GOVERNMENT RELATIONS BENEFITS FOR NASF MEMBERS

Benefits from Major Rulemakings

• Metals Products & Machinery (MP&M) Effluent Limits Rulemaking – Savings of $2Billion Annually for the Industry in Avoided Regulatory Costs (Over $300K Facility/Year).
• OSHA Workplace Exposure Standard for Hex Chrome – Savings of $1 Billion Annually for the Industry in Avoided Regulatory Costs ($330K Facility/Year)
• Plating & Polishing Area Source Rule – Savings of $50-!00K Facility/Year
• EPA’s Revised Definition of Solid Waste for F006 –Savings of $20-50K Facility/Year

Benefits for Each Member from Compliance Assistance & Information Tools

• Homeland Security Chemical Facility Security Top-Screen Guidance -- $1,500
• Plating & Polishing Initial Notification Sample Letter -- $1,500
• REACH Guidance for Job Shops -- $2,000
• REACH Guidance for Suppliers -- $2,000
• REACH Sample Customer Letter -- $1,000
• Summary of EPA’s Revised Definition of Solid Waste -- $1,500
• DOD Surface Finishng Workshops -- $1,000
• OSHA Safe Work Practices Manual -- $5,000

Additional General Benefits for the Industry

• Advocacy on Behalf of the Surface Finishing Industry
• Compliance Guidance for NASF Members
• Information on New and Emerging Legislative, Regulatory and Policy Issues Impacting the Surface Finishing Industry

HEXAVALENT CHROMIUM (Cr(VI))

On February 28, 2006, the Occupational Safety and Health Administration (OSHA) issued a standard that significantly lowered the limit on worker exposure to hexavalent chromium (Cr(VI)). The new permissible exposure limit (PEL) is 5 μg/m³ with an “Action Level” of 2.5 μg/m³.

	Regulatory Alert		OSHA:	Federal Register #71:10099-10385
				Standard §1910.1026
	Metal Finishing Cr(VI) PEL Air Monitoring Guidance by Joelie Zak, CEF-4, Scientific Control Laboratories, Inc.

As a result of the lower PEL, the finishing industry will face substantial new compliance costs and job loss. The industry has already filed a petition for judicial review of the new PEL challenging OSHA’s justification of the standard on technological and economic feasibility grounds. The goal of the litigation is to pursue a more favorable PEL or Action Level on technological and economic feasibility grounds, to secure more reasonable and appropriate implementation of the rule’s regulatory requirements of the rule, and to prevent the group Public Citizen from forcing OSHA to lower the PEL from 5 μg/m³ to 0.25 μg/m³. The industry needs your help to support the critical legal challenge ahead.

Chrome Defense Pledge Form