Attachment 9 - HAFB Contractor HAZMAT SOP - Nov 2019.pdf

HAFB Contractor Hazardous Materials Standard Operating Procedure

November 2019

66th CIVIL ENGINEERING DIVISION

HANSCOM AFB, MA 01731

OPR: 66 ABG/CEN

1. PURPOSE

To ensure that all hazardous materials (HAZMAT) brought onto Hanscom AFB are properly identified, managed, tracked, and disposed of.

2. SCOPE

This Standard Operating Procedure (SOP) applies to all government contractors involved in the purchasing, handling, and tracking of HAZMAT on Hanscom AFB. A copy of this SOP is to be made available to any employee(s) whose job may require them to purchase, handle, or track HAZMAT, and a copy will be supplied to any employee upon request.

3. GOVERNANCE

3.1 Federal Acquisition Regulation (FAR) Clause 52.223-3. Contractor will submit a list of HAZMAT required for the project to the Project Manager as soon as possible, however, no later than 15 days from the contract award date. The appropriate Safety Data Sheet (SDS) shall be submitted including any appropriate identification number, such as a National Stock Number or Special Item Number.

Project Manager will coordinate with HAZMAT Program Manager the approval process of Contractor’s HAZMAT.

Failure to submit the listing and associated SDS within that time may result in work delays non-reimbursable to the Contractor. If there is a change in the makeup of the materials previously submitted for the project making them inaccurate or incomplete, then the Contractor shall promptly notify the Project Manager of the change and immediately resubmit the list of materials for approval. Contractor will not be paid for claims related to work delays as a result of resubmission of material approval requests. Contractor is advised that no HAZMAT can be brought onto Hanscom AFB prior to obtaining materials approval. Contractor must allow a minimum of 10 working days from submission date of HAZMAT list to Project Manager for HAZMAT approval process to complete. Project Manager is responsible for timely passing the request for list approval to HAZMAT Program Manager or HAZMAT POC to ensure expeditious approval process.

3.2 Air Force Instruction (AFI) 32-7086, Hazardous Materials Management. The

AFI provides the Installation Hazardous Materials Management Program (HMMP) the authority to manage HAZMAT procurement and use, and to direct compliance with Environmental Safety and Occupational Health (ESOH) requirements. IAW the AFI, all organizations that use HAZMAT, including non-appropriated funds (NAF) activities, tenants, and contractors, participate in the HMMP. No one, to include government, contract, or military personnel, may bring a HAZMAT onto an installation, or use a HAZMAT on an installation until they receive all required authorizations.

Once the HAZMAT approval process is complete, HAZMAT Program Manager shall provide the Contracting Officer Representative (COR) a list of approved HAZMAT and supporting documentation sheets (SDSs) necessary to track HAZMAT usage information as part of monthly invoicing. Contractor must submit monthly consumption data with invoices. Invoices shall not be approved for payment until HAZMAT usage data is submitted and verified to be accurate by the HAZMAT Program Manager. Any delays or deviations in reported or unreported usage must be rectified prior to approval of monthly invoices for payment. Before contract closeout and release of final payment, the COR shall contact Project Manager to ensure the Contractor has fulfilled all contract HAZMAT requirements, including but not limited to removal of all unused HAZMAT from the installation.

3.3.1 Tracking and Reporting Contractors are required to complete and submit the Contractor HAZMAT Usage Tracking Form (attached) with monthly invoicing. The Contractor must provide the following information: material used, material unit of issue, quantities, frequency of usage, location of use/storage, process description, and intended disposal. Each HAZMAT product should be tracked on a separate form and shall be accompanied by the SDS. This includes any material in a liquid, gel or semi solid state.

Contractor shall provide HAZMAT usage reports to the HAZMAT Program Manager for the duration of the contract. For any project with a Period of Performance (POP) of six months or less, a single report is required upon project completion and prior to final payment. For any contract with a POP that exceeds six-months, HAZMAT reporting will be provided monthly.

