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Testimony:

Before the Subcommittee on National Security, Emerging Threats, and 
International Relations, Committee on Government Reform, House of 
Representatives:

United States Government Accountability Office:

GAO:

For Release on Delivery Expected at 10:30 a.m. EDT:

Tuesday, July 19, 2005:

Defense Health Care:

Occupational and Environmental Health Surveillance Conducted during 
Deployments Needs Improvement:

Statement of Marcia Crosse:

Director, Health Care:

GAO-05-903T:

GAO Highlights:

Highlights of GAO-05-903T, a testimony before the Subcommittee on 
National Security, Emerging Threats, and International Relations, 
Committee on Government Reform, House of Representatives: 

Why GAO Did This Study:

Following the 1991 Persian Gulf War, research and investigations into 
the causes of servicemembers’ unexplained illnesses were hampered by a 
lack of servicemember health and deployment data, including inadequate 
occupational and environmental exposure data. In 1997, the Department 
of Defense (DOD) developed a militarywide health surveillance framework 
that includes occupational and environmental health surveillance 
(OEHS)—the regular collection and reporting of occupational and 
environmental health hazard data by the military services.

This testimony is based on GAO’s report, entitled "Defense Health Care: 
Improvements Needed in Occupational and Environmental Health 
Surveillance during Deployment to Address Immediate and Long-term 
Health Issues (GAO-05-632)." The testimony presents findings about how 
the deployed military services have implemented DOD’s policies for 
collecting and reporting OEHS data for Operation Iraqi Freedom (OIF) 
and the efforts under way to use OEHS reports to address both immediate 
and long-term health issues of servicemembers deployed in support of 
OIF.

What GAO Found:

Although OEHS data generally have been collected and reported for OIF, 
as required by DOD policy, the deployed military services have used 
different data collection methods and have not submitted all of the 
OEHS reports that have been completed. Data collection methods for air 
and soil surveillance have varied across the services, for example, 
although they have been using the same monitoring standard for water 
surveillance. For some OEHS activities, a cross-service working group 
has been developing standards and practices to increase uniformity of 
data collection among the services. In addition, while the deployed 
military services have been conducting OEHS activities, they have not 
submitted all of the OEHS reports that have been completed during OIF. 
Moreover, DOD officials could not identify the reports they had not 
received to determine the extent of noncompliance. 

DOD has made progress in using OEHS reports to address immediate health 
risks during OIF, but limitations remain in employing these reports to 
address both immediate and long-term health issues. OEHS reports have 
been used consistently during OIF as part of operational risk 
management activities intended to identify and address immediate health 
risks and to make servicemembers aware of the risks of potential 
exposures. While these efforts may help in reducing health risks, DOD 
has not systematically evaluated their implementation during OIF. DOD’s 
centralized archive of OEHS reports for OIF has several limitations for 
addressing potential long-term health effects related to occupational 
and environmental exposures. First, access to the centralized archive 
has been limited due to the security classification of most OEHS 
reports. Second, it will be difficult to link most OEHS reports to 
individual servicemembers’ records because not all data on 
servicemembers’ deployment locations have been submitted to DOD’s 
centralized tracking database. To address problems with linking OEHS 
reports to individual servicemembers, the deployed military services 
have tried to include OEHS monitoring summaries in the medical records 
of some servicemembers for either specific incidents of potential 
exposure or for specific locations within OIF. Additionally, according 
to DOD and Veterans Affairs (VA) officials, no federal research plan 
has been developed to evaluate the long-term health of servicemembers 
deployed in support of OIF, including the effects of potential 
exposures to occupational or environmental hazards.

GAO’s report made several recommendations, including that the Secretary 
of Defense improve deployment OEHS data collection and reporting and 
evaluate OEHS risk management activities and that the Secretaries of 
Defense and Veterans Affairs jointly develop a federal research plan to 
address long-term health effects of OIF deployment. DOD plans to take 
steps to meet the intent of our first recommendation and partially 
concurred with the other recommendations. VA concurred with our 
recommendation for a joint federal research plan.

www.gao.gov/cgi-bin/getrpt?GAO-05-903T.

To view the full product, including the scope and methodology, click on 
the link above. For more information, contact Marcia Crosse at (202) 
512-7119 or crossem@gao.gov.

[End of section] 

Mr. Chairman and Members of the Subcommittee:

I am pleased to be here today as you consider the efforts by the 
deployed military services to implement policies for collecting and 
reporting occupational and environmental health surveillance data for 
Operation Iraqi Freedom (OIF) and the work under way to use these data 
to address both the immediate and long-term health issues of 
servicemembers deployed in support of OIF. The health effects from 
service in military operations have been of increasing interest since 
the end of the 1991 Persian Gulf War--an interest that was renewed when 
servicemembers were deployed in early 2003 to the Persian Gulf in 
support of OIF. Following the 1991 Gulf War, many servicemembers 
reported suffering from unexplained illnesses that they attributed to 
their service in the Persian Gulf and expressed concerns about possible 
exposures to chemical or biological warfare agents or environmental 
contaminants. Subsequent research and investigations into the nature 
and causes of these illnesses by the Department of Defense (DOD), the 
Department of Veterans Affairs (VA), the Department of Health and Human 
Services (HHS), the Institute of Medicine, and a Presidential Advisory 
Committee were hampered by a lack of servicemember health and 
deployment data, including inadequate occupational and environmental 
exposure data.

To address continuing concerns about the health of servicemembers 
during and after deployments and to improve health data collection on 
potential exposures, DOD developed a militarywide health surveillance 
framework for use during deployments beginning in 1997. A key component 
of this framework is occupational and environmental health surveillance 
(OEHS), an activity that includes the regular collection and reporting 
of occupational and environmental health hazard data by the military 
services during a deployment that can be used to monitor the health of 
servicemembers and to prevent, treat, or control disease or injury. DOD 
has created policies for OEHS data collection during a deployment and 
for the submittal of OEHS reports to a centralized archive within 
specified time frames. The military services are responsible for 
implementing these policies in preparation for deployments. During a 
deployment, the military services are unified under a deployment 
command structure and are responsible for conducting OEHS activities in 
accordance with DOD policy. Throughout this testimony, we identify the 
military services operating in a deployment as "deployed military 
services."

My remarks will summarize our findings on (1) how the deployed military 
services have implemented DOD's policies for collecting and reporting 
OEHS data for OIF and (2) the efforts under way to use OEHS reports to 
address both the immediate and long-term health issues of 
servicemembers deployed in support of OIF. My statement is based on our 
report, entitled Defense Health Care: Improvements Needed in 
Occupational and Environmental Health Surveillance during Deployments 
to Address Immediate and Long-term Health Issues (GAO-05-632), which is 
being released today.

To do this work, we reviewed pertinent policies, guidance, and reports 
related to collecting and reporting OEHS data obtained from officials 
at the Deployment Health Support Directorate (DHSD), the military 
services, and the Joint Staff, which supports the Chairman of the Joint 
Chiefs of Staff.[Footnote 1] We also conducted site visits to the Army, 
Navy, and Air Force health surveillance centers that develop standards 
and guidance for conducting OEHS.[Footnote 2] We interviewed DOD 
officials and reviewed reports and documents identifying occupational 
and environmental health risks and outlining recommendations for 
addressing risks at deployment sites. We interviewed officials at the 
U.S. Army's Center for Health Promotion and Preventive Medicine 
(CHPPM), which archives OEHS reports, both classified and unclassified, 
for all the military services. We also interviewed officials and 
military service representatives at DOD's Deployment Manpower Data 
Center on the status of a centralized deployment tracking database to 
identify deployed servicemembers and record their locations within the 
theater of operations. Additionally, we interviewed VA officials on 
their experience in obtaining and using OEHS reports from OIF to 
address the health care needs of veterans. Finally, we interviewed DOD 
and VA officials to examine whether the agencies have planned or 
initiated health research to evaluate the long-term health of 
servicemembers deployed in support of OIF using OEHS reports. We 
conducted our work from September 2004 through June 2005 in accordance 
with generally accepted government auditing standards.

