(CUI) HAFB HMOP chg 15 20230421.pdf

CUI

HANSCOM AIR FORCE BASE

HAZARDOUS MATERIALS OPERATION

PLAN

(HMOP)

Change 15 April 2023

66TH CIVIL ENGINEERING DIVISION

HANSCOM AFB MA 01731

OPR: 66 ABG/CEIE (CE Environmental Engineering Element)

Controlled by: 66 ABG/CEIE Controlled by: Environmental Engineering CUI Category: Toxic Substances Distribution/Dissemination Controls: D/L POC: Carole Kaslick 781-225-6152

DEPARTMENT OF THE AIR FORCE

HEADQUARTERS 66TH AIR BASE GROUP

HANSCOM AIR FORCE BASE MASSACHUSETTS

Revolutionizing the Warfighter’s Edge

MEMORANDUM FOR SEE DISTRIBUTION ANNEX Z

FROM: 66 ABG/CC

SUBJECT: Hanscom Air Force Base (HAFB) Hazardous Materials Operations Plan (HMOP), Change 15

1. The attached plan is effective upon receipt and supersedes the HAFB Hazardous Materials Management Plan, Change 14, dated March 2022.

2. The Office of Primary Responsibility (OPR) for this plan is the 66th Civil Engineering Division, Installation Management Flight, Environmental Element (66 ABG/CEIE).

3. Recipients should review this plan to ensure it adequately supports their requirements and submit recommended changes to the OPR, Ms. Carole Kaslick (5-6152 or e-mail carole.kaslick@us.af.mil) or to the Installation Office of Emergency Management (66 ABG/CEX), Ms. Theresa Needham (781-953-9483 or e-mail theresa.needham.2@us.af.mil).

TAONA A. ENRIQUEZ, Colonel, USAF Commander

Attachment:

HAFB HMOP, Change 15 mailto:theresa.needham.2@us.af.mil

HAFB Hazardous Materials Operations Plan Hanscom Air Force Base MA ii

SECURITY INSTRUCTIONS/RECORD OF CHANGES

Table of Contents

1. The long title of this document is Hanscom AFB Hazardous Material Operations Plan, change

15. The short title of this document is the HAFB HMOP, change 15. It supersedes the previous plan dated March 2022.

2. This plan is to be considered CONTROLLED UNCLASSIFIED INFORMATION (CUI) and complies with all governing Air Force Instructions (AFIs), US Environmental Protection Agency (EPA) regulations, and Massachusetts Department of Environmental Protection (MassDEP) regulations. This plan may be copied in part or in whole as needed for local use only.

3. Record of Changes.

CHANGE

NO.

CHANGE

DATED

DATE

ENTERED POSTED BY

1 January 2008 3 JAN 08 Theresa Needham 2 March 2009 21 APR 09 Theresa Needham 3 March 2010 22 MAR 10 Theresa Mickelwait 4 May 2011 10 MAY 11 Theresa Mickelwait 5 May 2012 18 MAY 12 Theresa Mickelwait 6 September 2013 4 OCT 13 Theresa Mickelwait 7 October 2014 20 OCT 14 Theresa Mickelwait 8 November 2015 7 DEC 15 Theresa Mickelwait 9 November 2016 30 Dec 16 Theresa Mickelwait 10 November 2017 24 Jan 2018 Theresa Needham 11 March 2019 27 Mar 2019 Theresa Needham 12 March 2020 15 Apr 2020 Theresa Needham 13 March 2021 27 April 2021 Theresa Needham 14 March 2022 8 April 2022 Theresa Needham 15 March 2023 Theresa Needham

4. Record of Review and Modification. This plan is to be reviewed annually at a minimum and sooner if changes occur.

REVIEWED BY RVW

DATE REMARKS

Theresa Needham AUG 07 Theresa Needham JAN 09 Theresa Mickelwait FEB 10 Theresa Mickelwait JAN 11 iii

REVIEWED BY RVW

DATE REMARKS

Theresa Mickelwait JAN 12 Theresa Mickelwait MAR 13 Theresa Mickelwait MAY 13 Theresa Mickelwait MAY 14 Change 7 published on 20 Oct 2014 Theresa Mickelwait MAY 15 Opened for review/update Theresa Mickelwait DEC 15 Change 8 published on 7 Dec 2015 Theresa Mickelwait DEC 16 Change 9 published Theresa Needham JAN 18 Change 10 published Theresa Needham MAR 19 Change 11 published Theresa Needham JAN 20 Change 12 published Theresa Needham JAN 21 Change 13 published T. Needham/C. Kaslick JAN 22 Change 14 published T. Needham/C. Kaslick JAN 23 See Summary of Revisions for changes.

iv

SUMMARY OF REVISIONS

Table of Contents

PG PARA REVISION/CHANGE

Administrative changes have been made throughout to include updating the Memo for Distribution page letterhead to the most current ABG letterhead, updating the Commander’s signature block to reflect the change of command effective June 2022, spelling out acronyms at first use and more frequently for clarity.

vi Acronyms Deleted list of acronyms.

vi Table Updated location of CE Material Control (MATCON).

1 References Added dates to all references and corrected titling where needed.

4 4.4.6. Updated note to reflect current process.

4 4.4.8. Appended agency names prior to listed office symbols for clarity.

6 4.5.8. Added Safety Data Sheet (SDS) compliance to example issues.

6 – 7 4.7.2.1. –

4.7.2.6. Added dates to all clauses.

7 4.7.2.2. –

4.7.2.4. Re-ordered paragraphs so that FARS clauses read in descending order.

10 4.11.3. Updated paragraph to reflect current requirements.

14 4.16.7. Added new paragraph and renumbered the remaining paragraphs accordingly.

14 4.16.11. Updated paragraph to reflect current training requirements.

18 4.2.3. Amended paragraph to reflect current requirements.

19 6 Deleted requirement to provide a recorder for meetings. Meetings are not recorded.

29 3.3. Added new paragraph 3.3.

39 3.1. Removed COCESS from this paragraph.

39 3.1.1. Amended paragraph to reflect correct processes.

