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NASF POLICY UPDATE

Date: October 23, 2024
Category: Chapter News, Events, NASF National, Regulation

 

October 2024

 

 

EPA Delays PFAS Proposed Rule for Wastewater Discharges from Surface Finishing ‎Operations: Key EPA Activities Ahead‎

 

We noted in recent weeks during the NASF Washington Forum and in association chapter ‎meetings that EPA’s schedule for the proposed rule to address PFAS in wastewater discharges ‎from surface finishing operations has been delayed from December 2024 until May 2026. EPA ‎is currently in the process of reviewing, evaluating, and analyzing the data from the surveys. In ‎addition, the agency must take additional key steps during this period, including:‎

  • conducting further follow up on survey responses;‎
  • completing site visits and onsite sampling for a small group of facilities;‎
  • reviewing industry discharge data and treatment technology options;‎
  • evaluating financial and economic data;‎
  • assembling a small business impact panel to assess potential impacts on small ‎operations; and
  • developing proposed rule language.‎

With respect to site visits, the agency plans to conduct single grab samples of wastewater at 20 ‎facilities and multiple samples at another five facilities. EPA does not expect to begin site ‎visits and sampling until after the first of the year. ‎

 

The NASF Government & Industry Affairs team continues to meet with EPA officials on these ‎and other developments in the PFAS wastewater discharge rule. If you have any questions ‎regarding EPA’s rulemaking for discharges of PFAS in wastewater from surface finishing ‎operations, please contact Jeff Hannapel or Christian Richter with NASF at ‎jhannapel@thepolicygroup.com or crichter@thepolicygroup.com. ‎

 

EPA Identifies 27 Candidates for “Priority” Selections Under Federal Chemicals Program: ‎Organics and 4 Metals Included

 

In a significant new development, EPA in late September named 27 candidate chemicals from ‎which they will choose five substances to “prioritize” under the Toxic Substances Control Act ‎‎(TSCA) for risk evaluation and ultimately regulation. The list included 10 chemicals that were ‎identified last year and 17 chemicals that were included for the first time. For the first time ‎ever, four metals were included on the candidate list: antimony, arsenic, cobalt and lead, and ‎their compounds. ‎

 

The 10 substances from last year are 4-tert-octylphenol [also known as (4-(1,1,3,3-‎tetramethylbutyl)-phenol)]; the high-profile plastic additive bisphenol-A (BPA); hydrogen ‎fluoride (HF); the anti-cracking chemical in vehicle tires known as 6PPD; styrene; benzene; ‎ethylbenzene; naphthalene; tribromomethane; and triglycidyl isocyanurate.‎

 

The 17 new candidates are 1-hexadecanol; 2-ethylhexyl 2,3,4,5-tetrabromobenzoate (TBB); ‎creosote; di-n-octyl phthalate (DnOP); n-nitroso-diphenylamine; p,p’-oxybis (benzenesulfonyl ‎hydrazide); m-xylene; o-xylene; n-xylene; antimony and antimony compounds; arsenic and ‎arsenic compounds; cobalt and cobalt compounds; lead and lead compounds; long-chain ‎chlorinated paraffins (C18-20); medium-chain chlorinated paraffins (C14-17); and bisphenol-S ‎‎(BPS).‎

 

Under TSCA, the existing chemicals EPA selects for its risk evaluation process must first go ‎through a “prioritization” process lasting nine to 12 months, where the agency considers ‎available data on uses, risks and other properties of the chemical or chemical group. The agency ‎then designates each as either high- or low-priority, and then must immediately begin risk ‎evaluations for high-priority chemicals. Based on the risk evaluation EPA will identify any ‎‎“unreasonable risks” associated with the use of the chemical, and propose regulations and ‎management options to address those risks.‎

 

This year EPA also decided to release the candidate list in a more public forum and has ‎promised to expand public input and data-gathering in the pre-prioritization process, including a ‎public comment period. Last year, EPA released 20 candidates for TSCA review only at ‎closed-door stakeholder meetings and faced complaints over the process from environmental ‎and industry groups not invited to those sessions. ‎

 

If you have any questions regarding EPA’s candidate list or the TSCA risk evaluation process ‎for existing chemical, please contact Jeff Hannapel or Christian Richter with NASF at ‎jhannapel@thepolicygroup.com or crichter@thepolicygroup.com. ‎

 

EPA Proposes to Expand List of PFAS Subject to TRI Reporting

 

EPA in early October proposed to add 16 individually listed per- and polyfluoroalkyl substances ‎‎(PFAS) and 15 PFAS categories representing more than 100 individual chemicals to the Toxic ‎Release Inventory (TRI) list of toxic chemicals subject to reporting requirements. The proposed ‎PFAS chemical categories are comprised of an acid, associated salts, associated acyl/sulfonyl ‎halides, and an anhydride. ‎

 

EPA proposed to set a manufacturing, processing, and otherwise use reporting threshold of 100 ‎pounds for each individually listed PFAS and PFAS category being proposed for listing by this ‎rulemaking and to designate all PFAS listed under this action as chemicals of special concern. ‎Fortunately, most surface finishing operations would not typically exceed the reporting ‎threshold of 100 pounds of PFAS. Facilities should, however, make a determination whether ‎the reporting threshold is met, especially chemical suppliers of PFAS products.‎

 

Finally, EPA also addressed what events may trigger the automatic addition of PFAS to the TRI ‎list, such as where EPA has identified a specific toxic value for a PFAS substance. For ‎example, a facility must now report 6:2 FTS under TRI if the reporting threshold of 100 pounds ‎is exceeded.‎

 

EPA also announced that it plans to designate the new additions as “chemicals of special ‎concern” that would prevents the de minimis exemption from applying to the chemicals. Under ‎TRI’s de minimis exemption, facilities that report to the inventory are allowed to disregard ‎minimal concentrations of chemicals in mixtures or trade name products in reporting releases ‎and other waste management calculations. But the de minimis exemption, which EPA ‎characterizes as a burden-reduction tool, does apply to chemicals classified as “chemicals of ‎special concern.”‎

 

The comment deadline for the proposed rule is November 7, 2024, but several industry trade ‎groups have requested extensions of the comment deadline. More information on the proposed ‎rule and a complete list of new PFAS that may be subject to TRI reporting are available on the ‎EPA website here.

