California Rules
Of all the states in the US, California has
long been the most active in environmental regulation. As
far back as 1988, the California Air Resources Board (CARB)
adopted an ATCM (airborne toxic control measure) on chromium
emissions which was the forerunner of the national EPA
regulation introduced seven years later – and which led to
the closing of a significant number of Californian hard
chrome plating shops.
According to the CARB, both Cr6+
and nickel are human carcinogens that contribute to cancer
and other adverse health effects. Nickel is considered less
hazardous than Cr6+, although more harmful than
the cleaning solvent trichloroethylene. As a result of
these classifications, several coating processes that
involve Cr6+ or nickel are now regulated in
California, together with certain coatings.
Chrome plating and chromic acid anodizing
California’s original ATCM on hard and
decorative chrome plating and chromic acid anodizing, which
applies to all chrome plating and anodizing facilities
established before 1998, resembles the current EPA
regulation on chromium compound emissions but is more stringent. Whereas the
emission limits in the EPA’s rule are concentration-based
(in terms of mg m-3 of exhaust air), the original
California rule has emission limits that depend on the
ampere-hours used in the plating or anodizing process. In
addition, the definitions of a large and small facility
differ in the two rules.
An amended ATCM was issued in 1998, bringing
the California regulation into line with EPA standards.
However, the amended concentration-based rule applies only
to new (installed after 1998) facilities, and older
facilities are still subject to the previous rule based on
ampere-hours. The 1998 amendment also establishes two tiers
of size (large and medium/small) for new facilities,
although older facilities continue to be divided into three
tiers (large, medium and small) regulated by the original
rule.
Thermal spray
Possibly the first regulation of its kind
worldwide, the California ATCM on thermal spray that went
into effect on September 30, 2005 strictly limits Cr6+
and nickel emissions from thermal spraying processes that
use materials containing chromium, nickel and their
compounds.
This has come about despite the fact that
thermal spray is one of the most commonly used technologies
for replacement of hard chrome plating, which
is already under strong environmental pressures itself
because of Cr6+ emissions. Although several
studies claim to have documented formation of Cr6+
during thermal spraying, these studies are in dispute and
there have been no definitive measurements of Cr6+
(or nickel) emissions under actual operating conditions.
The principal features of the new rule are:
-
All Cr6+ and
nickel emissions from thermal spray operations must pass
through an appropriate control device, which can range
from a water curtain to a high-efficiency filter, the
type of device being determined by the calculated annual
emissions from that operation
-
In the case of nickel,
maximum hourly emissions from all thermal spraying
operations must not exceed 0.01 lb from an individual
source (such as a stack) or 0.1 lb from the whole
facility
-
A facility is exempt from
the requirements when annual emissions of Cr6+
and nickel are less than 0.001 lb and 0.3 lb,
respectively, from an individual source; and less than
0.004 lb and 2.1 lb, respectively, from the whole
facility
-
Requirements on
permitting, monitoring, record keeping and reporting
must be met.
Automotive coatings
Similar to
Europe’s ELV directive, a California ATCM banning Cr6+
and cadmium in coatings for motor vehicles and mobile
equipment became effective on January 1, 2003. Unlike the
ELV rule that allows a maximum concentration of 0.1 wt.% of
Cr6+ and cadmium (as well as lead and mercury) in
automotive coatings, the Californian regulation prohibits
their use altogether in vehicles and equipment sold after
the effective date. The California rule also applies to a
much broader range of equipment than ELV, and includes
off-road vehicles, trains, agricultural equipment, concrete
mixers and even wheelchairs. The ATCM restrictions had
already applied locally in two parts of the state, the South
Coast Air Quality Management District and the Antelope
Valley Air Pollution Control District, from 1996.
WEEE and RoHS
California has recently passed laws similar
to the EU WEEE and
RoHS directives. Since
January 1, 2005, the state’s Electronic Waste Recycling Act
has imposed a fee on "covered electronic devices" currently
being sold in California, in order to fund a payment system
for the proper collection and recycling of these products at
the end of their service life. The same legislation also
requires covered devices sold in the state after January 1,
2007 to meet the same requirements as those found in the
RoHS rule. However, the product range in the Californian
law is much more limited than in the WEEE and RoHS
regulations, being restricted to certain video displays.
A new law,
effective from February 9, 2006, requires California
households and small businesses to keep "universal waste"
out of the trash. Universal waste (u-waste) is a category
of hazardous wastes that includes electronic devices,
batteries, fluorescent tubes, mercury-containing items
including electrical switches, and many other items.
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