Item M27
BOARD OF COUNTY COMMISSIONERS
AGENDA ITEM SUMMARY
Meeting Date: March 18. 2009
Division: BOCC District 1
Bulk Item: Yes ....x...-
No
Department: Commissioner Wigington
Staff Contact Person/Phone # Wilma Corbin 305-292-3440
AGENDA ITEM WORDING: Approval of a resolution by the Board of County Commissioners
of Monroe County to the Command of Naval Air Station Key West at Boca Chica, to
immediately cease and desist the flying of the F/A 18 generation aircraft until such time that The
Naval Audit Report, Consideration of Hazardous Noise in the Acquisition of the F/A-18 E/F
Super Hornet and EA-18G Growler Strike Fighter Variants has been completed by he Naval
Audit Service, until approval of the findings of The Naval Interim Audit Report, Consideration
of Hazardous Noise in the Acquisition of the F/A-18 E/F Super Hornet and EA-18G Growler
Strike Fighter Variants, October 2008 by the BOCC, and NAS Key West provides the Monroe
County BOCC with a valid Environmental Impact Statement directly associated with the flying
of F18 Super Hornet closely proximate to, adjacent, or over existing Monroe County homes.
ITEM BACKGROUND: The Naval Interim Audit Report, Consideration of Hazardous Noise
in the Acquisition of the F/A-18 ElF Super Hornet and EA-18G Growler Strike Fighter Variants,
October 2008. Department of Defense Inspector General Case #105900 - Inquiry regarding the
Environmental Assessment for the Introduction of the FA-18 E/F Super Hornet to Naval Air
Station Key West.
PREVIOUS RELEVANT BOCC ACTION: December 7, 2007 - BOCC requested the
installation of professional noise monitors with the affected areas of Monroe County
CONTRACT/AGREEMENT CHANGES:
STAFF RECOMMENDATIONS:
TOTAL COST:
N/A
INDIRECT COST: _N/A_BUDGETED: Yes _No
COST TO COUNTY:
N/A
SOURCE OF FUNDS:
REVENUE PRODUCING: Yes
No
AMOUNT PER MONTH_ Year
APPROVED BY: County Arty _ OMB/Purchasing _ Risk Management _
DOCUMENTATION:
Included x
Not Required_
AGENDA ITEM # mJ-]
DISPOSITION:
Revised 1/09
RESOLUTION NO.
. 2009
A RESOLUTION OF THE BOARD OF COUNTY COMMISSIONERS
OF MONROE COUNTY, FLORIDA,
TO THE COMMAND OF NAVAL AIR STATION KEY WEST AT BOCA CHICA
TO CEASE AND DESIST
THE FLYING OF FA-IS GENERATION AIRCRAFT
WHEREAS, The Naval Air Station of Key West at Boca Chica, Key West, Florida and the Board
of Monroe County Commissioners make numerous decisions that directly and indirectly affect the
safety, health, quality of life of the residents and property owners of those in close proximity to the
Naval Air Station; and
WHEREAS, an alliance of homeowners groups, neighborhood associations, and individual citizens
from Stock Island, Big Coppitt Key, and Geiger Key representing over 3 thousand property owners
who live in areas adjacent to or in close proximity to Naval Air Station Key West have joined together
to petition their government for redress of grievances and requesting relief forced injurious
circumstances and usurpation of rights and functions, resulting from manifold daily f1yovers from
military jet aircraft emitting dangerously high decibel levels of noise; and
WHEREAS, an October 31, 2008 Interim Audit Report, Consideration of Hazardous Noise in the
Acquisition of the F/A-18 ElF Super Hornet and EA-18G Growler Strike Fighter Variants, by the
Naval Audit Service found failure to comply with standards for mitigating for health and safety hazards
regarding the F/A-18 Super Hornet Noise, and an ongoing investigationiinquiry by the Department of
Defense Inspector General Case # 105900 may reflect further endangering the health and safety of
affected citizens; now therefore
BE IT RESOLVED BY THE BOARD OF COUNTY COMMISSIONERS OF MONROE
COUNTY, FLORIDA THAT:
1. The Board of County Commissioners of Monroe County (BOCC) requires the Command of
Naval Air Station Key West at Boca Chic a, to immediately cease and desist the flYing of the FIA
18 generation aircraft over developed commercial and residential properties until such time that:
a) The Naval Audit Service finalizes the Naval Audit Report, Consideration of Hazardous
Noise in the Acquisition of the F/A-18 ElF Super Hornet and EA-18G Growler Strike
Fighter Variants; and
b) The BOCC approves the findings of the final Naval Audit Report, Consideration of
Hazardous Noise in the Acquisition of the F/A-18 ElF Super Hornet and EA-18G
Growler Strike Fighter Variants; and
c) NAS Key West provides the Monroe County BOCC with a valid Environmental Impact
Statement directly associated with the flying of FIB Super Hornet adjacent to, in close
proximity to or over existing Monroe County homes.
Res re Navy Fly-overs
2. The Clerk shall send a copy of this resolution to: Captain Steve Holmes, Commanding
Officer, NAS Key West, and Naval Audit Service, Attn: Audit Requests, 1006 Beatty Place SE,
Washington Navy Yard DC 20374-5005.
PASSED AND ADOPTED by the Board of County Commissioners of Monroe County, Florida,
at a regular meeting of the Board held on the 18th day of March, 2009.
Mayor George Neugent
Mayor Pro Tem Sylvia Murphy
Commisioner Heather Carruthers
Commissioner Mario Di Gennaro
Commissioner Kim Wigington
Attest: DANNY L. KOLHAGE, CLERK BOARD OF COUNTY COMMISSIONERS
OF MONROE COUNTY, FLORIDA
By: By:
Deputy Clerk Mayor
Res re Navy FJy-overs 2
Inside the Navy - 1/12/2009 -
Service seeks to quiet F/A-18E/F, EA-18G
NAVY IGNORED REQUIREMENT TO CUT HAZARDOUS NOISE IN JET DESIGNS
The Navy's F/A-18E/F Super Hornet fighters and new EA-18G Growlers
built to fly electronic warfare missions emit very loud noise that is
hazardous to sailors' hearing, but the problem might have been less
severe had the service not ignored requirements to design quieter
jets, according to an internal naval audit.
Navy, Marine Corps and Air Force high-performance jets produce 130 to
150 decibels of noise, well above the 84 decibel level deemed
hazardous to hearing. The F/A-18E/F and EA-18G emit as much as 150
decibels. Jet maintainers' earplugs and earmuffs only provide limited
protection against such noise. When developing new aircraft, the
military is required to try to mitigate the problem through better
design.
But the previously undisclosed report reveals Navy officials tasked
with acquiring the Super Hornet and the Growler -- which are based on
a common Boeing design with GE engines -- ignored requirements to
actively address the hazardous noise problem early on. The ears of
countless sailors on carrier flight decks could be suffering the
consequences, according to the Naval Audit Service's Oct. 31, 2008,
interim report. Sister publication Inside the Pentagon obtained a copy
through the Freedom of Information Act.
The F/A-18E/F, which was developed in the 1990s, achieved initial
operational capability in 2001. By 2002, the Navy committed to
creating a Super Hornet variant, later dubbed the EA-18G, to replace
aging EA-6B Prowler electronic warfare planes. The Navy's online "fact
file" about the F/A-18 E/F trumpets the Super Hornet acquisition
program as "an unparalleled success." But auditors found that was not
the case when it came to the hazardous noise problem.
Super Hornet program officials at Naval Air Systems Command in
Patuxent River, MD, made no initial attempts to mitigate the flight-
line/deck jet noise hazard through design selection, the report says.
This defied a key military standard and the Navy's own system safety
program plan for the aircraft. Both documents include a "system safety
design order of precedence" urging the elimination of hazards through
better designs.
Auditors found there was no mention of noise limitations in the F/
A-18E/F and EA-18G acquisition strategy and contract statement of
work. The Navy also ignored guidance relating to risk levels and risk
acceptance authority levels and failed to track the noise hazard and
its residual mishap risk, the report says.
"These conditions may contribute to a hazardous environment of high
noise exposure associated with jet aircraft that, according to the
Naval Safety Center, increases the likelihood of permanent hearing
loss to sailors and Marines," the report states. Hearing loss is
costly for warfighters but also for the Navy at large, which faces
lost time and lower productivity, loss of qualified workers, military
disability settlements, retraining and medical bills.
Super Hornet and Growler program officials did not first try to
mitigate the noise hazard through design selection because they lacked
internal controls to ensure compliance with the system safety design
order of precedence, the report says. The program did not pursue
minimizing noise generated by the F/A-18E/F engines through design
because warfare sponsors did not identify noise requirements as key
performance parameters (KPPs) in the operational requirements document
(ORD), according to the report.
Program officials also told auditors that the emphasis on reducing
current personnel noise exposures did not exist at the time the ORD
was issued, and therefore, funding was not allocated to mitigate the
noise hazard. Further, program officials "stated that noise was always
part of the ship and aircraft environment and no viable technologies
were available at the time the engines were designed," the report
says.
Test results indicate that new high-tech hearing protection devices
will reduce noise exposure on the flight deck by at least 43 decibels,
but that is not enough, the report says. The resulting noise will
still exceed the level considered hazardous to hearing, auditors found
after consulting a professional audiologist.
But the Navy is now focusing more attention on the challenge of
quieting Super Hornets and Growlers. In a statement released to ITP
through a spokeswoman, Capt. Mark Darrah, the Navy's F/A-18 and EA-18G
program officer, said his office is committed to reducing the noise
levels.
"Our top priorities include the health and safety of our aircrews and
maintenance personnel as well as the environmental impact on the
surrounding communities," Darrah said.
Because of this, Darrah's office has formed a joint government and
industry team to research all proposed options for noise level
reduction. Current research indicates that placing chevrons on
variable exhaust nozzle seals of the F414 engine is the most viable
option for reducing noise levels, he said. Darrah's office and the
Office of Naval Research have jointly committed almost $6 million to
complete engineering and manufacturing development for this project.
"A contract is in place with General Electric Aircraft Engines on this
project and work is expected to begin shortly," he said. "While we
will continue to examine other options and technologies as they
mature, the solutions we put in place must be deployable and
affordable without degrading aircraft performance."
Boeing spokesman Philip Carder said the company is "consistently
looking for new and innovative technologies that can reduce the effect
of its operations, products and services on the environment" and that
noise reduction is a key part of that effort. Boeing is on Darrah's
government/industry team, he said.
GE Aviation spokesman Gregory Haas said a full scale test to
demonstrate and validate mechanical chevrons for noise reduction was
conducted by GE and the Navy on an F404 static engine. Test results
indicated the potential for 2.5-3.0 decibel noise reduction, roughly
equivalent to a 50 percent cut in noise energy level, he said.
Industry is continuing to work with the Navy to design, test, and
field mechanical chevrons for the F414 engine, he added.
The report says the Navy agreed to establish a formal process to
actively seek new, and document prior, ongoing and future efforts to
identify potential design solutions to fix identified hazards, and
pursue additional ways -- whether in design, devices, or other methods
-- to quiet Super Hornets and Growlers. The Navy also agreed to track
the noise hazard. But Navy officials are still sorting out how to
address a recommendation to re-establish risk levels and risk
acceptance authority levels in policies and procedures.