 

EPA Changes Name of RCRA Cleanup Program

 

On October 21, 2024, EPA announced that it is renaming its former Corrective Action Program ‎to the “Hazardous Waste Cleanup Program.” The program is responsible for remediation under ‎the Resource Conservation and Recovery Act (RCRA). According to EPA officials, renaming ‎the program is part of an effort to better explain the program’s goals in “plain English.” The ‎term “corrective action” is used in the RCRA statute and regulations to mean the cleanup of ‎hazardous waste and constituents, but in common use it has many other meanings, so the public ‎does not immediately connect it with cleanup. ‎

 

The new name for the program is not a change from a regulatory standpoint, as EPA will ‎continue to use the term “corrective action” as a regulatory and legal term. The rebrand is ‎simply intended to communicate more clearly the purpose and goals of the hazardous waste ‎cleanup program. ‎

 

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. All funds from the NASF 1000 program are used ‎exclusively to support specific projects and initiatives that fall outside the association’s day-to-‎day public policy activities. 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. ‎

 

The sustained commitment from industry leaders has helped the NASF remain strong and ‎credible in informing regulatory decisions across the nation. Specific projects funded through ‎the NASF 1000 make a measurable difference in how the industry navigates emerging ‎challenges, communicates credibly with policy makers, and advocates for a strong science base ‎for rules or standards that affect surface finishing. ‎

 

Please consider supporting the NASF 1000 program. For more information, contact: Christian Richter (202-257-‎‎0250) or Jeff Hannapel (202 257-3756) with NASF.‎

 

 

NEW ENGLAND CHAPTER HOSTS ANNUAL VIRTUAL FALL SEMINAR

Date: September 20, 2024
Category: Events, NASF Chapters, Regulation

NENASF logo

 

On September 18, 2024 the New England Chapter of NASF hosted their annual Fall Webinar for the benefit of their membership and the entire non-NENASF metal finishing community. This year’s event featured a cross section of varied technical presentations designed to enhance and broaden the knowledge of Wastewater Professionals as well as all interested members of the metal finishing community.   The event was presented free of charge to NENASF members, and at a modest fee for other interested parties, as an educational and bonding opportunity for the metal finishing community.

 

The Webinar was conducted by means of Zoom format and attracted about three dozen attendees. It consisted of three segments featuring three presenters over a two-hour period from 10:00am to 12:00 pm offering a user-friendly Zoom format for all attendees. In addition to offering vital regulatory and technical information the event also made available two Continuing Education Wastewater Treatment Operator Contact Hours needed for WWT Operator License renewal.

 

Fernando Carminholi from Hubbard-Hall opened the Webinar with a presentation on Membrane Filtration for a Cleaner and More Sustainable Future. His presentation showed factual technical data on the use of microfiltration as a means of removing saturated oil from cleaning solutions, thus adding to the life of the cleaning solution resulting in chemical make-up cost savings and disposal cost savings, thus reducing the impact to the environment with beneficial cost savings to the company. Fernando offered case studies that resulted in 35 to 45 % cost savings using membrane filtration over a multi-year period.

This was followed by a presentation by Brian Morrill, vice president of GZA GeoEnvironmental giving a detailed update on the rapidly evolving PFAS discharge regulation front. The EPA has already issued regulations on PFAS in public drinking water supplies, and wastewater discharge PFAS limit regulations are being mandated in the near future. The EPA is using the data accumulated by the comprehensive PFAS Survey that most metal finishers completed in early 2024 as a basis for promulgating PFAS discharge limits for our industry.

The webinar was concluded with a presentation by James Mitchell, R & D Associate chemist for PAVCO, who spoke on the use of inert Ion-Exchange Membrane Anodes used in acid zinc and zinc-nickel solutions as a means of minimizing metal growth in bathes thus offering cost and environmental savings resulting from not having to “cut” and dispose of plating solutions over time.

 

Once again, we want to give special thanks to Chris Capalbo, moderator, all the member of the NENASF who contributed to this successful Program, and a special thanks to the talented speakers who offered their time and talent to make this presentation come to fruition for the benefit of the Metal Finishing Community.

NASF POLICY UPDATE – August 2024

Date: August 27, 2024
Category: NASF Chapters, NASF National, Regulation

 

Regulatory Alert – New Federal Air Regulation for Chromium Launched for Finishing Industry: The NASF Government Affairs team recently met with EPA officials, who informed NASF that they have begun making plans to conduct the review of new control technology and work practices that may be available to further reduce hexavalent chromium emissions from chromium electroplating and anodizing operations.

 

Regulatory Alert – EPA Issues Long-Awaited Milestone Federal Health Assessment for Hexavalent Chromium: As NASF has anticipated, EPA has now completed its multi-year review for hexavalent chromium this month, with publication of its massive science document highlighting the extensive literature and studies on health effects for the chemical. This document is not a regulation or standard but will serve as the basis for future U.S. regulation.

 

House Committee Republicans Issue Report on How White House is Assessing Regulatory Impacts on Small Business: The Chairman of the House Committee on Small Business, Rep. Roger Williams (R-TX), along with the panel’s Republican members, recently released a staff report that criticized the Biden Administration’s consideration of small business regulatory burdens. The report notes that the Biden Administration has issued 891 final rules with regulatory costs of $1.47 trillion and 232.4 million paperwork hours to comply with those regulations.

 

Washington Forum, September 16-18, 2024: Join us at the Washington Forum in this important election year, with the event scheduled to take place September 16-18, 2024 at the historic Willard Hotel in Washington, DC. Program highlights include top election analyst Charlie Cook, who will keynote the Forum luncheon. Please make your plans to attend this key industry event. Registration is available on the .

 

For more details on these topics, please see our discussion below…

 

Regulatory Alert – New Federal Air Regulation Launched for Finishing Industry: EPA is Now Advancing a Revised Rulemaking Chromium Electroplating and Anodizing Operations

 

The NASF Government Affairs team recently met with EPA officials, who informed NASF that they have begun making plans to conduct the review of new control technology and work practices that may be available to further reduce hexavalent chromium emissions from chromium electroplating and anodizing operations.

 

While the surface finishing industry has been very successful in reducing hexavalent chromium emissions (i.e., NASF has noted the industry’s 99.9 percent reduction since 1995), the technology review will evaluate any new control technologies and work practices that can effectively reduce emissions further. NASF has offered to have industry representatives provide EPA with a briefing on the status of available control technologies and work practices in late 2024 or early 2025.

