HAZMAT Management Program Plan

105
Final Installation HAZMAT Management Program Plan Prepared for Wright-Patterson Air Force Base 88 Air Base Wing Environmental Management Division July 2006 Dayton, Ohio

Transcript of HAZMAT Management Program Plan

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F i n a l

Installation HAZMAT Management Program Plan

Prepared for

Wright-Patterson Air Force Base 88 Air Base Wing

Environmental Management Division

July 2006

Dayton, Ohio

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Contents

Abbreviations......................................................................................................................................v

1 Introduction ............................................................................................................................1-1 1.1 Regulatory Drivers .......................................................................................................1-1 1.2 Program Management..................................................................................................1-2

1.2.1 Base Organizations ..........................................................................................1-3 1.2.2 Contractors........................................................................................................1-4 1.2.3 Air Force Research Laboratories....................................................................1-4

2 Responsibilities .....................................................................................................................2-1 2.1 Commander, 88 Air Base Wing (88 ABW/CC) ........................................................2-1 2.2 Environmental Safety and Occupational Health Council (ESOHC)......................2-2 2.3 Hazardous Substance Steering Committee (HSSC) .................................................2-2 2.4 Hazardous Material Management Process (HMMP) Team....................................2-2 2.5 88 ABW/CEV—Environmental Management Division..........................................2-3 2.6 Hazmat Cell ...................................................................................................................2-4 2.7 88 ABW/CEF—Fire Department................................................................................2-5 2.8 88AMDS/SGPB—Bioenvironmental Engineering...................................................2-6 2.9 88 ABW/SE—Safety .....................................................................................................2-7 2.10 88 MSG/LGR—Logistics Readiness Division...........................................................2-7 2.11 88 ABW/JA—Legal ......................................................................................................2-8 2.12 88 CONS/PKC—Contracting Office..........................................................................2-8 2.13 88 CG—Communications Group................................................................................2-9 2.14 88 ABW/SFS—Security Forces Division ...................................................................2-9 2.15 Unit Environmental Coordinators (UECs) ................................................................2-9 2.16 Issue Point Managers (IPM) ......................................................................................2-10 2.17 Work-Area Supervisors..............................................................................................2-10 2.18 HAZMAT Users ..........................................................................................................2-11

3 Hazcode and Licensing Requirement ................................................................................3-1 3.1 Hazcode A......................................................................................................................3-1 3.2 Hazcode B ......................................................................................................................3-2 3.3 Hazcode C......................................................................................................................3-2 3.4 Hazcode O......................................................................................................................3-3

4 Hazardous Material Management Procedures.................................................................4-1 4.1 Base User ........................................................................................................................4-1

4.1.1 Establishing an Issue Point .............................................................................4-1 4.1.2 Purchasing ........................................................................................................4-3 4.1.3 Tracking.............................................................................................................4-5 4.1.4 Labeling.............................................................................................................4-6 4.1.5 Storage ...............................................................................................................4-6 4.1.6 Shelf-Life Management ...................................................................................4-7 4.1.7 HAZMAT Redistribution ...............................................................................4-7

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4.1.8 Disposal .............................................................................................................4-8 4.1.9 Personnel and PEGs.........................................................................................4-8

4.2 Sponsored Organizations.............................................................................................4-8 4.2.1 Reporting Use for Sponsored Organizations ...............................................4-9 4.2.2 Labeling and Storage of Hazardous Materials ............................................4-9 4.2.3 Empty Containers and Excess Materials ......................................................4-9

4.3 Transient Aircraft..........................................................................................................4-9 5 Ozone-Depleting Substance Procurement........................................................................5-1

5.1 Responsibilities..............................................................................................................5-1 5.1.1 HMMP Team ....................................................................................................5-1 5.1.2 Civil Engineering UEC (88 ABW/CEML)....................................................5-1 5.1.3 Civil Engineering UEC....................................................................................5-2 5.1.4 Weapon Systems Maintenance ......................................................................5-2 5.1.5 HAZMAT Cell..................................................................................................5-3 5.1.6 Work Area Supervisor.....................................................................................5-3 5.1.7 SE........................................................................................................................5-3 5.1.8 Contracting Office............................................................................................5-3

5.2 Class I ODS ....................................................................................................................5-4 5.3 Class II ODS...................................................................................................................5-5 5.4 ODS Purchases ..............................................................................................................5-6

5.4.1 Class I ODS .......................................................................................................5-6 5.4.2 Class II ODS......................................................................................................5-6

6 Unit Deployment ...................................................................................................................6-1 6.1 HAZMAT Purchasing, Tracking, and Storage .........................................................6-1 6.2 Plans and Procedures ...................................................................................................6-1 6.3 Pre-Deployment Requirements...................................................................................6-1 6.4 Deployment Requirements..........................................................................................6-1 6.5 Re-Deployment Requirements....................................................................................6-1

7 Contractor HAZMAT Management Requirements ........................................................... 1 7.1 Exempt Contractors ......................................................................................................... 1

7.1.1 Clean Air Act Section 112(r)—Risk Management Program.......................... 2 7.1.2 Inventory and SSSP ............................................................................................ 2 7.1.3 Container Labeling ............................................................................................. 2 7.1.4 Material Storage and Use................................................................................... 2 7.1.5 Spill Control and Reporting .............................................................................. 3 7.1.6 Removal or Disposal of Unused Materials...................................................... 3 7.1.7 Security/Management/Liability ...................................................................... 4

7.2 Non-Exempt Contractors................................................................................................ 4 7.2.1 Clean Air Act Section 112(r)—Risk Management Program.......................... 4 7.2.2 Management Requirements .............................................................................. 4

8 Training ...................................................................................................................................8-1 8.1 Introduction ...................................................................................................................8-1 8.2 HAZMAT-Training Requirements.............................................................................8-1

8.2.1 Training Agendas ............................................................................................8-1

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9 Pollution Prevention .............................................................................................................9-1 9.1 Pollution Prevention Opportunity Assessments......................................................9-1 9.2 Green Procurement Program ......................................................................................9-2

9.2.1 Biobased Products............................................................................................9-2 9.2.2 Ozone Depleting Substance Alternatives .....................................................9-3 9.2.3 Substitutes for EPA Priority Chemicals ........................................................9-3

Appendixes

A Guidelines for Chemical Compatibility and Storage of HAZMATs B Form 1465—Installation Hazardous Material Issue Point Storage Permit C Form 1407—Zone/Employee Input D Form 1408—Supervisor/Employee Movement Input E HAZMAT Issue Point Operating Instruction Outline F Suggested Outline for SSSP for the Issue Point G Hazardous Material/Hazardous Waste Out-Processing Record H How EPCRA Exemptions are Determined I Training Requirements and Frequencies Reference Table J Record Requirements AF Form 55

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Abbreviations

ABW Air Base Wing AF Air Force AFFARS Air Force Federal Acquisition Regulation Supplement AFMC Air Force Materiel Command AFOSH Air Force Occupational Safety and Health AFRL Air Force Research Laboratories AFTO Air Force Technical Order

BEE Bioenvironmental Engineering CEF Fire Department CEV Environmental Management Division CG Communications Group CONS/PKC Contracting

DLA Defense Logistics Agency DoD Department of Defense

EPA United States Environmental Protection Agency EPCRA Emergency Planning and Community Right-to-Know Act ESOHC Environmental, Safety, and Occupational Health Council

GCSS Global Combat Support Systems GPC Government-wide Purchase Card GPP Green Procurement Program HAZCOM hazard communication HAZMATs hazardous materials HMMP Hazardous Materials Management Process HMMS Hazardous Materials Management System HSSC Hazardous Substance Steering Committee IHMP Installation HAZMAT Management Program JA Legal

LGR Logistic Readiness Division

MAJCOM Major Command MOA Memorandum of Agreement MOU Memorandum of Understanding MSDS Material Safety Data Sheet

ODS ozone-depleting substance OSHA Occupational Safety and Health Administration

P2 pollution prevention P2OA Pollution Prevention Opportunity Assessment PEG Personnel Exposure Group

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RCRA Resource Conservation and Recovery Act

SAO Senior Acquisition Official SBSS Standard Base Supply System SE Safety SSSP Site Specific Spill Plan

UEC Unit Environmental Coordinator USAF United States Air Force

WPAFB Wright-Patterson Air Force Base WPAFBI Wright-Patterson Air Force Base Instruction WRM war reserve materiel

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SECTION 1

Introduction

The United States Air Force (USAF) and Wright-Patterson Air Force Base (WPAFB) are committed to the proper management of hazardous materials (HAZMATs). WPAFB uses a centralized tracking system to control HAZMAT procurement, receipt, labeling, storage, issue, use, and final disposal. By tracking the HAZMATs, the base is able to meet many regulatory requirements. The data collected within the centralized tracking system is used to:

• Report HAZMAT storage and use to regulatory agencies • Analyze HAZMAT data to execute the Clean Air Act Section 112 (r) Risk Management

Program • Provide HAZMAT usage data to track chemical exposures to base employees • Ensure proper safety and that personal protective equipment are utilized • Minimize HAZMAT and hazardous waste (HW) generation

The objective of this plan is to outline the requirements, responsibilities, and general procedures for managing HAZMATs. It is intended as a WPAFB HAZMAT user’s guide for addressing proper procurement, receipt, labeling, storage, issue, use, and tracking of HAZMATs as well as the redistribution, recycling, or disposal of excess HAZMAT.

1.1 Regulatory Drivers The need for centralized HAZMAT management at WPAFB has arisen in part from a variety of regulatory driving forces established for worker safety and protection of the environment. Department of Defense (DoD), USAF, and WPAFB regulations have been established as uniform methods for addressing many of the overlapping federal requirements. The following is a list of the most pertinent USAF and WPAFB regulations impacting the HAZMAT program:

• AFI 32-7086, Hazardous Material Management

• AFI 64-117, Air Force Government-wide Purchase Card (GPC) Program

• AFI 91-301, Air Force Occupational and Environmental Safety, Fire Protection, and Health Program

• AFOSH STD 48-22, Occupational Exposure to Hazardous Chemicals in Laboratories

• AFOSH STD 91-68, Chemical Safety

• AFOSH STD 91-501, Air Force Consolidated Occupational and Safety Standard

• AFJMAN 23-209, Storing and Handling Hazardous Materials

• WPAFBI 32-7001, Hazardous Waste Management

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• WPAFBI 32-7002, Hazardous Material Management

• AFI 32-7086, Hazardous Material Management provides other applicable regulations including federal and DoD

1.2 Program Management The Hazardous Materials Management Process (HMMP) consists of three programs:

1. Installation HAZMAT Management Program (IHMP)—the program for authorizing, procuring, issuing, and tracking HAZMAT.

2. Ozone-Depleting Substance Program—Program for authorizing, tracking and controlling mission-critical Class I and Class II ODS. The ODS Program requirements are presented throughout the WPAFB IHMP Plan, specifically in Sections 3 to 5.

3. Weapon System Hazardous Materials Program (WSHP)—ASC/ENV (https://www.en.wpafb.af.mil/env/env.asp) is the WPAFB organization responsible for the implementation of this program. Requirements for this program are not addressed in this plan.

The Environmental, Safety, and Occupational Health Council (ESOHC) and the Environmental Management Division (CEV) chartered the Hazardous Substance Steering Committee (HSSC). The HSSC provides an open forum to exchange information and to propose, develop, review, and implement policies and procedures. The HSSC also provides guidance for establishing installation goals and is empowered to make changes to improve the hazardous substances operation on base to maintain compliance. The HSSC consists of Unit Environmental Coordinators (UECs) or their designated alternates and coordinates with the ESOHC and CEV. The WPAFB HMMP Team is a subcommittee within the HSSC that focuses on HAZMAT issues. HMMP Teams are cross-functional teams established at all level (HQ USAF, MAJCOM, and installations) of HAZMAT management. Primary members of the WPAFB HMMP Team include CEV, Bioenvironmental Engineering (BEE), and Safety (SE). Other functional organizations such as the Fire Department (CEF), Communications Group (CG), Legal (JA), Logistic Readiness Division (LGR), Contracting (CONS), and the UECs are also members of the HMMP Team as required.

The WPAFB HMMP Team:

• Provides oversight of the IHMP and ODS Programs.

• Identifies and resolves issues, particularly in policy and resource guidance; cross-feeds smart procedures; evaluates performance; incorporates HAZMAT management initiatives into existing procedures; and validates and prioritizes strategies that support and enhance HAZMAT management.

• Communicates policy goals and objectives and develops efficient HAZMAT management plans.

• Provides the necessary teamwork, oversight, coordination, and cross feed to develop and sustain the Hazardous Materials Management System (HMMS) and associated interfaces.

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• Regularly schedules and holds meetings at least quarterly to address HMMP issues and concerns.

• Implements Data Quality Management (DQM) efforts in accordance with Section 1.5.4 of AFI 32-7086 by requiring semi-annual physical/ electronic data reconciliations by Issue Point Managers, and annual Issue Point inspections by the HAZMAT Cell.

The HAZMAT Cell is a decentralized unit that is located in CEV and receives assistance from SE, BEE, and Logistics Readiness Division (LRS). The HAZMAT Cell is the entity on base that is authorized to issue government-owned HAZMATs. The HAZMAT Cell is responsible for the management of Material Safety Data Sheets (MSDSs), licensing of HAZMATs, and tracking of HAZMATs within the HMMS.

Section 2, Responsibilities, outlines the specific tasks assigned to base organizations.

HAZMAT Users

HAZMAT users on WPAFB are divided into three categories:

• Base Organizations (Base Users, Sponsored Units, and Transient Aircraft)

• Contractors

• Air Force Research Laboratories (AFRL)

1.2.1 Base Organizations Base organizations include all Aeronautical System Center (ASC) and 88 Air Base Wing (ABW) units, as well as tenant organizations permanently assigned to WPAFB. ASC is the host for WPAFB and the 88 ABW is charged with operations and maintenance of facilities located on the installation. A tenant organization is any command outside of ASC that resides on the base. Through host-tenant support agreements, the 88 ABW provides utilities, communications, supplies, transportation, staff assistance, and other services necessary for the tenant organizations to accomplish their individual missions. The host-tenant agreements also require the tenant organizations to comply with the bases operating instructions. The base organizations are sub classified into three groups (Base Users, Sponsored Units, and Transient Aircraft) that are discussed below. Section 4, Hazardous Material Management, details the proper procurement, receipt, labeling, storage, issue, use, and tracking of HAZMATs for these base organizations.

1.2.1.1 Base Users Base Users are defined as base hosts or tenants the purchases Hazcode B and Hazcode C items. The specific HAZMAT management requirements are provided in Section 4.1, Base Users.

1.2.1.2 Sponsored Organizations Sponsored organizations are visiting military units or civilian groups whose activities require the use of HAZMATs. Materials used by these units are not purchased through the WPAFB HAZMT Management Program, but are usually brought by the unit’s home station. HAZMATs brought by these organizations must be tracked through the HAZMAT Cell.

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Section 4.3 of this plan outlines the HAZMAT Management steps for Sponsored Organizations.

1.2.1.3 Transient Aircraft Transient Aircraft Units are units on temporary duty assignment (TDY) or on a layover at WPAFB. Aircraft management by these units are serviced, refueled, and fluids topped-off by Transient Alert (88 MSG/LRGMT). If the aircraft requires maintenance while at WPAFB, maintenance personnel from the aircraft’s home station may be sent to make the repairs or Transient Alert may repair the aircraft. If the maintenance crew is from the aircraft’s home station and they bring HAZMATs with them to WPAFB, they are classified as a Sponsored Organization as defined in Section 1.3.1.3 and must meet the program requirements spelled out in Section 4.3 of this plan. Any HAZMATs brought on the base by Transient Aircraft Units must be managed in accordance with Section 4.4 of this plan.

1.2.2 Contractors Contractors performing work on WPAFB are required to manage their HAZMAT in accordance with this plan. Some contracted activities may be exempt from tracking requirements, but still must meet other HAZMAT management requirements. Guidance for exempt or non-exempt contractors is outlined in Section 7, Contractor HAZMAT Management Requirements.

1.2.3 Air Force Research Laboratories AFRL consists of five directorates located in Area B, WPAFB and three of the directorates utilize the Integrated Materials Management System (IMMS) to track and control HAZMATs. The system uses bar code technology to track the use of HAZMATs, and is geared to the laboratory environment. The AFRL IMMS administrator is required to provide HAZMAT reports as requested by the HAZMAT Cell. AFRL is responsible for compliance with AFI 32-7086 through procedures provided in an AFRL Supplement to this plan. CEV, BEE, and SE; may delegate all or part of the licensing authority to respective AFRL Environmental, Safety, and Occupational Health (ESOH) offices via Memos of Understanding (MOUs). Current (2 years or less) MOUs meet this requirement and will be based on the AFRL supplement, and must be maintained by each respective AFRL ESOH office. AFRL/HE, Human Effectiveness, and AFRL/VA, Air Vehicles, use HMMS and comply with tenant organization requirements of this plan.

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SECTION 2

Responsibilities

Each WPAFB organization is responsible for managing HAZMAT in compliance with federal, state, and local regulations, as well as, Air Force, AFMC, and WPAFB policy. Base compliance with the applicable regulations is the ultimate responsibility of the Installation Commander, through the Environmental Management Division. The following organizations have key responsibilities in ensuring that HAZMAT is properly managed on base.

• 88 ABW/CC—Air Base Wing Commander • Environmental, Safety, and Occupational Health Council (ESOHC) • Hazardous Substance Steering Committee (HSSC) • Hazardous Material Management Process Team (HMMP Team) • 88 ABW/CEV—Environmental Management Division • HAZMAT Cell • 88 ABW/CEF—Fire Department • 74th MG/SGPB—Bioenvironmental Engineering • 88 ABW/SE—Safety • 88 MSG/LGR—Logistics Readiness Division • 88 ABW/JA—Legal • 88 CONS—Contracting Office • 88 CG—Communications Group • 88 ABW/SFS—Security Forces Squadron • Unit Environmental Coordinators (UECs) • Issue Point Managers (IPM) • Work-Area Supervisors • HAZMAT Users.

Note: Definitions for Hazcodes A, B, C, and O are provided in Section 3, Hazcodes and Licensing Requirements.

2.1 Commander, 88 Air Base Wing (88 ABW/CC) 2.1.1 Establishes and implements a program for HAZMAT control and management to include written policies and directives.

2.1.2 Formally charters the ESOHC to establish environmental policies and instructions, disseminate information, and ensure compliance with all federal, state, and local regulations; executive orders; Department of Defense Instructions; and Air Force Instructions.

2.1.3 Assigns the responsibility for the WPAFB HMMP to the Environmental Management Division (88 ABW/CEV).

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2.1.4 Assigns coordinating responsibilities for the WPAFB HMMP to, Fire Department (88 ABW/CEF), Bioenvironmental Engineering Services (74 MG/SGPB), Safety (88 ABW/SE), Communications Squadron (88 CG), Legal (88 ABW/JA), Logistics Readiness Division (88 MSG/LGR), and Contracting (88 CONS).

2.1.5 Ensures that all wing (host) and tenant activities participate in the WPAFB IHMP.

2.1.6 Ensures resource requirements of this plan are addressed and programmed if needed.

2.2 Environmental Safety and Occupational Health Council (ESOHC)

2.2.1 Formally charter a cross-functional HMMP Team led by CEV.

2.2.2 Provide oversight for the HMMP Team.

2.2.3 Ensure that only appropriate aspects of the IHMP responsibilities are considered for contracting-out. If any IHMP functional responsibilities are contracted-out, those responsibilities must remain under the purview of the individual functional offices that this IHMP Plan assigns those responsibilities to, regardless of the extent that the given functional office has been contracted out. NOTE: Any IHMP task, including the HAZMAT authorization responsibilities, can be performed by contractors, provided the following elements are in place. First, the contract complies with applicable federal and military procurement policies and supports IHMP deployment requirements; second, the Air Force exercises appropriate and adequate contractor performance oversight.

2.3 Hazardous Substance Steering Committee (HSSC) 2.3.1 Form a sub-committee, the HMMP Team , which will focus on HAZMAT management.

2.3.2 Disseminates information pertaining to HAZMAT control and management.

2.3.3 Participates in committee decision making relative to HW and HAZMAT control and management.

2.3.4 Meets according to the schedule set forth in the Hazardous Substance Steering Committee Charter unless otherwise directed.

2.3.5 Address and resolves management concerns relative to the HAZMAT Cell and Issue Points operations.

2.4 Hazardous Material Management Process (HMMP) Team 2.4.1 Establish and maintain a management effort to ensure the quality of the installation’s IHMP data.

2.4.2 Provide the necessary teamwork, oversight, coordination, and cross-feed to implement the HMMP, HMMS, and associated interfaces.

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2.4.3 Ensure all functional areas provide resource advocacy in their respective areas for an effective interface between their functional area program and the IHMP.

2.4.4 Review, validate, and advocate for IHMP-related funding requirements.

2.4.5 Integrate IHMP requirements into support agreements as needed in accordance with procedures outlined in AFI 25-201.

2.4.6 Ensure personnel obtain and document applicable IHMP training requirements in accordance with AFOSH, Occupational Safety and Health Administration (OSHA), DOT, and environmental standards, local requirements, and in particular Section 7 of this document to maximize training efficiency. To the maximum extent possible, send people to applicable training at the earliest opportunity once assigned IHMP responsibilities. Once training is completed, retain those individuals in their IHMP related position as long as practicable.

2.4.7 Include guidance for HAZMAT management in contingency deployment plans.

2.4.8 Track funded IHMP projects to completion.

2.4.9 Collect data and report IHMP metrics to senior leadership and their MAJCOM HMMP Team as requested.

2.4.10 Ensure that any contracting initiatives involving any aspect of the IHMP specifically define responsibilities for executing the affected IHMP elements, especially IHMP deployment requirements. Note: Any aspect of the installation IHMP responsibilities, including the HAZMAT authorization responsibilities, can be performed by contractors, provided the following elements are in place. First the contract complies with applicable federal and military procurement policies and supports IHMP deployment requirements; second, the Air Force exercises appropriate and adequate contractor performance oversight.