43 Distro Updated distribution list to reflect current organizations on HAFB that should receive this plan.

v

TABLE OF CONTENTS

TABLE OF CONTENTS

TITLE PG #

Memorandum for Distribution Security Instructions and Record of Changes ii Summary of Revisions iv Table of Contents v List of Associated Facilities vi

BASIC PLAN 1

Annex A HMMP Team Charter and Responsibilities 17 Annex B General Procurement Procedures 21

Figure 1 HAZMAT Authorization Process 25 Annex C General Labeling, Tracking, and Storage Procedures 27

Annex D General Procedures for Redistribution and Disposal of Excess

HAZMAT 29

Annex E Shelf-Life Management 31 Annex F Removal of Excess Materials 33 Annex G HAZMAT Management Requirements for Contractors 35

Annex H HAZMAT Management Requirements for COCESS and

MATCON 39

Annex I Pollution Prevention and Air Force Policy 41 Annex Z Distribution 43 vi

LIST OF ASSOCIATED FACILITIES

Facility # Description 1110 Cargo Movement Section 1152 66 Logistics Readiness Squadron (LRS) Hazard Materials Tracking Activity

(HTA)

1833 Contractor Operated Civil Engineer Supply Store (COCESS) Center 1810 Civil Engineering (CE) Material Control (MATCON)

BASIC PLAN

Table of Contents

REFERENCES:

29 CFR 1910.1200, Occupational Safety and Health Standard (Hazard Communication) (15 Jan 2021) 29 CFR 1910.119, Occupational Safety and Health Standard (Process Safety Management of Highly Hazardous Chemicals) (15 Apr 2019) 40 CFR 262.32, Marking (30 May 2017) EO 13990, Climate Crisis; Efforts to Protect Public Health and the Environment, and Restoring Science to Tackle the Climate Crisis (20 Jan 2021) AFI 32-7001, Environmental Management (23 Aug 2019) AFI 90-801, Environment, Safety, and Occupational Health Councils (9 January 2020) AFI 90-821, Hazard Communication (HAZCOM) Program (13 May 2019) AFI 91-202, The US Air Force Mishap Prevention Program (12 Mar 2020) AFMAN 32-7002, Environmental Compliance and Pollution Prevention (4 Feb 2020) DAFMAN 91-203, Air Force Occupational Safety, Fire, and Health Standards (25 Mar 2022) AFPD 32-70, Environmental Considerations in Air Force Programs and Activities (30 Jul 2018) EPA List of Lists: Consolidated List of Chemicals Subject to the Emergency Planning and Community Right-To-Know Act (EPCRA), Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) and Section 112(r) of the Clean Air Act (Dec 2022) HAFB Hazardous Waste Management Plan (HWMP) (2022)

1. SITUATION. The Hazardous Materials Operations Plan (HMOP) directs a single point of control for hazardous materials (HAZMAT) and ozone-depleting substances (ODS), and the overall reduction of HAZMAT and ODS usage whenever possible. It ensures any organization or person using, or planning to use HAZMAT on HAFB is in compliance, to include 66 ABG and all assigned directorates, tenant organizations, contractors, visiting military, civilian groups, or persons whose activities require the use of HAZMAT with the exception of those noted on page 21, paragraph 4.1. in this plan. Each organization at HAFB is responsible for managing HAZMAT in compliance with federal, state, and local regulations, as well as AF, AF Materiel Command (AFMC), and HAFB policy.

2. MISSION. The HMOP implements the HAZMAT Management Process (HMMP) and sets forth a single, unified management philosophy, strategy, and framework for the procurement and use of HAZMAT at HAFB and is intended to fulfill the requirements of AFMAN 32-7002. The HMMP provides Air Force installations world-wide with standardized methods of managing HAZMAT procurement and ensures compliance with Environmental Safety and Occupational Health (ESOH) requirements. Additionally, it ensures only the smallest quantities of HAZMAT necessary to accomplish the mission are purchased and utilized by eliminating non-mission essential HAZMAT use and substituting reduced-risk materials whenever possible. Base compliance with federal, state, and local regulations is the responsibility of the Installation

Commander, through the CE Installation Management Flight, Environmental Engineering Element (66 ABG/CEIE). The development, implementation, and maintenance of this plan are the responsibility of 66 ABG/CEIE.

3. EXECUTION. HAZMAT usage is tracked by facility location and process when applicable.

The HAZMAT Program Manager (66 ABG/CEIE) provides customer support prior to obtaining HAZMAT. The HAZMAT Tracking Activity (HTA) is the facility where HAZMATs are managed and tracked through the Enterprise Environmental Safety and Occupational Health – Management Information System (EESOH-MIS). The HAZMAT Program Manager serves as the focal point for implementation and maintenance of the HMMP and, along with Bioenvironmental Engineering (66 MDS/SGOJ), and Base Safety (66 ABG/SE), is the only approving authority for the procurement and issuance of HAZMAT on the installation.

3.1. No individual or organization, to include military, civilian, contractor, or private party (e.g., pilots utilizing the Aero Club) may bring or use any HAZMAT to or on HAFB until they have received all required authorizations via the processes outlined in this plan. (NOTE: Certain retail organizations on HAFB are exempt from these processes. They are listed in Annex B.)

3.2. All organizations that purchase, store, issue, track, use, transport, or dispose of

HAZMAT are responsible for implementing and complying with all referenced directives and this plan.

4. RESPONSIBILITIES. The following organizations have key responsibilities in ensuring HAZMAT is properly managed on base:

4.1. The Commander, 66th Air Base Group (66 ABG/CC) will:

4.1.1. Establish and implement a program for HAZMAT control and management to include written base policies and directives.

4.1.2. Formally charter a HMMP Team to establish HAZMAT policy instructions, disseminate information, and ensure compliance with all federal, state, local, and AF laws and regulations governing HAZMAT.

4.1.3. Assign coordinating responsibilities for the HAFB HMMP to BE

(66 MDS/SGOJ), Base Safety (66 ABG/SE), the base Fire Department (66 ABG/CEF), and Operational Contracting (AFLCMC/PZI).

4.1.4. Ensure all installation host and tenant activities are active participants in the

HAFB HMMP.

4.1.5. Ensure any resource requirements in this plan are addressed and programmed as needed.

4.2. The Base Civil Engineer (66 ABG/CE) will: Assign the responsibility for the HAFB HMMP to the Installation Management Flight, Environmental Element (66 ABG/CEIE).

