text: Background Composition of Agent Orange Agent Orange is composed of two different chemical components—the n- butyl ester forms of 2,4-dichlorophenoxyacetic acid (hereinafter referred to as n-butyl 2,4-D) and 2,4,5-trichlorophenoxyacetic acid (hereinafter referred to as n-butyl 2,4,5-T)—that are manufactured separately and then combined to form the tactical herbicide. The U.S. EPA has determined that there was not adequate data either to support or to refute that the acid or ester forms of 2,4-D can cause cancer in humans. In 2015 the International Agency for Research on Cancer classified 2,4-D as possibly causing cancer to humans, since there was inadequate evidence in humans and limited evidence in experimental animals. According to an Institute of Medicine report, information on the toxic effects of 2,4,5-T alone is sparse. However, in the 2,4,5-T manufacturing process, the dioxin 2,3,7,8-tetrachlorodibenzo-p-dioxin (hereinafter referred to as 2,3,7,8-TCDD) is formed, particularly when the reaction temperature is excessive. The World Health Organization has determined that dioxins are highly toxic and can cause a variety of illnesses, including reproductive and developmental problems and damage to the immune system. The World Health Organization reports that 2,3,7,8-TCDD, a human carcinogen, is the most toxic dioxin-related compound. Moreover, according to the National Academies of Sciences, Engineering, and Medicine report, 2,3,7,8-TCDD has been shown by researchers to be very toxic in animals. Figure 1 depicts the proportion of the components of Agent Orange and the amount of 2,3,7,8-TCDD contamination that would be present in an average 55-gallon drum. Agent Orange Origins and Life Cycle The Crops Division of the U.S. Army Chemical Corps was established at Camp Detrick (now Fort Detrick), Maryland, in 1943 to conduct anti-crop research, development, and engineering. In 1944 the Crops Division was given the mission of developing chemical compounds to destroy or reduce the value of crops. These chemical compounds were intended to rapidly clear vegetation in military operations in order to eliminate concealed enemy positions, improve air and ground observations, and destroy or reduce the value of crops. Initial field trials at Camp Detrick were small-scale efforts involving test plots typically 6 by 18 feet in size, and the herbicides being tested were usually applied using a hand sprayer. Over the following three decades, DOD collaborated with the U.S. Department of Agriculture, universities, and private companies to conduct testing activities ranging from laboratory experiments to spray tests of larger-scale aerial dissemination of a variety of chemical compounds throughout the United States, U.S. territories, and abroad. The tactical herbicides used by the U.S. military in Vietnam were formulations based on tests of thousands of different chemical compositions at Camp Detrick in an effort to determine chemical agents and chemical compounds that would meet specific requirements. The U.S. military developed and tested six tactical “rainbow” herbicides that it used during the Vietnam War era—Pink, Purple, Green, Blue, White, and Orange. The chemical component n-butyl 2,4,5-T, which is known to have been contaminated with 2,3,7,8-TCDD, was present in four of these six tactical herbicides—specifically, Agents Pink, Purple, Green, and Orange. In late 1961, DOD began color-coding the herbicide formulations that it was testing in aerial spray trials in Vietnam and elsewhere in Southeast Asia. The tactical herbicides, which were used for a variety of different purposes, to include defoliation and crop destruction, were identified by colored bands placed around the drums, as shown in figure 2. Beginning in 1962, the U.S. Air Force received shipments of Agents Pink, Purple, and Green to supply the first spray missions for Operation Ranch Hand, the program for defoliation and crop destruction missions during the Vietnam War. Agent Purple was similar to the herbicide formulation that was later designated “Orange,” but it was more costly to purchase. Agents Blue and White were used in Vietnam extensively along with Agent Orange after 1964, but they were of a different chemical composition and did not contain any form of 2,4,5-T, the component that produced 2,3,7,8-TCDD as a by-product of the manufacturing process. Of the tactical herbicides, Agent Orange was used the most extensively in Vietnam. In 1964 DOD began to procure large quantities from U.S. manufacturers for military use in Vietnam. The first shipment of Agent Orange arrived in Saigon in February 1965 by merchant vessel. Together, nine manufacturers produced a total of approximately 13.9 million gallons of Agent Orange, and DOD is estimated to have used approximately 12.1 million gallons between 1965 and 1970 in operations in Vietnam, and much smaller quantities in Korea and Thailand. Evidence from animal and epidemiologic studies of adverse effects from Agent Orange exposure led the U.S. government to restrict the use of 2,4,5-T in April of 1970 and led DOD to temporarily suspend the use of Agent Orange. In 1972 the U.S. Air Force consolidated the approximately 1.36 million gallons of the herbicide that had remained unused in Vietnam and shipped them for storage on Johnston Island in the Pacific. DOD held its remaining stocks of Agent Orange—approximately 860,000 gallons—within the continental United States, at the Naval Construction Battalion Center Gulfport, Mississippi, until those stocks were also shipped toward Johnston Island in June 1977. All of these remaining stocks of Agent Orange were incinerated at sea aboard the M/T Vulcanus by September 1977. Comparison between Tactical and Commercial Herbicides In addition to the tactical herbicides used during the Vietnam War era, the U.S. military also used commercial herbicides to manage vegetation on its installations. The U.S. military managed tactical herbicides differently from commercial herbicides. According to DOD officials and archived military specifications, tactical herbicides were not authorized for use on lands owned by, or otherwise managed as military installations and were not to be diverted for domestic use. DOD developed military specifications for the tactical herbicides that provided detailed information on product requirements, quality assurance, packaging, and precautionary statements that prohibited domestic use. The tactical herbicides were centrally managed, first by the Army Chemical Corps and later by the U.S. Air Force Logistics Command. Agent Orange used in Vietnam was formulated for aerial spraying by aircraft and helicopter and applied at full strength without additional solvents at a rate of 3 gallons per acre. Agent Orange is soluble in diesel fuel and organic solvents, but it is insoluble in water, so equipment was cleaned using diesel fuel rather than water. Commercial herbicides, conversely, were widely available worldwide for use in vegetation management at military installations, to include controlling vegetation adjacent to flightlines or along perimeter fencing. Federal agencies developed federal specifications for these products to ensure that they met specific requirements, and these specifications were approved by the Commissioner, Federal Supply Service, in the General Services Administration for use by all federal agencies. According to DOD officials, during the Vietnam era there was no requirement for DOD to retain records concerning the use of commercial herbicides on military bases beyond 5 years. DOD officials also stated that DOD catalogued these herbicides available for use on military installations in the federal supply schedule under federal supply classification group 68, which contains chemicals and chemical products. In reviewing supply catalogues from that time period, DOD officials identified more than 35 different commercial herbicides that were listed in the federal supply system for use on DOD installations between 1960 and 1973. Some of these commercial herbicides contained 2,4-D; 2,4,5-T; or both, although they were not in the n-butyl form used in Agent Orange. These included at least 4 commercial herbicides that contained some form of 2,4,5-T, the component that contained the contaminant 2,3,7,8- TCDD. In addition, numerous commercial herbicides that were not in the federal supply system but were being widely used elsewhere for agriculture purposes contained the form of n-butyl 2,4,5-T found in Agent Orange and thus its associated contaminant, 2,3,7,8-TCDD. According to DOD officials, the commercial herbicides used on installations were mixed with diesel or water and sprayed by hand or truck. Tactical herbicides, however, were formulated for aerial spraying by fixed-wing aircraft or helicopter without being diluted. When the U.S. military was employing these tactical and commercial herbicides during the Vietnam War era, U.S. EPA had not yet been established, and the U.S. Department of Agriculture had oversight of commercial herbicides. The Federal Insecticide, Fungicide, and Rodenticide Act of 1947, then administered by the U.S. Department of Agriculture, governed the marketing and use of these commercial herbicides. Until amended in 1972, the Federal Insecticide, Fungicide, and Rodenticide Act review process was designed as a consumer protection measure that focused primarily on a product’s effectiveness, rather than on concerns about health or the environment. Agent Orange Legislative and Regulatory History The Agent Orange Act of 1991, as amended, requires a review of the available scientific evidence regarding the associations between certain diseases and exposure to tactical herbicides. The act specifically requires the VA to enter into an agreement with the National Academy of Sciences (the Academy), or with an alternative scientific organization, to review and evaluate the scientific evidence concerning the association between exposure to an herbicide agent and each disease suspected to be associated with such exposure. The Academy is required to submit periodic reports at least once every 2 years. The most recent report—the 2014 report—was issued in March 2016. The next report, which Academy officials told us would focus on inter-generational and trans-generational effects of exposure to herbicides, was at the time of our report scheduled to be issued in late 2018. In its biannual reports, the Academy identifies different levels of association between exposure to 2,3,7,8-TCDD or other chemical compounds in herbicides used in Vietnam and a wide range of health effects. These levels include the following: sufficient evidence of an association; limited or suggestive evidence of an association; inadequate or insufficient evidence to determine an association; and limited or suggestive evidence of no association. The Academy has identified that there is either sufficient evidence of an association with exposure to a tactical herbicide or limited or suggestive evidence of an association leading to certain diseases. For example, the Academy has identified both chloracne and non-Hodgkin’s lymphoma as having sufficient evidence of an association with exposure to a tactical herbicide, and both Parkinson’s disease and diabetes mellitus (type 2) as having limited or suggestive evidence of an association. Examples of diseases for which the Academy has found inadequate or insufficient evidence to determine an association include kidney disease and pancreatic cancer. In making determinations regarding the association between certain diseases and exposure to herbicide agents, the Secretary of Veterans Affairs is required to take into account the Academy’s reports. Once the Secretary finds that such an association existed, the Secretary is then required to prescribe regulations, providing that a presumption of service connection is warranted for that disease. The Agent Orange Act of 1991, as amended, also establishes a presumption of service connection, by reason of exposure to an herbicide agent, for diseases listed in the statute, to include Hodgkin’s disease and diabetes mellitus (type 2). This presumption applies to veterans who, during active military, naval, or air service, served in the Republic of Vietnam during the period beginning on January 9, 1962, and ending on May 7, 1975. Veterans who served in Vietnam and other specific locations and time frames and who have been diagnosed with those diseases are presumed to have incurred those diseases as a result of their service and are thus eligible for presumptive service connection for disability compensation. Figure 3 illustrates the diseases for which the Academy has found either sufficient, or limited or suggestive, evidence of an association. In addition, appendix II provides information on the 14 presumptive diseases that the VA currently identifies as being associated with exposure to Agent Orange or other tactical herbicides during military service for which veterans and their survivors may be able to receive disability compensation benefits. Veterans’ Benefits Under 38 U.S.C. § 1110, the United States will pay benefits to any veteran disabled for a disability resulting from personal injury suffered or disease contracted in line of duty, or for aggravation of a preexisting injury suffered or disease contracted in line of duty, in the active military, naval, or air service, during a period of war. The VA offers health registry exams, health care, disability compensation, and other benefits to eligible veterans who were exposed to herbicides during military service. According to the VA’s Claims Adjudication Procedures Manual, the claims evaluation process begins with the VA requesting any information missing from the veteran’s claim, such as the approximate dates and location(s) of service, claimed disability, and, for certain locations, the nature of the alleged exposure to herbicides. Generally, the veteran then has 30 days to submit the requested information. During the claims process, VA will check military records to confirm exposure to Agent Orange or other herbicides and qualifying military service. Certain diseases have already been presumed to be associated with herbicide exposure, and no further evidence of an association is needed. However, if the claimed disability is not a presumed condition, then VA will request that the veteran present scientific or medical evidence showing that the claimed condition is medically associated with herbicide exposure. If the veteran is not able to provide this information, the case is referred to DOD for verification of exposure to herbicides. Veterans’ claims can either be approved or denied based on the evidence submitted by the veteran, and, if needed, by DOD. The VA tracks its claims data for Agent Orange exposure according to whether the exposure occurred inside or outside of Vietnam, which includes the Korean demilitarized zone and certain locations in Thailand. According to VA officials, as of June 30, 2018, 557,653 living veterans and 199,451 deceased veterans have been granted benefits for diseases associated with Agent Orange exposure inside Vietnam, with 44,925 claims pending for