emerging chemicals: moving beyond compliance

Emerging Chemicals: Moving Beyond Compliance

Shannon E. CunniffSpecial Assistant, Emerging ContaminantsJoint Services Environmental Management ConferenceTampa, FLApril 12, 2005

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DoD MERIT

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Moving Beyond Compliance

Compliance Approach• $ provided for what you

legally have to do• Harder to find $ for smart to

do actions• Always reactive• Budget process cannot

handle emerging issues• Focuses on what you know• High potential for stopping

mission activities

Sustainability Approach• Equal footing: $ for activities

supporting mission sustainment• Proactive, predictive…able to

rapidly respond to new info• Focuses on what you need to

know & ought to do• Ties environmental activities to

mission accomplishment

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DOD Directive 4715.1 MERIT

4.1 Manage & apply DoD installation assets to sustain DoD mission 4.2 Use Defense Installations Strategic Plan to guide ESOH decision-making 4.3 Use ESOH management systems in planning & execution across all military ops and activities

4.4 Ensure all organizations plan, program, & budget to manage ESOH risks 4.5 Evaluate all activities for current & emerging ESOH resource requirements & make prudent investments to support mission accomplishment, enhance readiness, reduce future funding needs, prevent pollution, prevent illness & injury, ensure cost-effective compliance, & maximize existing resource capability

4.6 Ensure tenants comply with laws and DoD policies. 4.7 Protect DoD personnel from accidental dealth, injury or occupational illness. 4.8 Protect the public from risk of death, injury, illness or property damage because of DoD activities

4.9 Establish and maintain open and productive ESOH dialogue

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DoD MERIT

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SUSTAIN OUR ASSETS• RESTORE• MANAGE• MODERNIZE

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Emerging Chemicals

1,343,277 commercial chemicals

224,787 regulated chemicals

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Interest in Emerging Materials DoD: Responsible

for Sustaining Defense and

National Security

EPA/States: Need to Protect

Valuable Assets

Public: Needs to Feel Assured That They Are Protected From

DoD Substances

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DOD Mission is Affected by Emerging Materials Challenges

• Acquisition • Manufacturing• Training, research, and

development investments• Operations • Readiness and range

management

• Occupational health and safety

• Environmental management (compliance & clean-up)

• Demilitarization

GENERATES UNCERTAINTIES AND STRAINS RESOURCES

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DoD MERIT Vision

- Act as the principal agent of change for transforming the way DoD addresses the legitimate concerns of

the public, regulators and defense community about emerging health and environmental concerns.

- Through proactive and strategic investments pay the cost in time, money and frustration now to avoid

more costly issues in the future- Through better coordination and visibility of Services

efforts, address current issues with a single DoD voice effectively.

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DoD MERIT Goals

…principal agent of change…• DoD stovepipes….• DoD is culturally “locked-in” to cleaning up the

past.– Cleanup standards have lowered based on:

• Good science (fair enough, we clean-up)• Incomplete or inconclusive science and (legitimate) fear of the

unknown (we should provided more complete and conclusive science).

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DoD MERIT Goals

…legitimate…

• We are not trying to dodge responsibility, avoid liability or preach that our chemicals are benign.

• Concerns of the public are legitimate and should be addressed up front and honestly.

• We need to be prepared ahead of time to do just that.

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DoD MERIT Goals

…proactive and strategic investments…

• Pay the upfront cost to avoid future issues. • We cannot afford to be constantly entering the

regulatory and public fray from behind. • We cannot afford to constantly resort to defending

our materials and practices.

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DoD MERIT Goals

…better coordination and visibility…

• Enterprise risk management that:• Identifies and assess needs of all stakeholders.• Transforms substance management to be

forward looking, flexible and rapid (because concerns will still arise that take us by surprise).

• Coordinates DoD technical resources.• Maintains Service and installation autonomy to

address their unique issues as they see fit.

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DoD MERIT

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Materials of Evolving Regulatory Interest Team (MERIT)

Planning & Integration

Risk Assessment Risk Management

Communication

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Risk Assessment, Risk Management, & Outreach

Outreach

Risk ManagementRisk Assessment

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Risk Assessment &

Risk Management

Mission

PlaceChemical

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Predictive Assessments– Evaluating & leveraging work already done

• Environmental screening of replacement materials (QSAR)

• Prioritization of emerging materials using new algorithms (Army EQT Program)

• Prioritization of emerging materials using commercial databases (GMACS)

– Developing protocols for using predictive models to assess environmental and health affects

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Getting the Gears Moving Together

ECOS

EPA

Other Feds

Installation Managers

Clean-up

Toxicology Researchers

Manufacturing

Training

Technology ResearchersRemediation

Industry

ITRC

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Lubricating the Gears• Providing a science and studies registry• Being a toxicological info source• Identifying research and

investment priorities

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Toxicological Data Needs

Human EcologicalMERI Examples Oral (RfD) Uncertaintly FactorsInhalation (RfC) Cancer Mammals Birds Amphibians Reptiles

Depleted Uranium2,4,6-Trinitrotoluene1,3,5-TrinitrobenzeneHMX UF = 1000RDX UF = 100Nitroglycerin1,3-Dinitrobenzene UF = 30002-A-4,6-DNT4-A-2,6-DNTTrinitrophenol2,4-Dinitrotoluene2,6-DinitrotolueneTetryl UF = 10,000MNXTNXDNXTATB

- Benchmark exists- Conservative benchmark exists- No benchmark exists- Benchmark evalution underway b/c new data*- Generally not applicable

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Information Communication Strategies

• MERIT web site

• Public affairs and press releases

• Science & studies coordination systems

• Identifying science & study priorities & gaps

• Establish training module for acquisition training (DAU)

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Other Deliverables• Policies to position the department to

better manage resources

• Tools to implement polices

• Metrics with which to measure progress

• Processes for truly joint and systematic program execution and oversight

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What do we give up for MERIT?

• Services will sacrifice some independence for coordination

• The DoD “single voice” may not always be agreeable to all

• Funding channels and priorities will be visible and accountable

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What do we give up for MERIT?

• Duplication of effort• Ad-hoc approach• Assuming that someone else is working

on a particular issue• Passive acceptance of regulatory decrees• Not knowing what we don’t know

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MERIT Recent Accomplishments• Instituted interagency effort developed

consensus charge to evaluate state of the science for TCE.

• Initiated interagency discussions regarding IRIS update for several chemicals including naphthalene.

• Proposed options to promote transparency and sound peer review and timely interagency involvement in the regulatory process.

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