03 March 2010
Review of OPNAV Instruction 6000.1C
To: Chain of Command:
Subj: Review of OPNAV Instruction 6000.1C
After reviewing OPNAV Instruction 6000.1C there may be some areas of concern that will need to be addressed to support pregnant women on submarines. By pregnant on submarines I mean that there will be pregnancies that are unknown or that the woman fails to report (despite regulations that cite she has a responsibility to report). It will happen. When it does, what impact will it have on mission and what liability will navy be responsible for?
I can provide a few comments but this instruction needs an authoritative review before making an informed decision on this issue.
Additionally, this instruction will likely require revisions if women become submarine crew members (not a big deal, just that it will need to happen).
I have only included parts of the instruction that I had comments on. The complete instruction is available at the above link. Additionally please see my general comments at the end of this paper.
Very respectfully,
John A. Mason, ETCS(SS/SW) (USN Ret.)
3. Background
b. The overriding concern for commanding officers (COs), supervisory personnel, and Health Care Professionals (HCPs) responsible for pregnant servicewomen is to provide for the health and safety of the servicewoman and her unborn child while maintaining optimum job and career performance. Policy and procedures are developed to provide administrative support and ensure the health and welfare of pregnant servicewomen, while minimizing the impact pregnancy and parenthood have on operational readiness. Pregnancy status will not adversely affect the career patterns of naval servicewomen. Additionally, pregnancy should not restrict tasks normally assigned to servicewomen, but may impact their ability to perform routine tasks associated with their current Navy Enlisted Classification (NEC) code and/or billet and may require temporary reassignment as appropriate.
[Minimize impact on mission effectiveness and efficiency? Will this be possible?]
[Will it be possible to serve aboard submarines when pregnant and not restrict normal tasks?]
[May impact their ability to perform routine tasks associated with their NEC. Is this not a valid concern?]
[Guidance to Commanding Officers. Will they be able to comply with this concern?]
c. The establishment and maintenance of work sites that allow servicewomen to perform their assigned tasks, without adverse job-associated consequences, are primary responsibilities of the command. Included is the elimination of detectable hazards and the prevention of occupational illness and injury.
[Do work sites need to be modified ‘just in case’ a woman may get pregnant? What are the navy’s liabilities in this area?]
4. Policy
a. Pregnancy and parenthood status must be made known to designated command officials while ensuring the servicemember’s privacy.
[Again, we must consider unannounced pregnancies and their potential affect to both the mother, her fetus, and navy mission]
5. Action. All Navy COs, supervisory personnel, HCPs, and servicemembers will be made aware of this instruction in its entirety.
[How much burden will this impose on the submarine community and will the burden impact mission?]
101. Responsibilities
a. Commanding Officers (COs)
(1) Shall make every effort to ensure that pregnant servicewomen are not subjected to harassment, imposition of personal opinions, or infringement of legal rights per reference (b).
(2) Shall ensure servicewomen receive counseling once pregnancy has been confirmed. Counseling will include discussions on military entitlements to obstetrical (OB) care while on active duty per references (c) and (d), and Navy policy on worldwide assignability. Single parents and dual military servicemembers are required to sign NAVPERS 1740/6, Department of the Navy Family Care Plan Certificate and NAVPERS 1740/7, Family Care Plan Arrangements to appoint a guardian for their child(ren) per reference (e). Sample Pregnancy Counseling Form, Appendix D, provided. Command counseling will be documented and recorded by service record entries. Servicemembers ordered to overseas duty should be counseled concerning a command’s decision to sponsor or not sponsor their family member(s) per reference (d), article 1740-010.
(3) Shall advise servicewomen that requests for separation due to pregnancy will not normally be approved. In those cases where extenuating circumstances exist, requests for separation should be submitted with adequate lead-time, prior to the 20th week of pregnancy, to allow appropriate separation dates to be determined per reference (d), article 1910-112. Pregnant servicewomen requesting separation will be counseled on the limited medical benefits available after separation as per reference (d), articles 1740-030 and 1910-112.
