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entitled 'Afghanistan and Iraq: DOD Should Improve Adherence to Its 
Guidance on Open Pit Burning and Solid Waste Management' which was 
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Report to Congressional Requesters: 

United States Government Accountability Office:
GAO: 

October 2010: 

Afghanistan and Iraq: 

DOD Should Improve Adherence to Its Guidance on Open Pit Burning and 
Solid Waste Management: 

GAO-11-63: 

GAO Highlights: 

Highlights of GAO-11-63, a report the chairman, House of 
Representatives Committee on Veteran's Affairs, and Senator Russell 
Feingold. 

Why GAO Did This Study: 

From the start of military operations in Afghanistan and Iraq, the 
U.S. military and its contractors have burned solid waste every day in 
open burn pits on or near military bases. According to the Department 
of Defense (DOD), burn pit emissions can contain toxic substances that 
harm human health. U.S. Central Command (CENTCOM) guidance directs the 
military’s use of burn pits, and the Department of Veterans’ Affairs 
(VA) collects data on servicemembers’ health as they separate from 
service. 

GAO was asked to report on the (1) extent of open pit burning in 
Afghanistan and Iraq, and whether the military has followed its 
guidance; (2) alternatives to burn pits, and whether the military has 
examined them; and (3) extent of efforts to monitor air quality and 
potential health impacts. 

GAO visited four burn pits in Iraq, reviewed DOD data on burn pits, 
and consulted DOD and VA officials and other experts. GAO was unable 
to visit burn pits in Afghanistan. 

What GAO Found: 

Open pit burning is the most prevalent waste disposal method in both 
conflicts, and operators of burn pits have not always followed 
relevant guidance to protect servicemembers from exposure to harmful 
emissions. According to DOD, U.S. military operations in Afghanistan 
and Iraq generate about 10 pounds of non-hazardous solid waste per 
soldier each day. The military has relied on open pit burning to 
dispose of this waste mainly because of its expedience. In August 
2010, CENTCOM estimated there were 221 burn pits in Afghanistan and 22 
in Iraq. CENTCOM officials said the number of burn pits is increasing 
in Afghanistan and decreasing in Iraq, which reflects U.S. troop 
reallocations and efforts to install waste incinerators. Despite its 
reliance on burn pits, CENTCOM did not issue comprehensive burn pit 
guidance until 2009. Furthermore, to varying degrees, operators of 
burn pits at four bases GAO visited in Iraq were not complying with 
key elements of this guidance, such as restrictions on the burning of 
items, including plastic, that produce harmful emissions. DOD health 
officials also said that, from the start of each conflict, operators 
routinely burned items that are now prohibited. The continued burning 
of prohibited items has resulted from a number of factors, including 
the constraints of combat operations, resource limitations, and 
contracts with burn pit operators that do not reflect current guidance. 

Waste management alternatives could decrease the reliance on and 
exposure to burn pits, but DOD has been slow to implement alternatives 
or fully evaluate their benefits and costs, such as avoidance of 
future costs associated with potential health effects. DOD guidance 
states that, as bases become established, they must shift to 
incinerators and waste minimization programs, such as source reduction 
and recycling. DOD has installed 41 solid waste incinerators in Iraq 
and 20 in Afghanistan as of June 2010, and plans to install additional 
incinerators in Afghanistan. To date, source reduction practices have 
not been implemented in either country and recycling consists 
primarily of large scrap metals. DOD plans to increase recycling at 
its bases in Iraq by September 2010, but has no similar plans for 
Afghanistan. Further, DOD has not analyzed its waste stream in either 
country and lacks the information to decrease the toxicity of its 
waste stream and enhance waste minimization. 

U.S. Forces in Afghanistan and Iraq do not sample or monitor burn pit 
emissions as provided by a key CENTCOM regulation, and the health 
impacts of burn pit exposure on individuals are not well understood, 
mainly because the military does not collect required data on 
emissions or exposures from burn pits. Army public health officials 
have, however, sampled the ambient air at bases in each conflict and 
found high levels of particle pollution that causes health problems 
but is not unique to burn pits. These officials identified logistical 
and financial challenges in monitoring burn pit emissions, and U.S. 
Forces have yet to finalize a required monitoring plan. DOD and VA 
have commissioned studies to enhance their understanding of burn pit 
emissions, but the lack of data on emissions specific to burn pits and 
related exposures limit efforts to characterize potential health 
impacts on service personnel, contractors, and host-country nationals. 

What GAO Recommends: 

Among other things, GAO recommends that the Secretary of Defense 
improve DOD’s adherence to relevant guidance on burn pit operations 
and waste management, and analyze alternatives to its current 
practices. In commenting on a draft of this report, DOD said that it 
concurred with five of the six recommendations and partially concurred 
with the sixth. GAO addressed a DOD suggestion to clarify the sixth 
recommendation. 

View [hyperlink, http://www.gao.gov/products/GAO-11-63] or key 
components. For more information, contact David C.Trimble, (202) 512-
3841, trimbled@gao.gov. 

[End of section] 

Contents: 

Letter: 

Background: 

Open Pit Burning Has Been the Prevalent Waste Disposal Method at 
Military Installations in Afghanistan and Iraq, but Burn Pit Operators 
Have Not Always Followed Relevant Guidance: 

Alternatives to Open Pit Burning Include Source Reduction, Recycling, 
Incinerators, and Land Fills, but DOD Has Not Evaluated Their Benefits 
or Costs: 

Neither U.S. Forces in Afghanistan nor Iraq Have Monitored Burn Pit 
Pollutants as Directed, and the Health Impacts of Burn Pit Exposure on 
Individuals Are Not Well Understood: 

Conclusions: 

Recommendations for Executive Action: 

Agency Comments and Our Evaluation: 

Appendix I: Objectives, Scope, and Methodology: 

Appendix II: Comments from the Department of Defense: 

Appendix III: GAO Contact and Staff Acknowledgments: 

Tables: 

Table 1: Comparison of CENTCOM, USFOR-A, MNC-I and DTM Burn Pit 
Guidance Relevant to Issues Congress Identified in the FY 2010 NDAA: 

Table 2: Examples of Four U.S. Bases' Implementation of CCR 200-2 Burn 
Pit Health Provisions, as of January 2010: 

Table 3: Waste Management Practices at U.S. Bases in Iraq: 

Table 4: Recycled Materials at U.S. Bases in Iraq as of June 22, 2010: 

Table 5: Number and Percentage of MEG Exceedances in Afghanistan by 
Analyzed Substance: 

Table 6: Number and Percentage of MEG Exceedances in Iraq by Analyzed 
Substance: 

Table 7: Examples of Selected Health Surveillance Activities Executed 
by Force Commanders or the Armed Services: 

Figures: 

Figure 1: Burn Pit at Camp Taji, Iraq, January 2010: 

Figure 2: Poor Air Quality at Camp Taji, Iraq, January 2010: 

Figure 3: Burn Pit at Camp Warhorse, Iraq, January 2010: 

Figure 4: Local Contractor's Personnel Sorting Solid Waste, Camp Taji, 
Iraq: 

Figure 5: Solid Waste Incinerator, Camp Al Asad, Iraq. 

Figure 6: Number of Ambient Air Samples Collected in Afghanistan, by 
Year: 

Figure 7: Number of Ambient Air Samples Collected in Iraq, by Year: 

Figure 8: Fine Particle Test Results in Afghanistan Relative to 
Military Exposure Guidelines: 

Figure 9: Fine Particle Test Results in Iraq Relative to Military 
Exposure Guideline: 

[End of section] 

Abbreviations: 

APHC: Army Public Health Command: 

CENTCOM: U.S. Central Command: 

CJTF: Combined Joint Task Force: 

DCAA: Defense Contract Audit Agency: 

DCMA: Defense Contract Management Agency: 

DOD: Department of Defense: 

DOEHRS: Defense Occupational and Environmental Health Readiness
System: 

FRAGO: fragmentary orders: 

ISAF: International Security Assistance Forces: 

KBR: Kellogg, Brown, and Root: 

LOGCAP: Logistics Civil Augmentation Program: 

MEG: Military Exposure Guidelines: 

MNC-I: Multi-National Corps-Iraq: 

MNF-I: Multinational Forces-Iraq: 

USARCENT: United States Army Central: 

USF-I: U.S. Forces-Iraq: 

USFOR-A: U.S. Forces-Afghanistan VA Department of Veterans Affairs: 

VOC: volatile organic compounds: 

[End of section] 

United States Government Accountability Office:
Washington, DC 20548: 

October 15, 2010: 

The Honorable Bob Filner: 
Chairman: 
Committee on Veterans Affairs: 
House of Representatives: 

The Honorable Russell D. Feingold: 
United States Senate: 

U.S. military operations in Afghanistan and Iraq generate about 10 
pounds of waste per service-member each day.[Footnote 1] This waste 
may consist of plastic, Styrofoam, and food from dining facilities; 
discarded electronics; shipping materials such as wooden pallets and 
plastic wrap; appliances; and other items such as mattresses, 
clothing, tires, metal containers, and furniture. [Footnote 2] The 
military must expeditiously handle this waste to avoid public health 
risks and other problems. Since the beginning of current military 
operations in Afghanistan in 2001 and Iraq in 2003, the Department of 
Defense (DOD) has disposed of waste in open burn pits, as well as in 
landfills and incinerators, on or near military installations. 
Generally, burn pits are either shallow excavations or surface 
features with berms used to conduct open burning. According to DOD, 
the oversight and operation of burn pits varies substantially across 
installations, with waste management decisions made largely by base 
commanders and carried out by military personnel, contractors, or a 
combination. 

Figure 1: Burn Pit at Camp Taji, Iraq, January 2010: 

[Refer to PDF for image: photograph] 

Source: GAO. 

[End of figure] 

Burn pits help base commanders manage waste, but also produce smoke 
and harmful emissions that military and other health professionals 
believe may result in acute and chronic health effects to those 
exposed. Some veterans returning from both conflicts have reported 
pulmonary and respiratory ailments, among other health concerns, that 
they attribute to burn pit emissions. Numerous veterans have also 
filed lawsuits against a DOD contractor alleging that the contractor 
mismanaged burn pit operations at several installations in both 
conflicts, resulting in exposure to harmful smoke that caused these 
adverse health effects. DOD's response to concerns about burn pits has 
evolved over time. In May 2008, DOD health officials said that burn 
pits did not cause health problems. In April 2009, DOD clarified this 
position and said burn pit emissions may cause problems for 
servicemembers with elevated individual susceptibilities, such as 
preexisting health conditions or genetic factors. DOD also noted that 
it would conduct testing and monitoring to determine the impacts. 

Because U.S. environmental laws such as the Clean Air Act and the 
Solid Waste Disposal Act do not generally apply overseas, the military 
has developed policies and procedures to guide solid waste management 
during contingency operations.[Footnote 3] In September 2009, the U.S. 
Central Command (CENTCOM)--the geographic combatant command whose area 
of responsibility includes Afghanistan and Iraq--developed policies 
and procedures to guide solid waste management in its area of 
responsibility, including minimum requirements for operating and 
monitoring burn pits. This guidance applies to military personnel and 
civilian contractors who operate burn pits in Afghanistan and Iraq. In 
addition, the military commands in Afghanistan and Iraq have developed 
burn pit guidance, designed to meet the unique needs of their 
respective areas of operation. In March 2010, DOD issued additional 
guidance that directs the Commanders of the combatant commands (such 
as CENTCOM) to make a formal determination that no alternative 
disposal method is feasible before potentially harmful waste, such as 
tires, treated wood, or batteries, can be burned in open-air pits. The 
Defense Contract Management Agency (DCMA) and the Defense Contract 
Audit Agency (DCAA) work with the military commands in both countries 
to oversee contractors' adherence to relevant guidance. CENTCOM has 
also developed guidance for the implementation of waste minimization 
practices, including alternative methods of waste disposal and 
recycling. 

This report responds to your request that we review burn pits in U.S. 
military installations in Afghanistan and Iraq. It addresses the 
following objectives: (1) determine the extent to which the U.S. 
military installations in Afghanistan and Iraq have used open pit 
burning and adhered to guidance governing their use; (2) identify 
alternatives to open pit burning and the extent to which DOD evaluated 
these alternatives; and (3) determine the extent to which U.S. forces 
have monitored the air quality, exposures, and potential health 
impacts of burn pit emissions in accordance with relevant guidance. 

To address the first objective, we reviewed relevant DOD guidance and 
U.S. military base records, and visited four burn pit sites in Iraq--
Al Asad, Marez, Taji, and Warhorse. At each site visited, we observed 
burn pit operations and interviewed military officials, preventive 
medicine personnel, and contractors, and reviewed inspection reports 
conducted by DCMA. We also visited one site in Iraq that exclusively 
used incinerators to dispose of solid waste. We considered several 
factors when selecting the locations of our site visits, such as 
whether the burn pit was managed by the military or a contractor and 
our ability to safely access the location, among others. Our findings 
from the site visits are not generalizable to other bases that we did 
not visit. We were unable to observe burn pit operations in 
Afghanistan. To address the second objective, we reviewed DOD guidance 
and planning documents on current and future uses of alternatives to 
open pit burning, DOD waste disposal studies, and relevant literature. 
We also observed burn pit alternatives during our site visits in Iraq 
and discussed them with DOD officials and contractors. In addition, we 
interviewed DOD officials in the United States regarding alternatives 
to burn pits in Afghanistan and Iraq. To address the third objective, 
we analyzed data on ambient air sampling in Afghanistan and Iraq 
conducted from 2005 through 2009. We assessed the reliability of these 
data and determined that they were sufficiently reliable for the 
purposes of this report. In addition, we analyzed DOD air sampling, 
health risk characterization, and health surveillance documents; as 
well as documents from the Department of Veterans Affairs (VA). We 
also interviewed DOD officials regarding air sampling efforts and 
officials from VA and DOD regarding efforts to study the potential 
health impacts of burn pit emissions. 

Lawsuits have been filed in federal court in at least 43 states in 
which current and former servicemembers have alleged, among other 
things, that a contractor's negligent management of burn pit 
operations, contrary to applicable contract provisions, exposed them 
to air pollutants that subsequently caused serious health problems. 
[Footnote 4] The contractor has moved to dismiss the suits, arguing, 
among other things, that it cannot be held liable for any injuries 
that may have occurred to service personnel because its burn pit 
activities occurred at the direction of the military. We express no 
view in this report on any issue in this pending litigation involving 
burn pits. Moreover, because of the pending litigation, we did not 
evaluate whether the contractor has complied with the terms of its 
contract with respect to burn pit operations. 

We conducted this performance audit from September 2009 to October 
2010, in accordance with generally accepted government auditing 
standards. Those standards require that we plan and perform the audit 
to obtain sufficient, appropriate evidence to provide a reasonable 
basis for our findings and conclusions based on our audit objectives. 
We believe that the evidence obtained provides a reasonable basis for 
our findings and conclusions based on our audit objectives. 

Background: 

This section describes the manner in which the U.S. military is 
organized to carry out its missions, how the military uses contractors 
to perform many essential services during contingency operations, and 
the existing air quality in Afghanistan and Iraq. 

U.S. Force Structure in Afghanistan and Iraq: 

The U.S. command structure in each nation has evolved over time. To 
perform its military missions around the world, DOD operates 
geographic combatant commands that conduct activities within assigned 
areas of responsibility. Combatant commanders oversee U.S. military 
operations that take place within their area of responsibility. 
CENTCOM is one of six geographic combatant commands, with an area of 
responsibility extending from the Middle East to Central Asia, 
including Afghanistan and Iraq. In Afghanistan, American forces fought 
as part of the International Security Assistance Forces (ISAF), a 
multinational strategic unit. The Combined Joint Task Force (CJTF), 
which was subordinate to ISAF, was responsible for the command and 
control of operations throughout Afghanistan. In 2009, the U.S. 
troops' designation became U.S. Forces-Afghanistan (USFOR-A). 
According to Administration estimates, as of August 2010, about 98,000 
American troops, including almost all of the 30,000 reinforcements 
that arrived in December 2009, were deployed in Afghanistan. The 
United States plans to begin withdrawing troops from Afghanistan in 
July 2011. 

