NASF Report: West Coast Competition Highlights 16 Design Students

Sixteen students compete for scholarship awards through NASF's Bright Design Challenge West Coast.

The NASF believes that the future of surface finishing depends on the innovative ideas of our youth.  

This fall, NASF celebrates the seventh annual Bright Design Challenge West Coast as part of the Association's Surface Technology Initiative, featuring 16 students from the Art College of Design in Pasadena, California. Students will learn the essentials of metal plating, enjoy tours of both General Plating and K & L Anodizing, and receive additional training through curriculum presented by the College. Students will then develop projects representing decorative finishes.  

The program begins December 14th with student presentations, judging, and scholarship awards granted by NASF.  

 


 

EPA Proposing Restrictions on the Use of TCE

The EPA plans to propose a Toxic Substances Control Act (TSCA) Section 6 rule to restrict certain industrial uses of trichloroethylene (TCE), including its use as a commercial vapor degreasing solvent. EPA is using risk numbers more stringent than those used by OSHA when setting TCE workplace exposure levels.  

EPA is using TSCA to ban or restrict industrial uses of TCE that could be allowable under OSHA’s regulations. The proposed action marks the first time since 1991 that the EPA has initiated a rulemaking under Section 6 of TSCA.  

Under both the original and recently amended TSCA, Section 6 authorizes the agency to require labeling, specify use conditions or even ban a chemical in commerce that poses an unreasonable risk to human health or the environment. Pursuant to the new TSCA reform legislation, the Frank R. Lautenberg Chemical Safety for the 21st Century Act (Pub. L. No. 114-182), must consider information on the likely duration, intensity, frequency and ways that populations could be exposed to a chemical. The agency did not, however, have to make all of these analyses for the TCE proposed rule. Section 26 of the Lautenberg Act says the EPA could pursue TCE and certain other rulemakings for chemicals found posing unreasonable risks prior to the TSCA reform legislation’s passage, even though the agency's risk assessments were more narrow in scope than those conducted under the Lautenberg Act.

The proposed rule is currently being reviewed by the White House Office of Management and Budget (OMB). EPA has indicated that it intends to propose the rule by the end of December. For more information, please contact Jeff Hannapel with NASF at jhannapel@thepolicygroup.com.  

 

 


 

NASF Works with EPA and States on Plating and Polishing Area Source Rule Compliance Efforts

Based on recent enforcement actions, EPA Region V Office of Enforcement has identified multiple problems with compliance regarding the plating and polishing NESHAP rule for area sources (40 CFR Part 63,subpart WWWWWW). Before doing further inspections and initiating any additional enforcement, EPA asked the state Small Business Environmental Assistance Programs (SBEAPs) in Region 5 (IL, IN, MI, MN, OH, WI) if they can work with the industry to facilitate compliance.

The SBEAPs offers free and confidential compliance assistance to small businesses in the region. Although most SBEAPs are located in a regulatory agency, they are entirely separate from the sections that enforce the rules.

 Some of the compliance issues include:

  • Electroplating – record keeping violations, failure to use wetting agents or fume suppressants, failure to use a control device (mesh pad, packed bed scrubber or mesh pad mist eliminator) failure to cover tanks, failure to monitor pH;
  •  Electroless nickel plating and manganese phosphate coating – record keeping violations, failure to perform work management practices; and
  • Thermal spraying – record keeping violations, failure to perform work management practices. 

 

The SBEAP representatives invited NASF to brainstorm the best approach to facilitate further compliance with the plating and polishing area source rule. During the September 28, 2016 call, the NASF representatives indicated the industry’s willingness to assist in the guidance to ensure continued compliance with the requirements of the plating and polishing rule.  
For more information regarding the plating polishing area source rule and the industry’s efforts to promote compliance with EPA and the states, please contact Jeff Hannapel with NASF at jhannapel@thepolicygroup.com.  

 

 


Originally published in the November 2016 issue.