Report to Congressional Requesters

United States Government Accountability Office

GAO

April 2005 AGENT ORANGE

Limited Information Is 

Available on the 

Number of Civilians 

Exposed in Vietnam 

and Their Workers’ 

Compensation Claims 

GAO-05-371 
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

www.gao.gov/cgi-bin/getrpt?GAO-05-371.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact Robert E. 

Robertson at (202) 512-7215, 

robertsonr@gao.gov. 

Highlights of GAO-05-371, a report to 

congressional requesters 

April 2005

AGENT ORANGE

Limited Information Is Available on the 

Number of Civilians Exposed in Vietnam 

and Their Workers’ Compensation Claims 

While many federal agencies that were likely employers of civilian federal 

and contract workers during the Vietnam War had little information on these 

employees, a few provided us with limited information on federal employees 

and the amounts of contracts for companies that provided services to the 

military in Vietnam. We were unable to determine the reliability of the data 

provided. However, we used these data for the limited purpose of estimating 

that between 72,000 and 171,000 civilians may have worked for the U.S. 

government in Vietnam between 1964 and 1974. Our ability to provide more 

accurate information on the size of this workforce was limited because most 

agency records maintained during this period were not computerized, and 

because so much time has elapsed that many paper records have been 

destroyed and many agency personnel knowledgeable of the period are no 

longer working at these agencies. 

For the 32 Agent Orange-related claims identified (12 from federal civilians 

and 20 from contract employees), we found that these claimants faced many 

difficulties and delays because of a lack of readily available information on 

how to file a claim, their Vietnam era employers, and their exposure to Agent 

Orange, as well as processing delays caused by employers, insurance 

carriers, and Labor. Both Labor and private insurance carriers had difficulty 

identifying the number of claims they had received, largely because they do 

not assign a unique code to Agent Orange claims that would enable easy 

identification. Most of the claims we identified were filed in the past 10 

years, and most have been denied. Denials of the claims stemmed, in part, 

from the fact that under the laws governing these claims, claimants must 

demonstrate a causal link between their exposure to Agent Orange and their 

medical conditions, which is difficult to prove so many years later. 

If Congress chooses to address this issue, several legislative options could 

be considered to attempt to improve access to compensation for civilians 

who were exposed to Agent Orange and developed medical conditions as a 

result, although they could have significant cost and policy implications. 

Congress could amend current law authorizing benefits for veterans to cover 

certain civilians or set up a separate program to cover them. Another option 

is for Congress to amend the GI Bill Improvement Act of 1977, which allows 

DOD to retroactively grant military status and authorize full VA benefits to 

certain civilian groups that support the military during armed conflicts. 

However, it is difficult to assess the potential costs of these options because 

of the limited data available on the number of civilians and their claims for 

compensation. Despite the difficulty of assessing the potential costs, before 

any of these options are pursued, their fiscal impact and the precedentsetting implications for individuals involved in other wars and conflicts since 

the Vietnam era should be carefully considered. 

Concerns about difficulties civilian 

employees of the U.S. government 

may have in obtaining workers’ 

compensation benefits for medical 

conditions they developed as a 

result of their exposure to Agent 

Orange in Vietnam led to GAO 

being asked to determine (1) what 

is known about the number of 

civilians who served in Vietnam, 

both those employed directly by 

the U.S. government and those 

employed by companies that 

contracted with the government; 

(2) what is known about the 

number, processing, and 

disposition of claims filed by these 

civilians; and (3) what options are 

available if Congress chooses to 

improve access to benefits for 

civilians exposed to Agent Orange 

in Vietnam who developed illnesses 

as a result of their exposure, and 

what are their cost implications? 

What GAO Recommends

The Department of Labor (Labor) 

should enhance its processing and 

management of claims, including 

improving the information used to 

track claims, maintaining better 

information on the insurance 

carriers it licenses, and providing 

better information to claimants to 

use in filing claims. 

Labor generally agreed with our 

recommendations, while the 

Department of Veterans Affairs 

(VA) expressed serious concerns 

about the cost and policy 

implications of the options for 

improving civilians’ access to 

compensation. 
Page i GAO-05-371 Civilian Exposure to Agent Orange in Vietnam 

Letter 1

Results in Brief 2 

Background 5 

Because Information Is Limited, Our Estimate of the Number of 

Federal and Contract Employees in Vietnam during Wartime Is 

Imprecise 8 

For the Few Claims Identified, Claimants Faced Many Obstacles, 

and to Date, Most Claims Have Been Denied 11 

Legislative Options Could Ease Access to Benefits for Civilians 22 

Conclusions 27 

Recommendations for Executive Action 28 

Agency Comments 28 

Appendix I Technical Appendix 30 

Appendix II Comments from the Department of Labor 34 

Appendix III Comments from the Department of Veterans Affairs 36 

Appendix IV GAO Contacts and Staff Acknowledgments 41 

GAO Contacts 41 

Staff Acknowledgments 41 

Tables 

Table 1: Timeline Showing Difficulties One Claimant Experienced 

Locating His Former Employer’s Insurance Carrier 17 

Table 2: Criteria for Acceptance under DOD Directive 1000.20 25 

Table 3: Estimated Number of DOD Federal Employees in Vietnam, 

1964 to 1974 31 

Table 4: Estimated Number of DOD Contract Employees in 

Vietnam, 1966-1974 33 

Contents 
Page ii GAO-05-371 Civilian Exposure to Agent Orange in Vietnam 

Figures 

Figure 1: Conditions VA Recognizes as Related to Agent Orange 

Exposure 6 

Figure 2: Overview of the Workers’ Compensation Claims Process 

for Federal Employees 14 

Figure 3: Overview of the Workers’ Compensation Claims Process 

for Contract Employees 15 

Abbreviations 

CIA Central Intelligence Agency 

DBA Defense Base Act 

DOD Department of Defense 

FECA Federal Employees’ Compensation Act 

IOM Institute of Medicine 

OWCP Office of Workers’ Compensation Programs 

VA Department of Veterans Affairs 

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Page 1 GAO-05-371 Civilian Exposure to Agent Orange in Vietnam 

April 22, 2005 

The Honorable Bill Nelson 

United States Senate 

The Honorable Lane Evans 

House of Representatives 

The Honorable Mark Foley 

House of Representatives 

The Honorable Robert Wexler 

House of Representatives 

During the Vietnam War, U.S. civilians, along with military personnel, were 

in the country when Agent Orange, an herbicide containing dioxin, was 

used as a defoliant. Civilians—both federal and contract employees—

performed a variety of jobs in support of the military, including helicopter 

maintenance, road building, and cargo handling. After many years of 

controversy, in 1991 Congress passed the Agent Orange Act to provide 

military veterans who developed medical conditions related to dioxin 

exposure in Vietnam with easier access to compensation, such as 

payments for medical expenses. The act associates dioxin exposure with 

latent illnesses, including several forms of cancer. The act also includes 

several presumptions, including the presumed exposure to Agent Orange 

of any military service member who was in Vietnam and developed a 

dioxin-related disease. While civilians who worked for the U.S. 

government in Vietnam are not covered under the Agent Orange Act, 

workers’ compensation programs are available to restore lost wages and 

pay medical expenses of those who are disabled by an occupational 

illness. Federal employees file claims for workers’ compensation with 

their employing agency, which refers the claims to the Department of 

Labor (Labor) under the Federal Employees’ Compensation Act (FECA). 

Workers’ compensation coverage for employees who work under contract 

to the U. S. government outside the United States is provided under the 

Defense Base Act (DBA), which extends the Longshore and Harbor 

Workers’ Compensation Act. These individuals file claims through their 

employers with the employers’ insurance carriers. 

Concerned about difficulties civilian employees have had in obtaining 

workers’ compensation benefits for diseases that may be related to their 

United States Government Accountability Office

Washington, DC 20548 
Page 2 GAO-05-371 Civilian Exposure to Agent Orange in Vietnam 

exposure to Agent Orange in Vietnam, you asked us to determine (1) what 

is known about the number of civilians who served in Vietnam, both those 

employed directly by the U.S. government and those employed by 

companies that contracted with the government; (2) what is known about 

the number, processing, and disposition of claims filed by these civilians; 

and (3) what options are available to Congress if it chooses to improve 

access to workers’ compensation and benefits for civilians exposed to 

Agent Orange in Vietnam who developed illnesses as a result of their 

exposure, and what are their cost implications? 

To determine the number of civilian employees working in Vietnam during 

the war, we relied on interviews with and reports from the Departments of 

Defense (DOD), State, Agriculture, and Treasury as well as the Central 

Intelligence Agency (CIA), the Census Bureau, and the National Archives. 

To determine the number and disposition of workers’ compensation 

claims filed by federal employees, we reviewed the policies and 

procedures of Labor’s Office of Workers’ Compensation Programs 

(OWCP), interviewed agency officials and claims examiners, and reviewed 

claim files. For claims filed by contract employees, we contacted 

employers and the insurance carriers that provided a majority of the 

workers’ compensation coverage during the Vietnam War to obtain 

information on the number of claims filed and the disposition of these 

claims. We also interviewed Labor officials and examined files for claims 

filed by contract employees that were referred to Labor after being denied 

by the insurance carriers. To identify options for improving access to 

workers’ compensation and other benefits for civilian employees, we 

reviewed relevant laws and policies and discussed possible options and 

estimates of the potential costs with Labor and Department of Veterans 

Affairs (VA) officials. We conducted our work in accordance with 

generally accepted government auditing standards between June 2004 and 

March 2005. 

