ENVIRONMENTAL / HAZMAT STANDARD OPERATING PROCEDURE

176th Engineer Brigade (TXARNG)

Administrative Data

Field	Value
Effective Date	[DD MONTH YYYY]
Supersedes	[Previous SOP Date or N/A]
Review Date	[Annual Review Date]
Approval Authority	[Commander Name, Rank]

1. PURPOSE

This SOP establishes minimum hazardous material (HAZMAT) and environmental protection requirements for every unit in the formation—including Headquarters and Headquarters Company, battalions, companies, and detachments—to identify, control, handle, store, transport, inspect, report, and respond to hazardous materials, hazardous waste, environmental hazards, and hazardous material incidents.

This SOP is based primarily on AR 200-1, AR 350-1, and AR 600-55, and incorporates applicable U.S. Environmental Protection Agency (EPA) statutes and implementing regulations where they govern hazardous waste, releases to the environment, transportation, storage, training, recordkeeping, and reporting.

The purpose of this SOP is to prevent injury, exposure, contamination, fire, explosion, environmental damage, unsafe transportation, and improper storage of hazardous materials at the unit level. The scope of this SOP is expanded to include EPA regulatory requirements that apply to unit operations across the formation and to unit Standard Operating Procedures that implement this publication (for example, hazardous waste identification and management, contingency planning, spill and release reporting pathways, and alignment with installation environmental programs).

Every unit will publish Standard Operating Procedures that implement this publication and prescribe unit-specific hazardous materials, hazardous operations, storage locations, transportation requirements, spill response procedures, environmental protection measures, and training requirements required by that unit's mission.

This SOP applies to all hazardous materials, hazardous waste, hazardous operations, and hazardous exposure conditions encountered during unit operations, training, maintenance, storage, transportation, fueling, medical response, ammunition handling, and field activities conducted by formation units.

Common examples include fuels, POL, cleaning chemicals, solvents, batteries, compressed gases, corrosives, paints, adhesives, bloodborne pathogens, contaminated waste, ammunition, pyrotechnics, explosives, and hazardous maintenance byproducts.

2. APPLICABILITY

This SOP applies to all assigned, attached, supporting, and temporary duty military personnel, Department of the Army Civilians, contractors, and visitors operating within unit-controlled or formation-controlled facilities, motor pools, maintenance areas, training areas, ammunition holding areas, supply areas, fueling points, transportation operations, and field environments where hazardous materials are present.

This SOP applies during:

Garrison operations
Field training exercises
Convoy operations
Maintenance operations
Fueling operations
Ammunition operations
Recovery operations
Deployment operations
Emergency response operations
Railhead, airhead, and port operations
Temporary storage operations
Tactical assembly area operations

Every unit will publish Standard Operating Procedures consistent with this publication and installation requirements.

Nothing in this SOP replaces installation environmental requirements, fire code requirements, OSHA standards, ammunition and explosives safety requirements, federal transportation requirements, or technical manual guidance.

When conflicts exist between this SOP and higher guidance, the more restrictive requirement applies.

3. REFERENCES

3.1 Primary Governing Publications

AR 200-1, Environmental Protection and Enhancement
AR 350-1, Army Training and Leader Development
AR 600-55, The Army Driver and Operator Standardization Program

3.2 Supporting Publications

U.S. Environmental Protection Agency (EPA) regulations and officially published guidance applicable to hazardous waste, hazardous substances, emergency planning and release reporting, air and water protection, and pollution prevention where federal law applies
AR 385-10, The Army Safety and Occupational Health Program
AR 25-400-2, Army Records Management Program
AR 750-1, Army Materiel Maintenance Policy
DA Pam 750-8, The Army Maintenance Management System (TAMMS)
DA Pam 385-64, Ammunition and Explosives Safety Standards
49 CFR Parts 100-185
29 CFR 1910.1200
29 CFR 1910.1030
Resource Conservation and Recovery Act (RCRA)
Clean Water Act (CWA)
Applicable Safety Data Sheets (SDS)
Applicable Technical Manuals
Installation environmental guidance
Installation fire code guidance

