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DFARS Clause on Hexavalent Chromium published in Federal Register

04.11.10, by kmcgill, in Hexavalent Chromium, Policy/Guidance, Statutes and Regulations

On April 8, 2010 the long-awaited proposed DFARS clause on minimizing the use of hexavalent chromium from DoD contracts was published in the federal register. Written comments to the proposed rule will be accepted until June 7, 2010.

The published proposal differs in several potentially important ways from the draft last reviewed by Army ESO in the fall. The significant differences are discussed below:

1) The prohibition in sec. 223.7302 simplifies the language by stating that the prohibition for deliverables or the use of hexavalent chromium, shall be “in contract performance” rather than “during sustainment phases of a system.”

2) For legacy systems the revised language states that alternative “shall” (vice “should”) be considered during system modifications, …

3) The exception for “barium chromate based corrosion inhibitors” has been eliminated.

4) The prohibition language to be placed into contracts not only prohibits any “deliverables” from containing hexavalent chromium, but also prohibits contractors using such materials in performance of the subject contract. This clause would seem to then prohibit the use of hard chrome on DoD weapons systems without explicit approval.

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Senate Republicans move to bar NEPA analysis of warming impacts

04.20.10, by jblloyd, in NEPA

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Synopsis- The Clean Air Act Services Steering Committee subgroup on Global Climate Change and Green House Gases has been reviewing legislation put out by the EPA that would include a new requirement for Federal Agencies including the Army to look at the impact of global climate change during the NEPA review of facilities and weapon systems.  It would mean the analysis of greenhouse gas emissions on over climate change as part of the facility or weapon system NEPA process.  The proposed changes to the NEPA policy would be phased in and take effect in 2011.  This may be coming to an end as Senate republicans introduced a bill to prevent this requirement from being placed in NEPA legislation in the future.  The bill would bar any global climate change requirement from being introduced into the NEPA judicial process.  It would preclude the PM from having to quantitatively try to assess the effect of greenhouse gas emissions on the global climate.

 
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Meeting Minutes, Quarterly ESO IPR Conference Call, 30 March 2010 – follow- up and action items

04.19.10, by jheise, in IPR

Team ESO

Attached please find the approved meeting minutes from the ESO Quarterly IPR held on 31 March 2010.  ESO was waiting on ESO FY2010 Program Plan input from the IPT Chairs which is attached to the meeting minutes (Attachment 1).

The action items below were assigned during the subject meeting for your action.  Each action is listed with a suspense date and responsible person(s).  These action items have been updated in the meeting minutes with current status.

Action Items with current status:

  1. ESO (Dave Koehler) will coordinate the requirements for the ODS policy going forward  for continued use of halon in existing weapon systems.  A follow-on meeting with AMCOM, CECOM, TACOM, Dan Verdonik, Ken Davis, Steve McCormick, Lead Technical Engineer for fire protection and IPT Chairs. A meeting was held on 15 April with ESO and IPT Chairpersons to discuss the current policies and path forward for continued use of halon in weapon systems. (Action:  Dave Koehler/Dan Verdonik/IPT Chairs)
  2. ESO (Dan Verdonik/George Evans) will provide WEEKSUMS to IPT Chairs each week once approved by ESO. WEEKSUMS will be forwarded starting on 1 April 2010. (Action: Dan Verdonik/George Evans.  This action is being performed.  Action closed.
  3. ESO (Kevin McGill) will coordinate with the IPT Chairs to discuss the hexavalent chrome policy implementation.  Meeting was held on 14 April 2010 with ESO and IPT Chairpersons to discuss the actions and path forward on implementing the chrome policy.  ESO will continue to work the issues for PMs regarding definitions in the policy, DFARS implementation, the coordination process and the waiver process.  (Action: Kevin McGill/IPT Chairs)
  4. Provide input (IPT Chairs) to the FY 2010 ESO Program Plan to include the top program initiatives for 2010.  Inputs were provided for inclusion in the meeting minutes.  (Action:  IPT Chairs).
  5. Perform obligations/disbursement of FY 2010 program monies and review FY 2009 obligations/disbursements as soon as possible (Action:  IPT Chairs).
  6. Provide articles to ESO for the AMC Environmental Newsletter on program activities and updated legislation and proposed rule making.  This action is on hold due to legal review. (Action:  IPT Chairs/Dan Verdonik).

If you have any questions, do not hesitate to contact myself or Mr. Nate Craig regarding the attached information.  Also, attached to this email are the briefing materials from the Quarterly IPR.

Thanks,

Jean B. Lloyd

Program Manager

Prospective Technology Incorporated

 
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New Action Items – 30 March IPR

04.15.10, by jblloyd, in IPR

ESO IPR Quarterly Meeting, 30 March 2010

New Action Items:

  1. ESO (Dave Koehler) will coordinate the requirements for the ODS policy going forward  for continued use of halon in existing weapon systems.  A follow-on meeting with AMCOM, CECOM, TACOM, Dan Verdonik, Ken Davis, Steve McCormick, Lead Technical Engineer for fire protection and IPT Chairs. A meeting will be conducted in early April 2010. (Action:  Dave Koehler/Dan Verdonik/IPT Chairs)
  2. ESO (Dan Verdonik/George Evans) will provide WEEKSUMS to IPT Chairs each week once approved by ESO. WEEKSUMS will be forwarded starting on 1 April 2010. (Action: Dan Verdonik/George Evans)
  3. ESO (Kevin McGill) will coordinate with the IPT Chairs to discuss the hexavalent chrome policy implementation.  Meeting will be held in early April. (Action: Kevin McGill/IPT Chairs)
  4. IPT Chairs provide input to the 2010 ESO Program Plan to include the top program initiatives for 2010.  Please provide input to ESO prior to April 15, 2010 for inclusion in the meeting minutes (Action:  All IPT Chairs).
  5. Perform obligations/disbursement of FY 2010 program monies and review FY 2009 obligations/disbursements as soon as possible (Action:  All IPT Chairs).
  6. Provide articles to ESO for the AMC Environmental Newsletter on program activities and updated legislation and proposed rulemaking (Action:  IPT Chairs/Dan Verdonik).
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Protected: AAE ODS Policy memo Mar 10 v3

04.12.10, by dkoehler, in Ozone Depleting Substances, Policy/Guidance

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