FOR OFFICIAL USE ONLY
Consideration of Hazardous
Noise in the Acquisition of the
F/A-18E/F Super Hornet and
EA-18G Growler Strike Fighter
Variants
~ ~~:~~::~ =:::=::<<~:8:;:: ~:;:=:RlleF tile ~
Releasable outside the Department of the Navy
only on approval of the Auditor General of the Navy
N2009-0008
31 October 2008
FOR OFFICIAL USE ONLY
Obtaining Providing Suggestions
Additional Copies for Future Audits
To obtain additional copies of this report,
please use the following contact information:
To suggest ideas for or to request future audits,
please use the following contact information:
Phone:
Fax:
E-mail:
Mail :
(202) 433-5757
(202) 433-5921
NA V AUDSVC.FOIA@navy.mil
Naval Audit Service
Attn: FOIA
1006 Beatty Place SE
Washington Navy Yard DC 20374-5005
Phone:
Fax:
E-mail:
Mail:
(202) 433-5840 (DSN 288)
(202) 433-5921
NA V AUDSVC.AuditPlan@navy.mil
Naval Audit Service
Attn: Audit Requests
1006 Beatty Place SE
Washington Navy Yard DC 20374-5005
Naval Audit Service Web Site
To find out more about the Naval Audit Service, including general background, and guidance on what
clients can expect when they become involved in research or an audit, visit our Web site at:
htto :/Isecnavoortal. d on ha. navv. mi I/navalaud itse rvi ces
DEPARTMENT OF THE NAVY
NAVAL AUDIT SERVICE
1006 BEATTY PLACE SE
WASHINGTON NAVY YARD. DC 20374-5005
7510
N2007-NIAOOO-0066.003
31 Oct 08
MEMORANDUM FOR ASSISTANT SECRETARY OF THE NAVY (RESEARCH,
DEVELOPMENT AND ACQUISITION)
THE F/A-18 STRIKE FIGHTER PROGRAM OFFICE
(PROGRAM MANAGER AIR 265 (PMA265))
Subj: CONSIDERATION OF HAZARDOUS NOISE IN THE ACQUISITION OF
THE F/A-18E/F SUPER HORNET AND EA-18G GROWLER STRIKE
FIGHTER VARIANTS (FINAL INTERIM AUDIT REPORT N2009-0008)
Ref: (a) NA V AUDSVC Memorandum 7510 N2007-NIAOOO-0066, dated 10 Aug 07
(b) SECNA VINST 7510.7F, "Department of the Navy Internal Audit"
Encl. (1) Status of Recommendations
(2) Scope and Methodology
(3) Pertinent Guidance
(4) Center for Naval Analyses Veterans Hearing Loss Disability Costs
(5) Hearing Protection Suite
(6) Program Executive Officer (Tactical Aircraft Programs) - F/A-18E/F and EA-
18G Noise Exposure Risk Acknowledgement
(7) Commander, Naval Air Forces - F/A-18E/F and EA-18G Noise Exposure Risk
Acknowledgement (NOTAL)
(8) Appendix: Management Response from PMA265
1. Introduction.
a. This interim report addresses the results of our audit for the F/A-18E/F Super
Hornet and EA-18G Growler Strike Fighter variants (F/A-18 aircraft). A senior
Department of the Navy (DON) official requested that the Naval Audit Service
(NA V AUDSVC) verify that safety and occupational health issues were addressed during
the acquisition process of the F/A-18 aircraft through efforts to mitigate the identified
noise hazard. We determined that there were opportunities to improve the mitigation of
the flight-line/deck jet noise hazard. Details on our F/A-18 audit results are presented in
Paragraph 5, "Summary of Audit Results and Conclusions."
1
Subj: CONSIDERATION OF HAZARDOUS NOISE IN THE ACQUISITION OF
THE F/A-18E/F SUPER HORNET AND EA-18G GROWLER STRIKE
FIGHTER VARIANTS (FINAL INTERIM AUDIT REPORT N2009-0008)
b. Program Manager Air 265 (PMA265) responded to the recommendations.
Summaries of the management responses, with our comments on the responses, are in
paragraph 6. The complete text of the responses is in Enclosure 8.
(i) PMA265 concurred with Recommendations 1 and 3, which are open pending
completion of agreed-to actions. Because the target completion date for
Recommendation 1 is more than 6 months in the future, we are assigning an interim
target date of 30 April 2009. Open recommendations are subject to monitoring in
accordance with reference (b). Management should provide a written status report on the
recommendations within 30 days after target completion dates.
(ii) PMA265 partially concurred with Recommendation 2; however, we do not feel
that PMA265's position meets the intent of the recommendation. Because Naval Air
Systems Command (NA V AIR) 1.6 has agreed with PMA265's position on the
recommendation, we consider Recommendation 2 to be undecided, and we are elevating
it to the Assistant Secretary of the Navy for Research, Development, and Acquisition)
(ASN RDA) for action. ASN (RDA) should respond within 30 days indicating
concurrence or nonconcurrence with the recommendation.
(iii) Please send all correspondence to the Assistant Auditor General for
Installations and Environment Audits, Mr. Ron Booth, at ronnie.booth@navy.mil (phone
(202) 433-5551), with a copy to the Director, Policy and Oversight,
Vicki. McAdams@navy.mil.
2. Objective. Our objectivel was to verify that safety and occupational health issues
were addressed during the acquisition process of the F/A-18E/F and EA-18G aircraft
through efforts to mitigate the identified noise hazard.
3. Background
a. Consideration of Safety and OccupationalHeaIth Issues. In Military Standard
882D (MIL-STD-882D), Department of Defense Standard Practice for System Safety,
dated 10 February 2000, Department of Defense (DoD) stated that, as standard practice,
environmental, safety, and occupational health (ESOH) hazard management will be
integrated into the systems engineering process for acquisition programs. According to
MIL-STD-882D, management of mishap risk associated with actual environmental and
health hazards is directly addressed by the system safety approach. The standard defines
system safety as the application of engineering and management principles, criteria, and
techniques to achieve acceptable mishap risk within the constraints of operational
1 The original objective was to verify that safety and occupational health issues are addressed during the
acquisition process of the F/A-18E/F and EA-18G aircraft. The objective was refined to specify the issue (flight-
line/deck jet noise hazard) that was assessed.
2
Subj: CONSIDERATION OF HAZARDOUS NOISE IN THE ACQUISITION OF
THE F/A-18E/F SUPER HORNET AND EA-18G GROWLER STRIKE
FIGHTER VARIANTS (FINAL INTERIM AUDIT REPORT N2009-0008)
effectiveness and suitability, time, and cost, through all phases of the system life cycle.
The objective of system safety is to achieve acceptable mishap risk through a systematic
approach of hazard analysis, risk assessment, and risk management.
b. Noise Hazard to Flight Deck Personnel. Steady-state noise is defined in
Military Handbook-1908B, dated 16 August 1999, as periodic or random variation in
atmospheric pressure at audible frequencies. Steady-state noise may be continuous,
intermittent, or fluctuating, and have a duration exceeding one second. According to
Office of the Chief of Naval Operations (OPNA VINST) 5100.23G, dated
30 December 2005, potentially hazardous noise exposure to personnel occurs in areas
where noise levels exceed 84 decibels (dBs). According to a Naval Air Warfare Center
Technical Report, "U.S. Navy Flight Deck Hearing Protection Use Trends: Survey
Results," dated 18 May 2006, legacy military aircraft, such as the F-16 and F-22, produce
about 130-150 dBs. The report stated that aircraft carrier flight deck personnel work in
close proximity to high-level aircraft engine noise for extended periods of time. It further
reported that a typical busy day for flight deck personnel is approximately 60 aircraft
launches and recoveries, and that flight deck personnel are exposed to 20-30 seconds of
maximum power aircraft noise during each aircraft launch and 3 seconds during
recovery. PMA265 representatives stated that many flight-deck personnel exceed total
daily exposure limits in approximately one launch while wearing hearing protection that
provides 30 dBs attenuation. According to Naval Safety Center representatives,
continuous exposure to these hazardous noise levels reportedly leads to hearing loss
among sailors. Furthermore, the Center for Naval Analyses reflected in their report that
from 1996 to 2005 total Navy and Marine Corps veterans' disability costs associated with
hearing loss from various exposures have steadily increased. The cost in 2005 was
approximately $200.7 million (see Enclosure 4) for DON.2
c. The F/A-18E/F Super Hornet and EA-18G Growler Strike Fighter Variants.
According to the F/A-18E/F and EA-18G Programmatic Environment, Safety, and
Occupational Health Evaluation (PESHE)/ dated March 2007, the F/A-18E (single
seat)/F/A-18F (dual seat) variant is the third variant to the F/A-18 aircraft, managed by
NA V AIR, PMA265. It is a high-performance, twin engine, mid-wing, multi-mission,
tactical aircraft designed to replace the F/A-18C (single seat), F/A-18D (dual seat), A-6E,
and F-14 aircraft. The F/A-18E/F variant is fielded and in the Operations and Support
(O&S) phase of the acquisition cycle. According to DoD Instruction (DoDI) 5000.2,
2 Of the approximately $772 million in veteran hearing loss disability costs in 2005, the breakdown between the
Services was approximately 61.5 percent Army, 18 percent Navy, 12.5 percent Air Force, and 8 percent
Marine Corps.
3 The document has three objectives: (1) to summarize the current status of the ESOH program, actions, and
initiatives being undertaken by the F/A-18E/F and EA-18G Programs; (2) to formally identify ESOH issues that
require near-term resolutions; and (3) to provide a roadmap for embedding ESOH into the program throughout
its life cycle. According to SECNA VIST 5000.2C, the PESHE should include ESOH risks, a strategy for
integrating responsibilities, a method for tracking progress, and a schedule for National Environmental Policy Act
(NEPA) compliance.
3
Subj: CONSIDERATION OF HAZARDOUS NOISE IN THE ACQUISITION OF
THE F/A-18E/F SUPER HORNET AND EA-18G GROWLER STRIKE
FIGHTER VARIANTS (FINAL INTERIM AUDIT REPORT N2009-0008)
dated 12 May 2003, the objective of the O&S phase is to execute a support program that
meets operation support performance requirements and sustains the system in the most
cost-effective manner over its total life cycle. This is the last phase of the acquisition
cycle and will terminate with system disposal at the end of the useful life.
d. According to the PESHE, the EA-18G variant will be the fourth major variant of
the F/A-18 aircraft and will serve as the Navy's replacement for the aging fleet of
carrier-based EA-6Bs. The EA-18G platform is a modified version of the F/A-18F
platform equipped with weapon system upgrades and is being acquired through the Spiral
Development acquisition process. According to DoDI 5000.2, Spiral Development
occurs when a desired capability is identified, but the end-state requirements are not
known at program initiation. According to the F/A-18 PESHE, the EA-18G Program is
currently in Low-Rate Initial Production (LRIP) (Production and Deployment
Acquisition Phase), which is beyond System Design and Demonstration (SDD) phase.
DoDI 5000.2 states that LRIP should result in adequate and efficient manufacturing
capability to produce the minimum quantity of units necessary for Initial Operational Test
and Evaluation (lOT &E). Upon successful completion of operational testing, the next
phase of the acquisition cycle will be full-rate production.
e. Meetings. We briefed our audit results to PMA265 management on 11 June 2008.
