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					     TSP Number 052-E-2100
Enforce applicable environmental protection
           laws and regulations

                  July 2008
          Terminal Learning Objective

 ACTION: Enforce applicable environmental protection laws and regulations.

 CONDITION: As a small unit leader given a mission, environmental
  references and a unit environmental officer, with the responsibility to enforce
  compliance with applicable environmental legal requirements within the area of
  responsibility (AOR).

 STANDARD: Enforce environmental legal requirements within the AOR by
  assisting Soldiers in identifying specific environmental duties during mission
  activities and reporting problems to the chain of command with appropriate
              Safety, Risk and
          Environmental Concerns

 Safety Requirements: None

 Risk Assessment Level: Low

 Environmental Considerations: Training entirely of an
  administrative nature, with little or no environmental impact
 TM 38-410 Storage and Handling of Hazardous
 FM 3-100.4 Environmental Considerations in
  Military Operations
 TC 3-34.489 The Soldier and the Environment
 FM 5-19 Composite Risk Management
 AR 200-1 Environmental Protection & Enhancement
 The Army Strategy for the Environment
 29 CFR Labor (Occupational Safety and Health Act)
 40 CFR Protection of the Environment
 49 CFR Transportation
    Learning Objective #1

• Identify applicable environmental laws and regulations
    Hierarchy of Laws & Regulations

•   Federal/DoD/Army
•   Host Nation
•   State
•   Local/Installation
                 Federal Laws

•   National Environmental Policy Act (NEPA-1969)
•   Resource Conservation Recovery Act (RCRA)
•   Clean Water Act
•   Clean Air Act
•   National Historic Preservation Act
•   Endangered Species Act
•   Noise Control Act
    Federal Environmental Laws
• National Environmental Protection Act –NEPA
  – Any federal action requires that the
    proponent conduct an analysis to see if
    there are impacts to the environment.
  – Often considered an “umbrella” law
    because it encompasses the other
    environmental laws.

 Soldiers comply with the NEPA by-
    • By conducting Risk Assessments.
    • By following environmental SOPs, Laws and Regulations.
    Federal Environmental Laws
Resource Conservation and Recovery Act (RCRA)
 Primary HW reference is 40 CFR 260-279
 RCRA regulates the generation, transportation, treatment,
  storage and disposal of solid and hazardous waste.
 Massive and complex regulation
 Known as the “Cradle to Grave” Act

 Soldiers comply with the RCRA by-
   • Proper disposal of chemicals, solvents, and HW.
   • Accumulating HW in approved containers.
   • Reporting any spills of HW to their chain of command.
   • Proper bagging, storage and disposal of medical waste.
Federal Environmental
Clean Water Act (CWA)

 Soldiers comply with the CWA by-
  • Disposal of chemicals, solvents, and HW properly.

  • Washing vehicles in approved wash racks only.

  • Cleaning up spills in the work area immediately.

  • Reporting spills to the chain of command.
 Federal Environmental
Clean Air Act (CAA)

 Soldiers comply with the CAA by-
  • Checking with range control before using gas or smoke.

   • Observing local fire and burning restrictions.

   • Keeping solvent vats closed when not in use.

   • Maintaining and operating equipment properly to minimize air
   Federal Environmental
 National Historic Preservation Act (NHPA)

 Soldiers comply with the NHPA by-

   • Reporting the discovery of artifacts
      and sites to the chain of command.

   • Reporting any damages to historical,
     cultural and archeological sites.

   • Leaving sites undisturbed. Don’t take “souvenirs”.
   Federal Environmental
           Laws      Threatened/Endangered Species
 Endangered Species Act (ESA)

 Soldiers comply with the ESA by-

  • Recognizing signs and markers for
     protected areas.

   • Avoiding habitat areas during
     all operations.

   • Following installation regulations.

   • Obeying range control regulations for          Greater Spotted Eagle
   cutting brush and trees for camouflage.
      Federal Environmental Laws

 Noise   Control Act (NCA)
 Soldiers comply with the NCA by-

  • Avoiding creating unnecessary noise.

   • Respecting noise-buffer zones, minimum
   flight altitudes, no-fly zones, and nighttime
   curfews designated by the installation.
   Host Nation Environmental Laws
 Comply with host nation and international
environmental laws:
 • More or less stringent
 • Final Governing Standards (FGS)
 • Basel Convention Signatory
 • Status of Forces Agreement (SOFA)
      State Environmental Laws
• Comply with state
  – Most States have
  – State laws can be more
    stringent than federal
       Local Laws
• Comply with installation/local and unit
  environmental policies and SOPs.