While many federal agencies that were likely employers of civilian federal 

and contract workers during the Vietnam War had little information on 

these employees, a few provided us with limited information on federal 

employees and the amounts of contracts for companies that provided 

services to the military in Vietnam. Although we were unable to determine 

the reliability of this information, we used it for the limited purpose of 

estimating the number of civilians that may have worked for the U.S. 

government in Vietnam during the war. Using these data, we estimated 

that between 72,000 and 171,000 civilians may have worked for the U.S. 

government in Vietnam between 1964 and 1974. Our ability to more 

Results in Brief 
Page 3 GAO-05-371 Civilian Exposure to Agent Orange in Vietnam 

accurately identify the size of this workforce was limited by the fact that at 

that time, most records were not computerized, and many of the paper 

records have either been destroyed or were not organized in a way that 

would facilitate the identification of such personnel. For many other 

agencies likely to have had federal civilian or contract workers in Vietnam, 

officials with knowledge of the period were no longer there because of 

retirements, reassignments, and other staff turnover. Nevertheless, using 

numbers provided by two agencies that were able to locate some 

records—the Department of State and DOD—we developed estimates of 

the number of federal and contract employees in five agencies who may 

have worked in Vietnam between 1964 and 1974. 

For the 32 civilian workers’ compensation claims for diseases associated 

with Agent Orange exposure identified, we found that claimants faced 

many obstacles and that to date, most of the claims have been denied. 

Neither Labor nor private insurance carriers could readily identify the 

number of claims they had received, largely because they did not have a 

unique code to identify Agent Orange claims, and because some claims 

were not accurately recorded in Labor’s database. By asking claims 

examiners to recall information about claims that may have been related 

to Agent Orange exposure and conducting searches of their databases, 

Labor and the insurance carriers identified 12 claims from federal civilians 

and 20 claims from contract employees, most of which were filed in the 

past 10 years. However, because we were unable to determine whether 

additional claims that were not identified exist, the information we 

obtained about these claims does not necessarily represent the nature or 

disposition of all Agent Orange claims. Our review of these claims showed 

that claimants faced a number of difficulties and delays because of a lack 

of readily available information on how to file a claim, their Vietnam era 

employers, and their exposure to Agent Orange, as well as processing 

delays caused by employers, insurance carriers, and Labor. Labor’s denial 

of 11 of the 12 claims filed by federal employees (1 claim was withdrawn 

by the claimant) stemmed, in all but 1 case, from the fact that the 

claimants were unable to establish a sufficient causal link between their 

employment-related injury (exposure) and their medical conditions, as 

required under FECA. This was the case even when the claimants 

established that they were exposed to Agent Orange in connection with 

their employment and suffered from a serious illness or disease. 

Establishing this causal link between exposure and an illness or disease is 

difficult in cases involving cancer and other illnesses that may have 

multiple causes and take many years to develop. Of the 20 claims filed by 

contract employees, 9 were initially denied by the insurance carriers and 

1 was approved for payment. The disposition of the other 10 claims is 
Page 4 GAO-05-371 Civilian Exposure to Agent Orange in Vietnam 

unknown, because although Labor officials initially told us they were not 

Agent Orange claims, with our assistance, they later discovered that they 

were Agent Orange claims, but it was too late for us to include them in our 

analysis. Of the 9 claims initially denied by the insurance carriers, the 

claimants have taken no further action on 4 of them, 3 of the claimants are 

awaiting hearings by an administrative law judge, and Labor upheld the 

insurance companies’ denial for 2 of the claims—1 because it was not filed 

timely and the other because the claimant did not sufficiently prove his 

exposure to Agent Orange. The claim that was approved by Labor for 

payment involved a self-insured contractor to the CIA that was no longer 

in business. Absent an employer or insurance carrier, the CIA—acting in 

the role of the employer and the insurance carrier—stated that it “had no 

objections” to paying the claim. Labor reviewed the claim and accepted it 

for payment. 

If Congress chooses to address this issue, several legislative options could 

be considered to attempt to improve access to workers’ compensation or 

other benefits for civilian employees exposed to Agent Orange in Vietnam 

who developed medical conditions as a result of their exposure. Congress 

could amend the Agent Orange Act and related legislation authorizing 

benefits for veterans to include civilians who worked in Vietnam or 

authorize a separate program to specifically cover these individuals. 

Another option is for Congress to amend the GI Bill Improvement Act of 

1977, which allows DOD retroactively to grant military status and 

authorize providing full VA benefits to certain civilian groups that support 

the military during armed conflicts. All of these options, however, have 

cost and policy implications, as illustrated by the payments VA makes for 

claims paid under the Agent Orange Act. Currently, for the four most 

common medical conditions covered under the act, VA pays, on average, 

$8,500 annually for disability compensation and $1,000 for medical costs 

for each claim. Any consideration of these options should include an 

assessment of their cost and policy implications, such as whether they 

would set a precedent that could prompt other federal and contract 

employees who have worked for the U. S. government in a war zone since 

the Vietnam era to seek similar benefits. Such a precedent could have 

significant cost implications because the U.S. military has employed a 

much larger number of contractor personnel in recent wars and conflicts 

than in Vietnam. 

We are making several recommendations intended to improve Labor’s 

processing and management of workers’ compensation claims from 

individuals related to diseases associated with exposure to Agent Orange 

in Vietnam, including improving the information used to track claims, 
Page 5 GAO-05-371 Civilian Exposure to Agent Orange in Vietnam 

maintaining better information on insurance carriers authorized by Labor 

to provide coverage to contract employees, and providing better 

information to claimants to use in filing their claims. In its written 

comments on a draft of this report, Labor generally agreed with our 

recommendations and provided details of actions it plans to take to 

improve its handling of claims. In its written comments, VA stated serious 

concerns about the policy and cost implications of the legislative options 

we included in the report for easing civilians’ access to workers’ 

compensation benefits. As noted in the report, we agree that the cost and 

policy implications of these options should be carefully considered. 

DOD provided only an informal technical comment on the report. Labor 

and VA also provided a few technical clarifications, which we 

incorporated as appropriate. 

Agent Orange is one of several herbicides sprayed by the U.S. government 

in Vietnam in the 1960s and 1970s as a defoliant. It contains 

tetrachlorodibenzo-para-dioxin (dioxin), a chemical that the 

Environmental Protection Agency and the Occupational Safety and Health 

Administration have classified as highly toxic and carcinogenic. DOD 

sprayed an estimated 11 million gallons of Agent Orange in Vietnam during 

the war. In the ensuing years, dioxin has been a focus of research and has 

been associated with a number of latent illnesses, including cancer and 

most recently diabetes, which have developed among people who have 

been exposed to the chemical. The use of Agent Orange has also spawned 

much litigation over the years, including suits against the manufacturers of 

the product and against the United States.1

Until 1991, when Congress passed the Agent Orange Act, military veterans 

who believed their illnesses were caused by dioxin exposure had limited 

success in obtaining medical benefits and other compensation. Previously, 

the VA had denied benefits to most veterans who claimed adverse health 

effects from the herbicide because poor records made it difficult for many 

of them to demonstrate where and when they had come into contact with 

the chemical, and because VA had not accepted proof of a direct link 

between certain illnesses and dioxin. The Agent Orange Act subsequently 

authorized awards on the presumption that any veteran who served in 

Vietnam and who develops certain diseases identified by the National 

 1

See, e.g., Hercules, Inc. v. U. S., 516 U.S. 417 (1996); In Re: “Agent Orange” Product 

Liability Litigation, 818 F. 2d 194 (2d Cir. 1987), and No. 04-CV-400, 2005 U.S. Dist. LEXIS, 

3644 (E.D.N.Y. Mar. 10, 2005); and Nehmer v. U. S. Veterans Admin., 712 F. Supp. 1404 

(N.D. CA 1989). 

Background 
Page 6 GAO-05-371 Civilian Exposure to Agent Orange in Vietnam 

Academy of Sciences’ Institute of Medicine (IOM) and accepted by VA had 

been exposed to Agent Orange. The act also gave VA responsibility for 

providing information to veterans about health conditions related to Agent 

Orange exposure and assistance in preparing their claims. 

Over time, the body of research on the health effects of dioxin exposure 

has grown, and in recent years, research organizations such as IOM have 

learned more about positive associations between exposure and certain 

medical conditions. Further, both the National Institutes of Health and the 

Environmental Protection Agency consider dioxin a carcinogen on the 

basis of studies showing associations between exposure and medical 

conditions such as lung cancer. Under the Agent Orange Act, IOM is 

required to review and analyze all medical research on dioxin exposure 

every 2 years and advise VA on the degree to which it believes Agent 

Orange is associated with certain health conditions. On the basis of this 

research, VA has accepted a number of medical conditions associated with 

Agent Orange exposure. Most of these conditions are types of cancers, 

such as non-Hodgkin’s lymphoma and soft-tissue sarcomas, or skin 

disorders, such as chloracne. More recently, prostate cancer and diabetes 

were added to the list after research showed a higher than expected rate 

of these conditions among those exposed to dioxin. (See fig. 1.) 

Figure 1: Conditions VA Recognizes as Related to Agent Orange Exposure 

• Chloracne—a skin disorder resembling teenage acne

• Porphyria cutanea tarda—a skin disorder characterized by thinning and blistering of the 

skin in sun-exposed areas

• Acute or subacute transient peripheral neuropathy—a nerve disorder

• Type 2 diabetes

• Cancers, including non-Hodgkin’s lymphoma, chronic lymphocytic leukemia, soft-tissue 

sarcoma, Hodgkin’s disease, multiple myeloma, prostate cancer, and respiratory 

cancers—including cancers of the lung, larynx, trachea, and bronchus

• Spina bifida and other birth defects among Vietnam veterans’ children 

Source: VA. 