2.4.11 Ensure that releasable information on IHMP projects or metrics with potential community or media interest are provided to Public Affairs.

2.5 88 ABW/CEV—Environmental Management Division 2.5.1 Lead the HMMP Team and Co-chair the HSSC.

2.5.2 As HMMP Team Lead, CEV oversees the HAZMAT authorization process.

2.5.3 Maintain a written management plan or operating instruction outlining the roles and responsibilities of those involved with hazmat at the installation. Additionally, information on the type of storage to be used will be included.

2.5.4 Ensure HAZMAT facilities meet applicable ESOH requirements to support the IHMP.

2.5.5 Manage the Data Base Administration (DBA)/System Administration (SA)/Information System Security Officer (ISSO) responsibilities for the HMMS.

2.5.5.1 Provide CEV, BEE, SE, and other personnel, as appropriate, with operator training on the HMMS. Allow contractor personnel to attend the Air Force HMMS user training courses.

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2.5.5.2 Submit requested changes for the HMMS to the installation IHMP Team for review and possible validation.

2.5.6 Ensure HAZMAT on the installation is tracked by facility, quantity, and process to support fire protection, ESOH, disaster response, and environmental reporting requirements.

2.5.7 Submit environmental-eligible IHMP funding requirements through the environmental programming/budgeting system. CEV is responsible for providing appropriate funding support for the HAZMAT Cell.

2.5.8 Submit IHMP metric information as required by the MAJCOM HMMP Team.

2.5.9 Manage the HAZMAT Cell.

2.5.9.1 Provide safe and healthful workplaces that comply with environmental requirements.

2.5.9.2 Ensure personnel meet all installation-level responsibilities for executing the IHMP.

2.5.9.3 Work with CEV, BEE, and SE to ensure HAZMAT facilities meet applicable ESOH requirements.

2.5.9.4 Ensure the HAZMAT Cell performs all assigned responsibilities.

2.5.9.5 Ensure the training of HAZMAT Cell personnel on the operation of the HMMS.

2.5.9.6 Ensure all HAZMAT Cell personnel receive occupational safety and health training appropriate for their HAZMAT-related duties.

2.5.9.7 Plan, program, and budget for all necessary HAZMAT Cell resources (personnel, equipment, and funding).

2.5.9.8 Submit requested changes for the HMMS to the installation HMMP Team for review and possible validation.

2.5.9.9 Provide inputs on appropriate HAZMAT requirements to the Contracting Office for inclusion in the contract Quality Assurance Surveillance Plans and the contract Quality Assurance Personnel training.

2.6 Hazmat Cell The HAZMAT Cell is a decentralized unit comprised of CEV, SE, BEE, and LRS, and is managed within CEV. It is the entity on base that is authorized to issue government-owned HAZMATs.

2.6.1 CEV, BEE and SE, determine for each requested potentially hazardous material whether it meets the HAZMAT definitions (Hazcode A, B, C, or O) and, therefore, if it must be tracked using the HMMS.

2.6.2 Assess, at a minimum, environmental, fire protection, and emergency response risks of, and control options for, materials.

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2.6.2.1 Decide whether blanket (Hazcode B) or process-specific license (Hazcodes C and O) is appropriate for material that the HMMP Team determines meets the definition of a HAZMAT.

2.6.2.2 For process-specific licenses (Hazcodes C and O), evaluate each electronic authorization request. CEV reviews for Clean Air Act sect. 112 (r) Risk Management Process (RMP) requirements if applicable. Decide whether to authorize without additional restrictions, authorize with additional restrictions or not authorize the request to use a HAZMAT.

2.6.2.3 Develop and execute procedures to ensure hazardous materials brought onto the installation by all contractors are properly managed in accordance with WPAFBI 32-7002.

2.6.2.4 Establish, document, and implement a schedule for and procedures to review and revalidate each electronic authorization request. The objective of this is to review process changes, demand history, technology changes, and requirements changes that could impact the validity of a license.

2.6.3 Function as the Office of Primary Responsibility (OPR) for installation MSDS management and for transferring MSDSs to the approved automated MSDS repository.

2.6.4 Provide installation responses to HAZMAT data calls for the HMMS system.

2.6.5 Determine and document the procedures for effective tracking of HAZMAT from cradle to grave, for facilitating work center inspections for unauthorized HAZMAT, and for supporting the free-issue of unused HAZMAT.

2.6.6 Establish and implement procedures for HAZMAT reduction, recycling, reuse, or shelf-life control, in order to minimize the generation of HW. This includes reducing HAZMAT disposal through reduction, recycling, reuse, shelf-life control, etc.

2.6.7 Review the installation Self-Help program to ensure that the IHMP tracks and reports HAZMAT issued through the self-help store. Self-help customers do not require a license to use a HAZMAT on self-help projects, unless that HAZMAT requires a process-specific license.

2.6.8 Review and assess the validity of changes to the HMMS requested by installation personnel and forward validated change requests to the MAJCOM HMMP Team.

2.6.9 Assess customer satisfaction periodically (e.g., spot-check the time required to process electronic authorization requests), and make improvements whenever possible.

2.6.10 Support the development and implementation of HAZMAT transportation security plans and training.

2.7 88 ABW/CEF—Fire Department 2.7.1 Provide HMMP Team and HSSC participation as requested. The team member will be designated by the unit commander, in writing, to CEV.

2.7.2 Coordinate on HAZMAT authorizations as requested by the HAZMAT Cell.

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2.7.3 Perform annual facility inspections at each Issue Point location and associated HAZMAT storage areas to ensure HAZMAT storage is in compliance with all OSHA, Fire Department and National Fire Protection Association regulations.

2.7.4 Identifies un-barcoded or unlabeled HAZMAT to the HAZMAT Cell.

2.7.5 Coordinates on WPAFB form 1465, “Installation Hazardous Material Issue Point Permit.”

2.8 88AMDS/SGPB—Bioenvironmental Engineering 2.8.1 Provide HMMP Team and HSSC participation. The team member will be designated by the unit commander, in writing, to CEV.

2.8.2 Use HMMS for tracking, reporting, and BEE authorization purposes.

2.8.3 Ensure appropriate BEE personnel receive operator training on HMMS.

2.8.4 Participate in the HAZMAT Cell evaluation of materials that are potentially hazardous, but are not loaded in HMMS.

2.8.4.1 Decide whether BEE blanket (Hazcode B) or process-specific license (Hazcodes C and O) is appropriate for material that the HMMP Team determines meets the definition of a HAZMAT.

2.8.4.2 Maintain and update the pre-approved Hazcode A and Hazcode B lists as the Hazcodes are assigned.

2.8.5 For process-specific licenses (Hazcodes C and O), evaluate each electronic authorization request. BEE evaluations will include a review of HAZMAT-related work area surveys, and will identify conditions of use for HAZMAT. Decide whether to authorize without additional restriction, authorize with additional restrictions, or not authorize the request to use a HAZMAT.

2.8.6 Review electronic authorization requests submitted by contractors. This review of contractor electronic authorization requests does not involve evaluation and approval of the contractor’s safety and health programs. The purpose of this review is to at a minimum identify potential health risks to non-contractor personnel and resources and to advise CEV and the Contracting Office on how to mitigate identified hazards from planned contractor HAZMAT usage.

2.8.7 Ensure BEE maintains and updates BEE-related HAZMAT data fields in HMMS as required in user’s manual or online help.

2.8.8 Ensure BEE reviews HMMS data to help define requirements for BEE process evaluations.

2.8.9 Function as the OPR for developing and maintaining the workplace process list.

2.8.10 Ensure the incorporation of medical logistics HAZMAT data into HMMS.

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2.9 88 ABW/SE—Safety 2.9.1 Provide HMMP Team and HSSC participation. The team member will be designated by the unit commander, in writing, to CEV.

2.9.2 Use HMMS for tracking and authorization purposes.

2.9.3 Ensure appropriate SE personnel receive operator training on HMMS.

2.9.4 Participate in the HAZMAT Cell evaluation of materials that are potentially hazardous, but are not loaded in HMMS.

2.9.5 Decide whether SE blanket (Hazcode B) or process-specific license (Hazcodes C and O) is appropriate for material that the HMMP Team determines meets the definition of a HAZMAT.

2.9.6 For process-specific (Hazcodes C and O) licenses, evaluate each electronic authorization request. SE will use HAZMAT-related information from prior work area safety surveys in the electronic authorization review. SE will identify conditions of HAZMAT use, and worker occupational safety training requirements that must be completed prior to HAZMAT use. SE will also determine whether or not the process under review will require occupational safety analysis according to Air Force Occupational Safety and Health (AFOSH) Standard 91-119, Process Safety Management (PSM) of Highly Hazardous Chemicals. Decide whether to authorize without additional restrictions, authorize with additional restrictions, or not authorize the request to use a HAZMAT.

2.9.7 Review electronic authorization requests submitted by contractors. This review of contractor electronic authorization requests does not involve evaluation and approval of the contractor’s safety and health programs. The purpose of this review is to at a minimum identify potential health risks to non-contractor personnel and resources and to advise CEV and the Contracting Office on how to mitigate identified hazards from planned contractor HAZMAT usage.

2.9.8 Maintain and update SE-related HAZMAT data fields in HMMS as required in user’s manual or on-line help.

2.9.9 Advise HAZMAT storage facilities on compliance with all applicable OSHA, AFOSH, and local standards.

2.10 88 MSG/LGR—Logistics Readiness Division 2.10.1 Provide HMMP Team participation as requested. The team member will be designated by the unit commander, in writing, to CEV.

2.10.2 Designate the HMMP Team personnel who will:

2.10.3 Maintain and update the HAZMAT-specific fields in the SBSS [e.g., IEX Code 9 and requisition exception (REX) codes].

2.10.4 Conduct data queries as directed by the installation HAZMAT Cell.

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2.10.5 Development and implementation of HAZMAT transportation security plans and training. The plans and training will be in accordance with the DoD 4500.9R, DTR. Coordinate with the installation Force Protection Working Group and the HMMP Team to establish a HAZMAT security plan and training in accordance with the DoD 4500.9R, DTR.

2.11 88 ABW/JA—Legal 2.11.1 Participates as a member of the HSSC and HMMP Teams as needed.

2.12 88 CONS/PKC—Contracting Office 2.12.1 Participate as a member of the HSSC and HMMP Teams as requested. The team member will be designated by the unit commander, in writing, to CEV.

2.12.2 Include Federal Acquisition Regulation (FAR) Clause 52.223-3, Air Force Federal Acquisition Regulation Supplement (AFFARS) Clause 5352.223-9003, and installation-specific contract requirements in each contract/task/delivery order vehicle [contract, purchase order, blanket purchase agreement (BPA), etc.] in which processes require the use and/or distribution of HAZMAT on an installation.

2.12.3 Obtain guidance on contractor HAZMAT determination, authorization requests, and tracking from the HAZMAT Cell as required by the WPAFB Contractor Hazmat Program for Contractors, in support of contractor compliance with FAR Clause 52.223-3 and AFFARS Clause 5352.223-9003.

2.12.4 Before contract closeout, contact the HAZMAT Cell and the contract Quality Assurance Personnel to ensure the contractor has fulfilled all contract HAZMAT requirements.

2.12.5 Ensure that any contracting initiatives involving any aspect of the IHMP specifically define responsibilities for executing the affected IHMP elements in accordance with WPAFBI 32-7002, AFI 32-7086, and any associated MAJCOM supplements.

2.12.6 Any aspect of the installation IHMP responsibilities, including the HAZMAT authorization responsibilities, can be performed by contractors, provided the contract complies with applicable federal and military procurement policies, and supports IHMP deployment requirements.

2.12.7 Implement contract vehicles as needed to support the HAZMAT Cell.

2.12.8 Ensure that the requirements in WPAFBI 32-7002 for GPC purchases of HAZMAT are included in local GPC guidance and training. Ensure HMMP Team members participate in GPC training sessions to address these requirements.

2.12.9 Ensure that contract Quality Assurance Surveillance Plans include appropriate HAZMAT requirements, and that contract Quality Assurance Personnel training includes the local IHMP contractor procedures.

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2.13 88 CG—Communications Group 2.13.1 Participate in the HMMP Team as necessary. The team member will be designated by the unit commander, in writing, to CEV.

2.13.2 Validate HAZMAT communications and information requirements, in compliance with the Global Combat Support Systems (GCSS)-AF strategy and the Command, Control, Communications, Computers, and Intelligence (C4I) Support Plan.

2.13.3 According to Air Force 33-series publications, provide assistance to HMMS administrators in the performance of their DBA, SA, and ISSO duties.

2.13.4 Provide Local Area Network (LAN) support and access, as required for full functionality of HMMS.

2.14 88 ABW/SFS—Security Forces Division 2.14.1 SFS will support the LRS in the development and implementation of HAZMAT transportation security plans and training in accordance with paragraph 2.7 of AFI 32-7086.

2.15 Unit Environmental Coordinators (UECs) 2.15.1 Provide HSSC participation, and HMMP participation as requested.

2.15.2 Evaluate electronic authorizations to ensure the request for HAZMAT is properly justified. If the material is directed by technical order (TO), ensure the least hazardous directed material is being requested, and that the TO information is properly entered on the form.

2.15.3 Advise the work-area supervisor on any ESOH concerns resulting from an electronic authorization request that may have installation regulatory impacts, such as the use of a material that could cause a permit violation.

2.15.4 Manage their unit hazardous material program, working closely with CEV, BEE, and Safety offices and with the unit Safety and Operational Risk Management representatives.

2.15.5 Monitor the unit’s use of HAZMAT including sustainment of data requirements within the Air Force approved hazardous material tracking system(s).

2.15.6 Emphasize hazardous material/environmental guidance to unit supply/material acquisition managers and supervisors.

2.15.7 Review any unit-proposed HAZMAT process change or product substitutions to ensure that all changes have been properly reviewed and approved. [Only the Single Manager (SM) that controls a TO may make a change to the processes or HAZMAT requirements identified in the TO].

2.15.8 Review and coordinate with applicable offices on all unit HAZMAT-related inputs to base environmental plans or ESOH program requirements.

2.15.9 Serve as the unit focal point for HAZMAT environmental compliance.

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2.15.10 Support ESOH inspections such as Environmental Compliance Assessment and Management Program (ECAMP)/ESOHCAMP assessments.

2.16 Issue Point Managers (IPM) 2.16.1 Attend IPM Meetings as requested by the HAZMAT Cell.

2.16.2 Utilize HMMS to track and control all HAZMATs used within work areas assigned to their organization to include receiving, issuing, turn-in, transfer, and disposal of all HAZMAT utilized within their area of responsibility.

2.16.3 Request only the amounts of HAZMATs required by a process and apply pollution prevention techniques to eliminate/reduce the use of HAZMATS or to substitute a less hazardous or non-hazardous chemical.

2.16.4 Maintain continuity folders that contain the Site Specific Issue Point Operating Instruction, inventory reconciliations reports, zones and employees, HAZMAT licenses, MSDSs, miscellaneous.

2.16.5 Ensures all HAZMATs stored and used within their organization, regardless of the acquisition mode, are properly labeled and entered into HMMS for material tracking. Including HAZMATs purchased under “Black Program Contracts.”

2.16.6 Conduct a physical inventory two times a year in March and September of all HAZMATs associated with the respective Issue Points. The inventory will include HAZMATs with the “in use” status. The physical HAZMAT items, their status as “new materials” or “in use”, and their storage location must correlate with HMMS. If discrepancies exist, proper corrective actions will be initiated to resolve the problems.

2.16.7 Enforces all applicable OSHA, Hazard Communication (HAZCOM), storage and handling requirements for all HAZMAT stored within area of responsibilities.

2.16.8 Ensures MSDSs (manufacturers less than 5 years old) for all HAZMATs used are within their area of responsibility are maintained and/or readily accessible to the Work-Area Supervisor and employees who utilize HAZMAT.

2.17 Work-Area Supervisors 2.17.1 Comply with the IHMP.

2.17.2 Participate in HSSC/HMMP Team meetings, as required or to voice specific issues/concerns.

2.17.3 Provide safe and healthful workplaces that comply with environmental requirements.

2.17.4 Enforces all applicable OSHA, HAZCOM, storage and handling requirements for all HAZMAT stored within area of responsibilities.

2.17.5 Use electronic requests to submit HAZMAT requirements to the HAZMAT Cell prior to obtaining the required HAZMAT from any source.

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2.17.6 Provide additional information to authorizing offices as requested to complete electronic authorization requests (such as application methods, transfer methods, etc.).

2.17.7 Comply with all conditions of use identified on approved licenses.

2.17.8 Immediately notify the HAZMAT Cell of any changes to the conditions or processes as described on an approved electronic license. Note: Any change to the requiring document, procedures, HAZMAT, draw amount or draw frequency described on an approved electronic license invalidates the license.

2.17.9 Procure all HAZMAT using the process defined by base purchase guidance, regardless of payment method [e.g., Standard Base Supply System (SBSS); GPC; AF Form 9, Request for Purchase].

2.17.10 Provide work area personnel appropriate HAZMAT training (to include HAZCOM training). Document all appropriate training on AF Form 55, Employee Safety and Health Record, or similar training documentation form.

2.17.11 Ensure compliance with Air Force Technical Order (AFTO) requirements for use of HAZMAT until formally notified of a TO change to the requirements. Submit requests to eliminate a HAZMAT TO requirement on an AFTO Form 22, Technical Manual Change Recommendation and Reply, to the SM that controls the TO.

2.17.12 Maintain a list of typical HAZMATs within the work area with the SSSP and ensure that all HAZMAT containers have appropriate labeling.

2.17.13 Request only the amounts of HAZMATs required by a process and apply pollution prevention techniques to eliminate/reduce the use of HAZMATS or to substitute a less hazardous or non-hazardous chemical.

2.17.14 Maintain only minimal quantities of HAZMAT in the work area and turn in excess HAZMAT as soon as possible for reuse, redistribution, or proper disposal. Supervisors must avoid storing excess or expired products at the job site or in the work area.

2.17.15 Ensure, for those contracts for which the supervisor is responsible, that Quality Inspector and Quality Assurance Evaluation tasks involving HAZMAT licensing, reporting, and closeout of sites are taking place properly.

2.17.16 Certify on electronic authorization requests that the HAZMAT is required for use in the work area process described in the electronic authorization request and in accordance with the requiring document specified in the electronic authorization, in order to validate the requirement and to ensure the appropriate workers have the proper training and equipment to safely use the requested HAZMAT in the process identified in the electronic license.

2.18 HAZMAT Users 2.18.1 Follow and adhere to all WPAFB policies and procedures regarding HAZMATs and enforces all applicable OSHA, HAZCOM, storage and handling requirements for all HAZMAT stored within area of responsibilities.

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2.18.2 Process all new HAZMAT request through the HAZMAT Cell.

2.18.3 Request only the amounts of HAZMATs required by a process and apply pollution prevention techniques to eliminate/reduce the use of HAZMATS or to substitute a less hazardous or non-hazardous chemical.

2.18.4 Work with the Issue Point Manager to track the use of HAZMATs and return all empty containers or the yellow barcode label to the Issue Point Manager for disposal and clearance from the HAZMAT tracking system.

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Hazcode and Licensing Requirement

AFI 32-7086 defines HAZMATs as follows:

HAZMATs includes all items (including medical supply items with the exemption of drugs in their finished form and pharmaceuticals in individually-issued items) covered under the EPCRA [Emergency Planning and Community Right-to-Know Act] (or other host nation, federal, state, or local) reporting requirements, the OSHA Hazard Communication (HAZCOM) Standard, and all Class I and Class II Ozone Depleting Substances. It does not include munitions.

This WPAFB IHMP further divides HAZMATs into four categories (Hazcodes A, B, C, and O) to streamline licensing, purchasing, and tracking requirements. The information in this section defines the general guidelines that the HAZMAT Cell used to assign Hazcodes A, B, C, and O. This information can assist HAZMAT users in selecting the least-hazardous materials possible. Prior to reviewing the following sections, it should be noted that many factors such as physical state, exposure levels, and planned use can effect the Hazcode designation.

It should be noted that this classification system is replacing the Hazcode H and N system. Hazcode H items are considered hazardous would include the items now defined as Hazcodes A, B, C, and O. Hazcode N is used to classify non-hazardous items. Since the implementation of the new classification system will be performed over time as purchases are made, items in the current inventories will continue to be labeled as Hazcodes H and N.

3.1 Hazcode A A Hazcode A material is that having hazardous properties or presenting potential disposal concerns but not considered a significant threat to human health or the environment. Hazcode A materials are not tracked in HMMS but require evaluation prior to disposal. Hazcode A materials are defined in AFI 32-7086:

Any consumer product or hazardous substance, as those defined in the Consumer Safety Act (Title 15, United States Code, Chapter 47, Section 2051, et seq.) and Federal Hazardous Substance Act (Title 15, United States Code, Chapter 30, Section 1261, et seq.) respectively, where the employer can show that it is used in the workplace for the purpose intended by the chemical manufacturer or importer of the product, and the use in a duration and frequency of exposure which is not greater than the range of exposures that could reasonable be experienced by consumers when used for the purpose intended.

A Hazcode A materials list is available through the CEV website or on the BEE website. Materials on this list are pre-approved to be purchased outside of the HAZMAT-tracking system as long as they are used for consumer purposes as defined in this subsection and are disposed of properly.

