Review of FEMA Guidance for 

Monitoring Debris Removal Operations 

For Hurricane Katrina 

DEPARTMENT OF HOMELAND SECURITY 

Office of Inspector General 

 

OIG-07-63 August 2007 

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removal costs. At this rate, the cost to monitor the estimated $4.1 billion debris removal operations 

for Hurricane Katrina in LA and MS would amount to $328 million. 

Our review consisted of a limited assessment of FEMA guidance on debris monitoring, as well as 

the monitoring efforts of FEMA and the States of LA and MS. We did not review efforts of local 

governments or the guidance and monitoring efforts of the USACE. We interviewed FEMA and 

state officials and reviewed FEMA publications and award documents. The review was performed 

during October and December 2006. 

The nature and brevity of this assignment precluded the use of normal audit protocols. Therefore, 

we did not conduct the review according to generally accepted government auditing standards. Had 

we followed such standards, other matters may have come to our attention. 

RESULTS OF REVIEW

A. FEMA GUIDANCE ON MONITORING DEBRIS OPERATIONS

FEMA debris monitoring guidance is fragmented, disjointed, and incomplete. The guidance is 

contained in at least three separate publications. These publications individually address some, but 

not all, aspects of debris monitoring operations. 

The FEMA publications addressing debris monitoring are: 

1. Public Assistance Debris Management Guide, FEMA 325. FEMA developed this publication to 

provide guidance to community leaders for planning, mobilizing, organizing, and controlling a largescale debris removal and disposal operation. The guide contains general information on debris 

organization and staffing, removal and disposal activities, and contracting. The publication, 

however, contains limited guidance on debris monitoring. 

According to the guide local governments should use their own staff or hire a local engineering firm 

to monitor debris removal operations. Furthermore, local debris monitors are responsible for 

accounting for the amount of debris picked up and verifying the amount hauled to dump sites. The 

guide, however, does not address the need for local monitors to be familiar with FEMA debris 

eligibility requirements and the need to verify eligibility compliance during the monitoring process. 

2. Public Assistance Debris Operations Job Aid 9580.1. FEMA developed this publication for the 

benefit of FEMA public assistance staff. It contains guidance addressing FEMA public assistance 

debris management responsibility, mission assignment, and debris clearance, removal, and disposal 

strategy. Although not written for local government grant recipients, it specifies that local 

governments should have debris monitors and provides tips for monitoring debris removal efforts. 

 

3. Debris Monitoring Field Pocket Guide for FEMA Public Assistance Program Region III. The 

FEMA debris manager in LA said, in addition to the two publications above, they also used the 

Region III Field Pocket Guide. FEMA Region III developed this guide at the request of the FEMA 
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Headquarters Recovery Division, and Region III monitors have used it at disaster sites. The guide, 

however, is not an official FEMA publication and is not used nationally. 

Nonetheless, the guide is clearly the most comprehensive and useful debris monitoring publication 

of the three. It is exclusively devoted to debris monitoring, addressing such issues as roles and 

responsibilities of debris monitors, debris eligibility requirements, and debris monitoring operations. 

It also contains several useful checklists to assist monitors in fulfilling their responsibilities. 

B. RESPONSIBILITY FOR DEBRIS MONITORING AND LEVEL OF EFFORT 

None of the above publications address a state’s role, as a FEMA grantee, in the debris monitoring 

process. According to all of the publications, local government must, and FEMA may monitor 

debris removal operations. However, none of the publications clearly address the state’s role and 

responsibility for monitoring debris removal operations. 

44 CFR, Section 1340, assigns the state, as the grantee of FEMA funds, responsibility for monitoring 

the operations of its local sub-grant recipients. This technically includes debris removal operations. 

FEMA publications on debris operations, in addressing the monitoring responsibility of FEMA and 

local government, should also define a state’s responsibility in debris removal monitoring activities 

of its sub-grantees. 

FEMA and State Efforts in LA and MS. FEMA and the State of MS were very much involved in 

debris monitoring. FEMA and MS officials had a close working relationship and a staff of 25 and 

17 debris specialists, respectively. These specialists were responsible for determining debris eligible 

for pickup and disposal, monitoring debris loads from dump site observation towers, and roaming 

affected areas in the state to identify and resolve debris-related issues. FEMA officials and the state 

debris manager documented many monitoring problems, which were shared with the Homeland 

Security Inspector General’s investigative staff in MS. 

