Submariners Advocacy Group

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Introduction

The provided documents cover a range of topics related to health and environmental conditions within the military, particularly focusing on the Navy and submarine environments, chemical exposures, and hearing-related issues. They include reports, study analyses, workshop proceedings, and guidance documents detailing investigations into specific hazards, methodologies for assessing risks and setting exposure limits, and procedures for managing these concerns.

Here is a summary of the key information contained in the sources:

Reports Distribution

Some reports are explicitly stated as being sent to various government bodies and individuals, including the Senate Committee on Labor and Human Resources, the Subcommittee on Labor Standards of the House Committee on Education and Labor, Congressman George Miller, the Director of the Office of Management and Budget, the Secretary of Defense, and the Secretary of the Navy. Copies are also made available to other interested parties upon request.

Navy Position on Asbestos

The Department of the Navy concurs with recommendations for effective monitoring and enforcement of asbestos controls. The Navy is implementing improvements through organizational changes, staffing increases, and internal audits. The Navy also commented on draft reports, suggesting that the inference that asbestos exposure carries a certainty of disease could be attenuated with explanatory language.

Submarine Atmosphere Contaminant Studies and Guidance

  • Reports discuss the Absorption, Distribution, and Clearance of 2,6-Di-tert-Butyl-4-nitrophenol (DBNP), identified as a submarine atmosphere contaminant. A report documentation page for this type of study provides fields for details such as the report date, type and dates covered, title/subtitle, subject terms (like DBNP, DBP, nitrophenol, submarine atmosphere contaminant), number of pages, and security classification (UNCLASSIFIED). Instructions are provided for completing this report documentation page (SF 298), specifying information required for each block, including agency use, report date, report type, title, funding numbers, author, performing organization, abstract (maximum 200 words), subject terms, number of pages, price code, and security classifications.
  • The National Research Council (NRC) was organized by the National Academy of Sciences in 1916 to associate the broad community of science and technology with the Academy's purposes of furthering knowledge and advising the federal government. The NRC, functioning in accordance with Academy policies, serves as the principal operating agency for both the National Academy of Sciences and the National Academy of Engineering in providing services to the government, the public, and the scientific and engineering communities. It is administered jointly by both Academies and the Institute of Medicine.
  • NRC committees and subcommittees have been involved in developing Emergency and Continuous Exposure Guidance Levels (EEGLs and CEGLs) for selected submarine contaminants. These guidance levels are based on reviews of relevant human and animal data, using data selection criteria described in the NRC (2001) report Standing Operating Procedures for Developing Acute Exposure Guideline Levels for Hazardous Chemicals. Primary references (published or unpublished) are used whenever possible to derive these levels, with secondary references used to support the estimates and critical end points. The most sensitive endpoints are emphasized when developing 1-h and 24-h EEGLs.
  • A Submarine Atmosphere Contaminant Workshop was held, with goals including determining if atmospheric contaminant limits should be reevaluated by the NRC, amending paragraphs in the atmosphere manual for readability and usefulness, and identifying areas for new or continued research. The workshop arose from concerns and recommendations regarding submarine atmosphere contamination between the Naval Medical Research and Development Command (NMRDC), the operations command, and Naval Research Laboratory chemists. A memo presented as criteria for the study summarized these concerns and recommendations. Recommendations included conducting literature searches on long-term exposure health effects and factors used by agencies like OSHA to set safe thresholds. The Chief of Naval Operations (CNO) office responded by stating action should be taken in these areas.
  • A significant finding was that information in Committee on Toxicology records back to the mid-1950s did not identify a methodological approach for determining acceptable exposure limits for extended periods in confined environments like submarines. While an NRC staff officer initially suggested little thought went into limits, further research indicated a large effort was made to produce accurate meaningful limits for submarine use.
  • Major recommendations from the workshop included revising parts of Chapters 2 and 3 of the Nuclear Powered Submarine Atmosphere Control Manual. Ad hoc committees were to be convened to revise pertinent paragraphs. Areas covered included format changes for conciseness, labeling and logging of hazardous materials with attention to packaging and quantity, and elaborating scenarios and corrective actions for hazardous material spills in port and at sea. Suggestions were made to write the Atmosphere Manual as two documents: one for research with expanded technical sections and another as a working manual for the fleet. It was also discussed whether a committee should add or delete substances from the list of TLVs in the manual and improve the materials list similar to the British list.
  • Submarine Air Quality Monitoring reports discuss the health effects of airborne contaminants at increased pressures for divers and potential additive or synergistic effects of multiple contaminants. Contaminants of greatest concern are categorized by their toxicological effects: central nervous system depression, cardiovascular system effects, irritation of eyes/nose/throat/respiratory system, and known or suspected human carcinogens. Submarine air handling devices are summarized, with comments on potential sampling sites to gather needed data.

