United States General Accounting Office

GAO Report to the Chairman, Subcommittee

on Environment, Energy and Natural

Resources, Committee on Government

Operations, House of Representatives

November 1994 POLLUTION

PREVENTION

Status of DOD’s Efforts

GAO/NSIAD-95-13

GAO United States

General Accounting Office

Washington, D.C. 20548

National Security and

International Affairs Division

B-258433 

November 9, 1994

The Honorable Mike Synar

Chairman, Subcommittee on Environment, Energy

and Natural Resources

Committee on Government Operations

House of Representatives

Dear Mr. Chairman:

You requested that we provide information on the status of the

Department of Defense’s (DOD) pollution prevention efforts. Specifically,

you asked us to determine

• the extent to which DOD has collected and reported information on its

inventories and releases of toxic chemicals;

• what progress DOD has made in reducing the use of toxic chemicals;

• the challenges DOD faces in achieving reductions in the use of toxic

chemicals, including the progress DOD has made in reviewing and revising

military specifications; and

• the extent to which DOD has incorporated pollution prevention goals in its

procurement and inventory processes.

On October 5, 1994, we briefed your staff on observations emerging from

our work. This report presents the information that we provided during

the briefing.

Background Pollution is caused by the release of wastes into the environment.

Hazardous wastes result from the use of toxic materials found in a variety

of products, such as chemicals used in thinning paint, while nonhazardous

wastes, such as scrap paper, do not contain toxic materials. A glossary of

terms is at the end of this report.

In August 1993, the President signed Executive Order 12856, which

specifically requires federal agencies to take actions to reduce pollution,

including implementing the Pollution Prevention Act of 1990 and the

Emergency Planning and Community Right-to-Know Act of 1986. The

Pollution Prevention Act of 1990 established a national policy for reducing

pollution at its source as the method of choice in preventing pollution.

Other methods include recycling waste materials, treating wastes, and

disposing of wastes. The Emergency Planning and Community

Page 1 GAO/NSIAD-95-13 Pollution Prevention
B-258433 

Right-to-Know Act of 1986 establishes a requirement to, among other

things, inventory toxic chemicals and to measure and report certain

releases of hazardous wastes into the environment from certain public and

private facilities. This act had initially excluded most government

facilities.

Executive Order 12856 specifically requires federal agencies to place a

high priority on funding to reduce pollution by identifying and eliminating

or reducing requirements for toxic chemicals in military specifications and

by incorporating pollution prevention objectives into purchasing

decisions. Agencies are also required to monitor compliance with the

order and submit annual reports to the Environmental Protection Agency

(EPA) beginning on October 1, 1995. EPA is responsible for convening a

high-level interagency task force to assist agencies in implementing the

order, providing technical advice to agencies when requested, and

providing guidance and monitoring agency compliance with certain

aspects of the order related to reporting and emergency planning.

Results in Brief DOD is in the process of gathering information on toxic chemical

inventories and releases and anticipates it will have this information by

July 1, 1995, the reporting date required by Executive Order 12856. To help

DOD collect this information, a DOD-wide system is being developed but it

may not be ready in time to meet the reporting requirement. EPA has

provided draft guidance to federal agencies on collecting and reporting

information on toxic chemicals. DOD and EPA are negotiating several of the

proposed provisions in EPA’s draft guidance to reduce implementation

costs. EPA could not be certain when final guidance would be issued. (See

app. I.)

The extent that DOD has reduced the use of toxic chemicals cannot be

measured because that information is not now available. DOD’s past efforts

have focused on treating and controlling pollution generated from

processes rather than eliminating the use of toxic chemicals. DOD has

reported progress in reducing the amount of hazardous waste disposal and

the use of toxic chemicals. Much of the reported reductions have been

achieved through reducing the volume, but not the toxicity of hazardous

waste. For example, while removing water from hazardous waste reduces

overall waste volume, it does not reduce the amount of toxic substances in

the waste. (See app. II.)

Page 2 GAO/NSIAD-95-13 Pollution Prevention
B-258433 

DOD believes that significant reductions in the use of toxic chemicals will

be difficult. Making reductions in the use of toxic chemicals will require

more research, development, testing, and evaluation to identify potential

substitute processes and materials. The services believe their current

estimates of about $2 billion during fiscal years 1994 through 1999 for

pollution prevention efforts exclude potentially significant costs, such as

the costs to implement all the projects that are likely to be required to

achieve reductions, related changes in processes, and to identify and test

potential substitutes for toxic chemicals. (See app. III.)

As required by Executive Order 12856, DOD is reviewing military

specifications and standards that call for the use of toxic chemicals in

repairing and maintaining weapon systems and facilities. DOD needs to

identify requirements for toxic chemicals as the first step in revising these

requirements to allow the use of proven substitute materials and

processes. DOD will not likely meet the Executive Order requirements to

review and revise all military specifications and related technical

documents by the deadline. This is because each specification must be

analyzed separately to determine whether the requirements for toxic

chemicals are necessary and whether a suitable less toxic substitute is

available or should be developed. This process also includes testing

potential known substitutes, conducting research and development to

identify substitutes, the administrative process of making the revisions,

and modifying weapon system hardware and maintenance facilities and

equipment. DOD is emphasizing the use of commercial practices and

performance-based specifications to minimize the use of military

specifications and standards. Such an emphasis could reduce the review

and revision effort because fewer military specifications and standards

would need to be reviewed. (See app. IV.)

The services have not comprehensively incorporated environmental

concerns in the design, development, and production of weapon systems,

but are beginning to take steps to do so. DOD has not, on a systematic

basis, revised its procurement and acquisition regulations to address

environmental pollution concerns. Also, DOD’s supply system is not

designed to systematically provide visibility and control over hazardous

materials purchases, and acquisition regulations do not provide guidance

for addressing environmental concerns in day-to-day purchasing decisions.

