GAO

United States General Accounting Office

Report to the Committee on Veterans’ 

Affairs, U.S. Senate

January 2000 VETERANS’ 

BENEFITS

Independent Review 

Could Improve 

Credibility of 

Radiation Exposure 

Estimates

GAO/HEHS-00-32

Page 1 GAO/HEHS-00-32 Veterans’ Radiation Exposure

Contents

Letter 3

Appendixes Appendix I: Scope and Methodology 18

Appendix II: Comments From the Defense Threat Reduction 

Agency 19

Appendix III: Comments From the Department of Veterans Affairs 21

Appendix IV: GAO Contact and Staff Acknowledgments 22

Abbreviations

DOD Department of Defense

VA Department of Veterans Affairs

VBA Veterans' Benefits Administration

VHA Veterans' Health Administration
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United States General Accounting Office

Washington, D.C. 20548

Health, Education, and

Human Services

B-282605 Letr

January 28, 2000

The Honorable Arlen Specter 

Chairman

The Honorable John D. Rockefeller IV

Ranking Minority Member

Committee on Veterans’ Affairs 

United States Senate

Between 1945 and 1962, about 200,000 active military personnel 

participated in atmospheric nuclear tests, and some were exposed to 

potentially harmful doses of radiation.1

 Over the past 2 decades, veterans 

with diseases they believe have been caused by radiation exposure have 

filed claims for monetary compensation with the Department of Veterans 

Affairs (VA). For 16 types of cancer, veterans can receive compensation 

without documenting the radiation dose because VA presumes these 

cancers to be directly linked to the veterans’ exposures. For other cancers 

and certain nonmalignant ailments, the Department of Defense (DOD) 

estimates, or “reconstructs,” the radiation dose using information such as 

the duties and locations of veterans and their units during the atmospheric 

testing, the type and quantity of radioactivity released from the explosions, 

and readings from film badges worn by the veterans and from other devices 

that measure radiation dose in the vicinity. The results of these dose 

reconstructions are used by VA to decide compensation claims.

Because there has been significant controversy surrounding the way 

radiation doses are estimated, you asked us to review the validity of dose 

reconstruction as a tool for determining veterans’ eligibility for benefits. 

Specifically, we (1) reviewed studies that assessed the validity of dose 

reconstruction for estimating veterans’ radiation exposure and discussed 

the issue with experts in the field and other knowledgeable individuals, (2) 

determined what activities are in place to oversee the dose reconstruction 

process, and (3) examined alternatives for deciding veterans’ claims for 

compensation related to radiation exposure.

1

In addition to those veterans who participated in atmospheric tests, approximately another 

200,000 were potentially exposed to radiation as a result of their presence in Japan after 

World War II. These veterans were excluded from our review because a single dose 

reconstruction was done for all.
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To address these issues, we interviewed VA and DOD officials and 

contractors at headquarters and field locations and reviewed applicable 

government policies and procedures. We also interviewed radiation and 

dose reconstruction experts in private industry, educational institutions, 

and government agencies as well as veterans’ service organization 

representatives. In addition, we reviewed relevant studies and literature 

related to dose reconstruction and the health effects of radiation, including 

those by the National Research Council and the Institute of Medicine. (For 

the details of our methodology, see app. I.) We performed our review 

between November 1998 and October 1999 in accordance with generally 

accepted government auditing standards.

Results in Brief Some veterans, veterans’ organizations, and experts we talked with do not 

have confidence in DOD’s dose reconstruction program. They question the 

completeness of DOD’s data and methodology and believe that DOD’s 

involvement in estimating radiation doses from exposure to tests for which 

it was responsible presents a conflict of interest. However, independent 

studies by the National Research Council and the Institute of Medicine 

have validated the dose reconstruction process that DOD uses for deciding 

radiation claims. These studies point out that DOD’s reconstruction 

process tends to overestimate both external and internal doses—an 

outcome that would increase the likelihood that a claim would be decided 

in a veteran’s favor. DOD conducted separate studies to determine the 

accuracy of dose reconstruction and found that the external radiation dose 

estimates obtained through reconstruction methods were about the same 

as the readings directly measured by film badges worn by other 

participants at the same tests. Some experts we interviewed, including 

Health Physics Society representatives, also support the use of dose 

reconstruction for claims decisions.2

Although studies appear to validate DOD’s dose reconstruction program for 

deciding claims, the agency is not providing for independent oversight of 

the program. The Institute of Medicine has been critical of the program’s 

2

The Health Physics Society is a nonprofit scientific organization composed of 6,800 

