Advise Commander/Staff on Environmental Hazards

1. Advise Commander/Staff on Environmental Hazards

2. Terminal Learning Objective • Action:Identify environmental risks to personnel and mission prior to field training • Condition:In a garrison environment with appropriate references • Standard:Identify the risks and recommend appropriate controls

3. References AR 200-1, Environmental Protection and Enhancement dated 13 Dec 2007 FM 3-100.4 Environmental Considerations In Military Operations TC 3-34.489, The Soldier and the Environment FM 5-19 Composite Risk Management The Army Strategy for the Environment

4. Agenda • Identify the Army Strategy for the Environment • Identify the sources of environmental laws. • Identify penalties that can be assessed against units and individual Soldiers. • Describe environmental responsibilities of Soldiers, NCOs, and Officers. • Describe environmental risk management planning prior to conducting field training

5. 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

6. Hierarchy of Laws & Regulations • Federal/DoD/Army • State • Local/Installation

7. 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

8. Federal 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.

9. Resource Conservation 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.

10. Clean Water Act 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.

11. Clean Air Act 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.

12. National Historic Preservation Act  National Historic Preservation Act (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”.

13. Endangered Species Act 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. Basra Reed-Warbler Greater Spotted Eagle

14. Noise Control Act  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.

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

16. 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.

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

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

19. Penalties Against Installations and Individual Soldiers • Soldiers • UCMJ actions • Federal action • Penalties up to $32,500/day/per incident • Jail time for a criminal case • Installations • Fines • Damage awards • Increased monitoring • Intervention

20. Soldiers’ Environmental Responsibilities • Comply with unit SOPs, ARs, and environmental laws and regulations • Prevent environmental damage and pollution • Identify environmental risks • Support the Army Sustainability Program • Report hazardous materials and waste spills immediately • Make sound environmental decisions in the absence of supervision

21. NCOs’ Responsibilities • Apply environmental awareness to daily activities • Communicate the Army’s environmental ethic • Commit self to environmental protection • Identify the environmental risks associated with tasks • Plan and conduct environmentally sustainable actions and training • Protect the environment during training and other activities • Analyze the influence of environmental factors on mission

22. NCOs’ Responsibilities - Continued • Integrate environmental considerations into unit activities • Train peers and subordinates • Counsel Soldiers on the importance of protecting the environment • Ensure that Soldiers are familiar with laws, regulations, and SOPs • Incorporate environmental considerations in after-action reviews • Support the Army Sustainability Program • Report hazardous material and waste spills immediately

23. Officers’ Responsibilities • Apply environmental awareness to daily activities • Communicate the Army’s environmental ethic to subordinates • Develop positive commitment to environmental protection in subordinates • Analyze the influence of environmental factors on mission • Integrate environmental considerations into unit activities • Plan and conduct environmentally sustainable actions and training

24. Officers’ Responsibilities - continued • Protect the environment during all activities • Counsel subordinates on the need to protect the environment • Incorporate environmental considerations during AARs • Support the Army Sustainability Program • Report hazardous material and waste spills • Ensure that subordinates comply with unit SOPs, laws, and regulations

25. Composite Risk Management Process  Assessing environmental related risks is part of the composite risk management process, and is a critical component of the MDMP.  FM 5-19 outlines the risk management process and provides the framework for making risk management a routine part of everyday tasks.

26. Tactical and Accident Risk Tactical risk is risk concerned with hazards that exist because of the presence of either the enemy or an adversary. Accident risk includes all operational risk considerations other than tactical risk. It includes risk to friendly forces.

27. Environmental Benefits of Risk Management  Identify applicable environmental standards, laws, and ROE that affect the mission.  Ensure the health and welfare of personnel.  Identify alternate COAs that meet the intent of the law and operational requirements.  Ensure better use of limited resources  Minimize or eliminate damage to natural and cultural resources.

28. Identify Hazards 1 METT-TC Hazards Environmental Hazards Tactical and Accident Risks Assess Hazards Implement Controls 2 4 Develop Controls Make Decisions Supervise and Evaluate 5 3 Composite Risk Management Process The Five Step Risk Process.

29. CRM Worksheet

30. Step 1: Identify Environmental Hazards Identify environmental related hazards during mission analysis Hazards are defined as any actual or potential condition that can cause injury, or illness or death of personnel; damage to or loss of equipment or property; or mission degradation.

31. Common Environmental Hazard Areas Soils Noise/Air Archaeological

32. Common Environmental Hazard Areas Water Threatened/Endangered Species

33. Step 2: Assess Hazards To Determine Risk Risk assessment is a three stage process used to determine the risk of potential harm to the environment. Stage 1. Assess the probability of each hazard. Stage 2. Assess the severity of each hazard. Stage 3. Determine the risk level of each hazard.

