Hexavalent chromium is a key metal used by the military and the aerospace industry in order to prevent corrosion and resist wear. But the metal, a known human carcinogen, has come under increasing scrutiny due to its environmental and human health risks, with increasing restrictions. "These restrictions will continue to increase the regulatory burdens and life-cycle costs for DOD and decrease material availability," wrote DOD Under Secretary of Defense for Acquisition, Technology & Logistics John J. Young Jr., in an April 8 memo to the military service secretaries. Young also stated that there are replacements for many of DOD's current applications.
Young calls for more aggressive mitigation of the risks to DOD operations posed by hexavalent chromium by ordering the military services to update relevant specifications to authorize use of qualified substitutes, thereby minimizing the use of hexavalent chromium. He referred to the current state as “an extraordinary situation” that requires DOD to go beyond established hazardous materials management processes.
"We turned the tables" and put the onus on the continued use of hexavalent chromium, said one DOD official. If a substitute cannot be used, then it has be explained why it can't, the source says, noting the memo "puts everybody on notice" to change technical documents and specifications to allow the use of those substitutes deemed qualified to replace chromium.
In addition, the memo calls for the military services to: invest in research and development of substitutes; ensure the testing and qualification procedures for substitutes are funded and conducted; approve use of replacements (provided they perform adequately for the intended application); document the system-specific [hexavalent chromium] risks and efforts to qualify less toxic alternatives in a programmatic environmental and worker safety evaluation; and share knowledge from research and experiences with qualified replacements.
Finally, the memo requires that program executive offices take into consideration a number of factors such as cost, technical feasibility, and environmental and health risks if certifying that no alternative is acceptable for a particular application using chromium in a new system.
The changes affect use of chromium in both new weapon systems, equipment and processes, and operations and maintenance activities of existing equipment and materials. However, it does not go so far as to require the overhaul of all processes and equipment. The memo notes that the policy's application "to legacy systems will be limited to modifications where alternatives can be inserted in the system modification process and updated maintenance procedures."
Furthermore, the memo also calls for expanding an existing DOD technology database to include data on the research, development, testing, and use of alternatives to chromium—an effort the DOD official says will guard against people making assumptions about materials without the supporting data. To view the memo in its entirety, please visit InsideEPA.com