MEDICAL DOCUMENTATION OF ASBESTOS AND LEAD EXPOSURES ON COAST GUARD CUTTERS CONSTRUCTED PRIOR TO 1991

The Coast Guard is directing the documentation of possible exposure to asbestos and lead on ships that were built before 1991, which of course means most of them.

HEALTH, SAFETY AND WORK-LIFE SERVICE CENTER TECHNICAL DIRECTIVE 2017-009, HSWLSCTD 2017-009 14 December 2017

This TD applies to all Coast Guard members currently and previously assigned to CG cutters that were constructed prior to 1991. Documentation is for the purpose of identifying potential exposure to low levels of asbestos and lead below the Medical Surveillance Action Level (MSAL) required for enrollment into OMSEP. Medical documentation of these exposures may facilitate the processing of future Veterans Administration disability claims.

This is primarily aimed at active duty personnel, but an entry on the Coast Guard Retired Facebook page indicates an intention to also document possible exposure of those no longer on active duty.

New Coast Guard Officer Evals Don’t Go Far Enough–USNI

US Naval Institute has a discussion about how the new officer evaluation report (OER) might be improved.

This was always my least favorite part of being in the service. Frequently it seemed if you were honest and followed the instructions, it was the kiss of death–damning with faint praise.

Ultimately I came to believe we would be best served if the evaluation was a simple choice of three check boxes.

___ Make this officer Commandant

___ Does OK

___ Fire the SOB

Possible Checks/Alternatives to BMI as Weight Standard

I have to say I screwed up. I didn’t look up the current instruction before writing this.

The current instruction is COMDTINST M1020.8H “COAST GUARD WEIGHT AND BODY FAT STANDARDS PROGRAM MANUAL.” change 1, dated 17 April, 2015.

The current standards go beyond BMI and are more exhaustive than my suggestions.

1. General. Coast Guard body fat standards are mandated by reference (a), which states: “All the DoD components shall measure body fat using only the circumference-based method with one set of measurements (males: height, neck circumference, and abdominal circumference at the naval; females: height, neck circumference, waist circumference at the thinnest portion of the abdomen, and hips). This standardization avoids unnecessary confusion and perceptions of unfairness between services. No substitute methods of assessment are permitted.”
2. Standards for Separation. All members who exceed both their maximum allowable body fat (MABF) percentage by more than eight percent and exceed their maximum screening weight by more than 35 pounds are subject to separation. Screening weights and MABF percentages are listed in enclosure (1)

My original post is below.

————————————————————————————————–

Last October I wrote a post about why Body Mass Index (BMI) should not be used as a sufficient indicator of excess weight for the service to forcibly discharge an individual, because it does not differentiate between fat and muscle, and because it unfairly penalizes taller people.

I related how it resulted in the discharge of a very fit petty officer whose only crime was that he had spent too much time in the gym building muscle mass.

BMI has only one overriding advantage–it is easy to determine.

Recently found this article, “Calling BS on BMI: How Can We Tell How Fat We Are?” which provides two simple and quick alternatives that, in fact, reflect fat content rather than simply weight.

  • “For adults, Laursen suggests getting out a tape measure. Measure your circumference at your belly button. If your waist circumference is half your height or less, you are at a healthy fat level, if you are over that number, your fat could put you at risk for ill health.
  • “If you want something even simpler, look at your hip to waist ratio. It’s something even a doctor could eyeball quickly. “If the waist is bigger than the hips, it tells me that the risk carried with that weight is much higher for that person for premature death,” Lopez-Jimenez said.”

These two tests, which might be used in combination, give a better indication of fat content (and fat, particularly belly fat, is really what we should be concerned with) than BMI. Additionally it insures that the individual will look reasonably “military” in uniform, something BMI does not do.

If we consider meeting these two criteria sufficient, BMI would no longer useful for setting upper weight limits. Lower limits perhaps, but I believe there are better standards for that as well.