scientists, physicians, engineers, lawyers, and other professionals representing academia, 

industry, government, national laboratories, trade unions, and other organizations. The 

society promotes the practice of radiation safety and attempts to ensure that health 

physicists have information and capabilities to control the beneficial use of radiation in 

medical, research, and power generation activities to protect workers and the public from 

potential hazards. 
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lack of quality control, including the lack of a peer review process. The 

National Research Council has also suggested that dose reconstruction be 

reviewed, or subjected to peer review, by outside independent scientists. It 

has reported that such review could result in greater public confidence in 

dose reconstruction. Given the controversy surrounding the program, 

independent review could help resolve concerns about the integrity of the 

program. A VA official told us it was not VA’s responsibility to establish a 

process to oversee a DOD program. A DOD official explained that there 

had been no direct recommendation to DOD for a peer review process and 

that the program did not include this feature when it was designed. We 

therefore recommend that DOD establish a process for independent review 

of its dose reconstructions.

Finally, we did not identify any better alternatives currently available for 

deciding claims than dose reconstruction. For example, although some 

suggest expanding the list of presumptive diseases as an alternative to dose 

reconstruction, deciding which cancers to add to the presumptive list is 

controversial. Some advocate a restricted approach, such as adding only 

those cancers that statistically occur more frequently in the exposed 

veteran population than in other similar groups of nonexposed people. 

Such an approach would result in the addition of few, if any, cancers or 

ailments to the presumptive list because few cancers have been shown to 

be more prevalent among nuclear test participants than among 

nonparticipants. Others favor adding all human cancers to the list, but 

some experts, including officials at the National Cancer Institute, find little 

or no evidence that would link many cancers to relatively low levels of 

radiation, such as those levels to which most veterans were exposed.

Background Between 1945 and 1962, the United States conducted atmospheric tests of 

nuclear weapons—primarily at the Pacific Proving Grounds in the Marshall 

Islands and at the Nevada Test Site in southern Nevada. The tests were 

conducted for several reasons, including to determine the effects of atomic 

bombs on military installations and equipment and to provide training to 

crews in military tactics for using atomic bombs. Some veterans who 

participated in these tests were exposed to varying doses of radiation, and 

some subsequently developed a cancer or nonmalignant ailment. All 

veterans who have participated in a nuclear test can receive health care for 

conditions recognized by VA as potentially caused by radiation, including 

all forms of cancer. These veterans may also be eligible for disability 

compensation if their conditions are determined to be service-connected. 
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For example, a veteran without a spouse or dependents could generally 

receive from $98 to $2,036 a month, depending on the extent of disability.

Veterans who seek compensation can file a claim with VA’s Veterans’ 

Benefits Administration (VBA). To resolve these claims, VBA uses one of 

two processes, depending on the veteran’s cancer or ailment. If the veteran 

was a participant at an atmospheric test and has any one of 16 specific 

cancers, the veteran can be compensated, under 38 C.F.R. § 3.309(d), 

without further proof that the cancer was caused by radiation exposure. 

These 16 cancers are presumed, under 38 U.S.C. § 1112(c)(2), to have been 

caused by radiation that the veterans were exposed to as test participants.3

The second claims process, under 38 C.F.R. § 3.311, is used for veterans 

with all other cancers and certain nonmalignant ailments: tumors of the 

brain and central nervous system, nonmalignant thyroid nodular disease, 

posterior subcapsular cataracts, and parathyroid adenoma. This second 

claims process relies on dose reconstruction to decide the claim. 

Specifically, DOD, under an agreement with VA, uses scientific and 

personnel data to estimate the amount of radiation the veteran received 

during the atmospheric tests. Both external doses and internal doses—

those associated with inhalation or ingestion of radioactive material—can 

be estimated. For example, external radiation can be estimated from 

available radiation measurement devices or through calculations based on 

the proximity of personnel to radiation sources. Internal radiation can be 

estimated on the basis of the airborne concentration of radioactivity, the 

duration of exposure to airborne fallout or suspended particles in 

contaminated areas, and how the radioactivity enters and is transported 

through the body. When historical records documenting the exact radiation 

dose are incomplete, inaccurate, or missing, dose reconstruction is used to 

either complement or substitute for dose records.

