DOD’s Decision to Stop Actively Searching for Project 112 Individuals Was Not Based on a Sound and Documented Cost-Benefit Analysis

In June 2003, after having identified several thousand servicemembers and  hundreds of civilians as having been potentially exposed to chemical or  biological substances during Project 112, DOD stopped actively searching  for additional individuals. However, we found that DOD had not exhausted  all possibilities for identifying additional servicemembers and civilian  personnel who had been potentially exposed. Therefore, we recommended  that DOD determine the feasibility of addressing these unresolved issues. In response to our recommendation, DOD determined continuing an active  search for individuals had reached the point of diminishing returns, and  reaffirmed its decision to cease active searches. This decision was not  supported by any objective analysis of the potential costs and benefits of  continuing the effort. DOD’s Effort to Identify Individuals Potentially Exposed during Non-Project 112 Tests Has Several Shortcomings

Although DOD has taken action to identify individuals who were  potentially exposed during chemical or biological tests outside of Project  112, we identified several shortcomings in the current effort. Second, the scope of DOD’s current effort is unclear. DOD’s Current Effort Lacks Transparency

DOD’s current effort lacks transparency since it has not worked with  veterans, and it has not kept Congress and veterans service organizations  fully informed about the status of its efforts. DOD and VA Have Had Limited Success in Notifying Potentially Exposed Individuals

DOD and VA have had limited success in notifying individuals who were  potentially exposed to chemical and biological substances during Project  112 tests or testing that occurred outside of Project 112 due to several  factors. First, DOD has inconsistently transmitted information about  identified servicemembers to VA. Second, VA has not used all available  resources to obtain contact information for servicemembers who were  identified as having been potentially exposed. DOD Has Not Notified Civilians Due in Part to a Lack of Specific Guidance

DOD has not taken any actions to notify civilians who have been identified  as having been potentially exposed during Project 112 tests and other  chemical and biological tests, due in part to a lack of specific guidance  defining the requirements to notify civilians. During our review, DOD and Department  of Labor officials stated that they were unaware of a requirement for them  to notify civilians of their potential exposure. Conclusions

Since World War II, potentially tens of thousands of military personnel and  civilians have been exposed to chemical or biological substances during  previously classified DOD tests. While DOD has concluded that continuing an active  search for individuals potentially exposed during Project 112 has reached  a point of diminishing returns, it has not conducted an informed cost- benefit analysis, which could guide DOD in identifying the extent to which  it might need to take additional actions. Furthermore, until DOD  conducts such an analysis, Congress, veterans, and the public may  continue to question the completeness and accuracy of DOD’s efforts. To ensure that DOD’s current effort to identify individuals who were  potentially exposed during chemical and biological tests outside of Project  112 are more efficient, effective, and transparent, and to ensure that its  databases contain accurate information, we recommend that the Secretary  of Defense direct the Office of Under Secretary of Defense for Acquisition,  Technology, and Logistics to take the following four actions:  in coordination with the Office of the Under Secretary of Defense for  Personnel and Readiness and the Secretary of Veterans Affairs, modify  the guidance about the scope of work for its current effort, such as the  statement of work and concept of operations plan, to clearly define  consistent, reasonable, and acceptable goals and objectives, and the  type and amount of information that will need to be collected to meet  these goals and objectives;  implement effective internal controls and oversight practices, such as  periodic site visits, regular assessments of the contactor’s efforts, and  quality assurance reviews of the information provided by the  contractor;    coordinate and communicate with other entities that previously  identified exposed individuals to leverage existing information,  including institutional knowledge and documents; and    make its efforts transparent with regular updates to Congress, the  public, and veterans service organizations. The Department of Labor did not provide us any comments. In light of the increasing  number of individuals who have been identified since DOD provided its  report to Congress in 2003 and ceased its active search for additional  individuals, until the department provides a more substantive analysis that  supports its decision to cease active searches for additional individuals  potentially exposed during Project 112 tests, Congress and veterans may  continue to question the completeness and level of commitment to this  effort.
Why GAO Did This Study

Tens of thousands of military personnel and civilians were potentially exposed to chemical or biological substances through Department of Defense (DOD) tests since World War II. DOD conducted some of these tests as part of its Project 112 test program, while others were conducted as separate efforts. GAO was asked to (1) assess DOD's efforts to identify individuals who were potentially exposed during Project 112 tests, (2) evaluate DOD's current effort to identify individuals who were potentially exposed during tests conducted outside of Project 112, and (3) determine the extent to which DOD and the Department of Veterans Affairs (VA) have taken action to notify individuals who might have been exposed during chemical and biological tests. GAO analyzed documents and interviewed officials from DOD, VA, the Department of Labor, and a veterans service organization.

What GAO Found

Since 2003, DOD has stopped actively searching for individuals who were potentially exposed to chemical or biological substances during Project 112 tests, but did not provide a sound and documented basis for that decision. In 2003, DOD reported it had identified 5,842 servicemembers and estimated 350 civilians as having been potentially exposed during Project 112, and indicated that DOD would cease actively searching for additional individuals. However, in 2004, GAO reported that DOD did not exhaust all possible sources of information and recommended that DOD determine the feasibility of identifying additional individuals. In response to GAO's recommendation, DOD determined continuing an active search for individuals had reached the point of diminishing returns, and reaffirmed its decision to cease active searches. This decision was not supported by an objective analysis of the potential costs and benefits of continuing the effort, nor could DOD provide any documented criteria from which it made its determination. Since June 2003, however, non-DOD sources--including the Institute of Medicine--have identified approximately 600 additional names of individuals who were potentially exposed during Project 112. Until DOD provides a more objective analysis of the costs and benefits of actively searching for Project 112 participants, DOD's efforts may continue to be questioned. DOD has taken action to identify individuals who were potentially exposed during tests outside of Project 112, but GAO identified four shortcomings in DOD's current effort. First, DOD's effort lacks clear and consistent objectives, scope of work, and information needs that would set the parameters for its efforts. Second, DOD has not provided adequate oversight to guide this effort. Third, DOD has not fully leveraged information obtained from previous research efforts that identified exposed individuals. Fourth, DOD's effort lacks transparency since it has not kept Congress and veterans service organizations fully informed of the progress and results of its efforts. Until DOD addresses these limitations, Congress, veterans, and the American public can not be assured that DOD's current effort is reasonable and effective. DOD and VA have had limited success in notifying individuals potentially exposed during tests both within and outside Project 112. DOD has a process to share the names of identified servicemembers with VA; however, DOD has delayed regular updates to VA because of a number of factors, such as competing priorities. Furthermore, although VA has a process for notifying potentially exposed veterans, it was not using certain available resources to obtain contact information to notify veterans or to help determine whether they were deceased. Moreover, DOD had not taken any action with the civilian names, focusing instead on veterans since the primary impetus for the research has been requests from VA. DOD has refrained from taking action on civilians in part because it lacks specific guidance that defines the requirements to notify civilians. Until these issues are addressed, some identified veterans and civilians will remain unaware of their potential exposure.