Attachment 8 NETCINST 1500.13C (NETC High and Moderate Risk Training Safety Program).pdf
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·DEPARTMENT OF THE NAVY
COMMANDER
NAVAL EDUCATION AND TRAINING COMMAND
250 DALLAS STREET
PENSACOLA, FLORIDA 32508-5220
NETCINST 1500.13C
NOOX
· 9 JAN 2019
NETC INSTRUCTION 1500.13C
From: Commander, Naval Education and Training Command
Subj: NAVAL EDUCATION AND TRAINING COMMAND HIGH AND MODERATE
RISK TRAINING SAFETY PROGRAM
Ref: (a) OPNAVINST 1500.75D
(b) NAVEDTRA 135D ( c) OPNAVINST 5450.336D
(d) OPNAVINST 5102.lD ( e) MIL-HDBK 1027/lB ( f) NFPA 1403 ( g) OPNAVINST 3500.39D
(h) NETCINST 5100.lB ( i) NETCINST 1500.15A ( j ) NETCINST 1500.16
(k) OPNAVINST 1720.4B ( 1) SECNAV M-5216.5, Department of the Navy (DON)
Correspondence Manual
(m) NETCINST 1500.5C
(n) MILPERSMAN 1306-953
( 0) OPNAVINST 5100.23G
(p) DoD Instruction 1010.09 of 22 June 2012
1. Purpose. This instruction amplifies Office of the Chief of Naval Operations (OPNAV) policy and procedures to abate or minimize mishaps during high and moderate-risk training.
2. Cancellation. NETCINST 1500.13B.
3. Discussion
a. Aggressive training programs prepare personnel to perform mission essential high and moderate-risk tasks required to fulfill assigned duties. References (a) through (c) recognize Naval Education and Training Command (NETC) as a Training Agency, to ensure training is conducted in a realistic manner, while maintaining a safe learning environment. To comply with references (a) through (o), NETC has developed this
NETCINST 1500.13C
· 9 JAN 2019
policy that outlines roles and responsibilities for high and moderate risk training safety within the NETC claimancy.
b. NETC has authority to exempt high-risk classification of formal courses based on review of all hazards identified in the risk assessment, risk review, and careful review of historical data. NETC shall determine the command's ability to meet the requirements of high-risk training (HRT) as outlined in this instruction, and make informed risk decisions to change the high-risk classification based on an assessment of risks following evaluation of the hazards and historical data by a NETC assigned High-Risk Training Safety (HRTS) professional.
Formal high-risk courses may be lowered to moderate-risk by NETC. Roles and responsibilities for moderate-risk courses are listed in paragraph 6g.
c. Moderate-risk training is that which has been identified as moderate risk by NETC (NOOX), and in which a lack of stringent controls could lead to degraded mission capabilities in terms of the necessary standard and reduced mission capability if exposure occurs during training. It is training that contains practical application laboratories that require compliance with Occupational Safety and Health Administration (OSHA) , American National Standards Institute, National Fire Protection Administration, or OPNAV requirements. These could include, but are not limited to, fall protection, machinery guarding, use of personal protective equipment (PPE), and electrical safety controls.
4. Scope.
(military, evolutions
This instruction applies to all NETC personnel civilian, and contractors) whose duties include or tasks involving high and moderate-risk training.
5. Action. All levels of command are responsible for implementing and maintaining an effective HRTS program per references (a) and (b) , and a moderate-risk training safety program per this instruction.
6. Roles and Responsibilities. Implementation of the HRTS program for all NETC traditional and non-traditional (contractor) training provides a safe training and working environment for staff and students.
· g JAN 2019
a. NETC:
(1) Issue amplifying policy, and provide guidance and support to all subordinate commands conducting HRT.
(2) Designate all courses that meet the threshold for HRT as defined in reference (a) .
(a) Maintain a list of these courses by title and Course Identification Number (CIN) .
(b) Provide an updated list of all formal HRT courses to Commander, Naval Safety Center (COMNAVSAFECEN).
(c) If a course is being considered for removal from HRT, forward the risk assessment and supporting historical data to OPNAV (N09F) for concurrence.
(d) When reviewing high-risk classification, consider all submissions from activities and make informed risk decisions, based on available or provided assessments of risk, evaluation of the hazards, and any historical data available.
(3) Use Enterprise Safety Applications Management System (ESAMS) HRTS Module executive summary as well as results of Learning Site (LS) triennial High-Risk Training Safety Evaluations (HRTSEs) to provide a HRTS self-assessment, if requested by higher authority. This should not be confused with the Safety and Occupational Health (SOH) Self-Assessment referred to in other OPNAV and NETC safety policy documents.
NOTE: LS used throughout this instruction is a generic term that means any activity that conducts HRT.
(4) Pursue a HRTS program that minimizes the probability of mishaps and related injuries to students, staff, and Training Equipment (TE) during formal training.
(5) Schedule and lead, as applicable, on-site HRTSEs of all traditional and non-traditional high-risk courses, required by reference (a), at least once every 36 months.
NOTE:
· 9 JAN 2019
The NETC HRTSE Team is authorized to observe all HRT scenarios, including firefighter training, without completing NETC 1500/5.
(a) Conduct HRTSEs immediately after modifications to high-risk course platforms are completed, or when changes to existing high-risk courses introduce additional risk. This will be on a case-by-case basis as determined by NETC (NOOX) .
(b) Conduct HRTSEs of newly developed high-risk courses prior to, but no later than the first pilot course being taught. HRTSEs must be conducted at each site that desires to teach a high-risk course that they are not currently approved to teach.
