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One team, one voice delivering global acquisition insight that matters. Presented by: Shane Esola Technical Lead, Industrial Base Assessment DCMA Industrial Analysis Group NDIA Systems Engineering 23-26 Oct 2017 One team, one voice delivering global acquisition insight that matters. UNCLASSIFIED Assessing the impacts of Amended Toxic Substances Control Act (TSCA) to the DoD Mission and the Defense Industrial Base (DIB) DIB Mission Assurance and IB Risks Posed by Chemical Regulation DISTRIBUTION A. Approved for public release: distribution unlimited. UNCLASSIFIED

Assessing the impacts of Amended Toxic Substances Control ... · Technical Lead, Industrial Base Assessment DCMA Industrial Analysis Group NDIA Systems Engineering 23-26 Oct 2017

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Page 1: Assessing the impacts of Amended Toxic Substances Control ... · Technical Lead, Industrial Base Assessment DCMA Industrial Analysis Group NDIA Systems Engineering 23-26 Oct 2017

One team, one voice delivering global acquisition insight that matters.

Presented by:Shane Esola

Technical Lead, Industrial Base AssessmentDCMA Industrial Analysis Group

NDIA Systems Engineering 23-26 Oct 2017

One team, one voice delivering global acquisition insight that matters.

UNCLASSIFIED

Assessing the impacts of Amended Toxic Substances Control Act (TSCA) to the DoD Mission and the Defense Industrial Base (DIB)

DIB Mission Assurance and IB Risks Posed by Chemical Regulation

DISTRIBUTION A. Approved for public

release: distribution unlimited.

UNCLASSIFIED

Page 2: Assessing the impacts of Amended Toxic Substances Control ... · Technical Lead, Industrial Base Assessment DCMA Industrial Analysis Group NDIA Systems Engineering 23-26 Oct 2017

One team, one voice delivering global acquisition insight that matters. 2

Outline

o Introduce the Industrial Analysis Group (IAG)

o Problem Statement (DIB sector perspective)

o Pilot Assessment Results

o Degrees of Potential Market Collapse Due to Regulation

o National Security Exemptions

UNCLASSIFIED

UNCLASSIFIED

Page 3: Assessing the impacts of Amended Toxic Substances Control ... · Technical Lead, Industrial Base Assessment DCMA Industrial Analysis Group NDIA Systems Engineering 23-26 Oct 2017

One team, one voice delivering global acquisition insight that matters.

Pre-Concept

Technology

Maturation & Risk

Reduction

Engineering &

Manufacturing

Development

Production

& Deployment

Operations &

Support

Materiel Solution

Analysis

Major

Milestones

3

Industrial Analysis Group (IAG) Mission

Mission Statement:

• Deliver actionable acquisition insight to DCMA, DoD senior leadership, and the national critical infrastructure community

by continuously analyzing industrial capabilities and identifying strategic risks with recommended solutions through

a Mission Assurance (MA) framework in order to ensure Defense Industrial Base (DIB) industrial capabilities are

available to provide the most critical goods and services needed by the warfighter.

• Lead the execution of DCMA’s regulatory responsibility for national DIB Sector Mission Assurance.

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A B C

IOC FOCFRPLRIP

• Acquisition Strategy requires Industrial Analysis considerations prior to milestone decisions.

Design Development Production Sustainment

Page 4: Assessing the impacts of Amended Toxic Substances Control ... · Technical Lead, Industrial Base Assessment DCMA Industrial Analysis Group NDIA Systems Engineering 23-26 Oct 2017

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Industrial Analysis Group Mission Impacts

What IAG Does For DoD

1 DCMA is the lead DoD component for the DIB sector. Ensures DIB industrial capabilities are available to provide the most critical goods and services needed by the Warfighter.

2 Executes industrial base assessments in support of statutory and regulatory acquisition program requirements (e.g. supports Milestone Decisions). Feeds DIB MA Process.

3 Shares industrial base intelligence among DCMA, DoD Enterprise, and National Critical Infrastructure community to assist in understanding the DIB, build collective knowledge,assess/manage risk, maintain readiness, and prioritize workload/funding

“Director, DCMA executes assigned national sector responsibilities for the DIB on

behalf of the SECDEF and synchronizes these activities with the MA Construct.”

~ From DRAFT DoD Instruction 3020.45, “Mission Assurance Construct” (May 2017) ~

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UNCLASSIFIED

DIB ASSET IDENTIFICATION(DoD Suppliers)

ASSESSMENT

RISK MANAGEMENT

!!! Alert !!!

MONITOR/REPORT

Page 5: Assessing the impacts of Amended Toxic Substances Control ... · Technical Lead, Industrial Base Assessment DCMA Industrial Analysis Group NDIA Systems Engineering 23-26 Oct 2017

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Industrial Base Assessments (IBA)

Objective – Determine IB Risk

1. How important is a capability to DoD (criticality)?

2. How likely is it that the capability will be disrupted (fragility)?

Manage & Store DIB Data Analyze & Assess Industrial Capability Risk Report to Senior LeadersSurvey Industry & Gather Data

Industrial Base Assessment(Key Analysis Data Sets)

Company Profile

Business Profile

Product Profile

Industrial Capabilities

Critical / Key Sub-tier Suppliers

Alternate Sources of Supply

Program Risk (e.g. QA)

Financial Risk

Industrial Base Capability Risk

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UNCLASSIFIED

Page 6: Assessing the impacts of Amended Toxic Substances Control ... · Technical Lead, Industrial Base Assessment DCMA Industrial Analysis Group NDIA Systems Engineering 23-26 Oct 2017

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Why is the Chemical/Material Sector Important?

