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Comment 46 for Proposed Amendments to the ATCM for Chromium Electroplating and Chromic Acid Anodizing Operations (chromeatcm2023) - 45 Day.

First NameCathy
Last NameReam
AffiliationTeikuro Corporation
SubjectChrome Ban
     It is not possible to put a timeline on banning hexavalent
chromium because there is not a "one size fits all" solution to
replacing hexavalent chromium coatings as the function  and
properties needed can be different for different products. 
Sometimes, it can even be impossible. 
     I have not worked with trivalent chromium but I understand
that the color is different than hexavalent chrome, usually a
whitish color.  Do you think consumers want "white" bumpers and
chrome trim on their automobiles and restored automobiles?  Do they
want a white kitchen faucet?
     Chromium electroplaters and anodizers in California have spent
hundreds of thousands of dollars, if not millions of dollars, to
meet the current low emmisions regulations for hex chrome.  Of
these companies, some are large and some are small.  Some would
survive a hex chrome ban, but many, especially the smaller ones
that only work with chromium, would not.  What happens to the
owners when they have to walk away from the money that they already
have invested?
     I have worked in the metal finishing business for over 40
years, chromic anodizing in the past and the majority of my career
and most recently with hexavalent chrome industrial electroplating,
so I am speaking about electroplating in that it is a unique
process and the operators have a unique and special skill.  Many
have spent the majority of their careers in this business and are
facing the possibility of losing their jobs if the ban is enacted. 
I understand that the industrial chrome ban won't be effective for
17 years, but the decorative chrome ban is much sooner.  With these
special skills, what kind of employment will they be able to obtain
at the ages a lot of them are?  Even in 17 years, most probably
won't be retirement age yet, so I don't think that you are
considering the effect it will have on the workers and their
subsequent employement....and the supply chain workers and
      The PFOS/PFAS issue is a whole, separate and different issue.
 PFOS was and PFAS  is being used legally.  Getting rid of hex
chrome should not have as it's goal to get rid of PFAS.

Original File Name
Date and Time Comment Was Submitted 2023-01-16 11:41:56

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