HAZARDOUS AND SPECIAL WASTE
4–1. Classification
a. Hazardous waste. Hazardous waste is a regulatory term for certain discarded materials that are potentially harmful to human health or the environment. Examples of common HWs found in field settings include used solvents, compressed gas cylinders, and contaminated soil from fuel spills. Subtitle C of the Resource Conservation and Recovery Act (published in 40 CFR 260-280) governs CONUS HW management and serves as the foundation for OCONUS standards.
b. Special waste. Special wastes are discarded materials that do not meet the criteria for classification as an HW, but still pose hazards to human health or the environment. Units must often manage special wastes separately from regular trash. Examples include used oil or antifreeze collected for recycling, alkaline batteries, and asbestos-containing materials.
4–2. Training
Commanders must ensure all personnel assigned duties involving actual or potential exposure to HW receive training according to AR 200-1. Personnel need only receive training in the areas that relate to their specific duties. The USACHPPM points of contact listed in paragraph 1–5 of this TB MED can provide assistance in satisfying these training requirements.
a. Content. Hazardous waste training must prepare personnel to safely perform their assigned duties and comply with applicable HW requirements. Training must be conducted by qualified trainers who have completed an instructor training program in the subject, or have comparable academic credentials or experience. Commanders may also approve computer-based programs to provide training. At a minimum, HW training must cover: site-specific safety and health hazards, proper waste management procedures, spill response and cleanup, personal protective measures, emergency procedures and equipment usage, and recordkeeping requirements.
b. Frequency. Personnel must receive initial training prior to assumption of HW handling duties. Refresher training for these employees must occur annually.
c. Documentation. Hazardous waste training records must include the following information: employee name, job title and description, description of type and amount of initial and refresher training, and proof of training (such as a course completion certificate). Supervisors must maintain training records for at least 3 years after termination of duty of these personnel.
4–3. Identification
Classification of hazardous and special waste is based on the harmful chemical or physical properties of the discarded items. A good rule of thumb is if a discarded item is HW in garrison, it will be HW in the field.
a. Criteria. The specific criteria used to identify HWs are found in 40 CFR 261. State regulations and FGS may add to these criteria. Generally, in order for an item to be considered an HW, it must either be listed in 40 CFR 261 Subpart D or exhibit one or more of the following characteristics:
(1) Ignitability. Liquids with flash points <140°F(60°C).
(2) Corrosivity. Liquids with pH readings ≤2 or ≥12.5.
(3) Reactivity. Items capable of explosion or detonation, or that react violently with water.
(4) Toxicity. Substances whose toxicity test results meet or exceed regulatory levels listed in Table 1 of 40 CFR 261.24.
b. Sources of information. Several sources of information exist that are helpful in determining the harmful characteristics of a material and whether or not it becomes a hazardous or special waste when discarded. Examples include:
(1) Material Safety Data Sheets (MSDSs). Manufacturers create MSDSs for each hazardous material (HM) they produce. These data sheets provide information on the characteristics of specific materials such as flash point, pH, concentration, and toxicity. Many MSDSs also provide detailed disposal information. Manufacturers should provide copies of MSDSs with each shipment of HMs and/or make them available online.
(2) Hazardous Materials Information Resource System (HMIRS). The HMIRS is a database containing MSDSs for military supply items (figure 4–1). The DLA maintains this system and allows users to search for product information by several means such as by nomenclature or National Stock Number (NSN). The database is accessible online at http://www.dlis.dla.mil/hmirs/default.asp
(3) Military Item Disposal Instructions (MIDI). The MIDI database provides detailed disposal guidance for thousands of military items, including medical supplies. Like HMIRS, this system provides multiple search options. The MIDI, however, classifies each listed item as HW or non-HW and provides specific disposal information. A CD-ROM version of the database is published annually and is available from the USACHPPM at phone 1–800–276–MIDI. The MIDI database is also available online at http://chppm-www.apgea.army.mil/newmidi/.
(4) USACHPPM. Additional technical guidance is available from the USACHPPM Hazardous and Medical Waste Program at phone 410–436–3651/DSN 584–3651 or electronically at http://chppm-www.apgea.army.mil/hmwp/.
