Don’t Look,

Don’t Find

Researched and written by

Dan Fahey

The Military Toxics Project

P.O. Box 558

Lewiston, ME 04243-0058

(207) 783-5091

Fax (207) 783-5096

www.miltoxproj.org

miltoxpr@ime.net

The Military Toxics Project is a non-profit organization that unites activists,

organizations, and communities to remedy and prevent pollution created by the military.

Web sites containing information about depleted uranium include:

www.miltoxproj.org

www.globaldialog.com/~kornkven/

www.ngwrc.org

www.rama-usa.org

http://www.antenna.nl/wise/uranium/

Additional web sites are cited in Appendix B – References.

Special thanks to the Military Toxics Project, the National Gulf War Resource Center,

Swords to Plowshares Veterans’ Rights Organization, Veterans for Peace, Paul Sullivan,

Charles Sheehan-Miles, Chris Kornkven, Jerry Wheat, Doug Rokke and the many Gulf

War veterans, community groups, and concerned citizens who made this report possible.

i

Error and Bias in the RAND DU Report 33

Kidney Effects 37

Respiratory Disease 38

Immunological Effects 38

Neurological Problems 39

Reproductive Effects 39

Developmental Effects 40

Genotoxic Effects 41

Cancer 41

Children’s Susceptibility 44

Undiagnosed Illnesses 45

ii

1

On July 22, 1990, the U.S. Army released a comprehensive report about armor-piercing

ammunition made of depleted uranium, a chemically toxic and mildly radioactive heavy

metal. This visionary report predicted the combat use of depleted uranium (DU)

penetrators could create localized areas of contamination consisting of large amounts of

respirable-size uranium particles. Infantry troops were expected to receive the highest

exposures through inhalation of the dust, and the Army anticipated the health outcomes

could include cancer and kidney problems. Though no anti-DU movement existed at the

time, the Army predicted that depleted uranium munitions might be removed from the

arsenal by political force once the health and environmental impacts of depleted uranium

were widely known.

Fast-forward six months. During Operation Desert Storm, American aircraft and tanks

shoot 320 tons of depleted uranium in Iraq and Kuwait. Thousands of Iraqi tanks,

personnel carriers and other equipment are contaminated with depleted uranium dust and

debris. More than one hundred American soldiers are exposed to depleted uranium in

friendly fire incidents; more than twenty-five are wounded by DU shrapnel. After the

cease-fire, tens of thousands of front line and rear echelon troops move freely through

contaminated areas with no idea DU ammunition had been used, no training on ways to

avoid exposure, and no respiratory protection. Many people climbed on and entered

multiple destroyed vehicles to remove equipment, gather souvenirs and pose for victory

photos. The Pentagon did a splendid job of planning and executing the war, but it

neglected to inform the troops who secured the victory about the health hazards of

depleted uranium.

When thousands of Gulf War veterans started to report myriad health problems, the

Pentagon was quick to rule out depleted uranium (and chemical warfare agents, anthrax

vaccinations, PB pills, etc.) as associated with the illnesses. From the beginning, the

Pentagon vastly underreported the numbers of veterans who had known or suspected

exposures to depleted uranium, an action that helped to steer the course of Gulf War

illness research away from DU. The Army produced inaccurate exposure data which the

Pentagon misleadingly promoted as proof that not one Gulf War veteran was exposed to

enough depleted uranium to cause any health problems.

The government’s response to Gulf War depleted uranium exposures can be summed up

as ‘Don’t Look, Don’t Find.’ This is not an articulated policy, but rather a pattern of

inexcusable and negligent behavior. Five consecutive Gulf War illness investigations

barely scratched the surface of depleted uranium exposures, choosing instead to repeat

the prevarications whispered in their ears by Pentagon spin-doctors. Among the dozens

of congressional hearings on Gulf War illnesses, not one has been devoted to unmasking

the Pentagon’s failure to provide training, protective equipment, or requisite medical

testing to Gulf War troops.

At this point in time, it is virtually impossible to determine how many veterans might

have been exposed to depleted uranium. There are no reliable exposure estimates with

2

which to assess the impacts of depleted uranium on veterans’ current and future health.

Recent federal research on rats and a small number of Gulf War veterans indicates that

internal exposure to depleted uranium fragments may be associated with development of

tumors, immune system damage, neurological problems, and male and female

reproductive effects. The applicability of this research to the tens of thousands of

veterans who had unprotected contact with multiple contaminated vehicles remains

uncertain, but there is sufficient evidence of association to justify future research and

investigation.

