HAZARDOUS MATERIAL SHELF-LIFE MANAGEMENT
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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 that 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 its
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. While nothing is wrong with that practice, and it needs to be
done, 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. A DOD initiative is 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 determine the need for extensions. In-house inspections
and tests are adequate for most material. However, personnel cannot find descriptions of the specific inspections or tests
required to extend the shelf-life of particular items. No single
source of test information exists. 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. 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, 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 establishes procedures that provide
hazardous material users with the option to extend the life of certain
hazardous materials after their shelf-life term has expired. These
procedures provide facilities with 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; the Pollution Prevention Act (42 USC 13101-13109); and Executive Order (EO) 13148, Greening the Government Through Leadership in Environmental Management; 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). The compliance benefits listed here are only meant to be used as general guidelines 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
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Safety and Health: | Consult
your local industrial health specialist, your local health and safety
personnel, and the appropriate MSDS prior to implementing this
technology.
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Benefits: |
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Disadvantages: |
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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:
Click here to View an Active Spreadsheet for this Economic Analysis and Enter Your Own Values. To return from the Active Spreadsheet, click the Back arrow in the Tool Bar. | ||||||||||||||||||||||||
NSN/MSDS: | None identified.
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Approving Authority: | Appropriate authority for making
process changes should always be sought and obtained prior to procuring or implementing any of the
technology identified herein.
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Points of Contact: | For more information | ||||||||||||||||||||||||
Vendors: | This is not meant to be a complete list, as there may be
other suppliers 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 |