(c) Develop and promulgate an annual evaluation schedule by 1 October.
(d) Ensure all team members are trained and qualified as outlined in the "NETC Training Safety Evaluator & Mishap Investigator Job Qualification Requirement (JQR) ."
(e) Evaluate the performance of the supporting High risk Training Safety Administrator (HRTSA) during LS HRTSEs.
(6) Implement a process that ensures a complete review of all new training evolutions identified as high-risk, high risk mobile training team courses, major modifications to previously identified high-risk platforms, and/or elements that introduce additional risk to all courses of instruction.
(7) Analyze mishap data for all formal training courses.
Ensure that courses with adverse trends are evaluated to determine if additional hazard mitigation is warranted.
(8) Initiate a Safety Investigation Board upon notification of a Class A on-duty mishap, per reference (d).
All Class A and B mishaps shall be entered into ESAMS and Web Enabled Safety System (WESS) .
(9) Interpret standards, regulations, policies, and procedures. Provide guidance when they are lacking clarity or conflict exists.
(10) Ensure policy for HRTS processes and procedures is standardized across Learning Centers (LCs) and Naval Service Training Command (NSTC), when practical.
(11) Ensure all HRT platforms (small arms ranges, firefighter trainers, swimming pools, confidence courses, etc.)
are periodically evaluated to ensure they are safe to operate, comply with manufacturer's instructions and OPNAV, NETC, Naval Facilities Engineering Command, and Commander, Navy Installations Command directives, as applicable.
(12) Designate, in writing, a HRTSA in areas that contain multiple LSs with different LCs. Also designate a HRTSA where HRT course(s) and High-Risk Training Safety Officers (HRTSOs) are remotely located from the HRTSA. The following are prerequisites:
(a) HRTSAs must have skills in hazard and risk recognition, HRTS, and knowledge of referenced instructions.
(b) HRTSA must be a SOH professional (Occupational Series 0018), and have successfully completed the following courses (or equivalents if approved by NETC) :
NOTE: Course information is located at: http://www.public.
navy.mil/NAVSAFECEN/navsafenvtracen/Pages/CourseSchedu leV2.aspx
1. NAVOSH Assessment Tools and Strategies, A-493-0889 (online) .
2. Mishap Investigation (Ashore), A-493-0078.
3. Introduction to Navy Occupational Safety and Health (Ashore), A-493-0050 or A-493-0550 (online).
4. General Industry Safety Standards, A-493- 0061.
5. Electrical Safety Standards, A-493-0033.
6. Introduction to Hazardous Materials (Ashore), A-493-0031 or A-493-0331 (online).
9 JAN 2019
7. Introduction to Industrial Hygiene for
Safety Professionals, A-493-0035 or A-493-0335 (online).
8. Navy Ergonomics Program, A-493-0085 (online) .
9. Machinery and Machine Guarding Standards, A-493-0073.
(13) Determine a Course of Action (COA) for a training event when HRTSA, HRTSO or Area Safety Professional has determined that the established controls, within a course of instruction or training platform, are ineffective to mitigate the known hazards and an immediate threat to personnel safety, equipment, property or the environment could exist. The COA determined by NETC NOOX includes, but is not limited to:
(a) Event cancellation pending HRTSE.
(b) Implementation of additional mitigating controls to continue training.
(14) Evaluate all course risk assessments and make final determination on whether a course is to be high-risk.
b. HRTSA. All SOH Professionals within the NETC domain have a vital role in assisting with the management of the NETC HRTS Program. They may be designated, in writing, as a HRTSA per paragraph 6c(3) (c). They may also be assigned to committees, mishap investigation boards, or other tasks identified within this instruction. No HRTS Program is complete without the effective utilization of these personnel.
(1) Serve as the central point of contact for HRTS related matters within their Area of Responsibility (AOR) .
(2) Assist HRT activities within assigned AOR to identify and define mission unique HRTS requirements.
(3) Assist NETC in the development of HRTS policy and procedures, as requested.
(4) Develop an email distribution list of all assigned activity HRTSOs within their AOR, to aid in distribution of HRTS related materials received from NETC Headquarters.
(5) Ensure all reportable HRT related mishaps are entered into ESAMS, validated, and closed (within 30 days). All HRT related Class A and B mishaps shall be entered into ESAMS and WESS, as required. If the circumstances of the mishap (i.e., prolonged medical treatment and follow-up care, delays in receiving official reports or documentation, etc.) prevent closure of the report within 30 days, ensure periodic updates are entered into ESAMS and WESS to show progress on the report.
(6) Ensure that student HRT related mishaps are entered under the student Unit Identification Code (UIC) vice staff UIC.
(7) Monitor training and qualifications of area HRTSOs.
(8) Upon notification of a Class A training-related mishap at an assigned activity, contact the Commanding Officer or Officer in Charge, provide assistance in developing the 72-hour profile, and immediately begin the mishap investigation per reference (d) .
(9) Assist or lead mishap investigation teams, as requested by NETC (NOOX) .
(10) Offer assigned activities assistance in conducting an analysis of training-related mishaps.
(11) Ensure the appropriate Chain of Command (COC) and NETC (NOOX) are promptly notified when issues arise affecting the safety of HRT within assigned AOR.
(12) Ensure that student UICs are accurately entered into ESAMS for all assigned LSs.
(13) Conduct a HRTSO Safety Committee meeting within assigned AOR.
(a) Meetings will be conducted biannually.
