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Comment 79 for Proposed Amendments to the ATCM for Chromium Electroplating and Chromic Acid Anodizing Operations (chromeatcm2023) - 45 Day.

First NameBrad
Last NameKerr
SubjectDemise of Chromium Electroplating
To whom it concerns....There is no good reason to destroy an
industry when you have an alternative in rule 1469. If CARBS
alternative is implemented the repercussion can affect many jobs in
California and the beginning of the end to the aerospace industry
in Southern California. 

Having been in this industry for nearly forty years I have seen the
worst and best of chrome electroplating.  Honestly I can say the
worst is behind us with restrictions and controls that were
warranted, but that change began many years ago.  Today our
industry is tightly regulated, to the point chromic acid omissions
have a negligible impact on our air quality or our environment in
general.  Lack of documentation of detrimental affects of
hexavalent chromium with the restrictions in place today is really
alarming.  It is to the point of overkill and the impact can be

The demise of decorative hexavalent chrome plating will impact our
manufacturing industry and actually create other forms of
pollution.  Just consider the cost of companies to send parts
across our border to other States and Mexico.  The pollution
created to transport the parts is likely worse.  Consider the cost
to companies that will have to relocate for surely they won't be
able to compete with sending parts out of our state.

Then you attach the Aerospace industry which is the heart of SoCal
manufacturing.  Chromic anodize, hard chrome plating are critical
to this industry.  It will drive these companies out of our state
to areas that would welcome our jobs.  Even if the technology
existed the aerospace industry literally takes decades to approve
and change process.  But again why put our industry through so much
anxiety when there isn't documentation that todays standards
actually are detrimental to our environment.  Save jobs and truly
understand that ruling against hexavalent chromium electroplating
is the beginning of over regulation that will force so many types
of manufacturing out of our state or country.

Brad Kerr

Original File Name
Date and Time Comment Was Submitted 2023-01-17 22:33:13

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