Appendix_L_-_Affirmative_Proc_Plan.pdf

Supersedes FY-14 edition FY-15

CDRL CEV-15H

AFFIRMATIVE PROCUREMENT PLAN

Thule Air Base, Greenland

FINAL, FY-15

OPR: GREENLAND CONTRACTORS

Chief of Environmental Engineering DSN 629-3840 ext. 2698 Contract No. FA2523-05-C-9001

CDRL CEV-15H Affirmative Procurement Plan

Thule Air Base, Greenland 3/17 FY-15

TABLE OF CONTENTS

1 LETTER OF INSTRUCTION

1.1 Security and Administrative Instructions

2 GENERAL

2.1 Purpose

2.2 Scope

2.3 Regulatory Overview

3 ORGANIZATIONAL ROLES AND RESPONSIBILITIES

3.1 Installation Commander, 821 ABG/CC

3.2 Accounting and Finance, 821 ABG/FM

3.3 Environmental Engineering, GC/EE

3.4 Base Supply, GC/LGS

4 AFFIRMATIVE PROCUREMENT

4.1 Requirements of affirmative procurement

4.2 Preference program and exceptions

4.3 Comprehensive Procurement Guidelines (CPG)

5 HAZMAT PHARMACY PROGRAM (HPP)

6 PERSONNEL TRAINING

APPENDIX 1: DEFINITIONS AND TERMS

APPENDIX 2: CPG CATEGORIES AND DESIGNATED ITEMS

APPENDIX 3: DISTRIBUTION LIST

APPENDIX 4: REVIEW COMMENTS 2014

Thule Air Base, Greenland 4/17 FY-15

1 LETTER OF INSTRUCTION

1.1 Security and Administrative Instructions

Title

: The title of this document is “Affirmative Procurement Plan”, CDRL CEV-15H. The acronym APP will be used throughout the document.

Classification

: The document is unclassified.

Responsibilities

: Greenland Contractors, Environmental Engineering (GC/EE) is the office of primary responsibility (OPR) for establishing, implementing and maintaining the APP. The instructions given in the APP are applicable to all organizations and tenant units at Thule AB.

Organizations and tenant units are authorized to extract and reproduce those sections of the APP that are essential in the planning and preparation of supporting documents and reports.

Reviews/changes

: The APP will be reviewed and updated annually IAW the CDRL and distributed accordingly. A draft is submitted to 21 CES/CEIE by 1 Nov for review. Review comments, if any, will be provided within 60 days. Review comments received will be incorporated in the final version of the plan within 30 days; thereafter the document will be submitted to 821ABG/CC for signature. The signed plan will then be submitted as the Final edition.

Furthermore, the APP is subject to change if any of the applicable laws, regulations, or require-ments is altered.

Distribution APPENDIX : The APP is distributed to organizations listed in the distribution list ( 3).

Thule Air Base, Greenland 5/17 FY-15

2 GENERAL

2.1 Purpose

The APP establishes guidelines for the affirmative procurement program at Thule AB. The APP includes the acquisition of recycled content products, and environmentally preferable purchasing as one program. The APP contains the necessary guidance for developing an effective installation affirmative procurement program, which are required of all US Air Force installations in CONUS and overseas.

Thule AB is working towards improving pollution prevention strategies by encouraging all activi-ties/units to work together and consider the following factors:

a. Use of recovered materials.

b. Reuse of product.

c. Recyclables.

d. Use of environmentally preferable products.

e. Energy efficiency.

f. Waste prevention (including toxicity reduction or elimination).

2.2 Scope

The purchase and use of products and services can have a profound impact on the environment. Thule AB recognizes the positive impact that it can make on the environment through the purchasing decisions that its employees make. It is the intent of Thule AB to integrate environmental considerations into the aspect of acquisition.

The APP applies to all organizations that are located on Thule AB. The following plan has to be consulted: Pollution Prevention Management Plan, CDRL CEV-15D. Furthermore, the homep-age of Environmental Protection Agency (EPA) for purchasing designated items through US sources is used as a guideline (www.epa.gov/cpg).

2.3 Regulatory Overview

US State Laws: Not applicable

USAF: AFI 32-7080 Pollution Prevention Program AFI 32-7086 Hazardous Materials Management

Thule AB: SOW, Part 1, Chapter 4, para. 4.1 and Chapter 18, para. 8.8 Environmental, Safety, Occupational Health Council (ESOHC)

Host Country: Not applicable http://www.epa.gov/cpg�

Thule Air Base, Greenland 6/17 FY-15

3 ORGANIZATIONAL ROLES AND RESPONSIBILITIES

In order to ensure that materials and products purchased are handled in an environmentally correct manner, it is important that the purchase specialists are fully aware of their responsibilities in the affirmative procurement program. These responsibilities are outlined in the following:

3.1 Installation Commander, 821 ABG/CC

The Installation Commander has the overall responsibility for the management of affirmative procurement at Thule AB. The responsibility is implemented through the base Environmental, Safety, Occupational Health Council (ESOHC), of which the Installation Commander is the chairman.