(b) Meetings may be conducted face to face, through conference calls, or electronic media.
(c) Meetings will be documented in ESAMS using ESAMS Class Module and course ID 4956 - High-Risk Training Safety Committee.
(d) A copy of the meeting minutes shall be provided to the committee members.
(14) Assist with the conduct of HRTSEs, when requested by NETC (NOOX) .
(15) Monitor HRT at all activities within assigned AOR.
At a minimum, this shall consist of:
(a) Ensure Emergency Action Plan (EAP) monthly reviews, quarterly walkthroughs, and annual drills are conducted.
(b) Review instructor qualifications.
(c) Review all course risk assessments (initial and annual reviews) .
(d) Conduct periodic observations of HRT.
(16) Assist LSs within assigned AOR to develop a HRTSO
JQR.
(17) Assist HRTSOs, within assigned AOR, with annual evaluation of all HRT Equipment, devices, training areas, and/or platforms, if requested.
c. LCs (Includes NSTC and Naval Education and Training Security Assistance Field Activity (NETSAFA))
NOTE: Establishment of more stringent requirements by LCs shall be coordinated with NETC (NOOX) . LCs shall not duplicate reference (a) or this instruction as a LC instruction. Modification of NETC or OPNAV forms is not authorized.
(1) Curricula Related Responsibilities
(a) Validate and update the Special Course Indicator
Code within Corporate enterprise Training Activity Resource Systems (CeTARS) whenever high-risk courses are developed, modified, or when elements of risk are introduced into courses not previously considered high-risk courses.
(b) Ensure all curricula and Standard Operating Procedures (SOPs) for each HRT course are clearly annotated with identified risks.
(c) Ensure LSs conduct formal training and high-risk evolutions following only approved course curricula and only to the extent required to meet Terminal Objectives or graduation criteria.
(d) Provide Subject Matter Experts (SMEs) to assist NETC in the evaluation of the LS HRTS program and curricula, if requested.
(e) Ensure safety requirements, control measures, and lessons learned are incorporated into the appropriate HRT curricula.
(f) Identify student prerequisites for HRT courses that reflect physical, academic, and performance standards required for successful completion of courses. Ensure these standards are reflected in the Catalog of Navy Training Courses (CANTRAC) along with the requirement for parent commands to complete any required medical screening of prospective students.
(g) Update HRT curricula, as necessary, to comply with controlling technical directives.
(h) Develop and approve a Core Unique Instructor Training (CUIT) plan for the high risk course being taught.
Distribute to appropriate LSs. CUIT plans will include:
1. All requirements of the high risk course screening and certification process. This shall include, at a minimum, online service record review, medical and psychological screening, and commanding officer interview.
2. Completion of command safety indoctrination.
3. Cardiopulmonary Resuscitation (CPR) training from a recognized training moderate such as the American Heart Association, American Red Cross, National Safety Council, etc.
4. Requirement for initial bloodborne pathogen awareness training.
5. First aid training, unless exempt per paragraph 6d(7) (a).
6. Requirement for Operational Risk Management training.
7. Familiarization with:
a. All safety controls
b. EAP
c. Training Equipment
d. PPE
e. Daily Operation Readiness Test (DORT), as applicable
f. Site specific hazardous operations and training platforms
~- Applicable safety policies, directives, precautions, technical manuals for training platforms, lessons learned from fleet mishaps
h. Other subject matter deemed appropriate by the command
8. Definitions of and procedures for reporting mishaps, near-misses, and unsafe/unhealthy working conditions.
9. Guidance on Training Time Out (TTO) and Drop on Request (DOR) policies and procedures (as applicable) .
10. Instructor's full understanding of the training platform operation, identified risks, and control measures necessary to identify and prevent HRT mishaps.
11. Completion of Instructor Training or a civilian equivalent school prior to teaching students.
Equivalent instructor training courses from other services is acceptable.
12. Attending only the high-risk portions of a high risk course as a student.
13. Personalize instructor guide.
14. Requirement to receive, at a minimum, two evaluations assessing both technical knowledge of subject matter and instructional delivery skills (lab evaluations shall be in high-risk topics) .
NOTE:
15. Thorough understanding of the EAP.
All CUITS must be approved by the appropriate LC, NSTC, or NETSAFA. An interim CUIT shall also be approved by the LC, NSTC, or NETSAFA, and instructors shall complete it before commencing any pilot course(s).
(i) Distribute CUIT plans to all appropriate LSs.
(j) Review/update the CUIT when a course is changed, or revised. Also, ensure the CUIT is reviewed during all Formal Course Reviews.
(k) Approve HRT course schedule variations and sequencing of evolutions for all HRTS curricula.
(1) Submit recommendations to add or delete a course as a high-risk course to NETC (NOOX), with a copy to NETC (N7).
A risk assessment must be included with the recommendation.
(m) Ensure NETC (NOOX) is notified, as soon as possible, when new high-risk courses are being developed, or existing high-risk courses are being modified, and additional risk is anticipated. No new, or modified high-risk course that introduces additional risk, shall convene without NETC (NOOX) concurrence. Additionally, NETC (NOOX) must be notified prior to new trainers, training platforms, or training facilities being used.
1. HRTSEs of new courses, modifications of existing HRT platforms, and/or new elements that introduce additional risk to existing courses shall be conducted at the earliest stage possible by NETC (NOOX) . This must be completed no later than the pilot phase for new courses and prior to implementation of modifications to existing training. LCs are responsible for funding NETC travel costs associated with observing/approving newly developed high-risk courses.
