Waste Management: DOD Has Generally Addressed Legislative Requirements on the Use of Burn Pits but Needs to Fully Assess Health Effects
Published: 2016-09-26T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: Burn pits help base commanders manage waste generated by U.S. forces overseas, but they also produce harmful emissions that military and other health professionals believe may result in chronic health effects for those exposed. Section 313 of the NDAA for FY 2015 requires the Secretary of Defense to review DOD compliance with law and guidance regarding the disposal of covered waste in burn pits. DOD submitted a report on the results of its review in March 2016.
Section 313 also includes a provision for GAO to assess DOD's report and its compliance with applicable DOD instruction and law. This report evaluates the extent to which (1) DOD's report addressed the elements required in section 313; (2) DOD, including combatant commands, issued guidance for burn pit use that addresses applicable legislative requirements; and (3) DOD has assessed any health risks of burn pit use. GAO compared DOD's report to elements required in section 313, reviewed policies and procedures and interviewed DOD officials.
section_title: What GAO Found
paragraphs: In assessing the Department of Defense's (DOD) March 2016 report to Congress on the use of burn pits, GAO found that it generally addressed the requirements in section 313 of the Carl Levin and Howard P. “Buck” McKeon National Defense Authorization Act (NDAA) for Fiscal Year (FY) 2015. To complete this report, DOD tasked the military services, the Joint Staff, and the overseas combatant commands to provide information on the requirements in the mandate, including policies and procedures related to the disposal of covered waste (including certain types of hazardous waste, medical waste, and items such as tires, treated wood, and batteries) in burn pits during contingency operations. GAO found that DOD's report fully addressed four of the seven reporting requirements and partially addressed the remaining three. For example, the report addressed who is responsible for ensuring compliance with the legislative requirements, but partially addressed whether the waste categories are appropriately and clearly distinguished in surveys and assessments.
Although DOD established guidance to meet applicable legislative requirements through the issuance of DOD Instruction 4715.19, U.S. Central Command is the only overseas geographic combatant command that has established complementary policies and procedures for implementing this guidance. The instruction applies to all the combatant commands, but it does not specify how combatant commanders will ensure compliance with requirements in the instruction. Officials from the other geographic combatant commands stated that their commands have not developed similar policies and procedures because they do not utilize burn pits and there is an absence of current contingency operations in their respective areas of responsibility. Nonetheless, while most of the overseas geographic commands may not currently be involved in contingency operations within their areas of responsibility, waste disposal would likely be required if such operations arise in the future, and the use of burn pits would be one option for disposing of waste. Establishing policies and procedures would better position these commands to implement DOD's instruction.
The effects of exposing individuals to burn pit emissions are not well understood, and DOD has not fully assessed these health risks. DOD officials stated that there are short-term effects from being exposed to toxins from the burning of waste. However, the officials also stated that DOD does not have enough data to confirm whether direct exposure to burn pits causes long-term health issues. Although DOD and the Department of Veterans Affairs have commissioned studies to enhance their understanding of burn pit emissions, the current lack of data on emissions specific to burn pits and related individual exposures limits efforts to characterize potential long-term health impacts on servicemembers and other base personnel. A 2011 report by the Institute of Medicine outlined the data needed for assessing exposures and potential related health risks, and the Department of Veterans Affairs has established a registry to collect some information. However, DOD has not undertaken data-gathering and research efforts to specifically examine this relationship to fully understand any associated health risks.
section_title: What GAO Recommends
paragraphs: GAO made three recommendations to include establishing policies and procedures and ensuring research specifically examines the relationship between direct burn pit exposure and long-term health issues. DOD concurred with the first recommendation and partially concurred with the second, citing research it has or has plans to conduct. GAO agrees this research contributes to general understanding but continues to believe more specific research is needed.

section_title: Letter
paragraphs: Since the initiation of military operations in Afghanistan in 2001 and Iraq  in 2003, the Department of Defense (DOD) has employed several  methods to dispose of the waste that U.S. forces have generated in both  countries. In general, the methods employed have been left to the  discretion of base commanders and include the use of incinerators,  landfills, and open-air burn pits on or near military bases. According to  DOD officials, when making these decisions, base commanders may take  into consideration a number of factors, including the local security  situation, the number of personnel on the installation, and the amount and  type of waste generated by those personnel. As one of the options  available, burn pits help base commanders manage waste, but they also  produce smoke and harmful emissions that military and other health  professionals believe may result in acute and chronic health effects for  those exposed to the emissions. U.S. environmental laws, such as the  Clean Air Act and the Solid Waste Disposal Act, do not generally apply  overseas.