 

EPA Requirements under the Federal Clean Air Act

 

Under the Clean Air Act, EPA must conduct a technology review every eight years to determine if it needs to revise existing federal standards for chromium electroplating and anodizing operations. The last round of chromium air toxic standards was issued in September 2012 and the rule review required by EPA is now overdue. The agency has not yet been sued to accelerate its regulatory action on chromium and is not yet subject to a court-ordered consent decree to conduct the technology review.

 

Calendar Outlook for a Proposed and Final Rulemaking

 

By January 2025, EPA officials expect to have a better idea on the rulemaking schedule, but the proposed rule could be as soon as Fall 2025, with a final rule by Fall 2026. This schedule may be a bit ambitious, as the agency just issued its task order to engage its engineering contractor for the rulemaking and may need to conduct a small business impact panel for any proposed changes to the NESHAP.

 

NASF will continue to work with EPA officials and keep NASF members informed nationwide on any new developments. If you have any questions or would like more information on this rulemaking, please contact Jeff Hannapel or Christian Richter with NASF at  or .

 

Regulatory Alert – EPA Issues Milestone Federal Health Assessment for Hexavalent Chromium

 

As NASF has anticipated, EPA has now completed its multi-year review for hexavalent chromium with publication of its massive science document highlighting the extensive literature and studies on health effects for the chemical.

 

Final Assessment Includes Scientific Peer Review and Recommendations

 

The agency’s formal scientific review has been developed under EPA’s Integrated Risk Information System (IRIS) and includes a follow up analysis and response to the EPA Science Advisory Board’s Fall 2023 review and recommendations for improving the agency’s work.

 

One of the most important recommendations from the Science Advisory Board from last fall was addressing what top scientists on the expert review panel highlighted was the agency’s overly conservative approach to interpreting the scientific literature and various studies in a way that could lead to dramatically revamping current regulatory federal and state requirements and standards to extremely strict levels.

 

Early Implications of the IRIS Assessment

 

An earlier draft from the agency last year included calculations that translated to a “safe” level of 35 to 70 parts per trillion (ppt) in tap water, far below natural background levels of approximately 1 – 5 ppb depending on regional variation.

 

The final draft, which has incorporated several key changes, could translate to a “safe” level in tap water closer to 1 part per billion (ppb) or possibly higher. However, the science document is not a requirement or regulation, and key regulatory decisions will be made within the next 3 years, with a focus on a new national drinking water and cleanup standards. A challenge to the decision may be in order.

 

A recent compliance cost study by the American Water Works has shown that lowering the federal drinking water standard as low as only 1 part per billion (ppb) in comparison to the existing standard of 100 ppb for total chromium would result in an annualized cost to the nation’s drinking water utility infrastructure of between $7 and $16 billion.

 

This is a significant development for the future, and NASF will continue to be closely engaged in discussions with a range of officials and affected sectors moving into the fall and will provide a brief update on the latest developments on this topic during the Washington Forum in September.

 

House Committee Republicans Issue Report on How White House is Assessing Regulatory Impacts on Small Business

 

The Chairman of the House Committee on Small Business, Rep. Roger Williams (R-TX), along with the panel’s Republican members, recently released a staff report that criticized the Biden Administration’s consideration of small business regulatory burdens.

 

New Regulatory Costs Exceeded $1 Trillion with a Surge of Activity in April

 

According to the report, the Biden Administration passed 891 final rules with regulatory costs of $1.47 trillion and 232.4 million paperwork hours to comply with those regulations, and in an April surge of agency activity a number of rules were finalized with new regulatory costs of $875 billion.

 

A key statute, the Regulatory Flexibility Act (RFA), requires federal agencies to ensure that new regulations do not disproportionately burden small businesses and other small entities. The RFA also imposes protocols on federal agencies for assessing the specific potential impacts of regulation on small businesses, including economic impacts. One of the hallmarks of the law is that EPA, the Department of Labor and other agencies are required to convene a panel of small business representatives to provide input on potential impacts from a regulation before it is proposed.

 

List of Concerns Point to Shortfalls in Properly Assessing Impacts on Small Businesses

 

The report included several major findings on agency deficiencies in complying with the requirements of the Regulatory Flexibility Act:

  1. Avoiding Assessments for Small Business Impacts – Agencies have improperly concluded that rules have no small business impact in order to avoid conducting the required analysis under the law, leading to rules moving to final action that have not adequately assessed the consequences for small entities.
  2. Underestimating Costs and Scope of Impacts – Agencies consistently underestimated both the regulatory costs and the number of impacted small businesses when conducting an RFA analysis. Agencies also failed to adequately consider less burdensome alternatives, or chose to finalize a rule that is even more harmful to small businesses than other alternatives without adequate justification.
  3. Failure to Assess Overlapping or Conflicting Rules – Agencies repeatedly failed to appropriately assess if a rule is duplicative or conflicts with other rules, which causes small businesses to potentially face multiple overlapping regulations from both within the same agency and across the federal government.

The report concluded that many agencies are not properly following their obligations with regard to small business needs and, as a consequence, are imposing unnecessary burdens on small businesses.

 

NASF Engaged on Major Rules to Ensure Surface Finishing Impacts Are Assessed

 

Making sure that federal agencies adequately assess the potential impacts of new regulations on small businesses will be critical for NASF and the surface finishing industry in the next year, particularly with EPA’s focus on a number of rules for the industry including, among others, wastewater discharge standards for PFAS under the Clean Water Act and newly emerging chromium air emissions requirements from surface finishing operations under the federal Clean Air Act.

 

If you have any questions or would like additional information on this issue, please contact Jeff Hannapel or Christian Richter with NASF at  or .

 

 

Washington Forum, September 16-18, 2024

 

The Washington Forum will take place September 16-18, 2024 at the historic Willard Hotel in Washington, D.C. Please make your plans to attend this key industry event. Information regarding registration is available on the .

 

Forum Topics and Speakers

 

The Forum will include presentations and briefings from national and global experts on pertinent policy, technical, regulatory, and management issues impacting the surface finishing industry, including , speakers from EPA, DOD, the automotive supply chain, the Nickel Institute, leaders of U.S. drinking water agencies, and the U.S. Chamber of Commerce.

