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LESSON 2
ENVIRONMENTAL SELF-ASSESSMENT
Critical Task: 051-250-1002
OVERVIEW
LESSON DESCRIPTION:
This lesson addresses the use of a platoon-level environmental self-assessment.
TERMINAL LEARNING OBJECTIVE:
| ACTION: | You will learn how to inspect a platoon's compliance with environmental regulations. |
| CONDITION: | You will be given the material contained in this lesson. |
| STANDARD: | You will correctly answer all practice-exercise questions at the end of the lesson. |
| REFERENCE: | The material contained in this lesson was derived from FM 20-400. |
INTRODUCTION
Platoon actions can negatively impact the environment. When negative impacts are identified, appropriate steps must be taken to eliminate the damage.
2-1. Platoon Leaders' Responsibilities. When completion of a risk-management work sheet indicates that the platoon has some major environmental problems, an overall evaluation of the status of the platoon's compliance with laws and regulations is needed. This lesson addresses the protection of the environment during all activities (Item 6 from Table 1-1).
2-2. Platoon Compliance. There are several methods that can be used to determine a platoon's compliance:
a. Compliance can only be determined conclusively by a state or federal regulatory agency such as the United States (US) Environmental Protection Agency (EPA) or the US Fish and Wildlife Service. These organizations have the legal right and responsibility to inspect a platoon's activities. Regulatory inspections are normally coordinated with the installation's environmental office but are sometimes conducted without notice. Inspections may concentrate on a particular area such as HW management. However, there is a recent trend toward multiarea inspections. This type of inspection is performed on several environmental protocols simultaneously, such as HW, water, and air. Inspections may include a variety of areas to include personnel training records and the documentation of required training. Guidelines for frequency of inspections are established under the EPA Federal Facility Compliance Act. If a formal inspection by a regulatory agency uncovers major problems within a unit, frequent follow-up inspections can be expected.
b. The Environmental Compliance Assessment System (ECAS) is a process for self-evaluation. It was established as a means of achieving, maintaining, and monitoring self-compliance. Many environmental regulations are designed to be self-regulating. ECAS requires a facility to monitor its programs and notify the chain of command if the facility is out of compliance. The assessment program looks at training, planning, programming, researching, correcting past deficiencies, preventing pollution, managing natural resources, and meeting regulatory requirements for emissions. Units must conduct internal compliance assessments in support of facility programs. Units use compliance assessments as a vehicle to attain environmental program goals and to improve program visibility. By law, if a platoon handles HW/HM, it is required to conduct internal inspections. A HW management plan contains an inspection plan for HW generation points and accumulation sites at the platoon level. The local environmental office can provide an ECAS protocol or ECAS checklists for conducting an internal self-assessment.
c. Platoon self-assessment provides a first-level evaluation of compliance. The self-assessment process addresses nine areas of environmental compliance. Appendix I of FM 20-400 shows a generic checklist for leaders to assess the state of their unit's environmental program and the unit's compliance with environmental laws and regulations (see Appendix C).
2-3. Environmental Self-Assessment. Before starting a self-assessment, review the checklist and supplement it with host-nation, federal, state, and local environmental laws and regulations. Check with higher headquarters for similar aids designed for specific units or locations, and if possible, obtain a copy of the last ECAS inspection from higher headquarters. The nine areas of the environmental self-assessment are discussed below:
a. Management. Many environmental requirements at the unit level are simply extensions of existing management practices. The most basic is ordering only enough supplies to do the job and not stockpiling. The presence of HM makes this practice even more important. HM disposal is expensive and carries with it a significant administrative burden. Good housekeeping is another basic management practice. This involves a number of activities in maintenance, operations, and training.
b. Accumulation Sites. Accumulation sites must be provided for used petroleum products and HW. These sites will be placed above the ground on a nonpermeable, bermed, hard surface; labeled; and located 50 feet or more from any building. Leaking, corroding, or otherwise deteriorating containers must be overpacked in drums approved by the Department of Transportation (DOT).
c. Hazardous Materials/Hazardous Wastes. A motor pool is a unique environmental concern. Mechanics lubricate, service, and repair equipment that generates HW. Motor-pool personnel should—
- Requisition only the minimum amount of HM needed. Substitute nonhazardous material when possible.
- Practice inventory control of all HM/HW by monitoring HM shelf life, practicing first-in/first-out rotation, and tracking HW accumulation start dates. Tracking HW accumulation helps manage prompt transportation of HW.
- Store HM/HW in approved containers and areas.
- Maintain a material safety data sheet (MSDS) on each HM used.
- Obtain any necessary permits.
- Recommend changes when it is believed that there is a better way of accomplishing the job.
d. Solid-Waste Management. Disposal of solid waste is a problem faced by military units worldwide. Proper disposal of solid waste (a category which includes HW) is essential. Improper handling of waste can lead to penalties based on the laws governing the location (Table 2-1).
Table 2-1. Environmental-related penalties
e. Spill Prevention. Army policy, as well as federal law, requires units to apply spill-prevention measures for oil and hazardous substances and to respond promptly to contain and clean up any spills that may occur. These regulations prohibit any discharge of oil or hazardous substance from installation vehicles, aircraft, or watercraft into the environment without a discharge permit. During deployments, the deployment order directs spill-prevention and response procedures. During contingency operations or combat, spill-prevention and response procedures become a matter of host-nation or theater guidance and unit SOPs.
f. Recycling Program. A recycling program is one of the most visible and potentially cost-effective areas of any platoon environmental program. For example, recycling through reuse (used oil recycled-for energy recovery) is the most efficient method of recycling. This method allows for the consumption of used oil for the production of heat rather than paying for both the heating oil and the disposal of the used oil.
g. Washracks. Runoff from washracks is often a major source of water pollution and should only drain into treated sewer systems. Inspect washracks frequently. How often the washrack needs to be checked depends on how frequently it is used. Proper washrack maintenance is a crucial pollution-prevention opportunity, which should not be missed.
h. Land Management. Training land is a valuable resource. When stripped of vegetation, filled with holes, and littered with debris, it ceases to support realistic training. Ensuring that the platoon follows good land-management practices also ensures that training land will continue to be available.
i. Local Supplemental Requirements. Identify applicable installation and area-of-operation policies and procedures that assist the unit in complying with state and local environmental laws and regulations. Modify the generic checklist to include these procedures. Seek assistance from the commander and the installation environmental coordinator when modifying the checklist.
2-4. Follow-Up Action. When the self-assessment checklist is complete, the first-line supervisor can initiate corrective actions. Any item that receives a "no" should be addressed. The first-line supervisor should develop a plan to correct those issues and present the plan to the company commander.
2-5. Summary. This lesson discussed the evaluation of platoon-level environmental compliance. The lesson included the format and use of an environmental self-assessment.
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