3

In 1988, 13 cancers—leukemia (except chronic lymphocytic leukemia); multiple myeloma; 

lymphomas (except Hodgkin’s disease); primary liver cancer; and cancers of the thyroid, 

breast, pharynx, esophagus, stomach, small intestine, pancreas, bile ducts, and gall 

bladder—were legislatively deemed to be service-connected for veterans who participated 

in an atmospheric nuclear test. In 1992, two additional cancers—cancers of the salivary 

gland and urinary tract—were added to the list, and in 1999 bronchiolo-alveolar carcinoma 

was added.
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VA’s Veterans’ Health Administration (VHA) then compares the 

reconstructed doses with reports showing dose levels that have at least a 

small reasonable possibility of being as likely as not to have caused the 

cancer.4

 For example, one report shows that exposure to 17 rads of 

radiation at age 20 or to 33.1 rads of radiation at age 30 would have at least 

a 1-percent chance of being as likely as not to cause colon cancer.5

 In 

another example, exposure of a 20-year-old nonsmoker to 4.3 rads of 

radiation would have at least a 1-percent chance of being as likely as not to 

cause lung cancer. VHA’s medical opinions are considered by VBA in 

making decisions on benefit awards.

Since 1977, about 9,200 of the 200,000 nuclear test participants have filed 

claims with VA for compensation for illnesses that they believe were 

caused by exposure to radiation during atmospheric nuclear tests.6

 Not all 

of these veterans, however, have had dose reconstructions. For example, 

those with cancers on the presumptive list would not need a dose estimate. 

The applications for compensation of others may have lacked evidence of 

an ailment or appropriate military service. In all, DOD has used historical 

records to conduct dose reconstructions for about 2,900 veterans.7

Although VA does not keep data on the disposition of claims involving dose 

reconstructions, it estimated that there have been relatively few awards. 

According to VA officials, the agency denied the majority of claims because 

the radiation doses to which the veterans were exposed were too low to 

have been likely to cause their cancer or ailment.

4

Dose levels have historically been developed by groups such as the National Research 

Council and the Committee on Interagency Radiation Research and Policy Coordination, 

which was chartered through the Federal Coordinating Council for Science, Engineering 

and Technology, Office of Science and Technology Policy, Executive Office of the President. 

The National Cancer Institute recently began an effort to update the dose levels.

5

Doses from this report are based on a 99-percent lower credibility or confidence limit that 

has a probability of causation of 50 percent. A rad, or radiation absorbed dose, is a 

measurement of ionizing radiation energy that is absorbed. When DOD estimates a range of 

potential exposures for a veteran, VHA will use the upper limit.

6

On the basis of statistics from recent mortality studies, a DOD official told us that an 

estimated 70 to 75 percent of the 200,000 exposed veterans are presumed alive. In addition 

to compensating veterans for radiation-related claims, VA may also compensate the 

survivors of deceased veterans. 

7

According to a DOD official, the 2,900 dose reconstructions may include some that were 

done at the request of individual veterans who might not have filed claims with VA.
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Dose Reconstruction Is 

Considered Valid for 

Deciding Claims

Veterans and veterans’ service organizations have expressed concern over 

the completeness of data used by DOD and the methodology it uses to 

estimate doses, particularly doses from inhaled or ingested radioactive 

particles. Some are also skeptical about DOD’s ability to be unbiased in the 

dose reconstruction process, since DOD was responsible for the 

atmospheric testing that exposed the veterans to radiation.

However, studies conducted by DOD, the National Research Council, and 

the Institute of Medicine have generally shown that DOD’s dose 

reconstruction approach is valid for providing dose estimates for VBA to 

use in deciding claims. DOD has studied the validity of dose reconstruction 

by using the process to estimate doses for cases in which the actual dose is 

well documented. In such studies, DOD has found, for example, that 

reconstructed doses are similar to doses recorded on film badges, or 

radiation measurement devices, worn or used by some nuclear test 

participants. Independent reviews conducted by the National Research 

Council in 1985 and by the Institute of Medicine in 1995 showed that DOD’s 

reconstructed estimates are typically high, which would generally favor 

veterans in the claims process. In addition, representatives from the Health 

Physics Society and other experts express confidence that dose 

reconstruction is capable of producing dose estimates that are adequate for 

claims decision purposes.

