The EPA has set a new precedent and is adding a new chemical, n-propyl bromide (also known as 1-bromopropane), to the Clean Air Act list of hazardous air pollutants (PAHs) . This chemical is used as a degreaser and cleaner for metal parts in the surface finishing industry, with specific aeronautical and aerospace applications. PAHs are pollutants known or suspected to cause cancer or other serious health effects. The original list of PAHs in the Clean Air Act amendments of 1990 included 189 pollutants. Since 1990, the EPA has removed two pollutants from the list, but so far has not added any new ones.
The final rule was published in the Federal Register on January 5, 2022. The consequences of a new HAP list could be significant. New PAH listings could reopen the current air rules for industry source categories and result in changes to installation permits. The additional potential new emissions of PAHs could also cause some (smaller) sources to become major sources with more stringent requirements. EPA will endeavor to review current NESHAP regulations and identify if additional NESHAPs are warranted.
The addition of this new PAH will likely be the subject of a legal challenge as the administrative process the EPA used to add the new PAH was criticized by several stakeholders for not complying with notification requirements and Commentary on the Administrative Procedure Act. Several industry trade groups have indicated that they intend to challenge the EPA’s perceived “regulatory shortcut” to listing new pollutants. The outcome of the legal challenge will likely set a precedent for future HAP listing decisions, such as possible HAP listings for PFOS and PFOA.
EPA will endeavor to review current NESHAP regulations and identify if additional NESHAP requirements are warranted. As a separate action, the EPA is developing a regulatory infrastructure that will address compliance and enforcement issues that may arise from adding a new chemical to the PAH list. More information is available on the EPA website at: https://www.epa.gov/haps/addition-1-bp-npb-clean-air-act-list-hazardous-air-pollutants.
The NASF will continue to work with other industry trade groups on this effort and provide updates to members. If you have any questions or would like additional information on this issue, please contact Jeff Hannapel of NASF at [email protected]
This the update is courtesy of the National Association for Surface Finishing (NASF). For more information or to become a member, visit nasf.org.
Mechanical properties of electroformed metals
In 1996, EFSA hosted their highly regarded electroforming course, prepared by Ron Parkinson for presentation by the Nickel Development Institute (NiDI) and EFSF. The following is a slightly edited excerpt, specifically on the mechanical properties of electroformed metals. Much of this information has stood the test of time and provides a perspective on this technology at the turn of the century.
Development of a sustainability measurement system and a technical solution method for sustainable metal finishing: AESF research project # R-121, 6th quarterly report
The NASF Research Board funded a research grant to Wayne State University on sustainability in the surface finishing industry, under the direction of Professor Yinlun Huang. The aim of the work is to create a surface finish-specific durability measurement system to measure economic, environmental and social sustainability. In this report, a comparative study of five factories was undertaken to illustrate how sustainability assessment works.
Impact of the REACH regulation on the global finishing market
This article is a peer-reviewed and edited version of a presentation given at NASF SUR / FIN 2012 in Las Vegas, Nevada on June 12, 2012.