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Testimony:

Before the Subcommittee on National Security, Emerging Threats, and 
International Relations, Committee on Government Reform, House of 
Representatives:

United States General Accounting Office:

GAO:

For Release on Delivery Expected at 1:00 p.m. EDT:

Tuesday, June 1, 2004:

Gulf War Illnesses:

DOD's Conclusions About U.S. Troops' Exposure Cannot Be Adequately 
Supported:

Statement of Keith Rhodes, Chief Technologist 
Center for Technology and Engineering, Applied Research and Methods:

GAO-04-821T:

GAO Highlights:

Highlights of GAO-04-821T, a report to Subcommittee on National 
Security, Emerging Threats, and International Relations, Committee on 
Government Reform, House of Representatives 

Why GAO Did This Study:

Since the end of the Gulf War in 1991, many of the approximately 
700,000 U.S. veterans have experienced undiagnosed illnesses. They 
attribute these illnesses to exposure to chemical warfare (CW) agents 
in plumes—clouds released from bombing of Iraqi sites. But in 2000, the 
Department of Defense (DOD) estimated that of the 700,000 veterans,
101,752 troops were potentially exposed. GAO was asked to evaluate the 
validity of DOD, the Department of Veterans Affairs (VA), and British 
Ministry of Defense (MOD) conclusions about troops’ exposure. 

This testimony summarizes a report GAO is issuing today.

What GAO Found:

DOD’s and MOD’s conclusion about troops’ exposure to CW agents, based 
on DOD and CIA plume modeling, cannot be adequately supported. The 
models were not fully developed for analyzing long-range dispersion of 
CW agents as an environmental hazard. The modeling assumptions as to 
source term data—quantity and purity of the agent—were inaccurate 
because they were uncertain, incomplete, and nonvalidated.

The plume heights used in the modeling were underestimated and so were 
the hazard area. Postwar field testing used to estimate the source term 
did not realistically simulate the actual conditions of bombings or 
demolitions. Finally, the results of all models—DOD and non-DOD models—
showed wide divergences as to the plume size and path. 

DOD’s and VA’s conclusion about no association between exposure to CW 
agents and rates of hospitalization and mortality, based on two 
epidemiological studies conducted and funded by DOD and VA, also cannot 
be adequately supported because of study weaknesses. In both studies, 
flawed criteria—DOD’s plume model and DOD’s estimation of potentially 
exposed troops based on this model—were used to determine exposure. 
This may have resulted in large-scale misclassification. 

Troops under the path of the plume were classified as exposed; those 
not under the path, as nonexposed. But troops classified as not exposed 
under one DOD model could be classified as exposed under another DOD 
model. Under non-DOD models, however, a larger number of troops could 
be classified as exposed. Finally, as an outcome measure, 
hospitalization rate failed to capture the types of chronic illnesses 
that Gulf War veterans report but that typically do not lead to 
hospitalization.

What GAO Recommends:

GAO is recommending that the Secretary of Defense and the Secretary of 
Veterans Affairs not use the plume-modeling data for any other 
epidemiological studies of the 1991 Gulf War. VA concurred with our 
recommendation. DOD did not concur but we have clarified the 
recommendation to address DOD’s concerns as we understand them. GAO 
also recommends that the Secretary of Defense require no additional 
plume modeling of Khamisiyah and other sites. DOD concurred with our 
recommendation. 

The Central Intelligence Agency (CIA) did not concur with our report, 
stating it could not review the draft report in the time allotted.

www.gao.gov/cgi-bin/getrpt?GAO-04-821T.

To view the full product, including the scope and methodology, click on 
the link above. For more information, contact Keith Rhodes at (202) 
512-6412 or rhodesk@gao.gov.

[End of section]

June 1, 2004:

Mr. Chairman and Members of the Subcommittee:

We are pleased to participate in this international hearing by 
presenting our assessment of the plume modeling, conducted by the 
Department of Defense (DOD) and the Central Intelligence Agency (CIA), 
to determine the number of U.S. troops that might have been exposed to 
the release of chemical warfare agents during the Gulf War in 1990. We 
presented our preliminary results to you in our testimony on June 2, 
2003.[Footnote 1] My statement today is based on our final report, 
entitled Gulf War Illnesses: DOD's Conclusions about U.S. Troops' 
Exposure Are Unsupported, which is being issued today.[Footnote 2]

As you know, many of the approximately 700,000 veterans of the Persian 
Gulf War have experienced undiagnosed illnesses since the war's end in 
1991. Some fear they are suffering from chronic disabling conditions 
because of wartime exposures to vaccines, as well as chemical warfare 
agents, pesticides, and other hazardous substances with known or 
suspected adverse health effects. When the issue of the possible 
exposure of troops to low levels of chemical warfare agents was first 
raised, during the summer of 1993, DOD and the CIA concluded that no 
U.S. troops were exposed because (1) there were no forward-deployed 
Iraqi chemical warfare agent munitions and (2) the plumes--clouds of 
chemical warfare agents--from the bombing that destroyed the Iraqi 
chemical facilities could not have reached the troops.

This position was maintained until 1996, when DOD publicly disclosed 
that U.S. troops destroyed a stockpile of chemical warfare agent 
munitions after the Gulf War in 1991, at a forward-deployed site, 
Khamisiyah, in Iraq. Consequently, DOD and the CIA conducted several 
analyses using computer modeling, in an effort to estimate the number 
of troops that might have been exposed to chemical warfare agents. 
Recognizing that actual data on the source term--such as the quantity 
and purity (concentration) of the agent--and the meteorological 
conditions--such as the wind and the weather patterns--were not 
available,[Footnote 3] in 1996 and 1997, DOD and the CIA conducted 
field-testing and modeling of the demolition of Khamisiyah, to 
determine the size and path of the plume, as well as the number of U.S. 
troops exposed to chemical warfare agents within the area of the 
modeled plume's path. During these initial modeling efforts, DOD also 
asked the Department of Energy's (DOE) Lawrence Livermore National 
Laboratories (LLNL) to conduct modeling. In 1997, DOD and the CIA also 
combined the results of five different meteorological and dispersion 
models into a composite simulation of the plume area. They conducted 
additional simulations, using meteorological and dispersal models, to 
estimate the path of exposure from plumes during the bombings of sites 
other than Khamisiyah--Al Muthanna, Muhammadiyat, and Ukhaydir. In 
2000, DOD revised its modeling estimates for the destruction of 
chemical warfare agents at Khamisiyah, and estimated that 101,752 U.S. 
troops had potentially been exposed.

In response to your request, we evaluated how well conclusions--about 
the extent of exposure of U.S. troops and the association between CW 
exposure and troops' hospitalization and mortality rates--are supported 
by available evidence. Specifically, we have assessed the following:

1. How valid is the DOD and MOD conclusion---based on CIA and DOD 
plume-modeling results--about U.S. and British troops' exposure to CW 
agents?

2. What were the costs for the CIA's and DOD's various plume modeling 
efforts?

3. How valid are the DOD and Department of Veterans Affairs (VA) 
conclusions from epidemiological studies, based on DOD's plume modeling 
results, that there was no association between CW exposure at 
Khamisiyah and the troops' hospitalization and mortality rates?

Scope and Methodology:

To determine the validity of DOD's conclusion--that U.S. troops' 
exposures to chemical warfare agents were as DOD estimates suggested--
based on its plume-modeling analysis, we examined the meteorological 
and dispersion models DOD used to model chemical warfare agent releases 
from the U.S. demolition of Khamisiyah and Coalition bombings of Al 
Muthanna, Muhammadiyat, and other sites in Iraq during the Gulf War 
deployment period. We evaluated the basis for the technical and 
operational assumptions DOD made in (1) conducting the modeling for the 
bombing and demolition of Iraqi sites and (2) estimating the specific 
data and information used in the modeling, relating to source term, 
meteorological conditions, and other key parameters. We also evaluated 
the efforts of the CIA and DOD to collect and develop data on source 
term and other key parameters used in the modeling efforts.

