Attachment_0004_-_Stryker_STS_HMMP_Plan.docx

W56HZV-16-D-0037

Subject to Distribution D Statement

STRYKER STS CONTRACT W56HZV-16-D-0037

HAZARDOUS MATERIAL MANAGEMENT PROGRAM (HMMP) PLAN

Prepared By: DONALD BROCK

DOCUMENT NUMBER

CDRL A0009

CONTRACT REFERENCES, CDRL SEQUENCE NUMBER

20 MARCH 2017

DATE SUBMITTED

Prepared by:

General Dynamics Land Systems Inc.

38500 Mound Road Sterling Heights, Michigan 48310

Contents

Introduction Stryker new contracts for FY16 and beyond have redefined the environmental management requirements for the entire life cycle of the vehicle. The environmental management requirements are now in line with those for Abrams that prohibited hazardous materials shall not be used in designs, integration, production, and sustainment. Exception to the hazardous material requirement is permitted in certain applications listed below. In all other cases, request for deviation with justification must be prepared for submission to USG. Hardware/components containing prohibited hazardous materials shall not be delivered to USG without prior approval of the deviation.

The following are the prohibited hazardous materials:

· Asbestos

· Beryllium

· Cadmium

· Class I and Class II Ozone Depleting Substances

· Hexavalent Chromium

· Lead

· Mercury

· Radioactive Materials

· Group 1 Agents classified as carcinogenic to humans by the International Agency for Research on Cancer (IARC) Monographs

Exceptions to the prohibited hazardous materials are as follows:

· Cadmium on electrical connectors and back shells used to mate with cadmium electrical connectors on GFM

· Hexavalent chromium used as a post-treatment on cadmium plated electrical connectors and back shells used to mate with cadmium electrical connectors on GFM

· Chemical Agent Resistant Coating (CARC) primers and topcoats

· Lead in engine bearings

· Lead-acid batteries

· Lead solder

· Steel containing up to 0.35% lead by weight

· Aluminum containing up to 0.4% lead by weight

· Copper and brass alloys containing up to 4% lead by weight

· Beryllium used in electrical components

· Nickel and nickel alloys used in electrical components

· Mercury containing components compliant with European Union (EU) Directive 2002/95/EC (RoHS)

· Trace amounts of identified prohibited materials contained in base materials or alloys are to be reported in the Subcontract Materials Report and the Hazardous Materials Management Report (HMMR), but do not require a waiver. For the purposes of this contract, trace amounts are defined as <0.1% for carcinogens and <1% for all other materials.

HMMP Requirements This HMMP plan (CDRL A0009) is developed in accordance with the reporting requirements of the Data Item Description (DID) DI-MGMT-81398B and Section 4.3 of National Aerospace Standard (NAS) 411 for contract of W56HZV-16-D-0037, MOD P00004.

NAS 411 HMMP Objectives:

The HMMP plan shall define the management strategy to systematically eliminate, minimize, or control hazardous materials while maintaining an appropriate balance with performance requirements specified in the contract and the cost of the HMMP. The HMMP Plan shall define the contractor’s approach to assure:

1. Consideration is given throughout all acquisition phases of the system;

2. Hazardous materials and processes associated with each contract hardware deliverable item are selectively identified and evaluated based on environmental and health concerns;

3. Hazardous materials elimination, minimization, or control are considered and detailed in the system design and the manufacturing process.

Applicable Documents Industry and Government

National Aerospace Standard 411

Hazardous Materials Management Program

DI-MISC-81397

Hazardous Materials Management Program Report

DI-MGMT-81398

Hazardous Materials Management Program Plan

FED-STD-313E

Federal Standard, Material Safety Data, Transportation Data, and Disposal Data for Hazardous Materials Furnished to Government Activities

http://www.epa.gov/p2/pubs/p2policy/act1990.htm

Emergency Planning and Community Right-to-know Act of 1986

United Sates Environmental Protection Agency http://www.epa.gov/agriculture/lcra.html

http://www.gsa.gov/portal/content/104676

http://www.epa.gov/Ozone/ods.html U.S. EPA: Class II Ozone-Depleting Substances http://www.epa.gov/ozone/ods2.html

Issued April 8, 2009 by the Under Secretary of Defense for Acquisition, Technology and Logistics

http://www.gpo.gov/fdsys/pkg/FR-2011-05-05/pdf/2011-10882.pdf

Hazardous Materials Management Program

4.1 Organizational Structure

GDLS Materials Engineering is responsible for analyzing, decomposing, and flowing down hazardous materials requirements to design engineering, reviewing material selection, manufacturing processes, providing hazardous material-free alternatives to engineering and production personnel, and facilitating the implementation of these hazmat-free alternatives in the design.