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3.2 Hazcode B A Hazcode B material is a HAZMAT tracked within HMMS but that has been given blanket license as defined by AFI 32-7086:

The blanket authorization approves the use of particular units of issue of a HAZMAT independent of process. Each electronic license authorizing offices (CEV, SE and BEE) will make an independent determination of whether or not to provide a blanket authorization for a specific HAZMAT and HAZMAT container size. Each of the offices providing a blanket authorization must also specify a maximum draw amount for the HAZMAT and HAZMAT container size. Blanket authorizations must identify by specific HMMS assigned MSDS numbers. In addition, users must stay within the maximum draw amounts specified on their electronic license for the blanket authorization to remain valid. It is not necessary for all three (CE, SE, and BE) licenses to be of the same type (blanket or activity specific). However, all three offices must authorize (or review for contractor submittals) the request before the requestor can obtain the HAZMAT.

A Hazcode B materials list is available through the CEV website or on the BEE website. Materials on this list are preapproved to be purchased without a license but with the following conditions:

• The quantity maintained in stock must be equal to or less than that specified in the blanket authorization.

• The HAZMAT can be used only in processes defined in the blanket authorization.

• The HAZMAT must be entered into the HAZMAT-tracking system and labeled, stored, and disposed of as defined by this plan.

3.3 Hazcode C A Hazcode C material includes any material that (1) contains a chemical—regardless of the amount—that is defined by OSHA in 29 CFR 1910 Subpart Z or (2) whose constituents are greater than 1 percent by volume of any chemical classified as a carcinogen, teratagen, or mutagen.

An authorization request for a license must be obtained from the HAZMAT Cell prior to a Hazcode C material’s purchase. The license will be specific to the work zone where the material will be used, and the duration of the license will be based on the hazardous nature of the material requested, the process in which the HAZMAT will be used, the potential exposure of employees to the HAZMAT in a specified process, and the duration of the process (a one-time event or a daily task). The license issued will be either C1, C3, or C5 and will be valid for 1, 3, or 5 years, respectively. The length of the license will depend on toxicity or hazards associated with the HAZMAT. Most licenses will be approved for a period 5 years; only HAZMATs that are significantly dangerous to users will be licensed for shorter periods. This will allow BEE to ensure that chemical exposures to employees from these types of HAZMATs are closely monitored. Guidance for submitting a Hazcode C authorization request for a license is provided on the CEV website.

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3.4 Hazcode O A Hazcode O material is any material that contains a Class I or Class II ODS. A list of Class I and Class II ODS are provided Section 5. Class I ODSs, whose production ended on December 31, 1995, can be obtained only for mission critical processes through Air Staff. Class II ODSs authorization requests must be submitted through the HAZMAT Cell and a license obtained prior to being purchased. The licenses will be issued as O-I or O-II and will be valid for 1 year. Guidance for obtaining Hazcode O licenses is provided in Section 5.

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Hazardous Material Management Procedures

This section of the IHMP Plan outlines the basic HAZMAT management procedures that are required to comply with AFI 32-7086 and WPAFBI 32-7002. These procedures are applicable to all WPAFB organizations using HMMS.

HAZMATs are managed in the web-based HMMS. Authorization/licensing, purchases, tracking, and the generation of yellow barcode labels must be handled through the system. Training modules are available on the HMMS. If additional help is needed, the HAZMAT Cell can be contacted for assistance. The remainder of this section delineates the procedures for purchasing, receiving, labeling, storing, and disposing of.

4.1 Base User Base Users are responsible for the data entry for authorizations requests and purchase requests, data tracking in the HMMS, and label printing. These organizations are also required to develop a Site Specific OI.

4.1.1 Establishing an Issue Point Establishing an Issue Point is essential for the proper control and management of HAZMAT. The following steps should be taken to initiate an Issue Point. Some of these steps can be coordinated at the same time; others will need to be performed in sequence.

• Select the Issue Point location(s) with the greatest possible accessibility to the HAZMAT users. The location(s) should also meet HAZMAT storage requirements or be easily converted to meet the requirements. These areas should be ventilated and have secondary containment systems, cabinets, etc. The WPAFB Guidelines for Chemical Compatibility and Storage of HAZMATs (Appendix A) should be reviewed.

• Procure the appropriate equipment (fire extinguishers, spill kit, personal protective equipment, etc.) for the storage area(s).

• Complete WPAFB Form 1465, “Installation Hazardous Material Issue Point Storage Permit” (Appendix B). An inspection of the facility will be performed by the HAZMAT Cell, BEE, SE, and FD. Upon completion of the inspection, the HAZMAT Cell will assign the Issue Point a number and enter it into the HMMS.

• Work with BEE to set up zones to the work areas and assign personnel to those zones. WPAFB Form 1407, “Zone/Employee Input” (Appendix C), should be used to inform BEE of the new Issue Point designation. WPAFB Form 1408, “Supervisor/Employee Movement Input” (Appendix D), should be used to assign personnel to the new Issue Point.

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• Initially provide access for key people in the organization in the HMMS. Other personnel can be trained at a later date. The HAZMAT Cell will need the following information for each system user:

− Name (First, Middle Initial, and Last) − Phone number − Fax number if available − Organization − E-mail − Position (User, Issue Point Manager, UEC, Purchase Card Holder, Supervisor, or

combination of positions)

• The HAZMAT Cell will provide training on an individual basis for key personnel. Key personnel will then be responsible for training other personnel within their organization.

• Prepare Site-Specific Issue Point Operating Instructions detailing day-to-day HAZMAT management procedures and identifying the Issue Point personnel. The WPAFB HAZMAT Issue Point Operating Instructions outline (Appendix E) is recommended for the Operating Instructions and lists the minimum requirements that must be met for the development of a successful Issue Point operation. The outline is only a suggested format; however, any Operating Instructions developed must meet all of the requirements of the outline. The UEC and Issue Point Manager will review and update the Operating Instructions annually.

• Prepare an SSSP for the Issue Point. A suggested outline is provided in Appendix F.

• Maintain in each storage area a chronological record in a Continuity Binder that will contain the following:

− Site-specific Issue Point Operating Instructions − Manufacturers’ MSDSs − Physical inventory prepared in March and September − Licenses − Zones and employees − Denial listings − Shelf life extension data − Miscellaneous

Expired or excess HAZMAT that will not be used should be turned in for reuse or disposal. Reuse includes using the material for another purpose in-house, transferring materials to another organization on base (free issue), or to an outside agency (federal, state, privately owned, or a non-profit charity). The HAZMAT Cell uses an e-mail to assist with finding other potential users on base through its Excess Material Program. If a reuse option cannot be found, the CEV HAZWASTE website provides the necessary steps for turning in the materials.

• Inventory the HAZMATs and collect their corresponding MSDSs. The MSDSs should be manufacturer-generated and no older than 5 years or the latest version possible.

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• Access the HMMS to determine if the MSDSs are in the system and up to date. If the MSDSs are not in the system, the MSDSs should be e-mailed, faxed, or mailed to the HAZMAT Cell MSDS Entry/Customer Support. If the MSDS is faxed, a hard copy should be mailed at a later date.

• Once the MSDSs have been entered into the HMMS, the HAZMAT should be authorized, labeled, tracked, and stored in accordance with the remainder of this section.

4.1.2 Purchasing These are four methods by which to obtain HAZMATs at WPAFB:

• Government Purchase Cards (GPCs) • Standard base supply • Form 9 • ODS

Regardless of the method used to procure HAZMATs, the purchaser must verify that the MSDSs in HMMS are manufacturer-generated and no older than 5 years or the latest versions possible and that they have a current license in the system. The following steps are required:

• Once the need for a HAZMAT has been identified, the preapproved lists should be reviewed to determine if the product is available for purchase. If the item is Hazcode A, it can be purchased, and tracking the product as a HAZMAT is not required. If the product is Hazcode B, it can be purchase by any organization without a license as long as it is not purchased in a volume over the established maximum and it is used in the processes listed on the blanket authorization.

• If the product is not Hazcode A, a search must be performed in the HMMS to determine if the product is currently in the system. If the product is in the system, the MSDS should be checked to ensure it is less than 5 years old and generated by the manufacturer.

• If the MSDS in not in the system or is out of date, the current manufacturer’s MSDS should be e-mailed, faxed, or mailed to the HAZMAT Cell Customer Support personnel for it to be entered into the system. If the MSDS is faxed, a hard copy should be mailed as a follow-up.

• Once the MSDS is in the system, complete the Authorization page in the HMMS. Once the form is completed it will be forwarded for authorization request in the following sequence:

1. Requestor 2. Supervisor 3. Issue Point Manager 4. UEC 5. MSDS Entry/Customer Support 6. BEE 7. SE 8. HAZMAT Cell

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• The authorization request will be reviewed by the BEE and assigned a Hazcode. If the product is determined to be a Hazcode A or B, the user will be notified and the Hazcode A or B pre-approved list will be updated. If the product is determined to be a Hazcode C or O, an Issue Point–specific HAZMAT License for the product will be issued. The Hazcode C license will be either a C1, C3, or C5, good for 1, 3, or 5 years, respectively. The Hazcode O licenses will be for 1 year.

• Once the approvals are completed, the HAZMAT System Administrator enters the license into the HMMS.

4.1.2.1 Government Purchase Cards To purchase a Hazcode B or Hazcodes C and O product on a GPC, access the Purchase Page in the HMMS and choose the Purchase Card option. When the page opens, complete the purchase request information. If problems are encountered, the HAZMAT Cell will provide assistance as needed. Once the forms are completed, they will be forwarded electronically as follows:

1. Requestor 2. Issue Point Manager 3. UEC 4. HAZMAT Cell 5. GPC Holder

GPC orders can be delivered by the supplier directly to the requesting organization. If the products are purchased locally by government personnel, they can be transported only in government vehicles in quantities less than 30 gallons and quantities of less than 1 quart for acutely hazardous materials.

4.1.2.2 Standard Base Supply System To purchase a HAZMAT, access the Purchase Page in the HMMS and choose the Order Request page. When the page opens, complete the purchase request information. If problems are encountered, the HAZMAT Cell will provide assistance as needed. Once the forms are completed, they will be forwarded electronically as follows:

1. Requestor 2. Issue Point Manager 3. HAZMAT Cell

The HAZMAT Cell will then place the order for the HAZMAT within the SBSS system.

SBSS purchases will be delivered to the SBSS central storage area. The item will be barcoded and entered into the HMMS. The item will then be delivered to the requestor and transferred electronically into the requestor’s Issue Point.

At this time, MSDS number for the material will be compared to the order request by the requestor. Because one National Stock Number can represent several different products from different manufacturers, the new MSDS may not match the original MSDS submitted and a new Authorization request will need to be submitted.

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4.1.2.3 Form 9 WPAFB HAZMAT users cannot procure HAZMATs over $2,500 on a GPC but can option to use AF Form 9 for large orders. These orders are rarely made within the HMMS. However the regular electronic authorization request can be made within the HMMS as described in Section 4.1 of this plan. Once the license is obtained, the order can be placed within HMMS as a GPC option. The requestor will need to contact the HAZMAT Cell System Administrator to have the contracting officer added to the HMMS purchase approvers list. The requestor must manage the materials as outlined in Sections 4.1.3 through 4.1.8.

4.1.2.4 Ozone-Depleting Substances 4.1.2.4.1 Class I ODSs. WPAFB HAZMAT users cannot procure pure Class I ODSs through the regular electronic authorization request within the HMMS. These chemicals must be ordered from the Defense Logistics Agency (DLA) Class I ODS Defense Reserve Stockpile with approval of the Senior Acquisition Official (SAO). A hard copy AF Form 3952 must be submitted to the HAZMAT Cell with an attached document that specifies the exclusive need of a Class I ODS to justify the purchase. The AF Form 3952 is then submitted by the HAZMAT Cell to Headquarters AFMC and then the SAO for approval.

Products that contain Class I ODSs, in the form of mixtures (less than 100 percent ODS) or propellants are not part of the DLA stockpile. These products are not “pure” Class I ODSs and do not require written justification or SAO approval. These procurement requests are made electronically on HMMS and the materials are procured from the Standard Base Supply System or purchased commercially. An effort to replace the use of these products with environmentally preferable products is made through the WPAFB Pollution Prevention Program as described in Section 8 of this Plan.

4.1.2.4.2 Class II ODS. Class II ODS may be purchased through the regular WPAFB electronic authorization request within the HMMS as outlined in Section 4.1.2 of this Plan without any justification statements or additional approvals. Both pure Class II ODS and products containing Class II ODS may be procured in this manner. However, the phase-out in production of Class II ODS is intended to drive the development and use of environmentally preferable products. HAZMAT users are provided assistance in replacing Class II ODS and products containing Class II ODS through the WPAFB Pollution Prevention Program, as described in Sections 4.1.2.1 and 4.1.2.2 of this Plan.

4.1.3 Tracking The organization Issue Point Manager or the alternate is required to enter the HAZMAT into the HMMS within 1 working day of the HAZMAT’s arrival on base. If the item is ordered and received through the SBBS central storage area, the supply personnel will enter the HAZMAT into the central supply Issue Point in the standardized AF HAZMAT-tracking system and will store the material until delivery. Upon delivery the supply personnel will transfer the HAZMAT into the user’s inventory both physically and electronically. However, the Issue Point Manager will be required to “accept” the transfer of the HAZMAT before it can be entered into the inventory. The status of the material after it has been entered into the inventory is “new material,” and it will remain as such until it is issued to a user. After issue, the status of the material will be “in use.”

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Data Quality Management regarding shelf-life, storage location, usage rate, and redistribution and disposal will be performed as outlined in the Site-Specific Issue Point Operating Instructions.

To ensure that inventories are up to date, the Issue Point Manager or the alternate Issue Point Manager will perform a barcode inventory two times a year, run a reconciliation report, and make inventory corrections in the HMMS. If the Issue Point does not have a barcode scanner, the HAZMAT Cell will provide personnel with the necessary equipment to perform the inventory and assist with running the reconciliation reports.

4.1.4 Labeling All HAZMATs must have their manufacturer’s label. The organization Issue Point Manager or the alternate Issue Point Manager is required to generate and apply a yellow barcode label generated from the HMMS within 1 working day of the HAZMAT’s arrival on base. If the item is ordered and received through the SBBS central storage area, the supply personnel will generate and apply the yellow barcode label to the HAZMAT container or to the box containing multiple products. For organizations that do not have access to a label printer, the HAZMAT Cell customer support personnel will assist the Issue Point Manager or alternate Issue Point Manager with label printing. If a label becomes lost, worn, faded, or defaced in any manner, it must be replaced immediately. If a HAZMAT container is too small for placement of the label, the item can be stored in a plastic bag with the label attached. If HAZMATS are transferred to a smaller container, the smaller container must be labeled with the product name and the base MSDS number. Some HAZMATs that have been in storage for a long period of time have a rainbow barcode label. These labels are acceptable as long as they are legible and in good condition.

4.1.5 Storage The Issue Point storage areas must meet HAZMAT storage requirements as delineated in the WPAFB Guidelines for Chemical Compatibility and Storage of HAZMATs (Appendix A). The Site-Specific Issue Point Operating Instructions will establish the storage locations and storage requirements. The following documents will be stored near the point of egress to the storage area:

• Inventory • Current SSSP • Manufacturer’s MSDSs

4.1.5.1 Courtesy Storage in Building 247

The contractor operated HAZMAT Warehouse located in Building 247 in Area C will provide for the management and care of HAZMATs for organizations that do not have adequate storage capacity orconditions. Organizations wishing to store HAZMATs at the warehouse would need to enter into a Memorandum of Agreement (MOA) with the operating contractor. A copy of the MOA can be obtained from the warehouse superior. An organization would need to appoint a primary and alternate point-of-contact for the warehouse personnel and agree to the following:

• Ensure all HAZMATs are stored in sealed containers.

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• Maintain and update the shelf-life for all HAZMATs provided courtesy storage to include disposing of outdated HAZMATs as required.

• Assist with the inspection, loading, and unloading of materials as required. • Perform a semi-annual review of the MOA and HAZMATs being stored with the

Hazardous Warehouse Supervisor. The semi-annual inspection will be conducted in March and September of each year.

The Hazardous Warehouse personnel will pick-up and deliver an organizations HAZMATs as requested.

4.1.6 Shelf-Life Management Under the HAZMAT program, HAZMAT users should not be in possession of excess or expired-shelf-life materials. Organizations are prohibited from storing and hoarding HAZMAT in their work areas. Unnecessary waste generation can be caused by (1) over ordering HAZMAT, (2) ordering the wrong unit of issue, (3) allowing the shelf-life to expire, and (4) allowing chemicals to deteriorate and becoming unstable. Most of these problems are avoidable.

HAZMAT should be managed with the “first in, first out” policy. HAZMAT should be stored and distributed in such a manner that containers with the shortest shelf life are stored in what is called “first” position of the storage cabinet. It is mandated that these materials be consumed before any other HAZMAT of the same type can be opened. Each individual organization should establish guidelines in their Site-Specific Issue Point Operating Instructions by which to store and distribute their HAZMAT to prevent shelf-life expirations.

When HAZMATs are entered into HMMS as “new inventory,” the expiration date must be input in HMMS only if the shelf-life periods are established by the DLA when materials are assigned a National Stock Number. Shelf life periods assigned to non–National Stock Number materials are based on the shelf-life periods assigned to similar National Stock Number materials. Shelf-life periods should be monitored periodically and updated to prevent the expiration of HAZMATs. The AF has developed a program that establishes guidelines regarding the extension the shelf-life. To extend shelf-life of a HAZMAT contact, the Base Supply Inspector at 70819. Base Supply will annotate the correct, extended shelf-life in HMMS.

4.1.7 HAZMAT Redistribution Once it has been determined that a HAZMAT is no longer needed or useful for its purpose, it must be reused in a different manner or disposed. Reuse/recycling options that optimize utilization of raw materials and minimize waste should be explored first. All possible avenues should be exhausted before making the decision to dispose of a material as a hazardous waste.

Reuse includes using the material for another purpose in-house, transferring materials to another organization on base (free issue), or to an outside agency (federal, state, privately owned, or a nonprofit charity). The HAZMAT Cell uses an e-mail to assist with finding other potential users on base through their Excess Material Program.

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4.1.8 Disposal All excess and expired HAZMAT must be disposed of in accordance with the procedures delineated in the WPAFB Hazardous Waste Management Plan and WPAFBI 32-7001. When a HAZMAT is consumed or disposed of, the Issue Point Manager is responsible for removing it from the organizations HAZMAT inventory in the standardized AF HAZMAT-tracking system and turning the material over as a waste into the HAZWASTE-tracking system.

4.1.9 Personnel and PEGs Personnel Exposure Groups (PEGs) and Zones are used by BEE within the HMMS system to track and document employee chemical exposures.

4.1.9.1 Personnel Changes If supervisory or personnel changes are made within a PEG, the BEE should be notified by completing WPAFB Form 1408, “Supervisory/Employee Input.” This form is available in Appendix D.

4.1.9.2 Changes in PEGs If PEG determinations are changed during process changes or annual inspections by BEE, the Issue Point Manager should complete WPAFB Form 1407, “PEG/Employee Input,” and notify the appropriate BEE personnel. This form is available in Appendix C.

4.1.9.3 Personnel Out-Processing Personnel involved in the use of HAZMATs must complete the Hazardous Material/Hazardous Waste Out-Processing Record (Appendix G) at least 1 week prior to the individuals out-processing from an organization. This applies to all military and civilian government employees. The out-processing individual must ensure that all HAZMATs, HAZWASTE, and solid waste are properly transferred and managed before out-processing will be approved. The Hazardous Material/Hazardous Waste Out-Processing Record must be signed by the PEG Supervisor, Issue Point Manager, IAP Manager, and UEC.

If the individual out-processing is a primary or alternate Issue Point Manager, another individual must be appointed in writing by the Unit Commander and the HAZMAT Cell notified to the changes to the organization’s HAZMAT program.

4.2 Sponsored Organizations Sponsored Organizations are visiting military or civilian groups whose activities require the use of HAZMATs. These materials are brought on base by these units; they are not purchased through the WPAFB HAZMAT Cell. However, HAZMATs brought on the base by these organizations must be tracked through the HAZMAT Cell.

For these organizations, reporting, tracking, and managing HAZMAT is ultimately the responsibility of the Sponsor, the organization that accommodates the Sponsored Unit. HAZMATs cannot be stored or used at WPAFB unless the HAZMAT Cell has received prior written notification. Under circumstances where little notice is given to the Sponsor, all

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paperwork can be expedited through the HAZMAT Cell. An example would be the arrival of an aircraft maintenance unit performing emergency repairs.

4.2.1 Reporting Use for Sponsored Organizations The sponsoring organization must submit MSDSs for the sponsored organization’s HAZMATs for entry into HMMS along with the quantity and size of each container brought on base. Licenses for the items will not be required. The home station of the sponsored organization is responsible for tracking the chemical exposure of the employees. The HAZMAT Cell is only interested in tracking HAZMAT usage. The items will be entered into the sponsored organization’s inventory, and barcode labels will be printed.

4.2.2 Labeling and Storage of Hazardous Materials The Issue Point Manager or the UEC of the sponsoring organization is required to apply the yellow barcode tracking labels to the containers within 1 working day of their arrival on base. For organizations that do not have label printers, the HAZMAT Cell personnel will assist with printing the labels. The HAZMATs must be stored in compliance with the storage requirements as delineated in the WPAFB Guidelines for Chemical Compatibility and Storage of HAZMATs (Appendix E).

4.2.3 Empty Containers and Excess Materials After materials have been consumed, the sponsored organization should notify the HAZMAT Cell of this fact in writing or by e-mail within 2 working days. Inventory updates to HMMS will be made by the Base Users acting as sponsors.

All excess HAZMAT must be disposed of in accordance with the procedures delineated in the WPAFB Hazardous Waste Management Plan and WPAFBI 32-7001. When a HAZMAT is consumed or disposed, the Issue Point Manager is responsible for removing it from the organization’s HAZMAT inventory in the standardized AF HAZMAT-tracking system and turning the material over as a waste into the HAZWASTE-tracking system.