In addition, we briefed our audit results to the following customers/stakeholders:
· Deputy Assistant Secretary of the Navy (DASN) for Research, Development and
Acquisition (RDA) for Air Programs representatives - 19 March 2008;
· DASN for Safety (DASN(S)) - 8 May 2008;
· Director Air Warfare (N88) representatives - 25 March 2008;
· Fleet representatives from Fleet Forces Command, U.S. Pacific Fleet, Naval Air
Forces Safety, and Commander, Naval Air Forces - 9 April 2008; and
· Naval Safety Center representatives - 9 April 2008.
f. We provided a discussion draft to PMA265 representatives on 16 July 2008 and
received comments on 24 July 2008. There were no significant problems that needed to
be addressed during the audit.
4. Noteworthy Accomplishment. PMA265 was involved in the efforts of other
organizations (Office of Naval Research (ONR) and various universities) to identify
and/or develop design solutions to the jet noise hazard. Specifically, PMA265 provided
direct support in the form of aircraft, fuel, and personnel to conduct F/ A-18E/F aircraft
flyover noise footprints, which were used to establish a baseline for noise exposures.
According to PMA265 representatives, if future modifications are made, PMA265 will be
4
Subj: CONSIDERATION OF HAZARDOUS NOISE IN THE ACQUISITION OF
THE F/A-18E/F SUPER HORNET AND EA-18G GROWLER STRIKE
FIGHTER VARIANTS (FINAL INTERIM AUDIT REPORT N2009-0008)
able to accurately measure the reduction in noise levels. Based on documentation
reviewed, PMA265 provided two F/A-18C/D engines (F404-400 engine) to ONR in 2004
for testing of potential design solution noise mitigation initiatives. PMA265 also
requested funding in Fiscal Year (FY) 2008 through the Rapid Technology Transition
(R TT) Program, sponsored by ONR, to demonstrate and validate noise reduction
technology specific to the F/A-18 E/F and E/A-18G engine. According to PMA265
representatives, ONR has approved this request and, once PMA265 obtains confirmation
from N88 and end-user operational commanders through Memoranda of Agreement
(MOA), funding will become available in FY 2009.
5. Summary of Audit Results and Conclusions
a. According to PMA265 representatives, the F/A-18E/F aircraft emits, and the
EA-18G will emit, a maximum of 150 dBs, which is well above the noise level
considered hazardous to hearing (greater than 84 dBs). According to PMA265, they
made no initial attempts to mitigate the flight-line/deck jet noise hazard through design
selection. This is contrary to the system safety design order of precedence specified in
the MIL-STD-882D. Test results indicate that new technology hearing protection devices
will reduce noise exposure on the flight deck by at least 43 dBs; however, this is still
above the level considered hazardous to hearing. A professional audiologist further
validated that a hazard will continue to exist even with the improved hearing protection.
We also found that PMA265:
· Appropriately maintained a Risk Assessment Code (RAC) of
"Serious-Undesirable" associated with the flight-line/deck jet noise hazard;
however, they established risk levels (Risk Assessment Matrix) and risk
acceptance authority levels that did not comply with required guidance; and
· Did not maintain a current log of mitigation efforts associated with the
flight-line/deck jet noise hazard.
b. System Safety Design Order of Precedence. To determine ifPMA265 followed
the system safety design order of precedence requirements, as outlined in Table A, we
conducted meetings with PMA265 ESOH representatives, and obtained and reviewed the
following documentation:
· F/A-18E/F and EA-18G Operation Requirements Document (ORD) to determine
if jet noise was identified as a specific concern area or contained noise threshold
requirements as Key Performance Parameters (KPPs);
· The F/A-18E/F and EA-18G Acquisition Strategy;
· The F/A-18E/F and EA-18G Contract Statement of Work;
5
Subj: CONSIDERATION OF HAZARDOUS NOISE IN THE ACQUISITION OF
THE F/A-18E/F SUPER HORNET AND EA-18G GROWLER STRIKE
FIGHTER VARIANTS (FINAL INTERIM AUDIT REPORT N2009-0008)
· ONR jet noise reduction briefings, itineraries, results, and reports of noise
mitigation studies to determine PMA265's involvement in these ONR efforts; and
· E-mail correspondence to and from PMA265 representatives regarding jet noise
efforts during the design and development of the aircraft.
c. Based on our review of the above documentation and discussions with PMA265
representatives, we found that PMA265 did not follow the system safety design order of
precedence for mitigating the flight-line/deck jet noise hazard, as required by
MIL-STD-882D, Section 4.4; and F/A-18's own System Safety Program Plan,
Section 1.4 and 3.2.2. We also found that there was no mention of noise limitations in
the F/A-18E/F and EA-18G acquisition strategy and contract Statement of Work.
PMA265 provided an e-mail verifying that they did not initially attempt to mitigate the
flight-line/deck jet noise hazard through design selection, nor another method, during the
design and development of the F/A-18E/F and EA-18G aircraft. Table A lists each
criterion and its requirements.
6
Subj: CONSIDERATION OF HAZARDOUS NOISE IN THE ACQUISITION OF
THE F/A-18E/F SUPER HORNET AND EA-18G GROWLER STRIKE
FIGHTER VARIANTS (FINAL INTERIM AUDIT REPORT N2009-0008)
Table A: System Safety Design Order of Precedence - Required Guidance
Criteria Requirements
MIL-STD-
882D, Section
4.4
F/A-18E/F
Engineering
Manufacturing
Development
System Safety
Program Plan,
Sections 1.4
and 3.2.2.
Mishap risk mitigation is an iterative process that culminates when the residual mishap
risk has been reduced to a level acceptable to the appropriate authority. The system
safety design order of precedence for mitigating identified hazards is:
1. Eliminate hazards through design selection: If unable to eliminate an identified
hazard, reduce the associated mishap risk to an acceptable level through design
selection.
2. Incorporate safety devices: If unable to eliminate the hazard through design
selection, reduce the mishap risk to an acceptable level using protective safety
features or devices.
3. Provide warning devices: If safety devices do not adequately lower the mishap risk
of the hazard, include a detection and warning system to alert personnel to the
particular hazard.
4. Develop procedures and training: Where it is impractical to eliminate hazards
through design selection or to reduce the associated risk to an acceptable level with
safety and warning devices, incorporate special procedures and training.
Procedures may include the use of personal protective equipment.
Management understands that safety considerations are critical and that hazards should
be identified and controlled during the design phase rather than "reacted to" following
accidents.
The following precedence applies when corrective action is required to control a hazard
to an acceptable level of risk:
a. Design for Minimum Risk - Design to eliminate hazards. The maximum effort
consistent with contractual requirements will be made to ensure the optimum
degree of safety by selecting appropriate design features and qualified components.
b. Incorporate Safety Devices - Safety devices will be used when known hazards
cannot be eliminated by design.
c. Provide Warning Devices - Warning devices will be used in those instances when
it is not possible to eliminate or adequately control the risk of a known hazard
through design selection or safety devices.
d. Procedures and Training - Special operating and emergency procedures will be
recommended when it is not possible to control an identified hazard by design
selection, or by the use of safety and warning devices. Navy concurrence is
required whenever procedures are used to control a known Catastrophic or Critical
hazard to an acceptable level of risk.
7
Subj: CONSIDERATION OF HAZARDOUS NOISE IN THE ACQUISITION OF
THE F/A-18E/F SUPER HORNET AND EA-18G GROWLER STRIKE
FIGHTER VARIANTS (FINAL INTERIM AUDIT REPORT N2009-0008)
d. PMA265 did not first attempt to mitigate the maintainer noise hazard through
design selection because they lacked internal controls to ensure compliance with the
system safety design order of precedence. PMA265 representatives stated that they did
not pursue minimizing noise generated by the F/A-18E/F engines through design because
warfare sponsors (Commander, Naval Air Forces representatives) did not identify noise
requirements as KPPs within the Operational Requirements Document (ORD). They also
stated that the emphasis on reducing current personnel noise exposures did not exist at the
time the ORD was issued, and therefore, funding was not allocated to mitigate the
flight-line/deck jet noise hazard. We verified that noise requirements were not identified
as KPPs within the ORD. PMA265 representatives also stated that noise was always part
of the ship and aircraft environment and no viable technologies were available at the time
the engines were designed.
e. Because PMA265 did not mitigate the identified flight-line/deck jet noise hazard
in accordance with the system safety design order of precedence, the aircraft noise hazard
may not be mitigated to its lowest level. This could result in sailor and Marine exposure
to higher levels of noise. According to OPNA VINST 5100.230, Chapter 18, Section
1801, Paragraph (a), dated 30 December 2005, hearing loss has been, and continues to be,
a source of concern within the Navy. OPNA VINST 5100.230 further states that
occupational hearing loss resulting from exposure to hazardous noise, the high cost of
related compensation claims, and the resulting drop in productivity and efficiency
highlight a significant problem that requires considerable attention.
f. Although PMA265 verified that they did not mitigate the F/A-18E/F and
EA-180 flight-line/deck jet noise hazard through design selection in the design and
development phases, PMA265 has since sought design solutions, as noted in the
Noteworthy Accomplishment. PMA265 representatives stated that if solutions and/or
noise reductions to the jet noise hazard are recognized, ideally engine modifications
would be implemented as part of the normal life-cycle engine maintenance process.
g. Assignment of Risk Assessment Code (RAC). We conducted meetings with
PMA265 ESOH representatives. These meetings were held to determine if PMA265
assigned a RAC associated with the identified flight-line/deck jet noise hazard, and
maintained an appropriate process for evaluating the RAC in accordance with required
guidance. Additionally, we obtained and reviewed the following documentation:
· F/A-18E/F PESHE (According to SECNA VIST 5000.2C, dated
19 November 2004, the PESHE should include ESOH risks);
· Test result documentation for improved hearing protection;
· PEO (Tactical Aircraft Programs) Risk Acceptance Memorandum;
8
Subj: CONSIDERATION OF HAZARDOUS NOISE IN THE ACQUISITION OF
THE F/A-18E/F SUPER HORNET AND EA-18G GROWLER STRIKE
FIGHTER VARIANTS (FINAL INTERIM AUDIT REPORT N2009-0008)
· PEO (Tactical Aircraft Programs) Risk Acknowledgement Memorandum; and
· Commander Naval Air Forces Risk Acknowledgement Memorandum.
h. We found that PMA265 formally assigned a RAC for the flight-line/deck jet noise
hazard within their PESHE, dated March 2007, and appropriately maintained the
associated RAC as described below. The initial RAC for the flight-line/deck jet noise
hazard was assessed as "Critical" and "Likely" (classified as "Serious-Undesirable") (see
Table B). According to PMA265, the RAC assessment methodology included
recognizing jet noise as a longstanding problem for Naval aviation. PMA265 referenced
in their PESHE ongoing jet design and improved hearing protection noise reduction
efforts. However, since these mitigation efforts were not yet implemented,4 the
flight-line/deck jet noise hazard properly remained in the "Serious-Undesirable"
classification. The associated residual risk was raised to the PEO level for formal
program risk acceptance/acknowledgement, in accordance with SECNA VINST 5000.2
(see Enclosure 6 for the acknowledgement). Additionally, the residual risk was formally
acknowledged by Commander, Naval Air Forces (System Command level), in a risk
acknowledgement memorandum (See Enclosure 7).5 As a result, the flight-line/deck jet
noise hazard maintained appropriate awareness and visibility for the associated RAC of
"Serious-Undesirable. "
i. Risk Levels6 and Risk Acceptance Authority Levels. To determine ifPMA265
established risk levels and risk acceptance authority levels in accordance with required
guidance, we obtained and reviewed the following documentation from PMA265:
. "Risk Assessment Matrix";
· "Management and Decision Authority Based on RAC"; and
· "Updated Draft ESOH Risk Information."
j. We found that PMA265 established risk levels that did not align with definitions
and the risk matrix highlighted in SECNA VINST 5000.2C, Enclosure 7, Table E7T2.
