Attachment 1 - HMEP Expenditures Guide.pdf

HMEP Grants – Expenditures Guide Dec- 20

Hazardous Materials Emergency Preparedness Grant Program U.S. Department of Transportation

Pipeline and Hazardous Materials Safety Administration

HMEP Expenditures Guide

The Pipeline and Hazardous Materials Safety Administration’s Hazardous

Materials Grants Program HMEP.Grants@dot.gov www.phmsa.dot.gov/hazmat/grants

(202) 366-1109

Developed by the Pipeline and Hazardous Materials Safety Administration (PHMSA) in collaboration with the Hazardous Materials Emergency Preparedness (HMEP) Working Group.

mailto:HMEP.Grants@dot.gov http://www.phmsa.dot.gov/hazmat/grants

Pipeline and Hazardous Materials Safety Administration

HMEP Grants – Expenditures Guide Dec-20

Contents

1. Introduction

2. General Expenditures

3. Planning

3.1 Allowable Planning Expenditures

3.1 Allowable Planning Expenditures, concluded

3.2 Conditionally Allowable Planning Expenditures

3.3 Unallowable Planning Expenditures

4. Training

4.1 Allowable Training Expenditures

4.1 Allowable Training Expenditures, continued

4.1 Allowable Training Expenditures, continued

4.1 Allowable Training Expenditures, concluded

4.2 Conditionally Allowable Training Expenditures

4.3 Unallowable Training Expenditures

5. Grant Specifics

1. Introduction

The purpose of the Hazardous Materials Emergency Preparedness (HMEP) grant is to protect against the risks to life, property, and the environment that are inherent in the transportation of hazardous material in intrastate, interstate, and foreign commerce (Title 49 U.S.C. § 5101). The HMEP grant supports the emergency preparedness and response efforts of States, federally recognized Tribes, and Territories that deal with hazardous materials emergencies, specifically those involving transportation.

This grant also aids grantees in meeting the requirements of §§ 301 and 303 of the Emergency Planning and Community Right-to-Know Act of 1986 (Title 42 U.S.C. Chapter 116).

Through your participation in the HMEP grant program, PHMSA seeks to increase the effectiveness of hazardous materials response and preparedness efforts, and reduce the risks associated with the bulk transport of highly flammable liquids, and other hazardous materials, throughout the United States.

To advance PHMSA’s mission, the HMEP grant awards funding to States, U.S. Territories, and federally recognized Tribes to:

− Develop, improve, and implement emergency plans − Train public sector hazardous materials (hazmat) emergency response employees to respond to accidents and incidents involving hazardous materials in transportation − Determine flow patterns of hazardous materials within a State, between States, between States and federally recognized sovereign nations, and within Territories.

− Determine the need within a State for regional hazardous materials emergency response teams − Assess local preparedness and response capabilities − Conduct emergency response drills and exercises associated with emergency preparedness plans − Provide for technical staff to support the preparedness effort − Train public sector employees to respond to accidents and incidents involving the transportation of hazardous materials − Determine the number of public sector employees employed or used by a political subdivision who need the proposed training and to select courses consistent with national consensus standards or the Guidelines for Hazardous Materials Response, Planning and Prevention/Mitigation Training

− Design, develop and deliver comprehensive preparedness and response training to public sector employees, and financial assistance for trainees and for the trainers, if appropriate, such as tuition, travel expenses to and from a training facility, and room and board while at the training facility

− Deliver emergency response drills and exercises associated with training, a course of study, and tests and evaluation of emergency preparedness plans

− Evaluate courses to determine effectiveness of delivery and student retention − Pay expenses associated with training by a person (including a department, agency, or instrumentality of a State or political subdivision thereof, a Territory, or federally recognized Tribe) and activities necessary to monitor such training including, but not limited to, examinations, critiques and instructor evaluations

− Maintain staff to manage the training effort designed to result in increased benefits, proficiency, and rapid deployment of local and regional responders

− Support additional activities the Associate Administrator deems appropriate to implement the scope of work for the proposed project and approved in the grant https://www.phmsa.dot.gov/hazmat/dot-announces-the-2016-guidelines-for-hazardous-materials-response-planning-and-prevention-mitigation-training https://www.phmsa.dot.gov/hazmat/dot-announces-the-2016-guidelines-for-hazardous-materials-response-planning-and-prevention-mitigation-training

The information contained in this document is provided for guidance to administer the HMEP grant program. This document supersedes all previous versions and is effective for fiscal year (FY) 2019 grant awards. Examples of allowable activities provided in this document are not all-inclusive, and the absence of a specific activity does not preclude its possible approval. All proposed activities will be considered based on the proposed budget costs allocable to the approved project in accordance with 2 CFR Part 200, Subpart E, and Cost Principles.