(4) Shall ensure all pregnant servicewomen are afforded the opportunity for counseling by an occupational HCP, if requested, per reference (f).
(5) Shall ensure that pregnant servicewomen are not adversely evaluated or receive adverse fitness reports/evaluations as a consequence of pregnancy. Additionally, no comment on the pregnancy shall be made in the comments section. Weight standards exceeded during pregnancy through 6 months postpartum are not cause for adverse fitness reports/evaluations. Pregnant servicewomen who have recently delivered, who are otherwise fully qualified for and desire reenlistment, but who exceed acceptable weight standards per reference (g) will be extended for the maximum of up to 6 months after delivery.
(6) Shall authorize, if requested, a pregnant servicewoman to occupy off-base housing and be paid Basic Allowance for Housing (BAH) up to her 20th week of pregnancy, per reference (h). From the 20th week onward the host commander must approve a request to occupy off-base housing.
[Surface ships may have staff support to help CO accomplish this responsibility. Will a submarine CO & ship’s complement form enough personnel to meet this requirement without impacting mission readiness?]
c. Occupational Health Professionals. Will support COs in fulfillment of their responsibilities to provide a safe and healthy workplace for pregnant servicewomen. Depending on the circumstances and information required, the appropriate occupational health professional might be an occupational medicine physician, industrial hygienist, occupational health nurse, lactation consultant, audiologist, radiation health officer, toxicologist, or environmental health officer.
[Again, will the submarine community have to fulfill this requirement in anticipation that a woman may become pregnant while onboard a submarine, have an unknown pregnancy, or unreported pregnancy?]
e. Servicewomen
(1) Are expected to plan a pregnancy in order to successfully balance the demands of family responsibilities and military obligations.
(2) Shall seek confirmation of pregnancy by a military HCP or civilian HCP in cases of inaccessibility to a military treatment facility (MTF).
(3) Shall notify their CO or officer in charge (OIC) of a pregnancy as soon as possible, but no later than two weeks after diagnosis. This will facilitate planning a replacement requisition if the servicewoman is in a seagoing/deployable billet.
(4) Shall report as soon as possible to the supporting MTF to establish a prenatal care program.
[What about pregnancies that are reported or found out by the woman part way into the mission? Will the mission be aborted/interrupted to meet this requirement? How will mission readiness be affected]
f. Navy Environmental Health Center (NAVENVIRHLTHCEN) will maintain a current list of potential reproductive hazards based on professional review of the literature and analysis of available data, per reference (f). NAVENVIRHLTHCEN will provide guidance to medical departments on criteria for requesting occupational health consultation and will also provide reproductive hazard guidance on request or when indicated.
[Does NAVENVIRHLTHCEN have authoritative information specific to the unique submarine environment as pointed out in the current study reports? In fact, is this currently even scientifically possible on submarines given current state-of-the-art?]
g. Medical Treatment Facility (MTF)/Fleet Industrial Hygienists. At the time of a baseline industrial hygiene site survey, and during any survey updates, the presence of possible reproductive and lactation hazards will be evaluated, including potential exposure to agents on the NAVENVHLTHCEN list. Any positive findings will be brought to the attention of the CO or Safety Officer and Senior Medical Department Representative (SMDR) .
[Same comment as above]
m. Naval Education and Training Command (NETC) Will ensure training in sexually responsible behavior is conducted for officer and enlisted accessions. Additionally, NETC will ensure this topic is included in the General Military Training (GMT) plan.
[Does NETC currently have training that covers realistic human sexual behavior with an acknowledgment of the inevitable human nature factor inherent to male-female relationships, especially within the closed and isolated submarine environment for extended lengths of time?]
