Waste Management: DOD Has Generally Addressed Legislative Requirements on the Use of Burn Pits but Needs to Fully Assess Health Effects
Highlights
What GAO Found
In assessing the Department of Defense's (DOD) March 2016 report to Congress on the use of burn pits, GAO found that it generally addressed the requirements in section 313 of the Carl Levin and Howard P. “Buck” McKeon National Defense Authorization Act (NDAA) for Fiscal Year (FY) 2015. To complete this report, DOD tasked the military services, the Joint Staff, and the overseas combatant commands to provide information on the requirements in the mandate, including policies and procedures related to the disposal of covered waste (including certain types of hazardous waste, medical waste, and items such as tires, treated wood, and batteries) in burn pits during contingency operations. GAO found that DOD's report fully addressed four of the seven reporting requirements and partially addressed the remaining three. For example, the report addressed who is responsible for ensuring compliance with the legislative requirements, but partially addressed whether the waste categories are appropriately and clearly distinguished in surveys and assessments.
Although DOD established guidance to meet applicable legislative requirements through the issuance of DOD Instruction 4715.19, U.S. Central Command is the only overseas geographic combatant command that has established complementary policies and procedures for implementing this guidance. The instruction applies to all the combatant commands, but it does not specify how combatant commanders will ensure compliance with requirements in the instruction. Officials from the other geographic combatant commands stated that their commands have not developed similar policies and procedures because they do not utilize burn pits and there is an absence of current contingency operations in their respective areas of responsibility. Nonetheless, while most of the overseas geographic commands may not currently be involved in contingency operations within their areas of responsibility, waste disposal would likely be required if such operations arise in the future, and the use of burn pits would be one option for disposing of waste. Establishing policies and procedures would better position these commands to implement DOD's instruction.
The effects of exposing individuals to burn pit emissions are not well understood, and DOD has not fully assessed these health risks. DOD officials stated that there are short-term effects from being exposed to toxins from the burning of waste. However, the officials also stated that DOD does not have enough data to confirm whether direct exposure to burn pits causes long-term health issues. Although DOD and the Department of Veterans Affairs have commissioned studies to enhance their understanding of burn pit emissions, the current lack of data on emissions specific to burn pits and related individual exposures limits efforts to characterize potential long-term health impacts on servicemembers and other base personnel. A 2011 report by the Institute of Medicine outlined the data needed for assessing exposures and potential related health risks, and the Department of Veterans Affairs has established a registry to collect some information. However, DOD has not undertaken data-gathering and research efforts to specifically examine this relationship to fully understand any associated health risks.
Why GAO Did This Study
Burn pits help base commanders manage waste generated by U.S. forces overseas, but they also produce harmful emissions that military and other health professionals believe may result in chronic health effects for those exposed. Section 313 of the NDAA for FY 2015 requires the Secretary of Defense to review DOD compliance with law and guidance regarding the disposal of covered waste in burn pits. DOD submitted a report on the results of its review in March 2016.
Section 313 also includes a provision for GAO to assess DOD's report and its compliance with applicable DOD instruction and law. This report evaluates the extent to which (1) DOD's report addressed the elements required in section 313; (2) DOD, including combatant commands, issued guidance for burn pit use that addresses applicable legislative requirements; and (3) DOD has assessed any health risks of burn pit use. GAO compared DOD's report to elements required in section 313, reviewed policies and procedures and interviewed DOD officials.
Recommendations
GAO made three recommendations to include establishing policies and procedures and ensuring research specifically examines the relationship between direct burn pit exposure and long-term health issues. DOD concurred with the first recommendation and partially concurred with the second, citing research it has or has plans to conduct. GAO agrees this research contributes to general understanding but continues to believe more specific research is needed.
