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DOD Should Improve Adherence to Its Guidance on Open Pit Burning and Solid Waste Management

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DOD Should Improve Adherence to Its Guidance on Open Pit Burning and Solid Waste Management United States Government Accountability Office Report to Congressional Requesters GAO October 2010 AFGHANISTAN AND IRAQ DOD Should Improve Adherence to Its Guidance on Open Pit Burning and Solid Waste Management GAO-11-63 October 2010 Accountability • Integrity • Reliability AFGHANISTAN AND IRAQ DOD Should Improve Adherence to Its Guidance on Open Pit Burning and Solid Waste Management Highlights of GAO-11-63, a report to congressional requesters Why GAO Did This Study What GAO Found From the start of military operations in The military has relied heavily on open pit burning in both conflicts, and Afghanistan and Iraq, the U.S. military operators of burn pits have not always followed relevant guidance to protect and its contractors have burned solid servicemembers from exposure to harmful emissions. According to DOD, U.S. waste in open burn pits on or near military operations in Afghanistan and Iraq generate about 10 pounds of solid military bases. According to the waste per soldier each day. The military has relied on open pit burning to Department of Defense (DOD), burn dispose of this waste mainly because of its expedience. In August 2010, pit emissions can potentially harm CENTCOM estimated there were 251 burn pits in Afghanistan and 22 in Iraq. human health. U.S. Central Command CENTCOM officials said the number of burn pits is increasing in Afghanistan (CENTCOM) guidance directs the and decreasing in Iraq, which reflects U.S. troop reallocations and efforts to military’s use of burn pits, and the install waste incinerators. Despite its reliance on burn pits, CENTCOM did not Department of Veterans’ Affairs (VA) issue comprehensive burn pit guidance until 2009. Furthermore, to varying provides healthcare and other benefits to veterans and their families. 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 GAO was asked to report on the burning of items, including plastic, that produce harmful emissions. DOD (1) extent of open pit burning in officials also said that, from the start of each conflict, operators routinely Afghanistan and Iraq, and whether burned items that are now prohibited. The continued burning of prohibited the military has followed its items has resulted from a number of factors, including the constraints of guidance; (2) alternatives to burn combat operations, resource limitations, and contracts with burn pit pits, and whether the military has operators that do not reflect current guidance. examined them; and (3) extent of efforts to monitor air quality and Waste management alternatives could decrease the reliance on and exposure potential health impacts. to burn pits, but DOD has been slow to implement alternatives or fully GAO visited four burn pits in Iraq, evaluate their benefits and costs, such as avoided future costs of potential reviewed DOD data on burn pits, and health effects. Various DOD guidance documents discourage long-term use of consulted DOD and VA officials and burn pits, encourage the use of incinerators and landfills, or encourage waste other experts. GAO was unable to minimization such as source reduction. DOD has installed 39 solid waste visit burn pits in Afghanistan. incinerators in Iraq and 20 in Afghanistan, and plans to install additional incinerators in Afghanistan. To date, source reduction practices have not been What GAO Recommends widely implemented in either country and recycling consists primarily of large Among other things, GAO scrap metals. DOD plans to increase recycling at its bases in Iraq, but recommends that the Secretary of recycling at bases in Afghanistan has been limited. Further, DOD has not fully Defense improve DOD’s adherence to analyzed its waste stream in either country and lacks the information to relevant guidance on burn pit decrease the toxicity of its waste stream and enhance waste minimization. operations and waste management, U.S. Forces in Afghanistan and Iraq do not sample or monitor burn pit and analyze alternatives to its current emissions as provided by a key CENTCOM regulation, and the health impacts practices. In commenting on a draft of of burn pit exposure on individuals are not well understood, partly because this report, DOD said that it concurred the military does not collect required data on emissions or exposures from with five of the six recommendations burn pits. Army public health officials