DEFENSE 

INFRASTRUCTURE

DOD Can Improve Its 

Response to 

Environmental 

Exposures on Military 

Installations

Report to Congressional Committees

May 2012

GAO-12-412

United States Government Accountability Office

GAO
United States Government Accountability Office

Highlights of GAO-12-412, a report to 

congressional committees

May 2012

DEFENSE INFRASTRUCTURE

DOD Can Improve Its Response to Environmental 

Exposures on Military Installations

Why GAO Did This Study

There have been various reported 

incidents of individuals being 

potentially exposed to environmental 

hazards while on military installations. 

Indeed, some incidents, such as 

contaminated air due to burn pits in 

Afghanistan and Iraq and 

contaminated water at Camp Lejeune, 

North Carolina, have received 

considerable attention, and in the case 

of Camp Lejeune have resulted in 

claims seeking billions of dollars from 

the government.

Public Law 111-383, §314(2011) 

directed GAO to assess Department of 

Defense (DOD) policies regarding 

environmental exposures. GAO’s 

objectives were to determine (1) the 

extent to which DOD has policies that 

identify and respond to environmental 

exposures, (2) what programs exist to 

provide health care or compensation to 

individuals for environmental 

exposures, and (3) which features of 

other federal programs may provide 

options in designing future 

compensation programs. GAO briefed 

the Armed Services Committees in 

December 2011, to satisfy the

mandate. To address these objectives, 

GAO reviewed relevant 

documentation, visited installations, 

and interviewed relevant officials. 

What GAO Recommends

GAO is making recommendations to 

DOD to identify and respond to

limitations in its policies for responding 

to environmental exposures. DOD 

generally disagreed with GAO’s

recommendations, commenting that 

current policies are adequate. GAO 

believes the recommendations remain 

valid, as discussed in the report.

What GAO Found

DOD relies on four types of policies to identify and respond to many but not all 

aspects of environmental exposures: (1) environmental restoration policies 

address hazardous releases at military Installations; (2) occupational and 

environmental health policies address workplace exposures; (3) deployment 

health policies address the collection of occupational and environmental health 

data for deployed individuals; and (4) public health emergency management 

policies. Nonetheless, there are some limitations in the policies’ coverage. For 

example, DOD’s environmental restoration policies do not specify when to 

conduct public health assessments at its sites beyond the initial assessment of 

certain priority sites required by the Superfund law. In addition, DOD has not fully 

documented its responses to recommendations that result from the 

assessments. DOD officials responsible for oversight reported that they did not 

know what actions, if any, installations had taken on about 80 percent of the 

recommendations. Without a comprehensive tracking system, DOD has no 

assurance that it is addressing recommendations appropriately and could be 

missing opportunities to identify and resolve concerns about some health threats. 

Further, DOD has no policy guiding services and their installations on appropriate 

actions to address health risks from past exposures, which DOD attributes to the 

Superfund law not specifically requiring responsible parties to address such risks.

Although several programs potentially provide either health care or compensation 

to various types of individuals suffering from environmental exposures, the ability 

of some individuals to actually obtain benefits—particularly compensation—is 

often complicated by documentary, scientific, and legal factors. First, it is often 

difficult to document an environmental exposure because they are often not 

always identified at the time they occurred. Second, it is often difficult to establish 

causation between an environmental exposure and a health condition, because 

scientific research has not always established a clear link. Third, although under 

certain circumstances some individuals have legal standing under the Federal 

Tort Claims Act to file a lawsuit against the U.S. government for damages due to 

an environmental exposure, damages under the Federal Tort Claims Act are not 

available to other types of individuals, and for certain types of claims due to legal 

precedent or statutes.

In several cases, Congress has established alternative programs to provide 

compensation to specific populations exposed to specific environmental hazards, 

such as for individuals involved in the production of nuclear weapons and those 

who worked in coal mines. Agency officials in charge of managing these

alternative programs told us that certain features of these programs have proven 

to be beneficial to both claimants and administrators and should be considered 

for inclusion if any future programs are established to compensate individuals for 

environmental exposures on military installations. For example, Department of 

Labor and Department of Justice officials told GAO a compensation program that 

resolves claims in a nonadversarial manner and provides outreach to potential

claimants is more beneficial to both claimants and administrators. In contrast, a 

more adversarial with limited claimant assistance usually leads to delays and 

increased cost for both claimants and the agency adjudicating claims.

View GAO-12-412. For more information, 

contact Brian Lepore at (202) 512-4523 or

LeporeB@gao.gov and David Trimble at (202)

512-9338 or TrimbleD@gao.gov. 
Page i GAO-12-412 Defense Infrastructure

Letter 1 

Background 5

DOD Has Policies for Identifying and Responding to Environmental 

Exposures but They Have Limitations 9

Several Programs May Provide Health Care or Compensation for 

Environmental Exposures but Access May Be Affected by 

Various Factors 23

Certain Features of Alternative Programs for Compensation 

Established for Specific Environmental Exposures May Provide 

Potential Options for Future Programs 34

Conclusions 44

Recommendations for Executive Action 45

Agency Comments and Our Evaluation 45

Appendix I Objectives, Scope, and Methodology 51

Appendix II Selected Contaminants That Have Been Found on Some Military 

Installations and Their Effect on Humans 54

Appendix III Significant Health Studies and Notification Efforts Related to 

Contamination at Marine Corps Base Camp Lejeune 56

Appendix IV Comments from the Department of Defense 57

Appendix V Comments from the Department of Veterans Affairs 61

Appendix VI Comments from Department of Health and Human Services 62

Appendix VII GAO Contacts and Staff Acknowledgments 64

Contents
Page ii GAO-12-412 Defense Infrastructure

Related GAO Products 65

Table

Table 1: Examples of Selected Data Collection Efforts during 

Phases of Deployment 14

Figure

Figure 1: Four Types of Policies That Address Environmental 

Exposures 10

Abbreviation

DOD Department of Defense

This is a work of the U.S. government and is not subject to copyright protection in the 

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Page 1 GAO-12-412 Defense Infrastructure

United States Government Accountability Office

Washington, DC 20548

May 1, 2012

The Honorable Carl Levin

Chairman

The Honorable John McCain

Ranking Member

Committee on Armed Services

United States Senate

The Honorable Howard P. “Buck” McKeon

Chairman

The Honorable Adam Smith

Ranking Member

Committee on Armed Services

House of Representatives

Over the years, there have been various reported incidents of active and 

former members of the Armed Forces, their dependents, federal 

contractors, and civilian employees being exposed to environmental 

hazards,1 such as contaminated air and water, while living and working 

on military installations2 or while deployed on contingency operations.3

 

1 For the purpose of this report, an environmental hazard includes, among other things, 

the release or occurrence of a contaminant in the environment including the air, water, 

and land. Exposures to contaminants occur when humans have skin contact, inhale, or 

ingest (such as in drinking water) such contaminants at a threshold of toxicity that can 

potentially cause an adverse health condition. These hazards also include environmental 

conditions, such as those in occupational settings that may be harmful to humans. 

Whether or not an exposure is harmful may depend, in part, on the dose delivered to 

individuals and their susceptibility to it.

2 Section 2687 of Title 10 of the United States Code defines military installation, for the 

purpose of certain base realignments and closures as a base, camp, post, station, yard, 

center, homeport facility for any ship, or other activity under the jurisdiction of the 

Department of Defense, including any leased facility. Such term does not include any 

facility used primarily for civil works, rivers and harbors projects, flood control, or other 

projects not under the primary jurisdiction or control of the Department of Defense.

3 Under 10 U.S.C. §101(13), the term “contingency operation” means a military operation 

that is designated by the Secretary of Defense as an operation in which members of the 

armed forces are or may become involved in military actions, operations, or hostilities 

against an enemy of the United States or against an opposing military force or results in 

the call or order to, or retention of, active duty of members of the uniformed services under 

certain sections of Title 10 or any other provision of law during a war or during a national 

emergency declared by the President or Congress.

 
 

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Several incidents in particular—contaminated air at Naval Air Facility 

Atsugi, Japan; contaminated air due to open burn pits in Afghanistan and

Iraq; and contaminated water at Camp Lejeune, North Carolina—have 

recently garnered considerable congressional, public, and media 

attention. At Naval Air Facility Atsugi, an off-base incinerator released 

toxic fumes that drifted over the installation. The Department of Veterans 

Affairs estimates that, from 1985 through 2001, over 25,000 individuals 

on the installation could have been exposed to air contaminants. 

Similarly, since the start of military operations in Afghanistan and Iraq, the 

U.S. military and its contractors have burned solid waste, including 

plastics, electronics, and appliances, in open burn pits on or near military 

bases. These burn pits have produced smoke and harmful emissions that 

military and other health professionals believe may cause acute and 

chronic health effects. Moreover, at Camp Lejeune in the early 1980s, 

volatile organic compounds were discovered in some water systems 

serving installation housing areas. Exposure to certain volatile organic 

compounds increases the risk of adverse health effects, including cancer. 

The Congressional Budget Office estimates that 650,000 individuals were 

stationed at Camp Lejeune at some point during the contamination 

period, which lasted about 30 years, and officials at the Agency for Toxic 

Substances and Disease Registry estimate that up to one million 

individuals could have been exposed. According to the Navy, some 

former residents and individuals who worked on Camp Lejeune have 

recently filed administrative claims against the U.S. government totaling 

billions of dollars in potential damages for health conditions alleged to 

have resulted from exposure to the contaminated water. However, the 

Department of Defense’s (DOD) response in identifying, studying, 

addressing, and communicating these three environmental hazards has 

raised congressional concerns in general about how DOD responds to 

possible individual exposures to environmental hazards on its 

installations. Congress has also expressed interest regarding how the 

U.S. government provides compensation and medical benefits for those 

who may have suffered adverse health effects from their exposure to 

such hazards.

Section 314 of the Ike Skelton National Defense Authorization Act for 

Fiscal Year 2011 set out a number of congressional findings related to 

military environmental exposures and directed GAO to conduct an 

assessment of possible exposures of individuals to environmental 
 

Page 3 GAO-12-412 Defense Infrastructure

hazards while living and working on military installations.4

To determine the processes DOD has in place for identifying and 

responding to possible exposures to environmental hazards we reviewed 

and analyzed relevant laws as well as guidance from DOD, the 

Environmental Protection Agency, and the Agency for Toxic Substance 

and Disease Registry. In conducting this analysis we conducted content 

searches of DOD guidance documents to determine the extent to which 

they addressed environmental exposures on military installations and 

conducted a literature search to determine if there were any best 

practices in responding to environmental exposures. We also examined 

the database used to track the Agency for Toxic Substance and Disease 

Registry public health assessment recommendations and DOD’s 

In response to 

that mandate, our objectives were to determine (1) the extent to which 

DOD has policies for identifying and responding to possible human 

exposures to environmental hazards on its installations, (2) what 

programs currently exist to provide health care and compensation to 

individuals for health conditions resulting from environmental exposures 

on military installations and any factors that may affect how these 

individuals obtain access to health care or compensation, and (3) what 

features of alternative federal programs that provide medical benefits or 

compensation to large groups of individuals affected by a specific 

environmental exposure may be considered as possible options in the 

design of any future programs for individuals harmed by environmental 

hazards. To satisfy the mandate, we provided a briefing to the House and 

Senate Armed Services Committees in December 2011. This report 

provides additional information on the topics addressed in response to 

that mandate.

 

4 Specifically, GAO was directed to report on (1) An identification of the policies and 

processes by which the Department of Defense and the military departments respond to 

environmental hazards on military installations and possible exposures and determine if 

there is a standard framework. (2) An identification of the existing processes available to 

current and former members of the Armed Forces, their dependents, and civilian 

employees to seek compensation and health benefits for exposures to environmental 

hazards on military installations. (3) A comparison of the processes identified under 

paragraph (2) with other potential options or methods for providing health benefits or 

compensation to individuals for injuries that may have resulted from environmental 

hazards on military installations. (4) An examination of what is known about the 

advantages and disadvantages of other potential options or methods as well as any 

shortfalls in the current processes. (5) Recommendations for any administrative or 

legislative action that the Comptroller General deems appropriate in the context of the 

assessment.
 

Page 4 GAO-12-412 Defense Infrastructure

implementation of those recommendations. In addition, we interviewed 

DOD officials at the Office of the Secretary of Defense and the various 

components, the Environmental Protection Agency, the National 

Research Council, Agency for Toxic Substance and Disease Registry, 

and some members of the Agency for Toxic Substance and Disease 

Registry’s Community Assistance Panel for Camp Lejeune. We also 

conducted site visits to Camp Lejeune, North Carolina and Aberdeen 

Proving Ground, Maryland where the Army Public Health Command, as 

DOD’s Executive Agent for interaction with the Agency of Toxic 

Substances and Disease Registry, has its offices. To determine the 

programs that currently exist within the federal government to provide 

health benefits and compensation to individuals, we obtained, reviewed, 

and analyzed relevant laws and regulations, agency guidance, and other 

documentation to identify the eligibility requirements and determination 

procedures and extent of compensation and medical benefits provided 

through various processes currently available to different types of 

individuals possibly exposed to environmental hazards while working or 

living on military installations. We also interviewed officials from DOD, 

Department of Veterans Affairs, Department of Labor, Department of 

Justice, and officials from each of the Army, Navy, and Air Force Judge 

Advocate Offices. To determine the features of alternative federal 

programs that provide medical benefits and monetary compensation we 

reviewed and analyzed relevant laws and regulations, agency guidance, 

external studies, previous GAO reports, and other documentation to 

identify other comparable federal programs that provide medical benefits 

and monetary compensation to large groups of individuals that have been 

exposed to a specific environmental hazard. Through discussions with 

Departments of Veterans Affairs, Labor, Justice, and other federal agency 

officials who administer these programs, we identified the key features 

associated with each program and any challenges and lessons learned 

among the different features of these programs.

We conducted this performance audit between May 2011 and May 2012, 

in accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives. (See app. I for more 

information on our scope and methodology.)
 

Page 5 GAO-12-412 Defense Infrastructure

Various environmental laws govern the identification, study, and cleanup 

of environmental contamination at military installations.5

• Comprehensive Environmental Response, Compensation, and 

Liability Act: Better known as “Superfund,” the 1980 act established, 

among other things, government authorities to respond to actual and 

threatened releases of hazardous substances, pollutants, and 

contaminants that may endanger public health and the environment.

Under a key law, 

a public health agency has responsibilities for assessing the presence 

and nature of health hazards at certain DOD sites, among other items. In 

addition, statutes also specify DOD responsibilities for cleanup of its 

contaminated sites. These are described below:

6

DOD uses its own environmental restoration appropriations to finance 

its cleanups.7

• The Agency for Toxic Substances and Disease Registry: The 

Agency for Toxic Substances and Disease Registry is to conduct 

a health assessment of each site listed on the National Priorities 

List. These health assessments may result in recommendations 

The Environmental Protection Agency places some of 

the most seriously contaminated sites on the National Priorities List; 

141 DOD installations are currently on this list. The Comprehensive 

Environmental Response, Compensation, and Liability Act also 

authorized the establishment of the Agency for Toxic Substances and 

Disease Registry in the Department of Health and Human Services to 

assess the presence and nature of health hazards to communities 

affected by Superfund sites, to inform actions to prevent or reduce 

harmful exposures, and to expand the knowledge base about the 

health effects that result from exposure to hazardous substances.

 

5 Generally, the federal environmental laws described here apply to DOD facilities within 

the United States and its territories.

6 Pursuant to the Comprehensive Environmental Response, Compensation, and Liability 

Act, the National Priorities List is a list of priority hazardous waste sites for attention under 

the federal Superfund program. Environmental Protection Agency places sites on the 

National Priorities List using criteria and a process established in regulations. Hazardous 

waste sites that are not placed on the National Priorities List may be referred to as nonNational Priorities List sites.