4–4. Collection
The keys to proper waste collection are use of PPE, segregation, containerization, and marking.
a. PPE. Evaluate the need for PPE before handling any HM/HW. Safety equipment such as goggles, gloves, and protective footwear may be necessary to protect handlers from injury or harmful exposure. When selecting PPE, consult MSDSs and use professional judgment regarding the hazardous properties of the waste. It is important to note that PPE will not protect personnel from external gamma radiation exposure. Workers should clean or dispose of contaminated PPE as soon as possible after use. Remember to characterize contaminated PPE using the criteria described in paragraph 4–3 to determine if this equipment must be managed as an HW.
b. Segregation. Manage HW separately from trash and other solid wastes—mixing HW with non-HW violates environmental regulations, complicates turn-in procedures, increases disposal costs, increases potential health risks, and could result in dangerous chemical reactions.
c. Containerization. The best choice for containers is often the original container the material was shipped in prior to it being rendered a waste. If the original container is not available or the waste volume exceeds the capacity of the original receptacle, use any container that is in good condition (free from severe rusting, bulging, dents, or structural defects) and compatible with the waste. If reusing a container, remove or spray paint over markings that do not apply to the waste inside. Containers used to collect HW must also be kept closed when not adding or removing waste. When filling a container with liquid hazardous or special waste, ensure adequate headspace remains to allow for expansion of the material (about 3 inches in a 55-gallon drum, 2 inches in a 5-gallon can, and 1 inch in a 1-gallon can). Funnels or other flow control devices should be used to minimize spills when transferring liquids to or from containers. However, funnels must be removed and containers closed after the transfer is complete. Additionally, ignitable wastes should only be collected in grounded metal containers, and corrosive wastes should only be collected in plastic or plastic-lined containers.
d. Marking. Mark each container of hazardous or special waste with words that identify the contents, such as “Used Oil” or “Contaminated Soil” (see figure 4–2). Labels or words that identify the hazards of the material (such as “Ignitable”) and the name of the generating unit (such as A/4/13 INF) should also be placed on the outside of the container. Unless required by local policy, dates should not be placed on HW containers until the waste exceeds 55 gallons or until the container is moved to a consolidated storage area.
4–5. Storage
A collection site is considered a storage area when it contains more than 55 gallons of HW. In general, waste should not be stored longer than 1 year in an HW storage area, and should follow the guidelines presented in TM 38-410. In the United States, permits are normally required to store wastes onsite longer than 90 days.
a. Location. The logistics staff (S-4/G-4/J-4) should identify locations for waste consolidation and storage during the pre-deployment or planning phase of an operation. Safety and security are two important factors to consider when choosing a site. Planners must realize intentional attacks, as well as accidents during normal handling, could lead to harmful chemical releases or explosions. As a result, units must consider the sensitivity and vulnerability of areas adjacent to storage locations (such as billeting, work areas, and ammunition supply points). Whenever possible, locate waste storage areas at least 300 feet downslope and downwind from troop billeting and at least 100 feet from wells, surface water, and base camp boundaries. Provide protection from the sun and rain whenever possible, and avoid storing HW in low lying areas that may flood during heavy rains. Storage site managers should also use control measures such as signage (for example, "Danger: Unauthorized Personnel Keep Out”) and fencing to restrict access to the sites. Warning signs should be written in English and any other language predominant in the area.
b. Secondary containment. Provide secondary containment (any physical barrier used to prevent the spread of spills) for all waste containers. Common examples of secondary containment include plastic tubs, sumps, concrete pads with curbs to prevent runoff, spill-control pallets, and plastic-lined pits or trenches. Another option is to place containers of waste on a large plastic tarp and stack filled sand bags around the perimeter. To maximize containment, the edges of the tarp should be draped over the top of the sand bags and folded back into the storage area. Whatever method is used, secondary containment should have sufficient capacity to contain 10 percent of the total volume or 100 percent of the volume of the largest container, whichever is greater. Overhead cover (such as a tarp or a roof) should also be used to prevent rainwater from collecting in secondary containment devices.