  – Regional planning areas, counties, cities/town can have
    specific additional requirements.
  – Each installation has an environmental policy issued by the
    post commander (environmental Management System- eMS
    or Sustainability Program).
  – Every unit/organization should have an environmental SOP.
  Installation environmental
Management System (eMS) or
    Sustainability Program
   •   Recycling/Salvage
   •   Conservation
   •   Waste Minimization
   •   eMS or Sustainability Training
   •   Alternative transportation
   •   Alternative energy sources
   •   Sustainability
           Army Guidance

• The Army
  – AR 200-1 (13 Dec 2007)
     Army Environmental Strategy
      “Sustain the Mission – Secure the Future”

• Foster a Sustainable Ethic
• Strengthen Army
• Meet Test, Training and
  Mission requirements
• Minimize Impacts and
  Total Ownership Costs
• Enhance Well-Being
• Drive Innovation
              Operational Guidance
• Comply with Operations Orders (OPORDs), or
  Operations Plans (OPLANs)
   – Joint: Annex L
   – Army: Annex L

• Follow the Overseas Environmental Baseline Guidance Document

• Use FM 3-100.4 Environmental Considerations in Military
  Operations for practical guidance
       Learning Objective #2

• Identify the responsibilities for managing a
  unit environmental program
  Army Environmental Program
           Commander’s Responsibilities
        Army Regulation 200-1
                                  -Comply with environmental legal requirements.
                                  -Instill an environmental ethic
                                  -Incorporate environmental responsibilities and risk
        Environmental Quality
                                   management into unit SOPs/OPORDs
                                  -Integrate environmental considerations into all unit
        and                        operations
        Enhancement               -Ensure personnel receive required environmental
                                  -Appoint and train environmental officers at
                                   appropriate organizational levels.
                                  -Report noncompliance and spills
                                  -Support installation eMS/Sustainabililty Program
        Department of the Army
        Washington, DC
        13 Dec 2007

     Environmental Officer
• Appointment Orders

• Training

• Runs the Unit Environmental Program

• Coordination in planning and risk assessments
                    Team Training
 Ensure that key personnel/teams are trained
 This training should include:
   – Spill prevention/response
   – Hazardous waste operations and emergency response
   – Personal Protective Equipment and first aid for exposure
   – Environmental compliance officer training
   – Specific environmental laws, regulations, and treaties
   – HM/HW handling, storage, transport
   – MSDS recognition and use
   – Field sanitation
   – Satellite Accumulation Points
   – Cultural, historic, religious sites; endangered species
   – Pollution Prevention
        Personnel Requirements
 Training for personnel
    -Accumulation site managers
    -Spill or clean up teams
 Some of this training will require update/
  refresher training.
 Certification must be kept on file.
 Personal Protective Equipment (PPE)
    -Available for personnel
    -Training on PPE use and maintenance
Unit Environmental Program

•   An Environmental Officer/Alternate
•   Required references
•   Awareness Training
•   Unit SOP which includes an environmental section
•   Trained Environmental Teams
•   Spill Kits
•   Personal Protective Equipment
•   Unit Self Assessment
•   Environmental files and records
Environmental Training Sources
  •   Installation Environmental Training Courses
       – Environmental Officer
       – Spill Team Training
       – Field Sanitation

  •   Resident Training Courses
       – Army Logistics Management College, Fort Lee
       – Defense Logistics Agency, Fort Belvoir
       – Corps of Engineers Professional Development Center,

  •   Online Courses
       – Environmental Officer Course, MANSCEN Blackboard
       – Army e-Learning Skillsoft website
       – USAES-DEI website Product Catalog

  •   Army Correspondence Course Program (ACCP).

  •   TRADOC Critical Common Tasks (5 Environmental Tasks)