We interviewed DOD and CIA modelers and officials involved with the 
modeling and obtained documents and reports from DOD's Deployment 
Health Support Directorate. We also interviewed and received documents 
from DOE officials who were involved with the modeling at LLNL. In 
addition, we interviewed officials and obtained documents from the 
Institute for Defense Analyses (IDA) concerning the IDA expert panel 
assessment of CIA's modeling of Khamisiyah. We also interviewed U.S. 
Army officials at Dugway Proving Ground, Utah, to determine how 
chemical warfare agents might have been released during the Khamisiyah 
pit area demolitions. Finally, we interviewed officials at the U.S. 
Army Center for Health Promotion and Preventive Medicine, to determine 
how specific troop unit exposures were identified, and officials of the 
United Nations Monitoring, Verification, and Inspection Commission 
(UNMOVIC), to obtain information on source term data from the United 
Nations Special Commission's (UNSCOM) analyses and inspections of the 
Khamisiyah, Al Muthanna, Muhammadiyat, and other sites.

To determine the validity of DOD's and the Department of Veterans 
Affairs' (VA) conclusions--based on epidemiological studies--that 
there was no association between Khamisiyah exposure and the rates of 
hospitalization or mortality, we reviewed published epidemiological 
studies in which hospitalization and mortality among exposed and 
nonexposed U.S. troops were analyzed. We also interviewed the study 
authors and researchers and examined the Gulf War population databases 
provided to the researchers by DOD in support of these studies. We 
interviewed Veterans Benefits Administration officials and obtained 
documents and reports on their analyses of DOD's population databases. 
We did not examine whether plume modeling data were being used by VA to 
determine eligibility for treatment or compensation.

In an effort to identify the total costs associated with modeling and 
related analyses of chemical warfare agent releases during the Gulf 
War; we interviewed relevant officials and collected cost data from 
various DOD agencies and DOD contractors who supported the modeling 
efforts.

To determine the extent of British troops' exposure to chemical warfare 
agent-related releases during the Gulf War, we interviewed British 
Ministry of Defense (MOD) officials in London and at Porton Down, and 
reviewed U.K. Ministry of Defense reports concerning the potential 
effects of exposure to chemical warfare agent-related releases on 
British forces.

We conducted our work from May 2002 through May 2004 in accordance with 
generally accepted government auditing standards.

Results in Brief:

DOD and MOD's conclusions, based on DOD's plume-modeling efforts 
regarding the extent of U.S. and British troops' exposures to chemical 
warfare agents, cannot be adequately supported. Given the inherent 
weaknesses associated with the specific models DOD used and the lack of 
accurate and appropriate meteorological and source term data in support 
of DOD's analyses, we found five major reasons to question DOD and 
MOD's conclusions. First, the models were not fully developed for 
analyzing long-range dispersion of chemical warfare agents as an 
environmental hazard. Second, assumptions regarding source term data 
used in the modeling--such as the quantity and purity of the agent--
were inaccurate, since they were based on (1) uncertain and incomplete 
information and (2) data that were not validated. Third, the plume 
heights from the Gulf War bombings were underestimated in DOD's models. 
Fourth, postwar field testing at the U.S. Army Dugway Proving Ground, 
to estimate the source term data, did not reliably simulate the actual 
conditions of either the bombings or the demolition at Khamisiyah. 
Fifth, there is a wide divergence in results among the individual 
models DOD selected, as well as in the unselected DOD and non-DOD 
models, with regard to the size and path of the plume and the extent to 
which troops were exposed. Given these inherent weaknesses, DOD and MOD 
cannot know which troops were and which troops were not exposed.

The total costs for the various plume-modeling efforts to analyze the 
potential exposure of U.S. troops--from the demolition at Khamisiyah 
and the bombing of several other sites in Iraq--cannot be estimated. 
DOD organizations and other entities involved with the plume-modeling 
efforts could provide only direct costs (that is, contractors' costs), 
which totaled about $13.7 million. However, this amount does not 
include an estimate of the considerable indirect costs associated with 
the salaries of DOD, VA, and contractors' staff or costs of facilities, 
travel, and equipment. We requested, but DOD could not provide, this 
estimate. In addition, the CIA would not provide direct and indirect 
costs for Gulf War plume modeling because, in its view, our request 
constituted oversight of an intelligence matter, beyond the scope of 
GAO authority. The CIA's contractor, the Science Applications 
International Corporation (SAIC), also did not respond to our request 
for cost data.

DOD's and VA's conclusions--that there is no association between 
exposures to chemical warfare agents from demolitions at Khamisiyah and 
rates of hospitalization and mortality among U.S. troops--also cannot 
be adequately supported. DOD and VA based these conclusions on two 
government-funded epidemiological studies, one conducted by DOD 
researchers, the other by VA researchers.[Footnote 4] In each of these 
studies, flawed criteria were used to determine which troops were 
exposed. For example, in each study, the criteria used were based on 
(1) DOD plume modeling of exposures from postwar demolition of the 
Khamisiyah munitions depot and (2) DOD's estimates, using this 
modeling, of which troops were under the path of the plume. Troops 
under the path of the plume were classified as exposed, those not under 
the path as nonexposed. However, troops classified as nonexposed under 
one DOD model could be classified as exposed under another DOD model, 
thereby confounding the results. In the DOD models, a small area was 
identified as being under the path of the plume, resulting in a small 
number of troops identified as exposed. But in other modeling not 
selected for consideration, such as that performed at the LLNL, for 
example, a much larger, as well as different area, was identified as 
under the path of the plume, resulting in the potential classification 
of a larger number of troops as having been exposed. In addition, these 
exposed troops included different troops from those in the DOD models-
that is, troops classified as exposed in the DOD selected models would 
have been classified as nonexposed in the other models, even though the 
area of coverage was much greater.

These flaws may have resulted in large-scale misclassification of the 
exposure groups--that is, a number of exposed veterans may have been 
classified as nonexposed, and a number of nonexposed veterans may have 
been misclassified as exposed. In addition, in the hospitalization 
study, the outcome measure--number of hospitalizations--would not 
capture the chronic illnesses that Gulf War veterans commonly report, 
but which typically do not lead to hospitalization. Several published 
scientific studies of exposure involving Gulf War suggest an 
association between low-level exposure to chemical warfare agents and 
chronic illnesses.

In our report, we are recommending that the Secretary of Defense and 
the Secretary of Veterans Affairs not use the plume-modeling data for 
future epidemiological studies of the 1991 Gulf War, since VA and DOD 
cannot know from the flawed plume modeling who was and who was not 
exposed.

We are also recommending that the Secretary of Defense require no 
further plume-modeling of Khamisiyah and the other sites bombed during 
the 1991 Gulf War in order to determine troops' exposure. Given the 
uncertainties in the source term and meteorological data, additional 
modeling of the various sites bombed would most likely result in 
additional costs, while still not providing any definitive data on who 
was or was not exposed.

We obtained comments our draft of this report from VA, DOD, and CIA. VA 
concurred with recommendation that VA and DOD not use the plume-
modeling data for future epidemiological studies, since VA and DOD 
cannot know from the flawed plume modeling who was and who was not 
exposed. DOD did not concur with the recommendation, indicating that to 
them it called for a blanket prohibition of plume modeling in the 
future. The intent of our recommendation is only directed at 
epidemiological studies involving the DOD and CIA plume modeling data 
from the 1991 Gulf War and not a blanket prohibition of plume modeling 
in future. We have clarified the recommendation along these lines. DOD 
concurred with our second recommendation, indicating that despite 
enhancements in the models, uncertainties will remain. CIA did not 
concur with our report, indicating that it could not complete its 
review in the time allotted.

Background:

According to the CIA, modeling is the art and science of using 
interconnected mathematical equations to predict the activities of an 
actual event. In this case, modeling was used to determine the 
direction and extent of the plume from chemical warfare agents. In 
environmental hazard modeling, simulations recreate or predict the size 
and path (that is, the direction) of the plume, including the potential 
hazard area, and potential exposure levels are generated.

