TE-F Hazardous Waste Management Plan.pdf

UNITED STATES ARMY FIRES CENTER OF EXCELLENCE

and Fort Sill

HAZARDOUS MATERIAL/ HAZARDOUS

WASTE MANAGEMENT PLAN

MANAGING HAZARDOUS MATERIAL/

HAZARDOUS WASTE

TURNING IN HAZARDOUS

MATERIAL/HAZARDOUS WASTE

TRAINING AND INSPECTIONS

SPILL RESPONSE – LARGE & SMALL

Fort Sill, Oklahoma January 2023 Updated November 2023

Is an UNCONTROLLED DOCUMENT printed for reference January 2023

PAGE INTENTIONALLY LEFT BLANK

Fort Sill Hazardous Material and Waste Management Plan Table of Contents i January 2023

Table of Contents

Chapter 1. Introduction 1 Purpose and Scope 1 Reviews and Revisions 1 Applicable Regulations 1

State Regulations 1 Federal Regulations 1 Military Regulations 2

Responsibilities 4 Environmental Quality Division (EQD) 4 Medical Department Activity (MEDDAC) 5 Public Health Environmental Health Section 5 Public Affairs Office (PAO) 6 Safety Office 6 Logistics Readiness Center (LRC) 6 Other Staff Directorates, Activities, and Subordinate Commands 7 Environmental Officer (EO) 7

Forms for Submitting Changes to This Plan 8

Chapter 2. Managing Hazardous Materials 11 OSHA and GHS Classification and Labeling of Chemicals 11 Identifying Unwanted and Unserviceable HM 11 Obtaining and Cataloging Safety Data Sheets (SDS) 12 Determining Hazardous Material Compatibility 12

Method 1: Determining Compatibility Using HMIRS Generated SDSs 13 Method 2: Determining Compatibility Using DOT Hazard Labels 19 Method 3: Determining Compatibility Using OSHA Precautionary Labels 21

Maintaining and Extending Shelf Life 24 Setting Up Storage Areas 24

Storage Lockers 24 Storage Rooms and Buildings and Placards 25 Storage Racks 27 Storage for Compressed Gases 28 Moving Cylinders 29

Stocking a HM Storage Locker 30 Maintaining and Tracking Inventory 30 ii

Conducting an HM Inventory 31

Chapter 3. Managing Waste 33 Waste Management Made Easy – Waste Protocol Sheets 33 Waste Categories 34

Hazardous Waste (HW) 34 Universal Waste (UW) 34 Non-Hazardous Industrial Waste (NHIW) 35 Special Waste (Non-RCRA Regulated Waste) 35 General Refuse 35

Generating and Accumulating Waste 35 HW Satellite Accumulation Points 36 Non-HW Accumulation Points 36 Rules for Managing SAAs 37

Obtaining a Waste Accumulation Container 37 Adding Waste to Containers 38 Using Overpack Drums 39 Managing Empty Drums 39

Metal Drums 39 Plastic Drums 40

Chapter 4. Turning in HM and Waste 42 Funding Requirements 42 Turning in HM and Waste to the EQD 42 Turning in Vehicle Lead-Acid Batteries 46 Turning in Used Oil 47 Oil/Water Separator Cleanout 47 Mobile Fuel Tanker Purging 47 Transporting HM/HW on Fort Sill 48 Transporting HW off Fort Sill – Manifesting 48

Chapter 5. Training, Inspections, and Recordkeeping 50 Hazardous Waste Training Regulatory Drivers 50

Federal Regulations 50

State Regulations 51 Military Regulations 51

Fort Sill Hazardous Waste Training Program 51 Who Needs Hazardous Waste Training 51 When Hazardous Waste Training is Required 52 How Hazardous Waste Training Should be Conducted 52 iii

Fort Sill Oil-Handling Personnel Training Program 52 Federal Regulation 52 Hazardous Waste Generator Classroom Instruction 53 Facility Specific Oil-Handling Personnel Training 53

Required Inspections 53 Inspecting Accumulation Points 54 Inspecting Portable Oil Containers and Mobile Refuelers/Fuel Pods 54 Inspecting POL Containment Areas 54 Required Recordkeeping 55 Training Records 55 Inspection Records 55 Other Records 55

Other Inspections and Tests 56 Forms and Instructions 56

Chapter 6. Spill Response 67 Spill Response Actions 68

Incidental Spills 68 Small Spills 68 Large Spills 70 Reporting 71

Arrangement with Local Authorities 71 Installation On-Scene Coordinator 71 Emergency Response Equipment 72

Chapter 7. Glossary and Acronyms 75 Glossary 75 Acronyms 77

Appendix A. Waste Protocol Sheets 79

Appendix B. Memorandums 126 Impulse II Aqueous Parts Washer Operational Guidelines 127 Management of Lithium Sulfur Dioxide Batteries 128 IT-48WC Weapons Cleaning System 129 IT-32 and IT-48 Parts Cleaning System 130 Management of Used Fluorescent and High Intensity Discharge Lamps 131 Disposal of Appliances with Freon 132 Used Oil Storage Tank Guidelines 133 Expired Materials for Turn in as Hazardous Waste 134 Disposal of Fire Extinguishers 135 iv

List of Tables

Table 1-1. Major Program Requirements of AR 200-1 3 Table 1-2. EO Compliance Table 8 Table 2-1. Storage Segregation Matrix 14 Table 2-2. DOT Labels 20 Table 2-3. Precautionary Labels 21 Table 5-1. Hazardous Waste Training Category and Associated 50 Regulatory Agency/Body Table 6-1. RCRA Contingency Plan Requirements Referenced in ISCP/SPCC Plan 67

List of Figures

Figure 2-1. SDS Showing HCC 13 Figure 2-2. Sample DOT Labels 19 Figure 2-3. Example Precautionary Label 21 Figure 2-4. GHS/OSHA Pictogram Labels 23 Figure 2-5. Flammable Storage Locker 25 Figure 2-6. Safe Store® Building 26 Figure 2-7. Storage Rack 28 Figure 2-8. Locker Set 30 Figure 3-1. Safe Store® Building 37 Figure 4-1. Aerial Photograph of Waste Turn-In Access Route 44 Figure 4-2. DA 2765-1 for Vehicle Lead Acid Battery Turn-In 46 iv

