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Evaluation of the DoD’s Management of Health and Safety Hazards in Government-Owned and Government-Controlled Military Family Housing (DODIG-2020-082)

Evaluation

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Publicly Released: May 4, 2020

Objective

The objective of this evaluation was to determine if the DoD effectively managed health and safety hazards in Government‑owned and Government‑controlled (GO‑GC) military family housing. For this report, management is defined as the policies and procedures used by DoD officials to identify, mitigate or minimize, monitor, disclose, and oversee health and safety hazards in GO‑GC military family housing.

Background

In September 2018, Congress directed the DoD Office of Inspector General (OIG) to evaluate whether Service members and their families were exposed to lead hazards while living in GO‑GC military family housing. In November 2018, the DoD OIG announced an evaluation of the management of lead‑based paint hazards in GO‑GC military family housing. Subsequently, the Senate Armed Services and House Appropriations committees held several hearings that included discussion of other military housing problems, including construction defects, mold, pest infestations, and contamination from lead‑based paint, which affected the health, safety, and well‑being of Service members and their families in privatized family housing.

Although the statements from the Senate Armed Services and House Appropriations committee hearings focused on privatized military family housing, the concerns raised in the hearings prompted the DoD OIG to expand the scope of its GO‑GC military family housing evaluation. We expanded the scope of the evaluation of the management of April 30, 2020 lead‑based paint hazards in GO‑GC military family housing to also include the management of other health and safety hazards, such as asbestos‑containing material, radon, fire and electrical safety, drinking water quality, window fall prevention, mold, carbon monoxide, and pest management.

Federal laws regulate the management of health and safety hazards. The DoD and Services have applied the requirements of Federal laws at military installations worldwide through various policies for addressing health and safety hazards. Additionally, the DoD housing policies require the DoD and Services to:

• provide Service members and families access to affordable, quality housing reflecting contemporary community living standards;

• provide military family housing that is well maintained, structurally sound, and does not pose a health, safety, or fire hazard;

• provide program management for military family housing; and

• provide managerial oversight to ensure that the housing inventory is maintained in good condition and housing is managed in an effective and cost‑efficient manner.

Military family housing is divided into two broad categories: privatized and Government‑owned and Government‑controlled (GO‑GC) military family housing. Privatized military family housing is either leased to or built by a private entity and then managed by the private entity for Government use. The DoD privatized almost 99 percent (more than 200,000 units) of military family housing in the continental United States (CONUS). However, the DoD did not privatize military family housing that is outside the continental United States (OCONUS). GO‑GC military family housing is owned, managed, or maintained by the DoD. Approximately 95 percent (more than 36,000 units) of GO‑GC military family housing is located outside the continental United States (OCONUS).

We evaluated the management of health and safety hazards in GO‑GC military family housing at the following eight military installations.

• U.S. Army Garrison Humphreys, Republic of Korea

• U.S. Army Garrison Wiesbaden, Germany

• Naval Station Guantanamo Bay, Cuba

• Commander Fleet Activities Yokosuka, Japan

• Marine Corps Air Station Iwakuni, Japan

• Kadena Air Base, Japan • Spangdahlem Air Base, Germany

• Wright‑Patterson Air Force Base, Dayton, Ohio

These eight military installations host approximately 15,525 (41 percent) GO‑GC military family housing units worldwide. At these military installations we evaluated the management of nine potential health and safety hazards: lead‑based paint, asbestos‑containing material, radon, fire and electrical safety, drinking water quality, window fall prevention, mold, carbon monoxide, and pest management.

During our site visits to the eight military installations, we:

• reviewed records, including health and safety hazard management plans, policies and procedures, and health and safety hazard assessment and testing results, to determine whether installation officials had identified potential hazards and were implementing the requirements for the management of health and safety hazards in GO‑GC military family housing;

• interviewed officials to determine their knowledge of health and safety management requirements and their efforts to manage health and safety hazards in GO‑GC military family housing; and

• visually assessed a selection of 187 GO‑GC military family housing units to determine if health and safety hazards were effectively managed in GO‑GC military family housing.