Specifically, PMA265's Risk Assessment Matrix contained multiple occurrences of
lower risk-level classifications. For example, PMA265's matrix contains 10
categorizations of low-risk versus the 3 outlined in SECNA VINST 5000.2C. Risk levels
are a combination of severity 7 and probability8 levels. Tables Band C illustrate the
4 Naval Aircrew Systems Command (PMA202) verified that the improved hearing protection would not be
available for fleet purchase until August 2008. PMA202 further verified that the improved hearing protection
would provide 43 dBs of noise reduction.
5 The PEO risk acknowledgement memorandum superseded the Commander, Naval Air Forces risk
acknowledgement memorandum as the official recognition of risk.
6 The Risk Assessment Matrix is made up of various risk levels.
7 An assessment of the consequences of the most reasonable credible mishap that could be caused by a
specific hazard.
8 The aggregate probability of occurrence of the individual events/hazards that might create a specific mishap.
9
Subj: CONSIDERATION OF HAZARDOUS NOISE IN THE ACQUISITION OF
THE F/A-18E/F SUPER HORNET AND EA-18G GROWLER STRIKE
FIGHTER VARIANTS (FINAL INTERIM AUDIT REPORT N2009-0008)
differences between the PMA265 risk levels and those required by
SECNA VINST 5000.2C. After presentation of our audit results, PMA265 provided an
"Updated Draft ESOH Risk Information" document, which maintains a process (risk
matrix) that still does not align with SECNA VINST 5000.2C. The ESOH Risk
Assessment Matrix is still a 5x5 (5 levels of probability and 5 levels of severity) versus
the 5x4 (5 levels of probability and 4 levels of severity) referenced in
SECNA VINST 5000.2C. According to PMA265 representatives, the difference exists
because NA V AIR's Risk Management Instruction and Guide uses a 5x5 matrix to portray
program cost, schedule, and performance risks. PMA265 used a 5x5 matrix to ensure
consistency and translation of ESOH risks into the NA V AIR risk assessment process.
However, this still does not comply with SECNA VINST 5000.2C.
k. In addition, PMA265' s risk acceptance authority levels (decision authority for
residual risk) permit hazards categorized as "low" to be accepted by the Program
Manager (PM) or a designee. This does not comply with DoDI 5000.2, Section E7.1.6
and SECNA VINST 5000.2C, Enclosure 7, Section 7.3, which state that risk acceptance
authority may not be delegated below the PM. While PMA265 used an appropriate
acceptance authority for the flight-line/deck jet noise hazard, the established risk
acceptance authority levels provide the potential for the acceptance of risk below the PM
level. The following tables illustrate the differences between PMA265' s risk acceptance
authority levels and those reflected in SECNA VINST 5000.2C:
10
Subj: CONSIDERATION OF HAZARDOUS NOISE IN THE ACQUISITION OF
THE F/A-18E/F SUPER HORNET AND EA-18G GROWLER STRIKE
FIGHTER VARIANTS (FINAL INTERIM AUDIT REPORT N2009-0008)
TABLE B: F / A-I8 Program Office (PMA265) Risk Assessment Matrix
Consequence
Likelihood
Near Certainty (E)
Highly Likely (D)
Likely (C)
Low Likelihood (8)
Not Likely (A)
Decision Authori For Residual Risk
Component Acquisition Executive (ASN (RDA))
Program Executive Officer
PMA265 PM or F/A-18E/F and EA-18G PM
F/ A-18E/F and EA-18G PM or designee
F/A-18E/F and EA-18G PM or designee
*Note: Blue circle indicates the risk category and the black arrow indicates the risk acceptance level for the noise hazard.
TABLE C: SECNA VINST 5000.2C ESOH Risk Levels (Risk Matrix)
Improbable (E)
Serious
Medium
Critical (II)
Medium
Medium
Marginal (III)
Negligible (IV)
Program Manager
*Note: The colors were added for comparison purposes.
11
Subj: CONSIDERATION OF HAZARDOUS NOISE IN THE ACQUISITION OF
THE F/A-18E/F SUPER HORNET AND EA-18G GROWLER STRIKE
FIGHTER VARIANTS (FINAL INTERIM AUDIT REPORT N2009-0008)
1. PMA265 lacked internal controls to ensure compliance with DoDI 5000.2 and
SECNA VINST 5000.2C. After presentation of our audit results, PMA265 provided an
"Updated Draft ESOH Risk Information" document that contained revised risk
acceptance authority levels to comply with guidance (removing all reference to a
"designee").
m. Establishing risk levels that were not compliant with required guidance increases
the potential of hazards and residual risks to be assessed and classified in a manner that is
not standardized and consistent with other programs. This could limit DON leadership's
ability to properly evaluate similar ESOH risks across like programs.
n. In June 2008, PMA265 provided an "Updated Draft ESOH Risk Information"
document, which revised the risk acceptance authorities for all medium- and low-risks to
the PM level.
o. Tracking of Hazards and Residual Mishap Risk. To determine ifPMA265
tracked occupational health hazards and residual mishap risk, we reviewed the System
Safety Program Progress Report, dated 19 October 2007, that listed all Safety Action
Report hazards being tracked; however, no occupational health hazards were contained
within the report.
p. PMA265 did not track occupational health hazards and residual mishap risk in
accordance with required guidance. Specifically, PMA265 did not maintain a current log
of identified occupational health hazards, to include the flight-line/deck jet noise hazard,
and residual mishap risk throughout the system life cycle, as required by
MIL-STD-882D, Section 4.8 and A.4.4.8.1.
q. PMA265 lacked internal controls to ensure that a current log of identified
occupational health hazards and residual mishap risks were maintained. As a result of
not tracking occupational health hazards and residual mishap risk, a concise dated log of
hazard status, mitigation efforts, and their associated effectiveness is not readily available
for program management review. This may limit management's ability to efficiently
reference past efforts, associated levels of hazard severity and probability, and current
initiatives, as well as develop future goals and milestones. Basing program decisions on
incomplete and inaccurate information could lead to insufficient mitigation of noise and
other hazards, contributing to a hazardous environment to the sailor and Marine.
r. PMA265 representatives verified this weakness in an e-mail and stated that they
planned to use an existing Safety Action Report9 hazard database (which was used to
9 As stated in the F/A-18E/F System Safety Program Plan, Safety Action Reports document the official record of
opening a hazard and tracking mitigation efforts in an attempt to reduce the risk level (severity and probability) to
an acceptable level and close-out the hazard. Safety Action Report activity is to be updated at least monthly.
12
Subj: CONSIDERATION OF HAZARDOUS NOISE IN THE ACQUISITION OF
THE F/A-18E/F SUPER HORNET AND EA-18G GROWLER STRIKE
FIGHTER VARIANTS (FINAL INTERIM AUDIT REPORT N2009-0008)
track only safety hazards) to formally document and track occupational health hazards in
the future. The Safety Action Report database has the functionality to adequately meet
the requirements specified within MIL-STD-882D.
s. Summary. PMA265 maintained an appropriate process for evaluating the RAC
for the flight-line/deck jet noise hazard and identified jet noi~e as a serious risk.
However, PMA265 did not attempt to mitigate the jet noise hazard in the initial design
and development of the aircraft, did not follow required guidance relating to risk levels
and risk acceptance authority levels, and did not track the flight-line/deckjet noise hazard
and its residual mishap risk. These conditions may contribute to a hazardous
environment of high noise exposure associated with jet aircraft that, according to the
Naval Safety Center, increases the likelihood of permanent hearing loss to sailors and
Marines. According to the Naval Safety Center, in addition to the personal cost to the
sailor and Marine, the economic consequences of hearing impairment to the Navy
include: lost time and decreased productivity, loss of qualified workers through medical
disqualification, military disability settlements, retraining, and expenses related to
medical treatment. An example of Veterans hearing loss disability cost figures reported
by the Center for Naval Analyses is found in Enclosure 4. As stated in the noteworthy
accomplishment, PMA265 has pursued FY 2009 funding through the R TT Program to
demonstrate and validate noise reduction technology specific to the FIA-I8 ElF and
E/A-I8G engine.
6. Recommendations and Corrective Actions. Our recommendations, summaries of
the management responses, and our comments on the responses are below. The complete
text of the responses is in Enclosure 8.
We recommend that the FIA-I8 Program Office, PMA265:
Recommendation 1. Establish a formal process to actively seek new, and document
prior, ongoing, and future, efforts to identify potential design solutions to mitigate
identified hazards, and determine what additional mitigation efforts may be possible
(whether in design, devices, or other methods) to further reduce the noise hazard for
the FIA-I8 ElF and EA-I8G aircraft.
F/A-18 Program Office, PMA265 response to Recommendation 1. Concur.
PMA265 is actively engaged in ongoing research and development efforts for
engine noise reduction technologies. Future opportunities would also be
considered if promising. As reflected in the 5 March 2008 MFR, PMA265 will
annually assess available and viable technologies. A process to document
PMA265' s efforts and assessments will be identified in the next 6 to 9 months,
and would be implemented as part of PMA265 ' s commitment to the annual
assessment of solutions. However, PMA265 does not plan to "back track" since
13
Subj: CONSIDERATION OF HAZARDOUS NOISE IN THE ACQUISITION OF
THE F/A-18E/F SUPER HORNET AND EA-18G GROWLER STRIKE
FIGHTER VARIANTS (FINAL INTERIM AUDIT REPORT N2009-0008)
the inception of the F 414 engine and F / A -18E/F to document all past design
efforts. This could prove to be very time consuming with little return. Rather,
only the efforts of the last 2 to 3 years will be noted by PMA265. The estimated
date of completion is 31 October 2009.
Naval Audit Service comment on response to Recommendation 1.
PMA265' s planned actions meet the intent of the recommendation, which is
open pending completion of agreed-to actions. Because the target completion
date is more than 6 months in the future, we are assigning an interim target
date of 30 April 2009, and we ask that PMA265 inform us by that date of the
status of the agreed-to corrective actions.
Recommendation 2. Reestablish risk levels (Risk Assessment Matrix) and risk
acceptance authority levels in policies and procedures to ensure compliance with
DoDI 5000.2, Section E7.1.6 and SECNA VINST 5000.2C, Enclosure 7, Section 7.3.
