The Future of Finishing

January 1, 2008

NCMS

3025 Boardwalk Drive

Ann Arbor, Michigan, 48108-3266

Contact:

Paul D. Chalmer, Ph.D.

NCMS

Phone: (734) 995-4911

Fax: (734) 995-1150

paulc@ncms.org
Future of Finishing, page 2 of 65

Contents

Introduction..................................................................................................................................... 3

What do we mean by “surface finishing”? ................................................................................. 3

What is special about surface finishing?..................................................................................... 3

Implications for the future of finishing....................................................................................... 5

Global pressures.......................................................................................................................... 6

Acknowledgements......................................................................................................................... 9

I. Economic Trends....................................................................................................................... 10

Introduction: a note on methodology....................................................................................... 10

Overview of the finishing firm’s recent experience ................................................................. 10

Profitability challenges will continue ................................................................................... 11

Larger job shops faring better, but are not insulated from pressures.................................... 12

Small job shops holding their own on market share ............................................................. 13

U.S. finishing industry has resized, declined significantly................................................... 13

Job shop revenues in nominal terms..................................................................................... 14

Finishing industry revenues in real terms............................................................................. 15

Finishing revenue decline greater than U.S. manufacturing base......................................... 16

Job shop plating revenue as a share of manufacturing revenues .......................................... 17

Job shop employment ........................................................................................................... 18

Job shop plating employment as a share of manufacturing employment ............................. 19

The finishing industry will remain extremely fragmented ................................................... 19

Trend analysis........................................................................................................................... 21

II. Regulatory Trends.................................................................................................................... 23

Overview of existing U.S. regulations...................................................................................... 24

Air pollution control – the Clean Air Act ............................................................................. 24

Wastewater pollution control – the Clean Water Act (CWA).............................................. 28

Hazardous waste – the Resource Conservation and Recovery Act (RCRA)........................ 32

Toxic chemical reporting – EPCRA ..................................................................................... 33

The Toxic Substances Control Act (TSCA) ......................................................................... 36

International trends ................................................................................................................... 39

The future.................................................................................................................................. 41

III. Technology Trends ................................................................................................................. 46

Technology survey results ........................................................................................................ 47

Optimizing existing technology................................................................................................ 49

Optimize conventional wet processes to achieve near zero discharge and risk.................... 49

Improve process monitoring and control systems ................................................................ 51

Pursue sustainable manufacturing......................................................................................... 54

Improve energy efficiency .................................................................................................... 56

Developing and implementing new technology ....................................................................... 57

Change to “greener” process chemistries ............................................................................. 57

Change from “wet” processes to “dry” processes................................................................. 58

Change substrate materials from finished metals to non-metals .......................................... 60

Develop new metal alloys that reduce surface finishing requirements................................. 62

Develop nanotechnology ...................................................................................................... 63

Remarks on technology trends.................................................................................................. 64
Future of Finishing, page 3 of 65

Introduction

If you have a stake in the surface finishing industry, this report was written for you. Business 

owners, employees of job shop or captive surface finishing operations, suppliers and customers, 

environmental regulators and the public they serve – all will face some difficult choices in the 

next few years, and all have much to gain or lose by the outcome.

We can’t foretell the future, but we can do our best to understand the past and present. The 

report looks at recent trends in three crucial areas – economics, environmental regulations, and 

technology. Looking at the facts, we can try to distinguish what will continue, what will change, 

and what we can do about it.

What do we mean by “surface finishing”?

First, we need to agree on what kinds of operations we want the term “surface finishing” to 

include. We will use the term to refer to the application of relatively thin coatings, applied to 

protect a substrate layer, to improve its function, or to enhance its appearance. By “relatively 

thin”, we mean coatings that would not ordinarily be able to stand on their own – this 

distinguishes surface finishing from laminating. We also want to exclude surface treatments 

such as purely mechanical grinding, shot peening, or purely thermal heat treatment – operations 

that do not add any material to the substrate layer.

So for the purposes of this report, surface finishers are in the business of applying coatings to 

surfaces and making them stick.

Within that basic definition, surface finishers have many techniques at their disposal. The 

coating materials can be conveyed to the surface with the help of a liquid carrier, and the surface 

can be sprayed, spread, or dipped. The materials can be applied passively, or can be joined to the 

surface with the aid of a chemical or an electrochemical reaction. Or the materials can be 

applied directly, with no carrier medium at all, in the form of a heated spray or an ionized 

plasma. Each method has its own advantages– and its own worker safety and environmental 

challenges. Many examples are considered in detail in the report.

What is special about surface finishing?

To put the trends in context, we begin by considering some of the factors that give the surface 

finishing industry a unique structure as an industry sector.

A major fault line runs through the sector, dividing surface finishing operations into two distinct 

categories. We can see both the causes and the consequences of this rift mirrored in the structure 

of the trade and professional organizations that have developed to represent the interests of the 

two divisions.

Electroplating and related coating. On one side of the divide, we have the platers. The art and 

science of depositing neutral metal coatings from metal ions in solution goes back over two 

centuries, slowly evolving from a laboratory research tool to a common industrial process. In the 

United States, industrial electroplating is typically carried out by two types of facilities, 

independent “job shops” that typically provide plating services for a variety of parts 
Future of Finishing, page 4 of 65

manufacturers, and “captive shops” that operate as in-house production units for parts that are 

often manufactured in the same facility. Although the business models are different, the 

operations share many common features. Process details are typically worked out and 

supervised by skilled electrochemical engineers or electrochemists, or by platers with long 

experience. In smaller shops, the proprietor will be able to supply the expertise; in larger shops 

or captive operations, there will be trained professionals on staff. In either case, successful 

operation depends on the abilities of the process operator.

Until quite recently, three independent national organizations represented the interests of 

companies and individuals involved in industrial electroplating. The American Electroplaters 

and Surface Finishers Society, AESF, was the professional organization, with a strong emphasis 

on education and technical research. The National Association of Metal Finishers, NAMF, 

represented the independent “job shop” businesses. The Metal Finishing Suppliers Association, 

MFSA, represented suppliers of chemicals and equipment to plating operations. The 

organizations have since merged into a new organization (the National Association of Surface 

Finishers, NASF), but their individual functions are still represented in the range of activities of 

the new organization.

Paint and specialty coatings. On the other side, we have a very different landscape. Paint 

shops are ubiquitous in manufacturing facilities. In contrast to the situation with platers, 

independent businesses that specialize in painting parts that are manufactured elsewhere are 

virtually nonexistent.

Manufacturers of paints and coatings have a national trade organization, the National Paints and 

Coatings Association, NPCA. But when we search for trade or professional organizations that 

specialize in representing general paint and coating applicators, we find – nothing. There are 

trade organizations that promote specialized coating types, such as ultraviolet-curable coatings 

and powder coatings, and professional organizations that deal with general surface topics such as 

corrosion. But there is no counterpart to the AESF (as a professional organization) or the NAMF 

(as a trade organization) for this category of surface finishing.

The roots of the difference. What characteristics can account for the differences between 

plating operations and those involving other types of coatings?

It isn’t the use of electricity in the process: “electroless” nickel, a plating process, is carried out 

without electric power, and electrostatic spray coating, an “organic coating” type application, 

requires electric power. It isn’t necessarily the composition (inorganic vs. organic) of the coating 

material: galvanizing (coating with an inorganic material, zinc) is a dip coating process that has 

more in common with the “organic” coatings than with plating.

Nor is it simply a historical accident that platers have coalesced into a community with perceived 

common interests, while other types of coaters have remained, at least in their roles as users of 

coatings technologies, largely disconnected. There is a key characteristic in the coating process 

itself that accounts for the differences between to two subsectors, and which has implications for 

their respective futures.
Future of Finishing, page 5 of 65

The crucial difference lies in what is normally considered a mere bystander in the coating 

process – the carrier medium used to transport the coating material to the surface. More 

particularly, the crucial difference is the mode in which the carrier medium is employed.

For a typical non-electroplating application, the carrier does its job once, and then goes away. 

Paint solvents help spread the paint solids on the substrate, and then evaporate. Even when the 

carrier is needed to support chemical reaction at the surface, once the reaction has proceeded 

beyond a certain point, the carrier will leave the surface, and will play no further role in the 

process.

In contrast, most plating processes involve a medium that stays in the picture for the long haul. 

Typical plating baths are complex mixtures to begin with, and a variety of reactions occurring at 

two electrodes act continuously to shift the composition during the course of the process. 

Reagents consumed during the process must be continually replenished, and wastes must not be 

allowed to build up. Unlike others coatings applicators, platers need to keep a large suite of 

parameters within acceptable limits, often for months at a time. The requisite know-how is 

perhaps the most critical distinction between platers and others.

Bath maintenance might seem to be a routine chore, not a critical process element that shapes an 

entire industry. But the consequences run deep. It is much easier to design a carrier system that 

has a single job to do in a limited time than to devise a system that can maintain itself for months 

without human supervision. For many painting and coating processes, the intelligence is 

built into the coating system, and the process can be carried out by operators needing little 

knowledge of the details. But for plating, the skill and the knowledge of the coater remain 

indispensable.

As a result, plating retains an element of craft that is missing from other types of coating. And, 

at least until recently, suppliers of the materials and equipment for plating have not appeared to 

exert the same dominance on the technical side of their subsector as suppliers have done for 

other types of coating.

Implications for the future of finishing

How is this configuration, with suppliers dominating in areas other than plating, and a balance 

between suppliers and coaters in the plating sector, likely to develop in the future? There are two 

potential ways that the future could diverge from the historical pattern. Either new technologies 

could appear that require a particular level of judgment and skill on the part of the coater, or 

existing plating technology could evolve to the point where little skill is needed other than the 

ability to follow the supplier’s directions.

Consider the first possibility. What are the chances that a new craft will emerge alongside 

plating as a specialty enterprise? Among the new technologies reviewed in the Technology 

Trends section, the “dry” coating methods (such as HVOF and PVD) represent most radical 

departure from existing practice. Although the coatings, coating conditions, and application 

equipment needed for dry coating processes differ markedly, the skills required to apply such 

coatings successfully are similar to those for wet spray processes. It is easy to imagine the 

development of fully automated lines to apply the dry coating methods. The skill of the 
Future of Finishing, page 6 of 65

operator is not likely to be a crucial factor. As far as the other technologies discussed below are 

concerned, most either are variations of existing processes, or are concerned with topics other 

than the coating process. Thus, we do not see that any of the new technologies are likely to 

create a new subsector of independent firms specializing in coating applications.

Looking at the other possibility, what are the chances that the independent plating firm will be 

automated out of existence? One of the trends covered in the Technology Trends section, 

“Improve process monitoring and control systems”, bears directly on this point. As noted in that 

discussion, improved process control will almost certainly prove to be so advantageous that 

finishing firms will need to upgrade continually to remain competitive. But there is a wide gulf 

between a system that can provide better information to a process supervisor, and a system that 

can replace the supervisor by a set of algorithms. Suppliers to the finishing industry will no 

doubt continue developing process control technologies that attempt to approach that level of 

autonomy. How long it will take for them to succeed in creating plating systems that can 

essentially run themselves for long periods of time, without the intervention of human judgment,

is an open question.

Based on the trends described in the report, we believe that the independent plating shop will 

continue to exist for at least another generation, if not longer, but that success will increasingly 

involve a willingness and ability to adapt to change. At the same time, suppliers to the industry 

will also achieve some success in broadening the range of processes that can be carried out by 

non-specialists.

It is possible that the industry may go through a hybrid phase. Certain plating processes may be 

automated to the point that they can run unattended for extended periods, but still need 

occasional attention. Manufacturers might find it advantageous to set up captive operations

using the process, rather than sending the work to a job shop. However, they might also be

deterred by the need to keep someone on staff with the requisite skills, who is also familiar with

compliance requirements. The availability of these “nearly automated” processes might provide 

an opportunity for firms that would specialize in ensuring bath quality and regulatory 

compliance. Following the “chemical management” model, these “plating management” firms 

could offer manufacturers the option to contract out the management of their in-house finishing 

operations. Process supervisors working for the plating management firm would be responsible 

for operations at several facilities, so that no single manufacturer would bear the entire cost of 

plating expertise that was no longer required in a full time position. The ability to provide 

plating management services in addition to job shop plating could help keep some independent 

shops in business during the transition.

In any case, the changing nature of the finishing industry will affect both suppliers and finishers. 

Here is a brief summary of some of the likely changes that are considered in more detail in the 

rest of the report.

Global pressures

For many decades, the United States dominated the global economy. But in the past few years, 

the U.S. has experienced:

 a declining manufacturing base
Future of Finishing, page 7 of 65

 the rise of new global competitors

 an accelerating trade deficit

 a decrease in its commitments to scientific research

Some analysts argue that the American economy is at an “inflection point,” a “unique and 

delicate historic juncture” at which the U.S. for the first time in its history is facing challenges it 

has never before encountered. Are we witnessing the final days of the era of American 

economic dominance?

During most of that era, U.S. finishing firms served North American markets. What would the 

end of the American economic era mean for those firms?

A look at U.S. trade and global economic developments points to a world significantly different 

from what finishing firms faced only a decade ago. As recently as 1998, the Surface Finishing 

Market Research Board (SFMRB) asked in a survey, “What do you see as the greatest challenge 

to your metal finishing operations in the next 5 years?.” At that time, only 2.7 percent of 

respondents were concerned about “loss of manufacturing” in the U.S., and only 7.1 percent 

expressed concern about “foreign competition.”

But all the while, powerful economic forces, accelerated by the explosion of information 

technology and communications capabilities, were already altering the global competitive 

landscape. Things were changing so quickly that, by the 2004 SFMRB finishing survey, firms 

ranked “business moving offshore” as the industry’s number one challenge, an astonishing 

contrast to the prevailing view just several years earlier.

How has the finishing industry responded to the changes? A sizable percentage of finishing 

firms have simply exited the industry. Some observers have suggested that this trend is an 

ominous sign for what awaits those remaining. But others argue that a smaller industry, 

populated by more “stable and able” competitive firms, would be a welcome outcome.

Regardless of one’s view, several key indicators – some informing us of long term structural 

trends, and some of cyclical trends – indicate continued challenges, as well as opportunities, for 

U.S. finishers in the future. We can summarize the trends under the headings of

 price

 product

 process

Figure 1 illustrates these broad and momentous changes now underway in the finishing industry:

Price competition from Asia and U.S. “Profit Squeeze” – U.S. finishers face intense pricing 

pressures from China and other emerging economies. Particularly in China, low labor costs, 

currency policies, commodity subsidies and other trade protections together have driven prices 

down for manufactured goods and led to nothing less than a transformation of the global 

manufacturing supply chain. Finishers are living with the new reality of global sourcing by their 

multinational customers and intensified direct competition from Asian-based finishing 

operations. At the same time, steep structural overhead costs to operate in the U.S. (e.g., energy, 

metals, health care and regulation) are constraining profitability.
Future of Finishing, page 8 of 65

Product and Materials Regulation from the European Union – The European influence since 

the 1990s on global manufacturing policies and practices of multinational companies continues 

will continue to influence the nature and role of key metals and other chemicals associated with 

surface finishing. Regulatory restrictions on a growing number of finished materials for whole 

categories of products, informed primarily by more expansive European approaches to 

minimizing environmental and health risks under the “precautionary principle” – will continue to 

reshape and, in some cases, shrink market demand for certain metals and coatings while 

providing opportunities for alternative finishes.

Process Regulation from U.S. Environmental, Health & Safety Requirements – While the 

industry has in recent years successfully challenged certain poorly-conceived regulations on 

traditional finishing processes, finishing firms face the prospect of ever-tightening controls on an 

expanding range of operations and new demands for alternative coating technologies.

Figure 1

These three trends – the new global pressures on prices, products and processes – and the 

phenomena associated with them – global sourcing, changing market and regulatory demands, 

and emerging coating options – describe in essence the future terrain for finishing. We deal with 

them one by one in the following three sections.

Section I provides an overview of important economic trends relevant for the U.S. finishing 

industry, including the conditions of some of the primary finishing customer segments, domestic 

cost pressures and profitability trends for metal finishing job shops. Section II gives an overview 

of the regulatory context within which the finishing industry operates, and then discusses 

emerging and future legal requirements on finishing processes and products that are driving 

alternative coating technologies. Section III identifies the most relevant technology trends 

underway in the industry and the direction and scope of innovation.
Future of Finishing, page 9 of 65

Acknowledgements

Several individuals well known to the surface finishing industry contributed to this report. 

Christian Richter of The Policy Group, who has served as the leading representative of the 

surface finishing industry in Washington for the past decade, wrote the economics section and 

the “Global pressures” section of the introduction. George Cushnie, Technical Director of the 

National Metal Finishing Resource Center (NMFRC, the compliance assistance website for the 

surface finishing industry, at www.nmfrc.org), wrote the part of the regulatory section covering 

U.S. regulations, and Paul Chalmer of NCMS wrote the international and future parts. Kevin 

Klink and Peter Gallerani of Integrated Technologies, with the assistance of George Cushnie, 

conducted the survey and wrote the technical section.

