United States Government Accountability Office

GAO Testimony

Before the Subcommittee on National Security, 

Emerging Threats, and International Relations,

Committee on Government Reform, House of 

Representatives

DEFENSE HEALTH CARE

Occupational and 

Environmental Health 

Surveillance Conducted 

during Deployments Needs 

Improvement 

Statement of Marcia Crosse 

Director, Health Care

For Release on Delivery 

Expected at 10:30 a.m. EDT 

Tuesday, July 19, 2005 

 

GAO-05-903T
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

July 19, 2005

DEFENSE HEALTH CARE 

Occupational and Environmental Health 

Surveillance Conducted during 

Deployments Needs Improvement 

Highlights of GAO-05-903T, a testimony

before the Subcommittee on National 

Security, Emerging Threats, and 

International Relations, Committee on 

Government Reform, House of

Representatives

Following the 1991 Persian Gulf

War, research and investigations

into the causes of servicemembers’

unexplained illnesses were

hampered by a lack of

servicemember health and

deployment data, including

inadequate occupational and

environmental exposure data. In

1997, the Department of Defense 

(DOD) developed a militarywide 

health surveillance framework that

includes occupational and 

environmental health surveillance 

(OEHS)—the regular collection

and reporting of occupational and 

environmental health hazard data 

by the military services. 

This testimony is based on GAO’s 

report, entitled Defense Health 

Care: Improvements Needed in

Occupational and Environmental 

Hea h Surveillance during

Deployment to Address Immedia e

and Long-term Hea th Issues 

(GAO-05-632). The testimony

presents findings about how the

deployed military services have 

implemented DOD’s policies for 

collecting and reporting OEHS data

for Operation Iraqi Freedom (OIF)

and the efforts under way to use

OEHS reports to address both

immediate and long-term health

issues of servicemembers deployed

in support of OIF.

lt

t

l

Although OEHS data generally have been collected and reported for OIF, as

required by DOD policy, the deployed military services have used different 

data collection methods and have not submitted all of the OEHS reports that 

have been completed. Data collection methods for air and soil surveillance 

have varied across the services, for example, although they have been using 

the same monitoring standard for water surveillance. For some OEHS 

activities, a cross-service working group has been developing standards and 

practices to increase uniformity of data collection among the services. In 

addition, while the deployed military services have been conducting OEHS

activities, they have not submitted all of the OEHS reports that have been

completed during OIF. Moreover, DOD officials could not identify the 

reports they had not received to determine the extent of noncompliance. 

DOD has made progress in using OEHS reports to address immediate health 

risks during OIF, but limitations remain in employing these reports to

address both immediate and long-term health issues. OEHS reports have 

been used consistently during OIF as part of operational risk management 

activities intended to identify and address immediate health risks and to

make servicemembers aware of the risks of potential exposures. While 

these efforts may help in reducing health risks, DOD has not systematically

evaluated their implementation during OIF. DOD’s centralized archive of 

OEHS reports for OIF has several limitations for addressing potential longterm health effects related to occupational and environmental exposures. 

First, access to the centralized archive has been limited due to the security 

classification of most OEHS reports. Second, it will be difficult to link most 

OEHS reports to individual servicemembers’ records because not all data on 

servicemembers’ deployment locations have been submitted to DOD’s 

centralized tracking database. To address problems with linking OEHS 

reports to individual servicemembers, the deployed military services have

tried to include OEHS monitoring summaries in the medical records of some 

servicemembers for either specific incidents of potential exposure or for 

specific locations within OIF. Additionally, according to DOD and Veterans 

Affairs (VA) officials, no federal research plan has been developed to 

evaluate the long-term health of servicemembers deployed in support of OIF, 

including the effects of potential exposures to occupational or 

environmental hazards.

GAO’s report made several recommendations, including that the Secretary of 

Defense improve deployment OEHS data collection and reporting and 

evaluate OEHS risk management activities and that the Secretaries of 

Defense and Veterans Affairs jointly develop a federal research plan to 

address long-term health effects of OIF deployment. DOD plans to take

steps to meet the intent of our first recommendation and partially concurred 

with the other recommendations. VA concurred with our recommendation 

for a joint federal research plan. 

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

To view the full product, including the scope 

and methodology, click on the link above.

For more information, contact Marcia Crosse

at (202) 512-7119 or crossem@gao.gov.
Mr. Chairman and Members of the Subcommittee:

I am pleased to be here today as you consider the efforts by the deployed

military services to implement policies for collecting and reporting

occupational and environmental health surveillance data for Operation 

Iraqi Freedom (OIF) and the work under way to use these data to address 

both the immediate and long-term health issues of servicemembers 

deployed in support of OIF. The health effects from service in military

operations have been of increasing interest since the end of the 1991 

Persian Gulf War—an interest that was renewed when servicemembers 

were deployed in early 2003 to the Persian Gulf in support of OIF. 

Following the 1991 Gulf War, many servicemembers reported suffering 

from unexplained illnesses that they attributed to their service in the 

Persian Gulf and expressed concerns about possible exposures to

chemical or biological warfare agents or environmental contaminants. 

Subsequent research and investigations into the nature and causes of these

illnesses by the Department of Defense (DOD), the Department of

Veterans Affairs (VA), the Department of Health and Human Services

(HHS), the Institute of Medicine, and a Presidential Advisory Committee 

were hampered by a lack of servicemember health and deployment data, 

including inadequate occupational and environmental exposure data. 

To address continuing concerns about the health of servicemembers

during and after deployments and to improve health data collection on 

potential exposures, DOD developed a militarywide health surveillance 

framework for use during deployments beginning in 1997. A key 

component of this framework is occupational and environmental health

surveillance (OEHS), an activity that includes the regular collection and 

reporting of occupational and environmental health hazard data by the 

military services during a deployment that can be used to monitor the 

health of servicemembers and to prevent, treat, or control disease or

injury. DOD has created policies for OEHS data collection during a 

deployment and for the submittal of OEHS reports to a centralized archive 

within specified time frames. The military services are responsible for

implementing these policies in preparation for deployments. During a 

deployment, the military services are unified under a deployment

command structure and are responsible for conducting OEHS activities in

accordance with DOD policy. Throughout this testimony, we identify the 

military services operating in a deployment as “deployed military 

services.”

