United States Government Accountability Office

GAO Report to Congressional Committees

DISASTER 

PREPAREDNESS 

Better Planning Would 

Improve OSHA’s 

Efforts to Protect 

Workers’ Safety and 

Health in Disasters 

March 2007 

 

GAO-07-193 
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

March 2007

DISASTER PREPAREDNESS 

Better Planning Would Improve OSHA’s 

Efforts to Protect Workers' Safety and 

Health in Disasters 

Highlights of GAO-07-193, a report to 

congressional committees 

Concerns about the safety and 

health of workers involved in the

response to Hurricane Katrina 

included their exposure to

contaminated floodwaters and

injuries from working around 

debris. The Department of Labor’s 

Occupational Safety and Health

Administration (OSHA) is 

responsible for coordinating 

federal efforts to protect the safety

and health of workers involved in

the response to large national 

disasters. Under the Comptroller

General’s authority, GAO initiated a

number of Katrina-related reviews.

For this review, GAO examined 

(1) what is known about the 

number of response and recovery

workers deployed to the Gulf Coast 

in response to Hurricane Katrina;

(2) the extent to which OSHA 

tracked injuries and illnesses 

sustained by these workers; and 

(3) how well OSHA met the safety

and health needs of workers. To

address these issues, GAO 

reviewed reports; analyzed data; 

interviewed federal, state, and local 

officials; and conducted site visits. 

What GAO Recommends

GAO is making recommendations 

to the Secretaries of Labor,

Homeland Security, and Health and 

Human Services designed to

improve OSHA’s efforts during 

future disasters. Labor agreed with 

the recommendation to establish a 

system to better track injuries and 

illnesses but disagreed with some

of the findings on which the other 

recommendations were based. The 

other two agencies agreed with the 

recommendations in the report. 

No one, including OSHA, was responsible for collecting information on the total 

number of response and recovery workers deployed to the Gulf Coast in 

response to Hurricane Katrina and no one collected it, but 10 federal agencies

provided estimates showing that, on October 1, 2005, the agencies had about 

49,000 federal workers in the Gulf Coast area. In addition, six of these agencies 

estimated that their contractors had about 5,100 workers in the area on

December 1, 2005, but the other four either did not track the number of workers

employed by their contractors or did not employ contractors.

Although OSHA was responsible for tracking the injuries and illnesses that

federal response and recovery workers sustained during the response to 

Hurricane Katrina, the agency’s efforts to collect it were delayed and it was 

unable to collect usable information. According to OSHA, the Federal

Emergency Management Agency (FEMA) must assign and fund specific

responsibilities for each disaster. However, FEMA did not direct OSHA to collect 

injury and illness data until more than 3 weeks after the hurricane struck. OSHA

attempted to collect the data, but the information federal agencies provided

were incomplete and unreliable. OSHA and other agencies did track fatalities. 

They reported nine worker fatalities attributed to work-related accidents: three 

employees of federal contractors and six nonfederal workers or volunteers. 

OSHA provided assistance to many response and recovery workers who 

responded to Hurricane Katrina, but not all workers’ safety and health needs 

were met. OSHA quickly established operations in the Gulf area; intervened in

thousands of potentially hazardous situations; and assessed air, water, soil, and 

noise hazards at many work sites. However, disagreements between OSHA and 

FEMA about which agency was in charge of providing safety and health

assistance to federal agencies and workers and how it would be provided 

delayed some of OSHA’s efforts. Also, some agencies’ lack of awareness about 

the role OSHA plays in a disaster further hindered its ability to provide

assistance. As a result, OSHA did not fully meet workers’ safety and health

needs, particularly their need for training and protective equipment. OSHA also 

did not coordinate with the Department of Health and Human Services to ensure

that workers had needed mental health services, and OSHA was not assigned

responsibility for coordinating the needs of nonfederal workers, including state

and local agency workers; many immigrants; and volunteers.

Workers at an EPA Hazardous Waste Collection Facility near New Orleans, Louisiana 

 Source: GAO.

www.gao.gov/cgi-bin/getrpt?GAO-07-193.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact Daniel Bertoni 

at (202) 512-5988 or bertonid@gao.gov. 
Contents 

Letter 1

Results in Brief 2

Background 5

No One Collected Information on the Total Number of Response 

and Recovery Workers Deployed to the Gulf Coast, but 10 

Federal Agencies Collected Data on Their Workers 10 

OSHA Was Unable to Collect Information on Workers’ Injuries and 

Illnesses 12

OSHA Provided Assistance to Many Agencies and Workers, but Its 

Efforts to Meet the Safety and Health Needs of All Workers Were 

Hampered by Several Factors 15 

Conclusions 39

Recommendations for Executive Action 40 

Agency Comments and Our Evaluation 41 

Appendix I Scope and Methodology 45 

Appendix II Data on the Estimated Number of Federal 

Workers Who Responded to Hurricane Katrina 

and Their Injuries and Illnesses 48 

Appendix III Comments from the Department of Health & 

Human Services 59 

Appendix IV Comments from the Department of Labor 61 

Appendix V GAO Contact and Staff Acknowledgments 71 

Related GAO Products 72 

Page i GAO-07-193 Disaster Preparedness
Tables 

Table 1: Number of Fatalities Reported by OSHA and Other Federal 

Agencies 50

Table 2: Reported Number of Injuries and Illnesses for EPA, August 

2005 to June 2006 52 

Table 3: Reported Types of Injuries and Illnesses for EPA, August 

2005 to June 2006 53 

Table 4: Reported Number of Injuries and Illnesses for USACE, 

August 2005 to June 2006 54 

Table 5: Reported Types of Injuries and Illnesses for USACE, 

August 2005 to June 2006 55 

Table 6: Reported Exposures for the Coast Guard, November 2005 

to March 2006 56 

Table 7: Reported Injuries for the Coast Guard, November 2005 to 

March 2006 56 

Table 8: Reported Health Effects for the Coast Guard, November 

2005 to March 2006 57 

Table 9: Reported Timing of Symptoms for Health Effects for the 

Coast Guard, November 2005 to March 2006 57 

Figures 

Figure 1: Estimated Number of Federal Employees in the Gulf 

Coast Area on the First Day of Each Month, September 

2005 to April 2006 11 

Figure 2: Animals Such as Snakes and Alligators Presented Hazards 

to Workers in the Gulf Coast Area 17 

Figure 3: Selected Quick Cards Developed by OSHA for Hurricane 

Katrina 19 

Figure 4: Selected Fact Sheets Developed by OSHA for Hurricane 

Katrina 20

Figure 5: Work Zones with Equipment Not Protected from Traffic 

by Safety Cones 22 

Figure 6: Workers on a Water Tower without Fall Protection Such 

As Guard Rails or Safety Harnesses 23 

Figure 7: Workers on a Roof without Safety Harnesses and with 

Poorly Secured Ladders 24 

Figure 8: Airborne Hazards on the Gulf Coast 26 

Figure 9: OSHA Field Staff Sampling the Air, Water, and Soil on the 

Gulf Coast by Pinning a Small Personal Monitor to a 

Worker, Taking Water Samples, and Taking Soil Samples 27 

Page ii GAO-07-193 Disaster Preparedness
Figure 10: Driving Hazards Faced by Workers in the Gulf Coast 

Area 33

Figure 11: Safety Brochures in English, Spanish, and Vietnamese 38 

Abbreviations 

DOD Department of Defense 

EPA Environmental Protection Agency 

FEMA Federal Emergency Management Agency 

NRP National Response Plan 

OSHA Occupational Safety and Health Administration 

USACE U.S. Army Corps of Engineers 

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Page iii GAO-07-193 Disaster Preparedness
United States Government Accountability Office

Washington, DC 20548 

March 28, 2007 

Congressional Committees 

After Hurricane Katrina hit the Gulf Coast on August 29, 2005, federal

agencies undertook one of the largest rescue and recovery efforts in 

American history. Several agencies sent workers to the three states that 

suffered the most damage from the hurricane: Alabama, Louisiana, and 

Mississippi. Various reports have raised concerns about the safety and 

health of workers involved in the response to Hurricane Katrina and the 

dangers they faced, from animals such as snakes and alligators to 

floodwaters contaminated by chemicals, oil, corpses, and fecal matter. 

Public health advisories also warned about high temperatures and the 

potential spread of diseases such as West Nile Virus resulting from 

mosquitoes that breed in standing water. In addition, worker advocacy 

groups, public health advisors, and representatives of the Congress have 

raised concerns about the possibility of latent illnesses among workers 

deployed to the Gulf, especially in light of such illnesses among workers 

involved in rescue and recovery efforts at the World Trade Center disaster 

site. Many workers at the site in New York were not aware that they had

developed debilitating respiratory conditions or post-traumatic stress 

disorders until months or years after they left the site. 

After Hurricane Katrina hit the Gulf Coast on August 29, 2005, federal

agencies undertook one of the largest rescue and recovery efforts in 

American history. Several agencies sent workers to the three states that 

suffered the most damage from the hurricane: Alabama, Louisiana, and 

Mississippi. Various reports have raised concerns about the safety and 

health of workers involved in the response to Hurricane Katrina and the 

dangers they faced, from animals such as snakes and alligators to 

floodwaters contaminated by chemicals, oil, corpses, and fecal matter. 

Public health advisories also warned about high temperatures and the 

potential spread of diseases such as West Nile Virus resulting from 

mosquitoes that breed in standing water. In addition, worker advocacy 

groups, public health advisors, and representatives of the Congress have 

raised concerns about the possibility of latent illnesses among workers 

deployed to the Gulf, especially in light of such illnesses among workers 

involved in rescue and recovery efforts at the World Trade Center disaster 

site. Many workers at the site in New York were not aware that they had

developed debilitating respiratory conditions or post-traumatic stress 

disorders until months or years after they left the site. 

The safety and health of workers responding to Hurricane Katrina is 

addressed in a section, or “annex,” of the National Response Plan (NRP) of 

December 2004, the federal plan for responding to domestic emergencies 

and disasters. As lead agency for carrying out the provisions of the Worker 

Safety and Health Support Annex (the Annex), the Department of Labor’s

Occupational Safety and Health Administration (OSHA) is responsible for 

coordinating the worker safety and health efforts of responders—

including federal, state, local and tribal governments, and private and 

nonprofit organizations—in protecting the safety and health of their 

workers when the Annex is implemented. OSHA’s responsibilities under 

the Annex include identifying and assessing health and safety hazards, 

providing technical advice and support to safety officials, and collecting 

data on exposures and injuries. Given the large numbers of workers who 

responded to Hurricane Katrina and concerns about their health and 

safety, we addressed the following questions: (1) What is known about the 

number of response and recovery workers deployed to the Gulf Coast in 

response to Hurricane Katrina? (2) To what extent did OSHA track injuries 

The safety and health of workers responding to Hurricane Katrina is 

addressed in a section, or “annex,” of the National Response Plan (NRP) of 

December 2004, the federal plan for responding to domestic emergencies 

and disasters. As lead agency for carrying out the provisions of the Worker 

Safety and Health Support Annex (the Annex), the Department of Labor’s

Occupational Safety and Health Administration (OSHA) is responsible for 

coordinating the worker safety and health efforts of responders—

including federal, state, local and tribal governments, and private and 

nonprofit organizations—in protecting the safety and health of their 

workers when the Annex is implemented. OSHA’s responsibilities under 

the Annex include identifying and assessing health and safety hazards, 

providing technical advice and support to safety officials, and collecting 

data on exposures and injuries. Given the large numbers of workers who 

responded to Hurricane Katrina and concerns about their health and 

safety, we addressed the following questions: (1) What is known about the 

number of response and recovery workers deployed to the Gulf Coast in 

response to Hurricane Katrina? (2) To what extent did OSHA track injuries 

Page 1 GAO-07-193 Disaster Prepare saster Preparedness
and illnesses sustained by these workers? (3) How well did OSHA meet the 

safety and health needs of these workers? 

To address these objectives, we reviewed reports and documents related 

to the federal response efforts for Hurricane Katrina and other recent 

disasters; interviewed officials from 10 federal agencies identified by 

FEMA and OSHA as having deployed response and recovery workers to 

the Gulf Coast: OSHA; the Federal Emergency Management Agency 

(FEMA); the Environmental Protection Agency (EPA); the Coast Guard; 

the Department of Defense (DOD); the National Guard; the U.S. Army 

Corps of Engineers (USACE); and the Departments of Agriculture, Health

and Human Services, and the Interior. We also conducted site visits in 

Alabama, Mississippi, and Louisiana where we interviewed federal 

officials in all three states and selected state and local officials who were 

part of the rescue and recovery efforts. To obtain information on the 

number of response and recovery workers who responded to Hurricane 

Katrina, we contacted the 10 agencies identified by FEMA and OSHA and 

asked them to provide information on the number of workers each agency 

employed in the Gulf Coast. To obtain information on injuries and 

illnesses sustained by these workers, we asked these same agencies for 

this information for their workers. Of the 10 agencies, only four—USACE, 

EPA, the Coast Guard, and the Department of the Interior—had data on 

workers’ injuries and illnesses that were sufficiently reliable for us to 

report. We also obtained data on injuries and illnesses related to Hurricane 

Katrina from workers’ compensation claims filed by federal workers, and 

information on worker fatalities from OSHA and other federal agencies. To 

assess the reliability of the agencies’ data, we talked with agency officials 

about their data quality-control procedures and reviewed relevant 

documentation. We determined the data were sufficiently reliable for the 

purposes of this report. Finally, we interviewed workers’ rights 

organizations, including the Mississippi Immigrant Rights Alliance, Boat 

People SOS, the Center to Protect Workers’ Rights, and the New York 

Committee for Occupational Safety and Health. We conducted our work 

from October 2005 to December 2006 in accordance with generally 

accepted government auditing standards. For additional information, see 

appendix I. 