Although the report has benefitted greatly from the contributions of these authorities, their work 

has been edited in order to integrate the sections. The conclusions and interpretations offered in 

the report represent the outcome of NCMS Project 170414, Benchmarking Environmental 

Performance, and do not necessarily represent the opinions of the contributors. Please direct 

comments and suggestions to Paul Chalmer at NCMS, paulc@ncms.org or (734) 995-4911. 

This study was funded through a cooperative agreement with the Environmental Protection 

Agency. The project would like to thank EPA Small Business Ombudsman Karen Brown, and 

our Project Officer, Angela Suber, for their support throughout the Benchmarking Environmental 

Performance project.
Future of Finishing, page 10 of 65

I. Economic Trends

Introduction: a note on methodology

This section presents a picture of current economic trends affecting the U.S. finishing industry, 

and outlines what they may portend for the future. The picture is based primarily on U.S. Census 

data, proprietary data, and industry market research information, as well as qualitative 

information about the industry from countless discussions and interviews.

We need to proceed with some caution. It is not easy to present a clear and simple picture of

anything as complex as the finishing industry. In the story “The Blind Men and the Elephant”, 

the characters each touch different parts of an elephant and draw entirely different conclusions 

about what kind of an animal it must be. Similarly, our conclusions about how the finishing

industry is faring and where it may be headed will depend on where we look. Focusing on 

different finishing process types or different customer segments may lead to entirely different

interpretations of the same data. Nevertheless, we believe that the information is consistent 

enough that we can make reasonably accurate and meaningful statements about the economics of 

the finishing industry.

There remain some noteworthy challenges. For example, we can’t say with certainty how many 

jobs shops are currently operating in the U.S. Another challenge arises when we try to evaluate 

the impact of global competition on U.S. metal finishing.

The second challenge results from the way the Census bureau groups U.S. economic data. 

Production, employment and related data for finishing services (collected under NAICS code

332813 – electroplating) are collected and organized as a subsection of the larger “fabricated 

metals” sector (NAICS 3328) in the industrial census. Tracking increases or decreases for U.S. 

domestic production, employment and related activities is relatively straightforward. But 

imports and exports are another matter. Finishing is not a manufactured product that is imported 

or exported per se. Instead, it is the customers’ parts that are imported or exported. Finishing is 

considered a service performed on the parts. Official data are not available for the U.S. trade 

balance in finishing services. As a result, information on the finishing of imported and exported 

parts is not available directly. The U.S. “trade balance” in metal finishing can only be deduced 

by analyzing import or export patterns of the customer sectors, such as automotive or motor 

vehicle parts, hardware, appliances, electrical machinery, aircraft parts, and others, that purchase 

metal finishing services. These important trends are discussed further below.

Overview of the finishing firm’s recent experience

So what is happening to U.S. finishers at the firm level? To answer this question, we reviewed 

and analyzed data on manufacturing and the finishing industry from various sources, as well 

studies and literature from various organizations, think tanks and economic forecasting firms. In 

addition to the easily available data, we also looked at some harder to find information on 

profitability, growth in output and employment and related measures of economic health.
Future of Finishing, page 11 of 65

We found that the finishing industry’s experience in the past decade partly mirrors that of larger 

U.S. manufacturing – a severe downturn beginning in 2000, followed by a modest recovery since 

2003. Reports from many finishing firms in 2005-06 indicate that many finishers had begun

setting monthly or annual sales records. But at the same time, others were experiencing modest 

to severe difficulty. Some have even failed to sustain consistent revenue growth.

Here are some of the more important trends for U.S. finishing industry, set against the context of

the larger U.S. manufacturing picture:

Profitability challenges will continue

Profitability for the finishing industry overall is down from historic patterns. Chart 1 shows that 

while it has improved somewhat since the deep trough in 2001-02, it had not bounced back to 

historical levels moving into 2004. While more recent U.S. Census information is not yet 

available, a closer look at proprietary data on the pre-tax profits of the industry (NAICS 332813) 

indicate that for more than a decade between 1989 – 2000, profits fluctuated but remained in the 

range of 3 to 6 percent. Starting in 2000, profits dropped from over 4 percent to under 0.5 

percent, and while trending back upward more recently, had only recovered to 1.5 percent by 

2003 and 2.4 percent by 2004.

Chart 1

Avg. Pretax Profits for Job Shops (NAICS 332813)

(As a percent of Revenues)

0.0%

1.0%

2.0%

3.0%

4.0%

5.0%

6.0%

7.0%

Pre-tax Profits 5.3% 3.6% 3.6% 4.0% 4.7% 6.0% 5.4% 4.9% 5.5% 3.4% 3.8% 4.3% 0.4% 1.3% 1.6%

4/1/89-

3/31/90

4/1/90-

3/31/91

4/1/91-

3/31/92

4/1/92-

3/31/93

4/1/93-

3/31/94

4/1/94-

3/31/95

4/1/95-

3/31/96

4/1/96-

3/31/97

4/1/97-

3/31/98

4/1/98-

3/31/99

4/1/99-

3/31/00

4/1/00-

3/31/01

4/1/01-

3/31/02

4/1/02-

3/31/03

4/1/03-

3/31/04

Profitability trends in finishing appear to correspond to general profitability swings in U.S. 

manufacturing this decade. It is interesting to note that manufacturing profits in general are 

continuing to drop steadily overall – by about 2 percent a year for the 35-year period starting in 

1970, reflecting increased global competitive pressures, among other factors. Some analysts 

expect that the decline in profits and manufacturing growth may continue. While finishing firms 

have been faring better recently, they will continue to face some challenging headwinds on the 

profitability front.
Future of Finishing, page 12 of 65

Larger job shops faring better, but are not insulated from pressures

To determine whether the recent profit pressures for finishing are falling equally on small vs. 

larger finishing firms, we reviewed data for the 15-year period since 1990. Charts 2 and 3 below 

indicates what has appeared to be generally true – that larger plating firms, in terms of revenues, 

assets, or employment, have been more profitable than smaller ones. But the same is not 

necessarily true in other industries. Although some small shops have shown outstanding 

performance – particularly those with expertise and experience in niche markets – larger 

finishing operations face comparatively fewer hurdles in innovation and productivity 

improvements. Larger operations also frequently, but not always, find it easier to manage the 

burden and complexity of the many environmental, health and safety requirements and 

challenges facing the typical operation.

Chart 2

While profitability has tended to be higher for larger operations, anecdotal evidence and 

knowledge of recent industry developments indicates that even the largest operations are not 

immune from significant financial pressures associated with the recent manufacturing downturn. 

Indeed, some of the largest and well-known U.S. finishing firms have ceased operations in the 

past several years due to foreign competitive pressures and related factors.

Pretax Profit by Asset Class

For Surface Finishing Operations

-4.0%

-2.0%

0.0%

2.0%

4.0%

6.0%

Pretax Profit -2.0% 0.4% 2.4% 4.7%

0-500M 500M-2MM 2-10MM 10-50MM
Future of Finishing, page 13 of 65

Chart 3

Small job shops holding their own on market share

Despite the consistent historical lower profitability of smaller job shops relative to larger ones, 

small job shops appear to be maintaining their market share in the industry during the recent 

period for which data is available. From 1992 to 2002, smaller job shops (< 20 workers) 

continued to account for about 21 - 22 % of industry revenues and 24 - 25% of industry 

employment.

There has, however, been a slight shift over time in industry employment toward the largest job 

shops (100 or more employees) – in 1992 about 22% of industry employment was in these large 

job shops and the trend was continuing upward to 26% in 2002. This small shift in employment 

toward the largest job shops has not been matched by a similar shift in revenues. In general, 

smaller job shops have seemed to “hold their own” within the industry in terms of both 

employment and revenues, despite consistently lower historical reported profitability.

One important factor behind this phenomenon is that that the vast majority of small firms are 

family owned. Family capital is tied up in the business and family members are employed in the 

operation, and hence there are few options but to keep the shop open regardless of the business 

demands on the operation. Another factor is that a smaller business offers more opportunity for 

tax-advantaged accounting than does a larger operation. The small firm can take steps to keep 

reported earnings low while taking reasonable sums out of the business in ways other than 

through earnings. Overall, some of the difference in reported profitability is likely real and due 

to intrinsic economic advantages of a larger job shop, while some of the difference is due to the 

ability of firms to manage profits.

U.S. finishing industry has resized, declined significantly

Available data and evidence show the finishing industry has experienced modest to significant 

contraction over the past several years. Recent SFMRB surveys indicate that decline can be seen 

Pretax Profit by Revenues

For Surface Finishing Operations

-1.0%

0.0%

1.0%

2.0%

3.0%

4.0%

5.0%

6.0%

Profit 1.2% -0.6% 0.9% 2.2% 4.8% 3.9%

0-1MM 1-3MM 3-5MM 5-10MM10-25MM25MM & 

Over
Future of Finishing, page 14 of 65

across the board – in U.S. surface finishing markets, jobs and the number of operating 

companies. Even with anecdotal reports of U.S. finishing business moving to Canada or Mexico, 

both countries appear to be experiencing losses as well, although perhaps not of the same 

magnitude. The largest finishing industry chemical and equipment suppliers recently reported 

that capacity utilization in the three NAFTA countries fell off dramatically over four years 

beginning in 2000. The largest decline was for the U.S., which was estimated as dropping off by 

more than a third during this period. 

These capacity challenges are reflected in recent industry revenue and employment measures. In 

an attempt to better understand the revenue and employment picture, we reviewed available U.S. 

Census data. The period from 1977-2002 is instructive and shows several important trends that 

are reviewed below.

Job shop revenues in nominal terms

Chart 4 demonstrates a trend in revenues similar to that of employment above. Revenue shows 

what looks to be strong and steady growth from 1977 through 2000, then a sharp drop in 2001 

and 2002. The graph is in nominal dollars.

Chart 4

Electroplating Job Shop Revenue 

1977-2002

0.0

1000.0

2000.0

3000.0

4000.0

5000.0

6000.0

7000.0

1977197919811983198519871989199119931995199719992001

Year

Revenue (mm)
Future of Finishing, page 15 of 65

Finishing industry revenues in real terms

In contrast to the previous chart, the chart below – in constant year 2000 dollars – generally 

shows reasonably consistent growth from 1977 through 2000, but at a much lower overall rate of 

growth than is suggested by measurement in nominal dollars. Similarly, however, the drop from 

2000 to 2002 is sharp.

Chart 5

Electroplating Job Shop Revenue in 2000 US Dollars

1977-2002

0.0

1000.0

2000.0

3000.0

4000.0

5000.0

6000.0

7000.0

1977197919811983198519871989199119931995199719992001

Year

Revenue (mm)
Future of Finishing, page 16 of 65

Finishing revenue decline greater than U.S. manufacturing base 

Job shop revenues track manufacturing revenues relatively closely for this period, but the falloff 

in finishing since 2000 was steeper than that for manufacturing. This divergence may be an 

aberration, but it also may be a highly important, permanent trend. Data for finishing have not 

been available since 2002 to evaluate whether this relationship is continuing (the U.S. Census for 

2003 combined the job shop NAICS code (332813) with other NAICS codes for heat treating, 

coating, engraving, and other industrial operations).

Chart 6

Electroplating Job Shop Revenue vs. All Manufacturing Revenue 

1977-2002

0

500000

1000000

1500000

2000000

2500000

3000000

3500000

4000000

4500000

1977197919811983198519871989199119931995199719992001

Year

All Manufacturing Revenue (mm)

0.0

1000.0

2000.0

3000.0

4000.0

5000.0

6000.0

7000.0

Job Shop Plater Revenue (mm)

All Manufacturing

Job Shops
Future of Finishing, page 17 of 65

Job shop plating revenue as a share of manufacturing revenues 

This indicator is another way to explore the issue of the performance of the finishing sector vs. 

all manufacturing. It appears that job shops were slowly growing as a share of all manufacturing 

for 1977-1993, with a temporary decrease and strong comeback after the recession of 1990-91. 

They have since remained in slow decline. The decline becomes sharper for 2000-02. It may be 

accurate to say that "as manufacturing goes, so goes surface finishing", but since a high of 1993 

the finishing industry has not been keeping pace with manufacturing generally. 

Chart 7

Electroplating Job Shop Revenue as a Share of All Manufacturing 

Revenue, 1997-2002

0.0000

0.0002

0.0004

0.0006

0.0008

0.0010

0.0012

0.0014

0.0016

0.0018

0.0020

1977197919811983198519871989199119931995199719992001

Year

Share of Revenue
Future of Finishing, page 18 of 65

Job shop employment 

Chart 10 illustrates that finishing operations experienced rather slow growth from 1977 through 

2000, but showed a sharp drop in employment during the period 2001-02;

Chart 8

Electroplating Job Shop Employment

1977-2002

0.0

10.0

20.0

30.0

40.0

50.0

60.0

70.0

80.0

90.0

1977197919811983198519871989199119931995199719992001

Year

Number of Employees (k)
Future of Finishing, page 19 of 65

Job shop plating employment as a share of manufacturing employment 

With respect to the issue of finishing employment vs. all U.S. manufacturing, this chart shows a 

very slow but steady increase through 2000, then a drop. Surface finishing is traditionally more 

employee-intensive than manufacturing generally – the industry’s share of manufacturing 

employment is roughly 0.004, while its share of manufacturing revenues is less than half as 

much, roughly 0.0015. Finishers do have the option – depending on product types and processes 

involved – to substitute technology for labor, but this metric seems to show that technology may 

not be replacing labor at a pace equivalent to U.S. manufacturing generally.

Chart 9

Electroplating Job Shop Employment as a Share of All 

Manufacturing Employment, 1977-2002

0.0000

0.0005

0.0010

0.0015

0.0020

0.0025

0.0030

0.0035

0.0040

0.0045

0.0050

1977197919811983198519871989199119931995199719992001

Year

Share of Employees

The finishing industry will remain extremely fragmented

Competition in the finishing industry has more recently taken on a more extreme dimension. 

Finishers have been under constant pressure by customers in various industry segments to 

provide service at “the China Price”. In more than isolated cases during the recent recession, 

many finishers have serviced customers at unprofitable, unsustainable prices. This response to 

customer demands has exacerbated the problem of pricing power that finishers have traditionally 

faced in various markets, often putting those weaker firms engaging in this practice out of 

business and harming stronger competitors quoting prices that are linked to a more realistic profit 

structure. 

This is dissipating with the recent recovery, but prompts some analysis of the nature of 

competition and concentration in the finishing industry. "Concentration" refers to the degree to 

which market activity in the industry is concentrated among few firms, or dispersed among many 

firms. In effect, the level of concentration reflects whether an industry looks highly competitive 

(many producers competing in the market), oligopolistic (a few competitors) or monopolistic 
Future of Finishing, page 20 of 65

(only one).

Concentration ratios indicate the degree to which market power is concentrated in a few firms.

In Table 1 below, U.S. Census data is used to show concentration among the top 4, top 8, top 20 

and top 50 job shop firms. Economists use the "Herfindahl-Hirschmann Index" to measure 

overall concentration, with a higher HHI index meaning a more concentrated industry. Job shop 

finishers’ HHI for 1992 was 38. Ninety-seven percent of all manufacturing sectors in 1992 had 

HHI's higher than this figure. Put simply, the finishing industry is among the least concentrated

of all manufacturing industries in the United States.

Table 1

Concentration in the Job Shop Electroplating Industry

Year

% of Revenues Accounted for By the -- HerfindahlHerschmann 

Index

4 Largest 

Companies

8 Largest 

Companies

20 Largest 

Companies

50 Largest 

Companies

1992 10 14 21 30 38

1997 5 8 15 25 16

While data for 2002 will not be available until next year, a look at what occurred during the 

1990s – the 5 years from 1992 to 1997 – shows that the finishing industry became even less 

concentrated. The degree to which the industry is so highly competitive would be remarkable to 

those unfamiliar with the history of the industry. Most U.S. manufacturing industries have 

become more, not less concentrated over time.

During the late 1990s and prior to the 2000-01 U.S. manufacturing recession, several major 

efforts were made to roll up individual plating firms into larger companies in order to achieve 

economies of scale and integrate what could be considered niche process specialties into a single 

firm with the potential for servicing much larger and expanding global markets. This was – and 

continues to happen to some degree – in virtually every other manufacturing industry, including 

others which, like surface finishing, are both highly dispersed and relatively less profitable, 

including commercial printing, metal stampings, specialized tool and die making, sheet metal 

fabrication, and others. Of these, commercial printing, concrete block and ready-mix concrete 

have shown signs of concentrating significantly over time.

Since the period 1992-1997 and particularly since the period of 2001-2002, anecdotal evidence 

suggests that the industry may be experiencing a modest trend toward greater concentration, as 

falling profitability and related factors – including the “race to the bottom” pricing behavior 

described above – means failed companies’ accounts are being serviced by fewer, surviving 

firms. However, since even some of the largest companies have also exited the industry, the HH 

index may remain low for the industry as market power remains highly dispersed. There are 
Future of Finishing, page 21 of 65

fewer competitors now than in the past, but larger firms are not necessarily dominating the 

market at the expense of their smaller peers. 

Our review of quantitative as well as qualitative measures of profitability, revenue and 

employment points to historically significant pressures on the surface finishing industry. These 

trends have significant implications for the job shops’ ability to bear additional “structural” or 

operating costs in such areas as raw materials and energy, employee benefits and new 

regulations. 