List of Forms DA Form 2028 for Submitting Changes to This Plan 9 Quarterly Hazardous Materials Storage Inventory Form 31 Individual Hazardous Waste Training Record 57 Weekly Environmental Inspection Log 58 Monthly STI SP001 Portable Container Inspection Checklist 61 Monthly STI SP001 Mobile Refueler-Fuel Pod Inspection 62 POL Containment Drainage Record (POL or sheen observed) 65 Spill or Incident Report Record 73

Fort Sill Hazardous Material and Waste Management Plan Introduction

Chapter 1. Introduction This Hazardous Material and Waste Management Plan prescribes responsibilities, policies, and procedures for managing hazardous materials and wastes at the U.S. Army Fires Center of Excellence and Fort Sill (USAFCOEFS) required by Army Regulation (AR) 200-1, Environmental Protection and Enhancement. This Plan is written to ensure Fort Sill’s compliance with applicable federal, state, and local laws and regulations.

Purpose and Scope This Plan documents the Fort Sill hazardous materials and waste management program. It applies to the following:

• All organizations and activities located on Fort Sill

• Any outside organization or activity training at Fort Sill

Reviews and Revisions The Fort Sill Environmental Quality Division (EQD) will review this Plan at least once every two years. All Environmental Officers (EOs), as well as any other Fort Sill personnel directly involved in hazardous material (HM) or hazardous waste (HW) management, are encouraged to provide comments and input to this Plan. To do so, complete DA Form 2028 located at the end of this chapter and forward to the EQD at the Post Environmental Office.

Applicable Regulations

State Regulations The Oklahoma Department of Environmental Quality (ODEQ) has obtained primacy from the Environmental Protection Agency (EPA) to enforce solid and hazardous waste management standards. These standards are contained in Title 252 of the Oklahoma Administrative Code, Chapter 205, Hazardous Waste Management, and Chapter 515, Solid Waste Management.

Federal Regulations In order to comply with the Federal Facilities Compliance Act, Fort Sill must manage its waste in accordance with (IAW) the Resource Conservation and Recovery Act (RCRA), as amended by the Hazardous and Solid Waste Amendments (HSWA). Federal waste management regulations are codified in Title 40 of the Code of Federal Regulations (CFR).

This Plan provides procedures for complying with the following parts of 40 CFR:

• Part 260 through Part 272 for the regulation of hazardous waste

• Part 273 for the regulation of universal waste

• Part 279 for the regulation of used oil Fort Sill must also comply with the following:

• Defense Transportation Regulations which incorporate by reference 49 CFR Parts 170 through 177 regarding hazardous materials transportation

• 29 CFR Part 1910 regarding employee safety

Military Regulations Fort Sill personnel must comply with AR 200-1, Environmental Protection and Enhancement, which contains Army policy for hazardous material and waste management.

This Plan provides procedures for complying with these regulations. The following table cross-references the major program requirements of AR 200-1, Chapter 9 (Materials Management) and Chapter 10 (Waste Management) with this Plan.

Table 1-1. Major Program Requirements of AR 200-1

AR 200-1

Reference

Major Program Requirement

Plan Reference

9-1 d HM Management Program for identifying, storing, and transporting hazardous materials

Chapters 2, 3, and 4

• HM Inventory Chapter 2

• Transporting HM Chapter 4

• Designing Storage for HM Chapter 2

• Disposing of HM Chapters 3 and 4

• Managing Excess HM Chapters 2 and 4

• HM Not Owned by the Army Chapter 2

• Best Management Practices Throughout this Plan

• Accounting for Credit Card Purchases Chapter 2

• Cradle-to-Grave Tracking Chapters 3 and 4

9-2 b(4) Asbestos Management

9-2 c(4) PCB Management Chapter 3 (see DPW)

9-2 d(4) Lead-based Paint Management

10-1 d Hazardous Waste Regulatory Compliance Chapters 3, 4, and 5

10-1 d(1) RCRA Compliance Waste Streams Chapter 3, App. A

10-1 d(2) Hazardous Waste Training Chapter 5

10-1 d(3) Develop and Implement Hazardous Waste Management Plan to include the identification, storage, and transporting of HW; training of personnel; tracking manifests; and maintaining required records.

• RCRA Compliance Waste Streams Chapter 3, App. A

• Waste Accumulation, Storage, and Transfer Facilities Chapters 3 and 4

• Hazardous Waste Inventory Chapter 3

• Transporting Hazardous Waste Chapter 4

• Disposing of Hazardous Waste Chapters 3 and 4

10-1 d(4) Maintain Appropriate Hazardous Waste Records

10-1 d(5) Reporting Requirements

10-1 d (6)(7)(8)(9)

Local Procedures and Responsibilities Chapter 1

Minimizing Waste by Preventing Pollution Throughout

5-4 Storage, Handling, Application, and Disposal of Pesticides Chapters 3 and 4, Page A-30

5–4c Disposing of Samples or Waste Pesticides and Pesticide Containers Chapters 3 and 4, Page A-30

Responsibilities The following responsibilities are organized according to the USAFCOEFS.

Environmental Quality Division (EQD) The EQD will:

• Coordinate, inspect, or manage all aspects of installation actions relative to environmental regulations.

• Serve as the single point of contact for federal, state, and local agencies with regard to environmental permits, interpretation of regulatory requirements, and coordination and resolution of noncompliance issues or findings.

• Monitor installation compliance with federal, state, and local environmental requirements, including activities of tenants and sub-installations, and recommend to the Installation Commander necessary or advisable changes in policies to improve program management.

• Prepare all required status and compliance reports relative to solid and hazardous waste management, in accordance with applicable federal, state, and local regulatory requirements.

• Advise all waste generating activities of federal, state, local, and Army requirements for managing solid and hazardous waste, including requirements for permits, reporting, and recordkeeping to ensure compliance.

• Advise the Installation Commander on the most cost-effective and efficient means of waste storage, treatment, and disposal, to include the sighting of new waste management facilities.

• Provide technical assistance and guidance to hazardous waste generating activities, tenants, and operators of hazardous waste, storage and disposal who have approved Satellite Accumulation Area (SAAs).

• Ensure hazardous wastes are properly identified, segregated, and weighed pursuant to federal, state, and Army requirements prior to release for transportation or disposal.

