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Free MCTA Luncheon Update

Date: December 11, 2025
Category: Chapter News, Events, NASF Chapters, Regulation

Register Today
Free MCTA Luncheon Update

2025 in the Rear-View Mirror: 2026 Preview

Meet the New State Official Charged with Helping You with Regulatory & Permitting Issues

Agenda

  1. Legislative and State Regulatory Updates
    Update on significant legislative and regulatory issues from 2025 as we enter the second part of the legislative session.

  2. Introduction to the State’s new Regulatory Ombudsman Doug Gutro
    Have an issue related to a permit or regulatory issue? The new state Ombudsman is here to help! Doug Gutro was recently appointed to help companies get things done! He has extensive experience in government and is newly appointed to this position which is under the Secretary of Economic Development. Come hear how he may be able to assist you and your company.

  3. Member feedback and MCTA plans for 2026.

    To register, contact Katherine Robertson at katherine@masscta.org. A link will be sent to you.

2025 New England Surface Finishing Regional – Salem, Massachusetts

Date: November 19, 2025
Category: Chapter News, Events, Member News, NASF Chapters, NASF National, Regulation

NE Surface Finishing Regional Logo

 

The New England Surface Finishing Regional took place this past Friday November 7th in Salem, Massachusetts. It was a huge success with a 125 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 9th Annual Foundation Award to longtime supporter American Plating Power. The award was created to recognize a metal finishing supplier that has demonstrated outstanding contributions, support, and dedication to the annual regional event.

The 2026 the New England Surface Finishing Regional will be held November 6th in Newport, Rhode Island.

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

October 2025 NASF POLICY UPDATE

Date: November 1, 2025
Category: Chapter News, Regulation

 

While action in Washington has been disrupted by the federal government shutdown — now at 31 days and with potential for a major disruption and broader economic impact as it nears the record 35-day closure of 2018 – a number of issues remain in play for surface finishing.

 

This month’s update takes a closer look at new OSHA leadership and the agency’s effort to sort through some very thorny issues on how to address heat illness and injuries in both indoor and outdoor workplaces.

_____________

New OSHA Chief Confirmed: Top Priorities and a Major New Heat Rule Pending: In early October 2025, President Trump’s nominee David Keeling was confirmed by the U.S. Senate by a party-line vote of 51-47 to serve as Assistant Secretary of Labor for Occupational Safety and Health, taking the helm at OSHA. He will oversee a major workplace heat stress rulemaking decision for industry in 2026.

 

Outlook: OSHA’s Heat Illness and Injury Rule is Still Under Consideration: OSHA’s proposed regulatory package could be one of the more expansive standards developed by the agency based on its current scope and cost impact. First issued in the Biden administration in August 2024, it has been the topic of major concern for manufacturers and the employer community.

 

This Week: Small Business Administration Says OSHA Heat Rule Must Reflect the Needs of Small Operations: The Small Business Administration’s Office of Advocacy submitted a critique of OSHA’s heat rule on October 30, highlighting the concerns of small business and offering a list of recommendations to minimize burdens on operations nationwide if OSHA moves forward with a final rule or proposed a new standard.

 

NASF Position on PFAS from the Washington Forum is Available: During last month’s Washington Forum, members received the latest NASF PFAS Brief, which highlights the finishing industry’s long record of action on PFAS and its recommendation to Congress and EPA for a technically sound, economically feasible and small manufacturing-friendly outcome on the metal finishing PFAS regulatory proposal scheduled for next year.

 

The Deregulatory Agenda: A Look at the Latest Developments This Month: In a new effort to speed up deregulatory actions, The White House issued a late October memo that offers guidance to federal agencies to repeal what is highlighted as “facially unlawful” regulations without the typically required notice and comment rulemaking procedures.

For more details on these topics, see more below:

_______________________

 

New OSHA Chief Confirmed: Top Priorities and a Major New Heat Rule Pending

In early October 2025, President Trump’s nominee David Keeling was confirmed by the U.S. Senate by a party-line vote of 51-47 to serve as Assistant Secretary of Labor for Occupational Safety and Health, and now takes the helm at OSHA.

 

Top Priorities for a New OSHA

 

In his earlier nomination hearing Keeling, a former safety executive at UPS and Amazon who began his career as a Teamster, had signaled his top priorities would include:

  • modernizing rulemaking and regulatory oversight, including the use of new technology and predictive analytics;
  • expanding collaboration and cooperation among employers, unions and professional organizations as well as OSHA; and
  • transforming enforcement and safety culture, moving away from reactive enforcement and emphasizing proactive prevention.