In summary, although OEHS data generally have been collected and 
reported for OIF, as required by DOD policy, the deployed military 
services have used different data collection methods and have not 
submitted all of the OEHS reports that have been completed. Data 
collection methods for air and soil surveillance have varied across the 
services, for example, although they have been using the same 
monitoring standard for water surveillance. Compounding these 
differences among the services were varying levels of training and 
expertise among the deployed military service personnel who were 
responsible for conducting OEHS activities, resulting in differing 
practices for implementing data collection standards. For some OEHS 
activities, a cross-service working group, called the Joint 
Environmental Surveillance Working Group, has been developing standards 
and practices to increase uniformity of data collection among the 
services. In addition, the deployed military services have not 
submitted to CHPPM all OEHS reports that have been completed during 
OIF, as required by DOD policy. While 239 of the 277 OIF bases had at 
least one OEHS report submitted to CHPPM's centralized archive as of 
December 2004, CHPPM could not measure the magnitude of noncompliance 
because not all of the required consolidated lists that identify all 
OEHS reports completed during each quarter in OIF had been submitted. 
Therefore, CHPPM could not compare the reports that it had received 
against the list of reports that had been completed. According to CHPPM 
officials, obstacles to the services' reporting compliance may have 
included a lack of understanding by some within the deployed military 
services about the type of OEHS reports that should have been 
submitted. In addition, OEHS report submission may be given a lower 
priority compared to other deployment mission activities. Also, while 
CHPPM is responsible for OEHS archiving, it has no authority to enforce 
report submission requirements. To improve OEHS reporting compliance, 
DOD officials said they were revising an existing policy to add 
additional and more specific OEHS requirements.

DOD has made progress using OEHS reports to address immediate health 
risks during OIF, but limitations remain in employing these reports to 
address both immediate and long-term health issues. OIF is the first 
major deployment in which OEHS reports have been used consistently as 
part of operational risk management activities intended to identify and 
address immediate health risks. These activities included health risk 
assessments that described and measured the potential hazards at a 
site, risk mitigation activities intended to reduce potential exposure, 
and risk communication efforts undertaken to make servicemembers aware 
of the possible health risks of potential exposures. While these 
efforts may help reduce health risks, there is no assurance that they 
have been effective because DOD has not systematically evaluated the 
implementation of OEHS risk management activities in OIF. Despite 
progress in the use of OEHS information to identify and address 
immediate health risks, CHPPM's centralized archive of OEHS reports for 
OIF has limitations for addressing potential long-term health effects 
related to occupational and environmental exposures for several 
reasons. First, access to CHPPM's OEHS archive has been limited because 
most OEHS reports are classified--which restricts their use by VA, 
medical professionals, and interested researchers. Second, it will be 
difficult to link most OEHS reports to individual servicemembers 
because not all data on servicemembers' deployment locations have been 
submitted to DOD's centralized tracking database. For example, none of 
the military services submitted location data for the first several 
months of OIF. To address problems with linking OEHS reports to 
individual servicemembers, the deployed military services have made 
efforts to include OEHS summaries in the medical records of some 
servicemembers for either specific incidents of potential exposure or 
for specific locations within OIF, such as air bases. Additionally, 
according to DOD and VA officials, no comprehensive federal research 
plan incorporating the use of the archived OEHS reports has been 
developed to address the long-term health consequences of service in 
OIF.

In the report we are issuing today, we recommend that the Secretary of 
Defense ensure that cross-service guidance is developed to implement 
DOD's revised policy for OEHS during deployments and ensure that the 
military services jointly establish and implement procedures to 
evaluate the effectiveness of risk management strategies during 
deployments. We also recommend that the Secretary of Defense and the 
Secretary of Veterans Affairs work together to develop a federal 
research plan to follow the health of OIF servicemembers over time that 
would include the use of OEHS reports. In commenting on a draft of this 
report, DOD stated that cross-service guidance meeting the intent of 
our recommendation would be developed by the Joint Staff instead of the 
military services. DOD partially concurred with our other 
recommendations. VA concurred with our recommendation to work with DOD 
to jointly develop a federal research plan to follow the long-term 
health of OIF servicemembers.

Background:

As of the end of February 2005, an estimated 827,277 servicemembers had 
been deployed in support of OIF. Deployed servicemembers, such as those 
in OIF, are potentially subject to occupational and environmental 
hazards that can include exposure to harmful levels of environmental 
contaminants such as industrial toxic chemicals, chemical and 
biological warfare agents, and radiological and nuclear contaminants. 
Harmful levels include high-level exposures that result in immediate 
health effects.[Footnote 3] Health hazards may also include low-level 
exposures that could result in delayed or long-term health effects. 
Occupational and environmental health hazards may include such things 
as contamination from the past use of a site, from battle damage, from 
stored stockpiles, from military use of hazardous materials, or from 
other sources.

Federal OEHS Policy:

As a result of numerous investigations that found inadequate data on 
deployment occupational and environmental exposure to identify the 
potential causes of unexplained illnesses among veterans who served in 
the 1991 Persian Gulf War, the federal government increased efforts to 
identify potential occupational and environmental hazards during 
deployments. In 1997, a Presidential Review Directive called for a 
report by the National Science and Technology Council to establish an 
interagency plan to improve the federal response to the health needs of 
veterans and their families related to the adverse effects of 
deployment.[Footnote 4] The Council published a report that set a goal 
for the federal government to develop the capability to collect and 
assess data associated with anticipated exposure during deployments. 
Additionally, the report called for the maintenance of the capability 
to identify and link exposure and health data by Social Security number 
and unit identification code. Also in 1997, Public Law 105-85 included 
a provision recommending that DOD ensure the deployment of specialized 
units to theaters of operations to detect and monitor chemical, 
biological, and similar hazards.[Footnote 5] The Presidential Review 
Directive and the public law led to a number of DOD instructions, 
directives, and memoranda that have guided the collection and reporting 
of deployment OEHS data.

DOD Entities Involved with Setting and Implementing OEHS Policy:

DHSD makes recommendations for DOD-wide policies on OEHS data 
collection and reporting during deployments to the Office of the 
Assistant Secretary of Defense for Health Affairs. DHSD is assisted by 
the Joint Environmental Surveillance Working Group, established in 
1997, which serves as a coordinating body to develop and make 
recommendations for DOD-wide OEHS policy.[Footnote 6] The working group 
includes representatives from the Army, Navy, and Air Force OEHS health 
surveillance centers, the Joint Staff, other DOD entities, and VA.

Each service has a health surveillance center--the CHPPM, the Navy 
Environmental Health Center, and the Air Force Institute for 
Operational Health--that provides training, technical guidance and 
assistance, analytical support, and support for preventive medicine 
units[Footnote 7] in the theater in order to carry out deployment OEHS 
activities in accordance with DOD policy. In addition, these centers 
have developed and adapted military exposure guidelines for deployment 
using existing national standards for human health exposure limits and 
technical monitoring procedures (e.g., standards developed by the U.S. 
Environmental Protection Agency and the National Institute for 
Occupational Safety and Health) and have worked with other agencies to 
develop new guidelines when none existed. (See fig. 1.)

