HAZMAT Reduction Programs
In an effort to reduce the national aggregate release of certain toxic chemicals into the environment, the United States Environmental Protection Agency (EPA) launched its voluntary 33/50 Program in January 1991. Seventeen high-priority toxic chemicals were selected from the existing Toxic Release Inventory. (The TRI is a list of chemicals established in 1988 by the EPA. Releases of TRI chemicals are reported annually to EPA by industrial facilities under the Emergency Planning and Com-munity Right-to-Know Act, or EPCRA.) These 17 chemicals, commonly referred to as EPA-17 chemicals, were selected for reduction based upon their toxicity, high volume production/emission, and high potential for successful reduction through pollution prevention initiatives.

As reflected in its name, the 33/50 Program established an interim goal to achieve a 33% reduction in releases and off-site transfers of EPA-17 chemicals by the end of 1992 (from a 1988 base-line), and a final goal to achieve a 50% reduction by the end of 1995, at which time the 33/50 Program would end.

EPA-17 Chemicals
Benzene Cadmium & Compounds Carbon Tetrachloride Chloroform Chromium & Compounds Cyanides Methylene Chloride Lead & Compounds Mercury & Compounds Methyl Ethyl Ketone Methyl Isobutyl Ketone Nickel & Compounds Tetrachloroethylene Toluene 1,1,1-Trichloroethane Trichloroethylene Xylenes

Although not an official participant, the Air Force made a commitment to the spirit of EPA's 33/50 Program with the publication of the Joint Secretary of the Air Force/Air Force Chief of Staff "Air Force Pollution Prevention Program - Action Memorandum" and attached "Pollution Prevention (P2) Program Action Plan" in January 1993. Among the Plan's objectives were directives for all Major Commands (MAJCOMs) to: 1) reduce the use of HAZMATs in all phases of new weapon systems; 2) integrate fewer HAZMATs into new and existing weapon system T.O.s, MILSPECs, and Military Standards (MILSTDs); 3) accelerate replacement of HAZMATs in Air Logistics Center industrial processes; and 4) reduce purchases of EPA-17 chemicals 50% (from a 1992 baseline) by the end of 1996.

An overarching policy for hazardous material reduction and pollution prevention was first outlined in Air Force Policy Directive (AFPD) 32-70, "Environmental Quality," 20 July 1994, which states "...the Air Force will prevent future pollution by reducing use of hazardous materials and releases of pollutants into the environment to as near zero as possible.through source reduction, e.g. chemical substitution, process change and other techniques." Requirements for the Pollution Prevention Program set forth in AFPD 32-70 can be found in Air Force Instruction (AFI) 32-7080, "Pollution Prevention Program," 12 May 1994. This AFI outlines guidance and procedures and provides a framework for MAJCOMs and installations to ensure compliance with pollution prevention standards. The January 1993 Joint Secretary of the Air Force/Air Force Chief of Staff Action Memorandum was updated with a new Joint Memorandum, "Air Force Pollution Prevention Strategy," issued on 24 July 1995. This Air Force Strategy promotes the minimization of HAZMAT use and releases by encouraging broad institutional changes in awareness/education, processes/systems design, and policy/procedure development. In 1996, the Department of Defense (DoD) published a new Pollution Prevention Instruction (DODI 4715.4). This instruction contains policy for implementation of pollution prevention programs throughout the DoD, namely to ensure that installations comply with applicable environmental laws, regulations, Executive Orders, and standards. Similar to the strategy contained in the July 1995 Joint Air Force Memorandum, DODI 4715.4 sets a broad policy to reduce the use of HAZMATs, reduce the generation/release of pollutants, and reduce any adverse effects on human health and the environment caused by DoD activities.

Finally, the Air Force issued AFI 32-7086 "Hazardous Materials Management" on 1 August 1997. This AFI, which further implements the above-mentioned AFPD 32-70, establishes new procedures and standards that are revolutionizing the management of HAZMATs throughout the Air Force. Included in this AFI are chapters on the HAZMAT Pharmacy, Ozone Depleting Substance (ODS) Management, and the Hazardous Materials Management Process (HMMP).