F/A-18 Program Office, PMA265 response to Recommendation 2. Partially
concur. PMA265 has already corrected the risk acceptance authority levels for
identified ESOH hazards and their associated risks for consistency with
DoDI 5000.2 and SECNA VINST 5000.2C. While working with the NA V AIR 1.6
Environmental Programs Department, PMA265 will reevaluate over the next 3 to
4 months whether some of the risk levels currently ranked and reflected as "green"
should be changed to "yellow" for greater consistency with DoDI 5000.2 and
MIL-STD-882D. However, unless NA V AIR 1.6 changes the ESOH risk matrix
configuration in NA V AIR's PESHE Template, PMA265 will continue to use a
5x5 matrix vice the 4x5 matrix ofMIL-STD-882D. PMA265 will consult with
NA V AIR 1.6 on whether or not all of the exact ESOH risk definition terminology
of SECNA VINST 5000.2C (such as occupational health severity definitions and
probability levels of Fleet and individual systems) should be included in
NA V AIR's PESHE Template. Estimated date of completion is 28 February 2009.
Naval Audit Service comment on response to Recommendation 2.
PMA265' s planned actions only partially meet the intent of the
recommendation. The risk acceptance levels have been changed and are in
compliance with stated guidance. Therefore, upon updating internal program
policy, PMA265 has met the intent for this portion of the recommendation.
PMA265 subsequently provided an e-mail on 30 September 2008 stating that
as their PESHE for the F/A-18E/F & EA-18G is updated on an annual basis,
PMA265 will include the updated/revised Risk Acceptance Authority levels in
the next revision scheduled for completion by April 2009.
14
Subj: CONSIDERATION OF HAZARDOUS NOISE IN THE ACQUISITION OF
THE F/A-18E/F SUPER HORNET AND EA-18G GROWLER STRIKE
FIGHTER VARIANTS (FINAL INTERIM AUDIT REPORT N2009-0008)
However, the proposed actions related to the Risk Assessment Matrix do not
meet the intent of the recommendation. Specifically, PMA265 stated they
would continue to evaluate Environmental and Occupation Health hazards
using a 5x5 matrix vice the 4x5 matrix outlined within
SECNA VINST 5000.2C and MIL-STD-882D, unless NA V AIR 1.6 changes
the ESOH risk matrix configuration in NA V AIR's PESHE Template.
We plan to issue a summary report for "Consideration of Safety and
Occupational Health Issues in Acquisition of Major Department of Navy
(DON) Weapons Systems and Platforms." In that summary report, we plan to
address systemic issues, including enforcing use of a standard risk assessment
matrix to ensure programs apply a common set of rules and use standard
terminology in assessing risks. We believe standardization and consistency
across programs are essential to corporate-level evaluations of program risks.
Establishing risk levels that are not compliant with required guidance increases
the potential for the significance of hazards and residual risks to be
misunderstood. Additionally, lack of standardization could limit DON
leadership's ability to properly evaluate similar ESOH risks across like
programs. Each of the four programs reviewed for this audit utilized different
risk assessment matrices to assess the risk of hazardous noise. Accordingly, to
have a common understanding of the risks of hazardous noise across the four
programs, DON leaders would need to understand the nuances of each of the
different matrices.
A video teleconference (VTC) was conducted on 30 September 2008 with
PMA265, PEO(T), and NA V AIR 1.6 in an attempt to resolve this issue;
however, the involved parties could not come to an agreement on this matter.
During this meeting, NA V AIR 1.6 stated that "NA V AIR's PESHE Template,"
which includes a 5x5 matrix, is not official policy but rather is a tool used by
NA V AIR. NA V AIR 1.6 provided NA V AIR Instruction 5000.21B, "Naval
System Command Risk Management Policy," dated 24 January 2008 via
e-mail on 28 September 2008, which PMA265 felt supported their position.
This instruction includes a 5x5 Program Risk Matrix and a 4x5 System Safety
Risk Matrix. PMA265 explained that they assess ESOH risks with a 5x5
matrix because they feel the instruction only requires use of a 4x5 matrix for
safety risks. During the VTC, PMA265 maintained their position, and PEO(T)
and NA V AIR 1.6 supported the position, that SECNA VINST 5000.2C does
not contain specific guidance stating that ESOH hazards are to be evaluated
using a 4x5 risk assessment matrix.
We provided PMA265, PEO(T), and NA V AIR 1.6 with the details during the
VTC, and in a subsequent e-mail dated 2 October 2008, to support that a
15
Subj: CONSIDERATION OF HAZARDOUS NOISE IN THE ACQUISITION OF
THE F/A-18E/F SUPER HORNET AND EA-18G GROWLER STRIKE
FIGHTER VARIANTS (FINAL INTERIM AUDIT REPORT N2009-0008)
4x5 matrix is required. Specifically SECNA VINST 5000.2C, Section 4 states
that Enclosure 7 of this instruction should be utilized to support the Defense
Acquisition System. Enclosure 7, paragraph 7.3 states that risk acceptance
authorities shall be followed in accordance with the ESOH risk levels, as
defined in Tables E7T1 and E7T2 (derived from MIL-STD-882D).
Table E7T2 (see Table C of the finding) contains the Risk Assessment Matrix
to be used for analyzing and identifying ESOH risk levels, and outlines a
4 x5 matrix approach.
Additionally, the NA V AIR Instruction 5000.21 B provided by NA V AIR 1.6
references SECNA VINST 5000.2C and MIL-STD-882D, and further supports
our position that a 4x5 matrix be utilized for ESOH evaluation. Specifically,
Section 4a states: "MIL-STD-882 defines a system safety mishap as unplanned
event or series of events resulting in death, injury, occupational illness, damage
to or loss of equipment or property, or damage to the environment." Per this
definition, noise hazards resulting in hearing loss, which is an occupational
illness, would be considered a system safety mishap. Section 5f states, "The
management of a program's system safety process shall be in accordance with
SECNA VINST 5000.2C," which aligns with the MIL-STD-882D 4x5 risk
assessment matrix, as previously stated. Enclosure (3) of this instruction,
which "shows a tailored system safety risk matrix which meets a specific
community of systems (NA V AIR) needs," outlines a 4x5 approach for
analyzing system safety (ESOH) risks to be utilized by NA V AIR commands.
This matrix is in compliance with SECNA VINST 5000.2C and MIL-STD-
882D, and supports our position.
NA V AIR subsequently provided an e-mail on 16 October 2008 stating that the
Office of the Commander, NA V AIR understands and agrees with PMA265's
position.
Therefore, we have determined the recommendation to be undecided, and are
elevating it to ASN (RDA) for action.
Recommendation 3. Establish controls and provide oversight to ensure that the
FIA-18 ElF and EA-18G flight-line/deckjet noise hazard is formally opened in a
tracking database and that the associated residual risk, log of mitigation efforts, and
all other relevant information is tracked in a formal process with accurate record
keeping.
F/A-18 Program Office, PMA265 response to Recommendation 3. Concur.
PMA265 corrective action has been initiated in that PMA265 is evaluating the
feasibility of modifying data fields in the safety assessment report database used
16
Subj: CONSIDERATION OF HAZARDOUS NOISE IN THE ACQUISITION OF
THE F/A-18E/F SUPER HORNET AND EA-18G GROWLER STRIKE
FIGHTER VARIANTS (FINAL INTERIM AUDIT REPORT N2009-0008)
by the F/A-18E/F and EA-18G system safety engineers for hazard tracking. There
is a portion of the database that could possibly be modified to accommodate data
fields for "environmental" and "occupational health" hazards and their risks.
Configuration management of this database is maintained by the Boeing
Corporation, so PMA265 needs to evaluate what the costs would be for modifying
the database, the reasonableness of those costs, and budget accordingly for such
modifications if feasible. This evaluation will be conducted over the next 3 to
6 months. PMA265 will use, in the interim, a simple Excel spreadsheet for ESOH
risk tracking purposes. Estimated date of completion for Feasibility Assessment
of Database Modifications is 30 April 2009.
Naval Audit Service comment on response to Recommendation 3.
PMA265' s planned actions meet the intent of our recommendation, which is
for PMA265 to track ESOH hazards with accurate record keeping. While, in
our opinion, it would be most beneficial to achieve this with the use of a
database, a dedicated database is not required and tracking can be
accomplished with the use of an Excel spreadsheet as proposed by PMA265.
The recommendation is open pending completion of agreed-to actions.
PMA265 subsequently provided a target completion date of February 2009 for
implementing the interim Excel spreadsheet tracking process.
7. Other Information
a. Any requests for this report under the Freedom of Information Act must be
approved by the Auditor General of the Navy as required by reference (b). This audit
report is also subject to followup in accordance with reference (b).
b. We appreciate the cooperation and courtesies extended to our auditors.
/--;) ~,;J .2-
/'FrL->--,./;. ';t~~~
RON 1. BOOTH
Assistant Auditor General
Installations and Environment Audits
Copy to ( next page)
17
Subj: CONSIDERATION OF HAZARDOUS NOISE IN THE ACQUISITION OF
THE F/A-18E/F SUPER HORNET AND EA-18G GROWLER STRIKE
FIGHTER VARIANTS (FINAL INTERIM AUDIT REPORT N2009-0008)
Copy to:
UNSECNA V
OGC
ASSTSECNA V (MRA)
ASSTSECNA V (FMC)
ASSTSECNA V (FMC) (FMO)
ASSTSECNA V (IE)
DASN (S)
CNO (VCNO, DSN-33, N40, N41)
CMC (RFR) (ACMC)
DON CIO
NA VINSGEN (NA VIG-4)
DIRECTOR, AIR WARFARE (N88)
AF AA/DO
18
Status of Recommendations
2
Establish a formal process to actively seek new, and document
prior, ongoing, and future, efforts to identify potential design
solutions to mitigate identified hazards, and determine what
additional mitigation efforts may be possible (whether in design,
devices, or other methods) to further reduce the noise hazard
for the F/A-18 ElF and EA-18G aircraft.
Reestablish risk levels (Risk Assessment Matrix) and risk
acceptance authority levels in policies and procedures to
ensure compliance with 0001 5000.2, Section E7.1.6 and
SECNAVINST 5000.2C, Enclosure 7, Section 7.3.
Establish controls and provide oversight to ensure that the
F/A-18 ElF and EA-18G f1ight-line/deckjet noise hazard is
formally opened in a tracking database and that the associated
residual risk, log of mitigation efforts, and all other relevant
information is tracked in a formal process with accurate record
keeping.
u
ASN (ROA)
1211/08
3
o
PMA265
4/30/09
9 I 0 = Recommendation is open with agreed-to corrective actions; C = Recommendation is closed with all action
completed; U = Recommendation is undecided with resolution efforts in progress
Enclosure 1
Page 1 of 1
Scope and Methodology
On 10 August 2007, the Naval Audit Service began a broad audit of "Consideration of
Safety and Occupational Health Issues in the Acquisition of Major Department of Navy
(DON) Weapons Systems and Platforms." As of the date of this publication, that audit is
ongoing. Separate interim reports will be issued on each system audited, and a summary
report summarizing the individual system reviews and identifying systemic issues will be
issued upon completion of our audit work. We conducted this audit of the
"Consideration of Hazardous Noise in the Acquisition of the F/A-18E/F Super Hornet
and EA-18G Growler Strike Fighter Variants" between 9 January 2008 and 14 August
2008.
We evaluated internal controls and reviewed compliance with regulations related to
consideration of hazardous noise in the F/A-18E/F and EA-18G acquisition process.
Data quality was adequate for use in the audit.
We conducted site visits at Naval Air Systems Command, Patuxent River, MD, and
interviews with the F/A-18 Program Office (PMA265) Environmental, Safety, and
Occupational Health (ESOH) representatives to:
· Determine if selected F/A-18 aircraft jet noise level posed a hazard; and
· Assess PMA265' s process for mitigating the identified noise hazard.