3.3 External Environmental and Spill Reporting Resources

Texas Commission on Environmental Quality (TCEQ) Spill Response Program: https://www.tceq.texas.gov/response/spills
Texas Spill Reporting Rules - 30 TAC Chapter 327: https://texreg.sos.state.tx.us/public/readtac$ext.ViewTAC?tac_view=5&ti=30&pt=1&ch=327&sch=A&rl=Y
TCEQ Spill Reporting Guidance and Thresholds: https://www.tceq.texas.gov/response/spills/spill_rules.html
National Response Center (NRC) Oil and Hazardous Substance Reporting: https://www.epa.gov/emergency-response/national-response-center
EPA Oil Spill Reporting Requirements: https://www.epa.gov/oil-spills-prevention-and-preparedness-regulations/reporting-requirements-oil-discharges
OSHA Hazard Communication Standard (29 CFR 1910.1200): https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.1200
OSHA Bloodborne Pathogens Standard (29 CFR 1910.1030): https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.1030
Pipeline and Hazardous Materials Safety Administration (PHMSA): https://www.phmsa.dot.gov/hazmat
Electronic Code of Federal Regulations - 49 CFR Hazardous Materials Transportation: https://www.ecfr.gov/current/title-49/subtitle-B/chapter-I/subchapter-C
Army Publishing Directorate: https://armypubs.army.mil
Texas Department of State Health Services - Bloodborne Pathogen Information: https://www.dshs.texas.gov/hivstd/healthcare/bbp.shtm
EPA Used Oil Management Program: https://www.epa.gov/hwgenerators/used-oil-management-program
EPA Spill Prevention, Control, and Countermeasure (SPCC) Guidance: https://www.epa.gov/oil-spills-prevention-and-preparedness-regulations/spill-prevention-control-and-countermeasure-spcc-rule-overview
EPA Universal Waste (includes batteries and certain lamps): https://www.epa.gov/hw/universal-waste
EPA Hazardous Waste Generators Regulatory Summary: https://www.epa.gov/hwgenerators

4. DEFINITIONS

4.1 Hazardous Material (HAZMAT)

Any material capable of causing injury, illness, fire, explosion, contamination, environmental damage, or mission degradation when improperly handled, transported, stored, or disposed of.

4.2 Hazardous Waste

Any hazardous material designated for disposal or determined contaminated, leaking, expired, damaged, or unserviceable.

4.3 Secondary Containment

A containment system designed to capture leaks or spills from a primary container.

Examples include:

Spill pallets
Containment berms
Drip pans
Double-walled tanks

4.4 Spill

Any unauthorized release or discharge of hazardous material outside approved containment.

4.5 Exposure Incident

Any actual or suspected contact with hazardous chemicals, contaminated fluids, bloodborne pathogens, fuels, vapors, or explosives residue.

4.6 Universal Waste

Certain widely generated wastes—especially batteries (for example, lead-acid, nickel-cadmium, lithium)—and some lamps can qualify as universal waste when managed under streamlined EPA/state rules (container marking, proper storage time limits, no breakage/disposal in ordinary trash for hazardous components, and turn-in through authorized handlers). Units will not assume ordinary solid waste disposal without installation environmental approval.

5. RESPONSIBILITIES

5.1 Brigade Commander

Establish hazardous material and environmental protection policy for units in the formation.
Ensure all units in the formation implement compliant programs.
Ensure adequate training, inspections, spill response capabilities, and environmental controls exist.
Ensure hazardous operations are incorporated into risk management.

5.2 Battalion Commanders

Develop battalion Standard Operating Procedures implementing this publication.
Identify battalion-specific hazardous operations.
Conduct inspections and enforce compliance.
Monitor environmental protection compliance.

5.3 Company Commanders

Identify company hazardous materials.
Establish approved storage locations.
Ensure personnel are trained before exposure.
Ensure spill kits, PPE, SDS, and environmental controls are available.

5.4 First Sergeant

Ensure HAZMAT and environmental training is incorporated into training schedules.
Monitor unit compliance during operations.
Ensure deficiencies are corrected immediately.

5.5 Platoon Leaders and Platoon Sergeants

Coordinate hazardous material training.
Conduct walkthrough inspections.
Monitor hazardous operations.
Ensure personnel understand emergency procedures.

5.6 First-Line Supervisors

Identify hazards and unsafe conditions.
Ensure personnel are trained and supervised.
Stop unsafe operations immediately.
Ensure hazardous materials remain labeled and secured.
Ensure environmental contamination hazards are mitigated.

5.7 Individual Personnel

Will not handle hazardous materials unless trained and authorized.
Will report unsafe conditions immediately.
Will use required PPE.
Will stop unsafe acts when imminent danger exists.
Will immediately report spills, leaks, contamination, or damaged containers.