Federal employees and employees who worked under contract to the U.S. 

government in Vietnam are not covered by the Agent Orange Act. Rather, 

federal employees who are injured or become ill as a result of their 

employment, including those who worked in Vietnam, may file a claim 

under FECA, a comprehensive workers’ compensation law for federal 

employees. To obtain benefits under FECA, claimants must show that 

(1) they were employed by the U.S. government, (2) they were injured 

(exposed) in the workplace, (3) they have filed a claim in a timely manner, 
Page 7 GAO-05-371 Civilian Exposure to Agent Orange in Vietnam 

(4) they have a disabling medical condition, and (5) there is a causal link 

between their medical condition and the injury or exposure. Unlike 

veterans, federal employees who file claims under FECA based on Agent 

Orange exposure must demonstrate that they were personally exposed to 

Agent Orange while in Vietnam and that their medical conditions were 

“proximately caused” by this exposure, (i.e., that there was a causal link 

between the exposure and their condition). Labor has primary 

responsibility for processing all FECA claims and has assigned the 

processing of special types of claims, such as those for Agent Orange 

exposure, to specific OWCP offices. Labor also processes all appeals from 

claimants regarding claims that were denied. Claimants have three levels 

of appeal: (1) reconsideration by an OWCP claims examiner, (2) a hearing 

or review of the written record by OWCP’s Branch of Hearings and 

Review, and (3) a review by the Employees’ Compensation Appeals Board. 

Either a request for reconsideration by a senior claims examiner not 

involved in the initial decision or a hearing request is generally the first 

level of appeal, followed by an appeal to the Employees’ Compensation 

Appeals Board. A decision of the Employees’ Compensation Appeals 

Board is final—claimants cannot appeal Labor’s decisions in federal court. 

However, if new evidence becomes available after the decision, the 

claimant can request the claim be reopened for reconsideration and 

further review by Employees’ Compensation Appeals Board. 

Workers’ compensation coverage for employees who work under contract 

to the U. S. government outside the United States is provided by the 

employing contractor under DBA.2

 Under DBA, individuals who can show 

that they were harmed and that working conditions could have caused this 

harm are entitled to a presumption that their claims are work-related and 

valid. Claimants must also establish that their claim was filed timely and 

show proof of employment, exposure to Agent Orange, a disabling medical 

condition, and that their condition arose naturally out of employment (i.e., 

that their condition was related to their employment in Vietnam).3

 Under 

DBA, Labor is required to license the insurance carriers that provide the 

 2

DBA extends the provisions of the Longshore and Harbor Workers’ Compensation Act to 

certain contractor employees. In this report, when we discuss claims filed under DBA, we 

are referring to claims filed under the Longshore and Harbor Workers’ Compensation Act 

as extended by DBA. 

3

For an occupational disease, the time for filing is 2 years from the date the claimant 

became or should have become aware of the relationship between the employment and the 

disease, or if later, 1 year from the date of the last compensation. 
Page 8 GAO-05-371 Civilian Exposure to Agent Orange in Vietnam 

employers’ workers’ compensation coverage.4 To prevent employers and 

insurance carriers from an undue financial burden for insuring employees 

during a time of armed conflict, Congress enacted the War Hazards 

Compensation Act, which allows insurance carriers to obtain 

reimbursement from Labor when a claim is paid for an injury or death 

caused by a “war-risk hazard.”5 Contract employees who are injured file 

workers’ compensation claims directly with their employers and their 

employers’ private insurance carriers. The insurance carrier may either 

accept or “controvert” (deny) the claim.6

 Claimants may request that 

OWCP review the insurance carrier’s decision and may ask for a hearing 

with one of Labor’s administrative law judges. The administrative law 

judge issues a decision and order awarding or denying benefits. Claimants 

may appeal an administrative law judge’s decision to Labor’s Benefits 

Review Board. Claimants may also obtain review of the Benefits Review 

Board’s decisions in federal court.7

Many of the agencies we contacted were unable to locate records on 

federal and contract workers employed in Vietnam, but on the basis of the 

limited data available, we estimated that at least 72,000 civilian employees 

and as many as 171,000 may have worked in Vietnam between 1964 and 

1974. We developed these estimates using data we obtained from the 

Department of State and DOD but were unable to determine the reliability 

of the data. 

 4

Labor can allow employers to self-insure. 

5

As defined in the act, these hazards include “the discharge of any missile (including liquids 

or gas) or the use of any weapon, explosive, or other noxious thing by a hostile force or 

person in combating an attack or imagined attack by a hostile force or person.” 42 U.S.C. § 

1711(b)(1). 

6

In this report, we refer to DBA claims that were “controverted” by the insurance carriers 

as claims that were denied by the insurance carriers. 

7

Employers and insurance carriers have the same rights of review and appeal as the 

claimants throughout this process. 

Because Information 

Is Limited, Our 

Estimate of the 

Number of Federal 

and Contract 

Employees in Vietnam 

during Wartime Is 

Imprecise 
Page 9 GAO-05-371 Civilian Exposure to Agent Orange in Vietnam 

Most of the federal agencies we identified as likely to have had employees 

in Vietnam—DOD, CIA, and the Departments of State, Agriculture, and 

Treasury—were unable to provide us with the exact number of civilian 

employees they had working in Vietnam during the war. Agency officials 

told us they had difficulty identifying these workers because personnel 

records were kept solely on paper, as computers were not in common use 

at that time. Agency officials told us that these paper records may have 

been destroyed or, if such records still exist, were not indexed or 

organized in searchable formats. In addition, the location of some records 

was unknown because of the loss of institutional knowledge resulting 

from staff turnover over the years. 

Both the State Department and DOD located some historical data that we 

used to develop estimates of the number of civilians who worked in 

Vietnam. Three of the five agencies we contacted—CIA and the 

Departments of Agriculture and Treasury—were unable to provide us with 

any data on the number of federal and contract employees they had 

working in Vietnam during the war. The Department of State was able to 

identify its federal employees who worked in Vietnam between January 

1964 through November 1965 and January 1967 through November 1974 

from published quarterly lists of employees, but the agency was unable to 

determine the number of employees working for the agency in Vietnam 

under contract. Although DOD officials were unable to locate data, we 

located historical reports of civilian personnel strength by year at DOD’s 

Directorate for Information, Operations, and Reports but were not able to 

obtain an unduplicated count of civilians who were in Vietnam between 

1964 and 1974. This office later located service contract amounts during 

the Vietnam War period published in historical reports, from which we 

were able to estimate the number of contract employees. 

Using data from the Department of State and DOD, we estimated that at 

least 72,000 and as many as 171,000 civilian employees may have worked 

in Vietnam during the war. From the quarterly lists of employees provided 

to us by the Department of State, we estimated that the agency had about 

6,000 employees in Vietnam between 1964 and 1974. 

To estimate the number of DOD federal employees, we used annual 

civilian personnel strength data from historical DOD reports and assumed 

a 2-year rotation similar to that of military personnel to develop an 

unduplicated count of about 4,600 employees. We obtained the personnel 

strength data from published DOD reports but were unable to determine 

Many Agencies Were 

Unable to Locate Records 

on Civilians Employed in 

Vietnam, but a Few 

Provided Some Estimates 

Using Limited Data, We 

Estimated That There May 

Have Been as Many as 

171,000 Civilians Working 

in Vietnam during the War 
Page 10 GAO-05-371 Civilian Exposure to Agent Orange in Vietnam 

how the data were collected; therefore, we were unable to determine the 

reliability of these data. 

To estimate the number of DOD contract employees, we obtained from 

DOD the dollar amount of DOD service contracts, by year from 1966 to 

1974, where the workplace was Vietnam, and divided these annual 

amounts by a range of “burdened labor rate” estimates to calculate the 

number of employees represented by these contracts each year.8

 However, 

DOD was unable to provide us with information on the range of salaries 

paid to contract employees in Vietnam. Therefore, for our analysis, we 

assumed annual salaries of $7,500, $15,000 and $25,000—-which represent 

a range of low, middle, and high salaries of federal employees during that 

time—to obtain burdened labor rates of $15,000, $30,000 and $50,000 per 

person. As with the annual estimates of federal DOD employees, we 

assumed a 2-year rotation to obtain an unduplicated count, which ranged 

from about 43,000 to 142,000 contract workers. 

To determine the number of federal and contract employees from the CIA 

and the Departments of Agriculture and Treasury, we used numbers from 

the Department of State as a proxy, assuming that these agencies all had 

roughly the same number of employees in Vietnam and would not have 

had as many employees in Vietnam as the much larger number of DOD 

contract employees needed to support military operations. On the basis of 

these assumptions, we estimated that these four agencies may have had 

about 24,000 employees in Vietnam during the war. See appendix I for 

additional information on the methods we used to develop these 

estimates. 

 8

The “burdened labor rate” estimates include salary, subsistence, company overhead, 

profit, insurance, travel, and other costs that would have been included in the total contract 

amount. DOD advised us that doubling an employee’s annual salary would approximate 

this burdened labor cost. 
Page 11 GAO-05-371 Civilian Exposure to Agent Orange in Vietnam 

Although Labor’s claims examiners and the insurance carriers we 

interviewed had difficulty identifying claims, our review of the claims 

identified showed that civilians faced difficulty in pursuing them because 

of difficulty obtaining information about the claims process, their former 

employers, and their employers’ insurance carriers, and because of 

processing delays. Labor denied 11 of the 12 claims filed by federal 

employees (1 was withdrawn), primarily because the claimants were not 

able to prove a direct relationship between exposure to Agent Orange and 

their medical conditions, as required by FECA. Of the 20 claims filed by 

contract employees, 9 were initially denied by the insurance carriers and 

1 was approved for payment. We were unable to review the case files for 

the remaining 10 cases to determine whether or not they were paid 

because they were identified too late in our review to include them. 