102. Workplace Assignment and Medical Considerations
a. Few restrictions are required in an uncomplicated pregnancy of a physically fit servicewoman working in a safe environment. The servicewoman shall not be assigned to duties where she is a hazard to self or others. A pregnant servicewoman’s duties/occupation may cause or exacerbate symptoms such as light-headedness or nausea. In consultation with the appropriate HCP, the CO shall determine medical and work assignment limitations. Results of the industrial hygiene site survey, evaluation of the occupational HCP, or recommendations of the OB HCP may indicate the need for reassignment or work restriction(s) per reference (f).
[Again, effect of unknown/unreported pregnancies. ‘The servicewoman shall not be assigned to duties where she is a hazard to self or others’ EVERY crewmember on a submarine is a potential hazard due to unique nature of the submarine environment, i.e. one innocent mistake made by one individual can threaten the ship and its mission.]
[‘A pregnant servicewoman’s duties/occupation may cause or exacerbate symptoms such as lightheadedness or nausea.’ Acknowledgment of possible effects of a pregnancy on the woman.]
b. The command should ascertain whether the work site has had an industrial hygiene site survey. If the setting has not had a recent industrial hygiene site survey, temporary removal of the pregnant servicewoman from an industrial setting may be indicated; consult with an occupational HCP for evaluation of the site survey.
[Is the submarine community setup for this requirement? Is it scientifically possible in the submarine environment?]
c. The Occupational Exposures of Reproductive or Developmental Concern questionnaires as required by reference (f) (appendices B and C) shall be completed by the pregnant servicewoman and command supervisory personnel knowledgeable of the servicewoman’s workplace. If potential for exposure to a developmental hazard is present in the workplace, or if naval activities have not determined the possibility of such potential, the command shall arrange for an occupational HCP to evaluate the servicewoman as soon as possible. If the most recent industrial hygiene site survey documents that no potential for exposure to a developmental hazard exists in the workplace, an occupational medicine evaluation should occur if either the pregnant servicewoman or the CO requests it. A copy of the appropriate sections of the completed evaluations should be placed in the servicewoman’s medical record and in the servicewoman’s command safety office. Additional limitations will require the judgment of the CO in consultation with the HCP and the occupational health professional.
[Is the command capable of arranging for an occupational HCP onboard the submarine? Is environmental information available to perform an accurate HCP in the submarine environment?]
103. General Limitations
(1) Medical. After confirmation of pregnancy, a pregnant servicewoman shall be exempt from:
(a) The physical readiness program (PRP) during pregnancy and for 6 months following delivery. (Refer to Exercise sections 108 and 205).
[After recently discovered pregnancies while underway on mission, will this requirement relieve women submarine crewmembers of their damage control responsibilities? What about unknown pregnancies?]
2. Ergonomic. An ergonomic restriction would apply when a pregnant servicewoman’s physical configuration/abilities preclude her from continuing with specific activities. The safety office can be requested to provide an ergonomic assessment of the pregnant servicewoman’s workplace, if there are any concerns. Pregnant servicewomen shall be exempt from:
(a) Standing at parade rest or attention for longer than 15 minutes.
(b) Lying in the prone position for a prolonged period.
(c) Participating in weapons training, swimming qualifications, drown-proofing, diving, and any other physical training requirements that may adversely affect the health of the servicewoman/fetus (refer to Exercise, section 108).
(d) Lifting greater than 25 pounds.
[Common onboard submarines, particularly during stores load (e.g. TDU weights @ 70# per box) and damage control operations]
(e) Working in one position for prolonged periods.
(f) Performing prolonged work at heights (such as on ladders and step stools).
(g) Exposure to excessive heat or vibration.
[Is the submarine environment considered excessive in these areas, especially heat? What constitutes excessive heat? Is the heat inherent in the Engine Room/Diesel excessive?]
(3) Environmental.
(c) Exposure to chemical or toxic agents/environmental hazards that are determined unsafe by the occupational health professional or the OB HCP should be avoided. Areas with other questionably harmful effects such as chemical, biological, radiological, and nuclear effects (CBRNE) training should also be avoided.