DOD is developing approaches to provide better visibility and control over

hazardous materials inventories to help reduce the generation of

hazardous wastes. (See app. V.)

Page 3 GAO/NSIAD-95-13 Pollution Prevention
B-258433 

Scope and

Methodology

We collected data from DOD, the Air Force, the Army, the Navy, and the

Defense Logistics Agency to answer our objectives. We also discussed

pollution prevention issues with representatives of 7 major commands and

12 installations (see app. VI) and EPA.

We conducted our review from November 1993 to September 1994 in

accordance with generally accepted government auditing standards. As

requested, we did not obtain written agency comments on this report.

However, we discussed the results of our work with DOD officials and

incorporated their comments as appropriate.

Unless you publicly announce its contents earlier, we plan no further

distribution of this report until 30 days after its issue date. At that time, we

will send copies to interested congressional committees and Members of

Congress; the Secretaries of Defense, the Army, the Navy, and the Air

Force; the Administrator, EPA; and the Director, Office of Management and

Budget. We will also make copies available to others on request.

Please contact me at (202) 512-8412 if you or your staff have any questions

concerning this report. Major contributors to this report are listed in

appendix VII.

Sincerely yours,

Donna M. Heivilin, Director

Defense Management and NASA Issues

Page 4 GAO/NSIAD-95-13 Pollution Prevention
Page 5 GAO/NSIAD-95-13 Pollution Prevention
Contents

Letter 1

Appendix I 

Inventory and Uses of

Toxic Chemicals

8

DOD Is in the Early Stages of Gathering Information on Its

Inventories and Releases of Toxic Chemicals

8

DOD Is Developing a System for Reporting Toxic Chemical

Inventories and Releases, but It May Not Be Ready in Time to

Meet the Reporting Requirement

8

EPA Is Considering DOD Concerns in Its Draft Guidance for

Implementing the Executive Order

9

DOD Guidance for Implementing the Executive Order Does Not

Address Toxicity

9

DOD Reporting Meets Basic Requirements 10

Appendix II 

Reductions in Use of

Toxic Chemicals

11

Information Is Not Now Available to Measure DOD’s Progress in

Reducing the Use of Toxic Chemicals

11

Services Have Reported Reductions in Hazardous Waste Disposal

and Use of Toxic Chemicals

12

Reporting Releases of Toxic Chemicals Into the Air Has Not Been

Required in the Past

13

Appendix III 

Services Expect to

Make Additional

Progress

14

DOD Believes Significant Reductions in Use of Toxic Chemicals

Will Be Difficult

14

Funding Priority for Pollution Prevention Efforts Competes With

Other Budget Priorities

14

Estimated Future Costs to Prevent Pollution Exclude Some

Potentially Substantial Costs

15

Appendix IV 

Military Specifications

and Standards

17

Review of Military Specifications and Standards That Contribute

to Pollution Is Underway

17

DOD’s Review of Standardized Documents Will Not Likely Meet

the Executive Order Deadline

17

DOD Revisions to Standardized Documents Will Not Likely Meet

the Executive Order Deadline

18

Changing and Implementing New Military Specifications May Be

Costly

18

Page 6 GAO/NSIAD-95-13 Pollution Prevention
Contents

Researching, Developing, and Implementing the Use of

Substitutes Could Take 3 or More Years

19

Using Performance-Based Specifications Could Reduce the Time

and Cost of Reviewing Military Specifications

20

Appendix V 

Acquisition,

Procurement, and

Inventory Processes

22

DOD Is Beginning to Incorporate Into Its Acquisition Process

Provisions to Eliminate or Reduce the Use of Toxic Chemicals

22

DOD Procurement Processes Do Not Systematically Address

Environmental Concerns

22

DOD Is Taking Steps to Improve Hazardous Material Inventory

Practices

23

Appendix VI 

Major Commands and

Installations Visited or

Contacted

25

Air Force 25

Army 25

Navy 25

Appendix VII 

Major Contributors to

This Report

26

Glossary 27

Table Table III.1: Services’ Cost Estimates for Pollution Prevention

Activities, Fiscal Years 1994-99

15

Abbreviations

DOD Department of Defense

EPA Environmental Protection Agency

DECIM Defense Environmental Corporate Information Management

Page 7 GAO/NSIAD-95-13 Pollution Prevention
Appendix I 

Inventory and Uses of Toxic Chemicals

DOD Is in the Early

Stages of Gathering

Information on Its

Inventories and

Releases of Toxic

Chemicals

The Department of Defense (DOD) anticipates that it will have complete

information on toxic chemical inventories and releases by July 1, 1995, the

reporting date required by Executive Order 12856. Some DOD facilities are

already reporting inventories and releases of toxic chemicals. These

facilities include government-owned, contractor-operated facilities

originally covered under the Emergency Planning and Community

Right-to-Know Act of 1986 and other industrial-type facilities that had

anticipated the requirement. For example, Tinker Air Force Base,

Oklahoma, and Portsmouth Naval Shipyard, Maine, reported inventories

and releases for calendar year 1992.

DOD issued initial implementing guidance on the Executive Order to the

services on February 15, 1994. The Environmental Protection Agency

(EPA), which is responsible for implementation guidance on the collection

of this information, issued interim guidance to federal agencies dated

February 28, 1994. As of September 1994, however, EPA had not issued

final guidance to federal agencies.

DOD Is Developing a

System for Reporting

Toxic Chemical

Inventories and

Releases, but It May

Not Be Ready in Time

to Meet the Reporting

Requirement

The Defense Environmental Corporate Information Management (DECIM)

office has been developing an automated hazardous materials

management system to be implemented DOD-wide.1

 The DECIM office

expects to have an interim system available early in 1995 and a final

system sometime later. Both systems are expected to contain a wide array

of environmental information, including information on inventories and

releases of toxic chemicals, as required by Executive Order 12856. The

systems are intended to eliminate about 53 redundant hazardous materials

management information systems.

