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July 2008

TSP Number 052-E-1005 Comply with host nation, federal, state and local environmental protection laws and regulations. July 2008. Terminal Learning Objective. ACTION: Comply with host nation, federal, state and local environmental protection laws and regulations.

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July 2008

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  1. TSP Number 052-E-1005Comply with host nation, federal, state and local environmental protection laws and regulations July 2008

  2. Terminal Learning Objective • ACTION: Comply with host nation, federal, state and local environmental protection laws and regulations. • CONDITION: As a Soldier performing assigned duties in a garrison, training or deployed environment, and given access to environmental guidance provided in the references. • STANDARD: Comply with environmental legal requirements by implementing specific environmental duties during mission activities, applying environmentally sustainable practices to common activities and taking the appropriate course of action in the absence of guidance.

  3. Safety, Risk andEnvironmental Concerns • Safety Requirements: None • Risk Assessment Level: Low • Environmental Considerations: Training entirely of an administrative nature, with little or no environmental impact

  4. References • TM 38-410 Storage and Handling of Hazardous Material • FM 3-100.4 Environmental Considerations in Military Operations • TC 3-34.489 The Soldier and the Environment • FM 5-19 Composite Risk Management • AR 200-1 Environmental Protection & Enhancement • The Army Strategy for the Environment • 29 CFR Labor (Occupational Safety and Health Act) • 40 CFR Protection of the Environment • 49 CFR Transportation

  5. Learning Objective #1 • Describe a Soldier’s specific environmental duties

  6. Soldier Environmental Duties • Comply with federal, state, host nation environmental regulations, Army regulations, installation/local and unit environmental policies and SOPs • Protect resources by supporting the installation environmental Management System (eMS) or Sustainability Program, practicing hazardous waste minimization, pollution prevention, and resource conservation • Respond to HM/HW spills immediately • Report as required

  7. Hierarchy of Laws & Regulations • Federal/DoD/Army • Host Nation • State • Local/Installation

  8. Federal Laws • National Environmental Policy Act (NEPA-1969) • Resource Conservation Recovery Act (RCRA) • Clean Water Act • Clean Air Act • National Historic Preservation Act • Endangered Species Act • Noise Control Act

  9. Federal Environmental Laws • National Environmental Protection Act –NEPA • Any federal action requires that the proponent conduct an analysis to see if there are impacts to the environment. • Often considered an “umbrella” law because it encompasses the other environmental laws. • Soldiers comply with the NEPA by- • By conducting Risk Assessments. • By following environmental SOPs, Laws and Regulations.

  10. Federal Environmental Laws Resource Conservation and Recovery Act (RCRA) • Primary HW reference is 40 CFR 260-279 • RCRA regulates the generation, transportation, treatment, storage and disposal of solid and hazardous waste. • Massive and complex regulation • Known as the “Cradle to Grave” Act • Soldiers comply with the RCRA by- • Proper disposal of chemicals, solvents, and HW. • Accumulating HW in approved containers. • Reporting any spills of HW to their chain of command. • Proper bagging, storage and disposal of medical waste.

  11. Resource Conservation and Recovery Act (RCRA) RCRA ç¦ ç¦ Hazardous Waste Subtitle C Solid Waste Subtitle D Underground Storage Tanks Medical Waste

  12. Federal EnvironmentalLaws Clean Water Act (CWA) Soldiers comply with the CWA by- • Disposal of chemicals, solvents, and HW properly. • Washing vehicles in approved wash racks only. • Cleaning up spills in the work area immediately. • Reporting spills to the chain of command.

  13. Federal EnvironmentalLaws Clean Air Act (CAA) Soldiers comply with the CAA by- • Checking with range control before using gas or smoke. • Observing local fire and burning restrictions. • Keeping solvent vats closed when not in use. • Maintaining and operating equipment properly to minimize air pollution.

  14. Federal EnvironmentalLaws  National Historic PreservationAct (NHPA) Soldiers comply with the NHPA by- • Reporting the discovery of artifacts and sites to the chain of command. • Reporting any damages to historical, cultural and archeological sites. • Leaving sites undisturbed. Don’t take “souvenirs”.

