SOO - D - Less Lethal CI - 06022021.pdf

Less-Lethal Chemical Irritant (CI) For Crowd Control

June 2021 Science and Technology Directorate Department of Homeland Security

DISTRIBUTION NOTICE: Further dissemination only as directed by DHS Office of Policy DESTRUCTION NOTICE: Destroy by any method that will prevent disclosure of contents or reconstruction of the document.

Table of Contents

1.0 Problem Statement

2.0 Purpose and Scope

3.0 Background Environment

3.1 Mission Scenarios

3.2 Current Technology Shortfalls and Threats

4.0 Potential Solution Attributes

4.1 Concept of Operations (ConOps)

4.2 Additional Capabilities

5.0 Solution Capabilities and Requirements

5.1 Must Have Requirements

5.2 Desirable Capabilities or Characteristics

6.0 System Support

6.1 Contractual Requirements

6.1.1 Period and Place of Performance

6.1.2 System Affordability

6.1.3 Regulatory/Legal Requirements

6.1.4 Contract Deliverables

6.2 Solution Support

6.2.1 Support Concept

6.2.2 Training

6.2.3 Other Considerations

6.2.4 Storage and Maintenance

Less-Lethal Chemical Irritant (CI) Statement of Objectives

1.0 Problem Statement

During a 2020 First Responder Resource Group (FRRG) Virtual Meeting, first responders, predominately from law enforcement, discussed the challenges they face when using chemical irritants (CIs) in crowd environments. The U.S. Centers for Disease Control and Prevention (CDC) defines CI riot control agents as “chemical compounds that temporarily make people unable to function by causing irritation to the eyes, mouth, throat, lungs, and skin”.1 Those CIs most commonly used by law enforcement are o-chlorobenzylidene malonitrile (CS or tear gas) and oleoresin capsicum (OC or pepper spray).2,3 CIs are a type of less-lethal tool that helps law enforcement deescalate situations by creating time and/or distance in large crowds down to the individual in a dense urban environment and stop unlawful activity without needing to elevate to a higher level of force.4 There are multiple situations within a crowd environment for which CIs are utilized. For example, CIs are used to address individuals and small groups engaged in criminal activity occurring near protected First Amendment activity, such as demonstrations, and/or to disperse a crowd in the event of a dispersal order not being followed.

While the Chemical Weapons Convention (CWC) has prohibited the use of CIs in warfare5, their use by law enforcement in domestic riot control situations is allowed.6 However, the most reported criticisms are medical and environmental impacts, and the difficulty of decontamination.7 Oftentimes this is due to accidental misuse because there are no national standards and/or training policies for the use of CIs. Further, many manufacturers of CIs do not provide adequate information on concentrations of chemicals or the solvents and non-active ingredients that may contribute to toxicity.8 Due to these challenges, many state and local lawmakers have moved to restrict their use.

However, in a study commissioned by the National Institute of Justice (NIJ), authors found that less-lethal tools reduced the rates of injuries for law enforcement personnel and offenders compared to using physical force.9 Therefore, participants discussed the need for more effective CIs that minimize unintended impacts and assist law enforcement in addressing individuals and small groups engaged in criminal activity occurring near protected First Amendment activity and/or dispersing a crowd in

1 “Facts About Riot Control Agents Interim Document.” Centers for Disease Control and Prevention, Centers for

Disease Control and Prevention, 4 Apr. 2018, emergency.cdc.gov/agent/riotcontrol/factsheet.asp.

2 “Article I – General Obligations.” OPCW, www.opcw.org/chemical-weapons-convention/articles/article-i.

3 Ibid.

4 Seattle Office of Inspector General. Review of the SPD Crowd Dispersal Policy and Less Lethal Weapons. City of

Seattle, 14 Aug. 2020, herbold.seattle.gov/wp-content/uploads/2020/08/OIG-Review-of-the-SPD-Crowd- Dispersal-Policy-and-Less-Lethal-Weapons.pdf.

5 “Article I – General Obligations.” OPCW, www.opcw.org/chemical-weapons-convention/articles/article-i.

6 “Article II – Definitions and Criteria.” OPCW, www.opcw.org/chemical-weapons-convention/articles/article-ii-definitions-and-criteria.