6. HAZARDOUS MATERIAL HANDLING

6.1 General Requirements

Personnel will review SDS guidance before handling unfamiliar hazardous materials.
Hazardous materials will remain in approved and labeled containers.
Personnel will not mix chemicals unless specifically authorized by SDS or technical guidance.
Eating, drinking, smoking, or vaping is prohibited in hazardous handling areas.
Personnel will wash exposed skin immediately after handling hazardous materials.

6.2 Required PPE by Task Category (Four Protection Levels)

Selection rule: SDS Section 8 and installation industrial hygiene guidance override this paragraph. Manufacturer chemical compatibility charts (breakthrough / degradation) govern glove material for the exact product SKU in use. When uncertain, stop work and confirm with safety or environmental personnel.

Use the highest protection level required when multiple hazards overlap (for example, solvent-based brake cleaner is Level III, not Level II).

Level I — Standard POL (fuels, motor oils, hydraulic fluids, transmission fluids, greases)

Typical tasks: dipstick checks, filter changes with controlled drainage, filling approved reservoirs, wiping minor external seepage with rags, handling sealed factory containers.

Hands: Disposable nitrile gloves minimum (heavier-duty nitrile or supported nitrile when abrasion, heat, or longer contact is expected). Do not use damaged or solvent-softened disposables for fuel/oil work.
Eyes / face: ANSI/ISEA Z87.1 safety eyewear with side protection (side shields or documented wraparound geometry).
Body: Shop coat optional for cleanliness; add oil-resistant apron when substantial soak-through is likely.
Respiratory: Not routinely required for low-vapor POL handling unless SDS, odor/vapor complaint, or confined space controls dictate otherwise.

Level II — Chemical cleaning agents (aqueous and formulated cleaners, detergents, degreasers sold as cleaners, alkaline/acid wheel or bilge products)

Typical tasks: spraying or brushing commercial cleaners, mixing concentrates with water, scrubbing with chemical soak, pressure washing with detergent additives.

Hands: Verify SDS—commonly neoprene or thick nitrile for alkaline cleaners; acid cleaners may require different materials than alkaline. Replace gloves immediately after inner wetting or outer contamination.
Eyes / face: Chemical splash goggles (indirect vent or non-vented per hazard assessment) minimum; add face shield when pouring concentrates or working overhead spray.
Body: Chemical-resistant apron or sleeves matched to the cleaner class.
Respiratory: Ventilation first; NIOSH-approved respiratory protection only under a compliant respiratory program when SDS or exposure assessment requires it (mists, ammonia, chlorine compounds, etc.).

Level III — Solvents and solvent-heavy products (parts washers, mineral spirits, aromatic solvents, acetone/MEK-class materials, many aerosol non-aqueous cleaners including common brake/parts cleaners)

Typical tasks: soaking parts, spraying solvent cleaners, transferring solvents between containers, cleaning brakes or friction surfaces where solvent aerosolizes.

Hands: Assume disposable nitrile is insufficient until the compatibility chart proves otherwise. Common chart selections include butyl, fluoroelastomer (Viton-type), neoprene for subsets, or laminate / “silver shield” barrier gloves as an inner or outer layer—SDS + chart required.
Eyes / face: Chemical splash goggles + face shield when pouring, splashing, or overhead spray is credible.
Body: Solvent-resistant apron when soak or splash exposure is credible.
Respiratory / ignition: Control vapors with ventilation and source containment; use respiratory protection only under a compliant program when required. Enforce ignition source control for flammable solvents IAW AR 385-10 and local fire rules.

Level IV — Automotive lead-acid batteries (electrolyte = sulfuric acid; explosive hydrogen during charging; arc/short hazards)

Typical tasks: removal/installation, terminal cleaning, hydrometer checks, topping where authorized, handling damaged cells, spill response on battery acid.

Hands: Acid-resistant gloves with long cuff, selected against sulfuric acid on manufacturer charts (neoprene, natural rubber, PVC, or other chart-approved materials—verify SKU). Consider inner disposable + outer chemical layer only when approved by safety personnel.
Eyes / face: Chemical splash goggles and face shield when electrolyte exposure is reasonably foreseeable.
Body: Acid-resistant apron for spill-prone tasks.
Additional: remove watches/rings; use insulated tools where arc risk exists; ensure ventilation in charging areas; Level IV supersedes Level I glove choices even if hands also contact grease—wear acid protection first, then change gloves if moving to a different task.

