The Greening of Industrial Ecosystems. 1994.
Pp. 149-164. Washington, DC:
National Academy Press.
Preventing Pollution and Seeking Environmentally Preferable Alternatives in the U.S. Air Force
EDWARD T. MOREHOUSE, JR.
To seek environmentally preferable alternatives to its current business practices, the U.S. Air Force implemented a comprehensive Pollution Prevention Program. The program draws together environmental pronouncements embodied in executive orders, legislation, and Department of Defense (DOD) and Air Force policy statements, and it overlays sound business principles to produce a comprehensive program designed to integrate environmental considerations into the fabric of Air Force business. The Air Force model may be broadly applicable to other large government entities, and to private firms as well.
A number of environmental issues surfaced in approximately the same time frame, which provided the Air Force Pollution Prevention Division with an opportunity to propose a comprehensive program and successfully sell it to senior Air Force leadership. The most compelling issue was the renegotiation of the Montreal Protocol on Substances That Deplete the Ozone Layer, which calls for a complete production phaseout of ozone-depleting chemicals (ODCs). Since virtually every military system is dependent to some degree on ODCs, this issue became the first priority of the Pollution Prevention Program. Other issues included data indicating the unit cost of hazardous waste disposal had increased tenfold over a five-year period, the emergence of the Environmental Protection Agency (EPA) voluntary toxics reduction (33/50) program, passage of the Pollution Prevention Act, dramatic increases in costs of cleaning up contaminated waste sites, and the rapid disappearance of space to dump municipal solid waste. These issues taken together pointed to the need for a comprehensive, Air Force-wide program aimed at all environmental pollutants and supported at the highest levels of Air Force leadership.
By engaging the entire Air Force organization, the program encompasses all of the various roles played by a large federal agency, which include researcher, technology and product developer, large consumer of commercial and industrial products and technologies, operator of large industrial plants, construction agent, facility manager, and city manager. In each of these roles, the Air Force not only affects the environment but also has an opportunity to lead others, both inside and outside government, by example.
This paper describes the Air Force Pollution Prevention Program, explains how it was developed and is being implemented, and provides a perspective for assessing its significance.
DOD PROGRAM POLICY AND OBJECTIVES
On October 10, 1989, Secretary of Defense Dick Cheney issued a memorandum on environmental management policy to the secretaries of the military departments. The policy statement was direct and clear. Secretary Cheney said the ''Administration wants the United States to be the world leader in addressing environmental problems, and I want the Department of Defense to be the federal leader in agency environmental compliance and protection." The statement made the point that the Department of Defense, as the largest federal agency, has a great responsibility to meet this challenge and that Secretary Cheney wanted every command to set an environmental standard by which federal agencies would be judged. One of the most significant statements in the policy is "the first priority of our environmental policy must be to integrate and budget environmental considerations into our activities and operations." This provided a policy basis for identifying environmental investments needed to meet environmental goals and obtaining needed financial resources.
Complementing Secretary Cheney's policy is the DOD Directive 4210.15, Hazardous Materials Pollution Prevention. It states that the Military Services are to "select, use and manage hazardous materials so as to incur the lowest life cycle cost to protect human health, the environment and long-term liability." While this is a basic and sound business approach, implementation is an enormously difficult and complex task. Since the art and science of selecting materials and processes to minimize environmental impact are in their infancy, there was no implementing guidance to accompany the directive. This left significant discretion to program managers in a world of many competing priorities.
The activity that drives the greatest amount of hazardous waste generation in the U.S. military is system acquisition. The technologies used to develop, build, operate, and maintain weapons systems drive approximately 90 percent of the military use of hazardous materials/use and generation of hazardous waste. At first, the notion of a "green" weapons system may seem absurd, but in reality it is not. Weapons systems spend most of their lives in a peacetime role. Consequently, the environmental impact created by the system results in large part from train-
ing and maintenance. Many systems, aircraft in particular, often remain in the inventory for 30 years or more. During that time, maintenance and refurbishment performed at Air Force industrial plants use large quantities of hazardous materials and generate large quantifies of waste. The material and process selections made during system development dictate maintenance and operations procedures and define the environmental impact for the entire 30 years of ownership. These material decisions are made by program offices responsible for delivering new systems that meet performance criteria, on time, and within budget. DOD Instruction 5000.2, which prescribes acquisition procedures, includes a requirement to include hazardous material considerations in acquisition activities. As with the Hazardous Materials Pollution Prevention Directive, it is not specific about how to accomplish the task.