7 While Congress established a trust fund to pay for, among other things, remedial actions 

at nonfederal National Priorities List sites, the fund is not available for federal sites.

Background 

Some Federal Laws 

Requiring Cleanup of 

DOD’s Hazardous Waste 

Include Mechanisms to 

Consider Exposures
 

Page 6 GAO-12-412 Defense Infrastructure

from the Agency for Toxic Substances and Disease Registry to 

the agency responsible for the site and may include actions for 

reducing the public health risk or requests for additional data or 

analysis. The Agency for Toxic Substances and Disease Registry 

relies on records and data gathered by DOD and the 

Environmental Protection Agency for the assessments.8 With 

respect to toxic substance exposures, the agency is to maintain 

current research and literature on the health effects of toxic 

substances and prepare toxicological profiles, and, in cooperation 

with states, establish and maintain a national registry of serious 

diseases and illnesses and a national registry of persons exposed 

to toxic substances, among other things.9

• Superfund Amendments and Reauthorization Act: In 1986, the 

Superfund Amendments and Reauthorization Act added provisions to 

the Comprehensive Environmental Response, Compensation, and 

Liability Act, specifically governing the cleanup of federal facilities.10

These provisions also require the Secretary of Defense and the 

Secretary of Health and Human Services to enter into a memorandum 

of understanding regarding the manner in which DOD will support 

certain activities to be conducted by the Agency for Toxic Substances 

and Disease Registry, including the manner for transferring funds and 

personnel and for coordination of activities.11

 

8 The working relationship between DOD and the Agency for Toxic Substances and 

Disease Registry is established in a memorandum of understanding between the two 

agencies and they jointly develop annual work plans which require that DOD fund the 

Agency for Toxic Substances and Disease Registry’s efforts on DOD’s behalf. The 

Department of the Navy has also established a separate memorandum of understanding 

with the Agency for Toxic Substances and Disease registry for Camp Lejeune.

Under these provisions, 

a preliminary site assessment is to be completed by the responsible 

agency for each property where the agency has reported generation, 

storage, treatment, or disposal of hazardous waste. This preliminary 

assessment is reviewed by the Environmental Protection Agency, 

together with additional information, to determine whether the site 

poses a threat to human health and the environment or requires 

further investigation or assessment for potential inclusion on the 

National Priorities List.

9 42 U.S.C. § 9604(i) (2012).

10 Pub. L. No. 99-499 §120(a) (1986), codified at 42 U.S.C. § 9620 (2012).

11 10 U.S.C. § 2704(c) (2012).
 

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• Defense Environmental Restoration Program: Section 211 of the 

Superfund Amendments and Reauthorization Act established DOD’s 

Defense Environmental Restoration Program, providing legal authority 

and responsibility to DOD for cleanup activities at DOD installations 

and properties, including former defense sites12 in the United States 

and territories. DOD conducts cleanup activities under the Defense 

Environmental Restoration Program at its sites listed on the National 

Priorities List, as well as sites that are not. Among other things, the 

Defense Environmental Restoration Program provisions require the 

Secretary of Defense to take necessary actions to ensure that the 

Environmental Protection Agency and state authorities receive prompt 

notice of the discovery of a release or threatened release, the 

associated extent of the threat to public health and the environment, 

proposals to respond to such release, and initiation of any response.13

Specifically, when DOD identifies releases or threatened releases of 

hazardous substances, it is to notify the Environmental Protection 

Agency. These provisions also require the Secretary of Defense and 

the Secretary of Health and Human Services to enter into a 

memorandum of understanding regarding the manner in which DOD 

will support certain activities to be conducted by the Agency for Toxic 

Substances and Disease Registry, including the manner for 

transferring funds and personnel and for coordination of activities.14

Military installations are the site of various mission activities such as 

specialized operations and maintenance of equipment, as well as 

resembling “small cities” featuring offices, housing, water and wastewater 

systems, and solid and hazardous waste facilities. In some cases, these 

installations and surrounding areas became contaminated due to past 

storage and disposal practices for substances such as solvents, 

machining oils, metalworking fluids, and metals. Many of these 

contaminants, such as trichloroethylene, perchloroethylene, and vinyl 

chloride, are known or suspected carcinogens. On some installations, 

these contaminants have spread beyond their points of origin because 

 

12 Formerly used defense sites are located on properties that were under the jurisdiction 

of DOD and owned by, leased to, or otherwise possessed by the United States prior to 

October 17, 1986, but have since been transferred to states, local governments, other 

federal entities, or private parties. See 10 U.S.C. § 2701(c)(1)(B) (2010).

13 10 U.S.C. § 2705(a) (2010) (“Expedited notice”).

14 10 U.S.C. § 2704(c) (2012).

Contaminants on Military 

Installations and Pathways 

to Human Exposure
 

Page 8 GAO-12-412 Defense Infrastructure

they have been transported by wind currents or have entered ground 

water, resulting in potential environmental exposures.

An environmental exposure is quantified by estimating the amount (how 

much), duration (how long), and frequency (how often) of an individual’s 

exposure to a dose of a contaminant. The dose is a primary factor in 

whether the exposure may result in harm to the individual. Doses below 

health standards generally do not result in harm to the exposed 

individuals. For environmental exposures the routes of exposure are:

(1) ingestion—for solids and liquids; (2) inhalation—for gases and 

particulates; and (3) skin contact—for all types of agents. Some 

contaminants can cause harm at the site of exposure—for example, the 

lungs or skin—and some cause effects only after they have been 

absorbed into the blood stream and carried throughout the body. In their 

travel through the body, they have the potential to affect various organs in 

the body—such as lungs, liver, kidneys, heart, and brain. Appendix II 

contains a description of some of the contaminants found on military 

installations and their effects on humans.
 

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DOD has four types of policies to address aspects of environmental 

exposure: (1) environmental restoration policies that require the services 

to identify and respond to hazardous releases at military installations, 

(2) occupational and environmental health policies that require the 

services to identify and respond to unsafe or unhealthy activities in DOD 

workplaces, (3) deployment health policies that require the services to 

collect and analyze occupational and environmental health data for 

individuals deployed in military operations in order to help identify 

environmental exposures, and (4) public health emergency management 

policies that establish general guidance for responding to specific 

situations (see fig. 1). Limitations in DOD’s environmental restoration 

policies may hinder DOD’s ability to identify and respond to all 

environmental exposures.15 DOD recently updated a directive that 

complements these policies by including servicemembers’ dependents in 

its system for collecting, analyzing and interpreting health-related data—

called the health surveillance data system—when associated with a 

public health event such as a disease outbreak or widespread exposure 

incident.16

 

15 DOD has other policies that identify responsibilities and procedures for remediation of 

environmental contamination on overseas installations or facilities or caused by DOD 

operations. The policies are focused on remedies for “known imminent and substantial 

endangerments to human health and safety” and any applicable country-specific policy or 

international agreement, and are silent as to assessments of health risk from exposures. 

See DOD Instruction 4715.8 (1998), Deputy Secretary of Defense Memorandum, 

"Environmental Remediation Policy for DOD Activities Overseas," October 18, 1995.

16 DOD Directive 6490.02E, Comprehensive Health Surveillance, Feb. 8, 2012. The 

revised directive defines health surveillance as the regular or repeated collection, analysis, 

and interpretation of health-related data to monitor the health of a population and to 

identify potential health risks. The purpose is to enable timely intervention to prevent, 

treat, or control disease and injury. The health surveillance system is not exclusively 

focused on health issues related to environmental exposure. It also includes data on 

occupational (work-related) health and medical surveillance of health-related data in the 

military health system’s electronic medical records. 

DOD Has Policies for 

Identifying and 

Responding to 

Environmental 

Exposures but They 

Have Limitations
 

Page 10 GAO-12-412 Defense Infrastructure

Figure 1: Four Types of Policies That Address Environmental Exposures

Policies under the Defense Environmental Restoration Program, 

established by Section 211 of the 1986 Superfund amendments, require 

the services to identify and respond to hazardous releases at military 

installations and offer a structure for cleanup. Under the Defense 

Environmental Restoration Program, the services are required to identify 

relative risks to human health and the environment from contaminated 

DOD’s Environmental 

Restoration Policies 

Require the Services to 

Identify and Respond to 

Hazardous Releases at

Domestic Military 

Installations 
 

Page 11 GAO-12-412 Defense Infrastructure

sites––those areas with releases or threatened releases of hazardous 

substances. Because there have been thousands of contaminated sites 

on DOD properties, DOD prioritizes these sites for funding based on, 

among other things, whether a site presently poses a risk to human 

health. Within this program, DOD may conduct one or more response 

actions, such as investigation and cleanup of contamination from 

hazardous substances, pollutants, and contaminants, and demolition and 

removal of unsafe buildings and structures. The sidebar illustrates DOD’s 

approach to a hazardous release at a military installation.
 

Page 12 GAO-12-412 Defense Infrastructure

DOD’s Occupational and Environmental Health policies require the 

services to identify and respond to unsafe or unhealthy working 

conditions at military installations in the United States and abroad. The 

policies apply to DOD military and civilian personnel in any DOD 

workplace and certain contractors deployed with DOD.17,

18

DOD’s Occupational and Environmental Health policies also require the 

monitoring of workers exposed to hazards to identify work-related health 

problems and the collection of workplace hazards data to identify trends 

that may require intervention. The monitoring may include baseline 

medical examinations, periodic physical examinations, and clinical and 

biological screening. DOD’s manual on occupational medical 

examinations also suggests ancillary tests or biological monitoring to 

evaluate health issues such as blood, liver, renal, and pulmonary 

functions, and hearing loss.

Accordingly, 

the services are responsible for establishing and publicizing programs 

that encourage personnel to identify and promptly report to supervisors 

situations of imminent danger. In addition, according to these policies, the 

services must conduct surveys of workplaces to identify potential 

exposures and other worker safety and health risks, and establish 

workplace exposure profiles. They may also conduct periodic 

assessments to identify worksite environmental hazards.

19

 

17 DOD Instruction 6055.05 Occupation and Environmental Health (Nov. 11, 2008). While 

the instruction primarily covers DOD personnel in work settings, another stated purpose is 

to provide additional guidance to DOD Directive 4715.1E, Environment, Safety and 

Occupational Health (Mar. 19, 2005), to protect DOD personnel from accidents and 

occupational illness and the public from risk of death, injury, illness, or property damage 

because of DOD activities, among other objectives. With respect to protection of the 

public, the instruction does not specifically address any risky conditions or activities 

occurring outside of the workplace.

These tests seek to detect the biological 

effects of potentially serious exposures before the occurrence of clinical 

illness, at a point where intervention or treatment can decrease the 

severity of disease or limit disability and rehabilitation. Workers must be 

informed of the results of their occupational medical examinations as 

soon as possible following completion and are encouraged to alert a 

supervisor if they are concerned about a workplace hazard. When data 

18 The policy generally applies to contractor personnel deployed with the force. According 

to DOD, even in such situations, if contracts do not specify that DOD is responsible 

contractors are responsible for their personnel.

19 DOD Manual 6055.05-M, Occupational Medical Examinations and Surveillance Manual

(May 2, 2007).

DOD’s Occupational and 

Environmental Health 

Policies Require the 

Services to Identify and 

Respond to Unsafe or 

Unhealthy Working 

Conditions at Military 

Installations 
 

Page 13 GAO-12-412 Defense Infrastructure

suggest that an occupational environmental hazard exists, DOD’s 

occupational and environmental health policies call for the development 

of appropriate targeted intervention programs to reduce the occurrence of 

occupational injury and illness. The sidebar illustrates the use of this type 

of policy in a workplace condition.

DOD’s deployment health policies require the services to regularly collect 

and report a variety of data for deployed individuals to identify and 

respond to health threats they may have encountered during 

deployments. These policies apply to servicemembers, DOD civilian 

employees, and, depending on the contract, deployed DOD contractor 

personnel.20

 

20 DOD contractor personnel are only included to the extent provided in the applicable 

contracts, DOD Instruction 3020.41 (2005), or service policy.

These individuals may be subject to hazards that can include 

exposure to harmful levels of contaminants such as industrial toxic 

chemicals, chemical and biological warfare agents, and radiological and 

nuclear contaminants. Since harmful levels of exposure can result in 

immediate health effects or delayed or long-term health effects, the 

policies establish a system whereby DOD gathers and reports a variety of 

data on its servicemembers and civilian employees and examines the 

data over time to address specific exposure-related questions. DOD 

DOD’s Deployment Health 

Policies Require the 

Services to Collect and 

Analyze Data on 

Individuals in Deployment 

Settings 
 

Page 14 GAO-12-412 Defense Infrastructure

established specific guidance for the services in 2006 and again in 2007 

that lay out data collection requirements.21

DOD collects three types of data: (1) occupational and environmental 

health surveillance data, including ambient air, water, and soil samples; 

(2) daily individual servicemember location data, such as the duty station; 

and (3) health outcome data, acquired from servicemember medical 

records. The Defense Occupational and Environmental Health Readiness 

System (DOEHRS) Environmental Health module was developed to 

capture data about existing environmental conditions in contingency 

operations—military operations in which members of the armed forces 

are involved in actions against an enemy of the United States or against 

an opposing military force. Table 1 provides examples of the types of data 

collected before, during, and after deployment.

Table 1: Examples of Selected Data Collection Efforts during Phases of Deployment

Deployment phase Activity

Before deployment • Draw pre-deployment serum specimens for individual servicemembers.

• Update medical records and deployment health records for individual servicemembers.

• Conduct pre-deployment occupational and environmental health site assessments, including 

health risk assessments, of the deployment site.

During deployment • Conduct and validate health risk assessments of the deployment site.

• Conduct occupational and environmental health site assessments of the deployment site.

• Perform health surveillance activities to detect trends in the health of deployed personnel 

(includes biomonitoring, when required).

• Document occupational and environmental health monitoring data summaries and file in 

servicemembers’ deployment health records.

• Record servicemember location once daily and report out on a weekly basis.

Post-deployment • Complete post-deployment health assessments and reassessments of individual 

servicemembers.

• Draw post-deployment serum samples for individual servicemembers.

• Ensure all occupational and environmental health surveillance monitoring data and reports and 

health surveillance data and reports have been submitted. 

Source: DOD Instruction 6490.03.

Note: The steps listed in this table are required for all deployments outside the continental United 

States greater than 30 days with non-fixed U.S. medical treatment facilities; for other deployments, 

the relevant commander determines which steps are required.

 

21 DOD Instruction 6490.03, Deployment Health (Aug.11, 2006); and Joint Staff 

Memorandum MCM-0028-07 (Nov. 2, 2007).
 

Page 15 GAO-12-412 Defense Infrastructure

The Armed Forces Health Surveillance Center regularly monitors the 

health outcomes of both deployed and nondeployed servicemembers on 

a population-wide basis for abnormal trends that may indicate an adverse 

health outcome. In addition, it publishes a monthly report that reviews the 

incidence of a variety of deployment-related conditions, such as traumatic 

brain injury and motor vehicle accidents. The Millennium Cohort Study, an 

ongoing health evaluation led by the Naval Health Research Center, 

examines and issues reports on deployment-related health issues, for 

example the effects of deployment on servicemembers’ respiratory 

systems. 