Page 1 GAO-05-903T
My remarks will summarize our findings on (1) how the deployed military 

services have implemented DOD’s policies for collecting and reporting

OEHS data for OIF and (2) the efforts under way to use OEHS reports to

address both the immediate and long-term health issues of

servicemembers deployed in support of OIF. My statement is based on our 

report, entitled Defense Health Care: Improvements Needed in 

Occupat onal and Environmenta Hea h Surve ance during Deployments 

o Address Immedia e and Long- erm Health Issues (

i l lt ill

t t t

 

GAO-05-632), which is 

being released today. 

To do this work, we reviewed pertinent policies, guidance, and reports 

related to collecting and reporting OEHS data obtained from officials at

the Deployment Health Support Directorate (DHSD), the military services, 

and the Joint Staff, which supports the Chairman of the Joint Chiefs of

Staff.

1

 We also conducted site visits to the Army, Navy, and Air Force

health surveillance centers that develop standards and guidance for 

conducting OEHS.2

 We interviewed DOD officials and reviewed reports

and documents identifying occupational and environmental health risks 

and outlining recommendations for addressing risks at deployment sites. 

We interviewed officials at the U.S. Army’s Center for Health Promotion 

and Preventive Medicine (CHPPM), which archives OEHS reports, both 

classified and unclassified, for all the military services. We also

interviewed officials and military service representatives at DOD’s

Deployment Manpower Data Center on the status of a centralized 

deployment tracking database to identify deployed servicemembers and

record their locations within the theater of operations. Additionally, we

interviewed VA officials on their experience in obtaining and using OEHS

reports from OIF to address the health care needs of veterans. Finally, we

interviewed DOD and VA officials to examine whether the agencies have 

planned or initiated health research to evaluate the long-term health of 

servicemembers deployed in support of OIF using OEHS reports. We 

conducted our work from September 2004 through June 2005 in 

accordance with generally accepted government auditing standards. 

In summary, although OEHS data generally have been collected and 

reported for OIF, as required by DOD policy, the deployed military 

services have used different data collection methods and have not 

1

The Chairman of the Joint Chiefs of Staff is the principal military adviser to the President, 

the National Security Council, and the Secretary of Defense. 

2

The Navy supports OEHS activities for the Marine Corps. 

Page 2 GAO-05-903T
submitted all of the OEHS reports that have been completed. Data

collection methods for air and soil surveillance have varied across the 

services, for example, although they have been using the same monitoring 

standard for water surveillance. Compounding these differences among

the services were varying levels of training and expertise among the 

deployed military service personnel who were responsible for conducting 

OEHS activities, resulting in differing practices for implementing data 

collection standards. For some OEHS activities, a cross-service working 

group, called the Joint Environmental Surveillance Working Group, has 

been developing standards and practices to increase uniformity of data

collection among the services. In addition, the deployed military services

have not submitted to CHPPM all OEHS reports that have been completed

during OIF, as required by DOD policy. While 239 of the 277 OIF bases had 

at least one OEHS report submitted to CHPPM’s centralized archive as of 

December 2004, CHPPM could not measure the magnitude of 

noncompliance because not all of the required consolidated lists that

identify all OEHS reports completed during each quarter in OIF had been 

submitted. Therefore, CHPPM could not compare the reports that it had 

received against the list of reports that had been completed. According to 

CHPPM officials, obstacles to the services’ reporting compliance may have 

included a lack of understanding by some within the deployed military 

services about the type of OEHS reports that should have been submitted.

In addition, OEHS report submission may be given a lower priority

compared to other deployment mission activities. Also, while CHPPM is 

responsible for OEHS archiving, it has no authority to enforce report

submission requirements. To improve OEHS reporting compliance, DOD 

officials said they were revising an existing policy to add additional and 

more specific OEHS requirements. 

DOD has made progress using OEHS reports to address immediate health

risks during OIF, but limitations remain in employing these reports to

address both immediate and long-term health issues. OIF is the first major

deployment in which OEHS reports have been used consistently as part of

operational risk management activities intended to identify and address 

immediate health risks. These activities included health risk assessments 

that described and measured the potential hazards at a site, risk mitigation

activities intended to reduce potential exposure, and risk communication 

efforts undertaken to make servicemembers aware of the possible health

risks of potential exposures. While these efforts may help reduce health

risks, there is no assurance that they have been effective because DOD has

not systematically evaluated the implementation of OEHS risk 

management activities in OIF. Despite progress in the use of OEHS 

information to identify and address immediate health risks, CHPPM’s 

Page 3 GAO-05-903T
centralized archive of OEHS reports for OIF has limitations for addressing 

potential long-term health effects related to occupational and 

environmental exposures for several reasons. First, access to CHPPM’s 

OEHS archive has been limited because most OEHS reports are 

classified—which restricts their use by VA, medical professionals, and 

interested researchers. Second, it will be difficult to link most OEHS 

reports to individual servicemembers because not all data on 

servicemembers’ deployment locations have been submitted to DOD’s 

centralized tracking database. For example, none of the military services 

submitted location data for the first several months of OIF. To address 

problems with linking OEHS reports to individual servicemembers, the 

deployed military services have made efforts to include OEHS summaries

in the medical records of some servicemembers for either specific 

incidents of potential exposure or for specific locations within OIF, such 

as air bases. Additionally, according to DOD and VA officials, no 

comprehensive federal research plan incorporating the use of the archived

OEHS reports has been developed to address the long-term health 

consequences of service in OIF. 

In the report we are issuing today, we recommend that the Secretary of

Defense ensure that cross-service guidance is developed to implement 

DOD’s revised policy for OEHS during deployments and ensure that the 

military services jointly establish and implement procedures to evaluate

the effectiveness of risk management strategies during deployments. We

also recommend that the Secretary of Defense and the Secretary of 

Veterans Affairs work together to develop a federal research plan to follow

the health of OIF servicemembers over time that would include the use of

OEHS reports. In commenting on a draft of this report, DOD stated that

cross-service guidance meeting the intent of our recommendation would 

be developed by the Joint Staff instead of the military services. DOD 

partially concurred with our other recommendations. VA concurred with

our recommendation to work with DOD to jointly develop a federal

research plan to follow the long-term health of OIF servicemembers. 