 

Top Analyst Charlie Cook to Keynote Forum Luncheon

 

Longtime expert election analyst Charlie Cook will be keynote the Forum luncheon and provide an update and forecast on the upcoming election. In addition, Washington Forum participants also have the option during the event to meet with their congressional representatives and staff to educate them on the importance and impact of the surface finishing industry, the challenges facing companies across key sectors and regions, and specific policy priorities of concern.

 

We look forward to seeing you at the Washington Forum this year. If members have questions or would like additional information about the Washington Forum, please contact Jeff Hannapel or Christian Richter with NASF at  or .

 

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. All funds from the NASF 1000 program are used ‎exclusively to support specific projects and initiatives that fall outside the association’s day-to-‎day public policy activities. 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. ‎

 

The sustained commitment from industry leaders has helped the NASF remain strong and ‎credible in informing regulatory decisions across the nation. Specific projects funded through ‎the NASF 1000 make a measurable difference in how the industry navigates emerging ‎challenges, communicates credibly with policy makers, and advocates for a strong science base ‎for rules or standards that affect surface finishing. ‎

 

Please consider supporting the NASF 1000 program. If you have any questions or would like ‎additional information regarding the NASF 1000 program or the broad array of NASF public ‎policy activities, please contact Jeff Hannapel with NASF at .‎

NENASF ANNUAL RCRA AND ENVIRO UPDATE SEMINAR WITH A NEW TWIST

Date: May 18, 2024
Category: Chapter News, Events, NASF Chapters, Regulation

NENASF LOGOMCTA

The New England Chapter of the NASF was pleased once again to offer a Seminar for the benefit of its members, and the metal finishing community, featuring annual mandatory RCRA training as well as environmental updates on hot button issues impacting the metal finishers. This year, for the first time, the Seminar was offered free of charge to all New England Chapter members in good standing as an extra membership benefit and a means of thanking loyal members for their support of NASF ideals at both the local and national level. The event took place on May 15, 2024 at the Courtyard Marriott in Marlborough Massachusetts.

The more than thirty-five attendees first received their mandatory RCRA training by Jorge Bejarano of HRP Associates. This training is a requirement for all personnel who are responsible for hazardous chemicals and waste handling, storing and offering for transportation. Jorge gave a fast paced and thorough presentation covering all aspects of safe and proper hazardous chemical handling.

The second segment of the Seminar was dedicated to Environmental Issues. Three  speakers who were present from the Department of Energy & Environmental Affairs, along with one via video link, offered an enlightening look into the newly emerging Environmental Justice initiatives which involve community interaction between industry and residents of communities that are disproportionately impacted by industrial pollutants. This was followed by a presentation by MCTA Executive Director Katherine Robertson who gave insight into the legislative activities on Capitol Hill in Boston with special emphasis on updating TURA activities and potential industry impact. The closing speaker was Brian Morrill, Associate Principal and Vice President of GZA GeoEnvironmental, informing attendees about the latest PFAS regulatory happenings that could have future impact on the Metal Finishing Community.

This well attended event is another way that membership in the NASF, at both the Local and National level, can benefit metal finishers at all levels. Once again, thank you to all NENASF Board Members, NENASF membership as a whole, and talented members of the Metal Finishing Community for offering their time and talent to making beneficial events like this a reality.

NEW ENGLAND CHAPTER HOSTS ANNUAL VIRTUAL MARCH SEMINAR

Date: March 23, 2024
Category: Events, Member News, NASF Chapters, NASF National, Regulation

NENASF logo

The New England Chapter of NASF was, once again, pleased to host a virtual Wastewater Continuing Education Webinar for the benefit of our membership and the entire metal finishing community. This event was offered via Zoom format, at no charge to NENASF members, over a two-hour period from 10:00 am to 12:00 pm on Wednesday March 20, 2024.

 

The program, comprised of three speakers, offered vital technical and regulatory compliance information to the metal finishing community. Attendees also qualified for two Continuing Education Wastewater Treatment Contact Hours to be used towards Wastewater license renewal.

 

Frank DeSilva of Resin Tech opened the Webinar with an update on the current status of the very hot button PFAS issue and regulatory efforts by the EPA. After giving us some very helpful facts, he then offered remediation techniques and technologies for successful PFAS removal from waste streams.

This presentation was followed by one from Mark Schario of Columbia Chemicals who enlightened attendees with a history of Trivalent Chrome plating baths and how they have greatly improved in appearance and durability over the last three or four decades. The substitution of Hex Chrome plating baths with trivalent baths is a very timely presentation given the TSCA chemical banning frenzy that is taking place across all chemical user and manufacturer sectors, especially in the metal finishing community.

The closing speaker was Dave Calnan of CCI-A Chemicals offering practical solutions and techniques for, and benefits of, oxidizing wastewater prior to reduction and precipitation.

 

Special thanks, once again, to Chris Capalbo, Dev Massimi and Ralph Capalbo as Program Moderators and Speaker Facilitators for their contributions, and to the combined efforts of NASF Board Members, Committee Members, Chapter Membership and dedicated and talented members of the Metal Finishing Community as a whole for making events such as this available for the benefit of our membership.  Over thirty members of the NENASF and metal finishing community were in attendance and benefited from this program.

Public Policy Report – March 2024

Date: March 23, 2024
Category: NASF National, Regulation

NASF Logo

March 2024

 

 

EPA PFAS Survey Closes: The Surface Finishing Industry Response

 

The U.S. Environmental Protection Agency (EPA) launched the most recent stage of its PFAS rulemaking process with an extensive industry survey to over 2,000 facilities to inform one of two “first-of-its-kind” PFAS wastewater discharge rules for manufacturing. The survey included an sprawling set of information requests regarding facility operations and processes, use of PFAS, PFAS discharge data, water discharge permits, and financial information.

 

The NASF launched a series of webinars for members to guide the finishing industry on responding to the U.S. Environmental Protection Agency’s PFAS survey. Accurate responses to the survey that are representative of the industry are critical because the information from the survey will help to shape the rule for PFAS wastewater discharges.

 

As of mid-March 2024, EPA had received approximately 950 responses to the survey and nearly 650 were from chromium finishing operations. Any company still working on the survey response should submit it to EPA as soon as possible. This high response rate to the survey from the industry will ensure that more accurate information is used in rulemaking deliberations.