2. Decisions to conduct a HRTSE due to modifications of existing courses will be made by NETC (NOOX) on a case-by-case basis.
(n) Ensure all safety risks and hazardous materials exposures are identified and mitigated in the curriculum per the applicable curriculum development manual.
(o) Ensure safety policies, procedures, and awareness training are part of all curricula per the Navy School Management Manual (NAVEDTRA 135 (series)).
NOTE: Afloat directives may be incorporated into curricula when used to teach specific processes to students, (i.e., follow the Afloat Safety Instruction (OPNAVINST 5100.19E), appropriate NSTM, NAVSEA Technical Manual, and Tag-out User Manual when teaching how to conduct preventive maintenance on shipboard equipment. However, at a minimum, Ashore safety directives must be followed when conducting procedures outside of formal training, (i.e., follow the Navy Safety and Occupational Health Program Manual (OPNAVINST 5100.23G) when performing maintenance on the same piece of equipment)).
(2) Instructor Qualifications Related Responsibilities
(a) At a minimum, ensure that Statements of Work (SOW) for contract instructors teaching high-risk courses:
g JAN 2019
1. Clearly define instructor qualifications and requirements, including completion of Personnel Qualification Standards, JQRs, certificates of course completion in desired subjects, (i.e., basic instructor, small arms instructor, crew served weapons instructor, emergency medical technician, CPR, basic first aid, explosives driver, swim, firefighter, rigid hull inflatable boat) , and other assigned qualifications as applicable to the course of instruction and the CUIT.
2. Include a requirement to provide proof of medical evaluation by a licensed health care provider, drug screening, a statement of understanding on physical fitness criteria, National Criminal Investigative Check, Lautenberg compliance and/or other such desired elements as applicable to assigned duties. NETC reserves the right upon reason of belief to request a new urinalysis screening on instructor(s) to determine "fitness for duty". All urinalysis will be provided by the contractor at no additional cost to NETC.
3. Provide for NETC, through the Primary Contracting Officer, to have "Right of Refusal" of any instructor considered unqualified or unsafe.
4. Require compliance with safety policies established by the OSHA, and contained in Navy directives, (i.e., OPNAVINST 5100.23 (series), OPNAVINST 1500.75 (series), NETCINST 5100.1 (series), NETCINST 1500.13 (series) I and NETCINST 1500.16 (series)).
5. Contain a provision for the contractor to provide PPE and medical support and surveillance to its employees.
6. Contain a requirement for the contractor to have a safety plan for its employees that includes implementation of recommendations from Industrial Hygiene Surveys (i.e., enter contract instructors into medical surveillance program) .
7. Provide provision for the LC or LS to pre screen individuals proposed by the contractor for instructor duties.
8. Require that if a mishap involving services under this contract occurs, the contractor shall promptly report the incident within one hour to the LS Leadership, or others, as appropriate. If the Navy conducts an investigation of the mishap, the contractor shall cooperate and assist Navy personnel until the investigation is complete.
9. Provide guidance for contract renewal. Upon renewal, all requirements in the SOW must be re-certified and completed as stipulated in this instruction, to include updated medical screening and drug testing by the appropriate licensed health care provider for each contracted high-risk instructor.
(b) Establish policy on content and format for Instructor Training Jackets for subordinate activities.
(3) HRTSO and HRTSA Related Responsibilities
(a) Ensure the supporting HRTSA is informed during the pre-planning phase when a new high-risk course is developed, a course is relocated to a new site, equipment is moved to a new location, an existing platform is modified, or new equipment, trainers, training platforms, or training facilities are planned for use.
(b) Ensure a HRTSO is appointed for HRT that is conducted at non-traditional training sites. The HRTSO can be military, civilian, or a contractor. If a contractor is used, then they must be hired through a contract separate from the training delivery contract.
(c) Appoint an HRTSA in writing when the HRTSA and LS are within the LC COC and are both within the same geographical area. For example, a Safety Professional is assigned to Navy Diving and Salvage Training Center (NDSTC), and both the Safety Professional and NDSTC are within the Center for Explosive Ordnance Disposal and Diving COC. In this instance, the LC would appoint the Safety Professional as the HRTSA for NDSTC. Alternately, a Safety Professional in Mayport, FL is assigned to the Center for Naval Aviation Technical Training Unit (CNATTU) Jacksonville. In this case, there are numerous LSs within the Mayport geographical area, and all report to different LCs, so, NETC would appoint the HRTSA to provide support to all the LSs within the Mayport geographical area.
Provide a copy of all HRTSA appointment letters to NETC (NOOX) .
The following are prerequisites:
1. HRTSA must have skills in hazard and risk recognition, HRTS, and knowledge of referenced instructions.
HRTSAs are strongly encouraged to complete the HRTSO JQR for the courses they support.
2. HRTSAs must be SOH Professionals (Occupational Series 0018) that have successfully completed the following courses (or equivalents, if approved by NETC):
NOTE: Course information is located at: http://www.public.
navy.mil/~AVSAFECEN/navsafenvtracen/Pages/CourseSched uleV2.aspx
a. NAVOSH Assessment Tools and Strategies, A-493-0889 (online) .
b. Mishap Investigation (Ashore), A-493- 0078.
