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LESSON 6
SELF-ASSESSMENT
OVERVIEW
LESSON DESCRIPTION:
This lesson discusses the US Army's environmental self-assessment program.
TERMINAL LEARNING OBJECTIVE:
ACTION: |
Describe the Army's environmental self-assessment program. |
CONDITION: |
You will be given all material contained in this lesson. You will work at your own pace and in your own selected environment without any supervision. |
STANDARD: |
You will correctly answer questions on the practice exercise at the end of the lesson. |
REFERENCES: |
The material contained in this lesson was derived from FM 4-04.4 (FM 3-100.4), AR 200-1 and TVT 5-56P2. |
INTRODUCTION
Unit-level environmental programs require guidance and support from the chain of command. In developing a unit program, leaders incorporate environmental protection measures into unit SOPs and ensure that personnel receive appropriate environmental training. Major Army commands (MACOMs) conduct environmental-assistance visits to ensure that installations comply with appropriate environmental laws. Unit leaders coordinate with the installation's environmental office and their higher HQ for assistance visits and compliance audits within the unit area. Unit leaders or their designated representatives can also conduct self-assessments to determine how well their unit is following environmental-protection measures.
6-1. Environmental Compliance. The Army determines environmental-compliance status in two ways. Federal, state, and local regulatory agencies conduct formal compliance audits and spot checks on installations and report their findings to the military chain of command and the Environmental-Compliance Assessment System (ECAS), an Army program that provides installation inspections. Installations conduct internal evaluations, while Army MACOMs conduct external evaluations. Federal, state, or local inspections may result in civil and criminal penalties for noncompliance with environmental laws and regulations. Self-assessments may be conducted using the installation status report software, or unit leaders may choose to use a general checklist found in FM 4-04.4 (FM 3-100.4), Appendix H, to assess unit environmental compliance.
a. Federal and State Regulatory Inspections. Regulatory agencies have the legal right and responsibility to inspect units and facilities to ensure compliance with environmental laws and regulations. These agencies usually coordinate inspections through the installation's environmental office, or they may conduct inspections without prior notice. Inspections in other programs may occur at different frequencies. Installations or units with specific major problems can expect frequent follow-up inspections, which may include checks of training records and documentation, permit reviews, and storage facilities.
b. Environmental-Compliance Assessment System (ECAS). Many environmental regulations require self-regulation, which requires the installation to monitor its own programs and notify the regulatory agency when problems occur. The Army established the ECAS as a means of achieving, maintaining, and monitoring compliance with applicable environmental laws. The Army also uses compliance assessments as a vehicle to attain environmental program goals. The Army conducts internal compliance assessments for its installations. Units participate in these assessments, which review all aspects of the installation's environmental status.
6-2. Establishing a Unit-Level Program. To establish an effective unit environmental program, the unit leader should ensure that all unit personnel have had environmental awareness training, designate an ECO who is properly trained and qualified, and meet with key higher level unit staff counterparts and installation personnel who deal with environmental issues. When meeting with installation personnel and higher level unit staff, leaders must find out what their requirements are concerning environmental training, qualifications, and certification of unit personnel and any common environmental problem areas or ECAS inspections that may affect the unit. They must also ensure that the unit has a well-written SOP that addresses environmental issues and procedures that apply to the unit. The following are unit or installation environmental programs that units develop or adopt.
a. Hazardous-Material Management. The Army's objective is to minimize health hazards and environmental damage caused by the use and misuse of HM. A HM is one that, because of its quantity; concentration; and physical, chemical, or infectious characteristics may do the following:
Cause or significantly contribute to an increase in mortality or an increase in serious, irreversible, or incapacitating reversible illness.
Pose a substantial or potential hazard to human health or the environment when improperly treated, stored, transported, disposed of, or otherwise managed.
b. Dealing with Hazardous Material. Listed below are examples of what leaders should do when their unit deals with HM. A complete list may be found in FM 4-04.4 (FM 3-100.4), Chapter 6.
Ensure the best management practices for all HM.
Comply with all applicable regulations, policies, and procedures.
Order and use only what is required; do not stockpile HM.
Conserve resources through recovery, recycling, and reuse.
Establish a training program, and ensure that personnel are properly trained as required.
c. Hazardous Waste (HW). Hazardous substances, which result in some waste generation, are an unavoidable part of Army activities. The proper handling and disposal of this waste will minimize danger and ensure the safety of people and the environment. The following are some examples of what leaders should do if their unit deals with HW:
Establish an HW management program to comply with HW regulations.