7 JJ. Payne-James, E. Rivers, et al. “Health Impacts of Chemical Irritants Used for Crowd Control: a Systematic Review of the Injuries and Deaths Caused by Tear Gas and Pepper Spray.” BMC Public Health, BioMed Central, 1 Jan.

1970, bmcpublichealth.biomedcentral.com/articles/10.1186/s12889-017-4814-6.

8 Haar, Rohini J, et al. “Health Impacts of Chemical Irritants Used for Crowd Control: a Systematic Review of the Injuries and Deaths Caused by Tear Gas and Pepper Spray.” BMC Public Health, BioMed Central, 19 Oct. 2017, www.ncbi.nlm.nih.gov/pmc/articles/PMC5649076/.

9 Department of Homeland Security. “Less Lethal Technologies for Law Enforcement.” SAVER TechNote, Department of Homeland Security, June 2019, www.dhs.gov/sites/default/files/publications/saver-technote-less-lethal_28may2019_508.pdf.

the event of a dispersal order not being followed. Additionally, national law enforcement could use less-lethal CI solutions, developed based on this SOO, in other law enforcement situations that call for CIs to support a peaceful resolution (e.g., barricaded subjects). Submitted solutions can factor this aspect into their proposals. However, the primary focus of this SOO is to provide increased mitigation and arrest capabilities for criminal activity in crowd sitautions. Other law enforcement scenarios based on the CI proposal can be included as an added capability to crowd situations.

2.0 Purpose and Scope

The purpose of this statement of objectives document is to identify CIs that can address the legal, medical, and environmental challenges faced by existing CIs in addressing individuals and small groups engaged in criminal activity occurring near protected First Amendment activity, and/or dispersing a crowd in the event of a dispersal order not being followed. Law enforcement agencies are called upon to manage crowds related to planned and spontaneous events.10 However, unlawful assemblies can devolve from peaceful demonstrations or occur spontaneously. It is important that law enforcement officers have CIs for a crowd control environment to allow for distance between the officer and the criminal offender(s).

Participants at a 2020 FRRG virtual meeting discussed the need for solutions to assist them in quickly addressing individual or small group criminal activity and/or dispersing the crowd from a distance after declaring an illegal gathering, while having minimal unintended impacts. Law enforcement is often put in a difficult situation of having to decide when to use CIs without harming surrounding observers, the community, or themselves, while sometimes not knowing how great the impact will be.

Therefore, potential solutions should have varying range, minimal overspray or drift, pinpoint delivery to reduce collateral impact, and be non-carcinogenic and environmentally friendly. It should also be portable, quickly deployable, and easily decontaminated. Solutions may also have a positive impact on the perception of law enforcement legitimacy by the community and the public if the tools decrease the public’s unintended exposure to these agents. They should also positively impact law enforcement’s continued ability to use CIs when warranted.

3.0 Background Environment

During the summer of 2020, demonstrations in the United States rose to unprecedented levels.

Between May 24, 2020, and August 22, 2020, the Armed Conflict Location & Event Data Project (ACLED)11 recorded more than 10,600 demonstrations across the United States, mostly associated with the Black Lives Matter movement and protests to COVID-19 response measures. While the majority of these events were recorded as peaceful, the ACLED reports that approximately 5%

10 International Association of Chiefs of Police. “Crowd Management .” IACP, Apr. 2019, www.theiacp.org/sites/default/files/2020-08/Crowd Management FULL - 08062020.pdf.

11 The Armed Conflict Location & Event Data Project (ACLED) is a disaggregated data collection, analysis, and crisis mapping project. It is associated with the International Peace Research Institute and has received funding from the World Bank, the U.S. Department of Defense, and the European Research Council.

involved violent actors.12 In order to control these crowds, CIs were used by law enforcement in at least 100 jurisdictions during some of these events.13 The use of CIs by law enforcement for crowd control varies across jurisdictions in the United States.14 According to the Bureau of Justice Statistics Law Enforcement Management and Administrative Statistics Survey published in August 2020, pepper spray (i.e., OC spray or foam) was authorized for use by 90.8% of local police departments in 2016, whereas chemical agent projectiles (e.g., CS gas or OC pellets) was only authorized for use by 42.5%.15 As more effective less-lethal tactics, including CIs, are developed, the potential for the use of more force to occur, up to and including lethal force decreases. In a study commissioned by the National Institute of Justice (NIJ), authors found that less-lethal tools reduced the rates of injuries for law enforcement personnel and offenders compared to using physical force.16 A concern with CIs is that emergency responders do not have the ability to detect the extent of impact caused by riot control agents because it depends on the amount of exposure, the location of exposure (indoors versus outdoors), how the person was exposed, and the length of time of the exposure.17 Further, the volume and concentration of the chemical in each spray and aerosol vary considerably among manufacturers and countries, which may be misleading.18 The unknown effects and lack of studies on chemical agents in crowd control presents a challenge for law enforcement.19