LAUNCHING A NEW AIR FORCE POLICY
On November 13, 1992, the chief of staff of the Air Force, General Merrill A. McPeak, and the secretary of the Air Force, Donald B. Rice, jointly signed a memorandum to the commanders of all major commands, all assistant secretaries, and all deputy chiefs of staff proposing a comprehensive Pollution Prevention Action Plan. The memorandum asked for endorsement of specific goals and objectives, recommendations to improve the proposed program, and an estimate of the resources needed to achieve the goals. The Pollution Prevention Division used these endorsements and resource requirements to establish an investment strategy and to convince the Secretary of the Air Force that the projected economic and environmental benefits warranted the investment. On January 7, 1993, the chief of staff and the secretary of the Air Force signed a memorandum formally establishing the program. In the memorandum, they stated, "The Air Force is committed to preventing future pollution by reducing use of hazardous materials and releases of pollutants into the environment to as near zero as feasible. We must mobilize our whole team and find ways to move faster."
HIGHLIGHTS OF THE AIR FORCE POLLUTION PREVENTION PROGRAM
There are six objectives to the Pollution Prevention Action Plan. The first is to reduce the use of hazardous materials in all phases of new weapons systems from concept through production, deployment, and ultimate disposal. It includes subobjectives describing specific actions and milestones that lead to institutionalizing pollution prevention in the systems development and acquisition process. The assistant secretary for acquisition is responsible for achieving this objective and has authority to make the necessary changes in acquisition policy and procedures.
The second Objective is to "reduce the use of hazardous materials in existing
weapons systems by finding less hazardous materials and processes and integrating them into Technical Orders, Military Specifications and Standards." (Technical Orders are like owners manuals. They prescribe maintenance processes, including material prescriptions.) Most existing weapons systems were developed, built, and acquired before environmental considerations were part of the material decision process. Under this objective, their maintenance and operations procedures will be revisited and materials and processes changed to environmentally preferable alternatives. As with the first objective, there are many subobjectives with milestones. Responsibility and authority belong to the deputy chief of staff for logistics.
The third objective deals with the Air Force role as operator of installations, and requires the reduction of "hazardous material use and waste generation at installations and government-owned, contractor-operated (GOCO) plants." Subobjectives were negotiated with field commanders and responsible functional area leaders and prescribe reductions in volatile air emissions (50 percent by 1999), municipal solid waste disposal (25 percent by 1996 and 50 percent by 1997), purchase of ODCs (eliminate by June 1993 or April 1994 depending on end use), purchases of the 17 identified industrial toxics of the EPA 33/50 program (50 percent reduction by 1996), and generation of hazardous waste (25 percent reduction by 1996 and 50 percent by 1999). This objective also establishes a requirement to characterize waste streams to all media, so the Air Force can quickly address wastes that the EPA may target for future regulation, voluntary reduction programs, or reporting requirements. A comprehensive characterization of waste streams also provides data needed to identify future pollution prevention opportunities as the program evolves. Responsibilities to meet these reduction goals apply to each of the three major organizations in the Air Force that generate the pollution. Achieving the target for the 17 toxics in the 33/50 program at GOCOs should be easy since virtually all contractors who operate Air Force plants have voluntarily signed onto the program.
The fourth and fifth objectives say that the best pollution prevention technologies either be acquired from the private sector, other government agencies, or other nations or be developed internally and shared with others. Subobjectives challenge users and maintainers of weapons systems, support systems, and infrastructure to identify technologies needed to enable them to achieve the program goals and make those known to the research and development community. Again, responsibility is assigned according to lines of authority.
The final objective is to "establish an Air Force investment strategy to fund the Pollution Prevention Program." The Air Force Engineer is responsible for overall implementation of the Pollution Prevention Program and for working with the Acquisition and Logistics communities to ensure the financial requirements are identified and programmed into the budget.