No one, including OSHA, was responsible for collecting information on the 

total number of response and recovery workers deployed to the Gulf in 

response to Hurricane Katrina, and no one collected it, but 10 federal 

agencies provided estimates showing that, on October 1, 2005 (the month 

with the largest total number of federal workers), the agencies had about 

Results in Brief 

Page 2 GAO-07-193 Disaster Preparedness
49,000 federal workers in the Gulf Coast area. In addition, six of these 

agencies estimated that their contractors had over 5,100 workers in the 

area as of December 1, 2005 (the month with the largest total number of 

contractor employees), but three of the other four did not track the 

number of workers employed by their contractors, and one did not employ 

contractors for the response. 

Although OSHA was responsible for tracking injuries and illnesses for 

federal response and recovery workers, including federal contractor 

employees, deployed to the Gulf Coast during the response to Hurricane 

Katrina, the agency was unable to collect usable information from federal 

agencies on their workers’ injuries and illnesses. OSHA could not track 

workers’ injuries and illnesses because the agency (1) had not developed a 

process for collecting this information prior to the disaster, (2) was not 

directed by FEMA to track this information right away, and (3) received 

incomplete and unreliable data from federal agencies once it attempted to

collect the information. In the 8 months between the time the National 

Response Plan and the Annex was issued and Hurricane Katrina hit the 

Gulf Coast, OSHA focused its efforts on introducing the Annex to agencies 

that might respond to a disaster and did not develop a process for 

collecting data on workers’ injuries and illnesses. In addition, OSHA, like 

all other agencies under the NRP, must wait for FEMA to assign it specific 

responsibilities for each disaster and authorize funding for these activities, 

but FEMA did not direct OSHA to collect data on federal workers’ injuries 

and illnesses until more than 3 weeks after the hurricane struck. After 

receiving this assignment from FEMA, OSHA tried to obtain the data from

the logs that OSHA requires agencies to keep at each work site on 

workers’ injuries and illnesses. However, not all agencies that deployed

workers to the Gulf Coast provided these logs to OSHA as requested, and 

those that did provided incomplete and unreliable data. OSHA and other 

agencies also reported nine worker fatalities attributed to work-related 

accidents, including three employees of federal contractors and six 

nonfederal workers or volunteers. 

OSHA provided assistance to many response and recovery workers who 

responded to Hurricane Katrina, but OSHA’s efforts to meet all workers’ 

safety and health needs were hampered by several factors. OSHA used its 

own funds to quickly establish operations in the Gulf area prior to 

receiving authorization from FEMA in the form of a mission assignment 

implementing the Annex. OSHA developed health and safety plans; 

provided information on common safety hazards to many agencies and 

workers; intervened in thousands of potentially hazardous situations; and

assessed air, water, soil, and noise hazards at many worksites. However, 

Page 3 GAO-07-193 Disaster Preparedness
disagreements between OSHA and FEMA about which agency was in 

charge of providing safety and health assistance to federal agencies and

workers and how and when the Annex would be implemented delayed 

some of OSHA’s efforts to provide assistance. Once OSHA began its 

efforts, some agencies’ lack of awareness about the role OSHA plays in a 

disaster further hindered its ability to provide assistance. For example, 

many agency officials did not know that, in a disaster, OSHA provides 

technical assistance rather than conducting inspections of work sites or 

that OSHA can provide assistance such as assessing safety hazards and 

recommending the proper protective equipment for workers. This lack of 

understanding contributed to agencies’ not requesting OSHA’s assistance 

during the response and not inviting OSHA to participate in emergency 

preparedness exercises in the months leading up to Hurricane Katrina. In 

addition, although OSHA provided valuable assistance to many agencies 

and workers, it was not able to ensure that all workers’ needs for training, 

protective gear, and mental health services were met. The training OSHA 

provided was delayed for several weeks because FEMA did not officially

authorize OSHA to carry out its responsibilities under the Annex until 

more than 3 weeks after the hurricane, and some agencies did not request 

training from OSHA because they did not realize it was available. OSHA 

provided some personal protective equipment to workers in the Gulf Coast 

area but had not developed a plan for ensuring that workers had needed 

protective equipment as required by the Annex and FEMA, and some 

workers did not have equipment to protect them from hazards. For 

example, National Guard officials told us that some of their federalized 

workers did not have equipment such as rubber boots to protect them 

from contaminated floodwaters. OSHA also had difficulty getting 

counselors to provide mental health services in the locations and during 

the hours they were needed, and it did not coordinate with the Department 

of Health and Human Services to ensure that workers had needed mental 

health services. Finally, coordinating the safety and health needs of 

nonfederal workers—including state and local government workers, many 

immigrants, and volunteers—was not part of OSHA’s assigned 

responsibilities for Hurricane Katrina (nor any other federal agency’s 

responsibility), and some of their needs were not met. 

We are recommending that the Secretaries of the Departments of Labor 

and Homeland Security direct the Administrators of OSHA and FEMA to 

improve their ability to meet workers’ safety and health needs in the event 

of a future disaster in several areas, including clearly defining the criteria 

to be used in deciding when OSHA will be responsible for carrying out its 

duties under the Annex to the NRP; clarifying OSHA’s and FEMA’s roles 

under the Annex; and proactively working to provide information to other

Page 4 GAO-07-193 Disaster Preparedness
federal, state, and local agencies about the role that OSHA plays in a major 

disaster and the assistance it can provide. We are also recommending that

the Secretary of Labor direct OSHA to establish a process for collecting 

data on injuries and illnesses sustained by workers who respond to 

disasters and develop, implement, and monitor an incident personal 

protective equipment program as defined in the Annex. Finally, we are 

recommending that the Secretaries of the Departments of Labor and 

Health and Human Services develop a plan for coordinating and providing 

mental health services in the event of a future disaster. In responding to a 

draft of this report, officials with the Departments of Health and Human 

Services and Homeland Security agreed with our recommendations and 

provided technical comments that we incorporated as appropriate. The 

Department of Health and Human Services provided general written 

comments. (See app. III for a copy of its comments.) The Department of 

Labor agreed with one of our recommendations and, while it did not 

comment on the other recommendations, stated generally that we did not 

give the agency enough credit for the actions it took during its response to 

Hurricane Katrina and disagreed with some of the findings. (See app. IV 

for a copy of the agency’s comments and our response.) The Departments 

of Labor and the Interior; the Coast Guard; and the National Guard also 

provided technical comments, which we incorporated as appropriate. 

Although they were provided with a draft for comment, DOD did not 

respond to our request for comments. Officials with EPA, USACE, and the 

Department of Agriculture told us that they had no comments. 

The Occupational Safety and Health Act of 1970 authorizes OSHA to set 

occupational safety and health standards, rules, and regulations and to 

enforce their compliance. OSHA uses two approaches—enforcement and

compliance assistance. 

Background 

The Role of OSHA in

Occupational Safety and 

Health 

Enforcement is carried out primarily by using compliance officers to 

inspect employer work sites. Employers whose work sites fail to meet 

federal safety and health standards face sanctions, such as paying 

penalties for violations of safety and health standards. In this enforcement 

capacity, OSHA targets employers for inspection using injury and illness 

rates for industries and specific work sites. OSHA also conducts 

inspections when employers report fatalities or serious injuries and when

workers file complaints alleging that a violation of a safety or health 

Page 5 GAO-07-193 Disaster Preparedness
standard exists that threatens physical harm or that an imminent danger 

exists at their work sites. 

Cooperative programs, in contrast, use a variety of incentives to 

encourage employers to work with OSHA to reduce hazards and institute 

practices that foster safer and healthier working conditions. Such 

incentives include free consultations, recognition for exemplary safety and 

health systems, and exemption from routine inspections. 

OSHA has direct enforcement responsibility for federal workers in all 

states and for private sector workers in about half the states. In the 

remaining states, OSHA has granted approval for the states to conduct 

their own enforcement of private sector, state, and local government work 

sites.1

 None of the three states most affected by Hurricane Katrina 

conducts its own worker safety and health program; OSHA provides direct 

oversight for workers in these states. 

OSHA is organized by regional and area offices. The three states most 

affected by Hurricane Katrina are located in OSHA’s Region 4 (Mississippi 

and Alabama) and Region 6 (Louisiana). Its area offices in these states are 

located in Jackson, Mississippi; Mobile, Alabama; and Baton Rouge, 

Louisiana 

Federal and private sector employers are required by OSHA to maintain 

records documenting certain work-related injuries and illnesses: those that 

result in death, 1 or more days away from work, restricted work, loss of 

consciousness, or a significant injury or illness diagnosed by a physician. 

Each employer’s work site is required to record illness and injury data on a 

form known as an “OSHA 300 log.” While employers are not required to 

submit these logs to OSHA, they must be available for inspection upon 

request. Federal agencies are required to submit summary information to 

OSHA about their safety and health programs on an annual basis, but these 

reports generally do not contain information on specific injuries and 

illnesses sustained by their workers.

 1

At present, 22 states have been approved by OSHA to operate their own enforcement 

programs covering all private sector workers and state and local public sector workers, 

and 4 have been approved to cover state and local public sector workers only. 

Page 6 GAO-07-193 Disaster Preparedness
Based on lessons learned during the response to the World Trade Center 

disaster, OSHA now uses its statutory enforcement discretion during a 

disaster to exempt selected employers from normal enforcement 

operations and provide technical assistance and consultation in 

combination with traditional enforcement as required by the incident.2

 At 

the World Trade Center, OSHA made this decision based on the 

recognition that a rescue effort should not be hampered, that enforcement 

takes time and can affect the speed of the correction of safety and health

hazards, and that its goal was protection, not citation. The Assistant 

Secretary of OSHA, in conjunction with regional administrators, makes the 

decision when to exercise its enforcement discretion and move to a

technical assistance role, and when to return to traditional enforcement 

The Role of OSHA in a 

Disaster 

While federal, state, and local agencies as well as private sector employers 

are responsible for ensuring the safety and health of their workers, OSHA 

is responsible for coordinating with other federal cooperating agencies to

provide safety and health technical assistance to response and recovery 

workers involved in the response to a disaster. The federal cooperating 

agencies are DOD; the Departments of Energy, Health and Human 

Services, and Homeland Security; and EPA. 

As the lead coordinating agency for the Worker Safety and Health Support

Annex (the Annex), OSHA’s coordination responsibilities include 

1. providing occupational safety and health technical advice and 

support to safety officials at the Joint Field Office, a temporary 

federal facility established at the site of a disaster to coordinate

federal assistance to affected jurisdictions; 

2. developing and implementing site-specific occupational safety and 

health plans and ensuring that the plans are coordinated and 

consistent among multiple sites; 

3. identifying and assessing health and safety hazards and 

characterizing the incident environment, to include continued 

monitoring of incident safety on a 24-hours-a-day, 7-days-a-week 

basis; 

 2

OSHA retains the ability to enforce regulations and issue citations even when it is in a

technical assistance role and may cite employers that do not comply with the suggestions 

of OSHA staff or if there is an employee complaint or a fatality. 

Page 7 GAO-07-193 Disaster Preparedness
4. monitoring responder personal exposure on a 24-hours-a-day, 

7-days-a-week basis, including monitoring for chemical and 

biological contaminants, noise, heat or cold, and ionizing radiation; 

5. monitoring the medical condition of responders and, in 

conjunction with the Department of Health and Human Services, 

evaluating the need for longer term monitoring; 

6. assessing responder safety and health resource needs and 

identifying sources for those assets; 

7. developing, implementing, and monitoring an incident personal 

protective equipment program—including the selection, use, and 

decontamination of the equipment; implementation of a respiratory 

protection fit-test program—and distribution of equipment; 

8. collecting and managing data on exposures, accidents, and injuries 

to facilitate consistent formatting and data sharing among response 

organizations; 

9. communicating with labor unions, contractors, and other 

organizations regarding responder safety and health issues; 

10. coordinating and providing incident-specific responder training; 

11. providing psychological first aid during and after incident response 

and recovery activities; and 

12. identifying, in coordination with the Department of Health and 

Human Services, appropriate immunization and prophylaxis for 

responders and recovery workers. 

Even though OSHA has been assigned responsibility for coordinating the 

activities in the Annex, during an actual disaster, FEMA must issue a 

“mission assignment” that authorizes OSHA to receive reimbursement for 

carrying out some or all of these activities, depending on the needs of the

disaster and which groups are covered during each response effort. 

Without a mission assignment, services provided by an agency cannot be 

reimbursed by FEMA.3

 For Hurricane Katrina, FEMA issued mission 

assignments to OSHA tasking it with 11 of the 12 activities listed in the 

 3

Reimbursement is provided under the Robert T. Stafford Disaster Relief and Emergency 

Assistance Act (the Stafford Act) 42 U.S.C. § 5147. 

Page 8 GAO-07-193 Disaster Preparedness
Annex for federal agencies and their workers, including federal contractor

employees. The only activity in the Annex for which OSHA was not 

assigned responsibility for Hurricane Katrina was monitoring the medical

conditions of responders, including assessing the need for long-term 

medical monitoring because, according to FEMA, it does not have the 

authority under the Stafford Act to pay for the collection and management 

of data for long-term studies or analysis.4

 FEMA also did not assign 

responsibility to OSHA, or any other federal agency, for coordinating the 

safety and health of nonfederal workers, except workers employed by

federal contractors. State and local agency employees, private sector 

employees other than those employed by federal contractors, and 

volunteers were not covered under the Annex.5

 OSHA had difficulty 

addressing the needs of nonfederal workers not covered under its mission

assignment, but was able to provide some assistance to these workers 

using its own funds. 

