NASF Report- March 2015

Maine to Remove Nickel Metal from List of 49 “Worst Chemicals;" NASF Submits Comments on EPA’s Proposed SNUR for Chemical Substances Used as Cleaners and Brighteners; NASF Announces 2015 Executive Officers and more.

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Breaking News: Maine to Remove Nickel Metal from List of 49 “Worst Chemicals"
In a major new development, the state of Maine has decided to remove elemental nickel from the state’s “worst chemicals” list.

Maine’s decision caps off a series of discussions and petitions over two years, led by NASF’s strategic partner the Nickel Institute, in which industry argued that the state had erred in listing the category “nickel and nickel compounds” as one of 49 “worst of the worst” chemicals for children. Maine’s “Chemicals of High Concern” list is one element of the state’s safer chemicals policy, which empowers state officials to identify top chemicals of concern, require manufacturers to disclose and eliminate materials in products, and promote green chemistry.

The industry petitioned Maine last year, arguing among other concerns that the state had incorrectly categorized “nickel and nickel compounds” under the single CAS number for metallic nickel (CAS number 7440-02-0). The listing both needlessly conflated a range of chemicals under a single listing and inappropriately ranked all compounds as posing the highest threat level to human health.

Maine’s response in late January confirmed that upon closer review, metallic nickel does not meet the state’s own restrictive toxicity criteria to warrant its listing as a Chemical of High Concern, and therefore metallic nickel will be removed from the list. However, the state determined that nickel compounds as a category would remain listed.

Nickel Institute and the NASF are reviewing the decision and its impacts, and whether the state will go further in addressing nickel in products in the future. The groups are also monitoring other states that, like Maine, have been enacting laws that prioritize new and existing chemicals for use restrictions or bans.


 

NASF Submits Comments on EPA’s Proposed SNUR for Chemical Substances Used as Cleaners and Brighteners
In October of 2014, the EPA proposed a significant new use rule (SNUR) for 15 nonylphenol (NP) and nonylphenol ethoxylate (NPE) substances. EPA was not aware any of these substances were used and proposed that any use would be a significant new use and subject to the pre-manufacture notice requirements under the Toxic Substances Control Act (TSCA).

NPs are used as intermediates to produce NPEs, which are used in a variety of applications, including some surface finishing applications. This January, NASF submitted comments to EPA on the proposed SNUR and identified several of the NP and NPE substances that are currently used in a variety of surface finishing applications, including as building blocks or critical ingredients in cleaners, acid additives, coatings, rinse aids, surfactants, corrosion inhibitors, sealers, paint strippers, chromates, and organic brightener systems for zinc, tin and copper plating. More specifically, these chemical compounds are used in electroless nickel plating systems to reduce the surface tension of the plating bath, reduce pitting or imperfections in the surface of the plated part, and minimize nickel mist from the tank; acid tin plating systems as a wetting agent, deposit brightener, and grain refiner; and alkaline soak cleaner and electro-cleaner formulations to remove soils from ferrous and non-ferrous substrates.

EPA indicated that the proposed SNUR requirements would not apply to those uses that were ongoing as of October 1, 2014. Accordingly, these uses should not be considered significant new uses and should not be subject to the pre-manufacture notification requirements. If you have any questions or would like additional information regarding this rulemaking, contact Jeff Hannapel at jhannapel@thepolicygroup.com.


 

NASF and Industry Partners Urge Congress to Support Regulatory Reform Legislation
NASF, the National Association of Manufacturers (NAM) and other industry partners are urging Congress to pass The Small Business Regulatory Flexibility Improvements Act of 2015. This legislation, currently being considered by the House, would reform the regulatory process to ensure that all federal agencies appropriately consider the impact of their rules on small businesses across America.

In a letter sent to Congress, a large coalition of industry partners argue that the original Regulatory Flexibility Act (RFA), which requires federal agencies to transparently account for the impact of regulation on small businesses, has been arbitrarily applied across federal agencies and those that do apply it have widely divergent interpretations of its requirements.

Even with its limited adherence by federal agencies, NASF and its industry partners note that “in fiscal year 2014, the U.S. Small Business Administration’s Office of Advocacy reported compliance cost savings of $4.8 billion for small businesses” and that over the past 10 years that savings has been greater than $90 billion. Industry maintains that improvements to the RFA would create even higher savings by requiring the Office of Advocacy to establish standards for conducting regulatory flexibility analysis during the rulemaking process and requiring agencies to consider the true impact of their rules on the entire regulated community.

Duplicative and inefficient regulatory burdens significantly and disproportionately impact small businesses and manufacturers. Please contact your legislators today and ask them to support H.R. 527 to ensure that agencies are required to consider less costly alternatives to burdensome and unnecessary regulations.


 

EPA Proposes Significant New Use Restrictions for Perflourinated Chemical Compounds
EPA has just proposed a significant new use rule (SNUR) under the federal Toxic Substances Control Act (TSCA) for certain perfluorinated compounds or PFCs – specifically long-chain perfluoroalkyl carboxylate (LCPFAC) chemical substances. Under a new regulation, the agency would impose new use (including manufacturing, importing and processing) notification requirements for more than 25 LCPFAC chemical substances for any use that will not be ongoing after December 31, 2015. EPA has requested comments by March 23, 2015.

