HEADQUARTERS USARAF Pamphlet 200-6 UNITED STATES ARMY AFRICA (USARAF) Unit 31401, Box APO AE 09630 1 August 2011 Environmental Quality Hazardous Materials Management during African Operations *This is the first edition of USARAF Pamphlet 200-6 For the Commanding General hk oe Gs-1-Qeos Colonel, Chief of Official EUNICI LOK ‘Command Directives Officer Summa ry. a. ‘The intent of this pamphlet is to provide guidance to United States (US) forces in Africa operating under the control of the US Army Africa (USARAF) or if so designated by the task force Commander, applicable combined/joint task forces (CJTF) on the protection and management of cultural/historie/natural resources. b. ‘This pamphlet does not provide guidance or requirements associated with Chemical, Biological, Radiological, Nuclear materials or with the conduct of unexploded ordnance operations, Applicability. USARAF Pam 200-6a, ‘The guidance in this pamphlet is applicable to US forces in the African Theater of ‘Operations under the control of the USARAE or if so designated by the task force Commander, applicable CITP. b. Nothing in this pamphlet shall be construed to create, modify, alter, or amend any existing: (1) International or multilateral international agreement. (2) Bilateral agreement between the USA and any African Partner Nation (APN). (3) Obligation or requirement on the part of the USA (4) US Government regulation as it may pertain to the US military ¢. Nothing in this pamphlet shall create any right or benefit, substantive, or procedural, enforceable at law or equity by a party against the US, its agencies, its officers, or any person. Supplementation. Supplementation of this pamphlet and establishment of command and local forms are prohibited unless prior approval is obtained from the Commanding General, USARAF and/or applicable C/JTF commander, Forms. Records Management. Records created as a result of processes prescribed by this pamphlet must be identified, maintained, and disposed of according to AR 25-400-2. Record titles and escriptions are available on the Army Records Information System website at uiips:/ www arims.army mil Suggested Improvements. The proponent of this pamphlet is the command engineer, USARAF. Users may suggest improvements to this pamphlet by sending a DA Form 2028 (Recommended Changes to Publications and Blank Forms) to the command engineer, USARAF. Distribution, [Electronic Media Only. USARAF Pam 200-6 4Cable of Contents SARAF Guidance, 1.1. General 1.2. Military Use of Hazardous Materials. 1.3. Product Substitution. 2.0. Mastet Planning Criteria for Facilities with Hazardous Materials. 3.0. Engincering Design Criteria for Facilities with Hazardous Materials. 4.0, Storage of Hazardous Materials. 5.0. Hazardous Materials Inventories. 6.0. Safety Measures. 7.01. Shipments of Hazardous Materials. 7.1, General Requirements 7.2. International Shipments of Hazardous Materials 7.3, Intemational Shipments of Hazardous Wastes 8.0, Waste Determination, 9.0. Disposition of Hazardous Wastes. 10.0, Environmental Incidents. 11.0, Contract Requirements, Relerences USARAF Pam 200-6 51.0. USARAF Guidance. 4 Hazardous materials are any substances capable of posing an unreasonable risk to health, safety. or the environment. The harm may be immediate, or it may not be apparent for many years, Some of these materials may cause harm to future generations, or they may linger for extended periods of time in the environment. b. Physically these materials may be solid, semi-solid, liquid, or gas. They will be ignitable, corrosive. reactive, toxic, and/or radioactive, or be specifically listed as a hazardous material ¢. Hazardous wastes are hazardous materials that no longer can be used as intended and have no residual economic value. 1.2. Military Use of Hazardous Materials. a. Almost all military operations require the use of hazardous materials. Examples of common hazardous materials used by US forces include petroleum oil and lubricants (POL), explosives. chlorine-based products, cleaning solutions, battery acids, pesticides, and herbicides. b. To ensure mission accomplishment US forces must be able to properly manage the storage, transportation, use, and dispose of those materials, Failure to properly manage hazardous materials may harm the readiness of US forces. Improper management of hazardous materials may have a negative impact upon APN relationships. and may adversely impact the \vorld opinion of the US military. Actions to mitigate risks from improperly management materials may divert resources from operational requirements. ‘Therefore, US forces must take every reasonable step to properly management these materials and prevent such harm, ¢. Sites in APN operated by APN government or private firms may store or use hazardous materials. ‘Those sites may be where hazardous wastes were disposed. US forces must be aware of those sites, the risks those sites may pose, and what actions need to be taken to avoid negative impacts to mission accomplishment and to protect the health of US forces. . The management of most hazardous materials is regulated by international treaty and APN domestic laws and regulations. There is US and international technical guidance governing the transportation of these materials ¢. Itis extremely likely operations will produce hazardous wastes. US forces must properly package. store. transport, and dispose of the wastes they generate, In most cases wastes will be shipped to sites outside of Africa. All shipments must comply with applicable international agreements and APN legislation. 