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Comment 33 for Proposed Amendments to the ATCM for Chromium Electroplating and Chromic Acid Anodizing Operations (chromeatcm2023) - 45 Day.

First NameJim
Last NameMeyer
Email Addressjmeyer@aviation-repair.com
Affiliation
SubjectLess than 2 Hex Chrome Cancer Cases in California (Annually)
Comment
It would be nice if there were a reliable source of data from which
to perform these calculations. See my previous comment(s).

But using the data we have... 

The California population is around 40 million. So using the most
recent CARB data that show a cancer case rate attributable to hex
chrome of 16 per million, that computes to 640 cancer cases from
hex chrome annually statewide. See my source here -
https://www.arb.ca.gov/adam/toxics/statepages/cr6state.html

How many of those are from chrome platers?
 
CARB's Appendix B states chrome platers emit 0.90 pounds of hex
chrome annually. SC AQMD states that there are 0.8 pounds per day
of Hex chrome emissions in the South Coast basin (see data in SC
AQMD MATES V Table 3-4) from all sources. That computes to 292
pounds annually (0.8 X 365 = 292). So in the South Coast area
chrome platers make up 0.3% (0.9 / 292 = 0.0031) of the hex chrome
emissions in the area that everyone would agree contains the
highest percentage of chrome platers in the state.

So, since chrome platers make up 0.3% of emissions we can compute
the cancer cases attributable to chrome platers as 1.98 cases per
year. 

1.98 CANCER CASES PER YEAR IN CALIFORNIA FROM HEX CHROME
ATTRIBUTABLE TO THE ENTIRE CHROME PLATING INDUSTRY!!
 
Who is in control of CARB? What is the agenda? Setting priorities
is one of the most basic functions of management. CARB has spent
three years on this rule making.

Attachment
Original File Name
Date and Time Comment Was Submitted 2023-01-09 16:04:38

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