Attach__No__1B_-_Consolidated_HMMP_Playbook.pdf

Hazardous Materials Management Process (HMMP) – “Plan Phase” – Overview

Introduction to the HMMP Playbook

HMMP Playbook Purpose, Goals and Scope

In accordance with AFI 32-7001 Environmental Management and PAD 12-03 Implementation of Enterprise-Wide Civil Engineer Transformation, the HMMP program must meet EMS requirements and follow the Plan, Do, Check, Act (PDCA) framework in accordance with ISO14001 International Standard for Environmental Management Systems – Requirements with guidance for use. In lieu of a federal requirement or an AFI driver for a HMMP management plan, the HMMP Playbook serves as the HMMP management plan.

In accordance with the EMS (Plan, Do, Check, Act / PDCA) framework, the HMMP Playbook is organized in the following manner:

I. Plan

• HMMP Overview

II. Do

• Element I - Ongoing Functions

• Element II - Process maps and narratives

III. Check

• Monitoring and Measurement

IV. Act

• Corrective Actions and Continual Improvement

Limitation: This playbook does not replace, supersede, or circumvent existing DoD or Air Force policy.

Federal, state, local or OCONUS regulations and permit conditions take precedence over the guidance in this playbook. This playbook references the Enterprise Environmental, Safety, and Occupational Health Management Information System (EESOH-MIS).

Playbook Roles

The major roles involved in the HMMP program are AFCEC, CE HM Manager (also known as the Installation Hazmat Manager “IHMM”, or HMMP Team Lead), HMMP Team, Shop, Hazmart, and Data Steward. Detailed information about their responsibilities can be found in the Element I Ongoing Functions narratives.

Organization of the HMMP Playbook

The organization of HMMP Playbook follows the EMS PDCA cycle, with particular emphasis on the Do (Implementation and Operation) segment of PDCA.

The DO section of the HMMP Playbook is divided into two Elements. Element I documents all ongoing functions and responsibilities within the HMMP Program in textual narrative form. Element II documents the HMMP lifecycle and operational processes through process maps and accompanying textual narratives.

I. Plan

• Overview

II. Do (Implementation and Operation)

• Element I: HMMP Ongoing Functions o Establishing and Maintaining HMMP Team o AFCEC Functions o CE HM Manager (HMMP Team Lead) Functions o Shop Functions o Hazmart Functions o Data Steward Functions o Reporting (Regulatory and Process Improvement) o Training

• Element II: HMMP Lifecycle Process o 1.0 Establish HMMP Shop and Hazmart

1.1 Establish Hazmat Tracking

1.2 Create Shop/Hazmart Profile

1.3 Obtain Tracking System Access

1.4 Train Users on HMMP

o 2.0 Perform Process Authorization

2.3 Generate Authorization Request or Request Exemption

2.5 Conduct Environmental Approval

• 2.5.12 Consider Product Substitutions o 3.0 Track Hazmat

3.4 Process Request and Receive Hazmat

• 3.4.20 Decant Inventory

3.5 Manage Inventory

• 3.5.4 Manage Inventory Transaction

• 3.5.5 Initiate Periodic Audits

• 3.5.6 Perform Inventory Analysis Shelf Life

3.6 Use Hazmat

3.12 Determine Whether to Reuse/Redistribute or Dispose of Hazmat o 4.0 Manage Deployments III. Check

• Monitoring and Measurement IV. Act

• Corrective Actions and Continual Improvement

Introduction the HMMP Program About the HMMP Program Hazardous materials (hazmat) are used in every facet of the Air Force mission and pose risks to the health and safety of personnel, surrounding communities, and the broader environment. In 1997, with the first publication of AFI 32-7086, Hazardous Materials Management, the AF created the Hazardous Material Management Process (HMMP) to meet changing regulatory reporting requirements while more effectively reduce the risks and costs associated with the use of hazmat. These evolving environment, safety, and occupational health (ESOH) regulatory requirements for civil engineering (CE), bioenvironmental engineering (BE), and safety (SE) were becoming increasingly complex, and the Air Force could not adequately protect the mission and warfighter from non-compliance without taking greater responsibility for hazmat management. AFMAN 32-7002, Environmental Compliance and Pollution Prevention, chapter 3 is where the current policy for the HMMP can be found.

The development of the HMMP was in many ways a forerunner of today’s AFSO21 process improvement efforts. With AF Civil Engineers and AF Maintenance as champions, HQ USAF assembled a cross-functional integrated product team composed of subject matter experts from weapon system maintenance, supply, acquisition, contracting, CE, BE, and safety to breakdown functional stovepipes and re-engineer AF hazmat management.

Purpose of the HMMP Program Using the Environmental Management System (EMS) framework and Plan Do Check Act (PDCA) cycle, the purpose of the HMMP Program is to: (1) support Air Force missions; (2) evaluate and mitigate risk to the environment and protect the safety and health of personnel on Air Force installations and surrounding communities; (3) minimize Air Force use of hazmat consistent with mission requirements; (4) and maintain Air Force compliance with environmental reporting requirements related to hazmat usage.

HMMP Program Specific Mission and Goals

Mission Statement: The HMMP supports accomplishment of the AF mission by minimizing and effectively managing dependence on hazmat within acceptable levels of mission and ESOH risk. The HMMP is an asset management approach that allows the AF to systematically manage hazmat and optimize the associated performance, risk and expenditures over the lifecycle.

