Chapter 4
Establishing the Command Environmental Program
Whether conducting operations on a training installation, supporting a disaster recovery mission, or conducting contingency operations, the military's actions impact the environment and the environment impacts the mission. The Army and the Marine Corps manage millions of acres of land that may be scrutinized by public regulators, Congress, or the courts. The military needs that land to conduct training and other mission activities. In addition, there is the very practical need to sustain environmental resources in a manner that supports the mission and provides a high quality of life for our Soldiers and Marines; their families; and others that live on, work on, or visit those facilities. As well as sustaining resources on installations, the military must protect and sustain resources in foreign nations during deployments and contingency operations. The military also has legal requirements to conserve, protect, and restore natural and cultural resources while accomplishing its mission. By integrating proper environmental management into the mission, the military not only complies with federal, state, local, and foreign nation regulations but also enhances its mission through sustaining operations and realistic training conditions.
FOSTERING ENVIRONMENTAL STEWARDSHIP
4-1. Fostering environmental stewardship and sustainability in units provides a framework for Soldiers and Marines to integrate environmental considerations into daily operations. When Soldiers and Marines automatically analyze environmental impacts and keep environmental issues in mind, they avoid adverse actions and conditions. The command climate of a unit is the basis for fostering a sound environmental ethic.
COMMAND CLIMATE
4-2. From every philosophical or moral perspective, environmental stewardship and sustainment is the right thing to do. As humans make more demands on the shrinking resource base, ethical issues become clearer. Senior leaders must create ethical climates in which subordinate leaders recognize that the natural resources of the earth are exhaustible, that the environment has an impact on human health, and that they must take responsibility to protect the environment. This ethical climate also guides decisions in areas such as the law of land warfare. Ethical behavior is not restricted to the letter of the law when it comes to specific written laws, regulations, and treaties. Instead, it captures the ethos that generated those laws in the first place. By educating subordinates and setting the example, leaders enable their subordinates to make ethical decisions that in turn contribute to excellence.
4-3. Acknowledging considerations for environmental protection during training, operations, and logistics activities reduces environmental damage and costs. Consistently protecting the environment ensures that land will continue to be available to conduct realistic training and environmental problems will not disrupt operations. In short, environmental considerations must be instilled as an institutional and personal ethic. To be successful, the military must incorporate environmental considerations as a proactive measure rather than a reaction to laws and regulations. Commanders must train their subordinate leaders on stewardship and sustainability, counsel them on doing what is right, lead by example, and enforce compliance with laws and regulations.
4-4. Commanders must promote an ethical climate to ensure that subordinates make good decisions concerning environmental issues. Routine decisions may be as simple as emptying a bucket of solvent onto the ground or carrying it to an appropriate accumulation point. A commander must encourage his subordinates to make ethical decisions by ensuring that each of them ask the following questions when confronted with an environmental dilemma:
• What are my orders? Look to leaders for guidance and ensure that you understand what they expect. If instructions are unclear or confusing, ask for help. Review unit SOPs for environmental guidance.
• What have I been trained to do? Ask this question in the absence of specific orders or guidance.
• What does my concept of right and wrong tell me to do? Ask this question in the absence of training and orders. Most personnel know when an action will harm the environment. Do not perform environmentally related tasks without the proper guidance, especially if you have not been trained on the task or you doubt it is correct.
POLICY
4-5. Commanders establish a command environmental policy (see appendix I) to set forth procedures and responsibilities for integrating environmental considerations into planning and operations. Command policies help ensure that all military personnel and civilians in the unit make informed decisions regarding compliance with laws and regulations.
STANDING OPERATING PROCEDURES
4-6. SOPs provide units with standardized procedures for the execution of routine actions. Units develop SOPs that contain a detailed list of actions that are necessary to fulfill the daily environmental responsibilities of the unit to maintain environmental compliance with federal, state, local, and foreign nation laws and regulations (see appendix J).
ESTABLISHING THE PROGRAM
4-7. A unit's command environmental program is the basis by which unit commanders ensure that their personnel adhere to laws, regulations, and procedures and promote the sustainable use of natural resources. In addition, command environmental programs help to ensure that proper techniques and procedures are implemented and that unit members receive proper environmentally related training.