Figure 1: Entities Involved in Setting or Implementing Occupational and 
Environmental Health Surveillance (OEHS) Policy:

[See PDF for image]

[End of figure]

Deployment OEHS Reports:

DOD policies and military service guidelines require that the 
preventive medicine units of each military service be responsible for 
collecting and reporting deployment OEHS data.[Footnote 8] Deployment 
OEHS data are generally categorized into three types of reports: 
baseline, routine, or incident-driven.

* Baseline reports generally include site surveys and assessments of 
occupational and environmental hazards prior to deployment of 
servicemembers and initial environmental health site assessments once 
servicemembers are deployed.[Footnote 9]

* Routine reports record the results of regular monitoring of air, 
water, and soil, and of monitoring for known or possible hazards 
identified in the baseline assessment.

* Incident-driven reports document exposure or outbreak 
investigations.[Footnote 10]

There are no DOD-wide requirements on the specific number or type of 
OEHS reports that must be created for each deployment location because 
reports generated for each location reflect the specific occupational 
and environmental circumstances unique to that location. CHPPM 
officials said that reports generally reflect deployment OEHS 
activities that are limited to established sites such as base camps or 
forward operating bases;[Footnote 11] an exception is an investigation 
during an incident outside these locations. Constraints to conducting 
OEHS outside of bases include risks to servicemembers encountered in 
combat and limits on the portability of OEHS equipment. In addition, 
DHSD officials said that preventive medicine units might not be aware 
of every potential health hazard and therefore might be unable to 
conduct appropriate OEHS activities.

OEHS Reporting and Archiving Activities during Deployment:

According to DOD policy, various entities must submit their completed 
OEHS reports to CHPPM during a deployment. The deployed military 
services have preventive medicine units that submit OEHS reports to 
their command surgeons,[Footnote 12] who review all reports and ensure 
that they are sent to a centralized archive that is maintained by 
CHPPM.[Footnote 13] Alternatively, preventive medicine units can be 
authorized to submit OEHS reports directly to CHPPM for archiving. (See 
fig. 2.)

Figure 2: Submittal of Deployment Occupational and Environmental Health 
Surveillance (OEHS) Reports to the Centralized Archive:

[See PDF for image]

[A] The command surgeons of deployed preventive medicine units are 
either Joint Task Force command surgeons or military service component 
command surgeons. In OIF, there are two Joint Task Forces, each with a 
command surgeon. In addition, the Army, Navy, Air Force, and Marine 
Corps have their own subordinate component commands in a deployment, 
each with a command surgeon.

[End of figure]

According to DOD policy, baseline and routine reports should be 
submitted within 30 days of report completion.[Footnote 14] Initial 
incident-driven reports should be submitted within 7 days of an 
incident or outbreak. Interim and final reports for an incident should 
be submitted within 7 days of report completion. In addition, the 
preventive medicine units are required to provide quarterly lists of 
all completed deployment OEHS reports to the command surgeons. The 
command surgeons review these lists, merge them, and send CHPPM a 
quarterly consolidated list of all the deployment OEHS reports it 
should have received.

To assess the completeness of its centralized OEHS archive, CHPPM 
develops a quarterly summary report that identifies the number of 
baseline, routine, and incident-driven reports that have been submitted 
for all bases in a command. This report also summarizes the status of 
OEHS report[Footnote 15] submissions by comparing the reports CHPPM 
receives with the quarterly consolidated lists from the command 
surgeons that list each of the OEHS reports that have been completed. 
For OIF, CHPPM is required to provide a quarterly summary report to the 
commander of U.S. Central Command[Footnote 16] on the deployed military 
services' compliance with deployment OEHS reporting requirements.

Uses of Deployment OEHS Reports:

During deployments, military commanders can use deployment OEHS reports 
completed and maintained by preventive medicine units to identify 
occupational and environmental health hazards[Footnote 17] and to help 
guide their risk management decision making. Commanders use an 
operational risk management process to estimate health risks based on 
both the severity of the risks to servicemembers and the likelihood of 
encountering the specific hazard. Commanders balance the risk to 
servicemembers of encountering occupational and environmental health 
hazards while deployed, even following mitigation efforts, against the 
need to accomplish specific mission requirements. The operational risk 
management process, which varies slightly across the services, 
includes: 

* risk assessment, including hazard identification, to describe and 
measure the potential hazards at a location;

* risk control and mitigation activities intended to reduce potential 
exposures; and:

* risk communication efforts to make servicemembers aware of possible 
exposures, any risks to health that they may pose, the countermeasures 
to be employed to mitigate exposure or disease outcome, and any 
necessary medical measures or follow-up required during or after the 
deployment.

Along with health encounter[Footnote 18] and servicemember location 
data, archived deployment OEHS reports are needed by researchers to 
conduct epidemiologic studies on the long-term health issues of 
deployed servicemembers. These data are needed, for example, by VA, 
which in 2002 expanded the scope of its health research to include 
research on the potential long-term health effects on servicemembers in 
hazardous military deployments. In a letter to the Secretary of Defense 
in 2003, VA said it was important for DOD to collect adequate health 
and exposure data from deployed servicemembers to ensure VA's ability 
to provide veterans' health care and disability compensation. VA noted 
in the letter that much of the controversy over the health problems of 
veterans who fought in the 1991 Persian Gulf War could have been 
avoided had more extensive surveillance data been collected. VA asked 
in the letter that it be allowed access to any unclassified data 
collected during deployments on the possible exposure of servicemembers 
to environmental hazards of all kinds.

Deployed Military Services Use Varying Approaches to Collect OEHS Data 
and Have Not Submitted All OEHS Reports for OIF:

The deployed military services generally have collected and reported 
OEHS data for OIF, as required by DOD policy. However, the deployed 
military services have used different OEHS data collection standards 
and practices, because each service has its own authority to implement 
broad DOD policies. To increase data collection uniformity, the Joint 
Environmental Surveillance Working Group has made some progress in 
devising cross-service standards and practices for some OEHS 
activities. In addition, the deployed military services have not 
submitted all of the OEHS reports they have completed for OIF to 
CHPPM's centralized archive, as required by DOD policy. However, CHPPM 
officials said that they could not measure the magnitude of 
noncompliance because they have not received all of the required 
quarterly consolidated lists of OEHS reports that have been completed. 
To improve OEHS reporting compliance, DOD officials said they were 
revising an existing policy to add additional and more specific OEHS 
requirements.

Data Collection Standards and Practices Vary by Service, Although 
Preliminary Efforts Are Under Way to Increase Uniformity:

OEHS data collection standards[Footnote 19] and practices have varied 
among the military services because each service has its own authority 
to implement broad DOD policies, and the services have taken somewhat 
different approaches. For example, although one water monitoring 
standard has been adopted by all military services, the services have 
different standards for both air and soil monitoring. As a result, for 
similar OEHS events, preventive medicine units may collect and report 
different types of data. Each military service's OEHS practices for 
implementing data collection standards also have differed because of 
varying levels of training and expertise among the service's preventive 
medicine units. For example, CHPPM officials said that Air Force and 
Navy preventive medicine units had more specialized personnel with a 
narrower focus on specific OEHS activities than Army preventive 
medicine units, which included more generalist personnel who conducted 
a broader range of OEHS activities. Air Force preventive medicine units 
generally have included a flight surgeon, a public health officer, and 
bioenvironmental engineers. Navy preventive medicine units generally 
have included a preventive medicine physician, an industrial hygienist, 
a microbiologist, and an entomologist. In contrast, Army preventive 
medicine unit personnel generally have consisted of environmental 
science officers and technicians.