American forces fighting in Iraq originally came under a similar dual 
command structure. Multinational Forces-Iraq (MNF-I) was the strategic 
component. It housed a multinational staff that included logistics, 
procurement, intelligence, combat operations, and engineering, among 
other things. The engineering staff, with input from health officials, 
had responsibility for developing the policies that governed the 
management of solid waste in Iraq. In addition, Multi-National Corps- 
Iraq (MNC-I) constituted the operations component of the Iraq command 
structure. It, too, had a multinational staff that roughly paralleled 
the MNF-I staff, although it focused more on day-to-day operational 
issues. On January 1, 2010, MNF-I and MNC-I merged to form U.S. Forces-
Iraq (USF-I).[Footnote 5] As of August 2010, about 70,000 American 
troops remained in Iraq, and by September 1, that number was scheduled 
to decline to 50,000. The United States' presence in Iraq is scheduled 
to end by December 2011. 

Contracting Process: 

The U.S. military relies on civilian contractors to provide supplies 
and services, including managing some burn pits, in support of its 
contingency operations in Afghanistan and Iraq. Kellogg, Brown, and 
Root (KBR) has provided burn pit services in Iraq through the 
Logistics Civil Augmentation Program (LOGCAP) III contract. On April 
18, 2008, DOD announced the Army had awarded LOGCAP IV contracts to 
DynCorp International, Fluor Intercontinental, and KBR. The transition 
of requirements from the LOGCAP III to the LOGCAP IV contracts is 
ongoing and will be used for combat support services in Afghanistan, 
including burn pit management.[Footnote 6] KBR retains responsibility 
for burn pit support in Iraq, as well as a role in aiding the 
transition of LOGCAP III to LOGCAP IV in Afghanistan. 

Typically, contractors such as KBR, DynCorp, and Fluor work under task 
orders. The task order process begins when a military customer, such 
as a commander in Afghanistan or Iraq, identifies a need, such as 
assistance in managing a burn pit. This need is documented in a task 
order statement of work, which establishes the specific tasks for the 
contractor, and the time frames for performance. In the case of 
contracting for burn pit support, the customer contacts its contract 
program management office (the contract office), which obtains a cost 
estimate from a contractor and provides the cost information to the 
customer. If the customer decides to use the contractor's services, 
the contract office obtains funding and finalizes the statement of 
work, and the contracting officer issues the task order and a notice 
to begin work. If the customer identifies a change in need, the 
process begins anew. 

Additionally, the military services, as well as DCMA, perform contract 
management functions to ensure the government receives quality 
services from contractors at the best possible prices. Customers 
identify and validate the requirements to be addressed and evaluate 
the contractor's performance, and ensure that the contract is used in 
economical and efficient ways. The contracting officer is responsible 
for providing oversight and management of the contract. The 
contracting officer may delegate some oversight and management 
functions to DCMA, which may then assign administrative contracting 
officers to provide on-site contract administration at deployed 
locations and to monitor contractor performance and management systems 
to ensure that the cost, product performance, and delivery schedules 
comply with the terms and conditions of the contract. DCMA 
administrative contracting officers may have limited knowledge of 
field operations. In these situations, DCMA normally uses contracting 
officers' technical representatives, who have been designated by their 
unit and appointed and trained by the administrative contracting 
officer. They provide technical oversight of the contractor's 
performance, but they cannot direct the contractor by making 
commitments or changes that affect any terms of the contract. 

Air Quality Conditions in Afghanistan and Iraq: 

Air pollution in Afghanistan and Iraq is generally high. For example, 
the level of particulate matter is higher in Afghanistan and Iraq than 
in the United States. Particulate matter includes coarse particles 
between 2.5 and 10 micrometers in diameter, as well as fine particles 
smaller than 2.5 micrometers. Particle pollution may contain a number 
of components, including acids, organic chemicals, metals, and soil or 
dust particles, according to EPA. The size of particles is directly 
linked to their potential for causing health problems. Both coarse and 
fine particles pass through the throat and nose and enter the lungs. 
Fine particles can also become deeply embedded in lung tissue. Health 
problems associated with particle pollution identified by EPA include 
irritation of the airways, coughing, or difficulty breathing; 
decreased lung function; aggravated asthma; development of chronic 
bronchitis; irregular heartbeat; nonfatal heart attacks; and premature 
death in people with heart or lung disease. According to DOD, sources 
of particulate matter include dust storms, dust from vehicle 
disturbance of the desert floor, emissions from local industries, and 
open pit burning conducted by Afghans, Iraqis, and American troops. 

Figure 2: Poor Air Quality at Camp Taji, Iraq, January 2010: 

[Refer to PDF for image: photograph] 

Source: GAO. 

[End of figure] 

Open Pit Burning Has Been the Prevalent Waste Disposal Method at 
Military Installations in Afghanistan and Iraq, but Burn Pit Operators 
Have Not Always Followed Relevant Guidance: 

Since the beginning of hostilities in Afghanistan (2001) and Iraq 
(2003), the military has relied heavily on open burn pits to dispose 
of the large quantities of solid waste generated at its installations, 
but CENTCOM did not develop comprehensive guidance on operating or 
monitoring burn pits until 2009, well after both conflicts were under 
way. Furthermore, our site visits and review of DCMA and contractor 
documentation found that burn pit operators did not always comply with 
this guidance. In addition, DOD health officials said that many items 
now prohibited from burn pits, such as plastics, have been routinely 
burned at U.S. military bases from the start of each conflict. 

DOD Relies Heavily on Burn Pits for Solid Waste Disposal in 
Afghanistan and Iraq: 

Prior to 2004, the military used burn pits exclusively to handle waste 
disposal needs in Afghanistan and Iraq. Beginning in 2004, the 
military began to introduce alternative waste disposal methods, such 
as incinerators, which grew in use from 2005 to 2010. For example, 
during that time the number of operational solid waste incinerators in 
Afghanistan increased from 1 to 20, while the number in Iraq grew from 
2 to 39.[Footnote 7] We discuss incineration issues and other 
alternatives to open pit burning in more detail later in this report. 
As of August 2010, there were more active burn pits in Afghanistan 
than operational incinerators, or any other method of waste disposal. 
The reverse is true in Iraq, although this shift from burn pits to 
incinerators occurred recently. According to senior DOD officials, the 
military relies on burn pits because of expedience--especially in the 
early phases of both wars when combat operations were most intense--as 
well as funding constraints, procurement challenges, security 
concerns, personnel turnover, and other factors. 

Although senior DOD officials said virtually every U.S. military 
installation in both countries has used burn pits, it is difficult to 
determine the number of burn pits in use at any given time. First, 
CENTCOM does not routinely collect such data. In fact, to respond to 
our request for information, CENTCOM had to query individual base 
commanders to determine the number of burn pits in each country. In 
addition, the exact number of active burn pits in both countries 
varies with fluctuations in the number of bases. As of April 2010, the 
U.S. military operated 163 bases in Afghanistan and 103 in Iraq, but, 
as U.S. troops leave Iraq and additional troops arrive in Afghanistan, 
the number of bases and burn pits in each country will change. In 
November 2009, CENTCOM reported 50 active burn pits in Afghanistan and 
67 in Iraq. However, by April 2010, those numbers had changed to 184 
and 52, respectively. By August 2010, there were 251 active burn pits 
in Afghanistan and 22 in Iraq. 

Bases in both countries also vary substantially in their size and in 
the scope of their operations, resulting in varying amounts of solid 
waste, which influences base commanders' selection of solid waste 
disposal methods. For example, large bases may house 35,000 or more 
U.S. servicemembers, as well as thousands of U.S. civilian contractors 
and host country nationals, while a smaller outpost such as a patrol 
base may house only about 150 troops. Relatively small bases, such as 
patrol bases, are likely to rely on open burning for their solid waste 
disposal needs. Major bases, such as Bagram (Afghanistan) and Balad 
(Iraq), also may employ alternative solid waste disposal methods, such 
as incinerators, to handle a substantial portion of their solid waste. 

CENTCOM Did Not Develop Comprehensive Burn Pit Guidance until 2009: 

Although DOD has long recognized that burning waste in open pits is 
not environmentally acceptable--for example, June 1978 waste 
management guidance states that burning in open fires is not a method 
of disposal, except in limited situations--CENTCOM and its subordinate 
commands did not provide comprehensive guidance on managing and 
operating burn pits or minimizing associated dangers until 2009. 
Earlier guidance was largely limited to noting the inherent dangers of 
open burning and suggesting that various alternatives--such as 
landfills and pollution prevention--be used instead. An Army Technical 
Bulletin on Guidelines for Field Waste Management, issued in September 
2006, notes that troops should use open burning only in "emergency 
situations," because it can lead to "significant environmental 
exposures." However, this bulletin provides only minimal guidance on 
lessening the acknowledged risks associated with such burning and 
avoiding exposure of servicemembers, civilian contractors, and local 
nationals to those risks. 

According to a former senior military engineer stationed in Baghdad 
from 2005 to 2006, the lack of specific burn pit guidance may have 
been, at least in part, because the command structure in Iraq did not 
have the engineering expertise on-hand to develop such guidance, and 
because it was not clear organizationally which command unit--
engineers or health professionals--were responsible for developing 
such guidance. As a result, MNC-I policies and procedures did not 
emphasize solid waste management. When MNC-I established a dedicated 
engineering staff in 2005, it began developing more comprehensive 
environmental policies for Iraq, with advice from the Army Public 
Health Command. According to the former senior military engineer, the 
dedicated engineering staff included about 100 engineers, with about 
20 to 30 staff--including one environmental specialist--focusing on 
environmental guidance for Iraq. 

In 2006, the engineering staff developed environmental policies to 
cover each of the environmental issues of concern, including hazardous 
and solid wastes, among other things. CENTCOM issued these policies as 
fragmentary orders (FRAGO) to U.S. forces operating in Iraq. The solid 
waste FRAGO included limited guidance on burn pit operations. These 
FRAGOs were consolidated into a single document entitled MNC-I 
Environmental Standard Operating Procedure 2006 that discouraged the 
use of burn pits as a method of waste disposal. The guidance included 
suggested environmental practices, such as the segregation of waste 
that could facilitate reuse and recycling efforts. However, MNC-I 
Environmental Standard Operating Procedure 2006 did not include 
comprehensive policies for operating or monitoring burn pits. 

In April 2009, MNC-I revised the 2006 guidance to standardize 
procedures for environmental compliance and to provide environmental 
guidance to U.S. forces and their support units, including civilian 
contractors, operating in Iraq. MNC-I Environmental Standard Operating 
Procedure 2009 provides specific guidance for the handling of solid 
waste during contingency operations, including emphases on source 
reduction, waste minimization, and recycling to reduce the amount of 
solid waste requiring disposal. It also describes burn pits as an 
expedient means to destroy solid waste during contingency operations. 
However, the guidance notes that open burning is forbidden unless the 
base commander authorizes it in writing. In addition, it provides 
guidance on siting burn pits, securing them, managing burn pit ash, 
and overseeing open burning, among other things. In particular, it 
details waste items prohibited from destruction in burn pits, 
including hazardous waste, batteries, tires, electronics, and 
appliances, among other things. 

In September 2009, USFOR-A issued guidance to provide overarching 
environmental direction and best management practices for use during 
contingency operations in Afghanistan, including specific instructions 
for operating burn pits. According to senior military officers, the 
issuance of this guidance coincided with the arrival of a Joint Force 
Engineer Command in Afghanistan. Similar to the 2006 and 2009 MNC-I 
guidance, the September 2009 USFOR-A guidance stipulates that open 
burning is the least preferred method of solid waste disposal and that 
troops should use it only until they can develop more suitable 
capabilities. According to this USFOR-A guidance, the ultimate goal 
for enduring bases in Afghanistan is to transition to composting and 
recycling, to nearly eliminate the need for all forms of incineration, 
including burn pits. Further, this guidance states that, while U.S. 
forces may use burn pits early in contingency operations as an 
expedient way to control waste, "open burning will not be the regular 
method of solid waste disposal." It also establishes several criteria 
to control and manage the air emissions associated with burn pit 
operations, including general guidelines for burning and a list of 
prohibited items. Some of the USFOR-A prohibited items mirror those 
from MNC-I. For example, both lists include hazardous waste, and 
tires. However, USFOR-A guidance also includes pesticide containers, 
asphalt shingles, treated wood, and electrical wires, among other 
things, not included in the September 2009 MNC-I guidance. The MNC-I 
guidance directs plastics to be segregated for recycling, while the 
USFOR-A guidance explicitly bans plastics from burn pits. 

Also in September 2009, CENTCOM issued Regulation 200-2 to provide 
environmental guidance and best management practices for U.S. bases in 
CENTCOM's area of responsibility during contingency operations. The 
regulation provides U.S. military and civilian personnel detailed 
guidance for managing environmental concerns, such as hazardous 
materials, regulated medical waste, spill response, and solid waste, 
among other things. According to CENTCOM officials, the regulation 
provides the minimal acceptable standards for solid waste disposal, 
including burn pit operations, for all U.S. bases under its command 
including those in Afghanistan and Iraq. The regulation applies to all 
CENTCOM elements engaged in contingency operations throughout 
CENTCOM's area of responsibility, including all servicemembers, DOD 
civilians, and DOD contractors. According to CENTCOM officials, U.S. 
installations may adopt more stringent directions than those in 
CENTCOM's 2009 regulation if local commanders deem them necessary. 

According to CENTCOM officials, one of the main reasons for developing 
its 2009 regulation was to codify and expand the burn pit requirements 
in MNC-I Environmental Standard Operating Procedure 2009 and USFOR-A 
Standard Operating Procedure 2009. CENTCOM officials said that a 
CENTCOM regulation carries more weight and, thus, is more easily 
enforced than subordinate commands' standard operating procedures. 
Further, CENTCOM's 2009 regulation states that subordinate command 
guidance may be used when base commanders deem "additional 
environmental guidance" necessary to "supplement" the regulation. As 
such, subordinate command guidance provides commanders in Afghanistan 
and Iraq flexibility to increase waste disposal requirements to meet 
unique needs in their respective areas of operation, as long as they 
meet the minimum direction in the regulation. 

In October 2009, Congress passed the National Defense Authorization 
Act (NDAA) for Fiscal Year 2010.[Footnote 8] Section 317 of the act 
requires the Secretary of Defense to prescribe regulations prohibiting 
the disposal of covered waste in open-air burn pits during contingency 
operations except in circumstances in which the Secretary of Defense 
determines that no alternative disposal method is feasible. In March 
2010, in response to section 317 of the NDAA, DOD issued Directive-
type Memorandum (DTM) 09-032 prohibiting the disposal of covered waste 
in open-air burn pits during contingency operations except when the 
relevant commander of a combatant command makes a formal determination 
that no alternative disposal method is feasible.[Footnote 9] 

According to DTM 09-032, once the relevant field commander makes such 
a determination, the commander must forward the determination in 
writing to the Under Secretary of Defense for Acquisition, Technology, 
and Logistics so that it arrives within 15 calendar days of making the 
determination. The Under Secretary is to submit the determination to 
the Senate and House Armed Services Committees within 30 days of the 
commander's decision. The commander must also provide a written 
justification to the Under Secretary to continue open-air burning for 
each subsequent 180-day period during which the base plans to burn 
covered waste in burn pits. The Under Secretary must also forward 
these justifications to the Senate and House Armed Services Committees. 