While DOD has made progress in identifying potential occupational and 

environmental health hazards during deployments since the 1991 Gulf 

War, technological challenges remain. Currently, DOD estimates 

exposures using occupational and environmental health surveillance data 

coupled with individuals’ once-daily location tracking information, but 

cannot precisely determine exposure concentrations and durations that 

provide individuals’ unique exposure profiles. According to DOD officials, 

problems with collecting individual exposure data for all types of 

environmental exposures could be addressed in some cases by the use 

of certain dosimeters or exposure biomarkers,22 but such technologies 

have not been developed for all types of exposure hazards. DOD officials 

reported that DOD has partnered with the National Institute for 

Environmental Health Sciences and the National Research Council to 

learn more about the potential use of these technologies. They also told 

us that DOD is in the process of developing a personal dosimeter for 

naphthalene––a fuel component that may be carcinogenic––which they 

consider to be an important first step toward developing dosimeters for 

other chemicals and health threats. In addition to the technological 

limitations, DOD officials said there are logistical difficulties associated 

with the implementation of individual sampling devices on deployed 

personnel. The sidebar illustrates DOD’s data collection efforts and 

challenges in Afghanistan and Iraq.

 

22 Dosimeters are sensor devices that individuals wear to monitor real-time exposure to 

hazardous materials. Biomarkers of exposure consist of antibodies, metabolites, or the 

parent compound itself (or its metabolic products), present in biological fluids or tissues. 

Biomarkers of exposure indicate that the hazardous agents in the environment actually 

entered into the body (pathway completion) resulting in an exposure to that individual.
 

Page 16 GAO-12-412 Defense Infrastructure

DOD’s Public Health Emergency Management policy establishes 

guidance for the services in responding to public health emergencies, 

such as natural disasters or nuclear attacks, to protect installations, 

facilities, and personnel—including military and civilian personnel, 

dependents of military and civilian personnel, contractors, and other 

individuals visiting installations that are located either in or outside of the 

United States.23 While DOD officials told us the policy does not specify 

what steps should be taken immediately following an emergency, it does 

reference a number of other policies—including DOD’s Installation 

Emergency Management Program policy and Installation Chemical, 

Biological, Radiological, Nuclear, and High-Yield Explosive Emergency 

Response Guidelines—and gives the Under Secretary of Defense for 

Personnel and Readiness the authority to issue additional implementing 

guidance.24 DOD’s Installation Emergency Management Program policy 

aligns DOD emergency management activities with national 

preparedness and response guidelines and covers a range of potential 

hazards, including natural hazards, such as earthquakes and tsunamis, 

and human-caused hazards, including air or water contamination and 

terrorist attacks. According to a DOD official, each public health 

emergency is different, and the types of data that should be collected will 

depend on the significance of the hazard. This official told us that 

standard risk assessment models are applied in such emergencies and 

public health and occupational and environmental health professionals 

make decisions on how to respond on a case-by-case basis, based on 

what they perceive the health threat to be. The sidebar illustrates DOD’s 

response to the 2011 Fukushima Daiichi disaster in Japan.

 

23 In areas outside of the United States, DOD Instruction 6200.03 applies to the extent 

that it is consistent with local conditions, and the requirements of applicable treaties, 

agreements, and other arrangements with foreign governments and allied forces.

24 DOD Instruction 6055.17, DOD Installation Emergency Management (IEM) Program

(Jan. 13, 2009 with changes incorporated Sept. 16, 2008); and DOD Instruction 2000.18, 

Department of Defense Installation Chemical, Biological, Radiological, Nuclear, and HighYield Explosive Emergency Response Guidelines (Dec. 4, 2002).

DOD’s Policy on Public 

Health Emergency 

Management Establishes 

General Guidance and 

References Additional 

Documents for More 

Specific Guidance
 

Page 17 GAO-12-412 Defense Infrastructure

Because DOD’s environmental restoration policies do not fully address 

the use of public health assessments or what actions should be taken to 

respond to health risks that may have resulted from past exposures, 

DOD’s ability to identify and respond to environmental exposures on DOD 

installations may be limited. A goal of DOD’s strategic plan for 

installations is to provide effective, safe, and environmentally sound living 

and working places in support of DOD missions.25 Nonetheless, DOD 

policies under the Defense Environmental Restoration Program are silent 

regarding how to (1) document responses to public health 

recommendations and findings of significant risk, (2) specify when to 

conduct public health assessments beyond the initial assessment at 

National Priorities List sites,26

For DOD sites proposed for or listed on the National Priorities List, the 

Agency for Toxic Substances and Disease Registry conducts a public 

health assessment of the site that may result in recommendations to 

DOD.

and (3) respond to health risks associated 

with past environmental exposures.

27 Some assessments may also identify serious public health 

concerns known as “findings of significant risk.” The Defense 

Environmental Restoration Program’s management guidance states that 

DOD is to track the Agency for Toxic Substances and Disease Registry’s 

progress in completing public health assessments.28

 

25 Deputy Under Secretary of Defense, Installations and Environment, Defense 

Installations Strategic Plan, 2007.

This guidance is, 

however, silent regarding what actions DOD should take in response to 

26 While public health assessments are not required beyond the initial assessment, DOD 

officials stated that they can be useful. For example, restoration efforts that may take 

several years can include site characterization efforts that lead to additional information 

that could change the results of the initial health assessment. In addition, the initial 

assessments are required only at National Priorities List sites.

27 In 2010 we found that because the Agency for Toxic Substances and Disease Registry 

did not have policies and procedures that describe how the agency is to comprehensively 

assess and categorize the risk of work it initiates to prepare public health products, 

management could not ensure that it consistently managed the risk related to all new 

work, or established product preparation procedures commensurate with the risk. GAO, 

Agency for Toxic Substances and Disease Registry: Policies and Procedures for Public 

Health Product Preparation Should Be Strengthened, GAO-10-449 (Washington, D.C.: 

Apr. 30, 2010).

28 Office of the Deputy Undersecretary of Defense, Installations and Environment, 

Management Guidance for the Defense Environmental Restoration Program (September 

2001).

Limitations in DOD’s 

Environmental Restoration 

Policies May Hinder Its 

Ability to Identify and 

Respond to Exposures

DOD Has Not Fully 

Documented Responses to 

Public Health 

Recommendations 
 

Page 18 GAO-12-412 Defense Infrastructure

these recommendations and findings of significant risk or the timeliness of 

its response. According to a 1995 Guidelines document signed by the 

Deputy Under Secretary of Defense (Environmental Security) and the 

Assistant Surgeon General, DOD installations and the Agency for Toxic 

Substances and Disease Registry are supposed to report annually on 

actions taken in response to the recommendations resulting from health 

assessments, among other items. 29 A 2011 memorandum of 

understanding between DOD and the Department of Health and Human 

Services explicitly cites the Guidelines but gives no direction regarding its 

further implementation. The memorandum of understanding documents 

the working relationship between the two agencies but currently the 

process they follow does not ensure that status information on the 

recommendations is provided to or documented by the office of the DOD 

lead agent for the Agency for Toxic Substances and Disease Registry 

program. Status information may indicate that a recommendation has 

been fully implemented; a recommendation will be implemented in the 

future, as part of a planned study; DOD does not agree with a 

recommendation; or other relevant information. Under the Superfund law, 

department heads are to take steps to reduce the exposure and eliminate 

or substantially mitigate the risk if the Agency for Toxic Substances and 

Disease Registry finds that an exposure presents a significant risk to 

human health.30 Furthermore, federal internal control standards 

encourage the prompt resolution of audits and reviews, which would 

include public health assessments.

31

DOD developed a tracking system that identifies characteristics such as 

the date and nature of recommendations to particular installations; 

however, it does not always identify whether each installation responded 

to the recommendations or findings of significant risk. As a result, 

according to the DOD lead agent, the tracking system does not reflect 

 

29 Guidelines for the Coordination of the Comprehensive Response, Compensation and 

Liability Act (CERCLA) Activities Between the Agency for Toxic Substances and Disease 

Registry and the Department of Defense, February 1995.

30 42 U.S.C. § 9604(i)(11) (2012), 10 U.S.C. § 2704(e) (2012), Exec. Order 12580 § 2(k), 

52 Fed. Reg. 2923 (Jan. 23, 1987). 

31 GAO, Standards for Internal Control in the Federal Government, GAO/AIMD-00-21.3.1 

(Washington, D.C.: November 1999). According to these standards, government agencies 

are to promptly record the results of transactions and events that impact operations and 

ensure that the findings of audits and reviews are promptly resolved and communicated to 

management. 
 

Page 19 GAO-12-412 Defense Infrastructure

what actions, if any, DOD took on about 80 percent of the approximately 

1,200 recommendations made since the inception of the environmental 

restoration program.32

According to DOD officials, the installations are expected to elevate 

matters of concern with the public health agency’s recommendations to 

the Office of the Secretary of Defense as needed, but otherwise, the lead 

agent’s office does not systematically monitor recommendations or 

findings of significant risk. The Defense Environmental Restoration 

Program management guidance states that the Office of the Secretary of 

Defense provides oversight to the lead agent and components on Agency 

for Toxic Substances and Disease Registry involvement at installations. 

While DOD officials said they rely on individual installations to respond to 

recommendations from the Agency for Toxic Substances Disease 

Registry, without accurate data or a systematic means to track the status 

of responses to recommendations and findings of significant risk, the 

Office of the Secretary of Defense has no assurance that installations 

have responded to known public health risks. The sidebar illustrates 

DOD’s approach to a draft public health assessment with DOD-wide 

implications.

 

32 The DOD lead agent for the Agency for Toxic Substances and Disease Registry 

Program indicated that DOD has received almost 1,200 recommendations from the 

Agency for Toxic Substances and Disease Registry since the inception of the Defense 

Environmental Restoration Program. During the course of this engagement, DOD officials 

told us they are trying to obtain the status of Agency for Toxic Substances and Disease 

Registry recommendations from the installations.
 

Page 20 GAO-12-412 Defense Infrastructure

DOD’s Defense Environmental Restoration Program management 

guidance does not address if or when DOD components should 

voluntarily seek a public health assessment at National Priorities List sites 

beyond the initial assessment completed when a site is proposed for the 

list.33 After the initial public health assessment, it may take many years for 

site characterization and restoration. During that period additional 

contaminants or exposure pathways may be discovered that could make 

the original public health assessment obsolete. In addition, the guidance 

does not require public health assessments for non-National Priorities List 

sites, which could have environmental hazards equivalent to sites on the 

National Priorities List, and despite the fact that officials from the Agency 

for Toxic Substances and Disease Registry said that the majority of their 

DOD-related work in recent years involves non-National Priorities List 

sites.34 According to federal internal control guidelines, management 

should assess the risks faced from external (and internal) sources and 

decide what actions to take to mitigate them.35

DOD’s Defense Environmental Restoration Program is focused on 

cleanup to avoid present and future exposures but does not provide 

guidance on whether or when DOD should assess public health risks 

from past exposures or identify potentially affected individuals. For 

example, at Camp Lejeune, while environmental compliance and Defense 

Environmental Restoration Program policies were relevant to the actions 

While DOD officials said 

that DOD relies on the judgment of environmental professionals at the 

installations, without a standard set of guidelines on when to request a 

public health assessment other than an initial assessment for a site on 

the National Priorities List, DOD lacks assurance that it is consistently 

identifying and addressing possible health risks from exposures at some 

National Priorities List sites and non-National Priorities List sites.

 

33 See DOD, Defense Environmental Restoration Program Management Guidance (2008), 

p. 30. While the memorandum of understanding between DOD and the Agency for Toxic 

Substances and Disease Registry indicates that requests from installations to the Agency

for Toxic Substances and Disease Registry are to be coordinated through the service 

component and must be approved by DOD if deemed appropriate, program policies do not 

provide installations with information on whether and when they may request such 

assistance.

34 DOD had almost 34,000 non-National Priorities List sites in fiscal year 2010. As we 

have previously reported, 141 DOD sites were listed on the National Priorities List as of 

February 2012; only 2 DOD sites have been newly listed since 2005. 

35 GAO/AIMD-00-21.3.1. 

DOD’s Environmental 

Restoration Program Does Not 

Specify When to Conduct 

Public Health Assessments 

beyond the Initial Assessment 

at National Priorities List Sites

DOD Environmental 

Restoration Policies Do Not 

Address Health Risks from Past 

Exposures
 

Page 21 GAO-12-412 Defense Infrastructure

taken to provide safe drinking water and to begin investigating the 

groundwater contamination, there was no policy guiding installations on 

what actions it should consider to address past exposures. Instead, most 

actions to address past exposures have come about based on Agency for 

Toxic Substances and Disease Registry studies and congressional

direction.36

In determining priorities and requirements in the cleanup process, DOD 

officials told us DOD assesses relative risk to human health and the 

environment posed by contamination but does so in terms of present or 

future exposures; it generally does not identify or assess risks posed by 

past exposures.37

 

36 See John Warner National Defense Authorization Act of 2007, Pub. L. No. 109–364 § 

318 (Oct. 17, 2006) (requiring, among other things, the Navy to enter into an agreement 

with the National Academy of Sciences to conduct a comprehensive review and 

evaluation of the available scientific and medical evidence regarding associations between 

exposure to contaminated drinking water at Camp Lejeune and adverse health effects). 

Also, the National Defense Authorization Act for Fiscal Year 2008, Pub. L. No 110-181 § 

315 (Jan. 28, 2008) required, among other things, that the Secretary of the Navy make 

reasonable efforts to identify and notify directly certain individuals—those served by the 

contaminated water systems or civilian employees in particular time frames—who may 

have been exposed to the contaminated drinking water at Camp Lejeune. In addition, the 

act required that the Agency for Toxic Substances and Disease Registry develop a health 

survey that would voluntarily request personal health information from these individuals. 

The act stated that the survey may lead to scientifically useful health information 

associated with certain contaminants, such as trichloroethylene, tetrachloroethylene and 

vinyl chloride, identified in the Agency for Toxic Substances and Disease Registry studies 

that may provide a basis for further reliable scientific studies of potentially adverse health 

impacts of exposure to contaminated water at Camp Lejeune.

DOD officials told us that none of the cleanup laws 

require retroactive public health assessments or identification of 

individuals potentially affected by past exposures. However, officials from 

the Agency for Toxic Substances and Disease Registry also told us that, 

from a public health point of view, they consider it important to contact 

37 DOD officials told us that the Agency for Toxic Substances and Disease Registry, 

however, may consider risks posed by past exposures. DOD officials told us that there 

were only two examples of DOD attempting to identify individuals who might have been 

affected by past environmental exposures: (1) the ongoing efforts at determining the 

health effects of contaminated drinking water at Camp Lejeune; and (2) notifying, via the 

Internal Revenue Service, former residents about radon levels at higher than regulatory

standards in 2007 and 2008 in some housing at the Marine Corps Logistics Base, Albany, 

Georgia. The Agency for Toxic Substances and Disease Registry officials told us that, 

from a public health point of view, they would consider notification of prior site occupants 

when notification could result in actions that directly benefit people’s health, such as 

where past exposures are considered likely to have caused an increased incidence of a 

disease for which early screening has proven beneficial.
 

Page 22 GAO-12-412 Defense Infrastructure

prior site occupants when notification could result in actions that directly 

benefit people’s health. Moreover, where there has been a release of 

hazardous substances and where DOD is the lead agency, section 111(g) 

of the Superfund law, in conjunction with an executive order, requires 

DOD to notify potentially injured parties of such releases.38,39 However, it 

is not required to notify individuals directly; rather, it can issue a broad, 

public announcement, such as a newspaper notice.40 As a result, 

potentially affected individuals may not be aware of their exposure and 

subsequent health risks.

During the course of our review, we found that servicemembers’ 

dependents living on permanent overseas installations in nonemergency 

situations were not covered by any of the policies, but a revised policy

may reduce this gap. For example, servicemembers’ dependents, who 

were potentially exposed to contaminated air while at the Naval base in 

Atsugi, Japan, were not covered by any of the four types of policies. 