General Guidelines:

− Allowable expenditures are those that are: reasonable, necessary, and allocable to the approved project consistent with 2 CFR Part 200 and the Notice of Grant Award (NGA).

− Conditionally allowable expenses are only allowable from certain funding sources, or when the expenditures meet other conditions.

− Unallowable expenditures are costs prohibited by law or regulation, Federal cost principles, PHMSA policy, or special terms and condition of award.

The following items require prior approval and the submission of the Hazmat Grant Activity Request Form to PHMSA by selecting one of the following options in the HMEP Grants Portal at https://hazmatgrants.phmsa.dot.gov:

• Activities not specified in the approved grant application

• Budget revisions

• Change in Point of Contact for the Grant

Questions and other inquiries should be directed to your assigned Grant Management Specialist or via e-mail at: HMEP.Grants@dot.gov.

2. General Expenditures

Examples of allowable general expenditures that do not fall under preparedness or response training grant expenditures are listed below.

Allowable General Expenditures

Grants Management Courses Continuing Education Specific to Grants Management Functions Financial Management Courses with Grant Management Concentration

The purpose of this HMEP Expenditures Guide is to help grantees effectively administer their programs by providing examples (for reference only) of allowable, conditionally allowable, and unallowable activities.

Requests for reimbursement must be submitted via the Delphi eInvoicing System using OMB SF-270, Request for Advance or Reimbursement.

For new users, please coordinate with your assigned Grant Management Specialist for access.

https://hazmatgrants.phmsa.dot.gov/ mailto:HMEP.Grants@dot.gov

3. Preparedness

3.1 Allowable Preparedness Expenditures – Commonly Approved Expenditures

Enhancing Hazardous Materials Plans Developing, improving, and implementing emergency plans required under the Emergency Planning and Community Right-to-Know Act of 1986 Workshops, drills, and exercises associated with hazmat emergency plans Risk assessments to enhance plans Capability assessments that evaluate the ability for first responders, non-governmental organizations, and other involved stakeholders to respond to a hazmat emergency Gap analysis to enhance planning objectives Improving interagency interoperability to better respond to and mitigate hazmat incidents Determining commodity flow transportation patterns of hazmat and developing and maintaining a system to keep such information current Assessing the need for regional hazmat emergency response teams Providing technical staff to support planning efforts Aerial photography for use with Commodity Flow Study research Planning Courses Courses aimed at developing, improving, and implementing emergency plans under the Emergency Planning and Community Right-to-Know Act (EPCRA) §§ 301 and 303 (Title 42 U.S.C. Chapter 116) Hazmat transportation emergency preparedness and response courses Hazmat risk analysis Commodity Flow Study courses Regional Response Strategy Selection courses Equipment and Supplies1

Computer equipment dedicated to HMEP Grant activities (use for operations purposes not allowable) Supplies and equipment required for HMEP-funded exercises and activities

1 2 CFR § 200.33 defines equipment as tangible, non-expendable personal property with a unit acquisition cost of $5,000 or more (unless State policy sets a lower threshold) and with a useful life of more than one year. When calculating the cost of the property, it includes any accessories needed to make it operational.

Any items not meeting this definition should be shown as “supplies,” e.g., computers must be shown as “supplies,” based on their acquisition cost.

3.1 Allowable Preparedness Expenditures, concluded

Conferences and Meetings National Association of SARA Title III Program Officials (NASTTPO) TRANSCAER®*: TRANSCAER® (Transportation Community Awareness and Emergency Response) is a voluntary national outreach effort focusing on assisting communities with preparing for, and responding to, possible hazmat transportation-related incidents. TRANSCAER® educates emergency responders and their communities and includes safety training cars from the Firefighters Education and Training Foundation.

* Necessities, by ownership or rental, for the physical needs and comfort of the participants and training recipients such as, but not limited to: classroom tents, tables, chairs, water coolers, portable toilets, wash stations, public address systems, generators, fuel for generators, waste management, and outdoor fans; projectors and screens, video recording services; safety gloves, safety glasses; pens, pencils, books, brochures, certificates; administrative services, advertising costs, trainer fees; and instructor accommodations, travel, and meals.

International Association of Fire Chiefs (IAFC), International Hazmat Conference: The IAFC hosts the International Hazardous Materials Response Team Conference, which presents “what’s new in hazmat” and how it impacts today’s hazmat teams on the job.