3.1 Mission Scenarios

Peaceful demonstrations, otherwise known as lawful assemblies, can be declared unlawful assemblies, civil disturbances or riots, whenever they constitute a breach of the peace or there is a threat of collective violence, destruction of property, or other unlawful acts. More commonly, civil disturbances occur spontaneously.20 According to the International Association of Chiefs of Police (IACP) Law Enforcement Policy Center’s Model Policy for Crowd Management, law enforcement’s role during peaceful demonstrations and violent civil disturbances or riots is to:

• “Protect individual rights related to assembly and free speech;

12 Kishi , Roudabeh. “Demonstrations & Political Violence in America: New Data for Summer 2020.” ACLED, 5 Nov.

2020, acleddata.com/2020/09/03/demonstrations-political-violence-in-america-new-data-for-summer-2020/.

13 Van Ness, Lindsey. “Tear Gas Bans: A Policing Change Not Gaining Traction.” The Pew Charitable Trusts, 4 Aug.

2020, www.pewtrusts.org/en/research-and-analysis/blogs/stateline/2020/08/04/tear-gas-bans-a-policing-change-not-gaining-traction.

14 FRRG Virtual Meeting 2020 15 Brooks, Connor, et al. “Local Police Departments: Policies and Procedures, 2016.” U.S. Department of Justice, Aug.

2020, www.bjs.gov/content/pub/pdf/lpdpp16.pdf.

16 Department of Homeland Security. “Less Lethal Technologies for Law Enforcement.” SAVER TechNote, Department of Homeland Security, June 2019, www.dhs.gov/sites/default/files/publications/saver-technote-less-lethal_28may2019_508.pdf.

17 Ibid.

18 Haar, Rohini J, et al. “Health Impacts of Chemical Irritants Used for Crowd Control: a Systematic Review of the

Injuries and Deaths Caused by Tear Gas and Pepper Spray.” BMC Public Health, BioMed Central, 19 Oct. 2017, www.ncbi.nlm.nih.gov/pmc/articles/PMC5649076/.

19 Haar, Rohini J. “Lethal In Disguise: The Health Consequences Of Crowd-Control Weapons.” The International Network of Civil Liberties Organizations , Physicians for Human Rights , www.aclu.org/sites/default/files/field_document/lethal_in_disguise_inclo_single_page.pdf.

20 “Crowd Management .” International Association of Chiefs Of Police, Law Enforcement Policy Center, Apr. 2019, www.theiacp.org/sites/default/files/2020-08/Crowd%20Management%20FULL%20-%2008062020.pdf.

• Effectively manage crowds to prevent loss of life, injury, or property damage; and

• Minimize disruption to persons who are not involved.”21

In order to accomplish these objectives, law enforcement officers have several tools and tactics at their disposal, including officer presence, verbal interaction, touch control, and various levels of defensive tactics, depending upon the incident.22 CIs for crowd environments may be used by law enforcement to address individual criminal activity, deny access to certain areas, and to intentionally channel/direct/move a crowd after it has been determined that there is violent and/or destructive criminal activity and/or an imminent threat to life or property (following a dispersal order). Non-specific CIs may only be used by trained officers when authorized by the Incident Commander (IC). When the use of a non-specific CI is approved by the IC, law enforcement officers may use high volume OC delivery systems or CS in order to disperse the crowd.23 Specific uses of force by officers against individual perpetrators engaged in violent criminal activity should be governed by agency specific use of force policies. These uses of force could include electronic control devices, personal issue OC, and less-lethal impact munitions.

CS is used to disperse a crowd. Typical deployment methods include a canister or muzzle blast.24 OC has a variety of different uses depending on the product design and situation. The spray is used against specific individuals engaged in unlawful behavior or resisting arrest, an OC vapor grenade is used to target smaller groups, and a canister is used when approved by the appropriate authority during civil disturbances to disperse the crowd.

