III. RECOMMENDATIONS
D. General Recommendations
The Metal Finishing Subcommittee makes the following general recommendations
based on the above findings.
1. EPA should use this National Metal Finishing Environmental
R&D Plan to coordinate and support R&D directed toward
the needs of the metal finishing industry. More specifically:
a. EPA should work with the CSI Metal Finishing Subcommittee to
develop a communication and implementation strategy.
This would involve all stakeholders distributing and making
known to their constituencies the findings and recommendations
of this Plan and gaining increased commitments from them to implement
the recommendations of the Plan.
b. EPA's Administrator and Assistant Administrator for Research
and Development should contact their counterparts in other Federal
agencies to inform them about this Plan and to invite them to
participate in and co-fund implementation of the recommendations
in this Plan.
This will likely require one-on-one contact initially followed
by a meeting of the principals to establish an agreement on funding
levels, which agencies should perform what kinds of R&D, and
time periods.
c. EPA should bring to bear its considerable capabilities--e.g.,
those of the ORD National Center for Environmental Assessment
and National Exposure Research Laboratory--to develop and apply
simple techniques for characterizing the emissions and risks from
metal finishing operations.
d. EPA should identify significant resources to use for implementing
the technology-related recommendations in this Plan.
As one landmark for the potential costs involved, it should
be noted that the CSI Chromium Emissions MACT Standard Demonstration
project--which the Subcommittee regards as a model for R&D
prior to rule-making--cost $645K plus significant voluntary contributions
by industry and other stakeholders. This means that implementing
the recommendations below concerning hexavalent chromium, alone,
would require several million dollars in researh support over
several years.
2. EPA should use this National Metal Finishing Environmental
R&D Plan as a possible approach for other sectoral environmental
R&D plans. More specifically:
a. EPA should provide copies of this Plan to other CSI sectors
and other Agency sectoral activities indicating that they should
consider pursuing this type of environmental pollution prevention
R&D planning for their sector.
It should be recognized that other sectors are likely to develop
quite different plans. For example, the metal finishing industry
expressed a strong need for applied research and simple technologies.
Other industries may require more basic research and more complex
technological solutions.
b. EPA should provide resources for the types of activities that
are necessary to develop a plan of this type that accurately represents
industry priorities and has support from other stakeholders.
These activities include: workshops of experts and practitioners,
surveys of current public and private sector R&D, symposia
on R&D needs for specific topics, meetings with suppliers
and clients of the industry, and surveys of participant ratings
of projects.