Hazardous Property Requiring Special Processing
The following guidance outlines procedures for the turn-in of Hazardous Property (HP) which will be identified as either Hazardous Material (HM) or Hazardous Waste (HW). These procedures are intended to assist commanding officers, accountable supply officers, environmental staff and generating activities in conducting day-to-day business operations with their 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, state and local regulations, it is necessary that field sites obtain and become familiar with applicable Codes of Federal Regulation (CFRs), State regulations, DoD regulations, and Final Governing Standards (FGS) for host nations.
Hazardous Property (HP) must be properly identified. Your responsibilities include identifying hazardous property as either Hazardous Material (HM) or Hazardous Waste (HW) based upon applicable federal/state/local/foreign country laws and regulations. Hazardous Material (HM) is generally unused, unopened items capable of use as originally intended. Hazardous Waste (HW) is generally used, opened, damaged, contaminated, or expired materials that are no longer capable of being used for their intended purpose without undergoing some type of processing.
Receipt in Place (RIP) Agreement. DLA Disposition Services provides disposal services for customers by accepting accountability of HP through a “receipt in place (RIP)” agreement. RIP agreements can be arranged using one of the DLA Forms provided below, a Memorandum of Understanding (MOU) or an Inter Service Support Agreement (ISSA). These agreements allow turned-in property to be receipted onto Disposition Services accountable record while staying in physical custody of the generator.
Hazardous Waste Profile Sheet (HWPS), DLA Form 2511. Disposition Services customers are encouraged to prepare the HWPS electronically using the automated Hazardous Materials Management System (HMMS) or the Generator Communication (GenComm) system. A new HWPS is required from generating activities for each new waste stream. Annual renewal of a HWPS must be accomplished by submitting a replacement HWPS or a certification letter as identified in DoDM 4160.21-V2, Enclosure 7, paragraph 5d(2). A new HWPS is required when an activity’s process change results in changes to the characteristics described on a waste stream’s existing HWPS. Laboratory chemicals, processed in accordance with DoDM 4160.21-V4 are exempt from waste profile requirements; however, all other identification requirements apply (i.e., Safety Data Sheet (SDS)).
Once a HWPS is established for a given waste stream, a Waste Profile Number is generated to identify that HWPS. Future turn-ins of identical waste streams may use the corresponding Waste Profile Number rather than creating a new HWPS. The Waste Profile Number will be identified on the DTID itself.
A HWPS is not required for unopened HM downgraded to HW (e.g., expired shelf-life HM or HM that survives RTDS). However, a Safety Data Sheet (SDS) with all information required for identification of hazardous material, waste, or property is still required (either hard copy or by electronic transmittal). If an SDS is not available or indicates the composition is proprietary, a HWPS is required.
Information entered on the HWPS 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.
For overseas, assign the host nation or IMDG shipping description.
Safety Data Sheets (SDS) are an OSHA requirement placed on chemical manufacturers to provide specific information about the chemicals they produce and sell. An SDS is required to accompany all hazardous property when sold or transported. The Hazardous Materials Information Resource System (HMIRS) is the typical mode of providing SDS information during the turn in process. Laboratory analysis may be required if unable to obtain an SDS through HMIRS or by contacting the chemical manufacturer.
Turn-in activities shall provide a hard copy SDS or indicate on the DTID the SDS five digit alpha code from HMIRS.
Marking and Labeling Requirements. Chemical hazard labels are required to be attached to individual package or unit container. In the absence of proper labeling, DLA Form 2521 must be used. Generating facilities should become familiar with all federal, state, and local regulations as they pertain to each facility’s specific needs. The following links may be used as a starting point.
Turn In Instructions
Customers will prepare turn-in documentation in accordance with DODM 4160.21 V1-V4; Enclosure 4 of Volume 1 of this manual provides instructions on preparation of the DTID, DD Form 1348-1A. As of October 1, 2005, automated and electronic DTID transfer documentation will be mandatory for normal, day-to-day turn-in of HM or HW. Exception to automated and electronic transfers will be allowed in contingency operations or under unique circumstances when such transfer is not feasible.
The servicing Disposition Services site is available to provide assistance with preparing hazardous property and documentation for turn-in. Important information to be identified on the 1348-1A is depicted in the HAZMAT 1348-1A example provided on this page and listed below.
- Unit of issue and Quantity of Contract Line Item Number (CLIN) Requested
- Signal Code and MILSBILLS Fund Code
- Disposal Authority Code
- DEMIL Code
- Supply Condition Code
- Ship From and Ship To DODAAC
- Mark For HM (Hazardous Material) or HW (Hazardous Waste)
- Freight Classification and Nomenclature
- Total Weight, Number of Containers, & Type of Container
- Document Number (DTID)
- Contract Number, CLIN, & Bill to DODAAC
- Waste Profile Number/SDS Number
- Accumulation Start Date & Point of Contact Information
- Container Number, Storage Location, & EPA Waste Codes may be provided (Optional)
The Department of Defense (DoD) has identified specific property that requires 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 Reutilization, Transfer, Donation or Sale (RTDS) while other property on the list may have to be processed directly to disposal. See disposal guidance in DoDM 4160.21-V4 for hazardous property special processing requirements.