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Comment 14 for Proposed Amendments to the ATCM for Chromium Electroplating and Chromic Acid Anodizing Operations (chromeatcm2023) - 45 Day.

First NameJason
Last NameWenig
AffiliationOwner/President - The Creative Workshop
SubjectComments regarding the Hexavalent Chromium Airborne Toxic Control Measure (ATCM)

To whom it may concern:

My name is Jason Wenig and I am the owner of The Creative Workshop. The Creative Workshop is a nationally recognized, highly specialized car workshop business – noted for the forensic restoration of rare, exotic and unique, historically significant automobiles.

I am writing this letter as a representative of a billion dollar industry that works hand and hand with the decorative chrome industry – an integral and critical part of the highly specialized work we conduct.

Specifically, it seems California is looking to ban all use of Hexavalent Chrome. The subject of this initiative through CARB is “Hexavalent Chromium Airborne Toxic Control Measure (ATCM) for Chrome Plating and Chromic Acid Anodizing Operations”.

I have been deeply involved in the automotive world for over two decades and have worked with countless suppliers, craftsmen and supporting industries. My company was named a “Top 20 Restoration Company” in the country in 2018 by one of the industry’s leading publications and I was awarded “Master Craftsmen of the year” in 2019 by the America’s Automotive Trust. My biography is attached for further reference.

The vehicles entrusted to my company are some of the rarest and most valuable in the world, and require a diverse set of skills and supporting infrastructure to work on them.  Akin to rare artwork or historic building restoration, the vehicles we work on are meticulously and authentically rebuilt – using historical archives, original factory drawings and documents and numerous other, sometimes rather arcane methods. In addition, the materials, supplies and technology utilized to restore and maintain these historic artifacts are equally obscure.

Vintage cars touch all walks of life – and have become something much more than a niche hobby. To further reinforce this reality and the nature of these vehicles, we work with the Historic Vehicle Association, which is working in collaboration with the U.S. Department of the Interior in developing a National Historic Vehicle Register to carefully and accurately document and recognize America’s most historically significant automobiles, motorcycles, trucks and commercial vehicles. This project is the first of its type to create a permanent archive of significant historic automobiles within the Library of Congress.

As you can imagine, working with historically significant vehicles – and in turn, our collective history – details matter. As historians entrusted with this responsibility, when considering these details, “close enough” is not good enough. There is “correct” and “incorrect”, “right” and “wrong”. We work incredibly hard to ensure that restorative work is done correctly and right. Along these lines, the coatings used throughout the history of the automobile is very much a part of our responsibility to get right, and quite simply put – there is no substitute for proper, Hexavalent Chrome. Historians, collectors, aficionados, curators – we all know the difference between “proper decorative chrome” vs alternatives. Alternatives cannot be used and should not be used on these incredibly valuable and coveted assets.

Said another way, house paint would not be used to restore a Picasso just as plywood would not be used to restore a Tall Ship. To the untrained or uneducated eye, paint is paint and wood is wood – but for the integrity of our history, there is obviously a rather large difference when it comes to “correct” and “right”.

How we protect our history comes down to the front lines of the craftsmen that are entrusted to restore and maintain it – and the “tool kit” we have available to us, simply cannot be diminished.

What further complicates this situation is that the number of businesses dedicated to automotive decorative chrome continues to shrink – with a troubling few businesses left that are capable of doing this kind of work. The few that do remain, simply must be protected - we can’t afford to lose any more plating companies – wherever they may be located. For instance, we work with Sherm’s Custom Plating in Sacramento, California ( It took us years to find them. We performed tests with numerous companies located around the country, and only Sherm’s had the skills, capabilities and understanding of how to deliver correct, authentic chrome for historic cars.

An outright ban on this industry in California will cause irreparable repercussions that will ripple throughout the industry – not just for the plating companies located in California, but to and through all of the companies that rely on their services to “get the job done right” across the Country.

Massive events around the world celebrate the automobile – including the most prestigious car event in the world - the Pebble Beach Concours d’Elegance located in Monterrey, California. Cars invited to and displayed at Pebble, set the standard for the history books. The wealthiest individuals in the world attend, and the most valuable vehicles in the world are on display. Hundreds of millions of dollars of automotive history are on display every August – and simply put, chrome alternatives would never be accepted during the judging process – whereby the best and correctly restored vehicles are awarded. This reality would repeat itself at events the world over.

What’s interesting and salient is that the volume of materials and supplies used for this critical work is small compared to its importance, and pales in comparison to the volumes used in general industry, where chrome alternatives could readily be accepted. Penalizing small boutique businesses (and the low volume of supplies they use) to solve a problem that is fundamentally not caused by this group - that is already tightly regulated - is both near-sighted and counter-intuitive. The benefit to result ratio is completely off by targeting the decorative or even specifically, the automotive show chrome industry.

The decorative chrome industry, as well as other supporting disciplines to the automotive world, are used to operating under regulations and controls – including proper hazardous waste disposal, limitations on volume, specialty filtration and particulate control, etc. We understand this is done so a partnership between business and protecting our environment can establish itself. This balance and partnership is in place and evolves as necessary. An all out ban, of the entire industry in California – combining low-volume automotive businesses along with larger commercial or industrial platers, again, seems counter-intuitive.

For the record, I am particularly sensitive to this subject matter and debate. I am originally from New York, where my Father, the late Dr. Jeffrey Wenig, was director of Environmental Protection during the 1970’s. I grew up with the environment and our care of it, as an integral part of our lives. I take these matters very seriously and I am not writing this letter and voicing my opinion arbitrarily. I am hoping that healthy debate and logical terms can be established for the benefit of all parties involved.

All said, I implore you to understand the true nature of our industry and its reliance on a small portion of the Hexavalent Chrome that we use – and to engage with the vested community, so that we can continue forward in collaboration and partnership – considering all implications to our industry, our history, jobs and of course the environment.

I am available to provide any additional information or discuss in any way to help further this process along.

Thank you,

Jason Wenig

Owner and President

The Creative Workshop

118 Hill Street

Dania Beach, FL 33004


Original File NameATCM - Concerns.docx
Date and Time Comment Was Submitted 2022-12-13 16:41:17

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