GUIDANCE FOR MARINE CORPS ENTERPRISE LIFE CYCLE MANAGEMENT OF HAZARDOUS MATERIAL AND HAZARDOUS WASTE
Date Signed: 1/20/2016 | MARADMINS Number: 032/16
MARADMINS : 032/16
R 201329Z Jan 16
MARADMIN 032/16
MSGID/GENADMIN/CMC L LP WASHINGTON DC//
SUBJ/GUIDANCE FOR MARINE CORPS ENTERPRISE LIFE CYCLE MANAGEMENT OF HAZARDOUS MATERIAL AND HAZARDOUS WASTE//
REF/A/MSGID:DOC/MCO 4450.12A/YMD:19990113//
REF/B/MSGID:DOC/MCO P5090.2A/YMD:20130826//
REF/C/MSGID:DOC/EO 13693/YMD:20150319//
REF/D/MSGID:DOC/DODI 4140.01/YMD: 20111214//
REF/E/MSGID:DOC/MCO 4140.5A/YMD: 20150218//
NARR/REF A IS MARINE CORPS ORDER (MCO) 4450.12A, STORAGE AND HANDLING OF HAZARDOUS MATERIALS. REF B IS MCO P5090.2A, ENVIRONMENTAL COMPLIANCE AND PROTECTION MANUAL. REF C IS EXECUTIVE ORDER (EO) 13693, PLANNING FOR FEDERAL SUSTAINABILITY IN THE NEXT DECADE. REF D IS DEPARTMENT OF DEFENSE (DOD) INSTRUCTION 4140.01, DOD SUPPLY CHAIN MATERIAL MANAGEMENT POLICY. REF E IS MCO 4140.5A, MARINE CORPS SHELF-LIFE PROGRAM.//
POC/MR. EDMOND LETTINHAND /LPC-2/TEL: 571-256-7125/EMAIL: EDMOND.LETTINHAND (AT) USMC.MIL//
POC/MS. JENNIFER WILBER/MCICOM GF-5/TEL: 571-256-2810/EMAIL: JENNIFER.WILBER (AT) USMC.MIL//
POC/MS. TRISH MATHENA/MCICOM G4/TEL: 703-695-6965/EMAIL: TRISH.MATHENA (AT) USMC.MIL//
POC/MR. JOSEPH PINKOWSKI/CMC (SD)/TEL: 703-604-4378/EMAIL: JOSEPH.PINKOWSKI (AT) USMC.MIL//
GENTEXT/REMARKS/1.  Purpose.  This MARADMIN provides guidance for Marine Corps enterprise life cycle management of hazardous material (HM) and hazardous waste (HW).
2.  Applicability.  This MARADMIN applies to the total force and all tenant activities aboard Marine Corps installations.
3.  Situation.
3.a.  Due to the hazards, risks, and regulatory compliance requirements associated with HM and HW as outlined in references a-e, comprehensive HM life cycle management is required at each Marine Corps installation.  This must include stringent procedures and controls to monitor, store, handle, issue, utilize, and dispose of HM.  In addition, federal, state, and Department of Defense (DOD) regulations and policies require the Marine Corps to identify the type and quantity of all HM maintained in inventory and used aboard Marine Corps installations.
3.b.  HM life cycle management requires a teaming effort between Logistics, Environmental, and Safety at the Headquarters, Marine Corps (HQMC), Marine Corps Installations Command (MCICOM), regional, and installation levels.  In addition, tenant activities aboard an installation play a key role in determining HM requirements needed to support their mission and unit management of HM.
3.c.  HM Life Cycle Management.
3.c.1.  HQMC established a Marine Corps HM/HW Working Group (HM/HW WG) to coordinate all areas of HM life cycle management.  The HM/HW WG consists of representatives from Logistics, Environmental, and Safety with the following roles:
3.c.1.a.  Assistant Deputy Commandant, Installations and Logistics (Plans) (HQMC LP), in coordination with the Assistant Deputy Commandant, Installations and Logistics (Facilities) (HQMC (LF))/Commander, Marine Corps Installations Command (COMMCICOM), oversees HM requirements for mission support and is responsible for providing policy and procedures on ordering, receiving, issuing, and storing materials.  Logistics is responsible for validating HM requirements and can impact what activities can procure.  Therefore, Logistics Policy and Capabilities Branch (LPC) will serve as the lead for the Marine Corps life cycle management of HM.