  15. Federal EnvironmentalLaws Threatened/Endangered Species http://www.redlist.org  Endangered Species Act (ESA) Soldiers comply with the ESA by- • Recognizing signs and markers for protected areas. • Avoiding habitat areas during all operations. • Following installation regulations. • Obeying range control regulations for cutting brush and trees for camouflage. Greater Spotted Eagle

  16. Federal Environmental Laws  Noise Control Act (NCA) Soldiers comply with the NCA by- • Avoiding creating unnecessary noise. • Respecting noise-buffer zones, minimum flight altitudes, no-fly zones, and nighttime curfews designated by the installation.

  17. Host Nation Environmental Laws Comply with host nation and international environmental laws: • More or less stringent • Final Governing Standards (FGS) • Basel Convention Signatory • Status of Forces Agreement (SOFA)

  18. State Environmental Laws • Comply with state environmental regulations. • Most States have Primacy • State laws can be more stringent than federal laws

  19. LocalLaws • Comply with installation/local and unit environmental policies and SOPs. • Regional planning areas, counties, cities/town can have specific additional requirements. • Each installation has an environmental policy issued by the post commander (environmental Management System- eMS or Sustainability Program). • Every unit/organization should have an environmental SOP.

  20. Installation environmental Management System (eMS) or Sustainability Program • Recycling/Salvage • Conservation • Waste Minimization • eMS or Sustainability Training • Alternative transportation • Alternative energy sources • Sustainability

  21. Army Guidance • The Army environmental regulation. • AR 200-1 (13 Dec 2007)

  22. Army Environmental Strategy“Sustain the Mission – Secure the Future” • Foster a Sustainable Ethic • Strengthen Army Operations • Meet Test, Training and Mission requirements • Minimize Impacts and Total Ownership Costs • Enhance Well-Being • Drive Innovation

  23. Operational Guidance • Comply with Operations Orders (OPORDs), or Operations Plans (OPLANs) • Joint: Annex L • Army: Annex L • MACOM: FRAGO • Follow the Overseas Environmental Baseline Guidance Document (OEBGD) • Use FM 3-100.4 Environmental Considerations in Military Operations for practical guidance

  24. SPILL DRILL This is the basic SPILL DRILLbut every unit should have a tailored plan depending on the liquid hazards found in the unit.

  25. Learning Objective #2Legal Issues • Individuals and unit commanders can be held personally liable for violating environmental laws and regulations. • States and Federal agencies can levy fines. • Host Nations can hold the USA liable. • Negative publicity can harm the Army image.

  26. Penalties • ENVIRONMENTAL PENALTIES: Federal and state environmental regulatory agencies can impose penalties on the Army for violating environmental laws. These penalties include fines, increased monitoring and intervention by environmental regulators, and damage awards from lawsuits. • A Soldier who violates environmental laws or allows others to do so can be prosecuted by military authorities under the Uniform Code of Military Justice (UCMJ) or in federal district court. If convicted of environmental violations, the Soldier can receive fines up to $50,000 per day of violation and imprisonment up to two years. • DoD fines for FY 2007 totaled $566,545 which was a decrease from $1.2 million in FY 2006.

  27. Consequences of Noncompliance • It can have a negative impact on your overall mission. • It can cause irreparable damage to the environment where you live and train. • It can fracture the Army – Community relationship.

  28. Learning Objective #3 • Identify the responsibilities for managing a unit environmental program

  29. -Comply with environmental legal requirements. • -Instill an environmental ethic • -Incorporate environmental responsibilities and risk management into unit SOPs/OPORDs • -Integrate environmental considerations into all unit operations • -Ensure personnel receive required environmental training • -Appoint and train environmental officers at appropriate organizational levels. • -Report noncompliance and spills • -Support installation eMS/Sustainabililty Program Army Regulation 200-1 Environmental Quality Environmental Protection and Enhancement Headquarters Department of the Army Washington, DC 13 Dec 2007 UNCLASSIFIED Army Environmental ProgramCommander’s Responsibilities

  30. Environmental Officer • Appointment Orders • Training • Runs the Unit Environmental Program • Coordination in planning and risk assessments

  31. Team Training • Ensure that key personnel/teams are trained • This training should include: • Spill prevention/response • Hazardous waste operations and emergency response • Personal Protective Equipment and first aid for exposure • Environmental compliance officer training • Specific environmental laws, regulations, and treaties • HM/HW handling, storage, transport • MSDS recognition and use • Field sanitation • Satellite Accumulation Points • Cultural, historic, religious sites; endangered species • Pollution Prevention

  32. Unit Environmental Program • An Environmental Officer/Alternate • Required references • Awareness Training • Unit SOP which includes an environmental section • Trained Environmental Teams • Spill Kits • Personal Protective Equipment • Unit Self Assessment • Environmental files and records