Labor and the insurance carriers we contacted had difficulty identifying 

Agent Orange claims using their databases but were able to identify 

12 claims from federal employees and 20 claims from contract employees. 

However, because we were unable to determine whether additional claims 

that were not identified exist, the information we obtained about these 

claims does not necessarily represent the nature of all Agent Orange 

claims or their disposition. Most of the claims they identified were filed in 

the past 10 years. 

Because Labor does not assign a unique code to identify Agent Orange 

claims in its database, the agency was unable to locate any of the claims 

filed by federal employees under FECA by querying its database. Although 

Labor has a code for injuries caused by exposure to chemicals and toxins, 

this code is used for many claims involving toxins other than dioxin and 

therefore was not useful in identifying Agent Orange claims. In addition, 

this code was not used for several of the Agent Orange claims identified. 

Unable to locate claims using Labor’s database, we asked the claims 

examiners in OWCP assigned to review Agent Orange claims from federal 

employees if they could recollect how many of these claims they had 

processed. They identified 12 claims using information from e-mails, 

personal notes, and personal recollections of information about the 

claims.9

 However, we were unable to confirm that they had identified all 

 9

The claims examiners also identified 3 claims from federal employees who were exposed 

to Agent Orange while working at an Army depot in the United States that serviced 

helicopters that had sprayed Agent Orange in Vietnam. However, because these claimants 

were not exposed to Agent Orange in Vietnam, we did not include their claims in our 

analysis. 

For the Few Claims 

Identified, Claimants 

Faced Many 

Obstacles, and to 

Date, Most Claims 

Have Been Denied 

Labor and the Insurance 

Carriers Could Not Readily 

Identify Agent Orange 

Claims through Their 

Databases 

Claims from Federal 

Employees 
Page 12 GAO-05-371 Civilian Exposure to Agent Orange in Vietnam 

Agent Orange claims from federal employees. Of the 12 claims identified, 

most were filed in the past 10 years, although 2 were filed in 1988 and 1 in 

1991. 

In addition, inaccurately coded claims and inconsistent coding procedures 

prevented identification of Agent Orange claims. For example, for 9 of the 

12 claims identified by the claims examiners, the “cause of injury” code 

recorded in Labor’s database was “99—cause unknown,” a catch-all code 

used to identify the type of injury when the cause of injury reported by the 

claimant on the claim form is not clear.10 Other fields in the database, such 

as the type of medical condition, were not useful in identifying Agent 

Orange claims because such exposure could cause more than one type of 

condition, and because most of the medical conditions associated with 

Agent Orange exposure could also have other causes. One clerk who 

codes the claims told us she was sometimes uncertain which codes should 

be used for Agent Orange claims and that she received limited guidance on 

how to code them. For example, two of the claims files showed that Labor 

coded the same condition, diabetes, with two different nature of injury 

codes, “cardiovascular disease—other” for one, and “blood disorder” for 

the second claim. In addition, the agency has no procedures for checking 

for data entry errors, and our review of Agent Orange claims identified 

errors. For example, one claim coded as “exposure to chemicals and 

toxins” was actually a heart condition. One Agent Orange claim for breast 

cancer was coded “sprain/strain of ligament, muscle, tendon, not back.” 

Claims examiners told us that although they can request that the clerks 

who entered the codes go back and correct coding errors, there is little 

incentive for them to request that errors be corrected because it does not 

affect their ability to process claims. 

Labor and representatives from insurance carriers had difficulty 

identifying Agent Orange claims filed by contract employees under DBA 

largely because they did not have a unique code to identify these claims. 

However, with our assistance, Labor was able to identify 20 claims. Ten of 

the claims were initially identified by Labor using its database and 

recollections of claims by Labor officials. Labor located 5 claims by—upon 

our request—querying its database for claims where the date of injury was 

during the Vietnam War (January 1, 1964, through December 31, 1975) and 

the nature of the injury was an occupational disease, and then reviewing 

 10Clerks enter information on each claim in Labor’s database when the claims are first 

received. 

Claims from Contract 

Employees 
Page 13 GAO-05-371 Civilian Exposure to Agent Orange in Vietnam 

the list of claims produced to identify claims they remembered as being 

related to Agent Orange. In addition, Labor officials remembered the 

names of 3 claimants that were not identified in their query of the 

database. The insurance carriers we interviewed identified 2 additional 

Agent Orange claims. Labor located 1 of these claims but was not able to 

find the other claim because, according to Labor officials, it was not sent 

to the agency by the insurance carrier, as required.11 All but 1 of these 

10 claims was filed in the past 10 years. 

In addition, we assisted Labor in identifying 10 more claims from contract 

employees. Although 7 of these claims appeared on the printout from their 

initial database query, Labor officials initially told us they were not Agent 

Orange claims. In addition, because the employer noted on the printout for 

some of these claims was the same as the employer for 1 of the Agent 

Orange claims we reviewed, we asked Labor to go back and review the 

other claims to make sure that they were not Agent Orange claims. From 

this second review, Labor identified 3 additional claims. However, because 

they were identified so late in our review, we were not able to include 

these 10 claims in our analysis of the disposition of the claims. 

Both federal and contract employees faced difficulties pursuing claims for 

Agent Orange exposure because they lacked key information on the filing 

process, had difficulty identifying responsible parties and obtaining 

needed documentation, and experienced processing errors and delays. 

Our review of the files showed that several claimants had little information 

about the claims process because their first point of contact, their former 

employer, was difficult to locate. 

Although claims processing for both federal and contract employees 

begins with their former employer, the process differs thereafter. As 

shown in figure 2, federal employees obtain the appropriate forms and 

documentation from their former employers and file claims with those 

agencies or departments, which then forward the claims to Labor for a 

decision. As shown in figure 3, contract employees also obtain the 

appropriate forms and documentation from their former employers but file 

their claims with their employer’s insurance carriers. 

 11One carrier recalled 4 additional claims but, citing privacy concerns, would not provide 

identifying information that would allow us to ask Labor to locate the claims files. 

Therefore, we were unable to include these claims in our analysis or determine whether 

they were already included in the claims identified by Labor. 

Civilians Faced Difficulty 

in Pursuing Claims, in Part, 

because of Difficulty 

Obtaining Information 

about the Claims Process 

and Poor Records 
Page 14 GAO-05-371 Civilian Exposure to Agent Orange in Vietnam 

Figure 2: Overview of the Workers’ Compensation Claims Process for Federal Employees 

Claimant exposed to Agent Orange

in Vietnam

 Claimant develops disabling

medical condition 

Claimant files notice of occupational 

disease with employer

Employer verifies 

claim information

Employer sends

 claim to Labor

OWCP reviews claim

OWCP decides case

Request for 

additional 

information 

from claimant 

and employer

OWCP 

accepts claim

 OWCP 

denies claim

Reconsideration by 

claims examiner

Oral hearing or review of 

written record by Branch

of Hearings and Review Appeal to Employees' 

Compensation

Appeals Board

Claimant employed by 

U.S. government in Vietnam

OWCP notifies 

claimant of 

appeal process

Claimant appeals decision Claimant accepts decision

Source: GAO analysis.

Claimant realizes association between

exposure and medical condition
Page 15 GAO-05-371 Civilian Exposure to Agent Orange in Vietnam 

Figure 3: Overview of the Workers’ Compensation Claims Process for Contract Employees 

Claimant exposed to Agent Orange in Vietnam

 Claimant develops disabling medical condition 

Claimant files notice of occupational 

disease with employer

Employer verifies claim 

information

Employer files 

notice of injury 

with OWCP

Carrier reviews claim

Request for 

additional 

information 

from claimant 

and employer

 Carrier 

denies claim

Employer 

sends claim 

to carrier

 OWCP notifies claimant

Claimant employed by contractor in Vietnam

Carrier 

accepts claim

Claimant may contest denial 

and request informal conference with OWCP

Source: GAO analysis.

Claimant makes association between

exposure and medical condition

Claimant may disagree with OWCP’s 

recommendations and request formal hearing with 

administrative law judge

Carrier notifies OWCP

Claimant may appeal administrative law judge’s

decision to the Benefits Review Board

Claimant may appeal Benefits Review Board 

decision to federal court

Administrative law judge holds formal hearing 

and issues a decision and order
Page 16 GAO-05-371 Civilian Exposure to Agent Orange in Vietnam 

Our review of the claims files showed that federal and contract employees 

sometimes filed their claims incorrectly because they were unable to 

locate their former employers in order to obtain information about the 

filing process. Although the first source of information in filing workers’ 

compensation claims is the employer, since the Vietnam War, some 

employers have reorganized or are no longer in business. Of the claims we 

reviewed, 6 claimants had difficulty locating their former employer. Even 

federal employees can have difficulties locating their employer because of 

the many government reorganizations over the 30 years since the end of 

the Vietnam War. For example, one claimant who worked for DOD in 

Vietnam had difficulty determining which office to send his claim to 

because the workers’ compensation office of his former employer, the U.S. 