veterans who served in Vietnam and believe they were exposed to Agent Orange. For diseases associated with Agent Orange exposure outside of Vietnam, VA had granted service connection decisions to more than 10,758 veterans and denied service connection decisions to more than 58,250 veterans, as of June 30, 2018. According to VA, there are an additional 23,400 claims pending for veterans who did not serve in Vietnam but believe they were exposed to Agent Orange. Environmental Cleanup In 1980 Congress passed the Comprehensive Environmental Response, Compensation, and Liability Act, which established the Superfund program—the federal government’s principal program to clean up hazardous waste sites. The U.S. EPA is responsible for administering the Superfund program, which places some of the most seriously contaminated sites on the National Priorities List, and has oversight for federal and non-federal sites on that list. Additionally, amendments to the act in 1986 require the Secretary of Defense to carry out the Defense Environmental Restoration Program, which was specific to DOD environmental cleanup activities at active installations, formerly used defense sites, and base realignment and closure locations in the United States. The cleanup process under the Environmental Response, Compensation, and Liability Act process generally includes the following phases and activities: preliminary assessment, site inspection, remedial investigation and feasibility study, remedial design and remedial action, and long-term monitoring. Through this process, DOD and U.S. EPA cleaned up some U.S. sites where Agent Orange was known to have been present after the sites were tested and confirmed to have been contaminated with 2,3,7,8- TCDD. For example, U.S. EPA identified a site in Jacksonville, Arkansas, where 2,4,5-T had been manufactured, that was contaminated with 2,3,7,8-TCDD. In addition, under the Defense Environmental Restoration Program, DOD cleaned up the Naval Construction Battalion Center Gulfport, Mississippi, where Agent Orange had been stored while awaiting shipment for use in Southeast Asia. The site had also been used to store Agent Orange drums that were awaiting shipment to Johnston Island for disposal. According to a DOD report, approximately 860,000 gallons of the herbicide were stored at the site. An Agency for Toxic Substances and Disease Registry report further states that spills that occurred during storage caused 2,3,7,8-TCDD contamination around several water areas. According to a 5-year review completed by DOD in 2017, capping of the contaminated soil at the site where herbicides were stored has been completed, and long-term monitoring of the soil and groundwater began in 2012 and continues today. DOD also cleaned up the Johnston Island site where Agent Orange was ultimately disposed of. Once drums of Agent Orange were stored at Johnston Island, environmental sea conditions caused them to corrode and leak. Initial cleanup activities assessed and monitored the area to track the chemical components remaining as a result of Agent Orange contamination. Site remediation and environmental monitoring continued throughout the 1970s until February 1989, when the Air Force, in accordance with the Defense Environmental Restoration Program, completed a final site cleanup at Johnston Island by destroying all remaining 2,3,7,8-TCDD-contaminated soil. Figure 4 shows drums of Agent Orange stored at Johnston Island. In addition, U.S. EPA listed on its National Priorities List two former Agent Orange manufacturing sites—the Kanawha River site in West Virginia previously owned by the Monsanto Company and a site in Newark, New Jersey, owned by the Diamond Alkali Company—due to high levels of contamination from various sources and threats to human health. In 2017, U.S. EPA entered into an agreement with the Monsanto Company on a cleanup plan to address 2,3,7,8-TCDD contamination at the Kanawha River Superfund Site in Putnam and Kanawha counties, West Virginia. The cleanup effort will focus on a 14-mile stretch within the Kanawha River. Cleanup work will include constructing a cap over more than 9 acres of contaminated river sediments. Similarly, the Diamond Alkali site in New Jersey contained 2,3,7,8-TCDD contamination at both the manufacturing site and the nearby Lower Passaic River. The site was found to contain high levels of 2,3,7,8-TCDD and was placed on the National Priorities List in 1984. As late as 2014, the site was still undergoing cleanup actions to prevent exposure to the contaminated soil and prevent further releases to the river. It is difficult to isolate the specific costs of cleaning up Agent Orange contamination under the Comprehensive Environmental Response, Compensation, and Liability Act, according to DOD and U.S. EPA officials. Moreover, cleanup plans address multiple contaminants, making it difficult to isolate the costs for cleaning up a specific contaminant, according to DOD and U.S. EPA officials. For example, the Diamond Alkali site had multiple contaminants from a number of companies that owned or operated facilities from which hazardous substances, including 2,3,7,8-TCDD and pesticides, were potentially discharged into the river and found in the soil and groundwater. Various cleanup actions were taken to address not only 2,3,7,8-TCDD contamination but the other contaminants as well. These actions included a groundwater collection and treatment system and capping to prevent exposure to contaminated soil (including contaminated soil that originated at the facility and soil that was brought to the facility from neighboring lots) and prevent further releases to the river. The Federal Government Has Some Information on the Procurement, Use, and Destruction of Agent Orange, and Available Documentation Indicates at Least One Vessel Carrying Agent Orange Transited through Guam to Vietnam, but Information Is Not Complete The federal government maintains information on Agent Orange, and available records indicate that DOD procured approximately 13.9 million gallons of the tactical herbicide, which was either used in U.S. military operations in Southeast Asia, used for testing, or destroyed. Our analysis of the available logbooks for 152 of the 158 shipments (approximately 96 percent) of Agent Orange to Southeast Asia that we identified indicates that the vessels carrying tactical herbicides generally stopped at foreign ports and sometimes at U.S. ports en route to Southeast Asia. Available primary source materials, such as shipment documentation, are incomplete because they were likely not maintained during and after the Vietnam era. However, based on the available information, we identified at least one ship carrying Agent Orange that stopped at Port Apra (now Apra Harbor) on Guam on its way to Vietnam, although we could not locate any evidence showing that any cargo was offloaded. Further, while DOD documents identify the use of commercial herbicides on Guam, they do not identify the use of tactical herbicides there. Available Records Indicate That All of the Agent Orange Procured Was Either Used in U.S. Military Operations, Used for Testing, Damaged, or Destroyed Available records that the federal government maintains indicate that DOD procured approximately 13.9 million gallons of Agent Orange between 1963 and 1968, of which it used an estimated 12.1 million gallons in Southeast Asia from 1965 to 1970; used a small amount for testing; and incinerated another 2.3 million gallons in 1977. Thus, the total quantity of Agent Orange that DOD procured was approximately equal to the total quantity that records indicate was tested in the United States and its territories, damaged during storage and shipment, and used during the Vietnam War, combined with the total quantity that records indicate was disposed of afterwards. Procurement and Use. Based on available records we reviewed, DOD procured approximately 13.9 million gallons of Agent Orange from nine chemical manufacturers between 1963 and 1968. In 1963 DOD used small amounts of Agent Orange for testing. DOD procurement officers then advised the Military Assistance Command, Vietnam, in late 1964 that they could fulfill the supply requirements for tactical herbicides with Agent Orange. Available records further indicate that of the approximately 13.9 million gallons of Agent Orange procured, DOD used an estimated 12.1 million gallons in operations in Vietnam from 1965 to 1970. In addition to the quantity used in Vietnam, Agent Orange usage also included quantities that were tested in the United States and its territories; used or tested in countries outside of Vietnam; lost during shipment and storage; or removed from the inventory and used to test different disposal options after its use was suspended. With the exception of the disposal testing amounts, no archival resources we could locate and obtain provided definitive usage figures. The last known shipment of Agent Orange to Vietnam was aboard the SS Frederick Lykes and arrived in May 1970. Restrictions on Use. In 1969 the National Environmental Health Service of the Department of Health, Education, and Welfare conducted testing of n-butyl 2,4,5-T—the component of Agent Orange whose manufacturing process produced 2,3,7,8-TCDD as a by-product—on mice, which raised concerns about health effects of the herbicide for women of child-bearing age. These concerns led to several U.S. government decisions that ended the use of tactical herbicides. Specifically, in 1969 DOD restricted the use of Agent Orange in Vietnam to keep it away from population centers. In April 1970 the federal government began restricting the use of 2,4,5-T in the United States. Exceptions were made for the control of weeds and brush on range, pasture, and forests, or on rights of way and other nonagricultural land. On April 15, 1970, DOD temporarily suspended the use of Agent Orange, including new procurement, acceptance of product on terminated contracts, transfer of stocks at Gulfport, and ocean shipping operations. Consolidation and Incineration of Remaining Stocks. After the U.S. government restricted the use of n-butyl 2,4,5-T—a component of Agent Orange—in 1970, DOD decided to consolidate the remaining 2.3 million gallons of Agent Orange stored in Vietnam and Gulfport, Mississippi, as well as any remaining amounts of n-butyl 2,4,5-T. According to an Office of Air Force History monograph, on January 16, 1971, DOD ordered the termination of all crop destruction missions by U.S. forces in Vietnam, and on September 27 of that year, the Chairman of the Joint Chiefs of Staff directed the Air Force to return all remaining stocks of Agent Orange to the United States and to dispose of them. Specifically, Agent Orange stocks in Vietnam were temporarily stored at U.S. Air Force bases at Da Nang, Phu Cat, and Bien Hoa until they were moved to Johnston Island in 1972. In 1972 the U.S. military moved approximately 1.36 million gallons of Agent Orange onto Johnston Island for storage. The cargo vessel SS Transpacific picked up this quantity at three Vietnamese ports from March 15 to April 1, traveled to Johnston Island, arrived on April 18, and completed offloading on April 28 before returning to the United States. This consolidated quantity of Agent Orange from Vietnam remained at Johnston Island until 1977. The Naval Construction Battalion Center Gulfport, Mississippi, was the final storage location in the continental United States for Agent Orange until the U.S. Air Force began the incineration of Agent Orange in 1977. There were approximately 860,000 gallons of Agent Orange at this location in 1977, which takes into account amounts lost in Hurricane Camille in 1969 or shipped away for testing, as described previously. The 1977 figure also takes into account 14,025 gallons transferred to the Naval Construction Battalion Center Gulfport, from Eglin Air Force Base, Florida, where the Air Force had tested formulations of Agent Orange for aerial spraying. In addition, available records show that quantities of the two components of Agent Orange were stored at the former Kelly Air Force Base, Texas, until 1972 before they were transferred to the U.S. Department of Agriculture for brush control projects. These reported amounts included 106,260 gallons of n-butyl 2,4-D and 38,940 gallons of n-butyl 2,4,5-T. These records also show that 173,910 gallons of Agent Blue were stored at the installation; see figure 5. DOD chartered the incinerator ship M/T Vulcanus and loaded the 860,000 gallons stored at Naval Construction Battalion Center Gulfport, Mississippi, beginning in May 1977. The vessel left Gulfport, Mississippi, in June 1977, and began incinerating the Agent Orange on board in July 1977 in a research burn to test the incineration process at sea near Johnston Island. In August 1977, the M/T Vulcanus loaded the remaining 1.36 million gallons stored at Johnston Island and conducted two more incineration operations just southwest of Johnston Island, as shown in figure 6. By September 3, 1977, all stocks of Agent Orange had been incinerated. Available Records Indicate That Vessels Transporting Agent Orange Stopped at Various Ports en Route to Southeast Asia, but Shipment Information Is Not Complete Our review of documentation for the shipment of almost 12.1 million gallons of the approximately 13.9 million gallons (approximately 87 percent) of Agent Orange procured by DOD found, based on available shipment documentation, that vessels transporting Agent Orange made stops at various ports on the way to Southeast Asia. However, shipment documentation is incomplete. Manufacturers of Agent Orange blended the two components of the herbicide—the n-butyl forms of 2,4-D and 2,4,5-T—and marked 55-gallon drums for shipment to Southeast Asia. Available records indicate that manufacturers produced Agent Orange according to military specifications and marked all drums for shipment directly to the receiving U.S. military unit in Vietnam. These specifications indicated the precise herbicide formulation of Agent Orange (n-butyl esters, 50 percent 2,4-D and 50 percent 2,4,5-T) and general instructions for marking the 55-gallon drums for shipment. For example, according to a historical monograph by the San Antonio Air Materiel Area, DOD specified that each drum was to be marked with a colored band or bands around the center as well as with transportation and contract data. Figure 7 shows an example of these drum markings. DOD then arranged for the transport of these drums, as well as drums of other tactical herbicides, by train from the manufacturers to several U.S. ports. DOD transportation officials accepted the product by signing a Material Inspection and Receiving Report that indicated the destination of the rail shipment and the final destination in Vietnam. DOD primarily chartered merchant marine vessels to ship the drums to Southeast Asia, but we identified one official Navy vessel, the USNS Lt. George W.G. Boyce, that carried Agent Orange to Southeast Asia. The first known shipment of Agent Orange left the port of New Orleans, Louisiana, on the SS Adabelle Lykes and arrived in Vietnam in February 1965. The