2013-11-18 naoc briefing (jc king) · 2016-09-03 · pending policy changes dodi 4140.62, material...

Policy Updates

National Association of Ordnance Contractors (NAOC) Meeting

November 2013Assistant Secretary of the Army (Installations, Energy & Environment)

November 2013

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Agenda

• Army Mission• Army Mission• Program Needs• Current Issues• Current Issues• Explosive Safety Education

P t hi ith NAOC• Partnership with NAOC

Assistant Secretary of the Army (Installations, Energy & Environment)2

ARMY MISSIONARMY MISSION


Army Mission

Fight and win our Nation’s wars by providing prompt, sustained land dominance across the full range of military operations and spectrum of conflict in support of combatant Commanders.


PROGRAM NEEDSPROGRAM NEEDS


Program Needs

• Clear policy establishing priorities and program scopeprogram scope

• Common understanding of terminologyR li ti t ti d f di• Realistic expectations and funding

• Cooperative working relationships with public health officials and other regulatorshealth officials and other regulators

• Informed, knowledge-based decisionsU d t di th t t f 100 t• Understanding that a guarantee of 100 percent removal of military munitions is not realistic


Munitions Response Philosophy

• Risk reduction drives the program – Highest risk first, with consideration of other factors – Education considered quickest method of risk reduction– Management of residual risks

• Response actions based on current, determined orResponse actions based on current, determined or reasonably anticipated end use

• Success requires:– Early and continuous communication with regulators and

stakeholders– Transparency of decision making process

• Munitions response activities must:– Be integrated

Mi i i i t i t hil t ti lAssistant Secretary of the Army (Installations, Energy & Environment)

– Minimize impact on environment, while protecting people

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Munitions Response & Army Mission

• The Army’s mission statement does notThe Army s mission statement does not specifically include munitions responses

• Munitions responses are, however, conducted p , ,to:– Help sustain the Army mission– Protect human health and the environment– Comply with applicable laws


Use Available Resources Effectively

N t ibl t d ith l• Not possible to do more with less• ASA(IEE) – will meet requirements of applicable

l t b d l l d tlaws, not go beyond legal mandates– Ensure safety

Comply with legal requirements– Comply with legal requirements– Eliminate non-essential activities


CURRENT ISSUESCURRENT ISSUES


Pending Policy Changes

DoDI 4140.62, Material Potentially Presenting an Explosive Hazard (MPPEH):• A number of purely administrative changes made• Clarifies, given use of Munitions Response Advanced

Geophysical Classification Process (MRAGCP) that DoDGeophysical Classification Process (MRAGCP), that DoD MPPEH policy does not apply to “subsurface material”

• Changes the definition of MPPEH to exclude “non-munitions grelated material (e.g., horseshoes, rebar, other solid objects), munitions related solid metal fragments that do not realistically present an explosive hazard”present an explosive hazard



DoD-M 4140.62, Management of MPPEH ProceduresDoD M 4140.62, Management of MPPEH Procedures• Developed by joint Service workgroup – four year (+) effort,

with extensive informal coordination• Underwent formal coordination (2011) under

SD 106 - substantial comments required resolution• Service comments resolved re submitted for SD 106• Service comments resolved, re-submitted for SD 106

coordination in Feb 13 • Manual’s formal coordination under SD 106 delayed to y

reconcile it with DoDI 4140.62 and DoD 6055.9-M



• DoD Manual XXX, DoD Military Munitions Rule (MR) Implementation Procedures – Submitted for SD 106 coordination 22 Jan 13 – OSD recommended SD 106 process 12 Nov 13– Revision:Revision: Updates 1 Jul 98 DoD Munitions Rule Implementation Policy (MRIP) Clarifies, among other matters:

Th MR d t l t d t d d CERCLA• The MR does not apply to responses conducted under CERCLA• When unused and used military munitions become WMM• Responses to munitions emergencies • Updates references and definitions

• Revision of AR 200-1, Environmental Protection and Enhancement no significant impact on MMRP

Assistant Secretary of the Army (Installations, Energy & Environment)

Enhancement, no significant impact on MMRP

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OSD Policy:• Land Use Controls

• Interim Risk Management (IRM) Policy:– Applies to both IRP sites and MRS– Establishes procedures for considering and

implementing IRM activitiesimplementing IRM activities– Currently major emphasis– Association of State and Territorial Solid WasteAssociation of State and Territorial Solid Waste

Management Officials issued position paper


Munitions Response Dialogue

OSD Policy:• Policy for Orphan Munitions – in developmenty p p

– Munitions which cannot upon discovery be attributed to a specific DoD ComponentE bli h f d i i– Establishes a process for determining: Whether munitions encountered are DoD military

munitionsmunitions DoD responsibility (DoD Component or Program)

for addressing Should be of no concern to NAOC Members


DoD Explosive Safety Board (DDESB)

Army-drafted proposed revision of DDESB Technical Paper (TP) 18 Minimum Qualifications for Personnel Conducting(TP) 18, Minimum Qualifications for Personnel Conducting Munitions and Explosives of Concern-Related Activities• Generally retains content of current TP18• Addresses and clarifies training requirements for non-

