Agent Orange: Actions Needed to Improve Accuracy and Communication of Information on Testing and Storage Locations

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.

GAO is making six recommendations, including that DOD develop a process for updating its list of Agent Orange testing and storage locations, and that DOD and VA develop a process for coordinating the communication of information on where Agent Orange was known to have been present. DOD concurred with four recommendations. VA concurred with one recommendation and non-concurred with one recommendation.

From the 1940s to the 1970s, the U.S. government developed and tested  tactical herbicides in the United States and abroad. These tactical  herbicides were known as “rainbow herbicides” and included Orange,  Purple, Pink, Green, Blue, and White. Tactical herbicides were intended  for use by the U.S. military in the conflicts in Korea and Vietnam, but were  not intended for use on U.S. military installations. During the mid-1960s,  U.S. chemical companies manufactured and shipped large quantities of  tactical herbicides to Vietnam for use by the U.S. military to eliminate  enemy cover and destroy the enemy’s crops. The tactical herbicide  designated “Orange”—later known as Agent Orange—was first produced  in 1964, and approximately 12.1 million gallons were shipped to  Southeast Asia from several U.S. ports between 1965 and 1970. The  Department of Defense (DOD) suspended the use of Agent Orange in  Vietnam in 1970 and incinerated remaining stockpiles at sea in 1977.

In 1984, the U.S. Environmental Protection Agency (U.S. EPA)  determined that a form of dioxin that is a by-product of the manufacturing  process of one of the two components of Agent Orange had been  associated with a number of health effects, including cancer, in exposed  animals and in humans, including children. The Agent Orange Act of  1991, as amended, established a presumption of service connection for  certain diseases manifesting in veterans by way of exposure to herbicide  agents while deployed in the Republic of Vietnam at any time beginning  January 9, 1962, and ending on May 7, 1975. The act also required that whenever the Secretary of Veterans Affairs determined that a positive  association existed between humans’ exposure to an herbicide agent and  the occurrence of a disease in humans, the Secretary shall prescribe  regulations providing that a presumption of service connection was  warranted for that disease. The Department of Veterans Affairs (VA) has  developed procedures to assess veterans’ claims for disability  compensation for exposure to Agent Orange and provides on its website  a list of locations where tactical herbicides were thought to be tested,  stored, or destroyed. Both DOD and U.S. EPA have conducted some  remediation of dioxin-contaminated sites where these herbicides were  known to be present in the United States.

There has been long-standing congressional interest in and concern  about the effects of exposure to herbicides such as Agent Orange.  Although DOD policy restricted the domestic use of tactical herbicides,  the House Armed Services Committee has expressed concern that  additional exposures to Agent Orange may have occurred on Guam.  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 DOD and 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.

We scoped this review to include locations where Agent Orange or its  components were tested, distributed, and stored in the United States and  its territories. For each objective, we reviewed agency documents and  policies; interviewed officials from DOD, VA, and U.S. EPA, as well as  from the government of Guam; and met with some veterans and a  veterans service organization.

For objective one, we obtained through archival research available  shipping and agency records, including U.S. military correspondence and  logistics reports, and we reviewed these documents to trace the federal  government’s procurement, distribution, use, and disposition of Agent  Orange and its components. We analyzed this documentation, hereinafter  referred to as shipment documentation, to prepare summary information  on the quantities of Agent Orange and the vessels that carried the  shipments. We used this information to obtain official Navy and merchant  vessel logbooks—hereinafter referred to as logbooks—to the extent that  they were available, to identify the routes the vessels took from U.S. ports  to Vietnam and back, and to identify any port calls made en route.

For objective two, we obtained documentation from DOD and analyzed  archives search reports and other environmental studies for several U.S.  installations to identify additional locations where Agent Orange or its  components were tested and stored in the United States and its  territories. We compared the results with information DOD has provided  to VA for public dissemination on testing and storage locations of tactical  herbicides in the United States and its territories. We also compared the  results with DOD policies for conducting records research and responding  to inquiries related to past environmental exposures. We reviewed the  process by which DOD and VA communicate with veterans, to include  providing information about where Agent Orange was tested and stored.  We compared the communication process with DOD’s policy on  assessing long-term health risks and with VA’s process for determining  benefits based on veterans’ claims, and we assessed the extent to which  DOD and VA had responded to reports related to the information on  locations that were posted on VA’s website.

For objectives one and two, we held six discussion sessions with a non- generalizable sample of veterans—four sessions in person in Hawaii and  Guam, and two sessions that were moderated via telephone from  Washington, D.C.—to discuss veterans’ experiences specific to Agent  Orange. A total of 38 individuals attended the sessions, which ranged  from 1 to 10 participants per session. During the sessions, we discussed  information that individuals received from DOD, VA, and other federal  agencies about any links between exposure to herbicides and negative  health effects, or 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. We also asked  the veterans whether they believed they had been exposed to Agent  Orange in Vietnam, Guam, or another location, and, if so, to describe the  circumstances of the exposure. At the discussion sessions in Hawaii and  Guam, we also requested participants to complete a short questionnaire  about their military service and their recollections about experiences with  herbicides during their military service.

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. 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, and the Centers for Disease Control and Prevention. We  also reviewed the draft and final plan for testing for the presence of the  components of Agent Orange at three sites at Andersen Air Force Base  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 conducted a  site visit to Guam and visited the three sites where testing was  subsequently done. We also spoke with cognizant officials at DOD, U.S.  EPA, and Guam EPA about testing for the components of Agent Orange.  Further details on our scope and methodology can be found in appendix I.

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.

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.

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.

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.

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

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.

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.

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)

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

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.

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.

Veterans who were exposed to Agent Orange in the Vietnam War era may be eligible for disability compensation.

We examined how the Departments of Defense and Veterans Affairs communicated information to veterans and the public about possible Agent Orange exposure. Specifically, we looked at information about where Agent Orange had been tested, distributed, or stored in U.S. states and territories. We found that VA's website listing of locations outside of Vietnam where veterans may have been exposed is inaccurate and incomplete.

We made 6 recommendations to improve DOD and VA communication about Agent Orange.