3.2 Accounting and Finance, 821 ABG/FM

The Accounting and Finance office assists in setting up accounts for fund management.

3.3 Environmental Engineering, GC/EE

Greenland Contractors, Environmental Engineering (GC/EE) is the office of primary responsibility (OPR) for establishing, implementing and maintaining the APP.

• Assist Base Supply at Thule AB in identifying, characterizing and evaluating products and materials.

• Implementing an awareness program to promote affirmative procurement.

• Providing affirmative procurement consultation support to all personnel and organizations involved in the purchasing process.

• Providing recommendations to management personnel across all organizations involved in the purchasing process on the preparation, implementation, and monitoring of the

APP.

• Validation and approval of chemical products used at Thule AB, to ensure less hazardous materials are purchased.

• Identify and document whether green products and services are available and can satisfy local requirements for price, availability, and performance.

• Ensure that affirmative procurement requirements are identified, prior to submission to supply, so that approved purchase requests properly address all relevant affirmative procurement requirements.

3.4 Base Supply, GC/LGS

The requirement of implementing affirmative procurement is applicable where appropriated funds are used and purchase is worth $10,000 of a designated item or purchase $10,000 or more of the item in the previous year. Base Supply is responsible for:

• Providing oversight of contract execution to ensure affirmative procurement requirements are addressed in accordance with the terms of the contract. Along with this: Reviewing procurement requests to ascertain and validate whether green products or services are involved in the procurement action.

Thule Air Base, Greenland 7/17 FY-15

• Providing guidance to procurement request originators and facilitating acquisition planning with respect to green products and services.

• Gathering, sorting, and reporting of procurement data for the purpose of management evaluation of affirmative procurement performance, when such data is maintained in databases operated by procurement organizations.

• Complying with procedures for monitoring and annually reviewing the effectiveness of the

APP.

Thule Air Base, Greenland 8/17 FY-15

4 AFFIRMATIVE PROCUREMENT

4.1 Requirements of affirmative procurement

As a minimum, US Air Force major commands are required to establish procurement programs for all EPA guideline items, and in accordance with RCRA, subtitle F (Section 6002), and EO#12873. Each activity will review and revise specifications for the designated items to allow procurement of products containing recovered materials. While each procurement agency may design its own program, so long as it meets the requirements of RCRA, all affirmative procurement programs must have the following four elements:

1. A preference program.

2. A promotion plan.

3. Procedures for obtaining and verifying estimates, and certifications of the content of recovered materials.

4. Annual review and monitoring.

4.2 Preference program and exceptions

Each acquiring activity and procurement activity will make it a practice, when purchasing any of the items listed in APPENDIX 2, to show a preference for items with recovered material content.

There are three options to consider when purchasing these items:

Preference program:

a. Minimum-content standards: Identify the minimum content of recovered materials that an item should contain; these standards are located in Comprehensive Procurement Guidelines (CPG) and the Recovered Materials Advisory Notices (RMAN).

b. Case-by-case procurement: Open competition between products made of virgin materials and products made of recovered materials; procuring agencies or individuals must exercise a preference for the latter.

c. Other: Any approach which is substantially equivalent to the above approaches.

1. The price of items with recovered material is unreasonable.

Exceptions:

2. The requirement for items produced with recovered materials results in inadequate competition.

3. Obtaining items with recovered material results in unusual and unreasonable delays.

4. Items produced with recovered materials do not meet all reasonable performance specifications.

Purchase of Environmental Protection Agency (EPA) designated items (www.epa.gov/cpg) through US sources complies with the Thule AB Affirmative Procurement Plan. Exceptions are justified and documented. The requirement does not apply to non-appropriated fund purchases that, if any, will be separately identified.

GC Environmental Engineering evaluates selected purchasing orders from Base Supply and other shops for annual review and monitoring.

http://www.epa.gov/cpg/index.htm� http://www.epa.gov/cpg/index.htm�

Thule Air Base, Greenland 9/17 FY-15

4.3 Comprehensive Procurement Guidelines (CPG)

Federal Register “Final Rules” Comprehensive Procurement Guidelines (CPG)

The CPG is the document the EPA uses to formally designate the items covered by the APP. As a result the designated items are known as “guideline items”. The process begins as the EPA reviews a broad list of potential products made from recovered materials. They consider the availability of the item, the potential impact on the solid waste stream, the economic and technical feasibility of producing the item, and other uses of the recovered materials used to produce the item.