A senior DOD official said despite the prohibitions in CENTCOM's 2009 
Regulation, information gathered from field commanders led him to 
conclude that disposal of prohibited items in burn pits had become 
routine at many bases in Afghanistan and Iraq. According to this 
senior official, the DTM 09-032 exception process may provide 
incentives for field commanders to seek and employ alternatives to 
burn pits rather than have them attempt to justify continued burning. 
Except for the covered waste exemption process, the DTM does not 
differ significantly from the guidance provided in CENTCOM's 2009 
regulation. In August 2010, senior DOD officials said no field 
commanders in Afghanistan or Iraq had sought permission to burn 
covered waste in burn pits. 

According to a senior DOD official, the DTM is a worldwide policy that 
applies to all DOD components, including CENTCOM. As a result, CENTCOM 
must comply with DTM 09-032 and to the extent CENTCOM's 2009 
regulation does not conflict with the DTM, any additional measures in 
the regulation. The DTM directive for a Commander of a Combatant 
Command to make a formal determination that there is no feasible 
alternative to disposing of covered waste in a burn pit and the 
associated congressional notification applies only to wastes covered 
under the DTM. However, burn pit management in CENTCOM's area of 
responsibility must adhere to both documents. Thus, for example, 
CENTCOM's 2009 regulation's list of items prohibited from burn pits 
remains in effect, even though it is not identical to the list of 
covered wastes in the DTM. While the multiple guidance documents--
including those unique to each conflict as well as the CENTCOM 
guidance and the DTM--may be necessary to comprehensively direct the 
operation of burn pits, an operator of a burn pit would have to 
consult at least three guidance documents to ensure proper management 
of that burn pit. 

Table 1 compares the key elements of burn pit guidance developed by 
CENTCOM, USFOR-A, MNC-I, and DTM 09-032 that are relevant to the 
issues Congress identified in NDAA section 317. 

Table 1: Comparison of CENTCOM, USFOR-A, MNC-I and DTM Burn Pit 
Guidance Relevant to Issues Congress Identified in the FY 2010 NDAA: 

Guidance elements: Burn pits recognized as producing unhealthy air 
emissions; 
MNC-I (2009): [Empty]; 
USFOR-A (2009): [Check]; 
CCR 200-2 (2009): [Check]; 
DTM (2010): l. 

Pre-burn activities: Examine and sort waste to ensure prohibited items 
are not present; 
MNC-I (2009): [Check]; 
USFOR-A (2009): [Empty]; 
CCR 200-2 (2009): [Check]; 
DTM (2010): [Empty]. 

Pre-burn activities: Waste minimization/recycling required or strongly 
encouraged; 
MNC-I (2009): [Check]; 
USFOR-A (2009): [Check]; 
CCR 200-2 (2009): [Check]; 
DTM (2010): [Empty]. 

Duration of burn pit use: Burn pits are expedient in early phases of 
contingency operations; 
MNC-I (2009): [Empty]; 
USFOR-A (2009): [Check]; 
CCR 200-2 (2009): [Check]; 
DTM (2010): l. 

Duration of burn pit use: Burn pits are to be used as contingency 
operations begin, but use must be terminated as soon as practical; 
MNC-I (2009): [Empty]; 
USFOR-A (2009): [Check]; 
CCR 200-2 (2009): [Check]; 
DTM (2010): [Empty]. 

Duration of burn pit use: Long-term use of burn pits is discouraged; 
MNC-I (2009): [Empty]; 
USFOR-A (2009): [Check]; 
CCR 200-2 (2009): [Check]; 
DTM (2010): l. 

General burning guidelines: Burn pits should be sited so prevailing 
winds carry smoke away from occupied areas; 
MNC-I (2009): [Check]; 
USFOR-A (2009): [Check]; 
CCR 200-2 (2009): [Check]; 
DTM (2010): [A]. 

General burning guidelines: Minimize amount of dirt to reduce 
smoldering; 
MNC-I (2009): [Empty]; 
USFOR-A (2009): [Check]; 
CCR 200-2 (2009): [Check]; 
DTM (2010): [Empty]. 

General burning guidelines: Upon completion of burn, pit should be 
extinguished to limit smoldering; 
MNC-I (2009): [Empty]; 
USFOR-A (2009): [Check]; 
CCR 200-2 (2009): [Check]; 
DTM (2010): [Empty]. 

General burning guidelines: Minimize wet waste to reduce smoldering--
never more than 25 percent of total; 
MNC-I (2009): [Empty]; 
USFOR-A (2009): [Check]; 
CCR 200-2 (2009): [Check]; 
DTM (2010): [Empty]. 

Monitoring requirements: Burn pit emissions should be monitored; 
MNC-I (2009): [Empty]; 
USFOR-A (2009): [Check]; 
CCR 200-2 (2009): [Check]; 
DTM (2010): l. 

Monitoring requirements: Monitored emissions should include: dioxins, 
polycyclic aromatic hydrocarbons, volatile organic compounds, carbon 
monoxide, hexachlorobenzene, and particulate matter; 
MNC-I (2009): [Empty]; 
USFOR-A (2009): [Check]; 
CCR 200-2 (2009): [Check]; 
DTM (2010): [Empty]. 

Monitoring requirements: High levels of pollutants must be analyzed to 
determine cause and resolution; 
MNC-I (2009): [Empty]; 
USFOR-A (2009): [Check]; 
CCR 200-2 (2009): [Check]; 
DTM (2010): [Empty]. 

Monitoring requirements: Potential exposure to unhealthy emissions 
should be documented; 
MNC-I (2009): [Empty]; 
USFOR-A (2009): [Check]; 
CCR 200-2 (2009): [Check]; 
DTM (2010): [Empty]. 

Monitoring requirements: Burn pit ashes must be secured and tested for 
hazardousness; 
MNC-I (2009): [Empty]; 
USFOR-A (2009): [Check]; 
CCR 200-2 (2009): [Check]; 
DTM (2010): [Empty]. 

Items prohibited from burn pits: 

All hazardous waste/material; 
MNC-I (2009): [Check]; 
USFOR-A (2009): [Check]; 
CCR 200-2 (2009): [Check]; 
DTM (2010): l. 

Petroleum, oil, and lubricant products; 
MNC-I (2009): [Check]; 
USFOR-A (2009): [Check]; 
CCR 200-2 (2009): [Check]; 
DTM (2010): l. 

Rubber; 
MNC-I (2009): [Empty]; 
USFOR-A (2009): [Check]; 
CCR 200-2 (2009): [Check]; 
DTM (2010): [Empty]. 

Tar paper; 
MNC-I (2009): [Empty]; 
USFOR-A (2009): [Check]; 
CCR 200-2 (2009): [Check]; 
DTM (2010): [Empty]. 

Asphalt shingles; 
MNC-I (2009): [Empty]; 
USFOR-A (2009): [Check]; 
CCR 200-2 (2009): [Check]; 
DTM (2010): [Empty]. 

Tires; 
MNC-I (2009): [Check]; 
USFOR-A (2009): [Check]; 
CCR 200-2 (2009): [Check]; 
DTM (2010): l. 

Treated wood; 
MNC-I (2009): [Empty]; 
USFOR-A (2009): [Check]; 
CCR 200-2 (2009): [Check]; 
DTM (2010): l. 

Pesticides/pesticide containers; 
MNC-I (2009): [Empty]; 
USFOR-A (2009): [Check]; 
CCR 200-2 (2009): [Check]; 
DTM (2010): [Empty]. 

Asbestos-containing material; 
MNC-I (2009): [Check]; 
USFOR-A (2009): [Check]; 
CCR 200-2 (2009): [Check]; 
DTM (2010): l. 

Coated electrical wires; 
MNC-I (2009): [Empty]; 
USFOR-A (2009): [Check]; 
CCR 200-2 (2009): [Check]; 
DTM (2010): [Empty]. 

Plastic; 
MNC-I (2009): [B]; 
USFOR-A (2009): [Check]; 
CCR 200-2 (2009): [Check]; 
DTM (2010): l. 

Aerosol cans; 
MNC-I (2009): [Check]; 
USFOR-A (2009): [Empty]; 
CCR 200-2 (2009): [Check]; 
DTM (2010): l. 

Gas cylinders; 
MNC-I (2009): [Check]; 
USFOR-A (2009): [Empty]; 
CCR 200-2 (2009): [Check]; 
DTM (2010): l. 

Fuel cans; 
MNC-I (2009): [Check]; 
USFOR-A (2009): [Empty]; 
CCR 200-2 (2009): [Empty]; 
DTM (2010): l. 

Explosives; 
MNC-I (2009): [Check]; 
USFOR-A (2009): [Check]; 
CCR 200-2 (2009): [Check]; 
DTM (2010): l. 

Metal larger than a 24-ounce can; 
MNC-I (2009): [Check]; 
USFOR-A (2009): [Empty]; 
CCR 200-2 (2009): [Empty]; 
DTM (2010): [Empty]. 

Batteries; 
MNC-I (2009): [Check]; 
USFOR-A (2009): [C]; 
CCR 200-2 (2009): [Check]; 
DTM (2010): l. 

Appliances; 
MNC-I (2009): [Check]; 
USFOR-A (2009): [Empty]; 
CCR 200-2 (2009): [Check]; 
DTM (2010): [Empty]. 

Electrical equipment; 
MNC-I (2009): [Check]; 
USFOR-A (2009): [Empty]; 
CCR 200-2 (2009): [Check]; 
DTM (2010): [Empty]. 

Regulated Medical waste; 
MNC-I (2009): [Check]; 
USFOR-A (2009): [E]; 
CCR 200-2 (2009): [Check]; 
DTM (2010): l. 

Paint and paint thinners/strippers; 
MNC-I (2009): [D]; 
USFOR-A (2009): [Empty]; 
CCR 200-2 (2009): [Check]; 
DTM (2010): [Empty]. 

Any material that creates unreasonable amount of smoke, fumes, or 
hazardous air pollutants; 
MNC-I (2009): [Check]; 
USFOR-A (2009): [Check]; 
CCR 200-2 (2009): [Check]; 
DTM (2010): [Empty]. 

Unexploded ordnance; 
MNC-I (2009): [Check]; 
USFOR-A (2009): [Empty]; 
CCR 200-2 (2009): [Check]; 
DTM (2010): [Empty]. 

Source: GAO analysis of DOD data. 

Note: MNC-I 2009, USFOR-A 2009, and CCR 200-2 each define "hazardous 
waste" to include any waste exhibiting any of four hazardous 
characteristics: ignitability, corrosivity, reactivity, or 
flammability. Thus, wastes in the above table that exhibit these 
characteristics would be banned from disposal in burn pits even if 
they are not specifically discussed in the relevant guidance document. 
Similarly, the DTM adopts the RCRA statutory definition of hazardous 
waste, which includes wastes that pose a health or environmental 
threat because of concentration, or physical, chemical, or infectious 
characteristics. 42 U.S.C. § 6903(5). 

[A] DTM 09-032 does not explicitly state that burn pits should be 
sited so prevailing winds carry smoke away from occupied areas; 
however, it says burn pits should be located to prevent or minimize 
exposures to personnel in living, dining, and work areas. 

[B] MNC-I 2009 standard operating procedures do not explicitly ban 
plastic from burn pits, but do encourage the separation of plastic for 
recycling. 

[C] USFOR-A 2009 standard operating procedures identify some batteries 
as hazardous waste, thereby making them prohibited from burn pits. 

[D] MNC-I 2009 standard operating procedures do not explicitly 
prohibit paint and paint thinners/strippers from burn pits, but they 
are prohibited from solid waste receptacles. 

[E] USFOR-A 2009 standard operating procedures do not explicitly 
prohibit regulated medical waste from burn pits, but the guidance does 
establish separate procedures for its disposal. 

[End of table] 

DOD Has Not Ensured That Burn Pit Operators Consistently Followed 
Guidance: 

Military commanders and CENTCOM officials acknowledged that U.S. 
forces did not always adhere to relevant guidance concerning burn pits 
and that prior to 2009, many items CENTCOM's 2009 regulation now 
prohibits from burn pits, including regulated medical waste, hazardous 
waste, and plastic, were routinely disposed of in burn pits. The Army 
has also reported that live ammunition and unexploded ordnance have 
been inadvertently discarded in some burn pits. However, according to 
these officials, options for waste disposal, other than burning, were 
limited early in both wars. This was particularly true when combat 
operations were under way, as troop safety and mission success 
outweighed environmental concerns. However, DOD officials said that, 
as threat levels decreased, the military began working to replace burn 
pits with more environmentally sound methods of waste disposal. 

Between January to March 2010, we determined that, to varying degrees, 
the four burn pits we visited at bases in Iraq--one operated by 
military personnel and three operated by contractor personnel--were 
not managed in accordance with CENTCOM's 2009 regulation.[Footnote 10] 
For example, we determined that operators at all four of these burn 
pits burned varying amounts of plastic--a prohibited item that, 
according to EPA, can produce carcinogens when burned. The burn pit at 
Al Asad appeared to contain only trace amounts of plastic. At Camp 
Warhorse, burn pit operators said that, despite a limited program to 
sort the camp's waste, they did not sort plastic prior to burning. We 
found similar variability in the bases' use of incinerators. For 
example, Al Asad and Taji had solid waste incinerators to supplement 
their burn pits, but Marez and Warhorse did not. Although all four 
bases had programs in place to sort waste prior to burning in an 
effort to avoid burning prohibited material, Al Asad devoted 
substantially more resources to sorting waste than the other bases. 
Where waste was sorted, fewer prohibited items should have made their 
way into the burn pit which likely decreased the potentially harmful 
emissions from the burn pit. Conversely, where there was no sorting 
and less adherence to the key health protection provisions of 
CENTCOM's 2009 regulation, many U.S. personnel--both military and 
civilian--could have faced greater risks from exposure to burn pit 
emissions in their day-to-day activities. 

Figure 3: Burn Pit at Camp Warhorse, Iraq, January 2010: 

[Refer to PDF for image: photograph] 

Source: GAO. 

Note: This photograph shows the Warhorse burn pit immediately prior to 
U.S. personnel setting it afire in January 2010. The pit contains 
electric wire, plastic, and unopened trash bags--all prohibited from 
burn pit disposal under CENTCOM's 2009 regulation and/or MNC-I 
Environmental Standard Operating Procedure 2009. 

[End of figure] 

Table 2 provides our analysis of each base's adherence to CENTCOM's 
2009 regulation health-related burn pit provisions. 

Table 2: Examples of Four U.S. Bases' Implementation of CCR 200-2 Burn 
Pit Health Provisions, as of January 2010: 

CENTCOM Reg. 200-2 Guidance Element: Pre-burn activities: 

Examine and sort waste to ensure prohibited items are not present; 
AL ASAD contractor: Implemented; 
MAREZ contractor: Implemented; 
TAJI contractor: Implemented; 
WARHORSE military: Implemented. 

CENTCOM Reg. 200-2 Guidance Element: Duration of burn pit use: 

Burn pits are to be used as contingency operations begin, but must be 
replaced by incinerators when practical; 
AL ASAD contractor: Implemented; 
MAREZ contractor: Not implemented; 
TAJI contractor: Implemented; 
WARHORSE military: Not implemented;. 

CENTCOM Reg. 200-2 Guidance Element: General burning guidelines: 

Burn pits should be sited so prevailing winds carry smoke away from 
occupied areas; 
AL ASAD contractor: [B]; 
MAREZ contractor: [B]; 
TAJI contractor: Not implemented; 
WARHORSE military: Implemented. 

Minimize amount of dirt to reduce smoldering; 
AL ASAD contractor: [B]; 
MAREZ contractor: [B]; 
TAJI contractor: [B]; 
WARHORSE military: [B]. 

Minimize wet waste to reduce smoldering--never more than 25 percent of 
total; 
AL ASAD contractor: [B]; 
MAREZ contractor: [B]; 
TAJI contractor: [B]; 
WARHORSE military: [B]. 

Monitoring requirements: 

Burn pit emissions should be monitored; 
AL ASAD contractor: Not implemented; 
MAREZ contractor: Not implemented; 
TAJI contractor: Not implemented; 
WARHORSE military: Not implemented. 