 4

In the mission assignment FEMA issued to OSHA implementing the Annex for Hurricane 

Katrina, FEMA stated that it did not have authority under the Stafford Act to pay for the

collection and management of data for long-term studies or analysis. 

5

In order for state and local agency workers in a state to be covered by the Stafford Act in a 

disaster, the governor of the affected state must specifically request services from FEMA. 

For Hurricane Katrina, none of the governors of the three states requested assistance with 

safety and health issues. 

Page 9 GAO-07-193 Disaster Preparedness
No one, including OSHA, was assigned responsibility for collecting data on 

the total number of response and recovery workers deployed to the Gulf 

and no one collected it, but 10 federal agencies were able to provide 

estimates of the number of federal workers they deployed to the Gulf for 

specific points in time. However, only six of them tracked the number of 

workers employed by their contractors.6

 According to FEMA and OSHA, 

10 federal agencies deployed response and recovery workers to the Gulf in

response to Hurricane Katrina: the Departments of Agriculture, the 

Interior, and Health and Human Services; the Coast Guard; DOD; EPA; 

FEMA; OSHA; USACE; and the National Guard. We asked officials from 

these 10 agencies to provide us with the total number of response and 

recovery workers they had in the Gulf Coast from August 2005 through 

April 2006. Agency officials said they did not collect data in a way that 

would enable them to provide us with unduplicated counts of workers 

who rotated in and out of the Gulf Coast area. All 10 agencies, however, 

told us they could provide us with estimates of the number of workers 

they had in the Gulf Coast area at any specific point in time. Therefore, we

asked them to provide us with information on the number of workers they

employed in the three states on the first of each month for the period from

September 2005 to April 2006. 

No One Collected 

Information on the 

Total Number of 

Response and 

Recovery Workers 

Deployed to the Gulf 

Coast, but 10 Federal 

Agencies Collected 

Data on Their 

Workers

As shown in figure 1, the agencies estimated that they had about 

31,000 federal employees in the Gulf Coast area on September 1, 2005.

That number increased to approximately 49,000 workers on October 1, 

2005, and dropped to about 8,500 workers on April 1, 2006. 

 6

National Guard officials told us the agency did not employ any contractor personnel 

during the response to Hurricane Katrina. 

Page 10 GAO-07-193 Disaster Preparedness
Figure 1: Estimated Number of Federal Employees in the Gulf Coast Area on the 

First Day of Each Month, September 2005 to April 2006 

0

5,000

10,000

15,000

20,000

25,000

30,000

35,000

40,000

45,000

50,000

55,000

Sept. Oct. Nov. Dec. Jan. Feb. Mar. Apr.

Number of employees

Source: Data obtained from selected federal agencies.

2005 2006

30,900

48,700

19,800

15,400

10,000 10,600 8,700 8,500

The National Guard reported having the largest number of federal 

employees—about 31,000—in the Gulf Coast area on October 1, 2005, and 

FEMA reported the second largest number—about 4,800 workers. The 

Coast Guard reported the third largest number of federal employees in 

October—approximately 3,100 workers. OSHA reported that it had 84 staff 

in the Gulf Coast area on the first of October and November 2005. 

Of these 10 federal agencies, only six of the agencies that employed 

contractors in the Gulf area—EPA, OSHA, FEMA, and the Departments of 

Agriculture, Health and Human Services, and the Interior could provide 

data on the number of employees their contractors employed. These 

agencies estimated that their contractors had over 5,100 workers in the 

Gulf Coast area on December 1, 2005, the month with the largest total 

number. FEMA and EPA reported the most contractor employees: FEMA 

estimated that it had approximately 3,800 contractor employees at one 

point, and EPA estimated that its contractors had about 1,200 workers in 

the Gulf area. The other agencies reported much smaller numbers of 

contractor employees, ranging from 1 worker to 150. USACE and Coast 

Guard officials told us they could provide us with information on the 

number of contracts they issued, but they did not know the number of 

workers employed under each of these contracts. Officials with DOD told 

Page 11 GAO-07-193 Disaster Preparedness
us that, although DOD employed contractors in the Gulf area, they did not 

track the number of workers employed by their contractors. National 

Guard officials told us that they did not employ any contractors. 

Although OSHA was directed by FEMA to collect information from federal 

agencies on injuries and illnesses sustained by federal workers during the 

response to Hurricane Katrina, the agency was unable to collect useable

information from all of the agencies that deployed workers to the Gulf. 

Four federal agencies provided some information to us on their workers 

who were injured or became ill, and OSHA and other agencies provided 

information on worker fatalities that occurred during the response. 

Although the Annex assigned responsibility to OSHA for collecting data on 

workers’ injuries and illnesses during disasters, and FEMA directed OSHA 

to collect this information from federal agencies for Hurricane Katrina, 

several factors hindered OSHA’s efforts to collect these data as required. 

OSHA did not establish a process for gathering these data between the 

time the Annex was issued in December 2004 and when Hurricane Katrina

hit the Gulf Coast in late August 2005. According to OSHA officials, during

this 8-month period, they focused their efforts on introducing federal, 

state, and local agencies to OSHA’s new role under the Annex in a disaster 

rather than developing a process for collecting data on workers’ injuries 

and illnesses during a response. 

OSHA Was Unable to 

Collect Information 

on Workers’ Injuries 

and Illnesses 

Several Factors Hindered 

OSHA’s Efforts to Collect 

Data on Injuries and 

Illnesses 

The second factor that hindered OSHA’s ability to collect data on workers’ 

injuries and illnesses was that fact that FEMA did not issue a mission 

assignment directing OSHA to collect these data for federal agencies’

workers until more than 3 weeks after the hurricane hit the Gulf. FEMA 

instructed OSHA to track workers’ injuries and illnesses across all federal 

agencies that deployed workers to the Gulf in the mission assignment it 

issued to OSHA on September 21, 2005, more than 3 weeks after the 

hurricane struck on August 29, 2005.

Third, OSHA tried to collect data on injuries and illnesses for federal 

workers in the Gulf Coast area from the logs that OSHA requires agencies 

to maintain at each worksite on workers’ injuries and illnesses but 

received incomplete or unreliable data from federal agencies. In 

November 2005, OSHA asked federal agencies and their contractors to 

submit their injury and illness logs for worksites located in the Gulf area to

OSHA headquarters on a monthly basis. However, according to OSHA 

officials, because they did not request agencies to provide their injury and 

Page 12 GAO-07-193 Disaster Preparedness
illness logs to OSHA until five or six weeks after the hurricane hit, and 

because agencies are normally not required to send their logs to OSHA, 

not all agencies submitted their logs. In addition, many of the agencies 

could not separate data for workers assigned to the Gulf Coast area 

temporarily since employers are not required to establish separate logs for 

temporary worksites expected to be in operation for one year or less. 

Some agencies provided their logs to OSHA, but the data they provided 

were incomplete and unreliable, according to OSHA officials. For 

example, one agency’s logs included information on accidents involving 

heavy equipment but did not contain information on the related injuries to 

workers. OSHA officials cited several reasons for the poor quality of the 

data, including the fact that the agencies may have placed a low priority on 

recording injuries and illnesses while responding to a disaster.

In technical comments on the draft report, OSHA officials stated that 

neither their efforts to educate the federal community about the Annex 

nor the more than 3-week delay in receiving its mission assignment 

prevented them from developing a system for collecting injury and illness 

data. 

In a mission assignment, FEMA tasked OSHA to collect these data in order 

to facilitate consistent formatting and data sharing among response 

organizations. OSHA could then use the data to track emerging trends in 

the types of injuries and illnesses sustained by workers so that appropriate 

measures, such as providing specific safety training and information on 

hazards, could be taken to address emerging safety issues and prevent or

reduce injuries and illnesses. Although OSHA was unable to use injury and 

illness data to track emerging trends, it did identify some injuries and 

illnesses that occurred during the response through the information it 

obtained from other federal agencies at the Interagency Safety Committee 

meetings held at the Joint Field Office in each state. 

Available Data from Four 

Agencies Show Over 3,000 

Injuries and Illnesses 

Because OSHA could not provide data on injuries and illnesses, we asked 

the 10 agencies that deployed workers to the Gulf Coast area for these 

data. However, although agency officials told us they collected 

information on the injuries and illnesses for their workers on the injury 

and illness logs required by OSHA, most of them could not separate out 

this information for workers sent to the Gulf Coast. Four of the 

10 agencies—EPA, USACE, the Coast Guard, and the Department of the 

Interior—collected information on the injuries and illnesses their workers 

sustained in the Gulf Coast area using their own data systems. The four 

reported that their workers sustained over 3,000 injuries and illnesses 

Page 13 GAO-07-193 Disaster Preparedness
from the end of August 2005 through June 2006 including minor injuries 

that would not have been recordable on the OSHA logs. The most 

frequently cited injuries were bites from insects such as mosquitoes and 

dogs; sunburn; exposure to floodwater; heat stress; and exposures to 

chemicals, infectious or biological agents, mold, and carbon monoxide. 

(See app. II for additional information on the injury and illness data 

provided by these four agencies.) The data were not comparable across 

the four agencies because each one collected different types of 

information and categorized it differently. For example, EPA used 

nonstandard, detailed descriptions of the illness or injury, such as “tripped 

on wire and bruised knee,” while the Coast Guard described the health

effects of injuries or exposures using consistent and concise categories, 

such as “infected skin” and “skin laceration.” 

The Department of Labor’s Office of Workers’ Compensation Program, 

another source of data on injuries and illnesses, reported that federal 

workers filed 770 claims related to Hurricanes Katrina and Rita from 

August 2005 through June 2006.7

 While data on the number of claims were 

reliable, the information on the nature and causes of the injuries and 

illnesses was not reliable. Therefore, we could not use it to identify the 

types of injuries and illnesses sustained by federal workers in the Gulf 

Coast area. 

Eleven Worker Fatalities 

Related to Hurricane 

Katrina Reported 

OSHA and other agency officials identified 11 fatalities of workers 

involved in response and recovery work for Hurricane Katrina from 

September 2005 through June 2006, 9 of which occurred as a result of 

work-related accidents.8 No worker fatalities directly related to the 

response were reported in Alabama. In Louisiana and Mississippi, three 

federal agency contractor employees died in work-related accidents, 

including two employees of FEMA subcontractors and an employee of a 

USACE subcontractor. (See app. II for additional information.) 

 7

Officials with the Office of Workers’ Compensation Programs told us they could not use 

their computer database to distinguish claims for injuries or illnesses related to Hurricane 

Katrina from those related to Hurricane Rita, a hurricane that caused extensive damage in

Texas and Louisiana in September 2005. 

8

Some of the fatalities reported involved workers that were not covered under OSHA’s

mission assignment, such as volunteers or private sector employees. 

Page 14 GAO-07-193 Disaster Preparedness
Although FEMA did not issue a mission assignment to OSHA implementing 

the Annex until more than 3 weeks after Hurricane Katrina struck the Gulf 

Coast, OSHA was able to establish several of its operations within hours of 

the hurricane. FEMA officials told us that all of the NRP’s annexes take 

effect when the NRP is implemented, but OSHA officials said they must 

first receive a mission assignment from FEMA to receive funding and 

begin the work as described in the Annex. OSHA used its own staff and 

budget to establish operations and provide assistance to utility workers in 

the Gulf Coast before to receiving authorization from FEMA. OSHA staff 

developed health and safety plans, provided information on safety and 

health hazards to many workers, and intervened in thousands of 

potentially hazardous situations. OSHA staff also assessed air, water, soil, 

and noise hazards at many worksites. However, OSHA waited to provide 

assistance that involved substantial funding—such as deploying worker 

safety and health trainers and purchasing protective gear for other federal 

agencies—until FEMA formally authorized OSHA to receive

reimbursement for these activities through mission assignments. 

Disagreements between OSHA and FEMA delayed issuance of the mission 

assignment that implemented the Annex, which delayed OSHA’s efforts to 

provide assistance to workers. In addition, lack of awareness by other 

agencies about OSHA’s role in a disaster further hindered its efforts. 

Because of these and other factors, the agency was unable to ensure that 

all workers’ needs for safety and health assistance were met, including 

obtaining needed training, protective gear, and mental health services, and 

OSHA had difficulty addressing the needs of nonfederal workers not 

covered under its mission assignments. 

OSHA effectively used its existing relationships with private companies 

and another federal agency to quickly establish its operations in the Gulf 

Coast area and provide safety and health assistance to workers. Through 

these relationships, OSHA quickly set up staging areas for its staff, 

obtained needed equipment, and provided safety and health information to 

OSHA Provided 

Assistance to Many 

Agencies and 

Workers, but Its 

Efforts to Meet the 

Safety and Health 

Needs of All Workers 

Were Hampered by

Several Factors 

OSHA Established 

Operations Quickly,

Developed Health and 

Safety Plans, Provided 

Valuable Information, 

Intervened in Hazardous 

Situations, and Sampled 

Work Sites

OSHA Quickly Established 

Operations in the Gulf 

Page 15 GAO-07-193 Disaster Preparedness
workers early in the response. For example, when OSHA had difficulty 

finding housing for its staff in New Orleans, it contacted a chemical 

company that is part of one of OSHA’s cooperative programs, and the 

company gave OSHA space in its parking lot for recreational vehicles that

OSHA used to house several of its field staff. OSHA also obtained support 

from the Mine Safety and Health Administration, another agency within 

the Department of Labor, for almost 3 months after the hurricane. The 

agency provided OSHA with two large trailers equipped with satellite 

communications that it uses for mine rescue operations. OSHA used the 

trailers as mobile command post centers to communicate with other 

agencies at a time when communication in the area was very difficult. The 

agency also gave OSHA generators to power electricity and plumbing. 