UXO Support Workers and Non-UXO Sweep Personnel • Reduces non explosives safety related requirements• Reduces non-explosives safety related requirements• Clarifies dive qualifications and supervision as applies to

MEC-related activities• Requires UXO industry experience for some positions• Requires quality related training for UXOQCS


Underwater Munitions

• What’s new? – FUDS IGD, “Clarification of FUDS Property Eligibility and p y g y

Extent of FUDS Project Eligibility at Off-Shore Disposal Areas, Off-Shore Ranges or Target Areas, Water Ranges and Other Water Areas” under developmentRanges, and Other Water Areas under development

– State’s paper on Underwater Munitions is being finalized• Ordnance Reef (HI-06)Ordnance Reef (HI 06)

– Draft technology demonstration report - complete– Draft current modeling study - completeg y– Draft environmental investigation – complete (at OGC for

legal review)F ll i t l i ti ti i

Assistant Secretary of the Army (Installations, Energy & Environment)

– Follow-up environmental investigation – ongoing

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Underwater Munitions

Hawaii Undersea Military Munitions AssessmentHawaii Undersea Military Munitions Assessment (HUMMA) – Phase III:

• Part 1 conducted at HI-05 in Dec 12• Part 2 planned for 2014


RCWM-P Overview and Status

• SA delegated Executive Agent responsibilities to ASA(IEE) (1 Oct 12)ASA(IEE) (1 Oct 12)

• RCWM-P policy: Draft DoD Directive is at OSD for review

D ft D D M l t b i d t fl t h t Draft DoD Manual must be revised to reflect changes to Chemical Material Agency

• RCWM Integrating Office will:g g Integrate planning and support of RCWM-P Work with program managers to meet requirements

Ensure DoD retains the ability to meet unplanned Ensure DoD retains the ability to meet unplanned requirements


UXO/Countermine/Range Forum

• Not planned• Not planned• Current DoD and Army conference policy

complicatedcomplicated• Industry sponsorship of Forum may be possible,

but improbable given current policybut improbable given current policy


Major Challenges

• Addressing munitions from Acts of WarR l t tt t t it• Regulatory agency attempts to permit emergency operations (e.g., Level 1 or 2 permits) E l i f t it (S i DDESB)• Explosives safety community (Services, DDESB) involvement when response actions are not DoD conductedconducted


EXPLOSIVE SAFETY EDUCATIONEXPLOSIVE SAFETY EDUCATION


Explosive Safety Education(www.denix.osd.mil/uxo)

• Education is an integral part of risk managementA ti i t ll ti t h• Active installations must have a program

• Focus on preventing behaviors (touching, moving or disturbing) that may lead to injuryor disturbing) that may lead to injury

• Guiding principles:– Consistency of message– Consistency of message Munitions are dangerous Easy to remember by all agesE il d idl di i t d t– Easily and rapidly disseminated to affected communities

– Standardize materials


3Rs Explosive Safety Education Evaluation

• Purpose – Assess 3Rs program implementation d d t i ff tiand determine effectiveness

• Objectives – Evaluate the strengths and k f d ti l h dweaknesses of educational approaches and

identify improvements• Type of Assessment Knowledge Gap• Type of Assessment – Knowledge Gap

Assessment and Dialogue (KGAD) evaluation• Vehicle Study contracted to CALIBRE Systems• Vehicle – Study contracted to CALIBRE Systems• Six sites – Six groups of 4th - 6th grade children;

and one group of adultsAssistant Secretary of the Army (Installations, Energy & Environment)

and one group of adults

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3Rs Explosive Safety Education Evaluation

Findings:• 3Rs program provides value as a risk reduction tool• 3Rs program provides value as a risk reduction tool

for students based on statistical data and anecdotal information

• Identified:– Strengths of program– Important areas for improvementImportant areas for improvement

• Some instructions too complex• Some vocabulary needs explanation


Opportunities for Cooperation

• Exchange of:Lessons learned– Lessons learned

– User perspectives on: Emerging policiesEmerging policies New or improved technology Processes or procedures Research

• Harmonizing safety outreach programs


PARTNERSHIP WITH NAOCPARTNERSHIP WITH NAOC


Partnership with NAOC

• Provides DoD an industry perspective on:– Draft documents– PolicyNAOC hit id D D th i d t• NAOC white papers provide DoD the industry views on matters of concern to member companiesIdentifies emerging issues• Identifies emerging issues

• Makes recommendations for:Increasing efficienc (e g contract lang age red cing– Increasing efficiency (e.g., contract language, reducing red tape, identifying technology needs)

– Protection of workers


Contact

J C King COL (R)J. C. King, COL (R)Director for Munitions and Chemical Matters

Office of the Deputy Assistant Secretary of the ArmyOffice of the Deputy Assistant Secretary of the Army for Environment, Safety and Occupational Health

[email protected]


2013-11-18 naoc briefing (jc king) · 2016-09-03 · pending policy changes dodi 4140.62, material...

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