| Register Now: Assistant Secretary of Labor David Keeling to Deliver Morning Keynote at the Washington Forum: David Keeling, Assistant Secretary of Labor for Occupational Safety and Health and head of the Occupational Safety and Health Administration (OSHA), will deliver the morning keynote address at the NASF Washington Forum on September 22, 2026, at the Willard Hotel in Washington, D.C. Registration and hotel information are available on the NASF website.
Defense Procurement: Pentagon Suspends Key Cybersecurity Mandate to Review Small Business Compliance Burdens: The U.S. Department of War (DoW) suspended implementation of Cybersecurity Maturity Model Certification (CMMC) Phase II while conducting a review of the program’s impact on the defense industrial base, particularly small and medium-sized manufacturers. The action, announced on July 13, pauses the planned expansion of mandatory third-party certification requirements while the Department evaluates potential reforms intended to strengthen cybersecurity without creating unnecessary barriers for small businesses in the defense supply chain.
Water Regulation: New EPA Draft Guidance Highlights Industrial Source Reduction to Reduce Potential PFAS Risks in Biosolids: EPA released draft guidance in July outlining voluntary recommendations to reduce potential risks from PFOA and PFOS in biosolids while requesting public comment on future agency actions. The guidance follows the agency’s review of the Biden-era draft biosolids risk assessment, which EPA said relied on modeled higher-risk scenarios that did not adequately reflect typical biosolids management practices in the United States.
Chemicals Policy: Targeted TSCA Improvements Face Uncertain Path in Congress: Congress is considering legislation to make targeted improvements in how EPA implements the nation’s primary chemicals law, the Toxic Substances Control Act (TSCA). Much of the discussion has focused on improving the efficiency and predictability of EPA’s new chemical review program. However, many observers have become increasingly uncertain whether Congress will be able to complete legislative action this year.
Member Briefing: NASF Legal Update in July to Continue at Washington Forum: NASF’s Government Affairs member briefing last month focused on PFAS legal developments, featuring Keller and Heckman LLP, the Washington, D.C.-based law firm assisting NASF on chemicals policy issues. NASF will continue these discussions at the Washington Forum on September 22, 2026, at the Willard Hotel in Washington, D.C., where members will receive additional updates on significant federal chemicals policy and PFAS developments affecting the surface finishing industry. Registration and hotel information are available on the NASF website.
For more details on these topics, please continue reading below:
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NASF Report
NASF Events: Assistant Secretary of Labor David Keeling to Deliver Morning Keynote at the Washington Forum
David Keeling, Assistant Secretary of Labor for Occupational Safety and Health and head of the Occupational Safety and Health Administration (OSHA), will deliver the morning keynote address at the NASF Washington Forum on September 22, 2026, at the Willard Hotel in Washington, D.C.
Since assuming leadership of OSHA, Keeling has emphasized collaboration with employers, trade associations and safety professionals while outlining the agency’s regulatory, enforcement and compliance priorities. He has described OSHA’s mission as helping employers protect workers through practical solutions, compliance assistance and targeted enforcement where needed.
The keynote will provide NASF members with an opportunity to hear directly from OSHA’s senior leadership on the agency’s priorities and the direction of workplace safety and health policy under the current administration.
Registration and hotel information are available on the NASF website.
Defense Procurement: Pentagon Suspends Key Cybersecurity Mandate to Review Small Business Compliance Burdens
The U.S. Department of War (DoW) suspended implementation of Cybersecurity Maturity Model Certification (CMMC) Phase II while conducting a review of the program’s impact on the defense industrial base, particularly small and medium-sized manufacturers. The action, announced on July 13, pauses the planned expansion of mandatory third-party certification requirements while the Department evaluates potential reforms intended to strengthen cybersecurity without creating unnecessary barriers for small businesses in the defense supply chain.
The Department said the review is intended to ensure cybersecurity requirements remain effective while reducing unnecessary compliance burdens on companies supporting the Defense Industrial Base. A CMMC Reform Task Force has been established to evaluate the current framework and solicit public input before making recommendations on the program’s future direction.
SBA Highlights Small Business Concerns
The U.S. Small Business Administration (SBA) responded in support of the Department’s decision and noted that many small defense contractors had expressed concern over the cost and complexity of the planned Phase II certification requirements. SBA cited its engagement with small manufacturers and other defense industrial base stakeholders, concluding that compliance costs and limited assessment capacity could discourage participation by companies that play an important role in supporting national defense. SBA also stated that limited assessment capacity could delay certification even for companies prepared to comply.
The Department and SBA described the review as part of a broader effort to protect federal information while reducing compliance barriers for small businesses.
Existing Cybersecurity Requirements Continue
The suspension does not eliminate existing cybersecurity obligations for defense contractors. Existing contractual cybersecurity and CMMC Phase I self-assessment requirements remain in effect during the review process. Companies performing defense work should continue to comply with applicable contract requirements and monitor future Department guidance as the review proceeds.