The EPA also considers comments from end users, manufacturers, distributors, the general public, and other interested parties through a formal rulemaking process to designate items. The list of guideline items is complete when EPA publishes it as a Final Rule in the Federal Register

(APPENDIX 2).

Thule Air Base, Greenland 10/17 FY-15

5 HAZMAT PHARMACY PROGRAM (HPP)

The HPP provides for process-based authorizing, procuring, issuing, tracking, and disposing of Hazardous Materials (HAZMAT). It is a repository for data required to meet reporting require-ments, assess processes for pollution prevention opportunities, and measure success in mini-mizing HAZMAT use.

The program ensures HAZMAT users obtain the material required to perform their mission.

However, until the appropriate Environment, Safety and Occupational Health (ESOH) precau-tions are understood and in place, HAZMAT is not issued to users. This means personnel must have received proper training and/or are aware of the potential safety hazards of the product.

Furthermore, the program ensures that only the smallest quantities of HAZMAT necessary to accomplish the mission, consistent with the “Pharmacy” concept of operations, are purchased and used. This will be accomplished by eliminating HAZMAT usage not essential to mission ac-complishment, substituting reduced-risk HAZMAT whenever possible, and minimizing HAZMAT usage when the mission dictates their use. Decision making on minimization and substitution should take into account reducing overall ESOH.

During 2011 the EESOH-MIS (Enterprise Environmental, Safety and Occupational Health - Management Information System) software has been implemented at Thule AB and is used as a computerized tracking tool (database) designed to track hazardous materials from the time of purchase and arrival on base till the material has been consumed or disposed of (Cradle to Grave).

Thule Air Base, Greenland 11/17 FY-15

6 PERSONNEL TRAINING

The Affirmative Procurement Training (APT) is recommended for personnel that purchase materials and products.

GC Environmental Engineering can provide training in Affirmative Procurement and Chemical Hazard Communication.

AP training shall be incorporated into the general environmental awareness training. APT shall focus on procurement personnel. APT shall include, but not be limited to:

• Descriptions of products covered by CPG.

• How to identify if a product meets CPG standards.

• Where to find information on AP, CPG, and RMAN.

• How to order products meeting CPG standards.

Newly assigned personnel should be provided the training before starting the job; otherwise they must work under the direct supervision of a trained employee.

Training records for personnel involved in the affirmative procurement procedure must be kept on file by the organizations/departments, to which the employee in question is assigned, and retained for 3 years after termination. Records must identify the employee's position and responsibility in affirmative procurement, as well as the date when the training was received.

Thule Air Base, Greenland 12/17 FY-15

APPENDICES

Thule Air Base, Greenland 13/17 FY-15

APPENDIX 1: DEFINITIONS AND TERMS

Affirmative Procurement Program RCRA Section 6002 requires each procuring agency to establish an affirmative procurement program for maximizing its purchases of EPA-designated items. The program should be developed in a manner that ensures items composed of recovered materials are purchased to the maximum extent practicable consistent with Federal procurement law.

CPG

Through the Comprehensive Procurement Guideline (CPG), EPA designates items that must contain recycled content when purchased by federal, state, and local agencies, or by government contractors using appropriated federal funds. Under E.O. 13101 EPA is required to update the CPG every 2 years.

Designated Products Products that are or can be made from recovered materials that have been designated in the CPG through EPA's formal rulemaking process. Also referred to as "designated items".

Materials in Solid Waste Materials found in the various components of the solid waste stream. Generally, solid waste has several components, such as municipal solid waste (MSW), construction and demolition debris (C&D), and no hazardous industrial waste. Under RCRA Section 6002, EPA considers materials recovered from any component of the solid waste stream when designating items containing recovered materials.

Post consumer Materials A material or finished product that has served its intended use and has been diverted or recovered from waste destined for disposal, having completed its life as a consumer item. Post consumer materials are part of the broader category of recovered materials.

Pre-consumer Materials Materials generated in manufacturing and converting processes, such as manufacturing scrap and trimmings/cuttings.

Procuring Agency Any Federal agency or any state agency, or agency of a political subdivision of a state that is using appropriated Federal funds for procurement.