ESTABLISHING A UNIT-LEVEL PROGRAM
4-8. To establish effective unit environmental program requirements, the unit leader should-
• Assess the unit to understand the activities that affect the environment and the state of the command environmental program.
• Ensure that all unit personnel have had environmental awareness training.
• Designate an environmental officer who is properly trained and qualified. The Marine Corps has a specific military occupational specialty (MOS) 9631 (Environmental Engineering Management Officer) who deals with environmental matters. These individuals interface with appropriate environmental personnel and ensure that their units comply with environmental laws and regulations. Appendix H provides an example.
• Meet with key higher-unit staff counterparts (operations staff officer [S-3]/logistics staff officer [S-4] for a battalion-size organization), installation, and base camp personnel who deal with environmental issues. Find out their requirements concerning environmental training, qualifications, and certification of unit personnel; the Environmental Performance Assessment System (EPAS) (defined as the examination of an installation's environmental program review to identify possible compliance deficiencies [the definition was shortened, and the complete definition is printed in the glossary]) inspections affecting the unit and common environmental problem areas; and problem avoidance.
• Ensure that the unit SOP addresses environmental issues and procedures applying to the unit (coordinate environmental requirements with appropriate installation/chain-of-command personnel). Appendix J provides an example.
• Conduct environmental risk assessments before training and deployment operations.
4-9. The following are common unit, installation, and base camp environmental programs that commanders establish:
• HAZCOM.
• HM management.
• HW management.
• POL management.
• P2 and HW minimization.
• Recycling program.
• Spill prevention and response training.
• Sustainable range program.
TRAINING
4-10. The best use of available resources toward adequately training selected groups or individuals will positively impact quality of life, sustainment efforts, and unit compliance status. Personnel should know how to accomplish their tasks in a manner that has no or minimal impact on the environment, while complying with environmental regulations. Army Regulation (AR) 200-1 and Marine Corps Order (MCO) P5090.2A require that the military provide training to appropriate personnel and maintain training and certification records according to governing laws and regulations.
4-11. Many environmental laws require specific training requirements for personnel performing certain tasks or activities. These details are normally within federal or state regulations, which usually include refresher training requirements and specific recordkeeping. Sometimes the qualifications of the trainer are specified in the regulations. Required training types include the following:
• HW generators and accumulation points, shipping, and permitted storage or waste treatment.
Annual training is required.
• Packing, receiving, transporting, and certifying HM shipments. Refresher training is required every two years.
• Working with hazardous or toxic chemicals (except for personnel performing military-unique tasks). Some specific chemicals require training even if workers are infrequently exposed to the hazards. Initial training must be supplemented if hazards change.
• Uncontrolled HW site investigations and cleanup. Annual training is required for individuals working, visiting, or supervising workers at these sites.
• Asbestos demolition and removal, maintenance, and repair work involving asbestos disturbance and asbestos sampling. Refresher requirements vary.
• Exposure to lead-based paint during building maintenance, repair, demolition, or removal.
Refresher requirements vary.
• Discovery and response to spills of oil or hazardous substances. Annual training is required.
ENVIRONMENTAL PROGRAMS
4-12. Units are required to implement or establish training for a variety of environmental programs to ensure that their units meet the necessary requirements and promote sustainability. The extent of these programs will vary with the nature of the unit and the unit's specific requirements, along with the requirements of the installation or base camp where the unit is located.
HAZARD COMMUNICATION
4-13. An effective HAZCOM program will assist leaders in determining what hazardous chemicals are present in their units, how to protect their personnel from hazards those chemicals present, and how to properly store and use those chemicals. The installation or base camp safety officer is the point of contact for most HAZCOM matters, the MSDS program, and the HAZCOM training program.
Key References
4-14. The following laws and regulations are source documents that support the HAZCOM program:
• AR 40-5.
• AR 385-10.
• AR 700-141.
• Part 1910, Title 29, Code of Federal Regulations (CFR) (29 CFR 1910).
• United States Army Center for Health Promotion and Preventive Medicine (USACHPPM) Technical Guide (TG) 217.