As of the end of February 2005, an estimated 827,277 servicemembers had 

been deployed in support of OIF. Deployed servicemembers, such as those 

in OIF, are potentially subject to occupational and environmental hazards 

that can include exposure to harmful levels of environmental

contaminants such as industrial toxic chemicals, chemical and biological 

Background 

Page 4 GAO-05-903T
warfare agents, and radiological and nuclear contaminants. Harmful levels 

include high-level exposures that result in immediate health effects.3

Health hazards may also include low-level exposures that could result in

delayed or long-term health effects. Occupational and environmental 

health hazards may include such things as contamination from the past 

use of a site, from battle damage, from stored stockpiles, from military use 

of hazardous materials, or from other sources. 

Federal OEHS Policy As a result of numerous investigations that found inadequate data on

deployment occupational and environmental exposure to identify the 

potential causes of unexplained illnesses among veterans who served in 

the 1991 Persian Gulf War, the federal government increased efforts to 

identify potential occupational and environmental hazards during 

deployments. In 1997, a Presidential Review Directive called for a report 

by the National Science and Technology Council to establish an 

interagency plan to improve the federal response to the health needs of 

veterans and their families related to the adverse effects of deployment.

4

The Council published a report that set a goal for the federal government

to develop the capability to collect and assess data associated with 

anticipated exposure during deployments. Additionally, the report called 

for the maintenance of the capability to identify and link exposure and 

health data by Social Security number and unit identification code. Also in

1997, Public Law 105-85 included a provision recommending that DOD 

ensure the deployment of specialized units to theaters of operations to 

detect and monitor chemical, biological, and similar hazards.5

 The 

Presidential Review Directive and the public law led to a number of DOD 

instructions, directives, and memoranda that have guided the collection 

and reporting of deployment OEHS data. 

 3

Harmful levels of environmental contaminants are determined by the concentration of the 

substance and the duration of exposure. 

4

Presidential Review Directive/National Science and Technology Council – 5 (April 21,

1997). The National Science and Technology Council is a cabinet-level council that helps

coordinate federal science, space, and technology research and development for the 

president. 

5

National Defense Authorization Act for Fiscal Year 1998. Pub. L. No. 105-85, §768, 111 Stat.

1629, 1828 (1997) (“Sense of Congress”).

Page 5 GAO-05-903T
DHSD makes recommendations for DOD-wide policies on OEHS data

collection and reporting during deployments to the Office of the Assistant

Secretary of Defense for Health Affairs. DHSD is assisted by the Joint 

Environmental Surveillance Working Group, established in 1997, which 

serves as a coordinating body to develop and make recommendations for 

DOD-wide OEHS policy.

6

 The working group includes representatives 

from the Army, Navy, and Air Force OEHS health surveillance centers, the 

Joint Staff, other DOD entities, and VA. 

DOD Entities Involved 

with Setting and 

Implementing OEHS 

Policy 

Each service has a health surveillance center—the CHPPM, the Navy

Environmental Health Center, and the Air Force Institute for Operational 

Health—that provides training, technical guidance and assistance, 

analytical support, and support for preventive medicine units7

 in the 

theater in order to carry out deployment OEHS activities in accordance 

with DOD policy. In addition, these centers have developed and adapted 

military exposure guidelines for deployment using existing national

standards for human health exposure limits and technical monitoring

procedures (e.g., standards developed by the U.S. Environmental 

Protection Agency and the National Institute for Occupational Safety and 

Health) and have worked with other agencies to develop new guidelines

when none existed. (See fig. 1.) 

 6

The working group makes recommendations for deployment OEHS policy to the Deputy

Assistant Secretary of Defense for Force Health Protection and Readiness, who serves as

the director of DHSD.

7

Each military service has preventive medicine units, though they may be named

differently. Throughout this report, we use the term preventive medicine unit to apply to

the units fielded by all military services. 

Page 6 GAO-05-903T
Figure 1: Entities Involved in Setting or Implementing Occupational and Environmental Health Surveillance (OEHS) Policy 

Source: DOD policies, Deployment Health Support Directorate, U.S. Army Center for Health Promotion and Preventive Medicine,

Navy Environmental Health Center, Air Force Institute for Operational Health, and Art Explosion.

Implementation of OEHS policy

Setting of OEHS policy

Joint Environmental 

Surveillance 

Working Group

(includes DOD and 

VA representatives)

Office of the Assistant 

Secretary of Defense 

for Health Affairs

 Deployment Health 

Support Directorate

DOD 

policy

DOD

Department of 

the Army

Department of 

the Air Force

Department of 

the Navy

Army’s

guidance

of DOD 

policy

Air Force’s

guidance

of DOD 

policy

Navy’s

guidance

of DOD 

policy

Training

Manual

Training

Manual

Training

Manual

United States Army 

Center for Health 

Promotion and 

Preventive Medicine

Air Force Institute for 

Operational Health

Navy Environmental 

Health Center

Page 7 GAO-05-903T
DOD policies and military service guidelines require that the preventive 

medicine units of each military service be responsible for collecting and 

reporting deployment OEHS data.

8

 Deployment OEHS data are generally 

categorized into three types of reports: baseline, routine, or incidentdriven. 

Deployment OEHS 

Reports 

• Baseline reports generally include site surveys and assessments of

occupational and environmental hazards prior to deployment of

servicemembers and initial environmental health site assessments once 

servicemembers are deployed.9

• Routine reports record the results of regular monitoring of air, water, and 

soil, and of monitoring for known or possible hazards identified in the 

baseline assessment. 

• Incident-driven reports document exposure or outbreak investigations.10

There are no DOD-wide requirements on the specific number or type of

OEHS reports that must be created for each deployment location because

reports generated for each location reflect the specific occupational and 

environmental circumstances unique to that location. CHPPM officials 

said that reports generally reflect deployment OEHS activities that are 

limited to established sites such as base camps or forward operating 

bases;11 an exception is an investigation during an incident outside these 

locations. Constraints to conducting OEHS outside of bases include risks 

to servicemembers encountered in combat and limits on the portability of

OEHS equipment. In addition, DHSD officials said that preventive

medicine units might not be aware of every potential health hazard and 

therefore might be unable to conduct appropriate OEHS activities. 

 8

While in the deployment location, preventive medicine units create and store reports both 

electronically and on paper.

9

Some bases can have more than one baseline report. 