 

EPA will now review the survey results and begin to develop the proposed PFAS wastewater discharge rule. Before issuing a proposed rule, EPA will also have to conduct a small business impact panel to solicit information on the potential economic consequences of the proposed rule on small businesses and to consider options for minimizing that impact. Officials have targeted December 2024 as the date for a proposed rule, but with the delay in sending out the survey and the required analytical steps ahead for the agency, the deadline for the proposed rule may be extended into 2025.

 

The association will continue to work closely with EPA officials on the development of this critical rule for the surface finishing industry. If members have questions or would like additional information on the survey or the PFAS rulemaking process, please contact Jeff Hannapel or Christian Richter with NASF at jhannapel@thepolicygroup.com or cichter@thepolicygroup.com.

 

Latest Action on Federal Climate Disclosure Rules for Industry: Securities and Exchange Commission Scales Back Requirements under Pressure

 

On March 6, 2024, the Securities and Exchange Commission (SEC), responding to pressure from a wide range of industry and agriculture efforts, adopted narrower final rules to require publicly traded companies to disclose “any climate-related risks that have materially impacted or are reasonably likely to have a material impact on the registrant, including on its business strategy, results of operations, or financial conditions.” Specifically, the final rules require disclosure of more direct greenhouse gas (GHG) emissions (referred to as Scope 1 and Scope 2 emissions) on a phased-in basis by certain larger companies when those emissions are material.

 

In addition, climate-related disclosures must be incorporated into annual reports filed with the SEC. The final rules also include a phased-in compliance period for all companies (extending from FY 2025 to FY 2033), with the compliance date dependent on the company’s filer status and the content of the disclosure,

 

Changes from Proposed Rules

The final rules include significant changes from the proposed rule regarding GHG emissions disclosure requirements. In addition to the fact that the Scope 1 and Scope 2 disclosures are no longer mandatory for all companies, the amended rules no longer require companies to report certain indirect emissions, including from their supply chains and customers’ use of their products, such as coal or crude oil, or so-called Scope 3 emissions. Companies had opposed the requirement, saying they would be overly burdensome and complex.

 

Court Stays the Final Rules

Shortly after the SEC ruling, a coalition of 10 states filed a legal challenge, claiming that the rule was “illegal and unconstitutional.” In addition, an industry coalition led by the U.S. Chamber of Commerce also filed a suit seeking to halt implementation of the SEC rules. Other individual companies also filed legal challenges to the final rules.

 

On March 15, 2024, a U.S. appeals court has temporarily halted new rules issued by the SEC.

In arguing for an administrative stay of the final rules, the companies argued that the climate rules “directly or indirectly regulates significant aspects of the country’s economy under the guise of requiring detailed (and wildly speculative) disclosures about ‘climate-related risks’ and ‘greenhouse gas’ emissions,”

 

Impact on Surface Finishing Operations

First, the climate disclosure rules apply only to publicly traded companies. Surface finishing operations would have been most directly impacted if customers subject to the rule needed information from them regarding GHG emissions in the supply chain. Given that the SEC removed the reporting of Scope 3 emissions from the final rules, such information will not be federally mandated from surface finishing operations. In addition, it appears that legal challenges to the SEC rules will delay any implementation of the climate disclosure requirements. However, even though there may be no specific regulatory requirements climate disclosure, many large companies may still request climate-related information from its supply chain (including surface finishing operations) as part of their corporate sustainability programs.

 

Accordingly, NASF will continue to monitor regulatory developments and climate disclosure trends and how it may impact the surface finishing industry. If you have any questions or would like additional information regarding the SEC climate disclosure rules or GHG reporting requests, please contact Jeff Hannapel or Christian Richter with NASF at jhannapel@thepolicygroup.com or crichter@thepolicygroup.com.

 

Michigan Advancing on PFAS in Wastewater and Stormwater Discharges

 

NASF recently participated with Michigan industry leaders at MiNASF chapter’s annual technical and industry event in Grand Rapids, and met with officials from Michigan’s Department of Environment, Great Lakes, and Energy (EGLE) to discuss a range of topics, including: EPA’s PFAS wastewater discharge rule, EGLE’s industrial pretreatment program for PFAS, and EGLE’s stormwater program for PFAS. Michigan agency officials noted that its effort to address PFOS in wastewater discharges to POTWs has been successful thus far, and it is now beginning to focus on addressing PFOS in stormwater.

 

Industrial Pretreatment Program

With regard to the industrial pretreatment program for discharges to POTWs, EGLE reported that it had identified 181 sources of PFOS and 55 of them were metal finishing facilities. Of those 181 sources of PFOS, 87 had installed PFOS pretreatment, and 32 of the 87 were metal finishing facilities. Based on the industrial pretreatment program, POTWs reported reduction of PFOS in its effluent by 84 to 99 percent (with most POTWs having reductions in excess of 95 percent). In December 2019, only 72 percent of POTWs meet the Michigan surface water quality value of 12 ppt for PFOS (including all of the POTWs that did not have any sources of PFOS). As of February 2024, 93 percent of POTWs are now meeting the 12 ppt surface water quality value.

 

Industrial Stormwater Discharges

With the success of the industrial pretreatment program in significantly reducing the amount of PFOS in effluent discharges, EGLE has also turned its attention to reducing PFOS in industrial stormwater discharges. Approximately two years ago, EGLE started identifying potential sources of PFOS in stormwater and then conducted investigations to characterize stormwater discharges. 45 facilities were investigated and 20 facilities were set for enforcement and corrective action (15 of those 20 facilities were metal finishing facilities). EGLE sent letters to the facilities targeted for corrective action to initiate enforcement through a general administrative consent order (GACO).

 

After a lengthy period of inactivity on this matter, EGLE is now expected to proceed with implementing corrective action with facilities by Summer 2024 through the use of a GACO. The GACO process would not include any up-front penalties and would allow facilities to identify and implement appropriate site-specific corrective actions.

 

The corrective action would target source removal instead of requiring the collection and treatment of stormwater. Corrective actions could include the following:

  • Clean contaminated surfaces, equipment, tanks and other ancillary pipes,
  • Reseal or replace roofs,
  • Resurface parking lots,
  • Replacement of line contaminated storm sewer pipes and down spouts, replace air handling equipment, and
  • Elimination of stormwater exposure to contaminated equipment or materials.

The GACO would also include stormwater effluent goals, and failure to meet these goals would trigger additional corrective actions, but not financial penalties. In addition, the GACO would include ongoing compliance monitoring and performance certification.