Army Audit Agency, had been renamed and relocated. He initially filed his 

claim with his current DOD employer, the Defense Finance and 

Accounting Service, which advised him to send the claim to the 

Department of the Army’s Personnel and Employee Services, the office 

that now handles claims for former employees of the U.S. Army Audit 

Agency. 

Our review of the claims files also showed that contract employees and 

Labor had difficulty locating the responsible insurance carriers because of 

industry mergers, changes in carriers over time, and lack of easily 

accessible records. Some employers changed insurance carriers over time, 

so their current carrier was not the one that had provided coverage during 

the Vietnam War. Although Labor licensed the insurance carriers that 

provided coverage for contract employees during the war, the agency does 

not track information about the carriers in a format that is easily 

researchable. Labor officials told us that they keep the information on the 

licensed insurance carriers on handwritten 3 x 5 cards that are filed by 

employer name in filing cabinets. Searching for a carrier is a timeconsuming effort because there are hundreds of cards for multiple policies 

covering various periods of time. In addition, Labor does not track 

historical changes in the ownership of the insurance carriers over time, 

and companies may have been acquired by other companies—a common 

practice in the insurance industry, according to Labor officials. For 

example, an insurance company that provided coverage for contract 

employees for 3 of the claims we reviewed was purchased by another 

company, which could not locate claims for these individuals from the old 

company’s records. Labor had no information about the company being 

purchased by another company and had difficulty locating the insurance 

carrier liable for payment. 
Page 17 GAO-05-371 Civilian Exposure to Agent Orange in Vietnam 

Difficulties identifying insurance carriers can add up to extensive delays 

for claimants. Of the 10 claims we reviewed from contract employees, 

4 claimants had difficulty locating their insurance carrier. For example, 

one contract employee’s claim was delayed 13 months before the correct 

carrier was identified. Initially, the claimant mistakenly sent his claim 

directly to Labor instead of his employer and the employer’s insurance 

carrier. Once notified by Labor of the claim, the employer requested 

Labor’s assistance in locating the carrier. One of OWCP’s district offices 

searched its paper records (the 3 x 5 cards it retains on the carriers it 

licenses) and identified the correct carrier. At the same time, however, the 

employer asserted that another carrier was the responsible party. The 

claim was filed with this carrier, who later denied the claim, asserting that 

it was not the employer’s carrier during the period when the claimant 

worked for the employer. During the months that this carrier was deciding 

the claim, another of OWCP’s district offices, apparently unaware of the 

other district office’s efforts, identified yet a different carrier as the 

responsible party. When presented with the claim, this carrier also denied 

it because the carrier had not been the employer’s carrier during that time. 

Over a year since the claim was first filed, the employer correctly 

identified the correct carrier. The claim was filed with the correct carrier 

and was ultimately denied (see table 1). 

Table 1: Timeline Showing Difficulties One Claimant Experienced Locating His Former Employer’s Insurance Carrier 

Date Activity 

January 1996 Claimant filed claim with OWCP’s New York district office, and his former employer requested Labor’s 

assistance in locating the insurance carrier. 

February 1996 OWCP’s Seattle district office identified an insurance carrier (#1) as the responsible party. At the same time, the 

claimant’s former employer asserted that another insurance carrier (#2) was the responsible party and sent the 

claim to them. 

March 1996 OWCP’s New York district office identified another insurance carrier (#3) as the responsible party and notified 

the insurance carrier of the claim. 

April 1996 Insurance carrier #3 denied the claim, stating that although it provided coverage for this employer, it was not the 

responsible party during the period when the claimant’s alleged exposure occurred. 

May 1996 Insurance carrier #2 also denied the claim, stating that it had not provided coverage during the period when the 

claimant’s alleged exposure occurred. 

January 1997 Claimant’s former employer identified the correct insurance carrier (#1) and sent the claim to it. 

February 1997 The correct insurance carrier (#1) denied the claim. 

Source: GAO analysis. 

Employer and insurance carrier processing errors and difficulty locating 

records further delayed employees’ claims. For the claims we reviewed, 

several employers had difficulty verifying the claimant’s employment 
Page 18 GAO-05-371 Civilian Exposure to Agent Orange in Vietnam 

because they were unable to locate personnel records for employees who 

had worked in Vietnam. For example, one employer denied that the 

claimant had been one of its employees, although the claimant provided 

copies of pay stubs, employee identification documents, and several 

letters of recommendation from the company. Eventually, Labor 

interceded on behalf of the employee and insisted that the employer 

recognize the claimant as an employee. Insurance carriers also had 

difficulty determining if they had provided coverage to employers and 

claimants because of difficulties locating old records. Even federal 

employees can experience difficulty finding their employers and locating 

records. For example, one federal employee’s claim was delayed over 

2 years while the Department of Agriculture determined that he was an 

employee during the Vietnam War but was on detail to the Department of 

State. In its reply to Labor regarding the delay, the Department of 

Agriculture noted that it no longer had records for the period in question. 

Another federal employee, who was unable to obtain relevant medical 

records from his employer or the National Personnel Records Center, 

eventually withdrew his claim stating “at this time, I am under Hospice 

care and have not the energy to fight you anymore.” 

Once claims were submitted to Labor, both federal and contract 

employees faced additional delays because of processing errors at Labor, 

including claims being sent to the wrong office and information on the 

claims forms being typed incorrectly. For example, for one claim from a 

federal employee, Labor incorrectly processed the claimant’s request for 

reexamination of the written record by Labor’s Branch of Hearings and 

Review (typically, a claimant’s second level of appeal), instead sending it 

to the Employees’ Compensation Appeals Board (a claimant’s final level of 

appeal). This error created confusion and delayed processing of the claim 

for 11 months while the error was identified and the claim sent to the 

correct location. For the same claim, Labor continued to send notices to 

the claimant’s former federal employer at the wrong address for over a 

year, even though the post office returned these letters stamped 

“undeliverable” and the employer notified Labor of the correct address. 

Of the 12 claims filed by federal employees for medical conditions related 

to Agent Orange exposure, Labor denied 11 of them for failure to meet at 

least one of FECA’s five requirements, and 1 claim was withdrawn by the 

claimant. Of the 11 claims that were denied, Labor denied 10 of them 

because the claimant failed to prove a causal link between his medical 

condition and exposure to Agent Orange, and 1 claim was denied because 

it was not filed within the time limits prescribed by FECA. 

Claims Filed under FECA 

Require Proof of a Causal 

Link, and to Date, Labor 

Has Denied All but One 

Claim 
Page 19 GAO-05-371 Civilian Exposure to Agent Orange in Vietnam 

Furthermore, 5 of the claims denied by Labor were appealed by the 

claimants. Of those that were appealed, Labor upheld the denial of 

4 claims, and a decision is still pending on 1 claim. All of the claims that 

were appealed were initially denied because of the claimants’ failure to 

prove a causal link between exposure and their medical conditions. Three 

of the 5 claimants requested reconsideration of their claims by a claims 

examiner. Labor upheld its initial denial after reconsidering 2 of these 

claims, and to date, neither claimant has sought a hearing by OWCP’s 

Branch of Hearings and Review or a review by the Employees’ 

Compensation Appeals Board. The third claim for which a reconsideration 

was requested is still pending. Of the 2 remaining claims that were 

appealed, one of the claimants requested an oral hearing; the denial was 

upheld. The other claimant sought redress through both a written review 

by the Branch of Hearings and Review and an appeal to the Employees’ 

Compensation Appeals Board. The board upheld Labor’s decision. 

Almost all of these claims from federal employees—10 of the 11 claims—

were denied because the claimants failed to prove a causal link between 

their medical conditions and exposure to dioxin. Under FECA, to prove 

causation, claimants must provide “medical evidence establishing that the 

employment factors identified by the claimant were the proximate cause 

of the condition for which compensation is claimed, or, stated differently, 

medical evidence establishing that ... the diagnosed condition is causally 

related to the employment factors identified by the claimant.” To 

determine whether a claimant has shown proximate cause, Labor’s claims 

examiners and hearings representatives told us that they examine the 

medical research and the “rationalized medical opinions” provided by the 

claimants’ doctors to demonstrate an explicit cause and effect relationship 

between the medical conditions and alleged exposure. Claims examiners 

and hearing representatives told us that the claimants’ doctors may use 

medical literature to support these rationalized opinions, but the doctors 

must apply this research to the claimants’ specific circumstances. 

Claimants, however, have faced three challenges to proving a causal link 

between their medical conditions and their exposure to dioxin. First, some 

of the claimants’ doctors are not familiar with the link between dioxin 

exposure and the development of some illnesses. In one case file we 

reviewed, one of the claimant’s doctors stated: “I have very little training in 

epidemiology and cannot tell you much about the coincidence of Agent 

Orange exposure with the development of prostate cancer,” and another 

said he was “certainly unable to provide any kind of expert opinion” on the 

relationship between Agent Orange and the development of prostate 

cancer. 
Page 20 GAO-05-371 Civilian Exposure to Agent Orange in Vietnam 

Second, according to Labor, some of the claimants’ doctors relied on 

general medical research to support their opinions without applying the 

research to the individual claimant. For example, in one case, the 

claimant’s doctor stated that he had reviewed the research on Agent 

Orange, relying primarily on the IOM biennial report that showed an 

association between prostate cancer and exposure to dioxin to support his 

opinion that the claimant’s prostate cancer was related to his exposure to 

Agent Orange. Labor denied the claim because the doctor failed to give his 

opinion but rather inferred a connection by presenting an excerpt from an 

article published by the National Academies Press.12 The decision letter 

also stated that Labor has long established that causality cannot be 

inferred and publications are of no evidentiary value, as they are not case 

specific. 