OSHA also capitalized on relationships with utility companies established 

during previous responses to hurricanes in the three affected states to 

target its safety and health assistance. Utility companies are among the 

first responders on the scene of hurricanes, restoring power and 

communications in the affected areas. OSHA accompanied the utility 

companies to staging areas each morning to brief workers on safety and 

distribute printed safety information. OSHA also advised utility workers 

on using the proper safety equipment. For example, although utility 

workers were trained on how to safely handle downed power lines, some 

were not aware that they needed to wear boots with steel shanks to 

prevent puncture wounds from debris containing nails and other sharp 

objects or that floodwater and drainage pipes could contain alligators, 

snakes, or other animals. Figure 2 shows some of the wildlife encountered

by Hurricane Katrina response workers. 

Page 16 GAO-07-193 Disaster Preparedness
Figure 2: Animals Such as Snakes and Alligators Presented Hazards to Workers in the Gulf Coast Area 

Source: EPA.

OSHA developed a health and safety plan for the federal response to 

Hurricane Katrina that included all responders and hazards commonly 

encountered. The plan included information on how to 

OSHA Developed a Health and 

Safety Plan for the Entire 

Response and Helped Other 

Federal Agencies Develop 

Their Own Plans • monitor exposures; 

• provide adequate supplies of protective gear that was 

• appropriate for the hazard, 

• fitted to the employee, and 

• inspected, repaired or replaced as necessary; 

• provide training on safety and health hazards that was 

• conducted before deployment, 

• applicable to general conditions, 

Page 17 GAO-07-193 Disaster Preparedness
• customized for different sites, and 

• customized for specific tasks; 

• develop decontamination procedures; and 

• provide psychological first aid and other mental health services. 

OSHA also assisted other federal agencies in developing similar plans for 

their workers and ensured that all of the plans were coordinated and 

consistent across the response. 

OSHA also provided information about hazards on its Web site and 

directly to workers at public places such as hardware stores where they 

purchased materials. For example, OSHA developed 58 small, laminated

“quick cards” and 1-page fact sheets in English and Spanish with 

information about hazards and how to address them, such as how to safely 

handle traffic in work zones, how to operate a chain saw safely, how to 

work safely with electricity, how to prevent falls, and how to use ladders 

safely. See figures 3 and 4 for selected quick cards and fact sheets 

distributed by OSHA. 

OSHA Provided Information on 

Common Hazards on Its Web 

Site and in Public Places on the 

Gulf Coast 

Page 18 GAO-07-193 Disaster Preparedness
Figure 3: Selected Quick Cards Developed by OSHA for Hurricane Katrina 

Source: OSHA.

Page 19 GAO-07-193 Disaster Preparedness
Figure 4: Selected Fact Sheets Developed by OSHA for Hurricane Katrina 

Source: OSHA.

Page 20 GAO-07-193 Disaster Preparedness
OSHA also provided pre-recorded public service announcements on its 

Web site with information on safe work practices that could be aired by

local radio stations and stores. According to OSHA officials, one large 

national hardware chain played the public service announcements over its 

loudspeaker system in stores in the Gulf area as a safety and health 

reminder for its customers. 

From the beginning of the response in August 2005 through June 2006, 

OSHA’s field staff intervened in more than 15,000 potentially hazardous 

situations at work sites throughout the Gulf—6,800 in Louisiana and 

8,320 in Alabama and Mississippi.9

 OSHA targeted these visits based on 

information it received from other federal agencies and utility companies

about work sites with large numbers of workers or potential hazards. As 

shown in figures 5, 6, and 7, OSHA staff intervened in many different types

of hazardous situations, including work zones containing equipment not 

protected from traffic by safety cones and individuals working on water 

towers and roofs without proper fall protection such as safety harnesses 

and guard rails. 

OSHA Intervened at Work Sites 

by Correcting Potential 

Hazards 

 9

OSHA refers to these visits to work sites by its field staff in which potentially hazardous 

situations were identified and corrected as “interventions.” 

Page 21 GAO-07-193 Disaster Preparedness
Figure 5: Work Zones with Equipment Not Protected from Traffic by Safety Cones 

Source: OSHA.

Page 22 GAO-07-193 Disaster Preparedness
Figure 6: Workers on a Water Tower without Fall Protection Such As Guard Rails or Safety Harnesses 

Source: OSHA.

Page 23 GAO-07-193 Disaster Preparedness
Figure 7: Workers on a Roof without Safety Harnesses and with Poorly Secured Ladders 

Source: OSHA.

OSHA staff offered advice on safety and health measures and followed up 

to make sure hazards were corrected. For example, an OSHA official in 

Louisiana stopped work at a site until unprotected workers in an aerial lift

50 feet above the ground received safety harnesses and orange cones were 

placed around the lift to protect against traffic. On the few occasions when 

an employer did not follow OSHA’s recommendations, or if there were 

repeat problems with an employer, OSHA would elevate its concerns to 

company management or to the federal agency that contracted with the 

company and this usually brought abut the needed changes, according to 

OSHA officials. For example, OSHA staff told a supervisor at one worksite 

that workers repairing a bridge needed safety harnesses to protect them 

from falls, but the workers did not have the equipment when OSHA visited 

Page 24 GAO-07-193 Disaster Preparedness
the next day. OSHA staff then called the owner of the company, who 

promptly provided the safety equipment and made sure the workers 

used it. 

Other federal agencies asked OSHA to intervene in hazardous situations. 

For example, EPA asked OSHA to monitor the health of workers at the site 

of an oil spill where more than a million gallons of crude oil leaked from 

an above-ground storage tank. FEMA asked OSHA to provide a hazardous 

materials specialist to accompany its staff to jails and Department of 

Justice buildings in New Orleans and assess what protective gear was 

needed to enter and inspect buildings and to a local hospital to assess 

general safety and health hazards. FEMA also asked OSHA to conduct airmonitoring tests and assess hazards at local courts and other public 

buildings in the area, and OSHA staff advised FEMA on how to properly 

ventilate temporary housing trailers contaminated with formaldehyde gas 

emitted by construction materials such as plywood and rugs.

Officials with OSHA and other federal agencies told us that the technical 

assistance OSHA provided during the response was well received and was 

more effective in protecting workers than if the agency had been operating

in an enforcement mode. The officials noted that enforcement actions can

take months to complete due to the legal requirements of an investigation, 

the amount of documentation required, and the due process provided to 

employers to appeal citations. By providing technical assistance and

immediately addressing hazardous situations, OSHA officials said they 

were able to assist many more workers and correct more hazardous 

situations during the response than if they had been operating in an 

enforcement mode. OSHA typically conducts about 1,500 inspections each

year in the three affected states—about 430 in Alabama, about 530 in

Louisiana, and about 500 in Mississippi—but intervened in over 

15,000 potentially hazardous situations during approximately 11 months 

of the response. 

In addition to providing safety and health technical assistance, OSHA also 

took more than 6,000 samples at work sites throughout the Gulf Coast area 

to assess air, water, soil, and noise hazards. As shown in figure 8, workers 

in the Gulf Coast area faced many airborne hazards. 

OSHA Sampled Air, Water, Soil, 

and Noise Levels at Many Work 

Sites 

Page 25 GAO-07-193 Disaster Preparedness
Figure 8: Airborne Hazards on the Gulf Coast 

Source: OSHA.

EPA was responsible for sampling the general environment—such as the 

air, water, and soil—in order to assess the dangers to the public, while 

OSHA was responsible for sampling worksites for hazardous substances 

harmful to workers. For example, OSHA field staff pinned small personal 

monitors on workers’ clothing to sample for potential exposure to 

hazardous chemicals and substances, and sampled water and soil at 

worksites (see fig. 9). 

Page 26 GAO-07-193 Disaster Preparedness
Figure 9: OSHA Field Staff Sampling the Air, Water, and Soil on the Gulf Coast by Pinning a Small Personal Monitor to a 

Worker, Taking Water Samples, and Taking Soil Samples 

Source: OSHA.

OSHA field staff also monitored unoccupied buildings for carbon 

monoxide that may have accumulated from the use of generators before 

the building was vacated and to determine whether the siding and shingles

contained asbestos. OSHA officials told us they posted the results of the 

samples taken on the agency’s Web site and said they are developing a 

data management system for future disasters that will provide faster 

access to sampling results. 

Page 27 GAO-07-193 Disaster Preparedness
OSHA and FEMA disagreed about how and when to implement the Annex 

and about each agency’s responsibilities in the rescue and recovery effort.

As a result, some of OSHA’s efforts to provide assistance were delayed. 

Additionally, before Hurricane Katrina, OSHA provided limited 

information to federal, state, and local agencies about the Annex, and 

many agencies did not understand the services OSHA can provide or that 

OSHA provides technical assistance, not enforcement, in a disaster. This 

may have contributed to agencies not inviting OSHA to participate in 

emergency preparedness exercises held prior to Hurricane Katrina or 

asking for OSHA’s help during the response and recovery efforts once the 

storm hit. 

FEMA did not issue a mission assignment to OSHA implementing the 

Annex until September 21, 2005—more than 3 weeks after the hurricane 

hit the Gulf Coast. Before Hurricane Katrina, FEMA and OSHA had not 

developed criteria or procedures for implementing the Annex in a 

disaster.10 FEMA officials told us that all of the NRP’s annexes take effect 

when the NRP is implemented; however, OSHA said it must first receive a 

mission assignment from FEMA to receive funding and begin its work as 

described in the Annex. OSHA used its own staff and budget to establish 

operations and provide assistance to workers in the Gulf before receiving

authorization for reimbursement from FEMA. However, OSHA delayed 

activities that involved substantial funding, such as deploying worker 

safety and health trainers and purchasing protective gear for other federal 

agencies, until FEMA formally authorized funding through mission 

assignments, assuring that such activities would be reimbursed. However, 

although FEMA and OSHA were developing procedures for their 

operations in future disasters, as of December 2006, these procedures did 

not contain criteria that clearly defined when and how OSHA will carry 

out its responsibilities under the Annex or the type or magnitude of 

disasters in which OSHA will be involved. 

Disagreements with FEMA 

and Lack of Awareness of 

OSHA’s Role Hindered 

OSHA’s Efforts to Assist 

Other Agencies 

OSHA and FEMA Disagreed 

about Implementation of the 

Annex and about Each Other’s 

Roles and Responsibilities 

FEMA and OSHA also disagreed about which agency was in charge of 

worker safety and health for the response and recovery efforts and which 

workers should be covered. The agency in charge assumed the role of 

Safety Coordinator at the Joint Field Office in each state, where the 

federal agencies met to coordinate their response and recovery efforts. 

 10A majority of the disaster response efforts FEMA oversees involve small, regional 

disasters, such as flooding in a single county. FEMA oversees 50 to 60 such disasters

annually. 

Page 28 GAO-07-193 Disaster Preparedness
Because of their disagreement about leadership, FEMA and OSHA each 

fulfilled the role of Safety Coordinator for different periods of time in 

Louisiana, Alabama, and Mississippi, and other federal agencies did not 

know which agency was consistently and officially in charge. In addition, 

some FEMA officials viewed the role of the Safety Coordinator as 

providing support only to FEMA employees and personnel at FEMAmanaged facilities. In contrast, OSHA officials saw the role of the Safety

Coordinator as supporting all federal workers, including federal contractor 

employees involved in the response. For example, both FEMA and OSHA 

officials in Mississippi identified a need for driver training because of the

large number of motor vehicle accidents. FEMA’s Safety Coordinator in 

Mississippi sought the driver training for FEMA staff only, while, under its 

mission assignment, OSHA had already worked with the National Institute 

of Environmental Health Sciences to develop a similar program that was 

available to all federal responders. 

In addition, under the Annex, OSHA is responsible for coordinating with 

the Department of Health and Human Services to monitor the medical 

conditions of responders and evaluate the need for long-term medical 

monitoring. However, FEMA did not direct OSHA to coordinate this 

activity in the mission assignments issued for Hurricane Katrina because, 

according to FEMA officials, they do not have the authority under the 

Stafford Act to pay for the collection and management of data for longterm studies or analysis. Although it is not clear whether there is a need 

for this type of monitoring for response and recovery workers involved in 

the response to Hurricane Katrina, the fact that some workers at the World 

Trade Center disaster did not exhibit symptoms of illnesses until months 

or years after they left the site, and others developed acute conditions at 

the site that later worsened or became chronic, highlights the importance 

of considering these issues for rescue and recovery workers who 

responded to Hurricane Katrina or for those involved in future disasters. 

FEMA and OSHA are in the process of developing new procedures for 

future disasters. However, the procedures do not specify the type or 

magnitude of disaster in which OSHA will be involved, and they include 

FEMA’s definition of the scope of the Safety Coordinator as providing 

safety and health support only to FEMA employees and personnel at 

FEMA-managed facilities, not OSHA’s definition that covers all 

responders, including federal contractor employees at all facilities. As a 

result, OSHA may have difficulty providing assistance to all workers 

involved in future response efforts. The new procedures also do not 

resolve the issue of how OSHA will be able to monitor the medical 

condition of responders or evaluate the need for long-term medical 

Page 29 GAO-07-193 Disaster Preparedness
monitoring in future disasters as described in the Annex, given that FEMA 

does not believe it can authorize such activities or reimburse them under 

the Stafford Act. 

