“It is not technically feasible to institute a ban at this time given the uses of hexavalent chromium in critical systems,” Yaroschak wrote in an e-mail to Stars and Stripes. ECHA has published on its website a Question & Answer to clarify the legal obligations for downstream users of Chromium VI compounds after the sunset date which is 21 September 2017. Costa has worked as an expert witness on court cases related to hexavalent chromium exposure, including the 1993 lawsuit depicted in the movie “Erin Brockovich” that resulted in $333 million worth of damages paid to more than 600 victims in a California town where the chemical had been illegally dumped in the drinking water supply. Published 1 October 2005 From: Department for Environment, Food & … Follow the procedures in PGI 223.7305 (DFARS/PGI view). Chromium (VI) compounds (the hexavalent forms of chromium – chromates, dichromates and chromic acid) pose the most significant health hazards. “Our industrial hygienists know about that hazard and they protect [workers],” he said. Treatment formulators and paint makers are scrambling to find effective substitutes, but executives say the effort is a challenge. © 2020 Stars and Stripes. This can occur through short-term skin contact, especially if the skin is cut or damaged. 223.7302 Authorities. “We have strict worker protective requirements.”. Moreover, we can symbolize chromium as Cr, but the symbol for hexavalent chromium is Cr(VI) or chromium-6. 223.7300  (b)  Executive Order 13514 of October 5, 2009, Federal Leadership in Environmental, Energy, and Economic Performance. The DoD policy of April 8, 2009, “Minimizing the Use of Hexavalent Chromium,” contains requirements for weighing hexavalent chromium versus substitutes. In Table II (page 11236) the maximum holding time for chromium-VI is listed as 28 days with a reference to footnote 20. 223.7301 Policy. These compounds have been used widely as corrosion inhibitors and in the manufacture of pigments, metal finishing and chrome plating, stainless steel production, leather tanning, and wood preservatives. Hexavalent chromium is a form of the metallic element . Hexavalent chromium [Cr(VI)] is one of the valence states (+6) of the element chromium. The chemical is used in a number of industrial processes as well as for leather tanning, chromium plating, colored glass making and in paint pigments and inks that color plastics and fabrics and serve as corrosion-resistant coatings. It comes in several different forms, including trivalent chromium and hexavalent chromium. Meanwhile, the Occupational Safety and Health Administration greatly increased workplace protections against the chemical over the past three years. Their complaint contends KBR acted negligently in taking steps to protect people at the site. It is a known human carcinogen and can harm the eyes, skin, and respiratory system. 18540-29-9 Hexavalent chromium (Cr (VI)) compounds are a large group of chemicals with varying properties, uses, and workplace exposures. Health threats include lung cancer, kidney damage and asthma. However, Yaroschak said tougher federal health regulations that the DOD also operates under protects workers from those dangers. The REACH Regulation of the European Chemicals Agency effectively bans the use of hexavalent chromium for surface treatment as of 2017. chromium. Hexavalent chromium compounds have no medical uses and are known as mutagens and carcinogens [26]. Servicemembers who strip paint from equipment, for example, are among DOD workers who regularly come in contact with the chemical, Yaroschak said. (a)  Except as provided in 223.7304 and 223.7305, no contract may include a specification or standard that results in a deliverable or construction material containing more than 0.1 percent hexavalent chromium by weight in any homogeneous material in the deliverable or construction material where proven substitutes are available that provide acceptable performance for the application. However, bans on the aerospace industry’s main weapon against corrosion, compounds based on hexavalent chromium, is looming in Europe. Unlike the more stable form chromium-3, chromium-6 is rarely found in nature and is usually formed by industrial processes. In 2006, the European Union banned its use in a wide range of consumer electronics including radios, TVs, video cameras and household appliances because of health and environmental risks. (b)  However, unless an exception in 223.7304 applies, the incorporation of hexavalent chromium in items acquired by DoD shall be specifically authorized at a level no lower than a general or flag officer or a member of the Senior Executive Service from the Program Executive Office or equivalent level, in coordination with the component Corrosion Control and Prevention Executive. Still, Costa said of the DOD’s direction toward reducing its use of hexavalent chromium, “If you can find something else that is just as good or almost as good, you are going to protect people from being exposed to it. Hexavalent chromium is a form of the metallic element chromium. 