• Coordinate the analysis of waste to determine if it is hazardous and provide copies of waste analysis prior to release for off-post transportation or release to the Defense Logistics Agency Disposition Services (DLADS).

• Coordinate an installation-wide inventory of all hazardous waste generated and identify the waste generating activities annually.

• Establish, monitor, and execute programs in waste management, including waste minimization, resource recovery, reutilization, and recycling.

• Immediately advise the Installation Commander of the receipt of enforcement notices of violation, consent orders, or compliance agreements.

• Exercise staff responsibility for directing and coordinating the Hazardous Waste Management Program.

Medical Department Activity (MEDDAC) The MEDDAC will:

• Provide for the disposal of non-RCRA regulated medical, dental, and veterinary supplies and infectious waste in accordance with AR 40-5, federal and state laws and regulations, and this plan.

• Provide the Installation Commander with the solid waste and hazardous waste management implications of new and revised MEDDAC practices for review and concurrence.

• Prepare and maintain a management plan for the disposal of medical wastes.

• Provide workplace guidance on daily use of personal protective equipment, including respirators required for personnel involved in surveys, spill response, confined space entry, and abatement actions.

• Perform physical examinations before placement, annually during employment, and at the termination of employment for personnel working with asbestos, lead-based paint, or other hazardous materials, as required by TB MED 513.

• Maintain health records of all personnel and former employees involved in working with asbestos, lead-based paint, and hazardous materials as required by AR 40-5 and

AR 40- 66.

• Program and budget adequate resources to accomplish medical support responsibilities for the installation and supported activities.

• Provide expertise in compliance matters associated with Occupational Safety and Health Administration (OSHA) health-related federal, state, and local requirements.

• Exercise staff responsibility for administrative monitoring and medical surveillance of all personnel working on Fort Sill for hazardous and toxic occupational health hazards.

Preventive Medicine, RACH Preventive Medicine, RACH will:

• Conduct field investigations and special studies to support environmental management programs and recommend measures required for protection of health.

• Provide technical assistance in the identification of wastes and guidance on the health aspects of the management and disposal of hazardous and toxic materials.

• Forward all requests for Environmental Health and Engineering Services support from the U.S. Army Public Health Command (USAPHC) through the Chief, Preventive Medicine, MEDDAC, to the Director of Health Services. The primary responsibilities for medical surveillance of pollution sources are assigned to the Director of Health Services with cooperation and support from the Safety Office and the EQD.

Public Affairs Office (PAO) The PAO will:

• Ensure that the public is informed of Fort Sill’s accomplishments in environmental protection, enhancement, and management.

• Develop public information plans to stimulate active support of the environmental program throughout commands down to the individual soldier and civilian employee.

• Coordinate with the EQD to release appropriate information concerning environmental matters.

• Coordinate and conduct public involvement activities (e.g., public meetings and public hearings) that satisfy the requirements of environmental permits and National Environmental Policy Act (NEPA) activities. Assist in the preparation of public involvement activities sponsored by other agencies.

Safety Office The Safety Office will:

• Assist EQD, MEDDAC, and other activities on Fort Sill in applying safety procedures and standards.

• Manage and dispose of radioactive materials.

Logistics Readiness Center (LRC) The LRC will:

• Monitor the use of hazardous materials to achieve progress in meeting federal and Army hazardous waste minimization goals and requirements and provide quarterly progress reports to EQD.

• Provide a semiannual report to the Installation Commander recommending opportunities for, and progress in achieving, a reduction in the use and toxicity of hazardous materials, following the concurrence of EQD.

• Manage and dispose of radioactive materials.

• Advise installation units and activities on proper requirements for packaging, labeling, and shipping of solid and hazardous material.

• Monitor supply items to identify those that may be categorized as hazardous and/or toxic and report them to EQD. LRC will monitor the supply, usage, and disposal of radioactive materials other than medical supplies, and assist MEDDAC with disposal of excess or waste radioactive materials.

Other Staff Directorates, Activities, and Subordinate Commands Other staff directorates, activities, and subordinate commands will:

• Integrate environmental protection, conservation, and preservation into the planning and execution of the Fort Sill mission to the fullest extent feasible.

• Establish an organizational structure to plan, execute, and inspect established environmental and conservation programs within their area of responsibility.

• Appoint in writing an Environmental Officer and alternate, as needed, to assure compliance with directives.

• Provide required input to the Installation Status Report, Part II (Environment).

• Be fully aware of and comply with all applicable federal, state, and local laws and regulations, both substantive and procedural, for generating, treating, storing, disposing of, and transporting solid and hazardous waste, including the terms and conditions of state and federal solid and hazardous waste permits and reporting requirements.

• Ensure that program and budget requests identify resource requirements to manage solid and hazardous waste programs, including waste minimization, and to achieve and maintain compliance.

• Encourage the use of joint or regional resource recovery with federal and nonfederal agencies (including commercial waste treatment) when advantageous, cost-effective, or more efficient to Fort Sill.

• Minimize the generation and land disposal of solid wastes and hazardous wastes by promoting waste minimization.

• Generate, transport, store, and dispose of wastes such as pesticides; hazardous chemical stocks; medical, dental and veterinary supplies; radioactive materials; propellant;

explosive and pyrotechnic materials; explosive ordnance; or chemical warfare agents in a manner that protects public health and the environment.

Environmental Officer (EO) The EO will:

• Implement the procedures established by this Plan.

• Conduct inspections (or ensure that inspections are conducted) of waste accumulation areas.

• Implement hazardous waste spill procedures when necessary.

• Function as a liaison on all environmental issues between the unit and the EQD.

• Notify the EQD of changes to operations, including process changes, new waste streams, materials used, and materials stored.

• Ensure that appropriate unit personnel receive the proper level of waste management training.

• Ensure that unit regulated waste is turned in to EQD in a timely manner, to include wastes generated during training exercises.

• Responsible for properly maintaining HM to minimize safety hazards, prevent spills, and reduce hazardous waste generation

• Turn-in or accompany the turn-in of regulated waste to EQD

Table 1-2 contains a list of the unit/site required functions, where the information concerning these functions is located in this plan, and the frequency in which these activities must take place.

