California’s Ban on Hexavalent Chromium in Chrome Plating

California's Ban on Hexavalent Chromium

Why Is California Banning Chrome? California recently approved a landmark regulation to prohibit the use of hexavalent chromium, also known as chromium 6, in chrome plating operations across the state. This ban aims to phase out a highly toxic chemical that has been linked to cancer and other adverse health effects.

While the ban faces opposition from some in the chrome plating industry, it represents a major step forward in protecting public health – particularly for disadvantaged communities disproportionately impacted by this hazardous pollutant.

Hexavalent Chromium and Its Uses

Hexavalent chromium, or chromium 6, is a form of the metallic element chromium used industrially for chrome plating and other applications.

Chromium is found in the environment in two main forms:

  • Trivalent chromium (chromium 3) – A naturally occurring trace mineral needed by the human body in small amounts. Not highly toxic.
  • Hexavalent chromium (chromium 6) – A manufactured form of chromium, and the type used in chrome plating. Highly toxic even in small amounts.

Hexavalent chromium compounds are added to electroplating baths to deposit a decorative or protective chromium layer onto metal parts and products. This gives finished surfaces a shiny, stainless steel-like appearance.

Beyond chrome plating, hexavalent chromium is also used in:

  • Pigments and dyes
  • Wood preservation
  • Leather tanning
  • Anti-corrosion coatings

It’s the widespread industrial use of hexavalent chromium that has led it to become a major pollutant. The chemical is released into the air, water and soil during manufacturing and waste disposal.

The Health Dangers of Hexavalent Chromium Exposure

Hexavalent chromium is one of the most hazardous substances used in California industry today. It has been deemed a human carcinogen and potent toxic air contaminant by public health agencies.

Some key facts about the health risks of hexavalent chromium exposure:

  • Carcinogenicity: Hexavalent chromium is classified as a Group 1 carcinogen by the World Health Organization, meaning there is sufficient evidence of its cancer-causing effects in humans.
  • Lung cancer risk: Studies of workers chronically exposed to hexavalent chromium have found increased risks of lung, nasal and sinus cancers. Animal studies also demonstrate chromium 6’s carcinogenicity.
  • Other health effects: Acute exposure can cause harm to the eyes, skin, nose and throat. Higher exposure is linked to damage to the liver, kidney, gastrointestinal and neurological systems.
  • Inhalation hazard: Hexavalent chromium is most hazardous when inhaled, as it can be absorbed into the lungs. Airborne exposure most commonly occurs in industrial settings like chrome plating.
  • Extreme toxicity: Hexavalent chromium is over 500 times more toxic than trivalent chromium, and soluble chromium 6 compounds rank among the most toxic industrial substances.

Clearly, the scientific evidence leaves no doubt about the serious health hazards posed by hexavalent chromium exposure – even at low levels. This is what led California regulators to take action to protect communities from this toxic chemical.

Regulations to Control Hexavalent Chromium Emissions

Given the well-established health risks, hexavalent chromium emissions have been targeted by California environmental regulators for decades:

  • 1986 – Hexavalent chromium identified as a toxic air contaminant in California.
  • 1987 – Facilities using chromium 6 required to implement airborne toxic control measures.
  • 2011 – New public health goal set at 0.02 ng/m3 – over 1000 times lower than the previous level.
  • 2019 – Updated airborne toxic control measure adopted specifically for chrome plating facilities.

However, these earlier regulations still allowed the continued use of hexavalent chromium. It took until 2022 for California to approve a full prohibition on the toxic chemical.

California’s Ban on Hexavalent Chromium in Chrome Plating

In February 2022, the California Air Resources Board adopted a groundbreaking regulation that bans the use of hexavalent chromium in chrome plating operations.

This marks the first such prohibition of hexavalent chromium in the chrome plating sector in the United States. Some key details of California’s chromium 6 ban:

  • Phased timeline: The ban will be phased in, with full compliance required by 2039. Decorative chrome platers have until 2027.
  • Applies to new and existing facilities: Both new and existing plating facilities will be required to transition to alternative chemicals.
  • Allows no exemptions: The regulation applies to all chrome platers without exemptions, from large aerospace coaters to small bumper plating shops.
  • Covers training requirements: Facilities must train staff on the hazards of hexavalent chromium and safe handling of alternative chemicals.
  • Establishes reporting rules: Chrome plating businesses must submit reports on their transition progress and any use of alternative chemicals.
  • Enforced under AB 617: Non-compliance will result in penalties under California’s air quality enforcement programs.

