HAZARDOUS MATERIAL SHELF-LIFE MANAGEMENT

Revision Date: 4/03
Process Code: Navy/Marines: SER-011-99; Air Force: MA01; Army: N/A
Usage List: Navy: High; Marines: High; Army: High; Air Force: High
Alternative For: Disposal of expired materials
Compliance Impact: Medium
Applicable EPCRA Targeted Constituents and CAS Numbers: Various

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
  • Shelf Life Code
  • Acceptable Quality Level
  • Condition Code
  • Shelf-life Action Code (SLAC)
  • Sampling and Inspection Tests

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:

  1. Type I. An item of supply which is determined through an evaluation of technical test data and/or actual experience to be an item with a definite non-extendible period of shelf-life. The single digit shelf-life code designating Type I material is a letter (A-S).
  2. Type II. An item of supply having an assigned shelf-life time period that may be extended after completion of an inspection, test, or restorative action. The single digit shelf-life code designating Type II material is a number (1-9).

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

Material Class Federal Stock Code Current Shelf-life Term Recommended Increase in Shelf-life Term
Chemicals 5610, 5970, 6135, 6750, 6810, 6840, 6850 6-48 months
Average = 24 months
0-12 months
Paints, Sealants and Adhesives 7510, 7930, 8010, 8030, 8040 6-36 months
Average = 16 months
0-12 months
Petroleum, Oils, and Lubricants 9150 24-36 months
Average = 28 months
0-24 months

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


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:
  • Reduces disposal of expired hazardous materials.
  • Reduces reordering of additional hazardous materials to replace expired hazardous materials.


Disadvantages:
  • Shelf-life term lengthening process requires that changes be made at the military specification level, which can be time consuming.


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:

  • 35,000 gallons of detergent (NSN 7930-00-282-9699) is purchased annually.
  • Purchase cost: $12/gal.
  • 1,800 gallons disposed annually as a hazardous waste due to expired shelf-life term.
  • Disposal cost: $21.10/gal.
  • Current shelf-life term of detergent: 36 months.
  • Recommended shelf-life term: 48 months.
  • Increasing the shelf-life term by 33% (36 to 48 months) will result in a 33% savings in new purchase and disposal costs.

Annual Operating Cost Comparison for Lengthening the Shelf-Life Term of a Detergent from 36 Months to 48 Months

  36 Month Shelf-life Term 48 Month Shelf-life Term
Operational Costs:    
Labor: $0 $0
Material: $420,000 $280,000
Waste Disposal: $38,000 $25,300
Total Operational Costs: $458,000 $305,300
Total Recovered Income: $0 $0
Net Annual Cost/Benefit: -$458,000 -$305,300

Economic Analysis Summary:

  • Annual Savings for Shelf-life Term Lengthening: $152,700
  • Capital Cost for Diversion Equipment/Process: N/A
  • Payback Period for Investment in Equipment/Process: Immediate

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NSN/MSDS: None identified.


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.


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
P.O. Box 2001
Greenwood, DE 19950
Phone: (302) 349-5528
FAX: (302) 349-9435



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