4.3. The Section Chief, CE Installation Management Flight, Environmental Element (66 ABG/CEIE) will:

4.3.1. Ensure the HAFB HMMP pursues feasible pollution prevention opportunities.

4.3.2. Ensure the institutional resource requirements in this plan are identified and programmed.

4.3.3. Aggressively pursue HAZMAT substitutions, HAZMAT reductions, and P2 technologies to minimize HAZMAT use.

4.3.4. Develop and implement waste minimization procedures (material substitution, process assessments, technology transfer, and recycling potential).

4.3.5. Report HAZMAT purchases, usage, and releases for the entire installation to

AF, local, state, and federal authorities as required.

4.3.6. Process, manage, and track all hazardous waste (HAZWASTE) generated on

HAFB for disposal through the DLA-DS contract prescribed in AFMAN 32-7002, and IAW the

HAFB HWMP.

4.3.7. Comply with all federal, state, local, and AF environmental laws and regulations.

4.4. The HAZMAT Program Manager (66 ABG/CEIE) will:

4.4.1. Lead the HAFB HMMP Team and conduct HMMP Team meetings at least semi-annually, or more frequently as needed.

4.4.2. Ensure HAZMAT on the installation is tracked at a level sufficient to meet environmental reporting requirements and support fire protection, ESOH, and disaster response efforts.

4.4.3. Submit environmental-eligible HMMP funding requirements through the environmental programming/budgeting system via HQ Air Force Civil Engineer Center

(AFCEC).

4.4.4. Complete installation Emergency Planning and Community Right-to-Know Act

(EPCRA) reporting requirements using data from EESOH-MIS, as appropriate.

4.4.5. Assess, at a minimum, environmental, fire protection, and emergency response risks of, and control options for material and process authorizations.

4.4.6. Ensure the proper labeling of all HAZMAT stored on HAFB. Print and issue labels to the contractor for all approved HAZMAT to be brought on to the installation. NOTE:

Labelling of HAZMAT procured by all Hanscom personnel will be done by the HTA, except for the CE Material Control (MATCON) HTA which is completed by the Contractor Operated Civil Engineering Supply Store (COCESS).

4.4.7. Ensure all material handling procedures and practices associated with HAZMAT are stored in HAFB shops and are maintained and conducted IAW all applicable Occupational Safety and Health Agency (OSHA), Department of Transportation (DOT), and Environmental Protection Agency (EPA) regulations.

4.4.8. Employ an interdisciplinary HAZMAT Users team approach to execute the

HMMP Policy. This team will be comprised of representatives from the CE Installation Management Flight, Environmental Engineering Element (66 ABG/CEIE), Bioenvironmental Engineering (66 MDS/SGOJ), Base Safety (66 ABG/SE), The Hanscom Fire Department (66 ABG/CEF), CE Operations Flight (66 ABG/CEO), Logistics Readiness Squadron (66 LRS), Force Support Squadron (66 FSS), and Operational Contracting (AFLCMC/PK-PZI).

4.4.9. Maintain all policy, instruction, and direction from 66 ABG/CEIE and higher headquarters. Disseminate and provide guidance and information to all HAFB HAZMAT requesters and users.

4.4.10. Implement Air Force Policy governing the purchase, use, and management of controlled ODSs.

4.4.11. Execute the HMMP by serving as the installation focal point for all HAZMAT-related issues and concerns.

4.4.12. Update the HMOP annually or as installation policies and procedures are modified, and issue these changes through annual updates distributed to HAFB organizations that purchase, store, use, track, transport, or dispose of HAZMAT.

4.4.13. Develop and implement local operating procedures that meet AFMC and

HAFB policy relative to HAZMAT reductions and control, and develop guidance for work area supervisors.

4.4.14. Approve or disapprove all HAZMAT requests and authorizations received through EESOH-MIS.

4.4.15. Coordinate the efforts of all HAFB host and tenant activities in establishing and implementing operating processes to track, control, and reduce the variety and quantities of HAZMAT in use, HAZMAT in storage, and the disposal of hazardous waste.

4.4.16. Ensure HAZMAT users store HAZMAT in compliance with all OSHA

HAZMAT storage and handling regulations. The usage of HAZMAT must be tracked in EESOH-MIS from cradle-to-grave.

4.4.17. Manage the initial HAZMAT request submitted in EESOH-MIS and track its progress through the approval process.

4.4.18. Conduct site assistance visits to ensure compliance with AFI 32-7001, inform the organizational POC of any observations/findings, and track Environmental Inspection Process (EIP) findings in the Enforcement Actions, Spills, and Inspections Environmental Reporting (EASIER) database through to closure.

4.4.19. Review all EESOH-MIS HAZMAT data and SDS submittals to assess potential environmental requirements and policies for all new item requests.

4.4.20. Provide training to HAZMAT users and Facility Managers annually.

4.5. 66th Medical Squadron, Bioenvironmental Engineer Flight (66 MDS/SGOJ) will:

4.5.1. Participate in the installation HMMP Team to address potential health issues.

4.5.2. Provide guidance and information to HAFB HAZMAT requesters and users regarding OSHA HAZCOM Standard Requirements.

4.5.3. Be responsible for tracking and controlling radioactive HAZMAT on HAFB.

4.5.4. Ensure appropriate Bioenvironmental Engineering personnel receive operator training on the EESOH-MIS tracking system.

4.5.5. Use EESOH-MIS to review new HAZMAT requests for potential health hazards and personal protective equipment (PPE) control requirements.

4.5.6. Research and maintain health, safety, and environmental information concerning substitute materials.

4.5.7. Perform workplace assessments in areas using regulated HAZMAT, and where significant quantities of hazardous waste (HAZWASTE) are generated. Potential health hazards are assessed and opportunities to substitute a less hazardous material are highlighted. NOTE:

Assessments will not be conducted on contractors or contracted operations.

4.5.8. Ensure the shop supervisor and/or commander is notified via survey letter of all discrepancies found with HAZMAT issues (e.g., storage, handling, labeling, licensing, SDS compliance etc.) during all routine visits to workplaces.

4.5.9. Evaluate the intended methods of use and protective measures in place.

4.5.10. Provide technical assistance on matters relating to Safety Data Sheet (SDS) interpretation, PPE requirements, and occupational health controls for Air Force personnel.