Some Question the 

Reliability of Dose 

Reconstruction

A number of veterans and representatives of veterans’ service 

organizations told us that they do not have confidence in the process DOD 

uses to estimate radiation exposure. Specifically, they question the 

completeness of the data used and certain assumptions used to estimate 

doses.

Several veterans and veterans’ organizations we interviewed were skeptical 

about DOD’s knowledge of personnel activities and locations. For example, 

a veterans’ service organization official told us that military personnel 

swam in a lagoon contaminated by radiation shortly after a nuclear test, but 

that he doubted that such information would be recorded in documents 

available to DOD. Yet a DOD official told us that veterans are expected to 

include these types of assertions in their claims, and regulations require 

DOD to accept these assertions as fact unless DOD can prove them 

incorrect.
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Some veterans and veterans’ organizations also questioned the 

assumptions that DOD makes when information on a veteran’s exposure is 

incomplete or missing. These individuals believe that if DOD had more 

specific facts about veterans’ duties, dose estimates could be higher. For 

example, for one dose reconstruction for a veteran who washed 

contaminated aircraft, DOD estimated the radiation dose to the veteran’s 

skin on the basis of assumptions about the distance between the veteran 

and the aircraft. DOD officials told us that they believe assumptions that 

they are required to make are reasonable because specific evidence of 

exact activities does not always exist and that any inaccuracies in these 

assumptions generally do not significantly alter the dose estimates.

Some veterans also questioned DOD’s methodology for estimating internal 

radiation from inhaled or ingested radioactive particles. According to an 

expert at Oak Ridge National Laboratory, internal radiation doses are 

typically much smaller than external doses and are also very difficult to 

accurately estimate. In addition, a former health physicist from the Nevada 

Test Site believes that internal doses have been underestimated because 

particles in the soil from previous tests at the Nevada site could have been 

suspended in the air by subsequent nuclear detonations without 

corresponding indications of this radiation from previous tests appearing 

on film badges or other measuring devices. According to an official in 

DOD’s dose reconstruction program and to written dose reconstruction 

procedures, however, fallout from prior nuclear tests is factored into dose 

reconstructions.
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Evidence From Scientific 

Studies Supports DOD’s 

Dose Reconstruction

We identified five studies conducted since 1979 that assessed the validity of 

dose reconstruction in estimating radiation exposure. Three of these 

studies were conducted by the DOD contractor responsible for performing 

dose reconstructions. To determine the process’ validity, the contractor 

compared known doses recorded on film badges with estimated doses 

determined through the dose reconstruction process.8

 The DOD contractor 

reported in 1979, 1980, and 1981 that reconstructed doses were similar to 

those found on film badges for external doses.9

 For example, in 1981, the 

contractor prepared an analysis of nuclear radiation exposure of personnel 

in a Marine brigade during their participation in Exercise Desert Rock VII, 

Operation Plumbbob, at the Nevada Test Site in 1957. The report notes that 

“film badge dosimetry and other records of activity are sufficient to identify 

the personnel who had the greatest potential for exposure and to determine 

their specific activities.” Further, the report concludes that dosimetry data, 

or data from radiation measurement devices, “correlate well with 

calculated doses, thus providing the necessary confidence in the calculated 

doses, and group activities, for those personnel with no dosimetry 

records.”

8

In 1989, the National Research Council studied the reliability of film badges that were 

available for some participants in nuclear tests and found that film badge data were 

generally reliable. See National Research Council, Committee on Film Badge Dosimetry in 

Atmospheric Nuclear Tests, Energy Engineering Board, Commission on Engineering and 

Technical Systems, Film Badge Dosimetry in Atmospheric Nuclear Tests (Washington, D.C.: 

National Academy Press, 1989).