3.c.1.b.  Assistant Deputy Commandant, Installations and Logistics (Facilities) (HQMC LF)/COMMCICOM oversees environmental compliance and promotes pollution prevention and is responsible for providing policy and procedures on compliance with environmental regulatory requirements related to HM, disposal of HW, environmental reporting, spill reporting, and environmental training.
3.c.1.c.  The Director, Safety Division (SD) oversees the Marine Corps safety program and is responsible for policy and procedures as it relates to HM for occupational safety and health compliance, inspections, and mishap reporting.
3.c.1.d.  Each applicable office is responsible for incorporating appropriate requirements of HM life cycle management into their respective oversight/inspection processes.
4.  Mission.  Publish interim policy and guidance for Marine Corps life cycle management of HM.
5.  Execution.
5.a.  HM/HW Enterprise Application Software (HM/HW EAS)
5.a.1.  The Marine Corps HM/HW EAS provides central capability for the management, visibility, and reporting of all Marine Corps HM/HW.
5.a.2.  Within 180 days of the issuance of this MARADMIN, installations will track all HM and HW in the HM/HW EAS.
5.b.  HM Reuse.
5.b.1.  Installations will maintain a HM reuse program to include unused and/or partially used materials in acceptable condition.  Determination of acceptability for the reuse program rests with installation waste managers.
5.b.2.  Reuse will be the first source of supply for HM.  New HM will not be purchased/issued if available through the HM reuse program.  Reuse HM will be issued free of charge within the DOD.
5.b.3.  Installations will maintain accurate inventories of reuse HM in the HM/HW EAS.
5.c.  Authorized Use List (AUL) Management.
5.c.1.  Installations will charter an AUL working group (WG) comprising, at a minimum, representatives from Logistics Environmental, Safety, and from tenants (e.g., MSC/MEF/MFR G4) to serve as active participants.  Tenant commands will appoint an AUL member within 45 days of the release of this MARADMIN, and notify the Installation Commander of the appointment.  The AUL tenant representative shall be either a staff non-commissioned officer (SNCO) or officer to ensure sufficient authority to implement HM requirements and will be provided guidance on how to ensure AUL compliance.
5.c.2.  All activities will maintain an AUL and update annually or as needed, by submitting an AUL adjustment form (NAVMC11779 (06-11) (EF)) and material safety data sheet (MSDS)/safety data sheet (SDS) to the AUL WG.
5.d.  Consolidated Receiving of HM.
5.d.1.  Installations shall consolidate HM entry points through a centralized or distributed model.
5.d.1.a.  Centralized – a single receiving facility for all HM entering the installation.  HM can be managed by a central activity or the co-location of multiple ownership activities.
5.d.1.b.  Distributed – a single receiving facility for HM entering each major activity.
5.d.2.  Activities shall ensure all HM entering an installation on their behalf is received by a consolidated receiving facility prior to accepting ownership.  This includes HM that is part of initial issuing provisioning (IIP) packages.
5.d.3.  All HM received at consolidated receiving facilities will be entered into the HM/HW EAS.
5.e.  Out-sourcing HM/HW Management
5.e.1.  Installations may seek third-party logistic (3PL) opportunities for procurement of HM and/or out-sourcing of HM/HW services.
5.e.2.  To ensure HM life cycle management is incorporated into all out-sourcing programs, approval by HQMC (LP) is required prior to requests for proposals.
5.e.3.  All HM/HW under control of the 3PL provider will be entered into the HM/HW EAS.
5.e.4.  Operation of the Marine Corps HM/HW EAS, by the 3PL, will be written into all future 3PL contracts.
6.  Tasks.
6.a.  HQMC (LP).
6.a.1.  Serve as the lead for the HQMC HM/HW WG.
6.a.2.  Serve as the lead for development of policies and procedures governing Marine Corps life cycle management of HM.
6.a.3.  Coordinate with Marine Corps organizations/commands, including HQMC (LF)/COMMCICOM, HQMC (SD), Marine Corps Combat Development Command (MCCDC), and Marine Corps Systems Command (MARCORSYSCOM) to develop and achieve HM life cycle management goals.
6.a.4.  Promote use of the HM/HW EAS and ensure interfaces are developed, as appropriate, between the HM/HW EAS and supply/logistics systems to support centralized HM management.