He did not lay out specific priorities for rulemakings.

 

Other areas he emphasized that have been welcomed by industry include aligning future standards more closely with recognized consensus standards and industry best practices. Overall, the employer community viewed his remarks and pointing to more predictable enforcement and pragmatic workplace safety.

 

Some High-Consequence Decisions Ahead

 

Keeling inherits a slate of leftover items on the regulatory agenda, with OSHA managing more than a dozen active rulemakings. Among the most consequential is the long-anticipated Heat Injury and Illness Prevention in Outdoor and Indoor Work Settings proposal, which would establish the first federal standard addressing heat exposure across industries, including indoor manufacturing operations. For an update on its status and outlook, see below.

 

Outlook: OSHA’s Heat Illness and Injury Rule is Still Under Consideration

 

OSHA is currently considering a proposed regulatory package that could be one of the more expansive standards developed by the agency based on its current scope and cost impact. First issued in the Biden administration in August 2024, it has been the topic of major concern for manufacturers and the employer community. OSHA held a weeks-long series of public hearings on the proposal this summer and the post-hearing comment period has closed as of the end of October. A final rule could emerge in 2026.

 

Quick Summary: Major Provisions in the Heat Rule Impact Manufacturing

 

Under the current proposal, employers would be required to implement site-specific Heat Injury and Illness Prevention Plans (HIIPPs) when indoor or outdoor temperatures reach an initial trigger of 80 °F and expand controls at a high-heat threshold of 90 °F.

 

The draft includes provisions that both outdoor and indoor operations would incorporate into their plans, including:

  • access to cool drinking water,
  • shaded or cooled rest areas,
  • paid rest breaks at high heat (15 minutes every two hours),
  • acclimatization for new and returning workers,
  • periodic monitoring of conditions, and
  • a designated heat-safety coordinator, record keeping, and annual training.

Implications for the Surface Finishing Industry

 

For metal-finishing and plating operations, the implications are potentially significant. Many facilities operate in high-humidity or elevated-temperature environments due to ovens, dryers, and heated plating baths. Even though primarily “indoor,” many industrial operations could be subject to the standard once finalized. NASF Washington Forum attendees received a full briefing on the proposed heat rule and other pending issues from Marc Freedman, US Chamber Vice President of Employment Policy, and the association is monitoring developments closely to keep members updated on how possible requirements impacting ventilation, temperature-monitoring, rest-break policies and other areas will affect finishing operations.

 

Close Attention Will Be Necessary in 2026

 

As we continue to speak with OSHA officials on the emerging rulemaking agenda, we expect that the scope, key provisions and implementation timelines currently associated with the proposed heat rule to be modified, and the details will emerge in the coming months. If you have any questions or would like additional information, please contact Jeff Hannapel or Christian Richter with NASF at jhannapel@thepolicygroup.com or crichter@thepolicygroup.com.

 

This Week: Small Business Administration Says OSHA Heat Rule Must Reflect the Needs of Small Operations

 

The Small Business Administration’s Office of Advocacy submitted a critique of OSHA’s heat rule on October 30, highlighting the concerns of small business and offering a list of recommendations to minimize burdens on operations nationwide if OSHA moves forward with a final rule or proposed a new standard. The paper addresses several questions it asked witnesses during OSHA’s July public hearing on the proposed rule and responds to OSHA’s inquiry about how it might structure and enforce a more flexible, performance-oriented approach.

 

Recommended Changes to the OSHA’s Proposal

 

The SBA’s advocacy team has been actively involved in this OSHA rulemaking process for several years and has held multiple small business roundtables with trade associations, including NASF. Their latest comments urge several changes:

  • OSHA should avoid a one-size-fits-all rule and consider a more flexible, performance- oriented approach. Several possible alternatives include Nevada’s new state heat illness prevention regulation or an approach borrowed from other OSHA performance-oriented approaches, or issuing separate standards for different sectors such as general industry, construction, and agriculture.
  • OSHA should consider and provide for work environments and situations that are not currently addressed in the proposed rule, including hybrid or mixed outdoor/indoor work environments, situations where compliance would be impracticable, infeasible, or would create a greater hazard, and provide for employee vulnerabilities, susceptibilities or confounding factors.
  • OSHA should revisit its definition of “economic feasibility,” and, in light of the Supreme Court’s recent Loper Bright decision, adopt a more appropriate definition, such as an appropriate cost-benefit analysis from existing federal regulatory guidance.