According to DOD officials, several systems are being considered for the

standard system. The officials told us that a decision has not been made as

to which or how many of these systems will ultimately be deployed. They

said if a system is not deployed by late October 1994, the services will

need to consider deploying their own systems in order to meet reporting

requirements of the Executive Order. For example, the Air Force has

decided to modify the Joint Logistics System Center’s system, already

installed at some DOD depots, for use at its installations.

1

The DECIM program office is staffed by defense personnel temporarily detailed to the office. The

office is attached to the Army Environmental Center and reports to the Deputy Under Secretary of

Defense for Environmental Security through a panel of high-level service representatives. DECIM

received $13.5 million in funding for fiscal year 1994. It also has authority to request the services to

provide field staff for specific projects.

Page 8 GAO/NSIAD-95-13 Pollution Prevention
Appendix I 

Inventory and Uses of Toxic Chemicals

EPA Is Considering

DOD Concerns in Its

Draft Guidance for

Implementing the

Executive Order

DOD and EPA are negotiating several of the proposed provisions in EPA’s

draft guidance. The discussions centered around ways to reduce

implementation costs. For example, DOD has taken exception to reporting

emissions of toxic chemicals from mobile sources, such as motor vehicles

and aircraft, as a costly requirement that is outside the scope of the 1986

act. EPA has encouraged federal agencies to report on mobile source

emissions, but DOD will not be doing so. According to EPA officials, other

agencies have indicated an interest in conducting pilot tests for reporting

emissions from mobile sources. EPA officials told us that they could not be

certain when final guidance would be issued.

Also, on January 19, 1994, DOD advised EPA that expending limited

resources to develop pollution prevention plans and report releases of

toxic chemicals for installations to be closed in the near term is

unnecessary. DOD proposed that installations closing by December 31,

1997, should not prepare plans or report releases. DOD and EPA are

negotiating a separate agreement to resolve this issue.

DOD Guidance for

Implementing the

Executive Order Does

Not Address Toxicity

According to the Executive Order, establishing priorities for eliminating or

reducing the unnecessary acquisition and use of toxic chemicals should be

developed by each federal agency in coordination with EPA. EPA is

developing guidance to assist federal agencies in developing prevention

priorities. According to draft EPA guidance for implementing the Executive

Order, federal agencies should establish their own priorities for the

elimination or reduction of toxic chemicals based on factors such as

toxicity of the chemicals being used.2 DOD’s February 1994 implementing

guidance does not address toxicity. Some service officials told us that

unless prevention priorities included toxicity in addition to quantities,

funding priorities could be misplaced. According to these officials, funding

emphasis would likely be placed on reducing uses of reported chemicals,

whereas more highly toxic chemicals not meeting reporting thresholds but

presenting a greater risk to the environment may not be addressed. In

September 1994, DOD officials told us that they recently developed a

proposal to conduct a study in fiscal year 1995 on tools addressing the

toxicity of hazardous materials, which would assist systems acquisition

and maintenance officials in prioritizing their efforts.

2

Executive Order 12856 imposes the reporting thresholds of section 313 of the Emergency Planning

and Community Right-to-Know Act, which requires federal facilities with 10 or more full-time

employees that manufacture, import, or process 25,000 pounds or otherwise use 10,000 pounds of a

listed toxic chemical to report annually (reporting is required even if no release or transfer occurs).

DOD stated that facilities will generally meet the use reporting threshold requirement.

Page 9 GAO/NSIAD-95-13 Pollution Prevention
Appendix I 

Inventory and Uses of Toxic Chemicals

DOD Reporting Meets

Basic Requirements

Executive Order 12856 requires agencies to report releases of the 370 toxic

chemicals and compounds subject to section 313 of the Emergency

Planning and Community Right-to-Know Act as of December 1993. The

purpose of reporting is to ensure that federal agencies collect and make

information available to the public about the use, processing,

manufacture, disposal, and release of toxic chemicals.

In January 1994, EPA proposed adding 313 toxic chemicals to the required

list for toxic release inventory reporting by public and private facilities.

According to EPA, these chemicals were proposed for addition based on

their acute human health and environmental effects. EPA believes that the

addition of these chemicals will provide citizens with more comprehensive

information to better assess potential risks to health and the environment

in their communities. However, the 1994 baseline reporting will not

include these chemicals. Agencies have the option, under the Executive

Order, to report on other toxic chemicals, such as hazardous air pollutants

covered by the Clean Air Act Amendments of 1990. As of September 1994,

DOD has decided to report on the required list of toxic chemicals.

Page 10 GAO/NSIAD-95-13 Pollution Prevention
Appendix II 

Reductions in Use of Toxic Chemicals

Information Is Not

Now Available to

Measure DOD’s

Progress in Reducing

the Use of Toxic

Chemicals

Because DOD is in the process of gathering information on its inventories

and releases of toxic chemicals, we could not precisely measure DOD’s

progress in reducing its use of toxic chemicals. Prior laws (Resource

Conservation and Recovery Act of 1976 as amended by the Hazardous and

Solid Waste Amendments of 1984) did not require reporting of toxic

chemical releases and inventories. However, DOD did report on its efforts

to reduce the amounts of hazardous waste disposal.

DOD’s past reporting on hazardous waste disposal does not measure how

much of the reductions in these disposals are due to reductions in the use

of toxic chemicals or other factors such as defense downsizing. Much of

the hazardous waste generated in DOD is industrial waste associated with

the production, operation, and maintenance of DOD weapon systems.