The key to translating policy into practice is to change behavior, both within the Air Force and among the suppliers. For this program to be successful, all Air
Force employees need to understand the environmental requirements of their job and how to comply; all family members living in military housing need to understand how their behavior affects the environment and how to change it appropriately; and all contractors doing business with the Air Force need to understand how the environmental performance of their companies and their products will be factored into Air Force purchasing decisions. Each of these behavioral changes represents a major education and training challenge.
POLLUTION PREVENTION MEANS CULTURAL CHANGE
The Air Force is using several techniques for changing internal behavior. They include education and training, changes to accounting systems that "make polluters pay" and give "corporate" visibility to environmental compliance costs, creating pollution prevention scorecards that measure organizational progress toward meeting pollution prevention objectives, and using environmental protection committees (EPCs) to give leadership and high level visibility to how well organizations are meeting the program objectives.
Education and Training
Most people care about the environment and want to do the right thing environmentally. Showing people how to do their jobs in a way that protects the environment is one of the cornerstones of the program. Accordingly, the internal environmental education and training program reaches each and every Air Force employee. Different jobs have different requirements, and the curricula and methods for delivering the training are tailored accordingly. All recruits entering the Air Force receive environmental training as part of their basic military training. Airmen and officers whose jobs involve dealing with hazardous materials receive more in-depth, specialized training. The Air Force Institute of Technology (AFIT) offers a variety of environmental short courses, including one specifically on pollution prevention. Each installation pollution prevention manager is encouraged to take this course, and central funding is provided as an incentive. AFIT also offers master of science degrees in environmental management. Traveling teams from the Air Force Center for Environmental Excellence conduct regional training courses, in cooperation with the EPA, for all individuals at installations responsible for executing pollution prevention programs at the installation level. The Air Force Academy also offers degrees in environmental science and environmental management. The Reserve Officers Training Corps offers scholarships to students studying environmental sciences.
Courses required for enlisted members to advance in rank include environmental training. The Air Training Command conducts 105 technical training courses specifically for enlisted members and provides detailed training on hazardous material and hazardous waste management. Orientation courses required
for people transferring from one installation to another include a session on the environmental program at their new base. The Defense Systems Management Course (DSMC), which provides basic education required for all acquisition of-ricers, includes a section on the environmental impact of acquisition programs. However, it must be expanded to emphasize pollution prevention opportunities and to show how to incorporate pollution prevention into acquisition programs.
In addition to educating the workers, the Air Force has focused on educating leadership at all levels through a unique course called the Environmental Leadership Course, conducted by a general officer. Between 1990 and 1992, 15 courses were conducted for commanders and their staffs, and attendance exceeded 800. With only nine major commands and approximately 100 installations, coverage was very good. Each course included a presentation on the Pollution Prevention Program to explain why it is important to commanders, the financial benefits of a successful program, and tips for commanders to use to assess the health of their programs. This one- to two-day course had a significant effect on the attention commanders give to their pollution prevention programs.
The Environmental Comprehensive Assessment and Management Program (ECAMP) and opportunity assessments are additional tools for educating installations about their pollution prevention opportunities. Installations conduct an ECAMP self-assessment once a year using internal staff, and once every three years using external independent assessors. The assessment team uses a series of protocols to evaluate every aspect of the installation environmental program. The results of the ECAMP are for commanders to use to improve their programs. Opportunity assessments are detailed installation surveys conducted by local pollution prevention staffs and external pollution prevention experts. The surveys provide each installation with a roadmap for achieving the goals of the program.
Changes in the way installations pay for environmental compliance have also provided an incentive for changing internal behavior. Installation commanders are responsible for operating their installations within an operations and maintenance (O&M) budget. Until 1991, waste disposal costs were paid from a central account, not from the commanders' O&M account. Now, all hazardous material, hazardous waste, and municipal solid waste disposal costs are paid from the commanders' O&M account. This change in accounting procedures internalizes these costs to the installation and provides a financial incentive to reduce waste generation. This incentive becomes even more significant when considering that national regulations governing hazardous waste disposal have become more stringent and have driven the unit disposal costs up tenfold over the past five years. Pollution prevention offers commanders an opportunity to reduce the impact of this "must-pay" bill on their budget. This has prompted many installations to manage
more carefully their use of hazardous materials, and consequently has reduced the amount of waste generated.