This sweeping regulatory ban was enacted to protect public health in communities near chrome plating facilities. But California’s action faces criticism from industry groups who argue the ban goes too far.

Opposition to the Ban from the Chrome Plating Industry

The proposed hexavalent chromium prohibition was contentious. Chrome plating businesses and trade associations actively opposed the ban during the rulemaking process.

Their arguments against California’s chromium 6 ban included:

  • Lack of available alternatives: There are limited proven substitutes that can match the corrosion resistance and decorative qualities of hexavalent chromium plating.
  • Major costs for businesses: Transitioning to alternative processes will be expensive, forcing some smaller platers out of business.
  • Jobs and economy impacts: The regulation could lead to plating job losses and reduced tax revenues.
  • Existing regulations are adequate: Upgrading control equipment at facilities could reduce risks below public health goals under current rules.
  • Uncertainty over substitutes’ safety: New plating chemicals likely also pose environmental and health hazards that are still unknown.

However, California regulators maintain the ban is justified and will drive innovation. They argue any economic impacts are outweighed by the health benefits of removing this highly toxic pollutant from communities.

Why a Ban? Rationale for Phasing Out Hexavalent Chromium

Given the significant opposition, why did California opt to implement a complete ban on hexavalent chromium plating instead of less stringent regulations?

Several compelling reasons drove this decision:

1. Precedent for banning hazardous chemicals

Banning highly toxic chemicals with well-documented health risks has proven effective in the past. This includes lead in gasoline and products, asbestos, chlorofluorocarbons (CFCs) and DDT.

2. Availability of safer substitutes

Alternatives like trivalent chromium plating are less hazardous and can replace hexavalent chromium in many applications, especially decorative plating.

3. Persistent elevated concentrations

Hexavalent chromium air concentrations around plating facilities remain dangerously high despite existing control regulations.

4. Environmental justice for disadvantaged communities

Many chrome platers are in low-income minority communities already burdened by pollution, who would benefit most from reduced health risks.

5. Feasible timeline for compliance

The phase-in period allows businesses adequate time to modify processes and adopt alternative plating methods.

6. Drive technology innovation

The ban creates incentives to perfect safer chromium plating techniques and chemical substitutes.

7. Protective of public health

Phasing out this proven carcinogen is the most direct way to protect community health and achieve public health goals.

Given these compelling reasons, California concluded that prohibiting hexavalent chromium usage outright is the best and most responsible approach for protecting human health and the environment.

Healthier Alternatives to Hexavalent Chromium Plating

For California’s hexavalent chromium ban to succeed, suitable alternative plating processes must be adopted. The most promising options include:

Trivalent Chromium Plating

  • Uses trivalent chromium instead of the hexavalent form
  • Produces similar decorative finishes
  • Less toxic and environmentally hazardous
  • Lower energy and water usage
  • Limitations on corrosion protection for industrial uses

Electroless Nickel Plating

  • Deposits nickel-phosphorus alloy coatings
  • Excellent corrosion resistance
  • Harder than chromium with improved wear resistance
  • Higher cost than chromium plating
  • Surface appearance not as bright/reflective

Trivalent Aluminum Plating

  • Forms protective aluminum oxide layer
  • Replaces chrome on plastic parts
  • Lower temperature process
  • Less waste treatment needed
  • Limited use on metal components

Other Emerging Alternatives

  • Hexavalent-free chromium processes
  • Nanoceramic composite coatings
  • Conductive polymer plating
  • Trivalent chromium-free passivation

Many of these alternative processes have been tested successfully by leading companies. But further development is needed for broader adoption. The regulatory ban will accelerate innovation and commercialization.

Who is Impacted? Chrome Plating in California

California is home to over 160 facilities conducting chrome plating operations using hexavalent chromium. These businesses will be impacted by the incoming ban:

Aerospace Industry

A major chrome plating sector providing corrosion protection for aircraft and spacecraft parts. Facilities are concentrated in Los Angeles, Orange County and the Bay Area.

Automotive Industry

Both automobile and motorcycle manufacturers use chrome plating for decorative trim and styling features on new vehicles.

Heavy Truck Industry

Chrome plated parts like bumpers, grilles and wheels are common on big rig trucks and trailers.

Metal Finishers

Numerous smaller plating shops provide chrome services for metal products across many industries. Examples include bathroom fixtures, furniture hardware and industrial equipment.

Raw Materials Suppliers

Companies selling hexavalent chromium chemicals, compounds and plating process equipment will be impacted as demand changes.

For all these sectors, transitioning to safer alternatives will require significant investment and process modifications. But the long compliance timeline gives businesses time to plan strategically.

