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Compliance Assistance

Air | Solid/Hazardous Waste | Water/Wastewater
Health & Safety | Chemicals/Toxics | Other

 

Air

General compliance assistance tools for air emissions

Chromium Emissions

Solvent Emissions

Other Metal Finishing Related NESHAPs

Solid/Hazardous Waste

General

Hazardous Waste Manifest System

  • Hazardous Waste Manifest System. EPA's hazardous waste manifest system is designed to track hazardous waste from the time it leaves the generator facility where it was produced, until it reaches the off-site waste management facility that will store, treat, or dispose of the hazardous waste.

  • e-Manifest Compliance Assistance Tools. EPA established a national system for tracking hazardous waste shipments electronically. This system, known as "e-Manifest," will modernize the nation's cradle-to-grave hazardous waste tracking process while saving valuable time, resources, and dollars for industry and states. EPA launched e-Manifest on June 30, 2018. Under the e-Manifest Act and EPA's implementing regulations, manifest users may continue to use paper manifests, however, EPA strongly encourages the use of electronic manifests as these manifests will be the least expensive and easiest way to comply with the regulations. EPA has developed various resources to assist waste generators. These include the following:

Other Hazardous Waste Resources

Water/Wastewater

Wastewater

  • PFAS Resources. EPA anticipates publishing a proposed PFAS wastewater discharge regulation in December 2024 that will target chrome plating facilities. This resource will be maintained to help keep metal finishers updated on the anticipated new regulation.
  • STERC Plain Language Guides to Regulations – The STERC plain language guide to wastewater discharge compliance.

  • National Pretreatment Program. The national pretreatment program is designed to protect POTWs infrastructure and reduce conventional and toxic pollutant levels discharged by industries and other nondomestic wastewater sources into municipal sewer systems and into the environment. 

  • Electroplating Effluent Guidelines. EPA promulgated the Electroplating regulation (40 CFR Part 413) in 1974 and amended it in 1983. The regulation applies to certain facilities that discharge their wastes to POTWs. The requirements are incorporated into permits or other control mechanisms for indirect dischargers.

  • Metal Finishing Effluent Guidelines. EPA promulgated the Metal Finishing Effluent Guidelines (40 CFR Part 433) in 1983, with technical amendments in 1986. The regulations cover wastewater discharges from a wide variety of industries performing various metal finishing operations.

  • NPDES Compliance Inspection Manual (2017) (EPA 305-K-17-001). This Inspection Manual is an inspection support tool provided by the U.S. Environmental Protection Agency (EPA) for use by field personnel conducting inspections under the Clean Water Act (CWA) National Pollutant Discharge Elimination System (NPDES) programs. It is also of value to shop management.

  • Preliminary Review of the Metal Finishing Category (EPA 821-R-18-003). The Clean Water Act (CWA) requires Environmental Protection Agency (EPA) to review existing effluent guidelines annually. This study extends EPA's efforts beyond the annual review to better understand changes in metal finishing operations, wastewater characteristics, and wastewater treatment technologies since EPA promulgated the 1983 ELGs.

Stormwater

Other Water Issues

  • PFAS/PFOS. Per- and polyfluoroalkyl substances (PFAS) are a group of man-made chemicals that includes PFOA and PFOS, the latter of which was previously used in chrome plating fume suppressants. These chemicals are persistent in the environment and in the human body and they can accumulate over time. There is evidence that exposure to PFAS can lead to adverse human health effects. The following are available PFAS resources:

    • PFAS. EPA provides background information, tools and resources, and action plans including research and steps to reduce PFAS risk.

    • PFAS Strategic Roadmap: EPA's Commitments to Action 2021-2024. This EPA roadmap sets timelines by which EPA plans to take specific actions and commits to new policies to safeguard public health, protect the environment, and hold polluters accountable.

    • PFAS Resource Center. Although PFOS use in the surface finishing industry represented less than one half of one percent of U.S. and global PFOS use, the National Association for Surface Finishing (NASF) has taken a very active role in addressing the PFAS issues and has launched this site that includes background information on the use of PFAS in the surface finishing industry and extensive technical resources.
    • Spill Prevention, Control, and Countermeasure (SPCC) - Metal Finishing facilities are subject to the SPCC rule if they have aboveground oil storage capacity greater than 1,320 U.S. gallons, or completely buried oil storage capacity greater than 42,000 U.S. gallons.

Health and Safety

  • OSHA Hexavalent Chromium PEL. On February 28, 2006, OSHA published a final rule for a hexavalent chromium permissible exposure limit (PEL) that applies to the metal finishing industry and other sectors.

  • Periodic medical exams for electroplating workers exposed to chromic acid (2015 OSHA published interpretation). OSHA interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations.

  • OSHA has issued an Instruction to provide guidelines and establish uniform inspection and compliance procedures for the Chromium PEL. This new directive sets forth OSHA's policy and guidance for enforcing the hexavalent chromium workplace exposure standard. It can be used as a compliance guide for metal finishers.

  • NIOSH Chromium Assessment. On January 24, 2013, the National Institute for Occupational Safety and Health (NIOSH) posted a document entitled Criteria for a Recommended Standard: Occupational Exposure to Hexavalent Chromium in which NIOSH reviews the critical health effects studies of hexavalent chromium compounds to update its assessment of the potential health effects of occupational exposure to hexavalent chromium compounds and its recommendations to prevent and control these workplace exposures. The document provides a new Recommended Exposure Limit (REL) of 0.20 ug/m3 for workplaces. 

Chemicals/Toxics

  • TRI Reporting. An explanation of the TRI responsibilities for the metal finisher.

  • Toxic Chemical Release Inventory Reporting Forms and Instructions Revised 2021 Version (EPA-740-B-22-002). Please note that this Reporting Year 2021 version of the Toxic Chemical Release Inventory (TRI) Reporting Forms and Instructions document supersedes previous versions. Check EPA.gov for the most recent version.

  • Lead and TRI Reporting. A guidance document for determining the applicability of TRI reporting and links to reporting resources.

  • TRI Form R Reporting Threshold Determinations for Manufactured Metal Compounds in Plating Baths. EPA has recently acted to enforce the reporting obligation contained in Section 313 of the Emergency Planning and Community Right-to-Know Act of 1986 (EPCRA) that applies to surface finishing processes. The rules require facilities that manufacture, process, or otherwise uses a toxic chemical in an amount exceeding an applicable threshold quantity of that chemical during a calendar year to report releases of listed hazardous substances.

  • TRI Reporting hotlines and TRI Coordinators can help answer regulatory and reporting questions.
  • PFAS (Per- and Polyfluoroalkyl Substances). EPA is planning PFAS effluent guidelines (wastewater discharge regulations) for the metal finishing industry. Proposed rules are expected in 2024. Also, see NASF PFAS Resources for current information.
  • On October 20, 2023 EPA finalized a rule that improves reporting on per- and polyfluoroalkyl substances (PFAS) to the Toxics Release Inventory (TRI) by eliminating an exemption that allowed facilities to avoid reporting information on PFAS when those chemicals were used in small concentrations. More information.

Pollution Prevention/Other Topics

 

 

 

 


The information contained in this site is provided for your review and convenience. It is not intended to provide legal advice with respect to any federal, state, or local regulation.
You should consult with legal counsel and appropriate authorities before interpreting any regulations or undertaking any specific course of action.

Please note that many of the regulatory discussions on STERC refer to federal regulations. In many cases, states or local governments have promulgated relevant rules and standards
that are different and/or more stringent than the federal regulations. Therefore, to assure full compliance, you should investigate and comply with all applicable federal, state and local regulations.