DOD officials also said other issues could contribute to differences in 
data collected during OIF. DHSD officials said that variation in OEHS 
data collection practices could occur as a result of resource 
limitations during a deployment. For example, some preventive medicine 
units may not be fully staffed at some bases. A Navy official also said 
that OEHS data collection can vary as different commanders set 
guidelines for implementing OEHS activities in the deployment theater.

To increase the uniformity of OEHS standards and practices for 
deployments, the military services have made some progress-- 
particularly in the last 2 years--through their collaboration as 
members of the Joint Environmental Surveillance Working Group. For 
example, the working group has developed a uniform standard, which has 
been adopted by all the military services, for conducting environmental 
health site assessments, which are a type of baseline OEHS 
report.[Footnote 20] These assessments have been used in OIF to 
evaluate potential environmental exposures that could have an impact on 
the health of deployed servicemembers and determine the types of 
routine OEHS monitoring that should be conducted. Also, within the 
working group, three subgroups--laboratory, field water, and equipment-
-have been formed to foster the exchange of information among the 
military services in developing uniform joint OEHS standards and 
practices for deployments. For example, DHSD officials said the 
equipment subgroup has been working collaboratively to determine the 
best OEHS instruments to use for a particular type of location in a 
deployment.

Deployed Military Services Have Not Submitted All Required OEHS Reports 
for OIF, and the Magnitude of Noncompliance Is Unknown:

The deployed military services have not submitted all the OEHS reports 
that the preventive medicine units completed during OIF to CHPPM for 
archiving, according to CHPPM officials. Since January 2004, CHPPM has 
compiled four summary reports that included data on the number of OEHS 
reports submitted to CHPPM's archive for OIF. However, these summary 
reports have not provided information on the magnitude of noncompliance 
with report submission requirements because CHPPM has not received all 
consolidated lists of completed OEHS reports that should be submitted 
quarterly. These consolidated lists were intended to provide a key 
inventory of all OEHS reports that had been completed during OIF. 
Because there are no requirements on the specific number or type of 
OEHS reports that must be created for each base, the quarterly 
consolidated lists are CHPPM's only means of assessing compliance with 
OEHS report submission requirements. Our analysis of data supporting 
the four summary reports[Footnote 21] found that, overall, 239 of the 
277 bases[Footnote 22] had at least one OEHS baseline (139) or routine 
(211) report submitted to CHPPM's centralized archive through December 
2004.[Footnote 23]

DOD officials suggested several obstacles that may have hindered OEHS 
reporting compliance during OIF. For example, CHPPM officials said 
there are other, higher priority operational demands that commanders 
must address during a deployment. In addition, CHPPM officials said 
that some of the deployed military services' preventive medicine units 
might not understand the types of OEHS reports to be submitted or might 
view them as an additional paperwork burden. CHPPM and other DOD 
officials added that some preventive medicine units might have limited 
access to communication equipment to send reports to CHPPM for 
archiving.[Footnote 24] CHPPM officials also said that while they had 
the sole archiving responsibility, CHPPM did not have the authority to 
enforce OEHS reporting compliance for OIF--this authority rests with 
the Joint Staff and the commander in charge of the deployment.

DOD has several efforts under way to improve OEHS reporting compliance. 
CHPPM officials said they have increased communication with deployed 
preventive medicine units and have facilitated coordination among each 
service's preventive medicine units prior to deployment. CHPPM has also 
conducted additional OEHS training for some preventive medicine units 
prior to deployment, including both refresher courses and information 
about potential hazards specific to the locations where the units were 
being deployed. In addition, DHSD officials said they were revising an 
existing policy to add additional and more specific OEHS requirements. 
However, at the time of our review, a draft of the revision had not 
been released, and therefore specific details about the revision were 
not available.

Progress Made in Using OEHS Reports to Address Immediate Health Risks, 
Though Limitations Remain for Addressing Both Immediate and Long-term 
Health Issues:

DOD has made progress in using OEHS reports to address immediate health 
risks during OIF, but limitations remain in employing these reports to 
address both immediate and long-term health issues. During OIF, OEHS 
reports have been used as part of operational risk management 
activities intended to assess, mitigate, and communicate to 
servicemembers any potential hazards at a location. There have been no 
systematic efforts by DOD or the military services to establish a 
system to monitor the implementation of OEHS risk management 
activities, although DHSD officials said they considered the relatively 
low rates of disease and nonbattle injury in OIF an indication of OEHS 
effectiveness. In addition, DOD's centralized archive of OEHS reports 
for OIF is limited in its ability to provide information on the 
potential long-term health effects related to occupational and 
environmental exposures for several reasons, including limited access 
to most OEHS reports because of their security classification, 
incomplete data on servicemembers' deployment locations, and the lack 
of a comprehensive federal research plan incorporating the use of 
archived OEHS reports.

DOD Has Made Progress in Using Deployment OEHS Data and Reports in Risk 
Management but Does Not Monitor Implementation of These Efforts:

To identify and reduce the risk of immediate health hazards in OIF, all 
of the military services have used preventive medicine units' OEHS data 
and reports in an operational risk management process. A DOD official 
said that while DOD had begun to implement risk management to address 
occupational and environmental hazards in other recent deployments, OIF 
was the first major deployment to apply this process throughout the 
deployed military services' day-to-day activities, beginning at the 
start of the operation.[Footnote 25] The operational risk management 
process includes risk assessments of deployment locations, risk 
mitigation activities to limit potential exposures, and risk 
communication to servicemembers and commanders about potential hazards.

* Risk Assessments. Preventive medicine units from each of the services 
have generally used OEHS information and reports to develop risk 
assessments that characterized known or potential hazards when new 
bases were opened in OIF. CHPPM's formal risk assessments have also 
been summarized or updated to include the findings of baseline and 
routine OEHS monitoring conducted while bases are occupied by 
servicemembers, CHPPM officials said. During deployments, commanders 
have used risk assessments to balance the identified risk of 
occupational and environmental health hazards, and other operational 
risks, with mission requirements. Generally, OEHS risk assessments for 
OIF have involved analysis of the results of air, water, or soil 
monitoring.[Footnote 26] CHPPM officials said that most risk 
assessments that they have received characterized locations in OIF as 
having a low risk of posing health hazards to servicemembers.[Footnote 
27]

* Risk Control and Mitigation. Using risk assessment findings, 
preventive medicine units have recommended risk control and mitigation 
activities to commanders that were intended to reduce potential 
exposures at specific locations. For OIF, risk control and mitigation 
recommendations at bases have included such actions as modifying work 
schedules, requiring individuals to wear protective equipment, and 
increasing sampling to assess any changes and improve confidence in the 
accuracy of the risk estimate.

* Risk Communication. Risk assessment findings have also been used in 
risk communication efforts, such as providing access to information on 
a Web site or conducting health briefings to make servicemembers aware 
of occupational and environmental health risks during a deployment and 
the recommended efforts to control or mitigate those risks, including 
the need for medical follow-up. Many of the risk assessments for OIF we 
reviewed recommended that health risks be communicated to 
servicemembers.

