"I WASHINGTON w i r e

NEW DHS CHEMICAL FACILITY SECURITY REQUIREMENTS STAND TO IMPACT FINISHERS, CHEMICAL SUPPLIERS The Department of Homeland Security has issued regulations to establish chemical facility security standards. As a result, finishers and chemical suppliers are advised to review the requirements of this rule to determine if they need to submit an initial "Top-Screen" assessment of the potential risks regarding the chemi- cals that are manufactured, used, stored, or distributed at their facilities.

Facilities must submit Top-Screens by the end of August 2007 or face potential civil penalties or orders to cease operations.

EPA SET TO ISSUE PROPOSED AIR EMISSIONS RULE FOR PLATING AND POLISHING OPERATIONS The EPA is considering several con- trol options for the proposed rule for plating and polishing operations (EPA is required under The Clean Air Act to promulgate new air emis- sion regulations for plating and pol- ishing operations).

The industry is completing its ini- tial phase of discussion with Federal EPA air officials by providing the Agency with relevant technical infor- mation, real-world experience at the plant, and potential impacts of the control options under consideration for the surface finishing industry. EPA expects to issue the proposed rule by October 2007 and publish a final rule by June 2008.

NASF, ON BEHALF OF INDUSTRY, OFFERS COMMENTS ON EPA'S NEW DEFINITION OF SOLID WASTE The National Association for Surface Finishing (NASF) recently submitted comments to the EPA regarding the agency's proposed rule concerning the new definition of solid waste. The

aim, according to NASF, is to convince the oversight agency to enact regulatory changes that would encourage recycling of "hazardous" wastes while lowering materials han- dling costs for finishers.

This past March the EPA issued a supplemen- tal proposal to revise the definition of solid waste to encourage the recy- cling of more hazardous secondary materials. The proposed new definition of solid waste would exclude wastes that are recycled from regulation as a hazardous waste and could facilitate more recy- cling of electroplating waste water treatment sludge, i.e., the listed haz- ardous waste, F006.

PLANNING UNDER WAY FOR MORE DOD METAL FINISHING WORK- SHOPS After another successful workshop developed in collaboration between DOD and the surface finishing indus- try, plans are under way to organize future workshops and conferences on surface finishing applications for the military depot infrastructure and the defense supply chain for finishing. Approximately 100 representatives from the surface finishing industry and the Department of Defense (DOD) participated in the third DOD Metal Finishing Workshop held in Utah this past June. The workshop focused on specific needs, solutions, and performance data for replacing hexavalent chromium finishes for military applications. NEW LEGISLATION TO HELP SMALL BUSINESS COMPLY WITH FEDERAL REGULATIONS President Bush recently signed legis-

lation that requires federal agencies to publish a small business compli- ance guide for each new regulation that has a significant economic impact on a substantial number of small entities.

The legislation strengthens the existing provisions of the Small Business Enforcement Fairness Act (SBEFA) and requires federal agen- cies to submit annual reports to Congress on their efforts to provide useful guidance on compliance with federal regulations that impact small business.

For more information on these announcements, please visit the official web- site of the National Association for Surface Finisbing (NASF), www.nasf.or~ or con- tact headquarters at (202) 4S7-8404. You can also contact the NASF policy arm, The Policy Group, at (202) 4S7-0630.

LANDMARK MASSACHUSETTS BILLS TARGET HEX CHROME, LEAD, OTHER MATERIALS According to InsideEPA.com, legisla-

July/August 20071 meta|finishing 1 16 www.meta[finishing.com

tors in the Massachusetts House and Senate are considering identical bills that would force industry to substi- tute 10 substances in manufacturing, including hexavalent chromium and lead-which are used in the Defense industry-with safer alternatives, where alternatives exist. The legisla-

tion, if passed, would pioneer the concept of substitution in the United States, setting a precedent for other states to follow, backers of the bill say.

The bills' sponsors, Rep. Jay Kaufman (D) and Sen. Steven Tolman (D), maintain that the sub- stitution plan would be a business- friendly measure, making Massa- chusetts industry more competitive in the long term by removing barriers

to trade, notably with Europe. They also point to a growing body of evi- dence citing the dangers to human health and the environment of the chemicals to be substituted.

The act aims for a new approach to addressing hazardous substances, attempting to deal with many prob- lem materials at once, while stopping short of an outright ban. While hex chrome and lead are at the top of the list-and most relevant for metal fin- ishers-there are other substances that would be restricted by the Massachusetts law. They are as fol- lows: formaldehyde, trichloroethylene, perchloroethylene, dioxins and furans, organophsphate pesticides, poly- brominated diphenyl ethers, di-(2-eth- ylhexyl)phthalate (DEHP), and 2,4, dichlorophenoxy-acetic acid (2,4,D).

While the state legislature has twice before rejected similar legisla- tion, its supporters believe they now have the political momentum to push the measures through. Nonetheless, a key industry associa- tion in the state is opposing the leg- islation, saying it would put Massachusetts companies at a com- petitive disadvantage with compa- nies outside the state.

For more on this story, please visit metal finishing, com.

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