c. Segregation. Store waste containers in a manner that will prevent contact of incompatible wastes in the event of a leak or spill. Consult MSDSs and TM 38-410 for detailed information concerning chemical compatibilities of a substance. At a minimum, storage areas should segregate waste containers into five sections: reactives, ignitables (flammables), corrosives, oxidizers, and toxics. Further segregation may be required based on the compatibility of individual materials (for example, acids should be separated from bases). Each storage section should be separated by a distance of 6 feet or a physical barrier (such as a berm) to prevent incompatible wastes from mixing and producing a harmful chemical reaction or toxic vapors. In areas containing ignitable or reactive wastes, “No Smoking” signs should be prominently displayed, and all metal containers should be grounded.
d. Containers. Containers in waste storage areas must comply with the marking requirements cited in paragraph 4–4d of this chapter. In addition, HW containers must be marked with the date of arrival at the storage area and the words “Hazardous Waste.” Containers should be stored so labels are facing out to allow for easy inspection. All waste at HW storage areas should also be stored in containers approved for HM transport. These containers will normally bear United Nations (UN) specification markings, which can be interpreted by someone certified in HM transport. An example of a UN specification marking is shown in figure 4–3. Ordering information for common UN-approved containers can be found in table 8–1.
e. Emergency preparedness. Each HW storage area must contain appropriate equipment (such as a communication/alarm system, properly rated fire extinguishers, nonsparking shovels, gloves, plastic bags, PPE, potable water for eye washing and decontamination, and spill kits) to respond to onsite emergencies. See table 8–1 for supply ordering information. Supervisors must develop a written emergency response plan that describes the proper use and location of this equipment, and details employee responsibilities during an emergency. A written copy of this plan must be maintained at each storage area.
f. Inspections. Storage area managers must inspect their waste storage areas weekly to ensure all requirements described in paragraphs 4–5a through 4–5g of this chapter are being met and containers are in good condition. Inspectors must take immediate action to correct any deficiencies noted. Managers must also maintain records of weekly inspections. At a minimum, these records must include the date and time of inspection, the name of the inspector, a notation of the observations made, and the date and nature of any repairs or other remedial actions. See figure 4–4 for a sample format that may be used to record weekly inspections.
g. Recordkeeping. In addition to weekly inspection reports, each storage area manager must maintain a log of the types and quantities of waste received, the dates of arrival at and departure from the storage area, and the names of the units that generated the waste. Maintain all HW management records for at least 3 years.
4–6. Transportation
Hazardous and special waste shipments must comply with all HM transportation requirements.
a. Packaging. Package, mark, and label all HW shipments according to 49 CFR 171-185. Additionally, HW transported by military aircraft must comply with the Air Force Manual (AFMAN) 24-204(I).
b. Documentation. Some form of documentation must accompany all shipments of hazardous and special waste. When transporting HW over public roads in the United States, a U.S. Environmental Protection Agency or state-approved HW manifest must accompany each shipment. For all other waste shipments (to include HW shipments that remain within or along the border of a military installation), acceptable types of documentation include DD Form 836 (Dangerous Goods Shipping Paper/Declaration and Emergency Response Information for Hazardous Materials Transported by Government Vehicles/Containers or Vessel), DD Form 1348-1A (Issue Release/Receipt Document), DD Form 1348-2 (Issue Release/Receipt Document with Address Label), DA Form 3161 (Request for Issue or Turn-in), a Bill of Lading, or applicable host nation form.
c. Vehicles. The preferred means of transporting hazardous and special wastes is by highway or maritime vessel. Privately-owned vehicles must not be used to transport HMs of any kind, to include HW. Vehicles used to deliver HMs to units may also be used to transport or retrograde wastes. These vehicles are subject to the placarding requirements described in 49 CFR 172 (or host nation requirements) and should contain spill response equipment. Vehicles used to transport radioactive wastes must be surveyed by a Radiation Safety Officer or nuclear, biological, and chemical (NBC) personnel after each use to assess any residual contamination. The vehicle may not be used for transporting nonradioactive materials until cleared by the Radiation Safety Officer or NBC personnel.
d. Training. Personnel that sign HM shipping documents, to include HW manifests, must successfully complete an approved certification course listed in DOD 4500.9-R, Part II, Chapter 204, Section D. Refresher training for certifiers is required every 24 months. In addition, all drivers of HMs must receive training according to 49 CFR 177.