Section 317 of the National Defense Authorization Act for Fiscal Year  2010 (NDAA for Fiscal Year 2010) requires that DOD develop regulations  prohibiting the disposal of covered waste (including certain types of  hazardous waste, medical waste, and items such as tires, treated wood,  and batteries) in open-air burn pits during contingency operations, except  in circumstances where DOD determines that alternatives are not  feasible. In such a circumstance, the department is to submit notification  of this determination to the House and Senate Armed Services  Committees and include the circumstances, reasoning, and methodology  that led to such a determination. Since enactment of the NDAA for Fiscal  Year 2010, the department has submitted two notifications to the House  and Senate Armed Services Committees.
Section 313 of the Carl Levin and Howard P. “Buck” McKeon National  Defense Authorization Act for Fiscal Year 2015 (NDAA for Fiscal Year  2015) requires the Secretary of Defense to conduct a review of the  compliance of the military departments and combatant commands with  Department of Defense Instruction 4715.19 as well as with the provisions  of section 317 of the NDAA for Fiscal Year 2010 regarding the disposal of  covered waste in open-air burn pits. In addition, section 313 of the NDAA  for Fiscal Year 2015 requires that, not later than 1 year after its  enactment, the department is to submit a report to the congressional  defense committees containing the results of its review. DOD submitted  that report in March 2016. Section 313 also includes a provision for GAO  to assess the methodology used by DOD in conducting its review, the  adequacy of DOD’s report, and DOD’s compliance with DOD instruction  4715.19 and applicable law regarding the disposal of covered waste in  open-air burn pits by the military departments and combatant commands.  This report evaluates the extent to which (1) DOD’s March 2016 report  addresses the elements required in section 313 of the NDAA for Fiscal  Year 2015; (2) DOD, to include the combatant commands, issued  guidance for burn pit use that addresses applicable legislative  requirements; and (3) DOD has assessed any health risks of burn pit use.
To evaluate the extent to which DOD’s March 2016 report addresses the  elements required in section 313 of NDAA for Fiscal Year 2015, we  reviewed the methodology DOD used to create the report and analyzed  the content of DOD’s report to determine the extent to which it addresses  each of seven elements required in section 313. We also interviewed  knowledgeable officials about compiling information for the report and the  methodology used to develop the report, including individuals within the  Office of the Secretary of Defense; overseas geographic Combatant  Commands, including U.S. Central Command (CENTCOM), U.S. Africa  Command, U.S. European Command, U.S. Pacific Command, and U.S.  Southern Command; service component commands, including U.S. Army  Central Command and U.S. Air Force Central Command; and the Joint  Staff. Two GAO analysts independently reviewed DOD’s report and  compared its contents with each element required by section 313. The  analysts categorized each of the reporting requirements as one of the  following: (1) “addressed,” if our assessment showed that the information  reported by DOD fully addresses the element required by section 313 of  the NDAA for Fiscal Year 2015; (2) “partially addressed,” if our  assessment showed that additional information is needed to fully address  the reporting requirement; or (3) “not addressed,” if our assessment  showed that DOD did not report any information related to the reporting  requirement. The two analysts created a final assessment that reconciles  their two independent assessments and reflects the analysts’ consensus.  In the case of any conflicting determinations, a GAO staff attorney  adjudicated the difference.
To determine the extent to which DOD, to include combatant commands,  issued guidance for burn pit use that addresses applicable statutory  requirements, we gathered and assessed information regarding DOD’s  policies on the disposal of waste, including DOD Instruction 4715.19 and  DOD Instruction 4715.22. In addition, we identified any policies and  procedures that the overseas combatant commands have in place to  implement DOD guidance. We discussed the implementation of  CENTCOM’s policies and procedures with officials from CENTCOM and  U.S. Army Central Command. We also contacted U.S. Africa Command,  U.S. European Command, U.S. Pacific Command, and U.S. Southern  Command to obtain information on their use of burn pits and relevant  guidance they have developed. We did not contact U.S. Northern  Command because it was not in the scope of DOD’s report. We then  evaluated the policies, procedures, and actions identified against relevant  DOD guidance and applicable law, including section 313 of the NDAA for  Fiscal Year 2015 and section 317 of the NDAA for Fiscal Year 2010. We  were not able to verify the extent to which burn pits are used, but instead  relied on the information officials provided.
To evaluate the extent to which DOD has assessed any health effects of  burn pit use, we reviewed relevant health assessments on the effects of  burn pits, including a 2011 report by the Institute of Medicine that was  contracted by the Department of Veterans Affairs, as well as prior related  reports by GAO and the Special Inspector General for Afghanistan  Reconstruction. We also interviewed officials from U.S. Central  Command, U.S. Army Central Command, U.S. Air Force Central  Command, Department of Veterans Affairs, and Institute of Medicine to  discuss any effects of exposures to burn pit emissions, among other  things.
We conducted this performance audit from July 2015 to September 2016  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
subsections: section_title: DOD Burn Pit Use
paragraphs: In establishing related guidance on solid waste management in 1978,  DOD has recognized that burning waste in open pits poses environmental  and health hazards. However, burn pits—shallow excavations or surface  features with berms used to conduct open-air burning—were often  chosen as a method of waste disposal during recent contingency  operations in the CENTCOM area of responsibility, which extends from  the Middle East to Central Asia and includes Iraq and Afghanistan.
