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.

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

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.

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.

Responsibilities for Receipt and Disposal

Occupational Safety and Health Act (OSHA) Compliant Label

Hazardous materials manufacturers are required to have the label on their products. Where the OSHA compliant label information is missing or damaged, a DoD Hazardous Chemical Warning Label (DD Form 2521) will be attached to the HM per DoD 6050.5-H, Hazardous Chemical Warning Labeling System. Data elements for each section can be obtained from the MSDS.

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

Required Documents

Blank 1348

1348

1348 Instructions

1348

Refrigerant Removal Statement

Refrigerant Removal Statement

Hazardous Chemical Warning Label

Hazardous Chemical Warning Label

Hazardous Waste Profile Sheet

Hazardous Waste Profile Sheet