U.S. Service members and their families living in housing owned and operated by the government are at risk for exposure to hazardous concentrations of cancer-causing, radioactive radon gas, as detailed in a recent report released by the Department of Defense (DoD) Office of Inspector General (OIG).
According to the report, systemic deficiencies in the management of health and safety hazards, including radon, were identified at each of the eight military installations included in the evaluation. The report also states that the deficiencies identified at the eight military installations indicate the potential exists for similar deficiencies in government-owned and government-controlled (GO-GC) military housing worldwide.
The report concludes: 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 housing, the DoD and the Services will continue to risk the health and safety of Service members and their families.
Radon is a naturally occurring, odorless, colorless radioactive gas formed by the decay of uranium. Radon exists in varying amounts in all soils, rocks, and some groundwater supplies worldwide. Radon enters the lungs when inhaled and chronic exposure may lead to lung cancer. Exposure to radon is the leading cause of lung cancer among non-smokers (second overall to smoking) and is responsible for more than 21,000 annual deaths in the United States. Radon poses a relatively low threat to human health outdoors; however, radon can accumulate to dangerous levels indoors. The presence of high levels of uranium in the soil or rock is not the sole reason for elevated indoor radon potential. Building design, building usage, building construction material, airflow, occupancy pattern, and the operation of the building’s heating, ventilation, and air‑conditioning system influence the accumulation of radon indoors. Testing for radon is the only way to determine if radon hazards are present in GO‑GC military housing.
Released on May 4, the report details the findings of the evaluation, which was conducted to determine if the DoD is effectively managing health and safety hazards, including radon, in GO-GC military housing. Currently, more than 38,000 GO-GC military housing units are owned, managed, or maintained by the DoD worldwide.
Government‑Owned and Government‑Controlled Military Family Housing
Eight military installations containing approximately 15,525 (41 percent of total) GO-GC housing units were included in the evaluation:
- U.S. Army Garrison (USAG) Humphreys, Republic of Korea
- USAG Wiesbaden, Germany
- Naval Station (NAVSTA) Guantanamo Bay, Cuba
- Commander Fleet Activities (CFA) Yokosuka, Japan
- Marine Corps Air Station (MCAS) Iwakuni, Japan
- Kadena Air Base (AB), Japan
- Spangdahlem AB, Germany
- Wright‑Patterson Air Force Base (AFB), Dayton, Ohio
The evaluation included:
- A review of records, health and safety hazard management plans, policies and procedures, and health and safety hazard assessment and testing results to determine whether installation officials identified potential hazards and were implementing the requirements for the management of health and safety hazards in GO‑GC military housing.
- Interviews with installation officials from housing, operations and maintenance, engineering, environmental, fire, safety, and health departments to determine their knowledge of applicable health and safety management requirements and their efforts to manage health and safety hazards in GO‑GC military housing.
- A visual assessment of a selection of 187 GO‑GC military housing units to determine if health and safety hazards were effectively managed in GO‑GC military housing.
The Toxic Substances Control Act (TSCA) of 1976 assigns regulatory and program implementation responsibilities to federal agencies, such as the U. S. Environmental Protection Agency (EPA) and the U.S. Department of Housing and Urban Development (HUD), to control substances determined to cause unreasonable risk to public health or the environment. The TSCA currently covers the control of highly toxic substances, including radon. For purposes of the evaluation, the HUD’s Healthy Homes Program Manual for best practices and techniques to achieve a healthy home was utilized. Based on the OIG’s review of health and safety hazards described in the manual and observations from previous DoD OIG reports, the management of nine potential health and safety hazards, including radon, were included in the evaluation.
Evaluation Findings for Radon
At each of the eight military installations evaluated, systemic deficiencies in the management of health and safety hazards in GO-GC military housing were identified. Specific to radon, the following findings were noted:
- Installation Officials Did Not Establish a Radon Assessment and Mitigation Program – the evaluation determined that installation officials at USAG Humphreys, USAG Wiesbaden, and NAVSTA Guantanamo Bay did not establish a radon assessment and mitigation program for GO‑GC military housing. The report summarizes: Installation officials at USAG Humphreys, USAG Wiesbaden, and NAVSTA Guantanamo Bay could not determine the extent that radon hazards were present in GO‑GC military housing. Without establishing a radon assessment and mitigation program, installation officials cannot manage radon hazards, and residents may have been exposed to radon hazards in GO‑GC military housing.
- Installation Officials Established a Radon Assessment and Mitigation Program but Did Not Manage Radon Hazards – the evaluation determined that installation officials at CFA Yokosuka, MCAS Iwakuni, Spangdahlem AB, and Kadena AB were not evaluating hazards, controlling hazards, or informing residents of the presence of radon. The report summarizes: Installation officials are unable to identify the extent that radon hazards were present in GO‑GC military housing because installation officials did not evaluate and control radon hazards. Therefore, residents may have been exposed to radon hazards in GO‑GC military housing. Furthermore, without installation officials informing residents of radon hazards, residents may not be aware of the potential health effects of radon exposure.
Radon Hazard Management Program Summary by Installation
Report Recommendations for Radon
In response to the evaluation findings, the following recommendations were made in the report:
- Establish or revise appropriate DoD policies to address health and safety hazards, including radon, in military housing to manage health, safety, and environmental risks to acceptable levels for military housing residents.
- 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.
- Develop oversight policies and procedures to assess the management of health and safety hazards in GO‑GC military housing.
- Direct installation officials to correct the specific radon health and safety hazard management deficiencies discussed in the report.
Radon is the most significant environmental health risk present in GO-GC military housing. Unfortunately, installation officials could not determine the extent that radon hazards were present in GO-GC military housing at seven of the eight installations included in the evaluation, and residents may have been exposed to hazardous radon concentrations in these GO-GC military housing units.
As stated in the report, radon assessments were conducted in the 1990s at military installations worldwide by the Services in response to the TSCA requirement. Most likely, these assessments have never been updated, reinforcing the position that installation officials cannot determine the extent of radon hazards present today in GO-GC military housing, and residents may be exposed to hazardous radon concentrations in GO-GC military housing units. Because geological conditions change and renovations may be conducted that may significantly modify the building envelope and mechanical systems, the current consensus radon standards recommended by the EPA specify all buildings be assessed for radon a minimum of one time every five years (every two years in buildings under active mitigation).
The guidance contained within the Army policy (AR 420‑1), the Navy policy (OPNAVINST 5090.1D, also covering Marine Corps installations), and the Air Force policy (AFI 48‑148) require implementation of a radon assessment and mitigation program. However, this guidance appears to be outdated or fails to incorporate requirements for radon contractors working on GO-GC military housing to be certified through a proficiency program recognized by the EPA or follow current consensus radon standards.
In contrast, Section 3061 of the National Defense Authorization Act for Fiscal Year 2020 applies to privatized military housing units, which constitute more than 99 percent of military housing in the continental United States. This Act requires an ongoing radon assessment and mitigation program to be implemented for all privatized military housing that includes radon measurement and mitigation activities be conducted by a radon contractor certified by a proficiency program recognized by the EPA following the consensus radon standards recommended by the agency.
In our opinion, adoption of the same requirements being utilized for privatized military housing should also be adopted for GO-GC military housing. After all, why shouldn’t Service members and their families living in GO-GC military housing be provided with the same protection against cancer-causing, radioactive radon as those living in privatized military housing?