Hazardous Chemical Register for GTESPO
Description of the project
This project supported the Ground Telecommunication Equipment System Program Office (GTESPO) Remediation Project Plan by preparing & developing the embedded Hazardous Material (EHM) Register & Hazardous Chemical (HC) Registers for the Tactical Air Defence Radar System (TADRS). The TADRS platform is under the authority of the GTESPO located at the RAAF Williamtown.
By developing the methodology to create the EHM registers massive savings could now be realised. The innovative methodology is transferrable to all GTESPO platforms as they share common componentry such as transmitters, receivers, UPS and aerials.
The TADRS platform, in which ADF, APS &/or Defence Contractors (i.e. under CMS/CMC/BSA or GSS contracts) will essentially only conduct operational maintenance tasks. Operational maintenance (OM) in this instance is shared between the Operational Unit (Op Unit) of the Authorised Maintenance Organisation (AMO) & the Original Equipment Manufacturer (OEM) / Supplier, Lockheed Martin. Deeper maintenance (DM) & disposal (redundant platform) are conducted by the OEM.
The TADRS platform has OM tasks performed on the platform by Defence personnel & contractors. The OEM / Supplier conduct OM, DM & disposal of the redundant platform. Carriage repairs and refurbishment is conducted by an independent contractor, “Varley Engineering” in their own specialty facilities located at Tomago. This platform, in terms of the inherent risk it presents to GTESPO from HC & EHMs’ was considered to be low to medium.
Two Op-units are authorised to conduct maintenance on the TADRS Platform, 3CRU in RAAF, Williamtown, NSW & 114MCRU, RAAF, Darwin, NT. The TADRS IETM, Planned Schedule Servicing (PSS) & Technical Maintenance Plan (TMP) was reviewed. PSS OM tasks were identified & assessed in terms of the maintenance activities conducted, the frequency & the estimated duration of the tasks.
Where Operational Maintenance is performed in accordance with the TADRS Planned Servicing Schedule (PSS) by ADF/APS or Defence Contractors, only perfunctory maintenance tasks were conducted such as, visual inspections, topping up of service fluids and/or the removal & replacement of pull out / plug in, modular spare part assemblies etc. No OM tasks were identified requiring operations such as welding, sanding, spray painting, grinding, abrading, drilling, shot blasting, hot & cold cutting or any other processes able to form or create significant levels of hazardous particulates or fumes from embedded hazardous materials.
Following a review of the available data, it was concluded there was no requirement for a pro-active invasive testing regime of parts for the TADRS platform, as the OM procedures are perfunctory & unlikely to disturb hazardous materials to produce significant levels of particles or fumes. Testing of all parts for embedded hazardous materials to prepare these registers would have been both impractical and prohibitive in terms of cost and time.
It was determined that most parts in this platform could be classified under the status of “presumed to contain” a hazardous material unless a situation or the economics dictated otherwise. However it was recommended that beryllium alloys & ceramic parts that are presumed to contain beryllium should be positively identified by either the OEM through the original supply specifications, MIL SPEC or testing by a NATA certified laboratory.
Testing the parts over an extended time frame was considered an adequate control strategy given the low risk, a status of “presumed to contain” was therefore put in place as the interim default for parts suspected to contain beryllium or other hazardous materials .i.e. when the parts are replaced or have reached the end of their service life they could be tested.
An audit of the data held in the various Defence logistics systems was conducted on the TADRS platform by the Hibbs & Associates Pty Ltd.’s Lead Auditors. Part numbers were extracted from all relevant publications such as the IETM or AAP publications provided by the ESM.
Details of any innovations on these projects
Testing of all parts on all platform types for embedded hazardous materials to prepare EHM registers would have been both impractical and prohibitive in terms of cost and time.
By developing the TADRS EHM register template & methodology, enormous savings can now be realised across all 17 GTESPO platforms. The EHM Register template is transferrable to all GTESPO platforms as they share common componentry such as transmitters, receivers, UPS and aerials etc.
The innovative methodology can also be used by other SPO’s to prepare their own templates for the creation of EHM Registers.
Activities that provided value added options to the client, detailing any long term benefits
- The development of a consolidated EHM list through the review and cross checking of all available maintenance and technical documentation for this Platform associated with their location and use. This activity was conducted by our team of occupational hygienists, auditors and consultants with science and chemistry backgrounds to best derive a baseline list of EHMs which can be “trusted”. As a result of this, gaps were identified in the current system from a logistical and procedural perspective, corrective actions were provided to address the identified shortfalls.
- The development of the consolidated EHM List/Fact Sheet and storage within the Defence ChemAlert system for TADRS can be applied to and used for the other 16 platforms which are controlled by GTESPO, thus saving significant rework given the EHMs found within the TADRS system have common componentry across the rest of the GTESPO platforms.
- The development and consolidation of Embedded Hazardous Material (EHM) List within GTESPO/TADRS Platform.
- The EHM List is contained in a spread sheet, listing substance detail, chemical form, physical data, main areas of use, common applications, and confirmed locations of use, the latter from a review of the technical publications listed above.
- Appropriate Fact Sheet publications (e.g. by Defence DCOH) for various EHMs were then collated for the EHMs identified which provide generic SDS for embedded hazardous materials. This EHM list and their relevant Fact Sheets are then linked in the ChemAlert system for GTESPO/TADRS.