Information for Modeling:

In addition to identifying the appropriate event to model, modeling 
requires several components of accurate information:

* the characteristics or properties of the material that was released 
and its rate of release (for example, quantity and purity; the vapor 
pressure; the temperature at which the material burns; particle size; 
and persistency and toxicity); temporal information (for example, 
whether chemical agent was initially released during daylight hours, 
when it might rapidly disperse into the surface air, or at night, when 
a different set of breakdown and dispersion characteristics would 
pertain, depending on terrain, plume height, and rate of agent 
degradation);

* data that drive meteorological models during the modeled period (for 
example, temperature, humidity, barometric pressure, dew point, wind 
velocity and direction at varying altitudes, and other related measures 
of weather conditions);

* data from global weather models, to simulate large-scale weather 
patterns, and from regional and local weather models, to simulate the 
weather in the area of the chemical agent release and throughout the 
area of dispersion; and:

* information on the potentially exposed populations, animals, crops, 
and other assets that may be affected by the agent's release.

Types of Models Used:

Various plumes during the 1991 Gulf War were estimated using global-
scale meteorological models, such as the National Centers for 
Environmental Prediction Global Data Assimilation System (GDAS) and the 
Naval Operational Global Atmospheric Prediction System (NOGAPS). 
Regional and local weather models were also used, including the Coupled 
Ocean-Atmosphere Mesoscale Prediction System (COAMPS), the Operational 
Multiscale Environmental Model with Grid Adaptivity (OMEGA), and the 
Mesoscale Model Version 5 (MM5).

Transport and diffusion models were also used during the 1991 Persian 
Gulf War plume simulation efforts.[Footnote 5] These models estimate 
both the path of a plume and the degree of potential hazard posed by 
the chemical warfare agents. Dispersion models used during the Gulf War 
included the Hazard Prediction and Assessment Capability (HPAC) along 
with its component, the Second-order Closure Integrated Puff (SCIPUFF) 
model; the Vapor, Liquid, and Solid Tracking (VLSTRACK) model; the Non-
Uniform Simple Surface Evaporation (NUSSE) model; and the Atmospheric 
Dispersion by Particle-in-Cell (ADPIC) model.

DOD's Conclusion about U.S. Troops' Exposure to Chemical Warfare Agents 
Cannot Be Adequately Supported:

DOD's conclusion about the extent of U.S. troops' exposure to chemical 
warfare agents during and immediately after the Gulf War, based upon 
DOD and CIA plume model estimates, cannot be adequately supported. This 
is because of uncertainty associated with the source term data and 
meteorological data. Further, the models themselves are neither 
sufficiently certain nor precise to draw reasonable conclusions about 
the size or path (that is, the direction) of the plumes.

In particular, we found five reasons to question DOD's conclusion. 
First, the models DOD and the CIA selected were in house models not 
fully developed for analyzing long-range dispersion of chemical warfare 
agents as environmental hazards. DOD and CIA officials selected several 
in-house models to run plume simulations. For Khamisiyah and the other 
Iraqi sites selected for examination, DOD selected the COAMPS and OMEGA 
meteorological models and the HPAC/SCIPUFF and VLSTRACK dispersion 
models. However, these models were not at the time fully developed for 
modeling long-range environmental hazards.

Second, the assumptions about the source term data used in the models 
are inaccurate. The source term data DOD used in the modeling for sites 
at Khamisiyah, as well as Al Muthanna and Muhammadiyat, contain 
significant unreliable assumptions. DOD and the CIA based assumptions 
on field testing, intelligence information, imagery, UNSCOM 
inspections, and Iraqi declarations to UNSCOM. However, these 
assumptions were based on limited, nonvalidated, and unconfirmed data 
concerning (1) the nature of the Khamisiyah pit demolition, (2) 
meteorology, (3) agent purity, (4) amount of agent released, and (5) 
other chemical warfare agent data. In addition, DOD and the CIA 
excluded from their modeling efforts many other sites and potential 
hazards associated with the destruction of binary chemical weapons, 
vast stores of chemical warfare agent precursor materials, and the 
potential release of toxic byproducts and chemical warfare agents from 
other sites.[Footnote 6]

Third, in most of the modeling performed, the plume heights were 
significantly underestimated. Actual plume height would have been 
significantly higher than the height DOD estimated in its modeling of 
demolition operations and bombings. The plume height estimates that the 
CIA provided for demolition operations at the Khamisiyah pit were 0 to 
100 meters. However, neither DOD nor the CIA conducted testing to 
support estimated plume height associated with the bombings of Al 
Muthanna, Muhammadiyat, or Ukhaydir. According to DOD modelers, neither 
plume height nor any other heat or blast effects associated with these 
bombings were calculated from the models; instead, these data were 
taken from DOD's Office of the Special Assistant for Gulf War 
Illnesses. In addition, according to a principal Defense Threat 
Reduction Agency modeler, DOD's data on plume height were inconsistent 
with other test data for the types of facilities bombed.

Fourth, postwar field testing at the U.S. Army Dugway Proving Ground, 
in Utah, to estimate the source term data did not realistically 
simulate the actual conditions of the demolition operations at 
Khamisiyah or the effects of the bombings at any of the other sites in 
Iraq. For field testing to be effective, conditions have to be as close 
to the actual event as possible, but these tests did not provide more 
definitive data for DOD and CIA's models. The tests did not 
realistically simulate the conditions of the demolition of 122 mm 
chemical-filled rockets in Khamisiyah. The simulations took place under 
conditions that were not comparable with those at Khamisiyah. There 
were differences in meteorological and soil conditions; the 
construction material of munitions crates; rocket construction 
(including the use of concrete-filled pipes as rocket replacements to 
provide inert filler to simulate larger stacks); and the number of 
rockets, with far fewer rockets and, therefore, less explosive 
materials. In addition, in the tests, the agent stimulant used had 
physical properties different from those of the actual agent.

Finally, there are wide divergences--with regard to the size and path 
of the plume and the extent to which troops were exposed--among the 
individual models DOD selected. The models DOD used to predict the 
fallout from Khamisiyah and the other sites showed great divergence, 
even with the same source term data. While the models' divergences 
included plume size and paths, DOD made no effort to reconcile them. 
The IDA expert panel observed that the results were so divergent that 
it would not be possible to choose the most exposed areas or which U.S. 
troops might potentially have been exposed. IDA therefore recommended a 
composite model, which DOD adopted.[Footnote 7] However, this approach 
only masked differences in individual model projections with respect to 
divergences in plume size and path. In addition, DOD chose not to 
include in the composite model the results of the LLNL simulation, 
performed at the IDA expert panel's request. The LLNL simulation 
estimated a larger plume size and different path from DOD's models. The 
IDA panel regarded the LLNL model as less capable than other models 
because it modeled atmospheric phenomena with less fidelity. A modeling 
simulation done by the Air Force Technical Applications Center (AFTAC) 
also showed significant divergences from DOD's composite model.

MOD Relied on U.S. Plume Modeling to Determine Their Troops' Exposure 
to Chemical Warfare Agents:

According to British officials, the MOD did not collect any source term 
or meteorological data during the 1991 Persian Gulf War. It also did 
not independently model the plume from Khamisiyah, relying instead on 
the 1997 DOD and CIA modeling of Khamisiyah. However, according to 
British MOD officials, they were reassessing the extent of British 
troops' exposure, based on DOD's revised 2000 remodeling of Khamisiyah. 
We requested from the British MOD, but did not receive, information on 
the findings from this reassessment.

The MOD also determined that a number of British troops were within the 
boundary of the plume in the DOD and CIA composite model. The MOD 
estimated that the total number of British troops potentially exposed 
was about 9,000 and the total number of troops as "definitely" within 
the path of the plume, however, was about 3,800. In addition, of 53,500 
British troops deployed, at least 44,000 were estimated as "definitely 
not" within the path of the plume. However, since the MOD relied 
exclusively on DOD's modeling and since we found that DOD could not 
know who was and who was not exposed, the MOD cannot know the extent of 
British troops' exposure.

Total U.S. Plume-Modeling Costs:

The DOD and CIA were the primary agencies involved in the modeling and 
analysis of U.S. troops' exposure from the demolition at Khamisiyah and 
bombing of chemical facilities at Al Muthanna, Muhammadiyat, and 
Ukhaydir, but several other agencies and contractors also participated. 
Funding to support the modeling efforts was provided to various DOD 
agencies and organizations, the military services, and non-DOD agencies 
and contractors. We collected data on the direct costs these agencies 
incurred or funds they spent. As shown in table 1, direct costs to the 
United States for modeling the Gulf War were about $13.7 million.

