Historically, military organizations utilize multiple, independent procurement vehicles. Lack of acquisition, inventory, and management controls results in the generation and disposal of significant quantities of excess, expired and unserviceable hazardous materials. In response to an increasingly stringent regulatory framework, DoD organizations applied pollution prevention concepts to hazardous waste management.

A CHRIMP or Pharmacy is operated by multi-disciplinary teams representing a variety of organizations including supply, contracting, procurement, safety, industrial hygiene, environmental and public affairs. Successful facilities operate on a just-in-time delivery basis, eliminating the tendency to overpurchase and stockpile materials. The use of hazardous materials is restricted, based strictly on need. CHRIMP/Pharmacy staff endeavor to issue materials in the smallest container that meets mission requirements. Customers return unused materials to the pharmacy for reissue.

Establishing a CHRIMP/Pharmacy requires cooperation among all operations. Quantities of materials already on site must be inventoried, and each operation’s need for hazardous materials evaluated. A facility must be constructed or modified and equipment purchased and installed. CHRIMP/Pharmacy operating procedures must be defined. Staff require training in hazardous material and hazardous waste management and transportation. In addition, the CHRIMP/Pharmacy requires computer equipment and software to establish a tracking system.

The tracking function facilitates compliance with reporting requirements. Data from the tracking system can provide accurate accounting for EPCRA reporting as well as an historic record of reductions in the use of specific hazardous materials. The tracking begins when a material is ordered and follows the material and its container through receipt, issue, use, return, reissue, recycling and disposal.

The Naval Air Weapons Station (NAWS) at Point Mugu, California, implemented a Hazardous Material Minimization Center (HAZMINCEN) as an integral part of its base-wide CHRIMP. Staff established a system of credits and billings to control inventory and purchase of all hazardous materials. A delivery system was also established to respond to work order requests and pick up any unused materials. Efficient inventory management techniques reduced local purchases of hazardous materials. Pt. Mugu utilizes a Hazardous Inventory Control System (HICS). Using HICS, staff can create a unique bar-code for each container issued, process material requisitions and track receipts and issues. HICS also provides on-line inventory accounting and automatic data collection. In 1994, the Navy issued a CHRIMP manual including HICS software and a User's Guide that outlines the methodology for implementing a HICS-based, centralized hazardous material management program

A number of Air Force bases have committed to the Hazmat Pharmacy concept. At Andrews AFB, Maryland, the pharmacy provides a single point of control and accountability for hazardous materials for a joint services team including the Navy, Air National Guard, Army and Marines. The Andrews AFB pharmacy has virtually eliminated redundancy in procurement of hazardous materials. The pharmacy at Nellis AFB, Nevada, uses decentralized ordering and centralized delivery systems. Each request to purchase hazardous material must be approved by Bioenvironmental Engineering to ensure that personnel are trained and equipped to use the material properly. The Air Force Center for Environmental Excellence (AFCEE) developed the Commander’s Guide to The Implementation of the Hazardous Material Pharmacy, which provides guidance in planning and implementing a pharmacy. USAF Hazmat Pharmacies utilize the Air Force Environmental Management Information System (AF-EMIS), an automated data processing program.

The reduction of excess, expired and unserviceable hazardous materials means less hazardous waste. This benefit 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 centralized hazardous materials program will decrease the amount of hazardous materials purchased and stored on site and 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). A centralized hazardous materials 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.

Consult your local industrial health specialist, your local health and safety personnel, and the appropriate MSDS prior to implementing this technology.

• Ease of compliance with regulatory reporting requirements.
• Improper management and storage of incompatible materials is eliminated.
• Substantial reductions in the costs associated with acquisition, storage, management and disposal of hazardous materials. For example, at Pt. Mugu, total cost avoidance benefits exceeded $1 million.
• Improved quality and availability of materials for all operations.
• Elimination of excess, expired and unusable materials.
• Improved worker health and safety.
• Increased awareness of and emphasis on pollution prevention and substitution of less or non-hazardous products and processes.

• Resistance to change among facility staff.
• Substantial initial investment in site, equipment, staff training and labor to identify, authorize, and move hazardous materials to central pharmacy location.

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

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