To identify and eliminate hazardous materials used in design for Stryker, GDLS Materials Engineering communicates with design teams to prevent the use of parts containing prohibited hazardous materials and reviews the new designs to ensure hazmat-free parts and processes are being selected and used.

For production and manufacturing related activities, GDLS Materials Engineering reviews, approves/disapproves, and documents the consumable material purchases and usage in each of the production facilities. The process requires the submission of Safety Data Sheets (SDS) for review. The SDS use-request is reviewed by GDLS Environmental Health and Safety (EHS) and the Materials Engineering group. This ensures up-front screening is performed for all consumable materials used in support of the Stryker program.

Fig 1 below illustrates the interfaces of GDLS Materials Engineering with other functional organizations in controlling the use of hazardous materials for Stryker program.

Figure 1: Materials Engineering Functional Relationships

4.2 Hazardous Material Identification, Evaluation, and Analysis

Implementation of the prohibited material requirements is performed via the Subsystem Performance Specifications, Critical Item Development Specifications (CIDS), and vigorous communications with the design teams. When designs are subcontracted to external suppliers, the Statement of Work (SOW) is used to identify and impose hazardous materials requirements on these designs. In addition, subcontractor deliverables for hazmat identification within their designs is required.

4.2.1 Hazmat Identification

Throughout the design process, GDLS Materials Engineering reviews design documentation for hazardous material compliance. The reviews primarily consist of a review of the Bill of Materials (BOM) to ensure all parts have been reviewed for compliance. In addition, all engineering drawings per Engineering Release Plan (ERP) are reviewed to ensure clean surface finishes and material callouts are used. When vendor parts are identified, GDLS Materials Engineering will work with the design engineers to identify and eliminate hazardous materials used in these vendor selected COTS parts.

For this Styrker STS effort, GDLS Materials Engineering personnel will reinforce the requirements to eliminate parts containing hazardous materials from new designs and review progress on design activites on a biweekly basis. The current ongoing design activites include but are not limited to:

· WIN-T Next Gen Integration for Stryker C4ISR

· MGS Battery Box Redesign

· EA Seat/Troop Heater

· APS Installation and Demonstration

In instances where prohibited hazardous materials are found on new Stryker Designs, the design will be evaluated by GDLS Materials Engineering and the owner of the hardware for potential alternatives. In the cases where an alternative provides a complete (fully compliant) engineering solution, the alternative will be implemented. In the cases where the alternative presents a conflict with one or more of the other requirements, an engineering decision will be made (with the assistance of Project Engineering Management and the design owner) to choose the best path forward. This decision is made taking all aspects into account including, but not limited to hazardous materials requirements, functional performance, cost, and schedule impact.

If a clean alternative part cannot be found for a new Stryker design, permission will be requested through the deviation process citing the justification(s) for its use, where the part is being used, and any potential risks identified.

Figure 2 below illustrates the overall identification and evaluation process for hazardous materials:

Figure 2: Process for Supporting Engineering Design

4.2.2 Hazmat Analysis/Evaluation

For the current Stryker Program, Hazardous Materials are prioritized as follows:

1. Banned Materials

· Class I and Class II Ozone Depleting Chemicals (ODCs).

Banned materials are the materials for which a waiver will not be sought by Materials Engineering. These materials shall not be used in the design or manufacturing process.