Table 1: U.S. Direct Costs for Modeling Gulf War Illnesses:

Agency or contractor: BAHR Inc.; 
Direct costs[A]: $11,796; 
Work done: Reviewed (1) processes and technology used to produce 
estimates of U.S. forces potentially exposed and (2) draft reports on 
Khamisiyah.

Agency or contractor: Central Intelligence Agency; 
Direct costs[A]: [B]; 
Work done: Computer-modeling analysis.

Agency or contractor: Chemical Biological Defense Command, Aberdeen 
Proving Ground; 
Direct costs[A]: $140,000; 
Work done: Wood- surface evaporative modeling and environmental data 
support efforts.

Agency or contractor: Defense Threat Reduction Agency; 
Direct costs[A]: $870,000; 
Work done: Computer-modeling analyses with HPAC/ SCIPUFF dispersion and 
OMEGA weather models.

Agency or contractor: Institute for Defense Analyses; 
Direct costs[A]: $149,429; 
Work done: Convened a panel of experts to review Khamisiyah pit 
modeling analyses.

Agency or contractor: Lawrence Livermore National Laboratory; 
Direct costs[A]: $60,000; 
Work done: Computer-modeling analyses with ADPIC dispersion and MATHEW 
weather models.

Agency or contractor: National Center for Atmospheric Research; 
Direct costs[A]: $308,000; 
Work done: Computer-modeling simulations using MM5 weather model.

Agency or contractor: Naval Research Laboratory; 
Direct costs[A]: $1,090,000; 
Work done: Meteorological analysis to identify downwind hazard 
assessment with NOGAPS and COAMPS weather models..

Agency or contractor: Naval Surface Warfare Center; 
Direct costs[A]: $522,000; 
Work done: Computer-modeling analyses with VLSTRACK dispersion and 
COAMPS weather models.

Agency or contractor: Office of the Special Assistant to the Deputy 
Secretary of Defense for Gulf War Illnesses; 
Direct costs[A]: $7,980,000; 
Work done: Internal costs for producing case narratives for Al 
Muthanna, Khamisiyah, Muhammadiyat, and Ukhaydir.

Agency or contractor: Science Applications International Corporation; 
Direct costs[A]: [C]; 
Work done: Computer-modeling analysis.

Agency or contractor: U.S. Army Center for Health Promotion and 
Preventative Medicine; 
Direct costs[A]: $731,000; 
Work done: Exposure assessment and environmental modeling to determine 
U.S. troops' exposed to chemical releases from multiple incidents 
during the Gulf War.

Agency or contractor: U.S. Army Dugway Proving Ground; 
Direct costs[A]: $1,861,950; 
Work done: Field trials and laboratory testing using 122 mm chemical-
simulant filled rockets to develop source term data for modeling.

Agency or contractor: White Sands Missile Range; 
Direct costs[A]: $2,600; 
Work done: Missiles for testing at Dugway Proving Ground.

Agency or contractor: Total; 
Direct costs[A]: $13,726,775. 

Sources: Agency and contractor responses provided to GAO regarding 
their modeling and analysis costs.

[A] Direct costs for agencies includes funding for contracts provided 
by the Office of the Special Assistant to the Deputy Secretary of 
Defense for Gulf War Illnesses.

[B] The CIA denied our request for its costs for modeling chemical 
releases from Khamisiyah, as well as Al Muthanna, Muhammadiyat, and 
Ukhaydir.

[C] SAIC did not respond to our requests for information.

[End of table]

DOD's and VA's Epidemiology-Based Conclusions on Chemical Warfare 
Exposure and Rates for Hospitalization and Mortality Cannot Be 
Adequately Supported:

DOD and VA each funded an epidemiological study on chemical warfare 
agent exposure--DOD's on hospitalization rates and VA's on mortality 
rates. From the hospitalization study, conducted by DOD researchers, 
and the mortality study, conducted by VA researchers, on exposed and 
nonexposed troops, DOD concluded that there was no significant 
difference in the rates of hospitalization and VA concluded no 
significant difference in the rates of mortality. These conclusions, 
however, cannot be supported by the available evidence. These studies 
contained two inherent weaknesses: (1) flawed criteria for classifying 
exposure, resulting in classification bias, and (2) an insensitive 
outcome measure, resulting in outcome bias. In addition, in several 
other published studies of 1991 Persian Gulf War veterans, suggest an 
associations between chemical warfare exposure and illnesses and 
symptoms have been established.

DOD and VA Used Flawed Criteria for Determining Troops' Exposure:

In the two epidemiological studies, DOD and VA researchers used DOD's 
1997 plume model for determining which troops were under the path of 
the plume--who were estimated to be exposed--and which troops were not-
-those who were estimated to be nonexposed. However, this 
classification is flawed, given the inappropriate criteria for 
inclusion and exclusion.

In the hospitalization study, the DOD researchers included 349,291 Army 
troops "coded" as being in the Army on February 21, 1991. However, the 
researchers did not report cutoff dates for inclusion in the study--
that is, they did not indicate whether these troops were in the Persian 
Gulf between January 17, 1991, and March 13, 1991, the period during 
which the bombings and the Khamisiyah demolition took place. Although 
we requested this information, DOD researchers failed to provide it. 
Finally, the total number of 349,291 troops is misleading because many 
troops left the service soon after returning from the Persian Gulf and 
therefore would not have been hospitalized after the war in a military 
hospital--another criterion for inclusion in the study. Moreover, the 
researchers did not conduct any analyses to determine what number or 
percentage of those who left active duty were in the exposed or 
nonexposed group (including uncertain low-dose exposure or estimated 
subclinical exposure). Given all the methodological problems in this 
study, it is not possible to accurately estimate the total size or 
makeup of the exposed and nonexposed population that may have sought or 
may have been eligible for care leading to military hospitalization.

In the mortality study, the VA researchers included 621,902 Gulf War 
veterans who arrived in the Persian Gulf before March 1, 1991. Troops 
who left before January 17, 1991--the beginning of the bombing of Iraqi 
research, production, and storage facilities for chemical warfare 
agents--were included in the study. This group was not likely to have 
been exposed. Therefore, including them resulted in VA's overestimation 
of the nonexposed group.

Troops who came after March 1, 1991--the period during which Khamisiyah 
demolition took place--were excluded from the VA study. The Defense 
Manpower Data Center (DMDC) identified 696,000 troops deployed to the 
Persian Gulf, but the mortality study included only the 621,902 troops 
deployed there before March 1, 1991. This decision excluded more than 
74,000 troops, approximately 11 percent of the total deployed. In 
addition, 693 troops who were in the exposed group were excluded 
because identifying data, such as Social Security numbers, did not 
match the DMDC database. VA researchers did not conduct follow-up 
analysis to determine whether those who were excluded differed from 
those who were included in ways that would affect the classification.

DOD and VA Used an Insensitive Outcome Measure for Determining 
Hospitalization Rates:

Hospitalization rates--the outcome measure used in the hospitalization 
study--were insensitive because they failed to capture the chronic 
illnesses that 1991 Persian Gulf War veterans commonly report, but that 
typically do not lead to hospitalization. Studies that rely on this 
type of outcome as an end point are predetermined to overlook any 
association between exposure and illness.

Based on DOD's 1997 plume model, DOD's hospitalization study compared 
the rates for 1991 Persian Gulf War veterans who were exposed with the 
rates for those who were nonexposed. This study included 349,291 active 
duty Army troops who were deployed to the Persian Gulf. However, DOD 
researchers did not determine the resulting bias in their analyses, 
because they did not account for those who left the service.

The Institute of Medicine noted that the hospitalization study was 
limited to Army troops remaining on active duty and to events occurring 
in military hospitals. Conceivably, those who suffered from Gulf War-
related symptoms might leave active duty voluntarily or might take a 
medical discharge. Hospitalization for this group would be reflected in 
VA or private sector databases, but not in DOD databases. The health or 
other characteristics of active duty troops could differ from those of 
troops who left active duty and were treated in nonmilitary hospitals. 
Moreover, economic and other factors not related to health are likely 
to affect the use of nonmilitary hospitals and health care 
services.[Footnote 8]

This limiting of the study to troops remaining on active duty produced 
a type of selection bias known as the healthy warrior effect.[Footnote 
9] It strongly biased the study toward finding no excess 
hospitalization among the active duty Army troops compared with those 
who left the service after the war.

