|Subject||Demise 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 substantial. 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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