1.3. Product Substitution. USARAF Pam 200-6 4To mitigate risks to human health and the environment, whenever it is technically feasible unit commanders are to minimize the volume of hazardous materials transported into, or procured in Africa, To achieve this, commanders will replace hazardous materials with non- hazardous materials. 0), Master Planning Criteria for Facilities with Hazardous Materials. a. ‘The operation of almost all sites occupied by US forces will require that hazardous materials be stored and used on those sites. Risks from those materials cannot be eliminated. but those risks can be marginalized by keeping the materials as far away from people and at-risk environments as site conditions permit b. ‘The guidance provided in this section is intended to serve as a benchmark, It is under- stood that limitations at some sites may not permit commanders to meet the guidance. In those eases commanders are to assess elevated risks and implement risk mitigation actions. ¢. All locations where hazardous materials are located shall be noted on the site master plans, Asa general guideline, the numbers of locations where hazardous materials are stored on ie are to be kept to a minimum. d. Master Planning Criteria. (1) Master plans for locations (bases) to be occupied by US forces must be scalabl master plans should anticipate growth in the size of the base and the facilities on that base. (2) General Location Criteria, Mission constraints permitting, facilities using or storing hazardous materials will not be located in: (a) Wetlands, areas subject to flash flooding, and/or one hundred (100) year flood plains. (b) Areas with porous soils and/or unstable subsurface geology. (c) Critical habitats of endangered species. (d) Recharge zones of sole source aquifers. (c) Areas of significant historic or cultural value. (3) As mission constraints and available real estate permitting', master plans should place the footprints of hazardous material and waste facilities as far away from: (a) On-base living support areas (LSA) (housing, dining facilities, offices, MWR ized in most situtations some level of risk must be accepted when designing a base, and risks to human ce presidence over risks to the environment, is ree health ta USARAF Pam 200-6 5facilities. ete.) (b) Environment features that may serve as pathways for the spread of contamination. (c) Off-base locations occupied by APN population ities should be: (4) When practical, the footprints of environmental management fa (a) Atthe edge of the base. (b) Placed where drainage from those facilities will not pass through LSAs. (c) Placed where prevailing winds will not pass through LSAs. (5) All environmental management facilities are to be noted on the site master plans, ae Environmental is Management ae Facilities 4 ; ot a Population points Figure 1 (6) Specific Location Restrictions. Hazardous substance facilities will be located a minimum of five hundred meters (500 m) and downwind (if there is a prevailing wind) from: USARAF Pam 200-6 6(a) Natural bodies of water. (by Living support areas. (c) Food storage/preparation sites. (a) Dining facilities (c) Medical support areas, (1) Areas legally inhabited by non-US personnel. (21 Operational airerafi run-ways nd helipads. (71 Additional Location Restrictions. Hazardous substance facilities will be located at least two hundred meters (200 m) from ammunition storage sites, Natural body of water Direction Living Support Area Food Prep Area Dining Facility Medical Support Area ‘Ammo Storage Area Host Nation Living Area pea. Figure 2 USARAF Pam 200-6 7for Facilities with Hazardous Materials. ) g hazardous materials as far away from people and at-risk environments as possible. properly designed and operated facilities will lower tisk levels b. Facilities housing hazardous materials shall incorporate the general design guidance below (1) Whenever possible locations are to be constructed of fire-resistant materials. (2) Location are to have adequate secondary containment for liquid materials - containment area will be able to hold the volume of the largest single container or ten percent (10%) of the total anticipated volume, whichever is greater. (3) Locations are to have physically separated storage areas for incompatible materials. (4) Locations are to have overhead cover. (5) Locations are to be well ventilated. (6) Locations are to be able to accommodate the entry/exist, and internal movement of pated material handling equipment, (7) Location shall have appropriate communication and warning systems. are (8) Have emergency response and personnel protective equipment and supplies tw be stored where they ean be reached without having to transit through the facility (9) Locations are to have barriers to deny access to unauthorized personnel, (10) Locations are to have adequate warning signage in appropriate languages. ©. Underground storage tanks or confined spaces will not be utilized for the storage of hazardous materials Satellite Storage Facilities. Commanders may create temporary satellite storage locations Jor small quantities (¢.g., bench-stocks) of hazardous materials in maintenance arcas. (1) Satellite storage locations are to have all appropriate design and safety features. (2) Satellite locations for the