The Department of Defense is committed to reducing the use of Cr(VI)-containing materials and processes. This was reflected in the issuance of a memorandum from the Under Secretary of Defense for Acquisition, Technology and Logistics on April 8, 2009 titled, “Minimizing the Use of Hexavalent Chromium.” In it, the Under Secretary stated, “Due to the serious human health and environmental risks related to Cr(VI) use, national and international restrictions and controls are increasing. These restrictions will continue to increase the regulatory burdens and life-cycle costs for DoD and decrease materiel availability.” He further stated, “This is an extraordinary situation that requires DoD to go beyond established hazardous materials management processes.” He directed the military departments to:
- Invest in appropriate research and development on substitutes
- Ensure funding for testing to qualify alternative materials and processes
- Approve the use of alternatives where they can perform adequately
- Update all relevant technical documents and specifications to authorize use of qualified alternatives
- Document system-specific Cr(VI) risks and efforts to qualify alternatives in the Programmatic Environment, Safety and Occupational Health Evaluation for the system
- Share knowledge derived from research, development, test and evaluation of alternatives
- Require the Program Executive Office (PEO) or equivalent level to certify there is no acceptable alternative when Cr(VI) is to be used on a new system
This policy memo will be formalized in a new Defense Federal Acquisition Regulation Supplement (DFARS) to be issued in 2011. The memorandum also called out SERDP’s role as a source for information on alternatives.
SERDP and ESTCP have made major investments over the past 15 years in the area of
Cr(VI). Given the wide range of applications and the longstanding use of Cr(VI), investments have been required that range from fundamental research through advanced development to test and evaluation for acceptance of alternatives. Fundamental research has focused on understanding the corrosion-inhibiting mechanisms of Cr(VI)-containing compounds and alternative inhibitors. Advanced development has built on fundamental research to develop new materials, new testing procedures, and new coating technologies. Demonstrations have collected validation data for alternative coatings on numerous weapons systems components. These investments have been guided by numerous workshops sponsored by SERDP and ESTCP and have led to widespread implementation of Cr(VI) alternatives across DoD’s depots and original equipment manufacturers.