Specifically, according to DOD officials, the base was exempt from

(1) environmental restoration policies because these policies apply only in 

the United States,

41

 

38 Releases generally include any spilling, leaking, pumping, pouring, emitting, emptying, 

discharging, injecting, escaping, leaching, dumping, or disposing into the environment, 

including abandonment or discarding of barrels or containers. 40 C.F.R. § 300.5 (2012). 

Hazardous substances include substances such as toxic chemicals and hazardous 

wastes designated under Superfund and other laws.

(2) occupational and environmental health policies 

because the exposures occurred outside of the workplace, 

(3) deployment policies because permanent installations are not 

considered deployments, and (4) the public health emergency 

management policy because it did not fit the definition of a public health 

emergency. As such, no DOD policy existed to guide the Navy on their 

39 Section 111(g) directs the President to provide such notification. Executive Order 12580 

section 8, Employee Protection and Notice to Injured, delegates this responsibility to DOD 

for its facilities.

40 Comprehensive Environmental Response, Compensation, and Liability Act § 111(g), 42 

U.S.C. § 9611(g) (2012).

41 Outside the United States, the Defense Environmental Restoration Program does not 

apply; instead, environmental agreements may be negotiated with the host nation. The 

overseas environmental restoration policy does not specifically address exposures. See 

DOD Instruction 4715.8 (1998), Deputy Secretary of Defense Memorandum, 

"Environmental Remediation Policy for DOD Activities Overseas," October 18, 1995.

Revised DOD Policy May 

Reduce Previous Gap in 

DOD’s Response to 

Exposures 
 

Page 23 GAO-12-412 Defense Infrastructure

approach to conducting environmental surveillance, medical testing, or 

notification of the potentially exposed dependents. In February 2012, 

DOD revised its comprehensive health surveillance directive to include 

servicemembers’ dependents when collecting health surveillance data in 

the case of a possible environmental exposure or public health event at a 

domestic or overseas installation.42 DOD officials told us the revised 

directive has the potential to improve DOD’s response to environmental 

exposures, but not necessarily past exposures, since those would be 

addressed on a case-by-case basis. However, it is too soon to determine 

how this directive will be implemented and whether it will improve DOD’s 

ability to address dependents potentially affected by exposures.

Although several programs potentially provide either health care or 

compensation to active servicemembers, military retirees, veterans,

dependents, federal workers, or contractors suffering from adverse health 

conditions potentially caused by environmental exposures, the ability of 

some individuals to establish eligibility and actually obtain these 

benefits—particularly compensation—is often affected by documentary, 

scientific, and legal factors.

Servicemembers, veterans, military retirees, and their dependents, 

federal workers, and some contractors may have access to health care or 

health benefits either through the Departments of Defense, Labor, and 

Veterans Affairs, state workers’ compensation, or a private health care 

program regardless of the cause of the condition. Individuals, depending 

on their eligibility, may obtain health care or health benefits from one or 

more of the following programs:

• TRICARE: DOD’s TRICARE program may provide health care to 

servicemembers and their dependents, eligible National Guard and 

Reserve personnel and their dependents, and military retirees and 

their dependents and survivors. Servicemembers include members of 

the National Guard and Reserves on active duty for at least 30 days.43

 

42 DOD Directive 6490.02E, Comprehensive Health Surveillance (Feb. 8, 2012).

43 TRICARE is established under the authority of Chapter 55 of Title 10 of the United 

States Code.

Several Programs May 

Provide Health Care 

or Compensation for 

Environmental 

Exposures but Access 

May Be Affected by 

Various Factors

Several Programs May 

Provide Health Care or 

Health Benefits for 

Individuals Harmed by 

Environmental Exposures 

While Working or Residing 

on Military Installations
 

Page 24 GAO-12-412 Defense Infrastructure

• Veterans Health Administration: The Veterans Health 

Administration, within the Department of Veterans Affairs may provide 

health care to veterans, military retirees, and certain other individuals 

through numerous outpatient clinics, medical centers, and long-term 

health care facilities. The Veterans Health Administration may also 

provide health coverage to spouses, survivors, and children of 

veterans who are permanently and totally disabled from a serviceconnected disability or who died in the line of duty or from a serviceconnected disability.44

• Federal Employees’ Health Benefits: The Federal Employees’ 

Health Benefits program, which is administered by the Office of 

Personnel Management, may provide health care benefits to federal 

workers who choose to enroll.45

• Federal Employee Compensation Act: For appropriated fund 

employees, the Department of Labor’s Federal Employees 

Compensation Act program may provide benefits, including medical 

care, to covered employees who experience work-related injuries. 

When necessary, the Federal Employees Compensation Act program 

also provides vocational rehabilitation assistance to help injured 

workers return to work.46

• Nonappropriated Fund Instrumentalities Act: Under the 

Nonappropriated Fund Instrumentalities Act, an extension of the 

Longshore and Harbor Workers’ Compensation Act,47

 

44 See 38 U.S.C. §§1710 and 1781.

civilian 

employees employed by nonappropriated fund operations at domestic 

and overseas military bases (e.g., base exchanges, child care, food 

service, housekeeping, etc) may receive medical treatment for work45 See generally Chapter 89 of Title 5 of the United States Code.

46 See generally, Chapter 81 of Title 5 of the United States Code.

47 The Longshore and Harbor Workers’ Compensation Act, administered by the U.S. 

Department of Labor, provides medical benefits, compensation for lost wages, and 

rehabilitation services to longshoremen, harbor workers, and other maritime workers who 

are injured during the course of employment or suffer from diseases caused or worsened 

by conditions of employment. Several other statutes extend the provisions of the act to 

cover other classes of private-industry workers. These include workers engaged in the 

extraction of natural resources of the outer continental shelf, employees on American 

defense bases, and those working under contracts with the U.S. government for defense 

or public-works projects, outside of the continental United States.
 

Page 25 GAO-12-412 Defense Infrastructure

related injuries, including those resulting from environmental 

exposures. 48

• Defense Base Act: The Defense Base Act, an extension of the 

Department of Labor’s Longshore and Harbor Workers’ 

Compensation Program Act, requires U.S. government contractors 

and subcontractors to purchase workers’ compensation insurance 

coverage for their employees working overseas.49 This insurance 

would cover medical treatment required as a result of work-related 

injuries.50

• State Workers Compensation: Some state workers’ compensation 

programs may also provide health care benefits for work-related 

health conditions to contractors working in the United States, although 

eligibility requirements and benefits may vary from state to state. In 

some instances, the federal Longshore and Harbor Workers 

Compensation Act may provide such benefits.

The Departments of Defense, Veterans Affairs, and Labor, as well as 

some state workers’ compensation programs may also provide 

compensation to servicemembers, military retirees, veterans, federal 

workers, and contractors for service or work-related health conditions 

associated with issues such as exposure to environmental hazards. 

These programs include:

• DOD’s Disability Evaluation System: The Department of Defense 

Disability Evaluation System may provide compensation to 

servicemembers for service-connected health conditions. 

Servicemembers may receive either a lump sum for their health 

condition or monthly compensation, depending on the severity of the 

condition.

• Veterans Benefits Administration: The Veterans Benefits 

Administration programs within the Department of Veterans Affairs 

may provide monthly compensation to military retirees and veterans

 

48 See 5 U.S.C. §8171. Nonappropriated fund employees are civilian employees who are 

paid from funds that are not appropriated by Congress. Nonappropriated fund employees 

on military installations work, for example, in military exchanges and morale, welfare, and 

recreation programs.

49 Some exceptions may apply for employers who provide proof to the Secretary of Labor, 

showing the ability to pay compensation directly, and receive authorization to provide 

direct compensation.

50 See 42 U.S.C. §1651.

Several Programs May 

Provide Compensation for 

Individuals Harmed by 

Environmental Exposures 

While Working or Residing 

on Military Installations
 

Page 26 GAO-12-412 Defense Infrastructure

with service-connected health conditions and sometimes their 

dependents and survivors. 

• Federal Employees’ Compensation Act: The Federal Employees’ 

Compensation Act program may provide wage-replacement 

compensation to covered employees with work-related health 

conditions.

• Nonappropriated Fund Instrumentalities Act: The Nonappropriated 

Fund Instrumentalities Act, an extension of the Longshore and Harbor 

Workers’ Compensation Act, provides disability compensation for 

work-related injuries and survivor benefits for civilian employees 

employed by nonappropriated fund operations at domestic and 

overseas military bases (e.g., base exchanges, child care, food 

service, housekeeping, etc). Vocational rehabilitation services are 

available to assist permanently disabled workers to return to work.

• Defense Base Act: The Defense Base Act, an extension of the 

Longshore and Harbor Workers’ Compensation Act, may provide 

financial compensation to eligible civilian employees of U.S. 

government contractors with work-related health conditions who 

perform work overseas.

• State Workers Compensation: Some state workers compensation 

programs may provide wage-replacement compensation for workrelated health conditions to contractors at military installations within 

the United States, although eligibility requirements and benefits may 

vary from state to state. In some instances, the federal Longshore and 

Harbor Workers Compensation Act may provide such benefits.

Although spouses and dependents who are injured while residing on 

military installations may access health care through TRICARE or other 

health care programs, they are not eligible to receive financial 

compensation from the Departments of Defense, Veterans Affairs, or 

Labor, under the above programs, for adverse health conditions resulting 

from environmental exposures on military installations. They may, 

however, file a tort claim against the federal government seeking financial 

compensation under the Federal Tort Claims Act.51

 

51 28 U.S.C. §§1346(b), 2671-2680.

The act provides a 

means for some individuals injured by wrongful or negligent acts or 

omissions of federal employees to receive compensation from the U.S. 

government through an administrative claim process or, if not resolved at 

the administrative level, through the federal courts, subject to certain 

exceptions. For example, claimants will be unable to recover in cases in 
 

Page 27 GAO-12-412 Defense Infrastructure

which federal employees took actions that are susceptible to policy 

analysis.52

Although the above programs potentially provide either health care or 

compensation to active servicemembers, veterans, military retirees, and 

their dependents; federal workers; or contractors suffering from adverse 

health conditions potentially caused by environmental exposures, the 

ability of some individuals to establish eligibility and actually obtain these 

benefits—particularly compensation—is often affected by documentary, 

scientific, and legal factors.

Obtaining compensation for an environmental exposure may depend on 

an individual’s ability to document an actual exposure to a contaminant, 

since establishing a causal link between the exposure and the adverse 

health condition may be necessary for obtaining certain benefits or 

compensation under many existing adjudication processes. This usually 

requires not only documentation of a release of a contaminant but also 

that the individual was potentially exposed to the contaminant (i.e., in the 

area of the release at the time and place it occurred) at a level plausibly 

related to an adverse health outcome. However, it is often difficult to 

document the specific time, place, or level of an environmental exposure 

because such exposures are not always identified, defined, and 

measured at the time of the occurrence since adverse effects of the 

exposure may not be immediately apparent. This is true for environmental 

exposures both on and off military installations. When environmental 

exposures are not identified at the time of the release, the opportunity to 

collect data on both the level of exposure and individuals present at the 

time of the release may be lost. For example, in 2010 we reported that 

U.S. forces in Afghanistan and Iraq did not sample or monitor burn pit 

emissions as provided by a key U.S. Central Command regulation, and, 

as a result, the health impacts of burn pit exposure on individuals are not 

well understood. Although DOD and the Department of Veterans Affairs 

have commissioned studies to enhance their understanding of burn pit 

emissions, the current lack of data on emissions specific to burn pits and 

 

52 According to U.S. v. Gaubert, 499 U.S. 315, 323 (1991), “...the purpose of this 

exception is to prevent judicial ‘second-guessing’ of legislative and administrative 

decisions grounded in social, economic and political policy through the medium of an 

action in tort.” 

Access to Compensation Is 

Often Affected by 

Documentary, Scientific, 

and Legal Factors

Difficulty in Documenting an 

Environmental Exposure
 

Page 28 GAO-12-412 Defense Infrastructure

related exposures limit efforts to characterize potential health impacts on 

servicemembers and contractors.53

Additionally, it is often difficult to document those individuals who were 

potentially exposed to a harmful release because such exposures have 

not always been recorded in personnel medical files at the time they 

occurred. For example, after the Vietnam War one of the primary 

difficulties in determining who was exposed to Agent Orange in Vietnam 

was the lack of records.54

 

53 See 

Although many returning veterans suspected a 

scientific link between dioxin—a key contaminant in Agent Orange—and 

certain adverse health conditions, veterans filing claims and Department 

of Veterans Affairs officials adjudicating claims were hampered by a lack 

of information about who was in Vietnam when certain areas were 

sprayed with Agent Orange. In many cases, veterans and Department of 

Veterans Affairs adjudicators had to rely on rudimentary measures such 

as self-reports of exposure, service in Vietnam, military occupation, and

service in combat zones. Similarly, in 2005 we reported that most of the 

federal agencies identified as likely to have had employees in Vietnam—

DOD, the Central Intelligence Agency, 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. 

Officials from these agencies told us that it was difficult to identify 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 might have been destroyed or, if such records 

still existed, had not been indexed or organized in searchable formats. In 

addition, the location of some records was unknown because of the loss 

GAO-11-63. 

54 Agent Orange is a mixture of herbicides initially developed to control broad-leafed 

weeds in agricultural settings. In large quantities, it causes large-scale defoliation. It 

primarily was used during the Vietnam War to defoliate large areas in order to deprive the 

opposition forces of cover and food crops. Between 1962 and 1971, more than 21 million 

gallons of Agent Orange were sprayed across Southeast Asia. Though the military was 

unaware of it at the time of its initial use, it was later discovered that Agent Orange also 

contained a dioxin, which is a by-product of the manufacturing process. This dioxin is 

classified as a human carcinogen. According to the Department of Veterans Affairs, 

cancers currently associated with exposure to Agent Orange and other herbicides are 

chronic lymphocytic leukemia, Hodgkin’s lymphoma, multiple myeloma, non-Hodgkin’s 

lymphoma, prostate cancer, various respiratory cancers (lung, bronchus, larynx, trachea), 

and some soft tissue sarcomas. 
 

Page 29 GAO-12-412 Defense Infrastructure

of institutional knowledge resulting from staff turnover over the years.55

This lack of records may continue to be an issue, particularly for 

exposures occurring in the past that may at some point in the future result 

in adverse health conditions. For example, some veterans returning from 

Afghanistan and Iraq blame emissions from open air burn pits for several 

health conditions, including respiratory illnesses. However, the Institute of 

Medicine recently issued a report that was inconclusive regarding the 

connection between burn pit emissions and adverse health conditions. 

One of the major reasons cited by the Institute of Medicine for the 

inconclusive results was insufficient data on troops’ exposures to open air 

burn pits. According to the study, some of the incomplete information that 

hampered the Institute’s analysis included information on how many 

people worked in or near the pits, for how long, and how frequently.56

In many cases, obtaining compensation for an environmental exposure 

further depends on an individual’s ability to establish causation between 

an exposure and the adverse health condition, but this is often difficult 

because scientific research has not always established a clear link 

between the contaminant and an adverse health effect. This is true for 

environmental exposures both on and off military installations. Further 

complicating the matter is the fact that for many environmental exposures 

there is a latency period—the time period from initial exposure to a 

contaminant and the date an adverse health condition is diagnosed. 

When there is a long latency period between an environmental exposure 

and an adverse health condition, choosing between multiple causes of 

exposure may be difficult. Where multiple alternative causes are present, 

science is often unable to demonstrate that a particular individual’s 

environmental exposure was the cause of the condition. For example, it is 

difficult to definitively rule out other environmental or lifestyle risk factors 

that could have caused the condition during the years between the 

exposure and the appearance of the condition. Indeed, another major 

reason cited by the Institute of Medicine for the inconclusive results of 

their burn pit study was high background levels of ambient pollution from 

other sources, such as diesel fumes and dust that might also be 

 

55 GAO, Agent Orange: Limited Information is Available on the Number of Civilians 

Exposed in Vietnam and Their Workers’ Compensation Claims, GAO-05-371

(Washington, D.C.: Apr. 22, 2005).