temporary storage of hazardous waste shall not be design to store in excess of two hundered liters (200 1) of waste. ©. Vehicles or trailers used to store hazardous materials will meet the design guidance specified above, USARAF Pam 200-6 84.0. Storage of Hazardous Materials, a. Unless mission constraints specifically dictate to the contrary, the following guidance on the storage of hazardous materials will be followed: (1) Hazardous materials will only be stored in facilities meeting the design guidance specified in this pamphlet. (2) The quantity of hazardous materials in a location will not exeeed the design capacity of that location. (3) Only maintain the minimum quantity of hazardous materials required to meet reasonable mission requirements will be maintained. (4) Stocks of hazardous materials will be used on a first to reach expiration date basis. (5) All hazardous substance containers will be properly labeled (6) Hazardous materials will only be stored in approved containers. (7) All hazardous substance containers will remain closed except when materials are being dispensed from or poured into them. (8) Hazardous materials in dented or damaged containers will be used before materials in undamaged containers, (9) Hazardous materials will not be stored together with food stuffs (small quantities of cleaning materials can be stored with food stuffs if proper procedures are implemented). (10) If'vehicles or trailers are used to store hazardous materials, containers in those vehicles trailers shall be properly secured to prevent accident rupturing of the containers during movement b. Unless mission constraints specifically dictate to the contrary, the following additional ssuidanee on the storage of hazardous wastes will be followed. LL) Hazardous wastes will be stored separately from all other materials. (2) The volume of hazardous waste in a container shall not exceed 80% of the maximum, possible volume in that container. (3) The individual responsible for managing the waste will ensure a replacement container is ready once a container is $0% full, and containers in satellite storage locations are moved to the main storage facilities the day they reach the 80% full mark. USARAF Pam 200-6 9&. Unit commanders will incorporate the guidance above into their standing operating procedures 4. I mission constraints do not permit compliance with the guidance above, commanders shall do risk assessments and implement applicable risk mitigation measures to reduce the level ). Hazardous Material Inventories. a. Prior to deployment, (1) Commander will develop listings of all hazardous materials being ship into Africa or anticipated to be procured in Africa (2) Whenever technically feasible commanders will direct hazardous materials be replaced with non-hazardous materials. (3) Listings of hazardous materials will be consolidated at the USARAP/CITF level and transmitted to Defense Logisties Agency (DLA) Disposition Services Europe and Africa. This will allow DLA to start the process of obtaining authorizations to internationally ship hazardous wastes b. During operations. (L) Inventories of hazardous materials on-hand will be conducted in intervals of not less than 14 days. (2) An inventory of hazardous materials will be maintained for each location on a site where those materials are located. Containers of the same hazardous materials with identical xpitation dates may be combined as a single entry in the inventory with a notation of how many ‘containers are at the location, Each container of hazardous waste will be inventoried as a separate item. Inventories will identify the following data for each location: Name of hazardous substance Risk classification Quantity of substance Expiration date (not applicable for waste) Generation date (date waste was first placed in the container) Total quantity of hazardous materials by risk classification (3) Location inventories will be consolidated for the site. Consolidated listing will identity any materials not identified on the pre-deployment inventory. (4) Copies of consolidated inventories will be maintained in the site continuity book, and ient Response Team leaders, fire chiefs, security chiefs, and any other applicable provided to Inc USARAE Pam 200-6 10applicable first responder organizations. (5) Commanders will inform USARAFICITF engineer of the procurement of any hazardous materials not identified on the pre-deployment inventory. If requested copies of vonsolidated inventories will be provided to USARAF/CITF engineer staft (6) Unit commanders will ensure unit standing operating procedures incorporate the vuidance specified above. ¢. Hazardous Waste Inventories, (1) Each container of hazardous waste will have a unique identifying number. A log will he created for each container of hazardous waste generated, (2) Ancniry in the log shall be created each time waste is added to the containers. Data provided for each waste entry event will include (a) the organization responsible for generating the waste. (b) the quantity of waste being added, (c) date and time of the entry. 6.0, Safety Measures. ‘a. Ateach location where hazardous materials are located, material safety data sheets (MSDS) will be maintained for all hazardous materials at those sites, MSDS will be in all languages used by personnel working at those locations. bb. Each location where hazardous materials are located will have the appropriate type and {quantity of personal protective equipment (PPE). ¢. Each location where hazardous materials are located will have the appropriate fire fighting, first aid, and communication equipment/materials. 