Midwestern Hazmat Conference: Two-day conference on hazmat and related response training presented by instructors in the hazmat response community. (Only courses on hazmat response are eligible.)

Other Hazmat publications for permanent collections, such as the NFPA 472 guide

3.2 Conditionally Allowable Preparedness Expenditures

Conditionally allowable expenditures are those that are not commonly approved, but will receive special consideration upon proposal.

Examples of conditionally allowable preparedness expenditures are listed below.

Tier II Chemical Inventory Reports Tier II Databases Statewide conference emphasizing hazmat emergency response capabilities, collaboration, networking, and preparedness opportunities for responders, particularly those related to transportation. Conditions include: transportation hazmat-themed schedule http://www.transcaer.com/ http://www.iafc.org/ https://emerysafety.com/

Regional hazmat conferences and workshops, specifically those related to transportation Fire Department Instructors Conference (FDIC): Comprehensive training for all levels of fire service practitioners with more than 24 hands-on training evolutions, 34 pre-conference workshops, and more than 160 classroom presentations. Conditions include: transportation hazmat-themed schedule LEPC meeting expenses – Conditions include: LEPC meeting expenses are allowable when pertaining to the HMEP grant

Hospital Drills – Conditions include: Decontamination from a transportation incident (radiological, chemical, or other hazmat) Emergency Operating Center (EOC) Leadership Exercises – Conditions include: Leadership exercises for events concerning hazmat preparedness and response Title III Software (e.g., CAMEO/PEAC/PLUME) – Use of software must be tied to planning for hazmat transportation related accidents/incidents Fixed-facility hazmat preparedness – Conditions include: Exercises and plans that include transportation of materials to and from fixed-facilities; exercises that test the same capabilities that would be used to respond to a hazmat transportation incident Refreshments – Conditions include: Beverages for trainings that are in rural locations or training conducted outside where hydration is needed to ensure exercises are safely conducted.

3.3 Unallowable Preparedness Expenditures

Examples of unallowable preparedness expenditures are listed below.

Natural Disaster Exercises (e.g., Urban Avalanches, Pandemic Flu, Cruise Ship, Wildfire, Earthquake) All-Hazards Warning System Drills Joint Terrorism Task Force (JTTK) Exercises WebEOC (EOC-Emergency Operations Center) mapping Public Officials Conference that does not have a tie-in to hazardous materials transportation Town-wide alert system Development and distribution of a Hazmat Calendar Expenses counted as match funds toward another Federal grant program or cooperative agreement Entertainment costs Foreign travel Purchase of cell telephone(s), except for administration of the HMEP grant at the state level Any costs disallowable or stated as ineligible in 49 CFR part 110 and 2 CFR 200 Subpart E

Any cost specifically prohibited in the General Terms and Conditions of the award, PHMSA policy as detailed in this Expenditures Guide, or Special Terms and Conditions listed on the NGA (Remarks section) Membership fees and subscriptions, except as otherwise noted.

Food – Food purchased with HMEP funds for exercises, planning sessions, meetings, conference and more is unallowable under the HMEP grant program.

http://www.fdiconlineevent.com/

Stipends

FRI (Fire Rescue International): Fire Rescue International (FRI) annual conference for fire and emergency service leaders from across North America and around the globe for 5 days of networking, learning, and collaboration.

4. Training

4.1 Allowable Training Expenditures

Examples of allowable training expenditures are listed below.

General Training Expenditures Reimbursement for instructor(s) and trainees for tuition and travel expenses (lodging and per diem) to and from a training facility Facility rental cost reimbursement Expenses associated with training, such as staff to support the training effort, evaluation forms, etc.

National Fire Protection Association (NFPA) 472 or Occupational Safety And Health Administration (OSHA) 29 CFR § 1910.120 Competency Requirement Suggested Courses Hazardous Waste Operations and Emergency Response Standard (HAZWOPER) training with transportation tie-in Hazmat Incident Command System (ICS), includes the following courses:

− ICS-100: Introduction to the Incident Command System − ICS-200: Incident Command System for Single Resources and Initial Action Incidents − ICS-300: Intermediate Incident Command System − ICS-400: Advanced Incident Command System

Hazmat Awareness, Operations, Technician, Specialist, and Refresher Courses Hazmat Incident Commander Hazmat Officer/Safety Officer Industrial Fire Fighting- (rail yards, fuel transfer facilities, and ports) Confined Space Rescue Hazmat Basic Life Support/Advance Life Support Chemistry for Emergency Responders Marine Operations - Ship-board rescue, firefighting, and hazmat Airport Rescue Fire Fighting (aircraft response and rescue) Explosive Ordinance Disposal/Explosives involving transport of explosives Radiological (sources in transportation, but not Weapons of Mass Destruction.)