6.a.5.  Ensure compliance with federal, state, local, and foreign HM regulatory requirements and uniformly apply DOD and Marine Corps policy.
6.a.6.  Coordinate with HQMC (LF)/COMMCICOM to assist installations in resolving HM disputes with federal, state, local, and foreign regulatory agencies, as required.
6.a.7.  Serve as liaison with Defense Logistics Agency (DLA) and General Services Administration (GSA) to ensure adequate support of life cycle management, including the sustainable procurement program (SPP) (formerly Green Procurement Program (GPP)).
6.a.8.  Coordinate with HQMC (LF)/COMMCICOM to track Marine Corps progress towards meeting HM minimization and SPP goals.
6.b.  HQMC (LF)/COMMCICOM.
6.b.1.  Coordinate with HQMC (LP) to develop policies and procedures governing Marine Corps life cycle management of HM.
6.b.2.  Review HM management and reporting requirements and material substitution opportunities and develop procedures for minimization of HM to the greatest extent possible.
6.b.3.  Coordinate with HQMC (LP) to promote the use of the HM/HW EAS and ensure that interfaces are developed, as appropriate, between the tracking system and supply/logistics systems.
6.b.4.  Serve as the environmental subject matter expert (SME) for development of policies and procedures governing Marine Corps life cycle management of HM at Marine Corps installations.
6.b.5.  Oversee compliance with federal, state, local, and foreign environmental regulatory requirements and DOD and Marine Corps policies related to HM and HW.
6.b.6.  Implement and manage the HM/HW EAS to include serving as the technical project lead for the system and for centralized MSDS/SDS management.
6.b.7.  Incorporate life cycle management of HM into environmental guidance, policy, and oversight programs.
6.b.8.  Assist installations in resolving environmental disputes with federal, state, local, and foreign regulatory agencies, as required.
6.c.  HQMC (SD).
6.c.1.  Coordinate with HQMC (LF) and HQMC (LF/COMMCICOM) on the development of policies and procedures governing Marine Corps life cycle management of HM.
6.c.2.  Incorporate life cycle management of HM into safety policy, guidance, and oversight programs.
6.d.  Marine Corps Systems Command (MARCORSYSCOM) and Marine Corps logistics command (MARCORLOGCOM).
6.d.1.  Develop and implement HM elimination, reduction, or substitution processes for all applicable systems, weapons platforms, and operations.  This must include the identification, evaluation, and use of environmentally preferable materials and services that meet mission requirements.
6.d.2.  Develop and implement sustainable procurement goals and objectives.
6.d.3.  Revise all Marine Corps-owned, standardized documents that have been designated for retention to eliminate or reduce HM requirements and references and/or to replace those requirements with less HM, to the extent technically feasible and consistent with mission requirements.
6.d.4.  If non-HM substitutes do not exist, maximize use of substitutes with the least hazardous characteristics to protect human health and minimize potential environmental impacts.
6.d.5.  Ensure that an MSDS/SDS is obtained, reported, and loaded into the HM/HW EAS for all HM acquisitions and procurements.
6.e.  Commanding General Marine Corps Combat Development Command (MCCDC).
6.e.1.  Incorporate source reduction initiatives and consolidated HM concepts and procedures into appropriate Marine Corps individual training standards and develop HM management training to support consolidated HM operations.
6.e.2.  Incorporate consolidated HM concepts and procedures into doctrine applicable to the supporting elements.
6.e.3.  Incorporate source reduction and consolidated HM practices into combat service support requirement formulations and ensure that the use of HM, if a valid requirement, is supported and justified in mission needs statements or operational requirement documents.
6.e.4.  Coordinate with HQMC (LP), HQMC (LF)/MCICOM, HQMC (SD), and MARCORSYSCOM to review material substitution opportunities, as appropriate.
6.f.  Commanding General or Commanding Officer of Installations and Commander Marine Forces Reserves (MARFORRES).
6.f.1.  Create and distribute installation-level, life cycle HM policy and guidance to include contents of this MARADMIN and HQMC direction.  NAVSUP Publication 722 can be used as guidance to develop installation policy.
6.f.2.  All means for the procurement of HM on the installation shall incorporate HM minimization efforts to the greatest extent possible.
6.f.3.  Program, budget, and fund personnel, equipment, materials, training, monitoring, transportation, disposal, and other requirements necessary for installation operations to comply with HM management policy and guidance.