Defense downsizing has impacted these activities. For example, between

1985 and 1992, the Army ammunition budget has declined by 40 percent,

and depot labor hours have declined by 27 percent. Also, we recently

reported significant reductions in the Air Force’s depot maintenance

workload from 1987 through 1992, including an 11.3-percent reduction in

the number of aircraft with maintenance work completed, a 29.9-percent

reduction in the number of engines repaired, and a 46-percent reduction in

the number of weapon system subsystems and components repaired.1

Although the relationship between funding or labor hours and the amount

of hazardous waste disposal may not be one-to-one, decreased industrial

activity could account for a significant portion of the reported reductions.

The services plan to compare future releases to measures of industrial

activities, such as depot maintenance operations, as required by EPA.

Reported reductions in hazardous waste disposal also include reductions

in waste volume achieved through techniques, such as dehydration of the

waste. While this process does reduce the volume of hazardous waste that

must be disposed of, it does not reduce the amount of toxic chemicals in

the waste.2

 For example, about 155,000 tons, or about 86 percent, of the

Navy’s reported reductions between 1988 and 1992 resulted from the

dehydration of bilge wastes from ships. The Army and the Air Force have

also used dehydration to reduce the volume of hazardous wastes.

According to the services, these projects have been beneficial in reducing

waste volume and disposal costs. The services are not required and do not

1

Air Logistics Center Indicators (GAO/NSIAD-93-146R, Feb. 25, 1993).

2

According to the Pollution Prevention Act of 1990, source reduction does not include altering the

physical, chemical, or biological characteristics or volume of a hazardous substance, pollutant, or

contaminant through a process that is not integral to or necessary for producing a product or

providing a service.

Page 11 GAO/NSIAD-95-13 Pollution Prevention
Appendix II 

Reductions in Use of Toxic Chemicals

plan to separately identify and report reductions due to dehydration and

other volume-reducing techniques.

Services Have

Reported Reductions

in Hazardous Waste

Disposal and Use of

Toxic Chemicals

In establishing their hazardous waste minimization programs, the services

set a goal to reduce the amount of hazardous waste disposed of by

50 percent by 1992. Each of the services reported that it has met this goal

with the following reductions:

• the Air Force reported a 56-percent reduction in its disposal of hazardous

waste (from 50,678 tons in 1987 to 22,236 tons in 1992),

• the Army reported a 62-percent reduction (from 72,728 tons in 1985 to

27,726 tons in 1992), and

• the Navy reported a 63-percent reduction (from 288,232 tons in 1988 to

107,704 tons in 1992).

The services told us that they had recently implemented many successful

projects to reduce their use of toxic chemicals, but do not have a complete

list of these projects because management reports and budgets do not

segregate them from other environmental projects by purpose.3

 The

services’ past efforts to minimize hazardous waste focused on treating and

controlling pollution generated from processes rather than eliminating the

use of toxic chemicals that generated hazardous waste. The following are

examples of each service’s projects that focus on eliminating the use of

toxic chemicals:

• Elmendorf Air Force Base, Alaska, has substituted the toxic chemicals

used in deicing runways with more benign chemicals and reduced the use

of the benign chemicals by placing sensors below runways to better detect

when deicing is needed. Tinker Air Force Base, Oklahoma, has eliminated

cadmium, a highly toxic metal, from its electroplating process used in the

maintenance and repair of aircraft parts and substituted a less hazardous

material. In addition, Tinker reported over a 50-percent reduction in the

use of methylene chloride, a toxic chemical used to remove paint from

aircraft and rubber from aircraft engine parts, by substituting benzyl

alcohol and high-pressure water spray.

3

The Pollution Prevention Act of 1990 defines source reduction as reducing the amount of hazardous

wastes entering the environment, including fugitive emissions, prior to recycling, treatment, or

disposal and reducing the hazards to the public health and the environment. In practice, ambiguity

exists in classifying and reporting the purpose of various types of environmental projects. For

example, a project to reduce toxic chemicals in paint could be classified as either compliance with the

Clean Air Act to reduce emissions of hazardous materials into the air or prevention.

Page 12 GAO/NSIAD-95-13 Pollution Prevention
Appendix II 

Reductions in Use of Toxic Chemicals

• The Lake City Army Ammunition Plant, Missouri, has replaced methyl

chloroform and other hazardous materials used in cleaning machine parts

and tooling with parts washing machines that use soap and water. As a

result, the plant has reduced the generation of hazardous waste by 

6,000 gallons and is saving $12,000 annually. The Anniston Army Depot,

Alabama, reduced its use of the highly toxic metal, cadmium, by

substituting a nontoxic aluminum ion vapor deposition process for

electroplating a variety of parts for weapon systems. The depot estimated

that this process would reduce waste treatment and disposal costs by

$178,000 per year.

• Several Navy installations have replaced chemicals with water-based

processes for cleaning non-flight-critical aircraft components. In addition,

the Charleston Naval Shipyard, South Carolina, has replaced

ozone-depleting chemicals with sodium bicarbonate for paint removal and

certain cleaning operations.

Reporting Releases of

Toxic Chemicals Into

the Air Has Not Been

Required in the Past

Hazardous waste minimization goals and reporting have excluded releases

into the air because DOD’s hazardous waste minimization program did not

require reporting these releases. Since Executive Order 12856 now

requires the reporting of releases into the air, this information will begin to

be collected by defense installations. Data from Tinker Air Force Base

indicates that air releases could be significant: it reported that about

1.6 million pounds, or 99.9 percent, of its toxic chemical releases, was

released into the air during calendar year 1992.

