Comment Log Display

By Ted Ventrescsa President/COO CHEMEON Surface Technology

Due to time limitation for in person comments at the January 27th
meeting, CHEMEON representative, Mr. Frank Aguilar was  unable to
present the following on behalf of CHEMEON.  

CHEMEON is a proud member of the Metal Finishing Association of
California and is regarded as a global expert in the alternative
chemistries used to replace hexavalent chrome as a conversion
coating on light metals and as a replacement for sodium
dichromate/dilute chrome as an anodic seal. Our company mission and
vision align with the CARB goal to reduce and ultimately remove the
known carcinogen, hexavalent chrome. 

Over the past year, we have followed the Proposed Amendments to the
ATCM by CARB. We agree with the Metal Finishing Association that
the recommendations and proposals put forth by CARB will have a
severe impact on the metal finishing industry, the communities,
people, and businesses of the state who rely on the essential work
being done by the metal finishing industry, and unfortunately, it
would not achieve your admirable goal regarding the reduction and
ultimate removal of hexavalent chrome.  

To truly rid California, the U.S., and the world of continued use
of hexavalent chrome, the root cause of usage must first be
addressed. And, to be clear, the Metal Finishing Industry of
California is not the root cause. 

The root cause of the continued use of hexavalent chrome for
plating, finishing, conversion coating, and anodic seals is a
direct result of legacy specifications that, for over 70 years,
have required the use of hexavalent chrome by the manufacturers of
these parts and products, including many of those used by the U.S.
military and the Department of Defense. 

Until specifications allow for safer alternatives or remove
hexavalent chrome from the specification completely, the chemistry
will still be used.   

Why have some OEMs been slower to change specifications that still
require the use of hex chrome on certain metal parts? Possibly due
to their internal legacy systems and -- in some cases -- legacy
safety standards that may need extensive new testing and validation
to deviate or change from legacy chemistry. Certainly, the state
and federal governments understand the time involved in changing,
modifying, or moving away from legacy or outdated procedures. 

When CARB and other state and federal agencies address the root
cause of the issue, change becomes possible, and solutions become
clear.  

In recent years, the DoD and the automotive industry have made
great strides in the elimination of hexavalent chrome use at
military bases, depots, and commercial vehicle production. We know
this firsthand because CHEMEON products have provided some of the
safer alternative solutions. Through collaboration with OEM's Prime
Contractors -- and the DOD directly -- we have identified and
developed military-specified alternative chemicals and process
solutions to legacy hex chrome specifications. Hex chrome usage has
been significantly reduced by the DoD.   

How can CARB address the root cause of hexavalent chrome without
the harm to the state economy and Metal Finishing Industry of
California?  

We ask you to consider the following steps for CARB to implement in
an effort to truly help end the use of hex chrome for California
and the world:  

1.	 In the next six months, CARB and SCQAMD researchers will work
with industry and metal finishers to identify all part
specifications or industry coating standards that still call for
the use of hexavalent chrome. 

2.	 Take that information and begin collaborative work between the
OEM and Prime Contractors, safe chemical solution providers, and
metal finishing and process shops in a unified effort to test,
validate, and amend the specifications or to allow process shops in
California and across the U.S the ability for a "deviation" from
the hex chrome specification to alternate safe chemistries like
CHEMEON and other Tier 1 chemical manufacturers have created and
are available right now.  

3.	 CARB and SCQAMD may consider routing the funds slotted to
enforce your proposed updates to the ATCM instead to support and
incentivize collaborations between industry, safer chemical
manufacturers, and process facilities to accelerate their work to
identify, test, and implement existing alternatives to hexavalent
chrome.

4.	Work with the U.S. EPA and other federal agencies to require the
elimination of hexavalent chromium at the root cause: the
manufacturers who continue to require that this product be used
instead of the alternatives that are already on the market.

This approach will not only save jobs, but it will ultimately save
lives and the California economy. 

Please consider CHEMEON a resource in helping you implement
positive chemical and business solutions that protect the
environment, communities, and jobs related to the Metal Finishing
Industry of California and beyond.

Thank you.
Ted Ventresca
President/COO
CHEMEON Surface Technology
Chemeon.com/etcp