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 Public Policy Update – September 2021

POSTED: September 20, 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.



CATEGORIES: Law & Regulation


NASF Public Policy Update – July 2021

POSTED: July 15, 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.



CATEGORIES: Government Relations, Law & Regulation


NASF Public Policy Update – June 2021

POSTED: June 15, 2021

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

OSHA Issues Limited COVID Emergency Temporary Workplace Standard (ETS) — OSHA released its COVID-19 Emergency Temporary Standard (ETS) for the nation’s workplaces. While the ETS currently applies solely to the health-care industry, OSHA also issued updated guidance in alignment with CDC’s framework for COVID applicable to general.

Proposed Legislation to Regulate PFAS under Clean Water Act – Names Surface Finishing
Congress has proposed legislation to require EPA to regulate PFAS discharges under the Clean Water Act from nine industry sectors, including electroplating and metal finishing. The measure would also require water quality criteria to be finalized by a date certain.

NASF Submits Comments to Minimize Small Business Impact of EPA Rule for the Use of N-Propyl Bromide — NASF participated in a meeting of the Small Business Advocacy Review (SBAR) Panel to discuss EPA’s potential proposed rulemaking to impose restriction on the use of n-propyl bromide (1-Bromopropane) under TSCA §6(a). As part of this process, NASF submitted comments on EPA’s approach that is under considerations.

California Rule to Transition Hexavalent Chromium Processes to Trivalent Chromium — The California Air Resources Board (CARB) has issued its draft proposed regulatory language to transition hexavalent chromium plating to trivalent chromium. NASF, its members and expert industry representatives have voiced multiple concerns with the rule.

White House Goal Doubles the Number of OSHA Inspectors — President Biden plans to double OSHA’s inspection force by 2024. This effort is driven by frustration with OSHA’s inability to respond to an overwhelming number of worker complaints during the pandemic.

EPA Announces It Will Make Changes to Trump’s Rollback of Obama’s Clean Water Act Rule Defining which “Waters of the U.S.” Are Subject to Regulation — EPA chief Michael Regan announced the agency would embark on a major effort to overturn the Trump administration’s “Waters of the U.S.” rulemaking.

EPA Rescinds Trump Administration Clean Air Act Benefit-Cost Rule — EPA will rescind the Trump Administration Benefit-Cost Rule, entitled “Increasing Consistency and Transparency in Considering Benefits and Costs in the Clean Air Act Rulemaking Process.”



CATEGORIES: Law & Regulation


NASF Public Policy Update – May 2021

POSTED: May 19, 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.

EPA Announces Formation of PFAS Council — EPA Administrator Michael Regan announced the formation of the EPA Council on PFAS that will be tasked with developing a strategy for addressing PFAS in water, air and land and will compliment and attempt to focus the agency’s ongoing PFAS activities. The council will include senior EPA officials from a broad range of program offices and regions.

OSHA Sends COVID Emergency Temporary Workplace Standard (ETS) to White House for Final Review – OSHA is moving forward with its much-anticipated COVID-19 Emergency Temporary Standard (ETS) for the nation’s workplaces. The ETS was submitted to the White House Office of Management and Budget for review and is expected to be released this month.

OSHA National Emphasis Program for the Enforcement of COVID Protections in the Workplace — OSHA has launched a National Emphasis Program (NEP) to ensure that employees in high-hazard industries are protected from the hazard of contracting COVID in the workplace. The NEP targets establishments that have workers with increased potential exposure and ensures that workers are protected from retaliation for reporting alleged violations.

California Announces Rule to Transition Hexavalent Chromium Processes to Trivalent Chromium — California Air Resources Board (CARB) continues its rulemaking efforts to transition of hexavalent chromium processes to trivalent by 2023 for decorative chromium plating, by 2027 for functional chromium plating, and by 2032 for chromic acid anodizing. CARB expects to finalize the rule by the end of 2021.

NASF Provides Technical Input to Danish EPA on Nickel Coatings — NASF provided information on nickel-free coatings and the use of nickel in coatings to the Danish EPA who is working on a project for nickel-free coatings.

EPA to Move Forward on Proposed Rule for N-Propyl Bromide – EPA is seeking input from small business representatives (including NASF and two of its members) as it develops a proposed rule to identify management options for n-propyl bromide that protect human health and the environment and will minimize impacts on small businesses.

State Agency Chiefs Release Updated White Paper on PFAS — The Environmental Council of the States (ECOS) released an updated version of its “white paper” that outlines state efforts and considerations for future regulatory activities on PFAS.

