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 e. Recycling Program. The Army promotes separating products, substituting materials, changing
procedures to avoid the use of hazardous substances (source reduction), and recycling to reduce the
volume of solid waste. Most installations have a recycling program. Recyclable materials include:
computer printouts, corrugated cardboard, newspaper, aluminum cans, plastics, oil, solvents, glass, steel,
and brass. Check with installation personnel to verify what materials are being recycled on your
installation.
f. Spill Prevention and Response Plan. It is Army policy and a Clean Water Act (CWA) requirement
to prevent oil and hazardous-substance spills and to provide prompt response to contain and clean up
spills. The discharge of oil or hazardous substances from installations, vehicles, aircraft, and watercraft
into the environment without a discharge permit is prohibited. Every reasonable precaution should be
taken to prevent spills of oil and hazardous substances. AR 200-1, FM 3-100.4, and Title 40 CFR refer
to the applicable spill prevention references. A few examples of what a unit leader should do are listed
below. A more extensive list can be found in FM 3-100.4, Chapter 6.
Provide facilities in which to store, handle, or use oils and hazardous substances, and
implement proper safety and security measures.
Appoint a spill coordinator and members of a unit spill response team. Members and their
roles on the team must be documented in writing.
Maintain an up-to-date spill response plan. This requirement is generated by the installation.
Maintain an up-to-date inventory of all HM/HW; provide a copy to the post fire department
for use in case of a chemical fire.
3-4. 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. Non-Army regulatory agencies have the legal right and responsibility to inspect
units and individual facilities and actions to ensure compliance.
a. Once a year, EPA inspectors conduct spot inspections of the installations, often without notice.
Local and state inspectors also conduct frequent inspections. Inspection frequency guidelines have been
established under the EPA Federal Facility Compliance Strategy.
b. The Army established the ECAS as a means of achieving and monitoring compliance with the
applicable federal, state, regional, and local environmental laws and regulations. If a platoon deals with
HM or HW, leaders are required to conduct internal inspections. The 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 platoon leader may also request a copy of the ECAS
protocol to assist in developing inspection and record keeping plans and to conduct an internal and self-
compliance assessment.
3-5. Environmental Self-Assessment. Unit leaders use a checklist to assess the environmental-
compliance status. FM 3-100.4, Appendix H, has a general checklist that leaders may use. Higher-level
staffs within the chain of command or the installation environmental office may have similar aids
specific to a unit or a location. Unit leaders, with the assistance of the installation environmental staff,
determine the frequency of the self-assessment checks. The commander ensures that the unit
environmental program management system is effective through the self-assessment.
3-4
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