~- Introduction to Navy Occupational Safety and Health (Ashore), A-493-0050 or A-493-0550 (online).
d. General Industry Safety Standards, A-493-0061.
e. Electrical Safety Standards, A-493-0033.
f. Introduction to Hazardous Materials (Ashore), A-493-0331 (online).
g. Introduction to Industrial Hygiene for Safety Professionals, A-493-0035, or A-493-0335 (online).
h. Navy Ergonomics Program, A-493-0085 (online) .
i. Machinery and Machine Guarding Standards, A-493-0073.
(4) Risk Assessment Related Responsibilities
5 JAN 2019
(a) Request supporting HRTSA perform/review risk assessments with appropriate SME whenever new courses are developed or existing courses are modified.
(b) Ensure the NETC-established risk assessment format is employed (form can be found on ESAMS, under "resources") when new courses are developed or when an existing course is modified. An assignment of an initial Risk Assessment Code (RAC) of 1, 2, or RAC 3 in Severity Level I or II requires the course be considered high-risk and reported to
NETC (NOOX) .
1. A RAC 3 in Severity Level III or IV, although not high-risk by definition, shall be reviewed by the supporting HRTSA prior to commencement of formal training.
2. It is widely accepted that administrative training (classroom only) does not pose a reasonable element of risk to the staff and/or studentsi thus a risk assessment may not be necessary. However, if the classroom environment introduces equipment or items that will be handled by students, then this process must be included as a step (or steps) in the course risk assessment.
3. Ensure each step of the operation has been thoroughly evaluated in the risk assessment. Utilize approved curricula job sheets, or other similar curricula documents, while developing, revising, or reviewing HRT course risk assessments. Include, among other things, student-to-instructor ratios, contained in the CeTARS Course Master Schedule, as a control for mitigating known risks.
NOTE: Reference (a) allows NETC to change the risk determination (RAC) based on an evaluation of the hazards and historical mishap data.
(c) If a LC determines that a course is RAC 1, 2, or RAC 3 in the Severity Level of I or II during development or review of the course risk assessment, then NETC (NOOX) must conduct a careful re-evaluation of hazards and historical mishap data.
(d) LC Commanding Officers (COs) must approve (sign and date) all risk assessments for newly developed or modified high-risk courses that require the risk assessment to be revised. These risk assessments must be forwarded to NETC (NOOX) so an HRTSE can be scheduled. Annual reviews of high risk course risk assessments that have not been revised may be approved by the LS CO/Officer in Charge (OIC) .
(5) TTO and DOR Related Responsibilities
(a) Include DOR procedures in the curricula of all voluntary courses. See "Drop on Request Procedures" located in Resources/Instructions/NETC HRTS Instruction Addendum subdirectory on ESAMS.
(b) Include TTO procedures in all applicable curricula, using the "Training Time Out Procedures" located in the Resources/Instructions/NETC HRTS Instruction Addendum subdirectory on ESAMS. Add evolution-specific TTO procedures, standardized if feasible, to conform to established fleet distress indicators (e.g., standard small arms range procedures or diving distress signals, etc.). Some specialized training requires scenarios where effectiveness could be reduced by the application of traditional TTO procedures. In these instances, alternative TTO procedures should be developed to protect the student and staff without jeopardizing the training objectives.
These alternative procedures must be reviewed and approved by the Curriculum Control Authority.
(6) Emergency Action Plans the event of a Class A HRT mishap, and notify the NETC Duty Officer.
CO's discretion.
Related Responsibilities. In immediately suspend training Training may resume at the LC
NOTE: NETC (NOOX) will initiate a Safety Investigation Board per reference (d) .
(7) Other Responsibilities
(a) Forward and/or endorse formal safety correspondence (evaluation results, mishap investigations, and material marked official correspondence for distribution) per reference (1) .
NOTE: LCs conducting on-site safety inspections or evaluations do not meet the oversight criteria of
S JAN 2019
OPNAV or NETC. NETC (NOOX) retains that responsibility to ensure consistency throughout the NETC domain. The supporting Area Safety Professional (see reference (h)) should be contacted to conduct any on-site safety reviews to reduce cost of safety program management.
NETC (NOOX) encourages LCs, especially the Training Directorate, to participate in the NETC HRTSEs of their subordinate activities.
(b) Ensure NETC (NOOX) is promptly notified of issues affecting the safety of staff (military, civilian, and contractors), students, or HRT platforms.
d. LSs, Recruit Training Command (RTC), Officer Training Command (OTC) , and Other NETC subordinate activities conducting High-risk Training shall:
(1) Curricula Related Responsibilities
(a) Conduct training with approved curricula, ensuring safety precautions are in place, and that instructors adhere to established safety procedures and protocol.
(b) Forward recommendations to modify curricula to substitute or replace an element of risk with a less-hazardous element of risk to NSTC, LC, or Course Curriculum Model Manager (CCMM), as applicable.
(c) Recommend changes, via the appropriate LC or NSTC, to the Special Course Indicator Code within CeTARS when new courses are developed that potentially introduce an element of risk or whenever an existing course is modified to include an element of risk not previously considered and/or mitigated.
(d) Conduct HRT utilizing approved curricula, and following the policy and procedures outlined in this instruction as well as in reference (j).
(e) Advise appropriate LC, when new trainers, training platforms, or training facilities are planned for use.
(f) When a new or revised CUIT is received from the
LC, ensure it is compared with the current CUIT to identify additional qualifications required. This is commonly referred to as "cross-walking" the CUIT.
(2) Instructor Qualification Related Responsibilities
NOTE: The instructor screening and certification process must be completed prior to any high-risk instructor teaching Navy students without another qualified instructor present. Additionally, instructor certification and qualifications (to include the CUIT) shall be maintained in the instructor training jacket by the LS. If the CUIT is too large, then it may be maintained in another location, but the entire CUIT must be maintained.