If you have any questions or would like additional information, please contact Jeff Hannapel or Christian Richter with NASF at jhannapel@thepolicygroup.com or crichter@thepolicygroup.com.

 

NASF Position on PFAS from the Washington Forum is Available

 

Among the most prominent annual milestones for the industry was last month’s NASF Washington Forum. The event featured wide coverage of priorities for the industry on the economy, tariffs, critical minerals, the defense base and workforce issues.

 

Messaging For NASF Members

 

We also provided industry leaders in attendance a new NASF PFAS Brief, which highlights the finishing industry’s long record of action on PFAS and its recommendation to Congress and EPA for a technically sound, economically feasible and small manufacturing-friendly outcome on the regulatory proposal scheduled for 2026.

 

New Federal End-of-Pipe PFAS Standards is Unnecessary

 

The brief highlights what NASF has continued to advocate – that a new nationwide end-of-pipe standard is unnecessary given the industry’s successful elimination of legacy PFOS use, its transition to safer and ultimately PFAS-free alternatives, and ongoing collaboration with the automotive supply chain to phase out remaining uses.

 

Household PFAS, other Sectors Far Exceed Finishing’s Negligible Contribution to Nation’s POTWs

 

It also drives home an important takeaway from the POTW community and EPA studies, which show that metal finishing operations account for less than one percent of total PFAS loading nationwide, underscoring the negligible contribution from finishing relative to other industrial and consumer sources.

 

This point was echoed by Dr. Cynthia Finley, head of regulatory affairs for the POTWs trade association in Washington, the National Association for Clean Water Agencies (NACWA). In addition to thanking the finishing industry for working together with the local municipal treatment community, she noted that PFAS for wastewater utilities continues to be a top focus, and that a practical, phased approach is needed for POTWs rather than immediate rigid mandates from EPA.

 

NASF continues to work with EPA, the POTW community and other allies on the issue in the meantime. If you would like a copy of the brief, have any questions or would like additional information, please contact Jeff Hannapel or Christian Richter with NASF at jhannapel@thepolicygroup.com or crichter@thepolicygroup.com.

 

The Deregulatory Agenda: A Look at the Latest Developments This Month

 

In a new effort to speed up deregulatory actions, The White House issued a late October memo that offers guidance to federal agencies to repeal what is highlighted as “facially unlawful” regulations without the typically required notice and comment rulemaking procedures.

 

Agencies Can Streamline Repealing Current Rules

 

The memorandum cites the “good cause’ exemption of the Administrative Procedure Act (APA) as legal authority for certain deregulatory actions. The law’s “good cause’ exemption allows agencies to bypass traditional notice and comment rulemaking when an agency for any good cause finds that notice and comment rulemaking would be “impractical, unnecessary, or contrary to the public interest.” The White House memorandum suggests that the “good cause” exemption would apply to most deregulatory actions.

 

White House Shortening Its Own Review

 

In addition, to help streamline the deregulatory process the White House recommends shortening its traditional 90-day review process for major regulations to 28 days for deregulatory actions that are executed with good factual records and to 14 days for “facially unlawful” rules.

 

Environmental Advocacy Group Opposition, Litigation

 

The stated justification for the streamlined review process is that the more extensive regulatory review process is needed before new regulatory burdens are imposed, but the same process would not apply to deregulatory actions. The guidance in the memorandum is designed to help accelerate deregulatory actions currently underway.

 

Environmental advocacy groups have expressed strong opposition to the memorandum, claiming that it based on a flawed interpretation of the APA. They have promised to challenge this novel in court at the first opportunity.

 

We will continue to monitor the efforts to streamline the deregulatory process and provide updates to NASF members. If you have any questions or would like additional 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. For more information, contact: Christian Richter (202-257-‎‎0250) or Jeff Hannapel (202 257-3756) with NASF.‎

 

 

NENASF FALL WEBINAR SEPTEMBER 2025

Date: September 19, 2025
Category: Chapter News, Events, NASF Chapters, Regulation

New England Chapter of NASF Logo

The New England Chapter once again was pleased to offer a Wastewater Continuing Education Webinar for the benefit of our membership, and open to  the entire metal finishing community. The event took place on Wednesday September 17, 2025 from 10:00am to 12:00pm. This educational webinar was offered at no charge to NENASF members as a benefit of Chapter membership.

Almost forty attendees from the metal finishing community were in attendance.