have, however, sampled the ambient and partially concurred with the sixth. GAO addressed a DOD suggestion to air at bases in each conflict and found high levels of particle pollution that clarify the sixth recommendation. VA causes health problems but is not unique to burn pits. These officials reviewed the draft report and had no identified logistical and other challenges in monitoring burn pit emissions, and comments. U.S. Forces have yet to establish pollutant monitoring systems. DOD and VA have commissioned studies to enhance their understanding of burn pit View GAO-11-63 or key components. emissions, but the lack of data on emissions specific to burn pits and related For more information, contact David exposures limit efforts to characterize potential health impacts on service C.Trimble, (202) 512-3841, [email protected] personnel, contractors, and host-country nationals. United States Government Accountability Office Contents Letter 1 Background 5 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 8 Alternatives to Open Pit Burning Include Source Reduction, Recycling, Incinerators, and Landfills, but DOD Has Not Evaluated Their Benefits or Costs 22 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 31 Conclusions 45 Recommendations for Executive Action 45 Agency Comments and Our Evaluation 46 Appendix I Objectives, Scope, and Methodology 48 Appendix II Comments from the Department of Defense 50 Appendix III GAO Contact and Staff Acknowledgments 53 Tables Table 1: Comparison of MNC-I, USFOR-A, CENTCOM, and DTM Burn Pit Guidance Relevant to Issues Congress Identified in the FY 2010 NDAA 14 Table 2: Examples of Four U.S. Bases’ Implementation of the CENTCOM Regulation’s Burn Pit Health Provisions, as of March 2010 17 Table 3: Waste Management Practices at U.S. Bases in Iraq 23 Table 4: Recycled Materials at U.S. Bases in Iraq as of June 2010 25 Table 5: Number and Percentage of MEG Exceedances in Afghanistan by Analyzed Substance 38 Table 6: Number and Percentage of MEG Exceedances in Iraq by Analyzed Substance 38 Table 7: Examples of Selected Health Surveillance Activities Executed by Force Commanders or the Armed Services 41 Page i GAO-11-63 Afghanistan and Iraq Figures Figure 1: Burn Pit at Camp Taji, Iraq, January 2010 2 Figure 2: Poor Air Quality at Camp Taji, Iraq, January 2010 8 Figure 3: Burn Pit at Camp Warhorse, Iraq, February 2010 17 Figure 4: Local Contractor’s Personnel Sorting Solid Waste, Camp Taji, Iraq 21 Figure 5: Solid Waste Incinerator, Camp Al Asad, Iraq 27 Figure 6: Number of Ambient Air Samples Collected in Afghanistan, by Year 36 Figure 7: Number of Ambient Air Samples Collected in Iraq, by Year 36 Figure 8: Fine Particle Test Results in Afghanistan Relative to Military Exposure Guidelines 39 Figure 9: Fine Particle Test Results in Iraq Relative to Military Exposure Guideline 40 Page ii GAO-11-63 Afghanistan and Iraq Abbreviations APHC Army Public Health Command CENTCOM U.S. Central Command CJTF Combined Joint Task Force DCAA Defense Contract Audit Agency DCMA Defense Contract Management Agency DOD Department of Defense DOEHRS Defense Occupational and Environmental Health Readiness System FRAGO fragmentary orders ISAF International Security Assistance Forces KBR Kellogg, Brown, and Root LOGCAP Logistics Civil Augmentation Program MEG Military Exposure Guidelines MNC-I Multi-National Corps-Iraq MNF-I Multinational Forces-Iraq USARCENT United States Army Central USF-I U.S. Forces-Iraq USFOR-A U.S. Forces-Afghanistan VA Department of Veterans Affairs VOC volatile organic compounds This is a work of the U.S. government and is not subject to copyright protection in the United States. The published product may be reproduced and distributed in its entirety without further permission from GAO. However, because this work may contain copyrighted images or other material, permission from the copyright holder may be necessary if you wish to reproduce this material separately. Page iii GAO-11-63 Afghanistan and Iraq United States Government Accountability Office Washington, DC 20548 October 15, 2010 The Honorable Bob Filner Chairman Committee on Veterans’ Affairs House of Representatives The Honorable Russell D. Feingold United States Senate The Honorable Ron Wyden United States Senate The Honorable Tim Bishop House of Representatives The Honorable Carol Shea-Porter House of Representatives U.S. military operations in Afghanistan and Iraq generate about 10 pounds of waste per servicemember each day.1 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.2 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.
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