United States Government Accountability Office

Testimony
Before the Subcommittee on Federal Spending
Oversight and Emergency Management,
Committee on Homeland Security and
Governmental Affairs, U.S. Senate
For Release on Delivery
Expected at 2:30 p.m. ET
Wednesday, September 26, 2018

DRINKING WATER
Status of DOD Efforts to
Address Drinking Water
Contaminants Used in
Firefighting Foam
Statement of Brian J. Lepore, Director,
Defense Capabilities and Management
J. Alfredo Gómez, Director, Natural Resources and
Environment

GAO-18-700T

 September 26, 2018

DRINKING WATER
Status of DOD Efforts to Address Drinking Water
Contaminants Used in Firefighting Foam
Highlights of GAO-18-700T, a testimony
before the Subcommittee on Federal
Spending Oversight and Emergency
Management, Committee on Homeland
Security and Governmental Affairs, U.S.
Senate

Why GAO Did This Study

What GAO Found

According to health experts, exposure
to elevated levels of PFOS and PFOA
could cause increased cancer risk and
other health issues in humans. DOD
has used firefighting foam containing
PFOS, PFOA, and other PFAS since
the 1970s to quickly extinguish fires
and ensure they do not reignite. EPA
has found elevated levels of PFOS and
PFOA in drinking water across the
United States, including in drinking
water at or near DOD installations.

GAO reported in October 2017 that the Department of Defense (DOD) had
initiated actions to address elevated levels of perfluorooctane sulfonate (PFOS)
and perfluorooctanoic acid (PFOA) in drinking water at or near military
installations. PFOS and PFOA are part of a larger class of chemicals called perand polyfluoroalkyl substances (PFAS), which can be found in firefighting foam
used by DOD. In May 2016, the Environmental Protection Agency (EPA) issued
nonenforceable drinking water health advisories for those two chemicals. Health
advisories include recommended levels of contaminants that can be present in
drinking water at which adverse health effects are not anticipated to occur over
specific exposure durations.

This statement provides information on
actions DOD has taken to address
elevated levels of PFOS and PFOA in
drinking water at or near military
installations and to address concerns
with firefighting foam.
This statement is largely based on a
GAO report issued in October 2017
(GAO-18-78). To perform the review
for that report, GAO reviewed DOD
policies and guidance related to PFOS
and PFOA and firefighting foam,
analyzed DOD data on testing and
response activities for PFOS and
PFOA, reviewed the four administrative
orders issued by EPA and state
regulators to DOD on addressing
PFOS and PFOA in drinking water,
visited seven installations, and
interviewed DOD and EPA officials.
This statement also includes updated
information based on two 2018 DOD
reports to Congress—one on PFOS
and PFOA response and one on
firefighting foam—as well as
discussions with DOD officials.

View GAO-18-700T. For more information,
contact Brian J. Lepore at (202) 512-4523 or
leporeb@gao.gov or J. Alfredo Gómez at
(202) 512-3841 or gomezj@gao.gov.

In response to those health advisories, DOD’s military departments directed their
military installations to (1) identify locations with a known or suspected release of
PFOS and PFOA and address any releases that pose a risk to human health,
which can include people living outside DOD installations, and (2) test for PFOS
and PFOA in installation drinking water and address any contamination above
the levels in EPA’s health advisories. For example:
•

As of August 2017, DOD had identified 401 active or closed military
installations with known or suspected releases of PFOS or PFOA.

•

The military departments had reported spending approximately $200
million at or near 263 installations for environmental investigations and
responses related to PFOS and PFOA, as of December 2016. According
to DOD, it may take several years for the department to determine how
much it will cost to clean up PFOS and PFOA contamination at or near
its military installations.

•

DOD reported taking actions (such as providing alternative drinking
water and installing treatment systems) as of August 2017 to address
PFOS and PFOA levels exceeding those recommended in EPA’s health
advisories for drinking water for people (1) on 13 military installations in
the United States and (2) outside 22 military installations in the United
States.

