Afghanistan and Iraq: DOD Should Improve Adherence to Its Guidance on Open Pit Burning and Solid Waste Management
Published: 2010-10-15T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: From the start of military operations in Afghanistan and Iraq, the U.S. military and its contractors have burned solid waste in open burn pits on or near military bases. According to the Department of Defense (DOD), burn pit emissions can potentially harm human health. U.S. Central Command (CENTCOM) guidance directs the military's use of burn pits, and the Department of Veterans' Affairs (VA) provides healthcare and other benefits to veterans and their families. 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.
section_title: What GAO Found
paragraphs: The military has relied heavily on open pit burning 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 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 251 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 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 avoided future costs of potential health effects. Various DOD guidance documents discourage long-term use of burn pits, encourage the use of incinerators and landfills, or encourage waste minimization such as source reduction. DOD has installed 39 solid waste incinerators in Iraq and 20 in Afghanistan, and plans to install additional incinerators in Afghanistan. To date, source reduction practices have not been widely implemented in either country and recycling consists primarily of large scrap metals. DOD plans to increase recycling at its bases in Iraq, but recycling at bases in Afghanistan has been limited. Further, DOD has not fully 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, partly 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 other challenges in monitoring burn pit emissions, and U.S. Forces have yet to establish pollutant monitoring systems. 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. 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. VA reviewed the draft report and had no comments.

section_title: Letter
paragraphs: U.S. military operations in Afghanistan and Iraq generate about 10 pounds  of waste per servicemember each day. 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.  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.
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 the study of emissions from the largest burn  pit in Iraq did not indicate that burn pit smoke presented an elevated long- term health risk. 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. 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 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 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. 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 2002 through 2010. 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. 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.
subsections: section_title: Background
paragraphs: 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.
subsections: section_title: U.S. Force Structure in Afghanistan and Iraq
paragraphs: 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 extends 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 September 2010,  about 104,000 American troops, including 30,000 reinforcements that were  announced 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). By  August 31, 2010, about 65,000 American combat troops will have  withdrawn from Iraq, reducing U.S. troop levels to about 50,000. The  United States’ presence in Iraq is scheduled to end no later than December  31, 2011.
section_title: Contracting Process
paragraphs: 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.  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 (1) provide on-site  contract administration at deployed locations, and (2) 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.
section_title: Air Quality Conditions in Afghanistan and Iraq
paragraphs: 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 the Environmental Protection Agency (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.
section_title: The Military Has Relied Heavily on Open Pit Burning at Installations in Afghanistan and Iraq, but Burn Pit Operators Have Not Always Followed Relevant Guidance
paragraphs: 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 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.
subsections: section_title: DOD Has Relied Heavily on Burn Pits for Solid Waste Disposal in Afghanistan and Iraq
paragraphs: 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. For example,  according to DOD officials, between 2005 and 2010, there was a large  increase in the number of operational solid waste incinerators in both  countries. We discuss incineration issues and other alternatives to open  pit burning in more detail in the next section of this report. Nonetheless,  as of August 2010, burn pits remained an important waste disposal method  for the U.S. military in both wars. According to DOD officials, the  military’s reliance on open burn pits is primarily the result of their  expedience, especially in the early phases of both wars when combat  operations were most intense.
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 U.S. troops leave Iraq and additional troops arrive in  Afghanistan, these totals 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, resulting in  varying amounts of solid waste. For example, large bases may house 5,000  or more U.S. servicemembers, as well as U.S. civilian contractors, while 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), may employ alternatives, such as incinerators, to handle a  substantial portion of their solid waste disposal.
section_title: CENTCOM Did Not Develop Comprehensive Burn Pit Guidance Until 2009
paragraphs: Although DOD has long recognized the dangers of open pit burning—June  1978 waste management guidance states that U.S. personnel should not  burn solid waste unless there is no other alternative, in part because of the  environmental dangers it poses—CENTCOM and its subordinate  commands did not provide comprehensive instructions on managing and  operating burn pits or minimizing these 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. For example, an Army Technical  Bulletin on Guidelines for Field Waste Management, dated 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 employing open  burning in emergency situations to lessen the acknowledged risks  associated with open burning and avoid exposing U.S. 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––was 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.  One of their points of emphasis was to develop limited instructions for  operating burn pits.
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 development of this  guidance also advanced some environmental practices, such as the  segregation of waste to 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 as the most appropriate means of handling  solid waste. It also describes burn pits as an expedient means to destroy  solid waste during contingency operations. However, the guidance notes  that open burning is explicitly 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. Consistent with earlier waste disposal guidance,  including MNC-I Environmental Standard Operating Procedure 2006  and 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, oils, and tires. However,  USFOR-A guidance also includes pesticide containers, asphalt shingles,  treated wood, and coated electrical wires, among other things, not  specifically listed in the MNC-I guidance. The MNC-I guidance requires  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. Generally, the regulation’s requirements are more stringent  than the nation-specific guidance contained in MNC-I and USFOR-A. For  example, the regulation excludes more items from burn pits than the MNC- I or USFOR-A standard operating procedures.
