Hazardous Property Requiring Special Processing
The following guidance outlines procedures for the turn-in of hazardous material (HM) hazardous waste (HW), and other types of waste. Some HW may require disposal on a hazardous waste disposal contract in compliance with federal/state/host nation regulations, when discarded for disposal. These procedures are intended to assist commanding officers, accountable supply officers, environmental staff and generating activities in the day-to-day conduct of business with the Disposition Services site. It is not possible to identify the universe of regulatory requirements in this guidance, however, basic turn-in requirements are addressed. To ensure compliance with federal, statute and/or DoD regulations, it is necessary that turn in activities obtain and become familiar with applicable Codes of Federal Regulation (CFRs), state regulations, DoD regulations, and overseas, by the OEBGD or the Final Governing Standards (FGS) for the host nation.
Summary of Preparatory Steps
Detailed turn-in requirements are outlined at ensuing paragraphs. Your servicing Disposition Services site is available to provide additional information and assistance in preparing hazardous property and documentation for turn-in.
- Identify the property (HM or HW, other (e.g., PCBs), NSN/LSN, nomenclature or chemical
- Condition of Property - Non-leaking, safe to handle
- Packaging and transportation according to 49 CFR, if transporting HM/HW off-site
- Provide disposal funding information for the DTID (MILSBILLS fund code, Bill to DoDAAC, Contract Line Item Number (CLIN) cost per lb., Total CLIN Cost.
- 1348-1a
- For PCBs, gas chromatography lab analysis, PCB marking on PCB Items)
- For Hazardous Material
- Material Safety Data Sheet
- Hazardous Chemical Warning Label (DD Form 2521)
- Packaging, marking, labeling of property
- DoT Shipping Paper, if transporting HM off-site
- For Hazardous Waste
- Characterize the waste and prepare a Hazardous Waste Profile Sheet (HWPS)
- Use user's knowledge of waste or lab analysis or other identifying information
- Packaging, marking, labeling of property
- Hazardous Waste Manifest, Land Disposal Restriction(LDR), if transporting HW off-site
Identification of Hazardous Property
Hazardous Property (HP) must be properly identified. Your responsibilities include identifying hazardous property as either hazardous material (HM) or as hazardous waste (HW) based on the definitions of HM and HW in DoD 4160.21-M and various federal/state/local/foreign country laws and regulations. The following guidance is based on DoD policy and shall be used in conjunction with applicable federal, state, and/or local environmental regulations
- Hazardous Material (HM). Generally unused, unopened items capable of use as originally intended
- Hazardous Waste. Generally used, opened, damaged, contaminated, or expired materials that are no longer capable of being used for its intended purpose without undergoing some type of processing
- Polychlorinated Biphenyls (PCBs)
- Asbestos
The list below is property requiring special processing, which is subject to unique regulatory constraints, because of the nature of the property or its container. Some types of property may be processed for R/T/D/S, and other property on the list, may have to be processed directly to disposal. See disposal guidance in DoD 4160.21-M, Chapter 10, Attachment 1.
- Asbestos
- Asbestos contaminated safe/file cabinets
- Batteries
- Blast media
- Carbon composite fiber material
- Chemical Defense Equipment (CDE)
- Chlorobromomethane/Bromochloromethane (CB) fire extinguishers
- Compressed gas cylinders
- Containers (empty)
- Dental amalgam
- Drugs and Biologicals (FSC 6505)
- Epinephrine sharps
- Fluorescent lamp ballasts
- Fluorescent light tubes and high intensity discharge lamps (HID)
- Lab packs for small quantity chemical items
- Liquid rocket propellants and associated products
- Medical waste
- Mercury vapor lamps
- Metalworking machines
- Oil (used oil)
- Opened containers
- Organic peroxides
- Over-packed HM
- Ozone depleting substances (ODS)
- Pesticides
- Polychlorinated biphenyls (PCB)
- Radioactive mixed waste
- Refrigeration Equipment
- Spill residue and hazardous debris
- Storage tanks
- Tires - discarded/scrap
- Toxicological, biological and radiological agents/materials
- Treated wood products
- Universal waste
- Used oil filters
Turn-In Instructions for Hazardous Property
All property must be accompanied by a properly prepared DD Form 1348-1A, Disposal Turnin Document (DTID), according to DoD 4000.25-1-M, MILSTRIP. A minimum of an original and three legible copies must accompany property turned in for disposal processing. If a copy is needed for the delivery agent, an original and four legible copies must accompany the property.
- The following items must be provided with all Hazardous Material turn-ins:
- Valid NSN and noun name as cataloged in the supply system or LSN/FSC and chemical name of hazardous components
- Chemical name of hazardous contaminants and noun name of non-hazardous contaminants
- Amounts of hazardous and non-hazardous contaminants based on user's knowledge or testing of the item expressed in a range of content (percentage by weight or ppm) as applicable
- MILSBILLS fund code (position 52-53)
- Billing DoDAAC in block 27
- Contract Line Item Number (CLIN) in block 27
- Total cost of disposal in block 27
- Container certification statement, for HM or HW, in block 27, as follows: (1) The hazardous material is packaged in containers as prescribed in the Department of Transportation CFR 49 170-189, or (2) The hazardous material is packaged in containers of equal or greater strength or efficiency as prescribed in the Department of Transportation 49 CFR 170-189
- The following items must be provided with all Hazardous Waste turn-ins:
- "HW" in block 4 of the DD 1348-1A.