4.3 Transient Aircraft Transient Aircraft Units are units on temporary duty assignment or on a layover at WPAFB. Aircraft managed by these units are serviced, refueled and fluids topped off by Transient Alert (88 MSG/LGRMT). If the aircraft require maintenance while at WPAFB, maintenance personnel form the aircraft’s home station may be sent to make the repairs or Transient Alert may repair the aircraft. If the maintenance crew is from the aircraft home station and they bring HAZMATs with them to WPAFB, they are classified as Sponsored Organizations, as defined in Section 4.3 of this plan.

Transient Aircraft Units perform very little aircraft maintenance while on temporary duty at the base. Most HAZMATs used by these organizations consist of oil and hydraulic fluids used for topping-off engine fluids. These materials tend to be assigned a HAZCODE B, and the aircraft typically leaves the base along with any materials used. These HAZMATs will not be tracked. If, however, the transient crews use HAZMATs other than oils and lubricants, they must be reported to the HAZMAT Cell in the same manner required for

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Sponsored Organizations. Refer to Section 5.1 of this report for instructions. The Transient Alert is responsible for all HAZMAT reporting associated with repairs they perform for Transient Aircraft Units.

It is the responsibility of the Transient Aircraft Unit to dispose of any empty containers generated from these activities. Empty oil and lubricant containers should be given to the Transient Alert. The Transient Alert will collect the empty containers, drain them, and arrange for their disposal or recycling.

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Ozone-Depleting Substance Procurement

Chapter 4 of AFI 32-1086 contains detailed information on the Air Force’s ODS Program. In summary, the production of Class I ODS effectively ended on December 31, 1995, and production of Class II ODS will be reduced incrementally until final phase-out in 2030. Use of Class I and Class II ODS are critical to current defense missions and judicious use of these chemicals is necessary to maintain mission capability until existing weapons systems are replaced.

5.1 Responsibilities Each organization at WPAFB is responsible for managing ODS in compliance with federal, state, and local regulations as well as Air Force, AFMC, and WPAFB policy. The following organizations have key responsibilities in ensuring that HAZMAT is properly managed on base.

5.1.1 HMMP Team 5.1.1.1 Ensure that installation personnel using ODS are involved in a responsible-use program to prevent losses and to conduct recovery, recycling, and reuse of ODS to the maximum extent practicable.

5.1.1.2 Prohibit the use and discharges of Class I ODS Halons during both facility and weapons system training.

5.1.1.3 Prohibit the discharge of Class I and Class II ODS refrigerants during both facility and weapons system training.

5.1.1.4 Ensure deploying units provide the Class I ODS deployment report in accordance with paragraph 4.7.2.3.4 of AFI 32-7086.

5.1.1.5 Ensure the turn-in of installation excess refrigerants and Halons (including Halon bottles with the contents intact) to the DLA Class I ODS Defense Reserve in accordance with paragraph 4.4.2.5 of AFI 32-7086. In addition, installations must prohibit the transfer of excess installation Class I ODS outside the Air Force, except to the DLA Class I ODS Defense Reserve.

5.1.2 Civil Engineering UEC (88 ABW/CEML) 5.1.2.1 Manage facility air conditioning, refrigeration, and fire suppression equipment using existing CE Class I ODS stocks. Facility Class I ODS requirements may not be met by requisitions from the DLA Class I ODS Defense Reserve or purchase of Class I ODS.

5.1.2.2 Identify all excess facility Halons and Class I ODS refrigerants to the MAJCOM and ensure they are reallocated within the MAJCOM or the Air Force, or turned in to the DLA Class I ODS Defense Reserve according to established procedures.

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5.1.2.3 Advise SE of any inadvertent releases of Class I ODS from installation CE facilities, equipment, or processes for possible reporting as a mishap.

5.1.2.4 Ensure procedures are in place for the proper reporting of inadvertent installation releases of Class I ODS, in accordance with applicable federal, state, and local reporting requirements.

5.1.2.5 Issue an environmental Notice to Airman (NOTAM) within 30 work days of an inadvertent release of a Class I ODS that requires Class A or Class B mishap reporting in accordance with paragraph 4.12.6.1 of AFI 32-7086.

5.1.2.5.1 The NOTAM must include information on the release (date of occurrence, location, and amounts of Class I ODS released), the identification of causes, and recommended corrective actions.

5.1.2.5.2 Include MAJCOM/CEV and SAF/AQRE as addresses on each Class I ODS inadvertent release NOTAM, regardless of mishap category. These offices will provide the NOT-AMs to their respective HMMP teams.

5.1.2.6 Ensure the preparation and maintenance of current Halon and Refrigerant Management Plans.

5.1.2.7 Provide initial and revised Refrigerant Management Plans to the MAJCOM Refrigerant Manager and AFCESA for review and comment to include BCE exceptions to the Class I ODS policy for installation Real Property air conditioning and refrigeration equipment (in accordance with paragraph 4.8.2.2 of AFI 32-7086).

5.1.3 Civil Engineering UEC 5.1.3.1 Provide facility refrigerant inventory and (LOSS) system recharge data to the MAJCOM Refrigerant Manager on a quarterly basis, or as required.

5.1.3.2 Ensure refrigerant inventory and maintenance data is input in approved refrigerant management software to track refrigerant losses.

5.1.4 Weapon Systems Maintenance 5.1.4.1 Participate in the HMMP team, as necessary.

5.1.4.2 Manage weapon system Class I ODS according to SAO approvals, and ensure that there is a formal technical document (e.g., TO or commercial technical manual) requirement for each Class I ODS use.

5.1.4.3 Identify all excess weapons system Halons and Class I ODS refrigerants to the MAJCOM and ensure they are reallocated within the MAJCOM, the Air Force, or turned in to the DLA Class I ODS Defense Reserve according to established procedures.

5.1.4.4 Advise SE of any inadvertent release of Class I ODS from installation storage facilities, equipment, or processes for possible reporting as a mishap.

5.1.4.5 Advise CE of any inadvertent releases of Class I ODS from installation storage facilities, equipment, or processes, and comply with applicable federal, state, and local reporting requirements.

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5.1.5 HAZMAT Cell Ensure that the HAZMAT Cell obtains Class I ODS Requisition SAO approvals, in accordance with the procedures described at 4.6 in AFI 32-7086 , prior to requisitioning Class I ODS from the DLA Class I ODS Defense Reserve.

5.1.5.2 Ensure that the standardized Air Force HAZMAT-tracking system tracks Class I ODS requisitions.

5.1.5.3 Ensure the SBSS assigns appropriate USAF requisition exception code to all Class I ODS National Stock Numbers.

5.1.6 Work Area Supervisor 5.1.6.1 Participate in the HMMP team, as necessary.

5.1.5.2 Ensure that Class I ODS supplies are obtained only from an installation HAZMART, in accordance with the Class I ODS Requisition SAO approval procedures described in paragraph 4.6 of AFI 32-7086.

5.1.6.3 Ensure that there is a requiring document for each Class I ODS use that specifies the exclusive use of that Class I ODS.

5.1.6.4 Advise SE of any inadvertent releases of Class I ODS in their work area for possible reporting as a mishap.

5.1.6.5 Advise CE of any inadvertent releases of Class I ODS from work area facilities, equipment, or processes, and comply with applicable federal, state, and local reporting requirements.

5.1.7 SE 5.1.7.1 Investigate all inadvertent releases of Class I ODS to determine reporting requirements in accordance with AFI 91-204, “Safety Investigations and Reports.” Class I ODS must be valued at $100 per pound.

Note: Inadvertent release does not include releases resulting from the intended use of the material (e.g., the release of Halons in actual fire fighting or fuel tank inerting).

5.1.7.1.1 Review the mishap report with the other members of the HMMP team to include, at a minimum, CEV and BE, consistent with the restrictions on release of privileged information.

5.1.7.2 Mishap reports related to Class I ODS inadvertent releases are non-rate producing for mishap rate calculations.

5.1.7.3 Provide necessary support to CEV for the issuance of an environmental NOTAM that summarizes the inadvertent release of a Class I ODS.

5.1.8 Contracting Office 5.1.8.1 In accordance with AFFARS 5323.804, the Contracting Office will include AFFARS Clause 5352.223-9000 in solicitation and contracts.

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5.2 Class I ODS The Air Force and the DLA maintain a stockpile of “pure” Class I ODS (Table 5-1) to minimize risk to mission capability, minimize costs, and ensure sufficient supply is available for mission critical needs. Procurement of pure Class I ODSs (products that conform to the military or commercial specifications that define the ODS formulations) is highly controlled to protect this stockpile.

TABLE 5-1 Class I Ozone-Depleting Substances

Halocarbon Number Molecular Formula Name CAS Number

CFC-11 CCl3F Trichlorofluoromethane 75-69-4

CFC-12C Cl2F2 Dichlorodifluoromethane 75-71-8

CFC-113 C2Cl3F3 Trichlorotrifluoroethane 76-13-1

CFC-114 C2Cl2F4 Dichlorotetrafluoroethane 76-14-2

CFC-115 C2ClF5 Chloropentafluoroethane 76-15-3

Halon 1011 CH2BrCl Bromochloromethane 74-97-5

Halon 1202 CBr2F2 Dibromodifluoromethane 75-61-6

Halon 1211 CF2ClBr Bromochlorodifluoromethane 353-59-3

Halon 1301 CF3Br Bromotrifluoromethane 75-63-8

Halon 2402 C2F4Br2 Dibromotetrafluoroethane 124-73-2

CFC-13 CClF3 Chlorotrifluoromethane 75-72-9

CFC-111 C2Cl5F Pentachlorofluoroethane 354-56-3

CFC-112 C2Cl4F2 Tetrachlorodifluoroethane 76-12-0

CFC-211 C3Cl7F3 Heptachlorofluoropropane 422-78-6

CFC-212 C3Cl6F2 Hexachlorodifluoropropane 3182-16-1

CFC-213 C3Cl5F3 Pentachlorotrifluoropropane 2354-06-5

CFC-214 C3Cl4F4 Tetrachlorotetrafluoropropane 29255-31-0

CFC-215 C3Cl3F5 Trichloropentafluoropane 1599-41-3

CFC-216 C3Cl2F6 Dichlorohexafluoropropane 661-97-2

CFC-217 C3ClF7 Chloroheptafluoropropane 422-86-6

Carbon Tetrachloride CCl4 Tetrachloroethane 56-23-5

Methyl Chloroform C2H3Cl3 Trichloroethane (all isomers) 71-55-6

Methyl Bromide CH3Br Bromomethane 74-83-9

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5.3 Class II ODS As stated in AFI 32-7086,

The Air Force will not centrally stockpile Class II ODS to support continuing requirements after the phase-out of Class II ODS production in the United States. Therefore, the Air Force will not develop or procure any new weapon or facility systems scheduled to remain in the Air Force inventory beyond 01 January 2020 that require Class II ODS in their operations or maintenance.

The list of Class II ODS and the Class II ODS production phase-out schedule is available in Tables 5-2 and 5-3.

TABLE 5-2 Class II Ozone-Depleting Substances

HCFC Number Molecular Formula CAS Number HCFC Number Molecular Formula CAS Number

HCFC-21 CHFCl2 75-43-4 HCFC-225 C3HF5Cl2

HCFC-22 CHF2Cl 75-45-6 HCFC-225ca C3HF5Cl2 422-56-0

HCFC-31 CH2FCl 593-70-4 HCFC-225cb C3HF5Cl2 507-55-1

HCFC-121 C2HFCl4 354-14-3 HCFC-226 C3HF6Cl 431-87-8

HCFC-122 C2HF2Cl3 354-21-2 HCFC-231 C3H2Cl5 421-94-3

HCFC-123 C2HF3Cl2 306-83-2 HCFC-232 C3H2F2Cl4 460-89-9

HCFC-123b CHCl2CF3 — HCFC-233 C3H2F3Cl3 7125-84-0

HCFC-124 C2HF4Cl 2837-89-0 HCFC-234 C3H2F4Cl2 425-94-5

HCFC-124b CHFClCF3 — HCFC-235 C3H2F5Cl 460-92-4

HCFC-131 C2H2FCl3 359-28-4 HCFC-241 C3H3FCl4 666-27-3

HCFC-132b C2H2F2CI2 1649-08-7 HCFC-242 C3H3F2Cl3 460-63-9

HCFC-133a C2H2F3Cl 75-88-7 HCFC-243 C3H3F3Cl2 460-69-5

HCFC-141b C2H3FCl2 1717-00-6 HCFC-244 C3H3F4Cl —

HCFC-142b C2H3F2Cl 75-68-3 HCFC-251 C3H4FCl3 421-41-0

HCFC-151 C2H4FCl — HCFC-252 C3H4F2CI2 819-00-1

HCFC-221 C3HFCl6 422-26-4 HCFC-253 C3H4F3CI 460-35-5

HCFC-222 C3HF2Cl5 422-49-1 HCFC-261 C3H5FCI2 420-97-3

HCFC-223 C3HF3Cl4 422-52-6 HCFC-262 C3H5F2CI 421-02-03

HCFC-224 C3HF4Cl3 422-54-8 HCFC-271 C3H6FCI 430-55-7

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5.4 ODS Purchases TABLE 5-3 Class II ODS Production Phase-Out

Date Reduction from 1996 Base Level (%)

01 January 2004 35

01 January 2010 65

01 January 2015 90

01 January 2020 99.5

01 January 2030 100*

*All Class II ODS production must cease.

5.4.1 Class I ODS WPAFB HAZMAT users cannot procure “pure” Class I ODSs through the regular electronic authorization request within the HMMS. These chemicals must be ordered from the DLA Class I ODS Defense Reserve Stockpile with approval of the SAO. A hard copy of AF Form 3952 must be submitted to the HAZMAT Cell with an attached document that specifies the exclusive need of a Class I ODS to justify the purchase. AF Form 3952 is then submitted to Headquarters AFMC/A4NE and then the SAO for approval.

Products that contain Class I ODS, in the form of mixtures (less than 100 percent ODS) or propellants are not part of the DLA stockpile. These products are not “pure” Class I ODSs, and do not require written justification or SAO approval. These procurement requests are made electronically on HMMS and the materials are procured from the Standard Base Supply System or purchased commercially. An effort to replace the use of these products with environmentally preferable products is made through the WPAFB Pollution Prevention Program as described in Section 8 of this Plan.

5.4.2 Class II ODS Class II ODS may be purchased through the regular WPAFB electronic authorization request within the HMMS as outlined in Section 3 of this document without any justification statements or additional approvals. Both pure Class II ODS and products containing Class II ODS may be procured in this manner. However, the phase-out in production of Class II ODS is intended to drive the development and use of environmentally preferable products. HAZMAT users are provided assistance in replacing Class II ODS and products containing Class II ODS through the WPAFB Pollution Prevention Program, as described in Section 8 of this Plan.

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SECTION 6

Unit Deployment

6.1 HAZMAT Purchasing, Tracking, and Storage All HAZMATs stored at WPAFB must be purchased, tracked, and stored in accordance with Section 4 of this document in the standardized Air Force HAZMAT-tracking system. This includes HAZMATs received for war reserve material (WRM) stored for the purposes of knowing where and how much WRM HAZMAT is stored on the base.

6.2 Plans and Procedures Each unit that deploys personnel or equipment at WPAFB is required to prepare plans and procedures to support the HAZMAT requirements (to include tracking and reporting) for the deployed units as required in AFI 32-7086, Section 2.6. These plans will be submitted to the HAZMAT Cell for information purposes only. The plans and procedures should determine how HAZMAT management functions performed by military and contractors at the home station will be accomplished during deployment. The HAZMAT needs of contractors performing mission-related functions during deployments will be included in the plans and procedures.

6.3 Pre-Deployment Requirements In planning for deployments, Installation Deployment Officers and Unit Deployment Manager must notify the HAZMT Cell of the pending plans. HAZMAT and WRM (materials and amounts) should be identified for the deploying units and copies of the completed electronic license and MSDSs should be made for each material. To obtain HAZMATs for the WRM storage areas, the completed licenses and the MSDSs must be presented by the requester before the materials will be issued.

6.4 Deployment Requirements Upon deployment, the Installation Deployment Officer (IDO) or the Unit Deployment Manager (UDM) must ensure that the HAZMATs shipped off base are shown as no longer present on the base in the standardized Air Force HAZMAT-tracking system. HAZMAT usage data must be tracked for the duration of the deployment, regardless of the source of the HAZMAT, in the tracking system.

6.5 Re-Deployment Requirements Upon return from a deployment location, the HAZMAT Cell should be notified of any serviceable HAZMAT that the deployed unit brought back to WPAFB. The standardized Air

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Force HAZMAT-tracking system should be updated to reflect the return of these HAZMATs. Upon return, if HAZMATs are found to be no longer serviceable, they should be disposed of properly.

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SECTION 7

Contractor HAZMAT Management Requirements

AFI 91-301 Air Force Occupational and Environmental Safety, Fire Protection, and Health Program, Section 9, states that “contractors are solely responsible for compliance with OSHA standards and the protection of their employees.” However, owing to the potential for government employees being exposed to chemicals while working side by side with contractors, and the requirement for Federal Facilities to comply with EPCRA reporting requirements, contractors must comply with the requirements in this section. Therefore, contractors are categorized as Exempt or Nonexempt, and shall comply with the respective requirements in this section.

Note: All contractors are required to ensure that HAZMATs are used appropriately, in accordance with the manufactures MSDS and label, so as not to expose government employees or disrupt the work environment (office or building evacuations, etc.).

7.1 Exempt Contractors Exempt contractors (including their subcontractors) shall meet all the requirements of this subsection. For the purposes of this plan, Exempt contractors do not work side by side with government employees potentially exposing them to chemicals and are determined by CEV to be exempt from the base’s EPCRA reporting requirements. Appendix H details how EPCRA exemptions are determined. Therefore the following contractor activities fall into the Exempt category:

• Construction—Contractors who perform major construction projects such as building and repairing roads, walkways, buildings, and installation of major process equipment.

• Facility Maintenance—Contractors who maintain base heating, ventilation, and air conditioning (HVAC) equipment, process equipment (e.g., cleaning oil–water separators), or perform minor building maintenance functions.

• Janitorial—Contractors who clean base offices and restrooms.

• Laboratory Support—Contractors supporting Laboratory Research and Development work needed to support DoD activities (e.g., AFRL) when the contractor is solely responsible for the operations at the facility and no civilian or military employees are working in the same area.

• Vehicle Maintenance—Contractors used to maintain base vehicles (e.g., cars, small trucks, emergency vehicles, heavy construction equipment).

• Food Service—Contractors who operate base restaurants, cafeterias, and lunch rooms.

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7.1.1 Clean Air Act Section 112(r)—Risk Management Program Contractors planning to bring onto WPAFB bulk quantities of HAZMAT exceeding thresholds quantities in 40 CFR Part 68 must notify the HAZMAT Cell 30 working days prior to bringing the materials onsite.

7.1.2 Inventory and SSSP Prior to beginning work on base, exempt contractors will submit to CEV, through the contracting officer a list of the types of HAZMATs (paints, adhesives, fuel) that will be used at the project site along with an SSSP. If additional HAZMATs are utilized for the project, the contractor shall provide an updated HAZMAT inventory to CEV through the contracting officer and post update inventory at the site. A manufacturer’s MSDS must be onsite for each HAZMAT brought onto the base. The MSDS must be readily available and no more than 5 years old (unless the manufacturer’s most recently updated version is older). The use of Class I ODSs is prohibited on the installation unless written permission is obtained by CEV through the contracting officer.

A contractor onsite for fewer than 3 working days is not required to provide these submittals. However, an MSDS for each HAZMAT must be readily available at the project site or in the possession of the user.

7.1.3 Container Labeling All contractors must individually label each HAZMAT container with an adhesive label or tag with the following information:

• Contractor’s name • Contractor’s address • Contractor’s point of contact and phone number • Contract number

Durable, adhesive labels must be printed electronically or filled out legibly with a pen capable of withstanding diverse weather conditions. If paper labels are used, they should be protected with a plastic overlay to prevent deterioration. If a label becomes lost, worn, faded, or defaced in any manner, it must be replaced immediately. If a HAZMAT container is too small for a label to be placed on it, the item can be stored in a plastic bag with the label attached to the bag instead.

7.1.4 Material Storage and Use Each HAZMAT must have its manufacture’s label. In addition, all contractors must follow the manufacturer’s guidelines and professional recommendations for controlling humidity, temperature, cleanliness, and material handling relative to storage and use of all HAZMATs. The contractors must use, handle, and store all HAZMATs in accordance with all federal, state, local, and Air Force laws, policies, regulations, and procedures as specified, but not limited to, the WPAFB IHMP Plan and WPAFB OI 32-7002. The contractors will furnish all equipment necessary to manage HAZMATs. This equipment includes, but is not limited to, approved chemical security cabinets, locks, secondary containment, spill

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response equipment, fire extinguishers, and personal protective equipment, to securely manage HAZMATs at the project site.

7.1.5 Spill Control and Reporting Spill prevention and containment is the responsibility of the contractor. The contractor will develop an SSSP for each HAZMAT storage location that must be approved by CEV. All contractors must be familiar with the SSSP, including what actions to take in the event of a spill, required notifications to be made, and where the contractor’s spill containment equipment and materials are kept.

Contractors shall immediately report all spills that occur regardless of who is responsible. The spills shall be reported as follows:

• Fuel and Oil Spills: Report all spills of more than one gallon of materials or spills of any size if the material enters a sewer. Report all spills of any size that create a fire hazard. Report these spills to the Base Fire Department by calling (937) 257-9111, or on a base phone call 911 and also notify the government’s project inspector.

• Spills of Hazardous Chemicals: Report all spills of any size to the Base Fire Department by calling (937) 257-9111, or on a base phone call 911 and also notify the government’s project inspector.

• Spills of Other Materials (such as paints, tar, etc.): Report all spills that enter sewers or that have the potential to damage or pollute the environment. Report these spills to CEV at (937) 257-2201 and also notify the government’s project inspector. After duty hours report these to the Base Fire Department by calling (937) 257-9111 or on a base phone call 911.