Specific Chemical Hazards and Exposures

  • A report on Carbon Monoxide, Hydrogen, and Volatile Organic Compounds (VOCs) inside D5 missiles onboard a submarine found that CO concentrations were not expected to create an overexposure to the OELs considered. However, CO concentrations measured by the PHO-6 direct-reading multi-gas meter overestimated the true concentration about half the time. Although hydrogen (H2) was present in significant concentrations inside D5 missiles, it could not alone explain the difference between CO readings from the PHO-6 meter and laboratory analysis. Recommendations include instituting mitigation procedures to reduce and control benzene exposures below applicable OELs and complying with Navy and federal regulations concerning benzene exposure. Air samples were collected inside D5 missiles for VOCs, CO, and H2 as part of a Special Weapons Test to verify benzene and CO presence and determine if H2 caused erroneous CO readings. Sample collection and analytical methods are summarized, including SUMMA canisters for CO and H2 with lab analysis. Air samples were also collected in the missile compartment to characterize ambient air quality and determine if gases or VOCs detected inside missiles were present there.
  • Assessments suggest that vinylidene chloride, methyl chloroform, and toluene exposures in D5 missiles are likely acceptable, especially considering instantaneous measurements are compared to OELs with much longer averaging times (e.g., 90 days). The marked difference in concentrations between missile groups could suggest an external source rather than originating from the missile itself, though data is insufficient to prove this.
  • For benzene, acceptable exposure limits or guidelines have been established by various organizations, including occupational limits (ACGIH TLV, NIOSH REL, OSHA PEL), spacecraft limits (NASA SMAC), and submarine limits (NRC EEGL). A table provides specific exposure levels (ppm) for benzene from these organizations. The second NRC report on EEGLs and CEGLs includes benzene.
  • For DBNP (2,6-Di-tert-butyl-4-nitrophenol), due to a lack of available data, a NRC committee was unable to recommend exposure guidance levels. Research is needed to allow the derivation of these levels.
  • The second NRC report also covers Freon 12, Freon 114, hydrogen, 2190 oil mist, ozone, surface lead, toluene, and xylene. Xylene is usually found as a mixture of three isomers, with m-xylene predominating, and the term 'xylene' generally refers to this mixture. Small amounts of benzene and ethyl benzene may be present in technical xylene formulations but are not considered in that report. Reported concentrations of a "xylene isomer" were found in fan rooms, galleys, and engine rooms on submarines.
  • The third NRC report covers acetaldehyde, hydrogen chloride, hydrogen fluoride, hydrogen sulfide, and propylene glycol dinitrate.
  • A letter details the implementation of a confined space entry program for missile operations ashore and afloat, prompted by potential hazard findings related to benzene and carbon monoxide gas concentrations. It mentions a Special Weapons Test onboard USS Rhode Island (SSBN 740) where benzene and carbon monoxide levels in D5 missiles exceeded OSHA-specified safe limits. Near-term mitigation measures are directed to address these potential hazards, including testing confined spaces prior to personnel entry and measurement of carbon monoxide, oxygen, and potentially benzene using specific detectors. Ventilation equipment is authorized for use within the missile and loading tube environments. Mitigation procedures are being developed.