Table 1-2. EO Compliance Table

Function Information Frequency Location Weekly Monthly Quarterly Annually

Hazardous Materials Inventory Chapter 2 X and whenever new supplies are obtained and old supplies depleted

Shelf Life Update Chapter 2 X Inspection Chapter 2 X Portable Container Inspection

Chapter 5 X

Mobile Refueler/Fuel Pod Inspection

Chapter 5 X

Hazardous Waste Accumulation Point Inspection

Chapter 3 X

Training Hazardous Communication Chapter 5 X*

Hazardous Waste Chapter 5 X*

HAZMAT (Dept. of Transportation [DOT]) Personnel

Chapter 5 Biennial*

Environmental Officer Chapter 5 X*

* Initial training also required upon assignment.

Forms for Submitting Changes to This Plan This section includes DA Form 2028 to be completed to submit changes to this plan.

RECOMMENDED CHANGES TO PUBLICATIONS AND BLANK FORMS Use Part II (reverse for

Repair Parts and Special Tool Lists

(RPSTL)).

DATE

INSTRUCTIONS FOR SUBMITTING THE DA FORM 2028

This form may be submitted by mail or electronically. For changes to blank forms, submit the DA Form 2028 electronically to the publications control officer (PCO), and the forms management officer (FMO) of the organization that has oversight of the form/publication. See PCO/FMO email addresses on the APD Website at: https://armypubs.army.mil/default.aspx, then click on the 'RESOURCES' menu link at the top, then the link for the 'PC/PCO/FMO/EPCO Directory (CAC required for access)'. For comments/recommended changes to publications, users must submit the DA Form 2028 as required by the publication's proponent. (See suggested improvements paragraph on the title page of each publication to determine the proponent's preferred way to communicate.)

DETERMINING AND SELECTING THE PROPER PROPONENT

To identify the proper proponent for any publication or form, visit the APD Web site at: https://armypubs.army.mil/default.aspx and click on the 'RESOURCES' menu at the top, then click on the 'PC/PCO/FMO/EPCO Directory (CAC required for access)' link to access the directory.

TO: (Forward to proponent of publication or form) (Include ZIP Code) FROM: (Activity and location) (Include ZIP Code)

PART I - ALL PUBLICATIONS (EXCEPT RPSTL) AND BLANK FORMS

PUBLICATION/FORM NUMBER, CHANGE NUMBER

(If applicable)

PUBLICATION/ FORM

DATE

TITLE

For each comment, include as applicable: Comment number, work package number or data module code, page number, paragraph number, figure number, table number, recommended change, and reason for change.

TYPED NAME, GRADE/RANK, POSITION TITLE, E-MAIL

ADDRESS

TELEPHONE NUMBER/DSN/

EXTENSION

SIGNATURE

DA FORM 2028, JUN 2018 PREVIOUS EDITIONS ARE OBSOLETE. Page 1 of 1

January 2023 Page 9 https://armypubs.army.mil/default.aspx https://armypubs.army.mil/default.aspx https://armypubs.army.mil/default.aspx

Fort Sill Hazardous Material and Waste Management Plan Managing Hazardous Materials

Chapter 2: Managing Hazardous Materials Nearly all facilities on Fort Sill use HMs, which are essentially those items requiring a Safety Data Sheet (SDS) (formerly known as Material Safety Data Sheet or MSDS). The EO for the facility is responsible for properly maintaining HM to minimize safety hazards, prevent spills, and reduce hazardous waste generation. This chapter provides detailed guidance for managing HM. It addresses the following topics in the order one should follow when setting up an HM program for the first time:

• Identifying unwanted or unserviceable HM

• Obtaining and cataloging SDSs for each HM

• Determining HM compatibility

• Maintaining and extending HM shelf life

• Selecting HM storage units (includes Storing Compressed Gases)

• Stocking HM storage locations

• Conducting HM inventories

Follow the procedures outlined in this chapter as a minimum requirement for hazardous materials management. While each of the steps may not be required by regulation, they comprise a system that allows the user to prevent and/or reduce waste generation (i.e., pollution prevention), and ensure the safety of facility personnel working with HM.

OSHA and Globally Harmonized System of Classification and Labeling of Chemicals (GHS) The GHS was adopted by OSHA (Occupational Safety and Health Administration) Hazard Communication standard in 2012. This system was implemented at Fort Sill in September 2018. GHS was developed by the United Nations to bring into agreement the chemical regulations and standards of different countries. In short, it is an international attempt to get all countries on the same page when it comes to defining and communicating chemical hazards. The main purpose of this system is to classify the chemicals with a system that can be used across the world.

The GHS includes criteria for the classification of health, physical and environmental hazards, as well as specifying what information should be included on labels of hazardous chemicals as well as safety data sheets. GHS adoption affects everyone in the chemical lifecycle and includes special responsibilities for chemical manufacturers and employers that handle, use and store hazardous materials. GHS adoption requires chemical manufacturers to reclassify their chemicals using standardized GHS classification criteria, as well as to produce GHS-aligned labels and safety data sheets (SDSs). The GHS pictograms and hazards associated with each pictogram can be found on page 23.

Identifying Unwanted and Unserviceable HM Removing unwanted and unserviceable HM from facilities is key to minimizing safety hazards, preventing spills, and reducing/eliminating hazardous waste generation.

Approximately 60% of the hazardous waste generated by the DoD comes from unused HM.

To identify and remove unwanted and unserviceable HM, complete the following steps:

1. Walk around the entire facility and check closets, wall lockers, storage rooms, etc., for HM. Collect containers that are:

• Unwanted (excess) or unserviceable HM

• Unlabeled or unidentifiable material that may be hazardous

• Damaged, leaking, or subject to leaking

• Type I shelf-life items that have expired and cannot be renewed

• Type II shelf-life items that can no longer be extended

2. Obtain SDSs, as described in the next section, for all the unwanted and unserviceable HM and process them for turn-in IAW Chapter 4.

Obtaining and Cataloging Safety Data Sheets SDSs provide compatibility information for HMs. They also contain information about the manufacturer, the chemical ingredients, associated hazards, specific handling procedures, and spill response measures. Each facility must maintain a master binder that contains SDSs for all the HM being stored at the facility. This section explains how to obtain, and catalog required SDSs.

