Review of the U.S. Navy Environmental Health Center's Health-Hazard Assessment Process (2000)

THE NAVY AND MARINE CORPS use a broad range of materials in operations that occur on land at shore facilities, in the air in combat and reconnaissance aircraft, in surface vessels on seas around the world, and in submarine vessels that operate as self-contained environments. Many of these materials are unique to military operations. Some are also used in civilian operations, but the use of these materials by the Navy and Marine Corps can be substantially different. Although many of the materials used by the Navy might be relatively innocuous, there are a large number that can pose significant health hazards under specific exposure circumstances.

The Navy Environmental Health Center (NEHC) located in Norfolk, Virginia, is the primary organization within the Navy that is tasked with assessing occupational and environmental health hazards for naval personnel from exposures to toxic substances. It serves as the central source or corporate center that provides the Navy and Marine Corps, ashore and afloat, with technical support for preventive medicine, medical management, health promotion, drug screening, and occupational and environmental health programs. For many of these programs, NEHC reviews toxicological and related data and prepares health-hazard assessments (HHAs) for potentially hazardous materials under a variety of exposure conditions. Because NEHC is continually being asked to develop HHAs for new materials for the Navy and the

Marine Corps, and because the Navy is committed to protecting its personnel, their families, and communities surrounding the Naval sites from exposures to toxic chemicals, the National Research Council (NRC) was asked to assess the validity and effectiveness of NEHC 's HHA process; determine whether the process as implemented provides the Navy with state-of-the-art, comprehensive, and defensible evaluations of toxicological hazards; and identify any program elements that require improvement.

The NRC assigned this project to the Board on Environmental Studies and Toxicology's Committee on Toxicology (COT). The COT convened the Subcommittee on Toxicological Hazard Assessment to address this project. The subcommittee has expertise in general toxicology, inhalation toxicology, epidemiology, neurotoxicology, immunotoxicology, reproductive and developmental toxicology, pharmacology, medicine, risk assessment, and biostatistics.

NEHC and its directorates (including subordinate departments) fall under the direct command of the Navy's Bureau of Medicine and Surgery (BUMED). (Appendix A describes the history of NEHC and its relationship with other naval organizations). The Hazardous Materials Department (HMD) of the Industrial Hygiene Directorate is the primary group within NEHC responsible for conducting HHAs of materials or systems that range from single compounds to complex operational systems such as the Tomahawk cruise missile or helicopters. Recent examples of some of the HHAs developed by NEHC pertain to barrier coatings (e.g., antifouling paints and novel “preservative” coatings for surfaces exposed to salt spray), insulating materials, torpedo construction materials, and construction materials for temporary shelters.

HHAs developed for various chemicals used by the Navy play an important role in making decisions regarding the procurement of materials and operating systems by Naval Sea Systems Command – one of the largest acquisition commands of the Navy. HHAs also help to minimize the number and quantity of potentially toxic materials that are integrated into Navy operations by (1) reducing the number of toxic materials bought by the Naval Sea Systems Command and other

Navy commands, and (2) reducing the number of substances or systems integrated into Navy operations that produce hazardous waste. In practice, candidate materials or systems are first screened by the Naval Sea Systems Command or other commands for operational acceptability and cost. Candidate materials or operating systems that meet those criteria are then evaluated for potential human-health hazards by HMD using its HHA process. HMD also conducts life-cycle assessments of materials to minimize generation of hazardous waste. Program managers in the acquisition commands weigh the operational, economic, and health risk factors to choose an ideal candidate material for the Navy. In this way, selections tend to be biased toward a “front-end ” reduction of hazardous materials during the procurement process.

HHAs also provide commanders and commanding officers with technical assistance for evaluating and monitoring hazardous materials in the workplace and by recommending precautionary measures, including the development of lists of hazardous materials authorized for use.

Over the past few years, the need and urgency for HHAs has increased dramatically. This is in large part due to the fact that the reduction of crew sizes and the elimination of redundancy among many occupations in the Navy have put emphasis on quality-of-life concerns for naval personnel who are required to perform onerous functions (e.g., chipping paint below decks when in port). In addition, there is increasing reliance on advanced technologies to compensate for reductions in force levels and personnel. These new technologies often require careful analysis to identify their potential to adversely affect health and readiness.

Because NEHC must meet these obligations without any increase in resources, a scientifically sound and effective HHA process is needed. The subcommittee's report is intended to provide NEHC with recommendations that will improve and strengthen the HHA process and the Navy's efforts in preventive medicine.

The subcommittee's conclusions and recommendations, as presented in this report, are based on its review of documents submitted

by NEHC; presentations made by NEHC personnel at subcommittee meetings; and site visits to NEHC and the aircraft carrier, U.S.S. Constellation, while docked at the Naval Air Station North Island, San Diego, California. In addition, the subcommittee reviewed the HHA processes used by chemical and pharmaceutical companies for their adaptability and usefulness to the military situation.

The remainder of this report is organized into three chapters. In Chapter 2, the subcommittee reviews NEHC's current HHA process. The HHA process used by the chemical and pharmaceutical industry and its applicability and usefulness to the military situation is discussed in Chapter 3. Chapter 4 contains the subcommittee's conclusions and recommendations. Appendix A describes the relationship of NEHC with other Navy organizations; it also describes the role of BUMED with regard to the HHA program. Appendix B presents the policies and instructions issued by Department of Defense and the Department of the Navy with regard to the use of hazardous materials.