last known shipment left the port of Gulfport, Mississippi, on the SS Frederick Lykes and arrived in Vietnam in May 1970. By that time, DOD had suspended all further shipments of Agent Orange. The photos in figure 8 provide examples of drums of Agent Orange being shipped by rail and tactical herbicides being loaded onto a cargo ship. The bulk of materiel used to support U.S. military forces in Vietnam, including tactical herbicides, was transported from the continental United States to Vietnam via ship. The vessels carrying the tactical herbicides generally stopped at foreign ports and sometimes at U.S. ports on the way to Southeast Asia. Our analyses of available shipment documentation indicate that at least 114 unique cargo vessels carried Agent Orange to Southeast Asia on at least 158 different voyages from 1965 through 1970. For each of these voyages, merchant vessel captains submitted logbooks to the U.S. port authorities at the end of each voyage. We were able to locate and obtain logbooks for 152 of the 158 shipments (approximately 96 percent) we identified. For 3 of the 6 voyages for which we were not able to locate logbooks, we obtained copies of the vessels’ shipping articles. We were not able to obtain shipping articles for the 3 foreign-flagged vessels because documents for such vessels were not turned in at U.S. ports. The Military Sea Transportation Service directly chartered merchant vessels to carry tactical herbicides during the Vietnam War. At least 28 vessels owned by the New Orleans, Louisiana-based Lykes Brothers Steamship Company transported Agent Orange between 1965 and 1970 from Gulf Coast ports to Southeast Asia. Lykes Brothers vessels were designed to handle cargo with cables that could place the cargo in a series of holds— numerous compartmented internal storage spaces. Tactical herbicides were stored vertically on pallets in these holds. The first large shipments of Agent Orange took place on the SS Adabelle Lykes, SS Elizabeth Lykes, and SS Mayo Lykes, traveling from the port of New Orleans, Louisiana, through the Panama Canal, and refueling in the Philippines before offloading a total of 1,782 55-gallon drums (approximately 97,000 gallons) in Saigon, Vietnam, in February and March of 1965. Our review of the logbooks and shipping articles for vessels carrying Agent Orange and other tactical herbicides showed that these vessels made stops at several U.S. and foreign ports, both in going to and in returning from Vietnam. For example, we identified vessels that stopped at several West Coast ports to load cargo before traveling to Vietnam, and others that made port calls to refuel in Hawaii. We also identified vessels that stopped at foreign ports such as Okinawa, Thailand, and Taiwan, as well as locations near the major U.S. Naval Supply Depots in Yokosuka, Japan, or Subic Bay, Philippines. These supply depots were major logistics hubs for U.S. military operations in East Asia, and they provided supplies to commercial ships that were chartered by DOD’s Military Sea Transportation Service through contracts with shipping companies. These companies would reserve cargo space for military cargo and include Saigon, Vietnam, as a destination, but the voyages were otherwise made for normal commercial activities. From those locations, the cargo vessels traveled to one or more ports in Vietnam. However, while the logbooks we reviewed identify when vessels left the various ports as they traveled to and from Vietnam, logbooks do not provide information on whether and how much cargo was loaded and unloaded at those ports of call, nor do they indicate whether tactical herbicides were offloaded at any ports before the vessels reached Vietnam. Available Shipment Documentation Indicates at Least One Vessel Carrying Agent Orange Went Through Guam en Route to Vietnam, but Archival Information Lacks Details or Is Not Complete Based on our review of available logbooks, we identified at least one vessel carrying Agent Orange that stopped at Guam en route to Vietnam and at least three vessels that stopped at Guam on the return from Vietnam. However, in our review of available shipment documentation, we found no evidence indicating that Agent Orange or any other tactical herbicides were offloaded from those vessels or used in the U.S. territories of Guam or the Northern Mariana Islands. Figure 9 indicates the timelines of the four vessels known to have carried Agent Orange that stopped at Guam either on their way to or returning from Vietnam, each of which is discussed in detail below. Available shipment documentation indicates that hundreds of vessels delivered supplies to the Naval Supply Depot, including supplies bound for Andersen Air Force Base, on Guam during the Vietnam War due to both installations’ strategic location in supporting the war effort. While the logbooks we were able to locate and review for vessels that transported Agent Orange to Southeast Asia between 1965 and 1970 do not show that these vessels typically stopped at Guam or the Northern Mariana Islands at any time during their voyages, we identified one ship carrying Agents Orange, Blue, and White that did stop at Guam on its way to Vietnam. Specifically, available records indicate that sometime around February 1, 1968, the SS Gulf Shipper stopped at Port Apra (now Apra Harbor) on Guam en route to Vietnam. Figure 10 shows a photo of the logbook from the SS Gulf Shipper indicating the ship’s ports of call en route to Vietnam. The logbooks do not provide details about whether cargo was moved on or off the vessels during these port calls, or whether tactical herbicides were offloaded at these ports before the vessels reached Vietnam. However, the SS Gulf Shipper’s logbook indicates that the stop at Guam could have been related at least in part to the repatriation of an injured crew member to the United States, and not to matters related to the loading or unloading of cargo. Further efforts to locate information on cargo movements for the SS Gulf Shipper, such as customs records, manifests, or bills of lading, were unsuccessful, because those records were not routinely retained. As such, we were not able to verify why the SS Gulf Shipper stopped at Guam, what its crew did while there, or whether any cargo was loaded or unloaded. We also identified at least three vessels that stopped on Guam on their return from Vietnam, based on our review of available logbooks. Specifically, around November 30, 1969, the SS Aimee Lykes stopped at Port Apra on Guam and offloaded an injured crew member into a small motorboat so that he could be hospitalized on Guam. In addition, around December 23, 1969, the SS Buckeye Atlantic stopped at Guam and offloaded two injured crew members. Lastly, around May 5, 1970, the SS Overseas Suzanne stopped at Guam and offloaded an injured crew member. Based on a review of the vessels’ logbooks, it is not clear whether the stops at Guam were for reasons other than offloading injured crew members—for example, reasons related to the loading or unloading of any cargo. Appendix III describes information that we were able to obtain regarding the quantities of herbicides known to have been shipped to Southeast Asia on the four vessels that we identified as having stopped at Guam (either on the way to or from Vietnam) between February 1968 and May 1970. As noted earlier, based on our review of available shipment documentation, we were able to identify approximately 87 percent of the shipments of Agent Orange to Southeast Asia, and to obtain logbooks for about 96 percent of the vessels known to have transported Agent Orange from U.S. ports to Vietnam. Because we were unable to obtain logbooks for every shipment of Agent Orange, we cannot conclude with certainty whether any ships other than the SS Gulf Shipper that were transporting the tactical herbicide to Vietnam, or the three ships returning to the United States from Vietnam—the SS Aimee Lykes, the SS Buckeye Atlantic, and the SS Overseas Suzanne—made port calls either at Guam or the Northern Mariana Islands. Additionally, we found and U.S Air Force officials agreed that it is unlikely that Agent Orange was shipped by air to or from Guam. The U.S. Air Force transported small quantities of tactical herbicides by air to Vietnam in 1961. However, we did not identify any documentation showing the transport of tactical herbicides by air to Vietnam after 1961. During our visit, officials at Andersen Air Force Base stated that it would have been possible to fly 55-gallon drums from Guam to supply operations in Vietnam, but that such an action would have been an inefficient method of transporting large quantities of herbicides. Agent Orange weighed approximately 600 pounds per drum, or about 11 pounds per gallon, a weight that, according to a 1966 memorandum from the Military Assistance Command, Vietnam, would have precluded large- scale transport of the herbicide by aircraft. DOD Documents Identify the Use of Commercial but Not Tactical Herbicides on Guam Available records show that DOD stored and used commercial herbicides on Guam, possibly including those containing n-butyl 2,4,5-T, during the 1960s and 1970s, but documents do not indicate the use of tactical herbicides on Guam. Commercial herbicides were available through the federal supply system for use on U.S. military installations worldwide. For example, the fuel supply for Andersen Air Force Base was delivered by ship to the port at Naval Base Guam and was then delivered to the Air Force base by a cross-island fuel pipeline—see figure 11. A detailed 1968 report by the Naval Supply Depot states that the Public Works Center sprayed herbicides semi-annually to control the vegetation along fuel pipelines between the depot and Andersen Air Force Base. Additionally, draft environmental assessments written in 1999 and 2009 by Naval Facilities Engineering Command, Pacific, indicate that commercial herbicides containing 2,4-D were present on Guam, and that commercial herbicides containing 2,4,5-T, which included the contaminant 2,3,7,8-TCDD, had been used for weed control along power lines and substations through 1980. Further, a 1969 master storage plan for the Naval Supply Depot includes sketches of storage facilities that specify the location of weed killers. Commercial herbicides approved for DOD procurement for use on installations were issued in 55-gallon drums and 5-gallon containers during the Vietnam War era, as were a range of other products, such as fuel oil and diesel. According to DOD officials, records for such purchases were not typically retained due to short record retention policies related to such routine supply transactions. During the course of our review, we received photographs and written statements from veterans alleging the presence of Agent Orange on Guam. However, based on our discussion sessions with veterans and civilians and our review of this documentation, we could not substantiate the presence or use of Agent Orange or other tactical herbicides on Guam. We asked veterans in our six discussion sessions about their potential for exposure to Agent Orange and where, if, and how they believe they were exposed. In their responses, some veterans in each of the six discussion sessions stated that they believe they were exposed to Agent Orange while deployed in Vietnam or other areas where a presumption of service for benefits has already been granted, while some veterans in three of the six discussion sessions stated that they believe they were exposed to Agent Orange while stationed on Guam. Specifically, some veterans in our discussion sessions described using herbicides or witnessing the spraying of herbicides at locations on Andersen Air Force Base and along the pipeline, as well as the burning of contaminated fuel as part of firefighting training on the installation. As we previously stated, according to DOD officials and archived military specifications, tactical herbicides were not authorized or available for use on lands owned by, or otherwise managed as military installations. However, commercial herbicides were widely available worldwide for use in vegetation management at military installations, to include controlling vegetation adjacent to flightlines or along perimeter fencing. Selected Comments by Veterans at Discussion Sessions Moderated by GAO Regarding Where They Believe They Were Exposed to Agent Orange or Its Components I feel like I was exposed on Guam. I was temporary duty there during the conflict and my duties were as a squadron controller that worked the schedules for the B-52 Bombers on Guam. I did venture into the loading area because I was with the aircrew on the Navy field at Andersen Air Force Base. I thought I was in contact with Agent Orange in Guam loading bombs in sites. We would move from one site to another and they would spray those areas before we got there. I never saw spraying but could smell it. One time I was near that and I broke out in boils and blisters on my face and arms. I was a fuel specialist I witnessed spraying going on at the barracks at Marbo Annex, 2 to 3 miles off the main Air Force base. It was sprayed all around the barracks. As my job, I worked at POL —where they stored all of the 55-gallon drums—fuels, pesticides, herbicides—in bulk storage. Those were constantly sprayed around—for maintenance and fire safety. Also, I would work on the flightline and at the pump houses—these were about 20 yards from the security fence. As I was working there, I witnessed spraying. DOD’s List of Herbicide Testing and Storage Locations Is Incomplete, and Veterans Have Expressed Confusion about How to Obtain Information on Potential Exposure DOD’s official compilation of herbicide testing and storage locations outside of Vietnam, which is posted on the VA’s website, is inaccurate and incomplete, and DOD does not have a process for managing the list. Further, while DOD and VA each have methods for communicating information to veterans and the public about Agent Orange, they do not have a formal process for communicating the most accurate available information to veterans about potential locations where they could have been exposed to Agent Orange or other tactical herbicides. DOD’s List of Locations Where Herbicides Were Tested and Stored Is Inaccurate and Incomplete DOD developed a list that identifies locations and dates where herbicides, including Agent Orange, are thought to have been tested and stored outside of Vietnam, which VA has made publicly available on its website, but this list is neither accurate nor complete. DOD’s list includes information on testing and storage locations, applicable dates, the herbicide or herbicide components tested, a description of the project, and DOD’s involvement. See appendix IV for the list that was posted on the VA website as of September 2018. When we began this review, DOD and VA officials were unable to identify the origin of the DOD list that is posted on the VA website, which does not have a date. A DOD official subsequently informed us that the list was initially created in 2003 by an individual in the Office of the Secretary of Defense in response to a congressional