The HMMP provides for the identification, management, tracking, and minimization of hazardous materials. It consists of three main, interrelated components: the installation HAZMAT Pharmacy Program (HPP), the weapon system HAZMAT Reduction Prioritization Process (HMRPP), and the ODS Management Program. The AFI defines HAZMAT to include both Class I and Class II ODSs; however, it excludes hazardous wastes, munitions, and pharmaceuticals. An important aspect of the AFI is that it identifies cross-functional cooperation as the key to effective HAZMAT management and establishes formal cross functional HMMP teams at all levels of command in the Air Force. To ensure senior leadership visibility and support, these HMMP teams report directly to the chairperson of the Environment, Safety and Occupational Health Committee (ESOHC) or Environmental Protection Committee (EPC), typically the installation Vice-Commander.

The HMRPP links installation HAZMAT reduction needs with the weapon system operations and maintenance processes and the single managers that drive most of the hazardous material usage at Air Force installations. This linkage is critical because installations have the information necessary to be able to identify weapon system HAZMAT usage requirements that are creating unacceptable environment, safety, and occupational health (ESOH) compliance problems and costs at the base level. Conversely, single managers have the authority to change the weapon system technical documents that contain the HAZMAT usage requirements. Single managers must ensure that any change to a documented weapon system operations or maintenance process does not compromise mission capability or increase ESOH risks and costs.

ODS Reduction Programs
National and international scientific consensus exists in support of controlling, reducing, and/or eliminating the release of certain manufactured halogenated hydrocarbons that may contribute to the depletion of the Earth's stratospheric ozone layer. The stratospheric ozone layer protects the Earth from harmful ultraviolet (UV-B) radiation. The United Nations Environmental Program (UNEP) began negotiations to develop multilateral policies to protect the ozone layer in September 1987. Delegates from 43 nations signed the Montreal Protocol on Substances that Deplete the Ozone Layer, which was the first international treaty to address reducing the production and consumption of ozone depleting substances. The ultimate goal of the Protocol was to eliminate, with limited exceptions, the global use of ODSs in accordance with an agreed-upon phase-out schedule.

To implement and comply with the Protocol in the United States, as well as to enact certain sections of the Clean Air Act Amendments of 1990, the EPA published Subpart A, "Production and Consumption Controls," to Title 40 Code of Federal Regulations (CFR) Part 82, "Protection of Stratospheric Ozone." Subpart A imposes limits, according to specified schedules, on the production, consumption, and release of Class I and Class II ODSs and applies to any person that produces, transforms, destroys, imports, or exports certain ODSs. In October 1993, the EPA added Subpart D, "Federal Procurement," to Title 40 CFR Part 82. Subpart D requires Federal agencies to adopt procurement regulations which conform to the policies and requirements of Title VI of the Clean Air Act and which maximize the substitution in Federal procurement of safe alternatives for Class I and Class II ODSs.

Subpart G, "Significant New Alternatives Policy (SNAP) Program," was added to Title 40 CFR Part 82 in March 1994 and implements Section 612 of the Clean Air Act. The objectives of the SNAP Program are to identify substitutes for Class I and Class II ODSs, evaluate the acceptability of those substitutes, promote the use of substitutes presenting lower overall risks to human health and the environment, and prohibit the use of substitutes found to increase overall risks.

On 21 April 1993, the President signed Executive Order (EO) 12843, "Procurement Requirements and Policies for Federal Agencies for Ozone Depleting Substances." This EO requires Federal agencies, including the military services, to provide leadership in the phase-out of ODSs through compliance with the Montreal Protocol and to "reduce procurement and use of substances that cause stratospheric ozone depletion."

The previously mentioned January 1993 Joint Secretary of the Air Force/Air Force Chief of Staff Action Memorandum was published in anticipation of EO 12843. In addition to the HAZMAT guidance discussed above, this Memorandum imposed specific ODS purchase restrictions on the Air Force, with effective dates in 1993 and 1994. Certain applications deemed "mission critical" could continue to use Class I ODSs (obtained from a defense reserve supply established and maintained by the Defense Logistics Agency) if a waiver for the application had been approved by an Air Force Senior Acquisition Official (SAO). The Memorandum further outlined Air Force policy for minimizing the use of ODSs in the maintenance, disposal, design and acquisition of equipment.

As mentioned above, AFI 32-7080 requires MAJCOMs to execute Pollution Prevention Management Plans containing strategies for seven program elements, one of which is "Ozone Depleting Chemicals." AFI 32-7080 requires all MAJCOMs to: 1) prohibit the purchase of all Class I ODSs; 2) prohibit the purchase of halon fire extinguishing equipment and ODS air conditioning and refrigeration equipment for ground applications; 3) modify practices and implement conservation measures to reduce atmospheric discharge of ODSs; and 4) prioritize ODS use based on mission impact and act to convert such systems to non-ozone depleting chemicals.