EPA Announces Plan to Update Toxics Release Inventory to Advance Environmental Justice — EPA announced that it will be taking important steps under the Toxics release Inventory (TRI) to advance Environmental Justice, improve transparency, and increase access to environmental information.



CATEGORIES: Law & Regulation


NASF Public Policy Update – April 2021

POSTED: April 16, 2021

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

COVID Stimulus: The American Rescue Plan Act Becomes Law — President Biden signed into law the American Rescue Plan Act (ARPA) on March 11, 2021. The act provides for $1.9 trillion in aid and relief to individuals, businesses and local governments that continue to feel the impact of the coronavirus pandemic.

President Biden Announces Infrastructure Plan — The Biden Administration released its broad plan to address the country’s infrastructure. The “American Jobs Plan” calls for a grand total of more than $2 trillion in federal investment in a broad array infrastructure initiatives and supports President Biden’s other priorities, including climate change and environmental justice.

Proposed Legislation to Offer Medical Monitoring for PFAS — Senator Kirsten Gillibrand (D-N.Y.) and Representative Madeleine Dean (D-Pa.) has announced the “PFAS Accountability Act” that would create a medical monitoring program and encourage funding for safety research on the family of thousands of PFAS substances. The legislation would also allow courts to award medical monitoring, and would establish a federal cause of action allowing exposed people to bring claims against PFAS manufacturers.

California Announces Rule to Transition Hexavalent Chromium Processes to Trivalent Chromium — California Air Resources Board (CARB) announced its intent to initiate a rulemaking that would require the transition of all decorative chromium and functional chromium processes to trivalent and impose stringent control measures on other processes using hexavalent chromium. CARB has targeted the end of 2021 to finalize the rule.

EPA Grants Temporary Reprieve to TSCA PBT Chemical Prohibition — EPA issued a prohibition under section 6(h) of the Toxic Substances Control Act (TSCA) for five persistent, bio-accumulative and toxic (PBT) chemicals. To avoid imminent supply chain disruptions to large sectors of the economy, EPA agreed to a 180-day pause in enforcement of the rule and announced a 60-day comment period to re-examine the rule. Many surface finishing companies have received letters from customers asking them if any of the five PBT chemicals are used in the manufacture of any component or product that they purchase from them.

PFAS in Rainwater — New and phased-out PFAS substances were detected in rainwater collected in the Ohio-Indiana region. The next step in the research is to perform isomeric fingerprinting in the hopes of tracing some of the PFAS that were detected in rainwater back to local point sources in the region.

State Agency Chiefs Release Updated White Paper on PFAS — The Environmental Council of the States (ECOS) released an updated version of its “white paper” that outlines state efforts and considerations for future regulatory activities on PFAS.

Proposed Update to OSHA Hazard Communication Standard — OSHA recently issued a proposed rule to amend and update the agency’s Hazard Communication Standard. The proposal would update the current US regulation to align with the most recent version of the UN Globally Harmonized System of Classification and Labeling of Chemicals and would trigger additional compliance obligations for employers.



CATEGORIES: Law & Regulation


NASF Public Policy Update – March 2021

POSTED: March 23, 2021

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

NASF Chromium Finishing Symposium for CARB — NASF and its California chapters presented a chromium plating symposium for the California Air Resources Board (CARB), as it considers possible regulatory options to transition hexavalent chromium processes to trivalent chromium. The symposium included a slate of industry experts who discussed the status of trivalent chromium plating technology and the current barriers and timelines for a broad application of trivalent chromium processes.

White House Executive Order on Critical Supply Chains — President Biden signed an Executive Order directing a series of reviews of global supply chains to create more resilient and secure supply chains for critical materials and goods. The reviews will involve multiple departments within the Executive Branch and will implicate a broad range of policy-related concerns, including defense, intelligence, health, climate, the economy, geopolitics and human rights.

Interim Guidance on Destruction and Disposal of PFAS — EPA published a draft Interim Guidance on Destroying and Disposing of Certain PFAS and PFAS-Containing Materials That Are Not Consumer Products. The new interim guidance outlines the current state of the science on techniques and treatments that may be used to destroy or dispose of PFAS and PFAS-containing materials from non-consumer products. NASF joined the American Chemistry Council in submitting comments on the interim guidance.

Small Business Administration PPP Assistance — The U.S. Small Business Administration (SBA) established a 14-day, exclusive Paycheck Protection Program (PPP) loan application period for businesses and nonprofits with fewer than 20 employees to promote equitable relief for small businesses. These steps demonstrate the commitment to racial and gender equity, reaching low and moderate-income, rural, urban, and other underserved areas.