To blunt growing criticism of its depleted uranium policies, the Army recently announced

it will conduct live fire testing to obtain better exposure estimates, and it allocated $5

million for new research on DU health effects. This research may be too little too late for

some Gulf War veterans, however. In accordance with the Persian Gulf War Veterans

Act of 1998, the Institute of Medicine is currently determining the likely health outcomes

from a range of Gulf War chemical, biological, and radiological exposures. With respect

to depleted uranium, the Institute of Medicine may resolve the many uncertainties over

the scope and severity of exposures in favor of the veterans, or it could simply follow the

‘Don’t Look, Don’t Find’ path well-worn by its predecessors. Only time will tell.

More than 100,000 veterans have diagnosed and undiagnosed illnesses related to Gulf

War service. If a veteran has a respiratory disease or develops cancer ten years from now

or suffers neurocognitive problems due to exposure to depleted uranium or other toxins,

the government has a moral responsibility and a legal requirement to help the veteran and

the veteran’s family. In any case where there is doubt as to the origin of the condition or

the degree of its impairment, the benefit of the doubt must be resolved in favor of the

veterans. They deserve nothing less, and they ask nothing more.

Despite the U.S. government’s ‘Don’t Look, Don’t Find’ practices, there is growing

evidence that depleted uranium exposures during and after the Gulf War may be causing

health problems among veterans and civilians. The proliferation of DU ammunition and

its use in Nevada, New Mexico, Arizona, Indiana, Maryland, Iraq, Kuwait, Saudi Arabia,

Japan, Bosnia, Puerto Rico, Kosovo, and Serbia has created an international movement to

end the use of depleted uranium munitions. The more we learn about depleted uranium,

the more accurate the Army’s 1990 predictions become.

3

Advice to Raffaello Girolami when he

went as Ambassodor to the Emperor.

October 1522

during intense combat under adverse weather conditions. When the shooting stopped,

Battle Damage Assessment Teams (BDATs) visited battalion, corps, and theater

collection points to evaluate the losses and identify American vehicles disabled by

depleted uranium rounds. By May 14, 1991, the Army determined that depleted uranium

rounds penetrated six crewed Abrams tanks and fifteen Bradley Fighting Vehicles.

(AMCCOM, 1991). Four Abrams tanks were contaminated when on-board fires

consumed the DU rounds. (Ibid.). After action reports identified each vehicle and unit,

and in some cases listed the names of soldiers killed and wounded. (OSAGWI, 1998: End

Notes 142 to 181).

In accordance with occupational health and safety laws, Army regulations in place during

Operation Desert Storm required medical testing of any soldier wounded or otherwise

exposed to radioactive materials, including depleted uranium. In September 1990, the

Headquarters of the U.S. Army released a Technical Bulletin outlining procedures for

handling depleted uranium munitions fires, which states: "If ingestion or inhalation of

radioactive material is suspected, bioassays should be performed." (TB, 1990: 7-3.d.). A

month later, the Headquarters of the U.S. Army issued Army Regulation 40-5,

Preventative Medicine. The chapter titled "Radiation Protection" stipulates that

"[b]ioassay procedures will be performed when radioactive materials are used in such a

manner that they could be inhaled, ingested, or absorbed into the body." (AR40-5, 1990:

9-6.a.(2), emphasis added). These regulations – released while soldiers were deploying

to Saudi Arabia in anticipation of the war – have an unmistakable, common sense

message: soldiers wounded by or otherwise exposed to depleted uranium should be

medically tested.

The long paper trail of friendly fire reports should have led the Army medical command

directly to the soldiers wounded or otherwise exposed to depleted uranium. A review of

these primary records – all of which were generated between March 2 and May 14, 1991

– indicate that 13 crewmembers were killed while approximately 113 survived.

(AMCCOM, 1991; Rostker, 1998; Fahey, 1998: 55). Approximately 50 of the survivors

had been wounded. (AEPI, 1995: 79). Yet for reasons the Army has never explained, not

one soldier – not even the infantry and armor soldiers wounded by depleted uranium

fragments – was tested for DU after the war.

4

The days following the friendly fire incidents turned into weeks, then the weeks turned

into months, and the Army made no effort to identify or test friendly fire veterans

exposed to depleted uranium. Then, in January 1992, Congressman Ron Wyden (OR)

started asking questions about American vehicles hit by DU rounds. A month later –

after the General Accounting Office started to investigate the Army’s handling of

depleted uranium – a dormant Army Surgeon General’s Office suddenly came to life with

newfound interest in soldiers wounded by depleted uranium fragments. In late March

1992, a hastily written Army report recommended identifying soldiers who may retain

depleted uranium fragments "to watch for and catalogue signs of chronic kidney toxicity,

granuloma induction, and cancer." (Daxon, 1992: 7).