1. Obtain an SDS for each HM at the facility. SDSs can be obtained from the Hazardous Materials Information Resource System (HMIRS). You will first need to establish an account on HMIRS. Access HMIRS at: https://www.dla.mil/Information- Operations/Services/Applications/HMIRS/; Click Access to AMPS, Click First Time User.- Click Here to Register, Click user type, Fill out AMPS User Registration – User Information.. If the SDS is not available through HMIRS, request assistance from the EQD, or the manufacturer. The SDS must be specific to the product's National Stock Number (NSN) and CAGE number (manufacturer's code). These numbers are printed on the SDS and on the HM container.

2. Create a master binder with all SDSs and centrally locate it so an SDS can be located quickly in case of a spill or exposure. The binder must be accessible at all times for review by employees or emergency personnel.

3. Create an index in the front of the binder(s) listing the SDSs. Place all SDSs in the binder in an order such that they can be easily found. A preferred method for managing SDSs is to assign a unique number to each SDS and write the number on every container of that HM. This step allows an SDS to be placed in a binder in sequential order, making it easier for employees to find and easier to insert new SDSs.

EXAMPLE: There are five HMs in your facility, and you have ten containers of each.

Starting with any one of the HMs, write a “1” on the SDS and on all containers of that HM.

For the next HM, write a “2” on the SDS and on all containers of that HM. For the next HM, assign the number 3, and so on. Place the SDSs in the binder in numerical order (i.e., 1, 2, 3

Determining Hazardous Material Compatibility Once the SDSs are obtained for all the HM at the facility, the EO must determine https://usg01.safelinks.protection.office365.us/?url=https%3A%2F%2Fwww.dla.mil%2FInformation-Operations%2FServices%2FApplications%2FHMIRS%2F&data=05%7C01%7Cmichael.a.monroe18.civ%40army.mil%7Cc1522996630d4316a59208dbdfbfb50f%7Cfae6d70f954b481192b60530d6f84c43%7C0%7C0%7C638349786713043663%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C3000%7C%7C%7C&sdata=ekk8gEPBW1Sr6Eg%2FE%2BaNWnuDDQSag%2F8N9evcLcs2mss%3D&reserved=0 https://usg01.safelinks.protection.office365.us/?url=https%3A%2F%2Fwww.dla.mil%2FInformation-Operations%2FServices%2FApplications%2FHMIRS%2F&data=05%7C01%7Cmichael.a.monroe18.civ%40army.mil%7Cc1522996630d4316a59208dbdfbfb50f%7Cfae6d70f954b481192b60530d6f84c43%7C0%7C0%7C638349786713043663%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C3000%7C%7C%7C&sdata=ekk8gEPBW1Sr6Eg%2FE%2BaNWnuDDQSag%2F8N9evcLcs2mss%3D&reserved=0 compatibility of the material. Flammables, for instance, must not be stored with oxidizers.

The easiest way to determine compatibility is to use SDSs generated from the HMIRS. There are two other ways to determine compatibility, as well. All three are discussed in this section.

Method 1: Determining Compatibility Using HMIRS Generated SDSs When using the HMIRS SDSs method for determining compatibility, complete the following steps:

1. From the SDSs obtained through HMIRS, find the Hazard Characteristic Code (HCC) under Physical Chemical Properties.\

2. Using the Storage Segregation Matrix in Table 2-1, find the matching HCC located in the far left column.

3. Follow the row across the table and locate the * marking.

Figure 2-1. SDS Showing HCC

4. Follow the column up from the * marking to the Primary Segregation Letter. These letters stand for the following:

A Radioactive C Corrosive D Oxidizer E Explosive F Flammable G Gas, Compressed L Low Hazard (General Purpose) P Peroxide, Organic R Reactive T Poison

5. Hazardous materials may only be stored with items that have the same Primary Segregation Letter. For example, store Fs with other Fs (flammables with other flammables) and Cs with other Cs (corrosives with other corrosives).

6. Return to the HM's HCC row and find the "Note" under the Secondary Segregation column. Go to the back end of the table and read the note for any additional segregation requirements.

For example: A facility has an HM with a HCC of F7 (a corrosive alkali that is flammable) and an HM with an HCC of F6 (a corrosive acid that is flammable). Because they are both Fs, it first appears that they could be stored together. However, they both have a Secondary Segregation Note L, which states, “Separate from other flammables and flammables with secondary hazards by at least one four-foot aisle width."

7. Once compatibility is determined, the EO must store the HM accordingly. Go to “Selecting HM Storage Units” section in this chapter for more guidance; matrix and supporting tables can be found in Army Technical Manual 38-410.

Table 2-1. Storage Segregation Matrix

HCC Hazard Primary Segregation Secondary Characteristics Group Name A C D E F G L P R T

Segregation

A1 Radioactive, Licensed

* Note A

A2 Radioactive, License Exempt

* Note A

A3 Radioactive, License Exempt, Authorized

* Note A

B1 Alkali, Corrosive Inorganic

* Note B

B2 Alkali, Corrosive Organic

* Note C

B3 Alkali, Low Risk * Note F

C1 Acid, Corrosive & Oxidizer, Inorganic

* Note D

Group Name A C D E F G L P R T

Segregation

C2 Acid, Corrosive, Organic

* Note E

C3 Acid, Low Risk * Note F

C4 Acid, Corrosive & Oxidizer, Organic

* Note E

C5 Acid, Corrosive & Oxidizer, Organic

* Note E

D1 Oxidizer * None

D2 Oxidizer & Poison * Note G

D3 Oxidizer & Corrosive Acidic

* Note G

D4 Oxidizer & Corrosive Alkali

* Note G

E1 Explosive, Military * Note H

E2 Explosive, Low Risk

* Note A

F1 Flammable Liquid

DOT

PG I, OSHA IA

* Note J

F2 Flammable Liquid

DOT

PG II, OSHA IA

* Note J

F3 Flammable Liquid

DOT

PG III, OSHA II

* Note J

F4 Flammable Liquid

DOT

PG III, OSHA II

* Note J

F5 Flammable Liquid & Poison

* Note L

F6 Flammable Liquid & Corrosive, Acidic

* Note L

F7 Flammable Liquid & Corrosive, Alkali

* Note L

F8 Flammable Solid * Note K

Group Name A C D E F G L P R T

Segregation

G1 Gas, Poison (Nonflammable)