[Do we have scientific data available for the submarine-specific environment to ensure compliance with this requirement?]
104. Assignments
e. Specific Assignments
(2) Shipboard
(a) Pregnant servicewomen may remain onboard up to the 20th week of pregnancy.
(b) A pregnant servicewoman shall remain onboard if the time for medical evacuation to a treatment facility capable of evaluating and stabilizing OB emergencies is less than 6 hours. The 6-hour rule is not intended to allow pregnant women to operate routinely at sea, but rather to provide the CO flexibility during short underway periods (i.e., local operations such as changes in ship’s berth, ammunition anchorages, and transits to and from local shipyards).
[Can a submarine on mission meet this requirement?]
(c) For enlisted servicewomen, COs shall ensure the enlisted availability report includes the date the pregnant servicewoman will be in her 20th week of pregnancy, the date replacement required, and in the case of deploying units, the date of deployment. For officers, COs should notify the command placement officer as soon as possible for relief and transfer of the officer.
[Can a submarine CO meet this requirement?]
(3) Aviation Squadron
(a) Reference (i) discusses the considerations and requirements in regard to pregnant flight personnel.
1. Pregnancy is considered disqualifying for designated flight status personnel. [Why? Is the reason applicable to submarines? For example submarines have pressure changes, changing environments, etc.] However, waivers may be requested up to the beginning of the third trimester (28th week) Flight personnel may be waived to permit flight in transport, maritime, or helo type aircraft with a cabin altitude of less than 10,000 feet. No solo flight or ejection seat flight will be considered for waiver. Designated Naval Aviators (DNA) are waived to service group III (SG III) only. Pregnancy must be uncomplicated.
2. Close flight surgeon follow-up is mandatory. [As a general point, we do not have flight surgeons on submarines. Only hospital corpsman (HM) are available.]
Ergonomic factors must be observed and flight status altered if the member cannot safely perform her duties due to the confines of the aircraft. [‘cannot safely perform her duties due to the confines of the aircraft.’ While indeed an aircraft may be a confining environment, particularly in some smaller cockpits, most of the submarine work environment may be considered ‘confined’. Will the submarine be required to alter mission status to meet this requirement?]
(4) Reporting or Assigned as a Student
(a) Assignment of a pregnant servicewoman will be handled on a case-by-case basis. Consideration must be made for the course content and the limitations discussed in sections 101c through 102.
(b) If a servicewoman becomes pregnant during training, the CO of the training command will determine if she can complete her training, as per section 104.e. (4) (a) When disenrollment is required, it will be necessary to determine when training can be terminated. If possible, training will be terminated at a point academically feasible for the service member to reenter the training at a later date, without having to complete previously completed portions of training. Based on this information and the projected delivery date, the CO of the training command will determine the disenrollment date.
[Will submarine training requirements be affected by this requirement? Submarines have limited personnel and tight timelines for completing required training.]
(d) After returning to full duty, a servicewoman disenrolled for pregnancy will be afforded the opportunity to complete her training, consistent with manning and readiness conditions. NETC will determine if enrollment will be necessary for the entire course of instruction or only for the portion lost as a result of disenrollment for pregnancy.
[Interruption of shore-based training required for submarine crew will be affected by this requirement. Will there be an adequate number of women in the pipeline to ensure boats get required NEC’s on board when needed to support their missions?]
106. Evacuation of Pregnant Servicewomen
a. If noncombatant evacuation is ordered in any area, all pregnant servicewomen who have reached the 20th week of pregnancy will be evacuated as noncombatants.
b. The area commander will make the decision whether to evacuate servicewomen in the earlier (less than 20 weeks) stages of pregnancy. The area commander will consult with available medical authority and base a decision on:
(1) Ability of the pregnant servicewoman to perform in her specialty.
(2) Capability of field medical (or other support unit) to perform emergency OB care.
(3) Requirement for duties.
(4) Nearness of the hostilities.
