CHEMICAL AND MATERIAL RISK MANAGEMENT PROGRAM (CMRMP) TOXIC SUBSTANCES CONTROL ACT (TSCA) MARKET ANALYSIS

This Request for Information (RFI) is issued solely for information and planning purposes and does not constitute a solicitation. All information received in response to this RFI marked Proprietary will be handled accordingly.

Responses to the RFI will not be returned.  Responses to this RFI are not offers and cannot be accepted by the Government to form a binding contract. A response to this RFI is necessary to assist the Government in determining the potential levels of interest, adequate competition, market maturity and technical capabilities within the Large and Small Business Communities to provide the required capabilities.

The Government does not intend to award a contract based on this RFI or reimburse any costs associated with the preparation of responses to this RFI. It will also not consider any solutions that are proprietary.

Overview. This RFI is issued to gather information to identify and assess critical applications for the U.S. Department of Defense (DoD) and the defense industrial base (DIB) that necessitate the use of existing chemicals undergoing the U.S. Environmental Protection Agency’s (EPA) Toxic Substances Control Act (TSCA) section 6 risk evaluation process. This RFI will help the Office of the Assistant Secretary of Defense for Energy, Installations, and Environment (OASD(EI&E)) Chemical and Material Risk Management Program (CMRMP) better understand the use of TSCA existing chemicals in products leading into the defense supply chain. This RFI is focused on receiving information related to a portion of the TSCA existing chemicals as shown in Table 1 (the table can be found in the Instructions attachment). DoD seeks to better understand (1) applications that require the use of these chemicals; and (2) the criticality of those chemicals for industry and supply.  DoD will continue to issue RFIs to consider additional TSCA chemicals.

Background. The mission of the CMRMP is to enhance readiness, support the warfighter, and build supply chain resilience by identifying and managing risks associated with the chemicals and materials DoD uses in accordance with reference (a). The CMRMP does this by enabling more effective management of current and future risks from chemicals and, in so doing, encourages sustainable chemical practices, lowers lifecycle costs, drives innovation, and avoids the need for future crisis-driven retooling to comply with new regulations.

An essential function of the CMRMP is early identification of chemicals that are necessary and even critical to the DoD mission. Currently, the primary source of chemical ingredient data used by DoD originates from Safety Data Sheets (SDSs) submitted by industry who sell hazardous materials to DoD in accordance with reference (b). These SDSs, however, are limited, and only list chemical constituents classified as health or physical hazards in accordance with reference (c), thus limiting the capture, and sharing of chemical ingredients. Due to a reliance on SDSs, DoD lacks visibility in tracking upstream applications to understand the implications of developing regulatory drivers, such as TSCA, and respond to inquiries on supply chain uses.

As a result, DoD seeks to better understand (1) DoD applications that require the use of TSCA existing chemicals as shown in Table 1; and (2) the criticality of those chemicals for industry. If EPA determines unreasonable toxicological risks during the TSCA risk evaluation for a condition of use (COU), then EPA can introduce rulemaking options such as prohibitions or restrictions to address the unreasonable risk(s). DoD’s ability to identify critical applications earlier in the TSCA section 6 risk evaluation process will allow DoD to investigate the availability of alternatives, inform industry and interagency engagement, and better manage chemicals critical to national defense.

Responses will be used for DoD informational purposes only. DoD also welcomes discussion with industry after response submission, if there are additional details they wish to convey. Please reach out to program mailbox or POCs as listed below.

Submit your company’s written response to:

osd.pentagon.ousd-atl.mbx.cmrmp@mail.mil

Primary Point of Contact:

Kelsey Hendrixson

kelsey.v.hendrixson.civ@mail.mil

References. 

1. Department of Defense Instruction 4715.18, Emerging Chemicals of Environmental Concern. Effective September 4, 2019; Change 1 February 29, 2024. https://www.esd.whs.mil/Portals/54/Documents/DD/issuances/dodi/471518p.pdf.
2. FED-STD-313F, Material Safety Data, Transportation Data and Disposal Data for Hazardous Materials Furnished to Government Activities, October 12, 2018. https://www.gsa.gov/system/files/FED-STD-313F%20final%20(1).pdf  
3. 29 CFR 1910.1200, Occupational Safety and Health Standards: Hazard Communication. https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.1200