Tank Car Specialty http://fri.iafc.org/

4.1 Allowable Training Expenditures, continued

National Fire Protection Association (NFPA) 472 or Occupational Safety and Health Administration (OSHA) 29 CFR § 1910.120 Competency Requirement Suggested Courses, concluded Intermodal Tank Specialty Marine Tank Vessel Specialty Flammable Liquid Bulk Storage Flammable Gas Bulk Storage Radioactive Material Specialty in Transportation First Receiver Awareness Training Crude Oil Training Cargo Tank Specialty Other Allowable Training Course Examples Ammonia, Ethanol, Chlorine Response Alternative Fuels, used in transportation Developing a Plan of Action Chemistry of Hazmat-Part I/II Surveying a Hazmat Incident Level A/Level B Personal Protective Hazmat for Emergency Management System (EMS) Hazmat for Dispatcher Hazmat Containers Hazardous Materials Monitoring Refresher Hazmat Level B Dress-out and Decon Hazmat Technical Decon Refresher Hazmat Containment and Control Haz-Cat Training Pro Board® Certification for Hazmat Training Courses

4.1 Allowable Training Expenditures, continued

Other Allowable Training Course Examples, concluded Pipeline Incident in Transportation Response Training Haz Mat IQ Training (Above and Below the line, Advanced IQ & Tox Medic, etc.)

Emergency Medical Technician (EMT) Training for hazmat Employee Hazmat Emergency Response Readiness Training Creating and maintaining hazmat emergency response training websites CAMEO Training, particularly that related to transportation TRANSCAER® (travel and necessities* for physical needs and comfort of trainers and training recipients)

* Necessities, by ownership or rental, for the physical needs and comfort of the participants and training recipients such as, but not limited to: classroom tents, tables, chairs, water coolers, portable toilets, wash stations, public address systems, generators, fuel for generators, waste management, and outdoor fans; projectors and screens, video recording services; safety gloves, safety glasses;

pens, pencils, books, brochures, certificates; administrative services, advertising costs, trainer fees; and instructor accommodations, travel, and meals.

Allowable Training Equipment, Supplies and Materials Computer equipment used exclusively for activities allowable under this HMEP Grant (e.g., approved computer-based training activities).

Rental equipment necessary to provide specific training, whether consumed in the training (e.g., this isn’t equipment) or otherwise (e.g., a training suit). In most cases, equipment costs are expected not to exceed 5 percent of the total cost of the grant awarded and must be fully justified.

Publications, manuals, and other materials necessary to provide training and are used by instructor(s) and trainees--where appropriate, this may include the printing and copying of such materials and any cost of distributing these materials (such as mailing the materials to trainees in advance of the first training session).

Simulation software for hazmat training courses Hazmat training suits for specific transportation related exercises Firefighting foam for specific transportation related exercise

4.1 Allowable Training Expenditures, concluded

Conferences NASTTPO (National Association of SARA Title III Program Officials) Hazmat Continuing Challenge HOTZONE or COLDZONE IAFC International Hazmat Conference Midwestern Hazmat Conference http://nasttpo.com/ http://www.hazmat.org/index.cfm?section=1 http://hotzone.org/ http://www.coldzone.org/ https://www.iafc.org/topics-and-tools/hazmat https://emerysafety.com/

4.2 Conditionally Allowable Training Expenditures

Examples of conditionally allowable training expenditures are listed below.

Statewide conference emphasizing hazmat emergency response capabilities, collaboration, networking, and planning opportunities for responders.

Regional hazmat conferences and workshops

Fixed-facility hazmat training – Conditions include: Training that includes transportation of materials to and from fixed-facilities; training that addresses the same capabilities that would be used to respond to a hazmat transportation incident Refreshments – Conditions include: Beverages for trainings that are in rural locations or training conducted outside where hydration is needed to ensure safe training.

4.3 Unallowable Training Expenditures

Examples of unallowable training expenditures are listed below.