(5) Welfare of the unborn child.
c. Medical evacuation methods will not be used for pregnant servicewomen unless directed by a medical officer.
[Needs review by qualified person]
108. Exercise . Per ACOG and the DOD/VA Uncomplicated Pregnancy Clinical Practice Guideline (DOD/VA UPCPG), servicewomen with uncomplicated pregnancies should continue to perform an individualized exercise program that incorporates regular mild to moderate exercise in sessions of 30 minutes duration, three or more times per week during the pregnancy. The exercise program should be based on pre-pregnancy activity level and be approved by the OB HCP. Pregnant servicewomen should not participate in push-ups or sit-ups. Pregnant servicewomen should not engage in scuba diving, high-altitude (>10,000 feet above sea level) activities, contact sports, or activities that carry increased risk of falling or risk for abdominal trauma during pregnancy.
[Risk of violating this requirement due to unknown and/or unreported pregnancies?]
109. Disposition of Complicated/High Risk Pregnancies. Some pregnant servicewomen require significant amounts of time away from the work environment (i.e., past history of multi-problem pregnancy, bleeding or threatened abortions). In these instances, it is not unusual for the OB HCP to order the servicewoman to bed rest for extended periods, or until delivery. If this impacts the command adversely, the following disposition alternatives may be utilized:
[If a submarine crewmember has a pregnancy that becomes complicated/high risk, what will her disposition be afterward? Will she be disqualified from future submarine duty due to items pointed out here? What will be the effect on submarine personnel pipeline?]
Chapter 2 Parenthood
201. Responsibilities
a. Commanding Officers (COs)
(4) Shall ensure that servicemembers are afforded the opportunity to take advantage of available legal assistance for advice regarding their options in establishing paternity. Absent a court order or other competent authority, male servicemembers will not be compelled to have a paternity test. Department of the Navy (DON) medical facilities do not pay for paternity testing. Paternity testing will be obtained at the servicemember’S expense.
[What will happen if a submarine crew member becomes pregnant by a fellow submarine crew member? What impact will this have on the submarine and on the submarine community, i.e. training, personnel pipeline, morale, cohesiveness, legal requirements, etc.?]
(5) Shall develop written policies to delineate support of servicewomen with breastfeeding infants that includes information such as facilities provided and time allotted for breaks. The policies will ensure that the work environment supports and respects servicemembers who engage in healthy behaviors such as breast milk expression. The policies will prohibit harassment and discrimination of breastfeeding servicewomen.
[How will a woman submarine crewmember’s decision to breastfeed affect the ability of the submarine community to meet its manning and operational requirements?]
(6) Shall provide access to educational information from didactic materials and/or a lactation consultant for breast care, breast feeding education, counseling, and support during the pregnancy, after delivery, and on return to work for servicewomen and their families.
[Will this be required of the submarine community?]
(7) Shall engage the Navy Occupational and Safety Health Program, as necessary, to ensure that an Occupational Exposures of Reproductive or Developmental Concern Questionnaire has been completed, per reference (q), and that the current industrial hygiene site survey identifies potential environmental and occupational hazards that may impact servicewomen with nursing infants.
[Will this be possible within the submarine community?]
b. Servicemembers
(1) Are expected to plan a pregnancy and/or adoption in order to successfully balance the demands of family responsibilities and military obligations.
[Will it be acceptable for a woman submarine crewmember to plan a pregnancy given the affect it will have on operational commitments? The submarine community will not have personnel to substitute for a woman that chooses to become pregnant. Will the navy be willing to account for such possibilities by ‘over manning’ billets/NEC’s etc. The alternative is to enforce birth control while a woman is attached to a submarine. Is this legal?]
