The NASF has submitted a 100-page package of comments to the U.S. EPA in response to the agency's proposed rule for chromium finishing operations. In it, the association questions the agency's decision to tighten tough regulations even further when the industry has reduced emissions by 99.9 percent since 1995.
Christian Richter and Jeff Hannapel, who lead the NASF's Government Affairs office in Washington DC, say their comments also point to major flaws in EPA data and analysis, and raise concerns over EPA's approach to the rule that -- if left unchallenged -- will pose problems for the broader finishing indusutry in the future.
"Unfortunately, EPA's analysis has dramatically overestimated both emissions and potential risks from the industry," said Jeff Hannapel, NASF Government Affairs.
"This is not a favorable precedent - the actual data we've received from NASF members across the U.S. show that EPA counted emissions incorrectly - a majority of companies shown as emitters on the agency's list either don't exist, don't do chromium or have actual emissions far below EPA's "models" driving the new regulation," said Hannapel.
To see the executive summary and NASF's complete set of comments, please visit www.nasf.org.
NASF Government Affairs is still collecting company emissions data, and needs the industry's help to present a complete picture to the agency and the White House on U.S. chromium finishing emissions. They are asking job shops if their company's chromium emissions profile accurately represented in EPA's database. Please contact Government Affairs at jhannapel@thepolicygroup.com or crichter@thepolicygroup.com.
The proposed rules will be discussed at the NASF's Washington Forum, April 24-26. Register today for the 2012 Washington Forum or contact Cheryl Clark at cclark@nasf.org.
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