While risk management activities have become more widespread in OIF 
compared with previous deployments, DOD officials have not conducted 
systematic monitoring of deployed military services' efforts to conduct 
OEHS risk management activities. As of March 2005, neither DOD nor the 
military services had established a system to examine whether required 
risk assessments had been conducted, or to record and track resulting 
recommendations for risk mitigation or risk communication activities. 
In the absence of a systematic monitoring process, CHPPM officials said 
they conducted ad hoc reviews of implementation of risk management 
recommendations for sites where continued, widespread OEHS monitoring 
has occurred, such as at Port Shuaiba, Kuwait, a deepwater port where a 
large number of servicemembers have been stationed, or other locations 
with elevated risks. DHSD officials said they have initiated planning 
for a comprehensive quality assurance program for deployment health 
that would address OEHS risk management, but the program was still 
under development.

DHSD and military service officials said that developing a monitoring 
system for risk management activities would face several challenges. In 
response to recommendations for risk mitigation and risk communication 
activities, commanders may have issued written orders and guidance that 
were not always stored in a centralized, permanent database that could 
be used to track risk management activities. Additionally, DHSD 
officials told us that risk management decisions have sometimes been 
recorded in commanders' personal journals or diaries, rather than 
issued as orders that could be stored in a centralized, permanent 
database.

In lieu of a monitoring system, DHSD officials said that DOD considers 
the rates of disease and nonbattle injury in OIF as a general measure 
or indicator of OEHS effectiveness. As of January 2005, OIF had a 4 
percent total disease and nonbattle injury rate--in other words, an 
average of 4 percent of servicemembers deployed in support of OIF had 
been seen by medical units for an injury or illness in any given week. 
This rate is the lowest DOD has ever documented for a major deployment, 
according to DHSD officials. For example, the total disease and 
nonbattle injury rate for the 1991 Gulf War was about 6.5 percent, and 
the total rate for Operation Enduring Freedom in Central Asia has been 
about 5 percent. However, while this indicator provides general 
information on servicemembers' health status, it is not directly linked 
to specific OEHS activities and therefore is not a clear measure of 
their effectiveness.

Access to Most Archived OEHS Reports Is Limited by Security 
Classification:

Access to archived OEHS reports by VA, medical professionals, and 
interested researchers has been limited by the security classification 
of most OEHS reports.[Footnote 28] Typically, OEHS reports are 
classified if the specific location where monitoring activities occur 
is identified. VA officials said they would like to have access to OEHS 
reports in order to ensure appropriate postwar health care and 
disability compensation for veterans, and to assist in future research 
studies. However, VA officials said that, because of these security 
concerns, they did not expect access to OEHS reports to improve until 
OIF has ended.

Although access to OEHS reports has been restricted, VA officials said 
they have tried to anticipate likely occupational and environmental 
health concerns for OIF based on experience from the 1991 Persian Gulf 
War and on CHPPM's research on the medical or environmental health 
conditions that exist or might develop in the region. Using this 
information, VA has developed study guides for physicians on such 
topics as health effects from radiation and traumatic brain injury and 
also has written letters for OIF veterans about these issues.

DOD has begun reviewing classification policies for OEHS reports, as 
required by the Ronald W. Reagan National Defense Authorization Act for 
Fiscal Year 2005.[Footnote 29] A DHSD official said that DOD's newly 
created Joint Medical Readiness Oversight Committee is expected to 
review ways to reduce or limit the classification of data, including 
data that are potentially useful for monitoring and assessing the 
health of servicemembers who have been exposed to occupational or 
environmental hazards during deployments.

Difficulties Exist in Linking Archived OEHS Reports to Individual 
Servicemembers, but Some Efforts Are Under Way to Include Information 
in Medical Records:

Linking OEHS reports from the archive to individual servicemembers will 
be difficult because DOD's centralized tracking database for recording 
servicemembers' deployment locations currently does not contain 
complete or comparable data. In May 1997, we reported that the ability 
to track the movement of individual servicemembers within the theater 
is important for accurately identifying exposures of servicemembers to 
health hazards.[Footnote 30] However, the Defense Manpower Data 
Center's centralized database has continued to experience problems in 
obtaining complete, comparable data from the services on the location 
of servicemembers during deployments, as required by DOD 
policies.[Footnote 31] Data center officials said the military services 
had not reported location data for all servicemembers for OIF. As of 
October 2004, the Army, Air Force, and Marine Corps each had submitted 
location data for approximately 80 percent of their deployed 
servicemembers, and the Navy had submitted location data for about 60 
percent of its deployed servicemembers.[Footnote 32] Additionally, the 
specificity of location data has varied by service. For example, the 
Marine Corps has provided location of servicemembers only by country, 
whereas each of the other military services has provided more detailed 
location information for some of their servicemembers, such as base 
camp name or grid coordinate locations. Furthermore, the military 
services did not begin providing detailed location data until OIF had 
been ongoing for several months.

DHSD officials said they have been revising an existing policy[Footnote 
33] to provide additional requirements for location data that are 
collected by the military services, such as a daily location record 
with grid coordinates or latitude and longitude coordinates for all 
servicemembers. Though the revised policy has not been published, as of 
May 2005 the Army and the Marine Corps had implemented a new joint 
location database in support of OIF that addresses these revisions.

During OIF, some efforts have been made to include information about 
specific incidents of potential and actual exposure to occupational or 
environmental health hazards in the medical records of servicemembers 
who may have been affected. According to DOD officials, preventive 
medicine units have been investigating incidents involving potential 
exposure during the deployment. For a given incident, a narrative 
summary of events and the results of any medical procedures generally 
were included in affected servicemembers' medical records. 
Additionally, rosters were generally developed of servicemembers 
directly affected and of servicemembers who did not have any acute 
symptoms but were in the vicinity of the incident. For example, in 
investigating an incident involving a chemical agent used in an 
improvised explosive device, CHPPM officials said that two soldiers who 
were directly involved were treated at a medical clinic, and their 
treatment and the exposure were recorded in their medical records. 
Although 31 servicemembers who were providing security in the area were 
asymptomatic, doctors were documenting this potential exposure in their 
medical records.

In addition, the military services have taken some steps to include 
summaries of potential exposures to occupational and environmental 
health hazards in the medical records of servicemembers deployed to 
specific locations. The Air Force has created summaries of these 
hazards at deployed air bases and has required that these be placed in 
the medical records of all Air Force servicemembers stationed at these 
bases. (See app. I for an example.) However, Air Force officials said 
no follow-up activities have been conducted specifically to determine 
whether all Air Force servicemembers have had the summaries placed in 
their medical records. Similarly, the Army and Navy jointly created a 
summary of potential exposure for the medical records of servicemembers 
stationed at Port Shuaiba, the deepwater port used for bringing in 
heavy equipment in support of OIF where a large number of 
servicemembers have been permanently or temporarily stationed. Since 
December 2004, port officials have made efforts to make the summary 
available to servicemembers stationed at Port Shuaiba so that these 
servicemembers can include the summary in their medical records. 
However, there has been no effort to retroactively include the summary 
in the medical records of servicemembers stationed at the port prior to 
that time.