Ensure HW is properly identified. Label stored waste and the containers that hold HW with the correct danger and warning signs.
Ensure that waste does not accumulate beyond the allowable quantity and time limits.
Maintain proper HW records, and report periodically, as required by the EPA.
d. Hazardous Communication (HAZCOM). An effective HAZCOM program will assist leaders to determine what hazardous chemicals are present in their units, how to protect their soldiers from hazards those chemicals present, and how to properly store and use those chemicals. The installation safety officer is the point of contact (POC) for most HAZCOM matters, the material safety data sheet (MSDS) program, and the HAZCOM training program. Examples of what unit leaders should do in support of HAZCOM are:
Ensure that subordinates receive adequate training on HM to which they are exposed, in accordance with the occupational safety and health agency (OSHA) requirement.
Maintain an up-to-date list of all HM/HW known to be present in their area.
Ensure that containers of hazardous substances are labeled, tagged, or otherwise marked to identify the material and to warn soldiers of hazards.
Maintain an MSDS for every HM in the unit, and ensure that soldiers are trained to recognize, understand, and use the MSDS and labels for the HM to which they are exposed.
Refer to applicable HAZCOM references.
e. Pollution Prevention and Hazardous Waste Minimization (HAZMIN). HAZMIN means reducing the amount and toxicity of the HW generated or produced. Pollution prevention means reducing the amount of material, whether it is hazardous or not. Unit leaders should ensure that their units conduct inventory control. Units should not stockpile HM. If the HM has an expired shelf life, it can cost more to dispose of the item than it did to obtain it, since the HM will now have to be handled as HW. Product substitution is an easy way to reduce HW generation. Use nonhazardous or less hazardous substitutes if available. A process change can reduce the amount of HW generated, but it will still need to be treated as HW. Applicable pollution prevention and HAZMIN references can be found in FM 4-04.4 (FM 3-100.4).
f. Recycling Program. The Army promotes separating products, substituting materials, and changing procedures to avoid the use of hazardous substances (source reduction) and recycling to reduce the volume of solid waste. Most installations have a recycling program. Recyclable materials include: computer printouts, corrugated cardboard, newspaper, aluminum cans, plastics, oil, solvents, glass, steel, and brass. Check with installation personnel to verify what materials are being recycled on your installation.
g. Spill Prevention and Response Plan. It is Army policy and a CWA requirement to prevent oil and hazardous substance spills and to provide prompt response to contain and clean up spills. The discharge of oil or hazardous substances from installations, vehicles, aircraft, and watercraft into the environment without a discharge permit is prohibited. Every reasonable precaution should be taken to prevent spills of oil and hazardous substances. AR 200-1, FM 4-04.4 (FM 3-100.4), and Title 40 Code of Federal Regulation (CFR) refer to applicable spill prevention references. A few examples of what a unit leader should do are as follows:
Provide facilities to store, handle, or use oils and hazardous substances, and implement proper safety and security measures.
Appoint a spill coordinator and members of unit spill response team in writing.
Maintain an up-to-date spill response plan.
- Maintain an up-to-date inventory of all HM/HW,and provide a copy to the post fire department for use in case of a chemical fire.
6-3. Program Assessment. Environmental-compliance status can be determined through a formal inspection by a regulatory agency. It can also be determined through self-inspections using ECAS checklists as a guide.
a. Non-Army regulatory agencies have the legal right and responsibility to inspect units and individual facilities and actions to ensure compliance. Once a year, EPA inspectors conduct spot inspections of installations, often without notice. Local and state inspectors also conduct frequent inspections. Inspection frequency guidelines have been established under the EPA federal facility compliance strategy.
b. The Army established the ECAS as a means of achieving and monitoring compliance with applicable federal, state, regional, and local environmental laws and regulations. If a unit deals with HM or HW, leaders are required to conduct internal inspections. Installation HW management plans should normally contain information sufficient to develop an inspection plan for HW generation points and accumulation sites at the unit level. The unit leader may also request a copy of the ECAS protocol to assist in developing inspections and recordkeeping plans and to conduct an interior/self-compliance assessment.
6-4. Unit Self-Assessment. Unit leaders use a checklist to assess unit environmental compliance. FM 4-04.4 (FM 3-100.4), Appendix H, has a general checklist that leaders may use. Higher-level staffs within the chain of command or the installation's environmental office may have similar aids specific to a unit or location. Unit leaders, with the assistance of the installation's environmental staff, determine the frequency of self-assessment checks. The commander ensures that the unit's environmental program management system is effective through the use of these self-assessments.
a. Unit Management Practices. Many environmental requirements at the unit level are simply an extension of existing unit management practices. Units exercise good management practices by doing the following:
(1) Using the Army's Hazardous Substance Management System (HSMS). The HSMS applies centralized management and strict inventory control to reduce the use and disposal requirements for hazardous substances by tracking HM.
