4 The record articles

California Air Resources Board Proposes Rules to Phase out Hexavalent Chromium Use at Chrome Plating and Chromic Anodizing Facilities

Posted: July 25th, 2023

Authors: Aubree B. 

In late May, California Air Resources Board (CARB) proposed updated airborne toxics rules for chromium electroplating and chromic acid anodizing operations to phase out hexavalent chromium use by chrome plating and chromic acid anodizing facilities, citing both the potent toxicity of hexavalent chromium and a disproportionate effect of hexavalent chromium emissions on disadvantaged communities.

What does this mean for decorative chrome plating facilities? 

Decorative chrome plating facilities will have the option to meet either a 2027 or 2030 deadline to phase out hexavalent chromium.  Facilities that choose to meet the 2027 deadline will have more access to incentives that will help financially with the transition to less toxic alternatives. Facilities that choose to meet the 2030 deadline must implement building enclosure requirements by 2026 and may have less grant funding available for their transition.

What does this mean for functional chrome plating facilities? 

Functional chrome plating facilities, such as hard chrome plating and chromic acid anodizing for aircraft parts, will also be required to phase our use of hexavalent chromium by January 1, 2039.  CARB has stated that starting in 2032, an assessment of alternative technology for replacement of hexavalent chromium in functional chrome plating will begin.

Additionally, although functional chrome plating facilities will not be required to phase out hexavalent chromium until 2039, the facilities will be required to comply with housekeeping, best management practices, and building enclosure requirements identified by the key compliance dates discussed below.

What are the key compliance dates? 

Although the earliest date facilities in California must cease using hexavalent chromium in plating operations is January 1, 2027, there are some important earlier dates in the Proposed Amendments to the Airborne Toxic Control Measure for Chromium Electroplating and Chromic Acid Anodizing Operations (Chrome Plating ATCM) published in May 2023 that must be considered for both decorative and functional chrome plating.

  • January 1, 2024 – Updated housekeeping measures must be instituted. Additionally, chrome plating operations must be completed under the direction of an individual who has completed the California Air Resources Board Compliance Assistance Training Course on Chrome Plating (required every two years).
  • July 1, 2024 – Best Management Practices such as minimizing dragout, spray rinsing requirements, limitation of air sparging, and barrier requirements for buffing, grinding and polishing must be implemented.
  • January 1, 2025 – Facilities that will continue using hexavalent chromium in decorative chrome operations must inform the local air pollution control or air quality management district of the choice to continue using hexavalent chromium.
  • January 1, 2026 – Chrome plating tanks must meet emission limits in the Proposed Amendments to the Chrome Plating ATCM published in May 2023.
  • January 1, 2026 – Facilities that have not ceased using hexavalent chromium must comply with building enclosure requirements for plating and buffing, grinding, and polishing operations.
  • January 1, 2032 – CARB completes first technology review of functional chrome plating alternatives.
  • January 1, 2036 – CARB completes second technology review of functional chrome plating alternatives.
  • January 1, 2039 – Functional chrome plating using hexavalent chromium can no longer be conducted in California.

How can we help?

ALL4 has extensive experience helping facilities comply with California regulations. If you have any questions or want to discuss strategies for compliance please reach out to Aubree Bovat at abovat@all4inc.com.


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