Cross-cutting requirements

ANSI/ISEA Z87.1 marking must appear on primary eye protection used at all four levels.
Personnel requiring prescription correction will use prescription Z87.1 eyewear, OTG safety eyewear, or other approved solutions—street glasses are not sufficient.
Hearing protection when exposures exceed command hearing conservation thresholds.
Roadside / traffic: high-visibility apparel IAW installation motor transport policy (commercial schemes often cite ANSI/ISEA 107 Class 2 or 3).
Respiratory protection: NIOSH-approved devices only when required by SDS, ventilation limits, or assessment—and only with medical clearance, fit testing (when applicable), correct cartridges/filters, training, and maintenance. Improvised or unprogrammed respirator use is prohibited.

Units will stock distinct glove types for Levels I–IV (not one nitrile box for every task), inspect PPE before use, and discard gloves contaminated through the barrier.

6.3 Fuel Handling

Fuel operations will occur only in approved areas.
Engines will be shut off during refueling unless operationally required.
Smoking/open flames prohibited within 50 feet.
Ground guides required during fuel vehicle movement in congested areas.
Fuel spills will be reported immediately.

6.4 Battery Handling

Personnel handling batteries will wear Level IV hand and face protection IAW paragraph 6.2 whenever electrolyte exposure or charging hazards are reasonably foreseeable.
Damaged, swollen, leaking, or thermally stressed batteries will be isolated in non-combustible secondary containment, labeled as damaged, and reported through the chain of command and installation environmental guidance before disposal.
Battery charging areas will remain ventilated, posted no smoking, and clear of combustibles.
Metal tools or conductive jewelry will not bridge terminals; insulate terminals on removed batteries when directed by technical guidance or installation procedures (tape or approved caps).
Do not discard vehicle, tactical, tool, or rechargeable batteries in standard dumpsters, burial pits, burn pits, or drainage structures.
Turn-in, recycle, or dispose of batteries only through installation hazardous/universal waste channels, Defense Logistics Agency disposition, or other command-approved programs.

6.5 Compressed Gas Cylinders

Cylinders will remain upright and secured by chain or approved retention device.
Valve protection caps will remain installed during transport/storage.
Oxygen cylinders will be segregated from fuel gases.

6.6 Bloodborne Pathogens

Bloodborne pathogen kits will contain:

Disposable gloves
Face shield or mask
Absorbent material
Biohazard disposal bags
Approved disinfectant
Hand sanitizer

Personnel exposed to blood or bodily fluids will notify supervision immediately and seek medical evaluation.

6.7 Safety Data Sheets (SDS)

Minimum Requirements

Units will maintain Safety Data Sheets for every hazardous chemical product or formulation present in the unit footprint (garrison, armory, motor pool, maintenance bay, training support area, or forward staging) before personnel use, store, transport, or dispose of that product. SDS must reflect the current manufacturer revision (verify revision date and match to SKU/lot where multiple formulations exist).

SDS will meet 16-section GHS alignment when supplied under applicable hazard communication rules (typically OSHA HazCom-style Sections 1–16); if a legacy format sheet is encountered during transition, replace it as soon as practicable per manufacturer update or installation direction.

Required SDS Records

One current SDS per chemical identity/SKU actually present or authorized for order/stock (including floor-stock, bench cans, and authorized secondary-container recipes prescribed in unit Standard Operating Procedures).
Manufacturer contact and revision date visible on the SDS record kept by the unit.
Superseded SDS retained IAW records policy (AR 25-400-2 and installation records guidance) for liability and exposure-history traceability—do not destroy old revisions immediately unless policy permits.

Access and Availability

During any operation where hazardous chemicals are handled, SDS information must be readily accessible to every shift without delay—workers must not rely on memory or verbal paraphrase alone when Section 2 (hazards), Section 4 (first aid), Section 6 (accidental release), Section 7 (storage), Section 8 (PPE), Section 9 (properties), or Section 13 (disposal) could drive an immediate protective decision.

Acceptable access modes include controlled electronic libraries with verified offline backup, printed binders, installation-licensed SDS portals, or command-approved subscriptions—provided access survives power/network loss when the hazard still exists (for example, cached PDFs on designated rugged devices or printed excerpts for field operations IAW unit Standard Operating Procedures).