In 2010 we reported that there were 251 active burns pits in Afghanistan  and 22 in Iraq. Additionally, we reported that the military used burn pits  to dispose of waste because of their expedience, and that waste  management alternatives could decrease DOD’s reliance on the use of  burn pits. We recommended that DOD implement relevant guidance  related to burn pit operations, improve its adherence to relevant guidance  on waste management, and analyze alternatives to its current practices.  DOD generally concurred with the recommendations and took actions to  address them. For example, the Army Materiel Command began focusing  on solid waste management, including burn pits, and required contractors  to segregate non-hazardous, hazardous, and recyclable materials;  establish recycling systems; and maintain all solid waste operations in  accordance with DOD guidance.
According to DOD officials, while the Army considered alternative waste  disposal methods such as deployable, ready-made incinerators as  standard equipment to each Army unit, it ultimately decided against  issuing them due to logistical issues. Further, the use of waste disposal  alternatives other than burn pits is not always possible. For example,  DOD officials have stated that there have been times when incinerators  have not been used because of the challenges associated with obtaining  permits and visas for the personnel who were contracted to operate and  maintain them. In addition, DOD officials stated that using landfills as an  alternative waste disposal option has not always been an option because  of security concerns surrounding local landfills off base or space  constraints for landfills on base. When alternatives are not available,  military base commanders have resorted to the use of burn pits.
section_title: Health Concerns Related to the Use of Burn Pits
paragraphs: Although burn pits help base commanders to manage waste, they also  produce smoke and harmful emissions that military and other health  professionals believe may result in acute and chronic health effects for  those exposed. We previously reported that some veterans returning from  the Iraq and Afghanistan 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 Iraq and Afghanistan, resulting  in exposure to harmful smoke that caused these adverse health effects.  We also previously reported on the difficulty of establishing a correlation  between occupational and environmental exposures and health issues.  For example, in 2012 we found that establishing causation between an  exposure and an adverse health condition can be difficult for several  reasons, including that for many environmental exposures, there is a  latency period—the time period between initial exposure to a contaminant  and the date on which an adverse health condition is diagnosed. When  there is a long latency period between an environmental exposure and an  adverse health condition, choosing between multiple causes of exposure  may be difficult. In addition, in 2015 we found that the Army had recently  published a study that evaluated associations between deployment to  Iraq and Kuwait and the development of respiratory conditions post- deployment. However, the study was unable to identify a causal link  between exposures to burn pits and respiratory conditions.
section_title: Relevant Laws, DOD Guidance, and CENTCOM Regulations
paragraphs: Section 317 of the NDAA for Fiscal Year 2010 requires DOD to develop  regulations prohibiting the disposal of covered waste in burn pits during  contingency operations, except in circumstances where alternatives are  not feasible. This provision also requires DOD to notify Congress of the  decision to dispose of covered waste in burn pits, along with the  circumstances, reasoning, and methodology leading to the decision.  Additionally, for each subsequent 180-day period during which covered  waste is disposed of in a burn pit, DOD must submit to Congress a  justification for continuing to operate the burn pit. Further, even in the  absence of a contingency operation and applicable guidance, DOD  overseas environmental guidance exists prohibiting the use of burn pits,  except in certain instances.
In response to section 317, DOD issued department-wide guidance  regarding the use of burn pits, environmental management, and  occupational health. Specifically, in 2011 the Under Secretary of Defense  for Acquisition, Technology and Logistics issued DOD Instruction  4715.19, which establishes policy, assigns responsibilities, and provides  guidance regarding the use of burn pits during contingency operations.  In 2016 DOD issued Instruction 4715.22, which establishes policy,  assigns responsibilities, and provides direction for environmental  management at contingency locations. Additionally, the guidance directs  the Assistant Secretary of Defense for Energy, Installations, and  Environment to establish Contingency Location Environmental Standards  by February 2017. These standards are to define environmental  standards for implementation at contingency locations in order to protect  force health, minimize environmental impact, and sustain mission  effectiveness.
Two other DOD instructions, DOD Instruction 6055.05 and DOD  Instruction 6055.01, provide guidance regarding risk management  procedures associated with occupational or environmental factors.  Specifically, DOD Instruction 6055.05 expands risk management  procedures to anticipate, recognize, evaluate, and control health hazards  associated with occupational and environmental exposures to chemical,  physical, and biological hazards in DOD workplaces, including military  operations and deployments. The guidance is aimed at protecting DOD  personnel from accidental death, injury, and illness caused by hazardous  occupational or environmental exposures. Further, it applies risk  management strategies designed to achieve reductions in all mishaps,  injuries, and illnesses, and compliance with DOD safety and health  standards and policies. DOD Instruction 6055.01 provides guidance to  protect DOD personnel from accidental death, injury, or occupational  illness throughout all operations worldwide, with certain limitations.  Specifically, this guidance reinforces the concept of applying risk  management strategies to eliminate occupational injury or illness and loss  of mission capability and resources, both on and off duty.