Disproportionate Impacts in Disadvantaged Communities

A major driving factor for California’s ban is the disproportionate exposure of low-income and minority residents living near chrome plating facilities.

More than 70% of chrome platers are located in disadvantaged communities identified under the state’s environmental justice screening tool, CalEnviroScreen.

For example, the city of Vernon in Southern California has the state’s highest concentration of chrome plating businesses. It also ranks in the top 10% of disadvantaged communities.

Residents in these overburdened neighborhoods tend to face higher pollution burdens, greater health vulnerabilities, and less access to healthcare. This makes exposure to a carcinogen like hexavalent chromium even more hazardous.

By prohibiting this toxic chemical, the ban will result in the greatest health benefits for California’s most vulnerable populations. It represents a major victory for environmental justice.

Timeline for the Phase-Out

California’s hexavalent chromium prohibition sets out a phased compliance schedule for plating facilities to completely transition to safer alternatives.

December 2023

  • Earliest compliance date for decorative chromium platers.

January 2027

  • All decorative chromium plating must stop using hexavalent chromium.

January 2031

  • 50% of hexavalent chromium usage at larger plating and anodizing facilities must be phased out.

January 2035

  • 90% of hexavalent chromium usage at larger plating and anodizing facilities must be phased out.

January 2039

  • All remaining chrome plating businesses must eliminate use of hexavalent chromium.

This gradual timeline allows even the largest aerospace and industrial plating companies adequate opportunity to modify processes and adopt substitutes.

Strong enforcement of the ban will be crucial though. California air regulators plan to incorporate oversight and reporting requirements into operating permits. Facilities out of compliance will face penalties.

Outlook for a Future Without Hexavalent Chromium Plating

California’s first-in-the-nation chromium 6 prohibition marks a turning point for the plating industry and environmental health.

This groundbreaking ban overcomes years of opposition and inertia to remove a highly hazardous chemical from neighborhoods. It represents a major victory for community advocates who have long called for action.

However, success will depend on follow-through. Both government oversight and industry leadership will be needed to ensure adoption of safer alternatives and achieve full phase-out by 2039.

There are certainly challenges ahead given the entrenched nature of hexavalent chromium usage in plating. Some businesses will struggle with the transition.

But this forward-looking regulation positions California plating companies to lead the way in pioneering safer, cleaner production methods. It also provides a model that other states may adopt.

Most importantly, phasing out this dangerous carcinogen will benefit public health for generations to come – especially for those living near chrome plating facilities. That alone makes California’s hexavalent chromium ban a milestone worth celebrating.

References

  1. California Air Resources Board. “Chrome Plating Control Measure.” https://ww2.arb.ca.gov/our-work/programs/chrome-plating-control-measure
  2. California Office of Environmental Health Hazard Assessment. “Hexavalent Chromium.” https://oehha.ca.gov/chemicals/hexavalent-chromium
  3. International Agency for Research on Cancer. “IARC Monographs on the Evaluation of Carcinogenic Risks to Humans: Volume 100C.” https://monographs.iarc.who.int/wp-content/uploads/2018/06/mono100C-9.pdf
  4. U.S. Occupational Safety and Health Administration. “Hexavalent Chromium.” https://www.osha.gov/hexavalent-chromium
  5. Shepherd, B., Jones, C.A., Liu, Y., Mukherjee, D., Zeise, L. “Hexavalent Chromium: Overview of Issues Confronting California.” Journal of Public Health Policy. 2021. doi:10.1057/s41271-021-00289-6.
  6. Mancuso, T.F. “Chrome Plating Industry in California Struggles to Survive.” Products Finishing. 2019. https://www.pfonline.com/articles/chrome-plating-industry-in-california-struggles-to-survive
  7. Jacobs, J.A., Testa, S.M., Keenan, J.J. “Alternatives to Hexavalent Hard Chrome Plating.” Metal Finishing. 2018. doi: 10.31399/asm.hb.v05.a0006519.
  8. Lees, P.S.J. “Chromium and Disease: Review of Epidemiological Evidence with Particular Reference to Aerospace Workers.” Environmental Geochemistry and Health. 2020. doi:10.1007/s10653-019-00478-9.
  9. Nealer, R., Reich, B. “An Overburdened Community: Pollution, Public Health & Environmental Justice in Vernon, California.” The Greenlining Institute. 2019. http://greenlining.org/wp-content/uploads/2019/10/An-Overburdened-Community-Pollution-Public-Health-Environmental-Justice-in-Vernon-California.pdf
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