(a) Ensure all HRT instructors receive HRTS indoctrination applicable to site specific hazardous operations and training platforms.
(b) Upon receipt of a prospective HRT instructor 1 s orders, coordinate with the detaching command to initiate instructor screening.
NOTE: For courses that have both high-risk and non-high risk training segments (Recruit Basic Military Training, Explosive Ordnance Disposal, Expeditionary Combat Skills, and Master-At-Arms "A" school, etc.), an instructor does not need to be screened to teach a high-risk course if they will only be teaching non high-risk segments of the course.
(c) Ensure every instructor is properly screened prior to teaching students, per reference (a). The military instructor screening process must include:
1. Service record reviews and personal interviews at the training command conducted by the CO. The CO may delegate interviewing authority, in writing, to a designated subordinate within the command. This requirement may be waived if the training command can provide documentation that the prospective instructor was screened by the detaching command.
The service record, which is a portion of the Official Military
Personnel File, can be viewed by approved command personnel at https://nsipsprod.nmci.navy.mil/. A user guide and access form (NAVPERS 1070/857) is available at http://www.npc.navy.mil/ careerinfo/recordsmanagement/ompf_cmdview.htm.
2. Medical and psychological screening conducted by competent medical authority (i.e., Medical Officer or credentialed Physician Assistant (PA) , Nurse Practitioner (NP) (family practice), or Independent Duty Corpsman (IDC)).
The "High-risk Instructor Screening Guide," "Medical Officer's Interview Guide," "Sample Request for Medical Screening" for a high-risk instructor, and "Commanding Officer's Interview Guide" can all be located in reference (a) . The "High-risk Instructor Medical Questionnaire (OPNAV Form 1500/53)" can be found on Naval Forms Online, https://navalforms.documentservices.dla.mil/ web/public/home:
3. Document completion of service record review, personal interview, and medical and psychological screening via a NAVPERS 1070/613 (Page 13) service record entry indicating the member was screened and found suitable/unsuitable for high-risk instructor duty. Page 13 entries shall be signed by the CO or designated representative. "Sample Page 13 Entries, High-risk Instructors" can be located in the NETC HRTS Instruction Addendum subdirectory in ESAMS.
NOTE: The page 13 entries must state that a service record review, personal interview, medical and psychological screening was accomplished.
4. Submit Special Screening Deficiency Report (SPSDR) per reference (n) in regards to instructor candidates transferred and received by the command who have been improperly screened or do not meet the criteria, with an information copy to Navy Personnel Command (NPC) , Shore Special Programs Assignment Branch (PERS-4010), and applicable detailer.
5. The Health Insurance Portability and Accountability Act (HIPAA) of 1996 prohibits the filing of medical and psychological screening results in the local instructor training jacket. Those results are to be safeguarded to ensure the confidentiality of the information.
9 JAN 2019
Examples can be located in the Resources/ Instructions/NETC HRTS Instruction Addendum subdirectory on ESAMS under "Sample Page 13 Entries, High-Risk Instructor."
6. cos may conduct additional screening as they deem necessary.
(d) The screening process for civilian employees serving as high-risk instructors shall include:
1. Personnel record reviews and personal interviews at the training command conducted by the CO. The CO may delegate interviewing authority, in writing, to designated subordinate within the command. The CO shall consult with the servicing Human Resources Office (HRO) for access to civilian personnel records. cos should contact the supporting HRO Labor Relations Specialist via email for a review of past or present adverse actions (for current civilian employees only) .
2. Medical and psychological screening conducted by competent medical authority (i.e., Medical Officer or credentialed PA, NP (family practice), or IDC) . The "High risk Instructor Screening Guide," "Medical Officer's Interview Guide," "Sample Request for Medical Screening" for a high-risk instructor, "Commanding Officer's Interview Guide," and "High risk Instructor Medical Questionnaire" can all be located in reference (a) .
NOTE: Civilian employees teaching high-risk courses shall receive medical screening every three years unless directed more frequently by other directives such as the National Fire Protection Administration 1582 requirement for annual physicals for firefighters.
3. Document completion of personnel record review, personal interview, and medical and psychological screening via a memorandum indicating the member was screened and found suitable/unsuitable for high-risk instructor duty.
This memorandum shall be signed by the CO or designated representative and placed in the instructor's training jacket.
4. The HIPAA of 1996 prohibits the filing of medical and psychological screening results in the local instructor training jacket. Those results are to be safeguarded to ensure the confidentiality of the information.
5. cos may conduct additional screening as they deem necessary.
(e) The screening process for contractors serving as high-risk instructors must be renewed every three years and during contract re-compete or renewal, and shall include:
1. A medical screening conducted by a civilian medical doctor or credentialed PA or NP (family practice) must be documented and indicate that the instructor is physically capable of working to the desired standards associated with the duty assignment. The medical screening shall be renewed more frequently than listed above if required by other directives such as the National Fire Protection Administration requirement for annual physicals for firefighters.
2. Drug screening. Contract instructors must meet the requirements contained in reference (p) . The Government reserves the right upon reason of belief to request a new urinalysis screening on instructor(s) to determine "fitness for duty." All urinalyses will be provided by the contractor at no additional cost to the Government.
3. Psychological screening conducted by a qualified practitioner. The screening must indicate that the instructor has completed psychological screening per this instruction, or a commercially available screening guide (such as the Minnesota Multiphasic Personality Inventory, or other available screening processes and procedures) . The method employed must be indicated on the evaluation.