This action is consistent with EPA’s  2009 “Long-Chain Perfluorinated Chemicals Action Plan” and 2006 PFOA Stewardship Program, a voluntary partnership between EPA and eight global manufacturers of these chemicals: DuPont, Solvay Solexis, Asahi Glass Co., Daikin America Inc., Clariant International Ltd., 3M/Dyneon, Arkema Inc., and BASF. These companies all agreed to phase out the use of these chemicals by December 31, 2015. Any subsequent manufacture, import, or processing of these chemicals after that date would be subject to the proposed new use notification requirements under TSCA.

These proposed measures are intended to phase out the use of LCPFAC chemical substances in the U.S. and to keep them from re-entering the U.S. marketplace without substantial safeguards in place. The proposed action is also consistent with EPA’s ban on the use of perfluorooctane sulfonate (PFOS) based fume suppressants by September 2015 as part of the chromium electroplating NESHAP rule.

EPA has requested comments on: 1) whether any of the current uses of the LCPFAC chemical substances in current use will be ongoing after December 31, 2015; 2) whether there are any ongoing uses of those LCPFAC chemical substances that are currently deemed to have no ongoing use; and 3) whether there are any ongoing uses, including use as part of articles, of any of the LCPFAC chemical substances. Comments must be submitted to EPA by March 23, 2015. For a list of these chemicals, and or to provide comments or information on the use of these chemicals, please contact Jeff Hannapel at jhannapel@thepolicygroup.com.


 

NASF Announces 2015 Executive Officers
With new Board members in office, NASF elected the association’s 2015 Executive Committee during its January Board meeting. Presiding over his last meeting as President, Rick Delawder handed over the President’s gavel to newly inducted NASF President, Erik Weyls of Ohio-based Coventya Inc.

NASF Executive Committee
President: Erik Weyls | Coventya, Inc. | Ohio

Vice President: Paul Brancato | Epner Technology | New York

Secretary/Treasurer: Brian Harrick | KC Jones Plating | Michigan

Member at Large: Benie Haviland | Haviland Products | Michigan

Immediate Past President: Rick Delawder | SWD, Inc. | Illinois


 

NASF Chicago Midwest Chapter Holds First Meeting, Elects Board
The Chicago Midwest Chapter of NASF celebrated its inaugural meeting, marking the first time the Chicago Metal Finishers Institute (CMFI) and the Chicago Chapter of AESF met formally as a united group. Joining the celebration, attendees also included NASF President Rick Delawder; NASF Past President Tony Revier; and NASF Executive Vice President Christian Richter.

In a brief address to the group, Richter highlighted the chapter’s “incredible legacy, commitment to change, and a promising future” by relating their challenge to that which NASF faced when the association consolidated nearly a decade ago, remarking, “When we joined together the AESF Educational Fund had dropped to its lowest point of only $700,000, but over several years of hard work and restructuring, together we built the fund to almost $1.6 million today.” He noted the commitments from Chicago industry leaders in recent years to work with their colleagues to pursue “strong events, strong industry education and knowledge-building, and strong advocacy.”

Adding to the celebratory atmosphere and new networking opportunities, the new chapter also took the opportunity to thank outgoing CMFI President Kevin Pludeman for his service and to elect its first Board of Directors as a united group.

To close out the evening, attendees were treated to a presentation by NASF Technical Director Frank Altmayer on “An Incomplete History of Surface Finishing.” The presentation covered advancements from 6000 B.C. through modern times, with a focus on the rich history of surface finishing in Chicago, on which the The Chicago Midwest Chapter of NASF will certainly build in the years to come.


 

NASF TECHNICAL PAPER

edited by Jim Lindsay, NASF Technical Editor. 

Manufacturing of Electrocatalytic Material for Large Scale Hydrogen Production by the Combination of Electroplating, PVD, Thermochemical Diffusion and Leaching Processes

Cecilía Kjartansdottír,a Michael Caspersen,b Sune Egelund,b Lars Pleth Nielsen and Per Møllera

aTechnical University of Denmark, Lyngby, Denmark; bSiemens A/S Denmark; cDanish Technological Institute, Aarhus, Denmark

This paper is a fine example of the multitude of ways that surface finishing can be brought to bear in process development. In this case, a combination of processes is applied to large scale hydrogen production. Novel high performing electrodes for industrial alkaline water electrolysis have been manufactured by the physical vapor deposition of aluminum onto a nickel-plated substrate. Nanoporous high surface area nickel is obtained by thermochemical diffusion followed by selective leaching of aluminum. The developed porous nickel surface is uniform and has good interlayer adhesion due to its chemical bonding properties. Electrochemical measurements reveal that 400 mV less potential is needed to decompose water into hydrogen and oxygen with the developed electrodes as compared to a solid nickel electrode. High resolution scanning electron microscope (HR‐SEM) photographs reveal nickel-electrode surfaces characterized by a large surface area with pores down to a few nanometers in size. Durability testing (>9,000 hr) was carried out in a commercially produced electrolyzer stack, revealing no serious deactivation or decomposition during the test period. The full report can be accessed and printed here