4.5.11. Maintain access to SDSs contained in EESOH-MIS.

4.5.12. Attend HAZMAT Users meetings as scheduled by 66 ABG/CEIE.

4.6. Base Safety Office (66 ABG/SE) will:

4.6.1. Participate in the installation HMMP Team to address potential safety issues.

4.6.2. Use EESOH-MIS to review safety risks and control options.

4.6.3. Perform annual facility inspections at each issue point and zone (except for contractor run, or contracted operations) IAW AFI 91-202 to ensure compliance with OSHA regulations.

4.6.4. Provide guidance and suggestions on HAZMAT storage and personal protective equipment in accordance with the appropriate OSHA and safety regulations as needed.

4.6.5. Attend HAZMAT Users training as scheduled by 66 ABG/CEIE.

4.7. Operational Contracting (AFLCMC/PK-PZI) will:

4.7.1. Participate in the installation HMMP Team to address potential procurement issues.

4.7.2. Include HAFB-specific contract requirements in each contract vehicle (e.g., contract, purchase order, BPA, etc.). These processes will include locally developed HAZMAT tracking and reporting tasks necessary to ensure contractor compliance with this plan as well as compliance with the following Federal Acquisition Regulations (FARs), Air Force Federal Acquisition Regulations (AFFARs), and Defense Federal Acquisition Regulations (DFARs) Clauses:

4.7.2.1. FAR Clause 52.223-3, Hazardous Material Identification and Material

Safety Data. (Feb 2021)

4.7.2.2. FAR Clause 52.223-5, Pollution Prevention and Right-to-Know Information. (May 2011)

4.7.2.3. FAR Clause 52.223-7, Notice of Radioactive Materials. (Jan 1997)

4.7.2.4. FAR Clause 52.223-19, Compliance with Environmental Management

Systems. (May 2011)

4.7.2.5. DFAR Clause 252.223-7006, Prohibition on Storage, Treatment, and

Disposal of Toxic or Hazardous Materials. (Sep 2014)

4.7.2.6. AFFARS Clause 5352.223-9001, Health and Safety on Government

Installations. (Oct 2019)

4.7.3. Obtain guidance on HAZMAT determination, authorization, and tracking for contractors and contract operations from the HMMP Team as required.

4.7.4. Before contract closeout, contact 66 ABG/CEIE, and the contract Quality

Assurance Personnel (QAP) to ensure the contractor has fulfilled all contractual HAZMAT requirements.

4.7.5. Ensure HAZMAT requirements for Government Purchase Card (GPC) purchases of HAZMAT are included in local GPC training.

4.7.6. Attend HAZMAT Users training as scheduled by 66 ABG/CEIE.

4.8. Director, 66th Logistics Readiness Squadron (66 LRS/CL) will:

4.8.1. Comply with this HMOP.

4.8.2. Designate appropriate LRS personnel (with supply expertise) to participate on the HMMP Team.

4.8.3. Establish the base Cargo Movement Section (building 1110) for delivery of base

HAZMAT.

4.8.4. Establish the LRS HTA (building 1152) and appoint the LRS HTA supervisor.

4.8.5. Ensure the LRS HTA maintains and updates the HAZMAT-specific fields in the installation’s standard supply system (e.g., issue exception code 9).

4.9. 66th LRS Materiel Management Customer Support Section (66 LRS/LGRMC) will:

4.9.1. Maintain and update the HAZMAT specific fields in EESOH-MIS.

4.9.2. Conduct data queries as directed by the installation HMMP Team.

4.9.3. Receive, research, process, and approve or disapprove of installation ozone-depleting substances (ODS) and HAZMAT requests.

4.9.4. Only allow authorized parties to order and receive HAZMAT.

4.9.5. Coordinate all AF Form 3953 requests for ODS and maintain a record of all processed AF Form 3953 requests.

4.9.6. Review all GPC requests for HAZMAT purchase and assign control numbers to each request received. This may be accomplished in EESOH-MIS or on a hard copy form.

4.9.7. Certify that requested products do not contain any ODS unless there is an approved AF Form 3953 that authorizes it.

4.9.8. Verify all chemical authorizations and quantity requirements are recorded in

EESOH-MIS prior to procurement.

4.9.9. Ensure that HAZMAT is properly procured, and that the organization request is authorized in EESOH-MIS. NOTE: To further identify the area of use, each organization or shop code must be established as HAZMAT using either the HM or HZ code in EESOH-MIS. This code will aid in the identification of HAZMAT ordered through EESOH-MIS.

4.9.10. Notify 66 ABG/CEIE when HAZMAT is received without authorization in

EESOH-MIS.

4.9.11. Perform all stock control and demand processing functions to ensure that the requested and approved materials are en-route as soon as possible to the customer.

4.9.12. Provide coordination and assistance to ensure that the correct Material Stock

Number (MSN) or Local Stock Number (LSN) is assigned. Perform research and analysis to further ensure that no excess is due in.

4.9.13. Maintain records of all GPC HAZMAT purchase requests and ensure that each has an assigned control number.

4.9.14. Brief HAZMAT procedures at GPC training classes.

4.9.15. Maintain and provide the Government Services Administration (GSA) Defense Logistics Agency (DLA) Paints and Coatings, High-to-Low Volatile Organic Compound (VOC) Cross-Reference List to all organizations who require or request it. Check this list prior to processing EESOH-MIS orders to ensure that only low VOC paints and coatings are purchased unless the processes being requested are exempted from National Emissions Standards for Hazardous Air Pollutants (NESHAP) Reporting.

4.9.16. Utilize the Document Identifier Code A5J in the Integrated Logistics Systems –

Supply (ILS-S) as required.

4.9.17. Load all new requests for Hazardous Material Distribution Support Center

(HDSC) supported National Stock Numbers into the ILS-S using the customer’s Organizational Shop Code.

4.9.18. Review, validate, and be the approval authority of HAZMAT GPC and non-appropriated fund (NAF) requests.

4.9.19. Attend HAZMAT Users training as scheduled by 66 ABG/CEIE.

4.10. 66 LRS Asset Management Section, HTA Program Manager/Supervisor (66 LRS/LGRMS) will:

4.10.1. Participate as HMMP Team members.

4.10.2. Provide a safe and healthy work environment.

4.10.3. Work with CE, BE, Base Safety, and Unit Environmental Coordinators (UECs) to ensure HTA facilities meet applicable ESOH requirements.

