Emerging Contaminants (ECs) are chemicals and materials which either lack sufficient information about human health and environmental effects or our previous understanding about them and their effects is evolving. These changes may be due to new science, detection limits, or pathways. ECs can have significant negative impacts on people, the environment, resources, business functions, and the defense mission.
The Department of Defense’s Emerging Contaminants Program looks “over-the-horizon” to identify and assess chemicals and materials with evolving risks. It then develops proactive risk management actions that reduce risks to human health, the environment, and the mission before being required to do so by regulations and ideally before negative impacts occur. This program has turned the traditional way of dealing with these issues upside down. Previously, the Department of Defense (DoD) philosophy in dealing with ECs could be described as mostly reactive and compliance-oriented. Simply put, when and if a regulation requires an action, the DoD will comply. The EC Program has been able to implement a philosophy of proactive risk management, assessing EC risks and taking actions before regulatory requirements.
Regulators, Congress, and the public have voiced a high level of concern related to potential contamination of drinking water sources from perchlorate, an oxidizer used in DoD missiles and munitions. Thus, an important measure of success relates to assessing sites and taking action, where necessary, for perchlorate releases. Perchlorate is a particular concern in California. DoD and the State of California developed a site screening process called the “California Prioritization Protocol”. Over the past 3 years, 924 sites with potential perchlorate contamination were jointly screened using protocol parameters. The screening is essentially completed and indicates that no DoD sites are currently posing a threat to California drinking water based on information gathered to date. While follow-up work continues, this is a major success story, especially since DoD was initially thought to be the major source of contamination. An article about the protocol, jointly written by DoD and California regulators, was published in the December 2008 issue of Environmental Management magazine. Department-wide, over 47,000 perchlorate samples have been taken and a key goal has been achieved: 100 percent of sites with known perchlorate releases have been assessed and appropriate actions are completed or underway in coordination with regulators.
A measure with significant potential impact across DoD is the number of Risk Management Options (RMOs) approved by the EC Governance Council. The Council is made up of executives representing numerous DoD functions. Three program reviews have been held so far, in September of 2006, 2007, and 2008. The Council approved 100 percent of the recommendations, including the elevation of five ECs to the action list and approving seven RMOs for investments and actions. For example, the Council approved the development of an accelerated corrosion test protocol that will help minimize the use of hexavalent chromium currently used in numerous DoD platforms and systems. Hexavalent chromium has wonderful corrosion protection properties but is a highly toxic material. The test protocol will allow DoD program managers to better evaluate substitute materials.