EPA Releases Updated Environmental Justice Mapping Tool (EJSCREEN) — EPA released an update of EJSCREEN, the Agency’s publicly available environmental justice screening and mapping tool to identify environmental burdens on vulnerable populations. This update is a refresh of the environmental and demographic data currently contained in EJSCREEN and enhances the tool by adding new and improved functionality such as climate change indicators.

Superfund Listing of PFOS and PFOA – The Biden EPA is reviewing a January 14, 2021 Advance Notice of Proposed Rulemaking (ANPRM) on the potential listing of PFOS and PFOA as hazardous substances under CERCLA, better known as the federal Superfund law. EPA is expected to resubmit the ANPRM or issue a proposed rulemaking that may include a revised approach or modified language.

EPA Drinking Water Standard for PFOS and PFOA — EPA proposed a regulatory determination to regulate PFOS and PFOA in drinking water, which is the first step in setting a federal drinking water standard.

OSHA Proposed Hazard Communication Standard — The Occupational Safety and Health Administration (OSHA) issued a proposed rule to amend and update the agency’s Hazard Communication Standard. The move would update the current US regulation to align with the most recent version (revision 7) of the UN Globally Harmonized System of Classification and Labeling of Chemicals (GHS).



CATEGORIES: Law & Regulation


NASF Public Policy – February 2021

POSTED: February 23, 2021

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

President Issues Executive Orders — The Biden White House in the first few weeks has issued over three dozen executive orders, memorandums, proclamations, and other measures that focused on four priority issues: 1) Covid-19, 2) economic stimulus, 3) climate change policy, and 4) racial equity. These actions provide a blueprint for the Biden Administration’s expansive agenda over the next few years.

Regulatory Freeze Memorandum — The Biden Administration issued a “regulatory freeze” memorandum for all federal agencies to allow time for review any new or pending rules from the Trump administration.

NASF Webinar on COVID Workplace Practices — The webinar included a panel of NASF member companies who shared various measures they have taken to manage COVID in the workplace and mitigate the spread of Covid-19.

COVID-19 Relief Legislation — Congress passed $900 billion coronavirus relief legislation in December that extended relief through March 2021, providing support to help people and businesses get through the next several months of the pandemic. President Biden is advocating for a new 1.9 trillion-dollar stimulus package.

OSHA COVID Workplace Standards — The Occupational Safety and Health Administration (OSHA) recently issued an updated and strengthened its Guidance on Mitigating and Preventing the Spread of COVID-19 in the Workplace. In addition, OSHA is considering a federal emergency temporary standard (ETS) on COVID-19 with a March 15, 2021 deadline.

EPA Releases Effluent Guidelines Program Plan — EPA released its Effluent Guideline Program Plan 14 under Clean Water Act section 304(m). Plan 14 provides an update on the PFAS Multi-Industry study and includes organic chemical manufacturers, airports, rug and textile manufactures, pulp and paper manufacturers, and the metal finishing point source category.

Advance Notice of Proposed Rulemaking for Superfund Listing of PFOS and PFOA — EPA issued an Advance Notice of Proposed Rulemaking (ANPRM) on the potential listing of PFOS and PFOA as hazardous substances under CERCLA (or Superfund law). EPA requested public comment and data on whether it should use authority under CERCLA or RCRA to list PFOS and PFOA as hazardous substances.
EPA Drinking Water Standard for PFOS and PFOA — EPA took the next step to regulate PFOS and PFOA under the Safe Drinking Water Act by issuing final regulatory determinations. EPA will now initiate the process to develop a national primary drinking water regulation for PFOS and PFOA, which will include further analyses, scientific review, and opportunity for public comment.

Multi-Sector General Permit for Industrial Stormwater Discharges — EPA issued the final 2021 National Pollutant Discharge Elimination System (NPDES) Multi-Sector General Permit (MSGP) that authorizes stormwater discharges associated with industrial activity. The final MSGP allows for reduced monitoring burdens and increased flexibility in demonstrating compliance with the permit requirements for industrial stormwater discharges.

Federal Environmental Civil Penalties Increased for 2021 — U.S. EPA recently increased its maximum civil penalties for violations of air, water, chemical, and hazardous waste to keep pace with inflation.