Some Studies Suggest an Association between Chemical Warfare Exposure 
and Gulf War Illnesses:

We found some studies that suggest an association between chemical 
warfare agent exposure and Gulf War illnesses. Each of these studies 
has both strengths and limitations.

Gulf War Veterans Studies:

In a privately funded study, Haley and colleagues reported an 
association between a syndromic case definition of Gulf War illnesses, 
developed to model the ill veterans' symptomatic complaints, with 
exposure to CW agents.[Footnote 10] In this study, the authors 
developed questionnaires on symptoms and environmental exposure 
identified in pilot studies of ill Gulf War veterans, similar to 
epidemic investigations by the Centers for Disease Control and 
Prevention (CDC).[Footnote 11] These questionnaires were given to 249 
troops from a U.S. Navy Mobile Construction Battalion that participated 
in the Gulf War. Factor analysis of the data on symptoms was used to 
derive a case definition identifying six syndrome factors.[Footnote 12] 
Three syndrome factor variants found to be the most significant were 
(1) impaired cognition, (2) confusion-ataxia, and (3) arthro-myo-
neuropathy.

Impaired cognition (syndrome 1) was associated with troops' having worn 
flea collars that contained chlorpyrifos.[Footnote 13] Confusion-
ataxia (syndrome 2), the most severe clinically, was associated with 
three risk factors.[Footnote 14] The first was likely CW exposure; the 
second was the geographic location near the Saudi-Kuwaiti border around 
the fourth day of the air war, conducted January 18-23, 1991, when 
Czech chemical detection units detected sarin and mustard in ambient 
air near the Saudi-Kuwaiti border; and the third was side effects 
experienced after taking pyridostigmine. There was also a significant 
synergistic association between likely exposure to CW agents and the 
number of side effects from pyridostigmine.[Footnote 15] Arthro-myo-
neuropathy (syndrome 3) was associated with the amount of exposure to 
95 percent DEET in ethanol insect repellent and with the number of side 
effects of pyridostigmine.[Footnote 16]

The inference that these risk-factor associations represent causal 
effects is supported by (1) the large, highly significant relative 
risks; (2) the dose-response effects; and (3) the synergistic effect of 
the risk factor associations with the syndromic case definition. Risk 
factors found not to be significantly associated with the case 
definition include environmental pesticides, pesticides in uniforms, 
antibiotic or antimalarial prophylaxis, multiple immunizations, smoke 
from oil well fires, fumes from jet fuel, fumes from burning jet fuel 
in tents, petroleum in drinking water, depleted uranium munitions, 
smoking, alcohol use, and combat exposure.

Another study of Gulf War veterans by Nisenbaum and colleagues, funded 
by CDC, examined the risk factors in 1,002 Air Force 
reservists.[Footnote 17] They found, first, that the case definition of 
Fukuda and colleagues of "multisymptom illness" was strongly associated 
with at least one of the three chronic symptom groups fatigue, mood/
cognition, and musculoskeletal pain. And, next, they found that 
reported exposure to CW agents was most strongly associated with the 
"severe illness" case definition of Fukuda and colleagues and less 
strongly associated with their "mild-moderate illness" case 
definition.[Footnote 18]

Both case definitions were less strongly associated with the use of 
insect repellent (p = 0.006), the use of pyridostigmine (p = 0.01), and 
having an injury requiring medical attention (p = 0.03). But neither 
case definition was associated with smoke from oil well fires, coming 
under attack, seeing casualties, or having adverse health events in the 
family. The findings were attributed to the effects of stress but 
offered no empirical support for the explanation.

In a study that VA funded, Proctor and colleagues compared the exposure 
histories of 186 Gulf War veterans from Fort Devens, Massachusetts, and 
66 from New Orleans, including 48 who deployed only to Germany. 
Collectively, the 252 veterans are known as the Massachusetts-New 
Orleans cohort.[Footnote 19] The case definition was a set of eight 
body-system symptom scores (BSS, distributed from 0 to 4), each 
constructed by summing the 5-point frequency-of-occurrence scales (0 = 
occurs never, 4 = occurs almost every day) for three symptoms typical 
of a particular body system. The eight body systems were cardiac, 
dermatological, gastrointestinal, musculoskeletal, neurological, 
neuropsychological, psychological, and pulmonary. Post-traumatic 
stress disorder (PTSD) was diagnosed with the structural clinical 
interviews, Clinician Administered Posttraumatic Stress (CAPS) 
disorder scale, or a Mississippi Scale score of >89. The symptoms were 
obtained from the 52-item Expanded Health Symptom Checklist, the 
exposure measures from an environmental exposure questionnaire and an 
Expanded Combat Exposure Scale (CES) questionnaire. Multiple regression 
analysis--controlling for age, sex, education, study site, Expanded CES 
score, and PTSD status--was used to develop a risk-factor model for 
each BSS scale.

Exposure to CW agents and debris from SCUD missiles was associated with 
four BSS scales; exposure to smoke from tent heaters, with three BSS 
scales; exposure to pesticides, vehicle exhaust, and burning human 
waste, with two BSS scales; the Expanded CES, with only one BSS scale; 
and exposure to pyridostigmine bromide (antinerve gas pills) and smoke 
from oil well fires, with no BSS scale. Controlling for depression 
scores and excluding veterans diagnosed with PTSD did not substantially 
affect the associations.

Three additional studies conducted with VA and DOD funding extended the 
risk-factor research for the Massachusetts-New Orleans cohort. The 
association of self-reported CW agent (nerve agent) exposure was tested 
with different formulations of the case definition. White and 
colleagues used psychological and neuropsychological tests to define 
illness. They found that exposure to CW agents was associated with 
abnormal measures of mood, memory, and attention or executive 
function.[Footnote 20] Associations remained significant after 
controlling for age, sex, race, years of education, repeated grade in 
school, head injury, medication use, diagnosis of current PTSD (by 
CAPS), diagnosis of current depression (by structural clinical 
interviews), active duty versus Reserve or Guard status, seeking 
disability rating, and Vietnam service.

Lindem and colleagues developed multiple regression models for 
neuropsychological test measures as case definitions of Gulf War 
illnesses.[Footnote 21] Chemical warfare agent exposure was found to be 
associated with attention and executive function (continuous 
performance test), delayed verbal recall (California Verbal Learning 
Test and Visual Reproduction Test), and confusion and fatigue (Profile 
of Mood States). These associations remained significant when 
controlling for age, education, and PTSD diagnosis (by CAPS).

Wolfe and colleagues, studying 945 troops from the Massachusetts-New 
Orleans cohort, found that the CDC case definition of multisymptom 
illness was most strongly associated with having smelled a chemical 
odor, having taken up to 21 antinerve gas pills, or having experienced 
up to 10 formal alerts for CW agent attack.[Footnote 22]

Kang and colleagues conducted a random sample mail survey that VA 
funded. Obtaining responses from 11,441 Gulf War veterans and 9,476 
nondeployed Gulf War era veterans, they developed a case definition by 
factor analysis of symptoms measured by their questionnaire.[Footnote 
23] The first three syndrome factors closely resembled those that Haley 
and others derived (noted earlier). Finding that syndrome 2 was unique 
to the sample that had been deployed in the Gulf War (found in the 
deployed, but not the nondeployed, sample) and that the component 
symptoms were neurological in character, the researchers termed their 
syndrome 2 a possible unique Gulf War neurological syndrome. Four 
symptoms--blurred vision, loss of balance or dizziness, tremor or 
shaking, and speech difficulties--were associated with syndrome 2 only 
in the deployed sample. Consequently, Kang and colleagues established 
their case definition as having all four of these symptoms. In the 
deployed sample, 277 met the case definition and 6,730 who had none of 
the four symptoms constituted the control group. Of a large number of 
risk factors analyzed, only nine were associated with the case 
definition, with an odds ratio greater than 3.0. Of these, perceived 
exposure to nerve agent had the strongest association (odds ratio 15.1, 
95 percent, CI 11.5-19.9, p < 0.000001). This finding--a neurological 
syndrome appearing as the second factor in a factor analysis and being 
the most strongly associated risk factor, 15 times more common in ill 
veterans meeting the case definition than in controls--closely 
parallels the findings of Haley and colleagues. The finding received 
little notice, however, because the VA-funded mail survey did not (1) 
provide the odds ratio values in the table reporting the risk factor 
analysis results and (2) describe the finding in the text or abstract 
of the paper. When we noticed the finding, we manually calculated the 
odds ratios from the raw data in the table.