56 Institute of Medicine, Long-Term Health Consequences of Exposure to Burn Pits in Iraq 

and Afghanistan (Washington, D.C.: Oct. 31, 2011).

Difficulty in Scientifically 

Linking an Environmental 

Exposure to Health Condition
 

Page 30 GAO-12-412 Defense Infrastructure

responsible for the respiratory conditions. According to the Institute of 

Medicine, because of the existence of these pollutants, it could not 

establish a conclusive link between burn pit emissions and the adverse 

health conditions being experienced by some individuals.

The water contamination at Camp Lejeune further underscores the 

difficulties associated with these documentary and scientific factors. 

Specifically, little data exist regarding Camp Lejeune’s past water quality 

tests and the extent to which contaminants were found in the water. As a 

result, the Agency for Toxic Substances and Diseases Registry is 

conducting a water modeling assessment to fill in the gaps in the data. 

The Agency for Toxic Substances and Diseases Registry hopes the water 

modeling will help identify the time and place certain areas at Camp 

Lejeune received contaminated drinking water and ultimately help to 

determine who was exposed, at what levels, and for how long. For 

example, the data collection efforts for the Agency for Toxic Substances 

and Diseases Registry’s studies revealed that the area serviced by 

Holcomb Boulevard water system on Camp Lejeune received water that 

may have contained volatile organic compounds for a longer period than 

was previously thought. Furthermore, once it has been established that a 

veteran was exposed to contaminated water at Camp Lejeune, the 

Department of Veterans Affairs needs to determine whether the alleged 

health condition can generally be caused by the exposures received 

during service and whether the health condition in a specific claim was 

caused by the exposure in deciding whether to provide compensation. 

These difficulties may affect veterans’ ability to obtain benefits and 

compensation. Data provided by the Department of Veterans Affairs show 

that in calendar year 2011, the department completed decisions on 849 

claims from veterans alleging an adverse health condition resulting from 

the contaminated water at Camp Lejeune. Of these 849 claims, 212

(25 percent) claims were granted and 637 (75 percent) were denied. 

According to the Department of Veterans Affairs, those claims that were 

denied failed to demonstrate one or more of the following: (1) service at 

Camp Lejeune during the period of water contamination, (2) a current 

disease or disability, or (3) a medical nexus or link between a current 

disability and service at Camp Lejeune. According to the Department of 

Veterans Affairs, a total of 1,151 claims are still being adjudicated.

Active duty servicemembers, military retirees, veterans, and other federal 

workers are able to seek compensation through Departments of Defense, 

Veterans Affairs, and Labor programs, but other individuals may need to 

seek a remedy under the Federal Tort Claims Act. Certain individuals 

have legal standing under the Federal Tort Claims Act to file a lawsuit 

Difficulty in Seeking a Remedy 

for an Environmental Exposure 

under the Federal Tort Claims 

Act 
 

Page 31 GAO-12-412 Defense Infrastructure

against the U.S. government for damages due to an environmental 

exposure under some circumstances. But damages under the Federal 

Tort Claims Act are not available to other types of individuals, and for 

certain types of claims, due to legal precedent or statutes. For example, 

most active duty servicemembers, military retirees, and veterans may not 

bring suit under the Federal Tort Claims Act due to the doctrine outlined 

in the Supreme Court case Feres v. United States,

57

Although the Federal Employees’ Compensation Act effectively bars 

federal workers and their dependents from pursuing compensation 

through tort claims in civil lawsuits,

and its successor 

cases, for personal injuries that arise incident to their military service, and 

such claims or lawsuits they attempt to file under the Federal Tort Claims 

Act are subject to dismissal. However, active duty servicemembers, 

military retirees, and veterans may be eligible for compensation through 

Department of Defense or Veterans Affairs programs. Similarly, the 

Federal Employees’ Compensation Act provides the exclusive remedy for 

federal workers and their dependents if the worker is injured or killed in 

the performance of duties. Thus, the disability compensation, medical, 

and other benefits provided for under the Federal Employees’ 

Compensation Act are the exclusive means by which federal workers can 

seek compensation from the U.S. government. While compensation 

programs are established for some individuals who work on military 

installations, others, including dependents and contractors, may choose 

to pursue legal damages from the U.S. government, under the Federal 

Tort Claims Act, for injuries they sustained as a result of an environmental 

exposure.

58 employees of government 

contractors may pursue damages from the U.S. government for an 

environmental exposure received on the job and dependents of active 

duty servicemembers may seek compensation for their own personal 

injuries. However, success under the Federal Tort Claims Act may be 

unlikely. The discretionary function exception within the Federal Tort 

Claims Act prevents recovery for health conditions caused by 

discretionary actions or omissions of federal employees in cases in which 

the employees’ actions are susceptible to policy analysis.59

 

57 Feres v. United States, 340 U.S. 135 (1950).

According to 

58 5 U.S.C. §8116 (c).

59 28 U.S.C. §2680 (a).
 

Page 32 GAO-12-412 Defense Infrastructure

Department of Justice officials, this includes many decisions made by 

federal personnel, although not in cases where the government ignores a 

specific and mandatory agency rule or policy. Department of Justice 

officials told us that, as a result, many claims against the U.S. 

government alleging harm due to governmental negligence are eventually 

dismissed.

According to Navy officials, as of January 2012, about 2,900 former 

residents and former employees of Camp Lejeune had filed administrative 

claims against the U.S. government for adverse health effects, alleged to 

have resulted from contaminated water, seeking billions of dollars in 

potential damages. In accordance with limitations on adjudication of 

claims, set out in the National Defense Authorization Acts for Fiscal Years 

2011 and 2012,60 the Navy stated it is currently not adjudicating these 

claims, and is awaiting the outcome of several ongoing and planned 

studies by the Agency for Toxic Substances and Diseases Registry. In 

addition to filing administrative claims with the Navy, some claimants 

have also exercised their rights under the Federal Tort Claims Act and

filed lawsuits against the U.S. government in federal district courts. 

According to the Department of Justice, as of March 2012, 12 of the 

approximately 2,900 administrative claims had resulted in the filing of 

lawsuits in federal district court. Among other things, we were told that 

some of these lawsuits seek damages for various physical ailments and 

emotional distress alleged to have resulted from the government’s alleged 

negligence in protecting the water supply at Camp Lejeune. Furthermore, 

Department of Defense officials told us that lawsuits have been filed in 

federal court in at least 43 states in which current and former 

servicemembers have alleged, among other things, that a contractor’s 

negligent management of burn pit operations, contrary to applicable 

contract provisions, exposed them to air pollutants that subsequently 

caused adverse health conditions. According to officials, the contractor 

has moved to dismiss the suits, arguing, among other things, that it 

cannot be held liable for any health conditions that may have occurred to 

service personnel because its burn pit activities occurred at the direction 

of the military.

 

60 Limitations on adjudication are found in The Ike Skelton National Defense Authorization 

Act for Fiscal Year 2011, Pub. L. No. 111-383, §313 (2011).and the National Defense 

Authorization Act for Fiscal Year 2012, Pub. L. No. 112-81, §319 (2011). 
 

Page 33 GAO-12-412 Defense Infrastructure

In an effort to limit some of the difficulties associated with these factors, 

Congress has, in some cases, created presumptions that bridge gaps in 

the evidence related to causation and documentation, making it easier for 

a group of veterans to be compensated. For example, to qualify for a 

Department of Veterans Affairs disability compensation claim, a veteran is 

normally required to demonstrate the following: (1) that a health condition 

currently exists, (2) that an event of disease or injury occurred or was 

aggravated in the line of duty, and (3) that a medical connection or 

“nexus” can be shown between the service event and the existing health 

condition. However, when the exposures of military personnel in Vietnam 

to Agent Orange could not be clearly documented, Congress enacted 

legislation establishing the presumption that veterans who served in 

Vietnam during a specified time frame, and subsequently developed 

certain health conditions, provided in the statute or prescribed in 

regulations, had been exposed.61,62

In addition, DOD and Department of Veterans Affairs officials told us they 

are taking steps to overcome some of the difficulties in confirming 

scientific links between certain contaminants and adverse health 

conditions and in maintaining documentation regarding environmental 

exposures. DOD officials told us they are potentially implementing an 

electronic individual longitudinal exposure record for every 

servicemember that would be designed to provide linkages between 

differing types of data—environmental monitoring, biomarkers, and troop 

locations and activity—and an individual’s medical records. DOD and the 

Department of Veterans Affairs are also conducting scientific studies 

designed to follow a large group of individuals over a long period of time 

to determine any increased incidence of diseases, including those due to 

a potential environmental exposure. For example, the Millennium Cohort 

Study, an ongoing health evaluation led by the Naval Health Research 

Center, is targeted at examining deployment-related health conditions by 

comparing a cohort of servicemembers that were deployed and a cohort 

This presumption relieves the veteran 

of proving one or more of the eligibility requirements for direct service 

connection and shifts the burden of proof from the veteran to the 

government in order to rebut the presumption. 

 

61 Agent Orange Act of 1991, Pub. L. No. 102-4 (1991), as amended.

62 38 U.S.C. §1116. Similar statutory presumptions exist for prisoners of war, veterans 

exposed to ionizing radiation, and those who served in Southwest Asia during the Gulf 

War.

Actions Taken to Limit 

Difficulties Associated 

with These Factors
 

Page 34 GAO-12-412 Defense Infrastructure

that was not deployed. According to Department of Veterans Affairs 

officials, conducting these types of scientific studies will provide 

documentation and scientific information on adverse health conditions, 

that if found to be significantly different between deployed and 

nondeployed servicemembers, may provide officials with information to 

further examine the link between potential environmental exposures and 

adverse health conditions. These efforts may provide exposure-related 

documentation that is currently not readily available, and may remove 

some of the burden of documenting an environmental exposure.

Beyond the previously discussed traditional avenues generally available 

for seeking compensation for work-related injuries or injuries resulting 

from an environmental exposure, Congress has, in some cases, 

established alternative programs to provide compensation and some 

medical benefits to specific populations harmed by specific environmental 

exposures. The structures of these alternative programs for 

compensation vary and the programs are not generally designed to 

address all past or future environmental exposures occurring on military 

installations, such as those discussed in this report. However, in the past 

few years, Congress has considered several legislative options to provide 

benefits and compensation for certain individuals exposed to specific 

environmental hazards on military installations.63 Some features of the 

alternative programs for compensation may help to inform any future 

compensation programs that Congress may choose to create. 

 

63 Caring for Camp Lejeune Veterans Act of 2011, S. 277, 112th Cong. (2011), the Janey 

Ensminger Act, H.R. 1742, 112th Cong. (2011) and the Examination of Exposures to 

Environmental Hazards During Military Service and Health Care for Camp Lejeune and 

Atsugi Naval Air Facility Veterans and their Families Act of 2010, S. 3378, 111th Cong. 

(2010).

Certain Features of 

Alternative Programs 

for Compensation 

Established for 

Specific 

Environmental 

Exposures May 

Provide Potential 

Options for Future 

Programs
 

Page 35 GAO-12-412 Defense Infrastructure

In a few instances, Congress has established alternative programs for 

compensating specific populations harmed by specific environmental 

exposures that take the place of traditional avenues for seeking 

compensation and may help overcome some of the challenges in 

compensating individuals for health conditions that result from

environmental exposures. We identified three such programs64 designed 

to provide compensation and medical benefits to U.S. citizens harmed by 

exposure to contaminants and examined the programs’ structure and 

features for providing benefits.65

• The Radiation Exposure Compensation Program

These programs are:

66

• The Energy Employees Occupational Illness Compensation 

Program

provides partial 

restitution to eligible onsite participants, uranium miners, millers, and 

ore transporters, and nearby populations who were exposed to 

radiation from atmospheric nuclear weapons testing, or as a result of 

their employment in the uranium mining industry during the Cold War, 

and developed certain adverse health conditions.

67

• The Black Lung Program

provides compensation and medical benefits to eligible 

nuclear weapons workers and their survivors harmed from exposure 

to radiation or toxic contaminants.

68

 

64We identified one other environmental exposure-related compensation program, the 

Marshall Islands Nuclear Claims Tribunal, but did not include it our analysis because it 

does not provide compensation to U.S. citizens.

provides medical and income assistance 

to eligible individuals who were exposed to coal mine dust through 

work in the mines and were diagnosed with totally disabling 

pneumoconiosis (black lung disease). In such cases, the former 

65 Congress has also established compensation programs for injuries or death for injuries 

caused by factors other than environmental exposures, such as the Smallpox Vaccine 

Injury Compensation Program and the National Vaccine Injury Compensation Program. 

However, our analysis only included programs that provide compensation for injuries 

caused by an exposure to a harmful contaminant in the environment, not, for example, as 

a result of a vaccine. See app. I for a complete description of our compensation program 

selection criteria.

66 See the Radiation Exposure Compensation Act, Pub. L. No. 101-426 (1990), codified at 

42 U.S.C. §2210 note, as amended.

67 See the Energy Employees Occupational Illness Compensation Act of 2000, Title 

XXXVI of the Floyd D. Spence National Defense Authorization Act for Fiscal Year 2001, 

Pub. L. No. 106-398 (2000), codified at 42 U.S.C. §§7384- 7385s-15, as amended.

68 See Title IV of the Federal Coal Mine Health and Safety Act of 1969, Pub. L. No. 91-

173 (1969), codified at 30 U.S.C. Chapter 22, Subchapter IV, as amended.

Congress Has Established 

Alternative Programs for 

Compensation for Specific 

Populations Harmed by 

Specific Environmental 

Exposures 
 

Page 36 GAO-12-412 Defense Infrastructure

miner’s income assistance may be augmented on behalf of certain 

dependent family members. The program also provides income 

assistance to the survivors of miners who died due to black lung 

disease and to certain survivors of miners who were awarded benefits 

as a result of lifetime claims.

69

While these alternative programs for compensation were each designed 

to compensate individuals injured by exposure to harmful contaminants, 

the way in which the programs are structured varies, including who 

administers the program, how it is funded, and the benefits it provides. 

For example:

The sidebar illustrates how costs in 

these three programs exceeded initial estimates as the federal role in 

the programs expanded. 

• Administration: The administration of the programs differs. For 

example, the Department of Justice administers the Radiation 

Exposure Compensation Program. In contrast, the Department of 

Labor administers the Black Lung Program, and shares responsibility 

for administering the Energy Employees Occupational Illness 

Compensation Program with the Departments of Health and Human 

Services, Energy and Justice. Responsibility for administering the 

Black Lung Program has changed since its inception. Specifically, 

claims for the Black Lung Program were initially processed and paid 

by the Social Security Administration but, as designed by the original 

legislation, the Department of Labor began processing claims in 1973 

and took over all Black Lung Program claims processing in 1997. In 

2002, Congress officially transferred all legal responsibility and 

funding for the program to the Department of Labor.

• Funding: Funding for the three programs varies. Although initially 

funded solely through annual appropriations, the Black Lung Program 

is now funded largely by the coal mining industry. Individual claims 

are paid either by a responsible coal mine operator (or its insurance 

carrier) or by the Black Lung Disability Trust Fund, which is financed 

by an excise tax on coal and supplemented by additional funds. In 

contrast, the Energy Employees Occupational Illness Compensation 

Program and the Radiation Exposure Compensation Program are 

completely federally funded.