Recommendations for Executive Action
| Agency Affected | Recommendation | Status |
|---|---|---|
| Department of Defense | To better position combatant commanders to implement the requirements of DOD Instruction 4715.19 if burn pits become necessary and to assist in planning for waste disposal in future military operations, the Secretary of Defense should direct the combatant commanders of U.S. Africa Command, U.S. European Command, U.S. Pacific Command, and U.S. Southern Command to establish implementation policies and procedures for waste management. Such policies and procedures should include, as applicable, specific organizations within each combatant command with responsibility for ensuring compliance with relevant policies and procedures, including burn pit notification, and, when appropriate, monitoring and reporting on the use of burn pits. |
DOD concurred with this recommendation and on November 13, 2018 DOD updated DOD Instruction (DODI) 4715.19. According to this updated DODI, all geographic combatant commanders are responsible for developing and maintaining guidance and policies specific to their areas of responsibility (AOR) with regard to the use of open-air burn pits. In addition, they are to prepare health risk assessment reports for each open-air burn pit location for those location with more than 100 attached or assigned personnel in place for more than 90 consecutive days. Included in DODI 4715.19 is also a template outlining what information the health risks assessment reports should include that in turn, includes a description of the methodology used to formulate the report, an assessment of any heath risks cited in the reports, and applicable points of contact. Finally, DODI 4715.19 requires that the Under Secretary of Defense for Acquisition and Sustainment oversee the implementation of the of policies and procedures outlined in the DODI. Given the publication of the revised DODI 4715.19, and the specific policies and procedures it delineates as applicable to all combatant commanders with a geographic area of responsibility--which would include U.S. Africa Command, U.S. European Command, U.S. Indo-Pacific Command, and U.S. Southern Command--to include the requirement that each geographic combatant command develop guidance and policies specific to their areas of responsibility regarding the use of open-air burn pits, it is GAO's opinion that this recommendation can be closed as implemented.
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| Department of Defense | To better understand the long-term health effects of exposure to the disposal of covered waste in burn pits, the Secretary of Defense should direct the Under Secretary of Defense for Acquisition, Technology, and Logistics to, in coordination with the Secretary of Veterans Affairs, specifically examine the relationship between direct, individual, burn pit exposure and potential long-term health-related issues. As part of that examination, consider the results of the National Academies of Sciences, Engineering, and Medicine's report on the Department of Veteran Affairs registry and the methodology outlined in the 2011 Institute of Medicine study that suggests the need to evaluate the health status of service members from their time of deployment over many years to determine their incidence of chronic disease, with particular attention to the collection of data at the individual level, including the means by which that data is obtained. |
DOD partially concurred with this recommendation. According to a DOD update received in February 2018, DOD continues to collaborate with the Department of Veterans Affairs and other entities on research activities that address burn pit and other airborne exposures and the potential long-term health outcomes. Since the completion of our report, DOD and the Department of Veterans Affairs have held an Airborne Hazards Symposium (May 2017) and have worked to complete a Airborne Hazards Joint Action Plan. Moreover, they are continuing their research efforts to examine airborne hazard exposures and potential health-related issues. According to a DOD update to this recommendation received in February 2019, additional meetings between DOD and Department of Veterans Affairs representatives were conducted on September 23 and October 3, 2018. It is unclear, however, to what extent these meetings addressed the relationship between direct, individual, burn pit exposure and long-term health-related issues or the need to evaluate the health status of service members from their time of deployment over many years to determine their incidence of chronic diseases. in April 2020, DOD supplied additional information that further clarified joint DOD-Veterans Affairs efforts to examine the relationship between direct, individual burn pit exposure and potential long-term health issues. Specifically, DOD provided an outline of one of the DOD-Veterans Affairs conferences, specifically the one held in September 2018. According to this outline, among the topics discussed were the Veterans Affairs burn pit registry, the Institute of Medicine study, and ways to improve burn pit monitoring. The conference ended with the development of a "Way Forward" that was to prioritize future joint DOD-Veterans Affairs actions. Based on this latest information, it is GAO's opinion that DOD has met the intent of this recommendation.
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| Department of Defense | To better understand the long-term health effects of exposure to the disposal of covered waste in burn pits, the Secretary of Defense should direct the Under Secretary of Defense for Acquisition, Technology, and Logistics to take steps to ensure United States Central Command and other geographic combatant commands, as appropriate, establish processes to consistently monitor burn pit emissions for unacceptable exposures. |
DOD partially concurred with this recommendation. According to an update received in February 2019, in accordance with processes established in DOD Instruction (DODI) 4715.19, Use of Open-Air Burn Pits in Contingency Operations (November 13, 2018), DOD has taken steps to ensure U.S. Central Command and other geographic combatant commands, as appropriate, have established processes to consistently monitor burn pit emissions for unacceptable exposures. To demonstrate the steps U.S. Central Command has taken to monitor burn pit emissions for unacceptable levels. DOD's February 2019 update also includes health risk assessments associated with three separate burn pit locations, all of which were completed in accordance with processes outlined in DODI 4715.19. Based on the processes outlined in DODI 4715.19 that geographic combatant commands, as appropriate, should establish to consistently monitor burn pit emissions, and the health risk assessments completed by U.S. Central Command o the burn pits in its area of responsibility, this recommendation is assessed as closed and implemented.
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