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Hazardous Waste: Improvements Needed in DOD's Contracting System for Disposal of Waste

NSIAD-91-131 Published: Aug 06, 1991. Publicly Released: Sep 11, 1991.
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Highlights

Pursuant to a congressional request, GAO determined whether the Department of Defense (DOD) adequately ensured: (1) the capability of transportation and disposal contractors; and (2) that hazardous waste generated by DOD installations reached the proper disposal site.

Recommendations

Recommendations for Executive Action

Agency Affected Recommendation Status
Department of Defense The Secretary of Defense, through the Director, Defense Logistics Agency, should direct DRMS to issue disposal contracts that require transporters of hazardous waste to have disposal facilities send tracking manifests directly to the DOD generator.
Closed – Not Implemented
DOD believes its controls will achieve the same purpose as suggested by GAO. DOD imposed requirements on contractors to obtain copies of manifests from downstream handlers to the point of disposal. DOD said that verification of receipt of the manifest by the generator would be difficult. GAO will consider this issue for follow-up work.
Department of Defense The Secretary of Defense should study the costs and the benefits of issuing separate contracts for transportation and disposal of hazardous waste.
Closed – Not Implemented
DOD does not agree that further study of costs and benefits of using separate contracts for transportation and disposal of hazardous waste is warranted. DOD believes that its varied needs do not warrant specialized contracts but rather more flexible contracts. DOD said that separating transportation from disposal contracts will multiply the number of contracts to be administered.
Department of Defense The Secretary of Defense, through the Director, Defense Logistics Agency, should direct DRMS to consider tracking hazardous waste to final disposal by not allowing transporters to use interim storage.
Closed – Not Implemented
DOD said that the use of interim storage is necessary to preclude impacting storage facilities at the generation site. DOD said that due to the multiple waste streams generated by DOD activities, as well as the remote locations of the generators, direct shipment to the treatment or disposal facility is unrealistic and cost prhibitive. GAO will consider this issue for followup work.
Department of Defense The Secretary of Defense, through the Director, Defense Logistics Agency, should direct DRMS to give high priority to audits of hazardous waste disposals.
Closed – Implemented
DOD concurred with the recommendation, but said that it is essentially moot, since DRMS has placed increased emphasis on compliance auditing. DOD said that quotas will be established for routine inspection of service contractors, with appropriate frequency of inspections for all contractors used, based on associated risks.
Department of Defense The Secretary of Defense should require that the changes to hazardous waste disposal practices be required of all DOD installations.
Closed – Implemented
DOD concurred with the recommendation. It will continue to improve hazardous waste disposal procedures and practices and disseminate this information throughout DOD. DOD will include guidance on compliance auditing in the comprehensive environmental instructions. This instruction for updating DOD environmental policy is being developed.

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Topics

Contract oversightContract performanceDefense procurementDepartment of Defense contractorsGovernment liability (legal)Hazardous substancesService contractsSmall business contractorsWaste collectionWaste disposal