• Technical Bulletin (TB) Medical (MED) 593.
Unit Actions
4-15. In support of HAZCOM, unit leaders should-
• Ensure that their subordinates receive adequate training on the HM to which they are exposed, according to the Occupational Safety and Health Standards, Occupational Safety and Health Administration (OSHA) requirement.
• Maintain an up-to-date list of all HM/HW known to be present in the area.
• Ensure that containers of hazardous chemicals are labeled, tagged, or otherwise marked to identify the material and warn personnel of hazards.
• Maintain an MSDS for every HM in the unit (see Appendix K).
• Ensure that personnel are trained to recognize, understand, and use the MSDS and labels for the HM to which they are exposed.
• Ensure that personnel use proper procedures when working with hazardous chemicals and wear PPE.
• Refer to applicable HAZCOM references.
HAZARDOUS MATERIALS MANAGEMENT
4-16. The military's objective is to minimize health hazards and environmental damage caused by the use and misuse of HM. Hazardous material is defined as any substance that has a human health hazard associated with it; special storage, use, handling, and shipment safety procedures and protocols must be followed to help protect against accidental exposure; hazardous materials are specifically identified under federal law. It is a material that, due to its 1) quantity; 2) concentration; or 3) physical, chemical, or infectious characteristics, may-
• Cause or significantly contribute to an increase in mortality in serious, irreversible, or incapacitating reversible illness.
• Pose a substantial present or potential hazard to human health or the environment when improperly treated, stored, transported, disposed of, or otherwise managed.
Key References
4-17. The following source documents provide guidelines for the proper handling of HM:
• AR 200-1.
• AR 700-141.
• AR 700-68.
• MCO P5090.2A.
• 29 CFR 1910.
• Part 761, Title 40, CFR (40 CFR 761).
• Technical Manual (TM) 38-410.
• USACHPPM TG-217.
• DOD 4715.05-G.
Unit Actions
4-18. To effectively manage HMs, leaders should-
• Ensure that the best management practices are followed for all HM.
• Comply with all applicable regulations, policies, inspections/evaluations, and procedures.
• Order and use only what is required; do not stockpile HM.
• Use nonhazardous substitutes to the maximum extent practicable.
• Conserve resources through recovering, recycling, and reusing.
• Maintain records of all material on hand, received, or issued, to include MSDSs.
• Report HM use, storage, and acquisition by established policy.
• Establish procedures to identify and correct management deficiencies.
• Establish a training program and ensure that required personnel are properly trained.
• Ensure that drivers transporting HM are qualified. According to DOT HM 181 and 126F (see 49
CFR), transporters of HM must (by law) be trained.
• Ensure that adequate spill prevention and control equipment is on hand.
• Coordinate training requirements with the chain of command and the environmental management or safety office.
• Ensure compliance with special disposal and turn-in procedures for batteries.
• Establish HM spill procedures.
• Establish HM fire/explosion procedures.
• Establish emergency first aid procedures.
• Ensure that adequate protective equipment is available.
• Refer to applicable HM references.
HAZARDOUS WASTE MANAGEMENT
4-19. The presence of HW is a cause for concern among installationlbase camp personnel and nearby residential populations. However, hazardous chemicals are an unavoidable part of military activities and ultimately result in some waste generation. The proper handling and disposal of these wastes will minimize hazards and ensure the safety of people and the environment.
Key References
4-20. The following laws and regulations are source documents that provide guidelines for properly handling and disposing of HW:
• AR 200-1.
• MCO P5090.2A.
• Department of Defense Instruction (DODI) 4160-21-M.
• 29 CFR 1910.
• Parts 259, 260-281, 300-302, 761; Title 40; CFR (40 CFR 259, 260-281, 300-302, 761).
• Parts 106-178, Title 49, CFR (49 CFR 106-178).
• USACHPPM TG-217.
• TB MED 593.
Unit Actions
4-21. When a unit generates HW, it must take the following actions:
• Establish an HW management program to comply with HW regulations.
• Identify HW properly. Label accumulated waste and the containers that hold HW with the correct hazard warning labels. Inspect containers for leaks, corrosion, or damage.