10DOD officials said the analysis of servicemembers’ responses to a post-deployment health

assessment questionnaire is another means to identify potential exposures that should be

investigated. These assessments, designed to identify health issues or concerns that may 

require medical attention, use a questionnaire that is to be completed in theater and asks

servicemembers if they believe they have been exposed to a hazardous agent. 

11Throughout the testimony we refer to both base camps and forward operating bases

collectively as bases. A forward operating base is usually smaller than a base camp in troop 

strength and infrastructure and is normally constructed for short-duration occupation. 

Page 8 GAO-05-903T
According to DOD policy, various entities must submit their completed 

OEHS reports to CHPPM during a deployment. The deployed military 

services have preventive medicine units that submit OEHS reports to their 

command surgeons,12 who review all reports and ensure that they are sent

to a centralized archive that is maintained by CHPPM.13 Alternatively, 

preventive medicine units can be authorized to submit OEHS reports 

directly to CHPPM for archiving. (See fig. 2.) 

OEHS Reporting and 

Archiving Activities during 

Deployment 

 12The command surgeons of deployed preventive medicine units are either Joint Task

Force command surgeons or military service component command surgeons. In OIF, there

are two Joint Task Forces, each with a command surgeon. In addition, the Army, Navy, Air 

Force, and Marine Corps have their own subordinate component commands in a 

deployment, each with a command surgeon. 

13DOD has designated CHPPM as the entity responsible for archiving all OEHS reports from

deployments. 

Page 9 GAO-05-903T
Figure 2: Submittal of Deployment Occupational and Environmental Health 

Surveillance (OEHS) Reports to the Centralized Archive

a

The command surgeons of deployed preventive medicine units are either Joint Task Force command 

surgeons or military service component command surgeons. In OIF, there are two Joint Task Forces,

each with a command surgeon. In addition, the Army, Navy, Air Force, and Marine Corps have their 

own subordinate component commands in a deployment, each with a command surgeon.

Source: DOD and Art Explosion.

DOD

Centralized archives maintained by United States Army 

Center for Health Promotion and Preventive Medicine

Department of 

the Army

Preventive 

medicine unit

Preventive 

medicine unit

Preventive 

medicine unit

OEHS reports 

may go directly to 

CHPPM in certain 

circumstances.

ARR ME MATEY

OEHS

report

OEHS

report

OEHS

report

Command Surgeonsa

Standard reporting structure

Alternate reporting structure

Page 10 GAO-05-903T
According to DOD policy, baseline and routine reports should be

submitted within 30 days of report completion.14 Initial incident-driven

reports should be submitted within 7 days of an incident or outbreak. 

Interim and final reports for an incident should be submitted within 7 days 

of report completion. In addition, the preventive medicine units are 

required to provide quarterly lists of all completed deployment OEHS 

reports to the command surgeons. The command surgeons review these 

lists, merge them, and send CHPPM a quarterly consolidated list of all the 

deployment OEHS reports it should have received.

To assess the completeness of its centralized OEHS archive, CHPPM 

develops a quarterly summary report that identifies the number of

baseline, routine, and incident-driven reports that have been submitted for 

all bases in a command. This report also summarizes the status of OEHS 

report15 submissions by comparing the reports CHPPM receives with the 

quarterly consolidated lists from the command surgeons that list each of 

the OEHS reports that have been completed. For OIF, CHPPM is required

to provide a quarterly summary report to the commander of U.S. Central 

Command16 on the deployed military services’ compliance with

deployment OEHS reporting requirements. 

During deployments, military commanders can use deployment OEHS 

reports completed and maintained by preventive medicine units to identify

occupational and environmental health hazards17 and to help guide their 

risk management decision making. Commanders use an operational risk 

management process to estimate health risks based on both the severity of

the risks to servicemembers and the likelihood of encountering the 

specific hazard. Commanders balance the risk to servicemembers of 

encountering occupational and environmental health hazards while

deployed, even following mitigation efforts, against the need to 

Uses of Deployment OEHS 

Reports 

 14DOD policy does not prescribe a time frame for how long preventive medicine units have

to complete a report. 

15CHPPM also receives some deployment OEHS data that have not been incorporated into a 

report, such as tables of water sampling measurements. 

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

17Along with deployment OEHS reports, commanders also examine medical intelligence, 

operational data, and medical surveillance (such as reports of servicemembers seen by

medical units for injury or illness) to identify occupational and environmental health

hazards.

Page 11 GAO-05-903T
accomplish specific mission requirements. The operational risk 

management process, which varies slightly across the services, includes 

• risk assessment, including hazard identification, to describe and measure 

the potential hazards at a location; 

• risk control and mitigation activities intended to reduce potential

exposures; and 

• risk communication efforts to make servicemembers aware of possible 

exposures, any risks to health that they may pose, the countermeasures to

be employed to mitigate exposure or disease outcome, and any necessary

medical measures or follow-up required during or after the deployment. 

Along with health encounter18 and servicemember location data, archived 

deployment OEHS reports are needed by researchers to conduct

epidemiologic studies on the long-term health issues of deployed 

servicemembers. These data are needed, for example, by VA, which in 

2002 expanded the scope of its health research to include research on the 

potential long-term health effects on servicemembers in hazardous 

military deployments. In a letter to the Secretary of Defense in 2003, VA 

said it was important for DOD to collect adequate health and exposure 

data from deployed servicemembers to ensure VA’s ability to provide 

veterans’ health care and disability compensation. VA noted in the letter 

that much of the controversy over the health problems of veterans who 

fought in the 1991 Persian Gulf War could have been avoided had more 

extensive surveillance data been collected. VA asked in the letter that it be

allowed access to any unclassified data collected during deployments on 

the possible exposure of servicemembers to environmental hazards of all

kinds. 

 18Examples of health encounter data are medical records of in-patient and out-patient care,

health assessments completed by servicemembers before and after a deployment, and 

blood serum samples. 

Page 12 GAO-05-903T
The deployed military services generally have collected and reported 

OEHS data for OIF, as required by DOD policy. However, the deployed 

military services have used different OEHS data collection standards and 

practices, because each service has its own authority to implement broad 

DOD policies. To increase data collection uniformity, the Joint

Environmental Surveillance Working Group has made some progress in

devising cross-service standards and practices for some OEHS activities. 