(2) Conducting Good Housekeeping. Good housekeeping is another basic management practice. It involves areas such as maintenance, operations, and training. An example of good housekeeping is recycling. Recycling diminishes solid waste and helps eliminate unauthorized disposal of some types of HW. Another example is monitoring the shelf life, of HM. HM disposal is expensive and carries with it a significant administrative burden. When HM have a shelf life, use the first-in, first-out rule. This will help reduce the disposal of outdated HM.
(3) Using Standing Operating Procedures (SOPs). SOPs are an effective management practice requiring soldiers to understand and follow. Unit leaders ensure that the unit has a well-written SOP addressing environmental issues and procedures.
(4) Designating an Environmental Conditions Report (ECO). Commanders, down to the company, troop, and battery levels, must designate an ECO. AR 200-1 requires unit commanders to appoint an ECO in writing and to provide training for the ECO. The ECO coordinates with the installation's environmental staff and ensures that the unit complies with environmental laws and regulations.
(5) Ensuring that all Unit Personnel Complete Environmental Awareness Training. Commanders must also identify those soldiers who require special environmental training. The installation environmental offices and environmental staffs assist subordinate commanders to determine specific environmental-training requirements.
(6) Labeling containers. Labeling HM and HW is a legal requirement. Installation or shipping environmental guidelines specify labeling requirements. Materials not technically classified as hazardous, such as cleaning supplies, lubricants, and paint, must also be labeled. Each unit must develop and enforce procedures to maintain complete records of the environmental actions and activities they perform.
b. Maintenance. Unit maintenance activities have significant potential for environmental impact. The Army has environmental programs that affect maintenance operations in some way. Some specific areas of concern are listed below:
(1) Spill Prevention and Response. Both Army policy and federal law require units to prevent spills of oil and hazardous substances and to provide prompt response to contain and clean up such spills.
(2) HM/HW Storage and Handling. The unit's prescribed load list (PLL) section controls requisitions and receipts for HM and prepares documentation for turn-in of HW.
(3) Refueling. Refueling operations create significant potential for POL spills and fire hazards. Units must ensure that their SOP includes adequate procedures to prevent and respond to spills.
c. Supply. Unit supply personnel account for all materials during HM/HW requisition, transportation, storage, and disposal. Unit leaders ensure that their supply personnel observe stringent HM supply economy measures by ordering only the minimum amount of HM needed and, when possible, order biodegradable, environmentally safe materials. When storing products, use stock rotation to minimize the turn-in of out dated material. Leaders also ensure that supply personnel turn-in or dispose of HM/HW according to local regulations.
d. NBC Defense and Training. NBC hazardous materials are used in NBC defense and training. Unit NBC specialists exercise caution when storing and handling these materials. Leaders ensure that personnel dispose of materials according to local requirements and that the unit has a spill response program in place that addresses NBC activities.
e. Unit Mission Training. Unit leaders must exercise caution with noise pollution, air pollution, waste disposal, spill protection, water pollution, and cultural and natural resource protection. Unit leaders check with the installation training staff concerning training area restrictions and coordinate in advance for environmental guidance due to differing local, state, or HN regulations.
f. Communications. Modern communication systems use many types of batteries. Used batteries are considered a HW in most states, and therefore, unit personnel ensure that SOPs specify storage and disposal procedures for each type of battery in the unit.
g. Operations. Operations do not automatically suspend environmental considerations. Higher commanders' guidance is critical to determining the risk that will be applied to any operation. Leaders may use the risk management principles and the five-step process for guidance.
h. Special Requirements. In addition to meeting the previously stated requirement, some military units, such as the National Guard (NG) and reserve component (RC) units and units stationed in foreign countries must follow additional environmental guidelines. Check with the unit ECO and the supporting HQ for more information.
6-5. Summary. Unit commanders are responsible for building and implementing a unit environmental program. Assistance is available from the installation/garrison/base staffs as well as from unit higher HQ. Tools to assist unit leaders also include generic checklists, available for units to assess compliance with environmental laws and regulations in their daily operations and activities. One generic checklist may be found in FM 4-04.4 (FM 3-100.4), Appendix H. ECAS checklists provide a more comprehensive assessment. Leaders must remember that self-assessment is only a guide and does not provide final determination of compliance.
