Compliance Assistance

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

 

Air

General compliance assistance tools for air emissions

• STERC Plain Language Guide to Air Emissions Regulations. A STERC plain language guide.

• Air Pollution State Resource Locator. Find state and regional air regulatory agencies, rules and contacts.

• National Small Business Environmental Assistance Program State Contacts. Most states have designated a person that can provide confidential, environmental compliance assistance at no charge for your small business.

• Applicability Determination Index. A searchable web-based database that contains memoranda issued by EPA on applicability and compliance issues associated with air pollution regulations (e.g., Maximum Achievable Control Technology).

Chromium Emissions

• Chromium Electroplating Compliance Calendar. Prepared by the Florida Small Business Assistance Program.

• National Emission Standard for Hazardous Air Pollutants for Chromium Emissions from Hard and Decorative Chromium. The Chrome NESHAP affects all facilities that use chromium electroplating tanks, regardless of size. Activities your facility must perform to comply with the Chrome NESHAP are dependent upon the size of the operation and the type of process (hard, decorative, or anodizing). Also, see 2012 updates.

• Chromium Plating Emissions Calculator. This calculator, developed by the Illinois Environmental Protection Agency, is designed to estimate emissions from chromium plating and anodizing operations. Simply enter production information and press "Calculate Emissions."

Solvent Emissions

• NESHAP Halogenated Solvent Cleaning—May 2007 Revisions. On May 3, 2007, EPA published the first significant change in these rules since the National Emission Standard for Hazardous Air Pollutants (NESHAP) for solvent cleaning operations was published in 1994.

• Pollution Prevention (P2) Spotlight Reducing Trichloroethylene (TCE) Waste in the Fabricated Metals Sector (2016). Please note that this EPA document was written in 2016 and is based on 2012 TRI data for the entire Fabricated Metals Sector. More recent and specific TRI data (2022) show that only four US facilities in NAICS 332813 (Electroplating, Polishing, Anodizing and Coloring) reported any TCE releases. The total amount of TCE released by these four facilities was 37,179 pounds.
•  Scope of the Risk Evaluation for Trichloroethylene (EPA 740-R1-7004). This document presents the scope of the risk evaluation to be conducted for TCE. If a hazard, exposure, condition of use or potentially exposed or susceptible subpopulation has not been discussed, EPA, now, is not intending to include it in the scope of the risk evaluation.

Other Metal Finishing Related NESHAPs

• Metal Fabrication and Finishing Area Source Rule (40 CFR part 63, subpart XXXXXX). This rule covers dry abrasive blasting, dry grinding and dry polishing with machines, dry machining, spray painting, and welding for specific industry categories. The compliance date for existing facilities is July 25, 2011.

• 40 CFR Part 63 Subpart XXXXXX (6X) NESHAP -- Questions & Answers (Nov. 2011). This document combines Questions & Answers identified in the Nine Metal Fabrication and Finishing Source Categories Area Source NESHAP promulgation package and in subsequent conversations between stakeholders and EPA personnel.

• Kansas State Pollution Prevention Institute resources for visible emissions monitoring for NESHAP 6X (welding and dry abrasive blasting).

• Final National Emission Standards for Hazardous Air Pollutants (NESHAP) for Plating and Polishing Operations (WWWWWW, or 6W) (STERC Fact Sheet)

Solid/Hazardous Waste

General

• STERC Plain Language Guides to Regulations – The STERC plain language guide to hazardous waste management.

• RCRA/Hazardous Waste Resource Locator. The rules for managing hazardous waste vary from state to state. Find your state regulations, along with permit forms, guidance, contact information and other helpful resources.

• Managing Your Hazardous waste: A Guide for Small Businesses (EPA 530-K-19-001). This handbook provides an overview of the regulations to give you a basic understanding of your responsibilities when generating and managing hazardous waste.

• Summary of Requirements for Very Small Quantity Generators (EPA 530-F-20-002). If you generate no more than 100 kg (220 lbs) of hazardous waste and no more than 1 kg (2.2 lbs) of acute hazardous waste per month, you are a VSQG. As a VSQG, you must comply with three basic waste management requirements.

• Hazardous Waste Requirements for Large Quantity Generators (EPA 530-F-20-003). To assist your business in learning about these requirements, the U.S. Environmental Protection Agency (EPA) has prepared this summary fact sheet.

• EPA Hazardous Waste Generator Improvements Rule. On November 28, 2016, the U.S. Environmental Protection Agency (EPA) published in the Federal register the final Hazardous Waste Generator Improvements Rule. This regulation amends the requirements governing hazardous waste generators under the Resource Conservation and Recovery Act (RCRA).

• Hazardous Waste Portal. This resource catalogs over 800 hazardous waste compliance resources, including guidebooks, fact sheets, reports, checklists, web sites, contacts, and regulations. Various features are available to assist users in finding the best guidance materials and answers to specific questions.

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:

• Four-Step Guide to e-Manifest Registration.

• E-manifest System Help Guide.

• Frequent Questions about e-Manifest.

• Learn more about the e-Manifest System.

Other Hazardous Waste Resources

• Universal Waste Resource Locator. Some common items (batteries, pesticides, etc.) may be exempt from hazardous waste rules. Find out which items are designated as Universal Wastes in your state, link to state regulations, and local contacts at state agencies.

• Amendment to the F019 Hazardous Waste Listing. 

• California Inspectors Manual for Plating Operations. Find out what the inspector will be looking for before he shows up at your door.

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

• Stormwater Rules. A guide for metal finishers for meeting stormwater regulations.

• Industrial Stormwater Resource Locator. Find stormwater permit forms and guidance documents for industrial facilities, and persons you can contact in your state agency for additional assistance.

• Industrial Stormwater General Permit. Find the latest federal industrial stormwater permit and related compliance assistance resources.

• Stormwater Training Resource Locator. Find storm water training resources available in your state with this tool.

• Total Maximum Daily Load Resource Locator. Some streams and lakes are covered by Total Maximum Daily Load rules for sediment control. Find out about the TMDL program in your state and determine whether your facility will be affected by TMDL rules.

• Industrial Stormwater Fact Sheet. EPA fact sheet specific to the fabricated metal products industry. Includes, among other topics, an overview of the regulations and best management practices.

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.

• TRI Reporting. Check  here for annual updates to TRI reporting. 
  
• TRI-MEweb. In 2013, the TRI Program began requiring facilities to prepare and submit TRI reporting forms electronically using TRI-MEweb. This online software prevents many reporting errors that were common on the previously used paper reporting forms.
• 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

• EPA Region and State Pollution Prevention (P2) contacts.

• Pollution Prevention and Control Technologies for Plating Operations. Published by National Center for Manufacturing Sciences (NCMS), Ann Arbor, MI. this is the most widely referenced book on this subject. The author is George Cushnie, CAI Resources Inc.

• Pollution Prevention Metal Finishing Shops Shine with P2 (2021). EPA fact sheet.

• Chemical Facility Anti-Terrorism Standards. As of July 28, 2023, Congress allowed the statutory authority for the Chemical Facility Anti-Terrorism Standards (CFATS) program (6 CFR Part 27) to expire. Therefore, CISA cannot enforce compliance with the Cybersecurity and Infrastructure Security Agency(CFATS) regulations at this time.
• REACH — Registration, Evaluation, Authorization and Restriction of Chemical substances is a European Community Regulation (EC 1907/2006) that became effective on June 1, 2007. 
• Toxic Release Inventory Pollution Prevention Data. TRI information from metal finishers provides insights into successful P2 programs.