6.f.4.  Designate an installation HM management program point of contact (POC) to monitor the HM/HW EAS operations and coordinate with the HQMC system technical project lead.
6.f.5.  Comply with federal, state, DOD, local, and foreign requirements and DOD and Marine Corps policies and guidance related to HM/HW management.
6.f.6.  Establish, charter, and sustain an AUL working group (AUL WG) consistent with the contents of this MARADMIN.
6.f.7.  Ensure that inter-service agreements (ISA) and inter-service support agreements (ISSA) with tenant organizations are developed or updated to require compliance with Marine Corps HM policy.
6.f.8.  Establish consolidated receiving points to procure, receive, issue, distribute, store, and track HM throughout its material life cycle.
6.f.9.  Submit, as required, environmental compliance reports to federal, state, DOD, and local entities utilizing data collected in the HM/HW EAS and copy HQMC (LP) and HQMC (LF)/MCICOM.
6.f.10.  Develop and implement training programs for personnel involved in HM operations consistent with federal, state, local, foreign, and DOD and Marine Corps policy and guidance.
6.f.11.  Ensure that coordination occurs between the Logistics, Environmental, and Safety divisions on HM life cycle management and practices.
6.f.12.  Educate personnel about sustainability requirements and mandates.
6.g.  Marine forces and other tenant activities, to include contractors requiring use of HM performing contracted tasks.
6.g.1.  Incorporate the contents of the MARADMIN into standard operating procedures (SOP).
6.g.2.  Provide representation to and be an active participant in the installation AUL WG.
6.g.3.  Coordinate with installation personnel to ensure all HM/HW is tracked within the HM/HW EAS in accordance with the unit/activities AUL per paragraph five of this MARADMIN.
6.g.4.  Coordinate with installations on supporting sustainable acquisition and procurement program.
6.g.4.a.  Procure and store minimum quantities of HM needed to support unit or activities missions.
6.g.4.b.  Identify and procure sustainable products wherever possible.
6.h.  Installation AUL WG.
6.h.1.  Appoint an AUL WG manager from the Logistics division to lead the AUL WG and serve as the single POC for installation AUL stakeholders.
6.h.2.  Oversee development and approval of AULs for all applicable activities operating aboard the installation for 30 days or more.
6.h.3.  Develop an installation-wide, consolidated AUL based on the AULs of each activity.
6.h.4.  Monitor and enforce compliance with AUL policy and escalate issues to the Installation Commander for resolution when deemed necessary.
6.h.5.  Review and approve/deny all requests for additions to, or modifications of, specific HM on the AUL in a timely manner.  Materials granted an interim waiver shall be reviewed and given a final determination by the next quarterly meeting.
6.h.6.  Meet as needed, but not less than quarterly, to validate and/or discuss additions or modifications to installation or activity AULs.  Additional informal or virtual meetings are encouraged to process routine or expedited requests of high priority.
6.h.7.  Conduct annual reviews of the consolidated, installation-wide AUL to identify substitutions for SPP-compliant or less hazardous products and remove materials no longer necessary to satisfy mission requirements.  Distribute changes and recommended AUL updates to activities as necessary.
7.  This MARADMIN is not intended to apply to in-theater wartime operations, ammunition and explosives, nuclear or biological HM or waste, pharmaceuticals, radioactive materials, or ground pesticides.  These materials are governed under individual and unique policy and guidance.
8.  In cases where Marine Corps forces are a tenant organization, they are directed to comply with host installation processes, unless operating under a unique Environmental Protection Agency identification number.  Tenants of Marine Corps installations are expected to abide by ISAs. 
9.  Command and signal.  Questions concerning HM life cycle management policy should be addressed to:  LPC POC: Mr. Edmond Lettinhand (LPC-2), email: Edmond.Lettinhand (at) usmc.mil COMM (571)256-7134 DSN 225 and Ms. Jennifer Wilber (MCICOM/GF), email: Jennifer.Wilber (at) usmc.mil, COMM (571)256-2810, DSN 225.
10.  Action.  This MARADMIN replaces MCBULs 5100, 5103, and 5090 until incorporated into a Marine Corps Order and is applicable to the total force Marine Corps.  NAF activities will be required to meet the requirements set forth in this document, including maintaining AULs and HM/HW EAS tracking.
11.  Release authorized by LTGEN M.G. Dana, Deputy Commandant, Installations and Logistics.//