SDS—Supplemental Unit Procedures

Unit Standard Operating Procedures will document:

Primary and alternate SDS repository locations (physical binders, controlled network paths, installation portals, or other authorized systems).
Retrieval procedures for all operational conditions to include after-duty-hours, field training, deployment, and contractor support.
Custodial assignments for receiving manufacturer SDS revisions, updating repositories, and conducting periodic audits.
An SDS index cross-referenced to the unit hazardous material inventory (product identifiers, stock numbers, storage locations, or other traceability fields required by the commander).
New product introduction controls prohibiting issue or use until SDS is filed and labeling/container controls are satisfied.

SDS Revisions and Inventory Control

When inventory shows a product without a matching SDS, stop use until the SDS is obtained from the manufacturer/supplier or substitute product is approved. When SDS revision dates advance, units will replace archived copies and brief supervisors on material changes affecting storage class, PPE, or incompatibility.

7. HAZARDOUS MATERIAL STORAGE

7.1 Approved Storage Areas

Hazardous materials will only be stored:

In approved facilities
In approved cabinets
On approved spill containment
In designated hazardous storage areas

Unit Standard Operating Procedures will designate approved storage locations (for example, building, bay, cage, connex, field lay-down site, or ammunition holding area support point); assign custody and access control; prescribe segregation and quantity limits; establish inspection frequency; position spill kits; and coordinate storage execution with installation environmental and fire prevention offices as required. Unwritten practice does not satisfy this requirement.

7.2 Labeling and Secondary Containers

Factory-original containers (preferred)

Retain manufacturer labels whenever practical. Labels must remain legible (replace outer secondary labeling if the factory label degrades—do not obscure chemical identity).
Do not refill factory containers with different chemicals unless manufacturer / SDS explicitly permits it or environmental/safety personnel approve a controlled procedure.

Secondary containers (spray bottles, squirt bottles, oil cans, graduated cylinders, etc.)

Secondary containers are any vessel other than the shipped factory container used to hold hazardous material for storage or dispensing at the point of use.

Secondary containers may be used only when all of the following are true:

Material compatibility (rated / suitable construction): The container material of construction (polymer type, metal alloy, gasket elastomer, spray head chemistry, internal spring chemistry, etc.) is verified against the SDS and manufacturer chemical-compatibility guidance for the specific chemical or documented mixture stored inside. Containers will not be used unless rated or verified suitable—prohibition includes repurposed consumer spray bottles, beverage bottles, food jars, unmarked surplus bottles, or shop containers chosen only for convenience.
Authorized use: Unit Standard Operating Procedures or written commander authorization designate which secondary container types are permitted by work center or mission (for example, approved spray bottles for SKU-specific alkaline wheel cleaner only—not interchangeable labeling).
Locked-in identity: The secondary container holds only one authorized chemical formulation at a time; no sequential reuse for another chemical unless the container is cleaned and inspected IAW an approved procedure that addresses incompatibility and residue removal.

Minimum secondary-label content (in addition to hazard communication)

Every secondary container will display legible English labeling (printed or durable label stock—not fading marker-only labels as sole identification) showing at minimum:

Full product / chemical identity as stated on the SDS (no vague terms such as “stuff,” “degreaser,” “acid mix,” or “John’s bottle”).
Hazard communication: hazard warnings consistent with the SDS (signal word and/or pictograms/GHS-style labeling when required by regulation or installation policy; at minimum copy SDS Section 2 precautionary language summary where prescribed).
Concentration / dilution when not full-strength (for example, “10:1 with potable water,” “prepared [DATE]”).
Transfer date (date placed into the secondary container) and preparer/accountable custodian (printed name or unit-controlled identification code tied to a roster).
Expiration / discard-after date when shelf-life applies after dilution or opening—otherwise mandatory monthly/quarterly scrub dates IAW unit Standard Operating Procedures.
Storage code / segregation cue when units use color borders or numeric schemes prescribed in writing in unit Standard Operating Procedures.

Spray triggers, pumps, and pressurized hand sprayers

Trigger sprayers and pump assemblies must be chemically compatible with the fluid chemistry (many standard triggers fail on aromatic solvents, chlorinated solvents, strong acids, or petroleum fractions).
Replace damaged triggers, cracked bottles, or crazed plastic immediately; remove from service.

Unlabeled or ambiguous containers

Unlabeled containers, partially readable labels, “unknown” liquids, or containers with conflicting markings will be removed from service immediately, quarantined, and evaluated only by qualified environmental/safety personnel or disposed through installation hazardous waste procedures—do not smell, taste, or open near ignition sources during informal identification attempts beyond safe boundary checks.