 

69 Black lung is a term that includes coal workers’ pneumoconiosis and any other chronic 

respiratory or pulmonary impairment arising out of coal mine employment. 30 U.S.C.§ 902 

(b). 
 

Page 37 GAO-12-412 Defense Infrastructure

• Benefits: Benefits also vary among the three programs. Some of the 

benefits they provide include lump sum compensation payments and 

payments for lost wages, medical and rehabilitation costs, and 

attorney’s fees. For example, the Black Lung Program provides 

diagnostic testing for miners; monthly payments based on the federal 

salary scale for eligible miners or their survivors; medical treatment for 

eligible miners; and, in some cases, payment of claimants’ attorney 

fees. The Radiation Exposure Compensation Program, in contrast, 

provides only a lump sum payment for restitution to those that 

developed adverse health conditions or their survivors.

In the past few years, Congress has considered several legislative 

options to specifically provide compensation and benefits for individuals 

exposed to specific environmental hazards on military installations.

70

The Radiation Exposure Compensation Program and the Energy 

Employees Occupational Illness Compensation Program resolve claims in 

a nonadversarial manner; thus, claims are adjudicated through a process 

in which the adjudicator investigates the facts of the case to determine 

the eligibility of the claimant.

The 

alternative programs for compensation that we examined contain certain 

features that may provide potential options if future programs for 

environmental exposure compensation are considered. These features 

address such issues as whether to use an adversarial or nonadversarial 

approach to adjudicating claims, the kinds of outreach and claims 

assistance offered, how eligibility for benefits is determined, and the 

frequencies and types of payments when such compensation is awarded.

71

 

70 Caring for Camp Lejeune Veterans Act of 2011, S. 277, 112th Cong. (2011), the Janey 

Ensminger Act, H.R. 1742, 112th Cong. (2011) and the Examination of Exposures to 

Environmental Hazards During Military Service and Health Care for Camp Lejeune and 

Atsugi Naval Air Facility Veterans and their Families Act of 2010, S. 3378, 111th Cong. 

(2010). 

In contrast, the Black Lung Program is 

adversarial; thus, claims are adjudicated through a process in which two 

opposing parties, such as the coal miner and his former employer, 

present their arguments for and against awarding compensation, and 

71 See generally, 28 C.F.R. Part 79 for regulations pertaining to claims filed under the 

Radiation Exposure Compensation Program Act and 20 C.F.R. Part 30 for regulations 

pertaining to claims filed under the Energy Employees Occupational Illness Compensation 

Act. 

Certain Features of These 

Programs May Provide 

Potential Options for 

Future Programs

Nonadversarial versus 

Adversarial Proceedings 
 

Page 38 GAO-12-412 Defense Infrastructure

responsibility for the payment of benefits is assigned to the liable party if 

the claim is approved.

72 In this process, the coal mine operators typically 

serve as the opposing party to the claimant, and if a claimant is awarded 

benefits, the mine operator determined to be the responsible employer of 

the miner must generally pay the benefits, either directly or through 

insurance. If no mine operator can be held liable for payments, the Black 

Lung Disability Trust Fund pays the cost of black lung claims from funds 

collected through an excise tax on coal.

Department of Labor officials told us that they prefer the nonadversarial 

features of the Radiation Exposure Compensation Program and the 

Energy Employees Occupational Illness Compensation Program because 

these features can improve the timeliness of processing claims. 

Conversely, the adversarial features in the Black Lung Program have 

contributed to delays in reaching a final disposition of claims by allowing 

opposing parties to provide evidence to refute initial claims and to appeal 

claim decisions. For example, a party displeased with the initial decision 

of the Division of Coal Mine Workers’ Compensation in the Department of 

Labor’s Office of Workers’ Compensation Programs can request a 

hearing with a Department of Labor Administrative Law Judge within 30 

days after the Office of Workers’ Compensation Program decision is filed. 

Dissatisfied parties can appeal Administrative Law Judge decisions to the 

Department of Labor Benefits Review Board and Benefits Review Board 

decisions can be appealed to the appropriate United States Circuit Court 

of Appeals. Finally, Circuit Court of Appeals decisions may be appealed 

to the Supreme Court of the United States. In 2009, GAO found that this 

structure led to a high rate of appeals that prolong the resolution of 

claims.73 Both miners and coal mine operators frequently seek appeals, 

and for those claimants awarded compensation during the initial 

adjudication in fiscal year 2008, the coal mine operators found liable 

appealed the decision approximately 80 percent of the time.74

 

72 See generally 20 C.F.R. Part 725 for regulations pertaining to the claims process of the 

Black Lung Program.

Since 

decisions are routinely appealed, GAO previously found that each level of 

appeal review can take up to a year to adjudicate; ultimately, a claim may 

remain in the adjudication process for years with the administering federal 

73 GAO, Black Lung Benefits Program: Administrative and Structural Changes Could 

Improve Miners’ Ability to Pursue Claims,GAO-10-7 (Washington, D.C.: Oct. 30, 2009).

74 GAO-10-7. 
 

Page 39 GAO-12-412 Defense Infrastructure

agency incurring the cost for the years of processing the claim. For 

example, for claims between 2001 and 2008, 28 percent of the claims of 

miners awarded compensation from coal mine operators spent 3 to 8 

years within the adjudication process.75 During this period, the claimant’s 

ultimate entitlement to compensation will remain in doubt. 76

All three programs provide outreach and assistance services to potential 

claimants. The Energy Employees Occupational Illness Compensation 

Program sponsors outreach activities, including town hall meetings and 

traveling resource centers, to disseminate information about benefits and 

provide assistance to claimants in applying for benefits. For the Black 

Lung Program, 15 black lung grantees, which provide specialized 

diagnosis and treatment services, outreach, and educational programs to 

help patients and their families deal with the disease have been 

established through grants from the Department of Health and Human 

Services. The Radiation Exposure Compensation Program has 

established grant-based Radiation Exposure Screening and Education 

Programs that support programs for health screening, education, medical 

referral, and appropriate follow-up services for eligible individuals.

Departments of Labor and Justice officials told us that when programs 

provide outreach and assistance to potential claimants both claimants 

and administrators benefit because the filed claims are more complete 

and contain fewer errors. For the Radiation Exposure Compensation 

Program, these features allow program administrators to meet with 

citizens, respond to questions about the program, conduct town hall 

meetings, and assist in filling out claim forms. For the Energy Employees 

Occupational Illness Compensation Program, town hall meetings have 

provided information to more remote locations where individuals may not 

have known they might have been exposed to radiation and, according to 

the Department of Labor’s 2009 annual report, this outreach resulted in 

86 new claims in fiscal year 2009. In addition, resource centers located 

near major Department of Energy facilities helped claimants complete 

necessary claim forms and gather documentation such as employment 

 

75 GAO-10-7. 

76 The adversarial system in the Black Lung Program does not delay commencement of 

an awarded claimant’s benefits, however; the program provides that benefits shall be paid 

to awarded claimants prior to the final adjudication of the claim. If the responsible operator 

does not voluntarily pay interim benefits, the Black Lung Disability Trust Fund will pay on 

the operator’s behalf. See 20 C.F.R. 725.522.

Outreach and Claimant 

Assistance 
 

Page 40 GAO-12-412 Defense Infrastructure

verification to support their claims. In fiscal year 2009, this outreach 

helped claimants file 9,935 claims. Further, the Energy Employees 

Occupational Illness Compensation Program continues to assist 

claimants by enhancing its database on the types of chemical and toxic 

contaminants that existed at the major Department of Energy facilities, 

easing claimants’ evidentiary burdens and speeding the claims process.

According to officials from the agencies that administer the alternative 

programs for compensation we reviewed and our prior work, the eligibility 

requirements of a given program may have an impact on the difficulty of

claimants trying to establish eligibility, the time needed to process claims, 

and the cost of administering the program. The evidence needed by 

claimants varies based on the criteria for each program, which are set out 

in statutes and regulations. For example, under many compensation 

programs, claimants must typically show a link between an environmental 

exposure and subsequent adverse health conditions to be eligible. 

However, the three programs we examined have certain presumptions 

that alleviate the need for claimants to fully establish a causal link 

between an environmental exposure and subsequent adverse health 

condition. These presumptions address, among other things, locations at 

which environmental exposures are presumed to have occurred, time 

frames during which claimants present in certain locations are presumed 

to have been exposed, and health conditions that are presumed to have 

been caused by an exposure. According to officials from the agencies 

that administer the alternative programs for compensation, although 

presumptions may reduce the burden on the claimant they may 

potentially increase costs. In addition, very specific presumptions can 

reduce eligibility for individuals who do not meet established criteria but 

who, in fact, developed adverse health conditions due to exposure, while 

very broad presumptions may overstate the connection between an 

exposure and adverse health conditions, allowing claimants who were not 

harmed by the exposure to obtain benefits and potentially increasing the 

cost of the program unnecessarily. The three alternative programs for 

compensation that we reviewed further illustrate how eligibility 

requirements may have an impact on the difficulty of claimants trying to 

establish eligibility, the time needed to process claims, and the cost of 

administering the program.

• The Energy Employees Occupational Illness Compensation Program 

provides compensation for several different types of claimants. Part B 

provides compensation for, among others, employees of the 

Department of Energy, its contractors or subcontractors, and atomic 

weapons employers with radiation-induced cancer who developed the 

Eligibility Requirements and 

Associated Presumptions
 

Page 41 GAO-12-412 Defense Infrastructure

cancer after working at a covered facility and whose cancer is 

determined to be at least as likely as not related to the employment. 

The Energy Employees Occupational Illness Compensation Program 

relies on extensive medical and scientific processes that reconstruct 

the radiation dose exposure by estimating the type and level of 

radiation exposure to each affected organ to collect accurate evidence 

for those claimants with a potential radiation-exposure related cancer, 

which, based on previous GAO work, may increase the time and 

administrative cost to adjudicate a claim.77 In 2010, GAO found that it 

took 3 or more years to process claims that required a radiation dose 

reconstruction, while those that did not require this reconstruction took 

about a year to adjudicate.78 In addition, the direct administrative 

costs for cases that require a dose reconstruction for potential 

radiation-exposure related cancer, based on our 2010 report, are 

estimated at about $20,000 per case, while the administrative costs of 

other cases under the program ranged from $6,000-$8,000 per 

case.79 However, in some cases in which it is not feasible to estimate 

with sufficient accuracy the radiation dose received by employees at 

Department of Energy facilities who were likely exposed to radiation—

and there is a reasonable likelihood that such radiation dose may 

have endangered employees’ health—the Energy Employees 

Occupational Illness Compensation Program Act provides for the 

addition of a class of those employees to the special exposure cohort. 

Unlike claimants who are not members of the special exposure 

cohort, members of the cohort who are diagnosed with any of the 

cancers specified by Congress are not required to establish that the 

cancer was “at least as likely as not” related to their employment. For 

members of the cohort, this presumption reduces the evidence 

necessary to meet eligibility requirements by removing the need to 

establish causation between the exposure and the illness. According 

to Department of Labor officials, for members of any of the more than 

70 additional classes of employees added to the special exposure 

cohort, the claim approval rate is 60 percent, compared to 34 percent 

for claimants who are not in the special exposure cohort.80

 

77 GAO, Energy Employees Compensation: Additional Oversight and Transparency Would 

Improve Program’s Credibility, 

Agency 

GAO-10-302 (Washington, D.C.: Mar. 22, 2010).

78 GAO-10-302. 

79 GAO-10-302. 

80 GAO-10-302. 
 

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officials told us that the special exposure cohort alleviates the need for 

administrators to determine whether evidence supports the existence 

of a link between the employment and the illness for each individual, 

thus reducing administrative costs and the time needed for 

adjudicating claims. However, these presumptions may overstate the 

connection between an exposure and adverse health conditions and 

potentially increase the cost of benefits provided in the program by 

allowing claimants who were not harmed by the exposure to obtain 

benefits.

• In order to receive benefits under the Black Lung Program, claimants 

must generally show that the miner has or had pneumoconiosis, the 

pneumoconiosis resulted in total disability or death, and that the 

pneumoconiosis arose, at least in part, out of coal mine employment. 

The requirement to establish causation between the coal mine 

employment and the adverse health condition may increase the 

difficulty for claimants trying to establish eligibility. For example, prior 

GAO work has shown that few claimants have been able to meet the 

program’s evidentiary requirements set by law.81 In 2008, 87 percent 

of claims within the Black Lung Program were denied, with over 60 

percent of the claims denied during the initial adjudication because 

claimants could not prove that they had pneumoconiosis or that 

pneumoconiosis had caused disability or death.82 The Black Lung 

Program has some presumptions, set out in statute, that ease this 

requirement for claimants who worked at a coal mine.83 However, 

some of these presumptions are rebuttable, and according to agency 

officials, can still be refuted by the mine operator.

• Claimants seeking compensation under the Radiation Exposure 

Compensation Program must show that they were exposed to 

radiation from atmospheric nuclear testing or as a result of their 

employment in the uranium mining industry, and that they developed 

a related adverse health condition, specified in law or regulation. 

These claimants are not required to establish causation between the 

 

81 GAO-10-7. 

82 GAO-10-7. 

83 For example, 30 U.S.C. §921 (c)(1) states that “if a miner who is suffering or suffered 

from pneumoconiosis was employed for ten years or more in one or more coal mines 

there shall be a rebuttable presumption that his pneumoconiosis arose out of such 

employment.” 
 

Page 43 GAO-12-412 Defense Infrastructure

exposure and the adverse health condition. According to a 

Department of Justice report, the Radiation Exposure Compensation 

Program was designed to utilize existing records so that claims could 

be resolved in a reliable, objective, and nonadversarial manner, with 

little administrative cost to the program or person filing the claim. For 

example, residents who lived downwind of atmospheric nuclear 

weapons tests may use a record for ownership of a home to show that 

they were present in a location during a specific time frame to meet 

the qualifications of the program. While this approach may be 

beneficial for administrators and claimants, the officials from the 

agencies that administer the compensation programs told us that not 

requiring the establishment of causation using scientific evidence 

potentially diminishes the accuracy of decisions for claims, and may 

increase the number of claimants who were not harmed by the 

exposure but are approved for benefits. A study by the National 

Academy of Sciences emphasizes this by concluding that eligibility for 

the Radiation Exposure Compensation Program should be based on a 

more scientific approach that emphasizes a “probability of causation” 

model that uses a mathematical formula to determine whether 

radiation exposure is likely the cause of an individual’s cancer.84

The frequencies and types of payment provided vary among alternative 

programs for compensation, and may impact the administrative costs of 

compensation programs. For example, the Energy Employees 

Occupational Illness Compensation Program Act and the Radiation 

Exposure Compensation Act provide lump sum payments in varying 

amounts, while the Black Lung Program provides monthly payments. The 

Energy Employees Occupational Illness Compensation Program and the 

Black Lung Program also provide compensation for some medical 

expenses, and the Black Lung Program provides, in some cases, 

payment of claimants’ attorney fees. According to Departments of Labor 

and Justice officials who administer these programs, the frequency and 

type of payments a program provides impacts administrative costs of the 

program. For example, although a lump sum benefit payment has low 

administrative costs since it is a one-time payment, some officials noted 

that there may be moral implications with lump sum payments especially 

in cases where the claimant may misallocate their lump sum award and 

need to pursue benefits from other federal programs such as Social 

 

84 The National Academies Press, Assessment of the Scientific Information for the 

Radiation Exposure Screening and Education Program (Washington, D.C.: 2005).

Frequencies and Types of 

Payment 
 

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Security Disability Insurance. Conversely, although monthly payments 

may cost more in the longer term compared to lump sum payments, 

especially if an adverse health condition must be periodically monitored 

through the program in order to establish continued eligibility, a monthly 

or periodic payment, on the other hand, would provide a steady stream of 

income to the claimant but may also cost more to administer since the 

funding agency must process payments on a monthly basis. 