3.3 DIVISION 1, GENERAL REQUIREMENTS, UFGS 01 35 35

ENVIRONMENTAL PROTECTION. All HAZMAT to be used to complete projects on Hanscom AFB must be documented and tracked to meet Environmental Reporting requirements. Requests for HAZMAT approval should consider the installation’s regulatory compliance with waste, air, and water requirements. Some chemicals may be restricted from usage on the installation. HAZMAT users and contractors should consider the use of the least harmful chemical to humans and the environment. When a substitute chemical with less harmful properties than the one requested for use is available, the user/contractor may be directed to use that product instead. The user/contractor is further advised to seek an alternate substitute for products containing any of the following 17 toxic chemicals targeted by the EPA for reduction:

Benzene, Cadmium, Carbon Tetrachloride, Chloroform, Chromium, Cyanides, Dichloromethane, lead, mercury, Methyl ethyl ketone, Methyl Isobutyl ketone, Nickel, Tetrachloroethylene, Toluene, 1,1,1-trichoroethane, Trichloroethylene and Xylene.

4. COORDINATION

4.1 A list of HAZMAT to be used by Contractor shall be submitted to Project Manager who will coordinate material approval process with HAZMAT Program Manager or HAZMAT POC.

4.2 A current copy of all manufacturer-specific SDS shall be submitted to Project Manager on AF Form 3000 and AF Form 3952 IAW Section 3.3.

4.3 HAZMAT Program Manager or HAZMAT POC is responsible for reviewing material submittals to determine whether product is considered hazardous and to provide authorization and tracking as required by AFI, the installation Hazardous Materials Operating Plan (HMOP) and the contract.

5. APPROVAL

5.1 The Contractor submits a list of proposed HAZMAT to the Project Manager before or within 10 days of the contract award.

5.2 Project Manager notifies HAZMAT Program Manager or HAZMAT POC and requests approval of Contractor’s HAZMAT proposal through the automated Material Information System (EESOH-MIS).

5.3 HAZMAT Program Manager or HAZMAT POC will identify the

materials that require HAZMAT usage tracking on the Contractor’s Hazardous Materials Usage Tracking Form throughout the duration of the project. Program Manager will initiate materials approval process in EESOH-MIS and complete the process within 10 days of the request made.

5.3.1 The SDS and HAZMAT processes will be evaluated by HAZMAT Program Manager or HAZMAT POC in coordination with HMMP Team.

5.3.2 The Base Safety (SE) office will review Contractor HAZMAT request relative to the health and safety of Government employees that may be working or passing by the vicinity of where the HAZMAT will be used/stored.

5.3.3 The Installation HAZMAT Program Manager or HAZMAT POC will make the final determination to either approve the HAZMAT or request an alternative product, or equivalent equal if available, with less harmful properties.

5.4 The HAZMAT Program Manager or HAZMAT POC will notify the

Contracting Office and Project Manager what materials have been approved and what HAZMAT usage reporting (Appendix A) is required.

5.5 HAZMAT Program Manager or HAZMAT POC will assign each

contractor an EESOH-MIS shop code for materials tracking purposes and will issue a HAZMAT label(s) for approved product(s). Contractor will pick up approved product labels from the Environmental Office, Building 1825.

6. REPORTING

6.1 Project Manager will request Contractor’s HAZMAT consumption data for every product approved to be submitted with monthly invoices. Project Manager will share all consumption data submittals with the HAZMAT Program Manager who will verify the quantities and the COR who will approve invoices for payment only after chemical usage is accounted for and properly verified.

6.2 Contractor is responsible for including HAZMAT usage reports for all sub-contractor products for the duration of the contract.

6.3 HAZMAT Program Manager or HAZMAT POC will turn in label in EESOH-MIS once product is spent.

7. ADDITIONS

7.1 The Contractor must notify in writing the COR and the Project Manager if a need arises to use a new HAZMAT, or additional quantities of previously approved HAZMAT, to obtain approval prior to bringing the HAZMAT onto Hanscom AFB.

7.2 HAZMAT Program Manager or HAZMAT POC is responsible for the approval of all additional HAZMAT requests proposed during the execution of the contract. Timelines for the approval of additional quantities of HAZMAT previously approved for the project may be waived.

