August 1994
In the January 1993 Air Force Pollution Prevention Program * Action Memorandum, Chief of Staff General McPeak stated "Our goal is to prevent future pollution by reducing use of hazardous materials and releases of pollutants into the environment to as near zero as feasible. To achieve this, we must quickly move away from dependence on hazardous materials...to succeed we must mobilize our whole team and find ways to move faster." To meet this challenge, Headquarters, Air Force Center for Environmental Excellence has developed an innovative approach to hazardous material management: the Hazardous Material (HAZMAT) Pharmacy. The HAZMAT Pharmacy concept embodies a cultural change in the management of hazardous materials at the base level and establishes single point control and accountability over the requisitioning, receipt, distribution, issue and reissue of hazardous materials.
Air Force bases have historically had difficulty in achieving control over the acquisition and disposal of hazardous materials. Contributing to this problem is the presence of multiple independent procurement vehicles through which base organizations can acquire hazardous materials. As many as six to ten such vehicles are sometimes present. Base organizations may place the same requisition with two or more of these vehicles, or several organizations may order the same material through different channels. There are 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 are difficult to determine, and accountability for the issue and use or disposal of these materials cannot 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, demand that the Air Force change the way it manages hazardous materials. The HAZMAT Pharmacy is designed to help make that change.
The Hazardous Material Pharmacy concept is designed to improve 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 has been made in the field of hazardous material management by various military and civilian organizations. These organizations have 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. HQ AFCEE recognized the success of these organizations can form the basis for a model hazardous material management program for the Air Force and developed the HAZMAT concept.
To reduce the use of an gain better control of hazardous materials, the pharmacy follows a three-stage approach. The three stages, which are described more fully below, provide increased cradle-to-grave control of hazardous materials.
The pharmacy is the single point of authorization on an installation through which hazardous materials may be requested. Users who require hazardous materials submit their request to the pharmacy, where it is reviewed by a team of experts from logistics (supply and contracting), bioenvironmental engineering, civil engineering (environmental, disaster preparedness, fire safety), and other offices (legal, public affairs) as needed. The review assures: the requester is authorized to use the material; the most environmentally benign product will be obtained; and the quantity purchased will be the minimum necessary to fulfill the user's needs. This centralized requisition system and review process reduces inventories, by coordinating material availability throughout the installation. Following the review, if acquisition of the requested materials is authorized, the requisition is entered into a tracking system that will follow the material from acquisition through its eventual use or disposal.
Once hazardous materials are received on an installation, they come under the control of the pharmacy. Pharmacies may either operate from a separate facility at which hazardous materials are stored and issued, or they may issue directly from base supply. However organized, the pharmacy controls the actual issue of the materials assuring quantities issued are justified by customer needs. The pharmacy also collects unused quantities and makes them available to other users or for recycling or reclamation.
Central control offers Air Force bases several advantages. Waste is reduced by closely tailoring the quantities issued to the needs of each user. The pharmacy can keep track of total inventories and reduce shelf life expiration problems. This will save supply dollars and reduce the risks and costs of hazardous materials management outside the pharmacy. The pharmacy can match the materials available to all requestors on an installation and more easily identify recycling opportunities. In this way the pharmacy can limit the disposal of hazardous materials as hazardous waste.
By tailoring the quantities issued to the needs of each user, the pharmacy can reduce problems associated with distributing and dispensing hazardous materials. For example, the pharmacy can distribute materials in their original containers and in sizes suitable to the user's needs. This avoids problems associated with the acquisition of larger size containers (from which smaller quantities are dispensed). This approach is also more economical and eliminates health, safety and management problems associated with the dispensing and storage of excess hazardous materials.
Good management and regulatory requirements require Air Force bases to closely account for all hazardous materials on their installations. One of the principal benefits of the HAZMAT Pharmacy is its capability to provide such accounting.
Air Force bases have multiple data processing systems for ordering and accounting for supplies, including hazardous materials. These vary in the type and comparability of data they maintain, making it difficult to assemble a single, accurate list of hazardous materials present on an installation at any one time. Increasingly stringent environmental and health and safety regulations make this an unacceptable situation.