In the most recent Defense Installations Strategic Plan, DOD states its 

goals of providing effective, safe, and environmentally sound living and 

working places in support of DOD missions. However, limitations in some 

of the existing policies targeting such areas as environmental restoration 

complicate DOD’s efforts to consistently address environmental 

exposures for individuals living or working on its installations. DOD only 

recently revised its policy on health surveillance to include dependents 

when collecting data that could improve its ability to address health risks 

that may have resulted from environmental exposures. However, this 

policy does not apply retroactively to past events such as those at Camp 

Lejeune.

DOD does not fully track the status of its responses to recommendations 

and findings of significant risk from the Agency for Toxic Substances and 

Disease Registry’s public health assessments. In addition, the current 

process does not ensure that status information on recommendations is 

provided to or documented by the lead agent’s office, as prescribed in the 

guidelines referenced in the memorandum of understanding between the 

two agencies. As such, DOD cannot ensure that it has taken timely and 

appropriate responses to all public health risks. Furthermore, because 

DOD does not have a policy establishing when it is appropriate for 

installations to request public health assessments or follow-up work 

beyond the initial assessment of proposed National Priorities List sites by 

the Agency for Toxic Substances and Disease Registry, DOD could be 

missing opportunities to identify and resolve concerns about some health 

threats. While DOD officials told us that cleanup laws do not require 

identification of individuals potentially affected by past exposures, events 

like the contamination at Camp Lejeune indicate a need for some 

guidance on whether, when, and how to respond to health concerns 

raised about such individuals.

Conclusions 
 

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To ensure that DOD meets its goal of providing effective, safe, and 

environmentally sound living and working places, and to assess potential 

gaps in policy coverage for individuals living or working on its installations 

who are exposed to environmental hazards, the Secretary of Defense 

should direct the Under Secretary of Defense for Acquisition, Technology, 

and Logistics to take the following three actions:

(1) Establish procedures to comprehensively track and document the 

status and nature of DOD responses to Agency for Toxic Substances and 

Disease Registry recommendations and findings of significant risk to 

ensure that DOD and its components monitor the status of these 

recommendations and findings of significant risk and respond in a timely 

manner. These procedures should be reflected in an updated 

memorandum of understanding prepared in collaboration with the Agency 

for Toxic Substances and Disease Registry, and could include revisions 

to the agencies’ joint guidelines or other mechanisms.

(2) Establish a policy that identifies when installations should consider 

requesting public health assessments in addition to the initial 

assessments at National Priorities List sites.

(3) Provide guidance on what actions, if any, DOD should take to identify 

and address possible health risks faced by individuals from past 

exposures at military installations.

We provided copies of this report for review and comment to the 

Departments of Defense, Veterans Affairs, Health and Human Services, 

Labor, and Justice. The Departments of Defense, Veterans Affairs, and 

Health and Human Services provided written comment letters; all of the 

departments provided technical comments which we have incorporated 

as appropriate. The Departments of Defense’s, Veterans Affairs’, and 

Health and Human Services’ written comment letters are reprinted in 

appendices IV, V, and VI, respectively. The Department of Veterans 

Affairs supported the recommendations, stating that “the Department of 

Defense’s adoption of the report recommendations would likely lead to 

prompt provision of additional information on exposures, and ultimately 

help veterans and others potentially exposed.” The Department of Health 

and Human Services expressed its support for the first recommendation 

indicating that it would be available to collaborate with DOD to update the 

current memorandum of understanding. In its comments, DOD partially 

concurred with our first recommendation and did not concur with our 

Recommendations for 

Executive Action

Agency Comments 

and Our Evaluation
 

Page 46 GAO-12-412 Defense Infrastructure

second and third recommendations. We continue to believe our 

recommendations remain valid, as discussed in the report.

DOD partially concurred with our first recommendation––to establish 

procedures to comprehensively track and document the status and nature 

of DOD responses to public health recommendations and reflect these 

procedures in an updated memorandum of understanding. Specifically:

• DOD stated that it will review its procedures for tracking DOD’s 

responses to Agency for Toxic Substances and Disease Registry 

recommendations and, if needed, make the appropriate changes 

to its tracking system. As noted in our report, the tracking system 

data provided to GAO indicated that DOD did not have information 

on the status of DOD’s response to 80 percent of the 

recommendations. Therefore, we believe DOD needs to make 

improvements to its tracking system. Without these improvements, 

DOD is missing opportunities to ensure that vital public health 

issues are adequately addressed.

• In regards to the memorandum of understanding, DOD stated that 

changes are not necessary. We disagree. The current 

memorandum of understanding does not expressly call for 

tracking recommendations, which we believe is an important 

coordination activity. As we note in our report, the memorandum 

of understanding does refer to DOD guidelines for tracking 

recommendations, but these have not been updated in 17 years. 

Moreover, these guidelines are not being followed, as our report 

shows and DOD officials acknowledged. These guidelines called 

for regular updates and an annual report on the status of 

recommendations and public health actions at each site. On the 

other hand, the Agency for Toxic Substances and Disease 

Registry officials told us that updating the memorandum of 

understanding with DOD, to address tracking recommendations 

would be useful. Given that DOD is not following the tracking 

procedures in its existing guidelines and overlooking the status of 

80 percent of the recommendations, we believe that the 

memorandum of understanding should be revised to expressly 

address tracking responsibilities to help ensure that identified 

public health risks are addressed.

DOD did not concur with our second recommendation––to establish a 

policy that identifies when installations should consider requesting public 

health assessments in addition to the initial assessments at National 
 

Page 47 GAO-12-412 Defense Infrastructure

Priorities List sites. DOD stated that its agrees that there should be 

policies in place to guide decisions on soliciting public health 

assessments, but believes the appropriate policies and responsibilities 

are already in place. We disagree with DOD for several reasons:

• First, DOD states that additional public health assessments 

conducted by the Agency for Toxic Substances and Disease 

Registry would duplicate the risk assessments conducted by DOD 

and others, which it believes are more comprehensive. We believe 

DOD’s comments overlook the important distinctions between the 

two assessments. Risk assessments are intended to enable the 

selection of cleanup remedies to reduce or eliminate current and 

future exposures, but these risk assessments generally do not 

include epidemiology or assessments of health risk to populations 

from current, future, and past exposures, as the public health 

assessments do––a fact which DOD officials acknowledged. 

Thus, these assessments have distinct purposes and scopes.

• Second, DOD states that supplementary policy for additional 

public health assessments for DOD cleanup sites is not needed, 

but did not elaborate on the reasons why. In the course of 

conducting a DOD cleanup program, installations may become 

aware of past exposures––such as at Tyndall Air Force Base or 

Camp Lejeune––years after an initial health assessment was 

developed. In fact, site characterization and restoration activities 

may take many years, and new health risks may be discovered 

during this process. However, without this guidance, it is unclear 

when it is appropriate to request a new health assessment.

• Third, DOD states that its current policies require the assessment 

of health risks to servicemembers and their dependents living on 

its installations; however, until DOD’s February 2012 revised 

directive, it was unclear when and if health surveillance data were 

collected for servicemembers’ dependents. As we said in the 

report, it is too soon to determine whether the implementation of 

this directive will include all individuals living or working on DOD 

installations––particularly servicemembers’ dependents living on 

overseas installations. As such, policies beyond the general 

directive are needed to ensure appropriate data are collected that 

might support a public health assessment when necessary.

• Finally, DOD states that assessments at Naval Air Station Atsugi, 

Japan, and Naval Air Station Fallon, Nevada, were initiated based 
 

Page 48 GAO-12-412 Defense Infrastructure

on health concerns raised by military families living on these 

installations. However, in our view, these examples highlight 

DOD’s reactive––rather than proactive––approach to responding 

to health concerns. In the case of air pollution at Atsugi, no DOD 

policy existed to guide the Navy on their approach to conducting 

environmental surveillance, medical testing, or notification of the 

potentially exposed dependents. As a result, it took several years 

for DOD to complete a risk assessment and notify 

servicemembers and their dependents about the long-term health 

effects. It took at least 13 years after the initial complaints for DOD 

and the U.S. government to get the Japanese government to 

close the incinerator that contributed to the air pollution. Policies to 

guide decisions on soliciting public health assessments could 

accelerate DOD’s response to future public health concerns.

DOD did not concur with our third recommendation––to provide guidance 

on actions to identify and address possible health risks faced by 

individuals from past exposures at military installations. DOD stated that it 

follows federal law, and its current guidance and policy are adequate for 

reasonably anticipated actions. We disagree for two reasons:

• The experiences at Atsugi Naval Air Station and Camp Lejeune 

demonstrate that DOD’s current guidance and policy are not 

adequate to encompass situations that have potentially severe 

health implications, which DOD has already encountered in the 

past. At Atsugi, an off-base incinerator in Japan released toxic 

fumes that drifted onto the naval base and may have exposed 

over 25,000 individuals on the installation to toxic air contaminants 

from 1985 through 2001, according to the Department of Veterans 

Affairs, despite individual complaints starting around 1988. At 

Camp Lejeune, potential exposure to volatile organic compounds 

in drinking water has resulted in administrative claims by 

servicemembers against the U.S. government totaling billions of 

dollars in potential damages for health conditions alleged to have 

resulted from exposure to contaminated water. In these examples, 

no current DOD policy or guidance was available to provide focus 

and direction in how officials should address past exposures. We 

continue to believe that these experiences could inform new 

policies by DOD to provide guidance to the services and their 

installations on how to manage situations that encounter similar 

challenges in the future, while maintaining appropriate flexibility. 
 

Page 49 GAO-12-412 Defense Infrastructure

• DOD stated that its cleanup policy is adequate because the 

Comprehensive Environmental Response, Compensation, and 

Liability Act does not require responsible parties to identify 

individuals who may have been exposed to contamination in the 

past. We agree that the act does not generally require responsible 

parties to identify exposed individuals, but that was not the basis 

for our recommendation; moreover, DOD is not limited to meeting 

the minimum requirements of federal law. GAO was mandated by 

Congress to review the extent to which DOD has a standard 

framework for responding to environmental hazards and possible 

exposures, among other things, and to make recommendations 

for any administrative action “that the Comptroller General deems 

appropriate in the context of the assessment.”85

In its written comments on a draft of this report, the Department of 

Veterans Affairs stated that environmental exposure data should be 

available in service treatment records and that this information is vitally 

important for the Department to adequately adjudicate claims based on 

environmental exposures. Accordingly, the Department stated that DOD’s 

adoption of our report recommendations would likely lead to the prompt 

provision of additional information on exposures, and ultimately help 

veterans and others potentially exposed. The Department of Veterans 

Affairs’ written comments are reprinted in appendix V.

In determining 

whether there is a standard framework, we found these gaps in 

policy. In light of these gaps and our mandate, we believe it is 

appropriate and have recommended that DOD develop guidance 

to assist the services and their installations in these situations. 

Further, we emphasize that our recommendation calls for 

guidance, but leaves its substance—such as what actions, if any, 

are appropriate—to DOD.

In its written comments on a draft of this report, the Department of Health 

and Human Services stated that in regards to our first recommendation, 

the Agency for Toxic Substances and Disease Registry would be 

available for collaboration with DOD to update the current memorandum 

of understanding that is in place regarding the Agency for Toxic 

Substances and Disease Registry’s recommendations and findings for 

 

85 Ike Skelton National Defense Authorization Act of 2011, Pub. L. No. 111-383 § 314.
 

Page 50 GAO-12-412 Defense Infrastructure

significant risk. The Department of Health and Human Services’ written 

comments are reprinted in appendix VI.

We are sending copies of this report to interested congressional 

committees and the Secretaries of Defense, Labor, Veterans Affairs; the 

Under Secretary of Defense for Acquisition, Technology, and Logistics; 

the Attorney General; and the Director of the Centers for Disease Control 

and Prevention. The report also is available at no charge on GAO’s 

website at http://www.gao.gov. 

If you or your staff have any questions concerning this report, you may 

contact us at: Brian J. Lepore, (202) 512-4523 or leporeb@gao.gov or

David C. Trimble, (202) 512-9338 or trimbled@gao.gov. Contact points 

for our Offices of Congressional Relations and Public Affairs may be 

found on the last page of this report. Key contributors to this report are 

listed in appendix VII. 

Brian J. Lepore, Director

Defense Capabilities and Management

David C. Trimble, Director

Natural Resources and Environment 
Appendix I: Objectives, Scope, and 

Methodology

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The objectives of our report were to determine (1) the extent to which the 

Department of Defense (DOD) has policies for identifying and responding 

to possible human exposures to environmental hazards on its 

installations; (2) what programs currently exist to provide health care and 

compensation to individuals for adverse health conditions resulting from 

environmental exposures on military installations and any factors that 

may affect these individuals’ access to health care or compensation; and 

(3) the features of alternative federal programs that provide medical 

benefits or compensation to large groups of individuals affected by a 

specific environmental exposure, which may be considered as possible 

options in the design of any future programs for individuals harmed by 

environmental hazards.

To determine the extent to which DOD has policies for identifying and 

responding to possible human exposures to environmental hazards on its 

installations, we reviewed and analyzed relevant laws as well as DOD, 

Environmental Protection Agency, and Agency for Toxic Substance and 

Disease Registry guidance and other documentation to identify the extent 

to which DOD identifies and responds to environmental exposures that 

may pose a risk to human health. In conducting this analysis, we 

catalogued DOD guidance and conducted content analysis to determine 

the extent to which the guidance addressed environmental exposures on 

military installations. Additionally, we conducted a literature search in 

professional journals to identify DOD policies in responding to 

environmental exposures. We also examined the database used to track 

the Agency for Toxic Substances and Disease Registry’s public health 

assessment recommendations and DOD’s implementation of those 

recommendations. In addition, we interviewed DOD officials at the Office 

of the Secretary of Defense and the various components, as well as 

officials at the Environmental Protection Agency, the Agency for Toxic 

Substances and Disease Registry, and some members of the Agency for 

Toxic Substances and Disease Registry’s Community Assistance Panel 

for Camp Lejeune. The Agency for Toxic Substances and Disease 

Registry created the community assistance panel as the forum for the 

Camp Lejeune community to voice concerns and provide input into future 

health studies regarding the water contamination at Camp Lejeune. We 

attended the July 2011 meeting of the Community Assistance Panel held 

in Wilmington, North Carolina and also conducted site visits to Camp 

Lejeune, North Carolina and Aberdeen Proving Ground, Maryland where 

the Army, as DOD’s Executive Agent for interaction with the Agency for 

Toxic Substances and Disease Registry, has its offices.

Appendix I: Objectives, Scope, and 

Methodology 
Appendix I: Objectives, Scope, and 

Methodology

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To determine what programs currently exist to provide health care and 

compensation to individuals for adverse health conditions resulting from 

environmental exposures on military installations and any factors that 

may affect these individuals’ access to health care or compensation, we 

reviewed and analyzed relevant laws and regulations, agency guidance, 

scientific journals, and other documentation to identify the eligibility 

requirements and determination procedures and extent of compensation 

and medical benefits provided through various processes currently 

available to different types of individuals (veterans and servicemembers 

and current and former military dependents, federal civilian workers, and 

contractors) possibly exposed to environmental hazards while working or 

living on military installations. We reviewed the following programs: the 

Federal Employee Compensation Act Program, Department of Defense’s 

TRICARE, Department of Defense’s Disability Evaluation System, 

Department of Veterans Affairs’ disability benefits and health care 

benefits programs, State Workers’ Compensation Programs, the Defense 

Base Act, and Federal Employee Health Benefits Program. We then 

developed matrices comparing the eligibility requirements and 

determination procedures of the various programs to identify what types 

of individuals were eligible for the various programs and if there were any 

gaps in coverage. We met agency officials from the Departments of 

Defense, Veterans Affairs, Labor, and Justice, to obtain further insight 

into the administration and eligibility requirements of the various 

programs; find out the reasons for any gaps in coverage and what 

challenges exist in obtaining benefits or compensation; and determine the 

potential adverse effects any such gaps and challenges may have on 

individuals exposed to environmental hazards. In addition, we interviewed 

officials from each of the Army, Navy, and Air Force Judge Advocate 

Offices to obtain information regarding environmental exposure tort 

claims and the process for filing claims. To assess the reliability of claims 

data obtained from the Department of the Navy and the Department of 

Veterans Affairs, we interviewed agency officials regarding the processes 

and procedures used to verify accurate data are maintained within the 

databases. Although we did not independently validate the claims data, 

we found these data to be sufficiently reliable for our purposes.