inquiry about the use of Vietnam-era herbicides at specific locations in the United States and overseas. DOD subsequently provided this list to VA, which in turn posted the information on its website. VA’s Claims Adjudication Procedures Manual related to Agent Orange directs VA officials to review the DOD list to determine whether herbicides were used as claimed as part of verifying potential herbicide exposure when a veteran alleges exposure at locations other than the Republic of Vietnam, the Korean demilitarized zone, or Thailand. However, in our review of several sources provided by DOD and VA officials, we identified multiple examples of inaccurate and incomplete information in DOD’s list, to include the following: Omission of specific testing and storage locations: We identified additional testing and storage locations in the United States and its territories that were not included on DOD’s list. For instance, we identified additional testing locations at Belle Glade, Florida, and Stuttgart, Arkansas, where researchers reported small-plot field tests of the components of Agent Orange on rice. In addition, we found examples of shipments of herbicides to Kelly Air Force Base, Texas, where Agent Orange components were stored following the cancellation of tactical herbicide contracts. None of these locations are included on DOD’s list. Lack of clarity in descriptive information: DOD’s list lacks clarity in descriptive information, making it difficult to identify which specific herbicides or components were tested and stored, as well as when and where. For example, the size and scope of some testing activities are unclear from the descriptions provided in DOD’s list, making it difficult to differentiate between small-scale and large-scale testing. Some testing events on DOD’s list are described in detail, including the amount of herbicide or components tested, while descriptions of other testing activities contain little information about what took place. Furthermore, we could not identify the chemical components of some of the agents on DOD’s list. We asked DOD and VA officials to identify those specific agents for us, and they were unable to do so. Specifically, neither DOD nor VA officials could identify the chemical composition of 26 different agents on the DOD list, making it difficult to determine whether these agents should be included on the list. Omission of additional time periods for identified locations: We identified additional testing events of Agent Orange or its components at locations that are on the DOD list but that cover additional time periods not reflected on the list. For instance, the DOD list identified testing that took place at Aberdeen Proving Grounds, Maryland, in July 1969. However, our review uncovered additional testing events that took place at Aberdeen Proving Grounds in 1963, 1965, and 1966. In addition to the lack of clarity and omissions that we identified, reports commissioned by DOD and VA since 2003 have also identified omissions in the list. For example, a report prepared for DOD in 2006 identified 40 different locations where Agent Orange was tested or stored outside of Vietnam. However, during our review, we found several examples of locations in the United States and its territories that were included in that 2006 report but are not included on the DOD list that is currently posted on the VA website. These include locations in Arkansas, California, New Jersey, New York, Maryland, Ohio, Oregon, Puerto Rico, Texas, and Utah. Similarly, a report prepared for VA in May 2013 described locations where Agent Orange exposure to Vietnam-era veterans has been alleged. This report summarized additional sites where veterans alleged Agent Orange was used, stored, or destroyed. It also included an assessment of the DOD information posted on the VA’s website—and indicated, notably, that information had not changed since the 2006 report to DOD. In the assessment, the report identified that the list contained many errors of dates, chemicals, locations, and the governmental agencies or institutions responsible for conducting the tests or military operations. The report suggested specific criteria for validating the presence of a tactical herbicide at a site, including evidence that a veteran actually came into contact with a tactical herbicide at that site. Even though they have received reports dating back more than a decade that identified issues with the accuracy and completeness of the list, neither DOD nor VA has taken steps to validate or correct the list, or to develop the criteria they would use to determine which locations and dates to include on the list. As previously stated, this list is posted on the VA’s Agent Orange website as a primary source for veterans seeking information on Agent Orange. Despite its inconsistencies, the list can be accessed from multiple places on the VA website, and we found that some veterans service organizations and other groups also post this incomplete and inaccurate list of testing and storage sites on their websites, as well as communicate this information to their members. Standards for Internal Control in the Federal Government state that agencies should use quality information to achieve their objectives. We found and DOD officials agreed that DOD’s list was not as accurate or complete as available records would allow because (1) there are not clearly identified responsibilities for validating the information on this list, (2) there is no process for updating the list as needed, and (3) criteria have not been developed and used to determine which locations and dates to include on the list. Until recently, neither DOD nor VA has taken responsibility for ensuring the accuracy and completeness of the list, which is being provided to veterans and the public on the VA website. Federal internal control standards state that management should establish an organizational structure, assign responsibility, and delegate authority to achieve the entity’s objectives. As noted earlier, DOD and VA officials were initially unable to identify the source or date of this list, and neither agency took action to respond to reports about the problems with it. During the course of our review, DOD took some initial steps to begin validating the accuracy and completeness of information on its list by reviewing primary source records for additional locations and events of herbicide testing and storage. However, thus far in its efforts, DOD has not identified responsibilities for completing the validation of the information included on the list, nor has it established a process for updating the list as any new information becomes available. Moreover, it remains unclear whether DOD’s review will cover all locations, including non-DOD sites, where testing and storage of Agent Orange or its components were thought to have occurred, or if it will focus only on U.S. military installations. Private companies, academic institutions, and other federal agencies were involved in the testing of herbicides at some of the non-DOD sites on the list, and, in some of those cases, Army personnel were involved in the testing at the non-DOD locations. For instance, testing was performed by DOD personnel at non- DOD locations in Georgia and Tennessee in the 1960s. Some non-DOD storage locations included various U.S. commercial ports, such as Mobile, Alabama, where Agent Orange was transferred by rail from the manufacturers to be stored until it was loaded onto vessels for shipment to Vietnam. According to a DOD official, DOD’s priority in its review of testing and storage locations is to focus on DOD installations. Although this official told us that the department expects to eventually identify non- DOD locations where the department was involved in herbicide testing and/ or storage through collaboration or funding, the official was not able to provide information on the time frames for conducting this review. Finally, DOD has not established a process for how this list will be updated once it has been validated and revised, when and if new information about Agent Orange testing and storage locations is identified. In our analysis of the DOD list, we were also unable to determine the criteria that DOD initially used to select which locations and time periods to include—particularly given that the testing varied in intensity and duration, and that the likelihood that personnel at a particular location could have been exposed to the herbicides or components was unclear. For example, some tests on the list included small laboratory experiments on a couple of plants using a very small amount of chemical agents, as in bench tests of various compounds at Forts Detrick and Ritchie, Maryland, in the 1950s, while other tests included gallons of Agent Orange or other chemical agent components that were used in field testing trials or to test aerial spraying, as in a defoliation effort in which 13 drums were sprayed by helicopter over an area covering 4 square miles. Similarly, the duration of testing events could have been over a total of 3 days, as with spray testing in Marathon, Florida, or over several months or even years, as with spray testing of several tactical herbicides at Eglin Air Force Base, Florida. Because of the variance in the size and duration of testing events; the specific areas where the testing events took place at the locations; and the number of personnel who actually came into contact with the chemical agents during the testing, the presence of a location on this list does not clearly indicate the likelihood or extent of potential exposure that individuals not involved would have had if they were simply present at the locations on the list at the times indicated. In May 2018, during the course of our review, a DOD official noted that DOD and VA formed a joint Herbicide Orange Working Group to address the issues with the DOD list and identify criteria for including information on this list. This group held its first meeting on May 31, 2018. As of July 2018, a DOD official noted that the group was working to identify appropriate steps to take, but that it was too soon to report specific actions that were being implemented, and that no documentation on the group’s efforts was available. Without assigned responsibility for ensuring an accurate and complete list of locations where Agent Orange or its components were tested and stored; a process for updating the list as needed; and clearly defined and transparent criteria for what to include on this list, DOD will not have reasonable assurance that it has identified the most complete information possible for VA to use when informing veterans and the public of the full extent of locations where Agent Orange exposure could potentially have occurred. As a result, veterans may not have complete information about the risk that they could have been exposed to Agent Orange during their military service, and VA may not have quality information when making important decisions on claims for veterans who may not be eligible for benefits. DOD and VA Have Communicated with Veterans and Others about Potential Exposure to Agent Orange, but Veterans Have Expressed Confusion Regarding How to Obtain Needed Information Both DOD and VA have communicated with veterans in response to inquiries about Agent Orange, but veterans have expressed confusion regarding how to obtain information to determine their potential exposure to Agent Orange. Further adding to this confusion are inconsistencies in the list of testing and storage locations, as discussed above. As the agency responsible for reviewing and validating veterans’ disability compensation claims for possible Agent Orange exposure, VA communicates with veterans largely through the agency’s website, which contains information on Agent Orange regarding related diseases, benefits, exposure locations, and resources. The VA also communicates through other means, including an annual newsletter and forums with veterans service organizations. DOD also receives inquiries from veterans about the potential that they could have been exposed to Agent Orange at DOD installations outside of Vietnam. In addition, DOD receives Freedom of Information Act inquiries and congressional requests for information on where Agent Orange was present. A DOD official stated that while they will respond to veterans’ inquiries, they typically direct veterans with Agent Orange inquiries to VA. In responding to these inquiries, both DOD and VA officials stated that they rely on the expertise of staff at the Armed Forces Pest Management Board to provide details to answer questions related to locations where exposure might have occurred. According to a DOD official, the board received 109 inquiries in 2017 alone. In addition, DOD’s Joint Services Records Research Center provides information to VA regional liaisons electronically in response to their questions about where and when specific units were stationed or on temporary duty. The center extracts operational records from various record repositories and, if the information is available, corroborates the descriptions of incidents described by veterans in their claims. According to DOD officials, unless an herbicide-related incident was documented in some sort of unit record, the center would not have information on where Agent Orange was present. Despite these various approaches for communicating information to veterans and the public, veterans we spoke with expressed confusion as to where to obtain information on their potential exposure to Agent Orange. Specifically, we asked veterans in our six discussion sessions about what they had heard from DOD, VA, or other federal agencies about the potential that they could have been exposed to Agent Orange or its components at locations where Agent Orange was manufactured, transported, stored, used, or destroyed. Veterans in each of the six sessions stated that, generally, the federal government has not reached out to them regarding Agent Orange, but that they instead have relied on their own research to learn more about their potential for having been exposed, adding to the confusion about where to obtain information on Agent Orange exposure. Other veterans, however, stated that they have received information from VA regarding potential exposure. DOD officials acknowledged that there is confusion among veterans about a variety of issues related to their potential for exposure to Agent Orange, including where to go for information. U.S. EPA and DOD officials stated that veterans are contacting multiple agencies to get information on herbicide exposure. Selected Comments by Veterans at Discussion Sessions Moderated by GAO Regarding What They Had Heard from the Federal Government about Negative Health Effects Associated with Exposure to Herbicides, Including Agent Orange or Its Components I’ve heard things from multiple sources—media, newspaper, television, people themselves. It has mainly been from my own research, not from a federal agency. Just based on the fact that I have heart disease and going through the VA process means I receive updates from VA on just about everything going