Since 2008, CENTCOM has issued guidance relating to environmental  assets within its area of responsibility.  CENTCOM Regulation 200-1  requires bases within CENTCOM’s area of responsibility to have an  environmental assessment program, structured to optimize environmental  asset expertise, protection, enhancement, and security. This regulation  requires CENTCOM environmental leads to develop policies and  procedures for management and disposal of solid waste, hazardous  waste, and medical waste, among others. CENTCOM Regulation 200-2  guides solid waste management practices throughout CENTCOM’s area  of responsibility, including minimum requirements for operating and  monitoring burn pits. This regulation also provides guidance for  managing environmental concerns, such as hazardous materials and  regulated medical and solid waste. It also includes requirements for base  commanders to develop a solid waste management plan and strategy to  transition to alternative waste disposal methods, such as an incinerator.
section_title: DOD’s Report on the Disposal of Covered Waste in Burn Pits Generally Addressed Mandate Requirements
paragraphs: On the basis of our assessment of DOD’s March 2016 burn pit report, we  found that it generally addressed the requirements in section 313 of the  NDAA for Fiscal Year 2015. According to DOD officials, to gather  information for and develop its report, DOD tasked each of the military  services, the Joint Staff, and the overseas combatant commands—U.S.  Central Command, U.S. Africa Command, U.S. European Command,  U.S. Pacific Command, and U.S. Southern Command—to provide  information on the requirements in section 313, which included providing  information on the policies and procedures related to the disposal of  covered waste in burn pits during contingency operations. Section 313  contains seven specific reporting elements that DOD was required to  address in its report. We determined, based on our assessment, that  DOD’s report fully addressed four of the seven reporting requirements  and partially addressed the remaining three. Table 1 summarizes our  analysis of the extent to which DOD’s report addressed each of the  specific requirements in section 313.
Our assessment identified that reporting requirements 1, 3, and 5 are  partially addressed in DOD’s report because we found that the responses  to the reporting requirement lacked required detail and instead only  identified relevant policy. For example, we assessed reporting  requirement 3 to be partially addressed because DOD’s report included  guidance used to distinguish categories of waste but did not include  information about whether the categories were appropriately and clearly  distinguished in environmental surveys and assessments. Similarly, we  assessed reporting requirement 5 to be partially addressed because DOD  reported on the notification process by which burning covered waste in a  burn pit is requested and approved, and the process by which Congress  is notified, but did not discuss how this notification process could be  improved, if applicable.
The DOD official responsible for compiling the report stated that because  section 313 of the National Defense Authorization Act of Fiscal Year 2015  applies to the Office of the Secretary of Defense, which focuses primarily  on strategic and policy-related issues, the requests for specific  information contained in reporting requirements 1, 3 and 5 were outside  its purview, and information with this degree of specificity could be  provided only by lower-level commands. The Office of the Secretary of  Defense tasked lower-level commands, including each of the military  services, the Joint Staff, and the combatant commands, to provide  information for the report. However, the tasking order sent to these lower- level commands contained the same wording as the mandate language in  section 313 of the National Defense Authorization Act of Fiscal Year  2015, with little clarification of the level of detail that these entities should  include in their responses. As a result, the level of information obtained  and used to develop the report varied and partially addressed three of the  seven requirements.
section_title: DOD Established Guidance to Meet Applicable Law, but Most Combatant Commands Have Not Issued Policies and Procedures for Implementing DOD Guidance on Burn Pit Use
paragraphs: While DOD issued guidance on burn pit use, as required by law, it is not  clear how the guidance will be implemented in future contingency  operations because the overseas combatant commands, except for  CENTCOM, have not issued related policies and procedures for  implementing this guidance. As previously stated, in response to section  317 of the National Defense Authorization Act of Fiscal Year 2010, in  2011 DOD issued DOD Instruction 4715.19. This instruction defines  covered waste as hazardous waste, medical waste, and other items  including tires, treated wood, batteries, and plastics, among other  things. The guidance also prohibits the disposal of covered waste in  burn pits during contingency operations, except in circumstances where  alternatives are not feasible, and provides high-level guidance on the  notification process in such circumstances. Specifically, the instruction  states that the Under Secretary of Defense for Acquisition, Technology,  and Logistics must notify Congress within 30 days of the combatant  commander’s determination that no alternative disposal method for  covered waste, other than in a burn pit, is feasible. The instruction further  states that a justification for continued burning of covered waste in a burn  pit is also required to be submitted to Congress for each subsequent 180- day period.
