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Introduction Under Air Force Instruction 327086, "Hazardous Material Management," the Air Force has established roles, responsibilities, and requirements for a hazardous material management program (HMMP). The purpose of the HMMP is to manage the procurement and use of hazardous material (HAZMAT) to support Air Force missions, ensure the safety and health of personnel and surrounding communities, and minimize Air Force dependence on HAZMAT. The HMMP includes the activities and infrastructure required for ongoing identification, management, tracking, and minimization of HAZMAT. An integral part of the HMMP is the HAZMAT Pharmacy Program (HPP). The HPP is the single point of control and accountability over the requisitioning, receipt, distribution, issue and reissue of hazardous materials. The objectives of the HPP are to:
Background Air Force bases historically had difficulty in achieving control over the acquisition and disposal of hazardous materials. Contributing to this problem was the presence of multiple independent procurement vehicles through which base organizations could acquire hazardous materials. As many as six to ten such vehicles were sometimes present. Base organizations ordered the same material through different channels. There were often no controls over the placement of requisitions, and no means to consolidate records of hazardous material acquisition across all procurement vehicles. Quantities of hazardous materials entering bases were difficult to determine, and accountability for the issue and use or disposal of these materials could not be established. These problems, coupled with the need to comply with increasingly stringent Environmental Protection Agency (EPA) and Occupational Safety and Health Administration (OSHA) regulations, demanded the Air Force change the way it managed hazardous materials. The HPP is designed to make that change.
Concept The HPP is designed to improve the management and control of hazardous materials on Air Force installations. The concept was developed after consideration of Air Force needs and reviews of initiatives undertaken elsewhere. Significant progress had been made in the field of hazardous material management by various military and civilian organizations. These organizations demonstrated the ability to achieve reductions in hazardous material usage, procurement and hazardous waste generation through combinations of management controls, organizational changes and automated information system support. Based on these experiences and program support from the Headquarters Air Force Center for Environmental Excellence (HQ AFCEE), the HPP was designed and implemented throughout the Air Force.
How the HAZMAT Pharmacy Works To reduce the use of and gain better control of hazardous materials, the HPP provides a three-stage approach. The three stages, which are described more fully below, provide cradle-to-grave management and control of hazardous materials.
Requisition and Authorization
Distribution, Dispensation and Collection
Centralized control offers Air Force bases several advantages. Waste is reduced by closely tailoring the quantities issued to the needs of each user. The HPP can keep track of total inventories and reduce shelf life expiration problems. This saves supply dollars, reduces the risks and costs of hazardous materials management, and reduces hazardous waste disposal costs. The HPP can match the materials available to all requestors on an installation and more easily identify recycling opportunities.
By tailoring the quantities issued to the needs of each user, the HPP can reduce problems associated with distributing and dispensing hazardous materials. For example, the HAZMART can distribute materials in their original containers or in sizes more suitable to the user's needs. This avoids problems associated with the acquisition of large quantity containers, which may result in having excess material on hand and possible shelf life expiration. This approach is also more economical and eliminates health, safety and management problems associated with the dispensing and storage of excess hazardous materials.
Tracking and Accounting
The need for accurate accounting is made more urgent by Executive Order (EO) 12856, which mandates compliance with the Emergency Planning and Community Right-to-Know Act (EPCRA). Each Air Force base is legally obligated to maintain and provide certain information on the use of hazardous materials and their presence on base. In addition, EO 12856 mandates specific reductions in the use of hazardous materials by Federal government agencies. Meeting these requirements demands accurate and readily accessible data, which the HPP can provide through the approved tracking system.
The HPP tracking system begins when a hazardous material is first authorized and continues through ordering, receipt, issue, use, and/or disposal. For unused quantities, the HPP tracks collection or return, reissue, recycling and, if necessary, disposal. In this way, an installation has a readily accessible database that will reveal what hazardous materials are authorized for use, on order or present on base, where they are, their quantities and what happens to them. Health and safety information can also be obtained through the tracking system.
The availability of data from the HPP tracking system enhances the Air Force's ability to comply with the law and eliminates the need for costly, laborious and frequently inaccurate hand assembly of hazardous material inventories. The Air Force is better able to communicate health and safety information to its personnel and can better control the eventual disposition of hazardous materials. The system helps to assure beneficial uses are found for the maximum amount of unused materials, and, in cases where hazardous waste disposal is unavoidable, the system also helps to assure disposal will be done properly.
CE CE leads the HMMP team and is responsible for providing adequate facilities to support the HPP. CE is also responsible for managing the approved HAZMAT tracking system and providing training on system use to HPP personnel. CE also participates in the authorization process ensuring environmental requirements and control options are used as appropriate. CE ensures the approved tracking system is maintained and can meet fire, safety, disaster response, and environmental reporting requirements.
LG LG establishes, manages, and supervises the HAZMART and appoints appropriate personnel to participate in the HMMP Team.
SG SG ensures Bioenvironmental Engineering (BE) participation in the HMMP Team. BE evaluates AF Forms 3952 for health risks to Air Force personnel and evaluates exposure control options. BE reviews HAZMAT usage and the HAZMART AUL to help define requirements for BE process evaluations.
SE SE advises HAZMART facilities on compliance with applicable Occupational Safety and Health standards. SE also evaluates AF Forms 3952 for safety risks and appropriate control options and authorizes use of hazardous materials.
In addition to the above organizations, specific responsibilities are assigned to the work area supervisor. Work area supervisors are required to participate in the HPP, use AF Form 3952 to submit HAZMAT requirements, and comply with all conditions of use noted on the approved AF Form 3952. Supervisors must procure all HAZMAT through the HAZMART or other appropriate source of supply using the authorization process. This applies to all transactions including purchases made by the International Merchant Purchase Authorization Card (IMPAC) and Air Force Form 9, Request for Purchase.
Another benefit is cost savings. At Pt. Mugu NAWS, hazardous material purchases were reduced from $132K to $55K during the first year of operation with only one directorate participating in the program. Purchases were further reduced in the second year to $43K despite the fact the program was expanding to incorporate the rest of the base at a rate of one organization per month. It is also interesting to note that at the start of the program, the value of the hazardous material inventory on hand in shops was valued at $180K or 130 percent of annual purchases. The savings at Hill AFB are even more impressive. Material Acquisition costs dropped from $11 million in 1991 to $3.6 million in 1992. Similarly, on-hand inventory was reduced from $2.3 million in 1991 to $1.4 million in 1992.
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