4.10.4. Ensure the HTA performs the functions described in this plan and AFI 32-

7001.

4.10.5. Ensure that HTA personnel are trained on the use of EESOH-MIS.

4.10.6. Plan, program, and budget for all necessary HTA resources (personnel, equipment, and funding).

4.10.7. Manage the material receipt, inspection, issue, labeling, and distribution of

HAZMAT received on HAFB.

4.10.8. Develop procedures to ensure that HAZMAT compliance is maintained during all established shifts.

4.10.9. Ensure that all HTA personnel receive occupational safety and health training appropriate for their HAZMAT related duties.

4.10.10. Submit changes requested for EESOH-MIS to 66 ABG/CEIE for review and validation.

4.10.11. Attend HAZMAT Users training as scheduled by 66 ABG/CEIE.

4.11. 66th LRS Materiel Management Hazardous Materials HTA. (66 LRS/LGRMSH) will:

4.11.1. Initiate the HAZMAT tracking process for materials entering HAFB that are ordered by HAZMAT users.

4.11.2. Receive all HAZMAT from the Cargo Movement Section (building 1110) daily.

4.11.3. Verify that HAZMAT shipments are received with proper documentation and labels that identify the products. This includes all SDSs and appropriate Hazard Communication (HAZCOM) labels. Materials should be received and issued against the latest available SDS for that material. SDSs older than five years should not be used unless it’s been verified that it is still the current document.

4.11.4. Verify authorization for all HAZMAT requests in EESOH-MIS.

4.11.5. Notify the HAZMAT Program Manager if the SDS is not available in EESOH-

MIS upon receipt of the material. Temporarily hold the material pending input of the SDS into EESOH-MIS by the Data Steward.

4.11.6. Validate that the material received is in undamaged containers and has a serviceable shelf life.

4.11.7. Be the receiving function for 66 LRS/LGRD’s Cargo Movement Section submissions, and track Transportation Discrepancy Report (TDR) submissions for any damaged or expired product that has been delivered damaged. LGRM tracks and investigates the Supply Discrepancy Report (SDR). Ensure that 66 LRS Customer Support Section receives a copy of the TDR/SDR. Ensure that the 66 LRS Customer Support Section receives a copy of the Record of Discrepancy/SDR.

4.11.8. Ensure that all HAZMAT received from the HTA to each issue point is transferred in EESOH-MIS.

4.11.9. Ensure that EESOH-MIS is configured to print labels with a distinct color background for the LRS HTA.

4.11.10. Ensure that all HAZMAT received without proper GPC authorization will be held back and reported to the HAZMAT Program Manager to notify the user. The user will have 10 working days to get the proper GPC authorization, and at that time if no authorization is received, the HAZMAT will be returned to the vendor. In the event it’s not returnable, it will be slated for the reuse program.

4.11.11. Establish a Reuse/Recycling Program to minimize waste material as outlined in Annex D as a method of pollution prevention as described in AFMAN 32-7002.

4.11.12. Manage records information on all excess HAZMAT for reissue to maximize redistribution and minimize material disposal.

4.12. Commanders and Directors of All Units/Agencies Using HAZMAT will:

4.12.1. Ensure unit Quality Assurance Personnel (QAP) are monitoring contractors for compliance with installation HAZMAT policies and procedures.

4.12.2. Ensure units have guidance and training for preparing and submitting requests for HAZMAT through EESOH-MIS.

4.12.3. Ensure units are in compliance with this plan, and all guidance, policy, laws, and regulations governing the use, storage, and disposition of HAZMAT on HAFB.

4.12.4. Notify the HTA Program Manager (66 LRS/LGRMS) of any changes to the conditions or processes as described on the approved authorization in EESOH-MIS. NOTE:

Any changes to the conditions or processes described in EESOH-MIS voids the authorization and the process must be started over.

4.12.5. Ensure that all HAZMAT users attend HAZMAT Users training as scheduled by 66 ABG/CEIE.

4.13. HAZMAT User Work Area Supervisors and Shop Leads will:

4.13.1. Assess chemical product technical data, HAZMAT information, SDSs, and other resources in order to properly identify actual and potential safety and health risks, hazardous properties, necessary control measures, and PPE.

4.13.2. Provide safe and healthy work areas.

4.13.3. Use EESOH-MIS to submit HAZMAT requirements to the HTA.

4.13.4. Provide additional information such as application methods, transfer methods, etc. to authorizing offices as requested to complete the EESOH-MIS entry.

4.13.5. Comply with all conditions of use as identified on approved authorization in

EESOH-MIS.

4.13.6. Notify the HTA Program Manager (66 LRS/LGRMS) of any changes to the conditions or processes as described on the approved authorization in EESOH-MIS. (Note: any changes to the conditions or processes described in EESOH-MIS voids the authorization and the process must be started over.)

4.13.7. When applicable, procure all HAZMAT using the process defined in Annex B for tracking, regardless of payment method (e.g., ILS-S; GPC, NAFP Card, COCESS, etc.).

4.13.8. Ensure work area personnel receive HAZCOM training IAW 29 CFR 1910 and HAZCOM standards as outlined in AFI 90-821; and that the training is documented on each employee/member’s AF Form 55 or equivalent.

4.13.9. Maintain an inventory listing all of HAZMAT used or stored in the work area.

4.13.10. Maintain SDSs for all HAZMAT used or stored in the work area.

4.13.11. Only maintain limited quantities of HAZMAT in the work area. Turn in excess HAZMAT to the HTA as soon as possible for reuse or redistribution as appropriate.

4.13.12. Participate in all HAZMAT User training.

4.14. CE Material Control (MATCON) and Contractor Operated CE Supply Store (COCESS) will:

4.14.1. Establish CE MATCON as a separate HTA for all HAZMAT orders received and stored for use by 66 ABG/CE.

4.14.2. Utilize EESOH-MIS to track and control all HAZMAT used within their organization to include receipt, issue, turn-in, transfer, and disposal of all HAZMAT utilized within their area of responsibility.

4.14.3. Ensure all HAZMAT stored, received, and used within their organization, regardless of the acquisition mode, are properly labeled and entered into EESOH-MIS for material tracking.