4. If applicable, hazardous substance locations will be equipped with monitors to detect dangerous levels of those materials. ¢. Each site will be secured to prevent access by unauthorized personnel, £ Individuals working at locations with hazardous materials are to be adequately trained on the risks. mitigation measures, and incident response actions. Personnel with temporary access to such locations will be briefed on risks and incident response actions. i. Inspections of storage facilities will be conducted weekly, Record of inventories will be maintained in site continuity books h. Unit commanders will ensure unit standing operating procedures incorporate the guidance specified above, USARAF Pam 200-67.0. Shipments of Hazardous Materials, Hazardous materials have inherent risks; shipping those materials increases the risks. Though risks cannot be eliminated, there are actions that can mitigate risks 7.1, General Requirements. a. Military shipments are not directly subject to US Department of Transportation (DOT) regulations but the requirements found in DOT regulations", UN recommendations on shipping hazardous materials*, and various international commercial codes*, have been incorporated into military guidance documents*. All shipments are to comply with established military guidance, b. Key points (1) Communications. Ensure all interested parties (shippers, transporters, receivers, and those where the shipment will transit) know about the shipment and are prepared to do their part. Ensure all non-DOD parties are willing and able to perform. Q Training. Ensure all interested parties are trained to perform their assigned duties. (3) Incident preparedness. Ensure first responders (incident response teams, fire and security personnel, medical personnel) are prepared to react in the event of an incident. Ensure appropriate PPE is ready for use by handlers and drivers, (4) Shipping Documentation. Ensure inventories on bil all required shipping documentation is complete. of lading are accurate. Ensure (5) Permissions. Ensure all legal authorizations’ permits have been received. cflects of the materials and the anticipated physi of shipment are used. WW, (7) Marking of packages ~ ensuring the proper labels and marking have been placed on containers, (6) Packaging. Only use performance-orientated- packaging containers that are designed to withstand the a I demands wy Vile 49 Code oF Federal R lations (CFR), Parts 100-199 United Nations Recommendations on the Transport of Dangerous Goods - Model Regulations International Civil Aviation Organization (ICAO) TecAPNical Instructions, Intemational Air Transport Association (IATA) Dangerous Goods Regulations, International Maritime Organization (IMO) Dangerous Goods Code * Army Regulation 700-143, Packaging of Hazardous Material; TecAPNical Manual (TM) 38-250, Preparing, Hacardous Materials for Military Air Shipment; MIL-STD-129, Standard Practice for Military Markin USARAF Pam 200-6 12(8) Compatibility. Ensure incompatible materials are hysically separated during shipment. (9) Vehicles and containers, Ensure all vehicles and containers are in good operating condition, Ensure required warning placards are visible. (10) Proper loading and unloading procedures. Ensure to have the proper equipment 10 sately load and unload packaged materials. (11) Blocking and Bracing in vehicles and containers. Have and use the necessary materials to keep containers from shifting about in transit 7.2, International Shipments of Hazardous Materials. 4. Shipments of hazardous materials into and out from Africa are subject to close scrutiny by APN. Many African nations are parties to international conventions (to include the Vienna, Rotterdam. and Stockholm Conventions) and associated protocols which require them to regulate shipments of hazardous materials. b. In most cases shipments must comply with prior informed consent (PIC) procedures. PIC procedures require the place where the shipment is to go (state of import) agrees to allow the shipment to enter and is capable of managing the shipment in an environmentally sound manner. PIC procedures also requirement that places the shipment will pass through (states of transit) auree to allow passage of the shipment through their territory. This requirement is to be handled by the organization responsible for managing the shipment. Unless there is an agreement with the APN waiving compliance with APN legislation and reyulations. US forces must comply with those APN requirements. Many APN have incorporated the guidance found in the “United Nations Recommendations on the Transport of Dangerous Goods - Model Regulations” into their domestic regulations. 