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My unit is looking at using a brass deformer
IAW the DAP 385-64
Safety Site Planning
(13) Establishes or designates locations for equipment (such as, brass deformers) used to process spent cartridge cases, range residue, and so forth
Question: If the brass is already Certified and verified explosive free, as it would be going to DLA, why would the unit need a DDESB safety site plan?
Appears to be a disconnect within the regulations, OR, the Army has elected to make the requirement more restrictive. To your original question I'd say "becuse the DA Pam says you are required to have one". The services can absloutly add requirements above DOD guidance.
Once I dug into the DESR 6055.09 it would appear that a site plan would NOT be required if specific requirements were met.
V4.E184.108.40.206. Demilitarization processing operation locations meeting the requirements of paragraphs V4.E5.18.1. and V4.E5.18.2., and located outside of IBD from all PESs, do not require submission of a site plan to the DDESB as addressed in paragraph V1.E5.3.9.
The 18.1 and 18.2 referanced state:
I'd recommend reaching out to your supporting Safety office and DAC for specific guidance.
Thanks James! Hope all is well.
I do not think there is a disconnect with Army Guidance (DA Pam 385-64) and the DESR 6055.09. Reasoning: DA Pam 385-64, Chapter 4, para 4-1.a.13 requires a site plan for a brass deformer if it is within IBD from PES's (My Opinion). If the brass deformer is outside of IBD from PES's, and meets the requirements listed in DESR V4.E5.18.1 and 18.2 a site plan would not be required. (I do agree, we need to submit a change to DA Pam 385-64, para 13 to read "Establishes or designates locations for equipment (such as, brass deformers, and so forth) used to process spent cartridge cases, range residue within IBD of PES's". If the deformer is outside of IBD, you will not require a site plan.
Thank you Carl. Hope all is well.
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