These issues are discussed below in more detail, focusing specifically on key U.S. and global 

regulatory trends the industry is encountering. The fact that the finishing industry continues to 

be so highly non-concentrated presents major hurdles for the small firm facing rising regulatory, 

energy, raw materials, health insurance and other costs. In this emerging environment, many 

finishing firms may have even less leverage to pass on new costs to customers in the form of 

market-wide price increases.

Trend analysis

Finishers have responded to pricing and foreign competitive pressures in a range of ways. Most 

are not entirely surprising in the manufacturing context:

 cost reductions (reducing workforce, expanding temporary hires)

 quality improvements (minimizing defects and waste with lean manufacturing approaches);

 automation and technology to achieve productivity increases by minimizing labor (if capital 

is available);

 eliminate permanently or temporarily shut down unprofitable processes;

 shift to new processes (partly driven by environmental pressures) depending on the customer 

base, such as non-electrolytic coatings and non-hexavalent chromium replacement 

technologies for certain applications.

The industry is responding in other ways as well. Some reports show finishers forming formal 

corporate alliances locally with other finishers to increase leverage in purchasing from suppliers 

and reduce the costs of process chemicals and other products and services from outside vendors. 

Still other firms are employing relatively higher risk strategies to remain competitive and expand 

into rapidly growing markets. Responses include:

 partnering with foreign-based companies in Asia, India, Mexico or Europe to produce and 

sell into those markets;

 locating new operations in lower-price locales, such as Mexico, that are relatively accessible 

geographically;

 focusing strategy on finishing for products and components that are more logistically difficult 

or costly to source globally;

 building new capabilities beyond just surface finishing that offer much higher value to the 

customer.
Future of Finishing, page 22 of 65

Most if not all these responses appear to be allowing a declining universe of successful finishers 

to compete more effectively in the global marketplace. Reports from finishing firms indicate a 

more widely reported phenomenon is helping their businesses – not all global customers have 

had success in sourcing to foreign, lower-cost labor markets to get the “China Price.” 

Complaints about quality, reliability, intellectual property theft, and other factors have led many 

finishers to regain a foothold recently with customers and markets that appeared to be leaving for 

good just a few short years ago.
Future of Finishing, page 23 of 65

II. Regulatory Trends

Most of the basic environmental laws that apply to the surface finishing industry were enacted 

between 1970 and 1980. During that decade, the Environmental Protection Agency (EPA) was 

established, and key laws were written to regulate:

 air emissions (Clean Air Act 1970)

 water emissions (Clean Water Act, 1977), and

 solid and hazardous waste disposal (Resource Conservation and Recovery Act, 1980)

Based on those laws, the EPA developed and promulgated a set of detailed regulations that had a

significant impact on virtually every industry sector in the U.S.

In the years since, EPA has focused on writing additional specific regulations, fine tuning the 

rules to account for shifts in priorities and for advances in technology. In many cases, the rules

rapidly achieved results that were obvious to anyone – rivers no longer caught fire, lakes became 

clean enough for swimming again, and visibility improved. But beyond a certain point, it 

appeared that further tightening of the limits sometimes produced diminishing returns, or could 

even make matters worse. For example, the hazardous waste disposal rules, as written, were 

found to promote disposal and inhibit recycling, wasting valuable resources and energy. Other 

rules were found to have unintended consequences. Rules that forced facilities to install tertiary 

pollution control equipment to reduce emissions at one point in the system had the potential to 

create problems elsewhere – the toxic and greenhouse gas emissions associated with the 

generation of electricity needed to operate the additional control equipment could offset any 

improvement that the equipment could provide.

Notwithstanding these inherent limitations, the U.S. has largely maintained this basic regulatory 

strategy of focusing on manufacturing processes, limiting effluents at the “end of the pipe.” But 

other countries, most notably the European Union (EU), have been gradually evolving a very 

different approach. 

The European framework is based on two fundamental principles:

 Life-cycle thinking. Every material selection decision, every product design decision, 

and every manufacturing process, sets in motion a train of consequences. These 

consequences each have a set of impacts on humans and on the environment. All of these 

impacts matter, and must be taken into account.

 Producer responsibility. The original producer of the material, designer of the product, 

or manufacturer is ultimately responsible for the entire chain of consequences.

It takes a more “whole system” viewpoint than the U.S. model. As a growing and increasingly 

integrated global economy exerts more pronounced effects on a finite planet, and as we begin to 

appreciate the interconnectedness of ecological systems, the European approach may ultimately 

represent the future of environmental regulation in all nations, including the U.S.

At present, EU regulations exert a primarily indirect effect on finishing firms located in the U.S. 

Products destined for export to the European market may require new materials or technologies 

to comply with European requirements. For example, the EU has placed restrictions on products 

containing cadmium and hexavalent chromium, both commonly used in finishing processes. As 

more and more materials become affected (especially by the REACH framework that imposes 
Future of Finishing, page 24 of 65

significant burdens on virtually all materials, existing as well as new, commonly used in 

manufactured products), U.S. firms’ customers that export to Europe will begin demanding 

alternative coatings. Since customers are not likely to produce different versions of their 

products for the EU and U.S. markets, finishers may have to phase out processes they have used 

for decades to retain even a share of the U.S. domestic market.

International regulations are not the only changes that will affect U.S. finishers in the coming 

years. Two developments on the domestic front will also require their attention. The first is an 

increased level of concern for the threat posed by the malevolent use of chemicals. Users of any 

potentially dangerous chemicals are likely to be required to comply with new homeland security 

regulations. The second is an increased level of public awareness of the use and release of 

chemicals by individual facilities. As advanced information tools are being developed and 

deployed on the Internet, it is becoming easier for anyone to find out about the emissions profile 

of facilities in their community, and how their emissions are changing over time. Manufacturers 

in all sectors can expect to be operating under much greater public scrutiny in the years ahead.

In this section of the report, we will review existing U.S. environmental regulations, describe the 

emerging international trends, and attempt to project how these current trends are likely to 

coalesce into the future framework within which U.S. finishing firms will be operating in the 

coming decades.

Overview of existing U.S. regulations

Air pollution control – the Clean Air Act

The Clean Air Act (CAA) is the comprehensive Federal law that regulates air emissions from 

area, stationary, and mobile sources. The CAA and its amendments are designed to “protect and 

enhance the nation's air resources so as to promote the public health and welfare and the 

productive capacity of the population.” The CAA consists of six sections, known as Titles, 

which direct EPA to establish National Ambient Air Quality Standards (NAAQS), and for EPA 

and states to implement, maintain, and enforce these standards through a variety of mechanisms. 

It includes programs to address smog, acid rain, stratospheric ozone protection, and air toxics. 

Most of the sections applicable to metal facilities are found in Titles I and V. 

Note that while the federal law establishes the basic standards, it is generally up to state and local 

governments to manage and enforce many of its requirements. 

CAA Title I

Criteria pollutants. Pursuant to Title I of the CAA, EPA has established national ambient air 

quality standards (NAAQSs) to limit levels of “criteria pollutants,” including: 

 carbon monoxide

 lead

 nitrogen dioxide

 particulate matter

 ozone

 sulfur dioxide
Future of Finishing, page 25 of 65

Geographic areas that meet NAAQSs for a given pollutant are designated as "attainment 

areas"; those that do not meet NAAQSs are designated as "nonattainment areas". EPA 

provides an on-line resource called the Green Book that lists the status of each area of the U.S.

for each pollutant.

Under Section 110 and other provisions of the CAA, each state must develop a State 

Implementation Plan (SIP) to:

 identify sources of air pollution, and

 determine what reductions are required to meet federal air quality standards

Revised NAAQSs for particulates and ozone became effective in 2004. This may significantly 

affect facilities that are large sources of particulates (soot) and of volatile organic compounds or 

nitrogen oxides (which contribute to ozone formation), particularly those in nonattainment areas. 

New sources. Title I also authorizes EPA to establish New Source Performance Standards 

(NSPS). These are nationally uniform emission standards for new and modified stationary 

sources that fall within particular industrial categories. The standards are based on the pollution 

control technology available to that category of industrial source (see 40 CFR Part 60).

Hazardous Air Pollutants. Also under Title I, EPA establishes and enforces National Emission 

Standards for Hazardous Air Pollutants (NESHAPs). These are nationally uniform standards 

oriented toward controlling materials that appear on a specific list. Such materials are 

collectively known as hazardous air pollutants (HAPs).

Section 112(c) of the CAA directs EPA to develop a list of source categories that emit any of 188 

HAPs, and to develop regulations for these categories of sources. To date, EPA has listed 185 

source categories, and has developed a schedule for establishing emission standards. The 

emission standards are being developed for both new and existing sources.

NESHAPs are based on so-called “maximum achievable control technology” (MACT). The 

MACT for a particular source category is defined as the control technology achieving the 

"maximum degree of reduction" in the emission of the HAPs when cost and other factors are 

taken into account. Other designations (such as "BACT", or best available control technology, 

and "LAER" or lowest achievable emissions reduction) are used to specify technologies 

satisfying other criteria, like the maximum reduction without regard to cost. The distinctions can 

get complicated. The important point here is that cost is factored into MACT determinations. 

The regulations don't specify which technology to use, but they do require that whatever 

technology is used must achieve at least as much of an emissions reduction as the MACT can 

provide.

CAA Title V

Title V of the Federal Clean Air Act Amendments of 1990 (CAA) required development of 

permit programs which would require major sources of air emissions throughout the U.S. to 

obtain an operating permit. These operating permits are often referred to as "Title V Permits," or 

"Part 70 permits" since EPA issued rules for State Title V Programs under 40 CFR, Part 70. 
Future of Finishing, page 26 of 65

In general, a Part 70 permit is required of those facilities with the Potential To Emit (PTE) of 100 

TPY or more of any criteria pollutant (NOx, CO, SO2, Ozone, VOCs, PM10, and Lead), or 10 

TPY or more of any one Hazardous Air Pollutant (HAP), or 25 TPY or more of any combination 

of HAPs. Certain other sources, i.e., any affected source subject to the Acid Rain Rules, and any 

solid waste incinerator subject to Section 129(e) of the CAA, are required to obtain a Part 70 

permit regardless of their PTE. In addition, sources subject to a New Source Performance 

Standard (NSPS) or a National Emissions Standard for a Hazardous Air Pollutant (NESHAP), 

may be specifically required by the NSPS or NESHAP to obtain a Part 70 permit. 

The following is a list of the NESHAPs most applicable to metal finishing facilities. The 

referenced web pages contain links to the original rules and any amendments.

Cleaning/Degreasing

 National Emissions Standards for Cleaning with Halogenated Solvents. (Dec. 2, 1994). 

 National Emission Standards for Aerospace Manufacturing and Rework Facilities. (Sept. 

1, 1995). 

Electroplating/Anodizing

 National Emission Standards for Chromium Emissions From Hard and Decorative 

Chromium Electroplating and Chromium Anodizing Tanks. (January 1995) 

Surface Coating/Painting

 Standards of Performance for Surface Coating of Metal Furniture. (4May 23, 2003) 

 Standards of Performance for Automobile and Light-Duty Truck Surface Coating 

Operations. (April 26, 2004)

 Standards of Performance for Metal Coil Surface Coating. (June 10, 2002) 

 Standards of Performance for Industrial Surface Coating: Surface Coating of Plastic Parts 

for Business Machines. (April 26, 2004). 

 Miscellaneous Metal Parts and Products Surface Coating. (January 2, 2004)

Air Pollution Permits

Most metal finishing facilities are required to obtain an air pollution permit and to file for a new 

permit every five years or sooner. The requirement may be based on federal or state regulations, 

or both. Also, many regional and local governments have their own requirements. 

Federal and state requirements apply to the following types of operations:

 Facilities covered by the chromium and/or halogenated solvent “MACT” standards,

 Facilities with operations such as painting in addition to other metal finishing operations,

 Facilities that use volatile materials such as degreasing solvents,

 Facilities that use plating chemicals with air toxics,

 Facilities with a boiler or furnace that use #2 fuel oil,

 Facilities located in a non-attainment zone for air quality, and

 Facilities or operations that generate or contribute emissions of one or more of six 

criteria pollutants:

o Lead

o Particulate matter (PM10),
Future of Finishing, page 27 of 65

o Sulfur dioxide (SO2, released from burning #2 fuel oil),

o Nitrogen dioxide (NOX),

o Carbon monoxide, and

o Ozone, (ground level smog).

Different types of air permits apply, based upon the pounds of emission and the type of air 

pollutant emissions from your facility or operations. Again the pounds of emissions are 

calculated from the MTE and PTE mentioned earlier.

The General Operating Permit is required for most small or medium-sized industries that have 

emissions below certain thresholds or because they are covered by a specific Federal 

requirement.

A Major Source Air Operation Permit is also called a Title V Permit and is required for 

companies that have large or very large air emissions from their facilities. The Synthetic Minor 

Air Operation Permit is for sources that may have large potential emissions, but can take 

restrictions to stay below major source levels. It may also be referred to as a FESOP or Federally 

Enforceable State Operating Permit.

Generally, air-operating permits are good for 5 years, unless there are significant changes 

that require either a new permit or a permit modification. The date of expiration for the original 

permit, however, remains the same if the permit is just revised.

If a facility is a new source of air emissions, installing new equipment, or making configuration 

or process changes that may have an effect on air emissions, they must get a construction 

permit.

For example, if a facility is:

 Installing a new tank line,

 Changing or installing a new coating application systems,

 Installing a new cleaning system,

 Installing a new paint booth,

 Installing control devices, or

 Proceeding with other process additions or changes that affect air emissions.

Construction permits are generally good for 18 months, but vary due to state regulations.

CAA-Related State Regulations

In addition to federal air requirements, metal finishing facilities may be subject to a variety of 

state air regulations, including requirements to submit source registrations, obtain permits, report 

types and quantities of air emissions, and/or use particular emission control technologies.

Because air regulations are particularly complex and rapidly changing, a metal finisher should 

seek advice from their state agency or private counsel to determine which federal and state air 

emission regulations may apply. Local points of contact can be attained by using the NMFRC’s 

Air Pollution Resource Locator.

Future CAA Regulations
Future of Finishing, page 28 of 65

Under the Clean Air Act, EPA must promulgate standards to control the emissions of hazardous 

air pollutants (HAPs) for plating and polishing operations. As part of its effort to develop the 

new rule, in 2006 EPA sent out an information request questionnaire to hundreds of metal 

finishing facilities and collected information about air emissions and finishing operations to 

identify generally available control technology (GACT) that may be needed to control emissions 

for the plating and polishing source category. The surface finishing industry (www.nasf.org) has 

been working closely with EPA to clarify the information collected in the surveys and provide 

additional information on finishing processes and operations. 

Based on the Agency’s statutory authority and a series of technical and policy discussions with 

industry, EPA is focused primarily on emissions of:

 cadmium, 

 chromium, 

 cyanide, 

 lead, 

 manganese, and 

 nickel.

EPA is also considering possible control options that could include wetting agents to lower 

surface tension, management and housekeeping practices, covers for inactive tanks, filters for 

polishing and thermal spray operations, as well as possible ventilation, mist eliminators and 

scrubbers.

EPA is expected to propose the new air emissions rule in 2007 and issue the final rule in 2008. 

Wastewater pollution control – the Clean Water Act (CWA)

The primary objective of the Clean Water Act (CWA) is to restore and maintain the chemical, 

physical, and biological integrity of the nation's surface waters. Pollutants regulated under the 

CWA include "priority" pollutants, including various toxic pollutants; "conventional" pollutants, 

such as biochemical oxygen demand (BOD), total suspended solids (TSS), fecal coliform, oil and 

grease, and pH; and "non-conventional" pollutants, including any pollutant not identified as 

either conventional or priority.

The CWA regulates both direct dischargers and indirect discharges. The National Pollutant 

Discharge Elimination System (NPDES) program (CWA §402) controls direct discharges into 

navigable waters. Direct discharges or "point source" discharges are from sources such as pipes 

and sewers. NPDES permits, issued by either EPA or an authorized State (EPA has presently 

authorized forty-six States to administer the NPDES program), contain industry-specific, 

technology-based and/or water quality-based limits, and establish pollutant monitoring and 

reporting requirements. A facility that intends to discharge into the nation's waters must obtain a 

permit prior to initiating its discharge. A permit applicant must provide quantitative analytical 

data identifying the types of pollutants present in the facility's effluent. The permit will then set 

forth the conditions and effluent limitations under which a facility may make a discharge. 

A NPDES permit may also include discharge limits based on Federal or State water quality 

criteria or standards that were designed to protect designated uses of surface waters, such as 
Future of Finishing, page 29 of 65

supporting aquatic life or recreation. These standards, unlike the technological standards, 

generally do not take into account technological feasibility or costs. Water quality criteria and 

standards vary from State to State, and site to site, depending on the use classification of the 

receiving body of water. Most States follow EPA guidelines that propose aquatic life and human 

health criteria for many of the priority pollutants. 