(3) All single servicemembers and dual military couples with eligible family members are responsible for initiating a formalized family care plan per reference (e). A completed family care plan will certify that family members will be cared for during the servicemember’s absence. It will also identify the designated legal guardian of the eligible family member(s), as well as logistical, relocation, and financial arrangements. Servicemembers are advised to contact their local Fleet and Family Service Center (FFSC) to develop a family care plan. Servicemembers may consult with Fleet and Family Support staff if needed for assistance identifying or selecting caregivers. Single, separated or divorced servicemembers with possible custody issues are advised to consult with their legal assistance office when designating caregiver and legal guardians.
[This is currently a problem in the military in general. How will it specifically affect the submarine community?]
d. Servicewomen
(2) Who desire to continue breastfeeding upon return to duty will notify their chain of command at the earliest possible time to allow the command to determine how best to support them as well as to facilitate the prompt evaluation of the workplace for potential hazards. Questions regarding potential workplace hazard issues related to lactating servicewomen should be referred to Navy Occupational Health Program personnel to determine whether intervention is necessary.
e. NAVENVIRHLTHCEN. will maintain a current list of potential lactation hazards based on professional review of the literature and analysis of available data, per reference (f). NAVENVIRHLTHCEN will provide guidance to medical departments on criteria for requesting occupational health consultation and will also provide generic lactation hazard guidance on request or when indicated.
[Breastfeeding issue again]
202. Adoption
b. Servicemembers Adopting an Infant/Child
(1) The CO shall authorize up to 21 days permissive TEMADD for any servicemember adopting a child, dependent on the unit’s mission, specific operational circumstances, and the servicemember’s billet. Adoption leave may be authorized in conjunction with ordinary leave. In the event a dual military couple adopts a child in a qualifying child adoption, only one of the members shall be granted adoption leave as per references (s) and (t). A. qualifying adoption is defined as the member being eligible for reimbursement of qualified adoption expenses under Section 1052, title 10 United States Code.
(2) After placement of the infant/child, one parent shall be exempt from duty away from the home station, i.e., TEMADD and/or deployment for 4 months per reference (e), paragraph 4.13, and reference (u), paragraph 6.10.4.
[Will submarine personnel be allowed to adopt? What will be the impact if yes or no?]
206. Postpartum Depression
a. Medical department staff shall routinely assess and screen all pregnant servicewomen and new mothers for signs/symptoms of depression or a history of depression/psychosis during the following periods of care: new obstetric care visit, transfer obstetric care visit, last trimester of pregnancy, 6 weeks postpartum as well as each of the well-child care visits in the first 6 months of life at a minimum as per DOD/VA Uncomplicated Pregnancy Clinical Practice Guidelines and American College of Obstetricians and Gynecologists. This is important since a history of previous postpartum depression or major depression significantly increases the risk for the servicewoman developing postpartum depression.
[What affect will this have on the submarine community?]
b. Scientifically proven screening tools, such as the Patient Health Questionnaire Two (PHQ-2) Question Screening during pregnancy and the Edinburgh Postnatal Depression Scale (EPDS) should be offered to women in the postpartum period as part of a screening program for postpartum depression. The postpartum screening may be done in conjunction with the 6 week postpartum visit as well as each well-child care visit in the first 6 months of life at a minimum. Postpartum depression should be managed in the same way as depression at any other time, but with additional considerations regarding the use of antidepressants while breastfeeding.
[Same comment as above with the addition of breastfeeding complication.]
209. Workplace Support of Breastfeeding Servicewomen
b. Background
[All of section 209 must be reviewed in light of women submarine crewmembers and possible effects on submarine operations/missions/delay in returning to the submarine due to a woman’s choice to breastfeed.]
From Appendix A
2. Pregnancy is a condition that includes a range of physiological changes that can potentially lead to clinical findings that would result in your command having to modify the servicewoman’s job function/working hours. In addition, certain unforeseen conditions related to the pregnancy may arise that could warrant specific medical interaction and further physical limitation of the servicewoman’s activities.
[An acknowledgement of effects of pregnancy. These effects could possibly affect submarine operations/manning/etc.]