 

While EGLE’s GACO process provides flexibility, facilities will need to work with EGLE to identify and remove the source of PFOS in stormwater. As long as facilities continue to work with EGLE in implementing corrective actions to remove PFOS in stormwater discharges, the agency does not include to impose any penalties.

 

As NASF continues to work with EPA on the development of the PFAS wastewater discharge rule for the surface finishing industry, EGLE continues to address PFAS in wastewater and stormwater discharges and appears to be setting the standard for the surface finishing industry. If you have any questions, please contact Jeff Hannapel or Christian Richter with NASF at jhannapel@thepolicygroup.com or crichter@thepolicygroup.com.

 

EPA Racing to Complete Priority Rules Before Possible Congressional Review Act Deadline

 

EPA top officials have acknowledged that the agency is working to finalize a suite of major environmental regulations by the end of May 2024 to avoid a possible reversal of the regulations pursuant to the Congressional Review Act (CRA) should Republicans gain control of both chambers in the next Congress. The CRA applies to final rules, including major rules, nonmajor rules, interim final rules, and may even include guidance documents and policy memoranda. Typically, the CRA is most often applied to rules that were promulgated in the last six months of a previous Administration.

 

The CRA enables Congress to disapprove a final rule or policy issued by a federal agency. A rule or policy disapproved using this mechanism is not only nullified; the agency is also prevented from reissuing a “substantially similar” rule or policy in the future unless Congress authorizes it to do so via subsequent legislation.

 

As a result, EPA is accelerating its efforts to finalize several major air, water, waste, and chemicals management rules and policies in the next two months to avoid the potential risk that priority regulations could be rescinded by a new Congress after the November elections. Vicky Arroyo, head of EPA’s Policy Office indicated that this risk is “something that we’re very focused on,” and that the White House “is working very closely with [EPA] to ty to get our priority rules done as soon as possible because we are obviously . . . just aware of that risk.” NASF will continue to engage closely with EPA on its near-term regulatory agenda and provide updates to NASF members. If you have any questions or would like additional information regarding this issue, please contact Jeff Hannapel or Christian Richter with NASF at jhannapel@thepolicygroup.com or crichter@thepolicygroup.com.

 

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. All funds from the NASF 1000 program are used ‎exclusively to support specific projects and initiatives that fall outside the association’s day-to-‎day public policy activities. 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. ‎

 

The sustained commitment from industry leaders has helped the NASF remain strong and ‎credible in informing regulatory decisions across the nation. Specific projects funded through ‎the NASF 1000 make a measurable difference in how the industry navigates emerging ‎challenges, communicates credibly with policy makers, and advocates for a strong science base ‎for rules or standards that affect surface finishing. ‎

 

Please consider supporting the NASF 1000 program. If you have any questions or would like ‎additional information regarding the NASF 1000 program or the broad array of NASF public ‎policy activities, please contact Jeff Hannapel with NASF at jhannapel@thepolicygroup.com.‎

 

NENASF Partners with HRP Associates

Date: March 9, 2024
Category: Chapter News, Events, Member News, NASF Chapters, Regulation

                                                        NENASF LOGO

HRP Logo

The NENASF is pleased to announce that we have partnered with HRP Associates.  HRP has for years organized and run our Annual HAZMAT, RCRA, and DOT TRAINING seminars and will once again be doing so on May 15th, 2024!  

Please visit their sight to see what they have to offer!

HRP Associates

EXAMPLES OF TRAININGS OFFERED

RCRA Hazardous Waste ManagementDOT Hazardous Materials Transportation / IATA (Air) / IMDG (Vessel)

EHS Management Systems / ISO 14001:2015 / OHSAS 18001:2007

OSHA Health and Safety

8-Hour HAZWOPER Refresher

Asbestos AwarenessProcess Safety Management

Brownfields Opportunities / Environmental Due Diligence

Environmental Compliance Overview

Spill (SPCC) and Stormwater (SWPPP)

Company specific EHS Training

UST A/B Operator Training

January 2024 NASF Policy Update

Date: January 23, 2024
Category: NASF National, Regulation

NASF Logo

  • NASF Action Ahead on Major EPA Regulatory Push in 2024 – Finishing industry ‎burdens could exceed over a billion in future costs and liabilities if certain rules are ‎finalized. NASF will be fully engaged with policy makers this election year.‎
  • NASF Government Affairs PFAS Webinars – The association’s Public Policy team on ‎January 15th provided guidance to members from across the nation on the new survey, ‎and more advice and assistance is available.‎
  • Pentagon Proposes Cybersecurity Maturity Model Certification (CMMC) Program ‎Rule: NASF Review Underway – A proposed rule published in the Federal Register on ‎December 26, 2023 establishes a revamped CMMC 2.0 program and defines ‎requirements for the program and for each CMMC level. ‎
  • EPA Issues More Stringent Guidance for Soil Cleanup Screening Levels: Potential ‎Impacts Ahead for Certain Surface Finishing Operations – The new screening levels ‎could drive investigation and/or cleanup at hundreds of thousands of new parcels. ‎

Please see more details on these topics below:‎
NASF Action Ahead on Major EPA Regulatory Push in 2024‎
With a wide-ranging regulatory agenda set in December 2023 and funds still in the pipeline ‎from Biden initiatives passed by Congress, EPA this year will be rushing to meet deadlines to ‎complete far-reaching regulations and distribute billions of dollars by the end of 2024. The ‎agency is working to implement protections on air, climate, and water by late summer before ‎they may be in danger of reversal next year should Republicans win back full control of ‎Congress and the White House.‎
EPA Deputy Administrator Janet McCabe noted the agency’s work is “hard, tiring, and ‎rewarding” in a widely-circulated note to EPA staff, and advised that “2024 is also going to be a ‎big year for our regulatory programs – from rules that address climate pollution, to those that ‎protect our precious rivers, lakes coastlines, and wetlands, to those that ensure the air we ‎breathe, the water we drink, and the land we rely upon is safe and healthy. I want each rule ‎writer, regulatory development team member, economist, scientist, biologist, and public health ‎officer to know that Administrator Regan and I have got your back as you make your way ‎through your work this year. We have an important job to do, and I am confident that together ‎we will deliver.”‎
The finishing industry could be subject to new regulatory burdens and future liability exceeding ‎a billion dollars if EPA finalized some of its most significant rulemakings, including:‎