* Note M

G2 Gas, Flammable * Note N

G3 Gas, Nonflammable

* Note P

G4 Gas, Nonflammable, Oxidizer

* Note R

G5 Gas, Nonflammable, Corrosive

* Note S

G6 Gas, Poison, Corrosive (Nonflammable)

* Note T

G7 Gas, Poison, Oxidizer (Nonflammable)

* Note U

G8 Gas, Poison, (Flammable)

* Note V

G9 Gas, Poison, Corrosive Oxidizer

(NF)

* Note W

K1 Infectious Substance

* Note X

K2 Cytotoxic Drugs * Note Y

M1 Magnetized Material

* None

N1 Not Regulated as Hazardous

* None

P1 Peroxide, Organic, Type A-F DOT Regulated

* None

P2 Peroxide, Organic Type G (Low Risk)

* None

R1 ReactiveChemical, Flammable

* Note Z

Group Name A C D E F G L P R T

Segregation

R2 Water Reactive Chemical

* Note AA

T1 DOT Poison – Acute Toxin Inhalation Hazard

* None

T2 UN Poison, Acute Toxin Packing Group I

* None

T3 UN Poison, Acute Toxin Packing Group II

* None

T4 UN Poison, Acute Toxin Packing Group III

Note BB

T5 Pesticide, Low Risk

* None

T6 Health Hazard * None

T7 Carcinogen

(OSHA, NTP,

IARC)

* Note CC

V1 Miscellaneous Hazardous Materials – Class 9

* None

V2 Aerosol, Nonflammable

* Note EE

V3 Aerosol, Flammable

* Note EE

V4 DOT Combustible Liquid, OSHA IIIA Category 4

* None

V5 Hi-Flash Point Materials, OSHA IIIB

* None

V6 Petroleum Products * None

V7 Environmental Hazard

* None

Z1 Article Containing Asbestos

* None

Z2 Article Containing Mercury

* None

Group Name A C D E F G L P R T

Segregation

Z3 Article Containing Polychlorinated Biphenyls(PCB)

* None

Z4 Article, Battery, Lead Acid, Non-spillable

* None

Z5 Article, Battery, NickelCadmium, Non-spillable

* None

Z6 Article,Battery, Lithium

* Note DD

Z7 Article,Battery, Dry Cell

* None

Z8 Article Battery, Lithium Large Form

Note DD

DEFINITION OF NOTES

NOTE A Security Storage – must be well ventilated with limited access.

NOTE B Inorganic Alkali Storage – store away from acids by at least one 4-foot aisle width and away from organic alkalis by at least one 4-foot aisle width.

NOTE C Organic Alkali Storage – store away from acids by at least one 4-foot aisle width and away from inorganic alkalis by at least one 4-foot aisle width.

NOTE D Inorganic Acid Storage – store away from alkalis (caustics) by at least one 4-foot aisle width and away from organic acids by at least one 4-foot aisle width. Separate from other acids with subsidiary risk labels by at least one 4-foot aisle width.

NOTE E Organic Acid Storage – store away from alkalis (caustics) by at least one 4-foot aisle width and away from inorganic acids by at least one 4-foot aisle width. Separate from other acids with subsidiary risk labels by at least one 4-foot aisle width.

NOTE F Further separate into Acid and Alkali storage within the low hazard storage area to keep potentially incompatible products from mixing.

NOTE G Separate from other oxidizers and oxidizers with secondary hazards by at least one 4-foot aisle width.

NOTE H Magazine Storage.

NOTE J Segregate into Flammable Liquid storage separate from flammable solids by at least one 4-foot aisle width.

NOTE K Segregate into Flammable Solid storage separate from flammable liquids by at least one 4-foot aisle width

NOTE L Separate from flammables and flammables with secondary hazards by at least one 4-foot aisle width.

NOTE M Further segregate into Poison Gas storage within compressed gas area.

NOTE N Further segregate into Flammable Gas storage within compressed gas area.

NOTE P Further segregate into Non-flammable Gas storage within compressed gas area.

NOTE R Further segregate into Oxidizer Gas within the Non-flammable Gas storage that is within the compressed gas area.

NOTE S Further segregate into Corrosive Gas within the Non-flammable Gas storage that is within the compressed gas area.

Group Name A C D E F G L P R T

Segregation

NOTE T Further segregate into Corrosive Gas within the Poison Gas storage that is within the compressed gas area.

NOTE U Further segregate into Oxidizer Gas within the Poison Gas storage that is within the compressed gas area.

NOTE V Further segregate into Flammable Gas within the Poison Gas storage that is within the compressed gas area.

NOTE W Further segregate into Corrosive and Oxidizer Gas within the Poison Gas storage that is within the compressed gas area.

NOTE X Further segregate into Biomedical storage within the Poison storage area.

NOTE Y Further segregate into Medical Security storage within the Poison storage area.

NOTE Z Further segregate into Spontaneously Combustible storage within the Reactive storage area.

NOTE AA Should not store in areas protected with water sprinkler system. Fire protection should be non-water based.

NOTE BB Store away from food.

NOTE CC Further segregate within Poison storage area may be necessary if secondary hazards exist (i.e. flammable, corrosive, etc.).

NOTE DD Separate from other products within the Reactive storage area.

NOTE EE Store aerosols from flammables by placing in separate room or barrier such as floor to ceiling wire mesh, chain link fence, etc. to protect personnel from aerosols that can become self-propelled projectiles.

Method 2: Determining Compatibility Using DOT Hazard Labels

1. If an HMIRS-generated SDS is not available, look for a DOT Hazard Label on the container or the box the HM was shipped in.

Figure 2-2. Sample DOT Hazard Labels

Flammable Liquid Flammable Solid Flammable Gas Oxidizer Dangerous When Wet

Corrosive Poison Class 9 Non-Flammable Gas

2. If a DOT label is present, use Table 2-2 below to obtain an Interim HCC.

3. Once you have the Interim HCC, go back to Table 2-1 and follow Steps 2 through 7 under Method 1 to determine compatibility.