OSHA officials told us they did not have enough time to conduct extensive 

outreach to other federal agencies in the months between the issuance of 

the NRP in December 2004 and the end of August 2005 when Hurricane 

Katrina hit the Gulf Coast. They said they planned to inform other federal 

agencies about the Annex and OSHA’s new role in large disasters through 

a committee comprised of the key federal agencies that have a role in the

Annex in responding to disasters. OSHA was in the process of developing

this committee when Hurricane Katrina hit, but these efforts were 

suspended during the response.11

Many Agency Officials Were 

Not Aware of OSHA’s Role in a 

Large Disaster 

OSHA’s efforts to inform state and local agencies about its role under the 

Annex were limited to making presentations and staffing information 

booths at training sessions conducted by the Department of Homeland 

Security after the NRP and Annex became effective in April 2005. The 

sessions were offered in seven cities to state and local emergency and 

health officials from fire departments, police departments, and local 

hospitals. The Department of Homeland Security chose to visit cities it 

considered likely targets in future terrorist attacks: the District of 

Columbia, Chicago, New York, Los Angeles, Seattle, Miami, and Houston. 

According to OSHA and FEMA officials, the presentations were attended

by individuals from federal, state, and local agencies; trade groups; and 

support personnel. OSHA officials also said they provided information 

about the Annex at meetings and conferences held by organizations such 

as the National Governors’ Association. These presentations, however, 

were not targeted to the key state and local agencies involved in disaster 

response efforts, such as state emergency management agencies. 

Officials from several federal, state, and local agencies told us that they 

did not understand OSHA’s role in a disaster response, including providing 

information on potential hazards, recommending proper protective gear, 

 11The Annex assigns responsibility to OSHA for establishing a Worker Safety and Health 

Support Annex Coordination Committee. This committee—comprised of officials from 

DOD, the Department of Energy, the Department of Health and Human Services, the 

National Institute for Occupational Safety and Health, the National Institute of 

Environmental Health Sciences, the Coast Guard, and EPA—is responsible for 

coordinating the assets needed to protect worker safety and health at all levels of 

government during a disaster. 

Page 30 GAO-07-193 Disaster Preparedness
and testing for hazardous substances at work sites. They also did not 

know that, in a disaster, OSHA switches from enforcing regulations by 

conducting inspections of work sites to providing technical assistance. 

National Guard and EPA officials we interviewed told us they did not 

know OSHA’s role in disaster response. Representatives from state police 

and fire departments in Louisiana, the state highway patrol in Alabama, 

and the Federal Law Enforcement Officers Association—an organization 

that represents officers from more than 50 different federal law 

enforcement agencies—said they did not know that OSHA provides 

technical assistance in a disaster or that they could have asked for 

OSHA’s help. 

Because many federal, state, and local agency officials did not understand 

the assistance OSHA could provide in a disaster or its role under the 

Annex, OSHA was not invited to participate in many of the emergency 

preparedness exercises the agencies held prior to Hurricane Katrina. 

Moreover, in the few exercises to which OSHA was invited, the Annex was 

never implemented. For example, OSHA attended a national emergency 

preparedness exercise conducted by FEMA in June 2005 that simulated a 

response to a large, destructive hurricane, but the exercise did not include 

implementing the safety and health Annex. OSHA headquarters officials 

told us they thought the Annex was not implemented during these 

exercises because other agency officials did not fully understand the 

assistance OSHA can provide in a disaster or its new role under the Annex. 

OSHA’s participation in state and local emergency preparedness exercises 

held prior to Hurricane Katrina was also limited. Two of OSHA Area Office 

Directors in the affected states told us they had difficulty getting invited to

participate in state and local emergency preparedness exercises, and often 

when they were invited, they did not play an active role in the exercise. 

For example, the Director of OSHA’s Mobile Area Office told us he 

attended regional training exercises on his own initiative. It took him a 

year to convince the sponsoring agencies that OSHA provides assistance in 

a disaster, at which point they incorporated OSHA into an exercise 

involving a chemical spill from a railroad car, but OSHA’s services were 

not used during the exercise. 

OSHA Was Not Invited to 

Participate in Emergency 

Preparedness Exercises Held 

Prior to Katrina 

Since its response to Hurricane Katrina, OSHA officials say the agency has 

been invited to participate in more emergency response exercises where 

the Annex is implemented and the agency plays an active role. OSHA 

officials also told us they plan to participate in an exercise sponsored by 

EPA in 2007 that will simulate a large chemical spill. OSHA’s regional and 

area office directors told us they continue to look for opportunities to 

participate in regional, state, and local emergency preparedness exercises. 

Page 31 GAO-07-193 Disaster Preparedness
Because OSHA and FEMA disagreed about the process for issuing the 

mission assignment authorizing OSHA to receive reimbursement for its 

safety and health training to workers, FEMA did not issue it until more 

than 3 weeks after the hurricane hit the Gulf Coast. As a result, OSHA and 

its cooperating agency, the National Institute of Environmental Health 

Sciences, reported that trainers who were ready to begin work in the 

aftermath of the storm were not deployed to Mississippi until October 

2005 or to Louisiana until November 2005. In addition, some agencies did

not ask OSHA to provide training because they did not realize that OSHA 

offered this type of training. For example, EPA regional officials told us 

that, although their response managers noted a need for driver safety 

training in October 2005 because of the large number of motor vehicle

accidents that occurred in the Gulf Coast area during the initial response 

efforts, it was not provided until March 2006 because it took them several

months to determine that OSHA could provide this training. Workers faced

many hazardous driving conditions during the response to Hurricane 

Katrina, including missing road signs or signs pointing the wrong 

direction, debris-strewn streets, intersections without working traffic 

signals, and lack of street lights—which made nighttime driving especially

hazardous. (See fig. 10.)

OSHA Was Only Partially 

Successful in Providing 

Training, Distributing 

Protective Gear, Serving 

Nonfederal Workers, and 

Providing Mental Health 

Services 

Some of OSHA’s Training Was 

Delayed, and Some Agencies 

Did Not Request Needed 

Training from OSHA Because 

They Did Not Realize It Was 

Available 

Page 32 GAO-07-193 Disaster Preparedness
Figure 10: Driving Hazards Faced by Workers in the Gulf Coast Area 

Source: OSHA.

FEMA authorized OSHA to receive reimbursement for establishing a 

personal protective equipment program as described in the Annex for 

other federal agencies that included the selection, ad hoc distribution, fit, 

use, and decontamination of equipment for the response to Hurricane 

Katrina. While OSHA field staff distributed ear plugs, eye goggles, 

respirators, and safety vests to workers throughout the Gulf from supplies 

they had on hand for the use of OSHA staff, the agency was unprepared to

establish a program that included procuring and distributing needed 

equipment on an ad hoc basis to other agencies as required by its mission 

assignment from FEMA. In its lessons learned from the World Trade 

Center disaster, OSHA recognized the need to ensure an adequate supply 

of personal protective equipment before a future incident and to develop a 

OSHA Distributed Some 

Protective Equipment to 

Workers but Was Not Prepared 

to Establish a Protective 

Equipment Program, As 

Required 

Page 33 GAO-07-193 Disaster Preparedness
program to ensure for the storage, transportation, and distribution of this

equipment through FEMA and other federal agencies. However, OSHA did 

not have such a program in place prior to Katrina, and OSHA and FEMA 

disagreed on how to obtain personal protective equipment: OSHA ordered 

equipment from its Cincinnati Technology Center, while FEMA ordered 

equipment from its contractor. In addition, OSHA had not made prior 

arrangements for storing the equipment during the response. OSHA and 

FEMA resolved their disagreements about suppliers and OSHA arranged to

store equipment in its area offices and FEMA-managed facilities near the

Joint Field Offices in Louisiana and Mississippi, but these difficulties 

delayed the provision of some equipment to workers and highlighted the 

need to establish a personal protection equipment program in advance of a 

disaster. 

Some federal agency officials reported needing advice on proper 

protective gear, and other officials reported a shortage of equipment. For 

example, National Guard officials in Louisiana told us they would have 

liked information from OSHA on the hazards workers were facing, 

recommendations on how to protect workers, and assistance in obtaining 

protective equipment such as rubber boots needed to protect workers 

from contaminated floodwaters. USACE officials told us they had 

difficulty obtaining sufficient supplies of protective equipment such as 

gloves and reflective vests. 

OSHA officials told us the agency has not yet fully addressed what the 

personal protective equipment program, as defined in the Annex, should 

entail. Issues to be addressed include obtaining agreement with FEMA on 

how such equipment should be purchased and where it will be stored, how 

the equipment will be distributed at disasters, and which workers will be 

entitled to receive the equipment. 

FEMA tasked OSHA with coordinating with the Department of Health and 

Human Services to ensure that mental health assistance was provided to 

workers during the response to Hurricane Katrina.12 However, OSHA did 

not coordinate with them to ensure that all workers in the Gulf area who

needed mental health services received them, and OSHA had difficulty 

The Need for Mental Health 

Services Exceeded the 

Assistance OSHA Provided 

 12Specifically, OSHA was tasked with providing short-term psychological first aid during

and after incident response and recovery activities. Psychological first aid is an approach 

to help children, adolescents, adults and families in the immediate aftermath of disaster 

and terrorism. It is designed to reduce the initial distress caused by traumatic events and to

foster short-and long-term adaptive functioning and coping. 

Page 34 GAO-07-193 Disaster Preparedness
obtaining these services. OSHA and FEMA officials told us it was difficult 

to get mental health counselors to go to the base camps where workers 

lived during the response and to get counselors to provide services during 

off-hours to workers who did not have standard work schedules. They also 

said it was difficult to obtain mental health services for non-FEMA 

employees because while FEMA believed its contract with a unit of the 

Department of Health and Human Services, Federal Occupational Health ,

to provide counseling would cover all federal workers responding to 

Hurricane Katrina, the contractor interpreted the contract to only cover 

FEMA workers. In addition, instead of sending counselors to work sites 

throughout the Gulf, the contractor provided a toll-free number for 

workers to call. This was not an effective way to provide services because

phone service in the Gulf was widely disrupted, and OSHA and FEMA 

officials said they thought on-site counseling was a better way to help 

workers. Although the contractor eventually provided services to nonFEMA employees by sending counselors to work sites and base camps in 

the Gulf area and distributing literature about available services, these 

efforts did not begin until late December 2005—too late to address the 

needs of response workers who were most in need of these services and 

the needs of many recovery workers involved early in the response. 

According to a FEMA official, the agency recently began an effort to 

review its contracts to ensure that non-FEMA employees are explicitly 

covered in the event of a future disaster response. However, OSHA 

headquarters officials told us that, in their opinion, ensuring that mental 

health services are available to workers in a disaster response should not

be part of OSHA’s responsibilities under the Annex because the agency 

does not have the resources needed; this responsibility should be placed 

with a federal agency that has subject matter expertise and access to 

appropriate mental health resources, such as the agencies within the 

Department of Health and Human Services. OSHA officials we interviewed 

said they are coordinating with FEMA and the Department of Health and

Human Services to improve the delivery of psychological first aid and 

informational materials during future disasters. Such efforts include 

distributing pamphlets to workers and their families throughout the Gulf 

area; consulting with other agencies to learn what types of mental health

assistance are most appropriate for workers who respond to disasters; 

developing pamphlets on mental health issues for employers, employees, 

and their families; and distributing these pamphlets to OSHA area offices 

and other federal agencies to use during future disaster responses. 

Page 35 GAO-07-193 Disaster Preparedness
Although OSHA staff intervened to assist any worker when they observed

unsafe work practices, some of the safety and health needs of nonfederal 

workers not covered by OSHA’s mission assignments for Hurricane 

Katrina—state and local government employees, immigrants, and 

volunteers—involved in the response were not met.13 OSHA officials in 

Alabama, Louisiana, and Mississippi said it was difficult to address the 

needs of these populations. The mission assignment FEMA issued to 

OSHA only covered federal workers and federal contractor employees. 

OSHA’s efforts, therefore, were focused on those workers, and no other 

federal agency had responsibility for meeting the safety and health needs 

of nonfederal workers. OSHA had limited access to state and local 

workers because the states did not request the agency’s assistance. OSHA 

also had difficulty addressing the needs of immigrant workers because of

language barriers, low literacy levels among some immigrants, the 

transience of many employers that hire immigrant workers, and 

immigrants’ fear of deportation and the federal government. In addition, 

OSHA had no authority to compel volunteer workers in the Gulf to follow 

safe work practices. 

Although OSHA Provided Some 

Information and Training to 

Nonfederal Workers in the 

Gulf, the Safety and Health 

Needs of Some Workers Were 

Not Met 

Some state and local agency officials reported that they could have 

benefited from additional assistance from OSHA, including information 

about potential hazards and protective equipment for their workers. For 

example, Louisiana state troopers involved in recovering bodies were 

provided with boots and gloves, but officials said they would have liked 

additional information on potential hazards and guidelines on appropriate 

protective gear such as waders and on proper decontamination 

procedures. Similarly, many state and local agencies reported that they did 

not have waders to protect workers from contaminated flood waters. An 

official with the New Orleans Police Department told us the only staff who 

had waders to use during rescue efforts were fishermen and hunters who

owned their own waders. However, because the governors of the three 

states most affected by Hurricane Katrina did not request OSHA’s 

assistance, the mission assignments issued to OSHA by FEMA did not 

cover state or local workers, they only covered federal workers. As a 

result, OSHA’s efforts were focused on providing assistance to federal 

agencies and workers. 

 13Some immigrants may have been employed by federal contractors and, therefore, covered 

under OSHA’s mission assignments, but many of these workers were not employed by 

federal contractors. 

Page 36 GAO-07-193 Disaster Preparedness
Several advocacy groups have issued reports highlighting the worker 

safety and health issues among immigrant workers in the Gulf Coast area 

who lacked information on hazards, training, and protective equipment. 