Another type of discharge that is regulated by the CWA is one that goes to a publicly-owned 

treatment works (POTWs). The national pretreatment program (CWA 307(b)) controls the 

indirect discharge of pollutants to POTWs by "industrial users." Facilities regulated under 307(b) 

must meet certain pretreatment standards. The goal of the pretreatment program is to: 

1. protect municipal wastewater treatment plants from damage that may occur when 

hazardous, toxic, or other wastes are discharged into a sewer system and 

2. protect the quality of sludge generated by these plants. 

Discharges to a POTW are regulated primarily by the POTW itself, rather than the State or EPA. 

EPA has developed technology-based standards for industrial users of POTWs. Different 

standards apply to existing and new sources within each category. " 

Categorical" pretreatment standards applicable to an industry on a nationwide basis are 

developed by EPA. In addition, another kind of pretreatment standard, "local limits," are 

developed by the POTW in order to assist the POTW in achieving the effluent limitations in its 

NPDES permit. 

Regardless of whether a State is authorized to implement either the NPDES or the pretreatment 

program, if it develops its own program, it may enforce requirements more stringent than Federal 

standards. 

Electroplating Categorical Standards (40 CFR 413)

Electroplating Categorical Standards (40 CFR 413) are applicable to wastewater from these six 

specific operations: 

 Electroplating 

 Electroless Plating

 Anodizing 

 Coatings 

 Chemical Etching and Milling 

 Printed Circuit Board Manufacturing

Most facilities that were initially covered by the Electroplating Categorical Standards (1984 

compliance date for most facilities) were subsequently covered by the Metal Finishing 

Categorical Standards (1986 compliance date for most facilities). Excluded from the Metal 

Finishing rules are all existing indirect discharging job shops electroplaters and independent 

printed circuit board manufacturers. For these two groups of facilities, the Electroplating 

Standards still apply. 
Future of Finishing, page 30 of 65

The electroplating pretreatment standards for existing dischargers (Part 413) include an 

alternative mass-based standard for printed wiring board manufacturing facilities. The standard is

expressed in units of milligrams per square meter of boards processed per operation. An 

operation is any "electroplating" step (e.g., electroless copper plating, copper sulphate plating) 

that is followed by a rinsing step. These standards can only be used based upon prior agreement 

between a metal finishing facility and the regulatory authority. 

One purpose of the mass-based standards is to encourage the implementation of pollution 

prevention. For example, a facility that has a concentration-based copper limitation has less 

regulatory compliance incentive to install a drag-out tank and counterflow rinse than a facility 

with a mass-based limitation. That is because a facility with a concentration limit has to treat the 

wastewater to the same low concentration level regardless of the incoming flow rate and 

concentration. Alternatively, the facility with the mass-based standard may reduce the 

wastewater flow and mass of copper entering the treatment system and not have to achieve as 

low of and effluent concentration. 

For most affected facilities, the Electroplating Standards are administered by a local or state 

wastewater agency. 

Metal Finishing Categorical Standards (40 CFR 433)

The Metal Finishing Category covers wastewater from 46 unit operations : the six operations 

covered by the Electroplating Categorical standards, plus an additional 40 operations. If any of 

the six electroplating operations are present, then the Metal Finishing standards apply to 

wastewater from any of the 46 listed metal finishing operations. Also, all direct discharge

electroplating and metal finishing facilities are covered by the Metal Finishing Categorical 

Standards (i.e., the Electroplating Standards apply only to indirect dischargers). 

Excluded from the Metal Finishing rules are all existing indirect discharging job shops

electroplaters and independent printed circuit board manufacturers. For these two groups of 

facilities, the Electroplating Standards still apply. 

For most affected facilities, the Metal Finishing Standards are administered by a local or state 

wastewater agency. 

General Pretreatment Regulations (40 CFR 403)

The General Pretreatment Regulations affect all metal finishing and electroplating manufacturing 

facilities that discharge process wastewater to a POTW. 

 All facilities must comply with the Prohibited Discharge rules (40 CFR 403.5). 

 Certain provisions affect only facilities that are regulated by Categorical Pretreatment 

Standards. 

 Certain provisions apply to industrial users that are not regulated by Categorical 

Standards. For these provisions to apply, the industrial user must be a significant noncategorical industrial user. 
Future of Finishing, page 31 of 65

State and Local Regulations

A metal finishing or electroplating facility that discharges process wastewater to a city sewer 

system (publicly owned treatment works, or POTW) is an indirect discharger and is subject to 

pretreatment standards. Although pretreatment standards are mostly based on federal laws, 

discharges to a POTW are regulated primarily by the POTW itself, rather than the State or EPA. 

In small municipalities, the State or Regional EPA may be the regulating agency ("Control 

Authority").

POTW’s must enforce industrial discharge requirements that are at least as stringent as those 

found in the federal regulations (i.e., 40 CFR 413 and 433 for metal finishers). Many POTW’s 

have chosen to enforce more stringent standards for one or more parameters. In most cases, the 

lower limits are based on:

 POTW sludge disposal criteria and/or

 Correspondingly low limits for specific heavy metal pollutants regulated in the NPDES 

permit of the POTW.

Low POTW limits are increasingly being imposed state agencies as a result of total maximum 

daily load (TMDL) studies. A TMDL is a technical analysis that determines the maximum 

loading of a pollutant of concern a water body can receive and still both attain and maintain its 

water quality standards; and allocates this allowable loading to pollutant sources in the 

watershed. A TMDL takes a watershed approach in determining the pollutant load that can be 

allowed in a given lake or stream. By taking a watershed approach, a TMDL considers all

potential sources of pollutants, both point (e.g., POTWs) and non-point sources (e.g., stormwater 

runoff). 

With respect to sludge disposal, POTWs that would like to use land spreading as a disposal 

option, must meet relatively strict standards for metals such as cadmium. Since metals 

concentrate into the POTW sludge as a result of biological treatment, the POTW must regulate 

the sources of the metals, including industrial discharges.

Future Wastewater Regulations

The electroplating and metal finishing categorical regulations have been in effect for more than 

20 years, without any significant changes. In 1995 (and subsequently revised in 2001) EPA 

proposed Metal Products and Machinery category regulations that would have further regulated 

approximately 89,000 U.S facilities, including electroplating and metal finishing plants. The 

MP&M rule would have lowered the allowable metals discharge concentrations significantly. 

However, when the final rule was signed on February 14, 2003, it scaled back significantly the 

number of regulated entities from the initial proposal. The revised rule now applies to about 

2,400 facilities that generate oily wastewater (only facilities that discharge oil and grease and 

total suspended solids to rivers and streams), and therefore is no longer applicable to most 

electroplating and metal finishing shops.
Future of Finishing, page 32 of 65

Given the EPA MP&M decision regarding electroplating and metal finishing facilities, it does 

not appear that federal wastewater regulations will change in the near future. However, 

individual facilities may find that local and state agencies tighten discharge limits requirements.

Hazardous waste – the Resource Conservation and Recovery Act (RCRA)

The Resource Conservation and Recovery Act or RCRA is the central law that gave EPA the 

authority to control hazardous waste from the "cradle-to-grave." This includes the generation, 

transportation, treatment, storage, and disposal of hazardous waste. 

Under RCRA, hazardous waste generators are required to register and obtain an EPA 

identification number, and abide by a strict set of rules regarding waste accumulation, handling, 

storage, and disposal of hazardous waste. RCRA also has provisions covering employee 

training, recordkeeping, reporting, and emergency procedures.

RCRA hazardous waste regulations apply to all metal finishing shops, although the specific rules 

vary depending on the quantity of hazardous waste generated and to a lesser extent the state in 

which the facility is located. Conditionally exempt small quantity generators (less than 100 kg 

per month for most wastes) and small quantity generators (between 100 kg and 1000 kg per 

month for most wastes) have fewer rules to follow than large quantity generators (1000 kg per 

month for most wastes). State rules closely follow the federal regulations, although some 

differences exist (see below).

For the RCRA hazardous waste rules to be applicable to a particular substance, it must first be 

identified as a "hazardous waste." Generators must determine whether their generated material is 

first, a "waste," second, a "solid waste," and last, a "hazardous waste." There are two methods for 

making this third determination. The substance may be a "listed" waste, one of hundreds of 

substances that EPA has placed on a list of hazardous wastes. Alternatively, the substance may 

be a "characteristic" hazardous waste, one that through testing exhibits any of the following four 

hazardous waste characteristics: ignitability, corrosivity, reactivity, or toxicity.

Common listed hazardous wastes generated by metal finishing facilities include:

 F001 through F005 – Specific spent solvents and still bottoms.

 F006 – Wastewater treatment sludge from plating operations.

 F007 through F009 – Spent cyanide based plating, cleaning and stripping solutions and 

associated tank sludges.

 F019 – Wastewater treatment sludges from aluminum finishing.

In addition to the above listed wastes, metal finishing facilities commonly generate 

“characteristic” hazardous wastes, including spent solutions that are hazardous due to corrosivity 

(e.g., cleaning solutions) or toxicity (e.g., toxic metal-bearing solutions).

State Hazardous Waste Rules

Although RCRA is a Federal statute, many States implement the RCRA program. Currently, EPA 

has delegated its authority to implement various provisions of RCRA to 46 of the 50 States. 

For a state to be delegated RCRA enforcement authority, which is referred to as "RCRA 

authorization," EPA must approve the state's hazardous waste management rules. State 

hazardous waste management rules must be at least as stringent as, and consistent with, the 
Future of Finishing, page 33 of 65

federal RCRA rules in order for the state to receive RCRA authorization. Many states have 

added hazardous waste management rules that go beyond the federal standards. State hazardous 

waste rules have been complied by NCMS (see HWRL).

Future Hazardous Waste Regulations

Federal and state hazardous wastes regulations will probably not change significantly in the near 

future for metal finishers since there are no major hazardous waste regulatory efforts underway 

that will affect finishers. However, some fine tuning of the rules is taking place that may make it 

easier to recover waste products than treat/dispose of them. For example, in 2000, EPA passed a 

rule that allows metal finishing facilities to accumulate F006 waste on-site for a longer than 

normal time period, if the waste is shipped to a recovery facility. This change on the Federal 

level (sates are not required to adopt this change) is intended to promote recycling by facilities 

that otherwise could not accumulate a sufficient quantity of sludge for economical recycling.

Another change that may have a broader impact involves a proposed rule to modify the 

definition of solid waste (by definition, a material must be a “solid waste” to meet the definition 

of a hazardous waste). The proposed rule provides exclusions for: 

 materials that are generated and reclaimed under the control of the generator;

 materials that are generated and transferred to another person or company for reclamation 

under specific conditions; and

 materials that EPA deems non-waste through a case-by-case petition process.

The proposal also defines legitimate recycling to ensure that only legitimate recycling activity 

benefits from the streamlined requirements, not treatment or disposal under the guise of 

recycling.

The proposed new definition of solid waste could facilitate more recycling of F006 wastes. 

Under the proposed new definition, sludge that is reclaimed for metals recovery would not be 

considered "discarded", and would not, therefore, be subject to hazardous waste regulations 

(provided that plating shops and reclamation facilities meet a set of conditions regarding the 

management and recycling of the sludge).

Toxic chemical reporting – EPCRA

Many coating facilities are subject to one or more provisions of the Emergency Planning and 

Community Right-to-Know Act (EPCRA). The purpose of this law is to require industry to 

provide information about the type, amount, and location of chemicals they keep on-site and to 

report information about releases of toxic chemicals from their facility. Local planners and 

response personnel use this information to respond to chemical emergencies and this information 

is available to the public. 

Chemical Reporting (EPCRA Section 311)

OSHA's Hazard Communication Standard (HCS) requires facilities to procure or prepare 

material safety data sheets (MSDSs) for the hazardous chemicals found at the facility 29 CFR 

Section 1910.1200 . The MSDS contains important health and safety information. Any facility 

that is required by OSHA to prepare or have available an MSDS for a hazardous chemical is 

subject to EPCRA Sections 311 and 312 if the chemical is present on site at any one time in 

excess of threshold levels. There is no list of hazardous chemicals subject to reporting. The key 
Future of Finishing, page 34 of 65

to determining whether or not a chemical is considered hazardous is if it meets OSHA's 

definition of a hazardous chemical in 29 CFR 1910.1200(c).

Section 311 requires facilities that must prepare (or acquire) material safety data sheets (MSDS) 

under Occupational Safety and Health Administration (OSHA) regulations to submit either 

copies of their MSDSs or a list of MSDSs chemicals to their: 

 Local Emergency Planning Committee (LEPC) 

 State Emergency Response Commission (SERC), and 

 Local fire department with jurisdiction over the facility 

If the facility owner or operator chooses to submit a list of MSDS chemicals, the list must 

include the chemical or common name of each substance and must identify the applicable hazard 

categories. These hazard categories are: 

 Immediate (acute) health hazard 

 Delayed (chronic) health hazard 

 Fire hazard 

 Sudden release of pressure hazard 

 Reactive hazard 

If a list is submitted, the facility must submit a copy of the MSDSs for any chemical on the list 

upon the request of the LEPC or SERC. Also EPA has established threshold quantities for 

hazardous chemicals below which no facility must report. The current thresholds for Section 311 

are: 

 For extremely hazardous substances: 500 pounds or the threshold planning quantity, 

whichever is lower. 

 For all other hazardous chemicals: 10,000 pounds 

The initial submission of the MSDSs or a list of MSDSs chemicals was due on October 17, 1987. 

Facilities newly covered by the OSHA regulations must submit MSDSs or a list of MSDSs 

chemicals within three months after they become covered. 

A MSDS or a revised list must be provided when new hazardous chemicals become present at a 

facility in quantities at or above the established threshold levels after the deadline. A revised 

MSDS must be provided to update the original MSDS if significant new information is 

discovered about the hazardous chemical. 

Chemical Reporting (EPCRA Section 312)

EPCRA Section 312 requires submission of an annual report providing information on hazardous 

chemicals on-site to the SERC, LEPC, and local fire department. This report is due every March

1 and covers the previous calendar year. EPA created two types of inventory forms for facilities 

to use to fulfill this requirement: 
Future of Finishing, page 35 of 65

 Tier I-- requires facilities to report general information on the amount and location of 

hazardous chemicals. 

 Tier II-- requires more detailed information on each hazardous chemical. 

Facilities use the Tier II form to report chemical-specific information -- the name, chemical 

abstract service number (CAS), physical and health hazards, inventory amounts, and storage 

conditions and locations (40 CFR Section 370.25). Facilities may submit a Tier II in lieu of a 

Tier I. 

While federal regulations only require the submission of a Tier I form, EPA encourages, and 

some states require, the use of the Tier II form. States may also have lower thresholds that trigger 

Tier reporting. States may impose fees for processing Tier forms or even have their own forms 

that facilities must use to fulfill Section 312 requirements. 

The specific threshold quantities established by EPA for Section 312 for hazardous chemicals, 

below which no facility must report, are: 

 extremely hazardous substances: 500 pounds or the threshold planning quantity, which is 

lower. 

 all other hazardous chemicals: 10,000 pounds. 

The information submitted by facilities under Sections 311 and 312 must be made available to 

the public by LEPCs and SERCs during normal working hours.

Toxic Chemical Reporting: EPCRA Section 313

The purpose of the EPCRA Section 313 reporting requirement is to inform the public and 

government officials about routine releases of toxic chemicals to the environment. It will also 

assist in research and the development of regulations, guidelines, and standards. 

Reports are sent to EPA and designated state agencies. EPA established and maintains a national 

toxic chemical inventory (TRI). The public is able to access this database using the Internet and 

other means. 

Under TRI rules, applicable facilities are required to submit a “Form R” for specified chemicals. 

The form must be submitted to EPA and designated state officials annually by July 1, covering 

the preceding calendar year. 

Facilities are subject to Section 313 reporting if it meets all three of the following criteria: 

 Manufacturing is conducted (SIC codes 20 through 39) 

 10 or more full-time employees, 

 Facility uses toxic chemicals in amounts greater than "threshold" quantities (specified 

amounts of toxic chemicals used during the calendar year that trigger reporting 

requirements)
Future of Finishing, page 36 of 65

There are over 500 chemicals and chemical categories on the Section 313 chemical list. 

Chemicals commonly reported by metal finishing facilities include: cadmium, chromium, lead, 

and cyanide.

Toxic Chemical Reporting State Requirements

Most states closely follow the Federal reporting requirements for EPCRA sections 311, 312, and 

313. Some states have additional reporting requirements. NCMS has complied and maintains 

state TRI rules on the Toxic Release Inventory State Resource Locator.

The Toxic Substances Control Act (TSCA)

Overview

The Toxic Substance Control Act (TSCA) of 1976 was enacted to provide information about all 

chemicals and to control the production of new chemicals that might present an unreasonable 

risk of injury to health or the environment. TSCA authorizes EPA to require testing of chemical 

substances, both old and new, that enter the environment. TSCA also provides authority to 

regulate the manufacturing, processing, and use of chemicals. Because TSCA gives EPA such 

broad powers, the law covers virtually all manufactured and natural chemicals.

EPA maintains and publishes the TSCA Inventory (more than 75,000 substances), which 

includes a list of chemicals manufactured, imported, or processed for commercial purposes in the 

U.S. 

TSCA differs from other federal laws in that the Act requires testing and reporting of chemicals 

with unknown toxic or dangerous characteristics before the chemical reaches the consumer 

marketplace.