This is the basic SPILL DRILL
but every unit should have a
tailored plan depending on the
hazards found in the unit.
          Learning Objective #3
               Unit Self Assessment
• Demonstrate use of the Environmental Checklists in
  Appendix A, Table A-1 of TC 3-34.489 The Soldier and
  the Environment to conduct a unit self assessment.
                Vehicle Maintenance
•   Maintain vehicles and equipment in accordance with (IAW) TM
•   Clean up spills immediately
•   Collect used rags in a dirty rags container
•   Collect used dry-sweep compound for reuse
•   Recycle solvents and coolants
•   Return damaged parts and assemblies to
    the supply facility for rebuilding or recycling
•   Place drip pans, diapers, or absorbents under vehicles
•   Locate waste accumulation containers close to the source of the waste
•   Label and date waste accumulation containers
               Weapons Maintenance
•   Dispose of contaminated patches and cleaning equipment properly
•   Reuse cleaning equipment and lubricant containers when possible
•   Purchase lubricants in bulk, and refill smaller containers
•   Recycle cleaning solvents
•   Keep the lids on solvent vats closed when not in use
                 CBRN Maintenance
• Keep a copy of the applicable MSDS for each HM on hand in a
• Collect HM (used filters, decontamination materials, and cleaning
  solutions at the point of generation, and dispose of them properly
• Mark and turn in damaged equipment
• Reuse mask carriers and cleaning equipment
• Store STB containers in separate
  locations that are dry and well ventilated
• Dispose of HW and batteries according
  to the unit SOP
• Turn in excess repair parts so that other
  units can use them
• Dispose of out-of-date, chemical-agent
  kits properly as HW
     Supply, Storage, Transportation
• Substitute less hazardous solvents and cleaning solutions where
  permitted (use “green” cleaning supplies)
• Select items that have less packaging to dispose of
• Take leftover items (such as paint or excess parts) to the installation
  reissue center
• Store materials according to MSDS guidelines
• Keep a copy of the applicable MSDS for each HM on hand in a binder
• Label and date new supplies
• Place new supplies to the back of the storage area (First In – First
• Avoid stockpiling or keeping items around “just in case they are
• Keep recycling containers free of trash and garbage
• Turn in excess or damaged repair parts and tools as stated in the unit
  maintenance or supply SOP
• Turn in excess paint, solvents, cleaners, and supplies to the
  installation supply point
• Implement a shelf life watch program
   Supply, Storage, Transportation
• Purchase cleaning solvents and lubricants in bulk,
  and refill smaller containers as needed
• Recycle materials as required by the installation
  recycling program
• Reuse containers when possible
• Dispose of solid waste and HW according to local
• Purchase cleaning solvents and lubricants in bulk,
  and refill smaller containers as needed
• Transport paint, solvents, cleaners, and other HW
  and HM safely as required by existing
  requirements. Ensure that there are proper
  placards and that appropriate spill-containment
  equipment is with the vehicle
                 Refueling Operations
• Report spills immediately
• Ensure that a properly stocked spill kit and PPE are readily
• Place the refueling nozzle in a drip pan, not on the ground
• Place drip pans, diapers, or absorbent material (such as floor
  sweep) under vehicles when refueling
• Place fuel cans in a drip pan for refueling
  or storage
• Ensure that each refueling vehicle has at
  least two fire extinguishers
• Ensure that potable water is available for
  emergency eye washing
• Reuse overpack drums to transfer
  contaminated soil
• Recycle used or contaminated POL products
• Dispose of contaminated soil and absorbents according to
  installation policy
               Field Sanitation/Mess
• Enforce the use of field latrines instead
  of expedients such as “catholes”
• Collect litter and solid waste at the
  source (mess site, aid station, or issue
• Segregate the wastes
• Store perishable items (such as food)
  properly to reduce spoilage
• Reuse waste accumulation containers
• Ensure that waste accumulation
  containers have lids that keep out
  weather and pests
         Maneuver Damage Control
•   Identify environmental risks before going to the field as part of
    Composite Risk Management
•   Brief personnel on maneuver damage considerations and minimization
•   Develop a plan to minimize or eliminate environmental risks
•   Identify areas that contain threatened or endangered species
•   Observe convoy restrictions
•   Cross streams and ditches only at approved crossing points
•   Drive carefully in forested areas to avoid damaging vegetation
•   Drive only on approved road or trails
•   Avoid unnecessary noise by not revving
•   Use camouflage netting instead of live
•   Reuse wire, barrier materials, and sandbags
•   Recycle materials at collection points
           Weapons/Demo Training
• Check with range control for artillery noise-buffer zones near the
• Check with airfield operations concerning no-fly zones
• Adhere to nighttime-gunnery curfews
• Keep demolitions below the maximum permissible weight specified
  by range control
• Avoid excessive vehicle noise when homes are located near range
• Use the forest and the terrain as buffers between noisy training and
  noise-sensitive areas
• Aim firearms away from noise-sensitive areas
• Avoid detonating large charges when the wind is blowing from the
  demolition grounds towards noise-sensitive sites or when
  temperature inversions are likely to be present
• Avoid making noise in the habitat of endangered species
• Respect noise-buffer zones and altitude restrictions in forest-service
  land or other areas of exceptional quiet
• Police up all brass and packaging material
                         Wash Racks