For example, a study by the Advancement Project, the National 

Immigration Law Center, and the New Orleans Worker Justice Coalition 

concluded that, in their opinion, the level of health and safety training and 

equipment provided to many workers in the Gulf area, including 

immigrants, fell well below federal standards.14

OSHA trained its staff on the cultural aspects of working with immigrant 

populations, hired some bilingual field staff, and built relationships with 

immigrant advocacy groups. For example, OSHA’s Mississippi Area Office 

hired several Hispanic staff to provide training to immigrant workers and 

participated in several local cultural events and job fairs to improve 

workers’ awareness of OSHA’s role in protecting workers. In addition, 

OSHA officials in Alabama, Louisiana, and Mississippi developed worker 

safety literature in Spanish and Vietnamese, two languages frequently used

by non-English speaking workers in the Gulf Coast area, and distributed 

the literature at cultural events sponsored by immigrant groups. The unit 

that conducted most of OSHA’s training in the Gulf area through an 

interagency agreement, the National Institute of Environmental Health 

Sciences, developed brochures in Spanish and Vietnamese.15 (See fig. 11.)

 14The Advancement Project, the National Immigration Law Center, and the New Orleans 

Worker Justice Coalition, And Injustice For All: Workers’ Lives in the Reconstruction of

New Orleans, (2006).

15The National Institute of Environmental Health Sciences is part of the Department of

Health and Human Services’ National Institutes of Health. 

Page 37 GAO-07-193 Disaster Preparedness
Figure 11: Safety Brochures in English, Spanish, and Vietnamese

Source: National Institute of Environmental Health Sciences.

OSHA officials told us they issued five public service announcements in 

Spanish and translated 26 safety and health technical assistance 

documents into Spanish and 3 into Vietnamese. They also said they 

Page 38 GAO-07-193 Disaster Preparedness
worked closely with the Mexican Consulate offices in Houston, Texas and

Atlanta, Georgia to address concerns about the safety of Hispanic workers 

involved in the response. For example, according to OSHA, the consulate 

in Houston arranged several events in New Orleans designed to give the 

Hispanic community a chance to raise concerns and meet with OSHA staff. 

In addition, OSHA officials said they worked with local Catholic churches

to reach Hispanic workers in the New Orleans area. 

OSHA also raised concerns about the safety and health of volunteers who 

arrived in the Gulf Coast area to assist in the recovery efforts, including

concerns about the lack of training and protective equipment among the 

volunteers. For example, OSHA staff encountered several volunteers 

working on roofs without the proper training or proper fall protection. 

OSHA staff intervened when they encountered such situations and, 

according to agency officials in the Gulf area, provided on-site training and 

protective equipment to volunteer workers when it was available. 

Although OSHA did not have a lot of time to prepare for its new role in a 

disaster between the time the NRP became effective and when Hurricane 

Katrina struck the Gulf Coast, the agency moved quickly to provide 

assistance to workers who were part of the early response effort and those 

involved in recovery work. In preparing for future disasters, however, it is 

important for OSHA to note the areas in which its efforts in responding to

Hurricane Katrina could have been improved. Without the ability to collect 

data on injuries and illnesses sustained by workers involved in disaster 

recovery efforts, OSHA cannot fulfill its role as defined in the Annex to 

identify trends and use this information to prevent further injuries and 

illnesses by informing workers and their employers about potential safety

and health hazards. Furthermore, unless OSHA and FEMA clearly define

their roles, the type and magnitude of the disasters in which OSHA will be

involved, and how and when the Annex will be implemented, there may 

continue to be delays in providing critical assistance and information 

needed to protect workers in future disasters. As a result, workers may 

sustain injuries and illnesses that could have been prevented. In addition, 

if OSHA and FEMA do not resolve the issue of who is responsible for 

assessing the need and paying for long-term medical monitoring of 

workers involved in a response effort, these needs may not be met in 

future disasters. 

Conclusions 

Because OSHA has not taken a proactive role in educating many federal, 

state, and local agencies and their workers about the role the agency plays 

in large disasters, some of the agencies do not know about the assistance 

Page 39 GAO-07-193 Disaster Preparedness
OSHA can provide or how to request it. Similarly, by not seeking 

opportunities to participate in emergency preparedness exercises held by

federal, state, and local agencies, OSHA has not been able to demonstrate 

the assistance it can provide or how the agencies can obtain its services 

during a disaster. As a result, without knowledge of OSHA’s role, it is 

unlikely that state and local agencies will request OSHA’s assistance in 

future disasters, hampering the agency’s ability to meet the safety and 

health needs of nonfederal workers, many of whom are first responders. 

Further, because OSHA was not prepared to establish a program for 

providing information on what protective equipment is needed or how to 

use it during future disasters or for ensuring that agencies obtain adequate

supplies of equipment, workers may not be properly protected from 

potential hazards. Finally, some workers’ needs for mental health services

in future disasters may not be not met, and the full extent of workers’ 

unmet mental health needs will not be known because OSHA has not 

coordinated with the Department of Health and Human Services to 

determine how it will assess the need for mental health services or ensure 

that these services are provided to rescue and recovery workers. 

In order to improve the ability to meet workers’ safety and health needs in

the event of a future disaster, the Secretaries of the Departments of Labor 

and Homeland Security should direct the Administrators of OSHA and 

FEMA to 

Recommendations for 

Executive Action 

• clearly define the criteria to be used in deciding when OSHA will be 

responsible for carrying out its duties under the Worker Safety and 

Health Support Annex to the National Response Plan, including the 

types and magnitude of disasters in which OSHA will be involved, 

and 

• clearly define OSHA’s and FEMA’s roles under the Worker Safety 

and Health Support Annex, including resolving the issue of how the 

need for long-term medical monitoring of workers involved in the 

response to future disasters will be met; and 

• proactively work to provide information to federal, state, and local 

agencies about OSHA’s role in a disaster and the assistance it can 

provide under the Worker Safety and Health Support Annex, 

including seeking opportunities for OSHA to participate in

emergency preparedness exercises at federal, state, and local levels. 

Page 40 GAO-07-193 Disaster Preparedness
In addition, the Secretary of the Department of Labor should direct OSHA 

to 

• establish a process for collecting data on injuries and illnesses 

sustained by workers who respond to disasters as defined in the 

Worker Safety and Health Support Annex to the National Response 

Plan, such as requiring employers to record injuries and illnesses on 

logs maintained at each disaster work site and periodically submit 

them to OSHA during the response;

• use the information collected on injuries and illnesses to identify 

safety and health hazards and analyze injury and illness trends; and 

• develop, implement, and monitor an incident personal protective

equipment program as defined in the Worker Safety and Health 

Support Annex. 

In order to improve the ability to meet workers’ needs for mental health 

services in the event of a future disaster, the Secretaries of the 

Departments of Labor and Health and Human Services should 

• develop a plan for coordinating and providing mental health 

services to response and recovery workers as described in the 

Worker Safety and Health Support Annex to the National Response 

Plan. 

We provided a draft of this report to the Secretaries of the Departments of 

Agriculture, Health and Human Services, Homeland Security, the Interior, 

and Labor; EPA; the Coast Guard; DOD; the National Guard; and USACE 

for comment. We received written comments from the Departments of 

Health and Human Services and Labor, which are reproduced, along with

our response in appendixes III and IV. Both agencies also provided 

technical comments, which we incorporated in the report as appropriate. 

Agency Comments 

and Our Evaluation 

The Department of Health and Human Services agreed with our 

recommendations. The Department of Labor agreed with our 

recommendation for OSHA to establish a process for collecting data on 

injuries and illnesses sustained by workers who respond to disasters as 

defined in the Annex, although it noted several challenges in doing so. 

Although the agency did not comment on the other recommendations, it

disagreed with our findings in several areas and provided additional 

information on the actions it took to provide assistance to agencies and

Page 41 GAO-07-193 Disaster Preparedness
workers. Officials with the Department of Homeland Security stated in 

oral comments that they agreed with our findings and recommendations 

and provided written technical comments, which we incorporated as 

appropriate. The Department of the Interior, the Coast Guard, and the 

National Guard also provided technical comments, which we incorporated 

as appropriate. DOD did not respond to our request for comments. 

Officials with EPA, USACE, and the Department of Agriculture told us that 

they had no comments on the report. 

We will make copies of this report available upon request. In addition, the 

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

If you have any questions about the report, please contact me at 

(202) 512-5988 or at bertonid@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 the report are listed in appendix V. 

Daniel Bertoni 

Director, Education, Workforce 

and Income Security Issues 

Page 42 GAO-07-193 Disaster Preparedness
List of Congressional Committees

The Honorable Edward M. Kennedy 

Chairman 

The Honorable Michael B. Enzi 

Ranking Minority Member 

Committee on Health, Education, Labor, and Pensions 

United States Senate 

The Honorable Joseph Lieberman 

Chairman 

Committee on Homeland Security and Governmental Affairs 

United States Senate 

The Honorable Tom Harkin 

Chairman 

Subcommittee on Labor, Health and Human Services, 

Education and Related Agencies 

Committee on Appropriations 

United States Senate 

The Honorable Patty Murray 

Chairman 

Subcommittee on Employment and Workplace Safety 

Committee on Health, Education, Labor, and Pensions 

United States Senate 

The Honorable George Miller 

Chairman 

Committee on Education and Labor

House of Representatives 

The Honorable Tom Davis 

Ranking Minority Member 

Committee on Oversight and Government Reform 

House of Representatives 

The Honorable James T. Walsh 

Ranking Minority Member 

Subcommittee on Labor, Health and Human Services, Education and 

 Related Agencies 

Committee on Appropriations 

House of Representatives 

Page 43 GAO-07-193 Disaster Preparedness
The Honorable Henry Cuellar 

Chairman 

The Honorable Charles W. Dent 

Ranking Minority Member 

Subcommittee on Emergency Communications, Preparedness, 

 and Response 

Committee on Homeland Security 

House of Representatives 

Page 44 GAO-07-193 Disaster Preparedness
Appendix I: Scope and Methodology 

Page 45 GAO-07-193

Appendix I: Scope and Methodology 

We met with OSHA national, regional, and area office officials to obtain a 

general understanding of their specific roles and responsibilities under the 

National Response Plan (NRP) and the Worker Safety and Health Support

Annex (the Annex). We documented the steps OSHA took to ensure the 

safety and health of workers in the Gulf Coast area during the response to 

Hurricane Katrina; the extent of the agency’s coordination with other 

federal, state, and local government officials; and the lessons learned that 

included any new initiatives that had been implemented or were being 

considered.

We also met with officials from federal agencies that, according to OSHA 

and FEMA officials, deployed federal workers and contractor employees 

to the Gulf Coast in response to Hurricane Katrina: OSHA; FEMA; EPA; the 

Coast Guard; DOD; the National Guard; USACE; and the Departments of 

Agriculture, Health and Human Services, and the Interior. As a part of our

interviews, we asked about them the extent of their involvement with 

OSHA, lessons learned, and specific initiatives being implemented or 

planned to address the challenges faced by their workers during Hurricane 

Katrina. In addition, we interviewed representatives of several workers’ 

rights groups to obtain their perspectives on the role OSHA played in

protecting the safety and health of workers involved in the response to 

Hurricane Katrina, including the safety and health of the immigrant 

population. These groups included Boat People SOS, the Mississippi 

Immigrants Rights Alliance, the Center to Protect Workers’ Rights, and the 

New York Committee for Occupational Safety and Health. We also 

reviewed several studies on emergency preparation, response, and 

recovery efforts conducted prior to and during Hurricane Katrina. 

We conducted our work from October 2005 to December 2006 in 

accordance with generally accepted auditing standards. 

Analysis of Agency 

Documents 

We reviewed provisions of the NRP and the Annex to identify the specific 

roles and responsibilities of OSHA in an incident of national disaster or a 

catastrophic event. We also reviewed state emergency management plans 

in Alabama and Louisiana to determine whether these state plans had 

provisions for ensuring the safety and health of rescue and recovery 

workers. Mississippi did not have a current state emergency management 

plan. 

Disaster Preparedness
Appendix I: Scope and Methodology 

To provide some perspectives on the extent of OSHA effectiveness for 

ensuring safety and health of workers at the state and local levels, we 

conducted site visits in Alabama, Louisiana, and Mississippi, the states that 

suffered the most damage from Hurricane Katrina. We spoke with OSHA 

regional and area officials as well as federal officials from FEMA, EPA, 

and USACE. We also interviewed many state and local response and 

recovery workers, including state police in Louisiana and Mississippi; local 

law enforcement in New Orleans, Louisiana and Jackson, Mississippi; 

firefighters in New Orleans, Louisiana; the Louisiana Department of 

Wildlife and Fisheries; the Louisiana Department of Environmental 

Quality; and a county emergency management official in Mississippi. In 

addition, in March 2006, we attended a conference sponsored by the 

National Institute of Environmental Health Sciences that discussed the 

various lessons learned and challenges federal agencies encountered 

during the responses to Hurricanes Katrina and Rita. 

Because OSHA was unable to collect useable data on the number of 

injuries and illnesses sustained by federal workers in the Gulf Coast area, 

we asked the 10 agencies that sent rescue and recovery workers to the 

Gulf Coast to provide this information. Although agency officials told us 

that they tracked illnesses and injuries on the work site logs that OSHA 

requires them to maintain, they were not able to separate out this 

information for all workers deployed to the Gulf Coast because injuries 

and illnesses are recorded at the work sites where workers are 

permanently assigned, not the work sites to which they were temporarily 

assigned during the response. 

