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 customers. 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.
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|Date and Time Comment Was Submitted||2023-01-16 11:41:56|
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