Page 13 GAO/NSIAD-95-13 Pollution Prevention
Appendix III 

Services Expect to Make Additional

Progress

DOD Believes

Significant Reductions

in Use of Toxic

Chemicals Will Be

Difficult

The Executive Order requires DOD to reduce its releases and disposal of

toxic chemicals by 50 percent by December 31, 1999. Moreover, the order

requires that these reductions be achieved through source reductions to

the maximum extent practicable. The services told us that taking further

significant steps to reduce hazardous waste would be difficult. For

example, 78 percent of the Air Force’s reported reduction in hazardous

waste disposal between 1987 and 1992 occurred in 1988, and reported

disposal actually increased by 13 percent from 1991 to 1992.1

According to the services, making additional reductions in their use of

toxic chemicals will require more research, development, test, and

evaluation to identify potential substitute processes and materials and

capital investment for new equipment that the new processes are likely to

require. For example, replacing cleaning processes that use

ozone-depleting chemicals with less hazardous materials often requires

additional processing steps and related new equipment. In another

example, Tinker Air Force Base expects to spend about $21 million to

replace a process using a hazardous material for stripping paint from

aircraft with a robotics system using high-pressure water.

Funding Priority for

Pollution Prevention

Efforts Competes

With Other Budget

Priorities

Service officials told us they are committed to giving priority to pollution

prevention efforts and they believe funding has generally been adequate.

However, they also told us that funding these efforts in the future would

be a challenge in the current environment of defense downsizing and

declining budgets. For example, pollution prevention projects must

compete with environmental cleanup and compliance projects that are

also required by environmental laws and regulations and must be funded

to avoid large fines and potential criminal penalties. DOD’s fiscal year 1995

budget request included $5.7 billion for environmental programs, of which

$4.4 billion was for environmental cleanup and compliance and

$392 million for pollution prevention. Some pollution prevention activities

are included in other funding accounts, but the amount specifically spent

on these activities is not tracked. For example, as previously mentioned,

portions of some projects funded with compliance money could be for

pollution prevention.

1

Much of the reduction in 1988 may have resulted from decreased workload. For example, over

one-half of the 20.7-percent reduction in direct production hours at Air Force depots from 1987

through 1992 occurred between 1987 and 1988. According to the Air Force, the increase in 1992 was

due to a one-time cleanup of sludge ponds at numerous waste water treatment plants.

Page 14 GAO/NSIAD-95-13 Pollution Prevention
Appendix III 

Services Expect to Make Additional

Progress

Estimated Future

Costs to Prevent

Pollution Exclude

Some Potentially

Substantial Costs

DOD’s future costs to address pollution prevention under the Executive

Order will likely be higher than current estimates. The services’ cost

estimates for fiscal years 1994 through 1999 are shown in table III.1.

Table III.1: Services’ Cost Estimates

for Pollution Prevention Activities,

Fiscal Years 1994-99 Fiscal year

Dollars in millions

Service 1994 1995 1996 1997 1998 1999 Total

Air Force $157 $164 $108 $97 $89 $85 $700

Army 37 80 110 128 125 104 584

Navy 129 155 142 137 105 104 772

Total $323 $399 $360 $362 $319 $292a $2,056a

aDoes not add due to rounding.

The services developed these estimates in response to a December 1993

request from the Under Secretary of Defense for Acquisition to develop a

financial strategy for implementing the Executive Order. These cost

estimates generally include known costs of meeting these requirements,

such as reporting releases of toxic chemicals and preparing pollution

prevention plans. The services also reported that their cost estimates

exclude the following potentially significant costs:

• The Air Force expects additional requirements of at least $10 million per

year to achieve the goal of 50 percent reduction in toxic releases, revise

military specifications, and meet reporting requirements.

• The Army believes the $583.6 million cost estimate through fiscal year

1999 may be understated because it will not know its total requirements

until its installations’ pollution prevention plans are submitted in

December 1995 and the Army evaluates these plans. Therefore, according

to the Army, its cost estimate does not include the cost to implement all

the projects that are likely to be required to achieve reductions in the use

of toxic chemicals and related changes in processes.

• The Navy’s pollution prevention cost estimates do not include the costs to

review and change military specifications, standards, and standardization

Page 15 GAO/NSIAD-95-13 Pollution Prevention
Appendix III 

Services Expect to Make Additional

Progress

documents, and to test less toxic materials as replacements for the

current, more toxic materials.

Page 16 GAO/NSIAD-95-13 Pollution Prevention
Appendix IV 

Military Specifications and Standards

Review of Military

Specifications and

Standards That

Contribute to

Pollution Is Underway

DOD is beginning to review the 31,700 military specifications and standards

to determine which ones require use of toxic chemicals. Military

specifications describe the essential technical requirements for a product

and define the criteria for ensuring that these requirements are met.

Military standards describe the product design criteria and the engineering

and management processes for making and testing the product. DOD uses

military specifications and standards to maintain safety, reliability, and

performance in weapon systems and DOD operations.

DOD will not know how many specifications and standards require the use

of toxic chemicals until it completes its review, but it realizes the number

could be substantial. For example, as of April 1994, DOD had identified

about 540 specifications and standards that could require the use of

ozone-depleting toxic chemicals, scheduled to be banned from production

by the end of 1995, for which substitutes must be found.

DOD’s Review of

Standardized

Documents Will Not

Likely Meet the

Executive Order

Deadline

DOD will not likely meet the requirement to review all of the standardized

documents1

 to identify opportunities to eliminate or reduce the use of

toxic chemicals by August 3, 1995, as required by the Executive Order.

While DOD stated it is possible to complete the review of specifications and

standards on time, the review does not include about 1 million related

technical documents. These technical documents describe the

requirements for operating, maintaining, repairing, and disposing of

specific equipment, parts, and materials. DOD does not believe the

Executive Order requires the review of technical documents. However,

EPA’s February 28, 1994, draft implementing guidance defines standardized

documents to include technical documents. The status of the specification

and technical document review is as follows:

• The Air Force expects to complete its review of specifications and

standards by the deadline by computer matching a digitized version of

these documents to a digitized list of toxic chemicals. However, the Air

Force is not scheduled to complete its review of the 158,000 related

technical documents until December 2000. The Air Force has programmed

about $100 million over the next 5 years to digitize its technical documents

for computer matching to the digitized list of toxic chemicals.