4–7. Disposal
Logistics planners must determine the means of HW disposal prior to deployment by contacting the supporting DRMS. Decisions not to use the DRMS must receive concurrence from the component chain of command to ensure contracts and disposal criteria are at least as protective as criteria used by the DLA. If local contractors cannot meet the DLA criteria in DOD 4160.21-M, wastes must be backhauled to a DRMS facility. Units must never incinerate or bury any HW unless explicitly approved by both United States and host nation authorities.
Figure 4–4. Sample weekly inspection record format for hazardous waste storage areas.
4–8. Additional guidance on common field wastes
a. Batteries. Used lead-acid, nickel-cadmium, mercury, lithium, silver, and magnesium batteries usually meet the criteria for classification as HW, and are subject to all of the HW management requirements discussed above. If destined for recycling, however, batteries need only be collected in a manner that provides protection against possible leaks (such as on a spill pallet). It is also important to note that magnesium batteries can emit hydrogen gas and, therefore, should not be collected in air-tight containers. Used alkaline batteries are not HW and may be landfilled with regular trash. If trash is burned locally, however, alkaline batteries should be collected and disposed separately to prevent injury from batteries bursting in the fire.
b. Aerosol cans. Intact aerosol cans meet the criteria for reactive HW. Local policy may authorize the use of puncturing devices to render these wastes nonhazardous; however, units must ensure any remaining substances in the cans do not meet the requirements for classification as an HW. Once punctured, most cans may be recycled for scrap metal.
c. Light bulbs. Spent lamps (including fluorescent, high intensity discharge, neon, mercury vapor, sodium vapor, metal halide, and even incandescent) and lamp ballasts contain heavy metals and may meet the criteria for classification as toxic HW. Although most commonly used lamps contain extremely low levels of toxic substances, discarded bulbs can still pose environmental and health hazards when landfilled in large quantities. The best practice is to collect all spent lamps, especially mercury-containing bulbs (like fluorescent), in containers that will help prevent breakage (such as the cardboard sleeve or box in which replacement bulbs arrived), then turn-in for recycling. If lamps are broken, ventilate the area where breakage occurred, then sweep up the glass and metal and place in a sealed plastic bag. Broken mercury-containing bulbs should then be disposed as HW. Discarded light ballasts should also be recycled or evaluated for HW criteria.
d. Contaminated soil. Fuel spills are one of the most common sources of HW in field settings. Secondary containment (such as drip pans, pillows, absorbent, concrete pads, or tarps) is required for all fueling locations. Secondary containment should also be provided for all fuel stands and space heater overflow lines. When spills occur, personnel should immediately take action to protect themselves and prevent the spread of the spill. Contaminated soil or absorbent should then be shoveled into leakproof containers (such as plastic bags or drums) and transported to a designated soil collection facility or HW storage area. Contractor or engineer support may be required for large spills (defined in local policy). If approved by local authorities, biological remediation (for example, “land farms”) may be used for onsite treatment of petroleum, oil and lubricant (POL)-contaminated soil. This process involves mixing water with the contaminated soil and allowing bacteria to naturally degrade the POL products. Land farming is best suited for isolated areas located in hot, dry climates, and must be supervised by someone trained in the proper construction and operation of land farm systems.
e. Pesticides. Carefully adhere to disposal instructions printed on pesticide container labels or package inserts. Many waste pesticides meet the criteria for classification as HW. The best way to minimize pesticide waste is to carefully plan the amount needed prior to mixing, so all of the product will be consumed during use. Additional disposal guidance can be found in Armed Forces Pesticide Management Board (AFPMB) Technical Guide 21.
f. Flameless ration heaters (FRHs). When exposed to water, FRHs produce heat and hydrogen gas. In small numbers, these hazards are not great enough to warrant classification or management as HW, and the heaters may be disposed of with regular trash. Bulk quantities of unused FRHs (not issued to personnel and not packaged with MREs), however, may meet the criteria for reactivity. The best management practice is to collect unused FRHs for future use/reissue or instruct personnel to activate prior to disposal in the regular trash.