The Department has also requested public input through a formal Request for Information (RFI), with comments due by August 14, 2026, to help identify opportunities to improve the program while maintaining strong cybersecurity protections across the defense industrial base.
Implications for NASF Members
For NASF members that provide services for defense customers or participate in defense supply chains, the announcement provides additional time before implementation of the next phase of the CMMC program while reaffirming that cybersecurity remains an important policy priority. The Department has indicated it expects to complete its review and develop recommendations within approximately 60 days, or around mid-September 2026. Companies with defense-related business should continue maintaining compliance with existing contractual requirements and remain attentive to future Department announcements as the review progresses.
NASF will continue to monitor developments and provide updates as additional guidance becomes available.
Water Regulation: New EPA Draft Guidance Highlights Industrial Source Reduction to Reduce Potential PFAS Risks in Biosolids
EPA released draft guidance in July outlining voluntary recommendations to reduce potential risks from PFOA and PFOS in biosolids while requesting public comment on future agency actions. The guidance follows the agency’s review of the Biden-era draft biosolids risk assessment, which EPA said relied on modeled higher-risk scenarios that did not adequately reflect typical biosolids management practices in the United States. The agency is seeking additional public input as it considers future actions related to PFAS in biosolids.
EPA Discusses Risk-Reduction Strategies
Rather than proposing new national regulatory requirements, EPA’s draft guidance discusses several approaches to reducing PFAS entering wastewater systems, including:
- Source identification and source reduction to help reduce PFAS discharges before they enter wastewater systems.
- Monitoring and pollution prevention to better identify PFAS sources and evaluate opportunities for reduction.
- Industrial pretreatment and state programs, including examples from Michigan and other states that have used upstream source identification and pretreatment to reduce PFAS entering wastewater treatment systems.
- Recommendations for wastewater utilities, industrial dischargers, states and other stakeholders intended to reduce PFAS risks while supporting the beneficial use of biosolids where appropriate.
Implications for Surface Finishing
For the surface finishing industry, the biosolids guidance is particularly relevant because it discusses approaches that involve industrial dischargers working with wastewater utilities to reduce PFAS entering wastewater systems. Although the guidance is voluntary and does not establish new regulatory requirements, EPA states that public comments will help inform future agency actions related to PFAS in biosolids. Comments are due September 4, 2026.
NASF will continue monitoring EPA’s biosolids initiative and provide updates as the agency evaluates public comments and determines next steps.
Chemicals Policy: Targeted TSCA Improvements Face Uncertain Path in Congress
Congress is considering legislation to make targeted improvements in how EPA implements the nation’s primary chemicals law, the Toxic Substances Control Act (TSCA). Much of the discussion has focused on improving the efficiency and predictability of EPA’s new chemical review program. However, many observers have become increasingly uncertain whether Congress will be able to complete legislative action this year.
Broad Support from Industry
NASF shares the view of national manufacturing and chemical industry organizations that targeted improvements to EPA’s chemical review program are warranted. Among the priority issues are addressing lengthy review times for new chemical substances, improved communication between EPA and chemical manufacturers, providing greater predictability for industry and more efficiency in the chemical review process. Environmental and public health organizations, meanwhile, have urged Congress to ensure that any legislative changes preserve EPA’s authority to protect human health and the environment.
Uncertainty Ahead This Fall
Although discussions continue, attention has increasingly shifted toward the possibility of more limited legislation or inclusion of TSCA provisions in other must-pass legislation later this year should Congress be unable to complete broader legislation before the September deadline.
Benefits for Surface Finishing
For the surface finishing industry, these discussions are particularly relevant to chemical manufacturers and suppliers that develop new products and technologies. Improvements to the efficiency and predictability of EPA’s chemical review process could help support innovation and accelerate the development and introduction of new industrial chemistries throughout the surface finishing supply chain.
NASF will continue monitoring congressional activity and provide updates as legislative proposals advance.
Chemicals Policy: NASF Member Briefing in July to Continue at Washington Forum
NASF’s Government Affairs member briefing last month focused on PFAS legal developments, featuring David Fischer and Eric Gotting, partners with Keller and Heckman LLP, the Washington, D.C.-based law firm assisting NASF on chemicals policy issues.
Preparing Members for an Evolving PFAS Landscape
The briefing provided members with an overview of the evolving PFAS legal and regulatory landscape affecting downstream industrial users, including the surface finishing industry. Topics included recent PFAS litigation trends, developments in the federal multidistrict litigation (MDL), the types of claims being brought by drinking water utilities and other plaintiffs and emerging regulatory developments.
The webinar is part of NASF’s continuing effort to provide members with strategic, timely and actionable information as PFAS requirements continue to evolve at the federal and state level.
Next Discussion at the NASF Washington Forum
NASF will continue these discussions at the Washington Forum on September 22, 2026, at the Willard Hotel in Washington, D.C., where members will receive additional updates on significant federal chemicals policy and PFAS developments affecting the surface finishing industry. Registration and hotel information are available on the NASF website.
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.
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