TSCA has two regulatory features:

 Acquisition of information by EPA to identify and evaluate potential hazards from 

chemical substances. This is done by requiring manufacturers to:

o Submit a Premanufacture Notice (PMN) before producing or importing a new 

chemical substance.

o Follow "significant new use rules" (SNUR) before manufacturing chemical 

substances that may increase human or environmental exposure.

o File various reports and studies with EPA on production, health, and safety issues 

related to chemical substances.

 Regulation of the production, use, distribution, and disposal of toxic substances when a 

significant risk is posed to human health and the environment (e.g., PCBs, asbestos, lead 

paint, and hexavalent chromium used in water conditioning are all regulated under 

TSCA).

Key TSCA Provisions for Metal Finishers

TSCA standards may apply at any point during a chemical’s life cycle. Under Section 5, EPA 

has established an inventory of chemical substances. If a chemical is not already on the 

inventory, and has not been excluded by TSCA, a premanufacture notice (PMN) must be 

submitted to EPA prior to manufacture or import. The PMN must identify the chemical and 
Future of Finishing, page 37 of 65

provide available information on health and environmental effects. If available data are not 

sufficient to evaluate the chemical's effects, EPA can impose restrictions pending the 

development of information on its health and environmental effects. EPA can also restrict 

significant new uses of chemicals based upon factors such as the projected volume and use of the 

chemical. 

Under TSCA section 5(a)(2), after a chemical substance is placed on the TSCA Inventory, 

additional information for the chemical may be discovered that could affect human health or the 

environment that was not anticipated at the time the substance was initially placed in the 

Inventory or during PMN review. If EPA determines that a certain use of a chemical listed in the 

Inventory would constitute a "significant new use" that increases human or environmental 

exposure, EPA may issue a SNUR. A SNUR applies to any company (including small or large 

entities) who intends to engage in any activity described in the rule as a ‘‘significant new use.’’ 

Before promulgating a SNUR EPA requests comments and performs due diligence to determine 

which activities are existing.

A SNUR requires that anyone who wants to manufacture or process the chemical substance for a 

use that EPA has determined to be a "significant new use" must give 90 days' prior notice 

(significant new use notice, SNUN) to EPA. EPA then has the opportunity to evaluate the 

intended use, and, if necessary, to prohibit or limit that activity. Section 5(a)(2) of TSCA states 

that EPA’s determination that a use of a chemical substance is a significant new use must be 

made after consideration of all relevant factors including:

 The projected volume of manufacturing and processing of a chemical substance.

 The extent to which the use changes the type or form of exposure of humans or the 

environment to a chemical substance.

 The extent to which the use increases the magnitude and duration of exposure of human 

beings or the environment to a chemical substance.

 The reasonably anticipated manner and methods of manufacturing, processing, 

distribution in commerce, and disposal of a chemical substance. TSCA section 5(a)(2) 

authorizes EPA to consider any other relevant factors in addition to the factors 

enumerated in the bulleted items.

EPA’s experience to date is that, in response to the promulgation of over 1,000 SNURs (see 40 

CFR 721, the Agency receives on average only 10 SNUNs per year.

TSCA section 5(a)(2) also authorizes EPA to consider any other relevant factors in addition to 

the factors enumerated in the bulleted items. In effect, a SNUR can turn an existing chemical 

into a "new" chemical under TSCA and it can apply to processors as well as manufacturers and 

importers.

Under TSCA Section 6, EPA has broad authority to issue rules regulating a chemical substance 

or mixture if "there is a reasonable basis to conclude" that its manufacture, distribution in 

commerce, use, or disposal "presents or will present an unreasonable risk of injury to health or 

the environment." Under Section 6, the EPA Administrator may take a variety of actions to 

control or mitigate the risk posed by a chemical, including prohibiting the manufacture, import, 

processing, or distribution of a chemical substance. Chemicals regulated under Section 6 include 
Future of Finishing, page 38 of 65

PCBs, chlorofluorocarbons (prohibiting their use as aerosol propellants), asbestos, lead-based 

paint, certain substances in metalworking fluids, and hexavalent chromium in cooling tower 

chemicals. 

Future TSCA Regulations

At present, TSCA has only a peripheral impact on metal finishers potentially affecting facility 

infrastructure (e.g., PCB transformers, asbestos insulation, and use of hexavalent chromium in 

cooling towers) and machining operations. However, TSCA may have a broader and more

significant bearing in the future, especially if EPA’s future regulatory strategy takes advantage of 

the broad powers it has under TSCA and follows the chemical/product strategy being 

implemented in Europe. Discussed below are some examples.

Significant New Use Rule (SNUR). In 2007 EPA promulgated a SNUR for elemental mercury 

used in certain automobile light control systems (e.g., interior trunk and hood lights) (see Federal 

Register: October 5, 2007 Volume 72, Number 193). The rule requires those who intend to use 

mercury in the manufacture of these switches to notify EPA, who then has the opportunity to 

evaluate the intended use, and, if necessary, to prohibit or limit that activity. This regulation was 

promulgated despite the fact that U.S. and foreign automakers phased out the use of mercury 

switches by 2003. EPA’s rationale for promulgating the rule was that mercury use in switches 

could be reinitiated in the future.

It seems feasible that a similar approach could be taken by EPA that would affect the use of 

certain coating materials currently used by metal finishers. For example, EPA could promulgate 

a rule that would limit the use of hexavalent chromium or nickel coatings if they met the 

significant new use definition; for example, if new or increased hazards were discovered.

Perfluoroalkyl Sulfonates Fume/Mist Suppressants. A significant new use rule (SNUR) was 

promulgated by EPA to cover the chemical substance identified as chromate(3-), bis[7-

[(aminohydroxyphenyl)azo]-3-[[5-(aminosulfonyl)-2-hydroxyphenyl]azo]-4-hydroxy-2-

naphthalene-sulfonato (3-)]-, trisodium (9CI) (PMN P-95–1576;CAS No. 118716–62–4) (40 

CFR 721.9582). That rule was amended in October 2007 to include certain additional 

perfluoroalkyl sulfonate (PFAS) chemicals, including those used in fume/mist suppressants used 

by the plating industry (Federal Register, Vol. 72, No. 194, October 9, 2007). In the amendment, 

EPA specifically excluded fume/mist suppressants from the significant new use rule. However, 

EPA also stated that they are concerned about potential releases this specific chemical use and 

“will continue to work with state agencies and industry to identify best management practices for 

minimizing the release of this PFAS surfactant.”

Nanomaterials. Under TSCA substances are considered “existing” by virtue of their listing on 

the Inventory. Historically, existing chemicals are less likely to be investigated and regulated 

under TSCA than new chemicals. For engineered nanoscale materials, there is debate as to 

whether these are existing or new materials. Traditionally, EPA has not defined a substance as 

“new” under TSCA if its molecular structure is the same as a chemical already on the TSCA 

Inventory. Some have argued, however, that EPA does have the flexibility to regulate as “new” 

nanoscale versions of materials already on the Inventory. The policy argument in favor of 

regulating nanomaterials as “new” chemicals under TSCA is that these nanoscale versions of 
Future of Finishing, page 39 of 65

existing chemicals are different from their conventional counterparts, present different health and 

safety concerns, and should be subjected to the same level of EPA control as “new” chemical 

substances. 

In 2007 EPA issued a draft document, TSCA Inventory Status of Nanoscale Substances—

General Approach, and a draft concept paper summarizing a voluntary Nanoscale Materials 

Stewardship Program for chemicals regulated under the Toxic Substances Control Act (TSCA). 

Under the proposed stewardship program, participants would be asked to voluntarily submit 

information to EPA to provide a firmer scientific foundation for future policy decisions on 

regulating nanotechnology applications.

The proposed Stewardship Program would establish two levels of participation: basic and indepth. Under the “basic” program organizations would report “all known or reasonably 

ascertainable information” about the nanomaterial. Under the “in-depth” program, participants 

would also provide a broad scope of physical, chemical, hazard, production and other 

information detailed in the concept paper. The “in-depth” program would also entail the 

development of a long-term plan for data collection and submittal to provide a firmer scientific 

foundation for future policy decisions on regulating nanotechnology applications.

International trends

For over a decade, the European Union has been the driving force in environmental regulation, 

carrying the rest of the world (not always willingly) along its path. That trend seems likely to 

continue.

Prior to 2007, the following EU directives tended to have the greatest effect on U.S. finishing 

firms:

 End of Life Vehicles (ELV, Directive 2000/53/EC)

 Restriction of the Use of certain Hazardous Substances in Electrical and Electronic 

Equipment (RoHS, Directive 2002/95/EC)

 Waste Electrical and Electronic Equipment (WEEE, Directive 2002/96/EC)

(In the EU regulatory system, directives are pieces of legislation that set goals, but leave it to the 

individual “member states” (countries that are members of the EU) to work out the details. They 

do not take effect until the individual countries have passed their own laws. Regulations do not 

require any further action by the individual countries to take effect.) Each of these directives has 

been implemented by individual EU countries, with relatively minor variations. They have 

primarily affected firms with customers in the automotive and the electronics sectors. 

Although these directives have introduced new restrictions, they have not been game changers. 

Their goals are primarily to restrict the use of certain materials that are assumed to pose 

particular problems, and their effect has been to stimulate the development of alternative 

materials to satisfy their respective functional requirements. In the case of ELV, the targeted 

materials are lead, mercury, cadmium, and hexavalent chromium. There is nothing 

fundamentally new about regulatory pressure discouraging the use of these metals. The existing 

directives have made more of a difference in degree than in kind.
Future of Finishing, page 40 of 65

However, a new development, called “REACH” (Regulation on Registration, Evaluation, 

Authorization and Restriction of Chemicals), may create a much more momentous alteration of 

the regulatory landscape. In contrast to the directives, it is a regulation, and will be instituted as 

written throughout the EU (though enforcement will be up to the individual countries).

REACH is different from any previous piece of environmental legislation – just how different is 

perhaps not even appreciated yet by most Europeans. It will have consequences that that 

finishing firms have never before encountered. For example:

 Previous regulations have targeted specific materials for restriction or elimination. 

REACH could conceivably apply to any material, depending on the results of types of 

toxicity testing not even developed yet (or of political agendas not yet formulated).

 Overseas regulations have typically affected U.S. finishing firms through changing 

specifications from customers doing business in overseas markets. In the case of 

REACH, pressure may come not just from customers, but from anywhere in the supply 

chain, including upstream chemical suppliers.

 Until now, finishing firms were responsible for ensuring that their coatings perform 

according to their customers’ specifications, but determining whether those specifications 

were appropriate for the product’s intended use remained the responsibility of the 

customer. Under REACH, a finishing firm might (under some circumstances) be 

expected to know how their customer, and their customer’s customer (etc.), intends to use 

the products they coat, and might be held responsible if the ultimate user, no matter how 

far down the chain, no matter how “creative” their use, were not advised of potential 

hazards associated with the coating if used for that purpose. 

We are entering new territory here.

REACH works essentially as follows:

 REACH applies to virtually any man-made substance (with a few exceptions covering 

mostly substances regulated under other EU laws, like, pesticides, radioisotopes, etc.)

 Anyone who produces one of those substances in the EU, or who imports the substance 

into the EU, in quantities over one metric ton, is responsible for registering the substance 

with the European Chemicals Agency in Helsinki, Finland.

 These companies must prepare Safety Data Sheets for downstream users all the way 

down the supply chain. The Safety Data Sheets must tell the downstream users how to 

handle the material safely for each intended use of the material. Do not confuse these 

SDSs with the familiar Material Safety Data Sheets (MSDSs) required under U.S. 

regulations. The use-specificity requirement ensures that REACH-compliant SDSs will 

be MSDSs on steroids. In some cases (dangerous substances used in quantities over ten 

metric tons), manufacturers or importers will have to prepare detailed “exposure 

scenarios”.

It should be noted that REACH applies to materials, not “articles” (finished goods that 

incorporate the materials, but that would not be expected to release the materials under normal 

conditions of use). Won’t that let surface finishers off the hook in most cases? Don’t bet on it. 

True, U.S. finishing firms that do not have facilities in Europe are not likely to have to deal with 

European regulatory authorities. But any of their customers that sell their coated products in the 
Future of Finishing, page 41 of 65

EU, or any of their suppliers that produce materials in the EU, or that get their materials supplies 

from the EU, are going to be turning to the U.S. firms for information.

Another potential consequence of REACH will be considerably more disruptive than complying 

with information requests from suppliers and customers. It is possible that some materials that 

have been in common use for decades or centuries might become unavailable. Suppliers doing

business in the EU, or in other areas of the globe that adopt EU-style regulations, might decide 

that it is not worth their while to continue to supply the material if it means complying with the 

more burdensome regulatory and liabilities burdens imposed by the new framework. This could 

happen at any point along the supply chain.

How can finishing firms prepare for this new style of environmental regulation? At the very 

least, it would be prudent to research the vulnerability of common materials used in finishing to 

this kind of disruption. A thorough job would require looking at the entire life-cycle of 

materials, and would probably be beyond the resources of any single metal finishing firm. But 

the finishing sector has demonstrated that it can pool significant resources to deal with regulatory 

developments (as in the case of the “MP&M” water quality regulations proposed and later 

largely abandoned by the USEPA several years ago). A similar effort to prepare for the new 

international regulatory framework might be undertaken by the finishing industry

collaboratively, acting through a trade organization. The benefits might be even more positive. 

In the case of MP&M, a concerted effort by the plating industry defeated an ill-conceived 

regulatory initiative, but then wound up with nothing further to show for the effort but a return to 

the status quo. In responding to REACH, the industry could create a strong position, based on 

sound science, to deal with a coming regulatory framework that is itself much better informed 

than its politically-driven predecessor. This point of view is developed further in the following 

section.

The future

Two regulatory topics bear watching that have not been of particular concern to finishing firms 

before now, but that may become increasingly important in the future. Both may provide 

opportunities as well as burdens for finishing firms.

Global warming. The political climate that has so far insulated the U.S. economy from the 

effects of new burdens on greenhouse gas emissions will probably shift fundamentally over the 

next few years. While the prospect of the U.S. federal government imposing restrictions on 

carbon dioxide emissions from fossil fuel combustion seemed remote only a few years ago, such 

measures now seem inevitable. For most manufacturers, these developments will not involve 

new emissions limits on manufacturing processes, though large boilers may fall under new 

efficiency standards. The immediate effects of greenhouse gas regulation on U.S. finishing firms 

are likely to be indirect, increasing the relative cost of energy and possibly slowing economic 

growth overall.

But global warming concerns may have a more subtle role to play in shaping the outlook for the 

surface finishing sector. When regulating typical toxic emissions, it’s generally safe to assume 

that “less is better”, at least from the point of view of protecting health and environment. The 

question then becomes “how much less?” At what point does the benefit derived from lower 
Future of Finishing, page 42 of 65

emissions further stop making sense when weighed against the cost? But regulating greenhouse 

gases involves a more complicated set of criteria. It is no longer a matter of requiring individual 

manufacturers to install control equipment on isolated processes. Effective greenhouse gas 

regulation involves international treaties, sweeping changes in fundamental practices, and huge 

capital investments over decades.

With stakes that high, it becomes critical to evaluate the effects of proposed changes using much 

sharper tools than are typically applied today. At this point, a generally accepted, comprehensive 

framework for assessing the environmental impacts of various alternatives does not yet exist. 

The closest framework available at present goes by the name of “life-cycle assessment.” It was 

originally devised to provide a common basis for comparing alternative products. It will take 

some development before it can be applied to large scale systems, projected into the future. But 

it’s a start.

It turns out that when life-cycle considerations are applied to greenhouse gas mitigation, 

finishing firms have an opportunity to position their industry as an environmentally responsible 

alternative, as explained in the next section. 

“Life-cycle” methods. The second major regulatory development that is likely to occur over the 

next few years is the increasing application of life-cycle methods to the formulation of regulatory 

policy.

The best way to make the case that environmental regulations should be based on life-cycle 

thinking is to try to argue the contrary. Imagine a regulatory system where each point of 

emission is considered in isolation. Producers are required to keep the rate of pollutant emission 

at each point below an arbitrary level. In a complex production system, this may require that 

more pollutants are generated from more individual sources than would be the case if the whole 

system were regulated on an integrated basis. For example, suppose a finishing firm wanted to 

install a plating line that would make it possible to refurbish and reuse complex parts that were 

currently being scrapped. The process could be carried out profitably, except for the cost of 

installing and operating the required control equipment. The firm could demonstrate that the 

reduction in emissions resulting from not having to manufacture new parts far outweighs the 

emissions that would result from less stringent control of the plating line. Under our imaginary 

regulatory system, this argument would carry zero weight.

Does our imaginary system seem uncomfortably familiar? Of course, no rational society would 

adopt a system under which application of individual rules would work at cross-purposes to the 

overall goal. So why are we stuck with this legacy of irrationality?

The heart of the problem is that the current system is based on a “sin-and-redemption” model of 

environmental pollution. Stay under your limit, and you are innocent – you have done society no 

unacceptable harm. Cross the threshold, by no matter how small an increment, and you are 

guilty, a wrongdoer, and must be punished, typically by a fine, public humiliation, or worse.