Smith and colleagues showed that hospitalization rates for several ICD-
9 diagnoses were higher in veterans categorized in the Khamisiyah 2000 
plume than in those not in the plume, and the association for cardiac 
arrhythmias was statistically significant. However, this study suffers 
from the same deficiencies as the earlier study that we cited: use, 
inappropriately, of hospitalization outcome measures rather than 
measures of Gulf War illness, which usually do not result in 
hospitalization, and use of plume modeling based on flawed 
data.[Footnote 24]

The 2002 Kang and Bullman study has not been published in a peer-
reviewed journal and therefore should not have been included in a 
review of the scientific epidemiologic literature. The DOD studies were 
invalid for two reasons: (1) Hospitalization and mortality were 
inappropriate outcomes because they do not measure Gulf War illnesses, 
which often do not lead to hospitalization, and (2) The DOD studies, no 
matter how powerful their techniques, could not control for the 
selection bias that resulted from the disproportionate early discharge 
of the ill Gulf War veterans soon after the Gulf War. Including only 
DOD hospital records of service members remaining on active duty 
resulted in the exclusion of veterans who left service for poor health. 
No amount of sophisticated techniques can correct for this selection 
bias toward finding no difference.[Footnote 25]

Genetics Studies:

In one genetics study, Haley and colleagues found an association 
between the case definition of Gulf War illnesses in U.S. Gulf War 
veterans and low blood levels of the Q-type isoenzyme of the 
paraoxonase/arylesterase enzyme group (PON).[Footnote 26] The PON group 
of enzymes is a potentially important predisposing factor in Gulf War 
illnesses because one of its major functions in normal body physiology 
is to protect the nervous system from organophosphate chemical toxins, 
such as pesticides and nerve agents. This finding was remarkable 
because the only function of Q type of the PON enzyme group is to 
protect the nervous system from nerve agents sarin, soman, tabun, and 
VX. The R-type isoenzyme has as its main function protection from 
organophosphate pesticides, such as diazinon, malathion, and parathion. 
Thus, an association between Gulf War illnesses and blood levels of 
only the Q-type isoenzyme of PON points specifically to nerve agent 
exposure. In addition, the total PON level--that is, the sum of the Q 
and R isoenzyme levels--was not associated with the illnesses. And the 
genotype (QQ, QR, or RR) was only marginally associated with them, as 
expected, because the level of the Q-type isoenzyme is a more important 
determinant of susceptibility to nerve agents than the genotype.

In another genetics study, Mackness and colleagues reported lower blood 
levels of total PON in ill British Gulf War veterans than in civilian 
controls in a previously published study; however, they did not measure 
the blood levels of the Q and R isoenzymes of PON, needed for a 
definitive study of Haley's hypothesis.[Footnote 27] This finding could 
indicate that ill British Gulf War veterans represented a mixture of 
some with low Q-type PON and others with low R-type PON. In some 
veterans, the illness would be associated with exposure to nerve 
agents; in others, with exposure to pesticides. Alternatively, the 
difference in total PON levels may have resulted from differences in 
the assays or in the veterans, since (1) the enzyme assays in the 
controls were performed years before those for the ill veterans and (2) 
the controls were civilians studied in an entirely different setting.

In yet a third genetics study, Hotopf and colleagues reported results 
of tests for total PON levels in blood samples--obtained in a study by 
Unwin and colleagues--for four groups of British troops: (1) ill 
veterans of the Gulf War, (2) well veterans of the Gulf War, (3) ill 
nondeployed veterans of the Gulf War era, and (4) ill veterans of the 
Bosnian conflict.[Footnote 28] The case definition of illness was a 
score below 72.2 on the SF-36 Physical Status questionnaire. Again, the 
researchers did not measure the levels of the Q and R isoenzymes of 
PON, making the findings difficult to interpret. The researchers found 
a low mean level of total PON in both ill and well groups deployed to 
the Gulf War and higher levels in the Gulf War era and ill Bosnian 
groups.

The depressing of the total PON level, the researchers suggested, might 
be the result of some deployment-related exposures. However, instead of 
looking at exposure to CW agents, the researchers investigated the 
possible effect of multiple immunizations on total PON levels and found 
no evidence for it. An alternative explanation is that total PON level 
in both ill and well deployed veterans was the result of 
misclassification of veterans by the case definition. A score of 72.2 
on the SF-36 scale is not a very low score, particularly in ill Gulf 
War veterans, and it is a nonspecific measure of illness, given that a 
low score indicates illness from any cause.[Footnote 29] Consequently, 
many veterans ill from causes unrelated to the war would be 
misclassified as cases of Gulf War illness and, conversely, many ill 
from the war but with less disability would be misclassified as 
controls. This conclusion is supported by a nonsignificant trend 
showing that ill veterans who had been deployed to the Gulf War had a 
lower median total PON level than well veterans who had also been 
deployed to the Gulf War.

The many flaws of design and methodology in both British studies of PON 
levels do not contribute to an understanding of the PON hypothesis and 
leave the finding of Haley and colleagues in need of better 
replication.

Animal Studies:

A series of laboratory studies with animals have established the 
biological plausibility that brain cell damage results from low-level 
exposure to sarin. Husain and colleagues demonstrated in two studies at 
the Division of Pharmacology and Toxicology at the Defense Research and 
Development Establishment in Gwalior, India, that repetitive 
administration of low-dose sarin (approximately 0.25 LD50) daily for 10 
days caused delayed onset damage to neurons in the spinal cords and 
brains of mice exposed by inhalation and of hens exposed by 
subcutaneous injection.[Footnote 30]

Privately funded studies by Abou-Donia and colleagues demonstrated that 
combinations of organophosphates and similar cholinesterase-inhibiting 
chemicals in hens produce greater neurotoxic effect on brain and nerve 
tissue than any of the agents alone.[Footnote 31] Abou-Donia's 
subsequent work, funded by DOD, extended the findings to synergistic 
combinations involving sarin at moderate concentrations (0.5 
LD50).[Footnote 32] A similar study by Husain and Somani, also funded 
by DOD, on the delayed brain effects of low-dose sarin (0.05 LD50) in 
combination with pyridostigmine and exercise, confirmed these findings. 
In particular, it demonstrated that the neuronal damage from very low 
doses of sarin affected primarily the basal ganglia region of the brain 
(striatum).[Footnote 33]

A study by Henderson and colleagues, with DOD funding, found that 
repeated inhalation exposure to low-level sarin at subsymptomatic doses 
(0.1 LCt50) for 5 or 10 days, with or without heat stress, produced no 
immediate effects.[Footnote 34] But at 30 days after exposure to sarin, 
damage was produced to cholinergic receptors in several brain regions, 
including the basal ganglia. In the same study, Henderson and 
colleagues identified evidence of an autonomic nervous system injury 
affecting the function of T-cells in the immune system as 
well.[Footnote 35] In addition, chronic abnormalities of neuronal 
metabolism in the basal ganglia have been implicated in ill Gulf War 
veterans by several investigators through the use of magnetic resonance 
spectroscopy.[Footnote 36]

Two recent laboratory studies at the U.S. Army Medical Research 
Institute of Chemical Defense, Aberdeen Proving Ground, support the 
animal studies. Scremin and colleagues demonstrated that moderate doses 
of sarin (0.5 LD50) in combination with pyridostigmine bromide produced 
prolonged elevations in rats' cerebral blood flow but that neither 
agent alone had a prolonged effect on cerebral blood flow.[Footnote 37] 
A companion study, by Roberson and colleagues, demonstrated that 
repeated administration of sarin to guinea pigs in doses of 0.2 or 0.4 
LD50 produced no immediate ill effects on behavior, weight, body 
temperature, flinch threshold, or EEG brain wave activity. But at 100 
days postdosing, abnormal brain function was found, indicating 
neurochemical or pathological brain cell changes that affect 
behavior.[Footnote 38]

Conclusions:

In evaluating the plume models used, the results from the DOD and CIA 
modeling can never be definitive. Plume models can allow only estimates 
of what happens when chemical warfare agents are released in the 
environment. Such estimates are based on mathematical equations, which 
are used to predict an actual event--in this case, the direction and 
extent of the plume. However, in order to predict precisely what 
happens, one needs to have accurate data on relative to both source 
term and meteorological conditions. DOD had neither of these.

