HAZARDOUS MATERIALS SHELF LIFE OPTIMIZATION
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| Overview: | Management
of hazardous materials is dependent on several conditions, one of the most
important being the material’s expected usable life or "shelf life." The
effective management of hazardous materials prevents pollution. Additionally,
it is a national policy to prefer pollution prevention over recycling, treatment
in an environmentally safe manner, and ultimate disposal. Effective management
of hazardous materiel has become an economic, as well as an environmental
necessity, because once a hazardous material’s shelf life is exceeded, it
is no longer usable for its intended purpose. At that point in time, the
hazardous material becomes a hazardous waste. Proper disposal is not only
difficult and expensive, but may cause some long-term environmental impact.
Moreover, new material needs to be procured to replace that lost by expiration
of the shelf life.
One of the goals of a hazardous materials management program should be to manage the shelf-life materiel more effectively. This data sheet provides information on the basic aspects of a shelf life optimization program. The policies for optimizing shelf-life materiel are contained in DoD 4140.27-M, Shelf-Life Management Manual, as authorized by DoD Directive 4140.1, Materiel Management Policy. This policy provides for the supply chain (life-cycle management) of standard and hazardous shelf-life items contained in the federal supply system. Shelf life is the total period of time beginning with the date of manufacture, cure, assembly, or pack (subsistence only), that an item may remain in the combined wholesale (including manufacturer’s) and retail storage systems, and still remain usable for issue and/or consumption by the end user. Each item that meets the shelf-life criteria is assigned a National Stock Number (NSN) and a specific shelf-life code. Typical shelf-life items include food, medicines, batteries, paints, sealants, adhesives, film, tires, chemicals, packaged petroleum products, hoses/belts, mission-critical o-rings, and Nuclear/Biological/Chemical equipment and clothing. The shelf life code identifies the shelf-life time period by which an item must be used, or subjected to inspection/test/restoration or disposal action. These codes are identified in Appendix A of the DoD 4140.27-M, and consist of two types, Type I and Type II. Type I is an individual item of supply which is determined through an evaluation of technical test data and/or actual experience, to be an item with a definite nonextendible period of shelf life, and ends with the expiration date. Type II is an individual item of supply having an assigned shelf-life time period that may be extended after completion of inspection, test, or restorative action, and is identified by an inspection/test/date. Points of Contact (POC), Shelf-Life Extension System (SLES) information (QSL and MQCSS), training schedules and information, subcommittee updates, dates of future meetings, minutes of past meetings are included in the DoD Shelf-Life Program web site, http://www.shelflife.hq.dla.mil/ Measures that will improve management of hazardous materials shelf-life include:
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| Compliance Benefit: | Implementation
of measures addressed above that will optimize the shelf life of hazardous
materials (i.e., procurement of smaller at one time, improved storage conditions,
etc.) will decrease the amount of hazardous materials purchased and reduce
the amount of hazardous waste generated.
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 optimization program will decrease the amount of hazardous materials purchased and stored on site thereby 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). A shelf life optimization program may also decrease the amount of oil stored on site below threshold amounts for the requirement to develop and implement a Spill, Prevention, Control and Countermeasure Plan under 40 CFR 112. 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.
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| Materials Compatibility: | Materials
compatibility considerations are a key part of the analysis of each individual
hazardous product. This should include not only storage container compatibility,
but also storage conditions such as temperature, humidity, atmosphere, light
exposure, and mutual compatibility of chemical constituents of products.
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| Safety and Health: | Safety
and health are important benefits of maintaining an effective shelf life
program.
Materials that are used in critical applications within the DoD, especially those operations where use of aged material could jeopardize the safety or health of DoD personnel, may be assigned more conservative shelf life codes. Consult your local health and safety personnel, and the appropriate MSDS for specific precautions.
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| Benefits: | An effective
shelf life management program will:
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| Disadvantages: | None identified.
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| Economic Analysis: | The savings
incurred through shelf-life management of hazardous materials depend on
how the program is organized at each activity. Reduced material purchases
and waste disposed must be determined on an individual basis to assess the
economic benefit of a shelf-life program.
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| Approving Authority: | The following
directives describe appropriate shelf life management procedures and policy. DoD Directive 4140.2 DoD 4140.27-M DLAR 4155.37/AR702-18/NAVSUPINST 4410.56/AFJMAN 23-223/MCO 4450.13
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| NSN/MSDS: |
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| Points of Contact: | DLA: Mr. Mike Pipan Headquarters, Defense Logistics Agency Fort Belvoir, VA Phone: (703) 767-1585 DSN: 427-1585 FAX: (703)767-2628 Email: michael_pipan@hq.dla.mil
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| Navy: Ms. Debbie Trautman Navy Shelf-Life Pollution Prevention Program Mechanicsburg, PA Phone: (717) 605-1506 DSN: 430-1506 FAX: (717) 605-3480 Email: debbie_s_trautman@icpmech.navy.mil |
| Vendors: | This
is not meant to be a complete list, as there are other manufacturers of
this type of equipment.
National Concrete
Products |
| Sources: | Mr. Mike Pipan,
DoD, 9/98.
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