Team McGuire ECAMP Assessment Published Sept. 6, 2007 By Henery Klimkowski 305 CES MCGUIRE AFB, N.J. -- The Environmental Compliance Assessment and Management Program (ECAMP) is an on-going quality improvement program aimed primarily at assuring our compliance with the myriad of federal, state, and local environmental laws and regulations, as well as AF and DOD guidance. "The goal is to improve environmental management across the base and build supporting programs for funding environmental requirements," says Mr. Matt Bell, Chief of the 305th Civil Engineer Squadron's Environmental Flight. ECAMP includes an annual assessment in which the assessment team splits into smaller groups to comb the base seeking opportunities for improvement, and to recognize top environmental performers. In the shops, the ECAMP assessors will conduct record searches, interviews, and site surveys. To evaluate compliance status, site operations are compared to environmental standards. The result of the assessment is a culmination of findings, one for each deficiency or opportunity for improvement. "A successful ECAMP means that the inspectors will find violations," said Alice Veneziani, McGuire's environmental legal advisor. In fact, the average number of findings per base is well over 100. "Anyone who has an ECAMP is going to get a lot of write-ups," says Veneziani. "That's the purpose of it. We don't want to get hit by regulators later on; we'd rather be hit by ourselves so we can fix things before we have a problem." The worst situation to result from an ECAMP assessment is the discovery of a significant violation--an immanent threat to human health or the environment. This would be a rare occurrence, but should the ECAMP team find one, base personnel would immediately take appropriate actions to correct it. If the US Environmental Protection Agency (EPA) or New Jersey Department of Environmental Protection (NJDEP) were to discover the same situation, McGuire would be subject to a notice of violation and possibly a penalty, which could be a fine of up to $50,000 per day, according to Veneziani. For typical findings (major, minor, or management practice), the assessment team in coordination with the affected shop suggests a plan of action, and it is then up to the shop to assure that each finding is ultimately closed in a timely manner. In this manner, we gain an effective system of identifying and properly acting upon our environmental concerns; in the process continually gaining enhanced awareness which builds upon itself yielding higher and higher levels of overall environmental performance. This years' annual assessment will be held from Monday through Friday, Sep 10-14. Certain shops and personnel on base, due to the nature of their business, such as the many industrial and utility shops, will have much interaction with the ECAMP assessment team. Most, however, especially administrative offices will likely have little reason to suspect that they are here at all, except that they, and everyone else on base, remain subject to full compliance with the environmental requirements, which though limited, especially include solid waste management practices, including recycling, and the disposal of used fluorescent bulbs. Shop & Office Management of Used Fluorescent Bulbs The proper management of used fluorescent bulbs is currently a hot button with the regulators. Proper management requires the following: · Bulbs must be stored in a closed container that is labeled "Used Bulbs" · Labeling must also include the date that the first bulb was places in the container · Bulbs must be turned into the recycling center quarterly · It is preferred, however, that bulbs be turned into the recycling center as they are generated to avoid the regulatory liabilities associated with on-site storage The week starts with a Team McGuire inbrief session from 0800-0900 in the 2nd floor briefing room of Facility # 3390 (108th ARW Squad Ops Building) located on Wonnacott Ave. just to the south of the C-141 circle, and ends with a Team McGuire outbrief from 0900-1000 in the same location. Two crosstalks providing feedback from the assessment and an opportunity to provide pertinent input are also Team McGuire events. These will be held on Wed & Thurs mornings from 0730-0830. This year (and every third year) the ECAMP assessment is executed by an external assessment team led by the Chairman of the Environmental, Safety, and Occupational Health (ESOH) Council of another AMC base. The lead for the incoming team will be Colonel John McDonald, the 43 AW/CV from Pope AFB, and his team includes assessors from Pope AFB, Charleston AFB, and HQ AMC, as supported by several contracted personnel. Each of the other intervening two years calls for an Internal ECAMP assessment led by the 305th Civil Engineer Squadron's Environmental Flight (305 CES/CEV). While military personnel, especially, often refer to the ECAMP "assessment" as an "inspection", it is much more important, regardless of the terminology, to recognize ECAMP as a quality-improvement program. The immediate goal is to minimize regulatory liability, and the higher goal is world-class protection of human health and the environment for time on end. As such, it is important for us to be honest with ourselves to identify and incorporate opportunities for improvement on a day-to-day basis, and use these annual assessments to our advantage to ratchet-up changes for the better. Despite its name, ECAMP is not limited to environmental concerns. Within the past few years, Occupational Health issues have also been incorporated into ECAMP. While there was movement toward a name change to add Occupational Health's "OH" yielding the acronym EOHCAMP, it was decided to simply continue with the ECAMP acronym. All environmental & occupational health aspects are subject to evaluation at all organizational levels. Environmental & Occupational Health Aspects · air emissions · Air Installation Compatible Use Zone (AICUZ) · clean up of contaminated sites · cultural and historic resources · emergency response programs · Hazardous Communications (HAZCOM) · HAZMAT management, including fuels, and participation in the HAZMAT Pharmacy (HAZMART) program · natural resources, e.g. wetlands and endangered species · safe drinking water · stormwater pollution · underground storage tanks · practices to protect personnel from harmful exposures · the management of toxics · waste management, including solid waste, hazardous waste, medical waste, and recycling · wastewater disposal Individual shops are typically only affected by a small subset of these. For most industrial shops they include the management of HAZMAT, solid waste management; hazardous waste management; tank and fuel system management; Hazardous Communications (HAZCOM) and the practices to protect personnel from harmful exposures. The preparation and maintenance of the records associated with these aspects, and general housekeeping are also always key concerns at the shop level. One of the great aspects of ECAMP is that the findings the team brings to our attention will make us better. By closing out these findings, we will continue to institute the environmental ethic we strive to achieve. Former 305 AMW Vice Commander, Colonel Pugh left us with words that we have taken to heart... "The protection of the environment is something we take seriously not just because it is the law, but because it is the right thing to do." Top ten typical ECAMP findings: · Improper handling of batteries and used fluorescent bulbs · HAZCOM binder deficiencies (e.g. lack of MSDSs or AF Form 3952's) · Open/unlabeled/improperly labeled containers · Lack of eyewash station inspections · Improper use of flammable lockers · Excessive overstocking of materials (more than seven day supply) · Purchasing outside of HAZMAT pharmacy (HAZMART) program · Improper storage of HAZMAT and hazardous waste · Missing/improper training documentation · Poor recordkeeping of inspection and maintenance logs