The third challenge the claimants faced is ruling out other factors that 

could have caused their medical conditions. For long-latency illnesses, 

such as the cancers associated with dioxin exposure, it is difficult for the 

claimants’ doctors to definitively rule out other factors that could have 

caused the medical condition during the intervening years between Agent 

Orange exposure and the development of the medical condition. For 

example, in one case that was denied by Labor, five different doctors—

including one doctor to whom the claimant was referred by Labor—

asserted an association between the claimant’s medical condition and his 

exposure to Agent Orange. The doctor to whom the claimant was referred 

by Labor stated that “it is reasonable to assume that his exposure to Agent 

Orange and to other herbicides are the causative agent for his transitional 

cell carcinoma [i.e., bladder cancer].” Another doctor provided his opinion 

that the claimant’s bladder cancer was a consequence of his exposure to 

dioxin and other environmental toxins during his tenure in Vietnam. A 

third doctor stated in his written opinion that “chemical exposures in the 

course and scope of his duties as a federal employee are the cause of his 

bladder cancer.” However, the claim was denied because Labor 

determined that the claimant failed to submit medical evidence that 

attributed his bladder cancer to his exposure to herbicides in Vietnam. The 

decision letter stated that although one of the doctors provided a medical 

opinion stating a cause and effect relationship between the claimant’s 

medical conditions and his federal employment, the doctor “cannot state 

 12The National Academies Press publishes the IOM’s biennial report on dioxin exposure. 

This is the report VA uses to establish the diseases it will recognize as associated with 

Agent Orange exposure under the Agent Orange Act. 
Page 21 GAO-05-371 Civilian Exposure to Agent Orange in Vietnam 

with certainty that non-work related factors have no connection to the 

claimed conditions. Specifically, he admits that cigarette smoking and 

exposure to asbestos are also bladder carcinogens. Therefore, his opinion 

is considered speculative and equivocal in nature, and has little probative 

value.” The claimant requested four different reconsiderations by OWCP’s 

claims examiners, and after his death, his widow requested a fifth 

reconsideration; Labor’s decision was upheld each time. 

Although Labor and the insurance carriers identified a total of 20 claims 

from contractor employees, we were not able to include 10 of them in our 

analysis of the disposition of the claims because Labor identified them too 

late for us to include them. For the 10 claims we reviewed, 1 was accepted 

and 9 were initially denied by the insurance carriers. Of the 9 claims 

denied, 5 of the claimants asked Labor to review the insurance carriers’ 

decisions, and 4 claimants took no further action on the claims. Of the 

5 claims that the claimants asked Labor to review, 3 claimants are waiting 

for a hearing by one of Labor’s administrative law judges. For the other 

2 claims, Labor upheld the insurance carriers’ decisions—1 because the 

claim was not filed within the 2-year time period allowed under the law 

and the other because the claimant had not sufficiently proved that he had 

been exposed to Agent Orange in Vietnam. 

For the one claim accepted for payment, the claimant asked Labor to 

intervene because his employer, a self-insured contractor for the CIA, was 

no longer in business. Absent an employer or insurance carrier, the CIA—

acting in the role of the employer and the insurance carrier—stated that it 

“had no objections” to paying the claim. In accepting the claim, Labor 

referenced VA’s policy regarding Agent Orange claims and an 

Environmental Protection Agency report on the health effects of dioxin 

exposure to justify its approval of compensation. Noting VA’s presumption 

that any veteran who served in Vietnam and developed certain medical 

conditions associated with Agent Orange had been exposed, the claims 

examiner stated that it would be difficult for Labor to take a contrary 

position. This claim was also accepted for reimbursement under the War 

Hazards Compensation Act. Under the act, an insurer who pays a claim for 

an injury from a war risk may be reimbursed for the costs it bears in 

connection with the claim. However, according to Labor officials, some 

insurance carriers may not be aware that they can obtain reimbursement 

under the War Hazards Compensation Act. 

Labor Identified Few 

Claims from Contract 

Employees, but Insurance 

Carriers Initially Denied 

Most of the Claims 

Identified 
Page 22 GAO-05-371 Civilian Exposure to Agent Orange in Vietnam 

If Congress chooses to address this issue, several legislative options could 

provide more similar consideration of civilian claims as compared with the 

claims of their veteran counterparts and improve civilian access to 

workers’ compensation or other benefits. However, these options have 

cost implications, although the lack of data on the number of civilians in 

Vietnam and the difficulty potential claimants have in locating the 

information needed to file claims make it difficult to accurately assess 

their potential costs. In addition, these options should be carefully 

considered in the context of the current federal fiscal environment, as well 

as the significant policy and cost implications any changes could have for 

civilian employees involved in wars and conflicts since the Vietnam era. 

Congress could amend the Agent Orange Act and related legislation that 

authorizes benefits for veterans to include civilians. However, including 

civilians under these laws may raise concerns for those who feel that 

civilians should not be entitled to the same benefits as military veterans. 

Alternatively, Congress could create a separate program to cover claims 

for medical conditions that civilians develop as a result of their exposure 

to Agent Orange. In addition to the Agent Orange Act for veterans, 

Congress has established programs for some special populations exposed 

to toxic substances in the workplace that develop into serious medical 

conditions after long latency periods. For example, Congress passed the 

Radiation Exposure Compensation Act in 199013 to provide payments to 

individuals who contracted certain cancers and other serious diseases as a 

result of their exposure to radiation released during nuclear weapons tests 

or as a result of their employment in the uranium mining industry. More 

recently, Congress passed the Energy Employees Occupational Illness 

Compensation Program Act of 2000, as amended,14 which provides 

payments to contract employees working in Department of Energy 

facilities who were exposed to radioactive and hazardous materials and 

subsequently developed illnesses such as cancer and lung disease. 

 1342 U.S.C. § 2210, note. 

1442 U.S.C. § 7384-85. 

Legislative Options 

Could Ease Access to 

Benefits for Civilians 

Congress Could Amend the 

Agent Orange Act to 

Include Civilians or Set Up 

a Separate Program for 

Civilians Exposed to Agent 

Orange in Vietnam 
Page 23 GAO-05-371 Civilian Exposure to Agent Orange in Vietnam 

Some key components of these special programs are 

• Providing restitution: The Radiation Exposure Compensation Act was 

enacted to establish a procedure for making partial restitution to 

individuals who became ill because of radiation exposure from 

aboveground nuclear tests or uranium mining. Restitution payments 

range from $50,000 for testing victims to $100,000 for uranium miners. 

The Energy Employees Occupational Illness Compensation Program 

Act also makes payments to eligible claimants and provides medical 

coverage for specific illnesses. 

• Creating eligibility criteria based on a less stringent standard of proof 

for the causal link between exposure and medical conditions: Because 

of the inherent difficulties of proving a link between exposure to 

radiation or toxic substances and occupational diseases that occur 

after long latency periods, other compensation programs rely on a less 

stringent burden of proof than FECA or DBA. For example, the Energy 

Employees Occupational Illness Compensation Program Act allows 

payments if employment at an energy facility was “as least as likely as 

not” to have caused, contributed to, or aggravated the claimed medical 

condition. 

• Using ongoing research on conditions associated with exposure to 

determine eligibility: On the basis of recent research findings, the 

Radiation Exposure Compensation Act Amendments of 2000 expanded 

the list of diseases that may qualify individuals for compensation and 

decreased the level of radiation exposure that is necessary to qualify 

for compensation. Under the Agent Orange Act, VA uses IOM’s biennial 

review of research on dioxin exposure and recommendations to add to 

its list of accepted medical conditions related to Agent Orange 

exposure. 

• Assisting claimants in processing their claims: The Energy Employees 

Occupational Illness Compensation Program Act, as amended, created 

an ombudsman position to provide information to claimants. According 

to the Director of Labor’s Energy Employees Occupational Illness 

Compensation Division, the agency provides information and 

assistance to claimants in a variety of ways, including resource centers 

located throughout the country that assist claimants in completing 

claim forms and obtaining the documentation needed to support their 

claims. He also stated that Labor has provided pamphlets, public 

service announcements, and direct mailings to potential claimants that 

explain the program, benefits available, procedures for filing claims, 

and where they can obtain assistance. The Radiation Exposure 
Page 24 GAO-05-371 Civilian Exposure to Agent Orange in Vietnam 

Compensation Act also provides for outreach and information to 

potential claimants. The Department of Justice administers this 

program and has established an Internet Web site, conducts on-site 

visits to groups and organizations to promote the program, and 

operates a toll-free telephone line for program queries. 

Congress could amend the GI Bill Improvement Act of 1977,15 which allows 

DOD to retroactively grant military status and authorize full VA benefits to 

certain civilian groups that support the military during armed conflicts. 

Women who served in the Women’s Air Forces Service Pilots during World 

War II are the model for the statute, because they comprised a quasimilitary group that rendered service to the United States during wartime, 

but at the time, were excluded from joining the armed forces because of 

their gender. In 1977, Congress specifically recognized the service of that 

group as active military duty and directed DOD to issue regulations under 

which similarly situated groups could be recognized. In 1987, a federal 

court determined that DOD had failed to clarify the factors and criteria 

used in implementing this statute. As a result, DOD clarified the rules for 

accepting groups and issued DOD Directive 1000.20. Under this directive, a 

group must submit an application showing that it meets the criteria, 

including the criterion that it provided service to the U. S. government 

during a period of armed conflict, was subject to military control, and was 

integrated into the military organization (see table 2). Groups do not, 

however, have to meet all of the criteria in order to be accepted, but it 

remains unclear how many of the criteria must be met for a group to be 

accepted. 

