B.  Limitation to Not More Than 0.1 Percent Hexavalent Chromium

Comment: One respondent indicated that their products are already compliant with the prohibition on hexavalent chromium in the European Union Restriction of Hazardous Substances Directive. The respondent further noted that trace amounts of hexavalent chromium remain in the products but are well below the 0.1% threshold noted in the rule.

DoD Response: No change in the rule is necessary to address this comment. The decision to allow trace amounts of hexavalent chromium of less than 0.1 percent is consistent with worldwide standards, including Europe's Restriction of Hazardous Substances; thus these products will also be compliant with the this rule.

Comment: One respondent noted that the proposal does not reference any background or guidance document for testing for hexavalent chromium percent by weight.

DoD Response: There are a number of test procedures that could be used for testing for hexavalent chromium and the choice is dependent on the material being tested. Listing test methods is beyond the scope of the rule. Providers will have flexibility to choose the test method best suited to their application. International standard IEC 62321 "Determination of levels of six regulated substances (lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyls, polybrominated diphenyl ethers) is the most widely used and was finalized in May 2009. ISO Standard 3613 for metallic and organic coatings was updated in November 2010 and is also widely used.