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Brush Plating; Regulations

Hello: Thank you very much for the information that you provide and for steering me away from home tank plating. I am interested in brush plating. I have researched the subject quite extensively. Suddenly, I have seen what appears to be a flood of brush plating machines in the market place.

Question: Do you know of any pending or recently passed EPA guidelines that could be responsible for this; such as increased disposal regulations, etc.? Where may I obtain the guidelines for brush plating disposal regulations?

Len Turner
- Danville, Arkansas, USA

Having spent a career in designing plating shops and wastewater treatment systems, I have always eagerly tried to fully understand and track the EPA guidelines for small operations--without a lot of success I confess. To me it seems clear that all plating businesses are subject to either CFR413 or CFR433, no matter how small they are. But I have never found a clear delineation of who is not subject to CFR413 and CFR433.

It became apparent to me, for example, that some 'University Laboratories' do not consider themselves subject to these regulations even if they are in fact not university laboratories at all but actually businesses that operate on university property.

The following is not an interpretation you can bank on, only what I think-- but it seems that if you are a hobbyist you are not subject to the regulations. As soon as you sell a plated product, you are. This does not mean that you can operate with impunity even as a hobbyist because the fine print in your sewer contract says you can't discharge this kind of waste, and if you contaminate the land you will no doubt be held responsible.

Ted Mooney,
Ted Mooney, P.E.
Striving to live Aloha - Pine Beach, New Jersey

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