• The Army plans to complete its review of specifications and standards by

the deadline if funding is available by using several techniques, including

using the results of the Air Force’s computer matching described above. It

1

DOD’s planned review of standardized documents includes those in the DOD Index of Specifications

and Standards.

Page 17 GAO/NSIAD-95-13 Pollution Prevention
Appendix IV 

Military Specifications and Standards

also plans to require system program managers to perform the reviews.

The Army does not expect to complete the review of related technical

documents until 1999. The Army is not planning to digitize technical

documents due to lack of funding.

• The Navy plans to complete its review of specifications and standards by

the deadline if funding is available. The Navy is identifying known

hazardous materials from a list of authorized materials being used and

then identifying the applicable specification or standard requiring use of

the materials. The Navy also plans to use the results of the Air Force’s

computer matching of specifications and standards. According to Navy

officials, review of other technical documentation by the review deadline

will be limited since the Navy believes it cannot afford to digitize technical

documents.

DOD Revisions to

Standardized

Documents Will Not

Likely Meet the

Executive Order

Deadline

DOD will also not likely meet the Executive Order requirement to revise the

standardized documents by 1999. The revisions are to eliminate or reduce

the use of toxic chemicals wherever it is consistent with the safety and

reliability requirements of DOD’s mission. The targets for making revisions

by the services are as follows:

• The Air Force’s current goal is to revise 50 percent of the standardized

documents that require the use of 17 toxic chemicals targeted by EPA by

December 31, 2000, but has not set goals for the other 353 toxic chemicals

and compounds targeted in the Executive Order.

• The Army reported that it may not meet the 1999 deadline due to funding

and the need for extensive research and development to find suitable

substitutes for some toxic chemicals.

• The Navy reported that it believes it will make the 1999 deadline. However,

Navy officials told us that meeting the deadline will be a challenge due to

the large number of documents that must be reviewed and the lack of

resources for automating the review of technical documents.

Changing and

Implementing New

Military Specifications

May Be Costly

DOD has not estimated the total cost of making and implementing revisions

to standardized documents. However, these costs could be substantial. For

example, in responding to the December 1993 request from the Under

Secretary of Defense for Acquisition to develop a financial investment

strategy for implementing Executive Order 12856, the Army estimated

about $450 million would be required from fiscal years 1995 through 1999

to review and revise military specifications and standards and to

implement projects at installations. However, as discussed previously,

Page 18 GAO/NSIAD-95-13 Pollution Prevention
Appendix IV 

Military Specifications and Standards

these estimates do not include all the costs to implement projects that are

likely to be required to achieve reductions in the use of toxic chemicals

and related changes in processes because installations will not complete

their pollution prevention plans until 1995.

More reliable cost estimates will not be available until the services

complete their reviews of standardized documents. Costs will include

testing potential known substitutes, conducting research and development

on substitutes, and modifying system hardware and maintenance facilities

and equipment, as well as, the administrative cost of making the revisions.

DOD officials told us that budgetary constraints will require consideration

of economic trade-offs in implementing revisions.

The cost of testing and implementing potential substitutes and the

research and development related to substitutes are inherently difficult to

estimate because of the uncertainties that are involved. According to

service officials, testing potential substitutes must be specific as to how

the toxic chemical is used, so eliminating the use of one toxic chemical

could involve the testing for many individual applications. For example,

the Air Force built a facility at Kelly Air Force Base, Texas, that uses

plastic beads instead of a toxic chemical to remove paint from aircraft, but

this technology is not suitable for removing paint from the more sensitive

surfaces of aircraft radomes that protect electronic equipment in the nose

of the aircraft.

Several toxic chemicals have no known substitutes for certain specific

uses. For example, halon, an ozone-depleting chemical, has no known

suitable substitute for providing fire protection inside engine

compartments of military aircraft and crew compartments of Army

armored vehicles. The services are currently conducting tests to identify

potential substitutes. According to preliminary Army estimates, the cost to

replace halon in armored vehicles could be at least $400 million.

Researching,

Developing, and

Implementing the Use

of Substitutes Could

Take 3 or More Years

Research and development to identify potential substitutes for toxic

chemicals and testing the suitability of substitutes for specific applications

may be a time-consuming process, involving up to 3 years or more. For

example, the Army does not expect to find and install a suitable substitute

for fire suppressants containing halon used in the crew compartments of

armored vehicles until after 2005 due to the long lead time required for

testing potential substitutes. Therefore, substitutes not identified or tested

Page 19 GAO/NSIAD-95-13 Pollution Prevention
Appendix IV 

Military Specifications and Standards

now may not be available by the 1999 target date for revising standardized

documents unless test schedules are compressed.

According to service officials, compressing test schedules could

jeopardize worker safety and the reliability of weapon system

performance. For example, the Air Force has experienced problems in

implementing substitutes for ozone-depleting chemicals used to clean

liquid oxygen systems. Several accidents have occurred in cleaning liquid

oxygen systems that investigators believe were caused by using unproven

substitute materials and processes.

Using

Performance-Based

Specifications Could

Reduce the Time and

Cost of Reviewing

Military Specifications

DOD is attempting to improve its ability to stay abreast of commercial

practices, products, and processes by making military standardized

documents less prescriptive. Even though some prescriptive standards will

be necessary to meet unique military requirements, other prescriptive

standards may not. In April 1994, a DOD Process Action Team

recommended that DOD replace the current prescriptive military

specifications and standards with more flexible performance-based

specifications, commercial item descriptions, and nongovernment

standards. While military specifications and standards tell a contractor

how to make a product to meet a requirement, more flexible standards,

such as performance-based standards, specify the requirement and allow

the contractor to determine how best to achieve it. On June 29, 1994, the

Secretary of Defense approved the team’s recommendations and directed

the Under Secretary of Defense for Acquisition and Technology to

implement them. If successfully implemented, these recommendations

should help to expedite DOD efforts to eliminate or reduce the

requirements for toxic chemicals.