• Goal #1: Establish and sustain an effective installation HMMP Team o Communications and training

Communication Plan Training Plan o Protect the safety and health of personnel on Air Force installations and communities surrounding Air Force installations from Air Force misuse of hazmat.

o Consistent and active participation of team members.

KPI: Ensure that the HMMP Team has been formally chartered and established under the installation ESOH Council.

KPI: HMMP Team meetings will occur as specified in the approved HMMP Team charter.

o Comply with applicable hazardous material management laws, and regulations

KPI: Ensure data is available to support timely reporting (EPCRA, etc.)

o Executive Order(EOs), especially 13834, Efficient Federal Operations, whose implementation instructions require Federal Agencies to develop and implement hazardous chemical reduction goals Develop specific reduction goals on targeted chemicals Identify those NSNs with multiple vendors that have products with wide variances in chemical ingredients to create separate NSNs

• Goal #2: Establish and sustain effective Hazardous Material Tracking Activities (HTA) to manage all hazmat entering an installation o Organizations procuring hazmat must participate in a structure to manage and track all hazmat.

KPI: Periodic surveillance of Shops/Supply Activities starting with self audits to ensure that all hazmat entering the installation is captured within a Hazmart. Additionally, review GPC purchases to ensure tracking of local purchases.

o The HTA enables the efficient procurement and inventory of hazardous materials Minimize number of stock numbers/products used for hazmat procurement Identify most sensible source of supply/procurement methods for hazmat, e.g. Blanket

Purchase Agreements, Just-in-Time contracts, Government Purchase Cards (GPC), DLA E-Mall, GSA Advantage, etc.

Manage hazmat with shelf life to avoid disposal Minimize quantities of hazmat procured by shops

• Goal #3: Proactively identify ESOH risk reduction opportunities through cross functional process authorization o Identify, evaluate, minimize, mitigate, and authorize those processes that use a hazardous material to reduce ESOH risk and maximize NI capacity.

Effectively manage dependence on hazmat

• Number of negative incidents (spills, NOVs) related to hazmat use

• Number of self-audit findings related to hazmat use

Minimize ESOH risks and compliance burden

• Number of compliance reports supported by regulators

• Number of compliance findings supported by self-audits

Evaluate Process Authorization requests

• Percent/Number of process authorization materials changes to reduce

ESOH constraints, based on the corresponding EESOH-MIS values

• Number of authorizations per base

• Percent shops with authorizations o Provide work area supervisors with information necessary to comply with applicable hazardous material ESOH requirements.

Authorizations will document conditions of use as applicable Make available Hazard Communication information to the shop supervisor through the tracking system, e.g. physical hazards, inventory reports Provide ability to document/log hazmat usage to meet permit requirements, e.g. air emission tracking Allow shops to maintain and report on hazmat inventory o Protect the safety and health of personnel on Air Force installations and communities surrounding Air Force installations from Air Force misuse of hazmat.

• Goal #4: Optimize environmental management and reporting by fielding a standard enterprise hazmat tracking system o Collect, track and maintain data related to the receipt, issue, storage, use and disposal of hazardous materials to meet environmental reporting obligations and other ESOH requirements Implement EESOH-MIS (hazmat Tracking System)

• KPI: Percentage of base EESOH-MIS deployment to FOC at appropriate facilities.

100% FOC implies all Shops, HAZMARTs and inventories are tracked within the new system, the Legacy system can be shut down, all key personnel are trained on its use, and that the IT system is capable of performing the following functions:

o Manage hazardous materials that require authorization and tracking o Manage all hazmat using activities (shops)

Number of shops identified as hazmat users o Manage all contracting mediums using hazmat on the installation

Number of contracting shops identified as hazmat users o Establish Hazmat Tracking Activities (HTA, aka Hazmarts) where necessary to ensure all hazmat is tracked Number of HTAs established at an installation

Facilitate the accomplishment of compliance reporting, e.g. EPCRA, AEIs, etc.

• Goal #5: Continuously seek to minimize hazmat usage and disposal o War Readiness Material o Hazardous Waste: Minimize the generation and disposal of hazardous waste (HW).

Support reuse and redistribution alternatives AF wide Manage short shelf life items Facilitate reuse advertising o Weapon Systems Integrate weapon systems hazmat reductions into weapon systems requirements generation, prioritization, funding, and execution processes

• Template weapon systems processes, to include DOEHRs/DoD process codes, materials, aspects, etc. to facilitate standardization

• Work with Single Managers to include in new, updated Technical Orders (TOs) new/changed templates?

• Pursue and track TO change requests (AFTO Form 22, other) to achieve hazmat substitutions (HMMP).

o Exemptions o Product Substitutions o Source Reduction (P2 hierarchy) o Compliance Burden Reduction (e.g. TRI Reduction and Reporting) o Engineering Controls o Reuse/Redistribution o Manage mission critical requirements for Class I Ozone Depleting Substances (ODS)

Drivers of the HMMP

Amongst current key drivers of the HMMP are the Resource Conservation and Recovery Act (RCRA) which drives Waste Minimization certification requirements; Clean Air Act; Emergency Planning & Community Right-to-Know Act (EPCRA); Executive Orders 13834 Efficient Federal Operations; AFMAN 32-7002 Environmental Compliance and Pollution Prevention; AFI 32-7001 Environmental Management;

and PAD 12-03 Implementation of Enterprise-Wide Civil Engineer Transformation regarding the following specific components:

• 1.1 The AFCEC will manage the EQ and environmental planning function (EPF) responsibilities formerly located at MAJCOMs to include COCOM environmental support at USAFE and PACAF.