This was further accomplished by reviewing Safety Action Record hazard reports from
the system safety hazard database; ESOH memorandums; the F/A-18 Programmatic
Environment, Safety, and Occupational Health Evaluation (PESHE); System Safety
Program Plan; the Program Progress Report; the F/A-18 Acquisition Strategy; ESOH
Statement of Work sections; the Operational Requirements Document; engine noise
mitigation studies and reports; test result documentation for improved hearing protection;
and studies related to hearing loss.
We verified that the F/A-18 noise level posed a hazard to DON sailors and Marines
through discussions with Navy Safety Center (NA VSAFCEN) ESOH representatives,
Naval Aircrew Systems Command (PMA202), and professional audiologist specialists.
We further corroborated this hazard through meetings and discussions with the end users
such as Naval Air Forces Command and Fleet Forces Command. We assessed
PMA265's process of mitigating the identified hazards associated with jet noise.
Specifically, we assessed the PMA265's mitigation efforts related to the flight-line/deck
jet noise hazard (noise exposure to flight deck operators).
Enclosure 2
Page 1 of 2
ENCLOSURE 2: SCOPE AND METHODOLOGY
We conducted this performance audit in accordance with Generally Accepted
Government Auditing Standards. Those standards require that we plan and perform the
audit to obtain sufficient, appropriate evidence to provide a reasonable basis for our
findings and conclusions based on our audit objectives. We believe that the evidence
obtained provides a reasonable basis for our findings and conclusions based on our audit
objectives.
Enclosure 2
Page 2 of 2
Pertinent Guidance
Department of Defense Instruction (DoDI) 5000.2, "Operation of the Defense
Acquisition System," dated 12 May 2003; Section E7.1.6 states that the Component
Acquisition Executive (CAE) is the acceptance authority for high Environmental, Safety,
and Occupational Health (ESOH) mishap risks identified by the program. The
Instruction adds that the Program Executive Office (PEO)-level is the authority for
serious risks, and the Program Manager (PM) is the authority for medium and low risks,
as defined in the industry standard for system safety.
Military Standard 882D (MIL-STD-882D), "Department of Defense Standard Practice
for System Safety," dated 10 February 2000, outlines a standard practice for conducting
the Department of Defense (DoD) system safety approach and managing safety and
health mishap risks in order to meet the DoD commitment to protecting private and
public personnel from accidental death, injury, or occupational illness.
· SectionAAA.5 advises a program to reduce system mishap risk through a
mitigation approach mutually agreed to by the developer, program manager, and
using organization. Section AAA.8.1.2 states that the program manager will
evaluate the hazards and associated mishap risk in close consultation and
coordination with the ultimate end user, to assure that the context of the user
requirements, potential mission capability, and the operational environment are
adequately addressed.
· Section 4.4 states that mishap risk mitigation is an iterative process that culminates
when the residual mishap risk has been reduced to a level acceptable to the
appropriate authority. The system safety design order of precedence for mitigating
identified hazards is defined in this section. See the "Required Guidance" table
(Table 1) in the System Safety Design Order of Precedence section for details.
· Section 4.8 requires a program to track hazards, their closures, and residual
mishap risk. A tracking system for this information must be maintained
throughout the system life cycle. The program manager must keep the system user
apprised of this information. Section AAA.8.1 states each system must have a
current log of identified hazards and residual mishap risk, including an assessment
of residual mishap risk. As changes are integrated into the system, this log is
updated to incorporate added or changed hazards and the associated residual
mishap risk. The Government must formally acknowledge acceptance of hazards
and residual risk and keep users informed of hazards and residual mishap risk
associated with their systems.
Enclosure 3
Page 1 of 2
ENCLOSURE 3: PERTINENT GUIDANCE
Secretary of the Navy Instruction (SECNA VINST) 5000.2C, "Implementation and
Operation of the Defense Acquisition System and the Joint Capabilities Integration and
Development System," dated 19 November 2004, Enclosure 7, Section 7.3 includes the
following risk acceptance authority levels:
. High risks: Assistant Secretary of the Navy (Research, Development, and
Acquisition) (ASN (RDA))
· Serious risks: PEO/Systems Command (SYSCOM) Commanders, or Flag-level or
senior executive service (SES) designees/Direct Reporting Program Managers
(DRPM), Chief of Naval Research (CNR); and
· Medium/low risks: Program Managers (PM). Risk acceptance authority may not
be delegated below the PM.
Chief of Naval Operations Instruction (OPNA VINST) 5100.230, "Navy Safety and
Occupational Health (SOH) Program Manual," dated 30 December 2005, Chapter 18,
Section 1801, paragraph (a) states that occupational hearing loss resulting from exposure
to hazardous noise, the high cost of related compensation claims, and the resulting drop
in productivity and efficiency, highlight a significant problem that requires considerable
attention. Noise control and hearing conservation measures contribute to operational
readiness by preserving and optimizing auditory fitness for duty in Navy personnel. The
Instruction defines a potentially hazardous noise area as any work area where the
A-weighted sound level10 (continuous or intermittent) is greater than 84 dBs.
F/A-18 E/F Engineering Manufacturing Development System Safety Program Plan,
revision B, dated 25 January 2008, Section 1.4, states that management understands that
safety considerations are critical and that hazards should be identified and controlled
during the design phase rather than "reacted to" following accidents. Section 3.2.2 states
that the safety design order of precedence referenced in MIL-STD-882D applies when
corrective action is required to control a hazard to an acceptable level of risk.
10 According to OPNA VINST 5100.23G, A-weighted sound level is designated to approximate the response of
the human ear to sound.
Enclosure 3
Page 2 of 2
Center for Naval Analyses Veterans
Hearing Loss Disability Costs
Veterans Hearing Loss Disability Costs
1996-2005
.
Millions of Dollars
2005
Army $475,565,856
Air Force $ 95,747,136
Navy $137,412,468
Marine Corps $63,282,216
480
450
420
390
360
330
300
270
240
210
180
150
120
90
60
30
96
97
98
99
OOYear 01
02
03
04
05
I.Army .Air Force .Navy .Marine Corps I
Source: Center for Naval Analyses, "Computing the Return on Noise Reduction Investments in Navy Ships: A Life-
Cycle Cost Approach," September 2006.
Enclosure 4
Page 1 of 1
Hearing Protection Suite
.
Hearing Protection Roadmap
CURRENT
NEAR-TERM
....................................,.....
Hearing protection using foam
type devices varies depending
on properly wearing both earplugs
. . . . . . . . . . . . . . . .
...............................
. . . . . . . . . . . . . . .
:111:1:1:11111:1:11:1:1:1111:::1
:a:- ,'.. ~Iif;::::."':";:~:"Jr
.. .:;,...,.....,;.. ....0;, ......:~.
.: ,:'_".__ ,,' :.:":.::-. .~ . :.:":.:":.:":.;0:.:":.:":.:'
::.:.................:{........:....<.:.:::.:::<:.:>:::<:<:{:{:.:::.::
Integrated
43 dB Mean
Attenuation
30 dB Mean
Attenuation
Improved
Eannuff
+
Custom
Molded Deep
Insert Earplug
Legacy
Eannuff
+
.; .
~
"':,
it!-
i.!
.;
.:~:.~.:~~.:~;~,-"
lj~l
:3:~i:~'i
.~:
:. wI or wlo
~ Communication
"'0"
f:.
lJ':~';~
.~~e-
..~~~,:_.~it;_.~.,_"\"~.~,...
",.<Wi', " ,
Legacy Cranial
1, Naval personnel correctly wearing both legacy Foamy Earplugs = 7%, results in 22 dB protection.
2. Naval personnel with shallow insertion or not wearing legacy Foamy Earplugs = 79%, results in 0-6 dB protection,
FUTURE
Integrated
50 dB Mean
Attenuation
Active Noise
Reduction (ANR)
+
Improved
Eannuff
+
Custom Molded
Deep Insert
Earplug
wI or wlo
Communication
;#
Source: Program Manager Air - Naval Aircrew Systems (PMA202), "Flight Deck Cranial Status Brief to the
NESB," 25 March 2008
Enclosure 5
Page 1 of 1
Program Executive 0IIicer (Tactical Aircraft
Programs) - F/A-18EIF and EA-18G Noise Exposure
Risk Acknowledgement
Il':!!\.'. ....,' ,'......
\CI
DEPARTMENT Of' iHE NI\VV
I',":..I:!-I1....1oI t; ),tt..u !l',t uFFIC EA
'A.(: IIV.\!.. A"tlU\l,f I f'>l.c...::,.p,!\\~!;i
~ (I n 3L'9E .=!o.tn \-Ifill IP'
f' \ T;; (ENT FI!VE:i. ~4[); 20&''''; n,,~
!'HJO
Scr PEOTYl)L\
~ M.:II'08
MF.MORANOV M FOR THE RECOkH
'iuh:r FM..II(E..Y ,., ~u 1-,,. -I H(j N'fll~F f X P'()~PRf: fnSl\ ACKNOWL.f:D(iEI\U:Nf
Ref: (a) ttlSD/AT< r\JIl1l:~' .'Aelnl "1).-lt..'ft'>C ^~~I"i~iol1 S~~lem S.fet;~
Fm'inmmt.:t11. Sufel \' ami ()."=IJtIIJII(HlllJ t-k~ltl"lleSOH I ttl<\k ,'\cct'p'.aIK:~' 'If 1
Mo.07
I"> CNAF /tIC'111t.1 6f.O(} St!r NI~.r::!7;IC 114 ., ,.1.1.. fiN (NOT .>\11
I. Curntll Dqm1mcnl (1/ Dvf('II!!J..: (I):,.D f r:a..It~Yt'nJll~'" f'Jrncr.nm M~rn bJ u~ tbe
'>tnIC1un:d 1:n\'inXJIIUlnl, Safely_.snd O.:oJ,(Iationdll-le.lllll j BSOH I rlllk J..,~e\"mclS:
fr~uTlIl!w(lr" in the DoD SUlm.bnJ rT':]j.:I.k.~ ftlf Sy~n~ SuJrlY, "'tilllllf)' Sr.andnrd eMll
S1T>HtR2D f(lf uU de,,'~Jopmel1tnJ und~uj,.1I1il1il1~ dll!ittrlmnlf ':-U'tJII1V"I 'l1le ''''''ir.t~I~''~ i...