Recent passage of the Federal Facility Compliance Act provides additional financial incentive to minimize hazardous material use and waste generation by removing the federal exemption from some Resource Conservation and Recovery Act (RCRA) requirements. This act now exposes federal installations to potential fines and penalties for notices of violation (NOVs) issued by federal, state, and local environmental jurisdictions for mismanagement of hazardous materials and waste. The rules governing storage, handling, and paperwork requirements for hazardous materials and waste are complex and administratively cumbersome. Approximately 50 percent of all Air Force NOVs are for these types of violations. These represent potential financial liability for having hazardous materials on Air Force installations. Pollution prevention offers an avenue to reduce or eliminate these materials. Organizational accounting procedures that force polluters to pay their own environmental costs, fines, and penalties are a powerful technique for reducing waste generation and improving the corporate bottom line.
The metrics for the Pollution Prevention Program are based on installations reporting their baseline figures and updating these figures annually. The data are aggregated at major commands and ultimately at Air Force Headquarters. Score-cards, based on the data, are reported to the Air Force Environmental Protection Committee and rate all commanders on their progress toward meeting the objectives. Each installation, each major command, and Air Force headquarters conduct EPC meetings quarterly. The committees are headed by the commander or vice commander and include key staff from all functional areas. At Headquarters Air Force, the committee is cochaired by the deputy vice chief of staff and deputy assistant secretary for environment, safety, and occupational health. The EPC also regularly advises the chief of staff and secretary on the health of the program and current issues. This EPC provides an opportunity for leadership at all levels to assess the performance of the environmental programs of subordinate levels. Because of the emphasis senior leadership places on pollution prevention, these scorecards have become a basis for competition. Every commander wants to have the best program.
Changing External Behavior
Changing the behavior of suppliers is more difficult. The only control over the private sector is through incentives embodied in the contracting process. This influence can, however, have some effect by virtue of the size of the Air Force budget. For example, in fiscal year 1991, the Air Force executed nearly 5 million contracting actions totaling nearly 50 billion dollars. Throughout the Department
of Defense, there were nearly 12.3 million contracting actions totaling more than $150 billion. Purchasing Power of this magnitude and the keen competition among suppliers for government business impose a responsibility on the federal government to be an informed environmental consumer.
The Instrument of Change—The Government Contract
The government contract is not only an instrument for acquiring goods and services needed to execute government operations—it is also an instrument for implementing government policy by providing incentives. This is similar to the way the government uses Internal Revenue Service tax codes to encourage specific types of spending and investing behavior.
The Air Force, like the rest of the federal government, buys a wide range of products. This purchase power represents an opportunity to influence the direction of corporate product development efforts toward environmentally preferable performance. These purchases run the gamut from sophisticated, smart weapons systems to commodity items such as office supplies. The procedures for buying these items are similar in some ways but very different in others. One common feature is that each purchase is a contracting action. The only person authorized to commit the government to a contract action is a contracting officer (the actual buyer is someone else). The contracting officer provides a service to the buyer and is responsible for satisfying the needs of that customer. Customers describe their requirements through a technical description of the item or product. If the technical description does not include environmental considerations, they will not be a factor in the purchase. The buyers are a diverse group and the challenge is to educate the buyers to incorporate environmental considerations into their product requirements. To complicate matters, commercial items such as office supplies are purchased centrally by organizations like the General Services Administration (GSA). They buy in quantity and offer products to all agencies of government through catalogs, allowing buyers to purchase items by number through a central contract. Although GSA has introduced a recycled products catalog, it cannot force people to order environmentally preferable products. Under the current system, each office across the government must make sure its own supply organization is ordering the products containing recycled content. This is a classic situation of centralized versus decentralized decision making: Is it better to let each office make its purchasing decisions or to impose them at the contracting office?