Hearing Loss and Tinnitus

  • Studies analyze hearing loss and tinnitus in Navy personnel, drawing on medical records (specifically audiograms from the Defense Occupational and Environmental Health Readiness System - DOEHRS) and information on duty stations. Audiograms corresponding to active duty Navy enlisted and officer personnel from 1979 to 2004 were studied. This data allows analysis of the impact of time spent on different ship types versus shore duty stations on the probability of reduced hearing function.
  • A report summarizes evidence regarding military service and noise-induced hearing loss and tinnitus. It reviews mechanisms of noise-induced hearing loss, evidence on risk factors, noise hazards associated with military service, and the association of tinnitus with noise exposure and hearing loss.
  • It is recommended that audiograms be required at the completion of military service to ensure documentation of any hearing loss or tinnitus arising during service. The Department of Defense and Department of Veterans Affairs should explore using VA system resources for audiometric tests and tinnitus assessments for personnel completing service.
  • Public Law 107-330 (Dec 6, 2002) mandated a report from the National Academy of Sciences on activities under an agreement related to hearing loss and tinnitus. It also required the Secretary of Veterans Affairs to report on disability compensation and health care claims for hearing loss or tinnitus, including the number of decisions and awards.
  • The Duty MOS Noise Exposure Listing is relevant for determining service connection for hearing loss and tinnitus claims, especially if there is no documented evidence of an in-service event. If the duty position is listed as having "Highly Probable" or "Moderate" exposure to hazardous noise, this exposure can be conceded for establishing the in-service event. If sufficient evidence of a current disability and in-service exposure exists, the VA will order an examination to determine the probability of exposure related to the disability. Evidence of current hearing loss/tinnitus in service, or records documenting an event, injury, disease, or symptoms potentially related to an audiological disability are needed.
  • The Nexus Letter is described as important for service-connected disability claims with the Department of Veterans Affairs. A proper Nexus letter should be brief, supported by facts and service records, and include a statement from a medical professional linking the claimed condition to service with a degree of likelihood ("at least as likely as not," "more likely than not," "highly likely"). The author must provide credentials to add probative value to the letter.

Occupational Hygiene Studies (Oberon Class Submarines)

  • A retrospective occupational hygiene survey of Australian Oberon class submariners (in service 1967-2000) was conducted to create a hazard exposure profile. Systematic occupational hygiene and health studies of Oberon class or diesel electric submarines are noted as rare, with poor quality of exposure information.
  • The approach involved a literature review, a tour of a decommissioned submarine, and focus groups with experienced submariners. Hazards identified in the literature review are listed. Estimated exposures and risk of harm are based on available literature, existing Defence Science and Technology Organisation (DSTO) reports, professional judgment, focus group information, and observation. Tables detail the exposure profiles and level of evidence for identified hazards.
  • Hazards reviewed include diesel exhaust particles, diesel fuel/vapour, refrigerants, and air-independent propulsion. Specific substances like benzene, toluene, xylene, hexane, and naphthalene were reviewed for health effects. Concerns were raised about the lack of published occupational health data for pollutants in the Australian submarine environment, particularly for Oberon Class, and that monitoring results often did not conform to standard occupational hygiene practices for assessing exposure.
  • Discussion also included potential hazards like mercuric oxide spills from batteries, biological contamination of water supplies, lead levels in water tanks, and hazards identified in standard operating procedures such as less than atmospheric pressure, reduced oxygen content, and the possibility of hydrogen explosion. Fire is also a hazard that releases atmospheric contaminants. The consequences of exposure to some identified hazards may have long-term effects like hearing loss from noise or potential cognitive issues from chemical contaminants. Workplace-induced body odour and photosensitivity were also raised.
  • Different approaches to setting exposure limits were discussed, including those from the UK (Maximum Permissible Concentrations - MPCs) and the US (NRC EEGLs/CEGLs, ACGIH TLVs). The definition of MPC90 for continuous exposure for 90 days is provided.
  • Studies on oxygen (O2) and carbon dioxide (CO2) concentrations were reviewed, noting effects at certain levels. The difficulty of defining acceptable levels for the hundreds of hydrocarbons identified in submarine atmospheres was highlighted, noting that civilian exposure levels might result in adverse effects under continuous exposure.
  • Specific data points mentioned include benzene concentrations measured on nuclear and Oberon class submarines. The possibility of higher benzene exposure when hydrocarbon solvents like white spirit are used for cleaning was noted. The review also discusses diesel emissions, challenges in measuring them accurately, and differing approaches to setting exposure levels by international bodies.
  • Recommendations include that the Department of Veterans' Affairs note the exposure profile to assist in compensation claims for submariners and that Defence make relevant documents available for review. Further systematic occupational hygiene studies are suggested for Collins Class submarines.

General Toxic Exposure Screening

Information about a military toxic exposure screening is available through additional resources from Military Exposures—Public Health.

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