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

TO COMPLETE its mission effectively, the Department of efense(DOD), the Secretary of the Navy(SECNAV), Chief of Navy Operations, and the Bureau of Medicine and Surgery (BUMED) have published directives, instructions, and military standards. The purpose of this section is to review and summarize those documents, to assess whether the Navy management system for handling hazardous material clearly states its policy with regard to how such materials should be handled, who is responsible for implementing the policy decisions, and whether the Navy Environmental Health Center (NEHC) is adequately chartered to carry out the mission assigned to it.

Each of the relevant DOD or Department of the Navy (DON) documents are reviewed below.

This directive establishes policy, assigns responsibilities, and defines procedures for hazardous material pollution prevention. It is DOD

policy that hazardous materials are selected, used, and managed over their life cycle, so that DOD incurs the lowest cost required to protect human health and the environment. The preferred method of doing this is to avoid or reduce the use of hazardous material. If use of hazardous material might not be reasonably avoided, users must apply management practices that avoid harm to health and the environment. Emphasis is placed on reduction of hazardous materials in processes and products, as distinguished from end-of-pipe management of hazardous waste. The managers of DOD components are required to (1) facilitate the use of a less-hazardous material when the use of a hazardous material or a process using a hazardous material has been authorized, and a less hazardous substitute is or could be available; (2) evaluate hazardous-material decisions using economic analysis techniques that match the magnitude of the decision being made, cost factors, and other intangible factors; and (3) begin economic analysis of hazardous-material decisions at the earliest possible stage of the life cycle and modify analyses whenever better information becomes available.

This directive requires a management process be used for acquiring quality products that emphasizes effective acquisition planning, improved communications with users, and risk management.

Threat projections, life-cycle costs, cost-performance schedule trade-offs, affordability constraints, and risk management are major considerations at each procurement milestone. A hierarchy of potential material alternatives must be considered prior to a decision to commit to a new acquisition program. Program plans must provide for a concurrent systems-engineering approach to achieve a careful balance among system design requirements, which include safety considerations. Project bid documents from contractors require them to identify risks and provide specific plans to assess and eliminate risks or reduce them to acceptable levels.

This document establishes DOD policy, responsibilities, and proce-

dures for a comprehensive hazard-communication program. Properly implemented, this program ensures that DOD personnel are aware of potential health hazards associated with their occupation; informed of safe work practices and proper use of engineering controls; trained in the selection, use, and availability of appropriate personal protective equipment to prevent chemically related injuries and illnesses; and comply with OSHA regulations.

This instruction establishes DOD policy that requires DOD units to establish and maintain comprehensive and aggressive occupational, safety, and health programs to protect all personnel from work-related deaths, injuries, or illnesses.

This instruction establishes uniform procedures for recognizing and evaluating health risks associated with exposure to chemical, physical, and biological stressors in the workplace.

It is DOD policy to provide each employee with a healthful work environment that is free from recognized health hazards. DOD policy requires that health hazards must be identified, evaluated, and controlled.

Consistent, meaningful occupational health and environmental surveillance programs must be implemented to ensure that controls adequately protect the health of DOD personnel.

This standard is intended to ensure that safety systems are included in technology development and designed into systems, subsystems, equipment, facilities, and their interface and operation.

Governmental agencies and contractors are required to use a safety-management approach during the system acquisition process and throughout the life cycle of each system, making sure mishap risk is understood and risk reduction is always considered in the management-review process.

It emphasizes a formal safety program that stresses early hazard identification and elimination or reduction of associated risk as the principle contribution of an effective system safety program.

This instruction aligns DON policy with DOD policy and stresses safety and occupational health as inherent responsibilities of the Navy command structure. Navy programs are to be established, funded, and maintained to protect all civilian and military personnel from work-related mishaps, injuries, and illnesses. Navy activities should emphasize an awareness of good safety and health practices among all personnel, both civilian and military. It requires that safety and health hazards be identified, evaluated, and controlled.

Consistent, meaningful occupational health surveillance programs are to be implemented by Navy medical departments to ensure that controls adequately protect the health of personnel. Personal protective equipment is to be provided. Safety and occupational health precautions are to be integrated into training and indoctrination programs and into technical and tactical publications.