• 2.1.3.1: AFCEC: Plans, organizes, directs and controls the Air Force EQ programs of the installations on behalf of the AF/A7C and the MAJCOMs. Provides support for environmental compliance, conservation and P2 programs.

• 2.1.5.1: Installation: retains local compliance management of the installation environmental compliance, conservation, P2 programs to ensure compliance with all federal, state, and local laws and regulations. Accountability and primary responsibility for environmental compliance will remain at the installation.

• 2.1.3.2: AFCEC supports and maintains the effective implementation of the Air Force Environmental Management System (EMS) to include coordination with necessary mission support areas

• 2.1.5.2: Installation CCs will continue to chair installation-level ESOH Council and provide oversight of the installation EMS

Additionally, the ISO14001 International Standard for Environmental Management Systems – Requirements with guidance for use provides guidance on how the HMMP should be established, implemented, and maintained to operate under the EMS framework.

WITHOUT THE HMMP, there are no replacement processes or systems that ensure:

• Hazmat procurement and shelf-life management throughout the material life cycle maintains its efficiency (and associated cost reductions);

• Users have easy access to a standard hazmat tracking system that provides electronic access to hazardous material data, such as:

o the correct, validated MSDS, specific to the actual product being used and the ESOH hazards associated with specific chemical, in shop-specific processes;

o process-specific guidance on the PPE and operational controls that must be used to keep workers safe, reduce hazards to co-workers, and to protect and sustain our natural infrastructure resources;

o quality data is available for Environmental personnel to accomplish the complex environmental reporting, including chemical constituent and process tracking.

Installations/AFCEC require this data for regulatory reporting to demonstrate compline or for reporting to OSD in response to other initiatives (e.g. Annual Report to Congress, Executive Order (EO) 13834, emerging contaminants, etc.) and continually reduce our ESOH liability footprint;

o standardized data across the AF through a single system will facilitate gathering future program health indicators and measures.

• Materials used within shops or activities are in the appropriate quantities needed to keep shops from inadvertently violating applicable permit levels.

• An Environmental Management System (EMS) based process to continuously evaluate and improve AF work processes (environmental aspects) that impact the environment.

By providing these services and data, the HMMP provides critical support to Natural Infrastructure and Asset Management, the current Air Force Environmental Management System (EMS), as well as the evolving concepts of sustainability.

Hazardous Materials Management Process (HMMP) – “Do Phase” – Element I: Establishing and Maintaining HMMP Team

Introduction Narrative

Introduction

The HMMP Team oversees hazmat management, ensuring the HMMP program is conducted in accordance with EMS requirements (for more information on the EMS framework, refer to the EMS Playbook on the Civil Engineering (CE) Portal). The team consists of cross-functional stakeholders involved with hazmat. It must be formally chartered by the ESOH Council. The team ensures that hazmat management balances the user, supply, technical, and ESOH perspectives. CE is designated (representing environmental and fire protection) as the team lead, and identifies the core team members as Surgeon General (SG), Bioenvironmental Engineering (BE), Safety (SE), Communications and Information (SC or CS), Legal (JA), Maintenance, Logistics Readiness (with supply expertise), Contracting, and Hazmart supervisors. In order to execute the HMMP, the installation HMMP team requires the support of all of the core members.

The common factor in less successful installation HMMPs across the Air Force is an HMMP team that has incomplete support from its core team members. The HMMP may also not be empowered with enough authority at the installation to shoulder through the challenges that come with trying to implement a cross-functional policy. A strong presence and full support of the ESOHC is key to empowering the HMMP Team.

Narrative

As the HMMP Team lead, CE ensures teamwork, oversight, coordination, and a cross-representation voice for the program. CE is primarily responsible for EPCRA Reporting, metrics, data consolidation and validation, various training, system assurance, monitoring, and overall program compliance activities.

There are two scenarios that an HMMP Team Lead may encounter:

• Establishing a new HMMP Team - this will happen if there is a new installation, an installation where the HMMP Team had not been established previously, or an installation that has allowed their HMMP Team to lapse/dissolve and requires a new start

• Joining a pre-established HMMP Team (either functional or dysfunctional) – A new HMMP Team lead may be brought in to replace a former lead. The new HMMP Team lead may find that the HMMP Team is a fully functioning and effective team, or that the team is non-communicative and dysfunctional

Establishing a New HMMP Team Role: CE HMMP Team Lead (or “CE HM Manager”)

1. Locate Policies, Procedures, Charter, and Continuity Books: The HMMP Team Lead is responsible for locating and making accessible to all HMMP Team members the appropriate policies, procedures, HMMP Team charter, and existing continuity books. If these items do not exist, the HMMP Team Lead should identify and create a charter, approved by the local ESOH Council chair (required by AFMAN 32-7002, Environmental Compliance and Pollution Prevention, Chapter 3) and an installation HMMP Operating Instruction as a best practice. There should be references to assist the HMMP Team Lead in development of these items, including the Base Level SOP Template and Example Document (check with AFCEC counterpart)

2. Familiarize With Installation Elements: The HMMP Team Lead should be familiar with the installation mission and how the Hazardous Material Management Program supports the warfighter. Some best practices are to visit the established Shops and Hazmarts on the installations. There are some “red flags” that the HMMP Team Lead should be aware of during the site visits and familiarization such as noticing the lack of authorizations for customers and lack of training for teams at those Shops and Hazmarts. Reference the AF Team Guides available under Resources on the Management System and Compliance Audits site (use the Fed Center's Environmental Compliance Assessment Tools link, account required) in eDASH.

