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REPO RT Nickel Regulation and NASF Action Association reports interim success through collaboration. ASF continues to work closely on advocacy efforts to ensure that U.S. and global regulatory bodies make responsible and scientifically informed decisions on materials uses for a range of coatings processes. One way the association has advanced the industry's position is through its strategic partnership with the Nickel Institute. Closer collaboration between the two organizations as well as with European-based plating organizations has assisted in impacting decisions that ultimately get picked up in the U.S., either through regulation or through procurement policies by global OEMs that impact the entire supply chain regardless of geography. As the European Union has reviewed stricter hazard classifications, and restrictions or bans on nickel compounds, U.S. regulators at EPA and OSHA, and in some states have also considered changes to existing requirements or ratcheted-down standards. The good news on the nickel front is that NASF's collaboration with the Nickel Institute and other European plating and finishing associations has resulted in a decision to delay the European Union's consideration of restrictions for key nickel compounds used in plating. N Emerging Review of Nickel Compounds for Finishing In lieu of formally nominating nickel compounds for restrictions under REACH, ANSES (anses.fr), the French regulatory agency responsible for environment and occupational safety, recently has undertaken an analysis of so-called Risk Management Options (RMO) for a selected number of nickel containing chemicals. ANSES had been mandated by the French Ministry of Environment (REACH Competent Authorities) to perform a RMO analysis on 12 nickel containing chemicals. In addition to needing various information on hazard, emission and exposure data for nickel compounds for surface finishing, the French government and other interested agencies also required an analysis of uses and a detailed evaluation of volumes used in various sectors. This analysis is intended to fill in data gaps and inform discussions on the impacts of banning or restricting nickel compounds in plating. NASF Resources and Tools Will Inform the Review In addition to informing the U.S. and European discussions of nickel with key diagrams of nickel coating uses in automotive, aerospace and, now, mobile phones, the NASF just completed a joint report with the Nickel Institute that provided important data to analyze the mass flow of nickel compounds in finishing. A copy of the report is available to NASF members by contacting Christian Richter at crichter@thepolicygroup.com. Future reports to educate decision makers in the U.S. and Canada will be issued in the coming year as well. For preparation of the report, the NASF thanks its key author, Dr. Keith Legg of Rowan Technology, along with critical participation New OSHA Interpretation Union representatives can accompany OSHA inspector at a non-union worksite. OSHA is startling employers with a new "Interpretation Letter" employees as a walkaround representative so long as the individual that expands the rights of non-employees and union representahas been authorized by the employees to serve as their representatives during the walkaround portion of an OSHA inspection at tive. This right, however, is qualified by the Secretary's regulations, non-union workplaces. OSHA compliance Legal and safety experts are which allow exercise discretion officers In a recently released letter, which NASF (CSHOs) to over who stating the obvious—that out- participates in workplace inspections." members discussed at the Washington Forum in April with U.S. Chamber of Com- side organizations or unions The new letter disavowed and withdrew merce Labor Policy Director Marc Freedman, a 2003 Interpretation Letter suggesting that will be allowed to hijack the the OSHA law imposed more restrictions on OSHA responded to a United Steelworker safety representative who asked "whether workplace safety process for non-employee involvement in inspections workers at a workplace without a collecthan OSHA's new interpretation. reasons wholly unrelated to tive bargaining agreement may authorize a Many employers are just beginning to protecting workers. person who is affiliated with a union or a hear about the new interpretation and are community organization to act as their repreconcerned about the implications of the letsentative under the Occupational Safety and Health Act (OSH Act)." ter, but legal and safety experts are stating the obvious—that outOSHA answered, in part: "The OSH Act authorizes participation side organizations or unions will be allowed to hijack the workplace in the walkaround portion of an OSHA inspection by 'a represensafety process for reasons wholly unrelated to protecting workers. tative authorized by [the employer's] employees.'… Therefore, NASF members who would like a copy of the complete OSHA Ina person affiliated with a union without a collective bargaining terpretation Letter can email Christian Richter of The Policy Group agreement or with a community representative can act on behalf of at crichter@thepolicygroup.com. 12 JUNE 2013