This instruction also requires establishment of uniform procedures to evaluate safety and health risks associated with exposure to chemical physical, and biological stressors in Navy workplaces. It also requires identification of safety concerns related to emerging technology, as well as the establishment and maintenance of a formal hazard-tracking system, to ensure that significant hazards identified during system safety program reviews are properly documented, tracked, and resolved.

This instruction establishes the duties and responsibilities of the Assistant Secretary of the Navy with regard to the research, development, and acquisition processes.

This instruction provides policy and requirements for the Navy System Safety Programs to improve operational readiness and reduce costs by using system safety design and analysis techniques.

Engineering and management controls are to be applied to ensure that prior to system production, construction, and deployment, primary emphasis is placed on the identification, evaluation, and elimination or control of hazards.

System safety risk requirements, criteria, and constraints, and needed program resources are to be addressed by the originators of each operational requirement and summarized in a Decision Coordinating/System Concept Paper. System safety hazard assessments must also be presented at design and program reviews.

Procedures must be developed for the safe and environmentally acceptable use, stowage, and disposal or demilitarization of any hazardous materials and equipment associated with the system.

Data must also be developed to identify and control hazardous materials and items, including selection of the least-hazardous alternative and provide safety and health requirements with the planned maintenance system cards, along with material safety data sheets.

This instruction establishes a uniform policy, guidance, and require -

ments for the life-cycle control and total-quality management (TQL) of hazardous material acquired and used by the Navy. It requires the Navy to identify hazardous materials needed to meet mission requirements and, if feasible, substitute less-hazardous material. It requires incorporation of the necessary investigations and research studies for safety, environmental protection, health-hazard identification, and risk assessments into system research and development programs. Assessments are to be geared to control and reduce hazardous-materials requirements, and minimize the costs associated with hazardous-waste generation and disposal.

The Navy is to control and reduce the amount of hazardous material used and hazardous waste generated by up-front hazardous-materials control in acquisition, procurement, supply, and utilization through the development of mechanisms to identify materials in the system that are hazardous, and to limit quantities of hazardous materials acquired and stored.

The instruction requires establishment of activity-authorized use lists, and controls over hazardous-materials quantities used to reduce the generation of hazardous waste. Plans for the review of specifications that direct use of hazardous materials are required to further minimize the use of hazardous materials.

The instruction also establishes mechanisms for substituting less hazardous material for hazardous materials if technically feasible. Decisions to use hazardous materials or substitution of less-hazardous materials are to be supported by an economic analysis appropriate to the magnitude of the decision being made. Such analysis is to include cost factors and intangibles such as savings from reduction in training and other related hazardous-material or hazardous-waste impacts.

BUMED, is identified as the office responsible for providing workplace-hazard evaluations and health risk assessments specific to hazardous-materials applications in the Navy. Also, the Navy is to develop, maintain, and distribute technical information on health risks and assessments for hazardous materials used in Navy workplaces and operations.

NEHC is to provide commanders and commanding officers with technical assistance in evaluating and monitoring the use of hazardous materials in the workplace, prescribing precautionary measures, and assisting shore activities in developing authorized hazardous-materials use lists.

This instruction identifies the methods to be used to properly manage hazardous materials aboard surface ships and submarines.

NEHC efforts in recognizing potential health threats posed by hazardous materials are an integral part of this process. NEHC has recently begun a comprehensive program, in cooperation with the Naval Surface Warfare Center, Carterock Division, to become a major player in all decisions made about whether to allow a potentially hazardous material on ships, and inclusion in the Shipboard Hazardous Material List.

Requests by fleet and NAVSEA program managers for use of new materials must first receive NEHC review, along with line command consideration of the need any benefits of the new material.

An NEHC role in this process is to provide a comprehensive health-hazard evaluation report for each material, summarizing to what extent the material can be used safely aboard ships, and specific health-hazard control measures that will be necessary to ensure the safety of shipboard personnel.

NEHC also is instructed to develop a comprehensive Submarine Materials Review Program with the Naval Sea Systems Command (SYSCOM), so that all new materials contemplated for use in the construction or maintenance of nuclear-powered submarines can be reviewed by NEHC's Submarine Materials Review Board.