In addition, the deployed military services have not submitted all of the 

OEHS reports they have completed for OIF to CHPPM’s centralized

archive, as required by DOD policy. However, CHPPM officials said that 

they could not measure the magnitude of noncompliance because they

have not received all of the required quarterly consolidated lists of OEHS 

reports that have been completed. To improve OEHS reporting 

compliance, DOD officials said they were revising an existing policy to add 

additional and more specific OEHS requirements.

OEHS data collection standards19 and practices have varied among the

military services because each service has its own authority to implement 

broad DOD policies, and the services have taken somewhat different

approaches. For example, although one water monitoring standard has 

been adopted by all military services, the services have different standards 

for both air and soil monitoring. As a result, for similar OEHS events, 

preventive medicine units may collect and report different types of data.

Each military service’s OEHS practices for implementing data collection 

standards also have differed because of varying levels of training and 

expertise among the service’s preventive medicine units. For example, 

CHPPM officials said that Air Force and Navy preventive medicine units 

had more specialized personnel with a narrower focus on specific OEHS 

activities than Army preventive medicine units, which included more

generalist personnel who conducted a broader range of OEHS activities. 

Air Force preventive medicine units generally have included a flight 

surgeon, a public health officer, and bioenvironmental engineers. Navy 

preventive medicine units generally have included a preventive medicine 

physician, an industrial hygienist, a microbiologist, and an entomologist. In

contrast, Army preventive medicine unit personnel generally have 

consisted of environmental science officers and technicians. 

Deployed Military 

Services Use Varying 

Approaches to Collect 

OEHS Data and Have

Not Submitted All 

OEHS Reports for OIF 

Data Collection Standards 

and Practices Vary by 

Service, Although 

Preliminary Efforts Are 

Under Way to Increase 

Uniformity 

 19OEHS standards generally set out technical requirements for monitoring, including the 

type of equipment needed and the appropriate frequency of monitoring. 

Page 13 GAO-05-903T
DOD officials also said other issues could contribute to differences in data 

collected during OIF. DHSD officials said that variation in OEHS data 

collection practices could occur as a result of resource limitations during a 

deployment. For example, some preventive medicine units may not be 

fully staffed at some bases. A Navy official also said that OEHS data 

collection can vary as different commanders set guidelines for 

implementing OEHS activities in the deployment theater. 

To increase the uniformity of OEHS standards and practices for 

deployments, the military services have made some progress—particularly

in the last 2 years—through their collaboration as members of the Joint 

Environmental Surveillance Working Group. For example, the working 

group has developed a uniform standard, which has been adopted by all

the military services, for conducting environmental health site

assessments, which are a type of baseline OEHS report.

20 These 

assessments have been used in OIF to evaluate potential environmental 

exposures that could have an impact on the health of deployed 

servicemembers and determine the types of routine OEHS monitoring that

should be conducted. Also, within the working group, three subgroups—

laboratory, field water, and equipment—have been formed to foster the 

exchange of information among the military services in developing 

uniform joint OEHS standards and practices for deployments. For 

example, DHSD officials said the equipment subgroup has been working 

collaboratively to determine the best OEHS instruments to use for a 

particular type of location in a deployment. 

The deployed military services have not submitted all the OEHS reports 

that the preventive medicine units completed during OIF to CHPPM for

archiving, according to CHPPM officials. Since January 2004, CHPPM has

compiled four summary reports that included data on the number of OEHS 

reports submitted to CHPPM’s archive for OIF. However, these summary 

reports have not provided information on the magnitude of noncompliance 

with report submission requirements because CHPPM has not received all

consolidated lists of completed OEHS reports that should be submitted 

quarterly. These consolidated lists were intended to provide a key 

inventory of all OEHS reports that had been completed during OIF. 

Because there are no requirements on the specific number or type of 

OEHS reports that must be created for each base, the quarterly 

Deployed Military Services

Have Not Submitted All

Required OEHS Reports 

for OIF, and the Magnitude 

of Noncompliance Is 

Unknown 

 20This standard was approved in October 2003. 

Page 14 GAO-05-903T
consolidated lists are CHPPM’s only means of assessing compliance with 

OEHS report submission requirements. Our analysis of data supporting the 

four summary reports21 found that, overall, 239 of the 277 bases22 had at

least one OEHS baseline (139) or routine (211) report submitted to 

CHPPM’s centralized archive through December 2004.23

DOD officials suggested several obstacles that may have hindered OEHS 

reporting compliance during OIF. For example, CHPPM officials said there

are other, higher priority operational demands that commanders must

address during a deployment. In addition, CHPPM officials said that some 

of the deployed military services’ preventive medicine units might not 

understand the types of OEHS reports to be submitted or might view them

as an additional paperwork burden. CHPPM and other DOD officials

added that some preventive medicine units might have limited access to 

communication equipment to send reports to CHPPM for archiving.24

CHPPM officials also said that while they had the sole archiving 

responsibility, CHPPM did not have the authority to enforce OEHS 

reporting compliance for OIF—this authority rests with the Joint Staff and 

the commander in charge of the deployment. 

DOD has several efforts under way to improve OEHS reporting 

compliance. CHPPM officials said they have increased communication 

with deployed preventive medicine units and have facilitated coordination 

among each service’s preventive medicine units prior to deployment. 

CHPPM has also conducted additional OEHS training for some preventive 

medicine units prior to deployment, including both refresher courses and 

information about potential hazards specific to the locations where the 

units were being deployed. In addition, DHSD officials said they were 

revising an existing policy to add additional and more specific OEHS 

requirements. However, at the time of our review, a draft of the revision 

 21Incident-driven reports reflect OEHS investigation of unexpected incidents and would not 

be submitted to CHPPM’s archive according to any identified pattern. Therefore, we did not

comment on the services’ submission of incident-driven reports. 

22The U.S. Central Command has established and closed bases throughout the OIF 

deployment; therefore, the number of bases for each summary report varied. 

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

24DOD officials said that during a deployment, preventive medicine units share the

military’s classified communication system with all other deployed units and transmission 

of OEHS reports might be a lower priority than other mission communications traffic. Also,

preventive medicine units might not deploy with communications equipment. 

Page 15 GAO-05-903T
had not been released, and therefore specific details about the revision

were not available.