4.14.4. Ensure all manufacturer guidelines and professional recommendations for control, humidity, temperature, cleanliness, and material handling relative to storage and use are followed.

4.14.5. Maintain only limited quantities of HAZMAT in the work area and turn in excess HAZMAT to the HTA for reuse or redistribution as soon as possible. Supervisors must avoid storing excess or expired products at their job site or in their work area.

4.14.6. Enforce all applicable OSHA and HAZCOM Standard 29 CFR 1910 regulations for storage and handling of any HAZMAT stored within their areas of responsibility.

4.14.7. Ensure SDSs for all HAZMAT used within their area of responsibility are maintained and readily accessible to the Work Area Supervisors and employees who utilize the

HAZMAT.

4.14.8. Attend HMMP Team meetings as scheduled by 66 ABG/CEIE.

4.14.9. Establish a Reuse/Recycling Program to minimize waste material as outlined in

Annex D as a method of pollution prevention as outlined in AFMAN 32-7002.

4.15. Government Purchase Card (GPC) and Non-Appropriated Fund (NAF) P-Card Holders will.

4.15.1. Ensure all requests in EESOH-MIS are properly completed and approved prior to the purchase of any HAZMAT.

4.15.2. Ensure that the following address is used for HAZMAT shipments to LRS:

66 LRS/LGRMSH, 29 Randolph Road, Hanscom AFB, MA 01731-5000 ATTN: POC, EESOH- MIS GPC Approval Number.

4.15.3. Ensure that EESOH-MIS GPC authorization number and EESOH-MIS shop codes are entered in the remarks section of all approved HAZMAT GPC order shipping documents.

4.15.4. Pick up their HAZMAT when received by the HTA. If assistance is needed for bulky items, customers may request delivery assistance through the 66 LRS Vehicle Operations Section by emailing 66.LRS.LGRDDO.Vehicle.Request@us.af.mil.

4.16. HAZMAT Users will:

4.16.1. Follow and adhere to this plan and all base instructions, policies, and procedures developed by AFMC, the installation HTA, and the HAFB HMMP Team.

4.16.2. Process all new HAZMAT requests through EESOH-MIS.

4.16.3. Request only the amount of HAZMAT required.

mailto:66.LRS.LGRDDO.Vehicle.Request@us.af.mil

4.16.4. Eliminate or reduce (at the source) the use of HAZMAT by changing or modifying their work processes when authorized and approved by governing regulations, technical directives, and approval authorities.

4.16.5. Substitute less hazardous or non-hazardous chemicals when possible.

4.16.6. Ensure only HAZMAT approved and authorized in EESOH-MIS is used.

4.16.7. Perform occasional (not less that annual) inventory of the HAZMAT in the shop to ensure it matches the inventory listed in the EESOH-MIS.

4.16.8. Ensure that all flammable lockers have an inventory list on the inside and posted to outside of the cabinet.

4.16.9. Inform the 66 LRS Customer Support Section and HTA Program Manager

(66 LRS/LGRMS) when excess material is on hand.

4.16.10. Prior to the acquisition of any HAZMAT that has been identified as an ODS, obtain a waiver from Air Staff through the 66 LRS Customer Support Section. Upon receipt of the waiver, the requester must complete the EESOH-MIS request.

4.16.11. Participate in all HAZMAT User and EESOH-MIS training annually.

4.17. Contractors will:

4.17.1. Ensure that no HAZMAT is used or stored on base without prior authorization and approval from the HAZMAT Program Manager. NOTE: Contractor owned HAZMAT must be of a type and quantity that is listed in EESOH-MIS prior to the contractor bringing the HAZMAT on to the installation.

4.17.2. Ensure that manufacturer’s handling and storage guidelines, and professional recommendations for control of humidity, temperature, and cleanliness are followed.

4.17.3. Submit a list of HAZMAT required for the project to Contracting Officer

Representative (COR) as soon as possible, however, no later than 15 calendar days from the contract award date. The appropriate SDS shall be submitted including any appropriate identification number, such as a National Stock Number or Special Item Number.

4.17.4. The contractor will pick up labels from the HAZMAT Program Manager at building 1825 and will apply them to the containers.

4.17.5. Notify the COR and CE Engineering Project Manager, in writing, whenever a new HAZMAT, or additional quantities of a previously approved HAZMAT are required in order to obtain approval prior to bringing the HAZMAT onto the installation.

4.17.6. Notify the HAZMAT Program Manager, in writing, within two working days when a HAZMAT container is empty or removed from the base.

4.17.7. Ensure employee HAZCOM training is complete and documented prior to commencement of any work involving HAZMAT on base.

4.17.8. Complete and maintain the Contractor HAZMAT Usage Tracking Form.

4.17.9. Be responsible for the disposal of HAZMAT containers off-base. This includes excess HAZMAT containers, partially used and all empty containers.

4.17.10. Provide a HAZMAT Usage Report to the Service Contract Manager as part of monthly invoicing. Usage reports must accompany invoicing in order to process payments in a timely manner.

4.17.11. Ensure that all sub-contractor HAZMAT usage for the duration of their contract is included in the Contract Bid Package and HAZMAT Usage Report.

4.17.12. The Service Contract Manager will post the contractor’s monthly HAZMAT

Usage Reports, consumption records, and monthly invoices to the Wide Area Workflow Site.

4.17.13. 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 IAW the terms of the contract. The contractor will notify the CE Engineering Flight Project Manager when all HAZMAT has been removed so that the HAZMAT Program Manager can perform their final inspection to verify that the HAZMAT has been removed in a satisfactory manner IAW FAR 52.223-3.

4.17.14. Ensure compliance with all contractor specific mandates outlined in Annex G.

5. ADMINISTRATION AND LOGISTICS. This plan is executable using normal, HAFB administrative and logistics channels.

6. COMMAND AND SIGNAL. Normal command channels apply.

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ANNEX A TO HAFB HMOP

HMMP TEAM CHARTER AND RESPONSIBILITIES

Table of Contents

1. PURPOSE: This charter provides guidance and instruction for the formation and execution of the HAFB HMMP Team as required by paragraph 3.2.1 of AFMAN 32-7002, Hazardous Materials Management. The cross-functional HMMP Team develops and directs HAFB policy and program requirements associated with HAZMAT as described in AFMAN 32-7002. The team provides oversight and coordination for the installation HAZMAT Management tasks IAW

AFMAN 32-7002.