2. Prohibited Materials:

· Asbestos

· Hexavalent Chromium (HC)

· Cadmium (Cd)

· Mercury (Hg)

· Beryllium (Be)

· Lead (With the Exception of Lead Solder and trace amount of lead in alloys)

3. Radioactive Materials and Group 1 Agents

· Radioactive Materials

· Group 1 Agents classified as carcinogenic to humans by IARC

The substances listed above are all contractually prohibited and will therefore only be allowed on the Stryker platforms if they are legacy designs for which waivers already exist or a master deviation is required, if they are on the exception list identified in section 1 of the plan, or if no known/feasible alternatives exist and a program deviation is granted. All instances of known parts that utilize a prohibited material not found on the exception list will be sought through the request for deviation (RFD) process.

4. Other Hazardous Materials as defined by FED-STD-313D

GDLS evaluates hazardous materials that are not prohibited by contract on a case-by-case basis via the Material approval process for SDS’s. The full list of ‘restricted’ materials can be found in Appendix A of this document.

When materials are requested for use by manufacturing facilities or at the depot sites for Stryker, GDLS Materials Engineering is part of the approval process (in addition to Environmental Health and Safety) to ensure all materials being used in production and support of the Stryker program are reviewed for prohibited or restricted material content. Figure 3 below illustrates the material review process:

Material Purchase Request to SCM SCM Reviews Drawing New or Updated IMD?

Review Engineering Drawing/Program Requirements Select Material/ Qualified Suppliers Develop an IMD

SCM

CM

SCM Processes Request CM Stores the IMD in Database Peer Review Requester Review & Approval

(2) Approve/ Disapprove Material

(1) Production Support

Figure 3: Process for supporting material control.

Due to the large number of chemicals identified as ‘Restricted’, the basis for reporting this category will be through a ranking system that incorporates many different scoring criteria to establish a priority list for hazmat reduction. The following categories below are used to create a composite score for each SDS used, which can then be used to identify materials that may have the largest environmental, health, or safety impacts:

1. Toxicity

2. Carcinogen/Teratogen

3. Flash Point

4. Storage Requirements

5. Transportation Requirements

6. Environmental

Based on each category, each material is given a score from 0 to 25, with 25 being the most hazardous. From there, substances can be ranked accordingly and targeted for reduction or elimination. The scoring system used to rate each category can be found in Appendix B of this document.

4.3 Environmental and Health Evaluation

Due to the maturity of the Stryker program, most, heath risks due to hazardous materials have been designed out of the baseline platform. Similarly, the environmental footprint of the Stryker FoV has been minimized to a large extent since its inception. The majority of items containing prohibited materials on the Stryker FoV are in electrical connectors which use cadmium plating, hexavalent chromium finishes, and beryllium spring fingers. These uses of prohibited materials are now found on the exception list for GFE items or those mating to cadmium plated/HC finished GFE components, and therefore will not be required to a deviation request. Additionally, casual contact with these items has been shown to not pose any significant health risk to users.

As new materials are introduced to new designs for SES (System Engineering Support) and C4ISR (Command, Control, Communications, Computers, Intelligence, Surveillance, and Reconnaissance) projects, they will be investigated for possible health or environmental risks that they may pose. Through the review and scrutiny of Safety Data Sheets, each application is reviewed by the GDLS Environmental Health and Safety, as well as Materials Engineering to determine any risks that may be associated with their use in the manufacture of the vehicle. In the event that certain material(s) pose a health or environmental risk, Hazardous Materials Engineering collaborates with other engineering disciplines as needed (such as EHS, System Safety, Human Factors Engineering, Design Engineering, and Project Engineering) to determine if alternative materials can be used to eliminate the risk. When risks cannot be eliminated, steps are taken to mitigate risks to the lowest level possible, often thru the appropriate implementation of Personal Protective Equipment (PPE) requirements, training, and other specific use requirements for materials determined hazardous.

4.4 Trade-off Analysis and Documentation

In the event that hazardous materials requirements are in conflict with other Stryker requirements, a trade-off analysis will be performed. Trade-off analyses can take many forms, depending on the complexity of the requirements and other factors. Consequently, trade-off analyses are performed to the extent required to produce a decision that yields the most benefit for the program.

For many of the hazardous materials requirements issues, it is expected that an alternative can be used that provides similar technical performance while still complying with the Stryker performance requirements. In these cases, Hazardous Materials Engineering will work with design engineering and/or supply chain management to ensure clean alternatives are implemented.