In addition to actions initiated by DOD, GAO reported in October 2017 that the
department also had received and responded to four orders from EPA and state
regulators that required DOD to address PFOS and PFOA levels that exceeded
EPA’s health advisory levels for drinking water at or near four installations.
GAO also reported in October 2017 that DOD was taking steps to address health
and environmental concerns with its use of firefighting foam that contains PFAS.
These steps included restricting the use of existing foams that contain PFAS;
testing foams to identify the amount of PFAS they contain; and funding research
on developing PFAS-free foam that can meet DOD’s performance requirements,
which specify how long it should take for foam to extinguish a fire and keep it
from reigniting. In a June 2018 report to Congress, DOD stated that no
commercially available PFAS-free foam has met DOD’s performance
requirements and that research to develop such a PFAS-free foam is ongoing.
United States Government Accountability Office

 Letter

Letter

Chairman Paul, Ranking Member Peters, and Members of the
Subcommittee:
Thank you for the opportunity to be here today to discuss our report on
the Department of Defense’s (DOD) attention to drinking water
contaminants, part of our body of work on the federal government’s
environmental liabilities. 1 The federal government is financially liable for
cleaning up areas where federal activities have contaminated the
environment. Today’s hearing addresses federal liability for and
procurement of per- and polyfluoroalkyl substances (PFAS), a large group
of man-made chemicals that include perfluorooctane sulfonate (PFOS)
and perfluorooctanoic acid (PFOA). 2 PFOS, PFOA, and other PFAS can
be found in firefighting foam used by DOD since the 1970s for training
and emergency response activities to put fires out quickly while also
ensuring that they do not reignite. 3
Exposure to elevated levels of PFOS and PFOA could cause increased
cancer risk and other health issues in humans, according to the Agency
for Toxic Substances and Disease Registry. The Environmental
Protection Agency (EPA) has found PFOS and PFOA in drinking water
across the United States, including in drinking water at or near DOD
installations. EPA has not regulated PFOS and PFOA in drinking water,
but EPA did issue nonenforceable drinking water health advisories for
these contaminants in May 2016, which we discuss further in this
statement. Addressing PFOS and PFOA contamination represents a
potentially significant environmental liability for DOD because the
1

In 2017, we added U.S. Government’s Environmental Liabilities to our areas identified as
government operations with greater vulnerabilities to fraud, waste, abuse, and
mismanagement or in need for transformation to address economy, efficiency, or
effectiveness challenges. In fiscal year 2016 this liability was estimated at $447 billion (up
from $212 billion in 1997) and is likely to continue to increase. The Department of Energy
is responsible for 83 percent of these liabilities and DOD for 14 percent. Agencies spend
billions each year on environmental cleanup efforts but the estimated environmental
liability continues to rise. GAO, High-Risk Series: Progress on Many High-Risk Areas,
While Substantial Efforts Needed on Others, GAO-17-317 (Washington, D.C.: Feb. 15,
2017).

2

PFOS and PFOA are no longer manufactured in the United States but have been used
since the 1940s. PFOS and PFOA have been the most extensively produced and studied
PFAS chemicals, and are very persistent in the environment and human body—meaning
they do not break down and can accumulate over time.

3

PFAS have also been used to make consumer products more resistant to stains, grease,
and water; keep food from sticking to cookware; and make clothes and mattresses more
waterproof.

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GAO-18-700T Drinking Water

 regulatory requirements are still evolving, the scientific community is still
developing the underlying science, and the scope of work needed for
cleanup is not yet known.
In our statement today, we discuss actions DOD has taken to address
elevated levels of PFOS and PFOA in drinking water at or near military
installations and to address concerns with DOD’s firefighting foam. This
statement is largely based on our October 2017 report on DOD’s efforts
to manage contaminants in drinking water. 4 To perform our review for the
October 2017 report, we reviewed DOD policies and guidance related to
PFOS and PFOA and firefighting foam; analyzed DOD data on testing
and response activities for PFOS and PFOA; reviewed four administrative
orders issued by EPA and state regulators; visited seven installations;
and interviewed DOD and EPA officials. More detailed information on the
scope and methodology for that work can be found in the issued report.
This statement also includes updated information since our October 2017
report, based on our review of two 2018 DOD reports to Congress—a
March 2018 report on the department’s response to PFOS and PFOA
contamination and a June 2018 report on firefighting foam alternatives—
and on our discussions with DOD officials about these issues and their
actions in September 2018. 5
We conducted the work on which this statement is based 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
4

