What is/are the standard(s) for the securing of AE loads for transport when on installation boundaries?
Specifically when in reference to contractor operated facilities?
Also, what are the options for deviation from these requirements?
-Using the following illustration:
Contractor operates a production line that receives AE material from storage and transports AE material back to storage. Some of the AE is robust, as in artillery rounds, and some is more sensitive, as in propellant and bulk explosives. Assuming that DoDM 4145.26 (DoD contractors safety manual for ammunition and explosives) is incorporated into their contract, are they required to block and brace these loads?
If the contractor does not currently block and brace loads, is a DD Form 2977 (Deliberate Risk Acceptance Worksheet) an acceptable manner for the installation commander to accept the associated risk?
If a DD Form 7632, (Deviation and Risk Acceptance Document) is pursued to address the deviation from the safety standard, is it reasonable to say that each AE item may generate a different risk profile? In other words, the DARAD for the robust item could be an exemption, while the DARAD for the more sensitive AE items may only necessitate a short term waiver, as the correction may be relatively easy?
My chain of reasoning is this:
AR 385-10, 1-4, ll
ll. Commanders of installations and activities with an ammunition or explosives mission. Commanders of installations and activities with an ammunition or explosives mission will— (1) Establish an ESMP in compliance with this regulation and DA Pam 385–64.
DA PAM 385-64, 1-4, a
a. The words "shall," "will," and "must" are used to state mandatory requirements. Deviation from these provisions requires a DA Form 7632 per provisions of AR 385–10 and DA Pamphlet (DA Pam) 385–30.
DA PAM 385-30, 1-8, e
e. Risk assessments, with the exception of deviations from AE or chemical agent safety standards, will be documented using DD Form 2977 (Deliberate Risk Assessment Worksheet). Instructions for DD Form 2977 can be found in appendix B. DA Form 7632 is mandatory for deviations from AE or chemical agent safety standards. Instructions for DA Form 7632 can be found in appendix C.
DA PAM 385-64, 20-6 d
d. All ammunition or explosives loaded on vehicles will be secure and stable before movement. Additionally, ammunition or explosives will be blocked and braced in accordance with approved drawings.
DA PAM 385-64, 20-10 c
c. Ammunition will be blocked and braced or secured with suitable tie-down straps to prevent movement.
Since this is a deviation from AE Safety standards, a DARAD is correct.
Does the operating contractor have a requirement to comply?
Yes, IAW DoDM 4145.26 – DoD Contractor's Safety Manual for Ammunition and Explosives, C3.15
C3.15 Intraplant rail Transportation
C.3.15.1 Written Procedures. The contractor shall develop written procedures to ensure safe and efficient rail movement of AE. These procedures shall include, as a minimum, the following information:
C3.15.1.5 During transfer movements within establishments, full or partial loads of AE in rail cars shall be blocked and braced so they cannot shift position
