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, national policy is 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. Once the shelf life is exceed, the hazardous material
becomes a hazardous waste. Proper disposal is not only difficult and
expensive, but may cause adverse, 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 material 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 that an item remains usable for issue and/or consumption by the end user. It begins with the date of manufacture, cure, assembly, or packaging (subsistence only) and includes the time spent in wholesale (including manufacturer’s) and retail storage systems. 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 that is determined, through an evaluation of technical test data and/or actual experience, to be an item with a definite nonexpendable period of shelf life. As a result, these items are assigned an 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. The DoD Shelf-Life Program web site, http://www.shelflife.hq.dla.mil/ provides information about the Shelf-Life Extension System (SLES), Material Quality Control Storage Standards (MQCSS), and the Quality Status List (QSL) programs, Points of Contact (POC), training schedules, subcommittee updates, dates of future meetings, and symposium minutes. Measures that will improve management of hazardous materials shelf-life include:
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| Compliance Benefit: | By implementing measures that will optimize the shelf life
of hazardous materials (e.g., procurement of smaller units at one
time and improved storage conditions), the amount of hazardous materials
purchased will decrease and, in turn, the amount of hazardous waste
generated will be reduced.
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 optimization program will decrease the amount of hazardous materials purchased and stored on site, thus decreasing the possibility that the facility would meet any of the reporting thresholds of SARA Title III (40 CFR 300, 355, 370, and 372). A shelf-life optimization program may also decrease the amount of oil stored on site to below threshold amounts, thereby potentially eliminating the requirement to develop and implement a Spill, Prevention, Control and Countermeasure (SPCC) Plan under 40 CFR 112. 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: | Materials
compatibility considerations are a key part of the analysis of each
individual hazardous product. This analysis 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. Be aware that 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 industrial health specialist, your local health and safety personnel, and the appropriate MSDS prior to implementing this technology. |
| 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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| NSN/MSDS: | None identified.
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| Approving Authority: | The
following directives describe appropriate shelf-life management procedures
and policy.
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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: | Mr. Mike Pipan, DoD, 9/98
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