GAO, Drinking Water: DOD Has Acted on Some Emerging Contaminants but Should
Improve Internal Reporting on Regulatory Compliance, GAO-18-78 (Washington, D.C.:
Oct. 18, 2017). In addition to PFOS and PFOA issues, we reported in October 2017 that
DOD had not internally reported all data on compliance with health-based drinking water
regulations. We also reported that DOD had not used available data to determine why
systems that provide DOD-treated water had different compliance rates from systems that
provide non-DOD-treated water. We made five recommendations to improve DOD’s
reporting and use of drinking water data. DOD concurred with the recommendations and
in May 2018 reported actions that were planned or underway to implement them. For
example, the military departments stated that they were providing training to their
installations on DOD’s drinking water reporting requirements. We will continue to monitor
DOD’s status in implementing these recommendations.
5

The Deputy Assistant Secretary of Defense for Environment, Safety, and Occupational
Health, Addressing Perfluorooctane Sulfonate (PFOS) and Perfluorooctanoic Acid (PFOA)
(March 2018); Under Secretary of Defense for Acquisition and Sustainment, Department
of Defense Alternatives to Aqueous Film Forming Foam Report to Congress (June 2018).

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GAO-18-700T Drinking Water

 provides a reasonable basis for our findings and conclusions based on
our audit objectives.

Background

EPA regulates drinking water contaminants by issuing legally enforceable
standards under the Safe Drinking Water Act that generally limit the levels
of these contaminants in public water systems. 6 EPA has issued such
regulations for approximately 90 drinking water contaminants. Public
water systems, including the DOD public water systems that provide
drinking water to about 3 million people living and working on military
installations, are required to comply with EPA and state drinking water
regulations.
While EPA has not issued legally enforceable standards for PFAS in
drinking water, the agency has monitored water systems in the United
States for six types of PFAS chemicals—including PFOS and PFOA—in
order to understand the nationwide occurrence of these chemicals. 7 This
monitoring effort was part of a larger framework established by the Safe
Drinking Water Act to assess unregulated contaminants. Under this
framework, EPA is to select for consideration from a list (called the
contaminant candidate list) those unregulated contaminants that present
the greatest public health concern, establish a program to monitor
drinking water for unregulated contaminants, and decide whether or not to
regulate at least 5 such contaminants every 5 years (called a regulatory
determination). 8

6

The term “public water system” refers to the provision of piped drinking water to the
public, where the system serves at least 15 service connections or serves an average of
at least 25 people at least 60 days out of the year; it does not refer to whether the system
is publicly or privately owned.

7

This monitoring took place from 2013 through 2015 under EPA’s unregulated
contaminant monitoring rule program. According to DOD, 63 DOD public water systems
were sampled during this time. For more information on EPA’s unregulated contaminant
monitoring rule program, see GAO, Drinking Water: EPA Has Improved Its Unregulated
Contaminant Monitoring Program, but Additional Action is Needed, GAO-14-103
(Washington, D.C.: Jan. 9, 2014).
8

PFOS and PFOA were placed on the contaminant candidate list in 2009 and again in
2016. EPA met the time frame for publishing the first contaminant candidate list, but has
not adhered to the 5-year cycle for subsequent lists.

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GAO-18-700T Drinking Water

 EPA’s regulatory determinations are to be based on the following three
broad statutory criteria, all of which must be met for EPA to decide that a
drinking water regulation is needed:
•

the contaminant may have an adverse effect on the health of persons;

•

the contaminant is known to occur or there is a substantial likelihood
that the contaminant will occur in public water systems with a
frequency and at levels of public health concern; and

•

in the sole judgment of the EPA Administrator, regulation of such
contaminant presents a meaningful opportunity for health risk
reduction for persons served by public water systems.

