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Comment 1 for Proposed Amendments to the ATCM for Chromium Electroplating and Chromic Acid Anodizing Operations (chromeatcm2023) - 45 Day.

First NameJim
Last NameMeyer
SubjectCARB Board Governance / PFAS / Falsehoods

To the CARB board members,

CARB states in the Initial Statement of Reasons for the ATCM (ISOR, Page 8, second paragraph of 2. Environmental Impacts and Benefits), and I quote,

“An additional co-benefit of the proposed phase out is the elimination of perfluoroalkyl and polyfluoroalkyl substances (PFAS/PFOS) contained in the fume suppressants used in chrome plating operations.”

The quoted statement contains the following falsehoods.

False Statement 1 - “…contained in the fume suppressants used in chrome plating”. The reason this is false is because according to the CARB website here, the use of PFAS/PFOS fume suppressants has been banned in California since 2016.  CARB maintains a list of approved and unapproved fume suppressants here You can verify that the footnotes show the PFAS/PFOS fume suppressants are not allowed.

False Statement 2 - “An additional co-benefit of the proposed phase out is the elimination of perfluoroalkyl and polyfluoroalkyl substances (PFAS)”. The reason this is false is that a benefit can only exist when change occurs as a result. In this case, there is no change. Fume Suppressants are not being used by California chrome platers. So, no co-benefit is achieved by eliminating something already eliminated.

I provided this comment to the staff previously in one of the recorded working meetings. I am disappointed that it remains in the documents that are now being presented to the Board for decision. The inclusion of PFAS/PFOS as a co-benefit is a dog whistle that un-necessarily attracts attention to this rule-making and increases pressure upon the board to make decisions which are not based on current facts and data. If the board truly believes that PFAS/PFOS are still being used by chrome platers in California then it is an enforcement failure which would shine the light directly upon the CARB.

As an individual decision maker on the CARB board, you should ask yourself these questions.

1)     Why is staff adding this element to the decision I am being asked to make?

2)     Are the other benefits of the proposed ATCM so weak that these falsehoods and this appeal to emotion were necessary?

3)     Does CARB staff respect the independent decision-making authority of the board or is the board a rubber stamp?

Thank you for your service on the CARB board.

Original File Name
Date and Time Comment Was Submitted 2022-12-02 09:47:30

If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.

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