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We thought PFAS was going to be better than what came before.... but.... 
Over time, we find that some products do interesting things and are better than the alternative.   Sometimes, however, we find out that what we brought in to solve one problem created other problems.   Several industries, including electroplating, through that using PFAS as an additive would take care of losing the prior products, PFOS, from their plating baths.   Both PFOS and PFAS suppressed chromium mist.  However, PFAS has now been found to be problematic. 

I have worked with a world-class electroplating chemical manufacturer for thirty years.   In recent years, I've had the privilege of working with several electroplating companies in navigating the regulatory minefield that has become PFAS.   Specifically, NESHAP Subpart N didn't anticipate that the 2020s generation of chromium mist suppressants would not need to keep bath surface tensions below 33 dynes/cm.  And that the water and waste discharges would become so problematic that agencies are starting to regulate all things PFAS.   

Raiders Law is on the front lines of dealing with the PFAS problem, working as a technical consultant throughout the United States, working with EPA and several state agencies to navigate the PFAS problem and various solutions to keep platers and others in business while solving the PFAS problem.  Call us to discuss further.   

Raiders Law PC

Practicing business, environmental, land use and personal law.

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