on, including Agent Orange and all of the research they have done. I do know the Secretary is authorized by law from Congress late last year to add additional presumptive diseases associated with Agent Orange and how one would contract that. I had to do the research myself. It seems to be a secret with information coming out in spurts. When you have things happen to your body, they [the Department of Veterans Affairs] say it is not service connected. Sometimes when the government tries to explain something, they don’t give the whole thing and they give it piecemeal. It does not carry any essence of importance. I am not hearing anything from the federal government. Most of the information I get is from a USveterans.com website and I subscribe to a daily newsletter from the Vietnam Veterans of America and the Veterans of Foreign Wars. There is information on the VA website about conditions attributed to Agent Orange In that context, I went to the VA website and found that there are 21 states where Agent Orange was used, including on Hawaii in Kauai. It is because of this list that I became aware that people in Hawaii may have been exposed to Agent Orange. I learned that such exposure might increase the likelihood of having diabetes or cancer. I believe the list is still on the VA website and that there is also a list of units that were possibly exposed to Agent Orange. I have not been contacted by any government agency with regard to Agent Orange exposure or ill health. I first heard about Agent Orange and dioxin and cancer related issues/illnesses in late 1980s or early 1990s and later on after doing own research. Standards for Internal Control in the Federal Government state that management should internally and externally communicate the necessary quality information to achieve an entity’s objectives. The standard further states that management should evaluate the entity’s methods of communication so that the organization has the appropriate tools to communicate quality information throughout the entity on a timely basis. Additionally, DOD issued guidance in June 2017 establishing procedures for DOD components to implement when there is a scientifically plausible likelihood of a significant long-term health risk from a past environmental exposure to military personnel or civilians resulting from living or working on military installations. Even though the testing and storage of Agent Orange and its components occurred several decades ago, this instruction states that DOD components should provide targeted and effective health risk communication early and continuously, as new and credible information becomes available. However, DOD and VA officials stated that they have not developed a formal process for coordinating on how best to communicate information to veterans and the public regarding the presence of Agent Orange at locations outside of Vietnam. Officials stated that the DOD-VA Deployment Health Working Group—an existing forum for exchanging information—meets monthly to discuss health issues, including those related to Agent Orange. However, the working group is not focused on ensuring the availability and distribution of information on Agent Orange testing and storage locations. DOD’s and VA’s joint Herbicide Orange Working Group has the potential for being an effective forum for communicating this information; however, a DOD official noted that this is an ad hoc group, and as we discussed earlier, it has not yet determined the direction it will be taking for communicating with veterans regarding exposure to Agent Orange. By coordinating on how best to communicate this information, VA would be better positioned to provide veterans with information regarding their potential exposure to Agent Orange at locations where Agent Orange was known to have been present outside of Vietnam. Challenges Exist with Testing for Agent Orange Today Due to Degradation and Multiple Sources of Potential Contamination Testing to determine whether Agent Orange was present in a particular location is challenging because, for example, derivatives of Agent Orange—including the two components of Agent Orange (n-butyl 2,4-D and n-butyl 2,4,5-T) and the contaminant from the 2,4,5-T manufacturing process (2,3,7,8-TCDD)—degrade over time, and because derivatives of 2,4-D and 2,4,5-T can come from multiple sources. Regardless of these challenges, in response to a request by the Government of Guam, DOD developed a testing plan that was reviewed and accepted by U.S. EPA and Guam EPA to conduct a limited investigation into alleged Agent Orange use at three sites on Guam. Testing for Agent Orange Presents Challenges Due to Degradation and Multiple Sources of Potential Contamination Challenges Due to Degradation Testing to identify locations where Agent Orange may have been present is challenging because the components of Agent Orange degrade over time. It has been nearly 50 years since Agent Orange was last transported and used in support of military operations in Vietnam. According to scientific research, it is difficult to find traces of the two components of Agent Orange—n-butyl 2,4-D and n-butyl 2,4,5-T— because, under normal environmental conditions, the n-butyl forms break down rapidly into the acid forms. Scientific research indicates that the half-lives of the acid forms of the chemical components 2,4-D and 2,4,5-T in soil can range from several days to many months, depending on conditions. The World Health Organization has stated that the half-life of 2,4-D in soil is reported to range from 4 to 7 days in most soil types. According to the Centers for Disease Control and Prevention, the half-life of 2,4,5-T in soil varies with conditions, ranging from several weeks to many months. In addition, when Agent Orange is sprayed for defoliation, there are several things that can happen to it. For example, it can be washed out by rain, degrade in the presence of sunlight (photodegradation), or slowly turn into a vapor (volatize) from surfaces such as foliage. These factors reduce the chances of finding traces of Agent Orange components after 50 years. The amount of time it takes for the contaminant 2,3,7,8-TCDD to degrade is longer than that for the components of Agent Orange, although estimates vary. For example, according to the research cited by the Agency for Toxic Substances and Disease Registry, the half-life of 2,3,7,8-TCDD is approximately 9 to 15 years in surface soil and 25 to 100 years in subsurface soil. Further, 2,3,7,8-TCDD breaks down quickly when exposed to sunlight, providing one explanation for the shorter half- life in surface soil. Any 2,3,7,8-TCDD contamination from herbicide spraying—as opposed to being spilled onto the soil—would generally be expected to be found in surface soil, where it would be exposed to degradation due to sunlight. This reduces the likelihood of detecting this compound 50 years later. However, as discussed below, there are multiple sources of dioxins, including 2,3,7,8-TCDD, and the specific source of dioxin contamination is difficult to identify. Challenges Due to Multiple Sources of Potential Contamination Testing to identify locations where Agent Orange may have been present is challenging because there are multiple sources of 2,4-D and 2,4,5-T derivatives as well as multiple sources of the contaminant, 2,3,7,8-TCDD. Specifically, many commercial herbicides that were available at the time Agent Orange was used contained derivatives of 2,4-D; 2,4,5-T; or both. Additionally, 2,4-D derivatives are still used in commercial herbicides today. Therefore, even if testing were to show the presence of one of the two components of Agent Orange, it would be difficult to distinguish whether the chemicals were present from the use of commercial herbicides or the use of tactical herbicides. Further, because 2,4-D is still used in many commonly used herbicides sold today, the presence of this component could be due to a recent use of a commercial herbicide rather than a tactical herbicide used decades ago. Moreover, multiple sources of the contaminant 2,3,7,8-TCDD can be found in the environment today. DOD and U.S. EPA officials told us that if 2,3,7,8-TCDD is found in soil today, the source of the dioxin contamination could be a result of other sources besides Agent Orange. For example, according to the World Health Organization, dioxins— including 2,3,7,8-TCDD—are primarily released to the environment with the burning of materials such as wood and waste (see figure 12). Testing for the Components of Agent Orange on Guam Is Challenging In 2017 the Government of Guam coordinated with DOD to test for Agent Orange and other tactical herbicides at Andersen Air Force Base due to claims from veterans that they were exposed to Agent Orange while stationed on Guam during the 1960s and 1970s. In December 2017 DOD developed a draft testing plan in collaboration with U.S. EPA and Guam EPA to test for the acid form of the components 2,4-D and 2,4,5-T at three different sites on Andersen Air Force Base. The draft testing plan did not include testing for the presence of 2,3,7,8-TCDD. According to DOD and U.S. EPA officials, they are not testing for 2,3,7,8-TCDD because the test would not be able to conclusively link any positive results to the use of tactical herbicides, given that dioxins are also produced by, among other things, burning fossil fuels. These officials noted that, over time, large quantities of fuel have been burned at Andersen Air Force Base, and they stated their belief that if 2,3,7,8-TCDD were found, the likely source would be from combustion. The areas identified for testing included the fuel pipeline, a perimeter fenceline, and an area near some fuel storage tanks. See figure 13 for a photograph of the fenceline testing site near the fuel storage tanks on Andersen Air Force Base. Based on our initial review of the draft testing plan and a review of the scientific literature, we identified and discussed with DOD and U.S. EPA officials some challenges the two agencies would face in detecting the presence of Agent Orange on Guam due to two factors: (1) the short amount of time that it takes for 2,4-D and 2,4,5-T to degrade; and (2) the inability of testing to determine whether the presence of 2,4-D and 2,4,5-T is attributable to the use of Agent Orange or to some other source. Degradation of 2,4-D and 2,4,5-T: DOD officials and the jointly developed draft testing plan acknowledged that the planned testing would not be able to confirm the presence of Agent Orange, given that the components degrade over time. The draft testing plan indicates that the maximum half-lives of 2,4-D and 2,4,5-T are 14 days and 24 days, respectively, in soil and groundwater. Even given the possible variation in half-lives discussed above, it is likely that no detectable concentrations remain in soil today, given that the alleged period of use on Guam was in the 1960s and 1970s. Inability to distinguish whether the presence of 2,4-D and 2,4,5-T is attributable to the use of Agent Orange or some other source: Even if the results were to confirm the presence of either 2,4-D or 2,4,5-T in any form, it would be difficult to distinguish the source of the chemical, and whether its presence was attributable to the use of Agent Orange or some other source. For example, 2,4-D is still in use today, and 2,4,5-T was used in both tactical and commercial herbicides during the 1960s. In addition, if the components were found, the interpretation of those results could be complicated by, for example, natural variability in the potential half-lives and the possibility of more recent use of banned products. Further, the testing protocol will convert all forms of 2,4-D and 2,4,5-T, including the ester forms, to the acid forms, further complicating any attempt to identify the source of the compounds. We discussed with cognizant officials the challenges that we identified in the draft testing plan to determine how the information from the testing would be used to inform U.S. EPA, DOD, veterans, and the public about whether Agent Orange was present on Andersen Air Force Base. DOD officials subsequently stated that the questions raised by us and internally within DOD led them to reconsider the approach for testing for Agent Orange on Guam. For example, in December 2017, DOD officials told us that they would begin testing for Agent Orange and other tactical herbicides in March 2018. In late March 2018, a DOD official noted that the department had placed the testing on hold until they were certain that the methodology to be employed would meet scientific rigor and could be replicated in future testing efforts at other locations. In April 2018, DOD officials told us that the contract execution took longer than anticipated, and that soil sample testing would commence that month. In April 2018, DOD provided us with a copy of the final plan that was reviewed and approved by U.S. EPA and Guam EPA and was used to test for Agent Orange and other tactical herbicides at Andersen Air Force Base. When we reviewed the final testing plan and compared it with the draft previously provided, we found that some of the challenges we had initially identified in the draft testing plan, as described above, were still present. For example, based on our review of the final testing plan, with the proposed testing methodology, it would be difficult to determine if 2,4- D and 2,4,5-T came from Agent Orange or another source, and there were inconsistencies in the reported half-lives of the components of Agent Orange. At the same time, both DOD and U.S. EPA officials questioned the ability of any testing for 2,4-D or 2,4,5-T on Andersen Air Force Base to either confirm or deny the presence of Agent Orange on Guam. Specifically, the final testing plan states that more than 50 years have passed since the period of alleged use, and that a lack of detection provides no evidence that herbicides were not used historically. Moreover, U.S. EPA officials noted that the testing on Guam would not provide definitive proof of Agent Orange use on the island. Although DOD officials recognized these challenges and acknowledged the low probability of conclusively identifying the components of Agent Orange, they decided to move forward with testing to address veterans’ and the public’s concerns. In April 2018, samples were collected from the three areas at Andersen Air Force Base, according to DOD officials. Each sample was divided following procedures outlined in the final testing plan, resulting in two identical sample sets. A sample set was sent to two independent laboratories for analysis. According to officials from DOD and U.S. EPA, test results and associated quality control reports from both laboratories agreed on the results from two of the area samples, but did not agree on the third area sample. The jointly developed decision rules for the sampling and analysis plan required the results from both laboratories to agree in order to draw a conclusion on the presence or absence of Agent Orange. As a result, according to the officials, the DOD, U.S. EPA, and Guam EPA project team agreed in July 2018 to resample the one area where the