Courses not related to hazmat emergency response (with the exception of the pipeline training listed in section 4.1 above)

Pro Board® Accreditation and Membership Fees Emergency Preparedness Presentation to Child Care Providers

School Violence Prevention

Weapons of Mass Destruction (WMD) Terrorism courses

Weapons of Mass Destruction (WMD) Radiological Training

Mobile Meth Lab Training Active Shooter Training Pandemic Flu Exercises

Joint Terrorism Task Force (JTTF) Exercises

Equipment for the purpose of response operations, such as:

− Self-Contained Breathing Apparatus (SCBA) − PPE (Personal Protective Equipment) − Monitoring Equipment

Overtime of trainees and any other employees who “backfill” positions of trainees during the period of training.

Expenses counted as match funds toward another Federal grant program or cooperative agreement.

Entertainment costs

Purchase of cellular telephone(s), except for administration of the HMEP grant at the state level

Any costs disallowable or stated as ineligible in 49 CFR part 110 and 2 CFR 200 Subpart E

Any cost specifically prohibited in the General Terms and Conditions of the grant award, or identified in PHMSA policy guidance, or as a Special Terms and Conditions listed on the NGA (Remarks section).

Stipends

FRI (Fire Rescue International): Fire Rescue International (FRI) annual conference for fire and emergency service leaders from across North America and around the globe for 5 days of networking, learning, and collaboration.

Food – Food purchased with HMEP funds for exercises, planning sessions, meetings, conference and more is unallowable under the HMEP grant program.

5. Grant Specifics

Requests for Reimbursement

Requests for reimbursement must include a SF-270 that can be accessed online via the Delphi eInvoicing System or uploaded if the online SF-270 is not operational. Some grantees may be required to submit supporting documentation for payment requests. If this is the case, a special term and condition will be listed on the NGA indicating this status. PHMSA may request additional substantiation for supporting reimbursement payments at any time. Reimbursement may not be made for a project plan unless approved by PHMSA either in the application or via Activity Request.

Grantees are to keep supporting documentation on file in accordance with their internal policies and procedures. While supporting documentation may not be required for every payment, it may be requested during the course of PHMSA’s ongoing monitoring process. A lack of supporting documentation on file may result in questioned or unallowable costs.

Matching Funds

Grantees (States and Tribes) are required to provide the 20% match and may use the following2:

− Cash (hard-match), − In-kind contributions (soft match) − A combination of in-kind or soft match plus hard-match to meet this requirement.

Grantees may use matching funds from all seven object classes. Examples include: salary3; equipment or supply purchase; space usage; the value of a participant’s time during an allowable activity;

unrecovered indirect costs, or the dollar value of a grant-related activity or purchase.

Grantees must continually examine funding priorities to ensure that activities and/or expenditures counted as matching towards the grant are used for allowable activities.

Match must be verifiable through grantee records and be maintained with the same level of effort as Federal funds. Records must show how the value of a contribution is made. 2 CFR §§ 400-475 provide more detail on match requirements and expectations.

Match may include waived indirect costs and not be paid by the Federal Government under any other award.

http://fri.iafc.org/

Percent of Funds for Programmatic Activities

At least 75% of the funds must be for programmatic activities, this includes:

• Developing, improving, and implementing emergency plans

• Conducting commodity flow studies

• Conducting exercises

• Training public sector employees

As required by 2 CFR § 200.302, a grantee must expend and account for grant funds in accordance with state laws and procedures for expending and accounting for the state’s own funds. HMEP grantees must ensure that the management and administration (M&A) Federal cost of this grant program does not exceed 25%, as referenced in the FY 2017 funding announcement and required by the terms and conditions of the grant award.

Title 2 CFR, Grants and Agreements, provides greater clarity to the role and expectations for pass-through entities conducting oversight of subrecipients. It expands on the responsibilities of pass-through entities by providing for a more robust system of risk assessment, oversight and monitoring.

(See 2 CFR §§ 200.330 and 200.331)

2 Per 48 U.S.C.1469a, the requirement to provide a 20% match for the Planning and Training (direct and indirect) costs of all activities covered under the grant award program with non-Federal funds is waived for “Insular Areas” which include the Virgin Islands, Guam, American Samoa, the Trust Territory of the Pacific Islands, and the Government of the Northern Mariana Islands in order to minimize the burden caused by the existing application and reporting procedures.

3 2 CFR Section 200.430(i) require that all salaries and wages charged to a Federal award be documented to accurately reflect the work performed for the award. Salaries and wages used to meet cost-sharing or matching requirements must be treated in the same manner as salaries and wages directly charged to an award.

Audits

Recipient agencies are responsible for obtaining audits in accordance with 2 CFR Part 200 Subpart F.

Audits must be made by an independent auditor in accordance with generally accepted government auditing standards covering financial and compliance audits. PHMSA may audit a recipient agency at any time.