When a conflict in prohibited material requirements arises for which there is no obvious solution, more in-depth trade-off analyses will be performed. In these cases, Hazardous Materials Engineering, the design engineer, Supply Chain Management, Project Engineering Management, and any other affected party will collaborate to resolve the issue. The group will assesses all aspects of the requirements in question including, but not limited to technical capability, availability, cost, and schedule. Using these factors, a solution will be reached that considers all of these factors. If/when Stryker SES or C4ISR designs require this trade-off, the analysis of alternatives as well as estimated costs associated with implementing clean alternatives will be presented to the customer, most likely in the form of the formal contract waiver prepared and delivered by the Materials Engineering team.

Subcontractor Requirements

To ensure Stryker SES/C4ISR designs do not utilize any prohibited hazardous materials, GDLS Materials Engineering works closely with subsystem engineering as well as supply chain management (SCM) to ensure hazardous material requirements implemented in supplier Request for Proposals (RFPs), CIDS, and Purchase Orders (PO). For subcontractor designed parts, GDLS materials engineering allocated Stryker Prohibited material requirements through the CIDS and supplier SOW. Supplier compliance with the prohibited material CIDS requirements helps to ensure supplier parts are designed without the use of prohibited materials whenever possible.

For parts and materials purchased through SCM, additional measures are in place to help GDLS Material Engineering identify and eliminate prohibited materials in supplier parts. Each supplier Purchase Order includes language addressing prohibited and hazardous materials (Appendix C).

To help institute quality control and identification/elimination of hazardous materials, GDLS Materials Engineering is also involved in the creation, maintenance, and approval of all Indirect Material Drawings (IMD). IMD’s are drawings used by Supply Chain Management to purchase consumable materials used at all GDLS facilities. The drawings help to identify appropriate product information, SDS numbers, sizes, colors, quantities, (among other attributes) required by SCM to buy the consumable materials. Through management, maintenance, and approval of IMDs, GDLS Materials Engineering has another means to identify and eliminate hazardous or prohibited materials from the Stryker supply chain and production facilities.

Disposal

All parts, regardless of whether parts are being replaced at depot or at a GDLS facility, are processed and disposed of in accordance with the local environmental regulations and applicable laws at the repair site. In instances where there are no special disposal requirements, the parts will be processed consistent with local EHS policies and procedures.

Appendix A – Restricted Materials

NEW PROGRAM RESTRICTED MATERIALS

Appendix B – Hazardous Material Scoring Criteria

HMMP SCORING GUIDE FOR THE SELECTION OF MATERIALS

High Toxicity or Severe Hazard: (For ingredients >1.0%)*

Carcinogens: (For ingredients >0.1%)*

Teratogens: (For ingredients >0.1%)* (Known Birth Defect Producer)

Flash Point: (For ingredients >5.0%)*

Note: Excludes Flash point of Propellants used in Aerosol Cans

Storage Requirements: (See MSDS or TOXNET)

Strong Oxidizer

Transportation Requirements: (See MSDS or 49CFR & IATA Regulations)

Strong Oxidizer

Environmental Priority: (For ingredients >1.0%)*

(*) If a chemical in the material being rated is less than the indicated percentage, it will not be evaluated for that category.

When the total score is 7 or higher, the material is rejected if alternatives are available.. If it is an existing material, it will be scheduled for replacement if feasible. If the material is critical to research, production or maintenance and alternatives are not available; it may be used if safeguards and controls are implemented to minimize personnel exposure and release to the environment.

Appendix C - Standard CIDS Requirements Finish Metal Surface Pretreatment The procedures in MIL-DTL-53072 shall be adhered to for all metals with the exception of the application of hexavalent chromium based pretreatment. Hexavalent chromium shall not be utilized in any pretreatment process. Aluminum components not requiring electrical conductivity shall be treated in accordance with MIL-DTL-5541 using conversion coating Type II Class 1A or equivalent alternative.

