Emerging Chemicals: Moving Beyond Compliance

1. Emerging Chemicals: Moving Beyond Compliance Shannon E. Cunniff Special Assistant, Emerging Contaminants Joint Services Environmental Management Conference Tampa, FL April 12, 2005

2. DoD MERIT WHY?

3. 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 Moving Beyond Compliance

5. DoD MERIT What's that mean?

6. SUSTAIN OUR ASSETS • RESTORE • MANAGE • MODERNIZE

7. Emerging Chemicals 1,343,277 commercial chemicals 224,787 regulated chemicals

8. DoD: Responsible for Sustaining Defense and National Security EPA/States: Need to Protect Valuable Assets Interest in Emerging Materials Public: Needs to Feel Assured That They Are Protected From DoD Substances

9. Acquisition Manufacturing Training, research, and development investments Operations Readiness and range management Occupational health and safety Environmental management (compliance & clean-up) Demilitarization DOD Mission is Affected by Emerging Materials Challenges GENERATES UNCERTAINTIES AND STRAINS RESOURCES

10. SO?

11. DoD MERIT Vision - Act as the principal agent of change for transforming the way DoD addresses the legitimateconcerns 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.

12. 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).

13. 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.

14. 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.

15. 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.

16. DoD MERIT HOW?

17. Materials of Evolving Regulatory Interest Team (MERIT) Planning & Integration Risk Assessment Risk Management Communication

18. Risk Assessment, Risk Management, & Outreach

19. Risk Assessment & Risk Management

20. 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

21. Getting the Gears Moving Together Other Feds Toxicology Researchers ECOS Installation Managers Clean-up EPA Manufacturing ITRC Training Technology Researchers Remediation Industry

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

24. 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)

25. 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

26. SO? What's the catch?

27. 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

28. 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

29. Prove it!

30. 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.

31. Just the Beginning not THE END