On a practical level, there are three sections of a contract for which specific language is needed to put policy into action. The first is Section A of the contract, the "Solicitation Form." Here the Air Force is developing a general statement to be placed on the front page of all requests for proposals (RFPs) describing Air Force environmental policy and philosophy.
The second is Section L, "Instructions, Conditions and Notices to Offerors." For this section, specific formats are being developed that offerors will be re-
quired to use to describe the environmental performance of their product, system, or service.
The third is Section M, "Evaluation Factors for Award." It includes two parts called "items" and "factors," which is where the evaluation criteria used to judge the environmental performance of the offeror's proposal must be added. To develop items and factors that use environmental performance as an award selection criterion, several questions must be answered:
What attributes or criteria determine whether a product, service, or system has been designed for environment, incorporates the principles of industrial ecology, or demonstrates acceptable environmental performance?
How are those attributes or criteria to be measured?
Against what standards should the measurements be compared? (This is important because standards establish the minimum performance or compliance level an offeror must meet to satisfy the RFP.)
How are the attributes or criteria shown to be cost-effective when compared to "business as usual"?
Once the contractual language is developed that describes what is to be measured, how it is to be measured, and what standards will be applied, it must be incorporated at four stages throughout the contracting action: (1) the request for proposals, (2) the technical review, (3) the best and final offer, and (4) source selection.
Standards can be either quantitative or qualitative. Most people prefer quantitative standards because they are easy and straightforward. An example of a quantitative standard is, "At a weight not exceeding the basic design gross weight, the aircraft is capable of transporting a payload of (a) 30,000 lbs for 2,800 nautical miles (nm) distance, or (b) 48,000 lbs for 1,400 nm distance." The ability to influence the environmental performance of acquisition programs is limited by the ability to prescribe material or process selections or, alternatively, a methodology for making selections. Methodologies for making these selections are not very mature, but they are evolving.
For an organization like the Air Force unilaterally to develop and apply quantitative standards that can withstand legal scrutiny, they must be very specific and narrow in scope, and within the organization's expertise. An example of this type of standard would be "copier paper shall contain at least 50 percent postconsumer waste."
It would be difficult for the Air Force to develop and apply more comprehensive quantitative standards to evaluate the environmental acceptability of a commercially available product, system, or service. To be credible and not appear arbitrary, these types of standards would have to be developed by the EPA, Federal Trade Commission, or some other federal agency or competent government or industry group and would have to be applied to specific products. A national
"green stamp of approval," similar to Underwriters Laboratory certification of safety, may work as an evaluation standard.
Qualitative standards may be used in lieu of quantitative standards, but they are more subjective and difficult to evaluate. The following is an example of a qualitative standard extracted from government contracting documents:
The proposed system environmental program (SEP) will be evaluated for adequacy in effecting the design of changes or modifications to the baseline system to achieve special environmental objectives. The evaluation will consider specific tasks, procedures, criteria, and techniques the contractor proposes to use in the SEP. The standard is met when the SEP
Defines the scope of the system environmental effort and supports the stated environmental objectives.
Defines the qualitative analysis techniques proposed for identifying environmental impacts to the depth required.
Describes procedures by which engineering drawings, specifications, test plans, procedures, test data, and results will be reviewed at appropriate intervals to ensure environmental requirements are specified and followed.
This standard implies a definition of the environmental objectives of the program, an analysis technique, and procedures and means to evaluate their adequacy.
Despite these difficulties a number of efforts are under way to put environmental performance into the source selection process. By narrowing the initial scope of the effort, then using lessons learned and increasing understanding of the industrial ecology concept to broaden the scope over time, the acquisition process can evolve to increasing levels of sophistication.
Today, the start is modest. A standard Data Item Description (DID), and proposal formats to use for describing the environmental aspects of item, system, and service performance, are being developed. In the short term, contractors are being required to list components and end items that incorporate recycled materials. In the long term, changes to the Federal Acquisition Regulations that give preference to recycled products and that integrate environmental performance into source selection criteria may be required.
