NDIA 20
th
Annual Systems Engineering Conference (23-25 Oct 2017)
Presentation #19770
TSCA Panel: Assessing the impacts of Amended Toxic Substances Control Act (TSCA) to the
DoD Mission and the Defense Industrial Base.
Sustainable Hazardous Material Management:
Manage/minimize risks & identify safer alternatives to toxic chemicals while ensuring performance to meet mission
requirements
Protect Human Health and the environment
Reduce costs of regulation; hazardous waste storage and disposal, worker protection, and future liabilities
Stimulate innovation – research and development on chemicals of importance to DoD mission.
Risk Evaluation for Existing Chemicals under Amended TSCA
Purpose: “Determine whether a chemical substance presents an unreasonable risk to health or the environment under the
conditions of use (of the chemical substance)”
“Conditions of Use”
Means the circumstances under which a chemical substance is intended, known or reasonably foreseen to be
manufactured, processed, distributed in commerce, used, or disposed of.
Intended to avoid past practices of assessing only narrow uses of a chemical substance but towards a more inclusive
approach to chemical substance management
Intent is not on individual uses (to prioritize chemicals) but on substances that present a potential hazard and potential
route to exposure under the “conditions of use”.
End User Considerations:
Uses/Disposal – Applications/Performance; Management/Controls; Alternatives/Transitions(Implementation)/Resourcing.
Hazardous Chemicals are widely used in connection with all phases of the System Acquisition process.
System/Performance-Driven Requirements for use:
• Contained in technical manuals, specifications, etc., that govern the processes and procedures for weapon systems operations
and support.
Conditions Affecting Replacement or Elimination
Commercial availability of potential viable (equal to or improved performance) alternatives for specific applications.
Potential alternative(s) are less hazardous to personnel safety and environment under management and control processes and
practices.
Cost/Resourcing impact analysis of potential alternative chemicals/processes.
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