No Federal Research Plan Exists for Using OEHS Reports to Follow the 
Health of OIF Servicemembers over Time:

According to DOD and VA officials, no federal research plan that 
includes the use of archived OEHS reports has been developed to 
evaluate the long-term health of servicemembers deployed in support of 
OIF, including the effects of potential exposure to occupational or 
environmental hazards. In February 1998 we noted that the federal 
government lacked a proactive strategy to conduct research into Gulf 
War veterans' health problems and suggested that delays in planning 
complicated researchers' tasks by limiting opportunities to collect 
critical data.[Footnote 34] However, the Deployment Health Working 
Group, a federal interagency body responsible for coordinating research 
on all hazardous deployments, recently began discussions on the first 
steps needed to develop a research plan for OIF.[Footnote 35] At its 
January 2005 meeting, the working group tasked its research 
subcommittee to develop a complete list of research projects currently 
under way that may be related to OIF.[Footnote 36] VA officials noted 
that because OIF is ongoing, the working group would have to determine 
how to address a study population that changes as the number of 
servicemembers deployed in support of OIF changes.[Footnote 37]

Although no coordinated federal research plan has been developed, other 
separate federal research studies are underway that may follow the 
health of OIF servicemembers. For example, in 2000 VA and DOD 
collaborated to develop the Millennium Cohort study, a 21-year 
longitudinal study evaluating the health of both deployed and 
nondeployed military personnel throughout their military careers and 
after leaving military service. According to the principal 
investigator, the Millennium Cohort study was designed to examine the 
health effects of specific deployments if enough servicemembers in that 
deployment enrolled in the study. However, the principal investigator 
said that as of February 2005 researchers had not identified how many 
servicemembers deployed in support of OIF had enrolled in the study. In 
another effort, a VA researcher has received funding to study mortality 
rates among OIF servicemembers. According to the researcher, if 
occupational and environmental data are available, the study will 
include the evaluation of mortality outcomes in relation to potential 
exposure for OIF servicemembers.

Concluding Observations:

As we stated in our report, DOD's efforts to collect and report OEHS 
data could be strengthened. Currently, OEHS data that the deployed 
military services have collected during OIF may not always be 
comparable because of variations among the services' data collection 
standards and practices. Additionally, the deployed military services' 
uncertain compliance with OEHS report submission requirements casts 
doubt on the completeness of CHPPM's OEHS archive. These data 
shortcomings, combined with incomplete data in DOD's centralized 
tracking database of servicemembers' deployment locations, limit 
CHPPM's ability to respond to requests for OEHS information about 
possible exposure to occupational and environmental health hazards of 
those who are serving or have served in OIF. DOD officials have said 
they are revising an existing policy on OEHS data collection and 
reporting to add additional and more specific OEHS requirements. 
However, unless the military services take measures to direct those 
responsible for OEHS activities to proactively implement the new 
requirements, the services' efforts to collect and report OEHS data may 
not improve. Consequently, we recommended that the Secretary of Defense 
ensure that cross-service guidance is created to implement DOD's 
policy, once that policy has been revised, to improve the collection 
and reporting of OEHS data during deployments and the linking of OEHS 
reports to servicemembers. DOD responded that cross-service 
implementation guidance for the revised policy on deployment OEHS would 
be developed by the Joint Staff.

While DOD's risk management efforts during OIF represent a positive 
step in helping to mitigate potential environmental and occupational 
risks of deployment, the lack of systematic monitoring of the deployed 
military services' implementation activities prevents full knowledge of 
their effectiveness. Therefore, we recommended that the military 
services jointly establish and implement procedures to evaluate the 
effectiveness of risk management efforts. DOD partially concurred with 
our recommendation and stated that it has procedures in place to 
evaluate OEHS risk management through a jointly established and 
implemented lessons learned process. However, in further discussions, 
DOD officials told us that they were not aware of any lessons learned 
reports related to OEHS risk management for OIF.

Furthermore, although OEHS reports alone are not sufficient to identify 
the causes of potential long-term health effects in deployed 
servicemembers, they are an integral component of research to evaluate 
the long-term health of deployed servicemembers. However, efforts by a 
joint DOD and VA working group to develop a federal research plan for 
OIF that would include examining the effects of potential exposure to 
occupational and environmental health hazards have just begun, despite 
similarities in deployment location to the 1991 Persian Gulf War. As a 
result, we recommended that DOD and VA work together to develop a 
federal research plan to follow the health of servicemembers deployed 
in support of OIF that would include the use of archived OEHS reports. 
DOD partially concurred with our recommendation, and VA concurred. The 
difference in VA and DOD's responses to this recommendation illustrates 
a disconnect between each agency's understanding of whether and how 
such a federal research plan should be established. Therefore, 
continued collaboration between the agencies to formulate a mutually 
agreeable process for proactively creating a federal research plan 
would be beneficial in facilitating both agencies' ability to 
anticipate and understand the potential long-term health effects 
related to OIF deployment versus taking a more reactive stance in 
waiting to see what types of health problems may surface.

Mr. Chairman, this completes my prepared statement. I would be happy to 
respond to any question you or other Members of the Subcommittee may 
have at this time.

GAO Contact and Staff Acknowledgments:

For further information about this testimony, please contact Marcia 
Crosse at (202) 512-7119 or crossem@gao.gov. Contact points for our 
Offices of Congressional Relations and Public Affairs may be found on 
the last page of this testimony. In addition to the contacts named 
above, Bonnie Anderson, Assistant Director, Karen Doran, Beth Morrison, 
John Oh, Danielle Organek, and Roseanne Price also made key 
contributions to this testimony.

[End of section]

Appendix I: Example of an Occupational and Environmental Health 
Surveillance Summary Created by the Air Force:

PREVIOUS EDITION IS USABLE: 

AUTHORIZED FOR LOCAL REPRODUCTION:

CHRONOLOGICAL RECORD OF MEDICAL CARE:

SYMPTOMS, DIAGNOSIS, TREATMENT, TREATING ORGANIZATION (Sign each 
entry): 

ENVIRONMENTAL/OCCUPATIONAL HEALTHWORKPLACE EXPOSURE DATA:

This assessment covers individuals deployed to BAGHDAD AIR BASE (BDAB), 
IRAQ for the time period 15 DEC 03 to 30 APR 2004.

Purpose: To comply with the deployment health surveillance requirements 
of Presidential Review Directive 5 and JCSM 0006-02, Updated Procedures 
for Deployment Health Surveillance and Readiness. CENTAF/SG officially 
sanctions use of this form and recommends it be maintained in the 
individual s permanent medical record with the DD Form 2796, Post 
Deployment Health Assessment, covering the same time period.

Camps Sather and Griffin, the primary AF locations on Baghdad 
International Airport (BIAP), were part of the Iraqi Military Training 
portion of BIAP. However, this specific area was not heavily used. The 
small Iraqi terminal on site was for military guests and distinguished 
visitors. Base housing and training was on the other side of the main 
road outside Camp Sather. While there is farming around BIAP, we are 
not aware of any specific farming activities within Camp Sather; 
however, there is evidence of flooded fields in/around Camp Griffin. We 
are also not aware of any major spills within the BIAP AF cantonment. 
BDAB refers to both Camps Sather and Griffin.

Environmental Exposure Data and Risk Assessment:

1. Airborne Dust: The level of airborne particulate matter is high 
throughout the Middle East due to wind blown dust and sand. Expected 
health effects associated with exposures to airborne particulates 
include eye, nose, and throat irritation, sneezing, coughing, sinus 
congestion, sinus drainage, and aggravation of asthma conditions. Based 
on air sampling performed in and around BIAP, the overall health risk 
to personnel from exposure to airborne dust is assessed as low. PM sub 
10 and manganese air samples taken in late May 2003 indicated 
concentrations nearly double their respective military exposure 
guidelines. However, no long-term health affects are anticipated for 
personnel as for a period less than two years.