• Ensure that wastes do not accumulate beyond allowable quantity and time limits. Ensure that accumulation areas contain secondary containment.
• Maintain records of all material on hand, received, or issued.
• Employ HW minimization techniques as a part of P2 efforts.
• Comply with off-post HW transportation requirements. Public road use increases transportation requirements. Contact and coordinate with the installation Directorate of Logistics (DOL) or Facilities Management Office and the Defense Reutilization and Marketing Office (DRMO).
• Ensure that drivers transporting HW are qualified. According to DOT HM 181 and 126F, transporters of HM must (by law) be trained.
• Establish an HW training program and ensure that personnel attend proper training. Most installations conduct HW train-the-trainer programs.
• Maintain a liaison with key chain of command and installationlbase camp personnel.
• Ensure that unit personnel use their PPE when handling HW.
• Ensure that adequate spill prevention and control equipment is on hand.
• Establish HW firelexplosion procedures.
• Establish HW spilllleak procedures, and ensure that the unit conducts drill procedures annually, at a minimum.
• Establish emergency first aid procedures.
• Ensure that unauthorized storage or disposal of HW does not occur. HW must be stored only in authorized containers and disposed of as directed by the environmental management office, DRMO, or as directed in the OPORD (for contingency operations).
PETROLEUM, OIL, AND LUBRICANTS MANAGEMENT
4-22. Requirements for POL are an unavoidable consequence of modern military operations. Products sustaining the military each day (such as motor oils, paints, cleaning compounds, and aircraft fluids) are
significant health, safety, and environmental issues and management challenges. At a minimum, personnel must know how to handle, transport, and dispose of POL products.
Key References
4-23. References for managing POL products are similar to those applicable to HM/HW, HAZCOM, P2, HW minimization, recycling, and spill prevention and response. They also include CFR (40 CFR 110, 112, and 302); FM 10-67; FM 10-67-1; Parts 110, 112, and 302 (Hazardous Substances); and Title 40.
Unit Actions
4-24. The following actions are required when receiving, storing, and using POL products:
• Requisition only the amount of POL products required.
• Practice inventory control, to include monitoring (defined as the assessment of emissions and ambient air quality conditions [the definition was shortened, and the complete definition is printed in the glossary]) HM shelf life and HW accumulation dates.
• Store POL products in approved containers and locations.
• Maintain an MSDS for each POL product.
• Provide proper PPE for products handled by personnel.
• Supply labeled 55-gallon liquid-waste containers for the following waste streams:
• Used oil.
• Waste fuel.
• Waste antifreeze.
• POL-contaminated solids.
• Ensure that adequate spill prevention and control equipment is on hand.
• Ensure that adequate secondary containment exists for HM/HW storage facilities.
• Ensure that containers are properly marked and in good condition.
• Provide drip pans for vehicles and refueling operations.
POLLUTION PREVENTION AND HAZARDOUS WASTE MINIMIZATION
4-25. This program complements the HM, HW, and HAZCOM programs. HW minimization reduces the amount and toxicity of the HW generated or produced. P2 reduces the amount of material, hazardous or not. For example, recycling reduces the amount of trash that goes into landfills. The reduction in waste supports deployment operations by reducing transportation, storage, and landfill requirements and helping to reduce financial liability resulting from claims against U.S. forces.
Key References
4-26. P2 and HW minimization references include the following:
• AR 200-1.
• MCO P5090.2A.
• Executive Order (EO) 12856.
• Section 41, Part 262, Title 40, CFR (40 CFR 262.41).
• Pollution Prevention Act.
Unit Actions
4-27. Unit leaders should ensure that their units conduct proper inventory control. A unit should not stockpile HM. If an HM has an expired shelf life, it can cost much more to dispose of the item than it did to obtain it since the HM will have to be handled as an HW.
4-28. Product substitution is an easy way to reduce the HW a unit generates. Unit personnel should review the HM inventory in their areas and check to see if nonhazardous or less hazardous substitutes are available. Examples are using biodegradable degreasers instead of solvents or replacing the sand used in sandblasting operations with plastic beads, which last longer and can be recycled.