Aluminum components requiring electrical conductivity shall be treated in accordance with MIL-DTL-5541 using conversion coating Type II Class 3 or equivalent alternative. Ballistic steel, in excess of Rockwell C-40, shall be surface blasted to a finish profile of 1.0 to 3.0 thousandths of an inch and primed within six hours. High hard steel, in excess of Rockwell C-40, shall be surface blasted to a finish profile of 1.0 to 3.0 thousandths of an inch and primed within six hours. Non-ballistic High hard steel shall be surface cleaned in accordance with MIL-DTL-53072. An alternate cleaning method may be proposed in accordance with MIL-DTL-53072. GDLS shall be notified in advance if an alternate cleaning method is proposed. If primer is not applied within the specified time limit, a chemical wash KLEENINHIB 486 or equivalent shall be applied to prevent flash rust prior to the application of primer.

Rust inhibitor, KLEENINHIB 486 or equivalent, shall be removed prior to application of primer. On high hard steel, in excess of Rockwell C-40, the contractor shall prime the surface within six hours.

Anodizing Anodizing per MIL-A-8625 is permissible providing Type I and IB are not utilized. Anodized components shall use non-chrome containing sealers, as listed in Paragraph 3.8 of MIL-A-8625. Anodized components, being painted, shall use nickel or cobalt acetate based sealers. Anodized components, not subsequently painted, shall use EnviroSeal 2500 sealer or an equivalent.

Paint Component surfaces shall be CARC painted in accordance with procedures outlined in MIL-DTL-53072. The painting procedures in MIL-DTL-53072 shall be adhered to with the exception of hexavalent chromium containing materials; hexavalent chromium shall not be utilized. Unless otherwise specified herein, component surfaces shall be painted white in accordance with FED-STD-595, paint chip 17925. Primers and topcoats used on component surfaces shall be listed in MIL-DTL-53072 and on U.S. Military QPL or be validated through the U.S. ARL Experimental Products Program.

Hazardous Materials The ‘Assembly’ shall not use or contain the hazardous materials listed in Table XX in any form or process of manufacturing without specific prior written approval from GDLS Material Engineering.

TABLE XX Hazardous Materials Restrictions

b. If anodized components will be subsequently painted, sealers will be cobalt acetate

Use of lead-free solders is permissible, but must also be documented

U.S. Nuclear Regulatory Commission Regulations: Title 10, Code of Federal regulations, 25 May 2009. <<http://www.nrc.gov/reading-rm/doc-collections/cfr/part020/part020-appc.html>>

b. Classified by the National Toxicology Program, Eleventh Report as known to be or reasonably considered to be a Human Carcinogen (As defined in Part A <<http://ntp.niehs.nih.gov/ntp/roc/eleventh/known.pdf>> and Part B <<http://ntp.niehs.nih.gov/ntp/roc/eleventh/reason.pdf >)>

c. Regulated by OSHA as a carcinogen. <www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10007 <http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10007>> Contact GDLS Hazardous Materials Engineering for clarification or determination

Ozone Depleting Substances Ozone depleting substances, Class I and Class II as per US Environmental Protection Agency (42 USC 85 §7671a), shall not be used in the manufacture, assembly, or sustainment of the IVN ES.

Leaded/Lead Free Components and Solder All leaded and lead-free components shall be clearly identified by separate part numbers. GDLS shall be notified in advance prior to switching composition of the leads for electrical components and whether last time buys are available. If lead-free solders are used, the location of the solder and the specific type of lead-free solder must be identified. Test results of all performance and validation testing to validate the performance of the alternative solder shall be submitted to GDLS.

Acronyms

Distribution Statement D:

Distribution authorized to the Department of Defense and U.S. DoD contractors only. (Reason: Proprietary Information,Export Controlled) (Date of Determination: 1 October 2015). Other requests shall be referred to the Project Manager, Stryker Brigade Combat Team, (PM SBCT), ATTN: SFAE-GCS-SBCT, 6501 E. 11 Mile Road, MS 325, Warren, MI 48397-5000.

WARNING - This document contains technical data whose export is restricted by the Arms Export Control Act (Title 22, U.S.C., Sec 2751, et seq.) or the Export Administration Act of 1979 (Title 50, U.S.C., App. 2401 et seq.), as amended. Violations of these export laws are subject to severe criminal penalties. Disseminate in accordance with provisions of DoD Directive 5230.25.

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