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.
This advisory note has been prepared to clarify the intent with respect to new chromium plating, chromium anodizing and reverse etching facilities (that is, facilities starting operations after July 4, 2009) that control the release of hexavalent chromium compounds by using a point source control method to comply with the requirements of these regulations. Please note that in the event of inconsistencies between this advisory note and the regulations, the regulations shall prevail.
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
Control method notice
Submit at least 30 days before day 1
Submit by day 1
Submission of release test results
National Chromium Coordinator
Chemical Production Division
Environment and Climate Change Canada
351 Saint-Joseph Boulevard 11th floor
Gatineau QC K1A 0H3
For additional information or documentation regarding the regulations, please visit the web section on the management of toxic substances.
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