 1538 U.S.C. § 106, note. 

Congress Could Amend an 

Existing Statute to Grant 

Military Status to Certain 

Civilians 
Page 25 GAO-05-371 Civilian Exposure to Agent Orange in Vietnam 

Table 2: Criteria for Acceptance under DOD Directive 1000.20 

Criteria for application Criteria for acceptance 

1. Have been similarly situated to the Women’s 

Air Forces Service Pilots of World War II (a 

group of federal civilian employees attached 

to the U.S. Army Air Force in World War II). 

1. Uniqueness of service. Civilian service during a period of armed conflict is not 

necessarily equivalent to active military service, even when performed in a 

combat zone. Service must be beyond that generally performed by civilian 

employees and must be occasioned by unique circumstances. 

2. Have rendered service to the United States in 

what was considered civilian employment 

with the U.S. armed forces either through 

formal civil service hiring or less formal hiring 

if the engagement was created under the 

exigencies of war, or as the result of a 

contract with the U.S. government to provide 

direct support to the U.S. armed forces. 

2. Organizational authority over the group. The concept of military control is 

reinforced if the military command authority determines such things as the 

structure of the civilian organization, the location of the group, the mission and 

activities of the group, and the staffing requirements to include the length of 

employment and pay grades of the members of the group. 

3. Have rendered that service during a period of 

armed conflict. 

3. Integration into the military organization. Integrated civilian groups are subject 

to the regulations, standards, and control of the military command authority. 

4. Consist of living persons to whom VA benefits 

can accrue. 

4. Subjection to military discipline. During past armed conflicts, U.S. military 

commanders sometimes restricted the rights or liberties of civilian members as 

if they were military members. 

5. Not have already received benefits from the 

federal government for the service in 

question. 

5. Subjection to military justice. Military members are subject to the military 

criminal justice system. During times of war, “persons serving with or 

accompanying an Armed Force in the field” are subject to the military criminal 

justice code. Those who were serving with the U.S. armed forces may have 

been treated as if they were military and subjected to court-martial jurisdiction 

to maintain discipline. 

 6. Prohibition against members of the group joining the armed forces. Some 

organizations may have been formed to serve in a military capacity to 

overcome the operation of existing laws or treaty or because of a 

governmentally established policy to retain individuals in the group as part of a 

civilian force. 

 7. Receipt of military training and/or achievement of military capability. If a group 

employed skills or resources that were enhanced as the result of military 

training or equipment designed or issued for that purpose, this acts toward 

recognition. 

Source: 32 C.F.R. Part 47, DOD Directive 1000.20. 

Although five groups of civilians who worked in Vietnam during the war 

have applied for consideration under DOD Directive 1000.20, none has 

been accepted. To date, Slick Airways, a division of Airlift International; 

U.S. civil servants on temporary duty at Long Binh, Vietnam; U.S. and 

foreign civilian employees of CAT, Inc.; U.S. civilian crewmembers of the 

Flotilla Alaska Barge and Transport Company; and Vietnamese citizens 

who served in Vietnam as commandos under contract with the U.S. armed 

forces have applied for consideration under the directive. In its 

application, one of these groups claimed to have met all seven criteria for 

acceptance. In its decision, the DOD Civilian/Military Service Review 
Page 26 GAO-05-371 Civilian Exposure to Agent Orange in Vietnam 

Board16 stated that the group met the “organizational authority over the 

group” criterion, and that board members disagreed over whether the 

group met the “uniqueness of service” criterion. In addition, the board 

acknowledged that there was evidence of military command authority 

over the group but asserted that the group was not integrated into the 

military organization and was not subject to military discipline or military 

justice. The application was denied. 

The options presented above could have significant cost and policy 

implications. However, with little data available on the actual number of 

civilians in Vietnam, their exposure levels, and the number of claims that 

would be filed, it is difficult to estimate the costs of these options. 

According to information provided to us by VA officials, of the 2.3 million 

living military veterans who were in Vietnam during the war 

approximately 160,000 (less than 10 percent) are receiving disability 

compensation benefits from VA for the four most common medical 

conditions associated with Agent Orange exposure.17 VA’s average annual 

cost of providing workers’ compensation and medical expenses to 

veterans receiving benefits under the act for the four most common 

medical conditions is about $8,500 for disability compensation and 

$1,000 for medical expenses. Although these costs do not include the costs 

of administering the claims, when VA added diabetes as a condition 

related to Agent Orange exposure, it estimated that the administrative 

costs for each claim processed would be about $350.18

Including civilian employees who worked in Vietnam under these options 

also has policy implications. It could set a precedent that might prompt 

other federal and contract employees who have worked for the U. S. 

government in war zones since the Vietnam War—such as the Gulf War 

and the current conflict in Iraq—to seek similar benefits. Such a precedent 

 16The Civilian/Military Service Review Board reviews and makes recommendations 

concerning applications for veteran’s status and consists of representative from the Office 

of the Secretary of Defense and the Departments of the Army, Navy, and Air Force and, 

when relevant, the Coast Guard. 

17DOD provided VA with a list of the names of military personnel who worked in Vietnam 

during the war. 

18VA estimated that the general operating expenses for the expected 179,000 claims for 

Agent Orange-related diabetes would be about $62 million for a 5-year period. 

Easing Access to Benefits 

for Civilians Has Cost and 

Policy Implications 
Page 27 GAO-05-371 Civilian Exposure to Agent Orange in Vietnam 

could prove costly because the U.S. military has employed a much larger 

number of contractor personnel in recent wars and conflicts than in 

Vietnam. 

The fact that Labor does not collect data on Agent Orange claims that 

allow it to identify the claims using its database makes it difficult to 

identify trends in the number and disposition of claims. The coding errors 

in Labor’s database also make it difficult to identify and track these claims. 

In addition, while Labor is the licensor of insurance carriers for 

government contract employees, it is difficult, without proper records, to 

help claimants identify the insurance carriers or determine how well 

insurers are following through on their obligations. Both Labor and 

claimants are burdened by the difficulties the agency has in providing 

information to claimants—particularly contract employees filing claims 

under DBA—on how to file claims, locate their former employers, and 

identify the employers’ insurance carriers, difficulties that leave room for 

delays and errors in processing claims. 

Federal and contract employees who may have been exposed to Agent 

Orange while working for the United States during the Vietnam War have 

clearly had a different experience than their military counterparts in 

requesting compensation under the Agent Orange Act. In short, these 

employees must meet more stringent standards in pursuing claims under 

FECA and DBA. The cost implications of options designed to increase 

access to compensation for civilians exposed to Agent Orange should be 

carefully considered in the context of the current and projected fiscal 

environment. The lack of information available about the number of 

possible civilian Agent Orange claims, however, makes it difficult for us to 

estimate the potential costs were such options to be adopted. In addition, 

any consideration of these options should include an assessment of the 

policy and cost implications the changes could have for other civilian 

employees involved in wars and conflicts since the Vietnam War, such as 

the war in Iraq. Setting a precedent for expanding benefits to civilian 

employees could have a much larger impact in the future as the U.S. 

military increases its reliance on contract employees. 

Conclusions 
Page 28 GAO-05-371 Civilian Exposure to Agent Orange in Vietnam 

To improve the handling of civilian Agent Orange claims, the Secretary of 

Labor should 

• direct OWCP to assign a unique identifying code to Agent Orange 

claims and develop procedures to ensure that these claims are coded 

correctly; 

• provide better oversight of licensed DBA insurance carriers by 

requiring the Office of Longshore and Harbor Workers to track the 

information it retains on licensed insurance carriers for Vietnam era 

employers in an easily searchable format, such as in an automated file, 

and track changes in ownership for each licensed carrier in order to be 

able to determine liability for payments; and 

• direct the appropriate offices to provide contract employees with the 

information needed to file Agent Orange claims by taking such 

measures as posting information on Labor’s Web sites or developing 

informational brochures that include information on how to file a claim 

under DBA, such as which forms to use, and information on Vietnam 

era contractors with the names of their insurance carriers licensed by 

Labor. 

We provided a draft of this report to Labor, DOD, and VA for comment. 

Labor and VA provided written comments on the draft, which are 

reproduced in appendixes II and III. 

Labor generally agreed with our recommendations. The agency agreed to 

improve its handling of civilian Agent Orange claims by developing a 

unique code to use in identifying these claims, improving its oversight of 

licensed DBA insurance carriers, and assisting contract employees in 

obtaining information on filing claims by enhancing the information on its 

Web site. Regarding our recommendation to develop a better system for 

tracking information on licensed DBA insurance carriers, Labor stated that 

it does not have the funding needed to create a relational database or the 

resources to enter these data into such a database. However, it also stated 

that a current evaluation of its processes may provide some 

recommendations for enhancing its data capability in this area. Given the 

availability of easy to use, off-the-shelf database packages, we continue to 

believe that Labor could implement this recommendation with relatively 

little expense and that data entry could be phased in over time or 

contracted out. 

Recommendations for 

Executive Action 

Agency Comments 
Page 29 GAO-05-371 Civilian Exposure to Agent Orange in Vietnam 

VA expressed serious concerns about the legislative options for easing 

civilians’ access to workers’ compensation benefits. It highlighted the 

additional costs and administrative burdens associated with the options. 

VA also expressed concern about the precedent-setting implications these 

options could have for civilian employees involved in other wars and 

conflicts since the Vietnam War. As noted in the report, we agree that the 

cost and policy implications of these options should be carefully 

considered. 