Finding

At each of the eight military installations we visited, we found deficiencies in the management of health and safety hazards in GO‑GC military family housing. Specifically, we found systemic deficiencies in the management of lead‑based paint, asbestos‑containing material, and radon.

• At seven of the eight military installations we visited, installation officials did not maintain accurate records of the location and condition of lead‑based paint in GO‑GC military family housing. Therefore, installation officials could not determine the extent that lead‑based paint hazards were present in GO‑GC military family housing. Additionally, at each of the eight military installations we visited, installation officials did not provide required lead‑based paint disclosures to residents in GO‑GC military family housing. Therefore, residents may have been exposed to lead‑based paint or lead‑based paint hazards in their GO‑GC military family housing units without being aware of the hazard. For example, Wright‑Patterson AFB installation officials did not monitor the condition of “presumed” lead‑based paint, and we identified chipped and flaking paint at 11 GO‑GC military family housing units that is presumed to be lead‑based paint.

• At five of the eight military installations we visited, installation officials did not maintain accurate records of the location and condition of asbestos‑containing material in GO‑GC military family housing. Therefore, installation officials could not determine the extent that asbestos‑containing material hazards were present in GO‑GC military family housing. Additionally, at six of the eight military installations we visited, installation officials did not notify residents of asbestos‑containing material in GO‑GC military family housing. Therefore, residents may have been exposed to asbestos‑containing materials in their GO‑GC military family housing units without being aware of the hazard. For example, Naval Station Guantanamo Bay installation officials did not maintain accurate records, perform any surveillance, or notify residents of the existence of asbestos‑containing material in GO‑GC military family housing.

• At three of the eight military installations we visited, installation officials did not establish a radon assessment and mitigation program for GO‑GC military family housing. Additionally, at four of the eight military installations we visited, installation officials established a radon assessment and mitigation program but did not manage radon hazards in GO‑GC military family housing. Therefore, installation officials could not determine the extent that radon hazards were present in GO‑GC military family housing, and residents may have been exposed to radon hazards in GO‑GC military family housing units without being aware of the hazard. For example, USAG Humphreys and USAG Wiesbaden installation officials did not establish a radon assessment and mitigation program to manage radon hazards in GO‑GC military family housing.

Additionally, we found instances where installation officials did not manage other health and safety hazards, such as fire safety or drinking water quality. At two of the eight military installations we visited, installation officials did not incorporate fire safety requirements, such as window size requirements for fire escape, in GO‑GC military family housing. At one of the eight military installations we visited, installation officials did not test for all drinking water quality hazards in GO‑GC military family housing. Therefore, residents may have been exposed to fire safety and drinking water quality hazards in GO‑GC military family housing units without being aware of the hazard.

The deficiencies in the management of health and safety hazards at the eight military installations we visited occurred because the DoD’s housing policies do not define minimum standards for health and safety hazard management in GO‑GC military family housing. The DoDM 4165.63 states that DoD housing must meet “minimum standards for…condition, health, and safety” in GO‑GC military family housing. However, the DoDM 4165.63 does not define the “minimum standards for…condition, health, and safety.” Additionally, the DoD housing policies do not require any type of assessment of the condition of housing units to address the management of health and safety hazards in GO‑GC military family housing. Moreover, the DoD’s Unified Facilities Criteria for family housing only applies to new construction or renovation projects and does not address the management of health and safety hazards in existing military family housing.

The deficiencies in the management of health and safety hazards at the eight military installations we visited also occurred because Service oversight inspections and audits were not designed to identify deficiencies in the management of health and safety hazards. The DoDM 4165.63 states that the Services must “provide managerial oversight to ensure that the housing inventory is maintained in good condition and housing management is operated in an effective and cost‑efficient manner.” The Services are required by their policies to perform oversight over their programs, including military family housing; however, the oversight policies, procedures, and checklists for inspections and audits of their programs are not designed to address all requirements related to the management of health and safety hazards in GO‑GC military family housing.