  • the PFAS Superfund remediation listing regulation, ‎
  • the PFAS drinking water standard, ‎
  • several chemicals management rules, and
  • the wastewater discharge rule for metal finishing and electroplating.‎

NASF will continue working with EPA officials on these and other policy decisions and ‎providing members with critical updates in the coming year. If you have any questions or ‎would like more information, please contact Jeff Hannapel or Christian Richter with NASF at ‎jhannapel@thepolicygroup.com or crichter@thepolicygroup.com. ‎
NASF Government Affairs Webinars: Providing Guidance to Members on EPA’s Survey ‎for the PFAS Wastewater Discharge Rule ‎
Since late December, finishing facilities across the nation began receiving federal EPA’s ‎industry survey that will inform the agency’s surface finishing PFAS wastewater discharge rule. ‎The survey includes an extensive set of information requests regarding facility operations and ‎processes, facility uses of PFAS, PFAS discharge data, water discharge permits, and company ‎financial information. The submission of accurate responses to the survey that are ‎representative of the industry will be critical, as the information from the survey will help to ‎shape the rule to address – in some form – PFAS wastewater discharges from finishing.‎‎On January 15, NASF held a webinar for members to provide some guidance on responding to ‎the survey. The program prompted wide participation from association members across the ‎country. The guidance included, among other topics:‎

  • general considerations for the survey,‎
  • a brief summary of the “off ramps” for the survey, ‎
  • clarifications on the type of information that EPA is requesting and EPA’s rationale for ‎requesting it, ‎
  • the process for protecting some of the responses as confidential business information ‎‎(CBI), the survey submission deadline, and ‎
  • how to request an extension. ‎

In addition, The Policy Group answered questions from participants as part of the webinar and ‎in the days following. ‎The webinar is available on the NASF website in the members-only area.
NASF is planning some additional webinars on the survey and details regarding the upcoming ‎webinars will be provided soon. If you have any questions or would like additional information ‎on the survey, the new wastewater discharge rule for PFAS, or upcoming webinars on the ‎survey, please contact Jeff Hannapel or Christian Richter with NASF at ‎jhannapel@thepolicygroup.com or cichter@thepolicygroup.com.
Pentagon Proposes Cybersecurity Maturity Model Certification (CMMC) Program Rule: ‎NASF Review Underway
The Cybersecurity Maturity Model Certification (CMMC) Program is the Department of ‎Defense’s (DOD) process of ensuring that contractors are adequately protecting sensitive ‎information under DOD contracts. It requires DOD contractors to certify that they are ‎compliant with cybersecurity requirements for protecting sensitive information. DOD has been ‎making efforts to increase cybersecurity protections, including when it announced in November ‎‎2021 “CMMC 2.0” that established a program structure with three key factors: 1) tiered levels ‎of security, 2) assessment requirements, and 3) implementation through contracts.‎
A proposed rule published in the Federal Register on December 26, 2023 establishes a ‎revamped CMMC 2.0 program and defines requirements for the program and for each CMMC ‎level. Surface finishing operations conducting business with DOD and its contractors have been ‎in the process of implementing CMMC requirements at significant cost for some and will be ‎impacted by this rule. ‎
A copy of the proposed rule is available at the following link: ‎https://www.federalregister.gov/documents/2023/12/26/2023-27280/cybersecurity-maturity-‎model-certification-cmmc-program. ‎
Tier LevelsThe proposed rule preserves the three tier levels that were introduced in CMMC 2.0.‎

  • CMMC Level 1 – includes 15 requirements listed in the Federal Acquisition Regulation ‎‎(FAR) and would apply to contractors who store, process, or transmit Federal Contract ‎Information (FCI).‎
  • CMMC Level 2 – includes 110 requirements from the National Institute of Standards ‎and Technology (NIST) Special Publication (SP) 800-171, Rev. 2 and would apply ‎broadly to contractors who store, process, or transmit Controlled Unclassified ‎information (CUI).‎
  • CMMC Level 3 – includes 24 requirements from NIST SP 800-172 and full ‎implementation of NIST SP 800-171 and would apply to a small group of contractors ‎who store, process, or transmit high-value CUI.‎

AssessmentsThe proposed rule includes a mixture of self-assessments and third-party assessments depending ‎on the nature of the data.‎

  • CMMC Level 1 assessments will be self-assessments that require contractors to verify ‎their own compliance with the applicable security controls and submit their assessments ‎to DOD annually.‎
  • CMMC Level 2 assessments will be either self-assessments or a certification assessment ‎performed by a third-party assessment organization that must be completed every three ‎years. The proposed rule does not specify how DOD will determine which type of ‎assessment will be required.‎
  • CMMC Level 3 assessments will be certification assessments performed by the Defense ‎Industrial Base Cybersecurity Assessment Center every three years.‎

Certifications and Plan of Action and Milestones (POA&M)‎An assessment may result in a Final Certification or a Conditional Certification, depending on ‎whether the contractor has implemented all of the required security controls. The proposed rule ‎allows for some flexibility with the limited use of a Plan of Action and Milestones (POA&M) ‎for certain requirements and for a limited time where some controls are not yet implemented. ‎
For example, POA&Ms are not permitted for Level 1 assessments but can be used for some ‎Level 2 and 3 assessments. If a POA&M exists after an assessment, the contractor will be ‎granted a Conditional Certification and have 180 days to fully implement all of the security ‎controls listed in the POA&M. Failure to implement the security controls in the POA&M will ‎result in penalties or loss of the DOD contract.‎
Implementation TimelineThe proposed rule includes a four-phase implementation plan.‎

  • Phase One – begins on the effective date of the final CMMC rule and includes a CMMC ‎Level 1 or CMMC Level 2 self-assessment as a condition for contract award.‎
  • Phase Two – begins six months after Phase One and includes CMMC Level 2 ‎certification assessments for contract awards.‎
  • Phase Three – begins one year after Phase Two and introduces CMMC Level 3 ‎certification assessments.‎
  • Phase Four – full implementation of CMMC requirements begins on October 1, 2026.‎

