CARB Releases Draft Regulatory Language for Chromium Plating Rule

On April 26, 2022 the California Air Resources Board (CARB) held its 7^th Technical Working Group meeting of the hexavalent chromium air toxics control measures (ATCM) rule and released its draft regulatory language for the rule.  The draft language includes a ban on hexavalent chromium decorative plating by January 1, 2026 and a ban on hexavalent chromium functional plating and anodizing by January 1, 2039.  CARB will conduct technical reviews for functional plating and anodizing prior to 2039 to determine is non-hexavalent processes are commercially available.  The rule would also not allow any new permits for hexavalent chromium operations and would impose strict new emissions controls on facilities until the bans become effective.

NASF and the California Chapters continue to oppose the bans on hexavalent chromium plating, because banning the use of hexavalent chromium will produce significant negative economic impact for facilities, the surface finishing industry in California and the employees and their families that rely on these high-quality jobs.  Unfortunately, for many decorative plating facilities, trivalent chromium processes are not an option as customers prefer hexavalent chromium to achieve a desired product quality (e.g., color and luster) for plated parts.

In addition, these sources have the lowest existing emissions of hexavalent chromium of any sources. Forcing these sources in California to close would provide little, if any, environmental and public health benefits.

Throughout the rule development process, industry stakeholders have urged CARB to abandon the bans on hexavalent chromium processes and set an emission-based rule. The surface finishing industry has been successful in managing risk associated with hexavalent chromium and has significantly reduced hexavalent chromium emissions. NASF has highlighted USEPA data indicating that the industry has reduced its hexavalent chromium emissions by over 99 percent since the baseline year of 1995. In light of increasingly stringent local and state requirements in California, reductions of hexavalent chromium emissions in California have been even greater.

The surface finishing industry continues to urge CARB to set the lowest achievable hexavalent chromium emission limits based on best control technologies in place. The industry welcomes the opportunity to work with CARB to identify the appropriate hexavalent chromium emission limits that are protective of human health and the environment and sustainable for the industry and its critical supply chains.

NASF continues to work with and support its California Chapters on this effort.  If you have any questions or would like additional information regarding this rulemaking, please contact Jeff Hannapel with NASF at  jhannapel@thepolicygroup.com.

This update is courtesy of the National Association for Surface Finishing (NASF). For more information or to become a member, visit nasf.org.