As we take a moment today to celebrate our surface finishers across the country, it is also time for an update on federal and state issues as they pertain to the surface finishing industry. The National Association for Surface Finishing (NASF) stays on top of issues facing the surface finishing industry and provides updates to relevant parties. Here is what you may have missed...
Federal Issues
• EPA Pushes Back Timeline for Proposing Metal Finishing PFAS Effluent Limits: The proposed metal finishing standards to address PFAS is being pushed back from August 2024 to December 2024.
• OSHA, DOT and EPA Civil Penalties are Increasing in 2023: The Department of Labor recently revised civil penalty amounts for OSHA violations by employers, per an earlier authorization by Congress. The Department of Transportation has also increased civil penalties for all modes of transportation, including highway, by 7.745 percent. EPA’s new maximum penalties are now highest for Clean Air Act violations at $117,468 per day
• EPA Released Draft IRIS Assessment for Cobalt: EPA recently released its draft plan to assess the cancer potential from inhalation of cobalt that takes a “no safe-level” approach inconsistent with other available science.
State Issues
• California Air Board’s Proposed Ban on Hexavalent Chromium: Industry leaders in a recent hearing in California highlighted key reasons for state air authorities to chart a different path than phasing out all hexavalent chromium electroplating and anodizing.
• New York State Requires Environmental Justice Cumulative Impact Analysis: A new law will require a thorough review of the cumulative impacts of pollution on certain disadvantaged communities before an environmental permit is issued or renewed.
OSHA, DOT and EPA Penalties Recently Increased Penalties
As a reminder, the Department of Labor has revised civil penalty amounts for OSHA violations by employers, per an earlier authorization by Congress to keep up with inflation. Maximum penalties for serious violations have increased from $14,502 to $15,625 per violation. For willful or repeated violations, maximum penalties have increased from $145,027 to $156,259.
The DoT has also increased civil penalties for all modes of transportation, including highway, by 7.745%. The increases apply to dozens of Federal Motor Carrier Safety Regulations and Hazardous Materials Regulations violations, including violations related to:
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Out-of-service orders
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Recordkeeping
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Non-recordkeeping
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Hazardous materials regulations
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Commercial regulations
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Operating authority requirement
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Tariffs
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Loading and unloading
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Evasion of U. S. Codes
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Reporting and recordkeeping
Finally, the EPA has increased the maximum civil penalties for environmental violations as follows:
- Clean Air Act (CAA) $109,024 $117,468
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Clean Water Act (CWA) $59,973 $64,618
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Superfund and Right-to-Know (CERCLA/EPCRA) $62,689 $67,544
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Safe Drinking Water Act (SDWA) $62,689 $67,544
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Toxic Substances Control Act (TSCA) $43,611 $46,989
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Insecticides, Fungicides, and Rodenticides (FIFRA) $21,805 $23,494
EPA Releases Plan for New Health Risk Assessment for Cobalt
The agency recently released its plan for an extensive new health evaluation for cobalt inhalation and will focus its assessment on water-soluble and water-insoluble cobalt compounds. Officials indicated that it plans to carry out a cancer assessment that will likely be more stringent and generate new risk values that could drive additional future restrictions on cobalt use, much like the current hexavalent chromium evaluation under review by the agency.
The agency also recently announced a public meeting in January to discuss several matters related to its approach on inhalation risks from cobalt, including scientific complexities associated with the effort.
Summary
Rules and regulations can be hard to follow, but they are in place for good reason. Having a solid record of all business activities in a digital environment promotes visibility and organization to ensure regulations are followed, making audits a piece of cake. For more information about Job Shop Software, contact sales@gosteelhead.com.