Table 2-2. DOT Labels

DOT Label Interim HCC Recommended Storage Area

Primary Secondary

Explosive 1.1 E1 Explosive Magazine NA Explosive 1.2 E1 Explosive Magazine NA

Explosive 1.3 E1 Explosive Magazine NA

Explosive 1.4 E2 Explosive Security

Explosive 1.5 E2 Explosive Security

Explosive 1.6 E2 Explosive Security

Poison Gas G1 Compressed Gas Poison Gas Cylinder

Flammable Gas (Cylinder) G2 Compressed Gas Flammable Gas Cylinder

Flammable Gas(Aerosol Non-refillable Tank or Canister)

V3 Flammable Aerosol Containers

Nonflammable Gas G3 Compressed Gas Nonflammable Gas Cylinder

Flammable Liquid F1-F4 Flammable Flammable Liquid

Flammable Solid F8 Flammable Flammable Solid

Spontaneously Combustible R1 Reactive Spontaneously Combustible

Dangerous When Wet R2 Reactive DangerousWhen Wet, No Water Sprinklers

Oxidizer D1 Oxidizer None Required

Organic Peroxide P1 Peroxide Organic None Required

Poison T2 Poison None Required

Harmful Keep Away From Food T4 Low Hazard Away From Food

Infectious Substance K1 Poison Biomedical

Radioactive I A1 Radioactive Security

Radioactive II A1 Radioactive Security

Radioactive III A1 Radioactive Security

Corrosive C1, C2, C4, C5 (Acid)*

Corrosive Acid

Corrosive B1, B2, B3 (Alkali)

Corrosive Alkali

Class 9 V1 Low Hazard None Required

Magnetized Material M1 General Purpose None Required

* If it is not known whether a corrosive is an acid or an alkali, look on the SDS or contact the HMIRS for a technical determination.

Method 3: Determining Compatibility Using GHS/OSHA Precautionary Labels

1. If an HMIRS-generated SDS is not available, look on the HM container for a

GHS/OSHA precautionary label. Precautionary labels start with signal words followed by specific handling precautions. The three signal words used are Danger, Warning, and Caution.

Figure 2-3. Example Precautionary Label

2. If a precautionary label is present, use Table 2-3 below to obtain a Suggested Temporary HCC. Match the label with the “Signal Word” and “Statement of Hazard” in the first two columns of the table. The statement of hazard won’t always be exact. Choose the one that best describes the hazard.

3. Once you have the Suggested Temporary HCC from column 3, go back to Table 2-1 and follow Steps 2 through 7 under Method 1 to determine compatibility.

Table 2-3 Precautionary Labels

Signal Word Examples of Statements of Hazard

Suggested Temporary HCC

Recommended Primary Storage Area

Recommended Secondary Storage Area

DANGER! MAY BE FATAL IF

SWALLOWED

T2 Poison None Required

WARNING! HARMFULIF

SWALLOWED

T3 Poison None Required

WARNING! HARMFULIF

SWALLOWED

T4 Low Hazard* Away From Food

DANGER! MAY BE FATAL IF

ABSORBED THROUGH

SKIN

T2 Poison None Required

*WARNING! HARMFUL IF ABSORBED

THROUGHSKIN

T6 Low Hazard* None Required

DANGER! CAUSES(SEVERE)**

BURNS

C1, C2, C4, C5 Corrosive Acid

DANGER! CAUSES(SEVERE)**

BURNS

B1, B2 Corrosive Alkali

DANGER! EXTREMELY

FLAMMABLE

F1 Flammable Flammable Liquid

WARNING! FLAMMABLE F2, F3, F4 Flammable Flammable Liquid

WARNING! FLAMMABLE F8 Flammable Flammable Solid

+ WARNING! COMBUSTIBLE V4 Flammable None Required

WARNING! Contents under pressure. Do not puncture or incinerate. Do not store at temperatures above 120 degrees F.

Keep out of reach of children.

Signal Word Examples of Statements of Hazard

Suggested Temporary HCC

Recommended Primary Storage Area

Recommended Secondary Storage Area

DANGER! EXTREMELY

FLAMMABLE, CATCHES

FIRE IF EXPOSED TO AIR

R1 Reactive Spontaneously Combustible

DANGER! STRONGOXIDIZER,

CONTACT WITH OTHER

MATERIALSMAY

CAUSE FIRE

D1 Oxidizer None Required

DANGER! MAY BE FATAL IF

INHALED

T1 Poison None Required

WARNING! HARMFUL IF INHALED T2 Poison None Required

WARNING! MAY CAUSE ALLERGIC

RESPIRATORY

REACTION

T6 Low Hazard* None Required

+ WARNING! (VAPORGAS)**

REDUCESOXYGEN

AVAILABLEFOR

BREATHING

T6 Low Hazard* None Required

WARNING! CAUSES EYE

IRRITATION

T6, C3, B3 Low Hazard* None Required

WARNING! CAUSESIRRITATION T6, C3, B3 Low Hazard* None Required

WARNING! MAY CAUSE ALLERGIC

SKINREACTION

T6, T5, C3, B3 Low Hazard* None Required

Please note that “None Required” means no additional storage requirements.

* Material bearing precautionary label text will not be assigned a Low Hazard (General Purpose) location without notification and approval by the EQD.

** Enter proper term as appropriate.

+ Edited post-publish to change CAUTION to WARNING. CAUTION Signal Word is no longer used under the OSHA HAZCOM Standard.

4. If the GHS/OSHA Precautionary Labels are not available another option to obtain Hazardous Material compatibility is by the GHS/OSHA pictogram label. The SDS should indicate the GHS/OSHA pictogram label. If the SDS is not available or does not show or indicate the pictogram look on the HM container for a GHS/OSHA pictogram label. If you need further assistance, contact the EQD.

Figure 2-4 GHS/OSHA Pictogram Labels

Maintaining and Extending Shelf Life Shelf-Life Extension System (SLES) is the DoD Shelf-Life Management system regarding internal shelf-life policy information for the life-cycle management of standard and hazardous shelf-life items contained in the Federal supply system. Units can acquire the Shelf Life data online at https://www.shelflife.dla.mil.

Setting up Storage Areas

Storage Lockers

Storage lockers are intended for use in the immediate work area. They should be National Fire Protection Association (NFPA) approved and should contain only small quantities of HM that are used in the facility on a daily basis. Lockers should not be “stuffed” with HM such that they become a tinderbox should a fire break out. Store excess containers of HM in storage rooms or buildings away from the work area.