 

As was the custom, the program was comprised of three speakers offering vital technical and regulatory compliance information key to the metal finishing community. All attendees were eligible for two Wastewater Continuing Education Contact Hours awarded by the Mass DEP.

 

Brock Helton, the Preventive Maintenance Manager from Crossair, LLC gave the opening presentation. His focus was on the latest exhaust fan and fume scrubber technologies with an emphasis on proper preventive maintenance to keep these units running properly to achieve peak compliance results.

This was followed with a presentation by John Tracy, VP of Global Business Development from Aclarity, who offered a presentation on the current very fluid regulatory climate on PFAS wastewater discharge regulations. John  offered a unique remediation solution to PFAS removal in waste water through the use of electrochemical destruction.

The final speaker was Brittany McKinney from PAVCO who addressed the attendees on the benefits of various Trivalent Chrome Plating options as a replacement for traditional Hexavalent Chrome Plating processes that are currently in the cross hairs of regulatory agencies throughout the country.

 

The NENASF Chapter wants to once again thank our presenters for their time and expertise offered in an effort to enhance the knowledge and awareness of the metal finishing community. Also, many thanks to the dedicated NENASF members who work so hard to make educational events like this possible.

NENASF ANNUAL HAZMAT and WASTEWATER SEMINAR 2025

Date: May 13, 2025
Category: Chapter News, Events, Member News, NASF Chapters, Regulation

The attendance was great as over thirty-five members NASF New England Chapter, along with members of the metal finishing community as a whole, attended a Seminar sponsored by the Chapter on May 7, 2025 at the Courtyard Marriott in Marlborough, Massachusetts. The event was primarily a training session enabling attendees to receive their mandatory annual RCRA HazMat. The four-hour Seminar also included speakers on wastewater effluent management and plating rectifier selection as a means of achieving plating success with minimal environmental disruption.

The instructor for the two-hour RCRA Hazmat segment of the Seminar was David Webster, Environmental Health and Safety Project Manager for HRP Associates out of their Farmington, Connecticut office. This two-hour session was a very detailed and intense training exercise with strong emphasis on possible pitfalls of incorrect hazardous waste handling and documentation, and was concluded with a written competency test prior to awarding of Certificates of Completion by HRP Associates for the RCRA Training.

Rob Sheldon of Aquasgroup in East Providence then offered a presentation about rinse water management, and how Zero Limit Discharge (ZLD) could be viewed as the future of metal finishing. He tied that into efficient equipment design, such as doing what can be simply achieved to initially minimize rinse water contamination, and the rewards of this approach in solving potential discharge challenges.

The afternoon Seminar was concluded with a presentation by Dev Massimi of American Plating Power who gave a presentation on the review process necessary when purchasing a new plating rectifier. This segment focused on factors to consider such as technologies available, degree of protection, ripple, correct sizing and control methods, to name a few. A power source that efficiently produces quality product can mean less chance for rejects. Reject rework can add additional unnecessary strain on wastewater discharge systems.

This Seminar, which was offered at no cost to the NENASF members, along with other events and educational opportunities offered by the New England Chapter, are just another reason to join and actively participate in all that local Chapter membership in the National Association for Surface Finishing has to offer. Thanks to all participants for allowing events like this to happen.

NENASF 2025 SPRING WEBINAR

Date: March 26, 2025
Category: Chapter News, Events, NASF Chapters

New England Chapter of NASF Logo

 

In keeping with the core values of The New England Chapter of The National Association for Surface Finishing, the Chapter was, once again, pleased to host a virtual Wastewater Continuing Education Webinar for the benefit of our membership, and the entire metal finishing community. The 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 19, 2025.

This continuing education program was comprised of three speakers, and offered vital technical and regulatory compliance information to the metal finishing community. Attendees also qualified for two Continuing Education Wastewater Treatment Contact Hours as awarded by the Mass DEP, to be used towards Wastewater license renewal.

Dr. Bob Fan of Buck Scientific opened the Webinar with a presentation on the use of Atomic Absorption Spectrophotometry as, not only a wastewater discharge compliance tool, but also as an aid in process quality realization leading to less impact on a company’s wastewater treatment system.

This presentation was followed by a joint presentation by Robin Deal and Jeremy Morgan of Hubbard-Hall on Wastewater Treatment Operator responsibilities and training opportunities. This talk centered on balancing technical ability with wastewater operator licensing requirements, and interaction with plant processes and regulatory sewer authorities.

