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Introduction The majority of hazardous materials (HAZMAT) used on Air Force installations are associated with maintaining weapon systems and their associated support components. Operational needs, flight safety considerations, high purchase/replacement costs, and other factors demand high performance criteria for the products/materials used to maintain these systems. For this reason, very rigid controls are placed on what products/materials can and cannot be used on these systems. Before any potential alternative products are used on a weapon system they must first be evaluated and approved by the weapon system's Single Manager (SM). These individuals have engineering control over, and are responsible for modifying and maintaining Air Force products and systems. Once the SM is satisfied with the performance capabilities of an alternative product, its use is allowed through updates to the Technical Orders (T.O.s) and specifications that govern how the weapon system is maintained. As discussed in PRO-ACT's "Product Substitution" Fact Sheet, November 1998, the Air Force has recognized that T.O.s and specifications need to be updated so as to eliminate the use of products/materials that pose a serious risk to people and the environment. The Air Force Weapon System Hazardous Materials Reduction Prioritization Process (HMRPP) was initiated specifically to link Major Commands (MAJCOMs), installations, and SMs in an integrated process designed to reduce the service's reliance on HAZMATs for weapon system maintenance and support. The purpose of this fact sheet is to build upon the information provided in the "Product Substitution" Fact Sheet by providing a more detailed outline of the elements of the HMRPP and the organizations and people involved. It also explains the supporting "needs" collection activities of the 311th Human Systems Wing's Environmental Planning Directorate (311 HSW/XRE), and the roles played by the Installation HAZMAT Pharmacy Program (HPP), the various Hazardous Material Management Process (HMMP) Teams, and others who work together to identify, manage, track, and minimize the use of HAZMATs in Air Force weapon systems. Important Terms [From draft AFI 32-7080, Compliance Assurance and Pollution Prevention] Hazardous Material (HAZMAT) - Any item or class of items referenced in Federal Standard 313D, paragraph 3.2, and all Class I and Class II ozone depleting substances, including:
Life Cycle - A series of stages or processes through which a system, product, or entity passes from inception to termination and disposal. It includes conception, design, development, testing, production, deployment, training, maintenance, supply management, distribution, and disposal/demilitarization. Life Cycle Analysis - The comprehensive examination of the environmental and economic effects of a product or process throughout its lifetime including new material extraction, transportation, manufacturing, operations, and ultimate disposal. Life Cycle Cost - Total cost to the government for a program (e.g. weapon system) over its full life, including research and development, support equipment, initial inventories, training, data, facilities, and other investments. Life Cycle Costs may also include the costs associated with the operation, support, and demilitarization/detoxification of long-term waste storage activities. Single Manager (SM) - The Air Force acquisition program manager, or "Single Manager" is defined in Department of Defense Directive 5000.1, Defense Acquisition. SMs are responsible for all aspects of planning, development, sustainment, and evolution of the systems (e.g. weapon system) or products their program offices acquire and support. Program management directives identify the SMs and funding sources and amounts for individual programs. SMs do not advocate for funding as this is the responsibility of the major commands (MAJCOMs) that employ the systems or products. These MAJCOMs also define the cost, schedule, and performance requirements that the SMs must meet. Weapon System Hazardous Material Reduction Prioritization Process (HMRPP) - A requirements communication process for installations to identify weapon system-driven hazardous material (HAZMAT) reduction needs. This enables MAJCOM and installation priorities to drive weapon system HAZMAT reduction efforts. The weapon system HMRPP is not a separate requirements process. Rather, it integrates HAZMAT reduction requirements into the existing weapon system requirements, identification, prioritization, funding, and execution processes. Regulatory Drivers Listed below are the multitude of drivers for the HMRPP at the Federal, Department of Defense (DoD), and Air Force levels. Some of these drivers, such as DoD Directive 5000.1 and the "Air Force Pollution Prevention Strategy" policy letter, provide broad guidance on the need to eliminate hazardous materials from weapon systems. Other drivers, such as Air Force Instruction (AFI) 32-7086 and AFI 63-118, provide general responsibilities and procedures for implementing the HMRPP. In addition, MAJCOMs and individual installations may have supplements to some of these drivers that contain detailed instructions for completing the HMRPP. Participants in the HMRPP, and those with an interest in reducing HAZMAT usage at their installation, are encouraged to review these documents, copies of which are available from PRO-ACT.