Reason tells us that the threshold is arbitrary. There are degrees of impact and complex tradeoffs 

associated with every design decision and manufacturing process. “Life-cycle assessment” is 
Future of Finishing, page 43 of 65

simply another name for keeping track of the impacts. Wouldn’t a compensation-based system, 

balancing impacts against benefits and adjusting for the inequities, make more sense than a 

system based on arbitrary limits and penalties for exceeding them?

The problem is that the impact accounting system is still in development. There is currently no 

broad consensus on how to keep the books. And even as a consensus eventually materializes, it 

will not work smoothly into the current system. Life-cycle calculations are necessarily 

approximate. A penalty-based regulatory system needs sharp lines.

We probably needed to go through the sin-and-redemption phase. The framework of the current

environmental regulatory system was largely established in the 1970s and 1980s. Setting it up 

was a politically contentious process, with powerful forces resisting government interference in 

what had previously been considered private decisions. Academic concerns for sustainability 

would not have counted for much, given the politics and level of awareness then prevailing. The 

only countervailing force that could have moved the country to adopt (for the first time in 

history) laws specifically guaranteeing protection for the environment was an emotionally 

involved collection of citizens representing a significant fraction of the electorate.

Most people (for better or worse) do not become passionate advocates through appeals to reason. 

But people do respond to stories. One could observe the fact that the ever-increasing scale of 

industrial activity was gradually approaching the threshold where its environmental impacts were 

beginning to exceed the ability of natural forces to absorb and dissipate the effects. But that 

doesn’t make much of a story. It takes an old-fashioned rip-roaring drama, with good guys, bad 

guys, vulnerable maidens, and the forces of right battling the demons of darkness, to get people 

involved (and to sell papers or attract viewers).

The classic environmental story had all the elements. The factory owner was the perfect villain, 

driven by pure greed to despoil the surroundings. The reporter could assume the hero’s mantle 

for exposing the story, and the viewer could inherit it by carrying on the battle. Throughout the 

70s and 80s, the story kept coming back. The stories were often triggered by real problems –

Love Canal, Three Mile Island, Bhopal, but the narrative always seemed to fall into the familiar 

pattern. The manufacturer, motivated by greed, or by negligence born of greed, made 

irresponsible choices, with tragic consequences. The remedy generally involved punishment, to 

deter such behavior in the future, and stricter laws.

The sin-and-redemption model has proved to be a powerful motivating force. Something deep in 

the human nurturing impulse generates a strong protective reaction when our dependents are 

threatened by poisoning. Environmentalism probably had to become a gut issue to reach its 

present degree of political leverage. But the model has had other consequences.

First, note that it is self-perpetuating. The designated villains of the narrative, the grasping 

industrialists (who may in many situations be small business owners), have every incentive to 

deny, stonewall, cover up, and generally act the part. When an emissions problem is discovered,

the appropriate response, in the sin-and-redemption paradigm, is not primarily to solve it and 

correct the situation that led to it, but to expose the transgression and pillory the perpetrator. As 

a result, the individuals in the best position to fix the problem seek instead to distance themselves 
Future of Finishing, page 44 of 65

from it. This confirms their villainous nature in the eyes of the public, though it often serves to 

make the problem worse.

Another, even more insidious aspect of the sin-and-redemption model is that it provides a 

perverse incentive for public interest groups whose ostensible purpose is to eliminate the sin. 

The public is much more inclined to contribute to an organization whose mission is defeating the 

forces of evil than to one that is seeking optimal solutions for complex problems. It is virtually 

inevitable that demonization becomes standard operating procedure. (Worse yet, the same 

dynamic can occur at government agencies, where political support for a greater share of the 

budget can be as strong an influence as the demands of fund-raising. Theoretically, the activities 

of government agencies are subject to more internal constraints than the activities of private 

groups – the phenomenon of prosecutors turning into persecutors tends to be more prevalent in 

agencies dealing with money or national security than with environmental matters – but the drive 

to persecute sometimes infects environmental agencies as well. And the stakes when 

government acts are correspondingly higher than is generally the case with the private sector.)

The tendency to put manufacturing firms in the cross-hairs is not just a problem for the firms. 

Perhaps most notably, it impedes progress toward real solutions because it chokes the free flow 

of information. But beyond that, it deflects attention from root causes. Accountability is not 

causality. Even when the manufacturer has indeed cut corners, and is legally responsible for the 

consequences, closer examination will typically uncover a whole chain of people and firms who 

benefit from the manufacturer’s choices, from suppliers and distributors through ultimate 

consumers. They have declined to pay the cost of environmental responsibility. For the most 

part, they can justly claim ignorance – lower retail price does not automatically signal less 

responsible production. The only way to address that claim would be to provide the relevant 

information. In the ideal world, every purchaser of the article, from wholesaler to consumer, will 

be told: here is what the article will cost you, and here are

 the impacts that went into producing it

 the impacts that will occur throughout its normal service life

 the impacts associated with discarding or recycling the product

That information can be used in any of a number of ways – as a matter to be left up to the 

purchaser to use as desired, or as the basis for policy decisions such as taxes or deposits.

In any case, a system that actively discourages the conditions under which such information can 

be collected is clearly undesirable. At some point, the sin-and-redemption model of 

environmental responsibility becomes a self-defeating paradigm.

In the long run, it is in everyone’s best interests to move beyond the sin-and-redemption model 

to a more mature approach. Industrial production inevitably involves environmental impacts. 

While it will generally be advantageous to minimize the impacts, some damage is unavoidable. 

Consequently, compensating measures will always be required to ensure that the natural 

infrastructure can function sustainably. Rather than playing the blame game, the guardians of the 

commons, public and private, will do more good by devoting their efforts to ensuring that the 

responsibility for providing for that compensation is shared equitably all along the chain. 
Future of Finishing, page 45 of 65

Two major developments are needed to enable the shared responsibility model to supplant sinand-redemption. The first is technical. What is now called “life-cycle assessment” (and may 

ultimately be called simply “full cost accounting”) is currently a craft industry in its own right, 

practiced by specialists with proprietary databases and opaque methods. As the demand for 

impact information grows, this temporary phase will pass into a situation in which impact 

information will appear on a material’s spec sheet, along with density and other mundane 

parameters. Creating a life-cycle assessment will be as routine as compiling a bill of materials. 

Most of the information and methodology needed to support this capability is already in place 

now (2008), and needs only to be brought together in publicly accessible form. By 2015, it may 

be commonplace.

The other, less predictable impediment is the need to muster the will to change old habits. As 

indicated above, both regulatory agencies and public interests groups have a short-term incentive 

to stick with the sin-and-redemption model. For them, evolving beyond the old model will 

involve developing an appeal to supporters that is based on reason rather than emotion, but that 

still remains effective in generating budget allocations or contributions.

In any event, as environmental impact information becomes more reliable and available, it will 

eventually become the basis for regulations. That could very well mean some changes in 

emphasis. Some materials that have been under the gun in the old system, typically because of 

acute toxicity effects from uncontrolled emissions, may turn out to be less of a problem than 

others whose effects are more subtle or indirect. But in the absence of more detailed 

information, it is hard to guess which way the chips will fall in specific cases. The best advice 

for finishing firms would be to keep as vigilant an eye on technical developments in impact 

analysis as they have learned to do on regulatory developments.
Future of Finishing, page 46 of 65

III. Technology Trends

This section of the report looks at potential future technology changes that could affect the metal 

finishing industry. The information presented here is based on a survey of nine industry experts 

that was conducted in 2006. The survey asked the experts to use their crystal balls to predict 

which technology changes will have the greatest impact on metal finishing within time frames of 

5, 10 and 20 years. A set of nine potential technology changes were presented in the survey and 

the experts were permitted to add additional technology changes that they felt were important, 

although none did. The nine technology changes can be categorized as either optimization of 

existing technology or implementation of new technology:

Optimizing Existing Technology

 Optimize conventional wet processes to achieve near zero discharge and risk --

Improve the efficiency and performance of conventional surface finishing processes to 

reduce chemical usage, worker exposure risk and waste generation, while maintaining or 

improving surface finish quality, processing speed and capacity.

 Improve process monitoring and control systems – Automate surface finishing process 

lines. For manual process lines, deploy state-of-the-art software to enhance information 

access and process verification.

 Pursue sustainable manufacturing – Use processes and systems that are non-polluting, 

energy conserving, natural resource conserving, economically efficient, and safe for 

workers, the community, and consumers.

 Improve energy efficiency -- Use more energy efficient equipment and/or modify

manufacturing processes to increase efficiency and reduce energy consumption.

Developing and Implementing New Technology

 Change to “greener” process chemistries –Change to alternative “green” chemistries 

that can meet surface finishing process requirements while reducing or eliminating the 

use and generation of hazardous substances.

 Change from “wet” processes to “dry” processes -- Change from conventional surface 

finishing immersion chemistry solutions to alternative metal deposition technologies (e.g. 

HVOF or PVD)

 Change substrate materials from finished metals to non-metals -- Change materials 

and manufacturing processes from metal finishing to non-metals, such as composites or 

plastics.

 Develop new metal alloys that reduce surface finishing requirements -- Use new 

metal alloys that provide sufficient corrosion resistance and reduce or eliminate the need 

for metal finishing using toxic chemical processes (e.g. new stainless steel alloy that can 

replace steel coated with cadmium).

 Develop nanotechnology -- Use nanocrystalline metal coating processes or using 

nanomaterial-enhanced metal or non-metal substrates. 

The remainder of this section presents the survey results and a short capsule for each technology 

change, including examples.
Future of Finishing, page 47 of 65

Technology survey results

The following discussion highlights results from the expert survey. To obtain a copy of the 

survey form and/or a complete set of survey results, contact Paul Chalmer at NCMS, 

paulc@ncms.org or (734) 995-4911.

Figure 1 summarizes the experts’ opinions of how each of the nine technology changes is likely 

to impact manufacturing in 5, 10 and 20 years (based on a scale of 1 to 5, where one is not very 

likely and five is most likely). Overall, the results suggest that optimization of existing 

technologies will have a greater impact than new technologies, both near-term and long-term. 

All four optimization items scored high with the experts (average score for the four optimization 

changes was 3.8 for five years, 4.4 for ten years and 4.7 for 20 years). The highest scoring new 

technology change was a switch to green chemistries (score of 4.1 to 4.6 over the 20 year span). 

At the low end of the technology changes are transitioning from wet to dry processes and the 

development/implementation of nanotechnology. Both of these changes are expected to have 

very little impact during the next five years, followed by moderate increases in impact for the 10 

and 20 year periods. 

Figure 1.

Technology Trends -- Likelyhood to Impact Manufacturing

2.00

2.50

3.00

3.50

4.00

4.50

5.00 Optimize conventional wet processes to achieve near zero discharge Improved process monitoring and control systems Pursuit of sustainable manufacturing Improve energy efficiency Change to "greener" process chemistries

Change from "wet" process to "dry"processChange materials from finished metals to non-metals New metal Alloys Development of nanotechnology Average: Optimization Impacts Average:New technology Impacts Average Response (1 = not very likely, 5 = most likely)

5 years

10 years

20 years

Figure 2 summarizes the experts’ opinions of how likely companies are to invest in each of the 

nine technology changes in 5, 10 and 20 years. These results closely follow the impact trends 

shown in Figure 1; the optimization changes are more likely investments than new technology, 

with the exception of green chemistries.

Figure 2.
Future of Finishing, page 48 of 65

Technology Trends -- Likelyhood to Impact Manufacturing

2.00

2.50

3.00

3.50

4.00

4.50

5.00 Optimize conventional wet processes to achieve near zero discharge Improved process monitoring and control systems Pursuit of sustainable manufacturing Improve energy efficiency Change to "greener" process chemistries

Change from "wet" process to "dry"processChange materials from finished metals to non-metals New metal Alloys Development of nanotechnology Average: Optimization Impacts Average:New technology Impacts Average Response (1 = not very likely, 5 = most likely)

5 years

10 years

20 years

Figure 3 summarizes survey results, where the experts were asked which “drivers” (regulatory, 

technology and economic) would most significantly catalyze each of the nine technology 

changes. The results show that the experts expect regulatory drivers to be most significant with 

respect to changes to green chemistries and optimizing wet processes to achieve near zero 

discharge, and with moderate to zero impact on the other changes. Technology drivers are 

expected to be most significant with development of dry processes, new metal alloys and

nanotechnology. Economic drivers are expected to be most significant with the four process 

optimization changes.
Future of Finishing, page 49 of 65

Figure 3.

Technology Trends -- Drivers

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100% Optimize conventional wet processes to achieve near zero discharge Improved process control systems monitoring and Pursuit of sustainable manufacturing Improve energy efficiency process chemistries Change to "greener"

Change from "wet" process to "dry"process Change materials from finished metals to non-metals New metal Alloys nanotechnology Development of Percent of Respondents

Regulatory

Technology

Economic

Optimizing existing technology

The following are brief capsules explaining each of the nine technology changes listed in the 

survey. A “status report” on each technology is provided along with specific examples.

Optimize conventional wet processes to achieve near zero discharge and risk

Some firms are adopting a long-term strategy in dealing with stricter environmental regulations 

and future liability concerns. They are modifying conventional surface finishing processes by:

 converting to “greener” processes that use less toxic process chemicals

 converting to “dry” processes

 even switching to new coating materials or substrates to avoid toxic materials entirely

However, even after years of development, no viable substitutes have yet become available for 

many applications. We anticipate that conventional surface finishing processes will still be in 

use at thousands of surface finishing facilities through 2020 and beyond. 

Since pressures to reduce impact and liability will continue, if not increase, for the foreseeable 

future, prudent firms that expect to be using conventional processes are working toward

optimizing them. Two popular trends include:

 Approaching zero exposure – isolating employees from contact with materials or 

effluents in process operations, thus approaching zero risk conditions

 Approaching zero discharge -- maximizing material utilization and recovery, thus 

minimizing the impact on the environment from wastewater, air emissions, and 

concentrated waste streams (spent process solutions and treatment sludges and solids)
Future of Finishing, page 50 of 65

The techniques firms employ to achieve near zero exposure and discharge from wet processes

depend on the specific process and production situation, but can involve:

 Enclosing process lines (a common practice in the printed wiring board and 

semiconductor industries)

 Reducing and recovering dragout 

 Using process solution and rinse purification and recycle technologies

 Using racking and fixturing off-line to reduce operator exposure and using configurations 

that optimize process efficiency and yield and minimize waste

 Using process automation and control systems to optimize material usage and yield

 Modeling processes for optimization 

Examples of processes using metals with environmental health and safety (EH&S) concerns that 

can approach near zero discharge include:

 Chromium Plating

 Chromic Anodizing

 Nickel Plating

 Electroless Nickel Plating

 Cadmium Plating

 Lead Plating

 Tin-Lead Plating

Hundreds of surface finishing facilities have already implemented process optimization projects

that have resulted in near zero discharge. The improvements have typically yielded cost savings, 

since the optimized processes exhibit better performance, along with lower material usage and 

reduced waste generation. In addition, a small fraction of existing surface finishing facilities 

have enclosed, automated process lines with ventilation and air emissions control systems that 

provide near zero exposure risk. Industries like printed wiring board manufacture provide 

examples where such systems have been successfully implemented.

Trend Analysis. There is a substantial opportunity across surface finishing manufacturing

installations to optimize processes towards zero discharge and zero exposure risk. Hundreds of 

facilities have done so, but thousands more have not. The main barrier seems to be lack of 

recognition of the substantial opportunity for real economic benefits. In some cases, facilities 

that want to achieve reduced discharge and exposure focus on developing new replacement 

technology, but miss the opportunity to optimize the existing processes that they may continue 

operating for years to come. The most cost-effective time to implement process optimization is 

when new or renovated process are being designed and installed.

A number of forces can drive the trend of process optimization towards zero discharge and risk:

 EH&S regulations 

 Corporate EH&S goals

 Improved diffusion of technical information and industry education programs
Future of Finishing, page 51 of 65

 Continuous process improvement programs like Six Sigma and Lean\Kaizen that can 

identify the opportunities for improvement and provide justification for implementing 

changes

Improve process monitoring and control systems

Although systems for automating surface finishing process lines are commercially available and 

have been proven in a range of applications, more than 90% of surface finishing process lines are 

manually controlled. Process control systems provide significant enhancement of manual 

process lines with capabilities for more consistent processing and improved process tracking, 

documentation, and decision support. 

Commercial software and hardware systems for process monitoring and control will provide the 

technology for surface finishing manufacturers to improve process performance and profitability. 

Some of the major monitoring and control changes that will result in significant process 

improvements for surface finishing manufacturers will include:

 Manual process lines will be automated

 Software systems will be installed with process localized PC or PDA devices for manual 

process lines to prompt operators with load-specific process steps and to track and merge 

operator/load data with process tank sensor data

 Software systems will be installed for lab analyses for scheduling, automaticcalculations, statistical tacking and logic-based communication/output controls or actions 

based on analytical results or trends

 Production software will be used to track product quality and defects, correlate to 

production and target process improvements

 Company-instituted continuous-process improvement programs, like Six Sigma and 

Lean/Kaizen, will be used to identify and implement specific process monitoring and 

control needs and cost-effective process improvements.