Hearing: Coast Guard Requirements, Priorities, and Future Acquisition Plans (FY-2018)

 

May 18, the Commandant, Admiral Paul F. Zukunft, addressed the House Appropriations Homeland Security Subcommittee. The recorded testimony is above. It is fairly long (1h40m). The Commandant’s initial statement, following the introductions, begins at 8m40s and ends approximately minute 14.

The administration’s FY 2018 budget request was not available, but the Commandant was there to discuss future priorities, requirements, and programs. The Department Secretary, General Kelly, is expected to address the Subcommittee on May 24 at 3PM Eastern.

I will just mention a few of the items I thought significant.

Admiral Zukunft noted that Huntington Ingalls has begun cutting steel for NSC #9. Questioned about NSC#10, he said, if it were funded, the Coast Guard would of course use it, but that the Offshore Patrol Cutter (OPC) is the Coast Guard’s #1 priority. His response, that another NSC would have an effect on long-range operating cost, seemed to suggest anticipated significantly lower operating costs for the OPC. Significantly, there has been no mention of reducing the OPC program by one ship to offset the addition of NSC #9. (There is already a strong push to build more NSCs, a bill to authorized a multi-year buy of three more.)

He contended that the Coast Guard has taken a harder hit, due to budget restrictions, than other armed services and would need 5% annual growth and at least $2B annually for Acquisitions, Construction, and Improvements (AC&I). Later he stated that this annual AC&I appropriation would included about $300M annually for shore facilities. He pointed to a need to restore 1100 Reserve Billets and add 5,000 active duty military billets while retaining current levels of Civilian staff.

Apparently the FY2918 budget will begin a program to replace 35 Inland tenders at an estimated cost of approximately $25M each ($875M total). (Even if, in the unlikely event, this program were funded in only five years, that would only average $175M/year, so it is not a big program, but one that should have begun at least a decade ago.)

Cyber security for ports was discussed. The Commandant sees the Coast Guard role as decimating best practices, rather than imposing regulation. We now have a cyber program of record–still very small, two CG Academy graduates going directly into the program. The fact that two billets is worth mentioning, is probably the best indication of how really small the program is. A much smaller pre-World War II Coast Guard probably had more people working on breaking German and Japanese codes. 

Marine Inspection was addressed. The Commandant noted the increased demand for Inspections because 6,000 tugs have been added to inspection program. He noted a need for more stringent oversight of 3rd party inspectors, who in some cases have not been as meticulous as they should have been. He also noted that the US flag merchant fleet, notably the MSC’s Afloat Prepositioning Fleet, will need replacement, which will also raise demand for marine inspectors.

The Commandant also voiced his support for the Jones Act. He noted, we only have three shipyards building Jones Act ships in the US, and their loss would be short-sighted.

There was much discussion about the Arctic and the Icebreaker Fleet. Looks like follow-on funding for icebreaker program (at least after the first) will have to come from CG AC&I rather than the Navy budget. This may be difficult, but it is the way it should be. The chair of committee expressed his reservations about attempting to fund such big-ticket items through the DHS budget. The Commandant stated that the Coast Guard is still considering the acquisition of the commercial Icebreaker Aiviq (but apparently they are doing it very slowly–the chairman of the committee seemed a bit irritated about this).

The committee members seemed to latch onto the idea that the USCG, rather than the Navy, would be responsible for enforcing US sovereignty in the Arctic (which by US definition includes the Aleutians), and seemed to be asking if the Coast Guard was prepared to fight the Russians and/or Chinese in the Arctic. The Commandant suggested instead, that our role was to provide presence in the pre-conflict phase in order assert US sovereignty. He acknowledged that the National Security Cutters are only armed defensively and are not suitable for conventional naval warfare against an enemy combatant.

The Commandant acknowledged that, at some point it may be desirable to arm Polar Icebreakers, meaning they should be built with space, weight, and power reservations for additional weapons.

(I am all for keeping open the option of arming our icebreakers, so that they can defend themselves and do their part, if there is a conflict in a polar region, but there did not seem to be recognition among the Congression Representatives, that an Arctic conflict is most likely to be determined by submarines and aircraft. The icebreakers’ role is likely to be primarily logistical.)