CENTCOM is the only overseas geographic combatant command that  has established policies and procedures that govern waste management  during contingency operations, including implementing the DOD burn pit  guidance. Specifically, CENTCOM Regulations 200-1 and 200-2 provide  policies, assign responsibilities for implementing DOD Instruction  4715.19, and set environmental standards. CENTCOM Regulation 200-2  applies to military personnel and civilian contractors who operate burn  pits in the CENTCOM area of responsibility, and CENTCOM Regulation  200-1 applies to its components and to all other U.S. military forces  operating in CENTCOM’s area of responsibility. These regulations  provide, among other things, detailed guidance for submitting burn pit  notifications. Additionally, CENTCOM Regulation 200-2 acknowledges  that burn pits are typically used when bases are first established, but  provides a specific threshold—when an installation exceeds 100 U.S.  personnel for 90 days—after which burn pits must be replaced by  alternative waste disposal methods. If, however, there is no feasible  alternative to the use of burn pits, base officials are to forward the  rationale for the continued use of burn pits to the appropriate service  component command.
According to DOD officials familiar with CENTCOM’s procedures, this  determination is first sent to the appropriate land component or joint task  force command for review. These commands work in conjunction with the  base commander to ensure that the burn pit justification criteria are met.  The notification is then sent to the designated service component, and the  service component decides whether the notification will be further  processed. In doing so, the service component reviews the rationale,  such as the basis for the lack of alternatives, an estimate of how long  burn pits will continue to be used, or a preliminary health assessment,  and then forwards the notification to CENTCOM along with a  recommendation for approval or disapproval. Once approved by  CENTCOM, according to officials, the determination is forwarded to the  Under Secretary of Defense for Acquisition, Technology, and Logistics  within 15 days after approval.
The use of burn pits in the CENTCOM area of responsibility has declined  since our last report in 2010. As of June 2016, DOD officials told us that  there were no military-operated burn pits in Afghanistan and only one in  Iraq, of which Congress had been notified. According to DOD officials,  the decline in the number of burn pits from 2010 to 2016 can be attributed  to such factors as (1) using contractors for waste disposal and (2)  increased use of waste management alternatives such as landfills and  incinerators. DOD officials also acknowledged, however, that burn pits  are being used to dispose of waste in other locations that are not military- operated and that no notifications have been made in these instances  because the means of disposal are not within DOD’s control. Specifically,  these officials noted instances in which local contractors had been  contracted to haul away waste and subsequently disposed of the waste in  a burn pit located in close proximity to the installation. In such instances,  officials stated that they requested that the contractors relocate the burn  pit.
In contrast with CENTCOM, other geographic combatant commands have  not established additional policies and procedures that govern waste  management, including the disposal of waste in burn pits and the  notification procedures to be followed in the event that no other  alternatives are feasible. As of June 2016, according to an official from  U.S. Africa Command, command-specific burn pit policies and  procedures were being developed. According to officials from the other  overseas geographic combatant commands, their commands have not  developed similar policies and procedures because they do not utilize  burn pits and there is an absence of current contingency operations in  their respective areas of responsibility. In addition, a U.S. European  Command official explained that their operations are generally in  countries that have specific guidance that discourage the use of burn pits  as a method of waste disposal. Nonetheless, while most of the overseas  geographic commands may not currently be involved in contingency  operations within their areas of responsibility, waste disposal would likely  be required if such operations arise in the future, and the use of burn pits  would be one option for disposing of waste. Moreover, a U.S. Africa  Command official stated that while there were no known DOD-operated  burn pits in that command’s area of responsibility, burn pits were being  operated by local nationals near an installation on which there were DOD  personnel.
Moreover, DOD’s guidance on burn pits in DOD Instruction 4715.19  applies to all the combatant commands, including the requirements to  make determinations in circumstances in which no alternative disposal  method for covered waste, other than in an open-air burn pit, is feasible,  and to forward those determinations to the Under Secretary of Defense  for Acquisition, Technology and Logistics. However, the instruction does  not specify how combatant commanders will ensure compliance with  requirements in the instruction, including which organizations within the  commands would be responsible for notifications, or how they would  monitor and report on the use of any burn pits. In addition, other than  requiring a solid waste management plan that addresses the use of burn  pits, the instruction does not require combatant commanders to develop  complementary policies and procedures concerning burn pits relevant to  their respective areas of responsibility. Further, according to Joint  Publication 3-0, Joint Operations, waste disposal is a consideration  throughout planning and execution, and until forces redeploy. Moreover,  according to Standards for Internal Control in the Federal Government,  those in key roles may further define policies through day-to-day  procedures, and these procedures may include the timing of when a  control activity occurs and any follow-up corrective actions to be  performed by competent personnel if deficiencies are identified.