To date, PFOS and PFOA are unregulated because EPA has not made a
positive regulatory determination for these chemicals.
Even when EPA has not issued a regulation, EPA may publish drinking
water health advisories. In contrast to drinking water regulations, health
advisories are nonenforceable. 9 Health advisories recommend the
amount of contaminants that can be present in drinking water—“health
advisory levels”—at which adverse health effects are not anticipated to
occur over specific exposure durations. Most recently, in May 2016 EPA
issued lifetime health advisories for PFOS and PFOA. 10 These advisories
set the recommended health advisory level for each contaminant—or
both contaminants combined—at 70 parts per trillion in drinking water. 11
According to DOD, the department also considers information in these
health advisories when determining the need for cleanup action at
installations with PFOS and PFOA contamination.

9

EPA has issued administrative orders to address contaminated drinking water based on
health advisory levels. We discuss such orders related to PFOS and PFOA later in this
statement.

10
EPA, Drinking Water Health Advisory for Perfluorooctane Sulfonate (PFOS) (May 2016);
EPA, Drinking Water Health Advisory for Perfluorooctanoic Acid (PFOA) (May 2016).
These lifetime health advisories for PFOS and PFOA replaced provisional health
advisories that were issued by EPA in January 2009, which set health advisory levels of
200 parts per trillion for PFOS and 400 parts per trillion for PFOA.
11

One part per trillion is comparable to one drop in a swimming pool covering the area of a
football field 43 feet deep.

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GAO-18-700T Drinking Water

 DOD Has Initiated
Actions to Address
Elevated Levels of
PFOS and PFOA in
Drinking Water and
Concerns with
Firefighting Foam
DOD Has Initiated Actions
to Identify, Test, Address,
and Respond to Orders
from Regulators
Regarding PFOS and
PFOA in Drinking Water

We reported in October 2017 that, following the release of EPA’s lifetime
health advisory for PFOS and PFOA in May 2016, each of the military
departments directed their installations to
•

identify locations with any known or suspected prior release of PFOS
and PFOA and to address any releases that pose a risk to human
health—which can include people living outside DOD installations;
and

•

test for PFOS and PFOA in their drinking water and address any
contamination above EPA’s lifetime health advisory level.

We further reported that, as of December 2016, DOD had identified 393
active or closed military installations with any known or suspected
releases of PFOS or PFOA. 12 Since we issued our report, DOD has
updated that number to 401 active or closed installations, according to
August 2017 data provided in a March 2018 report to Congress on the
department’s response to PFOS and PFOA contamination. 13

12
We reported in October 2017 that this number included 391 installations identified by the
military departments and, according to DOD officials, 2 installations identified by the
Defense Logistics Agency. DOD efforts to test for and respond to PFOS and PFOA at
overseas installations were outside the scope of our October 2017 report.
13
The Deputy Assistant Secretary of Defense for Environment, Safety, and Occupational
Health, Addressing Perfluorooctane Sulfonate (PFOS) and Perfluorooctanoic Acid (PFOA)
(March 2018). This report was provided in response to language included in House Report
115-200, accompanying a bill for the National Defense Authorization Act for Fiscal Year
2018.

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GAO-18-700T Drinking Water

 We stated in our October 2017 report that the military departments had
reported spending approximately $200 million at or near 263 installations
for environmental investigations and response actions, such as installing
treatment systems or supplying bottled water, as of December 2016. 14
•

The Air Force had identified 203 installations with known or suspected
releases of PFOS and PFOA and had spent about $153 million on
environmental investigations and response actions (accounting for
about 77 percent of what the military departments had spent on PFOS
and PFOA activities as of December 2016). For example, the Air
Force reported spending over $5 million at Peterson Air Force Base in
Colorado. During our visit to that installation in November 2016,
officials showed us the current and former fire training areas that they
were investigating to determine the extent to which prior use of
firefighting foam may have contributed to PFOS and PFOA found in
the drinking water of three nearby communities. Additionally, the Air
Force had awarded a contract for, among other things, installing
treatment systems in those communities.