223.7304 Exceptions. Exemptions may be granted only in exceptional cases, such as military aviation applications. Metallic chromium found in stainless steel is not a RoHS substance. Hexavalent chromium (chromium 6) compounds are on the Proposition 65 list because they can cause cancer. Reduction goals have yet to be set, but the new policy is expected to create a “steady decline” in use over the next decade, according to the DOD Press Office. (a)  Executive Order 13423 of January 24, 2007, Strengthening Federal Environmental, Energy, and Transportation Management. One of the most commonly used form of hexavalent chromium is chromium trioxide. Unless an exception in 223.7304applies, or use has been authorized in accordance with 223.7305, use the clause at 252.223-7008, Prohibition of Hexavalent Chromium, in solicitations and contracts, including solicitations and contracts using FAR part 12 procedures for the acquisition of … Furthermore, you have suggested a nationwide ban of hexavalent chromium from all use in the metal finishing industry. The chemical “is kind of a Dr. Jekyll and Mr. Hyde,” said Paul Yaroschak, deputy director for Chemical and Material Risk Management at the Pentagon. Mark McManaway, a retired National Guard sergeant, and 15 of his fellow Indiana guardsmen say they developed health problems after being exposed to hexavalent chromium while deployed to the war zone in 2003. But for now, the DOD says hexavalent chromium remains too important to ban outright. Hexavalent chromium (Cr +6), in contrast, is toxic. Hexavalent chromium (chromium 6) compounds are also on the Proposition 65 list because they can cause birth defects or other … hexavalent chromium, (electroplating and coatings), cadmium (electroplating), mercury, or other highly toxic or carcinogenic materials •European Union (EU) RoHS and REACH legislation restricts or bans many hazardous materials including hexavalent chromium, cadmium, and lead. Hexavalent chromium, also known as chromium (VI) or chromium-6, is a form of the metallic element chromium. The order requires all military departments to fund and research alternatives in all new applications and provide a detailed explanation for certification if no substitute can be found. Currently, the legislation does apply to the Military. (b)  Additional sustainment related contracts (e.g., parts, services) for a system in which use of hexavalent chromium was previously approved. Chromium is a naturally occurring element found in rocks, animals, plants, soil, and volcanic dust and gases. “Legacy system,” as used in this subpart, means any program that has passed Milestone A in the defense acquisition management system, as defined in DoD Instruction 5000.02. You also want employers to be compelled to stop using hexavalent chromium or chromium (VI), as there are already less hazardous chemical substitutes available. “It is a superb corrosion inhibitor and we use it in primers, paints and coatings. Hexavalent chromium (CrVI) plating is cheap, fast and effective. The current European RoHS Directive bans the use of six substances, one of which is hexavalent chromium. ECHA/NA /17/20. (a)  The prohibition in 223.7303 does not apply to critical defense applications if no substitute can meet performance requirements. OSHA requirements, which the DOD says it adheres to, also limit exposure for workers during an eight-hour day to 5 micrograms per cubic meter of air, down from 50 micrograms before standards were toughened. The lawsuit is expected to go to trial in 2010, McManaway attorney Mike Doyle said. Hexavalent chromium compounds are a group of chemicals that have useful properties, such as corrosion resistance, durability, and hardness. But the new OSHA standards may not go far enough, said Dr. Max Costa, a professor and chairman of the Department of Environmental Medicine at the New York University School of Medicine. Since it creates hard metal coatings, hexavalent chromium was used as paint for many cars, boats, and planes. (6)  Corrosion performance difference of alternative materials or processes as determined by agency corrosion subject matter experts. Executive Order 13423, section 3, paragraph (a) requires that the heads of agencies reduce or eliminate the acquisition and use of toxic or hazardous chemicals. Hexavalent chromium compounds are also used as pigments or as an anti-corrosive agent in paints and other products, and can be used to electroplate chromium onto metal parts. Why is Hexavalent Chromium on the banned list? Approximately 136,000 tonnes of hexavalent chromium were produced in 1985. The ban on hexavalent chromium targets primarily corrosion resistant coatings, such as the chromate conversion coatings applied to zinc plating.