•   Ensure the oil/water separator works
    properly. If it does not, report it.
•   Ensure trash is properly disposed of
•   Use only approved detergents
•   Ensure police of the wash rack area
    when unit is done washing.
        Satellite Accumulation Point
 Containers cannot be larger than 55 gallons or 1 quart for
  acute HW.
 Containers are located near the HW point of origin.
 Containers controlled by generator.
 Containers must be clearly marked.
 Containers must be dated once
  first drop of waste is put in the
 Full containers must be turned in
  within 72 hours (includes
  non-business days).
                 Recycling Program

• Ensure Soldiers know what gets recycled.
• Ensure dumpsters are checked for violations.
• Identify a unit recycling POC.
    Solid Waste Program

•   Proper police of area of responsibility
•   Keep lids on dumpsters, trash receptacles
•   Don’t mix wastes
•   Police up brass/packaging at ranges.
    Ensure proper turn-in of brass.
           Spill Prevention
•   Ensure the unit has a current Spill Plan.
•   Have an inventory of unit liquids and their location.
•   Know where PPE and Spill Kits are located.
•   Know who to notify in the event of spills.
Hazardous Material

  Any material,
   including waste, that
   may pose an
   unreasonable risk to
   health, safety,
   property, or the
Common Hazardous Material

         Alcohol
         Antifreeze
         Batteries
         Paint
         Solvent
         Cleaning supplies
         Fuel
         Super Tropical Bleach
         Field sanitation kits
         Fuel antifreeze
General Rules for Managing HM
    Use non-hazardous substitutes when
    Have an MSDS for every HM.
    Do not mix different HM together.
    Do not stockpile HM.
    Consolidate storage of HM.
    Inspect HM storage areas weekly.
    Prevent spills.
    Ensure availability of PPE.
    Follow first in, first out rule.
    Implement shelf life program.
    Maintain an inventory list.
   General Rules for Managing HM

 Ensure labels are legible.
 Ensure lids are tight, containers are marked, labeled and
  visible to the observer.
 Provide secondary containment.
 Store flammable and reactive materials in accordance with
  regulations away from the property line.
 Secure containers.
Waste Determination
    There are three ways a waste
    can be regulated as hazardous:

     Meets the definition of one or more of the
      hazardous waste characteristics. The four
      characteristics are ignitable, corrosive,
      reactive and toxic.

     Is listed by EPA as a hazardous waste in 40
      CFR 261.

     Prior knowledge, e.g. testing
HM Transformation to HW

Expires    By Law      Discarded

Unusable   Mixtures   Contamination
        Common Facility/Unit Waste
   Contaminated oil
   Used batteries and acid
   Used solvents
   Contaminated fuels, when non-recyclable
   Discarded fertilizers, pesticides and herbicides
   Expired or discarded paints, inks, acids and oxidizers
   Mixed waste
   Used brake fluids
   Used filters
   Discarded explosives
   Lead tire weights and battery connectors
   Weapons cleaning material (all)
   Painting material
   Expired shelf-life material
            Learning Objective #4
               Areas of Noncompliance

• Enforce compliance when noncompliance is identified
   – Citing the laws and regulations that pertain
   – Make on-the-spot corrections
   – Reporting to the chain-of-command those areas that need
     command emphasis for remedy
   – Include recommended COA
          Example Area of Noncompliance
        Oil Water Separator not working at the unit wash rack

   – Citing the laws and regulations that pertain
   (Clean Water Act)
   – Make on-the-spot corrections
   (Close the wash rack, clean up any oily water residue, use
   another wash rack to finish washing vehicles)
   – Reporting to the chain-of-command those areas that
     need command emphasis for remedy
   – Include recommended COA
(Report this to the wash rack POC, environmental officer,
commander/staff. Have work order submitted. Recommend
the wash rack stay closed until it is repaired and tested)
          Terminal Learning Objective

 ACTION: Enforce applicable environmental protection laws and regulations.

 CONDITION: As a small unit leader given a mission, environmental
  references and a unit environmental officer, with the responsibility to enforce
  compliance with applicable environmental legal requirements within the area of
  responsibility (AOR).

 STANDARD: Enforce environmental legal requirements within the AOR by
  assisting Soldiers in identifying specific environmental duties during mission
  activities and reporting problems to the chain of command with appropriate

US Army Engineer School
Directorate of Environmental Integration
Phone: 573.329.1931

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