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

Letter

Background

DOD Burn Pit Use

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.

Health Concerns Related to the Use of Burn Pits

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.

Relevant Laws, DOD Guidance, and CENTCOM Regulations

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.

DOD’s Report on the Disposal of Covered Waste in Burn Pits Generally Addressed Mandate Requirements

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.

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

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.

DOD has not Fully Assessed the Health Risks of Burn Pits

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.

Conclusions

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.

Recommendations for Executive Action

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.

Agency Comments and Our Evaluation

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.

Appendix I: Comments from the Department of Defense

Appendix II: Comments from the Department of Veterans Affairs

Appendix III: GAO Contact and Staff Acknowledgments

GAO Contact

Staff Acknowledgments

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.