Chemical and Material Risk Management Program

Emerging Chemicals Program Basics

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The mission of the Chemical and Material Risk Management (CMRM) Program is to protect readiness, people and the environment by identifying and managing risks associated with the chemicals and materials DoD uses. We do this by enabling more effective management of current and future risks from chemicals and, in so doing, we lower lifecycle costs, drive innovation, and avoid the need for future crisis-driven retooling to comply with new regulations.

What We Do

  • Scan the horizon and identify chemicals or materials that either lack human health standards or have an evolving science and regulatory status โ€” these are called โ€œemerging chemicals.โ€
  • Determine which of these chemicals and materials DoD uses, or plans to use, and how we use them.
  • Assess the impacts of the science, toxicity, or regulatory changes on people, the environment, and DoD business functions and mission.
  • Collaborate with stakeholders within DoD and externally to mitigate the risks.
  • Develop policies, procedures and guidance for integrating lifecycle environment, safety and Health considerations into the DoD acquisition process.
  • Develop policies, procedures and guidance for chemical management and promote green procurement across the enterprise.
  • Integrate science, technology, and policy to pursue sustainable use of chemicals and materials.

Why We Do It

  • Protect people and the environment.
  • Protect vital DoD functions and applications.
  • Reduce lifecycle costs of weapons systems, platforms, equipment, and facilities.

How We Do It

  • Collaborate with multiple DoD Components and offices.
  • Build consensus on risks and spotlight actions and investments needed to minimize risks for decision-makers. Catalyze change by providing avenues for DoD to move toward more environmentally protective and sustainable practices.
  • Partner and collaborate with other agencies, industry, state organizations, academia, and non-governmental organizations to achieve common objectives.

DoDI 4715.18 Emerging Chemicals (ECs)

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Resources

The Toxic Substances Control Act (TSCA), amended on 22 June 2016, identified decaBDE as a persistent, bioaccumulative, and toxic (PBT) chemical that the U.S. Environmental Protection Agency (EPA) must expedite the elimination of. The final rule prohibiting all manufacturing (including importing), processing, and distribution of decaBDE and decaBDE-containing products or articles was issued on 6 January 2021 and became effective on 5 February 2021. This risk alert serves to notify DoD Program Managers of this prohibition and that EPA is adopting phase-out deadlines for certain uses.

The U.S. Environmental Protection Agency (EPA) is revising regulations for asbestos the Toxic Substances Control Act (TSCA). After this risk evaluation is complete, EPA will then undertake a rulemaking on the risk management aspects of asbestos use that it finds unreasonable. DoD program managers should be ready to create a plan/policy to deal with the potential and eventual ban on asbestos.

The Environmental Protection Agency (EPA) has identified TBBPA (CAS No. 79-94-7) for assessment under the Toxic Substances Control Act (TSCA) Work Plan effort. This may lead to increased regulation and/or production bans, which could pose risk to DoD supply chains and require actions to identify and qualify suitable alternatives.

The American Conference of Governmental Industrial Hygienists proposes to lower the threshold limit value-time-weighted average from 10 parts per million (ppm) to 0.1 ppm. If implemented, this change presents a risk to certain DoD industrial operations and may require actions to meet occupational health standards.

In response to regulatory pressures and resulting market changes, some phthalates are being phased-out of production. Unique defense or mission-critical phthalates, or products containing phthalates, may not be available.

International and Federal regulatory pressures are resulting in a phase-out of one of the worldโ€™s most widely used flame retardants. Components in DoD combat systems could be affected.

Some legacy Aqueous Film Forming Foam (AFFF)formulations contain chemicals that present human health and environmental risks and require special handling and disposal.

While the human health and environmental risks related to hexavalent chromium have been known for years, new scientific studies and risk assessments are resulting in even stricter standards that may result in higher life cycle costs for processes, controls and monitoring.

Revised Blood Reference Value for Lead New information about the health effects associated with lead exposure influence blood lead levels (BLLs) of concern for adults and children. The resulting progressively lower BLLs may impact air quality standards, soil screening concentrations, and occupational exposure limits.