2. Airborne Emissions From Petroleum Production/Other Nearby 
Industrial/Disposal Activities: There are multiple industrial 
activities near BIAP. Chemical storage and processing plants are 
located within 5-10 miles of BIAP, primarily to the east and south. 
However, operations at these facilities are severely limited in the 
aftermath of combat activities in/around BIAP. Multiple industrial 
activities, to include manufacturing, construction, and petroleum 
refining are located in the greater Baghdad metropolitan area. With the 
prevailing winds from the northwest, BIAP is located downwind from only 
a few industrial activities, primarily light to medium manufacturing 
facilities. Routine exposure of BIAP personnel to airborne emissions 
from off-base industrial sources is assessed as minimal to nonexistent, 
with no increased risk to health resulting from routine exposure. Army 
units in/around BIAP no longer burn out human and other waste products, 
and no units BIAP burn trash/garbage. There is no health risk expected 
from these intermittent exposures.

3. Endemic Diseases: Leishmaniasis (both cutaneous and visceral) occurs 
in Iraq at a sporadic level. On-base vector surveillance, during 
transmission season, yielded many sand flies from unbated traps, some 
of which tested positive for leishmaniasis. Risk to BDAB personnel is 
assessed as low, so long as the sand fly burden is kept under control. 
Cases may not present with symptoms until 4-6 months post-redeployment. 
Malaria is present in Iraq, but to date has not been a significant 
issue in the Baghdad area. Anopheles mosquitoes are present on BIAP and 
95% of endemic malaria is Plasmodium vivax. CENTCOM reporting 
instructions require personnel to treat uniforms with permethrin and 
apply DEET to exposed skin as necessary to prevent bites. Sanitation 
varies within the country, but typically is well below U.S. standards. 
Consuming local food or water poses a significant risk to personnel for 
bacterial diarrhea. Personnel were advised to consume only food, water, 
and ice from approved sources. Tuberculosis (TB) disease risk 
assessment for Iraq is low. Unless individuals had exposure to anyone 
known or suspected of having active TB, worked closely with refugees or 
prisoners, or had prolonged contact with the local populace, a post- 
deployment tuberculin skin test is not required. Plague is restricted 
to focal areas; enzootic foci historically have existed along the 
Tigris-Euphrates River--extending to Kuwait. Plague risk assessment is 
low.

4. Drinking Water: Bottled water is the source of 100% of the drinking 
water used on BDAB. All bottled water comes from approved sources and 
is tested by 447 EMEDS to ensure water quality meets all applicable 
standards. BDAB has a water distribution system that is supplied via 
truck by US Army reverse osmosis purification units located at North 
Palace, using water from a lake fed by the Tigris River. Tap water is 
considered non-potable and only recommended for cleaning and hygiene 
purposes.

5. Hazardous Animals and Insects: Several species of venomous snakes, 
scorpions and spiders have been identified on base. Generally, they are 
limited in number and BDAB personnel experience minimal sightings or 
contact. Unless otherwise specified in the medical record, individual 
reported no adverse contact (i.e. bites). Feral cats and dogs have also 
been noted in the area. Rats and mice have been a nuisance; one rat 
bite was reported in the summer of 2003.

6. Waste Sites/Waste Disposal: Hazardous waste storage on BDAB is 
limited to used and off-spec POL products, and small spill cleanup 
residue. Currently, proper handling, storage, and disposal of 
industrial waste generated on base (mainly oil, fuel and hydraulic 
fluid) are strictly enforced. Airborne exposure to base personnel from 
stored waste is assessed as minimal to nonexistent. No obvious signs of 
significant past spills or tank leakage were noted when coalition 
forces occupied BIAP, although POL personnel did drain and remove 
several extant tanks. Trash and garbage are containerized and routinely 
collected by contractors. Latrines are pumped out by trucks and waste 
is disposed off-BIAP.

7. Nuclear, Biological or Chemical (NBC) Weapon Exposure: There has 
been no evidence of any use, storage, release, or exposure of NBC 
agents to personnel at this site.

8. Agricultural Emissions: Surrounding land is moderately agricultural. 
Many farms are within 1-2 miles of the perimeter fence, with numerous 
potentially flooded fields for rice cultivation. Aerial photos previous 
to May 2003 revealed that much of BIAP, including parts of the AF 
cantonment, were rice cultivation areas. While we haven'''t witnessed 
any significant application, herbicide/pesticide use probably routinely 
occurs just outside the base. However, airborne exposure to base 
personnel is assessed as minimal to nonexistent.

9. Depleted Uranium (DU): DU is a component of some aircraft present 
and/or transient on/through BDAB. There is no evidence of DU munitions 
having been expended at BIAP. Therefore, there is no potential airborne 
exposure to DU. Exposure is classified as far below permissible 
exposure levels.

10. Hazardous Materials: There are only a few permanent structures on 
BDAB. Both lead-based paint and potential asbestos-containing material 
have been tentatively identified in various locations on BIAP; however, 
personnel are not performing activities that involve routine exposure, 
thereby minimizing health risk. There were multiple sites where Iraqi 
hazardous materials caches were located; however, personnel exposures 
were minimized/eliminated by removing or limiting access to the 
materials.

Occupational Exposure Data and Risk Assessment:

1. Noise: Aircraft, aircraft ground equipment, generators and other 
equipment produce hazardous noise. Workers routinely exposed to 
hazardous noise are those working on or near the flight line and/or in 
selected industrial shops. These workers have comparable noise exposure 
at home station and are on the hearing conservation program. For all 
individuals, appropriate hearing protection is provided for protection 
against hazardous noise. Additionally, the whole of Camp Sather is 
within 300 yards of an extremely active flightline.

2. Heat Stress: Daily temperature range: Mar - Oct from 75 F to 125 F; 
Nov - Feb from 55 F to 95 F. Personnel are continually educated on heat 
stress dangers, water intake and work/rest cycles. Unless separately 
documented, individual had no heat related injury.

3. Airborne Exposure to Chemical Hazards: Unless specified in a duty- 
specific supplement, individual exposure to chemical inhalation is 
considered similar to duties performed at home station. On base 
industrial activities include routine aircraft, equipment and 
installation maintenance. Generally, majority of the chemicals used on 
BDAB are oils, greases, lubricants, hydraulic fluids and fuel. Little 
to no corrosion control activities are performed and no solvent tanks 
exist on site. No industrial activity is performed that generates, or 
has been expected to generate, airborne exposures above permissible 
exposure levels or medical action levels.

4. Chemical Contact and Eye Protection: Unless specified in a job- 
specific supplement, individual exposure to chemical contact is 
considered similar to duties performed at home station. Workers are 
provided appropriate protective equipment (i.e. nitrile/rubber gloves, 
goggles, safety glasses and face shields) when and where needed.

5. Radiation: Ionizing radiation is emitted from medical/dental x-ray 
and OSI operations, and low-level radioactive materials present in 
equipment such as chemical agent monitors and alarms. No worker has 
been identified as exceeding 10% of the 5 REM/year OS HA permissible 
exposure level. Radio frequency (RF) radiation is emitted from multiple 
radar systems and communication equipment. Systems are marked with 
warning signs and communication workers receive appropriate training. 
Unless otherwise documented, no worker has been identified as exceeding 
RF-radiation permissible exposure limits. Significant UV radiation from 
the sun is expected on exposed unprotected skin. BDAB personnel have 
been advised to minimize sun exposure through the use of sunscreen and 
wear of sleeves down. Additionally, BDAB is a high light level 
environment. Many cases of photosensitivity dermatitis were observed. 
Some were no doubt exacerbated by the use of doxycycline for malaria 
prophylaxis. Unless otherwise stated in medical record, individual 
reported no radiation/light related injuries.

6. Ergonomics: Individual exposure to ergonomic stress from job related 
duty is substantially similar to duties performed at home station, with 
potential moderate increase in lifting involved with unique deployment 
requirements such as erection of tents and shelters. Unless otherwise 
stated in medical record, individual reported no ergonomic stress 
related injuries.