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In May 1995, representatives from the HQ USAF Weapon System Environment, Safety and Health (ESH) Integrated Product Team (IPT), the HQ AFMC Pollution Prevention (P2) IPT, other MAJCOMs, and Single Managers met in a working group to discuss and resolve disconnects in the identification, prioritization and reporting of Air Force Weapon System P2 efforts. This working group observed that the Air Force had pursued weapon system HAZMAT reduction and other weapon system P2 requirements outside of the existing weapon system requirements identification, prioritization, funding and execution processes, and concluded that this was the primary cause of the disconnects in Weapon System P2. The group developed the Weapon System Hazardous Material Reduction Prioritization Process (HMRPP) as a roadmap to integrate weapon system HAZMAT reduction requirements into the normal processes used for other weapon system requirements. In September 1995, the HQ USAF Environmental Protection Committee formally approved the HMRPP initiative. In August 1997, with the publication of AFI 32-7086, HQ USAF included the HMRPP as a key element of the Air Force Hazardous Materials Management Process.
It is important to understand that the HMRPP is not a separate requirements process. Rather, it is a thought process, a road map, that integrates HAZMAT reduction requirements into the existing weapon system requirements, identification, prioritization, funding and execution processes. To do this, the HMRPP seeks to establish formalized working relationships and a communication network between personnel and organizations. It is necessary at the installation and MAJCOM levels that the HMMP team work together to gather process-specific data on HAZMATs targeted for reduction, and develop prioritized HAZMAT weapon system reduction needs based on the costs and risks associated with HAZMAT use. In addition, the HMRPP establishes a clearer link between the MAJCOM HMMP team and the SM community to elevate specific MAJCOM HAZMAT reduction needs with the appropriate SM that can provide potential engineering and technical solutions. Finally, the HMRPP provides the link for the MAJCOM HMMP team to work with MAJCOM weapon system requirements and budget offices to obtain the funding to implement selected alternatives by inserting approved HAZMAT reduction requirements into the MAJCOM's weapon system planning, programming and budgeting system (PPBS) process. Once in the weapon system requirements process, the cost and risk data - developed earlier at the installation level and refined at the MAJCOM level - become key to making weapon system HAZMAT reduction needs competitive with the MAJCOM's other weapon system requirements.
The HMRPP process is organized to involve several organizations that evaluate a variety of process-specific data. The process, including the roles played by all involved Air Force organizations, is described in detail in AFI 32-7086. The major procedural components of the HMRPP are listed below and graphically represented in Figure 1.
Identification of Candidate Processes. The installation HMMP team starts the HMRPP by identifying the individual weapon system process or processes that are driving HAZMAT concerns at the installation. In the HMRPP, it is important that the installation HMMP team identify the specific processes, as defined by specific T.O. references or other SM-controlled technical data, because the technical and engineering solutions that SMs provide are, by necessity, process-specific. Therefore, all data that is collected through the HMRPP to identify and support a requested change must be process-specific.
AFI 32-7086 does not mandate any method for targeting a particular HAZMAT for reduction or elimination. Instead, installation HMMP teams should identify candidate weapon system-driven HAZMAT use for reduction or elimination based on local conditions and priorities or MAJCOM guidance. For example, perhaps a recent compliance site survey has identified a particularly high compliance burden associated with weapon system HAZMAT usage at a particular location. Maybe instead the installation wants to reduce a particular HAZMAT's release below the TRI reporting threshold. Or possibly the MAJCOM HMMP team has directed installations to focus on the top five HAZMATs measured by quantity used. Any of these methods, or others, are acceptable for targeting a HAZMAT for elimination or reduction. In the absence of MAJCOM guidance, installation HMMP teams may select as many or as few weapon system-driven HAZMATs for potential elimination or reduction as they deem necessary. However, installation HMMP teams should balance their desire to eliminate weapon system HAZMAT usage against the effort required to collect the necessary process-specific supporting data. The completeness and quality of the supporting data are critical to justify funding and to implement alternatives.
In some cases, the installation HMMP team will have in mind a specific weapon system "candidate process" that is causing concern at the installation. More often, the team will have a single HAZMAT or set of HAZMATs used on weapon systems that it wants to target for reduction. Therefore, the team will have to work with the installation HAZMART to identify the individual weapon system T.O. processes driving the HAZMAT use. Most Air Force hazardous materials tracking systems capture the T.O. process information that is collected as a part of the AF Form 3952 Hazardous Material Authorization process. The HAZMART can provide the HMMP team with a report of the T.O. processes driving a particular HAZMAT's use, as well as associated information like the quantities issued and the locations of shops that use the HAZMAT. The HMMP team can use this report to identify the "candidate process or processes" that will best contribute to their HAZMAT reduction objectives.
