Download - Emerging Contaminants - The New Frontier -
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Emerging Contaminants - The New Frontier -
Paul YaroschakDeputy Director for Emerging ContaminantsOffice of the Secretary of Defense
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Part 1 – EC Program Overview
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What is an Emerging Contaminant?
• Chemicals & materials with: – Perceived or real threat to human health or
environment– Either no peer reviewed human health standard
or an evolving standard
• May have: – Insufficient human health data/science– New detection limits– New exposure pathways
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U.S & International Interest
• U.S. National Geographic Magazine - Oct 06
• U.S. ES&T Magazine - Dec 06
• USGS Survey of 139 streams in 30 states– ECs found in 80% of streams
• U.S. Executive Order 13423 (January 24, 2007)– DoD Chemical Management Plan
• European Union – REACH– Registration, Evaluation, Authorization & Restriction of
Chemicals
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Our VisionImagine if the largest industrial complex in the nation could…
• Predict which chemicals we use, or might use, have evolving science that may change the regulatory status and pose health or environmental risks.
• Develop a consensus evaluation of types & magnitudes of the risks in using/releasing such chemicals.
• Develop risk management options and invest in high-payback actions.
• Achieve and measure risk reduction.
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EC “Scan-Watch-Action” Process
Review literature, periodicals, regulatory communications, etc.
RM Options to Governance Council
Over -the- horizon
Monitor events; Conduct Phase I qualitative impact assessment
Conduct Phase II quantitative impact assessment with risk management options
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Phase I Impact Assessment Process
ES&H Training & Readiness
Acquisition/ RDT&E
P,O&M,D of DoD Assets
Cleanup
Likelihood of Toxicity Value/Regulatory Change
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Impact on DoD Functional Areas
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• Recommendation – Move to Action List?• Initial Risk Management Options
Results:
Scoping and Data Collection1 2
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Plotting EC Risks to DoD
Severity of Impact
Pro
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Ө - Med
O - Low
OO
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Risk Change
• High risk at top right• Risk management
actions move ECs to lower left…lower risk
• Seek to quantify risk reduction
H
HL
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Developing Risk Management Options
Severity of Impact
Pro
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1 2 3 4 5
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OO
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• Fill tox science gaps• RDT&E• Material substitution• Process/spec changes• Regulatory engagement• Stockpile material• Exposure assessment & • monitoring• Personal Protective• Equipment (PPE) • Alert acquisition managers• Benchmark with industry• Risk communication• Training
Extensive RM Actions
Some RM Actions
Accept Risk
RM Options
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SF6 Phase I Impact AssessmentCompleted January 2008
Likelihood of Toxicity Value/Regulatory Change
1. Probability that Greenhouse Gas emission initiatives will restrict use/availability of SF6
2. Probability the OSHA will revise the permissible exposure limit (PEL) for SF6
Sulfur Hexafluoride (SF6): is used in waveguides for Air Force AWACS jets, in helicopter rotorblade leak tests, discharge testing in fire suppression systems, and in the propulsion systems of the MK50 torpedo and other emerging technologies.
5-10 yrsL
M
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Probability Timeframe
L
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H2-3 yrs
Severity of Impact
Pro
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f O
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ES&H PO&MD of Assets
Training & Readiness Cleanup
Acquisition/RDT&E
●X
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- Turning Options to Actions -Risk Management Examples
• $114M in Perchlorate RDT&E – Drinking water treatment…southern California– Cleanup technologies– Sources & analytical procedures…isotopic analysis– Material substitution…simulators, flares, rocket fuel
• $2M in RDX toxicity studies– Cancer studies completed & reviewed by EPA– Non-cancer studies to be completed end of 2007
• Small Business Innovative Research solicitation for naphthalene dosimeter– Two proposals accepted
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EC Action List
• Perchlorate
• Royal Demolition eXplosive (RDX)• Cyclotrimethylenetrinitramine
• Trichloroethylene (TCE)
• Hexavalent Chromium
• Naphthalene
• Perfluorooctanoic acid (PFOA)
• Beryllium
Notes: - Some risk management actions underway including research on toxicity, substitutes, & treatment.