The contractor is responsible for containing all spills. The contractor is responsible for maintaining spill containment equipment and materials onsite that are appropriate for the materials being stored and in sufficient quantities to provide containment for the volume of the materials stored. If containment is beyond the capability of the onsite personnel the contractor shall relay this during the emergency notification to the base fire department. The base fire department, with guidance from CEV, will determine the amount of containment required. Cleanup standards will be determined by the CEV. The contractor shall clean up all spills that result form the contractor’s actions or activities, including faulty equipment. The cleanup methods shall be as required by the Contracting Officer and the Contracting Officer’s Technical Representative. The contactor shall reimburse the Government for any materials and assistance provided by the Government and use in containment or clean up of those spills resulting from the contractor’s actions.

7.1.6 Removal or Disposal of Unused Materials Upon completion of the project, contractors must remove all HAZMATs from the project site and the base. No HAZMATs will be left by contractors unless specified in their contract. If the unused materials cannot be removed from the base or HW has been generated from the contractor’s activities, the materials will have to be disposed in compliance with WPAFBI 32-7001, “Hazardous Waste Management.”

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7.1.7 Security/Management/Liability All HAZMAT containers must be secured so that they are under control of the contractor and to prevent access to unauthorized personnel. Containers must be stored indoors or in an area not accessible by the general base population.

7.2 Non-Exempt Contractors Non-exempt contractors (including their subcontractors) must meet the requirements of this subsection. For the purposes of this plan, Non-exempt contractors work side by side with government employees, potentially exposing them to chemicals, and are not exempt from the base’s EPCRA reporting requirements as determined by CEV.

7.2.1 Clean Air Act Section 112(r)—Risk Management Program Contractors planning to bring onto WPAFB bulk quantities of HAZMAT exceeding thresholds quantities in 40 CFR Part 68 must notify the HAZMAT Cell 30 working days prior to bringing the materials onsite.

7.2.2 Management Requirements Non-exempt contractors’ HAZMATs will be managed in the web-based HMMS. MSDS reviews, tracking, and the generation of yellow barcode labels can be generated from the system. The web-based system must be used, and contractors can have access to the system at the HAZMAT Cell.

Each contractor must assign a contractor Issue Point Manager and an alternate contractor Issue Point Manager. Training modules are available on HMMS. If additional help is needed, the HAZMAT Cell can be contacted for additional training. The HAZMAT Cell will provide contractors with individual Issue Points in HMMS. Contractors will be required to develop a Site-Specific Issue Point Operating Instruction as outlined in Section 4.1.1 of this plan.

7.2.2.1 Acquisition and Notification A HAZMAT is classified as either Hazcode A, B, C, or O. The definitions of these classifications are provided in Section 3 of this plan. The following steps must be followed to enter your HAZMAT inventory into the HMMS:

• Once HAZMATs have been identified, the Hazcode A and Hazcode B preapproved lists should be reviewed to determine if the product is available for purchase. If the item is a Hazcode A, it can be purchased, and tracking the product as a HAZMAT is not required. If the product is a Hazcode B, it can be purchase by the contractor without an MSDS review as long as it is not purchased in a volume over the established maximum and it is used in the processes listed on the blanket authorization.

• If the product is neither a Hazcode A nor a Hazcode B, a search must be performed in the HMMS to determine if the product is currently in the system. If the product is in the system, the MSDS should be checked to ensure it has been generated by the manufacturer and is less than 5 years old (or, if older, is the most recent version).

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• If the MSDS in not in the system or is out of date, the current manufacturers MSDS should be e-mailed, faxed, or mailed to the MSDS Entry/Customer Support personnel for entry into the system. If the MSDS is faxed, a hard copy should be mailed as a follow-up.

• Once the MSDS is in the system, the Authorization page in the HMMS should be completed. If contractors are purchasing the material, they are not required to get Licenses, but use of this system is the easiest way to accomplish the MSDS review. If the contractor is purchasing the HAZMAT with government funds, then an Authorization request is required. Once the form is completed it will be forwarded to the following organizations for review:

− Requestor − MSDS Entry/Customer Support − BEE − SE − HAZMAT System Administrator/Alternate

• The authorization request will be reviewed by the BEE and assigned a Hazcode. The contractor will then be notified if they are permitted to bring the HAZMAT on the facility.

7.2.2.2 Container Labeling All HAZMATs must have the manufactures’ label. The contractor Issue Point Manager or the alternate contractor Issue Point Manager is required to generate and apply a yellow barcode label generated from HMMS within one working day of the HAZMAT arrival on base. The HAZMAT Cell customer support personnel will assist the contractor Issue Point Manager or alternate contractor Issue Point Manager with label printing. If a label becomes lost, worn, faded, or defaced in any manner, the label must be replaced immediately. If a HAZMAT container is too small for placement of the label, the item can be stored in a plastic bag with the label attached. If HAZMATS are transferred to a smaller container, it must be labeled with the product name and the base MSDS number.

7.2.2.3 Material Storage and Use All contractors must follow manufacturer’s guidelines and professional recommendations for control of humidity, temperature, cleanliness and material handling relative to storage and use of all HAZMATS. The contractors must use, handle, and store all HAZMATs in accordance with all federal, state, local, and Air Force laws, policies, regulations, and procedures as specified, but not limited to, the WPAFB IHMP Plan and WPAFB Operating Instruction 32-7002. The contractors will furnish all equipment necessary to manage HAZMATs. This equipment includes, but is not limited to, approved chemical security cabinets, locks, secondary containment, spill response equipment, fire extinguishers, and personal protective equipment, to securely manage HAZMATs at the project site.

The contractor Issue Point Manager or the alternate contractor Issue Point Manager is required to enter the HAZMAT into HMMS within one working day of the HAZMAT arrival on base. To ensure that inventories are up to date, the contractor Issue Point Manager or the alternate contractor Issue Point Manager will perform a barcode inventory

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two times a year in March and September, run a reconciliation report, and make inventory corrections in the HMMS. If the contractor Issue Point does not have a barcode scanner, the HAZMAT Cell will provide personnel with the necessary equipment to perform the inventory and assist with running the reconciliation reports.

7.2.2.4 Spill Control and Reporting Spill prevention and containment is the responsibility of the contractor. The contractor will develop a SSSP for each storage location where HAZMATs are stored that must be approved by CEV. All contractors must be familiar with the SSSP including what actions to take in the event of a spill, required notifications to be made, and where the contractor’s spill containment equipment and materials are kept.

Contractors shall immediately report all spills that occur regardless of who is responsible. The spills shall be reported as follows:

• Fuel and Oil Spills: Report all spills of more than one gallon of materials or spills of any size if the material enters a sewer. Report all spills of any size that create a fire hazard. Report these spills to the Base Fire Department by calling (937) 257-9111 or on a base phone call 911 and also notify the government’s project inspector.

• Spills of Hazardous Chemicals: Report all spills of any size to the Base Fire Department by calling (937) 257-9111 or on a base phone call 911 and also notify the government’s project inspector.

• Spills of Other Materials (such as paints, tar, etc.): Report all spills that enter sewers or that have the potential to damage or pollute the environment. Report these spills to CEV at (937) 257-2201 and also notify the government’s project inspector. After duty hours report these to the Base Fire Department by calling (937) 257-9111 or on a base phone call 911.

The contractor is responsible for containment of all spills. The contractor is responsible for maintaining spill containment equipment and materials onsite that are appropriate for the materials being stored and in sufficient quantities to provide containment for the volume of the materials stored. If containment is beyond the capability of the onsite personnel the contractor shall relay this during the emergency notification to the base fire department. The base fire department, with guidance from CEV, will determine the amount of containment required. Cleanup standards will be determined by the CEV. The contractor shall clean up all spills that result form the contractor’s actions or activities, including faulty equipment. The cleanup methods shall be as required by the Contracting Officer and the Contracting Officer’s Technical Representative. The contactor shall reimburse the Government for any materials and assistance provided by the Government and use in containment or cleanup of those spills resulting from the contractor’s actions.

7.2.2.5 Removal or Disposal of Unused Materials Upon completion of the project, contractors must remove all HAZMATs from the project site and/or the base. No HAZMATs will be left by contractors unless specified in their contract. If the unused materials cannot be removed from the base or HW has been generated from the contractor’s activities, the materials will have to be disposed in compliance with WPAFBI 31-7001, “Hazardous Waste.”

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7.2.2.6 Security/Management/Liability All HAZMAT containers must be secured so that they are under control of the contractor and to prevent access to unauthorized personnel. Containers must be stored indoors or in an area not accessible by the general base population

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Training

8.1 Introduction The WPAFB HAZMAT training program is geared toward all personnel who deal with HAZMAT according to AFI 32-7086 and WPAFBI 32-7002. General Hazardous Substance training is provided by CEV, SE,BEE, and Public Health must be supplemented by site-specific training given by the supervisor or assigned person in the organization that is familiar with site-specific hazards. Additionally, any time a new chemical is introduced into the workplace; site-specific training must be given to all employees to familiarize them with safe management and handling practices associated with the hazards of the new HAZMAT.

8.2 HAZMAT-Training Requirements HMMP Team members and personnel, who manage or handle HAZMATs, and their supervisors, must receive and successfully complete HAZMAT training prior to performance of any tasks involving HAZMATs. These personnel must successfully complete the required within 6 months after their date of employment or assignment. Employees must not work in unsupervised positions until they have completed the training as described in this section.

It is up to the judgment of the UEC, supervisor, and individual to determine the appropriate training classes required to cover the training needs of an individual. Appendix I provides a quick reference table detailing which of the listed training courses are recommended be taken for personnel working with HAZMAT and the frequency that refresher coursed must be taken.

8.2.1 Training Agendas 8.1.1.1 Environmental Safety and Occupational Health (ESOH) Awareness ESOH awareness training includes general awareness training about potential hazards, requirements, and proper procedures for handling HAZMAT and HAZWASTE, including: First Responder’s Awareness Training; HAZCOM refresher; personnel protective equipment; human health concerns associated with working with HAZMAT/HAZWASTE; safety notifications and requirements; and environmental impacts from poor HAZMAT/HAZWASTE management practices. Other ESOH topics are also covered. Representatives from CEV, SE, BEE, and Public Health teach the ESOH course.

8.1.1.2 Resource Conservation and Recovery Act Hazardous Materials/Hazardous Waste Required for Issue Point Managers and Hazardous Waste generators to meet Resource Conservation and Recovery Act (RCRA) training requirements. Course provides detailed information on the procurement, storage, and use of hazardous materials and hazardous waste management requirements. Representatives from CEV teach the RCRA course.

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8.1.1.3 RCRA Refresher The 4-hour refresher is required by hazardous waste generators to meet annual RCRA training requirements. Provides updates on program changes and new regulatory requirements. Representatives from CEV teach the RCRA course.

8.1.1.4 Hazardous Communication HAZCOM training, taught by Public Health, covers specific requirements of 29 CFR 1910.1200 and AFI 90-821 to provide employees with effective information and training on hazardous chemicals in their work areas at the time of their initial assignment. It covers employee’s right to know about the hazards of chemicals that they work with and trains them to safely work with these chemicals. Topics included in HAZCOM training are: the written HAZCOM plan, hazardous chemical inventory, MSDSs, labeling of containers, and employee training.

8.1.1.5 Train the Trainer A train the trainer course to meet the OSHA Hazard Communication Standard training requirements. This course is required by supervisor and managers who have employees who handle and use hazardous materials. The course is taught by taught by Public Health.

8.1.1.6 Department of Transportation This course is required by employees who label, handle, package, load, or transport hazardous materials or hazardous waste. This course is offered on a bi-annual basis and sponsored by CEV.

8.1.1.7 Department of Transportation Refresher This course is required by the DOT for employees who label, handle, package, load, or transport hazardous materials or hazardous waste. This course is offered on a bi-annual basis and sponsored by CEV.

8.1.1.8 UEC Training This course equips the UEC to maintain and improve environmental compliance/performance within their organization, recognize and address problems when they occur, and act as a basewide point of contact for environmental issues concerning their organization. Key topics discussed include UEC roles and responsibilities, overview of Air Force environmental management, and introduction to primary environmental players on the installation. Additionally, the course will discuss key functional responsibilities including the management of hazardous materials and waste; air and water resources; POL, tanks, and spills; natural and cultural resources; pollution prevention; toxic pollutants; compliance audits; project coordination; and how to minimize environmental impact during contingency operations. This course is offered by the Air Force Institute of Technology.

8.1.1.9 Environmental, Safety, and Occupational Health (ESOH) Compliance Assessments This course provides the detailed management philosophy behind the various aspects of an Air Force environmental, safety, and occupational health compliance assessment. Graduates will develop skills needed to serve as a member of either an internal or external assessment team. The student should leave the course ready to assist their installation in performing

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internal assessments and ready to assist their Command in performing external assessments at other bases by developing an in-depth understanding of the program, and a familiarity with team responsibilities. This course is offered by the Air Force Institute of Technology.

8.1.1.10 Record Keeping Requirements Training records are required to document that all personnel working with HAZMAT have successfully completed their required training. The employee’s supervisor must maintain official training records on AF Form 55 (Appendix J). Supervisors must also maintain the following records:

• A written description of the type and amount of both introductory and continuing training that will be given to each person filling a position related to management of HW based on the training descriptions above.

• Records that document that the training has been provided to, and completed by, base personnel. These records must be kept for current employees as long as they work at the installation, and for an additional three years after the date they leave the base (or stop working at a position related to HAZMAT management). Training records may accompany personnel transferred to another installation. Both military and civilian employees must submit a copy of their training records to Public Health during out processing actions.

• A written job description for each position related to HAZMAT management. For the purposes of training records, the job description need only describe the job as it related to the management of HAZMATs and must include the requisite skills, education, or other qualifications, and the duties of facility personnel assigned to each position.

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SECTION 9

Pollution Prevention

The Air Force takes a leadership role in pollution prevention (P2) by reducing the use of hazardous materials and the release of pollutants into the environment, as stated in AFI 32-7080.

The primary means of P2 is source reduction. Source reduction techniques are described in the Air Force Center for Environmental Excellence PROACT fact sheet on Pollution Prevention Opportunity Assessments (P2OA) (http://www.afcee.brooks.af.mil/pro-act/ fact/p2oa.asp) and include:

Material substitution, where the current product is replaced with another product with less hazardous constituents

• Process efficiency improvements by which the same task is performed with less energy or materials through the modification of the existing process

• Better inventory control of hazardous materials to prevent the generation of expired or contaminated products that must then be disposed of as hazardous waste, including purchasing materials in the proper unit of issue, maintaining only necessary quantities on hand, better distribution and tracking practices, and reissuing partially used materials

• Implementing better housekeeping practices and equipment preventive maintenance procedures to reduce the chances of spills and releases.

HAZMAT users also can use the HAZMAT Cell Material Excess Program prior to purchasing new materials and before disposing of excess materials as waste.

CEV provides P2 technical assistance to HAZMAT users. Examples include performance of P2OAs and the WPAFB Green Procurement Program (GPP). In addition, the C-5 Modernization Systems Wing (MSW/C5SG) ensures proper HAZMAT management, reduction, and control through contractual obligations with the aircraft suppliers.

9.1 Pollution Prevention Opportunity Assessments As described in the PROACT fact sheet, the P2OA is an environmental analysis tool used to evaluate processes and operations. The goal of the assessment is to:

• Identify and assess the amount of material disposed of as waste during a particular process or at a particular workplace;

• Summarize hazardous materials usage and waste production;

• Identify those operations needing improvement or replacement to accomplish pollution prevention; and

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• Establish a basis for prioritizing options developed during the assessment.

There are a variety of ways to conduct a P2OA, ranging from a simple mass balance to a comprehensive assessment. The most comprehensive assessment is the Process Specific Opportunity Assessment, which involves compliance risk analysis and detailed economic evaluation. The type of P2OA performed depends upon the complexity of the problem to be studied, and the potential return-on-investment. Most P2OAs involve the following steps:

1. Identify and select the process to be evaluated;

2. Select the P2OA team;

3. Examine the process;

4. Establish a baseline of material usage and waste generation;

5. Identify opportunities for improvement;

6. Rank opportunities based on criteria such as cost, health and safety, environmental impact, feasibility, and impact on mission; and

7. Recommend opportunities for implementation.

CEV identifies processes to be evaluated, provides the lead on the P2OA team, and helps ensure cost-effective P2 opportunities are implemented.

9.2 Green Procurement Program Federal agencies are required to procure environmentally preferable products as a means to conserve resources, reduce product lifecycle costs, and stimulate markets for alternative products and recycling. The CEV website http://www.abwem.wpafb.af.mil/ contains a wealth of information on Green Procurement resources, including links to guidance documents, policy letters, regulatory drivers, and educational materials. The United States Environmental Protection Agency (EPA) Database of Environmental Information for Products and Services at http://yosemite1.epa.gov/oppt/eppstand2.nsf provides information on products and services with reduced environmental impacts.

WPAFB established the Green Procurement Working Group (GPWG), which is chaired by the CEV GPP Manager. The GPP Manager provides technical guidance in explaining the program requirements, guides the GPWG in setting and achieving GPP goals, and assists HAZMAT users in identifying green products.

Previously known as the Affirmative Procurement Program, the GPP has three mandatory program elements that affect HAZMAT users. These mandatory programs involve the preferential purchase of biobased products, ODS alternatives, and substitutes for EPA priority chemicals.

9.2.1 Biobased Products Biobased products are renewable domestic agricultural materials that generally do not contain synthetics, toxins, or environmentally damaging substances. Use of biobased products provide markets for U.S. farm products and help reduce dependence on fossil

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energy (particularly imported oil), which contributes to U.S. energy, economic and environmental security.

Some biobased products such as citrus solvents are currently commercially available. The U.S. Department of Agriculture will be publishing and updating a list of biobased products that Federal agencies must purchase, once these products become available. Biobased product groupings that may affect WPAFB HAZAMAT users include:

• Lubricants and functional fluids • Paints and coatings • Cleaners and solvents

The GPP monitors availability of biobased products and provides information to HAZMAT users on potential substitutes.

9.2.2 Ozone Depleting Substance Alternatives The Significant New Alternatives Policy Program is EPA’s program to evaluate and regulate substitutes for ODS. The purpose of the program is to allow a safe, smooth transition away from these substances by identifying substitutes that offer lower overall risk to human health and the environment. EPA has identified a large number of ODS alternatives, and provides information on these alternatives at http://www.epa.gov/ozone/snap/.

The Significant New Alternatives Policy Program has reviewed substitutes for the following sectors that are of interest to HAZAMT users:

• Refrigeration and Air Conditioning • Cleaning Solvents • Fire Suppression and Explosion Protection • Aerosols • Adhesives, Coatings and Inks • Foam Blowing Agents

Products containing Class I and Class II ODS are still in use at WPAFB, mostly as aerosol propellants. Many of these products may be easily replaced to reduce environmental risk without adversely affecting mission capability. The GPP works with HAZMAT users of products containing ODS to identify appropriate environmentally preferred alternatives.

9.2.3 Substitutes for EPA Priority Chemicals EPA developed a list of priority chemicals used by the Federal Government that have significant health or environment risk and that have known, less harmful, and readily available substitutes. EPA recommended that Federal agencies begin their efforts by focusing on:

• Cadmium • Lead • Polychlorinated biphenyls (PCBs) • Mercury • Naphthalene

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EPA, the Air Force, and the GPP have made these five chemicals a top priority for substitution. These chemicals are a subset of the 31 priority chemicals that EPA has targeted for reduction. More information is found at http://www.epa.gov/epaoswer/ hazwaste/minimize/chemlist.htm.

The WPAFB P2 Program has an ongoing effort to reduce mercury usage and promote recycling of elemental mercury. Alternatives are available for thermometers, thermostats, switches, and other mercury devices. The GPP investigates the use of mercury and other priority chemicals, and helps identify appropriate, environmentally preferable alternatives.

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A Guidelines for Chemical Compatibility and Storage of HAZMATs B Form 1465—Installation Hazardous Material Issue Point Storage Permit C Form 1407—Zone/Employee Input D Form 1408—Supervisor/Employee Movement Input E HAZMAT Issue Point Operating Instruction Outline F Suggested Outline for SSSP for the Issue Point G Hazardous Material/Hazardous Waste Out-Processing Record H How EPCRA Exemptions are Determined I Training Requirements and Frequencies Reference Table J Record Requirements AF Form 55

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Appendix A Guidelines for Chemical Compatibility and

Storage of HAZMATs

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Chemical Compatibility and Storage of

Hazardous Materials

Introduction This document contains safety guidelines and reference information for the storage of hazardous materials in a contained area. If you have any questions, please contact the Hazardous Material (HAZMAT) Cell at (937) 257-9898. The storage of hazardous materials is regulated to minimize the hazards to building occupants and response personnel during emergencies and to ensure building construction and facilities are appropriate for the types and amount of hazardous materials stored.

Chemical Storage Guidelines Incompatible materials need to be segregated and stored separately in compatible groups. The guidelines below outline some basics of chemical storage. Hazard classification information helps in identifying storage groups; however, be aware that there are many materials in the same basic class that have specific incompatibilities. Check the Chemical Compatibility Storage Table (see Table 1) for examples of chemicals in the various compatibility groups. Contact the HAZMAT Cell if you have questions about the compatibility of specific chemicals.