CIs are relevant to crowd management and various types of police management of crowds, including directing a crowd, intervention such as addressing individual violent actors and crowd control to address an entire crowd.

A CI that has adequate information on the chemical makeup and proper use guidlidelines that are proportionate to law enforcement’s tasks will increase the perception of law enforcement legitimacy by the community and the public.

3.2 Current Technology Shortfalls and Threats

Currently, most CIs, including CS and OC, are indiscriminate in nature and they can affect not only the intended targets but also peaceful demonstrators, bystanders, nearby communities and residences, and law enforcement officers themselves.25 Additionally, decontamination of the area and or individual can be difficult, and current CIs persist too long.26 An increase in understanding by the public that law enforcement does not support the use of indiscriminate agents is needed.

21 Ibid.

22 Whitson, Don, et al. “A Guidebook For Less-Lethal Devices .” Weapons and Protective Systems Technologies

Center, Mar. 2010, nccpsafety.org/assets/files/library/Guidebook_for_Less-lethal_Devices.pdf.

23 “Crowd Management .” International Association of Chiefs Of Police, Law Enforcement Policy Center, Apr. 2019, www.theiacp.org/sites/default/files/2020-08/Crowd%20Management%20FULL%20-%2008062020.pdf.

24 “Chemical Irritants Fact Sheet.” International Network of Civil Liberties Organizations, Physicians For Human

Rights , Mar. 2016, www.inclo.net/pdf/lethal/CIfactsheet.pdf.

25 Ibid.

26 “Decontamination.” Federation of American Scientists, fas.org/nuke/guide/usa/doctrine/army/mmcch/Decontam.htm.

Some CI manufacturers may not be transparent enough about what is contained in their products. This means that CIs may contain numerous other toxic chemicals, including alcohols, organic solvents, halogenated hydrocarbons, and propellants such as Freon, tetrachloroethylene, and methylene chloride.27 Certain ingredients may be flammable and could ignite when exposed to other law enforcement less-lethal weapons such as electronic control devices. Due to the lack of transparency, the understanding of the effects of these irritants is minimal. When combined with the lack of national training standards, these irritants can be accidentally misused and may result in injury and/or long-term medical impacts.28 The use of existing less-lethal CIs by law enforcement for crowd environments may be restricted or banned because of these issues or perceptions, thereby limiting the tools available to law enforcement officers for use in crowd environments.

Current technology is easily defeatable by the intended targets (e.g., umbrellas for OC, respirators, quick decontamination, leaf blowers to blow away clouds of agent) and may becomes less effective over time due to suspect acclimation.29 While the majority of existing CIs do not address the needs identified within this SOO, malodorants may address several, although not all, of the requirements within this SOO.

Malodorant is not currently widely used within the United States, but it has been tested in the country and is regarded as highly effective. However, the Department of Defense has developed and tested a malodorant payload, which has not been successful as the chemical composition is highly volatile.30,31 Malodorant claims to achieve greater results faster and is claimed to be less harmful than other CIs, non-toxic, non-flammable, and environmentally friendly.32 However, it is indiscriminate in nature and affects the entire street where it is used.

This means that nearby businesses and residents suffer from the smell, regardless of their position during protests, and the smell has been known to stay on the surfaces it touches for days after use.33

4.0 Potential Solution Attributes

Potential solutions will provide the ability to address individuals and small groups engaged in criminal activity occurring near protected First Amendment activity, and/or disperse a crowd in the event of a dispersal order not being followed. Potential solutions should rapidly and safely identify a CI that can be used in crowd control with minimal harm and that is discriminate in nature.

27 Ibid.

28 Ibid.

29 Barrett, Maura, and David Douglas. “From 'De-Arrests' to Leaf Blowers, Portland Protesters Find New Ways to Stand up to Federal Agents.” NBC News, 29 July 2020, www.nbcnews.com/news/us-news/de-arrests-leaf-blowers-portland-protesters-find-new-ways-stand-federa-rcna61.

30 Nodum. “Skunk – a Weapon That Will Force You to Live in the Shower for Days.” NODUM, 26 Nov. 2019, nodum.org/malodorant-weapon-skunk/.