The Commandant apparently does expect that there may be disagreements with regard to the extent of the US authority over certain areas of the Arctic.

In discussing the need for land based Unmanned Air Systems, there was a curious note at minute 40 about go-fast boats going south. Where are they going?

Alien Migrant Interdiction (AMIO). We have gone for seven weeks without a single Cuban Migrant being interdicted. This is because of the end of Wet Foot/Dry Foot Policy. This has allowed reallocation of resources to drug interdiction South of Cuba and human trafficking from the Bahamas

A Congressional Representative, from Texas pointed out there is no CG presence on the Rio Grande River, in spite of it being an international waterway. There was no mention of it, but perhaps he was thinking of the Falcon Lake incident in 2010 when an American was allegedly shot in the head by Mexican drug runners. Maybe something we should reconsider.

The Commandant promised the CG would have an unfunded priority list for FY2018.

Worried about the Size of the U.S. Navy? Rearm the Coast Guard–The National Interest

Navy photo. MH-60R “Knighthawk” helicopters conducts an airborne low frequency sonar (ALFS) operation during testing and evaluation

Navy photo. MH-60R “Knighthawk” helicopters conducts an airborne low frequency sonar (ALFS) operation during testing and evaluation

The National Interest has a post subtitled, “A new challenge for Trump: redefine the U.S. Coast Guard’s defense roles” you might find interesting.

The author, a Coast Guard Officer and Cutterman, wants to see our larger cutters better armed. He recommends specifically, provision for support of the Navy’s MH-60R

“The U.S. Coast Guard should explore adding the ability to embark, operate with, maintain and rearm these aircraft from both the National Security Cutter and Offshore Patrol Cutter. Only complete solutions that see cutters equipped with ordnance handling facilities, surge berthing for a full-maintenance detachment and sensor integration through data links should be considered.”

and the 5″ Mk45 for the National Security Cutter.

“The addition of a true major caliber-deck gun offers immediate utility, but the system’s real potential will be unlocked if efforts to develop hypervelocity projectiles bear fruit. If so, the National Security Cutter would emerge as a true utility warship capable of providing fires to forces ashore at substantial range and meaningfully contributing to air defense.”

070111-N-4515N-509 Atlantic Ocean (Jan. 9 2007) - Guided missile destroyer USS Forest Sherman (DDG 98) test fires its five-inch gun on the bow of the ship during training. The Sherman is currently conducting training exercises in the Atlantic Ocean. U.S. Navy photo by Mass Communication Specialist Seaman Apprentice Joshua Adam Nuzzo (RELEASED)

Atlantic Ocean (Jan. 9 2007) – USS Forest Sherman (DDG 98) test fires its five-inch Mk 45 mod4 gun during training.U.S. Navy photo 070111-N-4515N-509 by Mass Communication Specialist Seaman Apprentice Joshua Adam Nuzzo

He does, however, see the services culture as an impediment.

“The lesson of the twenty-five years following the Hamilton experience is that a challenge to maintaining the U.S. Coast Guard’s warfighting capability lies in managing the service’s perception of its character…

He also notes that previous concepts of the Coast Guards wartime environment may be unrealistic.

“Attempts to define the U.S. Coast Guard’s defense roles following the Cold War have been challenging. Published in 1998, Coast Guard 2020 proclaimed that the “Coast Guard will be prepared to operate in low-threat conflict environments, and to provide specialized functions at all levels of operation.” The notions of low-threat operations and service-unique specialization are obstacles to interoperability. While U.S. Coast Guard buoy tenders and icebreakers absolutely provide specialized capability, the major cutter fleet’s warfighting role was never—nor should it have ever been—unique to the U.S. Coast Guard. Rather, the major cutter fleet provided an active augmentation force trained and equipped to provide service in any theater of war. This should be the target for the fleet’s future employment as the community of nations returns to its more normal mode of great power competition. As for the limitation of a low-threat environment, U.S. Coast Guard cutters have deployed recently to Southeast Asia, the Black Sea, the Arctic and the Arabian Gulf. Saber rattling among great powers and the HSV-2Swift incident demand that we ask: which of these locations will qualify as a low-threat environment on the first day of a global or major regional war?