The closing speaker was Brian Morrill of GZA Geo Environmental whose presentation centered on the newly proposed modification to Commercial, Industrial and Institutional (CII) Multisector Stormwater General Permit (MSGP).

As many as 3000 properties that are currently exempt may now be included.

Quarterly PFAS stormwater testing could become a mandatory requirement.

Thank you to all of the Speaker Facilitators for their time, expertise and overall contribution to making this educational opportunity available to the metal finishing community. Special thanks, once again, to Chris Capalbo as Program Moderator and all NENASF 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 three dozen members of the NENASF and metal finishing community were in attendance and benefited from this program.

In Memoriam – George Abelli

Date: March 20, 2025
Category: Chapter News, Member News, NASF Chapters, Obituaries

George Abelli

It is with sadness that we, the staff of F.M. Callahan & Son, must report the news that our beloved co-worker, George Abelli, has suddenly passed away. George, with his broad knowledge of metal finishing, has been a core contributor to our success over the past few decades. He served our clients well, providing them valuable insight into how their parts can be treated to enhance their performance over a long period of time. George spoke often to clients on the phone and was a subject matter expert when clients visited our facility. He will be dearly missed, not just for his expertise, but also because he was our friend.

 

Your friends at F.M. Callahan & Son

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.‎

 

 

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.

Summer 2024 NASF Online Courses Free to Members!

Date: April 19, 2024
Category: Chapter News, Events, NASF Chapters, NASF National

 

NASF Logo

New Courses – Summer 2024

INTRODUCTION: PLATING 101
Recommended Time & Experience: No experience or knowledge of the surface finishing industry required.
Description: This online, self-paced course covers the base concepts of Plating and the importance of personal and environmental safety in the workplace.
Designed For: Those who want to better understand when and how surface plating is used. Ideal for those new to the industry or as part of a new employee orientation.
Content Level: Introductory (100 Series)
Approx Hours to Complete: >1 Hour
Learning Objectives: Those completing this course will be able to:
• Describe the three methods and types of metal plating.
• Outline the steps in Plating: Loading, Pre-Treatment, the Electroplating Process, and Post-Treatment.
• Recognize and understand the elements and importance of personal and environmental safety in the workplace.
Registration Fee:
Online Course Member: $0 Non-Member: $175

CHEMISTRY REFRESHER
Designed for: Individuals who scored less than 100% on the Chem Test Your Knowledge test and need a refresher and intending to take the CAF, CEF, or one of the plating specific courses listed below.
• Aluminum Finishing
• Chromium Plating
• Electroless Deposition
• Wastewater Management
• Industrial & Precious Metals
• Plating Essentials
• Zinc & Zinc Alloy
Course Description: This online, self-paced course will cover important concepts that must be mastered to be successful in the courses listed above and on any of the respective exams where a demonstration of knowledge will be required. It covers basic chemistry concepts including definitions, chemical reactions and chemical properties as they relate to the industry.
Content Level: Introductory (100 Series)
Approx Hours to Complete: 1 Hour
Learning Objectives: Those completing this course will be able to:
1. Understand the atomic structures for the most used elements in the pla􀆟ng process.
2. Properly apply the principles of Ohm’s and Faraday’s Law.
3. Recognize and iden􀆟fy various chemical reac􀆟ons including water & salt, acids & bases,
anodes & cathodes.
Registration Fee:
Online Course Member: $0 Non-Member: $175

MATH BASICS (New course. Available July 1, 2024)
Designed For: Individuals who scored less than 100% on the Math Test Your Knowledge test and need a refresher and intending to take the CAF, CEF, or one of the plating specific courses listed below.
• Chromium Plating
• Electroless Deposition
• Wastewater Management
• Industrial & Precious Metals
• Plating Essentials
• Zinc & Zinc Alloy
Course Description: This online, self-paced course provides the learner a refresher in the math basics critical to understanding and fulfilling their role in the plating process. It includes basic and intermediate mathematical functions including scientific notations, solving algebraic and proportional equations, and units of measure.
Content Level: Introductory (100 Series)
Approx Hours to Complete: 1 Hour
Learning Objectives: Those completing this course will be able to:
• Those completing this course will be able to: Recognize mathema􀆟cal symbols, conven􀆟ons, and defini􀆟ons.
• U􀆟lize scien􀆟fic nota􀆟on and units of measure to solve algebraic and propor􀆟onal equa􀆟ons.
• Properly calculate surface areas.
Registration Fee:
Online Course Member: $0 Non-Member: $175

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