Given the unreliability of the input data, the lack of individual troop 
location information, and the widely divergent results of the 
simulations conducted based on varying models, DOD's analyses cannot 
adequately estimate the extent of U.S. troops' exposure to chemical 
warfare agents and other related releases. In particular, the models 
selected were not fully developed for projecting long-range 
environmental fallout, and the assumptions used to provide the source 
term data were inaccurate or flawed. Even when models with the same 
source term data were used, the results diverged. In addition, the 
models did not include many potential exposure events and exposures to 
some key materials--for example, binary chemical weapons, mustard agent 
combustion by-products, and chemical warfare agent precursor materials. 
It is likely that if models were more fully developed and more credible 
data for source term and meteorological conditions were included in 
them, particularly with respect to plume height as well as level and 
duration of exposure, the hazard area would be much larger and most 
likely would cover most of the areas where U.S. troops and Coalition 
forces were deployed. However, given the lack of verifiable data for 
analyses, it is unlikely that any further modeling efforts would be 
more accurate or helpful.

The results of DOD's modeling efforts were, nonetheless, used in 
epidemiological studies to determine the troops' chemical warfare agent 
exposure classification--i.e., exposed versus nonexposed. As we noted 
in 1997, to ascertain the causes of veterans' illnesses, it is 
imperative that investigators have valid and reliable data on exposure, 
especially for low-level or intermittent exposures to chemical warfare 
agents.[Footnote 39] To the extent that veterans are misclassified as 
to exposure, relationships will be obscured and conclusions misleading. 
In addition, DOD combined the results of individual models that showed 
smaller plume size and ignored the results of the LLNL which showed 
much larger plume size and divergent plume path. Given the 
uncertainties in source term data and divergences in model results, DOD 
cannot determine or estimate--with any degree of certainty--the size 
and path of the plumes or who was or who was not exposed.

Recommendations for Executive Action:

In our report, we are recommending that the Secretary of Defense and 
the Secretary of Veterans Affairs not use the plume-modeling data for 
future epidemiological studies of the 1991 Gulf War, since VA and DOD 
cannot know from the flawed plume modeling who was and who was not 
exposed.

We are also recommending that the Secretary of Defense require no 
further plume-modeling of Khamisiyah and the other sites bombed during 
the 1991 Persian Gulf War in order to determine troops' exposure. Given 
the uncertainties in the source term and meteorological data, 
additional modeling of the various sites bombed would most likely 
result in additional cost, while still not providing DOD with any 
definitive data on estimating who was or was not exposed.

We obtained comments on a draft of this report from VA, DOD, and CIA. 
VA concurred with the recommendation that VA and DOD not use the plume-
modeling data for future epidemiological studies, since VA and DOD 
cannot know from the flawed plume modeling who was and who was not 
exposed. DOD did not concur with the recommendation, indicating that to 
them it called for a blanket prohibition of plume modeling in the 
future, where the limitations of the 1991 Gulf War may not apply. The 
intent of our recommendation is only directed at epidemiological 
studies involving the DOD and CIA plume modeling data from the 1991 
Gulf War and not a blanket prohibition of plume modeling in the future. 
We have clarified the recommendation along these lines. DOD concurred 
with our second recommendation, indicating that despite enhancements in 
the models, uncertainties will remain. CIA did not concur with our 
report, indicating that it could not complete its review in the time 
allotted.

If you or your staff have any questions about this testimony or would 
like additional information, please contact me at (202) 512-6412 or 
Sushil Sharma, Ph.D., Dr.PH., at (202) 512-3460. We can also be reached 
by e-mail at rhodesk@gao.gov and sharmas@gao.gov. Individuals who made 
key contributions to this testimony were Venkareddy Chennareddy, Susan 
Conlon, Neil Doherty, Jason Fong, Penny Pickett, Laurel Rabin, and 
Katherine Raheb. James J. Tuite III, a GAO consultant, provided 
technical expertise.

Signed by: 

Keith Rhodes, Chief Technologist: 
Center for Technology and Engineering: 
Applied Research and Methods:

FOOTNOTES

[1] U.S. General Accounting Office, Gulf War Illnesses: Preliminary 
Assessment of DOD Plume Modeling for U.S. Troops' Exposure to Chemical 
Agents, GAO-03-883T (Washington, D.C.: June 2, 2003). www.gao.gov.

[2] U.S. General Accounting Office, Gulf War Illnesses: DOD's 
Conclusions about U.S. Troops Exposure Cannot Be Adequately Supported, 
GAO-04-159 (Washington, D.C.: June 1, 2004). www.gao.gov.

[3] Observations were few because Iraq stopped reporting weather 
station measurement information to the World Meteorological 
Organization in 1981. As a result, data on the meteorological 
conditions during the Gulf War were sparse. The only data that were 
available were for the surface wind observation site, 80 to 90 
kilometers away, and the upper atmospheric site, about 200 kilometers 
away.

[4] G. C. Gray and others, "The Postwar Hospitalization Experience of 
Gulf War Veterans Possibly Exposed to Chemical Munitions Destruction at 
Khamisiyah, Iraq," American Journal of Epidemiology 150 (1999); H. K. 
Kang and T.A. Bullman, "Mortality Among U.S. Veterans of the Persian 
Gulf War: 7 Year Follow-up," American Journal of Epidemiology 154 
(2001): 399-409.

[5] We use dispersion in this report to refer to both transport and 
diffusion models.

[6] A binary weapon mixes two less-toxic materials to create a toxic 
nerve agent within the weapon when it is fired or dropped.

[7] The composite approach DOD used is also known as the ensemble 
approach.

[8] Institute of Medicine, Gulf War Veterans: Measuring Health 
(Washington, D.C.: National Academy Press, 1999), p. 36.

[9] R. W. Haley, "Point: Bias from the 'Healthy-Warrior Effect' and 
Unequal Follow-Up in Three Government Studies of Health Effects of the 
Gulf War," American Journal of Epidemiology 148 (1998): 315-38.

[10] R. W. Haley and T. L. Kurt, "Self-Reported Exposure to Neurotoxic 
Chemical Combinations in the Gulf War," JAMA 277 (1997): 231-37.

[11] See Michael B. Gregg, ed., Field Epidemiology, 2nd ed. (New York: 
Oxford University Press, 2002).

[12] R. W. Haley and others, "Is There a Gulf War Syndrome? Searching 
for Syndromes by Factor Analysis of Symptoms," JAMA 277 (1997): 215-22. 
The six syndrome factors were impaired cognition, confusion-ataxia, 
arthro-myo-neuropathy, phobia-apraxia, fever-adenopathy, and weakness-
incontinence.

[13] Impaired cognition is characterized by problems with attention, 
memory, and reasoning, as well as insomnia, depression, daytime 
sleepiness, and headache. (Study results showed relative risk 8.2, 95 
percent, CI 2.9-23.5, p = 0.001.)

[14] Confusion-ataxia is characterized by problems with thinking, 
disorientation, balance disturbances, vertigo, and impotence.

[15] (1) CW exposure, relative risk 7.8, 95 percent, CI 2.3-25.9, p < 
0.0001; (2) geographic location, relative risk 4.3, 95 percent, CI 1.9-
10.0, p = 0.004; (3) pyridostigmine side effects, dose-response trend 
up to relative risk 32.4, 95 percent, CI 7.8-135.0, p < 0.0001; (4) 
synergistic association, Rothman synergy statistic 5.3, 95 percent, CI 
1.04-26.7, p < 0.05. See Jonathan B. Tucker, "Evidence Iraq Used 
Chemical Weapons during the 1991 Persian Gulf War," The 
Nonproliferation Review 4:3 (Spring-Summer 1997): 114-22. Center for 
Nonproliferation Studies, Monterey Institute of International Studies, 
http://cns.miis.edu/pubs (Apr. 28, 2004); and U.S. Department of 
Defense, Office of the Special Assistant for Gulf War Illnesses, 
Coalition Chemical Detections and Health of Coalition Troops in 
Detection Area (Washington, D.C.: Aug. 5, 1996). http://
www.gulflink.osd.mil/czech_french/czfr_refs/n08en011/coalitn.html 
(Apr. 28, 2004).