Automation of manual process lines allows for consistent processing based on load specific 

recipes by maintaining process step and transfer times, and integrating rectifier ramping and 

control, tank temperature control, and even auto-dosing of chemical additives. Operators can 

interface with the automated systems through local panel displays. Unlimited numbers of 

processes and part numbers are stored for retrieval when ready to run. The automation software 

can automatically track and report process tank specific and load specific conditions. The 

process data linked to load-steps provides essential process data and integrated trend plots for 

process troubleshooting and for process improvement. The data tracking and reporting 

capabilities significantly enhance the ability to manage, control, and improve process lines. 

Automation software can be available with a simulation mode that allows running process loads 

through selected process sequences and times showing any potential bottlenecks or processing 

conflicts. This functionality can be used for evaluation of workload scheduling or during process 

design to assure good workflow

On manual process lines, process monitoring and control can be enhanced by retrofitting with 

localized PDA or PC systems connected via wireless transmission to a base station computer 
Future of Finishing, page 52 of 65

and software package. Typical systems provide capabilities to prompt operators with loadspecific process steps while tracking step times for specific loads and then merging load steps 

with tank/time specific data (e.g. – pH, temp, conductivity, level, etc). This generates a process 

data set similar to an automated system, using operator input instead of the automatically 

tracked hoist/load information. The PDA or local PC-prompted process steps provide assurance 

that load-specific processing steps are followed (enhancing process consistency and 

documentation).

Lab analysis software is available that can provide support for statistical process control. Offthe-shelf software pre-customized for surface finishing processes can provide: 

 scheduling and tracking of sampling and analysis events, 

 automatically calculated results from raw data measurements, 

 statistics and trend charts, 

 event logs and reports, 

 required corrective actions are flagged and tracked, and 

 solution adjustment/addslips are generated, tracked, and documented.

Automating actions based on data results and/or statistical trends by defining condition-specific 

rules is a powerful process improvement capability. For manual process lines, lab software 

packages provide this functionality based on lab analytical results and statistical trends. For 

automated process lines, this process monitoring and control support functionality can be 

provided based on process operating parameters, and/or load specific parameters in addition to 

lab analytical results and statistical trends. Example actions that can be initiated include: 

 pop-up messages, 

 sending email notifications, 

 automatically performing and reporting supplemental calculations, 

 retrieving and sending situation-specific response procedures/documentation, and 

 sending signals to process alarms/controllers. 

Actions can be initiated when results indicate that an operating parameter limit has been 

exceeded. Alternatively, actions can be triggered proactively, based on rules that use statistical 

trends. In the latter case, even if the results are within control limits, the system will provide 

alerts warning the operator to anticipate problematic conditions if the data are consistently 

trending up or down toward control limits, or are with a set percentage of control limits. The 

ability to set up rules that initiate automatic actions that are automatically triggered by data 

results and statistical trends adds powerful process monitoring and control capability to manual 

or automated surface finishing processes.

Company-instituted continuous process improvement programs, like Six Sigma and 

Lean/Kaizen, involve creating process improvement teams and providing them with systematic 

methodologies to identify inefficiencies and areas for improvement. Teams are encouraged to 

focus on sequential process steps and compare how these are performed with how they should 

be performed to maximize process consistency, efficiency, and quality. Their insights may then 

be used to recognize monitoring and control needs and other specific process improvements, and 

to develop programs for implementing them. Such improvements might include process 

automation, software systems to support process monitoring and control, and focused process 
Future of Finishing, page 53 of 65

changes to facilitate improved monitoring and control. Examples of typical process 

improvement programs include: 

 Six Sigma directs manufacturers toward improvements in efforts to achieve statistically 

low target levels of defects. The Six Sigma methodology for process improvements 

follows a systematic process of define, measure, analyze, improve, control (DMAIC) 

that depends on getting good process data and using statistical and visual/graphical tools 

to analyze data and see, define and quantify process improvements.

 Lean methodologies lead to mapping and improving product value streams and flow of 

information, and to reducing the “seven deadly wastes” (overproduction, waiting, 

conveyance, processing, inventory, motion, and correction). Kaizen (continuous 

improvement of an entire value stream or an individual process to create more value with 

less waste) events are typically week long structured lean events to systematically look at 

specific processes using lean tools and methodologies and to define improvements and 

implementation approaches to realize process improvements. 

Trend Analysis. There is significant opportunity in the surface finishing industry to improve 

process monitoring and control, achieving potentially significant process improvements and cost 

savings. There are several forces at work in the industry driving facilities towards improving 

process monitoring and control:

 National Aerospace and Defense Contractors Accreditation Program (Nadcap)

requirements for the aerospace supply chain place stringent process monitoring, control, 

and documentation requirements on manufacturers. Aerospace prime manufacturers are 

now implementing a Nadcap Users Compliance and Audit Program (NUCAP) that is 

similar to Nadcap. The automotive industry is also looking at adopting a program like 

Nadcap. The lab statistical software and manual process line monitoring and control 

software are perfect tools for meeting Nadcap requirements. Automating process lines 

can put systems in place to automatically satisfy Nadcap requirements.

 Continuous process improvement programs like Six Sigma and Lean/Kaizen can identify 

the need for improved process monitoring and control systems and provide justification 

and means for moving forward with implementation. The DoD and many large 

corporations are adopting Six Sigma and/or Lean/Kaizen programs and in some cases 

these programs are becoming recommended or required for lower-tier suppliers to adopt.

 In recent years a powerful and highly useful suite of software products have been 

developed that significantly enhance surface finishing process monitoring and control at 

relatively low cost and/or relatively strong return on investment. Mass marketing of 

these products will expose thousands of surface finishing facilities to the benefits of 

improved process monitoring and control.

For many manufacturers, achieving the level of process improvement that is possible through 

implementing process monitoring and control systems may be critical to staying in business.
Future of Finishing, page 54 of 65

Pursue sustainable manufacturing

Sustainability addresses meeting present needs of resource consumption/production without 

compromising future generations, with respect to resource availability and the viability of 

environmental/ecological systems. Sustainable manufacturing involves production using 

processes and systems that are non-polluting, energy conserving, natural resource conserving, 

economically efficient, and safe for workers, the community, and consumers. Overall 

sustainability addresses both production and consumption, seeking ways to modify both to allow 

sustainability goals to be met. Sustainability necessitates a systematic approach to look at the 

life cycle of a product.

In the past few years, sustainability has been adopted in surface finishing manufacturing in the 

government and private sectors as a theme for industry and environmental conferences, as a goal 

for new construction projects, and in some cases, more broadly adopted into corporate or 

government entity overall goals. Sustainability has been mostly pursued with a narrow focus on 

production and facility improvements that move towards sustainability (e.g. green chemistry 

improvements, energy and water conservation, improved chemical utilization and 

purification/solution life extension). The full scope of sustainability is a much broader pursuit 

extending beyond the manufacturing facility boundary to acknowledge responsibility for 

minimizing effects throughout the product life cycle including up the supply chain (are materials 

from renewable sources?) and down the product distribution chain (can the product be recycled 

after use?). Sustainability implies that consumption and production are systematically 

coordinated such that resources and the environment are preserved for future generations. For 

some companies this will involve decisions to change production to produce more sustainable 

products, following a strategy that consumers will embrace the more sustainable products, 

resulting in good business and improved sustainability.

Example sustainability criteria that can be used to quantitatively rank level of sustainability for 

products and to help select between different product and production options:

 Percentage of products designed to be easily reused or recycled

 Percentage of suppliers receiving safety training per year

 Energy input for raw materials and packaging

 Expected annual energy use of product during normal use

 Tons of greenhouse gases generated transporting product to users

 Percent of water from local resources used relative to the local recharge rate

 Percent of total energy used that is from nonrenewable resources

 Percent of total energy used from renewable resources harvested sustainably

 Percent of raw materials that are from nonrenewable resources

 Maintaining ISO 14001 certification and compliance

One aspect of sustainable manufacturing is making the manufacturing facility itself more 

sustainable. The US Green Building Council has developed a Leadership in Energy and 

Environmental Design (LEED) system with a specific rating system totaling 69 possible points 

for an overall LEED score for new or renovated facilities. The LEED scoring system is a 

good quantitative measure of facility sustainability. The primary scoring categories are listed 
Future of Finishing, page 55 of 65

below with points available in each category and some of the specific criteria listed for each 

category:

 Sustainable Sites (14 points – brownfield or urban redevelopment, reduced site 

disturbance, stormwater management, landscape and exterior design to reduce heat 

islands, light pollution reduction)

 Water Efficiency (5 points – water efficient landscaping, innovative wastewater 

technologies, water use reduction)

 Energy & Atmosphere (17 points – fundamental building systems commissioning, 

minimum energy performance, CFC reduction in HVAC and refrigeration equipment, air 

quality protection, optimizing energy performance, renewable energy, additional 

commissioning, reducing ozone depletion, measurement & verification of energy and 

water use reduction, green power)

 Materials & Resources (13 points – storage and collection of recyclables, hazardous 

materials and waste management, building reuse, construction waste reuse/recycling, 

resource reuse, recycled content, local/regional materials, rapidly renewable materials, 

certified wood)

 Indoor Environmental Quality (15 points – minimum indoor air quality performance, 

environmental tobacco smoke control, acoustics and noise control, carbon dioxide 

monitoring, increase ventilation effectiveness, construction indoor air quality 

management plan, low-emitting materials, indoor chemical and pollutant source control, 

controllability of thermal, ventilation and lighting systems, thermal comfort, daylight and 

views)

 Innovation & Design Process (5 points – innovation in design, LEED accredited 

professional, integrated landscape management, deconstruction, advanced resource 

efficiency):

Scoring ranges that result in LEED certification and advanced LEED ratings are:

 LEED Certified (26-32 points)

 LEED Silver Rated (33-38 points)

 LEED Gold Rated (39-51 points)

 LEED Platinum Rated (52-69 points)

Ford Motor Companies’ brownfield renovation of its Dearborn, Michigan manufacturing facility 

was awarded the nation’s first LEED Gold rated building under the LEED certification 

criteria. The US Department of Defense has mandated that all military construction (MILCON) 

starting in 2007, including industrial manufacturing facilities, shall be LEED certifiable.

Trend Analysis. The sustainability theme will continue to spread throughout surface finishing 

manufacturers. Specific process improvement measures to improve sustainability will be 

identified and implemented as awareness increases that sustainability can be improved and cost 

paybacks can often be realized. Awareness of the LEED program will increase and companies 

will increasingly decide to target LEED certification or an advanced LEED rating (Silver, 

Gold, or Platinum) for new or renovated facilities. LEED is a very tangible, prescriptive, and 
Future of Finishing, page 56 of 65

quantifiable program for sustainability and the certification or advanced ratings are milestone 

achievements companies can use for positive image marketing and demonstration of corporate 

sustainability achievement.

The End-of-Life Vehicles (ELV) Directive (2000/53/EC) was passed into European law in 

October 2000, and applies to cars, vans, and certain three-wheeled vehicles. ELV significantly 

limits or eliminates the quantities of toxic materials that can be used in vehicle manufacturing 

(e.g. – hexavalent chromium, cadmium, lead and mercury), requires substantial increases in 

reuse/recovery/recyclability of vehicle materials, and places strict standards on disposal or 

treatment facilities for ELV. The ELV directive is an example of far-reaching regulation that is 

forcing automotive manufacturers towards more sustainable products. 

Eventually, coaters will begin to pursue broader sustainability goals, as the tools and procedures 

for performing life-cycle analyses of products slowly develop, and as awareness of what is 

required to achieve sustainability disseminates throughout the surface finishing industry. 

Regulatory restrictions like the ELV directive might motivate a small number of manufacturers 

to take the opportunity to pursue sustainability goals. Instead of simply complying, they will

look for new or modified products and processing technologies that are both more sustainable 

and that provide a competitive advantage. Such advantages include the ability to gain a market 

share by positioning the product as more sustainable than the alternatives, and to provide a 

chance to jump ahead of the competition in transitioning to new or modified products.

Improve energy efficiency

Improving energy efficiency is a major technology trend in all manufacturing industries, 

including surface finishing. In recent years there have been significant increases in process 

equipment energy efficiency and in process design and management for reducing energy usage.

Some examples of improving energy efficiency in the surface finishing industry include:

 Efficient ventilation system design – for example, push-pull ventilation can achieve 

required industrial ventilation levels at lower air flow rates than pull-pull systems. 

Ventilation systems can be designed using variable frequency drives that allow ramping 

ventilation rates up or down with changing process conditions and requirements. Building 

ventilation design should be coordinated with process ventilation to achieve overall 

efficient systems

 Enclosed process lines – reduce ventilation requirements.

 Tank cover systems – reduce evaporation and heat loss

 High efficiency chillers, boilers, fluid heaters, blower motors, and pumps – are available 

and can provide significant energy savings.

 Insulation -- reduces energy losses for elevated or reduced temperature process fluids

 Equipment layout and piping design for efficient operations and energy conservation –

can minimize pumping requirements by utilizing gravity flow and piping design for low 

friction losses and can minimize equipment energy consumption by utilizing good 

workflow.

 Conforming electrodes and good masking – can enhance process rate and efficiency and 

minimize energy consumed for rework and extra processing to meet specifications. 
Future of Finishing, page 57 of 65

 Well controlled process solution chemistry and contaminants – can reduce processing 

time and reduce additional processing and rework that consume additional energy.

 Well executed process procedures using automated systems or closely monitored and 

controlled manual systems – can enhance process consistency, documentation, and 

overall performance.

 Building automation systems and high efficiency heating, cooling, ventilation, and 

lighting systems -- reduce energy loads for production areas and general facility areas.

 Energy management systems – better energy use monitoring and control logic for 

situation-specific energy demand can optimize energy use when needed and result in 

overall energy savings. 

 Waste heat/energy recovery systems (air, steam, etc.) -- energy recovery systems provide 

a dual benefit in reducing potential thermal pollution and gaining energy reductions in 

proportion to the recovered energy. 

 Cogeneration – can recover waste heat and enhance overall energy efficiency for process 

and facility heating and cooling systems.

Trend Analysis. Improved energy efficiency will remain a strong trend in surface finishing due 

to high and potentially increasing energy costs and EH&S goals to reduce pollution and conserve 

resources.

Developing and implementing new technology

Change to “greener” process chemistries

Green Chemistry is the design of chemical products and processes that reduce or eliminate the 

use and generation of hazardous substances.

A recent example of a new “green” surface finishing chemistry is the U.S. Navy’s trivalent 

chromium conversion coating bath that replaces hexavalent chromate solutions. Hexavalent 

chromates have been restricted or banned in the automotive industry, are a target for elimination 

across the U.S. Department of Defense (DoD), and are a concern with many other industries due 

to carcinogenicity of hexavalent chromium. The Navy first tested a range of existing 

replacement chemistry products that all failed their replacement criteria. The Navy then 

developed a trivalent chromium-based post treatment (TCP) chemistry and process that 

performed successfully through extensive testing. The TCP showed excellent corrosion 

protection, coating durability, and paint and adhesive bonding for use on aluminum and on 

anodic aluminum coatings, with testing and demonstrated performance indicating good potential 

for use on cadmium, zinc and zinc alloys. 

Other non-chrome “green” replacements have been developed for replacement of hexavalent 

chromates. These chemistries have shown success in some applications and a lack of 

performance in others. For example, one of the non-chrome products tested alongside TCP 

showed acceptable performance in painted systems, but did not perform well in unpainted 

applications.

Other green chemistry developments in surface finishing over the past 30 years include:
Future of Finishing, page 58 of 65

 Replacements for cyanide plating chemistries

 Replacements for cadmium plating chemistries 

 Replacements for conventional water treatment chemicals that produce less toxic sludge 

(e.g. eliminating use of sulfide precipitants) and/or lower volumes of wastewater 

treatment sludge

 Trivalent chrome decorative plating chemistries

 Cobalt-free, trichrome passivates

 Organically stabilized electroless nickel (non-lead, cadmium, bismuth and antimony)

The development of alternate “green” chemistries is typically a multi-year endeavor by chemical 

companies and it requires a significant R&D investment. Even after successful development and 

demonstration of alternative “green” chemistry, potential users are typically hesitant to switch 

without completing their own testing, thereby dragging out substitution even further. The 

procedures employed by users often have an impact on the success rate of using new solutions. 

In many cases, companies switched to green chemistries but did not systematically or holistically 

implement the new process, and ultimately reverted back to their old process. Therefore, proper 

implementation of a process change requires strategic planning and transitioning, not just the 

chemistry, but also the applicable infrastructure, operations and maintenance procedures, and 

process support systems.

Trend Analysis. The green chemistry/process trend is expected to phase out most toxic 

chemical use as regulatory pressures and corporate environmental, green and sustainability goals 

provide strong motivation to find and transition to greener chemistries. Some recalcient 

applications of toxic processes will likely continue in the future due to specifications and 

technical limitations, although these will be reduced over time as research continues.