3. The AF guides can be found in the checklists folder, and HMMP can be found in the “Other” (OO) protocol in the “AF CONUS Supplement” or in the “OCAP OCONUS Supp –oaf”.

4. Identify and Meet Team Members: The HMMP Team Lead should identify their team members at the installation. The Team must consist of Surgeon General (SG), Bioenvironmental Engineering (BE), Safety (SE), and Supply. Other members can also include Communications and Information (SC or CS), Legal (JA), Maintenance, Logistics Readiness (with supply expertise), Contracting, and Hazmart supervisors.

If there are problems with assigning these roles, the HMMP Team Lead should reach to the local ESOH Council or AFCEC and seek assistance in engaging installation leadership.

5. Enroll Self and Team in Training: The HMMP Team Lead and team members should attend training as directed/provided by AFCEC and HMMP Team Lead (CE HM Manager). At a minimum, the HMMP Team Lead should enroll in the Air Force Institute of Technology (AFIT) HMMP Training Course “ENV 222” as soon as possible. Currently, AFIT offers three courses each year. The HMMP Team Lead should also ensure all “primary” team members (Bio, Safety, Hazmart) take the AFIT ENV 222 course so they are trained and fully understand the HMMP activities, goals, initiatives, processes. When conducting the site visit to the Shop and Hazmart locations, the training of the employees there should be assessed. These Shop and Hazmart workers can also attend AFIT-delivered satellite hazmat awareness training (check AFIT website on dates or check with AFCEC). The HMMP Team should also participate in Government Purchase Card (GPC) training. If the HMMP Team Lead encounters problems with registering team members or employees in training, they should reach to the appropriate AFCEC point of contact. Some contractors are unable to attend government funded training; a solution for this situation needs to be coordinated with the corresponding AFCEC point of contact.

6. Determine First Meeting Logistics: The HMMP Team Lead will arrange the team meetings.

Once the team members are identified, the meeting should be held during a time that all members can attend. Per AFMAN 32-7002, Environmental Compliance and Pollution Prevention, meetings should occur at the frequency indicated in the approved installation HMMP Team charter.

7. Assess Current Tracking System: The HMMP Team should work together on base procedures for conducting the hazmat process authorizations, including setting the role of the HMMP ESOH reviewers. This might include setting the routing of the authorization in the standard AF hazmat tracking system. Once procedures for ESOH reviewers are established, the team lead might need to check and track any pending authorizations. If there are overdue authorizations, this should be addressed during the HMMP Team meetings.

8. Engage Leadership at Installation: The HMMP Team Lead is responsible for engaging the

Installation leadership or ESOH Council with HMMP issues and concerns. The leadership should take an active role in supporting the direction of the HMMP Team and associated duties and responsibilities.

9. Develop Agenda for HMMP Meeting: The HMMP Team Lead is responsible for developing the agenda. The agenda is compiled from any HMMP Team “red flags” during site visits or other systemic HMMP issues. Some potential topics for this meeting can include:

• Installation specific metrics and benchmarking https://cs2.eis.af.mil/sites/10040/WPP/ProgramPage/ProgramPage.aspx?Program=Environmental%20Inspection%20Process%20(EIP)

• Self-audit results and Shop surveillance

• Open Authorizations that have problems

• Installation Policy creation

10. Lead/Facilitate Meeting: The HMMP Team Lead is responsible for leading all HMMP Team meetings. For the first HMMP Team meeting all team members should be present and engaged to discuss the way-ahead.

11. Ensure Requirements for Funding: The HMMP Team Lead is responsible for ensuring all requirements and budgeting aspects for the Installation HMMP Team are elevated to their AFCEC IST representative to ensure all funding needs are identified and met. Reference the environmental budget “EQ matrix” for types of projects supported for funding.

12. Continual Improvement: The HMMP Team Lead is responsible for assessing the program for continual process improvement. Some examples of process improvement areas are:

• Current Tracking System- assessing the quality of data for accuracy

• Managing GPC usage of purchases for Hazardous Material - looking at how the team will govern the procedure on the installation and how the purchases will be tracked; providing input on hazmat requirements to base GPC manager for incorporation into GPC user training

• Unidentified Hazardous Material Points of Contact- Where on the installation is hazardous material being used or purchased that is not currently tracked? How can those areas be added to the HMMP Program?

• P2 Program—Is there currently a P2 Program established based on EMS? Is there a way to operate this program better?

• Unidentified Entry Points- Reviewing the entry points of hazardous material assists in finding what is not currently being tracked

• Checking self-audit findings or shop self-inspection results to identify areas for improvement

• Developing local goals/performance metrics to track progress or accomplishments, such as HMMP effectiveness in reducing hazardous chemicals usage

• Verifying if training is effective and review training for improvement

Element I: AFCEC Functions

Introduction Narrative

Introduction This narrative has been added to the HMMP Playbook in order to comply with the PAD 12-03 Implementation of Enterprise-Wide Civil Engineer Transformation, Section 1.1, “AFCEC will manage the EQ… function responsibilities formerly located at MAJCOMs to include COCOM environmental support at USAFE and PACAF… All remaining MAJCOM CE environmental functions and responsibilities will be transferred to the AFCEC.”