  33. Environmental Training Sources • Installation Environmental Training Courses • Environmental Officer • Spill Team Training • Field Sanitation • Resident Training Courses • Army Logistics Management College, Fort Lee • Defense Logistics Agency, Fort Belvoir • Corps of Engineers Professional Development Center, Huntsville • Online Courses • Environmental Officer Course, MANSCEN Blackboard • Army e-Learning Skillsoft website • USAES-DEI website Product Catalog • Army Correspondence Course Program (ACCP). • TRADOC Critical Common Tasks (5 Environmental Tasks)

  34. Learning Objective #4Unit Self Assessment • Demonstrate use of the Environmental Checklists in Appendix A, Table A-1 of TC 3-34.489 The Soldier and the Environment to conduct a unit self assessment.

  35. Vehicle Maintenance • Maintain vehicles and equipment in accordance with (IAW) TM specifications • Clean up spills immediately • Collect used rags in a dirty rags container • Collect used dry-sweep compound for reuse • Recycle solvents and coolants • Return damaged parts and assemblies to the supply facility for rebuilding or recycling • Place drip pans, diapers, or absorbents under vehicles • Locate waste accumulation containers close to the source of the waste products • Label and date waste accumulation containers

  36. Weapons Maintenance • Dispose of contaminated patches and cleaning equipment properly • Reuse cleaning equipment and lubricant containers when possible • Purchase lubricants in bulk, and refill smaller containers • Recycle cleaning solvents • Keep the lids on solvent vats closed when not in use

  37. CBRN Maintenance • Keep a copy of the applicable MSDS for each HM on hand in a binder • Collect HM (used filters, decontamination materials, and cleaning solutions at the point of generation, and dispose of them properly • Mark and turn in damaged equipment • Reuse mask carriers and cleaning equipment • Store STB containers in separate locations that are dry and well ventilated • Dispose of HW and batteries according to the unit SOP • Turn in excess repair parts so that other units can use them • Dispose of out-of-date, chemical-agent kits properly as HW

  38. Supply, Storage, Transportation • Substitute less hazardous solvents and cleaning solutions where permitted (use “green” cleaning supplies) • Select items that have less packaging to dispose of • Take leftover items (such as paint or excess parts) to the installation reissue center • Store materials according to MSDS guidelines • Keep a copy of the applicable MSDS for each HM on hand in a binder • Label and date new supplies • Place new supplies to the back of the storage area (First In – First Out) • Avoid stockpiling or keeping items around “just in case they are needed • Keep recycling containers free of trash and garbage • Turn in excess or damaged repair parts and tools as stated in the unit maintenance or supply SOP • Turn in excess paint, solvents, cleaners, and supplies to the installation supply point • Implement a shelf life watch program

  39. Supply, Storage, Transportation (continued) • Purchase cleaning solvents and lubricants in bulk, and refill smaller containers as needed • Recycle materials as required by the installation recycling program • Reuse containers when possible • Dispose of solid waste and HW according to local policy • Purchase cleaning solvents and lubricants in bulk, and refill smaller containers as needed • Transport paint, solvents, cleaners, and other HW and HM safely as required by existing requirements. Ensure that there are proper placards and that appropriate spill-containment equipment is with the vehicle

  40. Refueling Operations • Report spills immediately • Ensure that a properly stocked spill kit and PPE are readily available • Place the refueling nozzle in a drip pan, not on the ground • Place drip pans, diapers, or absorbent material (such as floor sweep) under vehicles when refueling • Place fuel cans in a drip pan for refueling or storage • Ensure that each refueling vehicle has at least two fire extinguishers • Ensure that potable water is available for emergency eye washing • Reuse overpack drums to transfer contaminated soil • Recycle used or contaminated POL products • Dispose of contaminated soil and absorbents according to installation policy

  41. Field Sanitation/Mess • Enforce the use of field latrines instead of expedients such as “catholes” • Collect litter and solid waste at the source (mess site, aid station, or issue point) • Segregate the wastes • Store perishable items (such as food) properly to reduce spoilage • Reuse waste accumulation containers • Ensure that waste accumulation containers have lids that keep out weather and pests