g. Vehicle and equipment maintenance wastes. Maintenance operations should be conducted on a hardstand surface, tarp, or plastic liner. Drained fluids must either be returned to the vehicle or placed in a labeled waste container for recycling or disposal as an HW. Used oil cannot be used for dust suppression or road treatment. Waste solvents, grease, dry sweep, and used rags must be evaluated for classification as an HW. Generally, used rags can be laundered and reused. Oil, fuel, and other filters (not including air filters) must also be segregated from regular trash and collected for recycling or HW disposal. Used oil filters should be gravity-drained, with both the liquid contents and the drained filter collected separately in metal drums. Drained oil filters (nonterne-plated) may be disposed of in the regular trash or recycled as scrap metal.
h. Weapon cleaning waste. Cleaner, lubricant, and preservative (CLP) manufactured since 1994 (for example, Break-Free®) is nonhazardous, and rags, towels, and swabs containing CLP can be disposed of as regular trash. As an exception, patches used to clean weapon bores after firing may contain high levels of lead and should be collected as HW. Other types of solvents (and pre-1994 formulations of CLP) must also be evaluated for HW criteria and may be recyclable. Whatever solvent or CLP is used, ensure personnel use only the amount needed to maintain the weapon to TM specifications. (Break-Free® is a registered trademark of Armor Holdings, Inc., Jacksonville, Florida.)
i. Paints. Partially used paint containers can often be reissued by the HM control center to other units. Otherwise, discarded oil-based paints and paint solvents frequently meet the criteria for ignitable HW. Latex (water-based) paints manufactured after 1991 do not become HW when discarded, and may be disposed of as regular trash. Empty paint cans may be recycled as scrap metal.
j. FST wastes. Several unit FST supplies become HW when discarded. These include mercury thermometers and pesticides. Manage granular calcium hypochlorite as HW (even though some formulations may not meet the criteria for HW) because of the dangers posed by its highly corrosive and oxidizing nature. Calcium hypochlorite should not be burned with regular trash nor buried in landfills.
k. Asbestos. Seal all asbestos-containing waste (such as floor tiles and brake shoes) in air-tight containers. All asbestos abatement activities should be performed by approved contractors or other certified personnel. Asbestos-containing material should be wetted, then double-bagged, and each bag sealed with duct tape. Label all containers of asbestos waste with the following:
"DANGER - CONTAINS ASBESTOS FIBERS – AVOID CREATING DUST - CANCER AND LUNG DISEASE HAZARD." Disposal will normally occur in an approved landfill.
l. Range residues and waste munitions. All range residues (for example, used and unused ammunition, ammo boxes, and spent casings) should be returned to the ammunition supply point where it will be segregated for either HW disposal or recycling.
m. Radioactive wastes. Radioactive wastes should only be handled by designated radiation safety or NBC personnel and managed according to AR 700-48. DLA/DRMS does not manage radioactive waste. Don disposable gloves before handling small quantities of suspected low-level radioactive items (such as damaged tritium compasses, fire control azimuths, or chemical agent monitors), and double bag in plastic bags. Ensure the package is marked as “SUSPECTED RADIOACTIVE WASTE,” and the items are not removed from the bags until the package reaches its ultimate destination. Maintain a strict chain of custody for these items during transport. DD Form 1911 (Materiel Courier Receipt) may be used to document chain of custody. Record the names and units of any personnel that may have come into contact with the contaminated items and the dates of exposure. Provide this information to radiation safety and medical personnel.
n. NBC wastes. Turn in used protective mask filters, protective garments, personal decontamination kits, and NBC detectors to the unit NBC representative for proper disposal. All items suspected of chemical or biological contamination should be sealed in leakproof bags or drums and disposed as HW. Record the names and units of any personnel that may have come into contact with the contaminated items and the dates of exposure. Provide this information to radiation safety and medical personnel. Bulk decontamination agents, such as super tropical bleach and decontaminant solution 2, are extremely corrosive and must be managed as HW when discarded. For management of medical NBC defense materiel (MNBCDM), see chapter 5.