Collection of Supporting Data. In subsequent HMRPP steps, the MAJCOM HMMP team, working with MAJCOM weapon system requirements and budget offices, will prioritize candidate processes - and later decide whether to advocate for the funding of a selected solution - based primarily on the potential cost savings and risk mitigation that would result from the HAZMAT reduction effort. Ultimately, selected candidate processes will have to compete for funding with other weapon system requirements in the MAJCOM and Air Force Planning, Programming and Budgeting System (PPBS). Because all of the data concerning the costs and risks of a candidate process's HAZMAT use resides at the base-level, the installation HMMP team must forward each candidate process with all the process-specific supporting data necessary to justify MAJCOM and Air Force funding of the elimination or reduction efforts. The supporting data should represent the installation HMMP team's estimates of annual usage and associated annual costs by specific process, and contain a brief narrative describing any risks associated with the candidate process that the team cannot quantify (e.g., regulatory problems that impact operations or exposure hazards that impact worker health and productivity). The cross-functional composition of the installation HMMP team makes it well suited to access and analyze the available information to develop the supporting data for candidate processes. As a minimum, the process specific supporting data should include estimates of the following:
Submittal of Supporting Data to Single Managers (SMs). The MAJCOM HMMP Team submits the consolidated prioritized data to the HQ AFMC HMMP Team. Using the supporting data, the HQ AFMC HMMP team will forward specific candidate processes, with the supporting data package, to the appropriate SM. The HQ AFMC HMMP Team also provides feedback to the appropriate MAJCOM HMMP Team. In this manner, the HQ AFMC HMMP Team acts as a communication link between the SM community and the MAJCOM HMMP Teams. It also tracks SM progress on addressing candidate process requests. AFMC regularly performs these kinds of functions for MAJCOMs and SMs for other weapon system change requirements.
Evaluation of Candidate Processes and Supporting Data. The SM that controls the candidate process evaluates alternatives, proposes solutions, and identifies costs. First, the SM identifies alternative materials, equipment, or procedures that can reduce or eliminate the HAZMAT use in the candidate process. For each proposed alternative solution, the SM estimates the modification costs, life-cycle costs (LCC), the implementation schedule, and any performance impacts or enhancements. Using the current projected end-date for the candidate process and the supporting data supplied by the MAJCOM HMMP team, the SM also calculates the LCC of the existing HAZMAT usage associated with the candidate process. This "no-action" LCC will provide a baseline against which the MAJCOM can compare the costs of reducing or eliminating HAZMAT usage. Finally, the SM evaluates the ESOH risks and costs associated with each alternative, ensuring that no proposed alternative creates ESOH risks and costs that exceed the "no action" situation. Then, the SM provides a prioritized package of proposed alternatives, including all LCC cost comparisons, directly to the MAJCOM HMMP team.
In some cases, candidate processes may require additional technology development before they can be fully evaluated, funded, and successfully incorporated into the weapon system. These technology development "needs" are identified by the SMs and submitted, back down through the HQ AFMC HMMP Team, to the USAF Environment, Safety, and Occupational Health (ESOH) Technical Planning Integrated Product Team (TPIPT) for inclusion on their Technology Needs Survey (TNS), which is discussed in greater detail below. When engineering solutions for technology development needs are found to exist, SMs will inform the ESOH TPIPT so the need can be withdrawn.
Selection of Processes for Funding. Upon receipt of the weapon system solutions/modifications prioritized by the SMs, the MAJCOM HMMP Team selects which alternatives, if any, to pursue. This selection process is fiscally constrained because selected candidate process alternatives must compete with other MAJCOM weapon system requirements for scarce MAJCOM resources. Therefore, most often the MAJCOM HMMP team will use the cost comparison data supplied by the SM to select alternatives with the greatest return-on-investment potential. For those process changes the MAJCOM HMMP team decides to pursue, the HMMP team works with their respective MAJCOM requirements and budget offices to include the selected alternative in the MAJCOM's weapon system Program Objective Memorandum (POM) and to advocate for funding. At this point, the selected alternative is a part of the normal weapon system PPBS, and MAJCOM HMMP teams should work with the HQ USAF HMMP team to ensure the selected alternative receives further advocacy and support through the HQ USAF corporate board review. Under certain circumstances, MAJCOM HMMP teams may pursue a combination of sources to fund candidate process alternatives as stand-alone projects.
Although many candidate processes may go unfunded as stand-alone projects, this does not diminish the importance of their identification, validation, and advocacy through the HMRPP. Once validated through the HMRPP, the SM can incorporate candidate processes into future system modification efforts at little or no cost to the MAJCOM or the program. Failure to identify, validate, and advocate for HAZMAT reduction requirements through the HMRPP can and has already resulted in missed opportunities to incorporate needed HAZMAT reductions into modification programs.
For a new need to be formally submitted through the ESOH TPIPT process, all of the 20 questions contained in the FY98 ESOH TNS Questionnaire must be answered. Points-of-contact (POCs) from 311 HSW/XRE TNS are available to assist submitters and may be contacted at DSN 240-2129/3455. The questionnaire can be accessed by entering a user name and password at the WWW site: http://xre22.brooks.af.mil/hscxre/98Survey/TNSINTRO.htm. The ESOH TPIPT FY98 TNS Plan is available from PRO-ACT or at http://xre22.brooks.af.mil/hscxre/98Survey/98tns.htm.
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