Comment Deadline and Preparing for the RuleComments on the proposed rule are due on February 26, 2024. NASF will continue to review ‎and evaluate the proposed rule and plans to submit comments. Because the final rule is not ‎expected to look dramatically different from the proposed rule, surface finishing operations ‎subject to these requirements should consider continuing their efforts toward full compliance ‎with the CMMC requirements. ‎
If you have any questions or would like more information regarding the CMMC proposed rule ‎or compliance efforts, please contact Jeff Hannapel or Christian Richter with NASF at ‎jhannapel@thepolicygroup.com or crichter@thepolicygroup.com. ‎

EPA Issues More Stringent Guidance for Soil Cleanup Screening Levels: Potential Impacts ‎Ahead for Certain Surface Finishing Operations

EPA issued new guidance on recommended screening levels for cleaning up lead-contaminated ‎soil at federal Superfund cleanup sites and Resource Conservation and Recovery Act (RCRA) ‎corrective action facilities. Specifically, EPA lowered the screening level for lead in soil at ‎residential properties from 400 parts per million (ppm) to 200 ppm. ‎
For remedial actions, if there are other sources of lead exposure, such as lead in air and water, ‎EPA recommends screening level as 100 ppm. EPA notes that the guidance’s new thresholds ‎should apply to both existing and new sites. This action is expected to drive evaluation and ‎cleanup at a “significant number” of residential properties.‎
The new screening levels could drive investigation and/or cleanup at hundreds of thousands of ‎new parcels. EPA’s Office of Superfund Remediation and Technology Innovation estimate that ‎this could result in approximately 500,000 parcels (an order of magnitude estimate) needing ‎investigation and/or cleanup. ‎
New Screening Level to Drive More Stringent Cleanup Levels at More Sites
In the new guidance the agency emphasizes that screening levels are not cleanup levels, and are ‎used in the early stages of investigating a release to determine if the level of contamination is ‎high enough to warrant further investigation. Nonetheless, the new screening level will drive ‎substantially more stringent cleanup levels at significantly more sites. ‎
EPA requests that its own regional office work collaboratively with state, tribal, and public ‎health agencies to prioritize addressing sites, considering factors such as current levels of ‎exposure and communities with increased risk. Consistent with national policy, EPA will make ‎resource decisions for residential lead sites in a manner that balances resources across all ‎Superfund sites. Because many of the communities at highest risk are in urban areas, it could ‎have an impact on all industry sectors, including surface finishing operations.‎
NASF will continue to monitor this issue and its potential impacts on the surface finishing ‎industry. If you have any questions or would like more information, please contact Jeff ‎Hannapel or Christian Richter with NASF at jhannapel@thepolicygroup.com or ‎crichter@thepolicygroup.com. ‎

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. All funds from the NASF 1000 program are used ‎exclusively to support specific projects and initiatives that fall outside the association’s day-to-‎day public policy activities. 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. ‎
The sustained commitment from industry leaders has helped the NASF remain strong and ‎credible in informing regulatory decisions across the nation. Specific projects funded through ‎the NASF 1000 make a measurable difference in how the industry navigates emerging ‎challenges, communicates credibly with policy makers, and advocates for a strong science base ‎for rules or standards that affect surface finishing. ‎
Please consider supporting the NASF 1000 program. If you have any questions or would like ‎additional information regarding the NASF 1000 program or the broad array of NASF public ‎policy activities, please contact Jeff Hannapel with NASF at jhannapel@thepolicygroup.com.‎

The 2023 New England Surface Finishing Regional in Newport, Rhode Island

Date: November 11, 2023
Category: Chapter News, Events, NASF Chapters, Regulation

NE Surface Finishing Regional Logo

The New England Surface Finishing Regional took place this past November 3rd in Newport, Rhode Island. It was a huge success with a 120 people in attendance. There were speakers from all over the country that delivered educational and thoughtful presentations to all in attendance.

The New England Surface Finishing Regional is honored to have presented the 7th Annual Foundation Award to longtime supporter Alex Price of Luster-On Products. The award was created to recognize a metal finishing supplier that has demonstrated outstanding contributions, support, and dedication to the annual regional event.

The 2024 the New England Surface Finishing Regional will be held November 8th in Hyannis, Cape Cod Massachusetts.

Please continue to follow www.nensaf.org all year for news and events throughout the New England metal finishing industry.

 

NEW ENGLAND CHAPTER HOSTS ANNUAL VIRTUAL FALL SEMINAR

Date: October 4, 2023
Category: Chapter News, Events, Member News, NASF Chapters, NASF National, Regulation

NENASF LOGO

The New England Chapter of NASF hosted a virtual seminar for the benefit of their membership and the entire non-NENASF metal finishing community. The event was held on Wednesday September 13, 2023.  The event was presented free of charge to NENASF members, and at a modest fee for other interested parties, as an educational and bonding opportunity for the metal finishing community.

 

The Webinar was conducted by means of Zoom format and attracted about forty attendees. It was made up of three segments featuring three presenters over a two-hour period from 10:00am to 12:00 pm offering a user-friendly format for all attendees. In addition to offering vital regulatory and technical information the event also made available two Continuing Education Wastewater Treatment Operator Contact Hours needed for WWT Operator License renewal.

 

Ethan Ware of Williams Mullen Law Group opened the Webinar with a presentation on the upcoming EPA PSFAS Survey that will be sent out to nearly 2000 metal finishers this fall. He stressed that the demographics would not only include chrome platers but chromate conversion coaters as well. This is a very detailed Survey and asks many complex questions through eight sections over seventy-one pages. He covered the answering/data requirements both from a technical as well as a legal perspective. He very much stressed that the information gathered in this Survey will shape the future of Wastewater Discharge Permits for years to come.

This was followed by a presentation by Jeremy Riley of Omega Research giving a detailed description of how proper finishing specification required test sample preparation can make a difference in acceptable test results, while poorly prepared samples can fail causing ripple effects with customer job acceptance.

The webinar was concluded with a presentation by Tony Oriti on Zinc-Nickel and Zinc-Tin as an alternative to Cadmium Plating. Tony not only presented the latest technological advances in these two finishes as they try to replace a long-time exceptional performing and defense and aerospace specified finish, cadmium, but also gave the attendees a look at emerging technology in the form a triple alloy finish that is in the developmental stages.

 

Once again we want to give special thanks to Chris Capalbo for moderating, and to Dev Massimi and Ralph Capalbo as Program Speaker Facilitators for their contributions, and to the combined efforts of NASF Board Members, Committee Members, Chapter Membership and dedicated and talented members of the Metal Finishing Community as a whole for making events such as this available for the benefit of our membership.

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