10 d.".(!o (1I,If ESOJl ri~" l.'.fIrI~' in the i1l-quis:jli(1II prtx;C'SI. tli;,-;,'C\'(.'I.lJl'" uU rhA.~ (LIl' Oe
.dtn~nHlc,. Pri."f W l!.\l"'lSing fk.'Ople, ~quip'ncnt, 1.:(' I.hc t'n'\1nmDII.'ltr I... kra........II,}Mcln
1'('loled J:L~{'H haT.mi~. these ~h w.ml he ..d.nuwIMl;'l."lJ by the .mll'jf..r!tlj"ii rdf'ntiflcd in
nnf) fnlilrucuun 51))(1.1. Rdcn:ru.:c la.l uw:t.:u 1111:11 f,:CT11l11 t.:(.lm'uIl'eJlC-t 't'al~ tlt.~ .-.!'tlilrflof'>;l
fOC" nil w:n.au:o; lIJ1d nigh m.l ac~'t'pIIJI'!.I.."'C Ikt:nioll!> llKC O::l'lll'Utt't'II\.'(' pi Cnmf!'uMkft-t-
NQ'tll! lur 1;'1rces i... .dn..-uJ~ne..l rn rt!lcn.-n..--c ,b). ll!u MC/lJorulll.k.lttfl h)r It.Jt t<o.,,\,l>[J,j
1:t.:':UU'lC'fI1Hlllr ile'" rl/p,\'lcdilcmcnl of Ill1i'il! fxpn~r>: thllt rnr Ihco riA I SfJf aoJ E.-\ .)If(1.
und .dcu:rihrK om lL1j'ritil.'~ f.:l retJw::c this risk
J, I:i.SOf I riJio irH'o<'...in.~ l'~p:I"".lr>? t" ni~t'll lin,-A.I,'d: l''f 1l....'H. r' i'iYt."f(k-noJ \t'riOIl\.: fm Itr
fl.". J ~E.lf' alnll:,,-I:<<i Pl'ognll'fi,. T1J1"i i~ nlolll!. ,hIOOIDt IS\Ijl' ;ls~:':I."d WIth rnmy
t.:um:l\llll1d fLllIJl'1.: .~( illl'\:mll ul tM [JnL> lIH'rfllory. OJ;ff'Crv: h~'l.lfinJJ prlllex'lion Je,'icl!!>
Ih. ilL'" ndC~lllf<t'IS rn..'r\:~ IIni~~ o.l(I~r(" Ihallli.'f\JJnrtcl m~!)' e'1Jl('rkl1((,' "ll~n ".nrbnl/
;)I\~ ain:r.J11. PM..\265 he., ....k~ly rtll.lnll~'lhl~ 'r'iul'.l!n ~l'.ql ."'i1 S~M<'n~ C<'l11llU1lll
IA,JR ,t,J. &1 fl).'Of(r.;:-t" I." Na\al Jle~";l"'" ,ONlH 1,r11p.'\'r" tt'ICljo>o(1,l,.n d&~..dilrcn[l
h:cblllil.:aJ )i(tNIMJlr. 10 it'liltillllfoC .....H(lhlll.'II~'fl~l/t. 11.\ Itl!'kli"'C lc",c'h ilhoH'! (~L'ufl.l'l"nnl
SAlc4) unt.J Ht';tlth ..'drt'll"f.t~U""" IImt tl)j~n.1 SI;iltlo.,; N~..y 'J~h.lf,J$, ,\ numlK-r /.:4
Inlrl'1m fWl:-ot 'lIl11Ire,,,"~ Wn(l~rH ttA...(' he~n Il:lrntJtll;'11 rhm 1Tl1I)' (lITer pi1J"ll,u nc>n~ rcl.Jd
""flh(""ll('rtlant~'~ H"'plll'l~ It.. N.....;II or ,\it Fnn.:L' hi ph Jlc"rfurm..fl"~ mllitill) aire!"'Jt')
Pwmhdng J:>!I*"~~ ,1l11r{~","~ Wlot;\t' !ooIotf1l}O.......iit;) ir..'lu.k' Ihe Uni"~~11 y p.( MI-l,"'j;HiI'P'
Ic~11rw nt' {"'l1"!I~;)Io."j Il'f fll)Jllt: ""'ilk ''':j);<)~:!>1'';1~11 StOlt' I :l1h("(\.,iry' ~ '\onl illl'm
~1~1,Jp(il."11\f.l11Jdl"~, fill>.! flt.l(.inf ~ &\'{'I.'1l ,\II~k': NI\Ilh: N!li~ RniU":I""ll. ....h...,h
:tda~"t\ and :tppllL:'" lito:: l1t'\'....h:d lII~uh.: L:l'n.....'l11 ~, Ilk' {').Il:'JI1..,1 "y'Lll'ln ;1f lhl.' P"14 .e-flt,!1Ue.
Enclosure 6
Page 1 of 2
ENCLOSURE 6: PROGRAM EXECUTIVE OFFICER (TACTICAL AIRCRAFT PROGRAMS) - F/A-18E/F AND EA-18G
NOISE EXPOSURE RISK ACKNOWLEDGEMENT
'\"I~('tn~'f. Jt'J(- !.lllttlll~li ('lulpn)r;,"'f,1 fIlllllt;;j.~t:rur'Cr lor ..'1(' r4fM,Ifi4l.a. f'lIlfm~, (kmraJ
Ek....1ri.., ({;E, ""'inll~tlt h~. (II' y~~~''1 I'IM:='tlL'IOrl :,\-.j:..c R~Ju"'Ji\)n Tcchm:'.klf.lY
I :.....\'""IHrm~.I~t rf'njr~'I~I~ Im'I)Jn' i1 "Hd~ ....m"'y nfu:all!d 01&.:1:0\1 i;: 'HIJU(il.~llt;-sI~
""11\:11 a!-- 1111...h~ Jfl}'l:\ nnn ;111I,j w~L"'mirl:ll L'hCHIII\> /t. (1.111 ,~..Ic lllZKk a:n~In:: Ic~ II,J
t"'iYll'1t'\~It.U..'" lnd n.!idrdl'l :outh ICI,.I\I'kl(l1!:'&i":li ',lj11~ ":tlnrbxred hy CiE/N t\ V AIR. .1 .1, ul NlI'.i11
..\ If \\.'I.lfl ft"-' C~mrr 1.3kd~INI. ;1_ 2>< ~'\"I~'mh.t:~r }IIU I-(r."SUltl of tn,ir.. lit'~1 ..hl1W ~m:
pll,.III1i,e ...r,l.1JfltJ CJ}rl ~~ k~'d [I:J.ll..... 411.111 I,lfl f...tX X ...cnt~ (n~i.rrt"'i h ~Iu\d N m~ L.."t:sl
nr:lfic ("f tht;~ .){'(1b..:lsfi(III!<> lm'f\: I....-.:n hln:1 ("&lh1IJ,~~ii 1/1 LiflCrMinnnJ '''mlilj..(m.....
PMi\:!.,.1ij i, ul~, ..tjJ~\n~ ;It'rr\::l...t I'll ~11l-~"'mi (}f1I) eflml~ h1f lmplwc,t t.I,-.J;nny Jmlh."l:lll)J1
ib.....\;ft.:t~. ..;u..:l\.., I.t'1c' r'\l~enU;j,( ill,:( OJ~"lm Cnrnl\v.1I1'f;~J.i1ift'4. '-~ifCtf' 5y'l.em. lk";I..~ver.
C'*I':" WIUt UIl~ [rK.~ od...rlO~"\J t\ft.l..m~ ~'If1.)1('i.1;';lf\ 'Onder devr:":fInr~1. undl!r c:UK'mc-~y
h.ig.b 11l:J\~ t!X$K~"'tir(" ("I;lfldllll~'r, r\/:-"ftr'fJ{,<tl1 fj"J n rl\l11lrr ni;;!:'hl dfi.":'J. I he ~t nru!.e ~d"
reUilMn I.'Inill:\:eplable. In 1N€J)i I:un:!t. only tJlf.':t.alktnal mCfnLJrr;. <~": g., 1l1o\'i,tg I~' (1lmer
tlil!l-n .Je.:k J1~ hl1m.m.TI~ ~MIt'l al .1 furtbLT iji~{II)L'!t.' IrOln i~" ....'110U!'.1) I..rf,"f" ~U'
lenn '.olutwm....
.1.. .r\D ndtlilKll\i.d ...'()m:i~IHIft 1\ Ihe rarl tllal Ihl' t::A -IM.i J1ft)l.ill~.r,\ its, o,rilllntt ertre:f't.yl in
L:crtJin l'nXjucD.."JejJ RUlli [he 1:..\-(IB if n:rlh":~ dlK' 10 dl ftereOf <tllllmele:<bMm I1I)TJ.Je
L:L",Ii~~i""Jl~ r"(H' Lfli:l re:nl~. Ibt N",') ""-3." ul;ft,c: fl." .r:v ((If"'''''' WrdlOt. Findml'lIf NLl
Sign irkan I hnpld 1 R)NSl) hlr N!'.,~ ltit! l:.4.-I;r.:(j uIN~"ilJ .... Jt SlillllWl'J Whadt'ey (:lifoRd,
WA. Ifoo!!r NlJ,jL'ft1.l En~l:tUl1n1L'flliIJ P(!lk'~' .t\d (NEF..\/ ptCI(1..'durN.
.t Unttllhere U'e ,,'il1bJc lochD:lll'l,~ie" II) nUll$lIle cllln'lI( and r1aMil."'1.t llil)l....." Icvel:'l., 1'a:liloC
L!:\fKNJrc will Cl1nLitlut! CI. be nl1l";S~ lor Ib.: user CI\lll1mUlllI~'. t.~I):J,'I~JI:y *,.nnl iurcml
....lrricr!l /u 'tl.~uljum fxcL'Imc l1'rltilul*_ Pp,.1A2(,;\ ".I.,Il....."tu.. ...l.ui nJ1""mt ~...i~. lhe
l'illbdl!~ or ioc(lrptTi.llm~ J'ru''':'fIIi!chA'''\I.gI'''~ 1rt10 (til' f>'A-1HfJF ifJII' PA-Ili(fj
l.,J~4/~ .
1 ~~_._...
W M. SKINNER
Source: Risk Acknowledgement Memorandum was provided by PMA265
Enclosure 6
Page 2 of 2
Commander, Naval Air Forces - F/A-18EIF
and EA-18G Noise Exposure Risk
Acknowledgement (NOTAL)
9,
DEP~T OF THI NAVY
COMMAHDIlt NAVAl. _ FOllCU
~X_I
1M _. l:.IIII_ NU~1'llI1
6000
Ser N8/278
4 )far 01
MEMORANDUM FOR PROGRAM EXECUTIVE OFFICER (TACTICAL AIRCRAFT
PROGRAMS)
Subj: r/A-leE/F AND !:A-lBG NOISE EXPOSURE RISK ACKNOWLEDGEMENT
Ref: (a) OSD/AT'L Policy Memo -eefense Acquisition System
Safety Environment, Safety and Occupational Health
(ESOH) RiSk Acceptance~ of 7 Mar 07
(b) Dratt PEO(T) Memorandum for the Record -F/A-l8E/F and
&A-l8G Noise Exposure Risk Acknowledgement~
1. Per reference (a), Commander, Naval Air rorces concurs wlth
reference (b), acknowledqement of the noise exposure risk posed
by the r/A-1BE/F and EA-IBG weapons systems.
2. In concert with the acknowledgement of this risk, Commander,
Naval Air rorces supports efforts by the acquisition community
to develop weapons systems with reduced noise signatures and
hearinq protection systems that will reduce personnel noise
exposure to acceptable levels.
3. In addition, Commander, Naval Air Fore.. will continue to
rai.e awarene.s within the Naval Air Force of the hazards
associated with exposure to excessive noise levels produced by
jet englnes, the necessity of compliance with hearing
conservation directives, the proper wearing of hearinq
protection, and operational strateqies for miniaizinq personnel
exposure to harmful levels of nolse.
'x /
, . 'I
, I'W
,- ~, '--
T. J. KILCLINE
Source: Risk Acknowledgement Memorandum was provided by PMA265.
