NASF Report- February

EPA Releases More Stringent Definition of Solid Waste Regulation

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EPA Releases More Stringent Definition of Solid Waste Regulation

In December, the administrator of the U.S. Environmental Protection Agency (EPA) signed the final revisions to the Definition of Solid Waste rule. The primary purpose of the revisions was to close perceived regulatory gaps in the 2008 Definition of Solid Waste rule that allowed the recycling of hazardous secondary materials without sufficient regulatory controls. The new revisions state that the recycling of secondary materials can occur only if specific regulatory requirements are met. The rule was published January 13 in the Federal Register.

The biggest change in the 2014 revisions is the withdrawal of the “transfer-based” exclusion, replacing it with a “verified recycler” exclusion. Now, off-site, third-party facilities that receive secondary materials for recycling must have an RCRA permit. In addition, both generators must: 1) notify EPA or authorized state officials, 2) ensure that materials are contained, 3) maintain records of shipments of materials off site and 4) meet emergency response and preparedness requirements. 

Recyclers may also apply for a variance from the permit, provided that they are able to demonstrate certain requirements.

The new rule retains some of the existing exclusions for scrap metal recycling, in-process recycling, commodity-grade recycled products and the materials that remain under the generator’s control, such as on-site recycling, recycling within the same company and toll manufacturing agreements. In addition, the final rule includes a targeted manufacturing exclusion that allows certain spent solvents to be remanufactured into commercial-grade products.

In sum, while the new revisions provide additional safeguards for the recycling of secondary materials, it will be more difficult and more expensive to recycle many secondary materials. 


NASF Joins Over 100 Industry Associations to Support Federal TSCA Reform

The National Association for Surface Finishing (NASF) was one of over 120 trade associations that signed onto a letter sent to Congress under the umbrella of the American Alliance for Innovation (AAI) in support of meaningful changes to the Toxic Substances Control Act (TSCA). The law, first enacted in 1976, is the current U.S. federal legal framework governing the introduction and use of chemicals in commerce. According to the NASF, the effort is intended to overhaul and modernize the federal chemical law.
The AAI is a coalition that includes a range of chemical manufacturers, processors and distributors, as well as downstream users in the value chain. Recently, individual states such as California, Maine, Washington and others have adopted their own chemicals management regimes. Faced with a patchwork of laws with conflicting requirements along with growing pressures to voluntarily deselect materials affecting the value chain, NASF members and companies across the U.S. manufacturing sector want to regain federal uniformity and re-instill consumer confidence in product safety.
Two reasons for reform efforts include polls demonstrating declining U.S. public confidence in the chemicals sector and the assertive requirements of the European Union’s REACH framework, having jumped ahead of U.S. chemicals rules in shaping global and domestic corporate decisions on materials choices, according to the NASF.
The NASF will be coordinating with the AAI through 2015 and will brief attendees of the Washington Forum April 14-16 on the status and prospects for reform. 


Registration Now Open for Major NASF Events  
The NASF is gearing up for two of the year’s most significant events: the Washington Forum and the SUR/FIN 2015 Trade Show and Conference. Each provides education and networking to provide industry professionals opportunities to advance their businesses and careers as well as surface technology as a whole. 

Washington Forum
The 2015 NASF Washington Forum provides the opportunity to gain insights into the regulatory, legislative and legal challenges facing the finishing industry and manufacturing in general. The event will offer the chance to shape outcomes on the issues with the option of taking the industry’s message directly to regulators and lawmakers in Washington. This year’s Forum will include a special keynote session featuring Amy Walter, national editor of The Cook Political Report.  Registration opens in mid-February. Visit for details.

Sur/Fin 2015 Trade Show and Conference 
This year, NASF’s SUR/FIN event will explore “The Future of Surface Technology,” highlighting emerging technologies, processes and product and service developments that are moving the industry forward. Attendees will join industry professionals as well as top engineers, academics and business leaders for three days of networking, over 70 in-depth conference sessions and direct access to over 150 suppliers. This year’s keynote presentation will be delivered by Alan McGee, supply base manager at John Deere.
Exhibitor and training registration is now open at Attendee registration opens in late February.


NASF Announces 2015 Board of Directors
NASF is pleased to announce the association’s 2015 Board of Directors. This group intends to lead the way as NASF continues to find new ways to serve its members within the North American and global surface technology community while promoting the future of surface technology.
•    Paul Brancato | Epner Technology | New York
•    Phil Brockman | Techmetals | Ohio
•    Steve Brown | BroCo Products Inc. | Ohio
•    LaVaughn Daniel | Danco Metal Surfacing | California
•    Rick Delawder | SWD Inc.| Illinois
•    Steve Gaydos | Boeing | Missouri
•    Curtis Goad | GOAD Company | Missouri
•    Kyle Hankinson | KCH Services | North Carolina
•    Brian Harrick | KC Jones Plating | Michigan
•    Bernie Haviland | Haviland Products | Michigan
•    Bill Krenz | Atotech | Michigan
•    Brad Majoy | Pavco | North Carolina
•    Mitch Marsh | Marsh Plating | Michigan
•    Jim Miille | Chemical Solutions | California
•    Tony Revier | Uyemura | California
•    Jody Richards | Process Technology | Ohio
•    Milt Stevenson Jr. | Anoplate Corp. | New York
•    Erik Weyls | Coventya | Ohio


Upcoming NASF Events
Visit for event details and registration.
Web-based Environmental Stewardship Pollution Prevention
12-2 p.m. EST 
Feb. 3, 4, 10, 11, 17, 18
This training program is designed to be beneficial for operators and supervisors of job shops and captive shops performing metal finishing operations such as electroplating and/or anodizing. The course can also benefit sales personnel at pollution abatement suppliers. Visit for details.

2015 Management Conference
February 15-19
The 2015 Management Conference is taking place at the beautiful LaQuinta Resort and Club in Palm Springs, California.  From updates and workshops on timely, practical business and management issues to presentations on the major policy developments affecting the industry, the event offers a full agenda. Renowned business consultant Daniel Feiman will head two executive workshops with attendees on improving management, making better business decisions and sustaining future growth in organizations of all sizes. For complete details and registration, visit 

Washington Forum
April 14-16
We’ll welcome top commentator Amy Walter to the annual Washington Forum. An experienced political analyst, Walter has gained unparalleled access to campaign insiders and decision-makers as one of the best political journalists covering Washington. She is the national editor of The Cook Political Report and the former political director of ABC News. Walter will discuss the electoral process, congressional culture and the Washington political scene to take attendees on an insider's tour of Washington. Register at

NASF Sur/Fin 
June 8-10
NASF’s largest event of the year, the Sur/Fin Manufacturing and Technology Trade Show & Conference, will host John Deere’s Alan McGee.  As Supply Base Manager for Fasteners, he’ll provide insight and perspective on surface finishing at Deere, and highlight progress as well as current and future challenges for global customers of surface technology. Registration is available at