9

Science Applications, Inc., Analysis of Radiation Exposure for Task Force Warrior—Shot 

Smoky—Exercise Desert Rock VII−VIII Operation Plumbbob, DNA 4747F (1979); Analysis 

of Radiation Exposure for Task Force Big Bang, Shot Galileo, Exercise Desert Rock VII−VIII 

Operation Plumbbob, DNA 4772F (1980); and Analysis of Radiation Exposure, 4th Marine 

Corps Provisional Atomic Exercise Brigade, Exercise Desert Rock VII, Operation 

Plumbbob, DNA 5774F (1981).
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Studies by the National Research Council and by the Institute of Medicine 

have shown that dose reconstruction is a valid process for estimating 

radiation doses for VBA to use in deciding claims because dose 

reconstruction tends to overestimate doses, giving the benefit of the doubt 

to the veteran. In turn, this favors veterans in the claims process. 

Specifically, the National Research Council issued a report in 1985 on the 

comprehensiveness and scientific validity of the methods and procedures 

DOD’s Nuclear Test Personnel Review organization uses to estimate 

internal and external doses of radiation.10 The report concluded that “the 

methods used by the [Nuclear Test Personnel Review] team to assign 

external . . . doses are generally reasonable and make appropriate use of 

available data.” Although the National Research Council found that the 

methods used to estimate internal doses were based on unsupported 

assumptions, it nevertheless found that internal doses are relatively 

insignificant when compared with external doses, regardless of the 

estimate. The National Research Council also reported that if any bias 

exists in the estimates, it is probably a tendency to overestimate doses, 

especially internal doses. Similarly, the Institute of Medicine noted in a 

1995 letter to the Nuclear Test Personnel Review organization that DOD 

has resolved uncertainties in dose reconstructions by assigning veterans 

higher rather than lower doses.11

According to the Health Physics Society, dose reconstruction is a standard 

practice for estimating the amount of radiation exposure when more direct 

evidence, such as film badge readings, is not available. Other health 

physicists and experts with whom we spoke shared this view.

10National Research Council, Committee on Dose Assignment and Reconstruction for 

Service Personnel at Nuclear Weapons Tests, Board on Radiation Effects Research, 

Commission on Life Sciences, Review of the Methods Used to Assign Radiation Doses to 

Service Personnel at Nuclear Weapons Tests (Washington, D.C.: National Academy Press, 

1985).

11National Academy of Sciences, Institute of Medicine, A Review of the Dosimetry Data 

Available in the Nuclear Test Personnel Review (NTPR) Program, An Interim Letter Report 

of the Committee to Study the Mortality of Military Personnel Present at Atmospheric Tests 

of Nuclear Weapons to the Defense Nuclear Agency (Washington, D.C.: Institute of 

Medicine, May 15, 1995).
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Independent Review 

Could Enhance 

Confidence in the 

Program

Public and veteran confidence in dose reconstruction as a tool to decide 

compensation claims could be improved through independent oversight 

and validation of dose reconstruction results. However, ongoing 

independent reviews are currently not being conducted to validate program 

results. Biological testing to verify dose reconstructions is currently being 

investigated by the scientific community, and some scientists believe that 

this approach may be useful in the future.

DOD’s Dose Reconstruction 

Program Is Not 

Independently Reviewed

Some individuals we interviewed believe that DOD’s involvement in dose 

reconstruction poses a conflict of interest, since DOD was responsible for 

the atmospheric tests that exposed the veterans to radiation. In addition, 

one expert told us that DOD did not sufficiently monitor the nuclear tests 

and misled participants about the potential health effects of radiation. 

Allegations from veterans that data from nuclear tests are inaccurate and 

that DOD’s estimates of exposure are too low further reflect veterans’ 

distrust. Independent reviews of DOD’s dose reconstruction program could 

help mitigate some of these criticisms.

According to VA regulations, a veteran who disagrees with the dose 

estimate provided by DOD can obtain, at the veteran’s expense, an 

independent estimate from a reliable source. If the independent estimate is 

at least twice as large as the DOD estimate, VA contracts with a third party 

to reconcile the two estimates and uses the reconciled estimate to make 

compensation decisions. Officials in VBA’s Compensation and Pension 

Office told us that they could not remember an instance during the last 5 

years when any veteran presented an independent estimate. A dosimetry 

expert selected by VA to reconcile DOD dose estimates with veterans’ 

independent estimates told us that he completed four such reconciliations 

in the early 1990s. For one of the reconciliations, his estimate was higher 

than the DOD estimate but lower than that provided by the veteran; he 

generally agreed with DOD’s estimates for the other three reconciliations. 
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In a 1995 letter to the Nuclear Test Personnel Review organization, the 