Monitored emissions should include: dioxins, polycyclic aromatic 
hydrocarbons, volatile organic compounds, carbon monoxide, 
hexachlorobenzene, and particulate matter; 
AL ASAD contractor: Not implemented; 
MAREZ contractor: Not implemented; 
TAJI contractor: Not implemented; 
WARHORSE military: Not implemented. 

High levels of pollutants must be analyzed to determine cause and 
resolution; 
AL ASAD contractor: Not implemented; 
MAREZ contractor: Not implemented; 
TAJI contractor: Not implemented; 
WARHORSE military: Not implemented. 

Potential exposure to unhealthy emissions should be documented; 
AL ASAD contractor: Not implemented; 
MAREZ contractor: Not implemented; 
TAJI contractor: Not implemented; 
WARHORSE military: Not implemented. 

Alternatives in use: 

Incinerators; 
AL ASAD contractor: Implemented; 
MAREZ contractor: Not implemented; 
TAJI contractor: Implemented; 
WARHORSE military: Not implemented. 

Recycling program; 
AL ASAD contractor: Implemented; 
MAREZ contractor: Implemented; 
TAJI contractor: Not implemented; 
WARHORSE military: Not implemented. 

Landfill; 
AL ASAD contractor: Implemented; 
MAREZ contractor: Implemented; 
TAJI contractor: Not implemented; 
WARHORSE military: Not implemented. 

Prohibited items: 

All hazardous waste/material; 
AL ASAD contractor: Implemented; 
MAREZ contractor: Implemented; 
TAJI contractor: [A]; 
WARHORSE military: Implemented. 

Petroleum, oil and lubricant products; 
AL ASAD contractor: Implemented; 
MAREZ contractor: Implemented; 
TAJI contractor: [A]; 
WARHORSE military: Implemented. 

Rubber; 
AL ASAD contractor: Implemented; 
MAREZ contractor: Implemented; 
TAJI contractor: [A]; 
WARHORSE military: Implemented. 

Tar paper; 
AL ASAD contractor: Implemented; 
MAREZ contractor: Implemented; 
TAJI contractor: [A]; 
WARHORSE military: Implemented. 

Asphalt shingles; 
AL ASAD contractor: Implemented; 
MAREZ contractor: Implemented; 
TAJI contractor: [A]; 
WARHORSE military: Implemented. 

Tires; 
AL ASAD contractor: Implemented; 
MAREZ contractor: Implemented; 
TAJI contractor: [A]; 
WARHORSE military: Implemented. 

Treated wood; 
AL ASAD contractor: Implemented; 
MAREZ contractor: Implemented; 
TAJI contractor: [A]; 
WARHORSE military: Implemented. 

Pesticides/pesticide containers; 
AL ASAD contractor: Implemented; 
MAREZ contractor: Implemented; 
TAJI contractor: [A]; 
WARHORSE military: Implemented. 

Asbestos-containing material; 
AL ASAD contractor: Implemented; 
MAREZ contractor: Implemented; 
TAJI contractor: [A]; 
WARHORSE military: Implemented. 

Coated electrical wires; 
AL ASAD contractor: Implemented; 
MAREZ contractor: Not implemented; 
TAJI contractor: [A]; 
WARHORSE military: Not implemented. 

Plastic; 
AL ASAD contractor: Not implemented; 
MAREZ contractor: Not implemented; 
TAJI contractor: Not implemented; 
WARHORSE military: Not implemented. 

Aerosol cans; 
AL ASAD contractor: Not implemented; 
MAREZ contractor: Not implemented; 
TAJI contractor: [A]; 
WARHORSE military: Not implemented. 

Paint; 
AL ASAD contractor: Implemented; 
MAREZ contractor: Not implemented; 
TAJI contractor: [A]; 
WARHORSE military: Implemented. 

Batteries; 
AL ASAD contractor: Implemented; 
MAREZ contractor: Not implemented; 
TAJI contractor: [A]; 
WARHORSE military: Not implemented. 

Appliances; 
AL ASAD contractor: Implemented; 
MAREZ contractor: Implemented; 
TAJI contractor: [A]; 
WARHORSE military: Implemented. 

Electronics; 
AL ASAD contractor: Implemented; 
MAREZ contractor: Not implemented; 
TAJI contractor: [A]; 
WARHORSE military: Not implemented. 

Regulated Medical waste; 
AL ASAD contractor: Implemented; 
MAREZ contractor: Implemented; 
TAJI contractor: [A]; 
WARHORSE military: Not implemented;. 

Unexploded ordnance; 
AL ASAD contractor: Implemented; 
MAREZ contractor: Implemented; 
TAJI contractor: [A]; 
WARHORSE military: Not implemented;. 

Source: GAO observations and analysis. 

Implemented: in accordance with CENTCOM Regulation 200-2. 

Not implemented: in accordance with CENTCOM Regulation 200-2. 

[A] KBR officials at Taji said the company does not maintain data on 
items burned in the Taji burn pit because it is not contractually 
required to do so. However, KBR employees told us they do burn plastic 
at Taji. 

[B] Data not available. Neither our observations nor interviews with 
burn pit managers at these locations were able to determine the extent 
to which they implemented these aspects of CENTCOM Regulation 200-2. 

[End of table] 

The variability in implementation of CENTCOM's 2009 regulation at the 
bases we visited stems from several causes. First, environmental 
officials at two of the four Iraq bases we visited--Taji and Warhorse--
said they were unaware of the regulation and its provisions for burn 
pit operations. For example, the two servicemembers who managed the 
Warhorse burn pit said they were not aware of the regulation or MNC-I 
Environmental Standard Operating Procedure 2009. To manage the 
Warhorse burn pit, they used a standard operating procedure document 
provided to them when they began managing the burn pit in August 2009. 
According to one of the servicemembers, the main purpose of this 
guidance was to direct their dealings with contractors delivering 
waste to the burn pit. Without an awareness or understanding of 
relevant guidance, burn pit operators are limited in their ability to 
minimize the risks of exposure to potentially harmful burn pit 
emissions. 

Second, adherence to the regulation and other guidance is difficult, 
according to DOD and CENTCOM officials, because many of the supplies 
arriving on U.S. bases are either made of, or packaged in, materials 
that are prohibited from burn pits. For example, drinking water 
arrives in plastic bottles, shrink wrapped in plastic. By procuring 
supplies wrapped in plastic, the military installations face a 
challenge in disposing of a material that its guidance prohibits from 
disposing in the burn pits. 

Third, the contractor operating the burn pits at two bases we visited 
did not have contracts reflecting current guidance. Senior 
representatives of this contractor told us that, at the time their 
company negotiated its contract to manage burn pits for the military 
in Iraq, MNC-I Environmental Standard Operating Procedure 2006 was the 
most recent guidance. Thus their company provided Iraq burn pit 
management activities in the context of that guidance, which contained 
less stringent direction than the 2009 regulation. According to the 
contractor's representatives, their company prepared plans, which DOD 
reviewed and approved, based on the MNC-I 2006 guidance. In September 
2009, DOD officially requested the contractor incorporate MNC-I 
Environmental Standard Operating Procedure 2009 into its operations. 
According to senior military officials, such task order modifications 
are typically long and tedious, often requiring months of 
negotiations. As of July 2010, DOD and the contractor had yet to 
finalize this update because the contractor believed the new guidance 
would require activities beyond the scope of existing contracts that 
would result in additional costs and, therefore, should require a re-
negotiation of those task orders. 

Finally, another reason for the differences in implementation of the 
regulation is disparities in the resources devoted to burn pits and in 
the commitment shown by base commanders and environmental officers. 
For example, all four of the burn pits we visited had programs to sort 
incoming waste to avoid burning of prohibited items. However, the 
amount of resources devoted to this activity varied substantially. At 
Al Asad, for example, a commissioned officer oversaw all burn pit and 
incinerator activities, although a local contractor was responsible 
for the operation. At this base, an Iraqi contractor under U.S. 
servicemembers' supervision sorted waste before it went into the burn 
pit, segregating certain waste for recycling, such as large plastics, 
metals, wood, mattresses, rubber, and reusables (such as furniture). 
This process required a crew of 15 to 20 people and took all day. Some 
sorting also occurred before waste arrived at the burn site. For 
example, contractor personnel sorted dining facility waste at the 
dining facility; then, wet waste went directly to the landfill and 
recyclables went directly to the recycling area. Essentially, only dry 
and combustible materials, such as wood and paper, went into the Al 
Asad burn pit, although according to the officer-in-charge, there were 
a few instances when small amounts of prohibited items, such as 
plastic, slipped through and were burned. 

Figure 4: Local Contractor's Personnel Sorting Solid Waste, Camp Taji, 
Iraq: 

[Refer to PDF for image: photograph] 

Source: GAO. 

[End of figure] 

In contrast, at Warhorse, a warrant officer oversaw the burn pit with 
a staff of three enlisted servicemembers. Warhorse did not employ 
local contractors to assist in sorting the daily waste. As a result, 
according to the warrant officer in charge, sorting the base's solid 
waste each day was a challenge. While they attempted to sort and 
segregate the waste each day, the warrant officer in charge said the 
job was simply too large for four people. Because they had no 
machinery or equipment with which to move the waste, the official in 
charge said that they performed a cursory visual inspection. Further, 
the official said that the staff had other responsibilities at the 
burn site; therefore, they sorted waste for only about 2 hours per day. 

Our visit to Al Asad demonstrated that strong leadership and adequate 
resources can enhance a base's ability to meet the provisions of 
CENTCOM's 2009 regulation, and thereby help protect personnel from 
exposure to potentially harmful burn pit emissions. For example, the 
commissioned officer in command of Al Asad's burn pit is an 
environmental engineer, professionally trained for the task. None of 
the staff in charge of the other three burn pits we visited had such 
training, as their commanders simply assigned them temporary burn pit 
duty. In addition, with the local contractor's staff, servicemembers 
at Al Asad had ample personnel on site to meet most of the 
regulation's provisions, including the implementation of the waste 
disposal alternatives. 

Alternatives to Open Pit Burning Include Source Reduction, Recycling, 
Incinerators, and Land Fills, but DOD Has Not Evaluated Their Benefits 
or Costs: 

Alternative waste management practices, such as source reduction, 
recycling, incinerators and land filling are alternatives for managing 
DOD's wartime waste stream, decreasing its volume and potential 
toxicity, and reducing the potential health impacts of burn pits at 
U.S. bases in Afghanistan and Iraq. However, DOD has not evaluated the 
benefits and costs of these waste management alternatives relative to 
its existing practices, leading to a lack of key information to manage 
its solid waste. 

Source Reduction, Recycling, Incinerators, and Land Fills Are 
Alternatives to Open Pit Burning: 

Source reduction and recycling--also referred to as waste 
minimization--and the use of incinerators and landfills are 
alternatives for managing the waste stream, decreasing its volume and 
potential toxicity, and reducing the potential health impacts of burn 
pits.[Footnote 11] Senior DOD officials and guidance we reviewed 
described a successful approach to solid waste management as first 
characterizing the waste stream to identify its contents and volumes 
of materials and then evaluating ways to integrate these waste 
management alternatives.[Footnote 12] CENTCOM's 2009 regulation and 
Army Regulation 200-1 provide definitions of these waste management 
alternatives. Source reduction, which differs from recycling, is 
defined as any practice reducing the amount of contaminants entering 
the waste stream. Recycling is the process by which materials, 
otherwise destined for disposal, are collected, reprocessed or 
remanufactured, and eventually reused. CENTCOM's Regulation 200-2 
defines an incinerator as any furnace used in the process of burning 
solid or liquid waste for the purpose of reducing the volume of the 
waste by removing combustible matter with emissions passing through a 
stack, duct or chimney. A solid waste landfill is defined as a 
discrete area of land or an excavation used to dispose of non-
hazardous waste. Table 3 illustrates the solid waste management 
practices implemented at U.S. bases in Iraq at the time of our visit. 

Table 3: Waste Management Practices at U.S. Bases in Iraq: 

Source reduction: 
Al Asad: No; 
Marez: No; 
Warhorse: No; 
Taji[A]: No. 

Recycling: Scrap Metal; 
Al Asad: Yes; 
Marez: Yes; 
Warhorse: Yes; 
Taji[A]: Yes. 

Recycling: Aluminum; 
Al Asad: Yes; 
Marez: Yes; 
Warhorse: No; 
Taji[A]: No. 

Recycling: Plastic; 
Al Asad: Yes; 
Marez: No; 
Warhorse: No; 
Taji[A]: No. 

Recycling: Other [B]; 
Al Asad: No; 
Marez: No; 
Warhorse: No; 
Taji[A]: No. 

Solid waste incinerator(s): 
Al Asad: Yes; 
Marez: No; 
Warhorse: No; 
Taji[A]: Yes. 

Landfill/burial: Lined; 
Al Asad: Yes; 
Marez: No; 
Warhorse: No; 
Taji[A]: No. 

Landfill/burial: Not Lined; 
Al Asad: Yes; 
Marez: Yes; 
Warhorse: No; 
Taji[A]: Yes. 

Burn pit(s): 
Al Asad: Yes; 
Marez: Yes; 
Warhorse: Yes; 
Taji[A]: Yes. 

Source: GAO analysis of our site visits to U.S. bases in Iraq between 
January and March 2010. 

[A] Military personnel from Taji contacted our team after our site 
visit and reported that a recycling contract for plastic, wood, 
cardboard, aluminum, paper, small appliances, tires, construction 
debris, and mattresses had been approved with operations scheduled to 
begin in April 2010. 

[B] Other includes tires, glass, wood, mattresses, appliances, and 
electric wire. 

[End of table] 

Although DOD has partially characterized the waste stream at Bagram, 
Kandahar, and Camp Victory, it has not fully characterized the waste 
stream at any of its bases in either Afghanistan or Iraq as outlined 
in Army technical guidance.[Footnote 13] DOD has also been slow in 
implementing waste management alternatives because other logistical 
and operational priorities took precedence over environmental 
programs, according to CENTCOM officials. Specifically, DOD has not 
widely implemented source reduction practices at its bases in either 
country, despite the fact that units subject to the MNC-I and USFOR-A 
Environmental Standard Operating Procedure issued in 2009 were 
strongly encouraged to implement such practices. Source reduction 
involves more than base command decisions; it also includes 
procurement policies and processes that encompass a broad and complex 
cast of DOD logistics and acquisition communities. Yet many of the 
materials from DOD's supply chain that end up in DOD's waste stream 
may adversely impact base commanders' efforts to minimize waste, 
especially waste that CENTCOM's 2009 regulation prohibits in burn 
pits. For example, in March 2010, CENTCOM officials said USF-I Lead 
Environmental Component began evaluating ways to reduce the amount of 
solid waste generated at base dining facilities in Iraq, such as 
plastic utensils, plates, and containers. The content of these 
materials is incompatible with DOD's guidance on burn pit requirements 
because of the large volume of plastic that remains in the waste 
stream. However, no decisions to limit procurement of these materials 
and reduce this waste had been made as of July 2010. 

DOD's recycling practices at its bases in Afghanistan and Iraq were 
also limited and primarily involved large scrap metals. Our site 
visits to the four U.S. bases in Iraq found that only Al Asad recycled 
both aluminum and plastic materials in addition to scrap metal. 
CENTCOM officials and military personnel said that both Afghanistan 
and Iraq lacked markets for plastic and other recyclable materials and 
that plastic materials at bases in those countries had to be 
transported for purchase in Kuwait and Lebanon. However, our review 
found that such markets may exist in Afghanistan and Iraq. For 
example, military personnel at Al Asad said that aluminum and plastic 
were purchased by a Iraqi contractor and sold for profit in Iraq. 
Further, a May 2010 USF-I recycling plan called for initiating 
recycling contracts at eight bases in Iraq in support of USF-I's plan 
to eliminate the use of burn pits in Iraq.[Footnote 14] These 
contracts are to include the recycling of aluminum, appliances, 
cardboard, plastic and wood materials and are expected to be 
implemented in September 2010, according to USF-I officials. USF-I 
officials reported that recycling these additional materials will 
reduce solid waste generated at U.S. bases by 30 percent, supporting 
USF-I's goal to eliminate the use of burn pits in Iraq by December 31, 
2010. Table 4 identifies materials recycled at U.S. bases in Iraq as 
of June 2010. 

