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.
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.
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).
The Web-Based Chromium Plating for Engineering Applications is beneficial for operators and supervisors of job shop and captive shops performing hard chromium plating operations on a variety of substrates. This course is also beneficial to sales personnel who work for suppliers of hard chromium and equipment.
The goal of this course is for students to have a basic understanding of chemical and electrical principles as they relate to hard chromium plating and be able to apply Faraday’s law in calculating the time required to obtain a target thickness of chromium plate. At the conclusion of the course students will know the basics of the chromium plating process, including equipment, operational conditions and the role of impurities.
Course Dates: Tuesdays & Wednesdays noon – 2pm Eastern
May 4, 5, 11, 12, 18, 19, 24, 25
Registration Deadline: April 20, 2021
Course – $1150 | Optional Exam – $250
Discounted NASF Member Rate – $875 | Optional Exam – $150 ($375 savings!)
Chapters Covered in Course:
1. Chemistry for Hard Chromium Platers
2. Electricity for Hard Chromium Platers
3. Electrochemistry for Hard Chromium Platers
4. Equipment for Hard Chromium Plating
5. Masking Techniques
6. Mechanical Surface Preparation
7. Chemical Surface Preparation
8. Basic Chromium Plating Principles
9. Analysis & Control of Chromium Plating Solutions
10. Troubleshooting & Purification of Chromium Plating Solutions
Click HERE to learn more and register for the Chromium Plating for Engineering Applications course.
Questions regarding this NASF/AESF Foundation course and other course offerings can be directed to email@example.com
On Surface Finishing Day, Our Industry is More Vital Than Ever
There are many days in the year to recognize and celebrate. Today is National Surface Finishing Day and I’m pleased to highlight it on behalf of the National Association for Surface Finishing (NASF).
It’s not a day most Americans recognize or celebrate, and it’s certainly not a holiday for those of us in the plating, finishing and coatings industry. Far from it. In fact, the industry is as busy as ever, particularly through the ongoing challenges of the pandemic.
For this year’s National Surface Finishing Day, what is it specifically that we’re looking to recognize and celebrate about this industry that, incredulously, remains nearly invisible to consumers and citizens across the nation and most of the world?
To us it’s rather simple. We’re making the world better. All of us. Our job shops and captive shops, our chemistry and equipment suppliers, employees at all levels, and customers of all sizes in industries and value chains that are absolutely vital to our health, quality of life, our security and our future.
As we’ve highlighted through our NASF Surface Technology Initiative in recent years, we add value to millions of products by making them last longer, look better or perform in ways that would otherwise be impossible.
We’re passionate in this industry about what we do and the people who do it. And we’re enthusiastic about sharing it with a wide array of audiences, from the students, professionals and military personnel in our AESF Foundation training courses, the universities we partner with for our research grants, to our leaders in Washington and in our regulatory agencies in the U.S. and across the globe.
It’s worth taking a moment today to recognize the contributions of our industry that are more vital than ever. Most important is a sincere “thank you” to all of our NASF members who are supporting the work we do on behalf of the industry, our NASF 1000 contributors to help us advocate effectively, and our NASF Partners for investing in the association’s efforts to advance a sustainable future.
Jeff Brassard, NASF President
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.
NASF SUR/FIN is moving to November 2-4, 2021 Please mark your calendars!
In order to provide the best and safest experience for the industry, NASF is moving this year’s SUR/FIN Show and Manufacturing & Technology Conference from July to November 2-4, 2021.
This year’s event will be an excellent opportunity for the industry to come back together after our hiatus. We’re eager to see everyone from across the finishing community – our exhibitors, partners, speakers, colleagues, attendees and guests – and host you in Detroit at the TC Center for a productive and successful show. Please mark your calendars now for SUR/FIN 2021, November 2-4.
We’re confident SUR/FIN 2021 will be the event the industry has been waiting for. There will be many opportunities for networking, education and collegiality in a COVID-responsible environment.
Thank you for your continued support of SUR/FIN and the NASF, and we look forward to a successful event with you as we prepare for November.
For more information on SUR/FIN please visit, nasfsurfin.com.
The NASF/AESF Foundation is proud to announce its 2021 industry training schedule is available online for download here. Visit NASF.org/education today to download your copy of the training catalog, view detailed course descriptions and pricing, and register for upcoming courses.
NASF/AESF Foundation offers four separate training platforms which cater to all types of learners: Web-Based, Home Study, In-Person, and Custom. Each platform offers advantages to students as they work towards the Certified Electro-Finisher (CEF), Certified Aerospace Finisher (CAF), and Master Surface Finisher (MSF) designations.
- Begin Home Study anytime and complete at your own pace
- Hard-copy course materials are mailed directly to your home or work
- AESF Technical Director reviews chapter quizzes and provides feedback
- Proctored exams can be taken at your location
- Courses presented in a series of online sessions
- Live, online instruction taught by NASF/AESF Foundation instructors and other industry experts
- Live sessions take place on pre-determined Tuesday & Wednesdays between 12:00pm and 2PM eastern
- Session recordings are available to students for 30-days after the original posting date if students wish to review or miss live sessions
- Live interaction with instructor in a classroom setting
- Instruction takes place over 2-4 days (add 1 day for optional exam)
- Taught in select locations throughout the U.S.
- The most flexible of training platforms to meet larger training needs of companies
- Mix and match from 110 available course modules
- No travel required; one of our certified instructors will come to you
For additional information on NASF/AESF Foundation courses please contact, Education Manager, Josh Huff.
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.
Thank you to all who participated in the MAMF Golf Outing held Tuesday, October 1, 2019 at Oak Hill Golf Club. With 60+ players and record number of sponsors of Gold Outing presented the MAMF Environmental Fund with a check of $10,000.