The Importance of Chemical Ranking Systems: A Department of Defense Study Carole LeBlanc, Ph.D. Emerging Contaminants Directorate Office of the Deputy Under Secretary of Defense, ODUSD (Installations & Environment) 1

Conducted by Noblis for Emerging Contaminants (EC) Program to Purpose of Study Conducted by Noblis for Emerging Contaminants (EC) Program to Inform the Department of Defense (DoD) of the nature and the number of existing systems used within DoD Inform the Department of the comparative nature and the number of existing systems used outside DoD (by labeling agencies, industry, government and non-profits) Determine the extent of Current use of DoD systems within DoD Current (in any) and possible use of non-DoD systems within DoD 2

Criteria of Chemical Ranking Systems Study Accessibility By DoD Personnel Including Use Restrictions, Costs/Fees Different Needs of Many Potential DoD User Communities Quality of the Chemical Ranking System Frequency of Updates Range of Chemicals Included Breadth/Extent and Level of Detail Considered Current Uses of the System Applicability for DoD-Wide Use 3

Summary of Survey Comparative Results 4

Comparative Summary (cont.) 5

Top DoD Systems Identified Naval Sea Systems Command (NAVSEA) Prohibited and Controlled Chemicals List (PCCL) Army Aviation and Missile Lifecycle Management Command (AMCOM) Following the Army Hazardous Materials Evaluation via Regulatory Impact/Priority Order Ranking System for Hazardous Product Substitution Air Force F-22 Raptor Hazardous Materials Program 6

Top DoD Systems (cont.) and Labeling System Navy, Air Force, Marines F-35 Joint Strike Fighter Uses Lockheed Martin’s Hazardous Materials Elimination List (HMEL) New F-35/components require Hazardous Materials Management Program (HMMP) Green Seal U.S. based labeling system 7

Top Industry, Government and Non-Profit Systems S.C. Johnson GreenlistTM Dolphin Safe Source McDonough Braungart Design Chemistry, LLC (MBDC) Government U.S. EPA Design for Environment (DfE) Non-Profit Zero Waste Alliance (ZWA) Chemical Assessment and Ranking System (CARS) Earthster.org Life Cycle Assessment (LCA) tool Clean Production Action (CPA) Green Screen for Safer . . . … Chemicals 8

Conclusions of Chemical Ranking Study Many Systems Depend on the Generation of Lists Usually regulatory-driven (e.g., EPA’s ‘List of Lists’) Surprisingly Far more systems identified within DoD (17) than previously thought (out of ~100 systems examined) Not So Surprisingly Systems identified were found to be application-specific No One Existing System Is Likely to Meet All DoD’s Needs Partially because they rely on application-specific lists! Unlike many business models, regulatory specificity may not protect DoD from future risks 9

Recommendations of Study Establish and Support a Suite of Web-based Tools to Suit Unique DoD Users and Processes Implementing One Uniform Chemical Ranking System DoD-Wide Is Suboptimal Focus Resources on One Database for Chemical Ranking and Substitution That Includes ECs and Ensure That Linkages to Other Ranking Systems Are Seamless 10

Recommendations of Study (cont.) Institute a QA/QC Process for Each Selected Ranking System and the Supporting Database Combine Currently Operating Ranking Systems with a Customized Tool to Address Unique DoD Processes Leverage Experience Gained by States and Other Organizations That Provide Technical Assistance in Chemical Ranking and Substitution Efforts 11

Next Steps Provide a ‘Roadmap’ for DoD Decision-Makers to Select the Most Appropriate System for Their Purposes Maximizes utilization of existing tools Minimizes duplication of efforts Conduct a ‘Phase II’ Study to Determine the Feasibility of Incorporating Elements of Some/Several/All Systems to Develop a DoD ‘Master’ Chemical Ranking System Assists with ‘lifecycle’ efforts under Executive Order 13423 for more sustainable chemical management to reduce environmental, safety and health risks, based on sound business practices Requires educational/training module (i.e., curriculum development and testing), with input from the authors of the various chemical ranking systems 12

‘Pollution Prevention’ (P2) Speaks to the Past Facing the Future ‘Pollution Prevention’ (P2) Speaks to the Past Use of chemical lists of prohibited/restricted substances is a start, but by themselves… Not responsive enough to manage chemical risks in building today’s ‘business case’ It’s Not Enough to MINIMIZE HAZARDS It’s Time to MAXIMIZE GREEN CHEMISTRY! Speaks to the future and sustainability 13

Paul Yaroschak, EC Deputy Director Acknowledgements Paul Yaroschak, EC Deputy Director Drew Rak, Whitney Glaccum and Steve Gibb, Noblis Steven Strausbauch, AFIOH/RSRE Brooks Air Force Base 14

15

THANK YOU FOR YOUR ATTENTION! For More Information Carole LeBlanc, Ph.D. Special Expert Emerging Contaminants Directorate Telephone: 703.604.1934 Email: Carole.LeBlanc@osd.mil THANK YOU FOR YOUR ATTENTION! 16