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 enacted the National Defense Authorization Act  (NDAA) for Fiscal Year 2010. Section 317 of the act requires DOD 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.
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 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.
The DTM 09-032 exception process may appear to institute less stringent  controls over open-air burning than CENTCOM’s 2009 regulation because  it allows such burning when commanders deem it necessary, while the  regulation does not authorize the disposal of prohibited items in burn pits  under any circumstances. However, 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. As  of July 2010, 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.
Table 1 compares the key elements of burn pit guidance developed by  MNC-I, USFOR-A, CENTCOM, and DTM 09-032 that are relevant to the  issues Congress identified in NDAA section 317.
section_title: DOD Has Not Ensured That Burn Pit Operators Consistently Follow Key Health Protection Provisions of CENTCOM Regulation 200-2
paragraphs: DOD and CENTCOM officials, as well as senior military officers,   acknowledged that U.S. forces have not always adhered to relevant  guidance, and that prior to 2009, many items CENTCOM’s 2009 regulation  now prohibits from burn pits, including regulated medical waste,  hazardous waste, and substantial quantities of plastic, were routinely  disposed of in 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.  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 and 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. For example, we  determined that operators at all four of these burn pits burned varying  amounts of plastic—a prohibited item that can produce carcinogens when  burned.  For example, Al Asad appeared to have only trace amounts of  plastic in its burn pit.  At Warhorse, despite some limited waste sorting  efforts, a burn pit operator said they did not segregate plastic from the  waste stream. We found similar variability in the bases’ use of incinerators.  For example, Al Asad and Taji had solid waste incinerators in operation 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, or to remove anything that could be  used against U.S. forces, Al Asad and Taji devoted more resources to  sorting waste than Marez and Warhorse. This variability in meeting the key  health protection provisions of the CENTCOM 2009 regulation means  many U.S. personnel—military and civilian—may face greater risks from  burn pit emissions in their day-to-day activities.
Table 2 provides our analysis of each base’s adherence to CENTCOM’s  2009 regulation health-related burn pit provisions.
The variability in implementation of CENTCOM’s 2009 regulation at the  bases we visited stems from several causes. First, environmental officials  at one of the four Iraq bases we visited—Warhorse—said they were  unaware of the regulation and its requirements for burn pit operations.  The two servicemembers who managed the Warhorse burn pit said 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  severely 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 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. We discuss procurement issues in more detail  later in this report.
Third, the contractor operating the burn pits at two bases we visited did  not have contracts reflecting current guidance. According to a senior  representative of this firm, the MNC-I Environmental Standard  Operating Procedure 2006 is the guidance referenced in its burn pit  contract. Thus the company provided Iraq burn pit management activities  in the context of that guidance, which contains less stringent requirements  than the CENTCOM 2009 regulation. According to the contractor’s  representative, the company prepared plans, which DOD reviewed and  approved, based on the MNC-I 2006 guidance. However, DOD officially  requested the contractor incorporate MNC-I Environmental Standard  Operating Procedure 2009 into its operations. According to Army  contracting specialists, such contract modifications are typically long and  tedious, often requiring months of negotiations. As of June 2010, DOD and  the contractor had yet to finalize this update, at least in part because the  contractor believed the new guidance would require activities beyond the  scope of existing 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 and to remove anything that  could be used against U.S. forces. 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. 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.
In contrast, at Warhorse, a warrant officer oversaw the burn pit with a  staff of five 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 five  people. They had no machinery or equipment with which to move the  waste, so 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. 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.
section_title: Alternatives to Open Pit Burning Include Source Reduction, Recycling, Incinerators, and Landfills, but DOD Has Not Evaluated Their Benefits or Costs
paragraphs: 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.
subsections: section_title: Source Reduction, Recycling, Incinerators, and Landfills Are Alternatives to Open Pit Burning
paragraphs: 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. 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. DOD guidance discourages long- term use of burn pits and encourages the use of incinerators and landfills  instead. CENTCOM’s 2009 regulation and Army Regulation 200-1 provide  definitions of 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.
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. 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  practices such as source reduction and recycling 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 tasked a contractor to begin  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 military officers at one base we  visited in Iraq said plastic materials from some U.S. bases in Iraq were  transported to Kuwait and Lebanon for recycling. However, our review  found that such markets may exist in 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 seven bases in Iraq in  support of USF-I’s plan to eliminate the use of burn pits in Iraq. These  contracts are to include the recycling of aluminum, appliances, cardboard,  plastic and wood materials and were 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 a USF-I 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.
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 and Kandahar Air Field, 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 under LOGCAP grew  from 2 to 39. In Afghanistan, the number increased from 1 to 20 between  2003 and 2010. 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. 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.  Figure 5 illustrates a solid waste incinerator.