Using the Programming Plan (P-Plan) Revision 1 for Implementation of Enterprise-Wide Civil Engineer Transformation (PAD 12-03), Volume 2 as a basis, this narrative lists the offices of primary responsibility (OPRs) within AFCEC that execute AFCEC’s HMMP-related tasks. For tasks for which the installation is the OPR, the appropriate AFCEC offices of coordinating responsibility (OCRs) have been listed.

Narrative AFCEC has the following ongoing responsibilities to maintain a successful HMMP Program:

• EMS Program Management – OPR: AFCEC/CZCA o Ensure that the HMMP Program is an Environmental Management System (EMS)-based process with the goal of reducing risks to the environment, by ensuring compliance, preventing pollution, and looking for ways to continually improve (For additional information, refer to the EMS Playbook on the CE Portal)

• Participate in EMS audits if significant hazmat aspects are found – (Although the installation has primary responsibility, AFCEC/CZO, AFCEC/CZTQ, and AFCEC/CZCA have coordinating responsibility)

• Program centrally for all hazmat projects – OPR: AFCEC/CZO

• Conduct performance measurement & reporting – OPR: AFCEC/CZCA (For more information, refer to the Reporting narrative of this playbook and the Environmental Reporting Playbook on the CE Portal) o Identify significant hazmat environmental aspects and the KPI metrics o Develop proposed KPIs and PMTs o Develop contract to collect data to support KPIs and PMTs as needed o Review base input to KPI and PMT data in applicable reporting databases and AMPs o Prepare programming planning documents to fix/improve performance o Verify performance measurement data with installation as appropriate o Verify all data is collected and reported o Take corrective action to adjust data as needed o Program and validate potential project requirements o Perform trend analysis

• Ensure proper environmental reporting and record keeping – (Although the installation has primary responsibility, AFCEC/CZO, AFCEC/CZTQ, and AFCEC/CZCA have coordinating responsibility) o Identify AFCEC-specific recordkeeping requirements o Collect AFCEC data, documents, and maintain records/files/databases as needed o Provide installation appropriate records generated by AFCEC o Verify AFCEC records are accurate and current o Adjust recordkeeping process as needed to improve accuracy

• Ensure competence, training and awareness – OPR: AFCEC/CZCA (For more information, refer to the Training narrative of this playbook and the Environmental Education and Training (EE&T) Playbook on the CE Portal) o Coordinate with base to identify training needs o Develop hazmat training materials/templates and provide training for Hazardous

Materials Management Program (HMMP) o Review feedback from base o Prepare adjustments and updates to training provided by AFCEC (in-house or contract) o Coordinate with base to identify options to accomplish training o Train installation EESOH-MIS hazmat users o Participate in the EE&T panel/working group as required o Create and maintain training template for GPC training o Adjust and update training as needed o Participate in AFIT course reviews and provide input for hazmat course instruction o Provide instruction for AFIT hazmat training o Attend training as required to maintain professional qualifications, body of knowledge

• Perform PPBE Process – OPR for Planning: AFCEC/CP; OPR for Programming, Budgeting and Execution: AFCEC/CZCP o Work with installation to ensure all funding needs are identified o Ensure programming meets installation needs o Evaluate if funding was adequate or requires adjustment o Estimate funding amounts based on historical or other cost estimates o Verify contract support meets installation needs o Identify PPBE process improvement o Program funding requirements in ACES-PM, etc.

o Validate installation EQ funding request o Identify proposed changes to EQ program funding matrix o Prepare EQ funding trend and categorical analysis o Execute centrally managed EQ support contracts o Develop Air Force-wide IPL

• Provide regulation/legislation support – OPR: AFCEC/CZO REG/LEG o Identify applicable regulations (federal, state, local, FGS, or DOD) for installation o Review and submit Air Force comments to proposed regulations o Follow through on legislation or proposed rules as needed, e.g., were comments accepted and addressed o Organize process review of proposed regulations impacting installation o Program funding needs for installation o Develop OEBGD o Check new regulatory announcements; advise installation as needed o Provide guidance to installations on new regulations or changes in regulations o Develop FGS o Review and develop Air Force policy and guidance o Update Air Force policy and guidance to implement change to laws and regulations

• IT Use / EESOH-MIS – (Although the installation has primary responsibility, AFCEC/CZO, AFCEC/CZTQ, and AFCEC/CZC have coordinating responsibility) o Identify EESOH-MIS and other IT requirements o Assist in the maintenance of IT system data o Validate IT system meets needs o Evaluate performance of IT system o Identify, document and repot revisions to IT systems o Report requirements for changes to IT system o Validate data is consistent, accurate and complete o Program IT requirements for EESOH-MIS and eDASH and other relevant software o Serve as configuration control team within the Hazardous Material panel for IT systems (e.g., EESOH-MIS) o Validate and approve required changes for EESOH-MIS o Monitor effectiveness of EESOH-MIS o Modify standardized EMS architecture and tools as needed o Improve data collection quality within EESOH-MIS o Identify authoritative sources of data o Communicate and promote IT tools to senior leadership o Support external IT system requests for EMS requirements as needed o Ensure accessibility and sharing of data within IT systems at all levels

• Implement IT EESOH-MIS module – (Although the installation has primary responsibility, AFCEC/CZO and AFCEC/CZT have coordinating responsibility) o Contract for centralized product hazard data (PHD) entry (chemical and Safety Data