Buying Commercial Products
The markets for many recycled materials, like paper and glass, have been sluggish recently because the market for the products made from recycled materials is diminishing. This is frustrating Air Force efforts, and those of corporations and municipalities across the country, to increase the percentage of the municipal waste stream making its way back into the raw material stream. This is occurring at the very time municipal landfills are disappearing. In 1978 there were approximately 20,000 landfills in the United States. Today, there are about 4,000. Siting
new landfills is becoming difficult and often is an emotionally charged issue in communities. Incineration or waste-to-energy facilities are also highly contentious. The toxic air emissions, the low Btu content of the waste feed, and the potentially hazardous waste resulting from the incineration process make this a much less attractive alternative to recycling the waste into raw material. In addition, siting waste incinerators is difficult. As it turns out, much industrial waste could be reprocessed into raw materials if regulatory, technical, legal, and cultural barriers could be overcome.
While the size of the federal budget in general, and the defense budget in particular, is decreasing, it is still of sufficient size that federal procurement actions can make a difference between survival and failure of fledgling companies that use recycled materials to manufacture useful products. Requiring that purchased products contain recycled material would send a clear message that the private sector's product development efforts should include use of recycled materials, and would stimulate markets.
This is the principle behind one of the Air Force Pollution Prevention Program initiatives, Proactive Procurement, designed to close this material loop. On September 25, 1992, the secretary of the Air Force and the chief of staff signed a policy memorandum establishing an Air Force policy to purchase and use products containing recycled materials when available. Specifically, by the end of 1993, 10 percent of all nonpaper products and 50 percent of all paper products procured by the Air Force shall contain recycled materials. Based on Air Force paper use in the Pentagon alone, this policy will save more than 1,300 cubic yards of landfill space, almost 7,300 mature trees, 3 million gallons of water, 162,500 gallons of oil, and 1.75 million kilowatts of energy, and will eliminate 25,600 pounds of air pollutants each year. The policy also includes lubricating oils, re-treaded tires, building insulation, cement, and concrete under the nonpaper category. This policy puts leadership emphasis behind the requirements of RCRA Section 6002, and the EPA affirmative procurement guidelines.
ACQUIRING "GREEN" WEAPONS SYSTEMS: MILSPECS AND MILSTDS
A significant component of the environmental impact of weapons systems results from the use of technical requirements documents, particularly military specifications (MILSPECS) and military standards (MILSTDS). These documents were originally created to standardize the manufacture and maintenance of weapons systems to allow easier logistical support and ensure quality and reliability. Indeed, MILSPECS and MILSTDS became de facto industry standards around the world. The 1989 Montreal Protocol Solvents Technical Options Committee Report stated that approximately 50 percent of CFC-113 used worldwide for the manufacture of electronics circuit boards was driven by U.S. MILSPECS, because they had been adopted as industry standards, and by other governments
and organizations such as NATO. Unfortunately, the MILSPECS and MILSTDS system cannot react to market forces as quickly as the private sector. Thus, in rapidly changing areas such as elimination of ODCs, MILSPECS and MILSTDS rapidly become obsolete, hindering rather than encouraging environmental performance of products and manufacturing processes. Significantly, this also impedes the ability of defense industries to change quickly to new manufacturing technologies, an important issue as companies move from defense to commercial business ventures.
MILSPECS and MILSTDS were created at a time when environmental impacts were not thought of or understood. As a result, the documents focus on obsolete notions of reliability and performance rather than environmental concerns. Moreover, the process for Changing or eliminating them is far more cumbersome than for creating them. As a result, Air Force and DOD procurement is constrained by bureaucracy that tends to produce an ever-increasing body of requirements documents. The Defense Standardization Program, which formulates, issues, and implements policies and procedures governing MILSPECS and MILSTDS, is managed by the Defense Quality and Standardization Office. They are currently working with the Office of Management and Budget to adopt nongovernment standards in lieu of MILSPECS and MILSTDS. As of 1992, the DOD had adopted about 5,500 nongovernment standards. This trend will help the military services keep pace with the environmental ethic that industry is incorporating into manufacturing activities in response to customer demands, and free defense industries to move their processes closer to those in use in the commercial sector.