Table 4: Recycled Materials at U.S. Bases in Iraq as of June 22, 2010: 

Base name: Adder; 
Scrap metal: Yes; 
Aluminum: Yes; 
Plastic: Yes; 
Cardboard: No; 
Other[A]: No. 

Base name: Al Asad; 
Scrap metal: Yes; 
Aluminum: Yes; 
Plastic: Yes; 
Cardboard: No; 
Other[A]: No. 

Base name: Balad; 
Scrap metal: Yes; 
Aluminum: Yes; 
Plastic: Yes; 
Cardboard: Yes; 
Other[A]: No. 

Base name: Bucca; 
Scrap metal: Yes; 
Aluminum: Yes; 
Plastic: No; 
Cardboard: No; 
Other[A]: No. 

Base name: Delta; 
Scrap metal: Yes; 
Aluminum: Yes; 
Plastic: No; 
Cardboard: No; 
Other[A]: No. 

Base name: Echo; 
Scrap metal: Yes; 
Aluminum: No; 
Plastic: No; 
Cardboard: No; 
Other[A]: No. 

Base name: Falcon; 
Scrap metal: Yes; 
Aluminum: Yes; 
Plastic: No; 
Cardboard: No; 
Other[A]: No. 

Base name: Hammer; 
Scrap metal: Yes; 
Aluminum: No; 
Plastic: No; 
Cardboard: No; 
Other[A]: No. 

Base name: Kalsu; 
Scrap metal: Yes; 
Aluminum: Yes; 
Plastic: No; 
Cardboard: No; 
Other[A]: No. 

Base name: Marez; 
Scrap metal: Yes; 
Aluminum: Yes; 
Plastic: No; 
Cardboard: No; 
Other[A]: No. 

Base name: McHenry; 
Scrap metal: No; 
Aluminum: No; 
Plastic: No; 
Cardboard: No; 
Other[A]: No. 

Base name: Ramadi; 
Scrap metal: Yes; 
Aluminum: Yes; 
Plastic: No; 
Cardboard: No; 
Other[A]: No. 

Base name: Speicher; 
Scrap metal: No; 
Aluminum: Yes; 
Plastic: Yes; 
Cardboard: No; 
Other[A]: No. 

Base name: Sykes; 
Scrap metal: Yes; 
Aluminum: Yes; 
Plastic: Yes; 
Cardboard: No; 
Other[A]: No. 

Base name: Taji; 
Scrap metal: Yes; 
Aluminum: No; 
Plastic: No; 
Cardboard: No; 
Other[A]: No. 

Base name: Warhorse; 
Scrap metal: Yes; 
Aluminum: No; 
Plastic: No; 
Cardboard: No; 
Other[A]: No. 

Base name: Warrior; 
Scrap metal: Yes; 
Aluminum: No; 
Plastic: No; 
Cardboard: No; 
Other[A]: No. 

Base name: Victory; 
Scrap metal: Yes; 
Aluminum: Yes; 
Plastic: Yes; 
Cardboard: Yes; 
Other[A]: No. 

Source: GAO Analysis of Iraq site visits and USF-I recycling data as 
of June 2010. 

[A] Other includes tires, glass, wood, mattresses, appliances, and 
electric wire. 

[End of table] 

U.S. bases in Afghanistan have not developed recycling programs to the 
extent that such programs have been developed in Iraq. Larger bases in 
Afghanistan, such as Bagram Air Field, Kandahar Air Field, and Kabul, 
have implemented recycling programs for plastic bottles, aluminum 
cans, cardboard, paper, steel, wood, and other plastics such as 
flatware and cereal cups, according to USFOR-A reports. However, USFOR-
A officials said that there is little recycling occurring at its other 
bases because they are often located in remote areas lacking an 
infrastructure to support markets for recycled materials. CENTCOM 
officials said that it is often easier to burn waste than to implement 
an efficient recycling program, which would include managing a sorting 
facility, sorting the solid waste, locating markets for recycled 
products, and having trained environmental officers at a base. 

As mentioned above, DOD has begun relying more heavily on incinerators 
as an alternative to burn pits. For example, between 2005 and 2010, 
the number of solid waste incinerators installed in Iraq grew from 2 
to 39, while the number in Afghanistan increased from 1 to 20. 
According to DOD officials, incinerators are the best combustive 
alternative to open burn pits because of their (1) enclosed combustion 
chambers that provide a more complete burn, (2) ability to reduce 
large volumes of waste, and (3) ability to handle multiple waste 
streams.[Footnote 15] However, despite the more controlled process for 
burning waste, incinerators may also produce potentially harmful 
emissions. There are three main types of incinerators: solid waste, 
regulated medical waste, and hazardous waste incinerators. Burn boxes, 
a type of incinerator device designed for wood waste materials, are 
also used at some locations. However, burn boxes differ from solid 
waste incinerators because they do not contain a dual combustion 
chamber or a stack for dispersing emissions and are not designed for 
solid waste, such as food or plastic.[Footnote 16] Figure 5 
illustrates a solid waste incinerator. 

Figure 5: Solid Waste Incinerator, Camp Al Asad, Iraq. 

[Refer to PDF for image: photograph] 

Source: GAO. 

Note: This solid waste incinerator contains a dual combustion chamber, 
a stack for dispersing smoke emissions and is capable of combusting 30 
tons of solid waste per day. 

[End of figure] 

DOD officials reported challenges using incinerators in Afghanistan 
and Iraq, stating that incinerators were expensive and posed 
acquisition, logistic, and operational challenges. Regarding 
acquisition, DOD purchased 40 solid waste and medical waste 
incinerators for U.S. bases in Afghanistan and Iraq between 2003 and 
2005. However, according to senior DOD officials, approximately 100 
construction projects initiated under LOGCAP III were suspended by DOD 
in 2005, including the installation of 11 incinerators in Iraq, 
because DOD identified a lack of internal spending controls on LOGCAP 
III projects. This led to incinerators remaining uninstalled at bases 
in Iraq for approximately 5 years, until March 2010 when the USF-I 
engineer command ordered the installation of the 11 solid waste 
incinerators by July 2010. As of July 2010, there were 39 solid waste 
incinerators installed in Iraq, according to LOGCAP data. Two of the 
four bases we visited in Iraq had solid waste incinerators on-site, 
all of which were supported by LOGCAP. At Taji, there were two solid 
waste incinerators installed with the first incinerator beginning 
operations in February 2009, and at Al Asad there were two solid waste 
incinerators installed with the first incinerator beginning operations 
in April 2009. According to CENTCOM officials, once the United States' 
presence in Iraq ends, all solid waste incinerators will be 
transferred to the government of Iraq. 

Logistically, challenges included the transportation of incinerators, 
the availability of land to install them, and the life-expectancy and 
size of a base, which constantly fluctuates according to senior DOD 
officials. For example, in Afghanistan, CENTCOM officials said that 
incinerators arrived by ship in Pakistan and were loaded onto 
contractor vehicles for delivery to U.S. bases. CENTCOM officials 
reported that the lead time to get an incinerator to a U.S. base in 
Afghanistan ranged from 6 to 8 months. CENTCOM officials said there 
were operational concerns as well. For example, once an incinerator 
arrived, it must be inspected, constructed, and operated by personnel 
according to CENTCOM's 2009 regulation. CENTCOM officials said that 
there is a training program for operating personnel that must be 
completed before operations begin. In addition, CENTCOM officials said 
that U.S. military servicemembers did not operate incinerators, and 
that operations were left primarily to contractors. Senior DOD 
officials said that many bases conduct incinerator operations 24 hours 
a day, requiring trained personnel to continuously operate the 
incinerator. 

In early 2010, USFOR-A developed plans to use incinerators at its 
bases in Afghanistan and, as of June 2010, there were 20 solid waste 
incinerators operational and 46 awaiting installation, as well as 11 
burn boxes that were operational and 2 awaiting installation. DOD data 
also show that 114 additional solid waste incinerators should arrive 
incrementally in Afghanistan by the end of calendar year 2010. The 
types of incinerators installed at bases in Afghanistan differ from 
those at bases in Iraq; they are smaller, with burn rates ranging from 
1 to 20 tons per day, and most are portable.[Footnote 17] The 
portability provides USFOR-A commanders with the flexibility to 
relocate incinerators as bases close or as generated waste capacities 
fluctuate. 

In Iraq, our site visits found that incinerators and burn boxes were 
not always operated according to CENTCOM's 2009 Regulation and instead 
were operated according to the MNC-I guidance documents issued in 2006 
and 2009. The incinerators at Taji were operated by a LOGCAP 
contractor in accordance with the MNC-I Environmental Standard 
Operating Procedure 2006, rather than the 2009 guidance, referenced in 
the contractor's task order according to military personnel. However, 
the MNC-I Environmental Standard Operating Procedure 2006 does not 
include specific guidance on incinerator operation and maintenance, 
prohibited items, or methods for testing and disposing of incinerator 
ash.[Footnote 18] Though not required under the 2006 guidance, 
military personnel at Taji reported that preventive medicine personnel 
routinely tested the incinerator ash and submitted samples to the Army 
Public Health Command for laboratory analysis, assessment, reporting, 
and data archiving. At Al Asad, we observed that incinerators were 
operated in accordance with MNC-I Environmental Standard Operating 
Procedure 2009, which provides additional guidance on incinerator 
operation and maintenance, prohibited items, and methods for testing, 
and disposing of ash. 

In addition, USFOR-A officials and a DOD environmental plan completed 
in March 2009 reported that burn boxes in Afghanistan and Iraq are 
used to combust solid waste, such as wet waste and plastic materials, 
rather than wood, the material they were designed to burn. However, 
CENTCOM's 2009 regulation provides that incinerators and burn boxes 
must be used in accordance with the manufacturers' 
instructions.[Footnote 19] For example, the DOD environmental study 
reported that burn boxes at Bagram Air Field were used to combust over 
650 tons of solid waste per day from January to July 2008. The use of 
burn boxes to combust solid waste not only conflicts with the 
manufacturer's guidance, but also with recommendations made by the 
CENTCOM Surgeon and the Army Public Health Command that burn boxes be 
replaced with incinerators designed for solid waste. The 
recommendation by the Army Public Health Command was the result of an 
environmental assessment of burn boxes at Camp Bondsteel, Kosovo, in 
2001, which determined that the burn boxes used to combust wet waste 
and plastic materials produced air emissions that exceeded the long-
term military exposure guidelines to particulate matter less than 10 
micrometers (coarse particles) and concluded that burn boxes should be 
replaced with appropriate incinerators designed for solid waste. 

Landfills can facilitate the use of incinerators by providing an 
alternative disposal option for certain items that hinder efficient 
combustion and a location for disposal of incinerator ash. 
Specifically, landfills are used at larger U.S. bases in Afghanistan 
and Iraq to dispose of solid waste, including ash from incinerators 
and wet food, plastics, and styrofoam from dining facilities, 
according to CENTCOM, USF-I, and USFOR-A officials and military 
personnel. CENTCOM officials said that disposing of dining facility 
waste in landfills removes the waste from burn pits and incinerators, 
which improves combustion. For example, military personnel at Al Asad 
said that dining facility waste was diverted to a non-lined landfill 
and reported that both the incinerators and the burn pit improved 
their burn efficiency as a result. In addition, DOD officials reported 
that larger bases also diverted the overflow of solid waste--initially 
sent to incinerators--to a landfill because the amount of solid waste 
generated at larger bases exceeded the incinerators' capacity. 
However, challenges to using landfills, including the availability of 
land, high water tables, scavenging, and the need for proper lining to 
prevent waste materials from seeping into surrounding soil and 
possibly contaminating ground water, have limited their use in both 
Afghanistan and Iraq, according to DOD officials. Three of the four 
bases we visited in Iraq used a landfill to dispose of solid waste, 
including incinerator ash, although only Al Asad used a lined landfill 
to dispose of incinerator ash to prevent leaching. 

DOD Has Not Evaluated the Benefits and Costs of Waste Management 
Alternatives and Compared Them with Its Existing Practices: 

In April 2010, as part of its requirements under the National Defense 
Authorization Act for Fiscal Year 2010, DOD reported to Congress that 
during military operations, open air burning will be the safest, most 
effective, and expedient manner of solid waste reduction until current 
research and development efforts produces better alternatives. DOD 
officials added that burn pits are the most cost-effective waste 
management practice and that incinerators are the best alternative. 
However, DOD has not evaluated the benefits and costs of the waste 
management alternatives and compared them with the benefits and costs 
of its existing practices or taken into account all the relevant cost 
variables, including the environmental and long-term health impacts 
that burn pits could have on servicemembers, civilians, and host 
country nationals. 

We discussed the costs of burn pits and solid waste incinerators with 
DOD contract management officials, military officers in both 
countries, and other DOD officials to determine the extent to which 
DOD has analyzed these costs. We determined that DOD does not have 
complete information on costs to procure, install, operate, and 
maintain incinerators during contingency operations. In addition, DOD 
has not comprehensively analyzed alternative waste management 
practices, including the short and long term costs associated with 
their use. For example, overall cost figures are not readily apparent 
in the information submitted by LOGCAP contractors because burn pit 
and incinerator costs are combined with other waste management costs, 
by site, and because these data are not centrally managed or tracked. 
Although the military can request that contractors break out burn pit 
and incinerator cost data to facilitate cost analysis, no such 
analyses have been completed. Without comprehensive cost data and 
analysis, DOD does not have a sufficient basis to conclude that burn 
pits are the most cost-effective waste management practice or that 
incinerators are the best alternative to the use of burn pits. 

DOD officials said that, during wartime, environmental planning, 
including the management of waste, is not always a high priority 
because of the operational and logistical pressures, safety and 
security risks, and the overall lack of resources available initially 
to manage waste. Furthermore, DOD officials reported that base 
planning and resource investment decisions are difficult, including 
planning and implementing resources to manage waste, because bases are 
in constant flux during wartime operations. 

Neither U.S. Forces in Afghanistan nor Iraq Have Monitored Burn Pit 
Pollutants as Directed, and the Health Impacts of Burn Pit Exposure on 
Individuals Are Not Well Understood: 

USFOR-A and USF-I have not established systems to monitor burn pit 
emissions, as directed by CENTCOM's 2009 Regulation. While systems to 
monitor burn pits have not been established, preventive medicine and 
other personnel collected ambient air samples on many bases, some of 
which have active burn pits. However, because DOD and VA lack 
information on burn pit emissions and individuals' exposure to burn 
pits, the potential health impacts of burn pit emissions on 
individuals are not well understood. 

Neither USFOR-A and USF-I Monitor Burn Pit Pollutants as Required by a 
Key CENTCOM Regulation: 

Neither USFOR-A nor USF-I systematically samples burn pit air 
pollutants, as directed by CENTCOM's 2009 regulation. Among other 
things, this regulation directs the establishment of monitoring 
systems to sample pollutants emitted from burn pits and incinerators 
and the documentation of potential exposures. Further, when burn pit 
sampling shows high levels of certain pollutants, the regulation 
directs relevant officials to determine the cause and identify 
solutions. Additionally, the regulation identifies substances that 
should be considered for sampling from burn pits at least yearly. 
These substances and the health risks they pose as described by EPA 
and the Agency for Toxic Substances and Disease Registry include: 

* Carbon monoxide--an odorless gas produced from burning various fuels 
that can cause dizziness, confusion, nausea, fainting, and death, if 
exposed to high levels for long periods of time, according to EPA. 

* Dioxins--a class of chemicals that result from combustion and have 
been characterized by EPA as likely to cause cancer. 

* Particulate matter 10 and 2.5--(coarse and fine particle pollution 
described above). 