Michigan EGLE Screening Levels for Air Emissions of 6:2 FTS — The Michigan Department of Environment, Great Lakes, and Energy (EGLE), Air Quality Division issued an initial threshold screening level (ITSL) for air emissions of 6:2 fluorotelomer sulfonate (or 6:2 FTS). 6:2 FTS is used in the current formulations of fume suppressants for chrome plating applications. NASF submitted comments on the ITSL and met with state officials to discuss the industry’s concerns. In response to comments, EGLE concluded that the current screening level of 1 µg/m3 was determined to be appropriate and defensible.



CATEGORIES: Law & Regulation


January Update

POSTED: January 18, 2021

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

Here are some highlights:

Washington Transition Update – The incoming Biden administration and Georgia runoff election may shift environmental policy and chemicals policy (including PFAS regulation). NASF suspects environmental justice and climate change will be at the top of the agenda, as well as new initiatives on the labor, health and safety, tax, trade and other fronts.

TRI Data Release – The EPA has released updated 2019 Toxics Release Inventory (TRI) data that includes summary and trend information, but does not include EPA’s full analysis of the 2019 data. The 2019 TRI National Analysis, to be published in early 2021, will examine different aspects of the data, including trends in releases, other waste management practices, and pollution prevention activities.

Stormwater – In March 2020, the EPA published its proposed 2020 National Pollutant Discharge Elimination System (NPDES) Multi-Sector General Permit (MSGP) that authorizes stormwater discharges associated with industrial activity in areas where EPA is the NPDES permitting authority. NASF has submitted comments on the proposed MSGP.

Chemical Risk Evaluations – The EPA identified n-propyl bromide (1-bromopropane) as one of its first ten high priority chemicals under the Toxic Substances Control Act (TSCA). N-propyl bromide is used as a solvent to clean parts prior to surface finishing. EPA has one year from the risk evaluation to issue a proposed rule and two years from the risk evaluation to issue a final rule. NASF as well as a few of its members have been invited to participate in the Small Business Regulatory Enforcement Fairness Act (SBREFA) panel as small entity representatives (SERs).

EPA has also identified trichloroethylene (TCE) as one of its first ten high priority chemicals under the Toxic Substances Control Act (TSCA). TCE has been used as a solvent to clean parts prior to surface finishing.

PFAS Sampling Plan – NASF, with the assistance of Dr. Janet Anderson, developed a PFAS Sampling and Analysis Plan (SAP) for NASF members.

PFAS Federal Regulations – In 2020, the EPA proposed a regulatory determination to regulate PFOS and PFOA in drinking water. This is the first step in the regulatory process to establish a federal drinking water standard for PFOS and PFOA. NASF has encouraged the EPA to consider a treatment-focused regulatory approach to a drinking water standard for PFOS and PFOA, and that the treatment technologies considered must be technologically and economically feasible, consistent with the SDWA.

In 2020, the EPA issued a final significant new use rule (SNUR) for long-chain perfluoroalkyl carboxylate (LCPFAC) chemical substances that imposes notification and other regulatory requirements on the manufacture, import or processing of certain new uses of specified LCPFAC substances, including PFOA and its salts. This SNUR does include PFOS or 6:2 FTS, the substances used in fume suppressants in the surface finishing industry. Accordingly, the article exemption for PFOS and 6:2 FTS would not be impacted by this SNUR.

EPA has published the draft Interim Guidance on Destroying and Disposing of Certain PFAS and PFAS-Containing Materials That Are Not Consumer Products with a 60-day public comment period under docket EPA-HQ-OLEM-2020-0527.

PFAS State Regulations – EPA Region 5, EPA Office of Research and Development (ORD) and the Michigan Department of Environment, Great Lakes and Energy (EGLE) conducted PFAS testing of fume suppressants currently in use and effluent discharge at approximately 12 plating shops in Michigan. The goal of this project was to determine if any PFOS is present in the fume suppressant currently in use and which PFAS, if any, may be in the effluent discharges of finishing shops.

On September 24, 2020, the Michigan Department of Environment, Great Lakes, and Energy (EGLE), Air Quality Division issued an initial threshold screening level (ITSL) for air emissions of 6:2 fluorotelomer sulfonate (or 6:2 FTS) of 1 μg/m³, with annual averaging time. 6:2 FTS is used in the current formulations of fume suppressants for chrome plating applications.

Water Technology Research – NASF and the AESF Foundation have joined the Water and Environmental Technology (WET) Center Industrial Advisory Board, which focuses on a broad range of water and wastewater technologies and related public health issues.

To get more information on any of the stories mentioned above, access the full NASF January 2021 Public Policy Update here.



CATEGORIES: Law & Regulation


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


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