HAZARDOUS MATERIAL SHELF-LIFE MANAGEMENT
![]() |
|
Overview: | One of
the most effective waste minimization programs that can be established is
the active life-cycle management of hazardous materials before they become
hazardous waste.
The active life-cycle management program provides procedures that allows hazardous material users the option to extend the life of certain hazardous materials after their shelf life term has expired. These procedures include defining the following for each individual material stored:
Shelf-life Item. Item or material possessing deteriorative or unstable characteristics to the degree that a storage time period must be assigned to assure that item will perform satisfactorily in services. Shelf-life items are categorized into two types:
Shelf-life Code. A code assigned to a shelf-life item to indicate its storage time period. Shelf-life codes are standard within the Department of Defense (DOD) and are published regularly. For example, items used by the Navy which have an assigned shelf-life code are listed monthly in NAVSUP PUB 4105 (List of Items Requiring Special Handling [LIRSH]). Acceptable Quality Level. The maximum percent defective (or the maximum number of defects per hundred units) that, for purposes of sampling inspection, can be considered satisfactory as a process average. Condition Code. A code assigned to classify material in terms of its readiness for issue and use, or to identify action underway to change the status of material. The condition codes used by stocking activities in shelf-life procedures are listed below. "Users" of the material normally do not downgrade condition codes in this manner. They leave the material in "A" condition until the shelf-life has expired. Shelf-life Action Code (SLAC). A code assigned to a shelf-life item to specify the type of inspection, test, or restorative action to be taken when the item has reached the end of its designated shelf-life. It also specifies the allowed extension period for the item after the inspection, test, or restorative action has been completed. NAVSUP PUB 4105 promulgates the Shelf-life Action Code (SLAC) for items used by the Navy that have assigned shelf-life codes. Sampling and Inspection Tests. On-site tests conducted on Type II materials to extend the material’s shelf life. In most cases, shelf-life extension tests are not complicated, do not require a laboratory, and can be done on the spot by anyone with a minimum amount of training. In many cases they consist of visual checks for damage or deterioration. An effective shelf-life extension program is a critical part of life-cycle management. A significant portion of hazardous materials turned in for disposal are in their original packaging and meet the performance requirements as defined in the military specification. Unfortunately, the material is declared unusable solely because it has reached the end of its designated shelf-life term. The shelf life code of a given hazardous materials is dependent upon many parameters including storage conditions, packaging, the chemistry of the material, and it’s critical use. Shelf-life extension programs are the single most neglected aspect of shelf-life management. Organizations (users as well as suppliers) generally do not conduct in-house inspections of tests to extend the shelf-life of their material. They either don't extend shelf-life at all or rely on the monthly DOD Quality Status Listing (QSL) to tell them what shelf-life material can be extended and for how long. When the QSL is used, extension efforts often consist solely of re-marking material with the new expiration dates published in the QSL. There is nothing wrong with that, and it needs to be done, but the QSL primarily lists only DLA-managed items that require laboratory testing. Items that require only visual checks are not listed; neither are GSA-managed items. There is a DOD initiative underway to extend the QSL into a DOD listing that will include material managed by DLA and all military services. Unfortunately, it will be some time before it becomes fully integrated and it will never list items that require only visual checks to do extensions. In-house inspections and tests are adequate for most material. It is, however, often difficult for personnel to find descriptions of the specific inspections or tests required to extend the shelf-life of particular items. There is no single source of test information. GSA and all military services except the Navy have developed separate storage standards with extension criteria for the material they manage. Each DLA Inventory Control Point (ICP) has developed storage standards for material managed by the particular ICP. Every command should have a collection of those standards. Together, they represent the existing universe of shelf-life extension test and inspection guidelines. Individual product specifications are the only other source of inspection and test information. Storage Standard Points of Contact are listed in DOD 4140.27-M (Shelf-Life Item Management Manual). The Navy has not yet developed storage standards for shelf-life extension inspections and tests on Navy-managed material. In the absence of specific guidelines, use common sense. For most Type II material, shelf-life extension tests are not complicated, do not require a laboratory, and can be done on the spot by anyone with a minimum amount of training. They are usually nothing more than visual checks for damage or deterioration. Navy Item Managers refer callers to Fed-Std-793 (Depot Storage Standards) when asked what tests need to be conducted to extend the life of particular products. Another highly effective hazardous material shelf-life management technique is the comprehensive study of a specific hazardous material to determine the material’s true shelf-life term. In many cases the shelf-life term of hazardous materials are too conservative. In many cases, hazardous material users depend upon conservative manufacturer recommendations in defining shelf-life terms. It is also noteworthy that in recent years, the chemical stability and packaging of hazardous materials has improved significantly. As a result, shelf-life terms that were defined prior to these improvements are likely to be too conservative. The Naval Supply Systems Command (NAVSUP) has conducted several studies to determine the true shelf-life term of hazardous materials that are commonly procured by the Navy. Only hazardous materials that are purchased in large volumes and historically have been disposed as a hazardous waste due to expired shelf-life terms were considered for study. These studies have indicated that the shelf-life term of approximately 50% of hazardous materials procured by the Navy are too conservative. The primary classes of hazardous materials undertaken for study by NAVSUP were: (1) Chemicals, (2) Paints, Sealants, and Adhesives, and (3) Petroleum, Oils and Lubricants (POLs). The table presented below summarizes the results of the study
The table indicates that for many materials an increase in the shelf-life term is appropriate. However, prior to implementing an increase in shelf-life term for a specific material, the materials degradation mode, packaging and anticipated storage conditions must be studied to determine if a shelf-life term increase is appropriate. It is recommended that the reader contact the Points of Contact listed at the end of this datasheet for information regarding specific hazardous materials that they are storing.