2. BACKGROUND: The HMMP Team supports accomplishment of the Air Force mission by minimizing and effectively managing dependence on HAZMAT within acceptable levels of mission and ESOH risk, while reducing associated total ownership cost.

3. AUTHORITY: The following instructions, executive orders and policies provide requirements and actions for the HMMP Team:

3.1. 29 CFR 1910.1200, Occupational Safety and Health Administration, Hazard Communication (15 January 2021)

3.2. 40 CFR, Protection of Environment, Chapter 1 (25 January 2023)

3.3. AFPD 32-70, Environmental Considerations in Air Force Programs and Activities (30

July 2018)

3.4. AFPD 90-8, Environment, Safety and Occupational Health and Risk Management (23 December 2019)

3.5. AFMAN 32-7002, Environmental Compliance and Pollution Prevention Chapter 3, Hazardous Material Management (4 February 2020)

4. MEMBERSHIP: The HMMP Team consists of the below named units and organizations.

4.1. HMMP Team Lead: 66 ABG/CEIE. Oversees the HMMP Team and facilitates all meetings as required.

4.2. HMMP Team Members:

4.2.1. 66 ABG/CEIE (Environmental Element): Ensures that all matters involving environmental compliance, remediation, pollution prevention, and conservation are observed and followed.

4.2.2. 66 LRS/LGRM/LGRD (Materiel Management and Traffic Management):

Establishes the HTA and HAZMAT receiving and distribution procedures, and maintains and updates HAZMAT-specific fields in the HAFB ILS-S.

4.2.3. 66 ABG/SE (Safety Office): Reviews all new product requests received in

EESOH-MIS to ensure all matters involving occupational safety are observed and followed.

4.2.4. 66 ABG/SGOJ (Bioenvironmental): Reviews all new product requests in

EESOH-MIS to ensure that all matters regarding threats to human health and the environment are observed and followed.

4.2.5. 66 ABG/JA (Legal Office): Provides legal counsel regarding the HAZMAT management process.

4.2.6. 66 ABG/CEF (Fire Department): Assesses fire protection and emergency response risks of, and control options for, material and process authorizations.

4.2.7. AFLCMC/PK/PZI (Contracting):

4.2.7.1. Oversees outside contractors and GPC processes.

4.2.7.2. Ensures adherence to standard procedures when introducing HAZMAT on base and before contract closeout.

4.2.7.3. Ensures that the contractor has fulfilled all contract HAZMAT requirements.

4.2.8. 66 ABG/CEOER (CE MATCON): Operates the satellite HTA for materials procured by COCESS.

4.2.9. HTA Supervisors: Ensure that HTA facilities and personnel meet applicable

ESOH and training requirements.

4.2.10. Other Functional Areas: Other areas are called in to participate as members of the team, on an as-needed basis.

5. RESPONSIBILITIES: The HMMP Team reports directly to the ESOH Council. It has the authority and responsibility to elevate unresolved HMMP issues or concerns in order to invite senior leadership involvement when problems or obstacles hinder the effectiveness of the HMMP. The HMMP supports accomplishment of the Air Force mission by minimizing and effectively managing dependence on HAZMAT within acceptable levels of mission and ESOH risk, while reducing associated total owner costs. The specific responsibilities of the HMMP are to:

5.1. Collect and maintain HAZMAT data in EESOH-MIS, the standard AF tracking system used on HAFB.

5.2. Protect the safety and health of personnel of Air Force installations and communities surrounding Air Force installations from Air Force misuse of HAZMAT.

5.3. Manage mission critical requirement for Class I ODS.

5.4. Provide the work area supervisor with information necessary to comply with applicable

HAZMAT risk communication requirements, especially the OSHA Hazard Communication Standard.

6. ADMINISTRATION: The HMMP Team Lead will schedule semi-annual meetings, arrange for the meeting room, and prepare official meeting minutes. Meeting minutes will be completed within five working days after each completed HMMP Team meeting and forwarded to HMMP Team members. HMMP Team members will be given 10 working days to respond with edits.

Signed meeting minutes will be emailed to all HMMP Team members 15 working days after the meeting and posted to e-DASH as required.

7. MEETINGS: The HAFB HMMP Team will convene semi-annually or as directed by the HMMP Team Chair. This meeting may be combined with the Environmental Management System Cross Functional Team and ESOH Council meetings, as appropriate.

ANNEX B TO HAFB HMOP

GENERAL PROCUREMENT PROCEDURES

Table of Contents

1. SITUATION. The first step in the procurement process is to identify the need for a HAZMAT product, and the specific product desired. The HAZMAT user then works in conjunction with their organization’s MATCON, COCESS, or administrative supply technician to procure the material. At this time, pollution prevention is applied to ensure only HAZMATs that are truly needed are ordered. The following questions will be asked before any HAZMAT is procured:

1.1. Do you absolutely need this material?

1.2. Can you use a less hazardous material in its place?

2. MISSION. This annex is written to ensure HAZMAT procurement procedures are clear to all HAZMAT users on HAFB.

3. EXECUTION. See Figure 1 for the HAZMAT Authorization Process flowchart.

3.1. First-time Material Procurements. NOTE: Each evaluator in this process has the authority to approve or disapprove any chemical prohibited for use IAW federal, state, local, and AF regulations and policies.

3.1.1. The User will: Submit a purchase request through EESOH-MIS to the

HAZMAT Program Manager, along with a safety data sheet (SDS) for the material being requested. Contractors must coordinate HAZMAT requests to be brought onto the base through Contracting.

3.1.2. The HAZMAT Program Manager will: Review the request and the SDS.

3.1.3. The Installation Management Flight, Environmental Engineering Element

(66 ABG/CEIE) will: Evaluate the request in EESOH-MIS for environmental requirements, recommend and provide suitable substitutes whenever possible, and ensure the material is authorized for use. This will also be done for all contractor submissions.

3.1.4. Base Safety (66 ABG/SE) will: Evaluate the request to review supervisor recommendations for proper PPE as required per the chemical’s SDS.