two labs reported differing results. The project team is updating the sampling and analysis plan to address the various possible reasons for the differing laboratory results in order to provide a conclusive final testing result. DOD officials told us they do not anticipate completing the updates for the sampling and analysis plan, field sampling, analysis, and reporting until early 2019. As such, we were not able to comment on the results of the final testing in this report. Moreover, DOD officials said that, provided the final resampling results are negative, DOD does not have plans to conduct additional testing, because the testing was conducted in areas alleged to be the likeliest locations for the application of Agent Orange. However, an official from U.S. EPA said that the challenges associated with testing on Guam are not insurmountable and that the agency would like to continue this investigation. Given that (1) DOD, working with U.S. EPA and Guam EPA, made a decision to test for Agent Orange and other tactical herbicides; (2) DOD, U.S. EPA, and Guam EPA recognize the limitations associated with the testing; (3) the testing and analysis of results are still on-going; and (4) there is currently uncertainty regarding whether any additional testing will take place on Guam, we are not making any recommendations with respect to the testing plan or its execution. Conclusions DOD suspended the use of Agent Orange in Vietnam in 1970 and incinerated remaining stockpiles at sea in 1977, but concerns about the effects of exposure in U.S. locations have persisted. DOD developed a list that identifies locations and dates where herbicides, including Agent Orange, are thought to have been tested and stored outside of Vietnam, which VA has made publicly available on its website, but this list is neither accurate nor complete. Without assigning responsibilities for verifying the accuracy of the information included on the list; a process for ensuring that the list is updated, as new information is found; and clear and transparent criteria, indicating which locations should be included on the list, DOD and VA will not have assurance that they have the most complete information possible when informing veterans and the public of the full extent of locations where Agent Orange exposure could potentially have occurred. By relying on an inaccurate list, VA may not have quality information when making important decisions on claims for veterans who might or might not be eligible for benefits. Further, while DOD and VA both communicate with veterans in response to their Agent Orange inquiries, the two agencies do not have a formal process for coordinating on how best to communicate this information. Until DOD and VA develop a process for how best to coordinate to ensure that they are communicating information, veterans and the public may not have the information needed regarding their potential exposure to Agent Orange. Recommendations for Executive Action We are making six recommendations: four to the Secretary of Defense and two to the Secretary of Veterans Affairs. The Secretary of Defense should ensure that the Under Secretary of Defense for Acquisition and Sustainment assigns responsibility for ensuring that DOD’s list of locations where Agent Orange or its components were tested and stored is as complete and accurate as available records allow. (Recommendation 1) The Secretary of Defense should ensure that the Under Secretary of Defense for Acquisition and Sustainment develops a process for updating the revised list as new information becomes available. (Recommendation 2) The Secretary of Defense, in collaboration with the Secretary of Veterans Affairs, should develop clear and transparent criteria for what constitutes a location that should be included on the list of testing and storage locations. (Recommendation 3) The Secretary of Veterans Affairs, in collaboration with the Secretary of Defense, should develop clear and transparent criteria for what constitutes a location that should be included on the list of testing and storage locations. (Recommendation 4) The Secretary of Defense, in collaboration with the Secretary of Veterans Affairs, should develop a formal process for coordinating on how best to communicate information to veterans and the public regarding where Agent Orange was known to have been present outside of Vietnam. (Recommendation 5) The Secretary of Veterans Affairs, in collaboration with the Secretary of Defense, should develop a formal process for coordinating on how best to communicate information to veterans and the public regarding where Agent Orange was known to have been present outside of Vietnam. (Recommendation 6) Agency Comments and Our Evaluation We provided a draft of this report for review and comment to DOD, VA, U.S. EPA, the U.S. Department of Agriculture, and the U.S. Department of Health and Human Services. In its written comments, DOD concurred with each of our four recommendations directed to the Secretary of Defense and identified actions it plans to take to implement them. In its written comments, VA concurred with one recommendation directed to the Secretary of VA and described actions it would take to implement the recommendation. VA also non-concurred with one recommendation. In its written comments, the U.S. Department of Agriculture agreed with the report’s findings related to matters under the purview of agricultural research and programs, though we did not make any recommendations to the department. Comments from DOD, VA, and the U.S. Department of Agriculture are reprinted in their entirety in appendixes V through VII. We also received technical comments from DOD, VA, U.S. EPA, and the U.S. Department of Health and Human Services, which we incorporated as appropriate. Based on oral comments we received from DOD, we revised our recommendation regarding the development of clear and transparent criteria for what constitutes a location that should be included on the list of testing and storage locations to clarify that DOD and VA should collaborate on this effort. VA non-concurred with this recommendation, noting that DOD chairs the Herbicide Orange Working Group that will be responsible for developing the criteria (Recommendation 4). However, VA stated that as a member of the working group, it would work collaboratively with DOD as the lead. Doing so would meet the intent of our recommendation. In its overall written comments, VA stated that it was concerned that the report conflates the terms “commercial herbicides” with “tactical herbicides,” which the department noted were distinctive from one another. While VA stated that it does not dispute that some chemicals found in the VA regulation may be included in certain commercial herbicides, VA noted that exposure to tactical herbicides intended for military operations in Vietnam is required for VA to grant disability benefits on a presumptive basis. We recognize that the presumption for service- connection applies to exposure to tactical herbicides and nothing in our report states otherwise. VA also stated in its letter that the focus on commercial herbicides is not relevant for determining the list of locations where tactical herbicides were tested or stored. We agree and as we noted in this report, the U.S. military managed tactical herbicides used during the Vietnam War era differently from commercial herbicides in the federal supply system, which were widely available worldwide for use in vegetation management at military installations. To avoid conflating tactical and commercial herbicides, the report further notes that while some of these commercial herbicides contained 2,4-D; 2,4,5-T; or both, these commercial herbicides were not in the n-butyl form used in Agent Orange. However, commercial herbicides with 2,4,5-T likely contained some level of 2,3,7,8-TCDD. Moreover, we believe it is important to reiterate that numerous commercial herbicides that were being widely used elsewhere for agriculture purposes contained the form of 2,4,5-T found in Agent Orange and thus its associated dioxin contaminant, 2,3,7,8-TCDD. In its overall written comments, VA also recommended that GAO analyze its list to ensure that only locations where the presence of tactical herbicides has been confirmed are included on the list of locations. It is important to note that we do not maintain a list of herbicide testing and storage locations. As we noted in this report, DOD developed a list that identifies locations and dates where herbicides, including Agent Orange and its components, are thought to have been tested and stored outside of Vietnam, which VA has made publicly available on its website. We are sending copies of this report to the appropriate congressional addressees; the Secretaries of Defense, VA, Agriculture, and Health and Human Services; and the Administrator of U.S. EPA. In addition, the report will be available at no charge on the GAO website at http://www.gao.gov. If you or your staff have any questions about this report, please contact Brian Lepore at (202) 512-4523 or leporeb@gao.gov or J. Alfredo Gómez at (202) 512-3841 or gomezj@gao.gov. Contact points for our Offices of Congressional Relations and Public Affairs may be found on the last page of this report. GAO staff who made key contributions to this report are listed in appendix VIII. Appendix I: Objectives, Scope, and Methodology House Report 115–200 accompanying a bill for the National Defense Authorization Act for Fiscal Year 2018 included a provision that we review the government’s handling of Agent Orange on Guam. In response to both this provision and a separate request letter, this report examines (1) the extent to which the federal government has information about the procurement, distribution, use, and disposition of Agent Orange or its components at locations in the United States and its territories, including Guam; (2) the extent to which the Department of Defense (DOD) and the Department of Veterans Affairs (VA) have complete and accurate information about where Agent Orange and its components were tested and stored and communicated this information to veterans and the public; and (3) challenges associated with testing for Agent Orange. For objective one, we collected and reviewed available agency records and shipping documents on Agent Orange from the following sources: the U.S. National Archives and Records Administration; the U.S. National Agricultural Library; the U.S. Air Force Historical Research Agency at Maxwell Air Force Base, Alabama; staff historians at the Air Force Materiel Command at Wright- Patterson Air Force Base, Ohio, and Pacific Air Forces at Joint Base Pearl Harbor–Hickam, Hawaii; the Armed Forces Pest Management Board in Silver Spring, Maryland; the Defense Logistics Agency; the U.S. Army Corps of Engineers; and the Naval History and Heritage Command. The records we researched and collected include published and unpublished materials on the procurement, shipment, and disposition of Agent Orange, including U.S. military correspondence, logistics reports, and Navy and merchant vessel logbooks. We reviewed DOD documents related to Agent Orange contracts to determine the total quantity of Agent Orange that was produced by the nine manufacturers. To show how much Agent Orange was used in Vietnam, we used estimates from the National Academy of Sciences analysis of Operation Ranch Hand data. Details about the estimated quantity of Agent Orange that was destroyed in 1977 are available in public reports from DOD and the U.S. Environmental Protection Agency (U.S. EPA). We used a variety of archival sources to identify the shipping routes for Agent Orange, to include a database prepared for VA that lists records held in National Archives and Records Administration Record Group 341, which contains more than 200 boxes of unclassified records relating to tactical herbicides used in Vietnam. During our review of this record group, we identified and summarized the correspondence between and reports submitted by the U.S. military commands that managed the tactical herbicides, to identify details of tactical herbicide shipments and, to the extent that the data were available, to develop a consolidated list of shipments of Agent Orange, including vessel names, ports of embarkation and debarkation, time frames, and quantities. In some cases, individual source documents did not identify which specific tactical herbicides were being shipped. To the extent we were able, we used multiple sources to identify which shipments carried Agent Orange. For the purposes of this report, we refer to these records collectively as shipment documentation. Using this shipment documentation, we located and obtained from several regional facilities of the National Archives and Records Administration logbooks for the vessels that we had identified as having shipped Agent Orange—hereinafter referred to as logbooks—which accounted for approximately 83 percent of the shipments we found. Logbooks that were submitted to port authorities upon the vessels’ returns to the United States were consolidated at National Archives and Records Administration facilities including Fort Worth, Texas; Seattle, Washington; San Francisco and Riverside, California; New York, New York; Philadelphia, Pennsylvania; Boston, Massachusetts; Chicago, Illinois; and Atlanta, Georgia, as well as at Archives I in Washington, D.C., and Archives II in College Park, Maryland. These logbooks recorded basic details about each ship’s operation and route, which we analyzed to identify any shipments that stopped at locations in the United States or its territories before arriving in Vietnam. Because none of the logbooks we reviewed provided detail about the specific types of cargo that were loaded onto or unloaded from the vessels, we relied on available military correspondence and reports about those vessels to identify whether the ships carried Agent Orange. We attempted to locate the remaining 17 percent of the logbooks, or 27 shipments. Of those shipments, 3 were by foreign-flagged merchant vessels, which did not submit logbooks to U.S. ports. Working with officials from the U.S. Coast Guard, the agency that oversees the retention and archiving of logbooks, we coordinated with archivists at the Federal Records Centers to determine whether there were any unprocessed boxes of logbooks that had not yet been archived. When that effort did not turn up additional logbooks, we worked with archivists at Archives I to obtain copies of shipping articles—the articles of agreement between the captain of a ship and the seamen with respect to wages, length of time for which they are shipped, and related matters—for the remaining 24 shipments. While these documents focus on employment issues, the annotations include the locations where different personnel actions took place. We reviewed these documents to identify the locations and approximate dates of the ports of call during those voyages. We were able to obtain the shipping articles for the 24 remaining voyages, as well as for the one vessel that stopped in Guam on the way to Vietnam (SS Gulf Shipper) and the three that stopped