From Appendix B and Appendix C
[A checkbox for ‘Physical Conditions (1) Irregular or shift and (2) strenuous work’… both are inherent to submarine duty. This implies that pregnancy is threatened by (or possibly threatened by) these two conditions.]
From Appendix D
2. If any environmental hazards or toxins exist in a servicewoman’s work center, as identified by medical and or occupational health, the servicewoman will be reassigned or duties modified.
[Do we have scientific data about submarine environment to definitively address/meet this requirement?]
3. Pregnant servicewomen are exempt from the following:
a. Physical Readiness Program until 6 months after delivery.
b. Deployment until 12 months after delivery.
[Will the submarine community be able to endure the loss of a crewmember for 12 months? Will the personnel pipeline be setup to account for this 12 month ‘no deployment’ period. What will the affect be on follow-up tours? Submarine manning in general?]
d. Exposure to chemical or toxic agents/environmental hazards.
[Same as above]
7. Pregnancy is considered disqualifying for designated flight status personnel; however, a waiver may be requested up to the beginning of the third trimester (28th week).
[Similar requirement in submarine community and its affect?]
8. Pregnant servicewomen (less than 20 weeks pregnant) assigned shipboard shall not remain onboard ship if it is estimated that it will take greater than 6 hours to transport a servicewoman to a medical treatment facility capable of evaluating and stabilizing OB emergencies. Servicewomen assigned shipboard shall not remain onboard beyond the 20th week of pregnancy.
[What about pregnant women that find out they are pregnant while underway and report pregnancy? Will the submarine be able to meet this 6 hour requirement?]
11. Servicewomen who desire to continue breastfeeding upon return to duty will notify their chain of command at the earliest possible time to allow the command to determine how best to support them as well as to facilitate the prompt evaluation of the workplace for potential hazards. Questions regarding potential workplace hazard issues that are related to breastfeeding servicewomen should be referred to Navy Occupational Health Program personnel to determine whether intervention is necessary. When possible, COs shall ensure the availability of a clean, secluded space (not a toilet space) with ready access to running water for the purpose of pumping breast milk. The number of breaks needed to express breast milk is greatest when the infant is youngest, then gradually decreases (i.e., 15-30 minutes every 3-4 hours). Requests to breastfeed infants at work during duty hours should be handled on a case-by-case basis; however, breastfeeding an infant is not a reason for granting excessive time for meals or from work.
[Same comments as above re: the breastfeeding issue]
12. Servicemembers with children are required to make arrangements for childcare to cover regular working hours, duty, exercises, war, and combat contingency deployment.
[This is a problem within the military in general. How will this specifically impact the submarine community?]
Some closing comments in no particular order:
When I say ‘submarine community’ in my comments I mean specifically (1) current submarine crewmembers (2) crewmembers in submarine training pipeline (3) general submarine manning requirements, both male and female.
Someone more experienced than me will have to review of my comments and address them more authoritatively than I have. I hope my comments will be taken objectively and not as some crazed former submariner intent on keeping women off of submarines. I believe my comments are valid and will even be useful if and when a decision is made to allow women to serve as submarine crew members.
I might be off the mark with this whole instruction since there have surely been pregnant women from maintenance facilities working onboard submarines during refit and other non-at sea times. What is our experience in this area? Certainly we have no information about impact of pregnancy during extended, isolated time at sea. See 1995 SAIC (Submarine Assignment Policy Assessment) paper and Kane, J. L., and Horn, W. G. (2001) “The Medical Implications of Women On Submarines. (1219)”. There may be other studies as well.
The main thrust I see here are the risks of unknown or unreported pregnancies and what effect they will have on the mission and what liability will they impose upon the submarine force/navy. Additionally, the requirements of this instruction may be more onerous on the submarine community due to limited number of personnel on board each boat, types of missions required of submarines (i.e. extended lengths of time submerged and away from any friendly support).
Very respectfully
John A. Mason, ETCS(SS/SW)(USN Ret.)
© 2009-2022 John A. Mason