Institute of Medicine criticized DOD’s quality assurance program for dose 

reconstruction as limited and noted that there has been little peer review of 

the methods used and of the actual dose estimates. The Institute also noted 

that no evidence exists that dose estimates were verified by an independent 

source other than by the National Research Council in the 1980s. According 

to 1995 National Research Council guidance on dose reconstruction for 

epidemiological uses, dose reconstructions should undergo peer review if 

they are to be viewed as credible.12 The guidance is primarily directed at 

epidemiological studies of populations located near nuclear weapons 

plants. It suggests that all dose reconstruction studies be reviewed by 

groups of scientists and public health officials who are not directly 

involved in the study, either as participants or as advisors, and that time 

and resources be allocated for resolving any discrepancies in the results. 

Applying the same principle, independent validations of a sample of 

individual dose reconstructions could enhance confidence in the DOD 

program.

VA officials told us that they did not think it was VA’s responsibility to 

establish a dose reconstruction review program; if a program were to be 

established, they said it would be DOD’s responsibility to establish it. An 

official in DOD’s dose reconstruction program told us that there is no 

requirement for peer review of the program. In addition, he noted that the 

program was examined by the National Research Council in 1985 and the 

Institute of Medicine in 1995 and that there had been no direct 

recommendation to DOD for a peer review process. The DOD official also 

told us that a peer review program would not likely be acceptable to 

veterans if DOD had any involvement in the process.

Biological Technology Has 

Potential for Validating 

Dose Reconstruction 

Results in the Future

Some scientists believe biological measurement techniques could be useful 

in estimating radiation exposure and validating the results of dose 

reconstruction techniques. Once biological techniques are fully studied and 

tested, it is conceivable that they might eventually be used as a substitute 

for dose reconstruction. Unlike DOD’s reconstruction process and other 

dosimetric methods, biological techniques do not depend on the 

availability of data on military activities, locations, and atmospheric 

12National Research Council, Committee on an Assessment of CDC Radiation Studies, Board 

of Radiation Effects Research, Commission on Life Sciences, Radiation Dose 

Reconstruction for Epidemiologic Uses (Washington, D.C.: National Academy Press, 1995).
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conditions. Instead, biological techniques essentially use the body as a 

dosimeter and may, for example, measure chromosomal aberrations in the 

blood or the effects of radiation on teeth. In 1985, the National Research 

Council suggested that biological techniques be used in the dose 

reconstruction program and that biological testing be used to measure the 

presence of plutonium and strontium in veterans’ urine.

As suggested by the National Research Council, DOD recently started a 

program to test for veteran exposure to plutonium, a radioactive element 

found in fallout from atmospheric nuclear testing. Under the program, 100 

veterans who participated in nuclear tests volunteered to provide urine 

specimens that have been tested for plutonium by a national laboratory. 

Test results are being analyzed, and final results will be reported early in 

2000. According to a DOD fact sheet, results from DOD’s dose 

reconstruction program will be reevaluated for any veterans whose 

plutonium levels are found through urine testing to be significantly 

elevated. However, no reconstructed doses will be lowered as a result of 

biological testing. According to a DOD official, waiting for the results of 

separate feasibility studies by the National Institutes of Health, refining the 

testing technique, and obtaining funding have contributed to the delay in 

implementing the National Research Council suggestion.

Other biological measurement techniques for identifying radiation 

exposure include blood tests for aberrant chromosomes. Although the 

National Research Council’s 1995 guidance on conducting dose 

reconstruction studies cited this technique as promising for measuring past 

radiation exposure, it also reported that such testing was more accurate at 

higher rather than lower levels of radiation exposure. Scientists also 

suggested that determining the extent of radiation exposure in the teeth of 

test participants might be used to validate dose reconstructions. These 

biological measurement techniques, however, are still in the developmental 

stage.

