Administrative Oversight Delayed Military Action on PFAS Contamination for Five Years

August 4, 2021

The Department of Defense’s internal watchdog organization found that an administrative loophole delayed the assessment and cleanup of products containing PFAS chemicals at military facilities worldwide for five years, potentially exposing tens of thousands of troops and their families to PFAS contamination.

PFAS chemicals have been linked to a series of adverse health conditions like increased risk of testicular and kidney cancer, tissue damage in the liver and multiple changes to the immune system and thyroid.

At least two PFAS chemicals, PFOS and PFOA, are used to create Aqueous Film Forming Foam, the foam used to put out fires on military and civilian airfields nationwide.

Contractors perform a fire suppression foam test at Hangar 18 on Joint Base Elmendorf-Richardson, Alaska. U.S. Air Force photo by Airman 1st Class Caitlin Russell

Chemicals in the foam can leach into ground, potentially contaminating groundwater and drinking water at sources far from the area where the foam was used.

The DoD Office of Inspector General found that, despite an alert issued by the DoD in 2011, the agency did not act to identify or remediate PFAS chemical contamination or exposure until 2016 because it lacked the endorsement of the Emerging Chemicals of Concern Governance Council, a group representing several Defense Department subgroups that reviews decisions on emerging chemicals.

“Although EC Program officials issued the 2011 risk alert, the 2011 risk alert was not an RMA risk management action because it was not endorsed by the ECGC. Therefore, DoD officials were not required to plan, program and budget for any actions in response to the 2011 risk alert. EC Program officials did not require proactive RMAs for PFAS containing AFFF until 2016,” the office stated in a partially redacted report.

The Defense Department began the process of identifying where the foam was used or potentially released soon after receiving an endorsement from the council.

Richard Kidd, the DoD’s assistant secretary of defense for environment and energy resilience, told Congress 698 installations worldwide were identified where PFAS may have been used or potentially released, 13 of which are located in Indiana.

Traces of PFAS chemicals were found in drinking water at the Indiana sites, but none were above the U.S. Environmental Protection Agency’s lifetime health advisories for PFOA or PFOS, the baseline for the agency’s chemical investigation.

The DoD identified 22 installations in other states and territories where drinking water systems were found with PFOS and PFOA levels above the EPA lifetime health advisory.

While it worked to identify past AFFF releases, the Defense Department also worked to avoid future use of the foam and avoid unnecessary releases.

A sailor tests the aqueous film forming foam firefighting system on the flight deck of the amphibious assault ship USS Boxer. U.S. Navy photo by Mass Communication Specialist 3rd Class Brett Anderson

The Defense Logistics Agency in 2018 contracted two Indiana-based companies to incinerate the DoD’s stockpiles of the PFAS-laden firefighting foam around the country. Tens of millions of gallons of AFFF were incinerated in New York, Illinois, Ohio, Arkansas and Texas before lawsuits forced the cancellation of the contracts in 2020.

In October, the DoD began testing all of its firefighters for PFOA, PFAS and four other PFAS compounds associated with AFFF.

The department also banned the use of PFAS AFFF in testing and training in almost all military installations and said it was working to find a PFAS-free AFFF replacement.

Kidd said removing all currently known traces of PFAS from military installations would cost $29 billion.

According to the inspector general’s office, the defense department has no idea how much non-AFFF PFAS exists and whether that possible exposure could be affecting service members and their families.

The OIG found that once the Defense Department began acting to identify, mitigate and remediate PFAS risks, it focused almost entirely on firefighting foam releases and did not try to find all sources of PFAS contamination.

“As a result, people and the environment may continue to be exposed to preventable risks from other PFAS-containing materials,” the OIG wrote.

The defense department agreed with the OIG’s recommendation that it look for PFAS beyond the firefighting foam . Acting Assistant Secretary of Defense for Sustainment Paul Cramer said risk management options for PFAS would be presented to the Emerging Chemicals of Concern Governance Council between January and March 2022.

Administrative Oversight Delayed Military Action on PFAS Contamination for Five Years