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Officials Describe DOD's Efforts to Mitigate Impacts of PFAS Chemicals

Defense Department officials addressed cleanup efforts and measures being taken to address the recommendations of the DOD Inspector General report on  per- and polyfluoroalkyl substances (PFAS) — man-made chemicals used in many industrial and consumer products.

Richard G. Kidd, deputy assistant secretary of defense for environment and energy resilience, and Laura Macaluso, the DOD's acting deputy assistant secretary for force safety and occupational health,  testified about the DOD's ongoing measures to address PFAS at a Senate Homeland Security and Governmental Affairs Committee hearing.

A person wearing fire protection gear sprays foam on a fire in a 28-square-foot container.
Foam Test
John Farley, director of fire test operations at the Naval Research Laboratory, tests the effectiveness of aqueous film-forming foam by spraying it on a gasoline fire. The test took place at the laboratory in Chesapeake Beach, Md., Oct. 25, 2019.
Photo By: David Vergun, DOD
VIRIN: 191025-D-UB488-005Y

The department has invested significant effort into understanding and addressing the challenges posed by PFAS, said Kidd. To date, the DOD has invested more than $1.5 billion in PFAS related research and cleanup activities. 

It is estimated that over 98% of Americans have some form of PFAS in their blood today as a result of substances containing PFAS that are found in many products and firefighting foams, he said.

There is still a lot of uncertainty related to the effects of PFAS, and it's still unclear what exposure levels result in adverse health effects, Kidd said.

"The EPA has published analytic methods to detect fewer than 10% of the PFAS in [commercial products]. The lack of this clear set of measurable and objective health and environmental standards complicates our ability to take proactive actions," Kidd said.

"Based on what we know today, it will take years to define the scope of our cleanup and decades before it is complete," he added.

To help resolve these uncertainties and accelerate clean up, the department has a robust research and development effort in place and is cooperating closely with other federal agencies such as the EPA, the Department of Veterans Affairs, the Centers for Disease Control and Prevention and the White House's Office of Science and Technology and Council on Environmental Quality, Kidd said.

The DOD R&D effort is probably the largest of its kind and is focused on finding effective substitutes for firefighting foam, known as aqueous film-forming foam, or AFFF, which contains PFAS, he said. This effort also includes research into how to detect, treat and respond to PFAS found in the environment, with the aim of accelerating the cleanup response. 

A chemist in a lab begins filling a plastic container with foam.
Foam Test
Naval Research Lab Chemical Engineer Katherine Hinnant prepares to test an experimental aqueous film-forming foam at the NRL in Washington, Sept. 23, 2019. NRL scientists are conducting research to support the Defense Department’s effort to replace firefighting foams containing fluorine.
Photo By: Navy Petty Officer 3rd Class Manuel Najera, DOD
VIRIN: 190923-D-KT024-0131C
A chemist holds a stopwatch as he times an experiment of a small fire in a lab.
Timed Test
Naval Research Lab Research Chemist Spencer Giles prepares to test an experimental aqueous film-forming foam at the NRL in Washington, Sept. 23, 2019. NRL scientists are conducting research to support the Defense Department’s effort to replace firefighting foams containing fluorine.
Photo By: Navy Petty Officer 3rd Class Manuel Najera, DOD
VIRIN: 190923-D-KT024-0078C

The DOD Office of Inspector General's July 2021 report on PFAS made two recommendations for the undersecretary of defense for acquisition and sustainment, he said. 

The first recommendation was for the department to revise its emerging chemicals program instruction document. The second was for the department to complete the emerging chemicals process for PFAS containing materials other than AFFF. 

Kidd said both recommendations are being implemented.

The IG report did recognize that the department has proactively taken cleanup response actions to address PFAS resulting from AFFF. 

"The timeline is clear that the department responded quickly once EPA published a health advisory level for PFAS," Kidd said.

When it comes to cleanup, the department follows the federal law, known as the Comprehensive Environmental Response Compensation and Liability Act, he said.

While the program is both legally and technically complex, its underlying purpose is to address the releases that were made and protect the American people, he said.

A device used to determine bubble structure geometry of foams.
Dynamic Analyzer
The dynamic foam analyzer is used to determine bubble structure geometry of different foams tested at the Naval Research Laboratory in Chesapeake Beach, Md., Oct. 25, 2019.
Photo By: David Vergun, DOD
VIRIN: 191025-D-UB488-001C

The department has obligated nearly $1.2 billion for cleanup at 699 installations and National Guard facilities. The DOD estimates that the future costs at these known sites will exceed $2 billion, he said.

"Frankly, we expect that this amount will further increase as we continue with the cleanup investigations and have a better understanding of the nature of the challenges that we face. We believe that this is the largest cleanup effort in the country," he said.

Macaluso said the department is committed to maintaining the safety, health and readiness of its military and civilian workforce. This includes protecting them from potentially hazardous workplace exposures and associated health risks. 

"The department maintains a strong commitment for the well-being of our workforce by establishing comprehensive and robust safety and occupational health programs where potentially hazardous occupational exposures and risks are monitored, quantified and mitigated," she said. 

Dynamic Foam Analyzer
Bubble Count
The dynamic foam analyzer is used to determine bubble count and bubble structure geometry of the different foams tested at the Naval Research Laboratory, Chesapeake Beach, Md. Shown here is thee geometry display on the device.
Photo By: David Vergun, DOD
VIRIN: 191025-D-UB488-010A

For instance, the DOD has implemented PFAS blood testing for its firefighters and is working to improve its testing implementation plan.

The blood test results are provided to each firefighter and reported in their occupational medical records. PFAS fact sheets are provided to DOD firefighters and to occupational medicine practitioners. These fact sheets are based on health information from the CDC and the Agency for Toxic Substances and Disease Registry. 

"We are also taking action to qualitatively identify firefighter exposure trends and looking for opportunities to minimize firefighter exposures where possible," she said.

Macaluso noted that it's difficult to know which levels of PFAS in the blood were due to the occupational setting and which resulted from exposure to consumer products.

"The results of the scientific research on the health effects are needed before we can develop the occupational exposure limits and implement systematic workplace exposure characterization and controls," she said.

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