* Polycyclic aromatic hydrocarbons--a group of chemicals that result 
from incomplete burning and can cause cancer in humans from long-term 
exposures through breathing or skin contact, according to the Agency 
for Toxic Substances and Disease Registry. 

* Hexachlorobenzene--a chemical by-product classified by EPA as a 
probable human carcinogen that may also damage the liver and cause 
skin lesions. 

* Volatile organic compounds (VOC)--gases emitted from paints, 
solvents, fuels, and other products that, according to EPA, may cause 
eye, nose, and throat irritation; headaches, loss of coordination, and 
nausea; and damage to the liver, kidneys, and central nervous system. 
Some VOCs are also suspected or known to cause cancer in humans, 
according to EPA. 

Since 1978, DOD has recognized that burning waste in open pits is not 
environmentally acceptable. Some DOD guidance, such as DOD Instruction 
6490.03 (2006) and the Joint Staff Memorandum MCM 0028-07 (2007), 
established provisions to identify and assess all potential 
occupational and environmental hazards, including documenting and 
characterizing the risks associated with potential environmental 
exposures. However, these documents preceded CENTCOM's 2009 regulation 
and do not specifically direct U.S. forces to establish systems to 
monitor burn pit pollutants.[Footnote 20] 

Regarding monitoring, officials with CENTCOM and the Army Public 
Health Command (APHC)--one of three service health surveillance 
centers that provide support and technical guidance to USFOR-A and USF-
I on environmental sampling--said from a technical standpoint, 
monitoring burn pit emissions during contingency operations may not be 
possible, practical, or generally warranted from the standpoint of 
characterizing health risks[Footnote 21]. They noted the health risk 
assessment process requires ambient monitoring data at the locations 
where people are exposed to all hazards, regardless of source, and 
sampling only at locations proximate to burn pits would not meet this 
need. However, the CENTCOM regulation is unambiguous. It calls on all 
commands within its area of responsibility, including USFOR-A and USF-
I, to establish systems to monitor burn pit emissions. In describing 
the status of monitoring efforts and related challenges, a senior DOD 
official said neither historic nor current policy and guidance provide 
adequate details to ensure U.S. forces systematically collect burn pit 
emissions data in either country. 

APHC officials also said the regulation's monitoring provisions 
parallel U.S. domestic environmental regulations, which focus on 
monitoring and ensuring compliance with specific thresholds for 
various pollutants.[Footnote 22] However, the military does not 
approach emissions monitoring from that perspective. Rather, the 
military conducts exposure-based monitoring; that is, monitoring at 
locations where personnel may be exposed. To assess the potential 
health risk due to such exposures, the military uses Military Exposure 
Guidelines (MEG) which do not provide absolute limits on 
servicemembers' exposure to specific substances. MEGs are chemical 
concentrations representing estimates of the level above which certain 
types of health effects may begin to occur in some individuals after 
continuous exposure for the duration reflected by the MEG. Thus MEGs 
provide guidelines for various exposure time frames and health effect 
severity levels based on the concentration of chemical substances 
detected during ambient, or outdoor, air monitoring. According to DOD 
technical guidance, MEGs are an important tool to assist preventive 
medicine or other trained personnel in evaluating estimated levels of 
risk to servicemembers from chemical exposures during deployments. 

APHC officials said that instead of establishing systems to monitor 
burn pit emissions, ambient air monitoring should have been required. 
Such information, according to the officials, could provide 
information on the overall air quality to which servicemembers are 
exposed, including emissions from burn pits. APHC officials said that 
when CENTCOM's 2009 regulation was being drafted, they advised CENTCOM 
officials that compliance monitoring of burn pits would be difficult 
to implement, but that their feedback was not incorporated in the 
final version of the regulation. Given the disconnect between the 
sampling methodology proposed by APHC and the requirements included in 
the CENTCOM regulation, it is unclear whether the appropriate sampling 
will be done to collect data needed to understand servicemembers' 
potential exposure to burn pit emissions and to identify and minimize 
potential health risks to servicemembers. 

While Systems to Monitor Burn Pit Pollutants Have Not Been 
Established, Preventive Medicine and Other Personnel Have Collected 
Ambient Air Samples: 

While systems to monitor burn pit pollutants directly have not been 
established, preventive medicine and other personnel in Afghanistan 
and Iraq collected thousands of ambient air samples from at least 288 
locations to conduct occupational and environmental health 
assessments, among other things. [Footnote 23] APHC officials said 
ambient air samples were collected from areas where routine 
servicemember exposure was anticipated. APHC officials said in some 
instances, samples were collected near burn pits if servicemembers 
were continually located in the area. Although samples may be taken 
near the burn pit, APHC officials said it was difficult to determine 
whether the pollutants collected originated from burn pits or another 
source, such as windblown soil, auto exhaust, or nearby industrial 
sources. As a result, ambient air monitoring alone cannot establish 
burn pits' contribution to air quality problems. 

After ambient air samples are collected, they are sent to APHC for 
laboratory analysis and inclusion in the Defense Occupational and 
Environmental Health Readiness System (DOEHRS), an information system 
that stores environmental monitoring data, among other things. 
According to APHC officials, the specific substances and siting of the 
air samples collected vary by location, depending on factors such as 
the size of the base, potential environmental hazards, the personnel 
available to collect samples, and the professional judgment of the 
personnel involved in the sampling. If the concentrations of certain 
substances cause concern, preventive medicine personnel may recommend 
additional monitoring. Further, if a known environmental hazard, such 
as a burn pit, is present, APHC officials said that sampling may be 
adjusted to reflect the type of emissions expected from the potential 
hazard. For example, we reviewed air sampling data from Camp Taji and 
Camp Warhorse that the Army Center for Health Promotion and Preventive 
Medicine (now called APHC) collected in 2008 to help gauge the 
occupational and environmental health risk associated with deployments 
at these bases. The substances sampled at these bases differ 
substantially from one another.[Footnote 24] 

In our analysis of DOEHRS data as of June 2010, we determined that 
since 2002, 2,285 ambient air samples were collected in Afghanistan, 
and since 2003, 5,723 ambient air samples were collected in Iraq. 
Figures 6 and 7 provide information on the number of ambient air 
samples collected in each country by year. In both countries, the 
largest number of ambient air samples were collected in 2009. In 
Afghanistan, the number of ambient air samples collected in 2009 was 
nearly twice the number of samples collected in 2008. Similarly in 
Iraq, more ambient air samples were collected in 2009 than any other 
year, although the difference between 2008 and 2009 was only 19 
percent. 

Figure 6: Number of Ambient Air Samples Collected in Afghanistan, by 
Year: 

[Refer to PDF for image: vertical bar graph] 

Year: 2002; 
Number of samples: 58. 

Year: 2003; 
Number of samples: 25. 

Year: 2004; 
Number of samples: 78. 

Year: 2005; 
Number of samples: 82. 

Year: 2006; 
Number of samples: 229. 

Year: 2007; 
Number of samples: 206. 

Year: 2008; 
Number of samples: 291. 

Year: 2009; 
Number of samples: 886. 

Year: 2010; 
Number of samples: 450. 

Source: GAO analysis of DOEHRS ambient air sampling data. 

[End of figure] 

Figure 7: Number of Ambient Air Samples Collected in Iraq, by Year: 

[Refer to PDF for image: vertical bar graph] 

Year: 2003; 
Number of samples: 502. 

Year: 2004; 
Number of samples: 632. 

Year: 2005; 
Number of samples: 620. 

Year: 2006; 
Number of samples: 411. 

Year: 2007; 
Number of samples: 676. 

Year: 2008; 
Number of samples: 1,147. 

Year: 2009; 
Number of samples: 1,365. 

Year: 2010; 
Number of samples: 369. 

Source: GAO analysis of DOEHRS ambient air sampling data. 

[End of figure] 

Each ambient air sample may include various numbers and types of 
substances. The substances collected include volatile organic 
compounds, metals, and particulate matter. Other substances, such as 
polycyclic aromatic hydrocarbons and pesticides, were also collected. 
[Footnote 25] At the bases we visited in Iraq, the collected 
substances included metals and particulate matter. These substances 
partially correspond to the list of potentially harmful substances 
that CENTCOM's 2009 regulation suggests sampling. 

Our analysis of the DOEHRS data also determined that several 
substances listed in CENTCOM's 2009 regulation were infrequently 
collected, or not collected at all. For example, we determined that 
dioxins were collected at only two locations in Afghanistan and only 
one location in Iraq. According to APHC officials, there were several 
reasons for sampling dioxins infrequently. For example, APHC officials 
said this was because specially trained personnel are needed to 
collect those samples, the equipment used to collect the samples 
requires continuous power and meeting those power needs in contingency 
areas is difficult, and laboratory analysis of dioxin samples can cost 
several thousand dollars per sample. Additionally, APHC officials said 
that the results of a health risk assessment conducted at Joint Base 
Balad did not show levels of dioxins that would suggest further 
sampling was needed at other locations.[Footnote 26] We also 
determined that carbon monoxide--another substance the CENCTCOM 
regulation suggests should be monitored around burn pits--was not 
sampled in either Afghanistan or Iraq. According to an APHC official, 
the instrument needed to collect ambient carbon monoxide samples is 
sophisticated, expensive, and requires specially trained personnel to 
operate. Additionally, the only instrument in CENTCOM's area of 
responsibility was in Kuwait, although DOD said it was procuring 
additional carbon monoxide monitors for use in Afghanistan and Iraq. 

The results of ambient air sampling by APHC showed approximately 6.6 
percent of the 30,516 tests for substances from the samples collected 
in Afghanistan showed exceedances of relevant 1-year MEGs.[Footnote 
27] In Iraq, approximately 3.9 percent of 111,647 of such tests showed 
exceedances of relevant 1-year MEGs. According to APHC officials, 
exceeding a 1-year MEG in one sample or periodically over time does 
not necessarily imply that the servicemembers at that location will 
suffer negative health impacts since the MEGs were designed to protect 
against continuous exposures of up to 1 year in duration. Tables 5 and 
6 provide the number of MEG exceedances by country and the substances 
sampled 2009, and show that levels of fine and coarse particles almost 
always exceeded 1-year MEGs. Importantly, fine particles--which can 
become deeply embedded in lung tissue and are associated with numerous 
health conditions described above--were the substance that most often 
exceeded the MEG. 

Table 5: Number and Percentage of MEG Exceedances in Afghanistan by 
Analyzed Substance[A]: 

Substance Name: Coarse particles; 
Number of MEG exceedances per substance: 1,117; 
Total times substance tested: 1,223; 
Percentage of tests that exceeded MEGS: 91.3$. 

Substance Name: Fine particles; 
Number of MEG exceedances per substance: 883; 
Total times substance tested: 915; 
Percentage of tests that exceeded MEGS: 96.5%. 

Source: GAO analysis of DOEHRS ambient air sampling data. 

Note: In addition to the substances listed above, several substances 
exceeded MEGs less than 10 times: acrolein, benzene and manganese. 

[A] Table 5 includes all samples from Afghanistan, including sites 
with and without burn pits. 

[End of table] 

Table 6: Number and Percentage of MEG Exceedances in Iraq by Analyzed 
Substance[A]: 

Substance Name: Coarse particles; 
Number of MEG exceedances per substance: 3,183; 
Total times substance tested: 3,373; 
Percentage of tests that exceeded MEGS: 94.4%. 

Substance Name: Fine particles; 
Number of MEG exceedances per substance: 980; 
Total times substance tested: 1,009; 
Percentage of tests that exceeded MEGS: 97.1%. 

Substance Name: Acrolein; 
Number of MEG exceedances per substance: 62; 
Total times substance tested: 181; 
Percentage of tests that exceeded MEGS: 34.3%. 

Substance Name: Benzene; 
Number of MEG exceedances per substance: 34; 
Total times substance tested: 956; 
Percentage of tests that exceeded MEGS: 3.6%. 

Substance Name: Lead; 
Number of MEG exceedances per substance: 21; 
Total times substance tested: 4,330; 
Percentage of tests that exceeded MEGS: 0.5%. 

Substance Name: Vanadium; 
Number of MEG exceedances per substance: 15; 
Total times substance tested: 4,329; 
Percentage of tests that exceeded MEGS: 0.35%. 

Substance Name: Manganese; 
Number of MEG exceedances per substance: 11; 
Total times substance tested: 4,329; 
Percentage of tests that exceeded MEGS: 0.25%. 

Source: GAO analysis of DOEHRS ambient air sampling data. 

Note: In addition to the substances listed above, several substances 
exceeded MEGs less than 10 times: 1,2-Dibromo-3 Chloropropane, 
antimony, arsenic, barium, beryllium, cadmium, chromium, 
Hexachlorobutadiene, Hexane, Naphthalene, nickel, and Vinyl acetate. 

[A] Table 6 includes all samples from Iraq, including sites with and 
without burn pits. 

[End of table] 

Figures 8 and 9 illustrate the distribution of fine particle test 
results relative to the MEG, and show that many test results from 
sampling in each nation exceeded the MEG by a substantial margin. 

Figure 8: Fine Particle Test Results in Afghanistan Relative to 
Military Exposure Guidelines: 

[Refer to PDF for image: vertical bar graph] 

Concentration in micrograms per cubic meter: 0-15; 
Number of samples: 32. 

Concentration in micrograms per cubic meter: 15-30; 
Number of samples: 95. 

Concentration in micrograms per cubic meter: 30-45; 
Number of samples: 124. 

Concentration in micrograms per cubic meter: 45-60; 
Number of samples: 101. 

Concentration in micrograms per cubic meter: 60-75; 
Number of samples: 103. 

Concentration in micrograms per cubic meter: 75-90; 
Number of samples: 85. 

Concentration in micrograms per cubic meter: 90-105; 
Number of samples: 78. 

Concentration in micrograms per cubic meter: 105-120; 
Number of samples: 58. 

Concentration in micrograms per cubic meter: 120-135; 
Number of samples: 43. 

Concentration in micrograms per cubic meter: 135-150; 
Number of samples: 37. 

Concentration in micrograms per cubic meter: 150-160; 
Number of samples: 29. 

Concentration in micrograms per cubic meter: 160-180; 
Number of samples: 10. 

Concentration in micrograms per cubic meter: 180-190; 
Number of samples: 14. 

Concentration in micrograms per cubic meter: 190-210; 
Number of samples: 10. 

Concentration in micrograms per cubic meter: 210-225; 
Number of samples: 8. 

Concentration in micrograms per cubic meter: 225-255; 
Number of samples: 7. 

Concentration in micrograms per cubic meter: 255-270; 
Number of samples: 10. 

Concentration in micrograms per cubic meter: 270-285; 
Number of samples: 8. 

Concentration in micrograms per cubic meter: 285-300; 
Number of samples: 4. 

Concentration in micrograms per cubic meter: 300-315; 
Number of samples: 5. 

Concentration in micrograms per cubic meter: 315 and greater; 
Number of samples: 31. 

Source: GAO analysis of DOEHRS ambient air sampling data. 

[End of figure] 

Figure 9: Fine Particle Test Results in Iraq Relative to Military 
Exposure Guideline: 

[Refer to PDF for image: vertical bar graph] 

Concentration in micrograms per cubic meter: 0-15; 
Number of samples: 29. 

Concentration in micrograms per cubic meter: 15-30; 
Number of samples: 65. 

Concentration in micrograms per cubic meter: 30-45; 
Number of samples: 133. 

Concentration in micrograms per cubic meter: 45-60; 
Number of samples: 128. 

Concentration in micrograms per cubic meter: 60-75; 
Number of samples: 101. 

Concentration in micrograms per cubic meter: 75-90; 
Number of samples: 80. 

Concentration in micrograms per cubic meter: 90-105; 
Number of samples: 93. 

Concentration in micrograms per cubic meter: 105-120; 
Number of samples: 56. 

Concentration in micrograms per cubic meter: 120-135; 
Number of samples: 46. 

Concentration in micrograms per cubic meter: 135-150; 
Number of samples: 45. 