Better Alternatives to 

Dose Reconstruction 

Are Not Currently 

Available

We identified no better alternatives for deciding claims than dose 

reconstruction. Veterans and veterans’ service organizations advocate 

expanding the presumptive list of 16 cancers. However, the experts with 

whom we spoke do not agree on which additional cancers or ailments, if 

any, are caused by various levels of radiation exposure.
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Some experts have recommended adding to the presumptive list those 

cancers that occur more frequently in veterans who have been exposed to 

radiation than in similar groups that have not been exposed. This type of 

comparison is made in mortality studies. Theoretically, basing 

compensation on the results of these studies could potentially increase 

confidence that the cancers added to the presumptive list were statistically 

correlated with participation in atmospheric testing. But, in fact, the 

statistically significant health effects found by mortality studies vary. For 

example, many findings in a recent study by the Institute of Medicine 

comparing the mortality of about 70,000 individuals who participated in 

one of five nuclear tests with the mortality of about 65,000 

nonparticipants13 differed from the results of prior studies conducted by 

other researchers. The Institute of Medicine study found, for example, that 

the increased mortality from leukemia among test participants was not 

statistically significant, while other mortality studies found increases in 

mortality from leukemia that were significant. Leukemia is on VA’s 

presumptive list. Conversely, the Institute of Medicine study found 

statistically significant increases in mortality from nasal and prostate 

cancers. Other mortality studies have not found statistical elevations in 

mortality from these cancers, and they are not on the current presumptive 

list.14

Other experts advocate including all known cancers on the presumptive 

list, arguing that the science is not clear-cut on radiation-induced cancer or 

exposure levels that cause disease. For example, a professor of molecular 

and cell biology—who is also an expert in nuclear and physical chemistry—

told us that there is no evidence showing that radiation is safe at any level. 

Other experts, including officials from the National Cancer Institute, 

contend that the relationship between radiation and cancer is indeed well 

understood and that there is no evidence that links low levels of radiation 

to many cancers.

13Medical Follow-up Agency, Institute of Medicine, The Five Series Study: Mortality of 

Military Participants in U.S. Nuclear Weapons Tests (Washington, D.C.: National Academy 

Press, 1999).

14The Institute of Medicine study reported that its finding about nasal and prostate cancers 

has not been reported in other mortality studies or in studies of Japanese atomic bomb 

survivors. Furthermore, the Institute study explained the divergent findings on prostate 

cancer—which it acknowledges is generally not linked to radiation exposure—as possibly 

the result of veterans’ concerns about cancers caused by exposure. Such concerns may have 

led to more identifications of prostate cancer and a subsequent increase in reported deaths 

due to prostate cancer.
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Conclusions Available scientific studies indicate that dose reconstruction is a valid 

method for estimating veterans’ radiation exposure to decide disability 

claims, and we have not identified a better alternative. However, the dose 

reconstruction program lacks an independent review process. According to 

a DOD official, there has not been a direct recommendation for DOD to 

establish such a process and peer review was not included as part of the 

dose reconstruction program when it was established. Given the 

controversy surrounding the program, an independent review process for 

validating DOD’s dose reconstruction methods and estimates could 

mitigate concerns about the integrity of the program. In the future, DOD 

may be able to validate its dose reconstruction program by biological 

measurement methods, such as counting chromosomal aberrations or 

measuring radiation exposure in teeth, although such methods are still in 

the early stages of development.

Recommendation We recommend that the Secretary of Defense establish an independent 

review process for the dose reconstruction program under which 

independent verifications of a sample of individual dose reconstructions 

are made.

Agency Comments We provided a draft copy of this report to DOD and VA. Both agencies 

provided technical comments, which we incorporated where appropriate. 

The agencies’ comments concerning our recommendation and our 

response follow. DOD’s and VA’s comments appear in appendixes II and III, 

respectively.

Defense Threat Reduction 

Agency

The Director of the Defense Threat Reduction Agency agreed in principle 

with our recommendation. However, he stated that an organization 

separate from DOD, such as the National Institutes of Health, should 

support and direct the independent review process to avoid any 

appearance of conflict of interest and to build veterans’ confidence in the 

review process. We believe that DOD, as program manager, should 

maintain responsibility for program integrity, including establishing a 

review program. DOD could arrange for an independent entity, such as the 

National Institutes of Health, to conduct a peer review program and ensure 

the entity chooses a methodology that is independent of DOD influence. We 

would expect that DOD and any independent entity would consider the 
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views of others, including veterans and veterans’ organizations, on how the 

program would be set up in order to enhance their confidence in the 

program. 

