Waste Management:

DOD Has Generally Addressed Legislative Requirements on the Use of Burn Pits but Needs to Fully Assess Health Effects

GAO-16-781: Published: Sep 26, 2016. Publicly Released: Sep 26, 2016.

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What GAO Found

In assessing the Department of Defense's (DOD) March 2016 report to Congress on the use of burn pits, GAO found that it generally addressed the requirements in section 313 of the Carl Levin and Howard P. “Buck” McKeon National Defense Authorization Act (NDAA) for Fiscal Year (FY) 2015. To complete this report, DOD tasked the military services, the Joint Staff, and the overseas combatant commands to provide information on the requirements in the mandate, including policies and procedures related to the disposal of covered waste (including certain types of hazardous waste, medical waste, and items such as tires, treated wood, and batteries) in burn pits during contingency operations. GAO found that DOD's report fully addressed four of the seven reporting requirements and partially addressed the remaining three. For example, the report addressed who is responsible for ensuring compliance with the legislative requirements, but partially addressed whether the waste categories are appropriately and clearly distinguished in surveys and assessments.

Although DOD established guidance to meet applicable legislative requirements through the issuance of DOD Instruction 4715.19, U.S. Central Command is the only overseas geographic combatant command that has established complementary policies and procedures for implementing this guidance. The instruction applies to all the combatant commands, but it does not specify how combatant commanders will ensure compliance with requirements in the instruction. Officials from the other geographic combatant commands stated that their commands have not developed similar policies and procedures because they do not utilize burn pits and there is an absence of current contingency operations in their respective areas of responsibility. Nonetheless, while most of the overseas geographic commands may not currently be involved in contingency operations within their areas of responsibility, waste disposal would likely be required if such operations arise in the future, and the use of burn pits would be one option for disposing of waste. Establishing policies and procedures would better position these commands to implement DOD's instruction.

The effects of exposing individuals to burn pit emissions are not well understood, and DOD has not fully assessed these health risks. DOD officials stated that there are short-term effects from being exposed to toxins from the burning of waste. However, the officials also stated that DOD does not have enough data to confirm whether direct exposure to burn pits causes long-term health issues. Although DOD and the Department of Veterans Affairs have commissioned studies to enhance their understanding of burn pit emissions, the current lack of data on emissions specific to burn pits and related individual exposures limits efforts to characterize potential long-term health impacts on servicemembers and other base personnel. A 2011 report by the Institute of Medicine outlined the data needed for assessing exposures and potential related health risks, and the Department of Veterans Affairs has established a registry to collect some information. However, DOD has not undertaken data-gathering and research efforts to specifically examine this relationship to fully understand any associated health risks.

Why GAO Did This Study

Burn pits help base commanders manage waste generated by U.S. forces overseas, but they also produce harmful emissions that military and other health professionals believe may result in chronic health effects for those exposed. Section 313 of the NDAA for FY 2015 requires the Secretary of Defense to review DOD compliance with law and guidance regarding the disposal of covered waste in burn pits. DOD submitted a report on the results of its review in March 2016.

Section 313 also includes a provision for GAO to assess DOD's report and its compliance with applicable DOD instruction and law. This report evaluates the extent to which (1) DOD's report addressed the elements required in section 313; (2) DOD, including combatant commands, issued guidance for burn pit use that addresses applicable legislative requirements; and (3) DOD has assessed any health risks of burn pit use. GAO compared DOD's report to elements required in section 313, reviewed policies and procedures and interviewed DOD officials.

What GAO Recommends

GAO made three recommendations to include establishing policies and procedures and ensuring research specifically examines the relationship between direct burn pit exposure and long-term health issues. DOD concurred with the first recommendation and partially concurred with the second, citing research it has or has plans to conduct. GAO agrees this research contributes to general understanding but continues to believe more specific research is needed.

For more information, contact Cary Russell at (202) 512-5431 or RussellC@gao.gov.

Recommendations for Executive Action

  1. Status: Open

    Comments: DOD concurred with this recommendation. According to an update obtained in February 2018, DOD is in the process of updating DOD Instruction 4715.19 to better position commanders to implement requirements by requiring development of guidance and policy identifying responsibilities and procedures for compliance with the issue. The department expected that this would be completed by the third quarter of fiscal year 2018. However, as of August 2018, this had not yet been completed. We will continue to monitor the issue and update as necessary.

    Recommendation: To better position combatant commanders to implement the requirements of DOD Instruction 4715.19 if burn pits become necessary and to assist in planning for waste disposal in future military operations, the Secretary of Defense should direct the combatant commanders of U.S. Africa Command, U.S. European Command, U.S. Pacific Command, and U.S. Southern Command to establish implementation policies and procedures for waste management. Such policies and procedures should include, as applicable, specific organizations within each combatant command with responsibility for ensuring compliance with relevant policies and procedures, including burn pit notification, and, when appropriate, monitoring and reporting on the use of burn pits.

    Agency Affected: Department of Defense

  2. Status: Open

    Comments: DOD partially concurred with this recommendation. According to a DOD update received in February 2018, DOD continues to collaborate with the Department of Veterans Affairs and other entities on research activities that address burn pit and other airborne exposures and the potential long-term health outcomes. Since the completion of our report, DOD and the Department of Veterans Affairs have held an Airborne Hazards Symposium (May 2017) and have worked to complete a Airborne Hazards Joint Action Plan. Moreover, they are continuing their research efforts to examine airborne hazard exposures and potential health-related issues. According to DOD, there is no estimated completion date for this research since it will continue as needed for an undetermined amount of time. GAO will continue to monitor and update as appropriate.

    Recommendation: To better understand the long-term health effects of exposure to the disposal of covered waste in burn pits, the Secretary of Defense should direct the Under Secretary of Defense for Acquisition, Technology, and Logistics to, in coordination with the Secretary of Veterans Affairs, specifically examine the relationship between direct, individual, burn pit exposure and potential long-term health-related issues. As part of that examination, consider the results of the National Academies of Sciences, Engineering, and Medicine's report on the Department of Veteran Affairs registry and the methodology outlined in the 2011 Institute of Medicine study that suggests the need to evaluate the health status of service members from their time of deployment over many years to determine their incidence of chronic disease, with particular attention to the collection of data at the individual level, including the means by which that data is obtained.

    Agency Affected: Department of Defense

  3. Status: Open

    Comments: DOD partially concurred with this recommendation. According to an update received in February 2018, the department will be updating applicable DOD policies and procedures; its tactics, techniques and procedures manual; and its guidance for sampling and analysis plans to improve monitoring of burn pit and other airborne hazard emissions. The estimated completion date for this is first quarter of fiscal year 2019. GAO will continue to monitor and update as appropriate.

    Recommendation: To better understand the long-term health effects of exposure to the disposal of covered waste in burn pits, the Secretary of Defense should direct the Under Secretary of Defense for Acquisition, Technology, and Logistics to take steps to ensure United States Central Command and other geographic combatant commands, as appropriate, establish processes to consistently monitor burn pit emissions for unacceptable exposures.

    Agency Affected: Department of Defense

 

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