Sheet [SDS]) into EESOH-MIS o Review and maintain AFCEC SAARs o Review existing and inactivated user accounts and communicate user access requirements to the EESOH-MIS help desk o Identify user roles and notify help desk for EESOH-MIS user access o Lead the EESOH-MIS Hazardous Material FWG o Schedule and conduct FWG meetings and record minutes o Brief panels and PMO on EESOH-MIS requirements o Identify and approve EESOH-MIS change requests o Analyze and decompose EESOH-MIS requirements o Generate reports in support of ER requirements (EPCRA, CAA, etc.) and DOD/Air

Force required hazmat reporting (separate into local and Air-Force wide)

• Hazardous Material Panel governance – OPR: AFCEC/CZTQ o Identify appropriate hazardous material panel membership o Participate in hazardous material panel representing base and region o Represent enterprise and installation issues appropriately o Evaluate trends and report to panel as appropriate

• Guide regulatory inspections – (Although the installation has primary responsibility, AFCEC/CZO and AFCEC/CZT have coordinating responsibility) o Notify installation leadership o Review and analyze regulator’s report o Respond to regulator’s report o Work final issues with regulator for close-out

• Lead the installation HMMP team (Ref AFMAN 32-7002, para 2.15.16) – (Although the installation has primary responsibility, AFCEC/CZO and AFCEC/CZTQ have coordinating responsibility) o Determine standard contract language for incorporation of IHMP requirements into local base contracts o Develop and maintain standard language for support agreement requirements o Provides technical environmental assistance on hazmat issues o Analyze process hazmat metrics to identify opportunities to reduce hazmat usage, minimize waste generation, ensure proper tracking, identify process efficiencies

• Semi-annual Environmental Quality (EQ) Data Call – OPR: AFCEC/CZCA o Forecast data call requirements (e.g., annual Defense Environmental Programs

Annual Report to Congress “DEPARC”, Environmental Management Review "EMR") o Assemble and prepare HHQ data call response o Ensure reports and data calls completed o Analyze data for completeness, trends, and corrective actions o Program requirements in ACES-PM to correct discrepancies

• Provide Professional Hazardous Material Policy, Guidance, Technical Support and

Advice – OPR: AFCEC/CZTQ o Provide technical support on installation on spills and releases as needed o Research technical issues for installation

• Internal and External Communications – OPR: AFCEC/CZCA

Element I: CE HM Manager (HMMP Team Lead) Functions

Introduction Narrative

Introduction

The Civil Engineering Hazardous Materials (CE HM) Manager is also referred to as the HMMP Team Lead. In accordance with the PAD 12-03 Implementation of Enterprise-Wide Civil Engineer Transformation and the Programming Plan (P-Plan) Revision 1 for Implementation of Enterprise-Wide Civil Engineer Transformation (PAD 12-03), Volume 2, this narrative describes the ongoing responsibilities of the CE HM manager on the installation.

HMMP Team Leads have the following ongoing responsibilities to maintain a successful HMMP Program:

• Ensure that the HMMP Program is an Environmental Management System (EMS)-based process with the goal of reducing risks to the environment, by ensuring compliance, preventing pollution, and looking for ways to continually improve (For additional information, refer to the EMS Playbook on the CE Portal)

• Establish local procedures and plans o Establish local procedures, prepare and maintain management plans, and provide technical expertise with regard to hazmat management requirements o Check management plan to ensure it meets all requirements (e.g., regulatory and installation) by ensuring spot checks are performed o Oversee proper programming and recordkeeping procedures

• Lead the Installation HMMP Team (Ref AFMAN 32-7002, para 2.16.15. and para 3.2) o Create and maintain the HMMP team o Ensure procedures in place, such as a charter, to ensure an effective HMMP team o Ensure team is aware/clear on responsibilities for executing the Hazardous Material

Management Program (HMMP) o Conduct HMMP team meetings at the frequency specified in the approved installation

HMMP Team Charter. Topics can include:

1. Resource (funding and personnel) review, validation, and tracking

2. Support Agreements

3. Metrics

4. Contract hazmat requirements

5. Other HMMP issues o Work with team to establish procedures for hazmat reduction, recycling, reuse or shelf-life control, in order to minimize the generation of hazardous waste o Work with team to establish, document, and implement a schedule for and procedures to review and re-validate processes using hazmat based on process changes, demand history, technology changes, and requirements changes that could impact the validity of authorizations o Assess customer satisfaction periodically (e.g. with time being taken by team to process authorizations) o Work with team to establish procedures for contracting initiatives involving any aspect of the HMMP – includes activities that use hazmat that are contracted or functional responsibilities that are contracted (contracted functional responsibility can still perform HMMP team tasks) o Work with team to establish local GPC procedures for hazmat purchases and ensure participation in GPC training. Provide input on hazmat requirements to base GPC manager for incorporation into GPC user training o Identify training requirements o Coordinate/schedule required training for base personnel, including training for

