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What is ‘REACH’?

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What is ‘REACH’?

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  1. Society of American Military Engineers (SAME) Meeting January 20, 2010 The Department of Defense (DoD) ‘REACH’ Strategic Plan: A Brief Overview Carole LeBlanc, Ph.D. Chemical and Material Risk Management Directorate (CMRMD)Office of the Deputy Under Secretary of Defense (Installations & Environment) 1

  2. What is ‘REACH’? • REACH = Registration, Evaluation, Authorization and Restriction of Chemical Substances • Replaces some 40 pre-existing laws in the European Union (EU) • “No data, No market” for our industrial partners • Far more sweeping than RoHS (Restriction of Hazardous Substances) which regulated just 6 chemicals • According to one industrial source: 12-times the cost??? 2

  3. Why Was REACH Enacted? • To Provide Better Visibility and Transparency of Chemical Exposure Information to Consumers • To Decrease the Use of Toxic and Hazardous Chemicals in the EU • To Shift the ‘Burden of Proof’ for the Safety of Materials to the Manufacturer/Supplier • To Reduce Future Environmental and Health Damages Due to Chemical Release and Exposure Military applications were not considered! 3

  4. What Is the Focus of REACH? Increasing the Regulation of • Substances of Very High Concern (SVHCs) • Very persistent, very bio-accumulative (vPvB) • Carcinogens, mutagens and reproductive toxins • So-called High Volume Chemicals Eventual • Registration of products known as ‘articles’ that contain chemicals • May not have Material Safety Data Sheets (MSDSs) • Improvements to MSDSs • Limits use of product to specified applications • More explicit ‘exposure scenarios’ Transportation to be governed by GHS* *Globally Harmonized System of Classification and Labelling of Chemicals 4

  5. How Is REACH Being Implemented? • The European Chemicals Agency (ECHA) • Formed by EU to manage REACH chemical data and collection • Substance Information Exchange Forums (SIEFS) • Voluntary industry bodies created concerning specific chemicals to help gather and disseminate information • Non-profit organizations (NGOs) and the public may request this information 5

  6. Expected Outcomes of REACH • Limiting/eliminating some chemical availability • Decreased material availability and increased costs for certain chemicals/articles • Undisclosed substitution of chemicals in Commercial-Off-the-Shelf (COTS) Products • Accelerating the need to test and evaluate substitute materials • Increased equipment costs passed on to foreign customers when substitute materials are available to satisfy individual country requirements • Different interpretations of REACH by each of the EU participating (30) and neighboring states • Accidental release of confidential information 6

  7. Potential Impacts of REACH • Negative affects on U.S. military operations and maintenance in the EU • Disruption to defense supply chains outside the EU due to the global nature of supply • Failure or marginal performance of weapon systems or components of weapon systems • Increased DoD research and development costs • Increased equipment costs eventually passed on to DoD / disruption on U.S. market • Confusion for European Command (EUCOM) and North Atlantic Treaty Organization (NATO) interoperability • Inadvertent violation of the U.S. International Traffic in Arms Regulations (ITAR) 7

  8. More Reasons to Plan for ‘REACH’ • CMRMD Was Tasked by the Under Secretary of Defense for Acquisition, Technology and Logistics, USD(AT&L) in March 2009 to Do So • To Provide DoD with a Working Document ASAP, Since • Products are already undergoing re-formulation in Europe • Need to protect the Department from the ‘unknowing’ insertion of those products in our supply chains yesterday! • REACH Is the ‘Global Gorilla’ • Far more sweeping than any other international initiative • Goal: cover 30,000 chemicals in 10 years • Has the most countries involved • Is the most developed system • Passed in June 2007 8

  9. More Reasons to Plan for ‘REACH’(cont.) • In Planning for REACH, the Department Plans for the Future • The EU (i.e., REACH) is to the international Environment, Safety and Health (ESH) community what California is to the nation as a ‘bellwether’ state • Other countries’ initiatives are predicated on REACH • Broader, Global Issue Is Being Addressed with the Development of a New, DoD Sustainable Chemical and Material Management Directive Lead by CMRMD • Part of ongoing work under Executive Order 13423, Strengthening Federal Environmental, Energy and Transportation Management • IMTI-Facilitated Workshop Series (3) • DoD, AIA and NASA 9

  10. Purpose of DoD PlanMaintain Military Readiness by: • Identifying the strategies and solutions that must be enabled to minimize potentially significant negative impacts from the REACH regulation of chemicals and materials • Apportioning these responsibilities to the appropriate key DoD offices and personnel • Providing a roadmap to unify, coordinate and communicate these activities across the Department • Reducing the use of toxic and hazardous chemicals wherever feasible • Outlining the resources needed to achieve this principal aim 10

  11. Nine Major Goals of Plan(Individual Stakeholders and Objectives Also Identified) • Protecting the Availability of Substances with Significant Mission Impact • Ensuring the Performance of Substitutes • Guarding Against Disruptions to the Supply Chain • Supporting Defense Exemptions • Minimizing Negative Impacts to Foreign Military Sales • Capitalizing on ESH Improvements • Capitalizing on Chemical Management Opportunities • Assuring Acquisition Strategies • Planning for Future Regulations 11

  12. Contributors to DoD Plan ‘Thus Far’ • Army, Navy/Marines, Air Force • Business Enterprise Integration (BEI) • Defense Logistics Agency (DLA) • Defense Procurement Acquisition Policy (DPAP) • Defense Security Cooperation Agency (DSCA) • Defense Standardization Program Office (DSPO) • Environmental Readiness and Safety (ERS) • Industrial Policy (IP) • Office of the General Counsel (OGC) • Strategic Environmental Research and Development Program (SERDP) and the Environmental Security Technology Certification Program (ESTCP) • Supply Chain Integration (SCI) • CMRMD A ‘Living Document’ in need of periodic updates 12

  13. Status of Plan • ‘Fatal Flaw’ Adjudication Meeting Held Sept. 9, 2009 • Notes available upon request • Recorded in the Office of the Secretary of Defense ‘Task Tracker’ Nov. 2, 2009 • Coordination Requested by Dec. 1, 2009 • A few concurrences without comment • Several concurrences with comment – CMRMD ‘incorporation’ meeting with Contractor, Booz Allen Hamilton last week • No non-concurrences to date • Major Concern: ‘REACH’ Is Still Viewed by Most of DoD as an Environmental Issue ONLY • Which it is not…It is first and foremost a chemical and material supply chain and management issue 13

  14. Ode to ‘REACH’ There is a new law, EU 'REACH' Whose tenets we thought not to teach. These rules don't apply; But globally we buy. Leaving US supplies in the leach. 14

  15. Any Questions? • Dr. Carole LeBlanc Telephone: 703.604.1934 Email: Carole.LeBlanc@osd.mil THANK YOU FOR YOUR ATTENTION! 15

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