DOD provided only an informal technical comment on the report. Labor 

and VA also provided a few technical clarifications, which we 

incorporated as appropriate. 

We will send copies of this report to the Secretaries of Labor, Defense, 

Veterans Affairs, and other interested parties. We will also make copies 

available to others upon request. In addition, the report will be available at 

no charge on GAO’s Web site at http://www.gao.gov. 

Please contact me or Revae Moran on (202) 512-7215 if you or your staff 

have any questions about this report. Other contacts and staff 

acknowledgments are listed in appendix IV. 

Robert E. Robertson 

Director, Education, Workforce, 

 and Income Security Issues 
Appendix I: Technical Appendix 

Page 30 GAO-05-371 Civilian Exposure to Agent Orange in Vietnam 

Many of the agencies we contacted were unable to locate records on 

federal and contract workers employed in Vietnam, primarily because of 

the age of the records and the fact that they were not automated. 

However, using the limited historical data provided to us by the 

Department of State and the Department of Defense (DOD), we developed 

estimates of the number of civilian employees who worked in Vietnam 

during the war. 

The Department of State was not able to provide the total number of 

contract employees who had worked in Vietnam but was able to identify 

the names of federal employees who had worked there between January 

1964 through November 1965 and January 1967 through November 

1974 from its quarterly Foreign Service reports. As these are historical 

reports, we were unable to assess the reliability of these data for several 

reasons: Most records were not computerized in the 1960s or 1970s, most 

paper records have either been destroyed or were not organized in a way 

that would facilitate the identification of personnel, and most officials who 

were knowledgeable about employees in Vietnam are no longer with the 

agency. We entered the names from these quarterly lists into an automated 

file, sorted out likely duplicates, and counted the remainder. On the basis 

of our analysis, we estimated that about 6,000 employees of the 

Department of State worked in Vietnam during the war. 

In the absence of information from the Central Intelligence Agency (CIA) 

and the Departments of Agriculture and Treasury, we used the Department 

of State estimate as a proxy for the number of federal and contract 

employees each agency employed in Vietnam. We also assumed that these 

agencies did not have as many employees in Vietnam as the much larger 

number of DOD contract employees needed to support the military 

operations. On the basis of these assumptions, we estimated that these 

four agencies employed about 24,000 workers in Vietnam during the war. 

Although DOD officials were unable to locate information on the number 

of federal employees who had worked for the agency during the Vietnam 

War, we located historical reports of civilian personnel strength by year at 

DOD’s Directorate for Information, Operations, and Reports and used 

these data to develop estimates of the number of federal civilian 

employees who worked for DOD in Vietnam. These data provide a count 

of the number of employees for one point in time during the year. 

However, DOD officials told us that civilians likely stayed in Vietnam for a 

2-year rotation before returning to the United States, so totaling these 

annual counts would overestimate the total number of employees. To 

obtain an unduplicated count, we used the annual civilian personnel 

Appendix I: Technical Appendix 

Estimating the Number of 

Civilian Employees 
Appendix I: Technical Appendix 

Page 31 GAO-05-371 Civilian Exposure to Agent Orange in Vietnam 

strength data and assumed a 2-year rotation. For example, in 1964 DOD 

had 44 federal employees in Vietnam, but in 1965 had 51 employees—an 

addition of 7 new employees. In 1966, DOD had a total of 444 federal 

employees. However, assuming the 44 employees from 1964 had 

completed their 2-year rotation and returned home, they would not be 

included in this count. Therefore, the 444 is composed of the 7 employees 

who arrived in 1965 and 437 new employees who arrived in 1966. Using 

this methodology, we estimated that about 4,600 DOD employees were in 

Vietnam during the war (see table 3). We obtained the personnel strength 

data from published DOD reports but were unable to assess the reliability 

of the data for several reasons: Most records were not computerized in the 

1960s and 1970s, most paper records have either been destroyed or were 

not organized in a way that would facilitate the identification of personnel, 

and most officials who were knowledgeable about employees in Vietnam 

are no longer with the agency. 

Table 3: Estimated Number of DOD Federal Employees in Vietnam, 1964 to 1974 

Year 

Annual federal employee 

personnel strength data

provided by DOD

Estimated number of DOD federal 

employees entering Vietnam each

year, assuming a 2-year rotation

1964 44 44

1965 51 7

1966 444 437

1967 1,240 803

1968 1,427 624

1969 1,522 898

1970 1,133 235

1971 868 633

1972 646 13

1973 811 798

1974 919 121

1975 Not available Not available

Total 4,613

Source: DOD and GAO analysis. 

DOD was unable to provide information on the number of contract 

employees it had working in Vietnam during the war. However, from 

DOD’s Directorate for Information, Operations, and Reports we were able 

to obtain the annual dollar amount of DOD service contracts provided to 

companies between 1966 and 1974 for work in Vietnam, and we used these 
Appendix I: Technical Appendix 

Page 32 GAO-05-371 Civilian Exposure to Agent Orange in Vietnam 

data to develop estimates of the number of contract workers. DOD 

officials told us that service contracts were the most likely type of contract 

to be used to pay salaries to contract workers, as opposed to other types 

of contracts that would have been used to purchase items such as 

equipment and supplies. We were unable to assess the reliability of these 

data for reasons similar to those noted for the data we obtained for federal 

employees. In addition, the data are further limited because we were 

unable to determine if the service contracts would have been for salaries 

to U.S. citizens or foreign nationals and because 3 years of data (1964, 

1965, and 1975) were not available. 

Using the limited data available, we divided these annual amounts by a 

range of “burdened labor rates” to estimate the number of employees 

represented by these contracts each year. DOD officials told us the 

burdened labor rate—-salary, subsistence expenses, company overhead, 

profit, insurance, travel, and other costs that would have been included in 

the total contract amount—-could vary among contracts. However, a DOD 

official with experience administering contracts advised us that doubling 

an employee’s annual salary would approximate this burdened labor rate. 

However, DOD was unable to provide us with information on the range of 

salaries paid to contract employees in Vietnam. Therefore, to estimate 

annual salaries for contract employees, we obtained available salary scales 

for federal employees from 1964 to 1975 and selected a range of low, 

middle, and high salaries. For our analysis, we assumed annual salaries of 

$7,500, $15,000, and $25,000 and doubled them to obtain burdened labor 

rates of $15,000, $30,000, and $50,000 per person. We divided these 

burdened labor rates into the annual contract amounts to get an estimated 

number of contract employees employed in Vietnam each year. As with the 

annual estimates of federal DOD employees, we assumed a 2-year rotation 

to obtain an unduplicated count, which ranged from about 43,000 to 

142,000 contract employees (see table 4). 
Appendix I: Technical Appendix 

Page 33 GAO-05-371 Civilian Exposure to Agent Orange in Vietnam 

Table 4: Estimated Number of DOD Contract Employees in Vietnam, 1966-1974 

 Estimated number of DOD contract employees entering Vietnam each year, assuming a 2-year rotation

Year 

Assuming a burdened labor

rate of $15,000 per person 

Assuming a burdened labor 

rate of $30,000 per person 

Assuming a burdened labor 

rate of $50,000 per person

1964 Not available Not available Not available

1965 Not available Not available Not available

1966 47,253 23,627 14,176

1967 4,123 2,062 1,237

1968 29,823 14,912 8,947

1969 11,667 5,833 3,500

1970 27,203 13,602 8,161

1971 14,287 7,143 4,286

1972 2,060 1,030 618

1973 8,233 4,117 2,470

1974 -2,460a-1,230a -738a

1975 Not available Not available Not available

Total 142,190 71,095 42,657

Source: DOD and GAO analysis. 

a

The negative numbers near the end of the war indicate departures from Vietnam that were dictated 

by the conclusion of the war rather than the completion of average time of service there. 
Appendix II: Comments from the Department 

of Labor 

Page 34 GAO-05-371 Civilian Exposure to Agent Orange in Vietnam 

Appendix II: Comments from the Department 

of Labor 
Appendix II: Comments from the Department 

of Labor 

Page 35 GAO-05-371 Civilian Exposure to Agent Orange in Vietnam 
Appendix III: Comments from the Department 

of Veterans Affairs 

Page 36 GAO-05-371 Civilian Exposure to Agent Orange in Vietnam 

Appendix III: Comments from the 

Department of Veterans Affairs 
Appendix III: Comments from the Department 

of Veterans Affairs 

Page 37 GAO-05-371 Civilian Exposure to Agent Orange in Vietnam 
Appendix III: Comments from the Department 

of Veterans Affairs 

Page 38 GAO-05-371 Civilian Exposure to Agent Orange in Vietnam 
Appendix III: Comments from the Department 

of Veterans Affairs 

Page 39 GAO-05-371 Civilian Exposure to Agent Orange in Vietnam 
Appendix III: Comments from the Department 

of Veterans Affairs 

Page 40 GAO-05-371 Civilian Exposure to Agent Orange in Vietnam 
Appendix IV: GAO Contacts and Staff 

Acknowledgments 

Page 41 GAO-05-371 Civilian Exposure to Agent Orange in Vietnam 

Revae E. Moran, (202) 512-3863 

Karen A. Brown (202) 512-7240 

Nina E. Horowitz made significant contributions to this report. In addition, 

Margaret L. Armen, Susan C. Bernstein, Benjamin A. Bolitzer, Christina 

Cromley, and Jean L. McSween provided key technical and legal 

assistance throughout the engagement. 

Appendix IV: GAO Contacts and Staff 

Acknowledgments 

GAO Contacts 

Staff 

Acknowledgments 

(130384) 
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