Review of the U.S. Navy Environmental Health Center's Health-Hazard Assessment Process (2000) / Chapter Skim
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4 Conclusions and Recommendations
4 Conclusions and Recommendations
Pages 45-57
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From page 45... ...
In addition, the subcommittee reviewed HHA processes used by chemical and pharmaceutical companies for their adaptability and usefulness to the Navy situation. Based on its assessment, the subcommittee concludes that NEHC's HHA process is adequate for preparing routine HHAs, considering the available resources.
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From page 46... ...
The subcommittee believes that the efficiency, consistency, and "institutional memory" of NEHC can be enhanced if formal, documented SOPs for preparing HHAs are developed and implemented. Therefore, the subcommittee recommends that NEHC develop (and update regularly)
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From page 47... ...
Examples of such complex projects include those that involve determining the health hazards associated with the off-gassing of chemicals in submarine environments and the risk to personnel and their families from exposure to emissions from the Japanese incinerator in Catsup. The subcommittee recommends that NEHC recruit professional scientists with expertise in toxicology,
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From page 48... ...
However, because all naval operations need to have an adequate level of access to industrial hygienists, commensurate with the size of the facility and the mission (e.g., an aircraft carrier would need several shipboard billets, whereas a submarine would only need periodic access to such officers) , the subcommittee recommends that NEHC evaluate whether Navy facilities have sufficient level of support in industrial hygiene.
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From page 49... ...
The subcommittee recommends that NEHC develop a long-term strategy to deal with increasing demand for services in the face of declining resources. This strategy would include elements such as streamlined processes to conserve staff time; increased training of current staff to keep current with advances in toxicology, epidemiology, and risk assessment; and a workforce-planning strategy to replace retiring or relocated staff to ensure the basic quality and quantity of HHAs.
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From page 50... ...
Although this would allow more staff time to be devoted directly to the development of HHAs, the subcommittee recommends that specific directives be issued by the Navy to ensure continued HHA-development training for NEHC professionals. Areas of training should include industrial hygiene, toxicology, epidemiology, chem~stry, and risk assessment.
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From page 51... ...
Because the use of the MSDS has become a critical element of the HHA process, the subcommittee recommends that industrial hygiene personnel at regional or local occupational offices as well as those aboard Navy ships be provided with MSDSs as soon as possible. However, the subcommittee recommends that ship TH officers not solely rely on MSDSs because they sometimes over-estimate effects or fad!
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From page 52... ...
The subcommittee recommends that NEHC independently confirm key information presented in HSDB, RTECs, and IARC documents. To avoid duplication, the subcommittee recommends that NEHC thoroughly evaluate existing information from other governmental agencies, other organizations, and the open literature prior to conduct
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From page 53... ...
. The subcomm~ttee also recommends that NEHC consider using exposure limits recommended by other governmental and nongovernmental organizations, such as those recommended by the Occupational Safety and Health Administration, National Institute for Occupational Safety and Health, American Conference of Governmental Industrial Hygienists, and American Industrial Hygiene Association.
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From page 54... ...
HHAs associated with an intermediate hazard would be subject to systematic internal reviews. The subcommittee believes that periodic external review of NEHC's HHA process would assure scientific rigor and objectivity of the program and provide an opportunity for staff to obtain additional perspective, overview and consultation, and access to evolving technolog~es from scientists working in the field outside the Navy.
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From page 55... ...
In addition, there were no examples provided of anticipatory or "proactive" efforts by NEHC staff to identify and mitigate potential hazards, or to develop improved processes for HHA. The subcommittee recommends that NEHC develop a formal system or process to collaborate with other military organizations, such as CHPPM in developing HHA reports and distribute report findings to them.
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From page 56... ...
For the interim, the subcommittee recommends that data from the existing medical surveillance program be analyzed by NEHC to evaluate the effectiveness of HHAs on a regular basis. This is a key element of a properly functioning occupational health program, and is essential to verify the effectiveness of the HHA program and its recommendations.
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From page 57... ...
The subcommittee concludes that the development of formal, written SOPs; the addition of senior scientists with expertise in toxicology, epidemiology, risk assessment, and industrial hygiene; increased training of the current staff; better QA/QC procedures, including the formation of a peer review board; improvements in data acquisition and management; better coordination between NEHC and other organizations and stakeholders; the development of a centralized medical-data management system; and consideration of life-cycle issues would lead to a more effective HHA process that would stand up to critical and objective scrutiny. The subcommittee recognizes that many of its recommendations wig require significant resources to implement; however, the subcommittee believes that such investments to improve NEHC's HHA program would be cost effective and would result in significant and long-term benefits to naval readiness and mission fulfillment.
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