Department of Veterans 

Affairs

The Assistant Secretary for Planning and Analysis agreed with our 

recommendation that the Secretary of Defense establish an independent 

review process for the dose reconstruction program and said that VA would 

not be the appropriate organization to perform such reviews.

We are sending copies of this report to the Honorable William S. Cohen, 

Secretary of Defense; the Honorable Togo D. West, Jr., Secretary of 

Veterans Affairs; appropriate congressional committees; and other 

interested parties. We will also make copies available to others upon 

request. 

Please contact me on (202) 512-7111 if you or your staff have any questions. 

Another GAO contact and other staff who made major contributions to this 

report are listed in appendix IV.

Stephen P. Backhus

Director, Veterans’ Affairs and

 Military Health Care Issues
Page 18 GAO/HEHS-00-32 Veterans’ Radiation Exposure

Appendix I

Scope and Methodology AAppenednxidxeIis

To review assessments of the validity of dose reconstruction as a method 

for estimating radiation exposure, we relied on various studies and the 

expertise of scientists in this area. We conducted literature searches for 

journal articles, scholarly papers, and other similar materials related to 

estimating radiation exposure. In particular, we reviewed empirical studies 

that investigated the degree to which reconstructed dose estimates 

correlate with actual known doses. We also reviewed reports from those 

who have specifically critiqued the Department of Defense’s (DOD) dose 

reconstruction program. In addition, we reviewed statements from 

witnesses who testified at the 1998 hearing on ionizing radiation, veterans’ 

health care, and related issues before the Senate Committee on Veterans’ 

Affairs. We then contacted experts associated with scientific organizations, 

including the National Academy of Sciences, the National Research 

Council, the National Cancer Institute, and the Health Physics Society, who 

were knowledgeable about radiation exposure to get other expert opinions 

and to discuss conflicting views on the topic. In addition, we obtained the 

views of representatives from veterans’ groups, such as the National 

Association of Atomic Veterans, and veterans’ service organizations, 

including the American Legion, Disabled American Veterans, and Veterans 

of Foreign Wars.

To determine the oversight activities associated with the dose 

reconstruction program, we spoke with DOD officials responsible for such 

activities, including officials in the Defense Threat Reduction Agency, the 

DOD agency with responsibility for the program, as well as the contractor 

who actually performs the dose reconstructions. In evaluating the strength 

of DOD’s oversight activities, we reviewed National Research Council 

guidance on conducting dose reconstructions and compared DOD’s 

processes with this guidance. Additionally, we considered comments by the 

Institute of Medicine on DOD’s procedures.

In researching alternatives to dose reconstruction for deciding claims, we 

relied on existing scientific studies and the knowledge of the scientific 

community. In particular, when considering the use of presumptive lists, we 

reviewed studies of the health effects of radiation exposure, such as those 

prepared by the Committee on Interagency Radiation Research and Policy 

Coordination, the National Institutes of Health, and the National Research 

Council. We also reviewed studies that evaluated increases in mortality for 

radiogenic diseases for nuclear test participants. We also obtained the 

views of veterans’ organizations on using presumptive lists for deciding 

claims. 
Page 19 GAO/HEHS-00-32 Veterans’ Radiation Exposure

Appendix II

Comments From the Defense Threat 

Reduction Agency ApendxiI
Appendix II

Comments From the Defense Threat 

Reduction Agency

Page 20 GAO/HEHS-00-32 Veterans’ Radiation Exposure

Now on p. 16.
Page 21 GAO/HEHS-00-32 Veterans’ Radiation Exposure

Appendix III

Comments From the Department of Veterans 

Affairs ApendxIi

Now on p. 12.
Page 22 GAO/HEHS-00-32 Veterans’ Radiation Exposure

Appendix IV

GAO Contact and Staff Acknowledgments ApendxIVi

GAO Contact Ronald J. Guthrie, (303) 572-7332

Staff 

Acknowledgments

John A. Borrelli, Joseph J. Buschy, Nancy L. Crothers, Deborah L. Edwards, 

Chariti E. Gent, George L. Lorenzen, B. Behn Miller, and Karen M. Sloan 

also made key contributions to this report.

(105771) Letr
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