RCRA Section 6002 Section 6002 of the Resource Conservation and Recovery Act (RCRA) of 1976, as amended, directs EPA to designate items that are or can be produced with recovered materials and to recommend practices for buying these items. Among other things, RCRA Section 6002 also provides criteria for EPA to consider when selecting items for designation, and requires procuring agencies to establish affirmative procurement programs for designated items.

Recovered Materials Waste materials and byproducts that have been recovered or diverted from solid waste, but do not include materials and byproducts generated from, and commonly reused within, an original manufacturing process.

http://www.epa.gov/cpg/#sec6002� http://www.epa.gov/cpg/#recovered� http://www.epa.gov/cpg/#executive2� http://www.epa.gov/cpg/#recovered� http://www.epa.gov/cpg/#sec6002� http://www.epa.gov/cpg/#recovered� http://www.epa.gov/cpg/#recovered� http://www.epa.gov/cpg/#app�

Thule Air Base, Greenland 14/17 FY-15

RMAN

Recovered Materials Advisory Notices (RMANs) provide purchasing guidance and recommend recovered and post consumer material content levels for designated items. RMAN recommenda-tions are guidance and therefore are not codified in the Code of Federal Regulations.

Thule Air Base, Greenland 15/17 FY-15

APPENDIX 2: CPG CATEGORIES AND DESIGNATED ITEMS

Effective 2007, the CPG V covered a total of 65 items in eight product categories:

Paper and Paper Products Park and Recreation Products Printing and Writing Papers Park Benches and Picnic Tables Newsprint Plastic Fencing Commercial/Industrial Sanitary Tissue Playground Equipment Paperboard and Packaging Playground Surfaces Miscellaneous Paper Products Running Tracks Vehicular Products Landscaping Products Engine Coolants Compost Made From Recovered Organic

Materials Rebuilt Vehicular Parts Fertilizer Made From Recovered Organic Ma-terials Re-refined Lubricating Oils Garden and Soaker Hoses Retread Tires Hydraulic Mulch Construction Products Lawn and Garden Edging Building Insulation Products Plastic Lumber Landscaping Timbers and

Posts Carpet Cushion Nonpaper Office Products Cement and Concrete Containing Coal Fly Ash, Ground Granulated Blast Furnace Slag, Cenospheres, or Silica Fume

Binders (plastic covered, chipboard, and pressboard)

Consolidated and Reprocessed Latex Paint Office Furniture Floor Tiles Office Recycling Containers Flowable Fill Office Waste Receptacles Laminated Paperboard Plastic Binders Modular Threshold Ramps Plastic Clipboards Nonpressure Pipe Plastic Clip Portfolios Patio Blocks Plastic Desktop Accessories Polyester Carpet Plastic Envelopes Railroad Grade Crossing Surfaces Plastic File Folders Roofing Materials Plastic Presentation Folders Shower and Restroom Dividers and Partitions Plastic Trash Bags Structural Fiberboard Printer Ribbons Transportation Products Toner Cartridges Channelizers Miscellaneous Products Delineators Awards and Plaques Flexible Delineators Bike Racks Parking Stops Blasting Grit Traffic Barricades Industrial Drums Traffic Cones Manual-grade Strapping Mats Pallets Signage Sorbents

Thule Air Base, Greenland 16/17 FY-15

APPENDIX 3: DISTRIBUTION LIST

The document is distributed as PDF-format via email IAW the CDRL Distribution List.

21st Space Wing

21 CES/CEIE

Donald.Chase@us.af.mil

21 SW/PMD 21sw.pmd.thule@us.af.mil

821st Air Base Group

821 ABG/CC

821SPTS.cc.wf@us.af.mil

821st Support Squadron

821 SPTS/CE

821SPTSCEDISTRO@us.af.mil

Greenland Contractors, Thule AB All GC organizations on GC LAN

GC Intranet mailto:Donald.Chase@us.af.mil� mailto:Donald.Chase@us.af.mil� mailto:21sw.pmd.thule@peterson.af.mil� mailto:821SPTS.cc.wf@peterson.af.mil� mailto:821SPTSCEDISTRO@us.af.mil�

Thule Air Base, Greenland 17/17 FY-15

APPENDIX 4: REVIEW COMMENTS 2014

GC Reply

Comment no. 1: There are differences between Affirmative and Green procurement (e.g. the exemption for $10,000 and less only applies to Affirmative Procurement). While GC recognizes the review comment, the Base Maintenance Contract continues to use verbiage “An Affirmative procurement program is implemented for US purchases” (Part I, Section 18.8.8). If the government wishes to update this deliverable to include the requirements of Green Procurement, a Document Change Request (DCR) to the maintenance contract must be submitted and negotiated.