Reviewing the experience of the military in phasing out ODCs is a useful study in the dynamics of the MILSPECS/MILSTDS system. Over the past two years, the Defense Standardization Program has automated more than 600,000 pages of MILSPECS and MILSTDS to search for ODC requirements and has looked for opportunities to leverage its efforts to make changes. For example, the program found the one document requiring the use of ODCs in testing procedures for passive electronics devices was referenced by 1,700 other documents. The ODC requirement was eliminated, thus changing the other 1,700. The program also found more than 750 documents that referenced one requirement governing testing procedures for microelectronics. Again, by eliminating ODCs from the one, the program effectively changed the 750.
CHANGING MILSPECS AND MILSTDS
To create a MILSPEC, the preparing organization drafts and coordinates the document in collaboration with affected industries. Once the document is in circulation, anyone can use it. To change a MILSPEC, all the parties who have used it must coordinate on the change. In addition, there are ''lead agencies" responsible for specific documents used by others. For example, the Navy is responsible
for documents governing the manufacture of electronic circuits and is the only agency that can change them.
Once a MILSPEC is established, however, specific program offices are not bound to apply the specification as written. Because program offices are responsible for delivering the prescribed number of products or weapons systems that meet performance requirements, on time, and within budget, the program offices have the authority to use whatever technical requirements documents they deem appropriate. They can use industry standards, tailor MILSPECS for their program, create their own requirements, or ask the contractor to propose standards and prescribe an evaluation and approval process. The easiest path, and the one that presents no risk to the program office, is to use MILSPECs as written, which is therefore what almost always happens in practice. This is one of the reasons that contractors for major acquisition programs are still being required to adhere to MILSPECs and MILSTDS that require ODCs, despite the Montreal Protocol.
Acting on complaints from defense contractors, Congress added Section 326 to the National Defense Authorization Act for Fiscal Year 1993. The act requires that after June 1, 1993, for any contract over $10 million, any requirement to use ODCs must be approved by the service senior acquisition executive. It goes on to stipulate that this approval can be given only if, after an evaluation, the senior acquisition executive certifies that there is no alternative. In the Air Force acquisition programs, this is the assistant secretary for acquisition.
For new programs, the Solution is more straightforward than for existing programs: the contract prohibits ODCs and the program institutes a process for evaluating and making deliberate material choices based on environmental analysis. The Air Force F-22 weapons system program has implemented such a process and is an excellent case study for future programs. The F-22 office incorporated a Hazardous Material Management Program to identify all hazardous materials used for production and maintenance and the specific application for each material. The program office, in cooperation with the contractor, regularly reviews materials being proposed for use and looks for less hazardous alternatives. High on the list of materials to be eliminated are ODCs, heavy metals (such as cadmium and chromium), the 17 chemicals on the 33/50 toxics list, and other chemicals that pose unacceptable risks, such as hydrazine.
For existing programs, the task is more difficult. Contracts have been negotiated and awarded, and MILSPECS and MILSTDS are incorporated into that contractual agreement—the version of the MILSPECS and MILSTDS in effect at the time the contract was awarded. Changes to MILSPECS and MILSTDS that occur after the contract was awarded do not apply. This situation poses problems both for the program office seeking to change the selection of materials in manufacturing processes and for the contractor seeking to implement changes. A major acquisition program typically involves hundreds of individual contracts. Contractors typically use a single manufacturing process to produce parts for more than one program and often for programs belonging to more than one service. This
means a contractor wanting to change a process must identify each program and contract affected, individually convince each program office that the proposed change is technically sound, and negotiate a change to each contract with each contracting office. Each of these steps is labor intensive.
Probably one of the most difficult steps is convincing the program office that the proposed alternative is technically sound. Each program office has the authority to accept or reject the proposal, and demand any level of technical data from the contractor it deems necessary. After all, it is the contractor who is asking for approval. Moreover, there is a cultural dimension that influences the adoption of environmentally preferable alternatives. MILSPECS and MILSTDS have defined state of the art for quality and reliability for a long time throughout industry. Although it is dangerous to generalize, there is a tendency for organizations preparing the standards and for program offices not to consider private-sector experience in the commercial market with environmentally preferable technologies to be an appropriate basis for considering military use of the same technology. In support of this view it has been argued that military equipment is used in more harsh environments, or that the military needs better reliability. There may be some merit to these arguments for some applications, but the commercial experience cannot be discounted totally. When large, established corporations make significant investments in environmentally preferable manufacturing technologies, they do so with a confidence the products manufactured with the technology will perform reliably in the marketplace. Nevertheless, this attitude is a factor that must be considered.