Chapter 4 of AFI 32-7086 establishes the Air Force ODS Management Program, which is designed to mitigate risks to Air Force capability and reduce costs associated with continued reliance on ODSs. The objectives of the ODS Management Program include: 1) eliminating ODS usage wherever economically and technically feasible; 2) managing the allocation of mission critical Air Force supplies of Class I ODS; and 3) minimizing the release of ODSs into the environment. The program covers both facility and weapon system Class I and II ODS requirements. The AFI states that existing facility equipment that uses Class I ODSs can continue to rely on the Class I ODS until the facility equipment reaches the end of its economic life, then it must be replaced with equipment that does not use a Class I ODS. Additionally, AFI 32-7086 prohibits new facility equipment from requiring the use of a Class I ODS.

The AFI only requires existing weapon systems to eliminate Class I ODS requirements when a technically and economically feasible substitute is available. The Air Force's Defense Reserve stockpile of Class I ODSs enables weapon system single managers to make business-based decisions that do not increase the ESOH risks and costs when considering conversion to non-ODS systems and processes. Thus, single managers and the Major Commands (MAJCOMs) that use the weapon system may decide to continue to rely upon Defense Reserve supplies of a Class I ODS rather than funding the sometimes significant cost of implementing a non-ODS alternative. This business-based decision process does not apply to new weapon systems. They are prohibited by the AFI from including requirements for Class I ODS usage in their operations and maintenance. AFI 32-7086 also defines the Air Force Senior Acquisition Official (SAO) approval process. This process requires that an Air Force SAO approve any requirement in a contract for the use of a Class I ODS, as well as all allocations of Class I ODSs from the Defense Reserve to MAJCOMs and single managers. Air Force SAO approving officials are restricted to only those general officers or civilian equivalents in HQ USAF/ILE (Civil Engineering), HQ USAF/ILM (Maintenance), and SAF/AQR (Science, Technology, and Engineering). All requests for SAO approvals must first be processed through SAF/AQRE.

In addition to the restrictions placed on the purchase and use of Class I ODSs, AFI 32-7086 also establishes new restrictions on Air Force usage of Class II ODSs. New facility equipment and weapon systems whose projected lives extend beyond the year 2020 may not include any requirements for Class II ODS usage in their operations or maintenance. MAJCOMs and single managers are also tasked with eliminating existing requirements for Class II ODSs before production phase outs occur since the Air Force does not intend to stockpile Class II ODSs. Most Class II ODS production will phase out incrementally between 2004 and 2030; however, because of its high Ozone Depleting Potential, production of the solvent HCFC-141b will be phased out by 1 January 2003.

Other Drivers
The need to find acceptable product substitutions may also be driven by the requirements of other Federal mandates. For example, an installation may want to reduce the use of a particular chemical in order to avoid reporting requirements under EPCRA or Section 102(a) of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). Eliminating the need to obtain a National Pollutant Discharge Elimination System (NPDES) permit as required under the Clean Water Act (CWA) may also be a driver for reducing use of a specific chemical.

Additional drivers for product substitutions may come from provisions of the Clean Air Act. In response to EPA's National Ambient Air Quality Standards in Title 40 CFR Part 50 as required by Section 109 of the Clean Air Act, various federal, state, and local governments have established regulations to control emissions of volatile organic compounds (VOCs), which contribute to the formation of ground-level ozone. Section 112 of the Clean Air Act requires the EPA to develop National Emission Standards for Hazardous Air Pollutants (NESHAPs) to regulate hazardous air pollutant emissions from certain source categories, including the aerospace industry. Emission requirements for the aerospace industry can be found in Title 40 CFR Part 63, Subpart GG, "National Emission Standards for Aerospace Manufacturing and Rework Facilities." By reducing HAZMAT usage, the overall impact of these other drivers may be reduced or eliminated.

MAJCOMs may also develop specific initiatives that establish HAZMAT and/or ODS reduction goals over and above those set by existing Federal and Air Force requirements. In addition, States and local governments may establish similar policies and initiatives that apply to particular communities or geographic regions. It is important that each installation's environmental management staff consult with MAJCOM and State/local agencies to ensure compliance with all applicable regulations requiring reductions in HAZMAT and ODS use. Installations can also obtain assistance from an AFCEE Regional Environmental Office (REO).