Generally I agree with the thrust,

“The immediate challenges are acquiring and integrating combat systems and training crews in their employment. These are not trivial tasks and will necessarily consume time and resources. Better to act with dark clouds forming on the horizon, however, than in the midst of the storm.”

It is a two page post. The first page is mostly history lesson on the Coast Guard’s participation in past conflicts, but if he gives the impression the Coast Guard was historically ready for these roles on day 1, that would be a mistake. The Coast Guard entered WWII terribly unprepared. The cutters had no sonar or radar and no depth charge racks. There is nothing new about our current lack of readiness for war, it is not the exception, it is the norm.

Trouble is, we tend to have a binary approach. Either we are at peace and could care less about war-time roles, or we are all in after an attack. We need a more measured approach that responds to changing circumstance.

We really need to do better at preparing for a transition from peace to war. 

I don’t necessarily think removing the ASW systems from the 378s following the collapse of the Soviet threat was a mistake. It was a rational response to rapidly changing circumstance. Since then, we have had a quarter century without a substantial ASW threat, and the 378s are now on their way out. We probably should have removed the CIWS too, unfortunately it did mean we lost all the Coast Guard’s accumulated expertise in ASW. Hopefully we can rebuild it with the Navy’s help if needed.

But circumstances have changed again.

To me, a major conflict now appears more likely in the next ten to twenty years than at any time since I entered the Academy in 1965. We have a true peer challenger, with a chip on its shoulder and a belief in its inherent right to rule, in China. If that was not enough, Russia is rearming and acting increasingly obnoxious. Iran and North Korea may be annoying, but they are really not in the same league, at least in terms of a naval threat. Dealing with them would not stress our Navy, so would not really require Coast Guard assistance. China is the real threat, and if Russia sides with them, things could get dicey. Even without the Russians, the Chinese are building credible surface combattants at least as fast as the US. They already have a local superiority in the Western Pacific. We have to spread our fleet out, while they can concentrate their forces. To concentrate our forces in the Western Pacific, the US will be fighting at arm’s length with long vulnerable supply lines.

I don’t necessarily think war with China inevitable, but we need to recognize the possibility and plan for it.

Theoretically the process should start with an agreement between the Navy and the Coast Guard about what the Coast Guard, particularly its vessels and aircraft, will do in a general war. I see few indications that is happening. Certainly the OPC Concept of Operations did not include anything beyond a simple contingency operation.

I may be wrong about this, since I am way out of the loop, but if the service had an established general war mission focus to prepare for, it should be generally known. It should be reflected in our procurements. Perhaps the Navy thinks it would be presumptuous of them to assign the Coast Guard missions, and the Coast Guard does not want to push itself into Navy planning, but this is too important for delicate feelings to get in the way. Right now the Coast Guard is probably proportionately larger compared to the Navy than at any time in the last 100 years. When I entered the service, the Navy was 22 times larger than the Coast Guard in terms of personnel. Now it is only eight times larger. A combat ready Coast Guard may be the difference between victory and defeat.

Plans:

The Coast Guard has potentially important roles to fill in any general conflict. If the Navy cannot envision these roles, perhaps the Coast Guard should think for itself. Plans should include our aircraft as well as our vessels, but I will stick to the vessels for now.

What we need is not an overall strategy to defeat China, but a well developed range of options for employment and a good idea of what upgrades would be required.

In a major war, I see a major shortfall in open ocean escorts. Thirty years ago, when the threat was the Soviet Navy and the problem was projecting American power across the shorter distances of the Atlantic, the US had 36 cruisers, 69 destroyers, and 115 frigates (plus 12 WHEC 378s). Now they have 22 cruisers, 63 destroyers, and 8 LCS.