DOD officials acknowledged that limiting burn pit use for waste disposal is  important, as the relevant guidance stipulates, especially when disposing  of covered waste, because of the harmful toxins emitted in the air.  Without policies and procedures governing waste management during  contingency operations, including the use of burn pits, combatant  commanders are not well positioned to implement the requirements of  DOD Instruction 4715.19 if burn pits become necessary for disposing of  waste in a future contingency operation within their area of operation,  specifically with regard to notification procedures that are relevant  to the  conditions that exist in their respective areas of responsibility.
section_title: DOD has not Fully Assessed the Health Risks of Burn Pits
paragraphs: The impacts from exposing individuals to burn pit emissions are not well  understood, and DOD has not fully assessed these health risks. Under  DOD Instruction 6055.01, it is DOD policy to apply risk-management  strategies to eliminate occupational injury or illness and loss of mission  capability or resources. DOD Instruction 6055.01 also instructs all DOD  components to establish procedures to ensure that risk-acceptance  decisions are documented, archived, and reevaluated on a recurring  basis. Furthermore, DOD Instruction 6055.05 requires that hazards are  identified and risk is evaluated as early as possible, including the  consideration of exposure patterns, duration, and rates. Notwithstanding  this guidance, according to DOD officials, DOD has not fully assessed the  health risks of use of burn pits.
According to DOD officials, DOD’s ability to assess these risks is limited  by a lack of adequate information on (1) the levels of exposure to burn pit  emissions and (2) the health impacts these exposures have on  individuals. With respect to information on exposure levels, DOD has not  collected data from emissions or monitored exposures from burn pits as  required by its own guidance. DOD Instruction 4715.19 requires that  plans for the use of open-air burn pits include ensuring the area is  monitored by qualified force health protection personnel for unacceptable  exposures, and CENTCOM Regulation 200-2 requires steps to be taken  to sample or monitor burn pit emissions. A DOD official stated that the  department considers open air burning and other airborne contaminant  sources when determining its monitoring strategies for the potentially  exposed population and evaluating health risks in accordance with DOD  Instructions 6490.03 and 6055.05. However, the official also stated that  DOD has not collected direct data from burn pit emissions because the  data do not represent the overall air quality to which personnel are  exposed. Additionally, CENTCOM Regulation 200-1 requires  environmental surveying to be conducted at a base if the base is  occupied or is expected to be occupied for 30 or more days, or at the  base’s closure. According to DOD officials, environmental surveys are  conducted, generally once a year, and these surveys assist in identifying  both potential risks to servicemembers’ health and air pollutants.  However, DOD officials stated that there are no processes in place to  specifically monitor burn pit emissions for the purposes of correlating  potential exposures. They attribute this to a lack of singular exposure to  the burn pit emissions, or emissions from any other individual item;  instead, monitoring is done for the totality of air pollutants from all sources  at the point of population exposure. An official from U.S. Africa  Command, however, stated that efforts are underway in that command’s  area of responsibility to conduct an air quality study specifically because  of the use of burn pits by local nationals off the installation where DOD  personnel are housed. Given the potential use of burn pits near  installations and their potential use in future contingency operations,  establishing processes to monitor burn pit emissions for unacceptable  exposures would better position DOD and combatant commanders to  collect data that could help assess exposure to risks.
In the absence of the collection of data to examine the effects of burn pit  exposure on servicemembers, the Department of Veterans Affairs in 2014  created the airborne hazards and open-air burn pit registry, which  allows eligible individuals to self-report exposures to airborne hazards  (such as smoke from burn pits, oil-well fires, or pollution during  deployment), as well as other exposures and health concerns. The  registry helps to monitor health conditions affecting veterans and  servicemembers, and to collect data that will assist in improving programs  to help those with deployment exposure concerns.
With respect to the information on the health effects from exposure to  burn pit emissions, DOD officials stated that there are short-term effects  from being exposed to toxins from the burning of waste, such as eye  irritation and burning, coughing and throat irritation, breathing difficulties,  and skin itching and rashes. However, the officials also stated that DOD  does not have enough data to confirm whether direct exposure to burn  pits causes long-term health issues. Although DOD and the Department  of Veterans Affairs have commissioned studies to enhance their  understanding of airborne hazards, including burn pit emissions, the  current lack of data on emissions specific to burn pits limits DOD’s ability  to fully assess potential health impacts on servicemembers and other  base personnel, such as contractors. For example, in a 2011 study that  was contracted by the Department of Veterans Affairs, the Institute of  Medicine stated that it was unable to determine whether long-term health  effects are likely to result from burn pit exposure due to inadequate  evidence of an association. While the study did not determine a linkage  to long-term health effects, because of the lack of data, it did not discredit  the relationship either. Rather, it outlined a methodology of how to collect  the necessary data to determine the effects of the exposure.