Site Visits 

Data from Federal 

Agencies on Injuries and 

Illnesses 

We asked these agencies whether they maintained their own data on 

workers who were injured or became ill as a result of their work in the 

Gulf area. Four of the 10 agencies—EPA, USACE, the Coast Guard, and 

the Department of the Interior—provided data on injuries and illnesses for 

workers deployed to the Gulf Coast that were sufficiently reliable for us to

report. However, each of these agencies used different methods to report 

this information. In an effort to summarize the injury and illness data 

reported by the agencies, we developed a coding scheme for classifying 

and combining the data on injuries and illnesses provided by EPA and 

USACE into more consistent and concise categories. For example, we 

classified an injury described in USACE’s data as “contractor chain saw 

operator suffered laceration,” as a “laceration,” and an injury described in 

EPA’s data as “employee lost his footing and fell onto the deck landing,” as 

a “trip/fall.” We determined that the codes used by the Coast Guard were 

sufficiently reliable in coding scheme to use to report the number and 

Page 46 GAO-07-193 Disaster Preparedness
Appendix I: Scope and Methodology 

types of injuries and illnesses sustained by their workers. We received the 

data from the Department of the Interior too late to include it in its 

entirety but provided a brief summary of the types of injuries and illnesses 

sustained by its workers in the Gulf Coast area (see app. II). 

In addition, to determine the number and types of injuries and illnesses 

sustained by their workers, we looked at the nature and causes of the 

injuries and illnesses reported by the four agencies and, where possible, 

the number of injuries and illnesses reported for each month. Because 

some incidents reported by EPA and USACE contained more than one 

injury or illness, we used more than one code to report on the type of 

injury or illness sustained. For example, we classified an injury reported 

by EPA where an employee had “pulled and strain neck and back from a 

motor vehicle accident,” as a “motor vehicle accident” and a “pain/strain.” 

As a result, the total number of injuries and illness reported by the 

agencies may differ from the numbers we reported. 

Data on Federal and State 

Workers’ Compensation 

Claims 

Because the data on injuries and illnesses provided by the federal agencies 

on their workers were limited, we obtained information on workers’ 

compensation claims filed by federal workers from the Department of 

Labor’s Office of Workers’ Compensation Programs in order to obtain 

more information about injuries and illnesses sustained by federal workers 

involved in the response. The Office of Workers’ Compensation Programs 

provided us with data on 770 claims related to Hurricanes Katrina and Rita

filed from August 2005 through June 2006.1

 However, we found that the 

data provided to us on claims filed by federal workers were not 

sufficiently reliable to use in reporting the types of injuries and illnesses 

sustained by federal workers involved in the response. 

 1

Officials with the Office of Workers’ Compensation Programs told us they could not

separate claims related to Hurricane Katrina from claims related to Hurricane Rita using 

the information recorded in their database. 

Page 47 GAO-07-193 Disaster Preparedness
Appendix II: Data on the Estimated Number 

of Federal Workers Who Responded to 

Hurricane Katrina and Their Injuries and 

Illnesses 

Appendix II: Data on the Estimated Number 

of Federal Workers Who Responded to 

Hurricane Katrina and Their Injuries and 

Illnesses 

Officials with OSHA and FEMA told us the following federal agencies sent 

workers to Alabama, Louisiana, and Mississippi—the three states that 

sustained the most damage from Hurricane Katrina—to perform rescues 

and conduct recovery work such as clearing debris: 

1. the Department of Agriculture; 

2. the Department of the Interior; 

3. the Coast Guard; 

4. FEMA; 

5. EPA; 

6. the Department of Health and Human Services, including the Centers 

for Disease Control and Prevention, the National Institutes of Health, 

the Food and Drug Administration, the Office of Force Readiness and 

Deployment, and the Substance Abuse and Mental Health Services 

Administration; 

7. OSHA; 

8. USACE; 

9. DOD, including the Air Force, Army, Navy, and Marine Corps; and 

10. the National Guard. 

In early May 2006, we asked these agencies to provide us with the number 

of employees and contract employees they employed in the three states to 

assist with rescue and recovery work related to Hurricane Katrina from 

the beginning of the response through April 1, 2006. Many agency officials 

told us that they could not provide the total number of workers for the 

entire period because they did not collect data in a way that would enable

them to provide us with unduplicated counts of workers who rotated in 

and out of the Gulf Coast area. However, many said they could provide us

with estimates of the total number of workers for specific points in time so 

we requested such data from all 10 agencies. 

We asked them to provide the total number of full-time equivalent workers 

they employed in Alabama, Louisiana, and Mississippi on the first day of 

each month from September 1, 2005, through April 1, 2006. We also asked 

them to exclude employees of other agencies that were temporarily 

Page 48 GAO-07-193 Disaster Preparedness
Appendix II: Data on the Estimated Number 

of Federal Workers Who Responded to 

Hurricane Katrina and Their Injuries and 

Illnesses 

assigned to them or volunteers who were not government employees or 

contractors. All of the agencies submitted estimates for their federal 

employees working in the Gulf area, although some agencies were not able 

to provide information on all personnel deployed to the Gulf Coast.1

 Only 6 

of the 10 agencies tracked information on the number of workers 

employed by their contractors in these three states to work on response 

and recovery work related to Hurricane Katrina: the Departments of 

Agriculture, the Interior, Health and Human Services, EPA, OSHA, and 

FEMA. Although officials with three of the other four agencies—the 

Department of Defense, USACE, and the Coast Guard—said they 

employed contractors in the Gulf, they did not track the number of 

workers employed by their contractors. Officials from the National Guard 

told us they did not employ contractors in the Gulf Coast area.

We obtained data from OSHA and the other agencies on 11 response and 

recovery workers who died in the Gulf, 9 of whom were killed in workrelated accidents. OSHA provided information on 10 fatalities, 9 of which 

were work-related, and USACE on 2 fatalities, one of which was workrelated.2

 All of the other agencies said that none of their workers was 

killed during the response to Hurricane Katrina. (See table 1 for additional 

information on these fatalities.) 

 1

DOD, for example, did not track the number of active duty Navy personnel who assisted 

with rescue and recovery efforts in the Gulf because the Navy base was damaged by the

hurricane and they were not able to report this information.

2

Both OSHA and USACE provided us with information on one of the fatalities. 

Page 49 GAO-07-193 Disaster Preparedness
Appendix II: Data on the Estimated Number 

of Federal Workers Who Responded to 

Hurricane Katrina and Their Injuries and 

Illnesses 

Table 1: Number of Fatalities Reported by OSHA and Other Federal Agencies 

State Description of incident Employer

Workrelated?

Louisiana A worker was struck by a 

bulldozer at a debris site. 

Employee of a federal

subcontractor for USACE 

Yes 

Louisiana A worker was crushed during the 

installation of a parked trailer that 

was accidentally released and ran 

over him. 

Employee of a federal

subcontractor for FEMA 

Yes 

Louisiana A worker who was attempting to 

reinstall electrical services to a 

residence was electrocuted. 

Nonfederal employee or 

volunteer 

Yes 

Louisiana A worker suffered a massive heart 

attack while sitting in a company 

truck. 

Nonfederal employee or 

volunteer 

No 

Louisiana A maintenance worker fell 18 feet 

to his death after receiving an

electric shock. 

Nonfederal employee or 

volunteer 

Yes 

Mississippi A worker operating a tractor to 

clear debris died when the tractor 

overturned into a ditch with 51⁄2

feet of water, pinning the operator 

under the tractor. 

Employee of a federal

subcontractor for FEMA 

Yes 

Mississippi A worker was killed when a 75

foot pole fell from a forklift and 

struck him. 

Nonfederal employee or 

volunteer 

Yes 

Mississippi A worker fell 40 feet to the floor of 

a warehouse. 

Nonfederal employee or 

volunteer 

Yes 

Mississippi Two workers on a casino barge 

were overcome by hydrogen 

sulfide fumes and drowned. 

Nonfederal employees or 

volunteers 

Yes 

Mississippi Employee died on the way to work 

as the result of a car accident. 

Employee of a federal

subcontractor for USACE 

No 

Source: GAO analysis of OSHA and USACE data.

Because OSHA was unable to collect data on the number of injuries and 

illnesses sustained by federal workers in the Gulf Coast area, we asked the 

10 agencies that sent workers to the Gulf Coast area to provide this 

information. Although agency officials told us that they tracked illnesses 

and injuries on the worksite logs that OSHA requires them to maintain, 

they were not able to separate out this information for all workers 

deployed to the Gulf Coast because injuries and illnesses are recorded at 

the worksites where workers are permanently assigned, not the worksites 

to which they were temporarily assigned during the response.

Page 50 GAO-07-193 Disaster Preparedness
Appendix II: Data on the Estimated Number 

of Federal Workers Who Responded to 

Hurricane Katrina and Their Injuries and 

Illnesses 

We asked these agencies whether they maintained their own data on 

workers who were injured or became ill as a result of their work in the 

Gulf Coast area. Four of the 10 agencies—EPA, USACE, the Coast Guard, 

and the Department of the Interior—provided data on injuries and 

illnesses for workers in the Gulf area that were sufficiently reliable for us 

to report. However, each agency used different descriptions of the injuries 

and illnesses to report the information collected. In an effort to summarize 

the data reported by the agencies, we developed our own categories to use 

in classifying and collapsing the descriptions of injuries and illnesses 

provided by EPA and USACE into more consistent and easily understood 

categories. For example, for an injury described in USACE’s data as 

“contractor chain saw operator suffered laceration,” we reclassified it as a 

“laceration;” and for an injury described in EPA’s data as “employee lost 

his footing and fell onto the deck landing,” we reclassified it as a “trip/fall.” 

We determined that the descriptions and categories used by the Coast 

Guard were sufficiently clear to use in reporting the number and types of

injuries and illnesses sustained by their workers. We received the data 

from the Department of the Interior too late to reclassify it and report it in 

its entirety, but we provided a brief summary of the types of injuries and 

illnesses sustained by its workers deployed to the Gulf Coast on page 58. 

To determine the number and types of injuries and illnesses sustained by 

their workers deployed to the Gulf Coast, we looked at the nature and 

causes of the injuries and illnesses reported by the agencies and, where 

possible, the number of injuries and illnesses reported for each month. 

Because some incidents reported by EPA and USACE contained more 

than one injury and/or illness, we used more than one code to report on 

the type of injury and illness sustained. For example, where EPA reported 

that an employee had pulled and strain neck and back from a motor 

vehicle accident, we classified it as “motor vehicle accident” and 

“pain/strain.” As a result, the total number of injuries and illness reported 

by these agencies may differ from the types of injuries and illnesses 

reported for that same time frame. 

Page 51 GAO-07-193 Disaster Preparedness
Appendix II: Data on the Estimated Number 

of Federal Workers Who Responded to 

Hurricane Katrina and Their Injuries and 

Illnesses 

EPA reported information on the number of injuries and illnesses 

sustained by their federal workers and contractor employees. (See 

table 2.) 

Table 2: Reported Number of Injuries and Illnesses for EPA, August 2005 to June 

2006 

Month Region 4 Region 6 Total

August 0 0 0

September 0 7 7

October 1 22 23

November 1 32 33

December 0 14 14

January 0 13 13

February 0 12 12

March 0 7 7

April 0 5 5

May 0 8 8

June 0 2 2

Total 2 122 124

Source: GAO analysis of EPA data. 

Note: These numbers represent data on EPA agency personnel, employees of their contractors, and 

employees of the Tennessee Valley Authority. At OSHA’s request, EPA collected data on all types

and causes of hurricane response-related injuries and illnesses. However, according to EPA, the 

totals do not include some minor injuries and illnesses. 

Page 52 GAO-07-193 Disaster Preparedness
Appendix II: Data on the Estimated Number 

of Federal Workers Who Responded to 

Hurricane Katrina and Their Injuries and 

Illnesses 

EPA also provided information on the types of injuries and illnesses these 

workers sustained. (See table 3.) 

Table 3: Reported Types of Injuries and Illnesses for EPA, August 2005 to June 

2006 

Type of Injury or Illness Region 4 Region 6 Total

Cut/scrape/bruise 0 43 43

Skin condition 0 16 16

Pain/strain 0 13 13

Animal/insect bite 0 12 12

Sprain/fracture 1 10 11

Irritation 0 9 9

Chemical Splash 0 6 6

Trip/fall 0 4 4

Medical condition 0 3 3

Chemical exposure 0 3 3

Infection 0 2 2

Exhaustion/dehydration/heat stress 0 2 2

Smoke exposure 0 1 1

Nausea 0 1 1

Burn 0 1 1

Viral infection 0 1 1

Motor vehicle accident 0 1 1

Seizure 0 1 1

Acute appendectomy 0 1 1

Rupture 1 0 1

Total 2 130 132

Source: GAO analysis of EPA data. 

Page 53 GAO-07-193 Disaster Preparedness
Appendix II: Data on the Estimated Number 

of Federal Workers Who Responded to 

Hurricane Katrina and Their Injuries and 

Illnesses 

USACE reported information on the number of injuries and illnesses 

sustained by their federal workers and contractor employees. (See 

table 4.) 

Table 4: Reported Number of Injuries and Illnesses for USACE, August 2005 to June 

2006 

Month Total

August 0

September 64

October 99

November 49

December 40

January 95

February 70

March 75

April 46

May 17

June 7

Total 562

Source: GAO analysis of USACE data. 

Page 54 GAO-07-193 Disaster Preparedness
Appendix II: Data on the Estimated Number 

of Federal Workers Who Responded to 

Hurricane Katrina and Their Injuries and 

Illnesses 

USACE also reported information on the types of injuries and illnesses 

sustained by these workers. (See table 5.) 

Table 5: Reported Types of Injuries and Illnesses for USACE, August 2005 to June 

2006 

Injury/Illness Category Total

Motor vehicle accident 247

Motor vehicle rollover 90

Property damage 62

Struck by object 48

Trip/fall 25

Cut/scrape/bruise 24

Animal/Insect bites 13

Laceration 11

All other injuries 11

Pain/strain 8

Fire 7

Sprain/fracture 6

Broken limb 5

Limb caught in object 4

Skin conditions 3

Operational stress 3

Unknown 3

Burn 2

Contusion 2

Medical conditions 2

Fatality 2

Violence 2

Muscle spasm 1

Heat exposure 1

Gastrointestinal 1

Total 583

Source: GAO analysis of USACE data. 