Secondary Containers—Supplemental Unit Procedures

Unit Standard Operating Procedures will designate approved secondary container stock numbers or models (vendor, material of construction), chemicals authorized in each container class, standard label formats, personnel authorized to prepare transfers, and inspection requirements for motor pool and maintenance dispensing operations.

7.3 Flammable Materials

Flammable liquids will be stored in approved flammable storage cabinets or approved fuel storage areas.
Flammable materials will remain at least 50 feet from open flames, welding, generators, or ignition sources.
NO SMOKING signage required.

7.4 Secondary Containment

Secondary containment required for:

Fuel storage
Oil storage
Bulk chemicals
Hazardous waste accumulation

7.5 Spill Kits

Spill kits will contain at minimum:

Absorbent pads
Absorbent socks or booms
Oil dry
Chemical-resistant gloves
Disposal bags
Eye protection
Isolation tape
Spill reporting procedures

7.6 Fire Protection

Storage areas will maintain:

Properly rated fire extinguishers
Clear access lanes
Posted emergency contact numbers

7.7 Ammunition and Explosives

Ammunition will be segregated by compatibility requirements.
Damaged ammunition will be isolated immediately.
Ammunition storage areas will remain clear of combustible clutter.

7.8 Chemical Storage (RCRA / EPA Risk Controls)

Chemical products (cleaners, solvents, corrosives, oxidizers, pesticides where authorized, adhesives, paints, reagents) will be stored to prevent incompatible mixing, fires, and releases that could reach soil, storm drains, or groundwater:

Store chemicals only in approved locations (flammable cabinets, corrosive cabinets, locked cages, or installation-designated HAZMAT storage)—not in connex bays mixed with rations, sleeping areas, or uncontrolled shop clutter unless command-approved temporary field storage procedures apply.
Keep containers closed except during measured dispensing; replace deteriorated caps and gaskets; wipe threads clean before re-sealing.
Maintain segregation: separate acids from bases/cyanides where incompatible; separate oxidizers from fuels and organic solvents; follow SDS storage class guidance and installation HazMat segregation charts.
Maintain inventory discipline: dated receipt batches where required; rotate stock first-in, first-out for shelf-life limited materials; remove expired or illegibly labeled material from service pending environmental evaluation.
Secondary containment required where spill volume could escape the storage footprint (paragraph 7.4).
Do not store household chemicals, unauthorized pesticides, or unknown liquids without SDS and approval.

7.9 Battery Storage

Store intact batteries upright, secured against tipping, on shelving or spill pallets away from open ignition sources and incompatible reactive chemicals.
Segregate damaged batteries into clearly marked damaged battery accumulation containers approved by installation environmental personnel.
Label accumulation containers Universal Waste—Batteries (or installation-directed wording) and comply with installation accumulation time and storage quantity limits.
Charging stations will post ventilation requirements for hydrogen buildup from lead-acid charging where applicable.

8. HAZARDOUS MATERIAL TRANSPORTATION

8.1 Driver Requirements

Drivers transporting hazardous materials will be properly licensed under AR 600-55.
Drivers will receive hazardous material familiarization training.
Fatigued personnel will not operate vehicles transporting hazardous materials.

8.2 Vehicle Requirements

Vehicles transporting hazardous materials will maintain:

Fire extinguisher
Spill kit
Tie-down equipment
Warning devices
SDS access for transported material

8.3 Cargo Securement

Hazardous cargo will be secured to prevent shifting, leaks, or spills.
Damaged containers will not be transported.
Hazardous materials will not be transported in POVs unless specifically authorized.

8.4 Ammunition Transportation

Smoking prohibited within 50 feet.
Vehicles will not remain unattended unless operationally required.
Leaking or damaged ammunition will be isolated and reported immediately.

8.5 Accident Procedures

During transportation incidents:

Stop vehicle safely.
Isolate area.
Notify chain of command.
Notify emergency responders.
Deploy spill kit if safe.

9. SPILL PREVENTION AND RESPONSE

9.1 Prevention

Units will inspect hazardous areas routinely.
Drip pans required under leaking equipment.
Damaged containers removed immediately.

9.2 Spill Response

Personnel will:

Stop spill source if safe.
Isolate area.
Notify supervision.
Deploy spill containment.
Prevent contamination spread.
Notify emergency services and environmental office.