DOD officials reported challenges using incinerators in Afghanistan and  Iraq, stating that incinerators were expensive and posed acquisition,  logistical, and operational challenges. Regarding acquisition, DOD  purchased more than 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 incinerators by July 2010. As of August 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, solid waste  incinerators began operation in February 2009, and at Al Asad, solid waste  incinerators began operation 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 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 also reported that the lead time to get an  incinerator to a U.S. base in Afghanistan ranged from 6 to 8 months, and  that there were operational concerns as well. For example, once an  incinerator arrived, it had to be inspected, set up, and operated by trained  personnel. CENTCOM officials said that there is generally a training  program for operating personnel to complete before operations begin. In  addition, DOD 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.
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. 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  under the MNC-I Environmental Standard Operating Procedure 2006.
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. 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.
USFOR-A officials and a DOD environmental plan completed in March  2009 reported that burn boxes in Afghanistan are used to combust various  types of solid waste, including wet waste and wood products. Burn boxes  were designed to burn certain, but not all, wood products. However,  CENTCOM’s 2009 regulation provides that incinerators and burn boxes  must be used in accordance with the manufacturers’ instructions. For  example, the DOD environmental study reported that burn boxes at  Bagram Air Field were used to combust hundreds of tons of solid waste  per day from January to July 2008. The use of burn boxes to combust solid  waste conflicts 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 for  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  providing a location for disposal of incinerator ash. For example, landfills  are used at larger U.S. bases in Afghanistan and Iraq to dispose of solid  waste, including ash from incinerators as well as various non-combustible  items such as dining facility waste. Senior DOD 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  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 with  landfills include 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, according to  DOD officials. Three of the four bases we visited in Iraq used a landfill to  dispose of solid waste, although only Al Asad used a lined landfill.
section_title: DOD Has Not Evaluated the Benefits and Costs of Waste Management Alternatives and Compared Them with Its Existing Practices
paragraphs: 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 combustive  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.
section_title: 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
paragraphs: USFOR-A and USF-I have not established systems to sample or 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, in part 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.
subsections: section_title: Neither USFOR-A nor USF- I Monitor Burn Pit Pollutants as Required by a Key CENTCOM Regulation
paragraphs: 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 systems to sample or monitor  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 or 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  earlier.
Polycyclic aromatic hydrocarbons—a group of chemicals that result from  incomplete burning and can cause cancer in humans from long-term  exposure 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  sample or monitor burn pit pollutants.
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. 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. Nevertheless,  the CENTCOM regulation specifically directs the establishment of a  sampling or monitoring system to sample or monitor pollutants emitted  from burn pits, and to document potential exposures.  In describing the  status of monitoring efforts and related challenges, a senior DOD official  said historic and current policy and guidance did not 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.  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.
section_title: While Systems to Monitor Burn Pit Pollutants Have Not Been Established, Preventive Medicine and Other Personnel Have Collected Ambient Air Samples
paragraphs: 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 293 locations  to conduct occupational and environmental health assessments, among  other things. 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 Taji and 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.
In our analysis of DOEHRS data provided in July 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. 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.
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. 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. We also determined that  carbon monoxide—another substance the CENTCOM regulation states  should be considered for monitoring 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 exceeded relevant 1-year MEGs. 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  because 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, 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.
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.
section_title: DOD and VA Did Not Have Information on Individuals’ Exposure to Burn Pits
paragraphs: 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. 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. 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. Table 7  provides examples of the military’s health surveillance activities.
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 for documentation 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 to 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. 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 to 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.
section_title: DOD and VA Have Sponsored Studies to Better Understand the Health Impact of Servicemembers’ Exposure to Burn Pit Emissions
paragraphs: 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 of 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;    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. The health outcomes this study will examine  include:    birth outcomes in offspring of military personnel;    chronic and newly reported respiratory symptoms and conditions;    chronic multisymptom illness; and  the incidence of newly reported lupus and rheumatoid arthritis.
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 140,000 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 are 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 to 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, according to senior VA officials, 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 to  examine the impacts of burn pits throughout Afghanistan and Iraq.
section_title: Conclusions
paragraphs: 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 some bases. However, burn pits remain a significant waste  disposal method 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 the  expedience of burn pits, a lack of awareness of current guidance, and 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 new recycling  contracts, it has not analyzed the feasibility or benefits and costs of  alternatives relative to those of its current 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.
section_title: Recommendations for Executive Action
paragraphs: To help DOD decrease environmental health risks to service personnel,  contractors, and host country 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 develop the necessary 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.
section_title: Agency Comments and Our Evaluation
paragraphs: 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. 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, Secretaries of Defense and Veterans Affairs, and other  interested parties. In addition, the report will be available at no charge on  GAO’s Web site at 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.
section_title: Appendix I: Objectives, Scope, and Methodology
paragraphs: 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 the Department of  Defense (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 to 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. In addition, we reviewed  inspection reports conducted by the Defense Contract Management  Agency 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 the U.S. Central Command’s 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 2002 through 2010. 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 contract provisions, exposed them to air pollutants that  subsequently caused serious health problems.  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.
section_title: Appendix II: Comments from the Department of Defense
section_title: Appendix III: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
section_title: Staff Acknowledgments
paragraphs: 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.