[16] Arthro-myo-neuropathy is characterized by joint and muscle pains, 
muscle fatigue, difficulty lifting, and paresthesias of the 
extremities. (Results showed for exposure, dose-response effect to 
relative risk 7.8, 95 percent, CI 2.4-24.7, p < 0.0001; for side 
effects, dose-response effect to relative risk 3.9, 95 percent, CI 1.3-
12.1, p < 0.0001.)

[17] R. Nisenbaum and others, "Deployment Stressors and a Chronic 
Multisymptom Illness among Gulf War Veterans," Journal of Nervous and 
Mental Disease 188 (2000): 259-66.

[18] Association with "severe illness," adjusted OR 3.46, 95 percent, 
CI 1.73-6.91, p < 0.0001; association with "mild-moderate illness," 
adjusted OR 2.25, 95 percent, CI 1.54-3.27, p < 0.0001. See K. Fukuda 
and others, "A Chronic Multisymptom Illness Affecting Air Force 
Veterans of the Persian Gulf War," JAMA 280 (1998): 981-88.

[19] S. P. Proctor and others, "Health Status of Persian Gulf War 
Veterans: Self-Reported Symptoms, Environmental Exposures, and the 
Effect of Stress," International Journal of Epidemiology 27 (1998): 
1000-10.

[20] R. F. White and others, "Neuropsychological Function in Gulf War 
Veterans: Relationships to Self-Reported Toxicant Exposures," American 
Journal of Industrial Medicine 40 (2001): 42-54.

[21] K. Lindem and others, "Neuropsychological Performance in Gulf War 
Era Veterans: Traumatic Stress Symptomatology and Exposure to Chemical-
Biological Warfare Agents, Journal of Psychopathology and Behavioral 
Assessment 25:2 (2003): 105-19.

[22] Chemical odor, OR = 6.2, 95 percent, CI 3.9-9.9; antinerve gas 
pills, OR = 3.7, 95 percent, CI 2.4-5.6; formal alerts for CW attack, 
OR = 2.7, 95 percent, CI 2.0-3.7. See J. Wolfe and others, "Risk 
Factors for Multisymptom Illness in U.S. Army Veterans of the Gulf 
War," Journal of Occupational and Environmental Medicine 44:3 (2002): 
271-81.

[23] H. K. Kang and others, "Evidence for a Deployment-Related Gulf War 
Syndrome by Factor Analysis," Archives of Environmental Health 57:1 
(2002): 61-68.

[24] T. C. Smith and others, "Gulf War Veterans and Iraqi Nerve Agents 
at Khamisiyah: Postwar Hospitalization Data Revisited," American 
Journal of Epidemiology 158 (2003): 457-67.

[25] H. K. Kang and T. A. Bullman, Mortality among U.S. Gulf War 
Veterans Who Were Potentially Exposed to Nerve Gas at Khamisiyah, Iraq 
(Washington, DC: Department of Veterans Affairs, May 2002).

[26] R. W. Haley and others, "Association of Low PON1 Type Q (Type A) 
Arylesterase Activity with Neurologic Symptom Complexes in Gulf War 
Veterans," Toxicology and Applied Pharmacology 157 (1999): 227-33.

[27] B. Mackness and others, "Low Paraoxonase in Persian Gulf War 
Veterans Self-Reporting Gulf War Syndrome," Biochemical and Biophysical 
Research Communications 276 (2000): 729-33.

[28] See Matthew Hotopf and others, "Paraoxonase in Persian Gulf War 
Veterans," Journal of Occupational and Environmental Medicine 45 
(2003): 668-75, and C. Unwin and others, "Health of UK Servicemen Who 
Served in the Persian Gulf War," Lancet 353 (1999): 169-78.

[29] R. W. Haley and others, "Severely Reduced Functional Status in 
Veterans Fitting a Case Definition of Gulf War Syndrome," American 
Journal of Public Health 92 (2002): 46-47.

[30] K. Husain and others, "Delayed Neurotoxic Effect of Sarin in Mice 
after Repeated Inhalation Exposure," Journal of Applied Toxicology 13 
(1993): 143-45, and "A Comparative Study of Delayed Neurotoxicity in 
Hens Following Repeated Administration of Organophosphorus Compounds," 
Indian Journal of Physiology and Pharmacology 39 (1995): 47-50.

[31] Mohamed B. Abou-Donia and others, "Neurotoxicity Resulting from 
Coexposure to Pyridostigmine Bromide, DEET, and Permethrin," Journal of 
Toxicology and Environmental Health 48 (1996): 35-56, and "Increased 
Neurotoxicity Following Concurrent Exposure to Pyridostigmine Bromide, 
DEET, and Chlorpyrifos," Fundamentals of Applied Toxicology 34 (1996): 
201-22.

[32] Mohamed B. Abou-Donia and others, "Combined Exposure to Sarin and 
Pyridostigmine Bromide Increased Levels of Rat Urinary 3-Nitrotyrosine 
and 8-Hydroxy-2'-Deoxyguanosine, Biomarkers of Oxidative Stress," 
Toxicology Letters 123 (2001): 51-58; "Disruption of the Blood-Brain 
Barrier and Neuronal Cell Death in Cingulate Cortex, Dentate Gyrus, 
Thalamus, and Hypothalamus in a Rat Model of Gulf-War Syndrome," 
Neurobiology of Disease 10 (2002): 306-26; and "Sarin: Health Effects, 
Metabolism, and Methods of Analysis," Food and Chemical Toxicology 40 
(2002): 1327-33.

[33] K. Husain and S. Somani, "Delayed Toxic Effects of Nerve Gas Sarin 
and Pyridostigmine under Physical Stress in Mice," Journal of Burns and 
Surgical Wound Care 2 (2003): 2-19.

[34] R. F. Henderson and others, "Response of F344 Rats to Inhalation 
of Subclinical Levels of Sarin: Exploring Potential Causes of Gulf War 
Illness," Journal of Toxicology and Industrial Health 17 (2001): 294-97 
and 18:1 (2002): 48.

[35] See Henderson and others, "Response of Rats to Low Levels of 
Sarin," and "Subclinical Doses of the Nerve Gas Sarin Impair T Cell 
Responses through the Autonomic Nervous System," Journal of Toxicology 
and Applied Pharmacology 184 (2002): 82-87.

[36] See R. W. Haley and others, "Brain Abnormalities in Gulf War 
Syndrome: Evaluation by 1H Magnetic Resonance Spectroscopy," Radiology 
215 (2000): 807-17, and "Effect of Basal Ganglia Injury on Central 
Dopamine Activity in Gulf War Syndrome: Correlation of Proton Magnetic 
Resonance Spectroscopy and Plasma Homovanillic Acid," Archives of 
Neurology 57 (2000): 1280-85, as well as D. J. Meyerhoff and others, 
"Reduced N-Acetylaspartate in the Right Basal Ganglia of Ill Gulf War 
Veterans by Magnetic Resonance Spectroscopy," Proceedings of the 
International Society of Magnetic Resonance Medicine 9 (2001): 994.

[37] O. U. Scremin and others, "Effects of Chronic Exposure to Low 
Levels of Cholinesterase Inhibitors on Cerebral Blood Flow," paper for 
the Society for Neuroscience Meeting, Orlando, Florida, 2002.

[38] Melinda Roberson and others, "Depression of Cholinesterase 
Activity by Low-Dose Sarin Exposure May Lead to Persistent Changes That 
Influence Behavior," Society for Neuroscience, Washington, D.C., 
Program no. 205.3 (Abstract, 2002).

[39] U.S. General Accounting Office, Gulf War Illnesses: Improved 
Monitoring of Clinical Progress and Reexamination of Research Emphasis 
Are Needed, GAO/NSIAD-97-163 (Washington, D.C.: June 23, 1997).