PFAS Resources

There are thousands of per- and polyfluoroalkyl substances known as PFAS found in different consumer, commercial, and industrial products. Within the metal finishing industry, PFAS has been used in a range of products (wetting agents, dispersion products, coating additives, and corrosion inhibitors), but most notably in fume suppressants used to reduce air emissions from chromium plating. 

Over the past 15 years, considerable scientific and regulatory activity has been focused on chromium electroplating as a source of PFAS to the environment. In 2015, the use of PFAS containing fume suppressants was banned via a revision to Chromium Electroplating National Emission Standards for Hazardous Air Pollutants (NESHAP). Despite the ban, in 2018, testing in Michigan and Minnesota continued to find high levels (measured in parts per trillion) of PFAS in samples from metal plating shop effluent. 

Based on additional studies and testing, EPA has established a roadmap to reduce the human health and ecological risks of PFAS. As part of this effort, EPA anticipates publishing a proposed wastewater discharge regulation in December 2024 that will target chrome plating facilities. A mandatory EPA questionnaire was sent to nearly 2,000 chromium plating facilities in 2023 to collect additional information for the rulemaking.

Below are annotated links to EPA, state and industry resources pertaining to PFAS. This resource will be maintained to help keep metal finishers updated on the anticipated new regulations.

US EPA

EPA Strategic Roadmap (2021-2024). (October 2021). The 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. In October 2022, EPA published a progress report.

EPA Office of Water. Under the PFAS Action Plan, EPA plans to restrict PFAS discharges from industrial sources through their Effluent Limitations Guidelines Program to establish national technology-based regulatory limits for nine industrial categories, including metal finishing.

Metal Finishing Effluent Guideline. EPA determined facilities performing certain chromium operations (referred to as "chrome finishing facilities") including chromium plating, chromium anodizing, chromic acid etching, and chromate conversion coating operations, are the predominant sources of PFAS discharges by the Metal Finishing and Electroplating point source categories. A mandatory EPA questionnaire was sent to nearly 2,000 chrome finishing facilities in 2023 to collect additional information for their rulemaking. A proposed regulation limiting PFAS discharges is expected to be published by December 2024.

EPA Ban on PFOS Fume Suppressants. (2012). Under an amendment to the National Emission Standards for Hazardous Air Pollutants – Hard and Decorative Chromium Electroplating and Chromium Anodizing Tanks (40 CFR Part 63, Subpart N) EPA banned PFOS fume suppressants as of September 2015. PFOS is one of many identified PFAS chemicals.

Multi-Industry Per- and Polyfluoroalkyl Substances (PFAS) Study – 2021 Preliminary Report. (USEPA, September 2021). This preliminary report summarizes the available information and data that EPA's Office of Water collected and reviewed concerning industrial discharges of per- and polyfluoroalkyl substances (PFAS) from five industrial point source categories, including the metal finishing industry. . The report presents EPA's estimates of the types and concentrations of PFAS, including legacy long-chain PFAS and replacement short-chain PFAS, present in wastewater discharges from these facilities. EPA identified available wastewater treatment technologies, such as activated carbon, ion exchange, and membrane filtration, that may reduce PFAS in wastewater discharges from facilities in these industrial categories.

Drinking Water Proposed Regulation. (March 2023). EPA proposed a National Primary Drinking Water Regulation (NPDWR) to establish legally enforceable levels, called Maximum Contaminant Levels (MCLs), for six PFAS in drinking water. The proposed rule would also require public water systems to: 1. Monitor for these PFAS; 2. Notify the public of the levels of these PFAS; and 3. Reduce the levels of these PFAS in drinking water if they exceed the proposed standards.

State Information

PFAS in the Metal Plating and Finishing Industry. (Minnesota Pollution Control Agency, December 2022). An inventory of information about PFAS use, environmental release pathways, and source reduction strategies. 

Targeted and Nontargeted Analysis of PFAS in Fume Suppressant Products at Chrome Plating Facilities. (Michigan Department of Environment, Great Lakes and Energy, June 2020). EGLE and the US EPA conducted the study to assist in compliance efforts undertaken by the chrome plating industry in Michigan, where many platers have had to invest significant resources to install pretreatment systems to remove PFOS from their process wastewater.

Wisconsin Department of Natural Resources PFAS Technical Group. (August, 2022). PowerPoint file covering state and federal rules and standards.

Fume Suppressant Information. (California Air Resources Board). Includes list of approved fume suppressants.

Industry Information

NASF PFAS Resources. The National Association for Surface Finishing (NASF) represents the interests of businesses and professionals in the surface coatings industry. NASF maintains various resources related to PFAS. In March 2019, NASF published PFAS Background Information.

PFAS in the Metal Finishing Industry. (HPR Associates, undated). A fact sheet covering the PFAS studies and EPA rules.

PFAS in Surface Finishing: Where is it Going? (Products Finishing, Oct. 2022). A forward look at how PFAS regulations may affect the metal finishing industry.

PFAS is Coming: The Time to Prepare is Now. (Finishing and Coating, August 2022). A summary of EPA studies and actions related to the metal finishing industry.

EPA Targets Metal Finishers, Electroplaters Under the Clean Water Act. (Fabricator, May 2023). An update on EPA rulemaking.

DOD Information

PFAS Presence in Metal Plating Fume Suppressants. (Society of American Military Engineers, January 2021). Overview of PFAS issues related to chrome plating fume suppressants.

Other PFAS Information

PFOS Chromium Electroplater Study. (US EPA Region 5, 2009)

Capsule Report Hard Chrome Suppressants and Control Technologies. (US EPA, 1998)