Secret Sauce

UNSEEN RISK - these risks are buried within a complex, global supply chain

Can be enablers of Key PerformanceParameters (KPPs) and U.S. Military strategicadvantage

Fundamental ingredients - higher probabilityof impacting a greater number of programs

May enable a wide variety of industrial andmaintenance processes

Chemical sector accounted for 2% of GDP in2016 (largest contributor in manufacturing)

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UNCLASSIFIED

Page 7: Assessing the impacts of Amended Toxic Substances Control ... · Technical Lead, Industrial Base Assessment DCMA Industrial Analysis Group NDIA Systems Engineering 23-26 Oct 2017

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What Risks Can Result from Legislation/Regulation?

MARKET COLLAPSE and Unavailability of Chemical/Material

Increased burden on industry Limit competition by increasing barriers to entry Suppress innovation by decreasing design choice Foreign supplier dependency Increased cost of goods & services Program schedule delays Performance issues due to unmanaged substitution

Operational readiness impacts

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UNCLASSIFIED

Page 8: Assessing the impacts of Amended Toxic Substances Control ... · Technical Lead, Industrial Base Assessment DCMA Industrial Analysis Group NDIA Systems Engineering 23-26 Oct 2017

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What Can Be Done to Manage Potential Risk?

BALANCE human health risk management with industrial base and mission risk

Monitor pending regulatory and statutory changes Proactive industrial base assessment

▪ Industry participation is essential Exemptions

▪ Support with data (Gov & Industry) to make case ▪ DIB capabilities sustained under certain conditions

Alternative chemicals/materials or methods▪ Tradeoffs

Risk acceptance Develop organic industrial capability

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Page 9: Assessing the impacts of Amended Toxic Substances Control ... · Technical Lead, Industrial Base Assessment DCMA Industrial Analysis Group NDIA Systems Engineering 23-26 Oct 2017

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Pilot Assessment Results

OBJECTIVES

SELECT FINDINGS CONCLUSIONS

POPULATION

Investigate NMP and MeCl chemical form, DoD purchase quantity, DoD customers, and end users

Determine supplier fragility and assess criticality for NMP, MeCl, and alternatives

Evaluate the market impact of the proposed TSCA regulation Project the market effect of a national security exemption

Air Force is dominant user of MeCl; Air Force and Navy top users of NMP Most common purchase form is a mixture containing MeCl or NMP At least 17 MDAPS supported; aviation heavy Common defense applications: paint removal, cleaning, coating reapplication Market impact if TSCA restrictions are put in place:

▪ Some indicated they’d be out of business (incl. dominant DoD source)▪ DoD sales are insufficient to maintain overall business▪ Some indicated they would exit market (incl. dominant DoD source)▪ Others (perhaps more diversified) indicated minimal to no impact

Industry participation was poor DoD demand is minimal compared to overall NMP/MeCl production Current industrial capability risk is LOW (there are many active suppliers) Alternatives exist, but are less effective and Services are hesitant to adopt.

Recommend Joint, comprehensive trade-off assessment TSCA regulation likely to result in market correction and immediate DoD

impacts; formation of defense unique niche market dependent on foreign market viability

National security exemption might not prevent market collapse in this situation due to commercial demand dominance

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suppliers surveyed 61

Page 10: Assessing the impacts of Amended Toxic Substances Control ... · Technical Lead, Industrial Base Assessment DCMA Industrial Analysis Group NDIA Systems Engineering 23-26 Oct 2017

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Degrees of Potential Market Collapse Due to Regulation

Defense Unique Niche Market DoD demand is small fraction of commercial demand Exemption is in place to allow U.S. defense uses of chemical Foreign markets are not profitableIMPACT: Major supplier market correction. Capabilities will be sustained by Government investment. Limited number of suppliers (IB risk).

Defense Unique Niche Market Stabilized by Foreign Demand DoD demand is small fraction of commercial demand Exemption is in place to allow U.S. defense uses of chemical Foreign markets have less regulation and remain profitableIMPACT: Supplier market correction, but capabilities will remain. May see off-shoring of industrial capabilities.

Market Collapse DoD demand and Government investment is not incentive enough Domestic and Foreign markets are not profitableIMPACT: Capability loss (operational risk)

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Page 11: Assessing the impacts of Amended Toxic Substances Control ... · Technical Lead, Industrial Base Assessment DCMA Industrial Analysis Group NDIA Systems Engineering 23-26 Oct 2017

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When Is a National Security Exemption Effective?

Potential Conditions for Stabilizing Industrial Capability Using an Exemption:

Criticality Minimum Sustainment Rate (MSR) Product diversity Defense vs. commercial demand distribution Competition Foreign market viability Timeline Alternative solution

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Page 12: Assessing the impacts of Amended Toxic Substances Control ... · Technical Lead, Industrial Base Assessment DCMA Industrial Analysis Group NDIA Systems Engineering 23-26 Oct 2017

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Systems Engineering

Thank You

UNCLASSIFIED

UNCLASSIFIED