Elevated from Watch List 9-06}
}Elevated from Watch List 9-07
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EC Watch List
Tungsten
Tetrachloroethylene (PCE)
Dioxin
1,4-dioxane
• Nanomaterials
Perfluorooctyl sulfonate (PFOS)
Di-nitrotoluenes (DNT)Lead (Added 3-07)
Nickel (Added 3-07)
• Cerium (Added 7-07)
• Cobalt (Added 7-07)
Phase I Impact assessments completed
• Cadmium (Added 12-07)
• Manganese (Added 12-07)
• Sulfur Hexafluoride (SF6) (Added 12-07)
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Part 2 – Initiatives & Issues Update
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Accomplished
• Established & refined the scan-watch-action process for ECs
• EC News
• Established a FY-08-13 DoD funding line for ECs • Completed 20 Phase I Impact Assessments• Established EC web sites for DoD & public
• Perchlorate sampling data• EC info portal
• Designated “material champions” for ECs on the action list
• Completed two briefings to EC Governance Council – all recommendations approved
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DoD Tungsten Work Group
• Coordinating DoD efforts on:– Embedded fragments studies of tungsten-metal alloys (penetrator
munitions)…W-Ni-Co is highly carcinogenic– Sodium tungstate toxicity studies (tungsten bullets)…rodent
dosing studies underway – Tungstate fate & transport studies (tungsten bullets)…tungsten is both
soluble and mobile– Operational Risk Assessment of tungsten use…risks associated with
continued use…sponsored by Joint Ordnance Commanders Group
• Completed tungsten fact sheet for public
• Completed Q&A bank & key messages
for public affairs use
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Nanomaterials Work Group
• WG formed with EC and DDR&E co-chairs
• Charged with – Coordinating ESOH technical, policy, and legal information on
engineered nanomaterials– Developing well-reasoned, evidence-based, consistent and
coordinated DoD positions, messages, and actions on these issues.• Supports DoD nexus with the OSTP/CEQ/OMB
Nanomaterials Policy Coordination Group• Developed Fact Sheet on Nanomaterials as an EC• Drafted interim guidance on responsibilities to evaluate
and manage potential risks from nanomaterials– Awaiting NPCG agreement on definition of nanomaterials
• Drafting DoD Nanomaterials Q&A package– To ensure consistent messages– To assist PAO’s response to inquiries
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Projects of Interest to NMCPHC
• EC Risk to Ranges analysis• Database Query procedures for DoD EC Use• Benchmarking Government & Industry Chemical
Rating Systems - Phase I• Phase I Impact Assessments for W/Ni/Co alloys,
SF6, lead, cadmium• Phase II Impact Assessments & risk management
options for RDX, TCE, Be, PFOA, naphthalene, & hexavalent chromium
• Toxicity & Human Health Criteria for Chemicals in Development/Acquisition
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Summary
• EC management requires new thinking– Proactive vice reactive…a paradigm shift – Make targeted investments before regulatory action– Base decisions on life cycle costs
• Efficient process established for identifying & assessing ECs & developing risk management options – Leverages existing DoD assets/resources
• Potential large payback– Protects people, mission and assets
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Either stay ahead of the curve…………..
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Or get overtaken by it…………..
Stay Ahead of ECs with “Scan-Watch-Action”
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Questions & Discussion
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Backup Slides
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ECOS-DoD-EPA Work Group Products
• Issue: How do states define ECs? What are ECs of concern?- Product: State EC Survey
• How can states & federal agencies send a consistent risk message to the public?- Product: Risk communication paper
• What values should be used if no IRIS value?- Product: Provisional toxicity values paper
• What conditions, requirements, authorities influence the decision to expend funds on EC response when threat to human health is not clear?- Product: Action triggers paper
Done
Done
Done
Underway
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REACH Implications for the Defense Industry
• Regulated materials may become more difficult to obtain and more costly– Likely unexpected supply chain disruptions– DoD suppliers may not fully realize what chemicals are in their
parts/articles from sub-suppliers; cross-contamination issues– Small suppliers may not be able to comply cost-competitively
• May need to increase research/substitutes analysis during systems development– REACH calls for “the progressive substitution of the most dangerous
chemicals when suitable alternatives have been identified”
• Unknown effects on interoperability (e.g., NATO) and re-supply of U.S. forces in Europe
• Unknown implications for foreign military sales
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https://www.denix.osd.mil/MERIT