34. Risk Assessment Matrix Table 4. Risk Assessment Matrix E - Extreme H - High M - Moderate L - Low

35. Step 3: Develop Controls And Make Risk Decision • Develop controls to eliminate or reduce the probability or severity of each hazard, thereby lowering the overall risk. Controls are developed and annotated them on the worksheet, and consist of one of the following categories:  Educational  Physical  Avoidance

36. Residual Risk Once all feasible risk control measures are in place, some risk will always remain. This residual risk requires leaders’ attention. The necessary steps are: • Determine the residual risk for each hazard by applying the risk assessment matrix. • Enter the residual risk level for each hazard on the worksheet.

37. Step 4: Implement Controls  Inform subordinates, down to individual Soldier level, of risk control measures.  State how each control will be implemented and assign responsibility.  Annotate the “how to” of each of the controls on the worksheet.

38. Determine Overall Risk  Select the highest residual risk level and circle either Low, Moderate, High or Extreme on the worksheet.  This level becomes the overall mission risk.

39. Step 5: Supervise And Evaluate Leaders and staffs continuously monitor controls throughout the operation to ensure their effectiveness and to modify controls as required. They make on-the-spot corrections, evaluate individual and collective performance and hold those in charge accountable.

40. Checklist of Actions Before Training GENERAL Appendix A, TC 3-34.489 • Are environmental considerations part of training conditions and standards? • Are leaders including the environment in the METT-TC process? • Are forecasted weather considerations included in planned training? • Are alternate missions planned?

41. Checklist of Actions Before Training TRAINING AREA • Has range clearance been obtained? • Range briefing received, Range SOP on hand? • Have special land use permits been obtained? • Are areas of environmental concern verified during site reconnaissance? • Have leaders reviewed previous notices of violation, AARs, and lessons learned?

42. Checklist of Actions Before Training • PERSONNEL PREPARATION • Do Soldiers understand their responsibilities in reducing generation of hazardous waste and minimizing damage to the environment? • Have all Soldiers been briefed on range restrictions, endangered species, the use of camouflage, archeological sites, and other sensitive environmental resources? • Are identified environmental risks/controls discussed in unit training meetings? • Are transporters of hazardous material trained according to DOT standards?

43. Checklist of Actions Before Training • TRAINING PREPARATION • Has a Composite Risk Assessment been performed? • Are rehearsals conducted to ensure that all safety and environmental considerations are satisfied? • Has the environmental protection portion of the unit’s SOP been reviewed/updated, especially the areas concerning spill response and reporting? • When the unit transports hazardous materials (explosives and petroleum, oil, and lubricants (POL)), are the materials checked to ensure that they are properly labeled and that a MSDS is present for each substance?

44. Checklist of Actions Before Training • TRAINING PREPARATION – continued • Are provisions made for all waste streams during the training? • Are special provisions made for handling medical wastes? • Are needed tools, equipment, and materials available to respond to environmental emergencies? • Are personnel designated and trained for the spill response team(s)? • Are team members aware of the procedures for requesting additional spill assistance if required? • Is spill prevention training documented?

45. Checklist of Actions Before Training • CHAIN OF COMMAND • Have the Battalion Commander, CSM and the S3 been briefed on the plan? • Does the OPORD have an environmental annex or appendix? • Does this contain contact info for spills? Does it include off post contact info? State(s) contacts? • Is there a transportation annex to the OPORD with this information? • Does the unit have spill report forms on hand?

46. Unit Checks Before Training • Environmental concerns incorporated into SOPs, orders, and OPORDs • Procedures for hazardous waste rehearsed/checked • Map recon conducted • Risk assessment completed • Leaders briefed before the exercise • PMCS on vehicles conducted • Risks discussed in training meetings • Chain of command briefed • Environmental teams trained • Received range control guidance on waste turn in • First Sergeant counseled NCOs

47. Checks During Training • CATEGORIES Chapter 5, TC 3-34.489 • General • Vehicle movement • Wetlands/water courses • Threatened/endangered species • Cultural resources • Camouflage • Waste disposal • Hazardous material and waste • Refueling • Maintenance

48. Checks After Training • Chapter 5, TC 3-34.489 • Vehicles washed properly • Fighting positions refilled • Commo and barrier wire collected • Area properly policed • Spills located, contained, and reported • Leaders inspected area • Soldier’s proficiency assessed • Environmental concerns addressed in unit evaluation and AAR

49. The After Action Review • Identify procedures that must be changed to correct negative environmental practices. • Identify additional training requirements for the unit and individual Soldiers. • Identify actions that illustrate support of the Army Sustainability Program.

50. Positive Practices • Personnel are briefed before movement • Convoy speeds are enforced • Drip pans are used under vehicles • Existing road systems and secondary trails are used • Existing camouflage – tree outline is used • Camouflage netting is used • Existing excavations are used • Excavations are filled in at completion of training • Construction materials are carried to the field for fighting positions and overhead cover • Secondary containment is available for containers of used oil, antifreeze, and other fluids