SFIC Washington Forum Draws Finishers, Suppliers from Across the Nation

On May 11, 2005 representatives of the finishing industry came together for the Surface Finishing Industry Council's Washington Forum, a two-day event that provided an arena for exchange on vital issues facing the surface coatings industry.

Attendees on the first day of the event heard briefings on topics ranging from OSHA's proposed chromium worker exposure limit to the impact of emerging U.S. air regulations (nickel, copper, cobalt) and EU product requirements (WEEE, RoHS, REACH) on finishing processes. (For more on WEEE, RoHS and REACH, see the sidebar on page 56.)

Also featured was expert analysis of federal R&D efforts related to surface coatings, including federal nanotechnology and other research initiatives. Rounding out the program were presentations on energy challenges for manufacturing and the U.S. trade and competitiveness agenda.

The keynote speech was presented by Senator Joseph Lieberman (D-CT). Though Senator Liebermann was delayed as a result of the plane scare that necessitated the evacuation of the Capitol Building, he was able to deliver an abbreviated edition of his speech. In the speech, which featured a thoughtful reference to finishing as it was performed in the days of the Roman Empire, the Senator acknowledged the current energy crisis and discussed some of the issues related to doing business in today's global economy.

Day two of the event shifted focus. For those wishing to brief their representatives in Congress, the Forum provided a 2005 legislative “snapshot” and review of the industry's policy agenda. Participants were fully prepared to spend the day on Capitol Hill discussing industry priorities with their congressional delegation.

TABLE 1: Occupational Exposure Limits- Comparison of Selected Countries (2002)
Country	Occupational Exposure Limit
United States........................... ..............................................	1 ug/m3(proposed) 52 ug/m3 (current)
Japan.....................................	50 ug/m3
European Union.......................	50 ug/m3
France, Germany, UK, Finland...	50 ug/m3
China.....................................	50 ug/m3
India......................................	50 ug/m3
Sweden..................................	20 ug/m3
Denmark................................	5 ug/m3

OSHA Chrome PEL Update

One of the key topics of the event was an update of the OSHA proposed chrome PEL, provided by Jeff Hannapel (The Policy Group) and Stu Sessions (Environics, Inc.). The two provided a brief overview of the proposal and recapped industry's concerns about it. Hannapel and Sessions also reviewed some of the key discrepancies between OSHA and the industry:

Facilities Affected: While OSHA has presented the proposal as something that would affect decorative and hard chrome segments of the plating industry almost exclusively, the reality of the PEL is that it would affect a much broader group of finishers, including shops that perform chromic acid anodizing, chromate conversion coatings (e.g. Zn, Cd, Al), plating on plastics, passivation, welding, polishing and grinding.

Cost of compliance: Hannapel and Sessions reported that one of the biggest sticking points of the OSHA PEL continues to be the discrepancies in cost of compliance for the industry. Whereas OSHA has estimated this cost to be $68 million annually, industry numbers suggest that number—approximately $380 million—will be more than five times greater (Table 2). And when the numbers are adjusted to factor in those industry segments, which OSHA has overlooked, the projection doubles to $760 million.

Table 2: Compliance Cost of Proposed PEL- Metal Finishing Industry ($/year, in millions)
Selected Requirements	OSHA Cost	Industry Cost
Engineering Controls...............................	38,179...........	...............204,218
Exposure Monitoring................................	3,766.............	.................66,486
Personal Protective Equipment.................	12,163...........	.................65,861
Hygiene Areas and Practices....................	1,689.............	.................14,710
Housekeeping.........................................	9,189.............	..................9,392
Respirator Protection...............................	2,190.............	................14,938
Training and Information.........................	500................	..................2,579
Total Annualized Cost..........................	...$68 million	......$380 million
TOTAL COST (including 100% more affected facilities vs. OSHA Estimates)	........................$760 million

Benefits vs. costs: OSHA and industry also disagree on the cost/benefits ratio. Whereas OSHA asserts that total benefits from the PEL would exceed costs by more than $140 million, but the industry's review of how it arrived at its numbers suggests a reliance on incomplete and non-credible information. Industry's analysis projects the benefits at minus $152 million.

The session concluded with an affordability study that looked at six plating shops, along with an analysis of how each would be impacted by the rule if it is passed “as is.” According to the study, which takes into consideration “low” costs (engineering controls only) and “high” costs (additional expenses for respirators), the compliance costs would force three of the six shops to shut down outright. Two of the remaining three shops would close if required to implement respirators. The sixth would be able to stay in business, but would have to close its chrome plating lines.

Looking ahead, Hannapel stated that industry will continue with the strategic approach it has taken, coordinating its efforts with other affected industries as well as the Department of Defense, EPA, Small Business Administration and the White House Office of Management & Budget. The deadline for the final rule is set for January 18, 2006.