Advisory note: Chromium Electroplating, Chromium Anodizing and Reverse Etching Regulations

Clarification of the requirements for a new facility in performing a release test under the requirements of the Chromium Electroplating, Chromium Anodizing and Reverse Etching Regulations.

Background

The Chromium Electroplating, Chromium Anodizing and Reverse Etching Regulations came into force on July 4, 2009. In accordance with subsection 3(1) of these regulations, every person subject to these regulations must control the release of hexavalent chromium compounds from each tank by one of the following methods:

• using a point source control method in accordance with sections 4 to 6
• limiting the surface tension of the solution in the tank in accordance with section 7, or
• using a tank cover in accordance with sections 8 to 10

This advisory note has been prepared for those new facilities that choose the point source control method.

Requirements for existing versus new facilities subject to these regulations

Existing facilities are defined as facilities that were in operation when section 4 of the regulations came into force. Existing facilities that choose the point source control method are allowed 30 months to perform a release test to demonstrate compliance with the release limit specified in the regulations. Therefore, existing facilities have until January 4, 2012 to conduct a release test and demonstrate compliance with the release limit. The intent is to allow existing facilities sufficient time to install control equipment, establish “representative operating conditions,” then perform the release test.

“Representative operating conditions” are defined in the regulations as: “the conditions for obtaining an electrical output from a tank's rectifier while chromium electroplating, chromium anodizing or reverse etching is taking place that is equal to the average of the rectifier's output for the 30 days of use before a release test is performed.”

New facilities are defined as facilities which commence operations after July 4, 2009. Those new facilities that choose the point source control method are required to be in compliance with the release limit specified in the regulations from their first day of operation. However, new facilities will not have had an opportunity to obtain the 30 day average of rectifier settings data before the release test is performed. This advisory note presents the approach and time lines in order to meet the intent of the release test requirement and allow new facilities the opportunity to establish representative operating conditions before performing the release test.

The timelines for new facilities that choose the point source control method is presented in the following table.

Timelines for new facilities that chose the point source control method

Contact information

National Chromium Coordinator
Chemical Production Division
351 Saint-Joseph Blvd 19th floor
Gatineau QC  K1A 0H3

E-mail: EC.Chrome@ec.gc.ca

For additional information or documentation regarding the regulations, please visit the web section on the management of toxic substances.