9.3 Spill Reporting

Immediately report:

Fuel spills
Chemical spills
Sewage contamination
Bloodborne pathogen incidents
Ammunition incidents

10. ENVIRONMENTAL PROTECTION

10.1 General

Personnel will conduct all hazardous material operations in a manner that prevents soil contamination, groundwater contamination, storm drain contamination, air contamination, and damage to environmentally sensitive areas.

Environmental protection requirements apply during:

Maintenance operations
Fueling operations
Field training
Recovery operations
Ammunition operations
Wash rack operations
Spill response operations
Hazardous waste accumulation
Transportation operations

10.2 Spill Prevention

Drip pans will be placed under vehicles or equipment actively leaking fluids.
Vehicles with known leaks will not be parked directly on unimproved soil when hardstand or containment areas are available.
Fuel hoses, pumps, valves, and fittings will be inspected before fueling operations.
Personnel will not leave fueling operations unattended.
Absorbent materials will remain immediately available during fueling and maintenance operations.
Containers will remain closed when not actively dispensing material.
Units will immediately remove leaking containers from service.

10.3 Ground Contamination Prevention

Personnel will not intentionally discharge fuels, oils, solvents, antifreeze, batteries, chemicals, detergents, gray water, or hazardous liquids onto the ground.
Waste oil, used filters, oily rags, contaminated absorbents, and contaminated soil will be processed through approved disposal procedures.
Dry sweep and absorbent material contaminated by hazardous materials will be treated as potentially hazardous waste until evaluated by environmental personnel.
Personnel will not wash hazardous materials into drains, ditches, or roadways.

10.4 Storm Drain and Waterway Protection

Personnel will prevent hazardous materials from entering storm drains, culverts, drainage systems, streams, or waterways.
Spill containment materials will be emplaced immediately when spills threaten drainage systems.
Wash rack operations will only occur in approved locations.

10.5 Hazardous Waste Handling

Hazardous waste is regulated under RCRA (implemented by EPA and authorized states). Units typically operate as very small quantity, small quantity, or large quantity generators depending on monthly accumulation amounts—installation environmental personnel classify the unit/installation generator category and prescribe labeling, accumulation time limits, and shipping documentation.

Hazardous waste containers will remain closed except when adding or removing waste.
Containers will remain labeled with contents hazards and accumulation start dates IAW installation environmental office formats (for example, Hazardous Waste plus accumulation start date and hazard warnings).
Hazardous waste accumulation areas will remain clean, organized, inspected, and secured.
Incompatible hazardous wastes will not be mixed in the same container.
Personnel will not place hazardous waste into standard trash dumpsters, sanitary sewers, septic systems, burn pits, or surface impoundments improvised by the unit.
Personnel will coordinate characterization, packaging, storage time limits, profiling, and turn-in through approved installation environmental procedures (turn-in to installation hazardous waste facility, licensed contractor, Defense Reutilization and Marketing Office / DRMO routes when applicable, or other command-directed disposition).

Examples of hazardous waste commonly encountered in maintenance and motor pool operations include:

Used oil (manage separately from solvent wastes unless installation approves mixing—mixing can disqualify used oil recycling streams)
Solvent waste and solvent-contaminated wipes (evaluate wipes exclusions only through environmental office)
Contaminated dry sweep and spill debris (assume hazardous until characterized)
Paint waste, thinners, and spray booth filters (when contaminated)
Fuel-contaminated absorbents
Battery electrolyte and battery debris (manage as hazardous/universal waste per installation direction)
Non-empty aerosol cans (often hazardous waste when residual pressure/product remains)
Antifreeze (may be hazardous or recyclable depending on contamination—characterize)
Fluorescent lamps and some HID lamps (often universal waste—do not place in ordinary refuse)
PCB-containing articles where encountered (immediate reporting and specialized disposition)
Contaminated soil and remediation wastes from spills
Medical contamination waste managed through medical channels

10.6 Unit-Level Chemical Storage, Batteries, and Disposal (EPA-Aligned)

Chemical storage and inventory controls

Maintain chemical quantities as low as operationally practical; prefer factory-sealed containers until use.
Segregate and label partial containers; never guess compatibility when consolidating partial containers—request environmental/chemical safety review.
Expired, crystallizing, peroxide-forming, or off-spec chemicals will be quarantined, labeled DO NOT USE, and turned in for determination—do not field-dispose.