in Guam on the way back (SS Aimee Lykes, SS Buckeye Atlantic, and SS Overseas Suzanne). Using the information on voyage ending dates and ports that we obtained from the shipping articles, we were able to work with the regional archives to obtain another 21 logbooks, bringing the total number of logbooks obtained to 152, or 96 percent of the shipments we identified. We relied on the shipping article information for the remaining three voyages (excluding the shipments on the three foreign-flagged vessels) to provide some information on the routes taken by those vessels. However, one limitation of relying on shipping articles for port information and dates is that locations are mentioned only if a personnel action—such as an injury, hospitalization, or desertion—took place. If no personnel action took place at a location on a vessel’s route, that port would not be listed in the shipping articles. To obtain specific information about the SS Gulf Shipper voyage that stopped in Guam en route to Vietnam, to include documentation on its cargo and whether or not cargo was loaded or unloaded at the ports on the way to Vietnam, we contacted officials at several agencies. In Guam, we contacted the Customs and Quarantine Service, the University of Guam’s Micronesian Research Center, and officials at Naval Base Guam for information on vessels that stopped in Guam during the Vietnam War era, and any cargo they carried. We also contacted archivists at the Federal Records Center in Seattle, Washington, where the SS Gulf Shipper logbook is archived, and the regional archives in Fort Worth, Texas, for additional information on the vessel itself and guidance on retaining and archiving cargo information. The National Archives had some information on the SS Gulf Shipper, such as sales documents and company correspondence records. However, the National Archives did not have records for the manifest or bills of lading, which may have documented any cargo offloaded from the ship. We contacted U.S. Customs and Border Protection for information on movements of vessels engaged in foreign trade in and out of ports, which is found in customs forms that are required to be archived after 30 years. We were unsuccessful in locating the customs forms for the SS Gulf Shipper’s voyage to Vietnam through Guam; however, an official noted that although these records provide manifest numbers and ports of sailing, the manifests themselves are not archived. An online search on the SS Gulf Shipper through the U.S. Maritime Administration’s website identified the transfer of vessel ownership over the years. We contacted the latest company that owned the vessel to see whether the company had retained any cargo manifests or other historical records as the ownership changed hands. However, we could not obtain this information because, according to a company official we contacted, the vessel’s records, along with other historical documents, were stored in an off-site storage facility in New Jersey, and were subsequently destroyed in a fire in 1996. We also looked at articles from Guam newspapers and news sources such as the Military Sea Transportation Service Vietnam Chronicles for any information about vessel comings and goings in Guam in early 1968 to see if they mentioned the SS Gulf Shipper or specific cargo being offloaded in Guam. None of these contacts or written sources provided information specific to any cargo that was being moved through Guam, or about this particular vessel. We also obtained original DOD reports and command histories that provided additional operational details about the procurement, distribution, use, and disposition of Agent Orange and its components. According to an Office of History, Air Force Logistics Command, monograph, the command directly responsible for managing Agent Orange was the Directorate of Aerospace Fuels at the San Antonio Air Materiel Area at the former Kelly Air Force Base, Texas, which was a sub-component of the U.S. Air Force Logistics Command during the Vietnam War. The unclassified San Antonio Air Materiel Area command histories for the years 1966 through 1973 include chapters with extensive documentation on “herbicide management.” We obtained copies of command histories from the Air Force Historical Research Agency at Maxwell Air Force Base, Alabama, and the Air Force Materiel Command at Wright-Patterson Air Force Base, Ohio. To obtain information regarding herbicide use on Guam, we obtained command histories for Naval Base Guam and an analysis and summary of the available documentation by the historian at Andersen Air Force Base. We also spoke with Navy and Air Force officials on Hawaii and Guam to identify any relevant records pertaining to such use. In addition, we met with and obtained information from officials representing the Office of the Governor of Guam and senior members and staff from the Guam Legislature. We also met with officials representing a veterans service organization. Finally, as discussed below, we spoke directly with veterans about their recollections of herbicide use on Guam, and any documentation they might have pertaining to such use. For objective two, we analyzed the archival search records provided by DOD to identify additional locations where Agent Orange or its components were tested and stored in the United States and its territories. We reviewed Army archives search reports of herbicide testing at Aberdeen Proving Grounds (including Edgewood Arsenal), Maryland; Dugway Proving Ground, Utah; Fort Chaffee, Arkansas; Fort Gordon, Georgia; Fort Meade, Fort Ritchie, and Fort Detrick, Maryland; and two Air Force studies related to herbicide equipment testing at Eglin Air Force Base, Florida, to determine whether there were additional sites and testing events that were not included on the DOD list found on the VA website. We also reviewed the proceedings of the First, Second, and Third Defoliation Conferences, technical and special reports, and published papers provided by the Armed Forces Pest Management Board to determine whether there were additional sites and testing events that were not included on the list. We compared the information about testing locations and dates on the DOD list found on the VA website with information found in a 2006 report on locations where Agent Orange was tested and stored. To determine the locations where Agent Orange or its components were tested and stored, we attempted to identify the chemical composition of all the agents on DOD’s list found on the VA website. We located information on the chemical composition of agents on the list in archives search reports for Forts Detrick, Meade, and Gordon; a glossary of pesticide chemicals from the Food and Drug Administration; journal articles; and the defoliation conference proceedings. We also interviewed DOD and VA officials about the chemical composition of agents on the list, the origins of the list, how the list is used, and the role of each agency in managing the list. We compared the results with information that DOD and VA provided publicly on testing and storage locations of tactical herbicides in the United States and its territories, and with DOD policies for conducting record research and responding to inquiries related to past environmental exposures. We also compared the accuracy and completeness of the list with Standards for Internal Control in the Federal Government, which state that management should internally and externally communicate the necessary quality information to achieve the entity’s objectives. We also reviewed the extent to which DOD and VA have communicated health information to DOD personnel and veterans. We compared the communication process that both DOD and VA use with DOD’s guidance on assessing long-term health risks, and with VA’s process for determining benefits based on veterans’ claims. We also compared DOD and VA actions with Standards for Internal Control in the Federal Government, which state that management should internally and externally communicate the necessary quality information to achieve the entity’s objectives. The standard further states that management should evaluate the entity’s methods of communication so that the organization has the appropriate tools to communicate quality information throughout the entity on a timely basis. We also reviewed documents from DOD and VA on communication with veterans, including the VA’s website on Agent Orange. Further, we interviewed cognizant agency officials from DOD and VA, including officials from the Armed Forces Pest Management Board and DOD’s Joint Services Records Research Center. For objectives one and two, to better understand veterans’ experiences with Agent Orange and other herbicides and the health effects of exposure to them, we conducted six small discussion sessions with a non-generalizable sample of veterans. Four of the discussion sessions were conducted in person in the following locations: two discussion sessions in Guam, and two discussion sessions in Hawaii. We conducted two additional discussion sessions that were moderated via telephone from Washington, D.C.: one of those had individuals participate both in person and by telephone, while the other was held solely by telephone. We selected Guam because of the provision in House Report 115–200 accompanying a bill for the National Defense Authorization Act for Fiscal Year 2018 for GAO to review the government’s handling of Agent Orange on Guam. We selected Hawaii because of its strategic location during the Vietnam War and because of the VA presence in the region. A total of 38 individuals attended the sessions, which ranged from 1 to 10 participants per session and lasted approximately 1 to 2 hours. These discussion sessions were consistently moderated by the same team member using a prepared script and documented by several other team members. To select candidates for participating in our discussion sessions, we worked with the Veterans Health Administration as well as veteran clinics and veteran centers at the selected locations to identify non-combat veterans who had served during the Vietnam era. In Guam, we also worked with the Guam Environmental Protection Agency to coordinate a discussion session. Attendees included Vietnam-era veterans who self- reported that they were in active service between 1961 and 1977 in Vietnam, the United States, and its territories, including Guam. As we became aware of other veterans who might be interested in these discussion sessions, including Vietnam combat veterans, we reached out to offer them the opportunity to participate in one of our discussion sessions. Our six discussion sessions included questions to individuals regarding what, if anything, they had heard from DOD, VA, or other federal agencies about links between exposure to herbicides and negative health effects, and whether attendees believed that they had been exposed to Agent Orange or its components at locations where Agent Orange was manufactured, transported, stored, used, or destroyed. We also asked individuals if they believed they had been exposed to Agent Orange in Guam, Vietnam, or another location, and if so, to describe the situation. At the start of the discussion sessions, the moderator told participants that their responses would be kept confidential and that we were not recording their statements. The moderator noted that we would be taking notes to make sure we accurately captured the conversations, but that we would not attribute statements directly to individuals. For those discussion sessions held in person in Guam and Hawaii, we also administered a brief, written questionnaire about individuals’ experiences during the Vietnam era (for example, duty locations, military occupation, rank), and what they had heard and experienced related to Agent Orange and other herbicides. Due to logistical obstacles, we were not able to administer the questionnaire to participants in sessions held via telephone. However, the information requested in the questionnaire was also covered in the discussion sessions themselves. Therefore, we did not analyze the information from the completed questionnaires. We also solicited from the veterans any documentation they might have that could support their allegations of the use of Agent Orange on Guam, but we did not receive documentation that corroborated the use of Agent Orange on Guam. In addition, we met with officers from the Vietnam Veterans of America to discuss how, if at all, veterans could have been exposed to Agent Orange beyond serving directly in Vietnam as part of Operation Ranch Hand, and how the organization disseminates information, especially on Agent Orange, to veterans. For objective three, we reviewed scientific literature and agency documents regarding the degradation and sources of the components of Agent Orange and an associated dioxin contaminant, 2,3,7,8-TCDD, as well as other sources of dioxins. This review included documents from the Agency for Toxic Substances and Disease Registry and reports and protocols from U.S. EPA, the World Health Organization, the Centers for Disease Control and Prevention, and the American Industrial Hygiene Association. We also reviewed the draft and final plans for testing for the presence of the acid forms of the components of Agent Orange—2,4-D and 2,4,5-T—on Guam. We compared the information outlined in the testing plan with scientific literature on the environmental fate of the components of Agent Orange and other Agent Orange testing methodologies. We interviewed officials from DOD, U.S. EPA, and Guam EPA about the testing plan for Guam and the science surrounding Agent Orange testing. We also conducted a site visit to Naval Base Guam and Andersen Air Force Base on Guam and interviewed DOD and Government of Guam officials involved in the planning for the testing for Agent Orange on Andersen Air Force Base. We visited the three selected sites where the initial testing took place and took photographs of those sites. We conducted this performance audit from May 2017 through November 2018, in accordance with generally accepted government auditing standards. Those standards require that we plan and perform the audit to obtain sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objectives. We believe that the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objectives. Appendix II: Comparison of the Department of Veterans Affairs (VA) List of Diseases Associated with Agent Orange against Those Identified by the National Academy of Sciences The VA recognizes 14 presumptive diseases associated with exposure to Agent Orange or other herbicides during military service for which veterans and their survivors may be eligible to receive disability compensation benefits. The list of diseases provided by the VA has generally incorporated the findings of reviews performed by the National Academy of Sciences (the Academy). The list includes 5 diseases that have been identified as having sufficient evidence of association and 9 that have been identified as having limited or suggestive evidence of association. In the Academy’s biannual reports, for a disease identified as having sufficient