HMMP team members and users of the standard or legacy AF tracking system being used on base (EESOH-MIS). Verify training has been completed (e.g., by keeping a list of active HMMP team members that have received training – especially ENV 222 training), and identify/reschedule individuals that did not complete training. Also verify training was effective and review training for improvements o Provide guidance on determining whether potential materials to be procured meet the definition of hazmat per the AFI and participate in approving a hazmat “exemption” list for the base o Set up / plan for periodic, internal HMMP assessment procedures (base local assessments on Stage 1 and Stage 2 self-audits, develop/review tailored checklists) o Review and assess the validity of changes to EESOH-MIS requested by installation users; coordinate these change requests with the installation HMMP team o Ensure there is an installation-wide free-issue, reuse, and redistribution program for hazmat o Establish, approve, and track the appropriate number of hazmat tracking activities (HTAs, aka Hazmarts) for installation management of hazmat, including ensuring that the Hazmart meets ESOH requirements o Check base Self-Help programs to ensure hazmat issued through the program is appropriately tracked and reported o Establish a Data Steward Gatekeeper to ensure Safety Data Sheets that come on the base associated to products used are tracked; the gatekeeper is the focal point to submit these SDS to the AF Data Steward via prescribed AFCEC and A7CA/A7CRT approved procedures o Provide support for Panel Governance when base is member on the panel o Generate and review EESOH-MIS reports, as needed o Identify data for input to EESOH-MIS required to support supply process o Provide technical environmental assistance on hazmat issues o Review all material usages and determine if a material requires tracking and reporting based upon environmental regulatory requirements

• Interface with hazmat Users/Shops (to include training) o Interface with shop leadership to resolve data discrepancies and identify opportunities to reduce hazmat usage and update process authorizations o Implement procedures to ensure/track users maintain up-to-date process information, process names, and profiles, to include updating the AF-approved automated hazmat tracking system o Ensure that appropriate personnel are adequately trained (to include ensuring required training is scheduled, verifying training is completed by appropriate personnel, and ensuring individuals who missed training are identified and rescheduled for training) (For more information on training, refer to the Training narrative in this playbook and the Environmental Education and Training (EE&T) Playbook on the CE Portal) o Participate in the HMMP team evaluation of materials that are potentially hazardous but not loaded in EESOH-MIS o Decide whether CE blanket or process-specific authorization is appropriate for material that the HMMP team determines meets the definition of hazmat o For process-specific authorizations, evaluate each authorization submittal in the tracking system and ensure review beyond just hazmat manager review, such as CE Air manager, Hazardous Waste manager, Fire department. Decide whether to authorize with or without additional restrictions or not authorize the request. Work hard with original requestor to resolve the HMMP team non-authorization of a request to ensure no mission impact. Seek AFCEC IST guidance as needed

• Serves as the EESOH-MIS POC and ensures EESOH-MIS Data Base, System Administration, and Information System Security Officer (ISSO) responsibilities for EESOH-MIS are being met o Ensure users are meeting System Authorization Access Request (SAAR) requirement – users fill out DD Form 2875 and get the appropriate signatures o Maintaining the original form with original signatures on base for one year after termination of user's access to EESOH o Ensure new and current users’ status is tracked along with their roles in EESOH-MIS o Manage EESOH-MIS Change requests o Maintain and update CE-related hazmat data fields in EESOH-MIS as required in the

User’s manual/other training sources o Ensure hazmat on base is tracked by facility, quantity, and process to support fire protection, reduce ESOH risks, emergency response, and environmental reporting requirements o Identify and collect EESOH-MIS and other IT requirements, and post to system o Evaluate performance, perform gap analysis, and validate IT systems meet needs o Access, maintain, and utilize IT tools as directed by the AFCEC (e.g.,EESOH-MIS) o Validate data is consistent, accurate, and complete-- management effort should provide for continuous improvement of the HMMP through the quality Plan-Do- Check-Act cycle o Advocate, communicate, and train base-level users on EESOH-MIS o Ensure appropriate personnel have access to hazmat IT systems; Identify users and provide access to all IT systems required by base; Review existing and inactivated user accounts and communicate user access requirements to the EESOH-MIS help desk o Provide hazmat-specific feedback to AFCEC on AFCEC-directed IT systems o Manage EAPs within eDASH o Utilize eDASH framework to implement EMS with regard to hazmat o Coordinate and review annual program requirements with AFCEC using AFCEC-directed IT systems o Review and maintain installation SAARs o Maintain and update CE-related hazmat data fields in EESOH-MIS o Generate reports in support of ER requirements (EPCRA, CAA, etc.) and DOD/Air

Force required o Ensure local and Air-Force wide hazmat reporting is performed

• Interface with Regulators (except OCONUS) o Act as the liaison office for ensuring environmental reporting requirements are being met o Guide regulatory inspections by preparing for inspections, escorting regulators, reviewing and analyzing regulator’s report and responding as needed, tracking inspection results, ensuring notification and inspection results are entered into system, and working final issues with regulator for close-out o Complete auditing checklists ("Stage 2 checklists" at AFI, State, Federal levels) o Work with regulators, local community, and fire department on Emergency Planning and Community-Right-To-Know Act (EPCRA) requirements (see AFI 10-2501 Air Force Emergency Management (EM) Program Planning and Operations) o Ensure EPCRA reporting requirements such as Toxic Release Inventory (TRI) determinations and reporting are accomplished. Use AF hazmat tracking system to assist in preparing EPCRA reports based on chemicals stored/used on base

• Interface with Other Base Activities o Interface with Transient Contractors: Walk through contractor sites with contracting officer, COR or QA before and after occupancy and ensure that contractors follow the base HMMP or other OI procedures o Interface with Facility Utilization Board: Participate in quarterly Facility Utilization Board meetings to advise on base prioritization of CE projects based on environmental concerns o Interface with Planning Groups: Participate and advise within Planning Groups for new missions/beddowns, emergency response, community issues to ensure that environmental and HMMP requirements are addressed o Interface with Construction Activities: Attend construction planning meetings to ensure that any designs or locations are consistent with environmental and HMMP requirements. Also, conduct walk throughs of construction sites with contracting officer, COR or QA to ensure environmental compliance and proper reporting, tracking and handling of hazmat o Interface with Hazardous Waste, Air Managers, Others: Hazardous Waste & Air managers (and others as appropriate) must participate in SDS reviews and new process authorizations per AFMAN 32-7002, Environmental Compliance and Pollution Prevention, chapter 3.

