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Comment 8 for Proposed Amendments to the ATCM for Chromium Electroplating and Chromic Acid Anodizing Operations (chromeatcm2023) - 45 Day.

First NameKeaton
Last NameCurran
AffiliationMacDermid Enthone - Global Chemical Supp
SubjectFrom a Global Supplier of Plating Solutions
Hello to all it may address,

My name is Keaton Curran. I am a product management specialist for
decorative finishes and plating on plastic at MacDermid Enthone, a
global chemical supplier of plating solutions.

As a global supplier we share in the many woes and goals of
regulators, OEMs, and our customers -the chrome applicators - that
impact and guide this great industry. The goals and woes that we
are here discussing today, the elimination of hexavalent chrome, is
one we have listened to and made strides with at all levels of
impact on this industry. Our teams around the globe have called
upon and listened to applicators, OEMs, and regulating bodies to
guide our product offerings and market direction well into the
future.   Today, we recognize and share with many across the
industry the goal to offer sustainable solutions and meet our
customer needs.

These sustainable alternatives technologies are growing and
improved upon each and everyday as we commit to these goals but
also these alternatives have carried many hurdles for the industry
to adopt.

In the Decorative segment, a sustainable alternative solution we
offer is Trivalent Chrome. Today, Trivalent Chrome with the newest
generations can offer matching colors, new colors, leading
corrosion resistance, and exceptional uniformity of deposits. But
it's not as simple as pumping out hexavalent chrome tank, scrubbing
down the line, and pumping in Trivalent Chrome. Applicators must
adopt new equipment, train on new analyses, implement new
maintenance techniques, finalize local and regional permits, test
and market to current or new customers, and of course have the
space available, time, and financial capital to complete the

New technologies in Plating on Plastics eliminating Hexavalent
Etchants from the Plating on Plastics segments are also growing
acceptance into the industry. The fully Chrome-Free alternatives
have taken foot largely due to Automotive OEM commitments to
sustainability and expansion into new end use industries such as
aerospace and electronics but these technologies too have high
hurdles and high financial costs to implement. Many applicators in
Plating on Plastics will be required to construct or rebuild up to
half of their existing manufacturing line to implement these
alternatives technologies. This will incur vast costs, well above
the presented estimates by CARB, for line construction, testing,
implementation, permitting, and lost production time during

OEMs and their Tier level customers share in these many hurdles as
the risk to ensure retesting, re-PPAPing, and approvals are met
without interrupting the delicate supply chain this Industry
operates on.

Functional Hard Chrome applications eliminating hexavalent chrome
are not in our opinion industrially available today and any viable
technology are still years away. The development and adoption of
such technology will require extensive time and resources to
achieve a hexavalent chrome free industry.

As we step forward towards these goals and through the many hurdles
our teams at MacDermid Enthone ask with great magnitude to ensure
fully adequate funding and reasonable timeliness for applicators
and their customers to step firmly into these alternative

Thank you for your time, and please accept our open hand of
support, to everyone here today, to discuss any and all alternative
technologies we offer.

Keaton Curran 

Original File Name
Date and Time Comment Was Submitted 2023-01-27 09:46:44

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

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