court just this month agreed to hear arguments in litigation over the water rule. For surface finishing, EPA is still reviewing whether to propose tighter wastewater discharge limits for the industry, and NASF will continue to work closely with EPA and the Trump administration to inform the agency’s decision.

Department of Labor and OSHA – Selected Regulatory Targets

One of the most controversial labor regulations advanced by the Obama Administration has been the overtime rule. The rule, which would have raised the salary threshold for exemption from overtime pay, was blocked by a Texas district court judge just before it went into effect on Dec. 1, 2016. Both the incoming White House and Republicans in Congress have argued the rule should be scrapped, along with a growing list of other Obama-era labor rules and decisions from DOL, the National Labor Relations Board and the Equal Employment Opportunity Commission.

On workplace safety matters, the Occupational Safety and Health Administration’s efforts to make major changes in recordkeeping and reporting for business have been opposed by a range of industry groups, including NASF. Among these have been OSHA’s final electronic reporting rule to put injury and illness records of employers on the internet, and the agency’s pending final rule that would allow OSHA to cite employers for alleged injury and illness recordkeeping violations up to five years old, an extension much longer than the current limit of six months.

It’s only January, and a profound shift is underway in Washington. The regulatory agenda will be in a center spotlight this year, along with further action on tax reform, trade, immigration, health care and infrastructure. NASF has been closely engaged at the agencies and will continue to monitor and inform decisions that impact the industry as the year unfolds.  Look for new updates on specific issues in play in the coming weeks and months. In the meantime, we look forward to having you join us for the NASF Washington Forum in the nation’s capital on Apr. 25-27, 2017. For more information, go to www.nasf.org.

 



CATEGORIES: Business, Government Relations, International, Law & Regulation
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With Trump Regulatory Freeze, NASF Watching New EPA Superfund Clean-Up Rule’s Impact on Surface Finishing

POSTED: January 23, 2017

With the Trump administration’s aggressive focus on regulatory overhaul, one of several dozen issues the NASF has been watching is an otherwise obscure rule for the hardrock mining industry. But in early December, the U.S. Environmental Protection Agency proposed a new Superfund cleanup rule that NASF members should watch closely. The new proposal stems from an agency hazardous waste initiative under the Obama Administration that covers surface finishing as well as several other manufacturing sectors.

The latest proposed rule, which industry anticipated throughout 2016, would subject hard rock mining companies to a determination of future cleanup responsibilities and require each company to obtain bonds or insurance or self-assure to cover the cost of that clean up.

This is an important development for NASF members and finishing operations nationwide. A few years ago, EPA listed metal finishing on the list of sectors that would be targeted for what would be new, extremely burdensome requirements under the federal Superfund law that could potentially bankrupt both small and large companies.

NASF Has Advised Dropping Financial Assurance Requirements

NASF has been monitoring the rule’s progress for several years and held discussions with EPA, arguing that the agency’s approach was misguided on several fronts. EPA more recently expanded the metal finishing category to cover more facilities in the larger fabricated metals sector.

Outgoing EPA Assistant Administrator Mathy Stanislaus, who heads the federal hazardous waste program, argues that the agency’s approach of requiring a company to secure a bond, letter of credit or other financial assurance mechanisms would lead to more cleanups in the United States.

“This proposed rule, once finalized, would move the financial burden from taxpayers and ensure that industry assumes responsibility for these cleanups,” Stanislaus said. “The proposed rule would also give companies an economic incentive to use environmentally protective practices that can help prevent future releases.”

Mining Industry Shared “Case Study” with NASF Members in Washington

This past year, attendees at the NASF Washington Forum heard from National Mining Association’s Tawny Bridgeford, who highlighted the mining industry’s experience as a “case study.” She noted that the onerous EPA requirements in the pipeline for miners would severely impact surface finishing facilities if the rules weren’t curbed early in the process.

The proposed rule, which was moving to proposal stage in December, formally identified the next group of sectors in the pipeline for financial assurance rules, specifically electric power generation, transmission and distribution, and petroleum and coal products manufacturing.

The agenda of the new Trump administration will clearly have some bearing on the outcome of the mining and other regulations during 2017. Because the agency released its proposal so late in the year, the new temporary regulatory moratorium just announced by the White House over inauguration weekend is expected to delay and possibly derail it. More shortly.



CATEGORIES: Business, Government Relations, International, Law & Regulation
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NASF Closely Watching New EPA Superfund Clean Up Rule’s Impact on Surface Finishing

POSTED: December 6, 2016

The U.S. Environmental Protection Agency in early December proposed a new Superfund cleanup rule that NASF members should watch closely. The new proposal stems from an agency hazardous waste initiative under the Obama Administration that covers metal finishing as well as several other manufacturing sectors.

The latest proposed rule, which industry anticipated throughout 2016, would subject hard rock mining companies to a determination of future cleanup responsibilities and require each company to obtain bonds or insurance or self-assure to cover the cost of that clean up.

This is an important development for NASF members and finishing operations nationwide. A few years ago, EPA listed metal finishing on the list of sectors that would be targeted for what would be new, extremely burdensome requirements under the federal Superfund law that could potentially bankrupt both small and large companies.

NASF Has Advised Dropping Financial Assurance Requirements

NASF has been monitoring the rule’s progress for several years and held discussions with EPA, arguing that the agency’s approach was misguided on several fronts. EPA more recently expanded the metal finishing category to cover more facilities in the larger fabricated metals sector.

Outgoing EPA Assistant Administrator Mathy Stanislaus, who heads the federal hazardous waste program, argues that the agency’s approach of requiring a company to secure a bond, letter of credit or other financial assurance mechanisms would lead to more cleanups in the U.S.

“This proposed rule, once finalized, would move the financial burden from taxpayers, and ensure that industry assumes responsibility for these cleanups,” Stanislaus said. “The proposed rule would also give companies an economic incentive to use environmentally protective practices that can help prevent future releases.”

Mining Industry Shared “Case Study” with NASF Members in Washington

This past year, attendees at the NASF Washington Forum heard from National Mining Association’s Tawny Bridgeford, who highlighted the mining industry’s experience as a “case study.” She noted that the onerous EPA requirements in the pipeline for miners would severely impact surface finishing facilities if the rules weren’t curbed early in the process.

The proposed rule, which wasn’t yet published in the Federal Register at press time, formally identified the next group of sectors in the pipeline for financial assurance rules, specifically electric power generation, transmission and distribution, petroleum, and coal products manufacturing.

The results of the presidential election, however, clearly will have some bearing on the outcome of the regulations in 2017. Because the agency released its proposal so late in the year, it’s possible that a new EPA under the incoming Trump administration will elect not to make the rule final in the new year.



CATEGORIES: Business, Government Relations, Law & Regulation


Washington Forum, April 25 – 27, 2017: Register Now

POSTED: December 1, 2016

April 25-27, 2017

Ritz-Carlton Pentagon City

Arlington, Virginia

Each year, the NASF Washington Forum offers both strategic and practical updates from top thought leaders and decision makers on the challenges that impact the surface finishing industry. This year’s event included a day and a half of sessions and networking followed by an optional day of meetings with legislators and congressional staff. The 2017 Forum will continue to deliver. With the election settled and a new administration coming to Washington, attendees will get first-hand the most significant news on how decisions in and outside of Washington will affect their businesses in 2017 and the coming years.



CATEGORIES: Events, Government Relations, Law & Regulation


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