evidence of association, the evidence is sufficient to conclude that there is a positive association—that is, a positive association has been observed between herbicides and the outcome in studies for which chance, bias, and confounding could be ruled out with reasonable confidence. For a disease identified as having limited or suggestive evidence of association, the evidence is suggestive of an association between herbicides and the outcome but is limited, because chance, bias, and confounding could not be ruled out with confidence. Table 1 describes those 14 diseases and the extent of association identified by the Academy. The 2014 Academy biannual report, issued in 2016, listed four more diseases it categorized as having limited or suggestive evidence of association, as described in table 2. VA officials told us that these diseases are not included on the VA’s current list of presumptive diseases associated with exposure to Agent Orange or other herbicides because, as of October 25, 2018, the Secretary of Veterans Affairs had yet to make the determination based on the most recent biannual review (the 2014 report). According to the officials, the Secretary is also considering the inclusion of parkinsonism and Parkinson-like syndromes. Finally, according to the VA website, VA has recognized that certain birth defects among veterans’ children are associated with veterans’ qualifying service in Vietnam or Korea. For example, spina bifida (except spina bifida occulta) is associated with veterans’ exposure to Agent Orange or other herbicides during qualifying service in Vietnam or Korea. The affected child must have been conceived after the veteran entered Vietnam or the Korean demilitarized zone during the qualifying service period, and a child with spina bifida or covered birth defects who is a biological child of a veteran with qualifying service may be eligible for a monetary allowance, health care, and vocational training. The 2014 report moved spina bifida to the lower category of "inadequate or insufficient evidence to determine an association," as studies that have been released since the 1996 update do not support a link between the condition and exposure to herbicides. According to VA officials, VA does not currently plan to change its regulations based on this conclusion. Appendix III: Quantities of Herbicides Known to Have Been Shipped to Southeast Asia on Ships Identified as Having Stopped in Guam between February 1968 and May 1970 Based on available shipment documentation and logbooks, we identified one vessel—the SS Gulf Shipper—carrying Agents Orange, Blue, and White that stopped at Port Apra (now Apra Harbor) on Guam on its way to Southeast Asia. Additionally, we identified three vessels—the SS Aimee Lykes, the SS Buckeye Atlantic, and the SS Overseas Suzanne—that stopped in Guam on the return routes after having made various port calls in Southeast Asia. For each of these voyages, we obtained shipment documentation that outlined the quantities of herbicides that records indicate had been loaded onto the vessels while at port in the United States, and to the extent available, quantities of herbicides that were discharged in Southeast Asia. We also obtained logbooks that identified the routes the vessels took from U.S. ports to Vietnam and back, and identified any port calls en route. While we are unable to confirm the reliability of the information available in shipment documentation and logbooks, details on the quantities of herbicides that were documented to have been transported on these vessels during their routes are outlined below. SS Gulf Shipper: According to shipment documentation and the vessel’s logbook, the SS Gulf Shipper left the port of Mobile, Alabama, on January 9, 1968, and stopped at Port Apra (now Apra Harbor) on Guam and offloaded a mariner for repatriation to the United States on February 2, 1968. We are unable to state with certainty whether there were reasons why this vessel stopped in Guam beyond what was reported in available shipment documentation and the vessel’s logbook. The logbook further indicates that the SS Gulf Shipper then arrived in Saigon, Vietnam, approximately February 27, 1968, with subsequent stops in Cam Rahn Bay, Vietnam, approximately February 29, 1968, and Nha Trang, Vietnam, approximately March 2, 1968. According to available documentation, there is some discrepancy with regard to the amount of herbicides that records indicate were loaded onto the SS Gulf Shipper when it left the port of Mobile, Alabama. Specifically, shipment documentation indicates that 62,570 gallons of Agent Orange, 31,735 gallons of Agent White, and 4,620 gallons of Agent Blue—a total of 98,925 gallons of herbicides—were loaded onto the SS Gulf Shipper before it departed for Saigon, Vietnam. On the contrary, according to the available shipping documentation, the vessel’s manifest indicates that the vessel was carrying 86,270 gallons of herbicides, but does not break the total down by individual herbicide. The vessel’s manifest further indicates that the SS Gulf Shipper discharged 93,150 gallons of herbicide in Saigon, Vietnam, on March 1, 1968, which does not align with reported dates in the vessel’s logbook. However, we are unable to determine discharge quantities by specific herbicide—for example, the quantities of Agents Orange, Blue, or White discharged—because available documentation states that the breakdown of the herbicides would not be determined until arrival at the depot. Moreover, we are unable to account for the difference between the number of gallons of herbicides reported to have been loaded onto the vessel and the number of gallons reported to have been discharged in Saigon, Vietnam, or potentially any other location. SS Aimee Lykes: According to shipment documentation and the vessel’s logbook, the SS Aimee Lykes left the port of Beaumont, Texas, on October 4, 1969. The vessel arrived in Saigon, Vietnam, approximately November 9, 1969. The vessel made a subsequent stop at Da Nang, Vietnam, approximately November 23, 1969. Following its departure from Vietnam, the SS Aimee Lykes stopped in Apra Harbor on Guam approximately November 30, 1969, and offloaded an injured crew member. However, the logbook does not include Guam on its list of ports of call. Rather, there is a separate entry within the logbook that describes the vessel pulling into Apra Harbor and offloading the injured mariner into a small motorboat so that he could be hospitalized in Guam. Therefore, we cannot confirm whether the vessel docked at Port Apra during this voyage. According to available documentation, the SS Aimee Lykes left the port of Beaumont, Texas, with 880 gallons of Agent Orange on board—documentation does not indicate that there were any amounts of Agents White or Blue on this voyage. Based on the available documentation, we are unable to determine the quantity of Agent Orange that was discharged in Saigon, Vietnam, or potentially any other location. SS Buckeye Atlantic: According to shipment documentation and the vessel’s logbook, the SS Buckeye Atlantic left the port of New Orleans, Louisiana, on October 1, 1969. The vessel arrived in Saigon, Vietnam, approximately November 20, 1969. The vessel made a subsequent stop at Qui Nhon, Vietnam, approximately November 29, 1969. Following its departure from Vietnam, the SS Buckeye Atlantic stopped at various ports in Japan before stopping in Guam approximately December 23, 1969, and offloading two injured crew members, one who returned to duty and another who was repatriated to the United States. While on Guam, the SS Buckeye Atlantic also performed a fire and boat drill on December 26, 1969, before departing. According to available documentation, the SS Buckeye Atlantic left the port of New Orleans, Louisiana, with 17,105 gallons of Agent Orange on board. Based on the available documentation, we are unable to determine the quantity of Agent Orange that was discharged in Saigon, Vietnam, or potentially any other location. SS Overseas Suzanne: According to shipment documentation and the vessel’s logbook, the SS Overseas Suzanne left the port of New Orleans, Louisiana, on February 28, 1970. The vessel arrived in Saigon, Vietnam, approximately April 9, 1970. The vessel made a subsequent stop at Da Nang, Vietnam, approximately April 17, 1970, and at Cam Rahn Bay, Vietnam, approximately April 22, 1970. Following its departure from Vietnam, the SS Overseas Suzanne stopped in Taiwan and Japan before stopping in Guam approximately May 5, 1970, and offloading an injured crew member. The vessel then departed Guam on May 9, 1970. According to available documentation, the SS Overseas Suzanne left the port of New Orleans, Louisiana, with 80,795 gallons of Agent Orange and 48,537 gallons of Agent Blue on board. Based on the available documentation, we are unable to determine the quantity of Agent Orange that was discharged in Saigon, Vietnam, or potentially any other location. Appendix IV: The Department of Defense’s (DOD) List of Testing and Storage Locations Posted on the Department of Veterans Affairs (VA) Website Appendix V: Comments from the Department of Defense Appendix VI: Comments from the Department of Veterans Affairs Appendix VII: Comments from the U.S. Department of Agriculture Appendix VIII: GAO Contacts and Staff Acknowledgments GAO Contacts Staff Acknowledgments In addition to the contacts named above, Kristy Williams and Barbara Patterson (Assistant Directors), Karyn Angulo, Emil Friberg, Ashley Grant, Karen Howard, Kelly Husted, Richard Johnson, Amie Lesser, Keegan Maguigan, Jeff Mayhew, Dennis Mayo, Parke Nicholson, Shahrzad Nikoo, Josie Ostrander, Rebecca Parkhurst, Michael Silver, Anne Stevens, Rachel Stoiko, Roger Stoltz, and Cheryl Weissman made key contributions to this report. Related GAO Products Agent Orange: Limited Information Is Available on the Number of Civilians Exposed in Vietnam and Their Workers’ Compensation Claims. GAO-05-371. Washington, D.C.: Apr. 22, 2005. Agent Orange: Persisting Problems with Communication of Ranch Hand Study Data and Results. GAO/T-NSIAD-00-117. Washington, D.C.: Mar. 15, 2000. Agent Orange: Actions Needed to Improve Communications of Air Force Ranch Hand Study Data and Results. GAO/NSIAD-00-31. Washington, D.C.: Dec. 17, 1999. Agent Orange Studies: Poor Contracting Practices at Centers for Disease Control Increased Costs. GAO/GGD-90-122BR. Washington, D.C.: Sept. 28, 1990. Agent Orange: VA Needs To Further Improve Its Examination and Registry Program. GAO/HRD-86-7. Washington, D.C.: Jan. 14, 1986. VA’s Agent Orange Examination Program: Actions Needed To More Effectively Address Veterans’ Health Concerns. GAO/HRD-83-6. Washington, D.C.: Oct. 25, 1982.
target: The tactical herbicide Agent Orange was first produced in 1964, and some 12 million gallons were shipped from U.S. ports to Southeast Asia from 1965 to 1970. DOD suspended its use in 1970 and incinerated remaining stockpiles at sea in 1977. Congress has expressed long-standing interest in the effects of Agent Orange exposure. The House report accompanying a bill for the National Defense Authorization Act for Fiscal Year 2018 included a provision that GAO review the government's handling of Agent Orange on Guam. This report examines (1) information the federal government has about the procurement, distribution, use, and disposition of Agent Orange; (2) DOD and VA efforts to make information about where Agent Orange and its components were tested and stored available; and (3) challenges associated with Agent Orange testing. GAO reviewed agency policies, documents, and available archival records that GAO identified; interviewed DOD, VA, and other agency officials; and met with a non-generalizable sample of 38 veterans and a veterans service organization. Available shipment documentation indicates that nearly all of the Agent Orange procured was either used in U.S. military operations in Southeast Asia, used for testing, damaged, or destroyed. However, some records are incomplete, such as shipment documentation and logbooks that identify ports where vessels stopped on the way to Southeast Asia. GAO obtained and reviewed shipment documentation for over 12.1 million of the 13.9 million gallons of Agent Orange procured by the Department of Defense (DOD). GAO reviewed logbooks for 96 percent (152 of 158) of those shipments and identified that vessels stopped at various ports on the way to Southeast Asia, including at least one vessel carrying Agent Orange that stopped at Guam. While the logbooks GAO reviewed identify when vessels left various ports as they traveled to and from Vietnam, they do not show whether and how much cargo was loaded or unloaded at those ports. DOD's official list of herbicide testing and storage locations outside of Vietnam that is posted on the Department of Veterans Affairs' (VA) website is inaccurate and incomplete. For example, the list lacks clarity in descriptive information and omits both testing and storage locations and additional time periods covered by testing events. Also, the list has not been updated in over a decade, though DOD and VA have obtained reports on its shortcomings since 2006. Both DOD and VA communicate with veterans in response to inquiries about Agent Orange, but some veterans GAO met with expressed confusion regarding how to obtain information on potential exposure. DOD officials acknowledged this confusion and stated that veterans are contacting multiple agencies to obtain such information. However, DOD and VA have not established a formal process for coordinating on how best to communicate information to veterans and the public regarding the presence of Agent Orange outside of Vietnam. Without a reliable list with complete and accurate information and a formal process for DOD and VA to coordinate on communicating this information, veterans and the public do not have quality information about the full extent of locations where Agent Orange was present and where exposure could potentially have occurred. Challenges exist with testing for Agent Orange today due to degradation of the herbicide's two chemical components and a potential for sources of contamination other than the herbicide. According to scientific research, the half-life (average time for components to decrease by half of the original amount) of Agent Orange's two chemical components—n-butyl 2,4-D and n-butyl 2,4,5-T— in soil can range from several days to many months, depending on conditions. The suggested half-life of the dioxin 2,3,7,8-TCDD—a by-product of the 2,4,5-T manufacturing process—is much longer, but there are multiple sources of dioxins, including the burning of wood and waste. DOD and the U.S. and Guam Environmental Protection Agencies are testing for the acid form of the components of Agent Orange at Andersen Air Force Base on Guam. While acknowledging the low probability of conclusively identifying the components of Agent Orange on Guam, DOD has made a decision to move forward with testing to address veterans' and the public's concerns, and it expects to complete the updates for the sampling and analysis plan, field sampling, analysis, and reporting in early 2019.