DOD has made progress in using OEHS reports to address immediate 

health risks during OIF, but limitations remain in employing these reports

to address both immediate and long-term health issues. During OIF, OEHS 

reports have been used as part of operational risk management activities 

intended to assess, mitigate, and communicate to servicemembers any 

potential hazards at a location. There have been no systematic efforts by 

DOD or the military services to establish a system to monitor the 

implementation of OEHS risk management activities, although DHSD 

officials said they considered the relatively low rates of disease and 

nonbattle injury in OIF an indication of OEHS effectiveness. In addition, 

DOD’s centralized archive of OEHS reports for OIF is limited in its ability 

to provide information on the potential long-term health effects related to 

occupational and environmental exposures for several reasons, including 

limited access to most OEHS reports because of their security 

classification, incomplete data on servicemembers’ deployment locations, 

and the lack of a comprehensive federal research plan incorporating the 

use of archived OEHS reports. 

To identify and reduce the risk of immediate health hazards in OIF, all of 

the military services have used preventive medicine units’ OEHS data and 

reports in an operational risk management process. A DOD official said

that while DOD had begun to implement risk management to address 

occupational and environmental hazards in other recent deployments, OIF 

was the first major deployment to apply this process throughout the 

deployed military services’ day-to-day activities, beginning at the start of

the operation.

25 The operational risk management process includes risk 

assessments of deployment locations, risk mitigation activities to limit 

potential exposures, and risk communication to servicemembers and 

commanders about potential hazards. 

Progress Made in 

Using OEHS Reports 

to Address Immediate 

Health Risks, Though 

Limitations Remain 

for Addressing Both 

Immediate and Longterm Health Issues 

DOD Has Made Progress in

Using Deployment OEHS 

Data and Reports in Risk 

Management but Does Not 

Monitor Implementation of 

These Efforts 

 25OEHS risk management activities began to be employed during previous deployments,

such as Operation Joint Guardian in Kosovo and Operation Enduring Freedom in Central

Asia, but it was not formally adopted as a tool to assess deployment health hazards until 

2002. See Office of the Chairman, The Joint Chiefs of Staff, Memorandum MCM-0006-02, 

“Updated Procedures for Deployment Health Surveillance and Readiness,” Feb. 1, 2002. 

Page 16 GAO-05-903T
• Risk Assessments. Preventive medicine units from each of the services

have generally used OEHS information and reports to develop risk 

assessments that characterized known or potential hazards when new

bases were opened in OIF. CHPPM’s formal risk assessments have also 

been summarized or updated to include the findings of baseline and 

routine OEHS monitoring conducted while bases are occupied by 

servicemembers, CHPPM officials said. During deployments, commanders 

have used risk assessments to balance the identified risk of occupational

and environmental health hazards, and other operational risks, with

mission requirements. Generally, OEHS risk assessments for OIF have

involved analysis of the results of air, water, or soil monitoring.26 CHPPM

officials said that most risk assessments that they have received 

characterized locations in OIF as having a low risk of posing health 

hazards to servicemembers.27

• Risk Control and Mitigation. Using risk assessment findings, preventive 

medicine units have recommended risk control and mitigation activities to 

commanders that were intended to reduce potential exposures at specific

locations. For OIF, risk control and mitigation recommendations at bases 

have included such actions as modifying work schedules, requiring 

individuals to wear protective equipment, and increasing sampling to 

assess any changes and improve confidence in the accuracy of the risk 

estimate. 

• Risk Communication. Risk assessment findings have also been used in risk 

communication efforts, such as providing access to information on a Web 

site or conducting health briefings to make servicemembers aware of

occupational and environmental health risks during a deployment and the 

recommended efforts to control or mitigate those risks, including the need 

for medical follow-up. Many of the risk assessments for OIF we reviewed 

recommended that health risks be communicated to servicemembers. 

While risk management activities have become more widespread in OIF 

compared with previous deployments, DOD officials have not conducted 

systematic monitoring of deployed military services’ efforts to conduct

 26An Army operational risk management field manual describes the steps in determining 

risk level, including identifying the hazard, assessing the severity of the hazard, and 

determining the probability that the hazard will occur. DOD has also developed technical 

guides that detail toxicity thresholds and associated potential health effects from exposure 

to hazards. 

27Risk assessments can designate identified occupational or environmental health risks as

posing a low, moderate, high, or extremely high risk to servicemembers. 

Page 17 GAO-05-903T
OEHS risk management activities. As of March 2005, neither DOD nor the 

military services had established a system to examine whether required

risk assessments had been conducted, or to record and track resulting 

recommendations for risk mitigation or risk communication activities. In

the absence of a systematic monitoring process, CHPPM officials said they

conducted ad hoc reviews of implementation of risk management

recommendations for sites where continued, widespread OEHS 

monitoring has occurred, such as at Port Shuaiba, Kuwait, a deepwater 

port where a large number of servicemembers have been stationed, or

other locations with elevated risks. DHSD officials said they have initiated 

planning for a comprehensive quality assurance program for deployment

health that would address OEHS risk management, but the program was

still under development.

DHSD and military service officials said that developing a monitoring 

system for risk management activities would face several challenges. In 

response to recommendations for risk mitigation and risk communication 

activities, commanders may have issued written orders and guidance that 

were not always stored in a centralized, permanent database that could be

used to track risk management activities. Additionally, DHSD officials told

us that risk management decisions have sometimes been recorded in 

commanders’ personal journals or diaries, rather than issued as orders

that could be stored in a centralized, permanent database. 

In lieu of a monitoring system, DHSD officials said that DOD considers the

rates of disease and nonbattle injury in OIF as a general measure or

indicator of OEHS effectiveness. As of January 2005, OIF had a 4 percent 

total disease and nonbattle injury rate—in other words, an average of 

4 percent of servicemembers deployed in support of OIF had been seen by

medical units for an injury or illness in any given week. This rate is the 

lowest DOD has ever documented for a major deployment, according to

DHSD officials. For example, the total disease and nonbattle injury rate for 

the 1991 Gulf War was about 6.5 percent, and the total rate for Operation 

Enduring Freedom in Central Asia has been about 5 percent. However, 

while this indicator provides general information on servicemembers’

health status, it is not directly linked to specific OEHS activities and

therefore is not a clear measure of their effectiveness. 

Page 18 GAO-05-903T
Access to archived OEHS reports by VA, medical professionals, and 

interested researchers has been limited by the security classification of

most OEHS reports.