Concentration in micrograms per cubic meter: 150-165; 
Number of samples: 20. 

Concentration in micrograms per cubic meter: 165-180; 
Number of samples: 25. 

Concentration in micrograms per cubic meter: 180-195; 
Number of samples: 17. 

Concentration in micrograms per cubic meter: 195-210; 
Number of samples: 14. 

Concentration in micrograms per cubic meter: 210-225; 
Number of samples: 16. 

Concentration in micrograms per cubic meter: 225-240; 
Number of samples: 13. 

Concentration in micrograms per cubic meter: 240-255; 
Number of samples: 13. 

Concentration in micrograms per cubic meter: 255-270; 
Number of samples: 5. 

Concentration in micrograms per cubic meter: 270-285; 
Number of samples: 11. 

Concentration in micrograms per cubic meter: 285-300; 
Number of samples: 7. 

Concentration in micrograms per cubic meter: 300-315; 
Number of samples: 7. 

Concentration in micrograms per cubic meter: 315 and greater; 
Number of samples: 85. 

Source: GAO analysis of DOEHRS ambient air sampling data. 

[End of figure] 

DOD and VA Lacked Information on Individuals' Exposure to Burn Pits: 

DOD does not systematically collect detailed information regarding 
individual servicemembers' burn pit exposure. Similarly, VA does not 
focus on collecting or tracking health outcomes associated with 
exposure to burn pits.[Footnote 28] In the absence of data and 
information on burn pit emissions and individuals' burn pit exposure, 
the potential health impacts of burn pit emissions on individuals are 
not well understood. 

According to DOD guidance, it is the military's responsibility to 
document and evaluate occupational and environmental health hazards 
during deployments, which includes accomplishing specific health 
surveillance activities before, during, and after deployments. 
[Footnote 29] Such surveillance includes identifying the population at 
risk through questionnaires and blood and other samples and 
recognizing and assessing potentially hazardous health exposures and 
conditions, among other things.[Footnote 30] Table 7 provides examples 
of the military's health surveillance activities. 

Table 7: Examples of Selected Health Surveillance Activities Executed 
by Force Commanders or the Armed Services: 

Deployment Phase: Before Deployment; 
Activity: 
* Draft a deployment health risk assessment that identifies deployment 
specific health threats and appropriate protective measures; 
* Ensure servicemembers complete pre-deployment health questionnaires; 
* Collect blood samples from servicemembers for inclusion in the DOD 
serum repository. 

Deployment Phase: During Deployment; 
Activity: 
* Develop and implement plans to inform servicemembers of health 
threats and countermeasures; 
* Conduct occupational and environmental health site assessments at 
locations such as bases, to identify sources of hazardous exposures 
that may affect the health of personnel; 
* Document exposures and related monitoring data in servicemembers' 
deployment health records. 

Deployment Phase: After Deployment; 
Activity: 
* Ensure servicemembers complete post-deployment health questionnaires 
and that questionnaires are reviewed by a medical provider, who refers 
servicemembers for additional care as needed; 
* Collect post-deployment blood samples from servicemembers who were 
sampled before deployment for inclusion in the DOD Serum Repository; 
* Provide debriefings that, among other things, inform servicemembers 
of occupational or environmental exposures they may have experienced. 

Source: GAO analysis of DOD health surveillance guidance. 

[End of table] 

Servicemembers may document exposure to burn pit emissions in several 
ways. For example, their responses to questions in post-deployment 
health questionnaires, which have a question related to environmental 
exposures, can establish a possible exposure to such emissions. In 
addition to health surveys, servicemembers may report any health issue 
they think resulted from an environmental exposure, including burn 
pits, to their military medical provider to document these concerns in 
the servicemembers' medical record. However, these surveillance 
efforts do not collect data on specific individuals' level of exposure 
to burn pit emissions. Senior DOD officials said that systematically 
collecting data on individual level exposures would require 
servicemembers wear a collection device--which they said is beyond 
current technological capability. Senior VA officials said its efforts 
to properly care for veterans and handle their claims would be 
enhanced if DOD collected more individual, or population-level, data 
on exposure to burn pits.[Footnote 31] According to senior VA 
officials, such data are needed to understand the link between 
environmental exposures and health outcomes. 

According to VA officials, there are no VA health surveillance 
activities that focus on collecting or tracking health outcomes 
associated with veterans' potential exposure to burn pits. According 
to a senior VA official, its surveillance of emerging health issues is 
driven by concerns veterans report at its healthcare centers. 
Veterans' potential exposure to burn pits may be documented through 
encounters with the VA health care system when veterans receive acute 
or routine medical care. However, enrollment in VA health care is 
optional, and not all veterans choose to participate. Additionally, 
veterans who served in Iraq or at locations that support Operation 
Iraqi Freedom may report concerns regarding environmental exposure, 
including burn pits, through the Gulf War Registry. The registry is a 
data system established after the first Gulf War to identify possible 
diseases resulting from military service in areas of Southwest Asia. 
Participation in the registry is voluntary, and not all Gulf veterans 
choose to participate. Additionally, VA officials said they were 
developing a survey, which it will administer to about 60,000 randomly 
selected veterans in 2010, that seeks to identify health concerns 
among Operation Enduring Freedom and Iraqi Freedom veterans and will 
provide veterans with an opportunity to report any concerns they have 
regarding environmental exposures, including burn pits. VA officials 
said they expect the survey's results to be available in 2011. 

DOD and VA Have Sponsored Studies to Better Understand the Health 
Impact of Servicemembers' Exposure to Burn Pit Emissions: 

The U.S. Army Center for Health Promotion and Preventive Medicine (now 
the Army Public Health Command) and the Air Force Institute for 
Operational Health (now the U.S. Air Force School Aerospace Medicine) 
jointly conducted the studies of Joint Base Balad, described earlier, 
in response to concerns expressed by servicemembers about the possible 
health impacts of their exposures to burn pit emissions and to gain a 
better understanding of the situation at Balad. As noted above, we 
express no view in this report on the Balad studies because of ongoing 
litigation. 

Other studies have been initiated in response to concerns over 
servicemembers' exposure to burn pit emissions expressed by Congress, 
the VA, and DOD leadership. For instance, in October 2009, the Acting 
Deputy Assistant Secretary of Defense for Force Health Protection and 
Readiness directed the Armed Forces Health Surveillance Center (AFHSC) 
to assist in efforts to understand the health effects associated with 
exposure to burn pit smoke by conducting additional epidemiological 
studies. In response to this directive, AFHSC expects to release a 
report in fall 2010 that presents the findings of several studies on 
burn pit exposure. One of these studies will compare acute and long- 
term health care utilization among servicemembers deployed to Korea, 
at one of four locations within CENTCOM, and the health care 
utilization of never-deployed servicemembers based in the continental 
United States. The outcomes the study will examine include: 

* post deployment visits with medical staff for respiratory, 
circulatory and cardiovascular disease, ill-defined conditions, and 
sleep apnea; 

* self-reported responses on post-deployment health assessments forms; 

* and visits with medical staff for respiratory conditions while 
deployed in the CENTCOM area of responsibility. 

AFHSC is using data from DOD's Defense Medical Surveillance System and 
the Theater Medical Data Store, a medical information system that 
provides access to servicemembers' battlefield medical treatment 
records, among other things. 

As another part of AFHSC's fall 2010 report, the Naval Health Research 
Center (NHRC) will compare health outcomes in servicemembers who were 
exposed to burn pits at Joint Base Balad, Contingency Operating Base 
Speicher, and Camp Taji; and servicemembers who had not been exposed 
to burn pits.[Footnote 32] The health outcomes this study will examine 
include: 

* birth outcomes in offspring of military personnel; 

* chronic and newly reported respiratory symptoms and conditions; 

* symptoms of chronic-multi symptom illness; and: 

* the incidence of newly reported lupus and rheumatoid arthritis. 
[Footnote 33] 

Regarding the first health outcome, NHRC will use data from DOD's 
Birth and Infant Health Registry, which collects data to establish the 
prevalence of birth defects and evaluate the associations of various 
birth outcomes with specific exposures, such as deployment, among 
infants born to military families. NHRC will also rely on data from 
the Millennium Cohort Study to examine the three other health 
outcomes. The Millennium Cohort Study is an ongoing DOD evaluation of 
the long-term health impacts of military service and has 150,000 
participants who are active duty and Reserve or Guard servicemembers. 

In addition, officials from the APHC, U.S. Air Force School of 
Aerospace Medicine, the Navy and Marine Corps Public Health Center, 
and Naval Health Research Center were collaborating on an 
environmental health air surveillance plan to better understand the 
health risks of burn pits to servicemembers at specific locations in 
Afghanistan and Iraq. According to APHC officials, the purpose of the 
environmental health surveillance plan is to help quantify health 
risks from the air quality at particular locations with burn pits but 
is not intended to provide a definitive determination of the burn pit-
specific contribution to the overall health risk or generate data to 
predict the future health of individual servicemembers. In July 2010, 
DOD officials said that prospective locations in Afghanistan have been 
selected for the environmental health surveillance plan. APHC 
officials said they anticipate implementing the environmental health 
surveillance plan at the selected locations in early 2011. After 
implementing the environmental health surveillance plan and adjusting 
it based on lessons learned, APHC officials said the plan could be 
adapted to other locations. 

Finally, the VA commissioned the Institutes of Medicine to study and 
issue a report by spring 2011 on the potential health impacts of burn 
pit exposure. As of June 2010, the scope of the Institute of Medicine 
study had not been defined. However, in its charge to the Institute of 
Medicine, the VA encouraged the Institute of Medicine to examine the 
impacts of burn pits throughout Afghanistan and Iraq. 

Conclusions: 

The Department of Defense and its forces in Afghanistan and Iraq have 
increased their attention to solid waste management and disposal in 
both conflicts in recent years, including issuing comprehensive 
guidance on burn pit operations and pursuing some alternatives, such 
as installing incinerators at large bases. However, burn pits remain a 
predominant waste disposal option in each conflict and the overall 
incidence of exposure of service personnel, contractors, and host 
country nationals to burn pits and any related health outcomes is 
unclear. This is largely because of a lack of awareness of current 
guidance as well as the fact that some contracts for burn pit 
operators do not reflect the most recent guidance. Furthermore, the 
fact that DOD and its forces in Afghanistan and Iraq have not 
implemented a more comprehensive air sampling and monitoring plan 
leaves DOD and other affected stakeholders without the benefit of 
potentially useful information on emissions that could help in 
characterizing risks from burn pit emissions and possibly determining 
whether pollutants detected in ambient monitoring stem from burn pits 
or other sources. Progress in implementing this plan and better 
understanding any health risks from burn pits has been hindered by 
unresolved concerns among Army public health officials about the 
feasibility of adhering to CENTCOM's provisions for burn pit sampling 
and monitoring. In addition, by not characterizing its waste stream to 
identify its contents and opportunities for decreasing its toxicity 
and volume, DOD lacks information necessary to better incorporate 
waste minimization alternatives such as source reduction and 
recycling. Finally, while DOD has made limited progress in 
implementing alternatives to open pit burning, such as the 
installation of incinerators and landfills, it has not analyzed the 
feasibility or benefits and costs of alternatives to its current 
practices--including the potential health impacts of existing 
practices. As a result, DOD lacks the information it needs to make 
informed decisions about waste management practices that efficiently 
and effectively achieve public health objectives. 

Recommendations for Executive Action: 

To help DOD decrease environmental health risks to service personnel, 
contractors, and host county nationals, GAO is making six 
recommendations to the Secretary of Defense. Specifically, GAO 
recommends that the Secretary of Defense direct U.S. forces in 
Afghanistan and Iraq to: 

* Comprehensively implement relevant guidance related to burn pit 
management and operations. 

* Review and update contracts for burn pit operations to ensure that 
they reflect the most recent guidance. 

* Monitor burn pits, in accordance with current guidance, or if 
current guidance needs revision or is insufficient, direct CENTCOM to 
consult with the Office of the Secretary of Defense and other relevant 
parties to revise or clarify the guidance. 

* Analyze the waste stream generated by U.S. forces in each conflict 
and seek to identify opportunities for using materials that are less 
hazardous when burned and strategies for minimizing waste. 

* Improve their adherence to guidance on solid waste management 
practices and further pursue waste prevention through the re-use and 
recycling of materials. 

* Analyze the relative merits--including the benefits and costs--of 
alternatives to open pit burning, taking into account important 
considerations such as feasibility and the potential health effects of 
open pit burning. 

Agency Comments and Our Evaluation: 

We provided a draft of this report to the Department of Defense and 
the Department of Veterans Affairs. In its written response, included 
as Appendix II, DOD said that it concurred with five of the six 
recommendations and partially concurred with the recommendation that 
the Secretary of Defense direct U.S. forces in Afghanistan and Iraq to 
monitor burn pits in accordance with current guidance, or direct U.S. 
Central Command to collaborate with the Army Public Health Command and 
other relevant entities to propose alternative monitoring methods and 
amend the relevant guidance. In commenting on the report, DOD said 
that guidance for burn pit operations affects all combatant commands--
not just U.S. Central Command--and that Central Command and the Army 
Public Health Command should consult with the Office of the Secretary 
of Defense if current guidance for monitoring burn pits requires 
revision. We agree with involving the Secretary of Defense in any such 
changes to guidance for monitoring burn pits and revised the 
recommendation accordingly. DOD also provided technical comments, 
which we addressed as appropriate. The Department of Veterans Affairs 
said they appreciated the opportunity to comment on the draft and had 
no comments. 

We are sending copies of this report to the appropriate congressional 
committees, Secretary of Defense, Secretary of Veterans Affairs, and 
other interested parties. In addition, the report will be available at 
no charge on GAO's Web site at [hyperlink, http://www.gao.gov]. 

If you or your staff members have any questions about this report, 
please contact me at (202) 512-3841 or trimbled@gao.gov. Contact 
points for our Offices of Congressional Relations and Public Affairs 
may be found on the last page of this report. GAO staff who made key 
contributions to this report are listed in appendix III. 

Signed by: 

David C. Trimble:
Director, Natural Resources and Environment: 

[End of section] 

Appendix I: Objectives, Scope, and Methodology: 

This report addresses the following objectives: (1) determine the 
extent to which the U.S. military installations in Afghanistan and 
Iraq have used open pit burning and adhered to guidance governing 
their use; (2) identify alternatives to open pit burning and the 
extent to which DOD evaluated these alternatives; and (3) determine 
the extent to which U.S. forces have monitored the air quality, 
exposures, and potential health impacts of burn pit emissions in 
accordance with relevant guidance. 

To address the first objective, we reviewed relevant DOD guidance and 
U.S. military base records from 2001 to April 2010. From January and 
March 2010, we also visited four burn pit sites in Iraq--Al Asad, 
Marez, Taji, and Warhorse--to determine the degree to which burn pit 
operators adhered with guidance governing the use of burn pits at 
those sites. We observed burn pit operations and interviewed military 
officials, preventive medicine personnel, and contractors at each site 
visited. We also visited one site in Iraq that exclusively used 
incinerators to dispose of solid waste. In addition, we reviewed 
inspection reports conducted by DCMA for each of the four sites. We 
considered several factors when selecting the locations of our site 
visits, such as the number of personnel at each installation, whether 
the burn pit was managed by the military or a contractor, whether an 
incinerator was present, and our ability to safely access the 
location. Our findings from the site visits are not generalizable to 
the other bases we did not visit. We also attempted to observe burn 
pit operations in Afghanistan, using CENTCOMs most recent list of 
active burn pits to select several potential sites, including Bagram 
Air Base among others. In December 2009 when we arrived at Bagram to 
conduct observations, U.S. military personnel told us the burn pit was 
closed. However, we later learned this information was incorrect, as 
the Bagram burn pit remained operational until February 2010. Because 
of this and because of security and logistical issues, we were unable 
to observe burn pit operations in Afghanistan. 