Some of the most critical changes to the current policy discussed in the

Secretary’s memorandum follow:

• Performance-based specifications shall be used when practicable in

purchasing new systems, major modifications, upgrades to current

systems, and nondevelopmental and commercial items. If use of these or

nongovernment standards is not practicable, waivers for use of military

specifications and standards may be approved.

• The Defense Federal Acquisition Regulation Supplement will be revised to

encourage contractors to propose nongovernment standards and

industry-wide practices. Forming partnerships with industry associations

is encouraged for developing nongovernment standards.

Page 20 GAO/NSIAD-95-13 Pollution Prevention
Appendix IV 

Military Specifications and Standards

• A procedure will be developed for identifying and removing obsolete

military specifications and standards for new development efforts.

• Program managers and acquisition decisionmakers are directed to

challenge acquisition requirements that create unique military

specifications.

DOD officials told us that it is too early to determine the impact of this

policy on DOD’s review and revision of military specifications to prevent

pollution. However, they believe that the costs and time required to review

and revise specifications should be reduced to the extent that obsolete

specifications are eliminated and nongovernment standards can be applied

with less test and evaluation for specific applications.

Page 21 GAO/NSIAD-95-13 Pollution Prevention
Appendix V 

Acquisition, Procurement, and Inventory

Processes

DOD Is Beginning to

Incorporate Into Its

Acquisition Process

Provisions to

Eliminate or Reduce

the Use of Toxic

Chemicals

The services recently began incorporating environmental concerns in

weapon systems. This is an important step because, according to a DOD

Inspector General report,1 over 80 percent of the hazardous waste

generated in DOD is industrial waste associated with the production,

operation, and maintenance of DOD weapon systems.

DOD policy will incorporate National Aerospace Standard 411, a

commercial hazardous materials management program, that will provide

guidance to military contractors in eliminating or reducing use of

hazardous materials during the design, development, and production of

weapon systems. Actions taken by the services follow.

• The Air Force issued a policy in December 1993 requiring weapon system

program managers to evaluate requirements for hazardous materials,

including life-cycle cost analyses and chemical toxicity assessments,

during the design, development, and production of new weapon systems.

For existing systems, the Air Force has established committees to

coordinate the identification and testing of suitable substitutes for

hazardous materials for specific product areas, such as air vehicles,

munitions, and life support systems.

• The Army and the Navy are beginning to incorporate pollution prevention

into some of their major acquisition programs. For example, the Army has

initiated a life-cycle environmental analysis for the Advanced Field

Artillery System under development and is performing several pollution

prevention studies on this system, such as a study of its liquid propellant

for the presence of toxic metals. The Navy is also developing guidance to

assist program managers in incorporating pollution prevention into major

acquisitions and the Army recognizes guidance is needed.

DOD Procurement

Processes Do Not

Systematically

Address

Environmental

Concerns

DOD has acknowledged that its systems and procedures, including the

federal stock system, Federal Acquisition Regulation, and the Defense

Acquisition Regulation Supplement, do not ensure the reduction of

hazardous materials in products purchased. Also, the federal stock system

does not routinely provide information on the type and quantity of

hazardous materials contained in products purchased. This is because

products are generally ordered by a stock number, not by specific product.

A single stock number may contain products representing dozens of

manufacturers and formulations, some of which may or may not contain

hazardous materials. Moreover, manufacturers are not required to report

1

Hazardous Waste Minimization, DOD Inspector General Inspection Report, No. 93-INS-06, Dec. 28,

1992.

Page 22 GAO/NSIAD-95-13 Pollution Prevention
Appendix V 

Acquisition, Procurement, and Inventory

Processes

all hazardous materials in their products, in part because the reporting

mechanism was designed to protect worker safety rather than meet the

requirements of the Emergency Planning and Community Right-to-Know

Act.2

Procurement regulations do not systematically address environmental

concerns. For example, according to Defense Logistics Agency officials,

DOD has not issued guidance for performing life-cycle costs analyses for

comparing the costs of toxic chemicals with less toxic chemicals. As a

result, purchasing decisions are not always environmentally sound or

cost-effective because they are generally based on the initial price of the

material. Life-cycle costs associated with environmental considerations,

such as the cost to dispose of hazardous waste, are not considered and can

total more than the purchase price. Also, procurement officials told us

that, even though products can be purchased noncompetitively for certain

purposes, such as meeting a time-critical need, buying environmentally

friendly materials is not a justification for buying noncompetitively.

DOD Is Taking Steps

to Improve Hazardous

Material Inventory

Practices

DOD is implementing the recommendations in our prior report on

hazardous material inventory practices.3

 Specifically, DOD expects to

complete revisions to regulations by the end of 1994 to improve the

management of hazardous materials with limited shelf life by allowing DOD

facilities to order more materials directly from vendors. This revision

should reduce the amount of materials whose shelf life expires while being

stored in government warehouses. Materials with expired shelf life are

often disposed of as hazardous waste.

Totally eliminating materials with expired shelf life may not be possible.

For example, from January 1990 to June 1991, the Portsmouth Naval

Shipyard, Maine, disposed of 82 tons of material with expired shelf life as

hazardous waste. As a result, the Navy proposed that DOD establish

critical-use application dates for hazardous materials. These dates would

dictate how long material could be used for critical uses, such as special

paint used to protect submarine hulls, but would allow non-critical uses,

such as for painting interior doors and walls, after the critical-use date.

DOD is still considering this proposal.

