Comment Log Display

Here is the comment you selected to display.

Comment 21 for Proposed Amendments to the ATCM for Chromium Electroplating and Chromic Acid Anodizing Operations (chromeatcm2023) - 45 Day.

First NameJim
Last NameMeyer
SubjectEnjoy your Holiday Air Travel
Metal finishing disciplines support commercial aircraft. Decorative
chrome is mostly used on interiors. Functional anodize is used all
over the aircraft to protect parts from corrosion. Hard Chrome is
used to assure the correct function of thrust reversers, landing
gear, rudder and aileron actuators, propulsion systems, and other
flight and landing critical components.

If any members of the CARB board are traveling over the holidays,
you are only able to do so because the aviation industry has used
hexavalent chromium in California to keep you safe. 

Hard chrome platers support manufacturing, processing, repair and
maintenance of critical aircraft components. We follow the explicit
direction of engineers within the OEMs and the airlines, and use
federal and internationally recognized standards to perform the
work. In the United States, the design, production, and maintenance
of all aircraft are under the jurisdiction of the FAA who audit and
enforce the strict adherence to the requirements. Those
requirements dictate the use of hexavalent chrome. People go to
jail and/or are fined if regulations are not followed. 

The United States aviation infrastructure is interstate commerce.
Aircraft repair and maintenance is a necessary part of that
infrastructure. The CARB does not have authority to regulate
interstate commerce. 

Despite formal efforts by the US government and the aviation
community to identify a hard chrome alternative in the late 90's,
the industry has not yet found suitable alternatives. This ATCM is
not going to change the realities of physics, materials, etc.. Your
flight is only able to occur because hexavalent chromium makes it
safe and possible. 

Even the newest Boeing 787 aircraft which will be manufactured for
the foreseeable future and will fly for decades are designed to be
made and maintained with hexavalent chrome. Every aircraft in the
world contains a part that was hexavalent chrome plated in
California. Aircraft have usable lives spanning decades and will
persist beyond 2039. The California economy depends on tourism. A
hard chrome ban is misguided hypocrisy.

Enjoy your flight.

Original File Name
Date and Time Comment Was Submitted 2022-12-22 08:56:05

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

Board Comments Home