First Name | Bobbi |
---|---|
Last Name | Burns |
Email Address | bobbiburns@sbcglobal.net |
Affiliation | |
Subject | Amendment to Chrome ATCM |
Comment | For those reading public comments that may not be aware, Hexavalent Chromium can be found in many places in our everyday lives. Besides nature and plating shops, Hexavalent Chromium is found within industries of aerospace, ground transportation, concrete, welding, leather tanning, wood preserving, fireworks (there goes Disneyland), cosmetics, cleaning agents and tobacco. Some everyday items include products in our home like electronics, fixtures, hardware, furniture and keys. The Chromium finishes are essential to automobiles including electric cars, aerospace, industrial machinery, dies and molds; metal finishing adds a variety of protection, wear resistance, and in some cases restoration. Permits, inspections, testing and fees are the standard for any Chromium plating facility in California. Regulations here in California are the most stringent in the USA. California sets the standard and is the leader of environmental innovations in the Country. The proposed ban on Decorative Chrome in the upcoming amendment to the ATCM simply doesn't make sense. Banning the Decorative Chrome process here does not make the demand for the finish go away. There are countless manufacturing and restoration companies here in this State that will have to close or ship parts to other States, other States that have little to no control on the process, creating a new wave of problems. The technology used today to prevent pollution is superior to what was used decades ago. "In 2007, to further protect the public, CARB adopted additional amendments to the Chrome Plating ATCM, resulting in the most stringent and health protective emission standards applicable to chrome plating operations in the nation." This sentence was plucked straight from CARB's website. Since 2007 there has been a significant reduction in CrVI emissions from plating facilities. We account for less than 1% of the total CrVI emissions in the entire State. My point is that we are not a failed regulated industry. The proposed amendment should create an emission base rule for all covered process equally. The Decorative, Functional and Chromic Acid Anodize have the same chemistry so why ban just one? The amendment should be an emission based rule for any hexavalent chromium process. The Decorative Chrome process averages 10k to 40K amp-hrs annually but the Hard or Functional Chrome and Chromic Acid Anodize process can run-up to and over a million amp-hrs annually. It is discrimination. Proposing alternatives such as Tri-Chrome for decorative finishes should be an alternative, not the only choice. If a Decorative Chrome facility is meeting the emission standard, under the threshold or non-detect for CrVI emissions then why shut it down? The ATCM Amendment should be based on science and data, not emotions. Imposing a discriminatory ban on this process sets a bad precedent for California. I strongly urge CARB to stand by the side of California businesses that have maintained compliance and continue to invest in better technologies so that we can continue our craft and be of service to not only the large manufacturers but the hobbyist and enthusiasts that rely on our finishes. The stationary source of this hexavalent chromium is under control of not only the Operators, who are certified by CARB's program but also by the local Air Districts. I am a second generation metal finisher for over thirty years. I am in good health. My long-time employees are in good health. If I thought I was endangering my family or community we wouldn't be in business. Thank you for reading my comments. Biological fun facts: Ingested Cr(VI) is efficiently reduced to the Cr(III) by the gastric juices [De Flora, Badolati et al. 1987]. Cr(VI) can also be reduced to the Cr(III) in the epithelial lining fluid of the lungs by ascorbate and glutathione (Petrilli, Rossi et al. 1986; Suzuki and Fukuda 1990). Once absorbed into the bloodstream, Cr(VI) is rapidly taken up by erythrocytes after absorption and reduced to Cr(III) inside the red blood cells. In contrast, Cr(III) does not readily cross red blood cell membranes, but binds directly to transferrin , an iron-transporting protein in the plasma (made by the liver) EPA 1998; ATSDR 2000; Dayan and Paine 2001]. |
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Date and Time Comment Was Submitted | 2022-12-29 13:13:44 |
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