II.  Analysis of Public Comments

Eleven respondents submitted comments on the proposed rule. A discussion of those comments and the revisions made to the rule as a result of those comments is provided below. The comments are organized and presented in ten overall categories. Some comments did not pertain to the DFARS rule itself; however, they are addressed to assist in further clarifying the rule. Six of the eleven respondents supported the objective of minimizing the use of hexavalent chromium or indicated that they were already compliant. The remaining five respondents did not express support or object to the rule, but provided implications and examples of actions that will be required to minimize hexavalent chromium in deliverables. Three respondents questioned the need for the rule since DoD and industry have been working for years to develop substitutes. Despite reservations about the need for the rule, these respondents provided recommendations for improving the rule. A number of the most significant recommendations have been incorporated in the revised rule as discussed in more detail below.

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