Batteries (universal waste emphasis)

Accumulate intact spent batteries in structurally sound containers that prevent short circuits; follow installation procedures for Universal Waste—Batteries marking.
Damaged lithium batteries present thermal runaway and toxic gas hazards—isolate per installation/fire marshal guidance; do not discard in ordinary refuse.

Disposal prohibitions (common violations)

No dumping liquids onto soil, motor pools, tank trails, or training areas.
No pouring wastes into floor drains, industrial drains, or storm drains unless the drain is verified sanitary and authorized for that effluent (assume prohibited until proven otherwise).
No burying drums, batteries, absorbents, or containers.
No open burning of chemicals, aerosols, or unidentified liquids.

Used oil, antifreeze, fuels, and shop fluids

Store used oil in approved containers and tanks dedicated to used oil; keep containers closed and labeled Used Oil IAW installation policy.
Antifreeze will be recovered into closed, labeled containers and recycled or disposed only through approved routes—do not blend wastes into antifreeze without authorization.

Coordination requirement

Any proposed new waste stream, one-time disposal, large quantity turn-in, or unsure characterization will be coordinated in writing or through official environmental work orders with installation environmental staff before disposal actions occur.

10.7 Field Environmental Protection

Units operating in field environments will police all hazardous waste generated during operations.
Fuel cans, oil containers, batteries, and hazardous material containers will not be abandoned in training areas.
Spill kits will accompany field fueling and recovery operations.
Units will inspect bivouac and maintenance areas before departure to identify contamination or abandoned hazardous materials.

10.8 Environmental Incident Reporting

Immediately report:

Fuel spills
Chemical spills
Suspected groundwater contamination
Storm drain contamination
Hazardous waste violations
Large fluid leaks
Unauthorized dumping
Soil contamination
Damaged fuel systems
Environmental damage caused by training or operations

10.9 Environmental Inspections

Leaders will inspect:

Drip pan usage
Spill containment placement
Hazardous waste accumulation areas
Fuel storage areas
Maintenance bays
Wash rack operations
Storm drain protection
Field cleanup operations
Hazardous waste labeling
Spill kit serviceability
Chemical segregation and cabinet integrity
Battery accumulation containers (condition, labeling, short-circuit prevention)

11. TRAINING

Hazardous material and environmental protection training will be conducted and documented in accordance with AR 350-1, AR 200-1, AR 385-10, and AR 600-55 requirements.

Training will include:

SDS program: paragraph 6.7—current revisions on file, inventory cross-reference, point-of-use access works on every shift (including field/cache method)
Four PPE protection levels (POL, chemical cleaners, solvents, lead-acid batteries) and SDS-driven glove selection
Spill response
Fuel handling
Ammunition safety
Bloodborne pathogen response
Transportation procedures
Environmental protection procedures
Emergency reporting
Secondary container labeling, material compatibility (rated bottles/sprayers), and prohibition on informal spray-bottle practices
Battery handling, universal waste accumulation basics, and prohibited disposal
Hazardous waste accumulation rules directed by the installation environmental office (labels, closed containers, time limits)
Used oil versus solvent waste separation and antifreeze turn-in expectations

New personnel will receive orientation before exposure to hazardous operations.

12. INSPECTIONS

Units will inspect:

Spill kits
Storage areas
Fire extinguishers
Fuel points
PPE
Hazardous waste areas
Secondary dispensing containers (spray bottles, squirt bottles): paragraph 7.2 compliance—material suitability, legible durable labels, no food/beverage repurposing, no unknown contents
Battery accumulation points
Transportation procedures
SDS availability at point of use versus shelf stock (paragraph 6.7); binder/electronic paths functional

Deficiencies will be corrected immediately or elevated through the chain of command.

13. RECORDS MANAGEMENT

Units will maintain:

SDS (current manufacturer revisions plus archived superseded sheets IAW records policy)
SDS inventory index or cross-reference tying each SKU on hand to its SDS file location
Inspection records
Spill reports
Training rosters
Hazardous material inventories
Hazardous waste documentation
Environmental incident reports

Records maintained IAW AR 25-400-2.

14. ENFORCEMENT

Personnel violating hazardous material or environmental protection requirements may be:

Removed from operations
Subject to retraining
Subject to administrative action
Subject to UCMJ or disciplinary action when applicable

Leaders will immediately stop unsafe hazardous operations presenting imminent danger.

APPROVAL:

[LAST NAME, FIRST NAME MI.]

[RANK, BRANCH, COMPONENT]

Commanding

CMDP Reference: 10(4)-3