4. Contractors will prepare a letter (on company letterhead) reporting successful completion of the screening. The letter should include the date of completion, the name of the screener (including mailing address, telephone number, and email address), and a brief statement regarding the results (i.e., the requested screening and interview have been completed; information does/does not indicate that there are potentially disqualifying factors in the instructor's medical history; the candidate is/is not suitable for high-risk instructor duty) . This letter will be filed in the contract
9 JAN ?019
instructor's training jacket and retained at the LS to denote screening and interview have been completed and the individual is found suitable. The HIPAA of 1996 prohibits the filing of medical and psychological screening results in the local instructor training jacket. Those results are to be safeguarded to ensure the confidentiality of the information.
5. Upon contract award/renewal, all requirements in the SOW must be re-certified and completed as stipulated in this instruction to include updated medical evaluation, psychological screening, and drug testing by the appropriate licensed health care provider for each contracted high-risk instructor.
(f) Ensure high-risk instructors are certified for the courses they are instructing. One of the first steps in the certification process is completion of the CUIT, that includes:
1. All requirements of the high risk course screening and certification process.
2. Completion of command safety indoctrination.
3. CPR training from a recognized training moderate such as the American Heart Association, American Red Cross, National Safety Council, etc.
4. Requirement for initial bloodborne pathogen awareness training.
5. First aid training, unless exempt per paragraph 6d(7) (a).
6. Requirement for Operational Risk Management training.
7. Familiarization with:
a. All safety controls
b. EAP
c. Training Equipment
d. PPE
e. DORT, as applicable
f. Site specific hazardous operations and training platforms
g. Applicable safety policies, directives, precautions, technical manuals for training platforms, lessons learned from fleet mishaps
h. Other subject matter deemed appropriate by the command
8. Definitions of and procedures for reporting mishaps, near-misses, and unsafe/unhealthy working conditions.
9. Additionally, the CUIT must include guidance on TTO and DOR policies and procedures (as applicable) .
10. Ensure all approved CUIT processes place an emphasis on an instructor's full understanding of the training platform operation, identified risks, and control measures necessary to identify and prevent HRT mishaps.
11. Completion of Instructor Training or a civilian equivalent school, prior to teaching students.
Equivalent instructor training courses from other services is acceptable.
12. Attending high-risk portions of course as a student.
13. Personalize instructor guide.
14. Requirement to receive, at a minimum, two evaluations assessing both technical knowledge of subject matter and instructional delivery skills (lab evaluations shall be in high-risk topics) .
Note:
15. Thorough understanding of the EAP.
The two initial instructor evaluations required to become certified as a high-risk instructor shall not be removed from the instructor's training jacket as they document a step in the initial certification process.
(g) Develop an instructor training jacket for compiling all required instructor qualification documentation as set forth by this instruction and your LC.
(h) Ensure all required instructors, safety observers, and other support personnel are present whenever HRT is conducted. Assign additional instructors and/or safety observers to mitigate risks, as applicable.
(i) Ensure personnel have been properly trained to perform their duties in instances where non-instructors are required to fulfill a role in training (i.e., safety swimmers, observers, line handlers, etc.). Safety swimmers, observers, and other non-certified instructors shall not instruct or remediate students.
NOTE: Establish a clear set of written procedures for use of NETC swimming pools/aquatic facilities or for NETC personnel using other aquatic facilities for physical conditioning that is not associated with a formal course of instruction. This shall include developing a risk assessment and mandatory use of a pool deck safety observer. Although a full EAP is not required, activities shall have a list of emergency phone numbers on the pool deck in the event of a mishap.
(3) Training Safety Officer Related Responsibilities
(a) Designate a sufficient number of HRTSOs for each high-risk course or group of high-risk courses that are taught by the LS.
(b) Appoint the HRTSO(s) in writing. The appointment letter shall list all high-risk courses under the HRTSO's responsibility, as well as the course observation periodicity (no less than once per year) . This letter shall be loaded into the applicable course in the HRT module of ESAMS.
1. Ensure all assigned HRTSOs are knowledgeable of their responsibilities prior to assuming the duties and responsibilities for assigned HRT.
2. HRTSOs shall be in pay grade E-5 or above, if military, or civilian equivalent, and are required to complete a LS specific HRTSO JQR developed by the SME and reviewed by the HRTSA. An HRTSO cannot be a civilian Safety Specialist (0018 series) unless a waiver is submitted via their COC to NETC (NOOX) for approval. Any waiver submittals must contain a thorough justification.
3. HRTSO JQRs shall include, at a minimum:
a. Familiarization with HRTS instructions.
b. HRTSO responsibilities.
c. All applicable curricula and associated CUIT plans.
d. Familiarization with all high-risk evolutions, associated training platforms, and devices to the extent necessary to properly evaluate assigned training.
e. Familiarization with ESAMS and other appropriate reporting and recording methods.
4. LSs shall use the JQR provided on ESAMS (go to the Resources/Instructions/HRTS Instruction Addendums link in ESAMS) and modify it to reflect additional LS unique requirements.
5. Ensure HRTSOs conduct inspections of all HRT technical training equipment, devices, training areas, and/or platforms to ensure proper operation, maintenance, and compliance with applicable directives. These inspections shall be recorded in ESAMS, under the Inspection sub tab; inspection category: High-risk, and Internal inspection type: Annual.