•

The Navy had identified 127 installations with known or suspected
releases of PFOS and PFOA and had spent about $44.5 million on
environmental investigations and response actions (accounting for
about 22 percent of what the military departments had spent on PFOS
and PFOA activities as of December 2016). For example, the Navy
reported spending about $15 million at the former Naval Air Station
Joint Reserve Base Willow Grove in Pennsylvania. 15 During our visit
to that installation in August 2016, officials told us that the Navy was
investigating the extent to which PFOS and PFOA on the installation
may have contaminated a nearby town’s drinking water. At the time,
the Navy had agreed to pay for installing treatment systems and
connecting private well owners to the town’s drinking water system,
among other things.

•

The Army had identified 61 installations with known or suspected
releases of PFOS and PFOA and had spent about $1.6 million on
environmental investigations (accounting for less than 1 percent of

14
DOD did not provide updated information on costs for responding to PFOS and PFOA in
its March 2018 report to Congress. According to DOD data in our October 2017 report,
204 of the 263 installations where environmental investigations and response actions
occurred were active installations, and 59 had been closed under the Base Realignment
and Closure process—a process DOD has used to reduce excess infrastructure.
15

Naval Air Station Joint Reserve Base Willow Grove was closed under the 2005 Base
Realignment and Closure round.

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GAO-18-700T Drinking Water

 what the military departments had spent on PFOS and PFOA
activities as of December 2016), but had not yet begun any response
actions. At the time of our October 2017 report, the Army had not yet
completed testing its drinking water for PFOS and PFOA.
DOD’s March 2018 report to Congress provided updated information on
actions taken (such as providing alternative drinking water or installing
treatment systems) to address PFOS and PFOA in drinking water at or
near military installations in the United States, as shown in figure 1 below.
Specifically, DOD reported taking action as of August 2017 to address
PFOS and PFOA levels exceeding those recommended in EPA’s health
advisories for drinking water for people (1) on 13 military installations and
(2) outside 22 military installations. 16

16

At the time of our October 2017 report, DOD data showed that the department had
initiated actions to address PFOS and PFOA in the drinking water for people (1) on 11
military installations, as of March 2017, and (2) outside 19 military installations, as of
December 2016. Two installations (Chanute Air Force Base and Wright-Patterson Air
Force Base) that DOD had previously reported to us as locations where actions had been
taken to address PFOS and PFOA in drinking water outside the installations were not
included in DOD’s March 2018 report. DOD officials told us in September 2018 that there
are no PFOS and PFOA impacts to drinking water outside these installations.

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GAO-18-700T Drinking Water

 Figure 1: Military Installations Where DOD Has Reported Taking Action to Address Elevated Levels of PFOS and PFOA in
Drinking Water, as of August 2017

We reported in October 2017 that, in addition to actions initiated by DOD,
the department also took action in response to state and federal
regulators. DOD responded to four administrative orders requiring that
DOD address PFOS and PFOA levels that exceeded EPA’s health
advisory levels for drinking water. One order was issued by the Ohio
Environmental Protection Agency at Wright-Patterson Air Force Base in
Ohio, and three orders were issued by EPA at the former Pease Air Force
Base in New Hampshire; Horsham Air Guard Station in Pennsylvania;

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GAO-18-700T Drinking Water

 and the former Naval Air Warfare Center Warminster in Pennsylvania. 17
For example, at Wright-Patterson Air Force Base, levels of PFOS and
PFOA that exceeded EPA’s lifetime health advisory levels were found at
two wells on the installation in 2016. In response to the order from the
Ohio Environmental Protection Agency, the Air Force closed drinking
water wells, installed new monitoring wells, and provided bottled water to
vulnerable populations on the installation. Additional details on each order
and examples of actions by DOD to address the orders were reported on
in our October 2017 report.
According to DOD, it may take several years for the department to
determine how much it will cost to clean up PFOS and PFOA
contamination at or near its military installations. Additionally, DOD
officials told us in September 2018 that they believe a legally enforceable
EPA drinking water cleanup standard would ensure greater consistency
and confidence in their cost estimates because such a standard would
give them a consistent target to clean up to. In a January 2017 report on
environmental cleanup at closed installations, we recommended that
DOD include in future annual reports to Congress best estimates of the
environmental cleanup costs for contaminants such as PFOS and PFOA
as additional information becomes available. 18 DOD implemented this
recommendation by including in its fiscal year 2016 environmental report
to Congress (issued in June 2018) an estimate of the costs to respond to
PFOS and PFOA. 19