To address the second objective, we reviewed DOD guidance and planning 
documents on current and future uses of alternatives to open pit 
burning, DOD waste disposal studies, and relevant literature. We also 
observed burn pit alternatives during our site visits in Iraq and 
discussed these alternatives and their potential for future use with 
DOD officials and contractors. In addition, we interviewed DOD 
officials in the United States regarding alternatives to burn pits in 
Afghanistan and Iraq, locations where the U.S. military uses such 
alternatives, and the trade-offs of using alternatives. 

To address the third objective, we analyzed data from the Defense 
Occupational and Environmental Health Readiness System on ambient air 
sampling in Afghanistan and Iraq conducted from 2003 through 2009. We 
assessed the reliability of these data by (1) performing electronic 
testing of required data elements, (2) reviewing existing information 
about the data and the system that produced them, and (3) interviewing 
agency officials knowledgeable about the data. We determined that the 
data were sufficiently reliable for the purposes of this report. In 
addition, we analyzed DOD air sampling, health risk characterization, 
and health surveillance documents; as well as documents from the 
Department of Veterans Affairs (VA), which provides healthcare and 
other benefits to veterans and their families, on health surveillance 
efforts. We also interviewed DOD officials regarding air sampling 
efforts and officials from VA and DOD regarding efforts to study the 
potential health impacts of burn pit emissions. 

Lawsuits have been filed in federal court in at least 43 states in 
which current and former servicemembers have alleged, among other 
things, that a contractor's negligent management of burn pit 
operations, contrary to applicable guidance and contract provisions, 
exposed them to air pollutants that subsequently caused serious health 
problems.[Footnote 34] The contractor has moved to dismiss the suits, 
arguing, among other things, that it cannot be held liable for any 
injuries that may have occurred to service personnel because all its 
burn pit activities occurred at the direction of the military. We 
express no view in this report on any issue in this pending litigation 
involving burn pits. Moreover, because of the pending litigation, we 
did not evaluate whether the contractor has complied with the terms of 
its contract with respect to burn pit operations. 

We conducted this performance audit from September 2009 to October 
2010, in accordance with generally accepted government auditing 
standards. Those standards require that we plan and perform the audit 
to obtain sufficient, appropriate evidence to provide a reasonable 
basis for our findings and conclusions based on our audit objectives. 
We believe that the evidence obtained provides a reasonable basis for 
our findings and conclusions based on our audit objectives. 

[End of section] 

Appendix II: Comments from the Department of Defense: 

Office Of The Under Secretary Of Defense: 
Acquisition, Technology And Logistics: 
3010 Defense Pentagon: 
Washington, DC 20301-3010: 

October 5, 2010: 
	
Mr. John Stephenson: 
Director, Defense Capabilities and Management: 
U.S. Government Accountability Office: 
441 G Street, N.W. 
Washington, DC 20548: 

Dear Mr. Stephenson: 

Thank you for the opportunity to provide DoD comments to the GAO Draft
Report, GA0-10-942, "Afghanistan And Iraq — DOD Should Improve 
Adherence to Its Guidance on Open Pit Burning and Solid Waste 
Management," dated September 2010 (GAO Code 361123). 

We provide in the enclosure the DoD responses to the GAO 
recommendations. We partially concur with recommendation #3. If 
current guidance concerning monitoring burn pits needs revision, we 
would direct U.S. Central Command to seek additional guidance from the 
Office of the Secretary of Defense. We concur with all other 
recommendations. 

We also provide in the enclosure the DoD recommended changes to the GAO
report language to improve clarity and accuracy. We ask that GAO 
accept these changes. 

Sincerely, 

Signed by: 

Dorothy Robyn: 
Deputy Under Secretary of Defense: 
(Installations and Environment) 

Enclosures: As stated: 

[End of letter] 

GAO Draft Report Dated September 1, 2010: 
GAO-10-942 (GAO Code 361123): 

"Afghanistan And Iraq: DOD Should Improve Adherence To Its Guidance On 
Open Pit Burning And Solid Waste Management" 

Department Of Defense Comments To The GAO Recommendations: 

Recommendation 1: The GAO recommends that the Secretary of Defense 
direct U.S. forces in Afghanistan and Iraq to comprehensively 
implement relevant guidance related to burn pit management and 
operations. (See page 48/GAO Draft Report.) 

DoD Response: Concur. Office of the Secretary of Defense staff visited 
U.S. Central Command (USCENTCOM) Headquarters in August 2010 and 
confirmed that USCENTCOM is comprehensively implementing relevant 
guidance for U.S. Forces in Iraq and Afghanistan. 

Recommendation 2: The GAO recommends that the Secretary of Defense 
direct U.S. forces in Afghanistan and Iraq to review and update 
contracts for burn pit operations to ensure that they reflect the most 
recent guidance (See page 48/GAO Draft Report.) 

DoD Response: Concur. Army Material Command (AMC) reviewed its 
Logistics Civil Augmentation Program (LOGCAP) contracts for 
Afghanistan and found that the statements of work for those contracts 
referred to outdated guidance. AMC subsequently issued a letter of 
Technical Direction directing contractors to comply with the latest 
guidance. U.S. Forces are transitioning away from burn pit usage in 
Iraq, making a review of relevant contract language unnecessary. 

Recommendation 3: The GAO recommends that the Secretary of Defense 
direct U.S. forces in Afghanistan and Iraq to monitor burn pits, in 
accordance with current guidance, or if current guidance needs 
revision, direct U.S. Central Command to collaborate with the Army 
Public Health Command and other relevant entities to propose 
alternative methods to monitor bum pit emissions, and amend the 
relevant guidance (See page 48/GAO Draft Report.) 

DoD Response: Partially Concur. Guidance for burn pit operations 
affects future operations for all Combatant Commands and is more 
appropriately issued by the Office of the Secretary of Defense rather 
than CENTCOM. This recommendation should be restated as: "Monitor burn 
pits, in accordance with current guidance. If guidance is found to be 
insufficient, seek additional guidance from the Office of the 
Secretary of Defense." 

Recommendation 4: The GAO recommends that the Secretary of Defense 
direct U.S. forces in Afghanistan and Iraq to analyze the waste stream 
generated by U.S. forces in each conflict and seek to identify 
opportunities for using materials that are less hazardous when burned 
and strategies for minimizing waste. (See page 48/GAO Draft Report.) 

DoD Response: Concur. This recommendation will potentially affect unit 
Tables of Organization and Equipment, Basic Supply Loads, and 
logistical lines of operations. 

Recommendation 5: The GAO recommends that the Secretary of Defense 
direct U.S. forces in Afghanistan and Iraq to improve their adherence 
to guidance on solid waste management practices and further pursue 
waste prevention through the re-use and recycling of materials.
(See page 48/GAO Draft Report.) 

DoD Response: Concur. The Defense Reutilization and Marketing Service 
and the Army Material Command are improving solid waste management 
practices and establishing their own re-use and recycling programs in 
Iraq and Afghanistan, where opportunities for recycling in the local 
economies are limited. 

Recommendation 6: The GAO recommends that the Secretary of Defense 
direct U.S. forces in Afghanistan and Iraq to analyze the relative 
merits—including the benefits and costs—of alternatives to open pit 
burning, taking into account important considerations such as 
feasibility and the potential health effects of open pit burning. (See 
page 48/GAO Draft Report.) 

DoD Response: Concur. The Army is currently in the preliminary stages 
of considering the inclusion of deployable incineration equipment in 
future unit Tables of Organization and Equipment. If implemented, the 
availability of such equipment would represent a major change in the 
handling of solid waste at the unit level. 

[End of section] 

Appendix III: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

David C. Trimble (202) 512-3841 or trimbled@gao.gov: 

Staff Acknowledgments: 

In addition to the contact named above, Michael Hix (Assistant 
Director), Johana Ayers, John Bumgarner, Seth Carlson, Carole Coffey, 
Timothy Di Napoli, Phillip Farah, Quindi Franco, Cindy Gilbert, 
Melissa Hermes, Justin Jaynes, Richard Johnson, Joy Myers, Alison 
O'Neill, Mark Pross, Minette Richardson, Kiki Theodoropoulos, and 
Eugene Wisnoski made key contributions to this report. 

[End of section] 

Footnotes: 

[1] The military services include the four armed services (Army, Navy, 
Marine Corps, and Air Force) but not other Department of Defense 
components or contractors. 

[2] Military operations produce three principal types of waste: non- 
hazardous, hazardous, and medical. This report focuses on processes 
for handling non-hazardous waste at installations in Afghanistan and 
Iraq. 

[3] The U.S. military commonly uses the term "contingency operations" 
to refer to activities in combat zones. Contingency operations 
include, among other things, any military operation that the Secretary 
of Defense designates as an operation in which members of the armed 
forces may become involved in military actions against an opposing 
military force. 10 U.S.C. § 101(13)(A). 

[4] For preliminary purposes, the suits have been consolidated in the 
federal district court in Maryland. In re KBR Burn Pit Litigation, 
Civ. No. 09-2083 (D. Md.). 

[5] Many of the initiatives discussed in this report were undertaken 
before the transition from MNF-I to USF-I. Actions or initiatives 
undertaken before January 2010 will be attributed to MNF-I or one of 
its subordinates, e.g., MNC-I, as appropriate. Actions or initiatives 
taken after January 2010 or that are currently ongoing will be 
attributed to USF-I. 

[6] At present, the LOGCAP IV transition is in effect only in 
Afghanistan. 

[7] The United States' presence in Iraq is scheduled to end by 
December 2011. At that time, according to CENTCOM officials, 
incinerators remaining in Iraq will be transferred to the government 
of Iraq. 

[8] Pub. L. No. 111-84 (2009). 

[9] DTM 09-032 defines "covered waste" as hazardous waste; regulated 
medical waste; tires; treated wood; batteries; compressed gas 
cylinders; fuel containers; aerosol cans; polychlorinated biphenyls; 
petroleum, oils, and lubricants; asbestos; mercury; foam tent 
material; and any item containing any of these items. 

[10] Our visits to these four bases predated DOD's issuance of DTM 09- 
032 prohibiting the disposal of covered waste in open-air burn pits 
during contingency operations, except through a formal determination 
that no other disposal method is feasible. 

[11] Source reduction differs from recycling as it pertains to 
reducing the waste stream at the source, to include procurement 
policies and the way products are used and reused according to the 
United States Army Center for Health Promotion and Preventive 
Medicine's (CHPPM) Technical Guidance 197, Guide for Developing 
Integrated Solid Waste Management Plans at Army Installations, 
December 1999. 

[12] Waste stream characterization is the basis for all solid waste 
management decision-making and involves identifying each element of 
the waste stream, identifying the primary source of each element, and 
measuring the amounts generated for each, according to the U.S. Army 
Center for Health Promotion and Preventive Medicine, Technical 
Guidance 197. The Department of the Army Pamphlet 40-11 (DA Pam 40-11) 
states that preventive medicine personnel support the Army in 
integrating its solid waste management plans and solid waste 
characterization surveys to identify and evaluate source reduction and 
recycling opportunities. 

[13] U.S. Army Center for Health Promotion and Preventive Medicine 
Technical Guidance 197 states that waste stream characterization is 
the basis for all solid waste decision-making and involves identifying 
each element of the waste stream, identifying the primary source of 
each element, and measuring the amounts of each element generated. 

[14] U.S. bases in Iraq included in the recycling contract plan 
developed in May 2010 include Al Asad, Bucca, Delta, Echo, Kalsu, 
Irbil, Marez, and Warrior. In September 2010, USF-I awarded three 
recycling contracts--Al Asad, Marez, and Warrior. 

[15] According to CENTCOM Regulation 200-2, solid waste, regulated 
medical waste, and hazardous waste streams are maintained separately 
and disposed of in separate incinerators specifically designed to 
handle each type of waste stream, according to military officials. 

[16] A burn box is also referred to as an air curtain or Munson Burner. 

[17] Burn rates for solid waste incinerators installed at U.S. bases 
in Iraq range from 6 to 72 tons per day. 

[18] The 2006 guidance does include a limited discussion of 
incinerator ash resulting from regulated medical waste. 

[19] The AOR Environmental Component Plan, March 2009, was prepared 
for United States Army Central (USARCENT) by a DOD contractor. 

[20] In September 2006, U.S. Forces-Afghanistan issued environmental 
guidance stating that American regional commanders in that country 
should consider establishing a system to monitor pollutants emitted 
from burn pits. 

[21] According to a senior APHC official, APHC assumed a lead role in 
providing CENTCOM with support and technical guidance regarding 
environmental exposures because APHC is comparatively larger than 
other service health surveillance centers, and a large number of the 
bases in Iraq are managed by the Army. 

[22] Compliance monitoring is an oversight process designed to 
determine conformity with an environmental regulation. 

[23] Preventive medicine personnel may include Army or Navy preventive 
medicine personnel, Air Force bioenvironmental engineers, or other 
servicemembers assigned by commanders to perform preventive medicine 
tasks. However, according to a senior APHC official, APHC assumed a 
lead role in providing CENTCOM with support and technical guidance 
regarding environmental exposures because APHC is comparatively larger 
than other service health surveillance centers, and a large number of 
the bases in Iraq are managed by the Army. Occupational and 
Environmental Health Site Assessments are used to identify and 
document exposure issues that may affect the health of deployed 
servicemembers. Deployment Occupational and Environmental Risk 
Characterizations document the identification and assessment of 
chemical hazards that pose potential health and operational risks to 
deployed servicemembers. Among other things, Occupational and 
Environmental Health Risk Assessments provide information on the 
sources of potential hazards; the population potentially exposed; and 
the sampling data (air, soil, or water) used to develop risk 
estimates. Given the location and time specific nature of the 
information and data used to develop risk estimates, the results of 
screening health risk assessments may not necessarily be generalizable 
across locations. 

[24] At Taji, the sampled substances included carbon tetrachloride; 
benzene; hexane; toluene; 1,4-dichlorobenzene; ethylbenzene;1,2,4- 
trimethylbenzene; methylene chloride; and decane; among others. At 
Warhorse, the sampled substances included chromium, antimony, 
manganese, zinc, coarse particulate matter, arsenic, cadmium, and 
lead, among others. 

[25] Metals, such as arsenic, can cause respiratory irritation and 
lung cancer among other things, depending on the level and length of 
time exposed. We describe the health concerns with the other 
substances elsewhere in this report. 

[26] The APHC and the Air Force Institute for Operational Health 
jointly developed a health risk assessment of the ambient air 
associated with Joint Base Balad that was intended to collect 
pollutants expected to be emitted by the burn pit. Ambient air samples 
were collected from January 2, 2007, through April 21, 2007, and in 
May 2008. The substances sampled included dioxins, polycyclic aromatic 
hydrocarbons, volatile organic compounds, and PM10. Because of ongoing 
litigation, we express no view in this report on any aspect of this 
Balad study. 

[27] According to DOD, all relevant 1-year MEGs represent those levels 
of exposure at which negligible health effects are expected. 

[28] Health surveillance is the regular or repeated collection, 
analysis, and interpretation of health-related data to identify and 
monitor potential health risks to a population and inform 
interventions to prevent, treat, or control disease and injury. 

[29] Joint Staff Memorandum MCM 0028-7; DOD Instruction 6490.03. 

[30] DOD Instruction 6490.03. 

[31] VA officials suggested that data collection efforts could target 
populations that are more frequently exposed to burn pits, such as 
servicemembers posted to guard towers adjacent to burn pits. 

[32] The study defined servicemembers as exposed if they were known to 
have served at least one deployment within a 5-mile radius of the 
Joint Base Balad, Coalition Operating Base Speicher, or Camp Taji burn 
pit. 

[33] Chronic Multisymptom Illness is the presence, for 6 months or 
longer, of one or more the following: general fatigue, mood and 
cognitive abnormalities, and musculoskeletal pain. 

[34] For preliminary purposes, the suits have been consolidated in the 
federal district court in Maryland. In re KBR Burn Pit Litigation, 
Civ. No. 09-2083 (D. Md.). 

[End of section] 

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