AFFIRMATIVE PROCUREMENT POLICIES/PROCEDURES FOR OZONE DEPLETING SUBSTANCES

Revision Date: 4/00
Process Code: Navy/Marines: SR-11-99; Air Force: MA01; Army: N/A
Usage: Navy: High; Marines: High; Army: High; Air Force: High
Compliance Impact: Low
Alternative for: Procurement of Ozone Depleting Substances
Applicable EPCRA Targeted Constituents: Halons, CFCs, Carbon Tetrachloride (CAS: 56-23-5), 1,1,1-Trichloroethane (CAS: 71-55-6), Bromomethane (CAS: 74-83-9), HSFCs

Overview:

The United States Environmental Protection Agency (US EPA) has developed an "affirmative procurement" policy to encourage reduced purchase and use of ozone-depleting substances (ODS) and substitution of alternative products that offer lower overall risks to human health and the environment. Under section 612 of the Clean Air Act, US EPA established the Significant New Alternatives Policy (SNAP) Program. The SNAP mandates identifying and publishing lists of acceptable and unacceptable alternatives to ozone-depleting substances for major industry applications including: aerosols, adhesives, coatings, inks, foam blowing, fire suppression, refrigeration, solvents, and sterilants. The Clean Air Act makes it illegal to replace any Class I or Class II Substance with an alternative that has been identified as hazardous to human or environmental health, when acceptable alternatives are available.

President Clinton issued Executive Order 12843, "Procurement Requirements and Policies for Federal Agencies for Ozone-Depleting Substances," on April 21, 1993 to reduce the Federal government's procurement and use of substances that cause stratospheric ozone depletion. In accordance with the Montreal Protocol on Substances that Deplete the Ozone Layer, to which the United States is a signatory, the Executive Order instructs Federal agencies to comply with Title VI of the Clean Air Act Amendments dealing with stratospheric ozone protection. This includes to maximizing the use of safe alternatives to ozone-depleting substances and to modifying procurement practices and specifications to eliminate requirements for ozone depleting substances. A copy of the Executive Order 12843 is available on the Internet at: http://es.epa.gov/program/exec/12843.html

Federal agencies (including all military departments) shall, to the extent practicable, give preference to the procurement of alternative chemicals, products and manufacturing processes that reduce overall risks to human health and the environment. The objective of this policy is to utilize the procurement process to reduce significantly the use of ODSs so that the Federal government can become a leader in the worldwide phaseout of these substances.

Federal agencies are encouraged to cease the purchase of nonessential products containing or manufactured with ozone-depleting substances and to revise procurement practices. Federal agencies can implement cost-effective programs to modify specifications and contracts that require ozone depleting substances and to substitute non-ozone depleting substances. To the extent practicable agencies may need to:
1. Alter existing equipment and/or procedures to make use of safe alternatives;
2. Specify the use of safe alternatives and of goods and services that do not require the use of Class I substances and that limit the use of Class II substances in new procurements; and
3. Amend existing contracts to be consistent with the phaseout schedule for Class I substances.


Compliance Benefit:

This fact sheet summarizes the requirements of Executive Order 12843 requiring Federal agencies to maximize the use of safe alternatives to Class I and Class II ozone depleting substances, to the maximum extent practicable. Compliance with these requirements also allows facilities to comply with 40 CFR 82, Subpart D.

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:

Materials compatibility is based on the specific alternative procedure or product. In substituting for ODS, consider the potential impacts of the safe alternative on equipment and procedures. Evaluate the compatibility of the safe alternative with other materials or substances used in the process.


Safety and Health:

The stratospheric ozone layer protects the earth from dangerous Ultraviolet-B (UV-B) radiation. Depletion of stratospheric ozone allows more UV-B radiation to penetrate to the earth's surface. Increased radiation, in turn, has been linked to higher incidence of certain skin cancers and cataracts, suppression of the human immune system, damage to crops and aquatic organisms, and increased formation of ground-level ozone. In substituting for ODS, consider potential health and safety impacts of alternative products and procedures. Consult your local Industrial Health specialist, your local health and safety personnel, and the appropriate MSDSs prior to implementing any product substitution.


Benefits:
  • Compliance with Executive Order 12843;
  • Significant reduction in the purchase and use of ODS by Federal agencies;
  • Reduction in releases of ODS to the atmosphere from Federal facilities; and
  • Potential economic benefit from purchase of less costly alternative products.


Disadvantages:
  • Labor to identify acceptable substitutes for each application and process affected.
  • Potential substitute products or processes not included on the SNAP list may not be acceptable.


Economic Analysis: Rigorous economic analysis of the benefits of these affirmative procurement policies requires site-specific information regarding the target process, current material usage, existing procurement practices and the specific substitution proposed.


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:
Product NSN Unit Size Cost MSDS*
None Identified     $  

*There are multiple MSDSs for most NSNs.
The MSDS (if shown above) is only meant to serve as an example.

 

Points of Contact:

Air Force:
LTCOL Sherman Forbes
SAF/AQRE
1060 Air Force Pentagon
Washington, DC 20330-1060
Phone: (703) 588-7839
FAX: (703) 588-0066

Army:
Mr. Dave Koehler
Ocean City Research Corp.
4811-B Eisenhower Avenue
Alexandria, VA 22304
Phone: (703) 212-9006
FAX: (703) 212-9019
Email: dakoehler@aerols.com

EPA:
Stratospheric Ozone Protection Hotline
U.S. Environmental Protection Agency
Mail Code 6205J
401 M St., SW
Washington, DC 20460
Phone: (800)-296-1996 or (301)-614-3396

Marine Corps:
Mr. George Barchuk
Commandant of the Marine Corps
Headquarters, U.S. Marine Corps
ATTN: LPP-2
2 Navy Annex
Washington, DC 20380-1775
Phone: (703) 695-8926 or (703) 695-8934/8939/8946/8947
DSN: 225-8926 or 225-8934/8939/8946/8947
FAX: (703) 695-8905
DSN FAX: 225-8905
Email: gbarchuk@notes.hqi.usmc.mil

Navy:
LCDR Ranch
CNO N45F
2000 Navy Pentagon
Washington, DC 20350-2000
Phone: (703) 602-8794
DSN: 332-8794
FAX: (703) 602-5364

Mr. Peter Mullenhard
Navy Shipboard Environmental Information Clearinghouse, GEO-CENTERS, Inc.
1755 Jeff Davis Highway
Suite 910
Arlington, VA 22202
Phone: (703) 416-1023 ext 109 or (703) 416-1132
FAX: (703) 416-1178


Vendors:

Contact the Navy Shipboard Environmental Information Clearinghouse at (703) 416-1132 or by fax at (703) 416-1178 for appropriate vendors. In addition, each Point of Contact can provide guidance in identifying vendors of specific safe alternative products and processes. See also Pollution Prevention Opportunity Data Sheets on specific Ozone Depleting Substances (e.g., Halon 1301, Halon 1211).


Sources:

Mr. Peter Mullenhard, September, 1998


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