  42. Maneuver Damage Control • Identify environmental risks before going to the field as part of Composite Risk Management • Brief personnel on maneuver damage considerations and minimization measures • Develop a plan to minimize or eliminate environmental risks • Identify areas that contain threatened or endangered species • Observe convoy restrictions • Cross streams and ditches only at approved crossing points • Drive carefully in forested areas to avoid damaging vegetation • Drive only on approved road or trails • Avoid unnecessary noise by not revving engines • Use camouflage netting instead of live vegetation • Reuse wire, barrier materials, and sandbags • Recycle materials at collection points

  43. Weapons/Demo Training • Check with range control for artillery noise-buffer zones near the installation • Check with airfield operations concerning no-fly zones • Adhere to nighttime-gunnery curfews • Keep demolitions below the maximum permissible weight specified by range control • Avoid excessive vehicle noise when homes are located near range roads • Use the forest and the terrain as buffers between noisy training and noise-sensitive areas • Aim firearms away from noise-sensitive areas • Avoid detonating large charges when the wind is blowing from the demolition grounds towards noise-sensitive sites or when temperature inversions are likely to be present • Avoid making noise in the habitat of endangered species • Respect noise-buffer zones and altitude restrictions in forest-service land or other areas of exceptional quiet • Police up all brass and packaging material

  44. Base Camp and Installation Operations • Establishing base camps and occupying existing facilities such as ports and airfields requires extensive integration of environmental considerations. • These sites, sometimes approaching the size of small cities, require tremendous allocations of resources. • They generate waste in quantities similar to small cities, only without the existing infrastructure to support them. • HM/HW management in base camps is a key issue.

  45. Hazardous Material • Any material, including waste, that may pose an unreasonable risk to health, safety, property, or the environment

  46. Common Hazardous Material • Alcohol • Antifreeze • Batteries • Paint • Solvent • Cleaning supplies • Fuel • Super Tropical Bleach • Field sanitation kits • Fuel antifreeze

  47. Hazardous Material Identification • Check the container label. • Check the Material Safety Data Sheet (MSDS). • Check the DOD Hazardous Material Information Resource System (HMIRS). http://www.dlis.dla.mil/hmirs/ • Check with the supply officer, chain of command, installation environmental office (garrison), base camp management team or safety officer. • Call the manufacturer.

  48. Material Safety Data Sheets If you have never seen a MSDS, take a minute to look at one. Page 1 of 7 MATERIAL SAFETY DATA SHEET 1. CHEMICAL PRODUCT AND COMPANY IDENTIFICATION MATHESON TRI-GAS, INC. EMERGENCY CONTACT: 959 ROUTE 46 EAST CHEMTREC 1-800-424-9300 PARSIPPANY, NEW JERSEY 07054-0624 INFORMATION CONTACT: 973-257-1100 SUBSTANCE: DIMETHYL SULFATE TRADE NAMES/SYNONYMS: METHYL SULFATE; DIMETHYL MONOSULFATE; DIMETHYLSULFATE; DMS(METHYL SULFATE); DIMETHYL SULPHATE; SULFURIC ACID, DIMETHYL ESTER; BP-1195; RCRA U103; UN 1595; STCC 4933322; MAT07750; RTECS WS8225000 CHEMICAL FAMILY: organic, sulfates CREATION DATE: Jan 24 1989 REVISION DATE: Jun 17 2004 2. COMPOSITION, INFORMATION ON INGREDIENTS COMPONENT: DIMETHYL SULFATE CAS NUMBER: 77-78-1 PERCENTAGE: 100.0 3. HAZARDS IDENTIFICATION NFPA RATINGS (SCALE 0-4): HEALTH=4 FIRE=2 REACTIVITY=0 EMERGENCY OVERVIEW: COLOR: colorless PHYSICAL FORM: liquid ODOR: faint odor, onion odor MAJOR HEALTH HAZARDS: potentially fatal if inhaled, harmful if swallowed, respiratory tract burns, skin burns, eye burns, mucous membrane burns, suspect cancer hazard (in animals)

  49. General Rules for Managing HM • Use non-hazardous substitutes when possible. • Have an MSDS for every HM. • Do not mix different HM together. • Do not stockpile HM. • Consolidate storage of HM. • Inspect HM storage areas weekly. • Prevent spills. • Ensure availability of PPE. • Follow first in, first out rule. • Implement shelf life program. • Maintain an inventory list.

  50. General Rules for Managing HM (continued) • Ensure labels are legible. • Ensure lids are tight, containers are marked, labeled and visible to the observer. • Provide secondary containment. • Store flammable and reactive materials in accordance with regulations away from the property line. • Secure containers.

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