CA Proposes Banning Hexavalent Chromium
According to reports, a new proposal from the California Air Resources Board would ban the use of hexavalent chromium in decorative plating by 2027 and in industrial durability materials, such as in anti-corrosive coatings, by 2039.
The material, also referred to as chrome-6, is used to provide a silvery finish on consumer products, as well as provide rust-resistant coatings for aviation components. However, CARB has reported that the health hazards of the plating process are felt in low-income communities, posing a “substantial” cancer risk.
“We would be the first jurisdiction in the world to phase out hexavalent chromium in the plating industry,” said Jane Williams, Executive Director of California Communities Against Toxics.
“Even the EU hasn’t done it because they haven’t found a substitute for crucial uses. We would be working with the industry and the military to actually identify new coatings. That’s precedent setting,” said Williams.
Chrome-6 in California
According to the California government, chrome plating is the process by which an electrical charge is applied to a plating bath containing an electrolytic salt (chromium anhydride) solution. The electrical charge causes the chromium metal in the bath to fall out of solution and deposit onto various objects (usually metallic) placed into the plating bath.
This electrical charge during the process causes the hexavalent chromium to be emitted from the bath as an aerosol that, once emitted from the facility, can be inhaled and entrained inside the lungs.
California moves to ban chrome plating in next wave of environmental protection actions https://t.co/1mKl1WC3D3— Integrated Logistics Services (@IntegratedLogi5) January 30, 2023
First identified by the state as a toxic air contaminant in 1958, CARB found that hexavalent chromium should be considered a human carcinogen for which there is no safe threshold exposure level.
In 1988, an Airborne Toxic Control Measure (ATCM) was adopted to reduce hexavalent chromium emissions from both decorative and hard chrome plating facilities, as well as chromic acid anodizing operations. This measure reportedly reduced overall emissions from these facilities by 97%.
In 1998, the ATCM for Chrome Plating and Chromic Acid Anodizing operations was amended to establish equivalency with federal standards. These amendments did not change the limits already in place, but established separate limits for new sources.
Then, in 2006, amendments were made once again in an effort to further protect the public, setting fort the “most stringent” emission control requirements in the country. These amendments were adopted and became legally effective in 2007.
Generally, except for small facilities, the limits require the installation or the upgrade of add-on air pollution control devices at the plating tank.
The Los Angeles Times reports that there are over 110 chrome-plating facilities in California, with more than 70% of them located in disadvantaged communities. Los Angeles County reportedly has the greatest concentration of chrome platers in the nation.
Latest Proposal, Controversy
At a public hearing on Jan. 26, CARB reportedly heard from dozens of members in the metal finishing industry regarding the matter. Bryan Leiker, Executive Director of the Metal Finishing Association of California, said that these facilities are already required to comply with the strictest regulations in the nation, and that an outright ban would only compel businesses and jobs to leave California.
“California is trying to force something to happen that’s not ready to happen,” Leiker said. “The consequences are going to be disastrous, because you can lose an entire industry.”
CARB reportedly hopes that the proposed rule would encourage facilities to switch to trivalent chromium, which is a less toxic alternative. However, it has not been widely used in decorative plating due to its darker color.
“It’s a different color and it just wouldn’t look right on these older cars,” said Elayne Bendel, who is on the board of the Lincoln and Continental Owner’s Club Western Region. “It would never match what came out of the factory, let’s say, in 1960 or sometime back there.”
If adopted, Bendel said classic car owners here would probably have to send their parts out of state to have them chromed, making a difficult hobby even more expensive.
“There’s a scarcity of labor, a scarcity of parts, and if the ability to get good chrome locally goes away, then that’s just another aspect of the difficulty with owning these cars,” she told the Times.
Classic cars aside, California is also home to some of the world’s largest aerospace companies and defense contractors, where trivalent chromium coatings have not been proven to meet U.S. Department of Defense specifications for thickness, hardness and corrosion resistance.
“The Department of Defense is looking into less toxic alternative coatings to hexavalent chromium, including applications via additive manufacturing processes,” Navy Lt. Cmdr. Timothy Gorman, a Pentagon spokesperson, said in a statement.
“We will continue to work with our public and private industry partners and communicate on potential changes in this area,” said Gorman.
State data notes that California’s 58 large chrome platers produced less than 1% of hexavalent chromium pollution, with the vast majority coming from burning fossil fuels. According to the data, cement production and lumber industries produce more emissions.
“We’re less than 1% of emissions statewide, but we’re the only industry facing a ban right now,” Leiker said.
However, state regulators and environmental advocates argue chrome plating facilities can drastically elevate concentrations in the areas immediately surrounding them, posing a long-term health threat.
In acknowledging the wide-ranging effects, the state legislature has reportedly allocated $10 million to assist chrome platers with the transition. According to reports, the air board estimates that costs to transition would be around $323,000 for decorative platers and $4 million for industrial platers.
“This board has been intimately involved in switching technologies,” Williams said. “It has practically become your job description—switching from gasoline-powered cars to electric vehicles, switching from diesel-powered engines to other forms. This is exactly the same problem.”
The deadline to submit public comment was Jan. 17. The vote on the final proposal is anticipated in May.
Related materials, including the proposed regulation order and draft environmental analysis, can be found here.