2

The Emergency Planning and Community Right-to-Know Act of 1986 requires owners or operators of

certain facilities to submit material safety data sheets to state and local emergency planning and

response organizations. These data sheets report information about hazardous chemicals covered

under the Occupational Safety and Health Act of 1970.

3

Hazardous Waste: Attention to DOD Inventories of Hazardous Materials Needed (GAO/NSIAD-90-11,

Nov. 6, 1989).

Page 23 GAO/NSIAD-95-13 Pollution Prevention
Appendix V 

Acquisition, Procurement, and Inventory

Processes

The Air Force and the Navy are also implementing a medical

pharmacy-like approach to managing and controlling hazardous material

inventories that the Navy initiated in 1989. Under this approach, hazardous

materials are to be tightly controlled, much like the medical field controls

the dispensing of certain drugs through prescriptions approved by a

physician. Likewise, the services expect to achieve more control and

accountability of hazardous materials under this approach by allowing

only approved personnel and organizations to order hazardous materials

in prescribed quantities for prescribed uses. The services told us that this

program has already achieved results. According to the Air Force, Hill Air

Force Base, Utah, has reduced hazardous material purchases by 

50 percent. The Navy has reported that the program resulted in savings of

over $3 million at shore facilities and on eight ships. The Navy issued

implementing guidance for this program in January 1994. The Army has no

plans to implement a similar approach because officials believe it is too

labor-intensive and duplicates portions of the Army’s existing supply

system.

Page 24 GAO/NSIAD-95-13 Pollution Prevention
Appendix VI 

Major Commands and Installations Visited

or Contacted

Air Force Air Mobility Command, Illinois

Air Force Materiel Command, Ohio

Oklahoma City Air Logistics Center, Oklahoma

San Antonio Air Logistics Center, Texas

Warner-Robins Air Logistics Center, Georgia

Army Army Materiel Command, Virginia

Armament, Munitions and Chemical Command, Illinois

Depot System Command, Pennsylvania

Test and Evaluation Command, Maryland

Armaments Research, Development, and Engineering Center,

 New Jersey

Production Base Modernization Activity, New Jersey

Army Environmental Center, Maryland

Rock Island Arsenal, Illinois

Picatinny Army Arsenal, New Jersey

Letterkenny Army Depot, Pennsylvania

Aberdeen Proving Ground, Maryland

Lake City Army Ammunition Plant, Missouri

Tank and Automotive Command, Michigan

Navy Portsmouth Naval Shipyard, Maine

Page 25 GAO/NSIAD-95-13 Pollution Prevention
Appendix VII 

Major Contributors to This Report

National Security and

International Affairs

Division, Washington,

D.C.

David R. Warren

Nomi R. Taslitt

Jacob W. Sprouse, Jr.

Richard H. Clough

Stephen L. Pruitt

Edwin J. Soniat

Page 26 GAO/NSIAD-95-13 Pollution Prevention
Glossary

Contaminant Includes, but not limited to, any element, substance, compound, or

mixture, including disease-causing agents, which after release into the

environment and upon exposure, ingestion, inhalation, or assimilation into

any organism, either directly from the environment or indirectly through

the food chain, will or may reasonably be anticipated to cause death,

disease, behavioral abnormalities, cancer, genetic mutation, physiological

malfunctions (including malfunctions in reproduction), or physical

deformations, in such organisms or their offspring.

Environment Includes water, air, and land and the interrelationship that exists among

and between water, air, and land and all living things.

Facility All buildings, equipment, structures, and other stationary items that are

located on a single site or on contiguous or adjacent sites and which are

owned or operated by the same person (or by any person that controls, is

controlled by, or under common control with, such person). In certain

cases, facility also includes motor vehicles, rolling stock, and aircraft.

Hazardous material A substance or material, including a hazardous substance, which has been

determined by the Secretary of Transportation to be capable of posing an

unreasonable risk to health, safety, and property.

Hazardous substance Any substance designated pursuant to the Federal Water Pollution Control

Act; any element, compound, mixture, solution, or substance designated

pursuant to the Comprehensive Environmental Response, Compensation

and Liability Act of 1980; any hazardous waste having characteristics

identified by the Solid Waste Disposal Act; any hazardous air pollutant

listed under the Clean Air Act; and those pursuant to the Toxic Substances

Control Act.

Hazardous waste A solid waste, or combination of solid wastes, which because of its

quantity, concentration, or physical, chemical, or infectious characteristics

may (1) cause, or significantly contribute to an increase in mortality or an

increase in serious irreversible, or incapacitating reversible, illness or

(2) pose a substantial present and potential hazard to human health or the

environment when improperly treated, stored, transported, or disposed of,

or otherwise managed.

Page 27 GAO/NSIAD-95-13 Pollution Prevention
Glossary

Pollution prevention Source reduction, as defined in the Pollution Prevention Act, and other

practices that reduce or eliminate the creation of pollutants through

(1) increased efficiency in the use of raw materials, energy, water, or other

resources or (2) protection of natural resources by conservation.

Release Any spilling, leaking, pumping, pouring, emitting, emptying, discharging,

injecting, escaping, leaching, dumping, or disposing into the environment.

Source reduction Any practice that (1) reduces the amount of any hazardous substance,

pollutant, or contaminant entering any waste stream or otherwise released

into the environment prior to recycling, treatment, or disposal; and

(2) reduces the hazards to public health and the environment associated

with the release of such substances, pollutants, or contaminants. The term

includes equipment or technology modifications, process or procedures

modifications, reformulation or redesign of products, substitution of raw

materials, and improvements in housekeeping, maintenance, training, or

inventory control.

Toxic chemicals Any substance subject to section 313(c) of the Emergency Planning and

Community Right-to-Know Act of 1986.

Toxicity The amount of poisonous compounds or poisons in a substance.

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