• Do not store chemicals alphabetically, except within a hazard class • The fire code requires segregation of chemicals by hazard class • Pay attention to specific chemical incompatibilities • Keep flammables by themselves in approved storage cans or cabinets • Keep acids away from bases • Separate organics from inorganics • Store oxidizers away from flammables • Do not store corrosive materials in metal shelves • Separate combustibles from oxidizers or any source of ignition • Store strong oxidizers away from potential sources of fuel such as paper or cardboard packaging • Provide 8 to 10 inches of physical separation between classes, or as permissible by storage area • Radioactive materials should be properly labeled and stored as a group • Biohazards should be properly labeled and stored together as a group • OSHA Regulated Carcinogens (see page 3) must be properly labeled and segregated • Store large bottles and containers close to the floor • Store acids and caustics below eye level • Shelves should be bolted to the wall • Shelves should have lips or restraining cords to prevent bottles from falling • Storage areas should be well lit, properly ventilated and have an even temperature • Use secondary containment for spill containment whenever possible • Keep an appropriate spill kit nearby

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Table 1. Chemical Compatibility Storage Table Chemicals should be segregated into compatible groups when stored in the laboratory space or in a contained area. Use the following groups as a guide. Contact the HAZMAT Cell if you have questions about the compatibility of specific materials.

Material Group Definitions Examples 1. Combustible / Flammable Organic Liquids

Materials with a flash point <200 degrees Fahrenheit.

Hydrocarbons, alcohols, aldehydes, ketones, esters, acetonitrile, pyridine

2. Organic acids Organic substances that produce one hydrogen ion when they are put into solution.

Acetic, citric, lactic, oxalic, trichloroacetic, formic acids (carboxylic acids).

3. Organic bases Organic gases or very volatile liquids that when enter in contact with water, produce a caustic (corrosive) solution.

Alkylamines, aniline, heterocyclic bases.

4. Corrosive – Acids Materials with a pH<3 Sulfuric acid, hydrochloric acid.

5. Corrosives - Bases Materials with a pH>12 Sodium hydroxide (caustic soda).

6. Oxidizers Materials that may cause or enhance the combustion of other materials

Sodium peroxide, potassium peroxide, magnesium peroxide.

7. Poisons Materials which are toxic, but not flammable, corrosive, oxidizing or reactive, but can severely affect the health of a human being.

Arsenic, arsenate or lead, sodium arsenate, copper acetoarsenite (Paris green), carbon monoxide, nitric oxide.

8. Cyanides Materials if in contact with corrosives may generate cyanide gas.

Zinc cyanide, calcium cyanide, and potassium cyanide.

9. Peroxide formers Organic materials that due to autooxidation, react and produce peroxides.

Ethyl ether, tetrahydrofuran, dioxane, and butadiene.

10. Water reactive Materials that emit toxic fumes or catch fire when in contact with water.

Alkali organometallics, aluminum chloride, acyl halides, anhydrides, all sulfur-chloride (S-Cl) functionalities, some nitrogen containing compounds, carbides, phosphides, and phosphines.

13. Organic peroxides Peroxides which are capable of deflagration, but not detonation. These peroxides present a high explosion hazard through rapid decomposition.

Benzoyl peroxide, methyl ethyl ketone (MEK)

14. Explosives Homogeneous mixtures of solids, or liquids and solids that when exposed to a suitable energy activator, they rapidly and violently decompose, releasing large volumes of gas and heat.

Dry picric acid, out-of-date peroxide formers, heat-and-shock-sensitive materials.

15. Radioactive A material that spontaneously emits ionizing radiation.

Uranium, Plutonium.

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OSHA Regulated Carcinogens 2-Acetylaminofluorene Acrylonitrile 4-Aminodiphenyl Arsenic and inorganic arsenic compounds Asbestos Benzene Benzidine (and its salts) Bis-Chloromethyl ether 1,2-dibromo-3-chloropropane (DBCP) 1,2-Dibromomethane 3,3’-dichlorobenzidine (and its salts) 4-dimethylaminoazobenzene Ethylene oxide Ethyleneimine Formaldehyde Lead and inorganic lead compounds Methyl chloromethyl ether Alpha-Naphthylamine Beta-Naphthylamine 4-nitrobiphenyl N-nitrosodimethylamine Beta-Propiolactone 4-4’-Methylenebis (2-chloroaniline) Vinyl chloride

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Appendix B Form 1465—Installation Hazardous Material

Issue Point Storage Permit

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INSTALLATION HAZARDOUS MATERIAL ISSUE POINT STORAGE PERMITORGANIZATION OFFICE SYMBOL CONTROLLING ISSUE POINT # EXPIRATION DATE

LOCATIONAREA BUILDING NUMBER ROOM NUMBER

MATERIAL SAFETY DATA SHEETS AVAILABLE AT

SPILL PLAN POSTED:

PERSONNEL PROTECTIVE EQUIPMENT LOCATED AT:

SPILL KIT LOCATED:

ISSUE POINT MANAGER: ALTERNATE ISSUE POINT MANAGER:

NOTES/RESTRICTIONS/10 DAY INVENTORY QUANTITY

UNIT ENVIRONMENTAL COORDINATORNAME TITLE PHONE

SIGNATURE DATE

88 ABW/EMNAME TITLE PHONE

SIGNATURE DATE

74 AMDS/SGPBNAME TITLE PHONE

SIGNATURE DATE

ASC/SEGNAME TITLE PHONE

SIGNATURE DATE

88 CEG/CEFTNAME TITLE PHONE

SIGNATURE DATE

WPAFB FORM 1465, 19990401 (IMT-V1)

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Appendix C Form 1407—Zone/Employee Input

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1. HAZMAT TRACKING NUMBERZONE/EMPLOYEE INPUT

PRIVACY ACT STATEMENTAUTHORITY: Sections 133, 1071-87, 3012, 5031, 8012, title 10, United States Code and Executive Order 9397.PRINCIPAL PURPOSE: Personal information will facilitate and document your health care. The SSN of a member or sponsor is required to identify andretrieve health records.ROUTINE USE: Primary use of this information is to provide, plan, and coordinate health care. As prior to enactment of the Privacy Act, other possibleuses are to aid in preventative health and communicable disease control programs and report medical conditions required by law to federal, state, andlocal agencies; compile statistical data; conduct research; teach; determine suitability of persons for service or assignments; adjudicate claims ordetermine benefits; other lawful purposes, including law enforcement and litigation; conduct authorized investigations; evaluate care rendered;determine professional certification and hospital accreditation; provide physical qualifications of patients to agencies of federal, state, or localgovernment upon request in the pursuit of their official duties.DISCLOSURE: Voluntary. Failure to disclose requested information will prevent system updates from being made and denial of this request in itsentirety.

2. ZONE 3. WORKPLACE TITLE (Description) 4. DATE SUBMITTED

5. ORGANIZATION 6. OFFICE SYMBOL 7. BUILDING/AREA

8. ZONE NARRATIVE/DESCRIPTION OF POTENTIAL USAGE

8A. WHAT MATERIALS, HAZ CODE 'C', ARE USED IN THIS ZONE (i.e. solvents, paints, oils, greases, acids, etc.)

8B. WHAT TYPE OF PROCESSES ARE BEING PERFORMED IN THIS ZONE ( i.e., painting, degreasing, corrosion prevention, etc.)

8C. HOW IS THE ABOVE HAZARDOUS MATERIALS APPLIED (sprayed, brushed, with a cloth, used in vat or dip tank, etc.)

8D. HOW MANY PEOPLE ARE INVOLVED IN THE PROCESSES/TASKS DESCRIBED ABOVE

REQUESTER/SUPERVISOR DATA9A. LAST NAME 9B. FIRST NAME 9C. PHONE

REQUESTER

10A. LAST NAME 10B. FIRST NAME 10C. MI 10D. SSN 10E. SIGNATUREZONE SUPERVISOR

11A. LAST NAME 11B. FIRST NAME 11C. MI 11D. SSN 11E. PHONESUPERVISOR OFZONE SUPERVISOR

UNITENVIRONMENTALCOORDINATOR

12A. LAST NAME 12B. SIGNATURE

13A. LAST NAME 13B. SIGNATUREISSUE POINTMANAGER

14. EMPLOYEE DATA

LAST NAME FIRST NAME MI SSN RANK/GRADE JOB TITLE

15. REMARKS

16. HAZMAT (Data Entry Clerk) 17. DATE COMPLETED

WPAFB FORM 1407, 19970701 (IMT-V1)

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14. EMPLOYEE DATALAST NAME FIRST NAME MI SSN RANK/GRADE JOB TITLE

WPAFB FORM 1407, 19970701 (Reverse)

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Appendix D Form 1408—Supervisor/Employee Movement

Input

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1. HAZMAT TRACKING NUMBERSUPERVISOR/EMPLOYEE MOVEMENT INPUT

PRIVACY ACT STATEMENTAUTHORITY: Sections 133, 1071-87, 3012, 5031, 8012, title 10, United States Code and Executive Order 9397.PRINCIPAL PURPOSE(s): The personal information will facilitate and document your health care. The SSN of a member or spouse is required to identifyand retrieve health records.ROUTINE USE(s): The primary use of this information is to provide, plan, and coordinate health care. As prior to enactment of the Privacy Act, other possible uses are to aid in preventative health and communicable disease control programs and report medical conditions required by law to federal,state, and local agencies; compile statistical data; conduct research; teach; determine suitability of persons for service or assignments; adjudicateclaims or determine benefits; other lawful purposes, including law enforcement and litigation; conduct authorized investigations; evaluate care rendered;determine professional certification and hospital accreditation; provide physical qualifications of patients to agencies of federal, state, or localgovernment upon request in the pursuit of their official duties.

DISCLOSURE: Voluntary. Failure to disclose requested information will prevent system updates from being made and denial of this request in itsentirety.

2. REQUESTER NAME 3. PHONE 4. DATE SUBMITTED

5. SUPERVISOR (Name/Grade) 6. SUPERVISOR SIGNATURE 7. SUPERVISOR SSN

8. ORGANIZATION 9. OFFICE SYMBOL 10. BLDG/AREA 11. PHONE

12. IPM LAST NAME 13. IPM SIGNATURE 14. UEC LAST NAME 15. UEC SIGNATURE

16. EMPLOYEE MOVEMENT DATA

*NOTE: If a supervisor is being moved or deleted a replacement supervisor must be annotated. ZONE DATA*

NAME (Last, First, MI) SSN JOB TITLE FROM TO ADD DELETE

17. REMARKS

18. HAZMAT (Data Entry Clerk) 19. DATE COMPLETED

WPAFB FORM 1408, 19970701 (IMT-V1)

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16. EMPLOYEE MOVEMENT DATA*NOTE: If a supervisor is being moved or deleted a replacement supervisor must be annotated. ZONE DATA*

NAME (Last, First, MI) SSN JOB TITLE FROM TO ADD DELETE

WPAFB FORM 1408, 19970701 (Reverse)

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Appendix E HAZMAT Issue Point Operating Instruction

Outline

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Appendix E E.1 Developing a HAZMAT Issue Point Operating Instruction (OI) Each Large Quantity User will be required to develop an Operating Instruction (OI) detailing day-to-day HAZMAT management procedures. Figure F-1 provides a recommended outline for the OI and lists the minimum requirements that must be met for the development of a successful Issue Point operation. This outline is only a suggested format, however, any OI developed must meet all of the requirements of this outline. Introduction Purpose Explain the purpose and overall objective of the HAZMAT Management Program. Text from Section 1.0 of the HMMP can be modified to meet the specific needs of each organization’s program. Organization Description Provide a description of the overall mission of the organization. Provide a brief description of individual shops and laboratories that operate within the organization that utilize HAZMAT. Process Description Develop a list of the processes or operations that operate within the organization. Along with each process description, a table should be developed that lists the Hamates used in the process along with the MSDS number assigned by the HAZMAT Tracking System, National Stock Number, MIL SPEC number if applicable, and the estimated annual usage quantities. Figure F-2 provides an example table. An MSDS for each HAZMAT should be placed in an attachment of the OI in consecutive order by MSDS number. Obtaining HAZMAT All HAZMAT shall be procured through the IPM for the organization. This section should provide detailed instructions for making internal HAZMAT requests. This should include POCs, phone numbers, and any applicable forms required to procure HAZMAT. These procedures should be developed for Government Purchase Cards and Base Supply HAZMAT procurements. Receipt, Labeling, and Storage of HAZMAT Receipt and Labeling This section should define how HAZMAT is received and labeled by organization for each procurement process (Government Purchase Cards and Base Supply). The following requirements must be incorporated in the OI. • HAZMAT, greater than 30 gallons or quantities less than 1 quart for acutely hazardous

materials, purchased with Government Purchase Cards shall be delivered directly to the IP. • HAZMAT purchased from local retailers, that is less than 30 gallons or less than the

reportable quantity (whichever is smaller), may be transported on Base in government owned vehicles by military or Dodd personnel. HAZMAT in quantities greater than 30 gallons or greater than the reportable quantity must be delivered by the supplier.

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• Transporting HAZMAT on base in privately owned vehicles is strictly prohibited regardless of the quantity of the HAZMAT being transported.

• Labels must be applied to all HAZMAT containers within one working day of receipt of the material by the IPM.

Storage Locations This section provides a list of approved storage locations for HAZMAT maintained by the organization and the names and phone numbers of the IPM and their alternate. IPs should maintain a 10-day storage supply or the smallest quantity possible of the HAZMAT used in their daily operations. Each IP should develop a table that lists the HAZMAT used for each process along with the 10-day usage quantity. The table should also note any conditions, either seasonal or operational, that would affect the storage quantities. Figure 2 provides an example. Shelf-life management issues should be addressed along with procedures that ensure that materials are used in the order they are received. This will ensure that materials are used before their shelf-life expires. The OI should include or reference Spill Plans prepared for the storage areas. Guidance for the development of Spill Plans is provided in Attachment F of the IHMP. Distribution and Tracking of HAZMAT for Industrial Activities Provide a description of the methods used to issue and track the use of HAZMATs within your IP. Inventories will be performed twice a year in May and September.

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Distribution and Tracking of HAZMAT for Laboratories Air Force Research Laboratory (AFRL) has established procedures for the storage and distribution of HAZMATs. Under this plan HAZMATs can be stored in the user’s laboratory for extended periods. Due to the small quantities of materials used for most activities, usage quantities will not be updated on a daily basis. Inventories will be performed twice a year in May and September. Development of an IP Continuity Binder Each IP will maintain a continuity binder that will contain the following:

- Site-Specific Issue Point OI - Manufacturer’s Material Safety Data Sheets (MSDS) - Physical Inventory prepared in March and September - Licenses - Zones and Employees - Shelf Life Extension Data - Miscellaneous

Redistribution/Disposal of Excess HAZMAT This section should provide information on the redistribution of HAZMAT on base through the Excess Material System and off-site agencies. Information in Section 4.1.7 of the IHMP can be modified for the development of this section.

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1.0 Introduction 1.1 Purpose of OI 1.2 Organization Description 1.3 Processes 1.3.1 Process 1 Description HAZMAT Used MSDS Number National Stock Number Estimated Annual Usage Quantities

1.3.2 Process 2 Description HAZMAT Used National Stock Number MSDS Number Estimated Annual Usage Quantities

2.0 Obtaining HAZMAT 2.1 Government Purchase Cards Orders 2.2 Base Supply 3.0 Receipt, Labeling, and Storage of HAZMAT 3.1 Receipt 3.2 Labeling 3.3 Storage of HAZMAT Storage Location Shelf-life Management Spill Plan 4.0 Distribution and Tracking of HAZMAT 5.0 Development of a Continuity Binder 6.0 Redistribution/Disposal of Excess HAZMAT

Appendix A – MSDSs

Figure E-1. Recommended OI Outline.

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Process Name

MSDS #

NSN

MIL-SPEC Annual Usage

Quantity 10-day Storage

Quantity

Comments HAZMAT 1 HAZMAT 2 HAZMAT 3 HAZMAT 4

Figure E-2. Example of Process Material Usage Table.

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Appendix F Suggested Outline for SSSP for the Issue Point

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Site Specific Spill Plan (Sample Format)

OFFICE SYMBOL: DATE: LOCATION: TELEPHONE: ACTIVITY: Notification and Initial Response (For site specific organizations this may be broken out into categories of major, moderate or minor spills) 1. Evacuate Area 2. Phone 911 3. Make internal organizational notifications as deemed necessary (supervisor, UEC, etc.) 4. Determine and contain source of spill when possible without undue risk of personal injury. If the

nature of the spill material is unknown, evacuate area immediately. 5. Restrict all sources of ignition when flammable substances are involved without undue risk to

personal injury 6. Report to acting on-scene coordinator upon spill response team arrival and provide assistance

until response team is fully operational Response Information (When notifying fire department, the following information should be provided if known or can reasonably be determined.) 1. Name of individual reporting spill 2. Location of Spill 3. Number of personnel injured and the nature of injuries 4. Name of material spilled/released (may utilize MSDS) 5. Amount spilled 6. Hazard Information 7. Extent spill has traveled 8. Time incident occurred 9. Any other pertinent information (i.e., other potential hazards) Emergency Response Equipment/Procedures (Any equipment or procedure that minimizes the possibility or severity of leakage or spillage should be documented: routine inspections, secondary containment, preventive maintenance, monitoring and security.) 1. List of spill equipment (i.e., fire extinguisher, booms, absorbent, etc.) 2. Location of spill equipment (must be accessible in the event of a spill) 3. How utilized for specific spill 4. Material Safety Data Sheets 5. Warning signs posted where hazardous chemicals are stored or handled

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Description of Site 1. Room location, ventilation, sprinkler system, secondary containment (a map would be

helpful) 2. Material/Waste Stored (If this is a base supply activity indicate by listing that the site

contains acids/flammables/corrosives/explosives etc.) Probable Spill Route Describe where spill may travel (floor drains, sanitary sewer, storm drain and what final destination as in what outfall it may enter). If drain is identified as a sanitary sewer it flows into the WasteWater Treatment Facility. If the drain is identified as a storm drain you will need to contact Record Drawings at Building 11, Area C and retain a map of storm drains associated with your building. Information is needed on what body of water the drain eventually empties into (e.g., Outfall NPDES point 004). Posting Requirements 1. Hazard Warning Information/Signs/Placards (hazard storage area, flammable, corrosive, etc.) 2. This site specific spill plan will be posted in a prominent location or locations within the

potential spill area. This spill plan should be updated on an annual basis or anytime there is a change in operations or materials stored or at any time the plan has failed. The spill plan shall be coordinated though 88 ABW/EM.

Unit Environmental Coordinator Signature Date EM Signature Date

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Appendix G Hazardous Material/Hazardous Waste Out-

Processing Record

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HAZARDOUS MATERIALS/HAZARDOUS WASTE OUT-PROCESSING RECORD

INSTRUCTIONS TO THE SUPERVISOR

All persons involved in the use of hazardous materials must complete this form at least one-week prior to the individual’s out-processing from your organization. This applies to all military and civilian government employees. The out-processing individual must ensure that all hazardous materials, hazardous waste, and solid waste are properly transferred and managed before out-processing is approved. 1. Employee Name

2. Last Day of Work

Yes N/A Clearance Actions for Out-Processing 3. All hazardous materials has been turned into the designated issue point (IP) for storage

and re-issue. 4. All hazardous and solid wastes have been properly identified, labeled, and stored in an

Initial Accumulation Point (IAP). All waste turn-in forms have been properly completed, coordinated with the Unit Environmental Coordinator (UEC), and forwarded to EM.

5. If the individual out-processing is a primary or alternate IAP manager, another individual has been appointed to this position by unit commander and a revised IAP Permit has been submitted.

6. If the individual out-processing is a primary or alternate IP manager, another individual has been appointed by unit commander.

CERTIFICATION SIGNATURES

I CERTIFY THAT THE EMPLOYEE HAS COMPLETED ALL NECESSARY CLEARANCE ACTIONS LISTED ABOVE AND THAT ALL HAZAROUS MATERIALS, AND WASTES HAVE BEEN PROPERLY DISPOSITIONED. 8. Supervisor Signature Org Symbol Phone Date

9. Issue Point Manager’s Signature Date

10. Primary or Alternate IAP Manager’s Signature Date

11. Unit Environmental Coordinator Signature Date

12. Employee’s Signature Date

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Appendix H How EPCRA Exemptions are Determined

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Contractor EPCRA Reporting Requirements On 3 August 1993, President Clinton signed Executive Order (EO) 12856 requiring federal facilities to comply with the planning and reporting provisions of EPCRA. On 21 April 2000, EO 13148 was signed. EO 13148 builds on the successes of EO 12856 and continues the requirement for EPCRA compliance by federal facilities. Specifically, EO 13148 applies to federal facilities in any state of the United States, the District of Columbia, the Commonwealth of Puerto Rico, Guam, American Samoa, the U.S. Virgin Islands, the Northern Mariana Islands, and any other territory or possession over which the United States has jurisdiction. The following discusses when EPCRA regulatory requirements (if any) are applicable to contractors conducting work (which requires the use of hazardous materials) at WPAFB. The following types of contractors conducting efforts at WPAFB are addressed herein:

• Construction – contractors who perform major construction projects such as building and repairing roads, walkways, buildings, and installation of major process equipment;

• Facility Maintenance – contractors who maintain base HVAC equipment, process equipment (e.g., cleaning oil water separators) or perform minor building maintenance functions;

• Janitorial – contractors used to clean base office spaces and restrooms; • Laboratory Support – contractors supporting Laboratory Research and

Development work needed to support Department of Defense activities (e.g., Air Force Research Laboratories);

• Vehicle Maintenance – contractors used to maintain base vehicles (e.g., cars, small trucks, emergency vehicles, heavy construction equipment); and

• Food Service – contractors who operate base restaurants, cafeterias and lunch rooms.

General Overview of EPCRA regulatory reporting requirements to which WPAFB Contractors must comply: Emergency Release Notification - Section 304 (40 CFR 355): All contractors should immediately report any spill involving a hazardous material (as a result of an accidental release incident) to the WPAFB Office of Environmental Management (WPAFB EM). WPAFB will make the determination as to whether notifications are required. Under EPCRA Section 304, if there is a release of an EPCRA Extremely Hazardous Substance (EHS) or CERCLA Hazardous Substance (HS) within a 24-hr period that exceeds the reporting quantity (RQ) for that chemical WPAFB must notify the SERC and LEPC immediately. If the release involves a CERCLA HS, immediate notification of the National Response Center (NRC) is also required. WPAFB is also required to expeditiously follow up the verbal notification with a written report on the actions taken and any health effects associated with the release to both the SERC and LEPC.

