Are UXO Escorts Getting Short-Changed?

Washington, D.C. Several years ago the Department of Labor (DOL) added UXO Technician categories to the list of occupations and skill sets under Service Contract Act (SCA) contracts. SCA rates are the minimum hourly rates that companies are required to pay employees working under SCA contracts. The scale or wages vary by location including by State and county. conducted an evaluation of SCA wage lists from over a dozen of locations and came across some interesting results. All wage determinations examined had five categories for UXO technicians under the 30000 series (Technical Occupations). These included:

  • Code 30491 - UXO Technician I
  • Code 30492 - UXO Technician II
  • Code 30493 - UXO Technician III
  • Code 30494 - UXO Safety Escort
  • Code 30495 - UXO Sweep Personnel

In all cases examined from the DOL website, the minimum hourly rates for the Sweep Personnel and Safety Escort were equal to the rate for a UXO Technician Level I. However, what is more interesting is that the DDESBP and USACE policy requires escorts to be performed by a UXO Technician Level II or higher. Specific language from the respective policies are highlighted below:


DDESB 6055.09 Standard Update Released

Washington, D.C. The Department of Defense Explosive Safety Board (DDESB) Administratively Reissued their Explosives Safety Standard "DoD Ammunition and Explosives Safety Standards: 6055.09-M". In the re-issue process, the 6055.09 standard was reclassified as a "Manual" and was issued in a series of eight separate volumes.

The volume which impacts the UXO industry the most is Volume 7: "Criteria for UXO, Munitions Response, Waste Military Munitions, and Material Potentially Presenting an Explosive Hazard (MPPEH)". Specifically within Volume 7 are enclosures on several topics including enclosures for UXO, Real Property Known or Suspected to Contain MEC and chemical agents (CA), and MPPEH.

The revised Manual is close to the version that was updated and released in February 2008. However, the revised manual does have some interesting new or revised requirements that are worth noting.


ATF Updates The Federal List of Explosive Materials

Washington, D.C. The Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) published their annual updated list of explosive materials in the Federal Register. The list includes explosives, blasting agents, and detonators, that are subject to federal importation, manufacture, distribution, receipt, and storage regulations.

The updated list for 2010 includes 237 materials. One noticeable change from lists published in recent years is the absence of ammonium perchlorate composite propellant (APCP). APCP has been removed from the list as a result of a court decision in March 2009 and is no longer regulated under federal explosive laws.


DDDESB Releases Update to 6055.9 Standard

The DoD Explosive Safety Board (DDESB) released an updated version of their explosive safety standard 6055.9 STD. The update incorporates two series of changes and revisions which were initially incorporated in March and August 2009 respectively. Impacts to the UXO industry include updates to the section on Material Potentially Presenting An Explosive Hazard (MPPEH) (i.e., Section 16) which adds a sub section on the "Collection of MPPEH" (subsection 16-3).

Sub-section 16-3 covering collection of MPPEH does not incorporate any "new" requirements related to the management of MPPEH itself but rather updates the 6055.STD so that it agrees with language in DoD Instruction 4140.62 "Material Potentially Presenting an Explosive Hazard" which was updated in November 2008. The revised DDESB standard strengthens DoD's commitment to ensure that hazardous material is not released outside of its control and that all material inspected that is certified as safe (i.e., material documented as safe [MDAS]) is controlled and maintained to prevent potential co-mingling of MPPEH and material documented as an explosive hazard (MDEH).


Army Revises Policy on Certain CAIS

The Army released a policy memorandum providing clarification of guidance and procedures for use in field operations involving Chemical Agent Identification Sets (CAIS) containing dilute chemical agents. The policy specifically applies only to the K951/2, K953/4, and K955 CAIS and is applicable for range clearance activities on operational ranges as well as munitions response actions on other than operational ranges.

The policy basically allows certain CAIS recovered to be treated and disposed of as hazardous waste by contractors as an alternative to initiating a chemical event report and having the Army (i.e. Technical Escort) respond as an explosives or emergency response under the 20th Support Command (Chemical, Biological, Radiological, Nuclear, High Yield Explosives  CBRNE). The policy also waives the requirement for a chemical site plan and a munition response chemical safety submission for sites where only K951/2, K953/4 and/or K955 CAIS are recovered.


Congress Considering UXO Technology Transfer Initiatives

The current version of the national Defense Authorization Act for 2009 being debated in Congress provides some interesting new guidance on how DoD's research, development, test and evaluation (RDT&E) funds related to UXO technology can be spent. Section 314 of HR 5658 allows DoD to utilize a portion of the funds allocated for RDT&E activities to assist in the training of UXO detection equipment operators on the use of new instruments. The funds can be used on DoD funded technologies as well as technologies "developed by entities other than the DoD". A specific percent or vale (i.e., minimum or maximum ceiling) was not provided in the language itself.


Making Sense of UXO and MC From Live Fire Training

The current version of the National Defense Authorization Act for 2009 being debated in Congress provides some interesting language on the impacts of live fire training. Section 359 "Sense of Congress Regarding Procurement and Use of Munitions" of HR 5658 requires that with respect to decisions on the procurement of munitions, DoD develop methods to "account for the full life-cycle costs of munitions, including the effects of failure rates on the cost of disposal"; and undertake a review of live-fire practices for the purpose of reducing UXO and munitions constituent (MC) contamination without impeding military readiness.


EPA issues final permit decision for treatment of UXO at CNMI

Honolulu, Hawaii The U.S. Environmental Protection Agency has decided to grant a hazardous waste permit to the Commonwealth of the Northern Mariana Islands (CNMI) Department of Public Safety for storing and treating UXO.

CNMI began the process for a Remedial Action Plan, a unique kind of RCRA permit, in 2006, to address the hazards created by the millions of pounds of munitions and explosives abandoned in Saipan following World War II. The EPA issued a draft Remedial Action Plan in December 2007, followed by a public comment period that closed in January.


National Park Service Adopts New Policy on Ordnance

Petersburg, Virginia The National Park Service has adopted a new policy regarding Civil War ordnance. The new policy states that the bomb squad will be notified when Civil War ordnance items are found on historic properties. Prior to the policy, ordnance found sometimes made its way into the hands of museums or collectors.


USACE Releases Updated Guidance on Explosives Site Plans

Huntsville, Alabama The USACE released an Interim Guidance Document (IGD) related to Explosive Site Plans (ESP) for Army Military Munitions Response Program (MMRP) projects. The interim guidance establishes the requirement for the submittal of a separate, stand-alone ESP for Army MMRP sites and provides an updated standard format for an ESP.


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