Comment Log Display

Here is the comment you selected to display.

Comment 6 for Proposed Amendments to the ATCM for Chromium Electroplating and Chromic Acid Anodizing Operations (chromeatcm2023) - 15-3.

First NameDavid
Last NameHill
Email Addressdavidhill@electrolizingofla.com
AffiliationElectrolizing
SubjectHEX Chrome Ban
Comment
Our company is a chrome plating processing facility in Los Angeles
CA since 1947. We have been processing parts for aerospace, medical
equipment and military equipment applications among others.  We are
a necessary and essential business provider for our customers in
their various industries. Military and commercial aircrafts require
what we process as well as outline how we process. All
environmental and regulatory requirements set forth by the state of
California are the strictest in the nation and therefore required
to be adhered to in order to remain open and processing. The
regulations currently in place are specifically outlined to ensure
that NO harmful chemicals are being discharged into local waterways
or into the air from our facility. The county of LA is thoroughly
monitoring and testing all facilities to ensure current compliance
for PFAS and hexavalent chrome restrictions. We are a facility that
has been tested and found to be in full compliance with no
detriment to our employees and local environment. 
We here at Electrolizing have invested over $1 million to ensure
the safety of our employees and surrounding community. There is no
suitable alternative that would comply with the specification
requirements for original equipment manufacturers in aerospace.
Industrial chrome processing is highly regulated to ensure
environmental and personnel safety. Our processing is situated as
such that we emit no hexavalent chromium into the air at any time.
We have been a spearhead in the industry for air quality by adding
highly specialized covers and hydrogen gas absorbing filament in
those covers which filter/ resist 100% of the hexavalent chromium. 
 
What has not been published is what the industry is doing to ensure
that any detriment to the local population or environment is
mitigated / eliminated. Advancements in information that is
available as well as requirements that are currently being adhered
to are not mentioned. The article notes that California has the
strictest laws in the country regarding this issue.
With the time and dollar value invested for health and safety, our
company has taken into consideration far more then what was listed
or not listed in the article regarding what the industry is doing
to prevent any further detriment to the air, landscape and
waterways. Furthermore, our stance is that we should not be
included in the 2039 ban on hexavalent chrome use in California
based on the fact that we emit no hexavalent chrome fumes during
any point in our process. Being classified as an essential business
during COVID we continued to serve our US military and commercial
air crafts during the pandemic with industry leading parts to
ensure upmost safety. As a locally female owned business, we would
be remis to fall under the same classification as the unregulated
or noncompliant companies. 
Thank you for your consideration,
Susan B. Grant 
Owner / General Manager 

Attachment www.arb.ca.gov/lists/com-attach/457-chromeatcm2023-BmNROwBkVGQEdlAi.docx
Original File NameElectrolizing letter.docx
Date and Time Comment Was Submitted 2023-10-30 14:32:51

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


Board Comments Home