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2 The Navy's Current Health-Hazard Assessment Process
Pages 15-36

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From page 15...
... NAVY POLICIES AND DIRECTIVES RELATED TO HAZARDOUS SUBSTANCES Because the Navy is a very large organization spread out over the entire marine geography of the earth, it requires an integrated command structure to carry out its duties for sound and responsible handling of hazardous substances. Without a responsive command structure that acts in an effective, efficient, and coordinated manner to handle hazardous materials, the Navy's mission to protect and defend the nation and fulfill treaty agreements with allies could be jeopardized 15
From page 16...
... by incorporating elements of occupational safety, industrial hygiene, occupational medicine, and hazard communication. The documents also demonstrate that NEHC is given considerable responsibility for reviewing and assessing the impact of potential hazardous substances on the health of Navy personnel and communicating its findings to the Navy command structure.
From page 17...
... However, Navy operational units may screen materials—for small onthe-shelf types of purchases—through the safety office at site operations and regional occupational health centers. Only materials that are not cleared during the screening process at the unit level or by regional occupational health centers are sent to NEHC.
From page 18...
... 18 2 o E /oZ o a ~ 1 tozo Ul ~ ~ O ° ,,, f — — — — — _ _ _ _ I O Us I LIZ ZZ I ~ O 1 ~ C,0 ~ 1 111 En 1 ~ — ~ 1 U.!
From page 19...
... The NEHC healthhazard assessment program provides commanders and commanding officers with technical assistance for evaluating toxicity and other relevant data, identifying appropriate control measures, monitoring the use of hazardous materials in the workplace, and developing authorized hazardous-materials-use lists. NEHC's HHA process depends heavily on the availability and quality of toxicity and use information as well as on individuals capable of understanding and applying that information in an appropriate manner.
From page 20...
... with assistance/input from the environmental programs and occupational medicine directorates, or NHRC Toxicology Detachment. Prepare response to the requester.
From page 21...
... . If the safety office at the site operations cannot determine whether or not the substance is a health hazard, industrial hygienists and occupational medicine physicians at a regional occupational health department then review the material (Leve!
From page 22...
... Personnel Required to Perform Specific Projects B.S.-level industrial hygienist 2318 technical documentation packages via electronic media (10 December 1997 to 30 January 1998) B.S.-level industrial hygienist Requests from suppliers for 14 (10 December 1997 to B.S.-level industrial information pertaining to the 30 January 1998)
From page 23...
... 1 (Naval Air Warfare Center) 1 (Navy Environmental and Preventive Medicine Unit # 2, Norfolk, VA 1 (Naval Sea Systems Command)
From page 24...
... The subcommittee's assessment of NEHC's HHA process was based on documents provided by the Navy and presentations made by Navy personnel, observations and evaluations made during a site visit to NEHC in Norfolk, Virginia, and a site visit to the naval aircraft carrier U.S.S. Constellation while docked et the Naval Air Station, North Island, in San Diego, California.
From page 25...
... Molybdenum disulfide antiseize compound Solventless motor varnishes Washroom cleaner Rubber mounts and adhesives Armaflex insulation Provides review of off-gas testing data from samples analyzed at the National Aeronautics and Space Administration/ White Sands Test Facility (NASA/WSTF) , Las Cruces, NM, and assigns a recommended usage category for this antiseize compound.
From page 26...
... and their experience relevant to naval operations to evaluate the available toxicolog~cal, epidem~olog~cal, and related data; judge the nature and degree of the exposures that might occur; assess the potential health hazard from each; and recommend controls needed in a given use situation to minimize the health risk. If necessary, NEHC also provides interim recommendations to the requesting command to ensure that obvious health hazards identified early in the review process are made
From page 27...
... NHRC/TD also maintains toxicology databases that are presumably available for use by NEHC. Further, staff guidelines for the preparation of HHAs powt out that "if it is considered to be advantageous," assistance can be sought from the Environmental Programs Directorate or the Occupational Medicine Directorate for comment on the occupational medicine and environmental hazard aspects of a product's use a Drewyer, personal commun.
From page 28...
... number for each ingredient, a current MSDS for each ingredient, the temperature to which the product will be subjected during use as well as maximum use temperature, copies of toxicity studies related to the product and its ingredients, and copies of standard operating procedures that relate to the application or use of the product. · Desirable information to complete an HHA includes a small sample of the product as sold, copies of any industrial hygiene survey reports that address potential health hazards related to working with the material, copies of laboratory reports that address the composition and magnitude of pyrolysis products emitted from the product when it is involved in a fire or otherwise severely heated or allowed to contact molten metal, and a technical points of contact within the Navy and at major commercial users of the product should additional information pertaining to application or use experience be needed.
From page 29...
... ; an LC50 of less than 2,000 ppm by volume of gas or vapor, or 20 mg/liter of mist, fume, or dust; a dermal LD50 of less than 1,000 mg/kg of body weight (albino rabbits, 24 continuous hours skin contact) ; Navy occupational chemical reproductive hazards and sensitizers (dermal, respiratory, and systemic)
From page 30...
... NEHC then compares the safe-use assessment to the manufacturer's MSDS sheet and resolves any significant differences with the manufacturer. · As needed, NEHC seeks assistance from the Environmental Programs Directorate or the Occupational Medicine Directorate on the product's environmental and occupational hazards.
From page 31...
... . Ingestion hazards are not normally addressed due to the unlikelihood of occupational exposure via the ingestion route.
From page 32...
... Unlike civilian operations, exposures in the Navy occur under "normal workplace conditions" or under "operational conditions," that is, under exposure conditions driven by military mission performance requirements and under constraints very different from civilian exposure conditions. This subset of occupational exposures encompasses a continuum from training through combat.
From page 33...
... These factors, however, are not likely to be relevant for civilian employees of the Navy who are expected to have employment characteristics similar to that of the civilian workforce in the private sector. HUMAN RESOURCES AVAILABLE TO CONDUCT HEALTH-HAZARD ASSESSMENTS HHAs are conducted in whole or in part by professional and technical staff both the Industrial Hygiene Directorate and Environmental Programs Directorate, which are located at NEHC in Norfolk, Virginia.
From page 34...
... NHRC/TD has the capability of conducting experimental studies to determine the toxicological hazard of chemicals used by the Navy and to perform risk assessments for chemicals that involve complex issues. Staff experience and training in the Industrial Hygiene and Env~ronmental Programs Directorates are predominately in industrial hygiene; however, some staff are trained in environmental engineering, environmental sciences, and chemistry.
From page 35...
... Those requests for review were the mechanisms employed to obtain external review of the linkanpo Incineration Complex draft health risk analysis and the "Human Health Risk Evaluation for Past Firefighters' Activities at Naval Air Station Alameda California." The Naval Air Station Alameda assessment is highly visible due to potential occupational exposures from PCBs, diox~ns, and lead incurred during training exercises by fire fighters. The linkanpo assessment addresses a highly visible public health issue involving exposure of Navy staff, dependents, and facility tenants to industrial waste ~nc~nerator emissions generated by a crivateiv owned off-site firm re~ulated by a host country.
From page 36...
... Selection criteria for identifying which institutions and staff qualifications are needed to perform a given review are not known to the subcommittee. The routine NEHC criterion is to select external reviewers who have risk-assessment experience and are associated with the governmental regulatory sector.


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