28 Typically, OEHS reports are classified if the specific 

location where monitoring activities occur is identified. VA officials said

they would like to have access to OEHS reports in order to ensure 

appropriate postwar health care and disability compensation for veterans, 

and to assist in future research studies. However, VA officials said that,

because of these security concerns, they did not expect access to OEHS 

reports to improve until OIF has ended. 

Although access to OEHS reports has been restricted, VA officials said 

they have tried to anticipate likely occupational and environmental health 

concerns for OIF based on experience from the 1991 Persian Gulf War and 

on CHPPM’s research on the medical or environmental health conditions 

that exist or might develop in the region. Using this information, VA has 

developed study guides for physicians on such topics as health effects 

from radiation and traumatic brain injury and also has written letters for 

OIF veterans about these issues. 

DOD has begun reviewing classification policies for OEHS reports, as

required by the Ronald W. Reagan National Defense Authorization Act for 

Fiscal Year 2005.29 A DHSD official said that DOD’s newly created Joint

Medical Readiness Oversight Committee is expected to review ways to 

reduce or limit the classification of data, including data that are potentially

useful for monitoring and assessing the health of servicemembers who 

have been exposed to occupational or environmental hazards during 

deployments. 

Access to Most Archived 

OEHS Reports Is Limited 

by Security Classification 

 28Individuals desiring to review classified documents must have the appropriate level of 

security clearance and a need to access the information. VA officials have been able to

access some OEHS data on a case-by-case basis.

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

Page 19 GAO-05-903T
Linking OEHS reports from the archive to individual servicemembers will 

be difficult because DOD’s centralized tracking database for recording 

servicemembers’ deployment locations currently does not contain 

complete or comparable data. In May 1997, we reported that the ability to 

track the movement of individual servicemembers within the theater is 

important for accurately identifying exposures of servicemembers to 

health hazards.30 However, the Defense Manpower Data Center’s

centralized database has continued to experience problems in obtaining 

complete, comparable data from the services on the location of

servicemembers during deployments, as required by DOD policies.

31 Data

center officials said the military services had not reported location data for 

all servicemembers for OIF. As of October 2004, the Army, Air Force, and 

Marine Corps each had submitted location data for approximately 

80 percent of their deployed servicemembers, and the Navy had submitted 

location data for about 60 percent of its deployed servicemembers.32

Additionally, the specificity of location data has varied by service. For 

example, the Marine Corps has provided location of servicemembers only

by country, whereas each of the other military services has provided more

detailed location information for some of their servicemembers, such as

base camp name or grid coordinate locations. Furthermore, the military 

services did not begin providing detailed location data until OIF had been 

ongoing for several months. 

DHSD officials said they have been revising an existing policy33 to provide 

additional requirements for location data that are collected by the military

Difficulties Exist in 

Linking Archived OEHS 

Reports to Individual 

Servicemembers, but Some 

Efforts Are Under Way to 

Include Information in 

Medical Records 

 , i 30GAO, Defense Health Care: Medical Surveillance Improved Since Gulf War but M xed 

Results in Bosnia, GAO/NSIAD-97-136 (Washington D.C.: May 13, 1997). 

31DOD policy requires the Defense Manpower Data Center to maintain a system that

collects information on deployed forces, including daily-deployed strength, in total and by

unit; grid coordinate locations for each unit (company size and larger); and inclusive dates

of individual servicemembers’ deployment. See DOD Instruction 6490.3, “Implementation

and Application of Joint Medical Surveillance for Deployment,” Aug. 7, 1997. In addition, a 

2002 DOD policy requires combatant commands to provide the Defense Manpower Data

Center with rosters of all deployed personnel, their unit assignments, and the unit’s

geographic locations while deployed. See Office of the Chairman, The Joint Chiefs of Staff, 

Memorandum MCM-0006-02, “Updated Procedures for Deployment Health Surveillance and 

Readiness,” February 1, 2002. 

32The military services submitted location data for both OIF and Operation Enduring 

Freedom in Central Asia; Defense Manpower Data Center officials said they were unable to 

separate the data from the two operations. 

33DOD Instruction 6490.3, “Implementation and Application of Joint Medical Surveillance

for Deployment,” Aug. 7, 1997. 

Page 20 GAO-05-903T
services, such as a daily location record with grid coordinates or latitude 

and longitude coordinates for all servicemembers. Though the revised 

policy has not been published, as of May 2005 the Army and the Marine 

Corps had implemented a new joint location database in support of OIF 

that addresses these revisions. 

During OIF, some efforts have been made to include information about 

specific incidents of potential and actual exposure to occupational or

environmental health hazards in the medical records of servicemembers 

who may have been affected. According to DOD officials, preventive 

medicine units have been investigating incidents involving potential 

exposure during the deployment. For a given incident, a narrative

summary of events and the results of any medical procedures generally 

were included in affected servicemembers’ medical records. Additionally, 

rosters were generally developed of servicemembers directly affected and 

of servicemembers who did not have any acute symptoms but were in the 

vicinity of the incident. For example, in investigating an incident involving 

a chemical agent used in an improvised explosive device, CHPPM officials 

said that two soldiers who were directly involved were treated at a 

medical clinic, and their treatment and the exposure were recorded in

their medical records. Although 31 servicemembers who were providing

security in the area were asymptomatic, doctors were documenting this 

potential exposure in their medical records. 

In addition, the military services have taken some steps to include 

summaries of potential exposures to occupational and environmental

health hazards in the medical records of servicemembers deployed to

specific locations. The Air Force has created summaries of these hazards 

at deployed air bases and has required that these be placed in the medical 

records of all Air Force servicemembers stationed at these bases. (See 

app. I for an example.) However, Air Force officials said no follow-up 

activities have been conducted specifically to determine whether all Air 

Force servicemembers have had the summaries placed in their medical 

records. Similarly, the Army and Navy jointly created a summary of

potential exposure for the medical records of servicemembers stationed at

Port Shuaiba, the deepwater port used for bringing in heavy equipment in

support of OIF where a large number of servicemembers have been 

permanently or temporarily stationed. Since December 2004, port officials 

have made efforts to make the summary available to servicemembers

stationed at Port Shuaiba so that these servicemembers can include the 

summary in their medical records. However, there has been no effort to

retroactively include the summary in the medical records of

servicemembers stationed at the port prior to that time. 