4-29. A process change can reduce the amount of HW generated. For example, a vapor degreaser could be replaced by a soap and hot water parts cleaner.
RECYCLING PROGRAM
4-30. Source reduction is the decrease of hazardous waste generation at its sources. This reduction is to be achieved through product substitution, recycling, and inventory control and by developing new industrial processes that use less hazardous materials, such as bead blasting rather than solvents to remove paint. The military promotes 1) separating products, substituting materials, and changing procedures to avoid using hazardous substances and 2) recycling to reduce the volume of solid waste. Most permanent installations have a recycling program that units should incorporate into their SOPs. While recycling programs during contingency operations may be minimal, most established base camps will develop programs to recycle Class II and Class IV materials.
Key References
4-31. The following references provide the basis for recycling programs:
• AR 200-1.
• MCO P5090.2A.
• EO 13101.
Unit Actions
4-32. To support the recycling program, unit personnel should-
• Recycle all recyclable materials. Recyclable materials include computer printouts (after ensuring all sensitive material is shredded), corrugated cardboard, card stock, newspaper, high-grade white paper, aluminum cans, plastics, oil, solvents, glass, steel, and brass. Check with the installation environmental office to verify the material recycled locally.
• Separate materials to be recycled by type.
• Refer to applicable recycling references.
SPILL PREVENTION AND RESPONSE PLANNING
4-33. It is military policy and a Clean Water Act requirement to prevent oil and hazardous-substance spills and to provide prompt response to contain and clean up spills. A spill response plan must be available at each operation storing or accumulating HM/HW, such as maintenance facilities, supply activities, and tactical-refueling areas. The plan should address, at a minimum, site-specific response procedures and spill response equipment requirements for each operation. Exceptions will be made in cases of extreme emergency, where the discharge is-
• Considered essential to protect human life.
• Authorized by a discharge permit or installation on-scene coordinator during a spill incident response.
Key References
4-34. The following references are applicable to spill prevention and response plans:
• AR 200-1.
• MCO P5090.2A.
• 40 CFR 110.
• 40 CFR 302.
• Part 355 (Extremely Hazardous Substances), Title 40, CFR (40 CFR 355).
• TB MED 593.
Unit Actions
4-35. Units should take every reasonable precaution to prevent oil and hazardous-substance spills. The unit leader should-
• Provide facilities that store, handle, or use oils and HMs, and implement proper safety and security measures.
• Appoint (in writing) a spill coordinator and members of the unit spill response team.
• Maintain an up-to-date spill response plan. This requirement is generated by the installation.
• Conduct appropriate training and periodic spill response drills.
• Ensure that sufficient equipment and supplies (PPE and absorbent materials) for spill responses are on hand and pre-positioned in the unit.
• Locate all drains, drainage ditches, streams, ponds, and other water sources/outlets in the area, and plan how to prevent a spill from reaching them.
• Coordinate with the installation safety office, preventive medicine office, and environmental management office to determine proper PPE. Know when to attempt to clean up a spill and when to leave the area and contact the installation spill response team for cleanup. The installation environmental management office or installation on-scene coordinator will determine when to dispatch a spill response team.
• Maintain a copy of the installation spill contingency plan. This plan, available from the environmental management office, contains critical/necessary information.
• Maintain a current point of contact list of who to contact in case of an emergency (for example, the fire department, safety office, provost marshal, preventive medicine, and environmental management office).
• Maintain an up-to-date inventory of all HM/HW, and provide a copy to the installation fire department for use in case of a chemical fire.
• Ensure that pollutants are not discharged into storm or wash rack drains or poured on the ground.
• Ensure that small spills are properly attended to, cleaned up, and collected and disposed of.
• Strictly control the discharge of ballast water from watercraft.
• Ensure the management of waste or used oil complies with all applicable federal, state, and local requirements.
• Ensure that wastes produced during the cleaning of fuel storage tanks and combustion engine components are collected and managed as required before disposal.
• Monitor wastewater discharges containing oil or hazardous substances to comply with permit limits.
• Ensure that oil, fuel, or other hazardous pollutant spills are reported to the environmental management office and higher hea