emerging contaminants - the new frontier

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Emerging Contaminants - The New Frontier -. Paul Yaroschak Deputy Director for Emerging Contaminants Office of the Secretary of Defense. Part 1 – EC Program Overview. What is an Emerging Contaminant?. Chemicals & materials with: Perceived or real threat to human health or environment - PowerPoint PPT Presentation

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The New FrontierOffice of the Secretary of Defense
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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:
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
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Imagine 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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RM Options to Governance Council
Over -the- horizon
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Scoping and Data Collection
Cleanup
H
M
L
H
M
L
H
M
L
H
M
L
H
M
L
Initial Risk Management Options
Risk management actions move ECs to lower left…lower risk
Seek to quantify risk reduction
Severity of Impact
Probability of Occurrence
O
O
O
O
O
O
Accept Risk
RM Options
This slide shows example RM options. They range across full spectrum. In a given case we may simply notify PMs/PEOs of the risk….in other cases we may initiate studies to fill science gaps or initiate RDT&E
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Completed January 2008
Probability that Greenhouse Gas emission initiatives will restrict use/availability of SF6
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 yrs
2-3 yrs
Training & Readiness Cleanup
H
H
L
X
Based on the Phase I input from Service SMEs; assumed worst case impact scenario for those function areas with disagreements among the SMEs.
Likelihood of Regulatory/Policy Change Analysis:
What is the probability of the USEPA revising the existing toxicity benchmark in IRIS for TCE? Due to the highly complex and controversial nature of the IRIS reassessment for TCE, the USEPA’s estimated August 2009 completion date for publication of new IRIS toxicity values is likely optimistic. Thus, there is a low likelihood that the USEPA will complete the IRIS reassessment process in the next one to three years. However, there is a greater likelihood that the process will be completed in the next four to five years.
What is the probability of the USEPA revising the existing drinking water standard for TCE? Due to the fact that the USEPA has not yet finalized the revised IRIS toxicity values for TCE or initiated any action under the SDWA to re-evaluate the current National Primary Drinking Water Regulations (NPDWRs) for TCE, there is a low likelihood that the maximum contaminant level (MCL) for TCE will be revised in the next three to five years. Once revisions to the IRIS toxicity benchmark values are finalized, it is likely that the USEPA will decide to re-evaluate the current NPDWRs for TCE. However, the rule-making process to revise NPDWRs is likely to take five or more years.
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Cleanup technologies
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
Notes: - Some risk management actions underway including research on toxicity, substitutes, & treatment.
Elevated from Watch List 9-06
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Elevated from Watch List 9-07
Three ECs on initial action list – because they were so obvious in terms of impact on DoD. Various risk management actions are underway on each.
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Cadmium (Added 12-07)
Manganese (Added 12-07)
Sulfur Hexafluoride (SF6) (Added 12-07)
We currently have 15 ECs on our watch list – these have possible impacts to DoD.
Keep in mind that this list was created “on the fly”, before the process I just described was fully in place. However, we are conducting Phase I impact assessments for all ECs on the watch list except nanomaterials – these are a whole class of materials that we will be addressing separately via a proposed DoD work group.
The items shown in green will be covered specifically in Part 3 of this briefing where Shannon will be discussing our recommendations for these materials.
One example for illustration- PFOA- Primary use is in manufacture of high-performance, heat- and chemical-resistant materials known as fluoropolymers. Vital in making electronic components and protective clothing and equipment for astronauts, the military and firefighters. Based on EPA risk assessment, EPA working w manufacturers to Phase out – similar to ODS. (Some PFOA in teflon)
PFOAs also used in AFFF, especially that made by 3M. We have spills/discharges of AFFF throughout DoD—fire fighting training areas.
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EC News
Completed 20 Phase I Impact Assessments
Established EC web sites for DoD & public
Perchlorate sampling data
EC info portal
Completed two briefings to EC Governance Council – all recommendations approved
ECs can affect DoD in multiple ways.
Most importantly, ECs can affect human health. This has both human and financial dimensions since health related claims can emerge with the contaminant.
Dan mentioned the how ECs can reduce our use of assets (like ranges). We’ll look at some specific examples in a few minutes.
If the health or environmental consequences are severe, the material itself can become unavailable.
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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
A tungsten work group was formed with reps from the Army acquisition office and health affairs as co-chairs. The work group has been very beneficial – we’ve been able to get our arms around and coordinate a number of efforts going on in different parts DoD.
One of these efforts was the studies on embedded fragments of tungsten alloy penetrator munitions. I’ll discuss separately due to significance.
Two other studies relate to tungsten-nylon bullets as a replacement for lead. We’ve discovered that tungsten is indeed soluble, it forms a salt called sodium tungstate and can, under certain conditions, contaminate groundwater. These toxicity studies will help determine safe levels in drinking water. The fate and transport studies will help determine tungsten’s mobility and environmental effects.
We’re also coordinating with a an Operational Risk Assessment on tungsten being developed by the Joint Ordnance Commanders Group, The CHPPM studies are feeding that assessment and the risk to ranges study previously mentioned.
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Charged with
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
DoD is investing heavily in nanotechnology and nanomaterials.
A DoD work group was formed and is co-chaired by Dr. Rees in DDR&E and Ms. Cunniff in EC Directorate.
Similar to tungsten WG they are getting their arms around DoD nanomaterials activities so that there are consistent messages, positions and policies.
The formation of the WG was timely – the WG is providing a conduit for coordination with the White House level Nanomaterials Policy Coordination Group. As you probably know, there is much activity at the federal level on issues related to the safe development and use of nanomaterials.
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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
ECs can affect DoD in multiple ways.
Most importantly, ECs can affect human health. This has both human and financial dimensions since health related claims can emerge with the contaminant.
Dan mentioned the how ECs can reduce our use of assets (like ranges). We’ll look at some specific examples in a few minutes.
If the health or environmental consequences are severe, the material itself can become unavailable.
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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
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Stay Ahead of ECs with “Scan-Watch-Action”
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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
- 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
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
REACH may increase the number of emerging contaminants
“Manufacturers and importers will be required to gather information on the properties of their substances…and to register the information in a central database”
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