31 “Encapsulation and Delivery of Non-Lethal Malodorant in a 40mm-Munition or Hand-Thrown Grenade.” SBIR- STTR, America's Seed Fund, SBA, 2011, www.sbir.gov/content/encapsulation-and-delivery-non-lethal-malodorant-40mm-munition-or-hand-thrown-grenade.

32 “Skunk – Non-Lethal Malodorant .” Mistral Security , www.mistralsecurityinc.com/Portals/MistralSecurity/FINAL%20- %20MSI%20Skunk%20Product%20Brochure%205.16.13.pdf.

33 Nodum. “Skunk – a Weapon That Will Force You to Live in the Shower for Days.” NODUM, 26 Nov. 2019, nodum.org/malodorant-weapon-skunk/.

4.1 Concept of Operations (ConOps)

Prior to deployment, training on the proper use of any CIs should be provided to responders.

Training requirements for proposed solutions are listed in section 6.2.2. The solution should be a less-lethal CI with more dispersion than personal spray (i.e. mace) but less dispersion than gas grenades to reduce long-term side effects and the possibility of bodily harm. It should be quick and easy to deploy by a single officer once authorized by the IC but should be visually distinct from a lethal force or military weapon. Further, this solution should have the option to target localized suspect’s behavior or and/or small groups engaged in criminal activity within a crowd and/or to disperse a large crowd.

The solution should have multiple options for range, area, concentration, and persistence in one platform that can defeat suspect mitigation strategies (e.g., umbrellas). The solution should also have mid-range delivery and no spread/excessive drift. After deployment, the solution should dissipate quickly and be environmentally friendly. If needed, the solution should allow for easy decontamination and an immediate, proprietary antidote should be available for law enforcement purchase only. Lastly, the solution should have at least a five year shelf life and reliable operation in all weather conditions in the United States.

4.2 Additional Capabilities

Potential solutions would extend the capability of law enforcement to address individuals or small groups engaged in criminal activity within a crowd, while minimizing the effects on the rest of the crowd. The solution would improve officer understanding of safe use of the CI, as safety and testing criteria should be provided. It should also increase efficacy, as it will defeat mitigation strategies. The solution would also increase the perception of law enforcement legitimacy by the public and community, as the solution should minimize unintended impacts.

5.0 Solution Capabilities and Requirements

5.1 Must Have Requirements (Key Performance Parameters, KPP’s)

The proposed solution must have the following KPPs:

Levels of Performance

• Allow law enforcement to quickly address individual criminal activity and/or disperse the crowd from a distance, without inflicting long-term injury;

• Capable of accurately and consistently allowing the user to affect a single person within a crowd;

• Effective on the same percentage of the population as other current CIs;

• Be discriminate;

• Reduce overspray or drift and if it is a solution for an individual, be accurate to an individual; if it is a solution for an area, be accurate to the area claimed by the manfacturer;

• Have a variable range, including:

o 3 feet up to 10 feet o 12 feet up to 35 feet o 50 feet up to 150 feet;

• Be immediately deployable once authorized;

• Have the ability to be rapidly redeployed;

• Reduce long-term side effects when compared to existing CIs;

• Not likely to cause penetrating trauma or injury;

• Incorporate multiple routes of exposure (e.g., respiratory, dermal, ocular, etc.) to defeat mitigation strategies (e.g., gas masks, umbrellas, leaf blowers);

• Does not impact law enforcement officers/other first responders or defeat their PPE when properly deployed; and

• Not a source of ignition/non-combustible.

Physical Characteristics

• Be portable, with a total delivery system maximum weight of 6 pounds, and able to be carried by the officer for extended times;

• User-friendly and ergonomic;

• Be visually distinct from a lethal force weapon, does not appear to be a military weapon or lethal weapon; and

• Not capable of being redirected back at the officers or used as a weapon by rioters after it has been deployed.

Durability

• Safe enough to be transported on a person or in a vehicle without significant risk of deploying on its own;

• Resistant to shock and a wide range of temperatures (OC storage currently has the temperature range of 32° F (0° C)-120° F (48.88° C) and CS has a minimum operating temp of -20 ° F (-29 ° C)34,35;

• Reliable operation in all weather conditions across the United States;

• Doesn’t require a lot of maintenance to remain operational;

• 5 year shelf life; and

• Specify proper disposal at end of shelf life.