17
Under Section 1431 of the Safe Drinking Water Act, EPA may issue orders necessary to
protect human health where a contaminant in a public water system presents an imminent
and substantial endangerment and if appropriate state and local authorities have not acted
to protect human health. Pub. L. No. 93-523 (1974). These orders may require, among
other things, carrying out cleanup studies, providing alternate water supplies, notifying the
public of the emergency, and halting disposal of the contaminants threatening human
health. The Ohio Environmental Protection Agency has similar authority.
18

GAO, Military Base Realignments and Closures: DOD Has Improved Environmental
Cleanup Reporting but Should Obtain and Share More Information, GAO-17-151
(Washington, D.C.: Jan. 19, 2017).

19

Office of the Under Secretary of Defense for Acquisition and Sustainment, Defense
Environmental Programs Annual Report to Congress for FY 2016 (Washington, D.C.:
June 2018).

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GAO-18-700T Drinking Water

 DOD Has Taken Steps to
Address Health and
Environmental Concerns
with Its Firefighting Foam

In our October 2017 report, we found that DOD was taking steps to
address health and environmental concerns with its use of firefighting
foam that contains PFAS. 20 These steps included restricting the use of
existing foams that contain PFAS, testing DOD’s current foams to identify
the amount of PFAS they contain, and funding research into the future
development of PFAS-free foam that can meet DOD’s performance and
compatibility requirements (see table 1). 21 Some of these steps, such as
limiting the use of firefighting foam containing PFAS, were in place.
Others, such as researching potential PFAS-free firefighting foams, were
in progress at the time of our review.

Table 1: Department of Defense (DOD) Steps to Address Concerns about Perfluorooctane Sulfonate (PFOS) and
Perfluorooctanoic Acid (PFOA) in Firefighting Foam
Step

Goal

Actions/status

Restricting use of
firefighting foam

Following the May 2016 issuance of the
Environmental Protection Agency’s
lifetime health advisory for PFOS and
PFOA, the military departments issued
policies restricting the use of firefighting
foam at their installations.

Actions called for in military department policies:
Air Force: Stop routine testing of firefighting equipment unless the
released foam can be contained and managed. Treat all releases
of firefighting foam with PFOS or PFOA as hazardous material
a
releases.
Navy: Stop the uncontrolled release of firefighting foam except in
emergency situations. Ensure that any foam that is discharged in a
nonemergency situation is contained, captured, and properly
b
disposed of.
Army: Prohibit all nonemergency discharges of firefighting foam, to
c
include training and equipment testing.

20
Firefighting foam used by DOD contains other types of PFAS, in addition to PFOS and
PFOA.
21
DOD’s military specification for firefighting foam outlines performance and compatibility
requirements. For example, the specification states how long it should take for foam to
extinguish a fire and prevent the extinguished fire from reigniting and requires that
firefighting foam approved for use by DOD from one manufacturer be compatible with
foam from another manufacturer. At the time of our review, the military specification in
place for firefighting foam was DOD, Mil-F-24385F, Fire Extinguishing Agent, Aqueous
Film Forming Foam (AFFF) Liquid Concentrate, for Fresh and Seawater (Aug. 5, 1994).

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GAO-18-700T Drinking Water

 Step

Goal

Testing firefighting
foam with PFAS

DOD’s intent was to eventually replace
According to DOD, firefighting foams approved for purchase and
the existing firefighting foam that contains use by DOD since at least December 2015 do not contain PFOS,
PFOS and PFOA.
but these firefighting foams contain other types of PFAS and may
contain PFOA.
The Naval Research Laboratory was testing the different types of
firefighting foams that were approved for purchase and use by
DOD to determine the extent to which they contain PFOA and
d
other types of PFAS. Testing was expected to continue until late
2017 or 2018.
Navy and Army officials said that they planned to wait for final
testing results before deciding whether to select a specific
firefighting foam to replace the foam used at their installations. The
Air Force, however, had already selected a specific foam for use at
its installations. This foam contains PFAS but, according to the Air
Force, does not contain PFOS and contains little or no PFOA.
Officials said that all Air Force installations in the continental United
States had received this new foam.