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Failure to follow the EPCRA Section 304 and CERCLA HS notification procedures in a timely manner may result in fines of up to $500,000 and prison sentences of up to 3 years. EPA strictly enforces the immediate reporting requirement. Section 304 release notification requirements do not apply to releases that fit into any of the following six categories:

1. Releases that result in exposure to persons solely within the boundaries of the facility (notification is still required to the NRC under CERCLA).

2. Federally permitted releases as defined in Section 101 (10) of CERCLA. For WPAFB, this exclusion applies typically to releases covered by 1) an NPDES permit, 2) a CAA permit, and 3) releases in compliance with applicable categorical pretreatment standards and local limits and into a POTW with an approved pretreatment program.

3. Continuous releases as defined in 40 CFR 302.8(b). A continuous release is a release of a hazardous substance that is "continuous" and "stable in quantity and rate." Notification of continuous releases that equal or exceed the RQ need only be given annually to the NRC and whenever there is a statistically significant increase in the quantity being released.

4. Any release of a pesticide product exempt from CERCLA Section 103(a) reporting under Section 103(e) of CERCLA.

5. Any release not meeting the CERCLA Section 101(22) definition of release. These include releases resulting in exposures to persons solely in the workplace, motor vehicle emissions, nuclear incidents governed by the Atomic Energy Act, and the normal application of fertilizer.

6. Any radionuclide releases occurring naturally from soil or land disturbance activities (except those associated with uranium, phosphate, tin, zircon, hafnium, vanadium, monazite, and rare earth mines) or from coal ash storage and handling.

EPCRA Section 304 Contractor Applicability Assessment As shown above, there are no exemptions which can be applied to contractor activities in general under this regulation. The following are assessments as to the potential that a particular contractor could trigger reporting under Section 304. Construction Contractors – hazardous materials typically utilized by construction contractors will include items such as lubricants, greases, paints, solvents, adhesives, flammable (e.g., propane, acetylene) and inert compressed gases (e.g., argon, helium). Construction contractors may also use liquid petroleum products such as gasoline, diesel fuel, and kerosene to operate fuel burning equipment. Construction contractors are not expected to trip reporting under EPCRA 304. The hazardous materials they maintain on-hand are not expected to contain EHS or CERCLA HS in quantities needed to trip reporting. For example, construction contractors typically do not to use hazardous materials which contain EHS chemicals such chlorine gas, nitric

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acid, or sulfuric acid. In addition, spills involving paints which can contain CERCLA HS are also not expected to trip reporting since releases would need to exceed approximately 100 gallons (e.g., paint is typically not purchased in containers larger than 5 gallons). Spills involving pure solvents such as xylene (having an RQ of 100 pounds) are also not expected to exceed reporting thresholds. Releases of pure solvents used for paint application purposes would need to exceed approximately 15 gallons. Regarding the use of bulk fuels, CERCLA definitions of a hazardous substance also excludes from reporting releases of petroleum products. EPA interprets this provision to exclude crude oil, fractions of crude oil, including hazardous substances, such as benzene, that are inherently present in petroleum. Under this interpretation, blended gasoline, jet fuel, kerosene, diesel fuel, are within the scope of the petroleum exclusion. Therefore, since fuels do not contain EHS chemicals and are excluded under CERCLA, fuel spills are not reportable under EPCRA 304. Please note, that although the petroleum exclusion exempts releases of petroleum products under CERCLA and EPCRA, it may not be exempt under some other State or other federal notification requirement (e.g., releases to water regulated under the Clean Water Act). Facility Maintenance – hazardous materials typically utilized by facility maintenance contractors are materials needed to maintain base facilities (minor building repairs) and equipment such as cooling towers, heating plants, swimming pools, and HVAC equipment. Hazardous materials used include water treatment chemicals, refrigerants, and liquid chlorine. Minor amounts of paints, solvents, adhesives, and greases may also be used to conduct minor building repairs. Facility maintenance contractors are likely to have hazardous materials which contain EHS chemicals. Examples include sulfuric acid and cyclohexylamine which are used to treat water used in cooling towers and boilers. Since these chemicals are stored in tanks or in 55 gallons drums, reporting thresholds could easily be tripped in the event of an accidental release. Janitorial – hazardous materials typically utilized by these contractors include air fresheners, glass cleaners, liquid bleach, furniture polish, toilet bowl cleansers, floor waxes and polishing materials. Janitorial contractors are not expected to trip reporting under EPCRA 304 because the hazardous materials they maintain on-hand are not expected to contain EHS or CERCLA HS in quantities needed to trip reporting. Since these materials are used in occupied areas and typically are hand applied when used, the potential presence of an EHS (e.g., listed acid such as sulfuric) or CERCLA HS (e.g., listed organic solvent such as xylene) in quantities that would trip reporting in the event of an accidental release is unexpected. Laboratory Support – these are contractors supporting AFRL Department of Defense research and development studies. Work conducted by these laboratories includes a vast range of studies including human toxicology, aerospace propulsion, weapons development, and human engineering and design. As such, a variety of hazardous

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materials may be used including animal extract chemicals, flammable and inert compressed gaseous, paints, solvents, greases, aircraft lubricants, hydraulic fluids, jet fuel, adhesives, and laboratory chemicals. Laboratory contractors, due to research purposes, are likely to use hazardous materials which could contain an EHS or CERCLA HS. In addition, these chemicals could be stored in quantities at or near reporting thresholds. An example includes the chemical mercury which is commonly found in thermometers and pressure measurement devices used in chemistry labs. With a reporting threshold of only 1 pound, an accidental release of mercury could easily be tripped. Vehicle Maintenance – these contractors maintain base passenger vehicles (e.g., cars, trucks, heavy equipment, and emergency vehicles). During the maintenance and servicing of vehicles, hazardous materials used include engine oil, transmission fluid, break fluid, vehicle antifreeze, and automotive paints. Compressed gaseous such as acetylene, oxygen, and air conditioning refrigerants (e.g., Freon 12, HCFC-134A) may also be used. Vehicle Maintenance contractors are not expected to trip reporting under EPCRA 304. The hazardous materials they maintain on-hand are not expected to contain EHS or CERCLA HS in quantities needed to trip reporting. Sulfuric acid contained in battery electrolyte is the only EHS typically found in hazardous materials used to service vehicles. Releases involving battery electrolyte are not anticipated to ever exceed 250 gallons. This is the release quantity needed in order to trip the reporting threshold for sulfuric acid (RQ of 1,000 pounds). In addition, spills involving paints which contain CERCLA HS are also not expected to trip reporting since releases would need to exceed approximately 100 gallons (e.g., vehicle paints are typically purchased in containers no larger than 1 gallon). Spills involving pure solvents such as xylene (having an RQ of 100 pounds) are also not expected to exceed reporting thresholds. Releases of pure solvents used for vehicle paint application purposes would need to exceed approximately 15 gallons. A potential release of a large quantity of antifreeze (e.g., approximately >500 gallons), which contains the CERCLA HS ethylene glycol (RQ of 5,000 pounds), is also not anticipated. Food Service – these contractors operate base cafeterias and lunch rooms. These contractors may utilize a small amount of hazardous materials such as cleaners and soaps used for washing eating utensils, dishes, cooking pans, and eating areas. As such, it is highly unlikely that these materials would contain an EHS or CERCLA HS. As such, reporting under EPCRA 304 due to the use of hazardous materials by Food Service contractors is not anticipated. Hazardous Chemical Inventory Reporting – Section 311 –MSDS and Section 312 – Tier II Form (40 CFR 370). Section 311 is applicable to a facility if you are required to prepare or have available an MSDS for a hazardous chemical under the OSHA Hazard Communication Standard (29 CFR 1910.1200). The purpose of Section 311 is to provide general hazard information to local and state emergency planners that allow them to

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prioritize facilities for planning efforts. Section 311 requires the submission of MSDSs or a list of MSDSs for all hazardous chemicals present on site at any one time in quantities greater than or equal to 10,000 pounds and any EHS in quantities greater than or equal to 500 pounds or their TPQ, which ever is less. Reports are a one-time submission to the SERC, LEPC, and local fire department with jurisdiction over the facility. Updates are provided only as needed for new hazard data or new substances exceeding a threshold. Updates to the Section 311 submittal are required to be reported within 90 days of additional chemical or EHS has exceeded the TQs. Section 312 – Tier II form reporting requires annual reporting (March 1) of information such as storage location, storage condition, and average daily and maximum amounts on site of HS and EHS that surpass the Section 311 TQs for the previous calendar year. EPCRA 311 and 312 Exemptions (40 CFR 370.2). The following materials or items are not considered hazardous chemicals and are thus exempt for 311 and 312 reporting:

• Food, food additives, color additives, drugs, or cosmetics regulated by the Food and Drug Administration.

• Articles. These include any substance present as a solid in any manufactured item to the extent exposure to the substance does not occur under normal conditions of use. Examples include copper plumbing and machinery. Also, polychlorinated biphenyl (PCB) transformers are considered articles as long as there is no spillage or leakage of the PCBs.

• Substances used for personal, family, or household purposes or present in the same form and concentration as a product packaged for distribution and use by the general public. The term “form” refers to the packaging rather than the physical characteristics of the product.

• Substances used in a research laboratory, hospital, or other medical facility under the direct supervision of a technically qualified individual.

• Substances used in routine agricultural operations or a fertilizer held for sale by a retailer to the ultimate consumer.

• Any hazardous waste as defined by the Solid Waste Disposal Act.

• Tobacco or tobacco products

• Wood or wood products EPCRA Section 311 and 312 Contractor Applicability Assessment As shown above, there are several exemptions which can be applied to contractor activities under this section of the regulation. The following are assessments as to the potential that a particular contractor could trigger reporting under Section 311 and 312. Construction Contractors – the vast majority of hazardous materials (with the exception of fuels) utilized by construction contractors are exempt under the article or the household or consumer item exemption. As such, construction contractors are not expected to trip reporting under EPCRA 311 and 312. Therefore, collection of hazardous

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material inventory data from construction contractors is not warranted. However, if a contractor has on-hand greater than 10,000 pounds of any one hazardous material (e.g., large lay down area project) or maintains on-hand a fuel (e.g., gasoline, diesel fuel, kerosene, and propane), inventory and MSDS data should be provided to the WPAFB EM office. Facility Maintenance - Facility maintenance contractors are likely to have hazardous materials which contain EHS chemicals (e.g., sulfuric acid used to treat cooling tower water). In addition, these hazardous materials are purchased in bulk and stored in storage tanks or drums in quantities which exceed reporting thresholds. As such, facility maintenance contractors need to report to WPAFB EM office all hazardous chemicals present on site at any one time in quantities greater than or equal to 10,000 pounds and any EHS in quantities greater than or equal to 500 pounds or their TPQ, which ever is less. Janitorial – all of hazardous materials utilized by janitorial contractors are exempt under the household or consumer item exemption. As such, janitorial contractors are not expected to trip reporting under EPCRA 311 and 312. Therefore, collection of hazardous material inventory data from janitorial contractors is not warranted. Laboratory Support – the vast majority of hazardous materials utilized by laboratory support contractors (including fuels) are exempt under the research laboratory exemption. As such, laboratory contractors are not expected to trip reporting under EPCRA 311 and 312. Therefore, collection of hazardous material inventory data from laboratory contractors is not warranted. Vehicle Maintenance – the vast majority of hazardous materials (with the exception of fuels or materials purchased in bulk) utilized by vehicle maintenance contractors are exempt under the article or the household or consumer item exemption. As such, vehicle maintenance contractors are not expected to trip reporting under EPCRA 311 and 312. Therefore, collection of hazardous material inventory data from construction contractors is not warranted. However, if a contractor purchases hazardous material in bulk (e.g., 55 gallon drums) or maintains on-hand a flammable fuel (e.g., gasoline, diesel fuel, kerosene, and propane), inventory and MSDS data should be provided to the WPAFB EM office. Food Service – the vast majority of hazardous materials utilized by food service contractors are exempt under the food, food additives, color additives, drugs, or cosmetics exemption. As such, food service contractors are not expected to trip reporting under EPCRA 311 and 312. Therefore, collection of hazardous material inventory data from food service contractors is not warranted. Toxic Chemical Release Inventory Reporting – Section 313 - Form R Reporting (40 CFR 372). Section 313 of EPCRA requires the submittal of a Toxic Chemical Release Reporting Form (Form R) for all specifically listed chemicals that are manufactured or processed in excess of a threshold of 25,000 pounds per year or otherwise used in excess

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of a threshold of 10,000 pounds per year. There were significant additions to the list of TRI chemicals for reporting year RY2000, as a result of the Persistent Bioaccumulative Toxic (PBT) Chemical final rule published in the Federal Register in October 1999. This rule, effective January 1, 2000, added 15 individual chemicals and three chemical categories to the list of TRI chemicals with lower reporting thresholds (from 0.1 grams to 100 pounds) and special rules for the PBTs. For all chemicals exceeding the threshold, a Form R reporting the releases, off-site transfers, and other required information must be submitted to the U.S. EPA and state regulatory agency by July 1 of the following year. EPCRA Section 313 (40 CFR 372.38) defines the following categories of materials as exempt from reporting. Section 313 chemicals present in materials fitting these category descriptions should not be counted either when determining if reporting thresholds have been exceeded or when estimating environmental releases: EPCRA 313 De Minimis Exemption [40 CFR 372.38(a)] A toxic chemical may be exempted if present in a mixture in concentrations:

• Less than 1% (by weight) or

• Less than 0.1% (by weight), if it is a carcinogen. If a toxic chemical is below the de minimis and exempt, a facility is not required to consider the quantity of the toxic chemical in the mixture when determining a threshold or the amount released of that toxic chemical. It is possible to meet the threshold for a toxic chemical on a facility-wide basis, but not be required to calculate releases from a particular process because that process involves only mixtures containing the toxic chemical below the de minimis level. For mixtures that contain more than one member of a listed toxic chemical category, the de minimis level applies to the aggregate concentration of all such members and not to each chemical individually. EPA included the de minimis exemption in the rule as a burden-reducing step, primarily because facilities are not likely to have information on the presence of a toxic chemical in a mixture or trade name product beyond that available in the product’s MSDS. The de minimis levels are consistent with OSHA requirements for development of MSDS information concerning composition. For threshold determinations, the de minimis exemption applies to:

• A listed toxic chemical in a mixture or trade name product received by the facility or

• A listed toxic chemical manufactured during a process where the toxic chemical remains in a mixture or trade name product distributed by the facility (i.e., an impurity).

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The de minimis exemption does not apply to:

• A toxic chemical manufactured at the facility that does not remain in a product distributed by the facility (i.e., a byproduct). A threshold determination must be made on the annual quantity of the toxic chemical manufactured regardless of the concentration.

• A listed toxic chemical manufactured as a result of waste treatment. For example, quantities of a metal hydroxide created as a result of wastewater treatment must be applied toward the threshold for manufacture of this toxic chemical, regardless of the concentration of this toxic chemical in the wastewater.

• PBT listed EPCRA 313 chemicals.

EPCRA Article Exemption [40 CFR 372.38(b)] Quantities of a listed toxic chemical contained in an article do not have to be factored into threshold or release determinations when that article is processed or otherwise used at a facility. An article is defined as a manufactured item that:

• Is formed to a specific shape or design during manufacture,

• Has end-use functions dependent in whole or in part upon its shape or design during end-use, and

• Does not release a toxic chemical under normal conditions of the processing or otherwise use of that item at the facility.

The article exemption applies to the normal processing or otherwise use of an article. It does not apply to the manufacture of an article. Toxic chemicals processed into articles produced at a facility must be factored into threshold and release determinations. When the processing or otherwise use of an item generates fumes, dust, filings, or grindings, the article exemption is not applicable. The toxic chemical(s) in the item must be counted toward the appropriate threshold determination, and fumes, dust, filings, and grindings must be reported as releases or wastes. Scrap pieces that are recognizable as an article do not constitute a release. It is important to note that, if all other conditions of the article exemption are met and all “releases” (filings, grinding, and scrap) are collected and recycled, then the article exemption remains in tact. If the processing or otherwise use of similar articles results in a total release of less than 0.5 lb of toxic chemical in a calendar year to any environmental media, EPA will allow this release quantity to be rounded to zero, and the manufactured items remain exempt as articles. The 0.5 lb limit does not apply to each individual article, but applies to the sum of all releases from processing or otherwise use of like articles.

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EPCRA Activity Exemptions [40 CFR 372.38(c)] Structural Component Use Exemption 40 CFR 372.38(c)(1) exempts from reporting toxic chemicals that are structural components of the facility or that are used to ensure or improve structural or functional integrity. This exemption applies to listed toxic chemicals in material that are part of the facility’s structure (e.g., copper in copper piping used for the plumbing in the facility) and the facility does not have to account for the releases that result from passive degradation such as that which naturally occurs in structural components of a facility. Maintenance and repair activities performed by facility maintenance to the facility infrastructure are also consistent with the structural component exemption. Painting to maintain the physical integrity or function of the facility is included in the exemption. The exemption also covers small amounts of material passively abraded or corroded from pipes and other facility equipment. The facility infrastructure would include, but not be limited to, building, roads, runways, fencelines, and utilities.

Routine Janitorial/Grounds Maintenance Exemption 40 CFR 372.38 (c)(2) exempts the use of toxic chemicals contained in products for routine janitorial and installations grounds maintenance. The routine maintenance exemption is intended to cover janitorial or other custodial maintenance and all other installation grounds maintenance activities using substances such as cleaning supplies, fertilizers, pesticides, fungicides, herbicides, rodenticides, and insecticides similar in type and concentration to consumer products. Personal Use Exemption 40 CFR 372.38(c)(3) exempts from required reporting the personal use of listed toxic chemicals in products used by employees or other persons at the facility. This exemption also covers activities associated with facility-operated cafeterias, commissaries, DoD Exchanges, medical facilities, or activities associated with Morale, Welfare, and Recreation. Types of products that are used for personal use include, for example, foods, drugs, cosmetics, office supplies, or other personal items. The personal use exemption also covers toxic chemicals used strictly for reasons of personal comfort, necessity, or other such purposes, for example, heating and air conditioning units or lighting fixtures.

Special Note on Hospitals: It is DoD policy that activities associated with hospitals and other base medical facilities are exempt from TRI threshold calculations and release because such activities are exempted under the personal use exemption of the EPCRA regulations.

Motor Vehicle Maintenance Exemption 40 CFR 372.38(c)(4) exempts toxic chemicals contained in products used for the purpose of maintaining motor vehicles operated by a facility. A motor vehicle is anything that can be driven under its own propulsion, such as cars, trucks, and aircraft. Equipment with motors that cannot be driven are not motor vehicles, such as certain pieces of aerospace ground equipment and auxiliary power units. Many different motor vehicle maintenance

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scenarios can exist at a DoD base. The following discussions clarify what activities are and are not exempt:

• Facilities are exempt from reporting the use of toxic chemicals associated with the maintenance of motor vehicles, such as staff cars and base maintenance and support vehicles and privately owned vehicles.

• Personnel maintaining aircraft and vehicles under field conditions are exempt.

• Facilities are not exempt from reporting the toxic chemicals used at the intermediate and depot level for the maintenance of the tactical vehicles, and aircraft (including missiles). Intermediate and Depot levels are defined as follows: Intermediate Level (I-Level): Material maintenance that is the responsibility of, and performed by, designated maintenance activities in support of using organizations. The I-level maintenance mission is to enhance and sustain the combat readiness and mission capability of supported activities by providing quality and timely material support at the nearest location with the lowest practical resource expenditure. I-level maintenance includes limited repair of commodity-oriented components and end items; job shop, bay, production line operations for special mission requirements; repair of printed circuit boards; software maintenance; and fabrication or manufacture of repair parts, assemblies, components, jigs and fixtures, when approved by higher levels. Depot Level (D-Level): Material maintenance requiring major overhaul or a complete rebuilding of parts, assemblies, subassemblies, and end items, including manufacture of parts, modifications, testing, and reclamation as required. Depot maintenance serves to support lower categories of maintenance beyond their responsibility. Depot maintenance provides stocks of serviceable equipment because it has available in lower maintenance activities. Depot maintenance includes all aspects of software maintenance.

• Maintenance below intermediate and depot level (i.e., organizational level) maintenance is exempt. For example, field or organizational level units are exempt from reporting toxic chemicals used in the maintenance of vehicles outside the intermediate and depot level maintenance shop. Similarly, personnel maintaining aircraft and vehicles under field conditions are exempt from reporting their use of toxic chemicals. Organizational level maintenance is defined as follows: Organizational Level (O-Level): Maintenance normally performed by an operating unit on a day-to-day basis in support of its own

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operations. The O-level maintenance mission is to maintain assigned equipment in a full mission-capable status while continually improving the process. O-level maintenance can be grouped under the categories of “inspections,” “servicing,” “handling,” and “preventative maintenance.”

Motor Vehicle Maintenance Exemption Applied for Fuels Up to and including the 2001 reporting year (reports due 1 July 2002), the DoD policy was that the fueling of motor vehicles within DoD was not considered distribution of the fuels into commerce; therefore, it was not processing for purposes of Section 313. As a result, the fueling of motor vehicles is an otherwise use of the toxic chemicals in the fuels. Because it is an otherwise use activity, it is eligible for the motor vehicle maintenance exemption. Whenever fuels were provided to any DoD motor vehicle their use could be exempted under the scope of the motor vehicle maintenance exemption. Beginning with the 2002 reporting year (reports due 1 July 2003), a new policy will take effect. In November 2001, a memorandum was distributed from the DoD TRI Working Group that addresses the fueling of vehicles that are not owned or operated by the base. This new approach is consistent with EPA policy on the subject. The new approach states:

• The distribution and use of fuels within DoD is still considered otherwise use.