One major influence on the green chemistry trend is the anticipated targeting of additional metals 

for reduction/elimination (e.g., nickel and cobalt are on an EPA list). Adding metals to the list 

for elimination will impact numerous existing finishing processes and will likely spur additional 

R&D to develop replacements. Ironically, some of the “second tier” targets such as nickel were 

at one time considered a replacement technology themselves (e.g., replacing hexavalent hard 

chrome with electroless nickel). If that trend continues, a sequence of substitutions over many 

years can be expected.

Change from “wet” processes to “dry” processes

Transitioning from the traditional “wet” surface finishing processes to “dry” processes has been 

a trend in recent years in order to reduce operator exposure, air emissions, chemical handling, 

and waste generation.

An example of a “dry” process is high-velocity oxygen fuel (HVOF) thermal spray, which is 

displacing traditional hard chrome plating. This technology has been studied extensively, 

demonstrated/validated, and put into use by the Department of Defense and aerospace industry 

for aircraft manufacturing and maintenance activities. The HVOF process typically uses an 

oxygen-fuel mixture consisting of propylene, propane, or hydrogen. HVOF guns use different 

methods to achieve high velocity spraying, but generally, fuel gases are mixed in the HVOF 
Future of Finishing, page 59 of 65

nozzle and the thoroughly mixed gases are ejected from the nozzle and ignited externally. HVOF 

is a supersonic process which delivers well over 7,000 fps of velocity.

With HVOF, the combustion temperature is 5,000 to 6,000 F, depending on the fuel mixture. 

Masked parts are fixtured and set in place for the HVOF gun to move around by robotic control. 

Processing is done in a HVOF booth or room enclosure due to the excessive noise generated by 

the process. The operator controls the HVOF processing from outside the HVOF enclosure, 

while looking through a window. 

HVOF has demonstrated bond strengths of 12,000 psi and relatively high density coatings. 

Processing time for HVOF coating a single part is less than for hard chrome plating (typically 

one to two hours compared to 4-8 hours). However, the equipment is much more expensive to 

purchase and operate for moderate to high levels of production. Performance testing has shown 

that in some cases HVOF coatings are equal to or superior to conventional hard chrome plating 

in wear, fatigue, impact resistance, and corrosion resistance. A limitation of HVOF is that it is a 

“line-of-sight” coating technology and therefore is generally not applicable to coating “inside 

diameters”. Also, HVOF is not a totally “dry” technology as deposited metals must be stripped 

from fixtures in wet process solutions and some of the HVOF coatings are very difficult to 

remove.

Another proven dry coating process is physical vapor deposition (PVD). PVD involves 

vaporization from coating material stock (evaporation, sputtering, arc vaporization, and chemical 

vapors and gases), transfer from the vapor phase to the substrate (line-of-sight, molecular flow, 

plasma-induced vapor ionization), and deposition and film growth on the substrate. PVD 

coatings can be harder and more corrosion-resistant than electroplated coatings and can be 

extremely durable. Examples of PVD applications include:

 Delta Faucet was the first company to use PVD technology to create patented anti-tarnish 

decorative faucet finishes. Delta Faucet guarantees these PVD finishes for life to never 

tarnish, corrode or discolor.

 Ion Vapor Deposition (IVD) Aluminum – The IVD process is a variation of PVD using 

low vacuum plasma-induced vapor ionization of aluminum. The IVD-aluminum process 

has proven effective for replacing cadmium in aerospace applications and has been used 

in several military and commercial aircraft systems, missiles, and helicopters. IVD 

aluminum has been tested to outperform cadmium in actual service tests and acidic salt 

fog, does not induce hydrogen embrittlement or solid metal embrittlement, and helps 

relieve problems with dissimilar metals and galvanic corrosion. 

Trend Analysis. Significant momentum has built in the aerospace industry to use HVOF to 

replace hard chrome plating. The joint U.S. and Canadian Hard Chrome Alternatives Team 

(HCAT) has worked extensively to evaluate and promote HVOF as a replacement for hard 

chrome plating. The HCAT team is made up of DoD repair depots, manufacturers, laboratories, 

airlines, equipment suppliers, and representatives of groups who must approve any chrome 

alternatives for DoD repair depots. Its primary customers are the repair depots, who use hard 

chrome in overhauling Army, Navy, and Air Force aircraft and helicopters. As a result some 
Future of Finishing, page 60 of 65

substitution has occurred within DoD. However, for most applications, hard chrome plating 

remains as the primary wear-resistance coating for steel parts.

While there is significant momentum toward use of HVOF and similar dry processes, there are 

some potentially significant barriers to implementation, including:

 Major equipment capital cost for thermal spray, including robotics, noise control systems, 

and air emission control systems.

 Requires much higher level of trained employee to operate than hard chrome plating.

 Often requires manufacturer to perform troubleshooting and maintenance.

 Verification/approval process is typically done on a part by part basis and can be drawn 

out and expensive.

 Because HVOF and other dry processes are limited to line of sight applications, facilities 

may need to operate dual processes (e.g., HVOF and hard chrome) in order to meet all 

production requirements. 

 In 2005, The California Air Resources Board has passed an airborne toxic control 

measure to reduce emissions of hexavalent chromium and nickel from thermal spraying. 

This regulation, which could be adopted by EPA and/or other states, will likely add 

significant air emissions control and/or monitoring costs to thermal spray operations and 

may therefore be a significant deterrent to implementation of new thermal spray 

processes. 

The main barrier with PVD technology is high capital cost as new systems typically cost a 

minimum of several hundred thousand dollars. PVD systems can operate at very high 

temperatures and vacuums, requiring special operating considerations. Even with the relatively 

high capital cost and special operations requirements, PVD technology has show ability to 

replace conventional wet processes and provide superior coating performance for certain 

applications while eliminating environmental, health, and safety (EH&S) issues with wet 

processes using metals like chromium and cadmium. 

Change substrate materials from finished metals to non-metals

In recent years non-metals like composites and plastics have replaced finished metals in a 

number of products. Composites are material systems that are typically non-metallic and consist 

of fibrous reinforcement of either glass (relatively low cost reinforcement), carbon (provides 

stiffness), Kevlar® (provides impact resistance), or other materials encapsulated in a hardened 

(or cured) matrix of any one of several hundred resin systems. These materials are characterized 

by their relative high strength-to-weight ratios when compared to more traditional metallic 

components. The commercial and military aviation/aerospace industries have led the 

development of advanced composite materials in recent years with the goal to produce 

lightweight, high-strength structural components. 

Composites can offer many material property advantages over finished metals: 

 stronger and stiffer than metals per unit weight, 

 highly corrosion resistant, 

 electrically insulating, 

 controlled thermal expansion and energy absorption or transmission properties can be 

engineered to fit the application, 
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 excellent durability, and 

 can be transparent to or engineered to absorb electromagnetic radiation . 

Composites can offer significant manufacturing advantages with relatively low capital 

investment in fabrication equipment compared to metals fabrication, and reduced manufacturing 

and assembly can be achieved by manufacturing composite parts that replace several metal 

component parts. 

An example of extensive use of composite materials is the military aircraft B-2 “Stealth” 

bomber. Most of the B-2 body is made from composite materials that are specifically designed 

to absorb radio waves. Highly reflective metal components, including the engines, fully 

retractable landing gear, and bombs are all housed inside the composite body. 

Composites have also been used increasingly in commercial aircraft manufacturing. Where 

composite materials comprised less than 5% of Boeing’s 737 and 747 aircraft, the Boeing 787 

will reportedly use approximately 50% composites by structural weight. The Airbus A380 will 

reportedly use more than 20% composite materials. 

Composite blades have been used in aircraft propellers, helicopter rotors, boat propellers, wind 

turbine generators and fans. Other recent composite material applications replacing finished 

metals include: missiles and spacecraft, automobile components, golf clubs and tennis rackets, 

bicycles, and jet skis.

Plastics have also been used to replace metal components in recent years providing benefits like 

lighter weight, electrically non-conductive, vibration dampening, and low corrosion. Like 

composites, plastics can offer some manufacturing benefits over metals like part consolidation 

into larger manufactured assemblies, ease of manufacturing complex shapes and reduced 

assembly. There is a wide range of design flexibility for plastics and they are easy to color and 

decorate. Metals offer advantages in applications where higher strength and stiffness, thermal 

and electrical conductivity, and flame retardance are needed. 

Amorphous plastics that have been used to replace metal components include: acrylic, 

acronitrile butadiene styrene (ABS), polystyrene, polyvinyl chloride (PVC), and polycarbonate. 

Crystalline plastic materials that have been used to replace metal components include: nylon, 

polypropylene, acteal, polyester, and polyethylene.

Processes for plating on plastics have been developed for many years for some applications 

where bright, polished metallic surfaces are needed (e.g. – automobile grilles). 

On the down side, recycling of composites is likely to pose more challenging problems than is 

the case for metal alloys.

Trend Analysis. Since composites are very lightweight compared to metals and have excellent 

and highly tailorable properties to fit specific applications, there will continue to be new 

applications developed where composites can provide superior performance and beneficial

overall life cycle cost to replace finished metals. One potential application for composites that is 

being considered is in Navy ships to achieve benefits like weight reduction and reduced magnetic 
Future of Finishing, page 62 of 65

signatures. Where composites have been used for niche applications in the automotive industry, 

research is ongoing looking into developing methods for higher volume automotive production 

of composite chassis and body panels. Composites are also expected to continue to grow in use 

in the aerospace industry. Research and development is ongoing for airplane fuselages and 

wings made from composite materials and manufacturers seem confident that demonstration and 

certification of the new airplanes with significantly higher portions of composites will be 

successful. 

Recently, fireproof composite resins have been developed resulting in panels that can withstand 

2000 F for up to 90 minutes; this overcomes a weakness of composites that can burn at 

relatively low temperatures. Nanotechnology may also impact the trend towards composite 

materials with nanoscale additives and nanoscale structures providing breakthrough material 

property enhancement.

There is significant potential for plastics to continue to replace metals in a number of 

applications. Developments in plastics engineering are anticipated to improve material 

properties, leading to broader use of plastics. One technology development that could boost the 

use of plastics is the development of plastics that conduct heat by addition of thermally 

conductive additives like specialty graphite fibers, carbon fibers, and ceramics like aluminum 

nitride or boron nitride. The production of thermally conductive plastics is currently limited by 

the relatively high cost of the additives.

Develop new metal alloys that reduce surface finishing requirements

Developing new metal alloys that provide sufficient corrosion resistance without the need for 

surface finishing using toxic chemical processes is a promising technology trend that addresses 

the need to eliminate use of certain surface finishing processes while not requiring a major 

change from existing substrate materials. 

The U.S. DoD has an ongoing project to demonstrate and validate a newly-designed, highstrength stainless steel alloy for use in aircraft landing gear applications to replace conventional 

high-strength, low alloy carbon steels. Preliminary material performance testing demonstrated 

that the new alloy, “Ferrium S53”, can provide the corrosion resistance necessary for landing 

gear applications without the need for cadmium plating. A number of application-specific 

benefits can be derived from the new corrosion resistant stainless steel alloys that lead to overall 

reduced life-cycle costs:

 Eliminate need for use of cadmium plating and all associated toxic chemical use, worker 

exposure, and waste disposal issues;

 Provide a superior performance alloy that will lead to fewer service failures;

 Decrease component repair frequency; and

 Reduced turnaround time for repairs

Besides the newly developed alloy, the U.S. DoD demonstration project is also demonstrating 

and validating computer modeling techniques to expedite alloy design and to supplement 

material property measurements with data from validated computer models.
Future of Finishing, page 63 of 65

Development of lower cost extraction methods for titanium ore could potentially provide less 

expensive titanium alloys and lead to wider use of titanium.

“Super alloys” based on nickel and cobalt are being investigated in attempts to improve 

performance in engine hot sections for blades, cases, disks, fasteners, shafts, and vanes. Jet 

engine efficiencies can be increased at higher operating temperatures, and new alloys can make 

this possible. Low-density aluminum-lithium and aluminum-magnesium-scandium alloys are 

being developed to reduce weight and compete with new composites that are being developed to 

replace aluminum structural components like wings and fuselages.

Trend Analysis. Developing new metal alloys that meet application-specific performance 

requirements with reduced or eliminated need for surface finishing using toxic chemical 

processes is a specialized material advancement requiring significant research, development, and 

demonstration/validation testing. The broader use of new metal alloys developed for specific 

applications are to be determined.

Nanotechnology shows promise with developing new metal alloys. An ultra-high strength 

stainless steel has been developed with nanotechnology. This nano-stainless steel demonstrates 

ultra-high strength, good formability, and good corrosion resistance. A high modulus of 

elasticity and ultra-high strength can yield components that are lighter than those made from 

titanium or aluminum. The nano-stainless steel is already in use in medical equipment and is 

expected to be used in lightweight chassis applications and sports equipment.

 

Develop nanotechnology

Nanotechnology deals with the creation of materials and devices in the nanometer size scale 

(typically 1 to 100 nanometers). A nanometer is one thousandth of a micron, one millionth of a 

millimeter, and one billionth of a meter. Individual atoms and molecules are in the lower range 

of the nanometer scale or a single decimal fraction of a nanometer.

The creation of nanomaterials through nanotechnology is being researched extensively and 

shows potential for significant impacts on surface finishing technology. Nanocrystalline finishes 

can be developed through vapor phase processing, inert gas condensation, mechanical alloying or 

high-energy ball milling, chemical synthesis and electroplating. Nanocrystalline coatings can be 

extremely dense with low porosity and with highly uniform fine-grained structure. Some 

benefits noted for nanocrystalline coatings and nanocrystals:

 Nanocrystalline metals can provide superior magnetic, hardness, optical, and corrosionresistant properties compared to conventional metal finishes.

 Nanocrystalline metals (nickel, cobalt, palladium, copper, and some alloys of these 

metals) can produce relatively thin coatings that are more wear-resistant than 

conventional electroplated finishes.

 Nanocrystalline metal coatings can reduce weight as thinner deposits can be used to 

achieve desired performance results.

 Nanocrystalline metals and alloys can have higher ductility and improved resistance to 

fatigue (due to the absence of microcracking).
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 Nanocrystalline metal and alloy plating can yield high current efficiencies, reducing 

hydrogen embrittlement issues.

 Nanocrystals of various metals are 100 to 300% harder than the same materials in bulk 

form.

An example of nanotechnology development in surface finishing is the ongoing research and 

development of nano-crystalline cobalt-phosphorous coatings and deposition processes to 

provide corrosion and wear resistance in extreme temperature ranges for landing gear and jet 

engine components and to replace conventional hard chrome plating. 

Trend Analysis. Nanotechnology is a broad-based technology initiative with significant 

funding. Dozens of universities and research organizations have created a broad range of 

nanotechnology R&D and education programs. Nanotechnology clearly has a strong link to 

surface finishing and surface finishing applications are and will continue to be an important 

focus area for nanotechnology development.

Remarks on technology trends 

1. ROI is the controlling factor. For individual companies or facilities, the estimated return 

on investment (ROI) is typically the most important factor in deciding whether or not to 

implement a process improvement or a new technology. An acceptable time to break-even 

typically varies from six months to three years, with an average around two years.

2. Greater awareness would increase investment in improvements. Technology already 

available today provides significant opportunities for: 

 optimizing conventional wet processes

 improving process monitoring and control (including automation)

 improving energy efficiency

 changing to greener process chemistries.

Many finishing firms appear to be unaware of the benefits and savings that they could 

achieve in a short period of time were these technologies to be applied.

3. Some of the newer developments will take a few years to become established. 

Nanotechnology, technology change to “dry” processes, and new metal alloys have 

demonstrated successes, but we expect the level of investment and the degree of impact to be 

relatively low over the next five years. But looking ahead between five and twenty years 

from now, we anticipate a significant increase in both investment and impact. 

4. Key process improvement technologies will remain important for several years. We 

expect a high level of investment over the next five years, moderating somewhat but 

remaining significant between five and twenty years from now, in the following process 

improvement technologies:

 Change to “greener” process chemistries

 Improved process monitoring and control (including automation)

 Improved energy efficiency
Future of Finishing, page 65 of 65

5. Product manufacturers in several sectors will continue moving toward substrate 

materials that do not need surface finishing. Manufacturers are already changing substrate 

materials from metals that require finishing to non-metals, particularly with composites in the 

aerospace industry and plastics in the automotive industry. We expect this trend to continue 

at a moderate to high level over the next 20 years.

6. Sustainable manufacturing will become increasingly important. Sustainable 

manufacturing is expected to have moderate to high relative investment level and industry 

impact over the next 20 years. Several of the technology trends contribute to more 

sustainable manufacturing: greener process chemistries, optimizing conventional wet 

processes to achieve near zero discharge and risk, improved process monitoring and control 

systems and improved energy efficiency. The other technology trends also show promise for 

increased sustainable manufacturing, including some potential for major improvements. 

However, each needs to be evaluated from the broad sustainability view to quantify. 

Sustainable manufacturing is already major commitment for some major corporations and is 

becoming an important pursuit for corporate image for some.

7. Points to keep in mind when evaluating improvements and innovations. A 

comprehensive evaluation of options should include consideration of:

 projected costs and benefits associated with improving or optimizing existing process 

systems, weighed against the cost of replacement technologies

 appropriate combinations of technology changes 

 phased implementation, so that actual cost savings can be verfied prior to additional 

investment