Page 21 GAO-05-903T
According to DOD and VA officials, no federal research plan that includes

the use of archived OEHS reports has been developed to evaluate the longterm health of servicemembers deployed in support of OIF, including the 

effects of potential exposure to occupational or environmental hazards. In

February 1998 we noted that the federal government lacked a proactive 

strategy to conduct research into Gulf War veterans’ health problems and 

suggested that delays in planning complicated researchers’ tasks by 

limiting opportunities to collect critical data.

34 However, the Deployment

Health Working Group, a federal interagency body responsible for 

coordinating research on all hazardous deployments, recently began 

discussions on the first steps needed to develop a research plan for OIF.

35

At its January 2005 meeting, the working group tasked its research 

subcommittee to develop a complete list of research projects currently

under way that may be related to OIF.36 VA officials noted that because 

OIF is ongoing, the working group would have to determine how to 

address a study population that changes as the number of servicemembers 

deployed in support of OIF changes.37

Although no coordinated federal research plan has been developed, other 

separate federal research studies are underway that may follow the health

of OIF servicemembers. For example, in 2000 VA and DOD collaborated to

develop the Millennium Cohort study, a 21-year longitudinal study 

evaluating the health of both deployed and nondeployed military 

personnel throughout their military careers and after leaving military 

service. According to the principal investigator, the Millennium Cohort

study was designed to examine the health effects of specific deployments 

if enough servicemembers in that deployment enrolled in the study. 

However, the principal investigator said that as of February 2005 

researchers had not identified how many servicemembers deployed in

support of OIF had enrolled in the study. In another effort, a VA researcher 

has received funding to study mortality rates among OIF servicemembers. 

According to the researcher, if occupational and environmental data are 

No Federal Research Plan 

Exists for Using OEHS 

Reports to Follow the 

Health of OIF 

Servicemembers over Time 

 34GAO, Gulf War Illnesses: Federal Research Strategy Needs Reexamination, 

GAO/T-NSIAD-98-104 (Washington D.C.: Feb. 24, 1998).

35The Deployment Health Working Group includes representatives from DOD, VA, and

HHS. 

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

37Epidemiologic studies generally have a fixed study population that does not vary over

time, according to VA officials. 

Page 22 GAO-05-903T
available, the study will include the evaluation of mortality outcomes in 

relation to potential exposure for OIF servicemembers. 

As we stated in our report, DOD’s efforts to collect and report OEHS data

could be strengthened. Currently, OEHS data that the deployed military 

services have collected during OIF may not always be comparable because

of variations among the services’ data collection standards and practices. 

Additionally, the deployed military services’ uncertain compliance with

OEHS report submission requirements casts doubt on the completeness of

CHPPM’s OEHS archive. These data shortcomings, combined with 

incomplete data in DOD’s centralized tracking database of

servicemembers’ deployment locations, limit CHPPM’s ability to respond 

to requests for OEHS information about possible exposure to occupational

and environmental health hazards of those who are serving or have served

in OIF. DOD officials have said they are revising an existing policy on 

OEHS data collection and reporting to add additional and more specific

OEHS requirements. However, unless the military services take measures

to direct those responsible for OEHS activities to proactively implement 

the new requirements, the services’ efforts to collect and report OEHS 

data may not improve. Consequently, we recommended that the Secretary

of Defense ensure that cross-service guidance is created to implement 

DOD’s policy, once that policy has been revised, to improve the collection 

and reporting of OEHS data during deployments and the linking of OEHS 

reports to servicemembers. DOD responded that cross-service 

implementation guidance for the revised policy on deployment OEHS 

would be developed by the Joint Staff.

While DOD’s risk management efforts during OIF represent a positive step 

in helping to mitigate potential environmental and occupational risks of

deployment, the lack of systematic monitoring of the deployed military 

services’ implementation activities prevents full knowledge of their 

effectiveness. Therefore, we recommended that the military services

jointly establish and implement procedures to evaluate the effectiveness of

risk management efforts. DOD partially concurred with our

recommendation and stated that it has procedures in place to evaluate 

OEHS risk management through a jointly established and implemented 

lessons learned process. However, in further discussions, DOD officials 

told us that they were not aware of any lessons learned reports related to

OEHS risk management for OIF. 

Concluding

Observations 

Page 23 GAO-05-903T
Furthermore, although OEHS reports alone are not sufficient to identify

the causes of potential long-term health effects in deployed 

servicemembers, they are an integral component of research to evaluate 

the long-term health of deployed servicemembers. However, efforts by a 

joint DOD and VA working group to develop a federal research plan for 

OIF that would include examining the effects of potential exposure to

occupational and environmental health hazards have just begun, despite 

similarities in deployment location to the 1991 Persian Gulf War. As a 

result, we recommended that DOD and VA work together to develop a 

federal research plan to follow the health of servicemembers deployed in

support of OIF that would include the use of archived OEHS reports. DOD 

partially concurred with our recommendation, and VA concurred. The 

difference in VA and DOD’s responses to this recommendation illustrates a 

disconnect between each agency’s understanding of whether and how

such a federal research plan should be established. Therefore, continued

collaboration between the agencies to formulate a mutually agreeable

process for proactively creating a federal research plan would be

beneficial in facilitating both agencies’ ability to anticipate and understand

the potential long-term health effects related to OIF deployment versus 

taking a more reactive stance in waiting to see what types of health 

problems may surface. 

Mr. Chairman, this completes my prepared statement. I would be happy to 

respond to any question you or other Members of the Subcommittee may 

have at this time. 

For further information about this testimony, please contact Marcia

Crosse at (202) 512-7119 or crossem@gao.gov. Contact points for our 

Offices of Congressional Relations and Public Affairs may be found on the 

last page of this testimony. In addition to the contacts named above, 

Bonnie Anderson, Assistant Director, Karen Doran, Beth Morrison, John 

Oh, Danielle Organek, and Roseanne Price also made key contributions to

this testimony. 

GAO Contact and 

Staff 

Acknowledgments 

Page 24 GAO-05-903T
Page 25 GAO-05-903T

Appendix I: Example of an Occupational and 

Environmental Health Surveillance Summary 

Created by the Air Force 
(

290480) Pag

e 26GAO-05-903T
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