AMMTIAC-WSTIAC Journal, Vol. 1, No. 2 - Advanced Materials ...

ated to meet the new application requirements. For example,using an alternative coating system on an interior may requiremold resistance, or similarly, using the alternative on an applicationwhere stress loads vary will require mechanical testing of thecomponent to provide reliable data for design allowables. Subjectmatter experts (SMEs) should be employed to establish the testingand evaluation criteria for components/systems. Lastly, theuse of alternatives will likely require new procedures resulting intraining of personnel and updating technical manuals (TMs) andtechnical orders (TOs).POLICIES AND REGULATIONSIt will be increasingly difficult in the future for program officesto include CrVI-containing compounds as part of their overallcorrosion prevention strategy. This is due in large part to thenumerous changes in ESOH regulationsimplemented over the past decade.Recent DoD policies have added to thisstricture, by first requiring the Services to more aggressivelyimplement corrosion prevention and control measures in Defensesystems and infrastructure, and then subsequently directingComponents to minimize, to the degree possible, the use of CrVIin military assets. These new policies push for using alternativesto CrVI as the new default, and only using CrVI in cases whereno alternative is acceptable. This section summarizes relevantpolicies and regulations.It will be increasingly difficult forProgram Offices to use CrVIThe 2003 Wynne MemorandumCongress passed a provision as part of the 2003 DefenseAuthorization Act, 10 USC Sec. 2228, which mandated that theDoD institute formal steps to minimize the impact of corrosion toDoD systems and infrastructure.On November 12, 2003, then-Principal Deputy Undersecretaryof Defense for Acquisition,The DoD is required by law to takeeffective steps to minimize the impactof corrosion on Defense assets.Technology, and Logistics (PDUSD/AT&L) Michael W. Wynneissued a memorandum to the Secretaries of the MilitaryDepartments directing that corrosion prevention and controlplanning be an integral part of the initial design and acquisitionprocess, subject to the Defense Acquisition Board (DAB) review.This memorandum set the stage for reduced life cycle costs of newsystems by designing-in corrosion resistance.The 2009 Young MemorandumOn April 8, 2009, John J. Young Jr., then-Director, DefenseResearch and Engineering (DDR&E), issued a memorandum tothe Secretaries of the Military Departments calling for minimizingthe use of CrVI. It was in response to stricter regulations setforth in both the US and Europe. Thememorandum does not ban the use ofCrVI, rather provides for specificinstances where its continued use isacceptable. What it did change specifically was that for all designdecisions where CrVI use would be considered, PMs would berequired to furnish a rationale and justification for their materialselection regardless of whether CrVI or an alternative was chosen.The following actions were called out in the memorandum:Invest in appropriate research and development on substitutes.• Ensure testing and qualification procedures are funded andconducted to qualify technically and economically suitablesubstitute materials and processes.• Approve the use of alternatives where they can perform adequatelyfor the intended application and environment. Where CrVI isproduced as a by-product for use or manufacture of other acceptablechromium oxides, explore methods to minimize CrVI production.• Update all relevant technical documents and specifications toauthorize use of the qualified alternatives and, therefore, minimizethe use of materials containing CrVI.• Document the system-specific CrVI risks and efforts to qualifyless toxic alternatives in the programmatic ESOH evaluationfor the system. Analysis should include any cost/schedule risksand life cycle cost comparisons among alternatives. Life cyclecomparisons should address material handling and disposalcosts and system overhaul cycle times/costs due to any differ-PMs will be required to furnish arationale and justification for CrVI oran alternative, regardless of choice.Figure 2. Minimization Policy 4The AMMTIAC WSTIAC Journal, Volume 1, Number 2 6http://ammtiac.alionscience.comhttp://wstiac.alionscience.com