o Interface with Environmental Management System focal point & Cross-functional team: Interfaces with the EMS program to ensure proper identification of EMS aspects and impacts, development of goals, targets, and plans for significant aspects, continuous improvement efforts and ESOH risk reduction o Interface with ESOH Council: Prepares briefings and tracking metrics for hazmat specific issues. Also, report on root causes for hazmat violations o Interface with ESOHCAMP Stage 2 under the AF Inspection System: Participate in internal self-audits annually to inspect hazmat shops and Hazmarts throughout the base for compliance

• Ensure proper environmental reporting and record keeping (For more information on the reporting process, refer to the Reporting narrative of this playbook and the Environmental Reporting Playbook on the CE Portal) o Maintain required hazmat related records in an approved environmental reporting system and IAW retention times prescribed by the Air Force RDS o Identify base-specific recordkeeping requirements o Collect base data, documents and maintain records/files/databases (including training records/documentation) o Verify base records are accurate and current o Adjust recordkeeping process as needed to improve accuracy o Accomplish hazmat emergency planning and reporting in accordance with EPCRA or if not the OPR, assist the EPCRA POC on providing hazmat usage data o Accomplish DOD/AF required hazmat reporting, including information derived from

EESOH-MIS, such as refrigerant usage information as part of Greenhouse Gas (GHG) inventory reporting

• Budgeting, programming and execution of Hazardous Material requirements o Oversee proper programming and recordkeeping procedures o Submit environmental-eligible HMMP funding requirements through the environmental programming/budgeting system (using ACES-PM, Environmental funding eligibility matrix & standard titles) (CE currently responsible for supporting central HTA (Hazmart) tracking system, training, HMMP TDY requirements) o Work with AFCEC to ensure all funding needs are identified and met o Work with AFCEC counterpart to plan for HMMP training; EESOH-MIS sustainment and training requirements; other workshops, hosting training as directed by AFCEC and providing training as necessary when limited AFCEC availability impacts ability for timely training o Work with AFCEC to support performance measurement o Provide regulation/legislation support for regulatory changes at state level, including reviewing and providing comments on proposed regulations through and in coordination with AFCEC, identifying required actions to implement changes to laws and regulations, briefing local leadership and management as needed, identifying potential funding requirements resulting from regulatory changes, and implementing processes to comply with new regulations applicable to the installation

Element I: Shop Functions

Introduction Narrative

Introduction

In accordance with the PAD 12-03 Implementation of Enterprise-Wide Civil Engineer Transformation and the Programming Plan (P-Plan) Revision 1 for Implementation of Enterprise-Wide Civil Engineer Transformation (PAD 12-03), Volume 2, this narrative describes the ongoing responsibilities of the Shop.

Narrative

The following shop responsibilities occur on an ongoing basis and are essential for a successful HMMP Program:

• Interfacing with HMMP Team

Shops must interface and coordinate with the HMMP Team on a regular basis. At a minimum, shops using a hazardous material must notify the HMMP Team of their existence and of any key changes that occur (i.e. changes in management, new phone numbers, process changes). Shop notices, communications and coordination with the HMMP Team must occur via email, verbal communication or through EESOH-MIS, and include the following:

o Notification of Existence: At the establishment of a new Shop, the Shop must notify the HMMP Team o Participation in HMMP Team Meetings: Shops may participate in HMMP team meetings, as required, to voice specific issues/concerns. It is a best practice for Shops to be actively involved in HMMP Team meetings. Meetings may accommodate all shops on a rotating basis or include high impact shops regularly. Shops can have more active engagement by involving or contacting their Unit Environmental Coordinator (UEC) to provide input or ideas, or to seek information etc.

o Notification of Shop Aspects or Impacts: Shops must ensure that the EMS Cross Functional Team (CFT) is informed of all Shop Aspects and Impacts and that the HMMP Team is made aware of those aspects involving hazmat or hazwaste o Notification of Changes: Shops must immediately notify the HMMP Team (and HTA, a.k.a., Hazmart) of any changes to the conditions or processes as described on an approved Process Authorization.

o NOTE: Any change to the requiring document, procedures, hazmat, draw amount or draw frequency described on an approved authorization invalidates the authorization.

Notifications of changes include the following:

Significant personnel changes, such as supervisor changes, UEC changes, and any other hazmat POC changes

Process changes, such as acquiring equipment requiring permitting, change of TO, change in mission, new materials, hazwaste generation, or engineering design changes

Relocation needs such as needs for expansion or if a mission change requires relocation

Non-Routine tasks: The HMMP team must be notified when any non-routine tasks arise (i.e. shop cleaning, self-help projects, equipment maintenance, temporary mission changes)

Needed changes to conditions of use

• HAZCOM Responsibilities

Shops must be familiar with AFI 90-821, Hazard Communication (HAZCOM) Program, which documents HAZCOM responsibilities in detail. NOTE: Shops must provide a SDS to the HMMP Team for items not loaded in EESOH-MIS.

• Monitor Shop EESOH-MIS Data

Shops must use continuous…