Use the lockers for their intended purpose. For instance, do not store non-flammables, such as oil, in a Flammables Locker. Only store flammables (those with a flashpoint <200°F) in Flammables lockers. Keep lockers clean and orderly, and maintain all structural integrity and hardware, including doors, hinges, and shelves. Do not remove the door or ventilation bungs, penetrate the wall, modify ventilation, or otherwise modify the locker. Keep locker doors closed. To set up a locker, complete the following steps:

1. Select a location for the locker:

• Locate the locker indoors in a well-ventilated area near where the HM will be used, or outdoors under cover.

• Maintain easy access to the locker; do not block doors or place “stuff” on the locker.

• Do not place the locker near doors, break rooms, bathrooms, offices, or other occupied non-shop areas.

• Do not place the locker near floor drains, drainage channels, or areas with high foot or vehicle traffic.

• Keep storage lockers away from storm drains.

2. Coordinate with the EQD and Fire Department to ensure that the correct NFPA locker is being used. NFPA lockers are already marked/labeled. Do not place unauthorized signs, labels, stickers, or markings on the locker.

3. Ensure that an appropriately rated fire extinguisher and spill response equipment are located nearby.

NOTE: To make it easier to track HM usage, conduct inventories, and ensure that HM is stored in its proper location, consider assigning a four-character identifier to the locker and mark it on the front, top, right corner (See Figure 2-5). This identifier will consist of one of the three abbreviations used to differentiate locker contents and a two-digit sequential number (e.g., FL 01). The abbreviations are: FL – Flammable Locker, CL – Corrosive Locker, OL – Oxidizer Locker.

Figure 2-5. NFPA Flammable Storage Locker

Storage Rooms and Buildings and Placards Storage rooms and buildings (Safe Store®) are intended for storage of backup supplies of HM not kept in storage lockers and large containers of HM (>1 gallon). Locate storage rooms and Safe Store® out and away from the work area. Keep them clean and orderly, and maintain all structural integrity and hardware including doors, hinges, and shelves. Do not remove doors, penetrate walls, modify ventilation, or otherwise modify the room or building, if it has already been approved. To set up a storage room or building, complete the following steps:

chosen.

1. Have the EQD, Fire Department, or designated representative approve the location

2. Provide primary and secondary containment as required by 40 CFR Part

64.175(b)(3). Secondary containment should be 10 percent of the volume of all containers, or the volume of the largest container, whichever is greater.

NOTE: For storage rooms, the floor space itself usually provides enough secondary containment. However, ensure that the spill cannot escape the room. For example, equip each door with a sealed threshold, or store HM in pans or tubs on the shelf, making sure the HM is compatible with the container.

3. Ensure that an appropriately rated fire extinguisher/extinguisher system and spill response equipment is located nearby.

The correct placard for storage buildings and rooms is the NFPA704. The national Fire Protection Association has developed a rating system to identify and rank hazards of a material. The label is diamond-shaped, made up of four smaller diamonds one blue, red, yellow, and white. A number or special symbol is placed on the four diamonds.

4. The blue diamond, appearing on the left side of the label, conveys Health Hazard information for persons exposed to the material. A number from 0 to 4 is written in the blue diamond. The higher the number the higher the hazard as follows:

0 – No hazard under fire conditions beyond that of ordinary combustible materials.

1 – Can cause irritation if not treated.

2 - Can cause injury. Requires prompt treatment.

3 - Can cause serious injury despite medical treatment.

4 - Can cause death or major injury despite medical treatment.

• The red diamond, appearing at the top of the label, conveys Flammability Hazard information. Again the numbers 0 to 4 are used to rate the flammability hazard as follows:

0 – Will not burn.

1 – Ignites after considerable preheating.

2 - Ignites when moderately heated.

3 – Can be ignited at all normal temperatures.

4 – Very flammable gases or very volatile flammable liquids.

• The yellow diamond appearing at the right side of the label, conveys Reactivity (or

Stability) information. The numbers 0 to 4 are also used to rank reactivity hazards as follows:

0 – Normally stable. Not reactive with water.

1 – Normally stable. Unstable at high temperatures and pressure. Reacts with water.

2 – Normally unstable but will not detonate.

3 – Can detonate or explode but requires strong initiating force or heating under confinement.

4 – Readily detonates or explodes.

• The white diamond appearing at the bottom of the label, conveys Special Hazards information. This information is conveyed by use of symbols that represent the special hazard. Some of the common symbols are shown here:

W - denotes the material is water reactive.

OX - denotes an oxidizing agent.

COR - denotes a corrosive hazard.

ALK - denotes an Alkali hazard.

ACID - denotes an Acid hazard.

To determine the NFPA Hazard Ratings for a material that does not have the label affixed, check the SDS. NFPA Hazard Ratings are commonly displayed there.

Besides the NFPA placard also put the correct label (flammable or corrosive) on the storage buildings.

Placards and labels for storage room/buildings can be ordered at http://www.grainger.com. After ordering the NFPA704 placard(s) needed, contact the Fire Department to ensure the proper number or symbol is displayed in the diamonds. Unit Movement (Building 2276, 442-3661) supplies placards for vehicle. Do not use vehicle placards on storage rooms/buildings.

http://www.grainger.com/

NOTE: To make it easier to track HM usage, conduct inventories, and to ensure HM is stored in its proper location, consider assigning a four-character identifier to the storage area and mark it on each storage area door (See Figure 2-6). This identifier will consist of one of the two abbreviations used to differentiate contents and a two-digit sequential number (SB 01, SB 02 etc.).

abbreviations are: SB – Storage Building, SR – Storage Room

Figure 2-6. Safe Store® Building (Storage Room/Building)

Storage Racks

To set up a storage rack, complete the following steps:

1. Have the EQD and Fire Department approve the location chosen.

2. Provide primary and secondary containment. Secondary containment must be 10 percent of the total volume of containers, or the volume of the largest container, whichever is greater. If stored outside, provide enough secondary containment to contain a spill from the largest single container, plus an additional 10 percent. For instance, if the largest container is 55 gallons, provide 55 gallons of secondary containment plus 10%, or 5.5 gallons (a total of

60.5 gallons). Place drip…