Reports issued to NAVSEA via BUMED recommend proposed-use categories, and contain additional health-hazard control guidance to ensure the material is used in a safe manner.

This document addresses the Navy's Hazardous Material Control and Management Program. Responsibilities of BUMED include providing workplace-hazard evaluations and health risk assessments specific to hazardous-material applications, and developing, maintaining, and distributing to activities technical information on health risks and assessments for hazardous materials used in Navy workplaces and

operations. BUMED is also responsible for providing commanders and commanding officers with technical assistance in evaluating and monitoring the use of hazardous material in the workplace, prescribing precautionary measures.

BUMED is to evaluate and confirm requirements for toxicological research for new systems or for Navy-unique hazardous material or Navy-manufactured hazardous materials. BUMED is to ensure development of needed data for the safe use and handling of the material in Navy systems, both ashore and afloat.

This instruction establishes the policy, guidance, and requirements for the life-cycle control and TQL of hazardous material acquired and used by the Navy Medical Department.

It tasks NEHC to assist Navy systems commands, program managers, and medical department activities in support of the Hazardous Material Control and Management Program. This includes performing health-hazard risk assessments when requested by Navy systems commands, and involves the development, maintenance, and distribution of technical information on health risks and assessments for hazardous materials used in workplaces and operations, which is to be coordinated with Naval Medical Research Institute, Toxicology Detachment (NMRI/TD).

NEHC is to assist SYSCOM and program managers in reviewing hazardous-materials controlling documents (such as maintenance plans, maintenance requirement cards, and technical documents) that require the use of hazardous materials in the support, maintenance, or operation of systems and equipment.

NEHC is also to provide SYSCOM program managers with reviews of performance specifications and guidance on permissible exposure limits for the engineering control of hazardous materials in the workplace and to coordinate with the NEHC/TD to identify required toxicity studies and development of needed data.

SYSCOM program managers are directed to select nonhazardous materials or less-hazardous substitutes.

This instruction is intended to minimize the health hazards posed by materials or by systems under development. It establishes formal procedures for obtaining toxicological information on materials in the research and development process being evaluated for introduction into the naval service or for new applications for existing materials.

It assigns responsibilities to NEHC for performing health-hazard assessments, and for publishing appropriate guidance for controlling potential occupational health hazards.

Programs involved in the research, development, and testing or evaluation are to forward requests for evaluation via their chain of command to NEHC. These requests are to be made early in the developmental phase of each program to allow sufficient time for the evaluation to be performed.

Information to be sent to NEHC includes a point of contact, details of the material or process, intended use, details regarding whether it replaces another material plans for introduction and reporting deadlines for the evaluations, availability of funding to support any research required, and immediate notification to NEHC should adverse health effects attributable to exposure to the new hazardous material be documented or suspected.

NEHC is to provide interim responses to the requesting command to ensure obvious health hazards are identified early in the process, with recommendations for surveillance and control of hazards. Additional guidance is to be provided as results from further research become available.

Other commands (outside of research and development activities) must identify proposed new materials requiring an evaluation. New materials identified at operational unit levels are reviewed by the safety office of the operational command or by the regional Navy occupational medical department. If the information needed for assessment purposes is beyond that available to the local medical department representatives, the local industrial hygienist is directed to refer the request to the NEHC, where it will be evaluated.

NEHC is to be responsible for undertaking a formal review of new

materials upon request and for providing an assessment of potential exposures, and the sufficiency of information to adequately characterize the risk provided by the new material. NEHC is to provide an interim assessment if there is insufficient toxicological information to characterize the risk presented by the new material.

This instruction includes recommendations for surveillance and controls, based on a reasonable and conservative interpretation and extrapolation of the available information. Required, but missing, data must also be identified.

NEHC is to coordinate with the Navy's TD in developing assessments for review of toxicological data, determining additional research required, estimating resource availability and project duration, and estimating additional resources required to advance such a project to meet the requesting command's deadlines.

NEHC is directed to disseminate information, as appropriate, on the hazards identified to ensure control of potential exposures and protect the health of personnel working with the new material.

One of the functions outlined is to provide technical and professional consultative support and assistance to activities responsible for identifying, evaluating, monitoring, and correcting health hazards.