|
||||||||||||||||||||||||
Compliance Benefit: | The active
life-cycle management program provides procedures that allows hazardous
material users the option to extend the life of certain hazardous materials
after their shelf life term has expired. These procedures allow facilities
a way to decrease their hazardous waste generated from chemicals that have
exceeded their shelf life date. In addition, shelf life extensions may allow
facilities to purchase less hazardous chemicals since the chemicals in stock
are still usable.>
The reduction of hazardous waste helps facilities meet the requirements of waste reduction under RCRA, 40 CFR 262, Appendix, and may also help facilities reduce their generator status and lessen the amount of regulations (i.e., recordkeeping, reporting, inspections, transportation, accumulation time, emergency prevention and preparedness, emergency response) they are required to comply with under RCRA, 40 CFR 262. In addition, a shelf life management program will decrease the amount of hazardous materials purchased and stored on site therefore decrease the possibility that the facility would meet any of the reporting thresholds of SARA Title III (40 CFR 300, 355, 370, and 372; and EO 12856). The compliance benefits listed here are only meant to be used as a general guideline and are not meant to be strictly interpreted. Actual compliance benefits will vary depending on the factors involved, e.g. the amount of workload involved.
|
||||||||||||||||||||||||
Materials Compatibility: | N/A
|
||||||||||||||||||||||||
Safety and Health: | Consult
your local industrial health specialist, your local health and safety personnel,
and the appropriate MSDS prior to implementing this technology.
|
||||||||||||||||||||||||
Benefits: |
|
||||||||||||||||||||||||
Disadvantages: |
|
||||||||||||||||||||||||
Economic Analysis: | The savings
incurred through reduced disposal costs and reduced reordering of materials
varies widely depending on the quantity of material purchased annually and
the purchase and disposal costs. The example presented below is of a common
detergent with a shelf-life term of 36 months. A study of this detergent’s
degradation mode, packaging and storage conditions revealed that 48 months
is a more appropriate shelf-life term.
Assumptions:
Annual Operating Cost Comparison for Lengthening the Shelf-Life Term of a Detergent from 36 Months to 48 Months
Economic Analysis Summary Annual Savings
for Shelf-life Term Lengthening: $152,700 Click Here to view an Active Spreadsheet for this Economic Analysis and Enter Your Own Values.
|
||||||||||||||||||||||||
Approving Authority: | Approval
is controlled locally and should be implemented only after engineering approval
has been granted. Major claimant approval is not required.
|
NSN/MSDS: |
|
Points of Contact: | Navy: Ms. Lynn M. Torres Naval Facilities Engineering Services Center 1100 23rd Avenue Port Hueneme, CA 93043-4370 Phone: (805) 982-1388 FAX: (805) 982-1458 |
Vendors: | This
is not meant to be a complete list, as there are other manufacturers of
this type of equipment.
National Concrete
Products |
Sources: | Shelf-life
Management Chart from Hazardous Material Control & Management/HMIS CD
ROM System. Shelf-life Specifications for Hazardous Materials, Final Report, NFESC, Pollution Prevention Division, Port Hueneme, CA 93043-4328
|
[Back]