Enclosure 7
Page 1 of 1
FOR OFFlelAL USE ONL'(
Management Response from PMA265
e
DEPARTMENT OF THE NAVY
NAVAl.AlR SYSTEMS COMMAND
RAOM WILLIAM A. MOfFETT BUILDING
47123 BUSE ROAD. BLOO 2272
PATUXENT RIVER, MARYtAND 20870-1547
7540
AIR-00G4A1073
SEP 1 0 200B
From: Commander, Naval Air Systems Command ,
To: Naval Audit Service, Assistant Auditor General for Installations and Environment Audits
Subj: NAVAL AUDIT SERVICE DRAFI' INTERIM AUDIT REPORT ON
CONSIDERATION OF HAZARDOUS NOISE IN TIlE ACQUISmON OF TIlE
F/A-18EJF SUPER HORNET AND EA-18G GROWLER STRIKE FIGHTER
VARIANTS (DRAFT N2007-NIA000-0066.(03)
Ref: (a) NA V AUDSVC Memo 7510 N2007-NIAOOO-0066.003 of 14 Aug 08
Enc1: (1) PMA265 Response to Subject Draft Interim Audit Report
1. Reference (a) forwarded the subject draft interim audit report for review and comments.
Accordingly, enclosure (1) provides our response.
2. Please ,direct questions concerning the response to
I FOUO - FOIA (b)(6) I
~
. . y
Inspector General .
Acting
FOR 9FHCYd. l:JSE 8Nl.\"
Enclosure 8
Page 1 of 4
POR OPPI81AL USI: 8NLY
ENCLOSURE 8: MANAGEMENT RESPONSE FROM PMA265T
PMA265 RESPONSE TO
NA VAlJDSVC DRAFl' INTERIM AUDIT REPORT ON
"CONSIDERATION OF HAZARDOUS NOISE IN THE ACQUISITION OF TIlE F/A-
18FJF SUPER HORNET AND EA-l8G GROWLER STRIKE FIGHTER VARIANTS"
DRAFI' INTERIM AUDIT REPORT N2007-NIAooo..oo66.003;DATED 14 AUGUST 2008
SUMMARY: PMA265 maintained an appropriate process for evaluating the Risk Assessment
Code (RAe) for the flight-lineJdeckjet noise hazard and identified jell noise as a serious risk.
However, PMA265 did not attempt to mitigate the jet noise hazard in: the initial design arid
development of the aircraft. did not foUow required guidance relating to risk levels and risk
acceptance authority levels, and did not track the fligbt-lineJdeckjet noise hazard and its residual
mishap risk. These conditions may contribute to a hazardous environment of high noise
exposure associated with jet aircraft that, according to the Naval Safety Center, increases the
likelihood of permanent hearing loss to sailors and Marines. According to the Naval Safety
Center, in addition to the personal cost to the sailor and Marine, the economic consequences of
. hearing impairment to the Navy include: lost time and decreased productivity, loss of qualified
workers through medical disqualification, military disability settlements, retraining, and
expenses related to medical treatment.
p~s RESPONSE: Partially Concur. This sUlllttlal'y does not present a complete picture of
the findings in the report. Specifically. PMA26S requested in July 2008 (based on the discussion
draft report) the inclusion of a statement recognizing that despite the findings. there has been and
continues to be a concerted effort by PMA265 to n;rltigate the identified hazard of jet noise.
Request the following sentence be inserted.at the end of the swnnwy: "Recognizing there
are personnel exposure risks fromjet noise, PMA26S has committed and continues to proactively
seek viable and effective solutions to reduce noise generated from the high performance engines
of the F/A-18FJF and EA-18G."
Also. PMA265 requested in July 2008 the Memorandum for Record (MFR) of 5 May 2007
(Enclosure 6) be removed from the report. This MFR is now considered void with the issuance
of the 5 March 2008 MFR (Enclosure 7).
RECOMMENDATION 1: Establish a formal process to actively seek new, and document prior,
ongoing, and future. efforts to identify potential design solutions to mitigate identified hazards,
and determine what additional mitigation efforts may be possible (whether in design, devices, or
other methods) to further reduce the noise hazard for the F/A-18 FJF and EA-180 aircraft.
PMA265 RESPONSE: Conem. PMA265 is actively engaged in on-going research and
development efforts for engine noise reduction technologies. Future opportunities would also be
considered if promising. As reflected in the 5 March 2008 MFR. PMA265 will annually assess
available and viable technologies. A process to document PMA265' s efforts and assessments
Enclosure (I)
Enclosure 8
Page 2 of 4
ENCLOSURE 8: MANAGEMENT RESPONSE FROM PMA265T
will be identified in the next six to nine months, and would be implemented as part of PMA265's
commitment to the annual assessment of solutions. However, PMA26S does not plan to. "back
track" since the inception oCthe F414 engine and P/A-18FJF to document all past design efforts.
This could prove to be very time consuming with little return. Rath~, only the efforts of the last
two to three years will be noted by PMA26S. Estimated date of completion is 31 October 2009.
RECOMMENDATION 2: Reestablish risk levels (Risk Assessment matrix) and risk
acceptance authority levels in policies and procedures to ensure compliance with DoDI 5000.2,
Section E7.1.6 and SECNA V AINST 500.2C, Enclosure 7, Section 7}.
PMA265 RESPONSE: Partially Concur. PMA265 has already corrected the risk acceptance
authority levels for identified Environmental, Safety, and Occupational Health (ESOH) hazards
and their associated risks for consistency with DoDI 5000.2 and SECNA VlNST 5000.2C.
PMA26S, working with NA V AIR 1.6 Environmental Programs Department, will re-evaluate
over the next three to four months whether some of the risk levels currently reflected/ranked. as
"green" should be changed to "yellow" for greater consistency with DoDI 5000.2 and MIL-STD-
882D.
However, unless NA V AIR 1.6 changes the ESOH risk matrix configuration in
NA V AIR's Programmatic Environment, Safety and Occupational Health Evaluation (pESHE)
Template, PMA265 will continue to use a 5x5 matrix vice the 4x5 matrix ofMII..rSID-882D.
As previously discussed during the audil1 the mishap categories and associated ESOH risk matrix
of Mn..-SID-882D are "suggested" and offer "guidance." An acquisition program can still
choose to tailor their approach as long as the risk acceptance authorities are the same as
mandated by DoDI 5000.2 and SECNA VINST 5000.2C. It is the position ofPMA265 that the
Sx5 ESOH risk matrix is appropriately aligned with DoD's and NA V AIR's risk assessment
process which is founded on a 5x5 matrix. ESOH hazards and their risks are no different than all
the other hazards and risks that are assessed. by an acquisition program manager based on the
DoD risk assessment process. Therefore, using a similar risk matrix approach for ESOH
continues to make sense.
In additio~ while not verbatim to SECNA VINST 5000.2C, Table E7Tl, the risk
consequence and probability definitions of the current ESOH risk matrix used by PMA265 and
NA V AIR are appropriately aligned and consistent with the terminology in MR.-STD-882D, as
well as including basic DoD risk definitions used by acquisition program managers. PMA265
will consult with NA V AIR 1.6 on whether or not all of the exact ESOH risk definition
terminology of SECNA VINST SOOO.2C (such as occupational health severity definitions and
probability levels of Fleet and individual systems). should be included in NA V AIR's PESHE
Template. Estimated date of completion is 28 February 2009.
RECOMMENDATION 3: Establish controls and provide oversight to ensure that the F/A-18
FJF and EA-18G fiight-lineldeckjet noise hazard is formally opened in a tracking database and
that the associated residual risk, log of mitigation efforts, and all other relevant information is
tracked in a formal process with accurate record keeping.
2
Enclosure 8
Page 3 of 4
ENCLOSURE 8: MANAGEMENT RESPONSE FROM PMA265T
PMA26S RESPONSE: Concur. Action bas been initiated in that PMA265 is evaluating the
feasibility of modifying data fields in thc safety asscssmcnt report database used by the FI A-
18FJF and EA-18G system safety engineers for hazard tracking. Thcre is a portion of the
databasc that could possibly be modified to accommodate data fields for "cnvironmental" and
"occupational health" hazards and their risks. The current hazard Iiport would be used for
recording associated infonnation on the hazard. Configuration management of this database is
maintained by the Boeing Corporation. therefore PMA265 needs to evaluate what the costs
would be for modifying the database, the .reasonableness of those costs. and budget accordingly
for such modifications; if feasible. This evaluation will be conducted over the next three to six
months.
PMA265 will use. in the interim. a simple Excel spreadsheet for ESOH risk tracking
purposes. In addition, future PESHEs will be developed using NA V AIR 1,6's PESHE
Document Authoring Tool. which includes a standardized ESOH risk assessment modulc for
identified technical hazards and their risks. This module includes a component to document
mitigation plans with both assigned actions and associated milestones. This offers another
mechanism for formally tracking and documenting ESOH risk management. Estimated date of
completion for Feasibility Assessment of Database Modifications is 30 Apri12009.
FREEDOM OF INFORMATION ACf lFOlA) MARKING: PMA265 has no position on
FOIA release. The information contained in the draft report is unclassified and generally in the
public domain. However, should noise induced hearing loss (NDiL) by United States Navy
personnel ever become the basis of a class action suit against the Departmcnt of Navy. there may
be cause to restrict release.
Naval Audit Service response to paragraph on FOIA marking:
PMA265 has indicated that it has no position on possible release of
this report under FOIA, and that the information contained in the
report is unclassified and generally in the public domain. Because it
is already in the public domain, there would be no justification for
withholding the material in this report even if NIHL should become
the basis of a class action suit against DON. Therefore, this report
will be marked FOUO only for the protection of and possible
redaction of personally identifiable information under
Exemption (b)(6) of the Freedom of Information Act. All other
information in the report will be released if requested under FOIA.
3
Enclosure 8
Page 4 of 4
rOR OrrlCIAL us!: ONLY
Use this sheet 8S
for priRted ~opie.
at this I'e.,art
rOR OrrlGIAL USE ONLY
INSPECTOR GENERAL
DEPARTMENT OF DEFENSE
400 ARMY NAVY DRIVE
ARLINGTON, VIRGINIA 22202-4704
- . ~
OCCL
.. .
Mr. John Hammerstrom
P.O. Box 860
Tavernier, FL 330.70
orT 0, 9 2008
D~ar Mr. Hammerstrom:
. This is in response to your Freedom of Information .Act (FOIA) request dated and
received in this office on October 7, 2008. You are requesting "all documents or other
information gener~ted or gathered by DODIG and by agencies that reported to DODIG
relating to Case # 1 05900 - the inquiry regarding the Environmental Assessment for the
Introduction of the F/A-18E/F Super Hornet to Naval Air Station Key West.
We have a backlog of pending FOIA requests that were received prior to yours. In
an attempt to afford each requester equal and impartial treatment, we have adopted a
general practice of assigning requests in the order of receipt. Your FOIA request has
been assigned case number 09-0005. Please mention this number in any future
correspondence to this agency regarding this mater.
We will notify you of the decision on your FOIA request as soon as possible. The
necessity of this delay is regretted and your continuing courtesy is appreciated. Should
you have any questions regarding this matter, please contact me at (703) 604-9785 or
e-mail atfoia@dodig.1uil.
Sincerely,
J..l...- oJ . '--' -
Keith O. Mastromichalis
Acting Chief
FOIA Requester Service Center/
Privacy Act Office