7. Bloodborne Pathogens: Individual exposure to bloodborne pathogens 
from job related duty is considered similar to duties performed at home 
station. Applicable workers are provided appropriate protective 
equipment and have been placed on the bloodborne pathogen program. 
Unless otherwise stated elsewhere in the medical record, individual 
reported no significant unprotected exposures.

//SIGNED//:

HOSPITAL OR MEDIAL FACILITY: 447 EMEDS, Baghdad Air Base Iraq:

RELATIONSHIP TO SPONSOR: Self:

PATIENT S IDENTIFICATION: (For typed or written entries, give: Name 
last, first, middle; ID No or SSN; Sex; Date of Birth; Rank/Grade.)

CHRONOLOGICAL RECORD OF MEDICAL CARE:

Medical Record:

STANDARD FORM 600 (REV. 6-97) Prescribed by GSAHCMR:

FIRMR (41 CFR) 201-9.202-1:

STANDARD FORM 600 (REV. 6-97) BACK: 

[End of section]

FOOTNOTES

[1] The Chairman of the Joint Chiefs of Staff is the principal military 
adviser to the President, the National Security Council, and the 
Secretary of Defense.

[2] The Navy supports OEHS activities for the Marine Corps.

[3] Harmful levels of environmental contaminants are determined by the 
concentration of the substance and the duration of exposure.

[4] Presidential Review Directive/National Science and Technology 
Council - 5 (April 21, 1997). The National Science and Technology 
Council is a cabinet-level council that helps coordinate federal 
science, space, and technology research and development for the 
president.

[5] National Defense Authorization Act for Fiscal Year 1998. Pub. L. 
No. 105-85, §768, 111 Stat. 1629, 1828 (1997) ("Sense of Congress").

[6] The working group makes recommendations for deployment OEHS policy 
to the Deputy Assistant Secretary of Defense for Force Health 
Protection and Readiness, who serves as the director of DHSD.

[7] Each military service has preventive medicine units, though they 
may be named differently. Throughout this report, we use the term 
preventive medicine unit to apply to the units fielded by all military 
services.

[8] While in the deployment location, preventive medicine units create 
and store reports both electronically and on paper.

[9] Some bases can have more than one baseline report. 

[10] DOD officials said the analysis of servicemembers' responses to a 
post-deployment health assessment questionnaire is another means to 
identify potential exposures that should be investigated. These 
assessments, designed to identify health issues or concerns that may 
require medical attention, use a questionnaire that is to be completed 
in theater and asks servicemembers if they believe they have been 
exposed to a hazardous agent. 

[11] Throughout the testimony we refer to both base camps and forward 
operating bases collectively as bases. A forward operating base is 
usually smaller than a base camp in troop strength and infrastructure 
and is normally constructed for short-duration occupation.

[12] The command surgeons of deployed preventive medicine units are 
either Joint Task Force command surgeons or military service component 
command surgeons. In OIF, there are two Joint Task Forces, each with a 
command surgeon. In addition, the Army, Navy, Air Force, and Marine 
Corps have their own subordinate component commands in a deployment, 
each with a command surgeon. 

[13] DOD has designated CHPPM as the entity responsible for archiving 
all OEHS reports from deployments. 

[14] DOD policy does not prescribe a time frame for how long preventive 
medicine units have to complete a report.

[15] CHPPM also receives some deployment OEHS data that have not been 
incorporated into a report, such as tables of water sampling 
measurements.

[16] The U.S. Central Command is the combatant command responsible for 
all OIF operations.

[17] Along with deployment OEHS reports, commanders also examine 
medical intelligence, operational data, and medical surveillance (such 
as reports of servicemembers seen by medical units for injury or 
illness) to identify occupational and environmental health hazards.

[18] Examples of health encounter data are medical records of in- 
patient and out-patient care, health assessments completed by 
servicemembers before and after a deployment, and blood serum samples. 

[19] OEHS standards generally set out technical requirements for 
monitoring, including the type of equipment needed and the appropriate 
frequency of monitoring.

[20] This standard was approved in October 2003.

[21] Incident-driven reports reflect OEHS investigation of unexpected 
incidents and would not be submitted to CHPPM's archive according to 
any identified pattern. Therefore, we did not comment on the services' 
submission of incident-driven reports.

[22] The U.S. Central Command has established and closed bases 
throughout the OIF deployment; therefore, the number of bases for each 
summary report varied. 

[23] A base may have had both baseline and routine reports submitted to 
the OEHS archive.

[24] DOD officials said that during a deployment, preventive medicine 
units share the military's classified communication system with all 
other deployed units and transmission of OEHS reports might be a lower 
priority than other mission communications traffic. Also, preventive 
medicine units might not deploy with communications equipment.

[25] OEHS risk management activities began to be employed during 
previous deployments, such as Operation Joint Guardian in Kosovo and 
Operation Enduring Freedom in Central Asia, but it was not formally 
adopted as a tool to assess deployment health hazards until 2002. See 
Office of the Chairman, The Joint Chiefs of Staff, Memorandum MCM-0006- 
02, "Updated Procedures for Deployment Health Surveillance and 
Readiness," Feb. 1, 2002.

[26] An Army operational risk management field manual describes the 
steps in determining risk level, including identifying the hazard, 
assessing the severity of the hazard, and determining the probability 
that the hazard will occur. DOD has also developed technical guides 
that detail toxicity thresholds and associated potential health effects 
from exposure to hazards.

[27] Risk assessments can designate identified occupational or 
environmental health risks as posing a low, moderate, high, or 
extremely high risk to servicemembers.

[28] Individuals desiring to review classified documents must have the 
appropriate level of security clearance and a need to access the 
information. VA officials have been able to access some OEHS data on a 
case-by-case basis.

[29] Pub. L. No. 108-375, §735, 118 Stat. 1811, 1999 (2004). 

[30] GAO, Defense Health Care: Medical Surveillance Improved Since Gulf 
War, but Mixed Results in Bosnia, GAO/NSIAD-97-136 (Washington D.C.: 
May 13, 1997).

[31] DOD policy requires the Defense Manpower Data Center to maintain a 
system that collects information on deployed forces, including daily- 
deployed strength, in total and by unit; grid coordinate locations for 
each unit (company size and larger); and inclusive dates of individual 
servicemembers' deployment. See DOD Instruction 6490.3, "Implementation 
and Application of Joint Medical Surveillance for Deployment," Aug. 7, 
1997. In addition, a 2002 DOD policy requires combatant commands to 
provide the Defense Manpower Data Center with rosters of all deployed 
personnel, their unit assignments, and the unit's geographic locations 
while deployed. See Office of the Chairman, The Joint Chiefs of Staff, 
Memorandum MCM-0006-02, "Updated Procedures for Deployment Health 
Surveillance and Readiness," February 1, 2002.

[32] The military services submitted location data for both OIF and 
Operation Enduring Freedom in Central Asia; Defense Manpower Data 
Center officials said they were unable to separate the data from the 
two operations. 

[33] DOD Instruction 6490.3, "Implementation and Application of Joint 
Medical Surveillance for Deployment," Aug. 7, 1997.

[34] GAO, Gulf War Illnesses: Federal Research Strategy Needs 
Reexamination, GAO/T-NSIAD-98-104 (Washington D.C.: Feb. 24, 1998).

[35] The Deployment Health Working Group includes representatives from 
DOD, VA, and HHS.

[36] This effort also includes identifying research for Operation 
Enduring Freedom.

[37] Epidemiologic studies generally have a fixed study population that 
does not vary over time, according to VA officials.