For LA, FEMA assigned more than 100 staff members to debris monitoring in various LA parishes. 

Some of these employees reportedly worked side-by-side with local monitors at dump site towers 

observing and recording the amount of debris delivered to those sites. 

LA efforts in monitoring the debris removal activities of local governments was less prevalent. The 

state used a contractor to help manage the FEMA programs. The contractor, in turn, subcontracted 

with one company for debris monitors and another company for advice, and expertise regarding 

debris monitoring, supervision, and training. According to the contractor’s debris manager, who was 

authorized to speak as a representative of the state, the subcontractors did not monitor the debris 

removal operations of local governments. Instead they served as debris technical advisers to the 

state, representing the state and local governments’ interest in debris removal issues with FEMA. 

When a subcontractor employee observed improper debris activities while traveling the state, they 

verbally reported their observations to parish officials. He advised that there were no written reports 

prepared on such incidents. 

 
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Local Government Efforts in LA and MS. According to the three FEMA publications, primary 

responsibility for monitoring debris removal operations resides with the affected local governments 

who hired contractors to perform debris removal work. The FEMA debris removal award contained 

funding for debris removal monitoring or funding was provided under separate projects. 

The debris monitors were retained to oversee the removal and management of the debris, ensure that 

only eligible debris is removed and it is done in a safe manner, and ensure that the correct volumes 

of debris are recorded. However, we did not assess the quality of work of the local governments’ 

debris monitors. 

C. CONTRACTING FOR DEBRIS MONITORS

FEMA needs to clarify its guidance on contracting for debris monitors. The two official FEMA 

publications (Guides 325 and 9580.1) suggested that local governments retain a local engineering 

firm to monitor their debris removal operations when local government employees are unavailable. 

According to Guide 9580.1, however, registered professional engineers are not necessarily required 

for monitoring activities. 

Several local governments retained engineering firms under existing contracts to monitor debris 

removal operations (see Reports GC-MS-06-55 and GC-MS-06-48). Rather than negotiating lower 

rates for debris monitoring, the local governments used the existing rates for engineering services. 

As a result, the local governments failed to comply with OMB Circular A-87, which requires 

compensation to be commensurate with the nature of services performed, and 44 CFR 13.36 (f) (1), 

which requires cost or price analyses for noncompetitive contract or contract modifications. 

CONCLUSION

The Director of FEMA’s Public Assistance Division provided us with two recently developed draft 

publications and said that another document would be developed to satisfactorily address our 

concerns. 

The first publication is a revised draft Debris Management Guide, FEMA 325. This guide 

encourages local governments to develop a debris management plan for use in the event of a disaster 

and to include debris monitoring as a major component. The second publication is a draft debris 

monitor field pocket guide, tailored after the FEMA Region III guide, which is being developed as a 

quick reference for FEMA monitors to use when in the field. 

Additionally, in view of our findings, the director told us that FEMA will develop a comprehensive 

debris monitoring guide to assist FEMA, state, and local monitors. This guide will reportedly 

outline the debris monitoring responsibilities and the specific tasks of contractors, grant recipients 

(sub-grantees), states (grantees), and FEMA, and provide operational guidance to assist those parties 

in fulfilling their monitoring responsibilities. 
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RECOMMENDATIONS

We recommend the Acting Assistant Administrator for Disaster Assistance: 

1. Develop a comprehensive consolidated guide for monitoring debris removal operations that: 

(a) addresses the monitoring role of FEMA, states, and local monitors; (b) provides an 

organized and cohesive overview of debris monitoring operations, and identifies the related 

expectations of FEMA, state, and local monitors; and, (c) clarifies the requirements for 

contracting for debris monitoring services and emphasizes the need for competitive 

contracting and negotiated rates that are commensurate with the nature of services provided. 

2. Finalize the draft Debris Management Guide FEMA 325 for local governments and the field 

pocket guide for FEMA monitors. 

DISCUSSION WITH MANAGEMENT AND AUDIT FOLLOWUP

We discussed the results of the review on March 13, 2007, with the Director of FEMA’s Public 

Assistance Division. The director agreed with our findings and reported that actions are underway to 

address shortcomings. 

Please advise us within 30 days of the target date for full compliance with the recommendations. 

Should you have any questions concerning this report, please call me, or your staff may contact 

Norm Brown at (202) 254-4100. 

cc: DHS Audit Liaison 

 FEMA Audit Liaison 
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