3.1.5. Bioenvironmental Engineering (66 MDS/SGOJ) will: Evaluate the request for potential health hazards and PPE control requirements

3.2. Post-Approval Procurements. After a material has been approved by the HAZMAT Program Manager, it can be procured via four channels at HAFB:

3.2.1. The GPC or NAF P-Card. These are held by individual organizations for

HAZMAT purchases. The GPC or NAF P-Card holder makes these purchases and coordinates them with the HTA.

3.2.2. The HAFB Self-Help Store maintains a supply of common construction materials that can be obtained by CE Facility Managers through EESOH-MIS to perform minor facility renovations or repairs on their own time. The Self-Help Store is responsible for notifying CE MATCON HTA of any transferred material.

3.2.3. Purchases that are not covered under contract (see Annex G in this plan) are accomplished through the Form 9 purchase process. All Form 9’s must be approved via the 66 LRS/LGRM authorization process.

3.2.4. If the HAZMAT has a proper material stock number, it should be ordered by the

GPC or NAF P-card holder through EESOH-MIS.

3.3. Hazardous Materials Shipment. Purchased hazardous materials are to be shipped to the HTAs (excludes geographically separated units of Fourth Cliff Family Recreation Area and the Sagamore Hill Solar Observatory due to their distance from the base).

4. EXEMPTIONS.

4.1. The Army and Air Force Exchange Service (AAFES) Base/Post Exchange (BX/PX), Defense Commissary Agency (DeCA), the Base Service Station (Auto Pride) Retail Sales, Hunt Housing Maintenance, and Massachusetts Institute of Technology, Lincoln Laboratory (MIT/LL) are exempted from this procurement and inventory process.

4.2. Chemical Tracking Waiver List. The following chemicals are exempt from being tracked on HAFB:

• Precious Gemstone Substrates/Wafers (e.g., sapphire, diamond etc.)

• Sputtering Targets

• Crystals (e.g., sapphire, quartz etc.)

• Heat Sink Compound

• Pressure Treated Lumber

• Sealed Lead Acid Batteries

• Canned Air

• Turtle Wax

• Sodium Bicarbonate

• Ice Melt – unless purchased in bulk (e.g., cases, gallons, drums, etc.)

• Face Paint, Camouflage

• Rug + Upholstery/Carpet Cleaner

• Window Cleaner-unless purchased in bulk (e.g., cases, gallons, drums, etc.)

• Laundry Detergent

• Dishwashing Detergent

• Furniture Polish

• Bathroom Cleaners-unless purchased in bulk (e.g., cases, gallons, drums, etc.)

• Silica Gel

• General office Supplies:

o Glue (e.g., Elmer’s, glue stick, etc.)

o Ink Pads o Toner Cartridges/Ink Jet Cartridges o Developer for Printers o Computer Screen Cleaner/Dry Erase Board Cleaner

• Shoe Wax/Polish and Stain

• Scouring Powder

• Gold/Brass Cleaner

• Metal Polish

• Shredder Oil

• Distilled Water

• Simple Green

• Hand Cleaner

• General Purpose Cleaner-unless purchased in bulk (e.g., cases, gallons, drums, etc.)

• Alcohol Towelettes (e.g., isopropyl wipes used for medical purposes)

• Wood Filler (Wood Dough)

• Dap Glazing Compound

• Goof-Off

• Mouse traps

• Lamps/lightbulbs (please ensure sodium lamps and fluorescent are recycled at the

HazWaste Bldg)

• Carbon Cartridge, Gas Mask Canisters

• Snoop Detector (water/Surfactant)

• Alkaline Batteries (AA, AAA, C, D, 9 VOLT)

• Hand Sanitizer

• Bioesque

4.3. Dental Waiver List. The following products used in the HAFB Dental Clinic are exempted from being tracked on HAFB:

• Arestin (RX)

• Variolink Esthetic DC-try in

• Hemodent

• Prophy Paste Assorted with/without fluoride

• Prophy Pumice

• ULTRASEAL XT PLUS REFILL

• ICON Smooth Surface

• Filtek Supreme Flowable Restorative (2 different shades A1 + A2)

5. SUBSTITUTIONS. Any 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-trichloroethane

• Trichloroethylene

• Xylene(s)

Figure 1 - HAZMAT Authorization Process.

ANNEX C TO HAFB HMOP

GENERAL LABELING, TRACKING, AND STORAGE PROCEDURES

Table of Contents

1. SITUATION. All HAZMAT received at HAFB is managed through its life-cycle using EESOH-MIS. Base organizations utilize EESOH-MIS for HAZMAT tracking. EESOH-MIS makes use of barcode technology to track HAZMAT. All HAZMAT containers are assigned a unique tracking number and a label is applied to the container to ensure it can be tracked from the moment it arrives on base until its eventual disposition (i.e., cradle-to-grave).

2. MISSION. To establish HAFB HAZMAT labeling, tracking, and storage procedures.

3. EXECUTION. HAZMAT users are divided into large, small, and administrative organizations, based on the quantity and toxicity of the HAZMAT they use. Before HAZMAT can be issued, HAZMAT users must have an established issue point. The HTA will assign an issue point when deemed necessary. All HAZMAT must be stored in designated issue points.

Organizations are encouraged to maintain a minimum supply of HAZMAT meaning either the smallest possible quantity required for the work being done, or a quantity that will last for one month or less. All HAZMAT users will obtain their property and barcode labels through their assigned HTA.

3.1. The barcode tracking system enables the HAZMAT Program Manager and the issue point to track the storage area and “in use location” of HAZMAT containers, maintain HAZMAT usage rate information, provide a real-time inventory of HAZMAT stock, and track the ultimate disposition of the HAZMAT container. The issue point and the HTA continually update HAZMAT material usage information.

3.2. Facilities and organizations exempted from these procedures are listed in paragraph 4.1.

in Annex B.

3.3. All emptied HAZMAT containers will be disposed of through the installation

Hazardous Waste Management Program. Each empty container must be labeled with its appropriate EESOH-MIS label. If no label is attached, the user must fill out the document stating when the material was purchased, why there was no label attached, and provide the proper SDS.

ANNEX D TO HAFB HMOP

GENERAL PROCEDURES FOR REDISTRIBUTION AND DISPOSAL OF EXCESS

HAZMAT

Table of Contents

1. SITUATION. Once it has been determined that a particular HAZMAT is no longer needed or useful for its original purpose, it must be reused in a different manner or disposed of.