- A valid NSN and noun name as cataloged in the supply system, or LSN/FSC and chemical name of hazardous components, if the waste is not identified by NSN
- MILSBILLS fund code (position 52-53 of the DD 1348-1A)
- Billing DoDAAC in block 27 of the DD 1348-1A
- Contract Line Item Number (CLIN) in block 27 of the DD 1348-1A
- Total cost of disposal in block 27 of the DD 1348-1A
- Disposition Services site-assigned HW profile reference number in "Remarks" section, if this is not the initial turn-in of the waste stream
- For non-NSN HW, the word "waste" followed by the proper shipping name in block 27, as shown in DoT 49 CFR 172
- For NSN HW, the word "waste" followed by proper shipping name in block 27
- Container certification statement in block 27
Responsibilities for Receipt and Disposal
Occupational Safety and Health Act (OSHA) Compliant Label
- For turning-in hazardous material, an OSHA compliant chemical label is to be attached on the
individual package (unit container). The OSHA requires the following information on the label:
- Hazardous chemical(s)name
- Health hazard warnings/protection information (including target organ effects)
- The name, address of the manufacturer, importer or other responsible party
Material Safety Data Sheet
The MSDS is an OSHA requirement levied on chemical manufacturers to provide specific
information about the chemicals they produce and sell. The MSDS must accompany the
product(s) when sold. Subsequently the buyer, or whoever uses the chemicals, must maintain
the MSDS in their plant or storage area, to ensure the MSDS information is available for the
safety of the employees who use or handle the chemicals. The MSDS is prepared by private
industry and must be prepared by professional chemists and/or industrial hygienists who know
and understand the chemical and physical properties of the chemicals, and who sign and verify
its correctness. OSHA (29 CFR) provides a specific outline of what must go in an MSDS. DLA
or DoD employees (unless they are chemists or industrial hygienists who has responsibility to
prepare MSDSs) do not prepare, verify or sign an MSDS.
Turn-in activities shall provide a hard copy MSDS, or indicate on the DTID the MSDS five digit
alpha code from the Hazardous Material Information System (HMIS), with turn-ins of unused,
unopened HM, and with used and/or opened HM.
he MSDS must match the specific manufacturer of the hazardous material and should
include the manufacturer's name or CAGE code
In addition to an MSDS, used and/or opened HM requires that the chemical name of any hazardous contaminants and the noun name of any non-hazardous contaminants be identified on the DTID. Used and/or opened HM may have become contaminated with constituents not reflected on the MSDS. A Hazardous Waste Profile Sheet may also be required for used/opened HM going directly to waste disposal contract.
Hazardous Waste Profile Sheet (HWPS)
Turn-in activities are required to provide a Hazardous Waste Profile Sheet, DRMS Form 1930 with the turn-in of each initial waste stream and once a year thereafter
A HWPS is required with turn-ins of HW and used and/or opened HM that meets the definition of a HW when discarded by disposal service contract. Used and/or unopened HM is considered contaminated and may not be the same property described in an MSDS
Generators will complete the form by providing requested information or by entering "N/A" when applicable. The information may be based on user's knowledge and/or laboratory analysis of the waste. Supporting documentation may be required if user's knowledge does not identify or characterize the waste sufficiently or correctly
Supporting documentation consists of chemical analysis, description of waste production processes including raw materials, end products, and other sources of how the waste was generated
After the initial turn-in of the waste, turn-ins of identical waste will not require a HWPS; instead, generators will enter a Disposition Services site-assigned HWPS reference number in block 27 of the DTID
The turn-in activity shall certify each HWPS annually by either providing to the Disposition Services site a new signed and dated HWPS or an electronically transmitted HWPS for each waste which will be generated during the following year
For overseas, assign the host nation or IMDG shipping description
Laboratory chemicals are exempt from waste profile requirements provided they are processed according to DoD 4160.21-M, Chapter 10, Attachment 1
Marking and Labeling
Hazardous property shall be marked and labeled in conformance with established environmental, safety and transportation laws and regulations
Turn in activities are required to ensure that HM is properly labeled according to 29 CFR requirements. OSHA compliant hazard warning labels, tags or markings are required to be completed and attached/affixed to all HM except for the specific exclusions found in DoD 4160.21-M
Before transporting HM/HW off-site, generators must label and mark each package according to DoT/EPA regulations. Labeling and marking requirements for transport of HW are prescribed in 40 CFR 262.31 and 262.32. Marking and labeling requirements for both HM and HW are prescribed in 49 CFR 172, Subparts D and E.
PCB markings requirements are prescribed in 40 CFR 761. Items containing 50 ppm or more PCB must be marked, with the exception of transformers. Only transformers with 550 ppm or more PCB must be marked
Friable asbestos packages must be labeled with the following wording:
DANGER
CONTAINS ASBESTOS FIBERS
AVOID CREATING DUST
CANCER AND LUNG DISEASE HAZARD
Placarding. Before transporting HM/HW off-site, generators must placard or offer the initial transporter the appropriate placards according to 49 CFR 172, Subpart F