The need for accurate accounting is made more acute 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 its installations. In addition, EO 12856 mandates specific reductions in the use of hazardous materials by Federal government agencies. Meeting these requirements demands accurate data, which the HAZMAT Pharmacy will provide.
The pharmacy tracking system begins when a hazardous material is first ordered and continues through receipt, issue, use, and for unused quantities, collection or return, reissue, recycling and, if necessary, disposal. In this way, an installation will have a readily accessible data base that will reveal what hazardous materials are 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 data base.
The availability of data from the pharmacy 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 information. The Air Force is better able to communicate needed health and safety information to its personnel and can better control the eventual disposition of hazardous materials, assuring beneficial uses are found for the maximum amount of unused materials and where disposal as hazardous waste is unavoidable, such disposal will be done properly.
Air Force Major Commands are in various stages of establishing HAZMAT Pharmacies at their installations, and have reported a variety of experiences. Some observations to date:
The pharmacy must be staffed by a multi-disciplinary team, utilizing personnel from a variety of organizations and career fields. These people must have in-depth knowledge of the disciplines involved in supply procurement and distribution as well as handling hazardous wastes. They must receive training, including hazardous waste management, hazardous waste operation and Department of Transportation hazardous material transportation requirements.
The pharmacy must be housed in a facility adequate to meet its needs. It can be either newly constructed or a modified existing building. The facility must be designed to handle, dispense and store hazardous materials and often hazardous waste.
To document the HAZMAT Pharmacy concept, HQ AFCEE prepared case studies of three installations: the Naval Air Weapons Station (NAWS) at Point Mugu, California, Hill Air Force Base (AFB) in Ogden, Utah and Kelly AFB in San Antonio, Texas.
The most important benefit from the use of the HAZMAT pharmacy concept is regulatory compliance. The Resource Conservation and Recovery Act (RCRA) prescribes a complex management system for hazardous waste that is expensive and carries heavy penalties for non-compliance. By taking advantage of the opportunities the pharmacy offers to reduce or eliminate production of hazardous waste, Air Force bases can reduce the costs and risks of compliance with RCRA. Improper management or disposal of hazardous waste can also create liability for Air Force bases under the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA). If an Air Force base is found to have improperly disposed of hazardous waste, CERCLA can require the facility to clean up the waste; a liability that can run into millions of dollars. Reducing the amount of waste available for disposal will greatly reduce the potential for future problems. Finally, as already mentioned, HAZMAT pharmacy practices greatly simplify compliance with the requirements of EO 12856.
Another 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 have 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.
Using the information developed from case histories, HQ AFCEE has developed the Commander's Guide to The Implementation of the Hazardous Material Pharmacy. This publication provides a plan of action and guidance to implement a hazardous materials pharmacy.
HQ AFCEE also publishes a periodical entitled Pharmacy which presents information, ideas and case histories related to HAZMAT control and reduction. Further, HQ USAF/LG and MAJCOMs are developing policies which provide additional direction.
To obtain information about the Hazardous Material Pharmacy concept, contact the PRO-ACT office at DSN 240-4214 or toll free at (800) 233-4356.
ACC; Captain Ardyce Clements
HQ ACC/CEV
DSN 574-3252
AETCRick Whittier
HQ AETC/CEVP
DSN 487-3422
AFCESAMSgt Jim Whitcomb
HQ AFCESA/DMG
DSN 523-6411
AFMCJohn Moody
HQ AFMC/CEVV
DSN 787-6212
AFRESJesse Marzette
HQ AFRES/CEV
DSN 497-1067
AMCMSgt Brion Au (Until October, 1994)
TSgt Blake Bryan (Starting October, 1994)
HQ AMC/CEVP
DSN 576-5763
ANGRCShelah Roberts
ANGRC/CEVC
DSN 858-8844 Extension 8132
PACAFLtCol Mike Winters-Maloney
HQ PACAF/LGQ
DSN 449-5330
AFSPCFletcher Lantz
HQ AFSPC
DSN 692-5630
USAFADiana Dean
HQ USAFA/CEVV
DSN 259-4483
USAFESMSgt Larry Carter
HQ USAFE/CEVA
DSN (314) 480-7490
TI #0836A - August 1994
Call PRO-ACT
DSN 240-4214 (800) 233-4356
Last Updated: November 13, 1995