6. Ensure the HRTSO(s) attend HRTSA safety committee meetings.
7. Ensure HRTSOs (or other designated personnel) enter and maintain data in the HRTS module of ESAMS to include instructor evaluations, observation notes, risk assessments, and EAP information.
(4) Student Related Responsibilities
(a) Develop and implement student indoctrination that includes discussion of safety requirements, precautions, and safeguards incorporated into the curricula, and the definitions of and procedures for reporting mishaps, near misses, and unsafe/unhealthful working conditions.
(b) Ensure students participating in HRT complete NETC 1500/5 prior to reporting for HRT. This form may be downloaded from the Resources/Forms, Checklists, and Documents link in ESAMS, Naval Forms Online (see paragraph 8), and is available in CANTRAC and Fleet Training Management Planning System (FLTMPS) and shall be reviewed and signed by the student's medical department. If a course requires medical screening different from NETC 1500/5 (i.e., Navy Diving Courses;
Chemical, Biological, Radiological Defense Specialist Course;
Survival, Evasion, Resistance, Escape Course; Recruit Training), then the LS must request authorization to deviate from NETC
(NOOX) .
NOTE: Activities that have students attending back-to-back high-risk courses and find the 45-day limit for the Student Medical Screening Form a challenge, may request an exemption to the 45-day limit. The request must be submitted to NETC (NOOX) in writing, via the chain of command, and include a detailed explanation of the problem and the relief requested.
1. Part I - Answering "YES" to any of questions 1-27 on NETC 1500/5 requires a decision regarding suitability for participation in HRT by a medical provider (supplying command physician or authorized command health care professional to include MD, PA, NP, or IDC) before allowing the student to continue the screening process. If all questions are answered "NO," a HM may sign Part I.
2. Part 2 - Any "YES" answers or issues may be cleared at the discretion of the Training Site Authority. The
Training Site Authority is any individual at the LS who the CO/OIC appoints in writing to make the final determination if an individual is approved to attend training. The intent is for a senior staff member to be the TSA.
3. All Student Medical forms shall be destroyed no later than 30 days after trainee has graduated.
NOTE: Students from NETC accession points (RTC/OTC) and Midshipmen will not have NETC 1500/5 when reporting to their respective A-Schools or HRT events 1 as screening does not occur during the Sailor transition process. In those cases 1 NETC 1500/5 may be completed prior to the HRT by an authorized command health care professional such as one provided by a military medical clinic or civilian contract.
(c) Establish a process to ensure students meet course prerequisites that reflect physical requirements and assess the student 1 s medical status and fitness for training prior to participation in HRT. Procedures must include a system to ensure instructors are informed of students who were previously "set back11 due to medical conditions that might cause future problems. These procedures must not rely solely on students informing instructors of changes in their medical status.
1. Students evaluated as unfit for duty or not suitable for training shall be removed from training immediately until medically cleared.
2. Use tags 1 rings 1 or other appropriate methods for identifying students with specific medical conditions or concerns. For example: Students with known allergies may be identified by a color-coded tag or ring clipped to their uniform during evolutions that may expose them to a particular allergen. Students unable to bend or stoop may be identified by a different color-coded tag or ring clipped to their uniform. These methods may not be appropriate at all training sites and during evolutions or under certain conditions.
(d) Authorized Students for High Risk Courses.
1. Department of Defense (DoD) (military or civilian)
2. U. S. Coast Guard
3. National Oceanographic and Atmospheric Administration (NOAA)
4. International Military Students
5. Individuals who are not members of the organizations listed above (e.g., non-DoD civilians, Naval Reserve Officers' Training Corps, etc.) may under certain circumstances be allowed to attend specific high-risk courses.
However, prior written approval is required by NSTC for courses under their cognizance (courses for which they are the CCMM) , and NETC (NOOX) for all other courses. All such requests must be submitted via the applicable LC or NSTC. All individuals approved must meet the same requirements for attendance as outlined in this instruction. In no case, may Navy Junior Reserve Officer Training Corps students or Naval Sea Cadets attend a high-risk course. NSTC shall provide NETC (NOOX) a copy of all correspondence related to authorizations to attend their high-risk courses. NSTC is not authorized to delegate this authority to subordinate activities.
a. A "Hold Harmless Agreement" must be signed prior to attending NETC High-Risk courses. A sample "Hold Harmless Agreement" can be found on the Resources/Forms, Checklists, and Documents link on ESAMS.
b. VIPs, media, historians, film crews, and other interested parties often request to observe portions of high-risk courses. These requests must be in writing, and routed to NETC Public Affairs Office (PAO) for staffing. If approved, NETC (NOOX) will provide additional controls beyond those found in this instruction, as appropriate. A "Hold Harmless Agreement" must be signed prior to attending NETC High Risk courses. A sample "Hold Harmless Agreement" can be found on the "Forms, Checklists, and Documents" link on ESAMS.
(5) Risk Assessment Responsibilities
(a) Ensure the NETC-established risk assessment format (form can be found on ESAMS, under "resources") is employed when new courses are developed or when an existing course is modified. An assignment of an initial RAC of 1, 2, or RAC 3 in Severity Level I or II, requires that the course be considered high-risk and reported to NETC (NOOX) .
1. A RAC 3 in Severity Level III or IV, although not high-risk by definition, shall be reviewed by the supporting HRTSA and LC prior to commencement of formal training.
2. It is widely accepted that administrative training (classroom only) does not pose a reasonable element of risk to the staff and/or students; thus, a risk assessment may not be necessary.
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