We believe the deficiencies we identified at the eight military installations we visited indicate that the potential exists for similar deficiencies in the management of health and safety hazards in GO‑GC military family housing worldwide. If the DoD and the Services do not improve policies and procedures to identify, mitigate or minimize, monitor, disclose, and oversee health and safety hazards in GO‑GC military family housing, the DoD and the Services will continue to risk the health and safety of Service members and their families.

Recommendations

We recommend that the Under Secretary of Defense for Acquisition and Sustainment (USD[A&S]) and the Under Secretary of Defense for Personnel and Readiness (USD[P&R]) collaboratively establish or revise appropriate DoD policy(s) to address health and safety hazards—including lead‑based paint, asbestos‑containing material, radon, fire and electrical safety, drinking water quality, window fall prevention, mold, carbon monoxide, and pest management—in military family housing to manage health, safety, and environmental risks to acceptable levels for military family housing residents.

Additionally, we recommend that the Services revise Army Regulation 420‑1, Chief of Naval Operations Instruction 5009.1, Marine Corps Order 11000.22, Air Force Instruction 32‑6001, and all other housing‑related policies to align with recommended DoD policy revisions. Furthermore, we recommend that the Services develop oversight policies and procedures to assess the management of health and safety hazards in GO‑GC military family housing. Finally, we recommend that the Services direct installation officials to correct the specific lead‑based paint, asbestos‑containing material, radon, fire safety, and drinking water quality health and safety hazard management deficiencies discussed in this report.

 

Management Comments and Our Response

The Acting Assistant Secretary of Defense for Sustainment, responding on behalf of the USD(A&S), and the Official Performing the Duties of the Under Secretary of Defense for Personnel and Readiness, partially agreed with the recommendation to establish or revise appropriate DoD policy(s) to address health and safety hazards in military family housing. Comments from the Acting Assistant Secretary of Defense for Sustainment and the Official Performing the Duties of the Under Secretary of Defense for Personnel and Readiness, partially addressed the recommendation, but did not provide any details on what specific action(s) would be taken or when the action(s) would be taken; therefore, the recommendation is unresolved. We request that both the USD(A&S) and the USD(P&R) describe specific actions that they will take to determine (1) which policies will be issued or updated, (2) who will be responsible for updating the policies, (3) what will be updated in the policies, and (4) the timeline for when the policies will be released.

The Deputy Assistant Secretary of the Army for Installations, Housing and Partnerships, responding for the Assistant Secretary of the Army for Installations, Energy and Environment, agreed with the recommendation to update Service policies, develop oversight policies and procedures, and direct corrective action for the health and safety hazard deficiencies identified in this report. Comments from the Deputy Assistant Secretary addressed the recommendation; therefore, the recommendation is resolved but will remain open. We will close the recommendation once the DoD updates policies for health and safety hazard management and we verify that the Army took actions to fully address the recommendation.

The Acting Assistant Secretary of the Navy for Energy, Installations and Environment agreed with the recommendation to update Service policies, develop oversight policies and procedures, and direct corrective action for the health and safety hazard deficiencies identified in this report. Comments from the Acting Assistant Secretary addressed the recommendation; therefore, the recommendation is resolved but will remain open. We will close the recommendation once the DoD updates policies for health and safety hazard management and we verify that the Navy and Marine Corps took actions to fully address the recommendation.

The Principal Deputy Assistant Secretary of the Air Force for Installations, Environment and Energy, responding for the Assistant Secretary of the Air Force Environment and Energy, agreed with the recommendation to update Service policies and develop oversight policies and procedures, but only partially agreed with the recommendation to direct corrective action for the health and safety hazard deficiencies identified in this report. Comments from the Principal Deputy Assistant Secretary addressed the recommendation by agreeing to conduct corrective action and providing a different office to coordinate the corrective actions, but did not provide any details on what specific action(s) would be taken or when the action(s) would be taken; therefore, the recommendation is resolved but will remain open. We will close the recommendation once the DoD updates policies for health and safety hazard management and we verify that the Air Force took actions to fully address the recommendation.

 

This report is the result of Proj. No. D2019-D000PT-0052.000