Specifically, the 2011 study outlined the feasibility and design issues for  an epidemiologic study—that is, a study of the distribution and  determinants of diseases and injuries in human populations—of veterans  exposed to burn pit emissions. The elements of a well-designed  epidemiologic study of the potential health effects of an environmental  exposure include identification of a relevant study population of adequate  size; comprehensive assessment of exposure; careful evaluation of  health outcomes; adequate follow-up time; reasonable methods for  controlling, confounding, and minimizing bias; and appropriate statistical  analyses. Further, the 2011 study reported that there are a variety of  methods for collecting exposure information, but the most desirable is to  measure exposures quantitatively at the individual level. Individual  exposure measurements can be obtained through personal monitoring  data or biomonitoring. However, if individual monitoring data are not  available, and they rarely are, individual exposure data may also be  estimated from modeling of exposures, self-reported surveys, interviews,  job exposure matrixes, and environmental monitoring. Further, to  determine the incidence of chronic disease, the study states that  servicemembers must be tracked from their time of deployment, over  many years. The 2011 study goes into further detail on how data can be  collected, with alternatives, and processed without biases.
While the methodology of how to conduct an epidemiologic study is  outlined, DOD has not taken steps to conduct this type of research study,  specifically one that focuses on the direct, individual exposure to burn pit  emissions and the possible long-term health effects of such exposure.  Instead, some officials commented that there were no long-term health  effects linked to the exposures of burn pits because the 2011 study did  not acknowledge any. Conversely, Veterans Affairs officials stated that a  study aimed at establishing health effect linkages could be enabled by the  data in its airborne hazards and open-air burn pit registry, which collects  self-reported information on servicemembers’ deployment location and  exposure.
Further, in response to a mandate contained in section 201 of Public Law  112-260, the National Academies of Sciences, Engineering, and Medicine  will convene a committee to provide recommendations on collecting,  maintaining, and monitoring information through the registry. The  committee will assess the effectiveness of the Department of Veterans  Affairs’ information gathering efforts and provide recommendations for  addressing the future medical needs of the affected groups. The study will  be conducted in two phases. Phase 1 will be a review of the data  collection methods and outcomes, as well as an analysis of the self- reported veteran experience data gathered in the registry. Phase 2 will  focus on the assessment of the effectiveness of the actions taken by the  Department of Veterans Affairs and DOD and will provide  recommendations for improving the methods enacted. According to  officials, the expected release date of the report is late fall of 2016.  Considering the results of this review as well as the methodology of the  2011 Institute of Medicine study as part of an examination of the  relationship between direct, individual exposure to burn pit emissions and  long-term health effects could better position DOD to fully assess those  health risks.
section_title: Conclusions
paragraphs: For over three decades, DOD has understood that disposing of waste in  burn pits poses health hazards. In light of its experience in Iraq and  Afghanistan, CENTCOM has taken steps to reduce burn pit use in its  area of responsibility through the use of alternative methods of waste  disposal, such as incinerators. However, DOD likely cannot completely  eliminate the need for burn pits in future contingency operations. Although  CENTCOM has specific policies and procedures for burn pit operations in  its area of responsibility, other geographic commands do not, potentially  leaving them ill-prepared to plan for and to safely and effectively manage  burn pits in the event of contingency operations in their respective  geographic regions. Moreover, although DOD and the Department of  Veterans Affairs have commissioned studies to enhance their  understanding of airborne hazards during deployments, given that DOD  may have to use burn pits in future contingency operations, as allowed  under current policies, ensuring that research efforts specifically examine  the relationship between direct, individual exposure to burn pit emissions  and long-term health issues could help improve the understanding and  potentially minimize risks related to such exposure.
section_title: Recommendations for Executive Action
paragraphs: To better position combatant commanders to implement the requirements  of DOD Instruction 4715.19 if burn pits become necessary and to assist in  planning for waste disposal in future military operations, we recommend  that the Secretary of Defense direct the combatant commanders of U.S.  Africa Command, U.S. European Command, U.S. Pacific Command, and  U.S. Southern Command to establish implementation policies and  procedures for waste management. Such policies and procedures should  include, as applicable, specific organizations within each combatant  command with responsibility for ensuring compliance with relevant  policies and procedures, including burn pit notification, and, when  appropriate, monitoring and reporting on the use of burn pits.
To better understand the long-term health effects of exposure to the  disposal of covered waste in burn pits, we recommend that the Secretary  of Defense direct the Under Secretary of Defense for Acquisition,  Technology, and Logistics to take the following two actions:
Take steps to ensure CENTCOM and other geographic combatant  commands, as appropriate, establish processes to consistently  monitor burn pit emissions for unacceptable exposures.
In coordination with the Secretary of Veterans Affairs, specifically  examine the relationship between direct, individual, burn pit exposure  and potential long-term health-related issues. As part of that  examination, consider the results of the National Academies of  Sciences, Engineering, and Medicine’s report on the Department of  Veteran Affairs registry and the methodology outlined in the 2011  Institute of Medicine study that suggests the need to evaluate the  health status of service members from their time of deployment over  many years to determine their incidence of chronic disease, with  particular attention to the collection of data at the individual level,  including the means by which that data is obtained.
section_title: Agency Comments and Our Evaluation
paragraphs: We provided a draft of this report to DOD and the Department of Veterans  Affairs for review and comment. In its written comments, DOD concurred  with our first recommendation and partially concurred with our second  and third recommendations. The Department of Veterans Affairs provided  general comments on our draft report but did not comment specifically on  the recommendations. DOD’s and the Department of Veterans Affairs’  comments are summarized below and reprinted in their entirety in  appendixes I and II, respectively. Additionally, DOD and the Department  of Veterans Affairs also provided technical comments, which we  incorporated into the report, as appropriate.