One way to accelerate the approval process is to shift the burden of proof. Rather than require the contractor to prove that the proposed alternative performs better than the current process, let the program office show cause why the alternative is inadequate. For ODCs this is exactly the effect that Section 326 of the Defense Authorization Act for Fiscal Year 1993 will have on the approval process. For any contract requiring ODCs, the senior acquisition executive must certify that no alternative exists, based on technical evaluation. This forces program offices to certify up through command channels to the assistant secretary why alternative technologies will not meet performance requirements. Most military use of ODCs is for solvents, and based on the conclusion of the most recent United Nations Solvent Technical Options Committee, there are alternatives for virtually all of the solvent uses it identified. Today many major weapons systems development and production programs would come to a halt if the supply of ODCs to contractors were suddenly stopped. One small step that would help those contractors eager to move toward environmentally preferable alternatives would be to allow them to adopt MILSPEC and MILSTD changes enacted since the contract was awarded simply by notifying their program offices, without the need for approval.
To move toward environmentally preferable alternatives, program offices must be receptive to new design ideas, manufacturing processes, material choices,
and products. The process for approving environmentally beneficial changes to programs must be streamlined.
THE NEED FOR TECHNOLOGY ASSISTANCE
Program offices tend to have relatively small staffs, and as a result, most of the technical expertise resides with the contractor. This places the program offices at a distinct disadvantage when trying to evaluate the attributes and risk of a contractor-proposed, environmentally preferable alternative technology. By definition, contractors and their government customers are adversaries. One way of relieving the program office of some of the burden of risk of change is to establish a means of validating environmentally preferable technologies for military use. This could be done by abandoning MILSPECS and MILSTDS in favor of industry standards, or by accelerating the process of changing them and giving environmental considerations a high priority. There are many research and development resources available for this mission, including national laboratories. The key is institutionalizing the means of communicating the endorsed technologies to the program offices and the organizations that prepare MILSPECS and MILSTDS across the services.
The federal government has an opportunity and a responsibility to help improve the global competitiveness of U.S. defense industries (and other U.S. industrial sectors as well). As defense industries look toward commercial markets to replace defense business in a climate of decreasing defense budgets, the government can stimulate improvements in the environmental performance of manufacturing process technology and of manufactured products in a variety of ways. As a large consumer, the federal government should be an informed and responsible environmental consumer and use contracting incentives to stimulate markets for environmentally preferable products. As a large and sophisticated research organization, the government can provide new seed technologies for the private sector to incorporate into environmental products and services for a global commercial market. As a developer, builder, and owner of high-technology systems, the government can support the integration of environmentally preferable technologies into the U.S. manufacturing base and stimulate a better understanding of the environmental impact of material choices for processes and products. As a major consumer of commercial products, the government can stimulate markets for recycled products and stem the flow of waste to landfills. And as operator of major installations that are, in effect, small cities, the government can reduce the environmental impact of its internal operations and provide a model for municipalities nationwide in their effort to improve environmental quality.
The Air Force Pollution Prevention Program is comprehensive and multidis-
ciplinary and has a heavy technology focus. It exploits opportunities to choose environmentally preferable alternatives presented by each of the roles it fulfills in society. It also exploits the opportunities government has to find and support environmentally preferable choices through a comprehensive program of educating team members about the opportunities presented by their jobs, establishing internal goals and objectives designed to improve the environmental performance of Air Force operations, instituting a series of metrics and scorecards to measure performance, and implementing an investment strategy. Goals are defined and measurable and, to the extent possible, reflect a systems-based approach. It will thus be possible to measure progress over time. In this way, the Air Force offers a model for applying industrial ecology concepts in the short term across a complex organizational structure.