7.3. International Shipments of Hazardous Wastes. &. ‘The transport of hazardous wastes is closely regulated by APN legislation and regulations, \ hich in most eases are required by the provisions of international agreements. US forces are to respect the sovereignty of other nations, and comply with APN requirements. b. The wo main international agreements impacting the transboundary movement of hazardous Wastes in Africa are the “Convention on the Control of Transboundary Movements of Hazardous Wastes and their Disposal” (Basel Convention) and the “Convention on the Ban of the Importation into Affica and the Control of Transboundary Movement and Management of Hazardous Wastes in Africa” (Bamako Convention) USARAF Pam 200-6 2B(1) Basel Convention. Per the convention, the import or export to/from non-party states is prohibited. Shipments between parties must be managed by authorized persons in an environmentally sound manner. All shipments are required to be packaged/labeled/ transported in accordance with recognized international rules and standards, and accompanied by movement dlocuments. and there must be adequate disposal facilities in the importing state. The ires Parties to reduce the amount of hazardous waste they generate, and to minimize trans-boundary shipments of wastes. Shipments are to be covered by insurance, bond. or other guarantee as required by the state of import or transit. In the event a shipment cannot be completed in accordance with the agreed upon terms, the convention requires the state of export take back the shipment. convention re (2) Bamako Convention. The convention prohibits the importation of all hazardous wastes. to include radioactive wastes into Africa, and requires the enforcement of the prohibition against dumping/ineineration of hazardous wastes at sea or in internal waters. The convention Specifies that shipments not conforming to PIC procedures are illegal, and establishes procedures defining which party is responsible for managing illegal shipments. Parties to the convention are required to enact domestic legislations to make the illegal traffic in hazardous waste a criminal offense. The convention does not restrict the sovereign right of states to enact stronger controls: on shipments ¢. All international shipments of hazardous wastes will be managed by the Defense -yeling and Marking Serviee ~ International «green”) tecnologies into work preformed and/or products delivered. b. Hazardous Materials, KO/CORs shall ensure responsibility resides with the performing contractor for the management of hazardous/toxic/radiological materials, solid wastes, and ‘wastewaters that are transported into, procured and/or generated within, treated and/or disposed of in, or transported out of the African area of responsibility. ¢. Incident Response. Responsible KO/CORs shall ensure: (1) Contractors have spill response plans, adequate materials, and equipment to respond 1o incidents, and trained personnel. (2) Contractors respond fo environmental incidents in a timely manner, and that upon. completion of the response action no residual risk to the environment and/or human health exists (3) Contractors report environmental incidents in accordance with the procedures established in USARAF Pamphlet 200-7. dL Due Diligence. Responsible KO/CORs shall perform due diligence on contractor ciperations fo ensure contractor operations do not endanger human health and/or the environment, USARAF Pam 200-6 7References Litke 49 Code of Federal Regulations (CFR), Parts 100-199 Army Revulation 700-143, Packaging of Hazardous Material, 14 January 2000 echnical Manual (TM) 38-250, Preparing Hazardous Materials for Military Air Shipment, 01 Mareh 1997 MIL-S1'D-129, Standard Practice for Military Marking, w/C-4, 19 September 2007 United Nations Recommendations on the Transport of Dangerous Goods - Model Regulations, August 2007 United Nations Environmental Program (UNEP), “London Guidelines for the Exchange of Information on Chemicals in International Trade”, as amended, 25 May 1989 United Nations Food and Agriculture Organization (FAO), Intemational Code of Conduct on the Distribution and Use of Pesticides, November 1989 Intemational Civil Aviation Organization (ICAO) Technical Instructions ~ 2011-2012 Edition, Ww: addendum # 3, as of 05 May 2011 international Air Transport Association (IATA) Dangerous Goods Regulations, 2011 edition {international Maritime Organization (IMO) Dangerous Goods Code, w/ Amendment 35-10, Feburary 2010 Vienna Convention for the Protection of the Ozone Layer, 22 March 1985, Vienna, Austria Protocol on Substances that Deplete the Ozone Layer (Montreal Protocol), 16 September 1987, Montreal. Canada Cairo Guidelines and Prineiples for Environmentally Sound Management of Hazardous Wastes, 1 December 1985, Cairo, Egypt Convention on the Control of Transboundary Movements of Hazardous Wastes and their Disposal (Basel Convention), 22 March 1989, Basel, Switzerland Protocol on Liability and Compensation for Damage Resulting from Transboundary Movements of Hazardous Wastes and their Disposal, 10 December 1999, Basel, Switzerland Fourth African, Caribbean, and Pacific Groups of States ~ European Economic Community (ACP-EC) Convention of Lomé, 15 December 1989, Lome, Togo USARAF Pam 200-6 18International Convention on Oil Pollution Preparedness, Response, and Cooperation, 30 November 1990, London, England Convention on the Ban of the Importation into Africa and the Control of Transboundary Movement and Management of Hazardous Wastes in Africa (Bamako Convention), 30 January 1991, Bamako, Mali \lrican Nuclear Weapon-Free Zone Treaty (Pelindaba Treaty), 23 June 1995; Addis Ababa, Hahiopia ‘Convention on the Prior Informed Consent Procedure for Certain Hazardous Chemicals and Pesticides in International Trade, 10 September 1998, Rotterdam, Netherlands ‘Convention on Persistent Organic Pollutants (Stockholm Convention), 22 May 2001, Stockholm. Sweden USARAF Pam 200-6 19