The Coast Guard provided information on injuries and illnesses sustained 

by their workers and contractor employees from November 2005 though

March 2006 in several different categories. According to Coast Guard 

officials, about 5 percent of the data it received on illnesses and injuries 

Page 55 GAO-07-193 Disaster Preparedness
Appendix II: Data on the Estimated Number 

of Federal Workers Who Responded to 

Hurricane Katrina and Their Injuries and 

Illnesses 

that occurred during this period had not been entered into its injury and 

illness tracking system. It reported data on the number of types of 

exposures their federal workers and contractor employees experienced

during the response. (See table 6.) 

Table 6: Reported Exposures for the Coast Guard, November 2005 to March 2006 

Type of Exposure Total

Animal vector (e.g., bites from insects such as mosquitoes or animals such as 

snakes and dogs) 

1,171

Sunburn 1,002

Floodwater 737

Heat stress 727

Chemicals 684

Infectious agents or biological agents 659

Mold exposure 562

Carbon monoxide 246

Total number of exposures 5,788

Source: GAO analysis of Coast Guard data. 

The Coast Guard also reported the number of injuries sustained by their 

federal workers and contractor employees. (See table 7.) 

Table 7: Reported Injuries for the Coast Guard, November 2005 to March 2006 

Injuries Total

Penetrating injury 419

Slips, trips, falls 136

Total number of injuries 555

Source: GAO analysis of Coast Guard data. 

Page 56 GAO-07-193 Disaster Preparedness
Appendix II: Data on the Estimated Number 

of Federal Workers Who Responded to 

Hurricane Katrina and Their Injuries and 

Illnesses 

In addition, the Coast Guard provided data on the health effects of the 

injuries and illnesses sustained by their federal workers and contractor 

employees. (See table 8.)

Table 8: Reported Health Effects for the Coast Guard, November 2005 to March

2006 

Health Effects Totals 

Sinus infections 299

Diarrhea 196

Skin rash 179

Dehydration 174

Other (e.g., cough, fatigue, flu, headache) 157

Joint pain 151

Loss of appetite 139

Muscle strain 138

Depression 134

Nausea 132

Difficulty concentrating 128

Skin lacerations 87

Cramps 61

Vomiting 50

Skin puncture 50

Infected skin 45

Confusion 38

Excessive weight loss 22

Total number of health effects 2,180

No known long-term health effects 1,295

Source: GAO analysis of Coast Guard data. 

The Coast Guard noted which symptoms occurred during workers’ 

deployment and which occurred post-deployment. (See table 9.) 

Table 9: Reported Timing of Symptoms for Health Effects for the Coast Guard, 

November 2005 to March 2006 

Symptoms During and Post Deployment to the Gulf Coast Area Total 

Symptoms while deployed 729

Symptoms post deployment 506

Source: GAO analysis of Coast Guard data. 

Page 57 GAO-07-193 Disaster Preparedness
Appendix II: Data on the Estimated Number 

of Federal Workers Who Responded to 

Hurricane Katrina and Their Injuries and 

Illnesses 

Finally, the Department of the Interior reported that 90 workers sustained 

injuries or illnesses during the response to Hurricane Katrina from August

2005 through April 2006. They included injuries such as falls, slips and 

trips; strains from lifting; dermatitis from exposure to poison ivy; and 

reactions from exposures to toxins, dust, gas or chemicals. 

We took several steps to assess the reliability and reasonableness of the 

data the agencies provided. To assess the reliability of the agencies’ data,

we talked with agency officials about their data quality control procedures 

and reviewed relevant documentation. For example, we asked about the 

types of procedures and systems they had in place to ensure that the data

were collected and reported consistently. We found the data were 

sufficiently reliable for the purposes of this report. 

Page 58 GAO-07-193 Disaster Preparedness
Appendix III: Comments from the Department Appendix III: Comments from the of Health & Human Services 

Department of Health & Human Services 

Page 59 GAO-07-193 Disaster Preparedness
Appendix III: Comments from the Department 

of Health & Human Services 

Page 60 GAO-07-193 Disaster Preparedness
A

of Labor and 

ppendix IV: Comments from the Department 

GAO’s Response

Page 61 GAO-07-193

Appendix IV: Comments from the 

Department of Labor and GAO’s Response 

Note: GAO comments 

supplementing those in 

the report text appear at 

the end of this appendix. 

See comment 1. 

See comment 2. 

Disaster Preparedness
Appendix IV: Comments from the Department 

of Labor and GAO’s Response

Page 62 GAO-07-193 Disaster Preparedness
Appendix IV: Comments from the Department 

of Labor and GAO’s Response

See comment 3. 

See comment 4. 

See comment 5. 

Page 63 GAO-07-193 Disaster Preparedness
Appendix IV: Comments from the Department 

of Labor and GAO’s Response

See comment 6. 

Page 64 GAO-07-193 Disaster Preparedness
Appendix IV: Comments from the Department 

of Labor and GAO’s Response

See comment 7. 

See comment 8. 

Page 65 GAO-07-193 Disaster Preparedness
Appendix IV: Comments from the Department 

of Labor and GAO’s Response

See comment 9. 

See comment 10. 

Page 66 GAO-07-193 Disaster Preparedness
Appendix IV: Comments from the Department 

of Labor and GAO’s Response

Page 67 GAO-07-193 Disaster Preparedness
Appendix IV: Comments from the Department 

of Labor and GAO’s Response

1. We disagree that our report does not fairly and adequately capture the 

actions OSHA took to prevent occupational injuries and illnesses and 

work-related fatalities in the Hurricane Katrina response operations. 

The information on pages 15 through 27of the report details many of 

these activities, but the purpose of the report was to provide a broader 

picture of OSHA’s overall effectiveness. While the magnitude of the 

activities accomplished by OSHA’s field staff was noteworthy, the 

agency’s overall effectiveness was hampered by its lack of preparation 

for implementing its responsibilities under the Annex at the national 

level. This was also noted by the Department of Homeland Security’s 

National Preparedness Task Force, which stated in its technical 

comments that, “As a signatory agency, Department of Labor should 

have anticipated and put in place mechanisms to ensure the success of 

OSHA in meeting their Workforce Safety responsibilities.” In addition, 

our work focused on OSHA’s activities through December 2006, not

December 2005. 

GAO’s Response to 

OSHA’s Comments 

2. Although OSHA provides more detailed information about its action 

during the response to Hurricane Katrina, our report mentions many of 

these same activities. For example, on page 33 of the report, we stated 

that OSHA distributed personal protective equipment to many agencies 

and workers; on pages 25 to 27, we noted that OSHA sampled many 

worksites for hazards; on pages 19 and 20, we provided examples of 

the quick cards and fact sheets OSHA developed and distributed 

throughout the Gulf; and on page 21, we discussed the thousands of 

interventions that the agency’s staff conducted. 

3. We agree that OSHA, nor any other federal agency, was responsible for 

collecting information on the number of workers deployed to the Gulf 

area in response to Hurricane Katrina. In the absence of such

information, we attempted to collect it ourselves but, as noted in the 

report, were not entirely successful because many of the agencies we 

contacted did not have systems in place for tracking the number of 

workers deployed. 

4. We noted on page 9 of the report that the mission assignment FEMA 

issued to OSHA implementing the Annex for Hurricane Katrina 

included all of the activities listed in the Annex except long-term 

medical monitoring. We measured the effectiveness of OSHA’s 

performance only against those activities included in its mission 

assignment. 

5. Despite OSHA’s efforts, as noted on page 32 of the report, other agency

officials told us that there still were gaps in the training provided to 

Page 68 GAO-07-193 Disaster Preparedness
Appendix IV: Comments from the Department 

of Labor and GAO’s Response

workers involved in the response effort and additional information was 

needed about available training. 

6. While we agree that establishing a personal protective equipment 

program for a disaster response is a difficult and complex task, we 

continue to believe that the underlying issue is the need for OSHA to 

define how it will implement and monitor such a program as specified 

in the Annex. The issues that OSHA raises need to be addressed in 

developing an incident personal protective equipment program for 

future disasters, including developing a process for deciding what 

providing equipment on an “ad-hoc” basis means, what types of 

equipment will be provided, who will provide it, which workers will 

receive it, and where will it be stored. 

7. We disagree with OSHA’s comment that our statement about its lack of 

coordination with the Department of Health and Human Services is 

inaccurate. Our statement is based on OSHA’s lack of coordination 

before the disaster in order to ensure that the cooperating agencies 

were adequately prepared to meet the mental health needs of workers. 

Furthermore, in technical comments on the report, the Department of 

Homeland Security’s National Preparedness Task Force also noted this 

lack of coordination. It stated that OSHA did not seek assistance from 

cooperating agencies that have provided mental health services during 

major events in the past, such as the Department of Health and Human 

Services’ Substance Abuse and Mental Health Services Administration. 

8. We disagree with OSHA’s assertion that the report does not accurately 

reflect the awareness of the Annex among federal agencies before 

Hurricane Katrina. As noted in the report, many of the agency officials 

we interviewed who were in charge of day-to-day operations in the 

Gulf area were not aware of OSHA’s role or the services it could 

provide. We continue to believe that OSHA needs to provide 

information to federal, state, and local agencies about its role in a 

disaster, including seeking opportunities to participate in emergency 

preparedness exercises at all levels of government. Because so many 

responders are associated with nonfederal agencies, it is particularly 

important for OSHA to reach out to state and local agencies to provide 

this information. 

9. We used the word “suspend” to describe the fact that, in its press 

releases, OSHA noted that it had “exempted” large areas of the three 

affected states from its normal enforcement operations for specific 

periods and limited its inspections to cases involving fatalities, 

catastrophic accidents, or complaints, as noted on page 7 of the report. 

We changed the wording of the report in response to OSHA’s technical 

Page 69 GAO-07-193 Disaster Preparedness
Appendix IV: Comments from the Department 

of Labor and GAO’s Response

comments and no longer use the term “suspend.” However, we believe

that this is an accurate reflection of the change in OSHA’s activities 

during a disaster. 

10. The challenges OSHA recognizes in its comments regarding the use of 

its standard recordkeeping forms (OSHA forms 300 and 301) to collect 

data on injuries and illnesses sustained by workers during a disaster 

correctly identify some of the drawbacks involved in using the forms 

for this purpose. OSHA’s comments also emphasize the need for it to 

develop a process for collecting needed data that overcomes the 

challenges identified. We disagree, however, that the forms are a good

platform on which to build such a process. They do not contain 

detailed information on injuries, and employers are not required to 

include many of the more minor injuries and illnesses sustained by 

workers, such as those requiring only first aid. In addition, the use of 

the logs could cause confusion among federal agencies about whether 

the standard rules for recording injuries and illnesses are to be applied. 

For example, federal agencies are not normally required to submit 

their injury and illness logs to OSHA, but OSHA will need to obtain this 

information on a timely basis during a disaster response in order to 

monitor injuries and illnesses and identify trends. 

Page 70 GAO-07-193 Disaster Preparedness
Appendix V: 

A

GAO Contact and Staff 

cknowledgments 

Page 71 GAO-07-193

Appendix V: GAO Contact and Staff 

Acknowledgments 

Daniel Bertoni, (202) 512-5988 or bertonid@gao.gov

Revae E. Moran, Assistant Director, and Karen A. Brown, Analyst in 

Charge, managed all aspects of the assignment. Amanda M. Mackison, 

Claudine L. Pauselli, and Linda W. Stokes made significant contributions 

to the report. In addition, James D. Ashley, Lise Levie, Sheila R. McCoy, 

Jean L. McSween, David Perkins, and Tovah Rom provided key technical 

and legal assistance. 

GAO Contact 

Acknowledgments 

Disaster Preparedness
Related GAO Products 

Page 72 GAO-07-193

Related GAO Products 

September 11: HHS Has Screened Additional Federal Responders for 

World Trade Center Health Effects, but Plans for Awarding Funds for 

Treatment Are Incomplete. GAO-06-1092T. Washington, D.C.: September 

8, 2006. 

Catastrophic Disasters: Enhanced Leadership, Capabilities, and 

Accountability Controls Will Improve the Effectiveness of the Nation’s 

Preparedness, Response, and Recovery System. GAO-06-618. Washington, 

D.C.: September 6, 2006. 

Coast Guard: Observations on the Preparation, Response, and Recovery

Missions Related to Hurricane Katrina. GAO-06-903. Washington, D.C.: 

July 31, 2006.

Hurricane Katrina: Better Plans and Exercises Needed to Guide the 

Military’s Response to Catastrophic Natural Disasters.GAO-06-643. 

Washington, D.C.: May 15, 2006. 

Hurricane Katrina: Status of the Health Care System in New Orleans 

and Difficult Decisions Related to Efforts to Rebuild It Approximately 6 

Months After Hurricane Katrina. GAO-06-576R. Washington, D.C.: March 

28, 2006. 

GAO’s Preliminary Observations Regarding Preparedness and Response 

to Hurricane Katrina and Rita. GAO-06-365R. Washington, D.C.: 

February 1, 2006. 

Hurricanes Katrina and Rita: Provision of Charitable Assistance.

GAO-06-297T. Washington, D.C.: December 13, 2005. 

September 11: Monitoring of World Trade Center Health Effects Has 

Progressed, but Not for Federal Responders. GAO-05-1020T. Washington,

D.C.: September 10, 2005. 

(130530) Disaster Preparedness
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