8. TRACKING

8.1 HAZMAT Program Manager or HAZMAT POC must maintain current status of all HAZMAT usage in EESOH-MIS.

8.2 Project Manager is responsible for maintaining timely receipt of all Contractor’s HAZMAT usage (consumption) reports and for sharing information in a timely manner with HAZMAT Program Manager who will verify reported consumption data through field inspections and communicate in writing with Project Manager and the COR any field noted discrepancies and/or confirm accountability. Monthly payments and final closeout shall only be issued when satisfactorily tracking and full accountability has been demonstrated.

9. UPDATES and CONTRACT CLOSEOUT

9.1 HAZMAT Program Manager or HAZMAT POC will attend monthly

meetings with Project Managers to obtain applicable contract information updates on contract awards and to report the status of monthly HAZMAT usage submitted for established contracts.

9.2 HAZMAT Program Manager or HAZMAT POC will frequently

inspect Contractor’s HAZMAT management for compliance and to verify monthly reporting of all HAZMAT usage with assistance of Project Manager.

9.3 The Project Manager is responsible for obtaining delinquent HAZMAT usage reports from Contractors and shall promptly share information with COR and HAZMAT Program Manager. All delinquent requests for HAZMAT usage reporting must be obtained by Project Manager within 7 working days of the initial due date of the deliverable to avoid delays of monthly payment to the Contractor.

9.4 HAZMAT Program Manager will brief on Contractors’ HAZMAT

monthly status reports to the quarterly HMMP Team meetings and communicate issues needing HMMP Team’s input and/or intervention.

9.5 Upon work completion and prior to contract closeout, the Contractor is responsible for removal of all HAZMAT brought onto work site, including empty HAZMAT containers. Contractor shall communicate to Project Manager when all HAZMAT has been removed so that HAZMAT Program Manager or HAZMAT POC can perform final inspection to verify removal of project HAZMAT.

9.6 Upon satisfactory verification of Contractor’s HAZMAT (product and/or empty containers) removal off-base and verification of all spent HAZMAT in EESOH-MIS, the final payment to the Contractor shall be issued.

9.7 Should the Contractor not comply with the requirement to remove the HAZMAT, COR shall withhold the final payment under “Cleanup” requirements until all conditions of project site cleanup with respect to HAZMAT management are met.

Appendix A Contractor Hazardous Materials Usage Tracking Form

Block Description Information Required 1 Shop Code Shop Code provided by the HAZMAT Manager 2 Base Identify the Installation the Contractor is residing 3 Contractor Name Name of contractor and/or sub-contractor 4 Date of Report Date the report is prepared 5 Reporting Period The dates the reporting period covers (Example: 1 Jun 2012 -

30 Jul 2012) 6 Project/Contract Manager Contract or Project Manager assigned to the contract/project 7 Contractor POC for obtaining

Hazardous Materials information Point of contact of contractor responsible to provide SDS and usage data

8 Contract # Contract number assigned by contracting 9 Project # Project number assigned by Project Manager 10 Location of Work + Contract Title

Description Enter building number(s) where work is to take place & brief description of the work being performed by the contractor.

11 Project/Contract Start Date & End Date

Date work begins and ends (estimate)

12 Product Identifier Name of product as listed on SDS 13 Part Number Part number as listed on SDS 14 Manufacturer Name of the Manufacturer (not the distributor) 15 Type of Container The type of container that the product comes in.

Example: can, barrel, bottle, container, cylinder, drum, etc… 16 Size of Container Size as listed on container. Example: oz, lbs, Liter, Quart, Gallon, etc…

**Note** It is crucial you input the data on the form and follow the guidelines when creating your Contractor’s HAZMAT Usage Tracking Form. This form can be utilized for embedded and short term contractors. Unless there are new products that need to be added to this form, once all the HAZMAT is listed, the only changes that will occur each month are the “Total Quantity Used”. Please DO NOT REMOVE any materials that are currently listed. If the reporting month did not consume any usage, the contractor still needs to report and place a quantity of “0” for each item(s) usage and submit it to Contracting Officer.

1. Form can be found on E-Dash/Hazardous Materials/Documents/Resource Tools/Sample-Contractor HAZMAT Tracking Forms Package.