• Refueling of motor vehicles, including aircraft, that are owned or under the operational control of the facility is exempt under the motor vehicle maintenance exemption. This includes base vehicles, tenant vehicles, vehicles temporarily under operational control during training, and other situations where there is some operational connection to the installation.

• Refueling of motor vehicles, including aircraft, that are not owned or under operational control of the facility cannot be exempted. The amount of fuel provided to these transient vehicles is considered otherwise used for purposes of Section 313 and toxic chemicals in the fuels must be included in a threshold determination. Purely transient vehicles are, in effect, using the base as a gas station/rest stop.

This new approach to fueling of vehicles is effective for reporting year 2002 reports due in 2003 and the future. It is not necessary to submit amended reports for previous reporting periods.

Emissions from motor vehicles (i.e., products of combustion in exhaust) are still considered exempt and are not considered manufactured for purposes of Section 313.

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Intake Water/Air Exemption 40 CFR 372.38(c)(5) exempts facilities from reporting toxic chemicals present in process water or no-contact cooling water as drawn from the environment or from municipal sources. The exemption also covers toxic chemicals present in air used either as compressed air or as part of combustion.

Laboratory Activity Exemption [40 CFR 372.38(d)] The laboratory activity exemption applies to those listed toxic chemicals manufactured, processed, or otherwise used in a laboratory for quality control, research and development, and other laboratory activities. It is not intended as a blanket exemption for any facility that has the title “laboratory” in its name. To qualify, the listed chemical(s) must be used directly in or produced as a result of a laboratory activity at a DoD facility and the manufacture, processing, or other use must occur under the supervision of a technically qualified individual. Generally, bench-scale activities are considered exempt. Activities that do not directly support research and development, sampling and analysis, or quality assurance and control are not exempt. Specialty chemical production and pilot plant scale activities do not qualify for the laboratory activities exemption. It is important to note that the laboratory activity exemption includes toxic chemicals that are manufactured in a laboratory. As a result, toxic chemicals coincidentally manufactured from laboratory activities are exempt under the scope of the laboratory exemption.

Property Owners of Leased Property [40 CFR 372.38(e)] A federal agency is not required to report for a facility if it merely owns the real estate on which an establishment covered by EPCRA is located; that is, the facility has no “business” interest in the operation of that establishment. The operator of that establishment, however, may be subject to the reporting requirements and is solely responsible for meeting all reporting requirements. For example, the Air Force leases space at an inactive ammunitions plant to a private industry and the Air Force has no control over that industry’s activities. The private company, not the Air Force, would be responsible for reporting on activities conducted on that site.

• De minimis materials - Includes chemicals present in materials below a concen-tration of 1 percent [0.1 percent for carcinogens as defined in the Occupational Safety and Health Administration (OSHA) Hazard Communication Standard (HCS) (29 CFR 1910.1200)]. The list of Section 313 chemicals in the EPA Reporting Instructions identifies the appropriate de minimis level for each chemical. For mixtures that contain more than one member of a listed toxic chemical category, the de minimis level applies to the aggregate concentration of all such members, and not to each individually.

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For threshold determination, the de minimis exemption applies to:

- A listed toxic chemical in a mixture or trade name received by the facility;

- A listed toxic chemical manufactured during a process where the toxic chemical remains in a mixture or trade name product distributed by the facility.

- A listed toxic chemical in which the raw material is "processed". The exemption applies even if the listed toxic chemical is concentrated above the de minimis level in the waste stream resulting from that processing activity. Because the de minimis exemption can be taken, 1) the quantities processed do not have to be applied to the processing threshold for that toxic chemical at the facility, and 2) quantities of the listed toxic chemical that are released or otherwise managed as a waste as a result of this specific processing activity are exempt from release and other waste management determination (EPA Q&A 1997 No. 220).

- A listed toxic chemical which is present in raw materials or non-wastes which are otherwise used. For instance, if the amount of chromium in coal burned for energy is below de minimis, the amount of chromium in the coal should not be counted toward the otherwise use threshold. However, if the valence state of the chromium changes during the combustion of the coal, causing a new chromium compound to be incidentally manufactured, the amount of new compound created must be included in the threshold determination, regardless of the concentration.

The de minimis exemption does not apply to:

- A toxic chemical manufactured at the facility that does not remain in a

product distributed by the facility. A threshold determination must be made on the annual quantity of the toxic chemical manufactured regardless of the concentration. For example, quantities of formaldehyde created as a result of waste treatment must be applied toward the threshold for “manufacture” of this toxic chemical, regardless of the concentration of this toxic chemical in the waste.

- The de minimis exemption also does not apply to chemicals manufactured in waste streams such as hydrochloric and sulfuric acids formed by coal combustion and nitrates formed in wastewater from neutralization of nitric acid.

- The de minimis exemption does not apply to the processing or otherwise use of a waste stream. Therefore, if a TRI chemical is known to be present in a waste brought on site for further waste management at a concentration below the de minimis level, the amount of chemical in that waste must be counted toward the otherwise use threshold.

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- Materials which are articles - Includes chemicals present in solid form for which there is no potential for chemical release. An article is a manufactured item that is formed into a specific shape or design during manufacture, that has end-use functions dependent in whole or in part upon its shape or design during end-use, and that does not release a toxic chemical under the normal conditions of the processing or use of that item at the facility. Some operations negate the article exemption such as recharging batteries (Note: fork lift batteries, but not vehicles manufactured at the plant, are exempt from Section 313 under motor vehicle exemption) and grinding or welding metals.

Items which are considered articles include:

- Molded plastic parts; - Metal wire that is cut or bent (but with no change in wire diameter); and - Sheet metal that is cut, punched, stamped or pressed (but with no substantial change in thickness).

Items which are not considered articles include:

- plastic pellets, - welding rods, and - metals which require extrusion to make the final product. The article exemption is not applicable if the article is disassembled, ground, melted or processed such that a release could result. Under this definition, stamped metal scrap would be considered an article whereas grinding swarf would not be considered an article.

• Materials which are structural components of the facility - Includes chemicals present in materials used to construct, repair, or maintain the facility buildings; for example, solvents and metal compounds present in paint used to coat the structural components of the facility are exempt. U.S. EPA changed the definition of structural component such that process equipment is not included in this exemption. Use as a structural component of the facility include: - Painting of the walls, floors, beams, exteriors, aisle striping, etc. (pigments

and solvents); - Welding of structural components such as columns (welding rods and gases);

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The exemption does not include:

- Machine lubricants (oils, greases); - Production welding; - Painting of process equipment; or - Welding of process equipment. U.S. EPA's definition of "process equipment" is not clear. However, pipes, machinery, guards directly attached to the machinery, and tanks should be treated as process equipment. Platforms and guards associated with the platforms or aisle guards would not be included.

• Materials used for janitorial or facility grounds maintenance - Includes chemicals present in materials used for routine janitorial or facility grounds maintenance; for example, cleaners, fertilizers, and garden pesticides. Use in routine janitorial or facility grounds maintenance includes: - Cleaning supplies, fertilizers or pesticides similar in type or concentration to

consumer products. Consumer packaging is an indication of this, but is not necessary as in the EPCRA Section 312 exemption.

• Materials used with facility motor vehicles - Includes chemicals present in

materials used for operating and maintaining motor vehicles operated by the facility; for example, gasoline, radiator coolant, and windshield washer fluid used in cars operated by the facility. Materials used to operate and maintain fork-lifts, including batteries, are exempt. The tailpipe emissions from facility motor vehicles are not exempt because new chemicals are "manufactured" in a "waste" stream.

• Personal items - Includes chemicals present in materials such as foods, drugs, cosmetics, or other personal items. Examples include materials used in the facility cafeteria and infirmary. Personal use items for employees and other persons include: - Foods, cosmetics, prescription drugs, supplies for facility cafeterias and

infirmaries, correction fluid, and copier/printer toners. - Fuels used to heat work areas for personal comfort. - Chemicals used in air conditioning or heating units used for cooling/heating of

personnel but not for cooling/heating of production processes.

The exemption does not include: - Ammonia used in blueprint machines.

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- The chemicals "manufactured" by combustion of fuels used to heat work areas for personal comfort.

• Laboratory materials - Includes materials used in laboratories that are under the supervision of a technically qualified individual. This exemption applies to some pilot-plant operations if the product is not sold. It applies to all quality assurance testing. Laboratories include quality control labs. Note: QC labs are not regulated under the OSHA Lab Safety Standard. The use of gasoline in testing vehicles or engines is included in the laboratory exemption.

• Materials as they are drawn from the environment - Includes process water,

non-contact cooling water, and combustion air as drawn from the environment. In other words, Section 313 chemicals that are present in materials drawn directly from the environment need not be considered. If chemicals are added to process or non-contact cooling water, however, this exemption ends at the point at which the chemical is added. City water is not considered as drawn from the environment because this water has been chemicals treated.

EPCRA Section 313 Contractor Applicability Assessment As shown above, there are several exemptions which can be applied to contractor activities under this section of the regulation. The following are assessments as to the potential that a particular contractor could trigger reporting under Section 313. Construction Contractors – the vast majority of hazardous materials utilized by construction contractors are exempt from EPCRA 313 under the structural component use exemption. As such, construction contractors are not expected to have reportable EPCRA 313 chemical usage which would contribute to the reporting threshold. Therefore, collection of hazardous material usage data from construction contractors is not warranted. Facility Maintenance - the vast majority of hazardous materials utilized by facility maintenance contractors are exempt under EPCRA 313 under the structural component or personal use exemption. As such, facility maintenance contractors are not expected to have reportable EPCRA 313 chemical usage which would contribute to the reporting threshold. Therefore, collection of hazardous material usage data from facility maintenance contractors is not warranted. Janitorial – the vast majority of hazardous materials utilized by janitorial contractors are exempt under EPCRA 313 under the routine janitorial/grounds maintenance exemption. As such, janitorial contractors are not expected to have reportable EPCRA 313 chemical usage which would contribute to the reporting threshold. Therefore, collection of hazardous material usage data from janitorial contractors is not warranted.

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Laboratory Support – the vast majority of hazardous materials utilized by laboratory support contractors are exempt under EPCRA 313 under the laboratory use exemption. As such, laboratory support contractors are not expected to have reportable EPCRA 313 chemical usage which would contribute to the reporting threshold. Therefore, collection of hazardous material usage data from laboratory support contractors is not warranted. Vehicle Maintenance – the vast majority of hazardous materials utilized by vehicle maintenance contractors are exempt under the motor vehicle maintenance exemption (no Depot or Intermediate level maintenance is performed at WPAFB). As such, vehicle maintenance contractors are not expected to have reportable EPCRA 313 chemical usage which would contribute to the reporting threshold. Therefore, collection of hazardous material usage data from vehicle maintenance contractors is not warranted. Food Service – the vast majority of hazardous materials utilized by food service contractors are exempt under EPCRA 313 under the personal use exemption. As such, food service contractors are not expected to have reportable EPCRA 313 chemical usage which would contribute to the reporting threshold. Therefore, collection of hazardous material usage data from food service contractors is not warranted. Regarding EPCRA 313 reporting as it applies to DoD facilities, reporting is typically only triggered because of one of the following reasons:

1) The facility is considered to be a Depot (not applicable to WPAFB) 2) The facility manufactures TRI chemicals as a byproduct of combustion or from

treating domestic waste water; or (is applicable to WPAFB due to coal fired plants)

3) The facility has transient motor vehicle fuel use (may be applicable to WPAFB due to transient aircraft jet fuel use).

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EPCRA Reporting Exemption Guidelines for WPAFB Contractors

Contractor Type

EPCRA 304Emergency Release

Notification†1EPCRA 304

Exemption(s)EPCRA 312

Tier II

Most ApplicableEPCRA 312

Exemption(s)†2EPCRA 313TRI Form R

Most ApplicableEPCRA 313

Exemption(s)†4

Construction Applicable None Exempt†3 40 CFR 370.2 (2) and (3) Exempt 40 CFR 372.38 (c)(1)Facility Maintenance Applicable None Exempt†3 40 CFR 370.2 (2) and (3) Exempt 40 CFR 372.38 (c)(1) and (c)(3)Janitorial Applicable None Exempt 40 CFR 370.2 (3) Exempt 40 CFR 372.38 (c)(2)Laboratory Support Applicable None Exempt 40 CFR 370.2 (4) Exempt 40 CFR 372.38 (d)Vehicle Maintenance Applicable None Exempt†3 40 CFR 370.2 (3) Exempt 40 CFR 372.38 (c)(4)Food Service Applicable None Exempt 40 CFR 370.2 (1) Exempt 40 CFR 372.38 (c)(3)

†1 All contractors should immediately report any spills involving a hazardous material to the WPAFB Office of Environmental Management (EM).WPAFB EM will make the determination as to whether notification of the National National Response Center (NRC), State, SERC, LEPC, and/or local fire department is necessary.† 2 EPCRA 312 exemptions (see 40CFR370.2 - Definition of Hazardous chemical)(1) Any food, food additives, color additives, drugs, or cosmetics regulated by the Food and Drug Administration.(2) Any substance present as a solid in any manufactured item to the extent exposure to the substance does not occur under normal conditions of use. (3) Any substance to the exent it is used for personal, family, or household purposes or present in the same form and concentration as a product packaged for distribution and use by the general public. The term “form” refers to the packaging rather than the physical characteristics of the product.(4) Any substance to the extent it is used in a research laboratory, hospital, or other medical facility under the direct supervision of a technically qualified individual.(5) Substances used in routine agricultural operations or a fertilizer held for sale by a retailer to the ultimate consumer.†3 Exemption is not applicable if contractor purchases material in bulk (e.g., 55 drum or larger) and it contains an EHS or CERCLA HS above inventory threshold quantities.Exemption is also not applicable if contractor maintains on-hand a fuel (e.g., gasoline, diesel fuel, kerosene, and propane). If so,chemical inventory and MSDS data should be provided to the WPAFB EM Office.† 4 EPCRA 313 exemptions (see 40CFR372.38)(a) De Minimis Exemption: A toxic chemical may be exempted if present in a mixture in concentrations less than 1% (by weight) or less than 0.1% (by weight), if it is a carcinogen.(b) Article Exemption: Quantities of a listed toxic chemical contained in an article do not have to be factored into threshold or releasedeterminations when that article is processed or otherwise used at a facility. An article is defined as a manufactured item that is formed to a specific shape or design during manufacture, has end�use functions dependent in whole or in part upon its shape or design during end�use, anddoes not release a toxic chemical under normal conditions of the processing or otherwise use of that item at the facility.(c) Activitity Use Exemptions:(1) Structural Component Use Exemption 40 CFR 372.38(c)(1) exempts from reporting toxic chemicals that are structural components of the facilityor that are used to ensure or improve structural or functional integrity. (2) Routine Janitorial/Grounds Maintenance Exemption 40 CFR 372.38 (c)(2) exempts the use of toxic chemicals contained in products for routine janitorial and installations grounds maintenance) (3) Personal Use Exemption 40 CFR 372.38(c)(3) exempts from required reporting the personal use of listed toxic chemicals in products used by employeesor other persons at the facility. This exemption also covers activities associated with facility-operated cafeterias, commissaries, DoD Exchanges,medical facilities, or activities associated with Morale, Welfare, and Recreation.(4) Motor Vehicle Maintenance Exemption 40 CFR 372.38(c)(4) exempts toxic chemicals contained in products used for the purpose ofmaintaining motor vehicles operated by a facility. A motor vehicle is anything that can be driven under its own propulsion, such as cars, trucks, and aircraft. (5) Intake Water/Air Exemption 40 CFR 372.38(c)(5) exempts facilities from reporting toxic chemicals present in process water or no-contactcooling water as drawn from the environment or from municipal sources. The exemption also covers toxic chemicals present in air used either ascompressed air or as part of combustion. (d) Laboratory Activity Exemption: The laboratory activity exemption applies to those listed toxic chemicals manufactured, processed, or otherwiseused in a laboratory for quality control, research and development, and other laboratory activities. (e) Property Owners of Leased Property: A federal agency is not required to report for a facility if it merely owns the real estate on which an establishment covered by EPCRA is located; that is, the facility has no “business” interest in the operation of that establishment.

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Appendix I Training Requirements and Frequencies

Reference Table

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HAZMAT Training Requirements

HMMP Team

UEC IPM Supervisors Employees Contractors*

ESOH Training

X

X

X

X

X

X

HAZCOM Training

X

X

X

X

X

X

HAZCOM Annual Refresher

X

X

X

X

X

X

Train the Trainer

X

X

X

X

RCRA Training

X

X

X

X

X

X

RCRA Annual Refresher

X

X

X

X

X

X

DOT Training

X

X

X

DOT Bi-annual Refresher

X

X

X

UEC Training

X

X

ESOH Camp Training

X

X

X

*The level of training/briefing for contractors will be based on the types of HAZMATs used and the tasks being performed on the contract. Any questions regarding this training should be coordinated with the contracting officer and CEV.

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Appendix J Record Requirements AF Form 55

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AF IMT 55, 19961101, V3

2. SSN 3. ORGANIZATION & OFC SYMBOL AND/OR WORKPLACE IDENTIFIER1. NAME (Last, First, Middle Initial) GRADE

4. OCCUPATIONAL SERIES OR PRIMARY AFSC 5. DUTY TITLE

6. HAZARDS ASSOCIATED WITH PRESENT JOB OR TASKS AND WORK AREAS (NOISE, ELECTRICAL SHOCK, RADIATION HAZARDOUS MATERIALS, ETC.)

7. OCCUPATIONAL HEALTH MEDICAL EXAMINATION (OHME) REQUIRED

EMPLOYEE SAFETY AND HEALTH RECORD

The AF Form 55 will be maintained by the supervisor in the work place. For Department of the Air Force civilian personnel, this form may be filed with AF Form 971, Supervisor's Employee Brief. For military personnel - file with any records. See AFI 91-301.

I MANDATORY ITEMS (To be briefed to all personnel, as applicable)

1. HAZARDS OF THE JOB OR TASKS, AND SAFETY PROCEDURES TO BE FOLLOWED (See Item 6)

2. HAZARDS OF THE WORK AREAS (See Item 6)3. OSH STANDARDS AND GUIDANCE THAT APPLY TO JOB AND WORK PLACE

4. PERSONAL PROTECTIVE EQUIPMENT THEY WILL NEED AND HOW, WHEN, AND WHERE TO USE IT (To be entered into Sections II and III of this form)

5. LOCATION AND USE OF EMERGENCY AND FIRE PROTECTION EQUIPMENT

6. EMERGENCY PROCEDURES THAT APPLY TO THEIR JOB AND WORK PLACE

7. REPORTING UNSAFE EQUIPMENT, CONDITIONS OR PROCEDURES TO SUPERVISOR IMMEDIATELY

8. LOCATION, SUBMITTING PROCEDURES, AND PURPOSE OF AF FORM 457, USAF HAZARD REPORT (AFI 91-202)

9. MISHAP REPORTING PROCEDURES (AFI 91-204)

10. EMERGENCY TELEPHONE NUMBERS

11. LOCATION AND REQUIRED REVIEW OF APPROPRIATE SAFETY BULLETIN BOARDS, AF VISUAL AIR 91-307

12. LOCATION OF MEDICAL FACILITIES AND PROCEDURES FOR OBTAINING TREATMENT

13. REQUIREMENTS FOR DOCUMENTATION AND NOTIFICATION OF ON-THE-JOB INJURY OR ILLNESS

14. PURPOSE AND FUNCTION OF THE AF FORM 1118, NOTICE OF HAZARD

15. INDIVIDUAL RESPONSIBILITIES FOR ENSURING OWN SAFETY

16. REQUIRED USE OF SAFETY BELTS

17 PERSONNEL RIGHTS (AFI 91-301)

18. AIR FORCE HAZARD COMMUNICATION PROGRAM REQUIREMENTS

19. CONFINED SPACE REQUIREMENTS, IF REQUIRED (AFOSH STANDARD 91-25)

20. MANUAL LIFTING GUIDANCE (AFOSH STANDARD 91-46)

21. JEWELRY SAFETY (AFOSH STANDARD 91-66)

22. POTENTIAL HAZARDS ASSOCIATED WITH THE SURROUNDING LOCAL AREA (If operational activities require travel off installation)

23. OTHER (List in remarks or on continuation sheet, if necessary)

II PERSONAL PROTECTION ISSUED III PERSONAL PROTECTION PROVIDED IN WORK AREA

PREVIOUS EDITION MAY BE USED PAGE 1 OF 2 PAGES

1. FOOT PROTECTION

2. ARM/HAND PROTECTION

3. EYE PROTECTION

4. HEARING PROTECTION

5. RESPIRATORY PROTECTION

6. HEAD PROTECTION

7. OTHER (List)

1. FOOT PROTECTION

2. ARM/HAND PROTECTION

3. EYE PROTECTION

4. HEARING PROTECTION

5. RESPIRATORY PROTECTION

6. HEAD PROTECTION

7. OTHER (List)

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AF IMT 55, 19961101, V3

EMPLOYEE SAFETY AND HEALTH RECORD

PREVIOUS EDITION MAY BE USED(REVERSE) PAGE 2 OF 2 PAGES

IV. RECORD OF SAFETY, FIRE PREVENTION, AND HEALTH BRIEFING AND JOB SAFETY TRAINING

TYPE TRAINING INITIAL RECURRING DATENAME/SIGNATURE OF SUPERVISOR/TRAINER

SIGNATURE OF EMPLOYEE

V. REMARKS

FOR OFFICIAL USE ONLYAUTHORITY: PRINCIPAL PURPOSES:ROUTINE USES:DISCLOSURE:

10 U.S.C., Chapter 40; 37 U.S.C., Chapter 9, EO 9397, November 1943.For documentation of occupational safety, fire protection, and health training.Use to create a record of training and to retrieve record of safety, fire protection, and health training.Disclosure of SSN is voluntary.