Then we had the advantage, that the Soviet Fleet was split into four parts and their egress to our supply lines was limited by the presence of powerful European Allied navies that restricted their access to our supply lines.

In a Pacific War with China, the distances are much greater, our allies fewer, and, with the exception of Japan and S. Korea, much weaker. Our Navy’s fleet, currently 274 ships, with ambitions of 355, is scattered across three oceans while China’s fleet, likely soon to be 500 ships, is geographically concentrated.

If we needed over a hundred frigates to cross the Atlantic, we probably need at least that many to push across the Pacific. As it is, the Navy cannot meet their current peacetime commitments, and replenishment ships cross the oceans unescorted and unarmed.

The Navy seems to have belatedly recognized this with moves toward a new frigate to be based on one of the LCS designs, but even if they complete all 52 small surface combattants currently planned, less than half will be completed as frigates, and if based on the LCS designs, they will have limited range, survivability, and crew size. The Independence class LCS will likely be permanently employed as mine countermeasures (MCM) vessels (There were 22 of those in 1987). The Freedom class will likely be employed in enforcing a blockade (perhaps with help from Webber class WPCs). Even with some backfitting of LCS  25-32, that leaves at most 28 frigates in the current plan. 35 ASW equipped cutters could make a huge difference.

The Cutters:

Cutters should be designed with wartime roles in mind, even if they will not be initially fully equipped with combat systems.

In the Bertholf class and Offshore Patrol Cutters, we will have most of the elements of modern warships. To not be prepared to add the few systems necessary to make them effective warships, if the nation were engaged in combat, would be criminal. If we do not already have plans to upgrade the Bertholf class National Security Cutters and the Offshore Patrol Cutters to give them significantly improved ASW, AAW, and ASuW capability we should start those plans.

At some point perhaps we should prototype an installation of these capabilities on at least one NSC and one OPC. Then we need to wring them out by deploying with the Navy and getting feedback on their performance, and periodically update plans for mobilizing their war-time potential.

The People: 

Just as we have marine inspection, fisheries, and drug enforcement specialist, the Coast Guard needs a cadre of officers in the Office of Counter Terrorism and Defense Operations Policy (CG-ODO) who have a deep understanding of the needs of modern naval warfare, who will advocate for naval capabilities consistent with both wartime missions and the Ports, Waterways, and Coastal Security (PWCS) mission. Likely this means revival or strengthening of officer exchange programs, Tactical Action Officer training, and War College education.

Perhaps the longest lead time item in mobilizing the Coast Guard for war would be the senior enlisted we would need for rating not currently found in the peacetime Coast Guard. It might be possible for the Navy to identify some reservist to augment the crews of Coast Guard cutters upon mobilization, but even a small cadre within the Coast Guard, founded on prototyping systems on at least a couple of cutters would provide valuable continuity and advice in defining required capabilities.

Bottom Line–When we get in trouble, we cannot make it up as we go along. Sweat now, saves blood later.

Thanks to Lyle for bringing this to my attention.

Navy to Eliminate Rating System for Enlisted, CG to Follow?

The US Naval Institute News Service is reporting that the Navy will eliminate its 241 year old job specific rating system and move to a system more like that used by the Army, Air Force, and Marines.

I would assume the Coast Guard will follow suite. Changes to uniforms, schools, even the way petty officers are addressed.

The Navy will reportedly drop the Airman, Fireman, Seaman distinction for non-rates and call them all Seaman. Will we have Coast Guardsman Recruit, Coast Guardsman Apprentise, and Coast Guardsman as the new E-1, E-2, and E-3?

Personnel Reforms in the Wind

This is a DOD initiative, but it will likely effect the Coast Guard as well. According to this report from GlobalSecurity, Secretary of Defense Carter is looking to increase flexibility in the DOD’s personnel promotion and acquisition system for both military and civilians under what he calls the “Future Force Initiative.”

I would add that (based on some admittedly old observations) a lot of the federal government’s hiring problems are related to how long it takes to complete mandatory background checks. The best people will simply will not wait months for a job offer.