prevent spills of oil and hazardous substances. AR 200-1, FM 4-04.4 (3-100.4), and Title 40 Code of
Federal Regulation (CFR) refer to applicable spill prevention references. A few examples of what a unit
leader should do are as follows:
Provide facilities to store, handle, or use oils and hazardous substances, and implement
proper safety and security measures.
Appoint a spill coordinator and members of unit spill response team in writing.
Maintain an up-to-date spill response plan.
Maintain an up-to-date inventory of all HM/HW,and provide a copy to the post fire
department for use in case of a chemical fire.
6-3. Program Assessment. Environmental-compliance status can be determined through a formal
inspection by a regulatory agency. It can also be determined through self-inspections using ECAS
checklists as a guide.
a. Non-Army regulatory agencies have the legal right and responsibility to inspect units and
individual facilities and actions to ensure compliance. Once a year, EPA inspectors conduct spot
inspections of installations, often without notice. Local and state inspectors also conduct frequent
inspections. Inspection frequency guidelines have been established under the EPA federal facility
b. The Army established the ECAS as a means of achieving and monitoring compliance with
applicable federal, state, regional, and local environmental laws and regulations. If a unit deals with HM
or HW, leaders are required to conduct internal inspections. Installation HW management plans should
normally contain information sufficient to develop an inspection plan for HW generation points and
accumulation sites at the unit level. The unit leader may also request a copy of the ECAS protocol to
assist in developing inspections and recordkeeping plans and to conduct an interior/self-compliance
6-4. Unit Self-Assessment. Unit leaders use a checklist to assess unit environmental compliance. FM
4-04.4 (3-100.4), Appendix H, has a general checklist that leaders may use. Higher-level staffs within the
chain of command or the installation's environmental office may have similar aids specific to a unit or
location. Unit leaders, with the assistance of the installation's environmental staff, determine the
frequency of self-assessment checks. The commander ensures that the unit's environmental program
management system is effective through the use of these self-assessments.
a. Unit Management Practices. Many environmental requirements at the unit level are simply an
extension of existing unit management practices. Units exercise good management practices by doing the
(1) Using the Army's Hazardous Substance Management System (HSMS). The HSMS applies
centralized management and strict inventory control to reduce the use and disposal requirements for
hazardous substances by tracking HM.
(2) Conducting Good Housekeeping. Good housekeeping is another basic management
practice. It involves areas such as maintenance, operations, and training. An example of good
housekeeping is recycling. Recycling diminishes solid waste and helps eliminate unauthorized disposal
of some types of HW. Another example is monitoring the shelf life, of HM. HM disposal is expensive