To determine the features of alternative federal programs that provide 

medical benefits or compensation to large groups of individuals affected 

by a specific environmental exposure, which may be considered as 

possible options in the design of any future programs for individuals 

harmed by environmental hazards, we reviewed and analyzed relevant 

laws and regulations, academic journals, external studies, and previous 

GAO reports to identify alternative compensation programs that (1) 
Appendix I: Objectives, Scope, and 

Methodology

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provided monetary compensation for specific adverse health conditions or 

death and/or medical benefits, (2) provided compensation based on 

exposure to a harmful contaminant in the environment, and (3) were 

federal programs that covered U.S. citizens. Using these criteria, we 

identified three programs: The Black Lung Program administered by the 

Department of Labor, the Energy Employee Occupational Illness 

Compensation Program administered by the Department of Labor, and 

the Radiation Exposure Compensation Program administered by the 

Department of Justice as the most comparable of environmental 

exposure compensation programs. We identified one other environmental 

exposure-related compensation program, the Marshall Islands Nuclear 

Claims Tribunal, but did not include it our analysis because it does not 

provide compensation to U.S. citizens. Although we collected and 

reviewed information regarding other compensation programs such as the 

Smallpox Vaccine Injury Compensation Program, the National Vaccine 

Injury Compensation Program, and the September 11th Victim 

Compensation Fund, we did not include these programs in our analysis 

as they do not provide compensation for injuries caused by environmental 

hazards. Both the Smallpox Vaccine Injury Compensation Program and 

the National Vaccine Injury Compensation Program provide 

compensation for injuries caused by vaccines and the September 11th 

Victim Compensation Fund only provides compensation based on death 

or injury caused by terrorist attacks. To identify and assess the features of 

these alternative compensation programs, including the benefit and 

challenges to the design of features, we reviewed prior GAO reports, met 

with GAO experts who have reported on these programs, interviewed 

agency officials with the Departments of Labor and Justice, and obtained 

and reviewed documentation and claims data on the programs from 

agency officials. To assess the reliability of claims data obtained by the 

Departments of Labor and Justice, we interviewed agency officials and 

received written documentation on internal control used by the agencies 

and the processes and procedures used to verify accurate data are 

maintained within the databases. Although we did not independently 

validate the claims data, we found these data to be sufficiently reliable for 

our purposes.

We conducted this performance audit between May 2011 and May 2012 

in accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.
Appendix II: Selected Contaminants That Have 

Been Found on Some Military Installations and 

Their Effect on Humans

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The Department of Defense has 141 installations on the national priorities 

list. In some cases, these installations and surrounding areas became 

heavily contaminated due to storage and disposal of substances such as 

solvents, machining oils, metalworking fluids, and metals. Many of these 

contaminants, such as trichloroethylene, perchloroethylene, and vinyl 

chloride, are known or suspected carcinogens. On some installations, 

these contaminants have spread far beyond their points of origin because 

they have been transported by wind currents or have leached into 

groundwater supplies, resulting in potential environmental exposures. 

Some of these contaminants include:

• Perchlorate is a rocket fuel component and by-product of rocket and 

missile testing and is also found in some fertilizers and fireworks. 

Now ubiquitous in the environment, it has spread from numerous 

manufacturing sites into drinking water systems and can also 

accumulate in leafy food crops and fruit irrigated by perchloratecontaminated water. According to the Agency for Toxic Substances 

and Disease Registry, perchlorate’s main target for toxicity in humans 

is the thyroid gland. In humans, perchlorate accumulates in the thyroid 

gland and can block iodide transfer into the thyroid, resulting in iodine 

deficiency and lower thyroid activity. The populations most sensitive to 

perchlorate exposure are children and fetuses, as adequate iodide is 

crucial for neurological development.

• Trichloroethylene and Perchloroethylene are solvents that have 

historically been used as metal degreasers and as ingredients in drycleaning spot removers, adhesives, paint removers, and typewriter 

correction fluids. According to the Environmental Protection Agency, 

exposure to trichloroethylene and perchloroethylene can result in 

cardiac arrhythmia, liver damage, and possible kidney effects, as well 

as an increased risk for a variety of cancers (esophagus, kidney, 

bladder, lung, pancreas, and cervix). Trichloroethylene and 

perchloroethylene degrade in groundwater over time to vinyl chloride.

• Vinyl chloride is a colorless gas with a sweet odor. Vinyl chloride is 

used to manufacture numerous products in building construction, the 

automotive industry, electrical wire insulation and cables, piping, 

industrial and household equipment, and medical supplies, and is 

depended upon heavily by the rubber, paper, and glass industries. 

Vinyl chloride is a known human carcinogenic and, according to the 

Environmental Protection Agency, long-term exposure to vinyl 

chloride may lead to liver cancer.

Appendix II: Selected Contaminants That 

Have Been Found on Some Military 

Installations and Their Effect on Humans
Appendix II: Selected Contaminants That Have 

Been Found on Some Military Installations and 

Their Effect on Humans

Page 55 GAO-12-412 Defense Infrastructure

• Benzene is a colorless liquid with a sweet odor that is highly 

flammable, evaporates in the air very quickly, and dissolves slightly in 

water. Benzene is formed from both natural processes and human 

activities. Natural sources of benzene include volcanoes and forest 

fires. Benzene is a natural part of crude oil, gasoline, and cigarette 

smoke. It is widely used in the United States. Some industries use 

benzene to make other chemicals that are used to make plastics, 

resins, and nylon and synthetic fibers. Benzene is also used to make 

some types of lubricants, rubbers, dyes, detergents, drugs, and 

pesticides. In humans, benzene causes cells not to work correctly.

For example, it can cause bone marrow not to produce enough red 

blood cells, which can lead to anemia. Also, it can damage the 

immune system by changing blood levels of antibodies and causing 

the loss of white blood cells. The Department of Health and Human 

Services has determined that benzene causes cancer in humans.

• Lead is extensively used in ammunition and firearms and, as a result, 

is prevalent in the soil of current and former firing ranges on many 

military installations. Lead can affect almost every organ and system 

in the body. The main target for lead toxicity is the nervous system, 

both in adults and children. Exposure to high lead levels can severely 

damage the brain and kidneys in adults or children.
Appendix III: Significant Health Studies and 

Notification Efforts Related to Contamination 

at Marine Corps Base Camp Lejeune

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Source: DOD and Agency for Toxic Substances and Disease Registry.

Appendix III: Significant Health Studies and 

Notification Efforts Related to Contamination 

at Marine Corps Base Camp Lejeune

1997 – An Agency for Toxic Substances and Disease Registry health assessment stated that exposure to volatile organic compounds in three 

drinking water systems on base was a public health hazard. The Agency also stated that the exposures were not likely to cause health problems in 

adults but recommended that studies be conducted to evaluate the risks of childhood cancer related to volatile organic compound exposure at Camp 

Lejeune and noted that adverse pregnancy outcomes were also of concern.

1998 – An Agency for Toxic Substances and Disease Registry study found a statistically significant association between exposure and some adverse 

pregnancy outcomes.

1999 – 2012 – An Agency for Toxic Substances and Disease Registry case-control study of specific birth defects and childhood cancers at Camp 

Lejeune was initiated to evaluate whether in utero exposure and/or exposure during the first year of life to contaminated drinking water at the base 

was associated with specific birth defects and childhood cancers. Agency for Toxic Substances and Disease Registry expects completion of the study 

some time in 2012.

2005 – An expert panel reported on the Agency for Toxic Substances and Disease Registry’s computer models of past Camp Lejeune drinking water 

systems. The Agency for Toxic Substances and Disease Registry said it accepted the panel’s recommendations for more rigorous record searches in 

order to reconstruct events for the water modeling studies.

2007 – A Marine Corps online notification registration database and a new telephone line was activated to place former Camp Lejeune residents, 

workers, and other interested parties on a contact list to receive results from research initiatives.

2008 – The National Defense Authorization Act for Fiscal Year 2008, Pub. L. No 110-181 § 315 required, among other things, that the Secretary of 

the Navy make reasonable efforts to identify and notify directly certain individuals – those served by the contaminated water systems or civilian 

employees in particular timeframes—who may have been exposed to the contaminated drinking water at Camp Lejeune.

2008 – A Marine Corps and Internal Revenue Service mailing was sent to about 150,000 individuals who resided or worked at Camp Lejeune during 

the applicable timeframe encouraging individuals to join the contact list to be notified about research initiatives. 

2009 – The Agency for Toxic Substances and Disease Registry said it withdrew its 1997 public health assessment after additional information 

emerged related to exposures to volatile organic compounds in drinking water at Camp Lejeune. The public health agency said inaccuracies 

regarding the exclusion of benzene in the 1997 assessment caused the withdrawal. The Agency for Toxic Substances and Disease Registry plans to 

revise the public health assessment once a water modeling study is complete. In the meantime, the Agency for Toxic Substances and Disease 

Registry said it stands behind the information related to the other nine exposure pathways. 

2009 – The National Research Council completed a report in response to a request from the Navy, mandated by Congress (Pub. L. No. 109-364, 

§318), to review evidence on whether adverse health outcomes are associated with past contamination of the water supply at Camp Lejeune. Among 

other things, the National Research Council concluded that most questions about whether exposures at Camp Lejeune resulted in adverse health 

effects cannot be answered definitively even with further scientific study.

2010 – The Agency for Toxic Substances and Disease Registry began conducting a mortality study looking at all causes of death, including cancers 

and other fatal diseases to determine if there is a link between the death and exposure to contaminated drinking water at Camp Lejeune. The study 

focuses on Marines who started active duty and DOD civilian employees who began work at Camp Lejeune between June 1975 and December 1985.

2011 – The Agency for Toxic Substances and Disease Registry launched a health survey of 300,000 Marine Corps personnel and civilians regarding 

diseases that may be associated with chemical exposures in the drinking water, in response to a mandate in the 2008 National Defense Authorization 

Act. This is the largest health survey ever conducted by the Agency for Toxic Substances and Disease Registry, which expects to release its findings 

in 2014.
Appendix IV: Comments from the Department 

of Defense

Page 57 GAO-12-412 Defense Infrastructure

Appendix IV: Comments from the 

Department of Defense
Appendix IV: Comments from the Department 

of Defense

Page 58 GAO-12-412 Defense Infrastructure
Appendix IV: Comments from the Department 

of Defense

Page 59 GAO-12-412 Defense Infrastructure
Appendix IV: Comments from the Department 

of Defense

Page 60 GAO-12-412 Defense Infrastructure
Appendix V: Comments from the Department 

of Veterans Affairs

Page 61 GAO-12-412 Defense Infrastructure

Appendix V: Comments from the Department 

of Veterans Affairs
Appendix VI: Comments from Department of 

Health and Human Services

Page 62 GAO-12-412 Defense Infrastructure

Appendix VI: Comments from Department of 

Health and Human Services
Appendix VI: Comments from Department of 

Health and Human Services

Page 63 GAO-12-412 Defense Infrastructure
Appendix VII: GAO Contacts and Staff 

Acknowledgments

Page 64 GAO-12-412 Defense Infrastructure

Brian J. Lepore, (202) 512-4523 or leporeb@gao.gov

David C. Trimble, (202) 512-9338 or trimbled@gao.gov

In addition to the individuals named above, Diane Raynes (Assistant 

Director), Mark J. Wielgoszynski (Assistant Director), Shawn Arbogast, 

Elizabeth Beardsley, Marissa Dondoe, Laurie Ellington, Dani Greene, 

Joanne Landesman, Nicholas McKay, Jennifer Neer, Alison O’Neill, 

Daniel Semick, Amie Steele, and Nicole Willems made key contributions 

to this report.

Appendix VII: GAO Contacts and Staff 

Acknowledgments 

GAO Contacts

Acknowledgments 
Related GAO Products

Page 65 GAO-12-412 Defense Infrastructure

Hearing Loss Prevention: Improvements to DOD Hearing Conservation 

Programs Could Lead to Better Outcomes. GAO-11-114. Washington, 

D.C.: January 31, 2011.

Afghanistan and Iraq: DOD Should Improve Adherence to Its Guidance 

on Open Pit Burning and Solid Waste Management. GAO-11-63. 

Washington, D.C.: October 15, 2010.

Superfund: Interagency Agreements and Improved Project Management 

Needed to Achieve Cleanup Progress at Key Defense Installations. 

GAO-10-348. Washington, D.C.: July 15, 2010.

Agency for Toxic Substances and Disease Registry: Policies and 

Procedures for Public Health Product Preparation Should Be 

Strengthened. GAO-10-449. Washington, D.C.: April 30, 2010.

Energy Employees Compensation: Additional Oversight and 

Transparency Would Improve Program’s Credibility. GAO-10-302. 

Washington, D.C.: March 22, 2010.

Black Lung Benefits Program: Administrative and Structural Changes 

Could Improve Miners’ Ability to Pursue Claims. GAO-10-7. Washington, 

D.C.: October 30, 2009.

Superfund: Greater EPA Enforcement and Reporting are Needed to 

Enhance Cleanup at DOD Sites. GAO-09-278. Washington, D.C.: March

13, 2009.

Radiation Exposure Compensation: Radiation Exposure Compensation 

Act: Program Status. GAO-07-1037R. Washington, D.C.: September 7, 

2007.

Environmental Contamination: Department of Defense Activities Related 

to Trichloroethylene, Perchlorate, and Other Emerging Contaminants. 

GAO-07-1042T. Washington, D.C.: July 12, 2007.

Defense Health Care: Issues Related to Past Drinking Water 

Contamination at Marine Corps Base Camp Lejeune. GAO-07-933T. 

Washington, D.C.: June 12, 2007.

Defense Health Care: Activities Related to Past Drinking Water 

Contamination at Marine Corps Base Camp Lejeune. GAO-07-276. 

Washington, D.C.: May 11, 2007.

Related GAO Products
Related GAO Products

Page 66 GAO-12-412 Defense Infrastructure

Federal Compensation Programs: Perspectives on Four Programs. 

GAO-06-230. Washington, D.C.: November 18 2005.

Defense Health Care: Improvements Needed in Occupational and 

Environmental Health Surveillance during Deployment to Address 

Immediate and Long-term Health Issues. GAO-05-632. Washington, D.C.: 

July 14, 2005.

Perchlorate: A System to Track Sampling and Cleanup Results is 

Needed. GAO-05-462. Washington, D.C.: May 20, 2005.

Agent Orange: Limited Information Is Available on the Number of Civilians 

Exposed in Vietnam and Their Workers’ Compensation Claims. 

GAO-05-371. Washington, D.C.: April 22, 2005.

Environmental Compliance: Better DOD Guidance Needed to Ensure 

That the Most Important Activities Are Funded. GAO-03-639. Washington, 

D.C.: June 17, 2003.

(351607)
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