Environmental Requirements

• Less toxic and more environmentally friendly than CS, specifically to humans.

Compatibility and Interoperability

• Doesn’t require a lot of other tools to remain in operation.

Certification

• Comply with applicable federal standards depending on delivery system and munitions; and

• Standardize and professionalize the application of tools.

Other

34 “Pepper Spray Frequently Asked Questions.” Sabre Red, www.sabrered.com/pepper-spray-frequently-asked-questions-0.

35 “Hand-Held Aerosol Tear Gas Weapons.” NCJRS, U.S. Department of Justice , Sept. 1985, www.ncjrs.gov/pdffiles1/nij/099858.pdf.

• Provide transparency into its composition, including active and inactive ingredients;

• Have a fairly low cost barrier (system affordability is further addressed in Section 6.1.2);

• Ability to produce scientific evidence of safety, particularly objective third-party verified data to show effects and causal factors, satisfactory to authorizing bodies;

• Be legally acceptable; and

• Provide education on tools to law enforcement, critics, and the general public, including training resources (e.g., manual, video, train the trainer course).

5.2 Desirable Capabilities or Characteristics

In addition to the must-have requirements reported in subsection 5.1, there are performance and/or system standards that exceed the proposed solution requirements:

Levels of Performance

• Dissipate and/or self-neutralize in variable timeframes, including shorter than existing CIs;

• Ability to be deployed outside the range of projectiles or from behind a barrier—non-line-of-sight;

• State the situations in which it can be used; and

• Identify/mark those who are attacking officers or engaged in other criminal behavior for later identification.

Environmental

• Be able to be rapidly decontaminated or have a range of exposure life spans (5 mins, 30 mins, etc.); and

• Be biodegradable.

Compatibility and Interoperability

• Not Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) regulated;

• Not rely on the same technology (e.g., gun powder or explosives) as firearms and if it does, follow all applicable regulations; and

• Compatible with existing delivery systems (e.g.: munition that works with 40mm system).

Other

• Have an immediate, proprietary antidote that is only available for purchase by law enforcement and other first responders; and

• Prefer a single device for all missions.

6.0 System Support

6.1 Contractual Requirements

6.1.1 Period and Place of Performance

The length of time of the contract shall be between 12-18 months and shall not exceed the latter. All developmental activities will be performed at the contractor designated site(s).

DHS may require the contractor to perform critical design reviews and/or product presentations at DHS specified locations.

6.1.2 System Affordability

First responders’ budgets are limited and should be taken into consideration when developing and determining a price per unit cost model.

6.1.3 Regulatory/Legal Requirements

If the solution is ATF regulated, it must meet all applicable requirements.

6.1.4 Contract Deliverables

DHS is committed to ensuring the success of their technology by requiring the project performer to provide DHS multiple prototype deliverables which will be used for post-contract testing and evaluation. A minimum of 5 prototype devices for evaluation by emergency responders shall be provided as a final project deliverable.

6.2 Solution Support

6.2.1 Support Concept

The technologies required to support this solution may include existing deployment mechanisms (e.g., canisters and impact munitions), power sources, and water resistant or other types of technology that ruggedize a device.

6.2.2 Training

Training information as required shall be provided on any specialized equipment, and shall include how to properly store, clean, deploy, and maintain the basic ensemble/unit. Any specialty requirements of personnel conducting maintenance, storage, extraction, or delivery will be identified including certification requirements. Training material shall be available initially in hard-copy, and subsequently in soft-copy format.

6.2.3 Other Considerations

Human Interface Requirements: The target user includes law enforcement that respond to incidents in crowd environments where they have to address individuals and small groups engaged in criminal activity occurring near protected First Amendment activity, and/or disperse a crowd in the event of a dispersal order not being followed. Its size should be deployable by a single officer on foot.

Logistics and Readiness: The solution developed under this award is envisioned as either a new piece of equipment or an improved version of current offerings. It should also be cost effective so that emergency responders from a wide variety of jurisdictions will be able to afford it.

6.2.4 Storage and Maintenance

The contractor shall identify all necessary storage and maintenance requirements for the proposed solution including: the required maintenance schedule, identification of the specific components of the ensemble that requires the maintenance, the type of maintenance required, and whether the maintenance can be performed in the field by operational personnel or if it will be required to be returned to the manufacturer for the required maintenance.