Actions/status

Funding firefighting
foam research

DOD was funding research into the
development of PFAS-free firefighting
foam because DOD believes that such a
foam would significantly reduce the
environmental impact of fire suppression
training and operations, while maintaining
the safety of personnel from fire hazards.

In October 2015, DOD’s Strategic Environmental Research and
Development Program issued a statement of need calling for
proposals to develop a PFAS-free firefighting foam that can meet
DOD’s performance requirements and be compatible with existing
foams and equipment.
In fiscal year 2017, DOD funded three research projects that
responded to the statement of need—one led by the Naval Air
Systems Command, one led by the Naval Research Laboratory,
and one led by a private firefighting foam manufacturer—with an
estimated total cost of $2.5 million and an estimated completion
date of 2020.

Source: GAO analysis of DOD data.   GAO-18-700T
a

Office of the Assistant Secretary of the Air Force for Installations, Environment, and Energy
Memorandum, SAF/IE Policy on Perfluorinated Compounds (PFCs) of Concern (Aug. 11, 2016).

b
Office of the Assistant Secretary of the Navy for Energy, Installations, and Environment
Memorandum, Aqueous Film Forming Foam (AFFF) Control, Removal, and Disposal (June 17, 2016).
c

Assistant Chief of Staff of the Army for Installation Management Memorandum, Limiting Use of
Aqueous Film Forming Foam (June 29, 2016).

d

Navy officials told us during our review that they were testing the firefighting foam products that were
currently included on DOD’s qualified product list, which is the list of firefighting foams that have been
approved for purchase and use by DOD.

DOD’s military specification for firefighting foam, which outlines
performance and compatibility requirements, also requires that firefighting
foam purchased by the department contain PFAS. We reported in
October 2017 that, according to DOD, there was no PFAS-free firefighting
foam that could meet DOD’s performance and compatibility requirements.
As a result, the Navy—which is the author of the military specification—
had no plans to remove the requirement for firefighting foam to contain
PFAS. However, Navy officials told us during our review that if a PFASfree foam were to be developed that could meet DOD performance and

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GAO-18-700T Drinking Water

 compatibility requirements the Navy would make any necessary revisions
to the military specification at that time. Navy officials also said during our
review that they were planning to revise the military specification to set
limits for the amount of PFAS that are allowed in firefighting foam,
following their testing on the amounts of PFOS, PFOA, and other PFAS
found in foam used by DOD.
In June 2018, DOD reported to Congress that its military specification for
firefighting foam was amended to set a maximum level of PFOS and
PFOA (800 parts per billion). 22 DOD officials told us in September 2018
this maximum level applies to the amount of those chemicals in
firefighting foam concentrate before it is mixed and diluted with water to
create firefighting foam. 23 The DOD officials also said that 800 parts per
billion is the lowest level of PFOS and PFOA that can be detected in
firefighting foam concentrate by current testing methods and
technologies, but DOD is working with foam manufacturers and
laboratories to achieve lower detection limits. According to the June 2018
report, DOD plans to establish lower limits for PFOS and PFOA in
firefighting foam in late 2018. The June 2018 report reiterated that,
according to DOD, no commercially available PFAS-free foam has met
the performance requirements of the military specification, and the report
also stated that DOD-funded research efforts to develop a PFAS-free
foam that can meet performance requirements are still ongoing.
Chairman Paul, Ranking Member Peters, and Members of the
Subcommittee, this completes our prepared statement. We would be
pleased to respond to any questions that you may have at this time.

22

Under Secretary of Defense for Acquisition and Sustainment, Department of Defense
Alternatives to Aqueous Film Forming Foam Report to Congress (Washington, D.C.: June
2018).
23
This level is distinct from EPA’s lifetime health advisory levels for PFOS and PFOA (70
parts per trillion), which apply to drinking water and not to, for example, firefighting foam
concentrate.

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GAO-18-700T Drinking Water

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GAO-18-700T Drinking Water

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