DOD concurred with our first recommendation that the Secretary of  Defense direct the combatant commanders of U.S. Africa Command, U.S.  European Command, U.S. Pacific Command, and U.S. Southern  Command to establish implementation policies and procedures for waste  management, to include burn pit notification and, when appropriate,  monitoring and reporting on the use of burn pits.
DOD partially concurred with our second and third recommendations in  the draft report, that it take steps to ensure that CENTCOM and other  geographic combatant commands, as appropriate, establish processes to  consistently monitor burn pit emissions and that the department, in  coordination with the Secretary of Veterans Affairs, sponsor research to  examine the relationship between burn pit exposure and potential health- related issues. In its response, DOD stated that it will ensure that  geographic combatant commands establish and employ processes to  consistently monitor burn pit emissions for unacceptable exposures at the  point of exposure and, if necessary, at individual sources. However, DOD  also stated that our recommendation in the draft report to sponsor  research did not acknowledge the volume of research conducted and  planned by the department and the Secretary of Veterans Affairs, in  collaboration with other research entities. Specifically, DOD stated in its  letter that research studies have already been completed, are ongoing, or  are planned to improve the understanding of burn pit and other ambient  exposures to long-term health outcomes, and that the studies, where  applicable, consider and incorporate the methodology outlined in the  2011 Institute of Medicine study. Additionally, DOD stated that it has  implemented an Airborne Hazards Joint Action Plan process  collaboratively with the Department of Veterans Affairs as a primary  means of identifying research needs within DOD and the Department of  Veterans Affairs to address burn pit and other ambient air exposures  during deployments.
In our report, we acknowledge that DOD and the Department of Veterans  Affairs have commissioned studies to enhance their understanding of  airborne hazards during deployment, including burn pit emissions, many  of which are listed in the department’s response to our recommendation  in the draft report. We also agree that the ongoing and planned research  studies listed in DOD’s response will continue to contribute to the general  knowledge of health effects of airborne hazards during deployment.  However, during the course of our review, DOD and other officials told us  that they have not specifically examined the relationship between direct,  individual burn pit exposure and potential long-term health-related issues.  Further the research studies presented in DOD’s response to our draft  recommendation do not directly make this linkage either. This current lack  of data on direct, individual exposure to burn pit emissions limits DOD’s  ability to fully assess potential long-term health impacts on  servicemembers. As we discussed in the report, the 2011 Institute of  Medicine study outlines a methodology of how to collect the necessary  data to determine the effects of exposure. Specifically, the 2011 study  states that the most desirable method to measure exposures  quantitatively is at the individual level. Individual exposure measurements  can be obtained through personal monitoring data. The intent of the  recommendation in the draft report was to address this linkage.  Therefore, we have clarified our recommendation and our report and  continue to believe that research that addresses individual exposure to  burn pit emissions and the potential long-term health effects would help  provide important information to fully understand and mitigate future  health risks.
In its general comments, the Department of Veterans Affairs noted that it  coordinates with DOD in collecting data on veterans and servicemembers  potentially exposed to burn pit emissions and other airborne exposures,  to address relevant research needs. Additionally, the Department of  Veterans Affairs stated that eligible servicemembers are urged to  participate in the Airborne Hazards and Open Burn Pit Registry, and as of  August 14, 2016, 84,958 individuals have completed an online  questionnaire to elicit responses to multiple categories of health, among  other things.
We are sending copies of this report to the appropriate congressional  committees, the Secretary of Defense; the Secretary of Veterans Affairs;  the Under Secretary of Defense for Acquisition, Technology and  Logistics; the relevant combatant commanders, and the Chairman of the  Joint Chiefs of Staff. In addition, the report is available at no charge on  the GAO website at http://www.gao.gov.
If you or your staff have any questions about this report, please contact  me at (202) 512- 5431 or russellc@gao.gov. Contact points for our  Offices of Congressional Relations and Public Affairs may be found on  the last page of this report. Key contributors to this report are listed in  appendix III.
section_title: Appendix I: Comments from the Department of Defense
section_title: Appendix II: Comments from the Department of Veterans Affairs
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, Guy LoFaro (Assistant Director),  Lorraine Ettaro, J. Alfredo Gomez, Mike Hix, Shahrzad Nikoo, Leigh Ann  Sheffield, Cheryl Weissman, Natasha Wilder, and Eugene Wisnoski made  key contributions to this report.