While the Army Surgeon General’s Office started to get busy, the General Accounting

Office tried to ascertain the total number of soldiers exposed to DU. The Army replied

that it did not know "the full extent to which its personnel were exposed to DU

contamination during the Gulf War." (GAO, 1993: 3). However, the Army Surgeon

General’s Office told the GAO that a review of medical records showed that 35 soldiers

were exposed to DU in friendly fire incidents, and that 22 of these soldiers likely retained

DU fragments. (Ibid.: 3). This was the first time the Army intentionally misled Federal

investigators about the number of soldiers exposed to depleted uranium, but sadly, it

would not be the last.

In its final report, Army Not Adequately Prepared to Deal With Depleted Uranium

Contamination, the General Accounting Office recommended "the testing of all crew

members inside vehicles penetrated by DU munitions." (GAO, 1993: 7 emphasis added).

The Army concurred with this recommendation and stated that the testing "of all crew

members" would begin in July 1993. (Ibid.: 37).

For the next five years, through four major government investigations of Gulf War

veterans’ illnesses, the Army continued to misrepresent the number of friendly fire

veterans exposed to depleted uranium. In their final reports, the Defense Science Board

and the Institute of Medicine simply repeated the Army Surgeon General’s declaration

that only 35 friendly fire vets had been exposed. (DSB, 1994: 26. IOM, 1996: 56).

Inexplicably, both the Presidential Advisory Committee on Gulf War Veterans’ Illnesses

and the Senate Veterans’ Affairs Committee’s Special Investigation Unit reported that 36

friendly fire veterans had been exposed to DU. (PAC, 1996: 99. SIU, 1998: 113).

The Department of Veterans Affairs, which established the Depleted Uranium Program at

the Baltimore, MD VA Medical Center to research the health effects of depleted uranium

on friendly fire veterans, was also apparently deceived by the Army Surgeon General’s

Office. In November 1997, Dr. Melissa McDiarmid, director of the Depleted Uranium

Program, expressed her frustration to the VA’s Expert Scientific Advisory Committee:

I have a letter that my colleague Jim Keogh, MD, wrote to DoD three years ago

saying, can I have a list of everybody who was on or in one of those vehicles? He

got a list, and it was never confirmed what the criterion were to get on the list. He

presumed it was everybody . . . Three or four years into the problem people are

5

saying and I’m saying, wait a minute, this doesn’t seem like we have everybody

here . . . We just sent a letter back to DoD two weeks ago that said, you know, we

depended on you to give us the information. We had no way of knowing except

common sense that we didn’t have everybody. It is to this day unclear as to either

who made the decision and how what we would call a case definition was made.

The occupational medicine community would have wanted anybody on the

vehicle. It appears that you probably had to have been wounded to get on the list.

However, I am also told that some of the guys that are now being found that I

don’t know about were also wounded. So I don’t know what happened. (VA,

1997).

The Pentagon continued to publicly insist only 35 friendly fire veterans were exposed to

depleted uranium until March 1998, after the Case Narrative: Depleted Uranium

Exposures was released. Using declassified documents obtained through the Freedom of

Information Act, the Case Narrative estimated 122 friendly fire veterans were exposed to

DU – more than three times the number previously reported by the Pentagon. (Fahey,

1998: 55). In response to the Case Narrative’s disclosure, Bernard Rostker, director of

the Office of the Assistant Secretary of Defense for Gulf War Illnesses (OSAGWI), gave

an angry speech to the American Legion in which he casually acknowledged the

existence of approximately 113 friendly fire veterans. (Rostker, 1998: 3). Two years

later, Rostker lowered this number to 107. (Rostker, 2000).

Why did the Army Surgeon General’s Office tell four Federal investigations – including

one by the Institute of Medicine – that only 35 friendly fire veterans were exposed to

depleted uranium? Was it simply a bureaucratic blunder? An innocent mistake? Or was

it an intentional effort to publicly downplay the number of soldiers exposed to depleted

uranium? History and a review of available documentation support the last presumption,

though the issue remains clouded by the Pentagon’s refusal to release documents that

have been repeatedly requested through the Freedom of Information Act.

Among the five Federal investigations that queried the Pentagon about depleted uranium,

the Senate Veterans’ Affairs Committee merits special notice. Five months after Bernard

Rostker acknowledged there were 113 friendly fire veterans, the Special Investigation

Unit released its final report which stated that only 36 friendly fire veterans existed.

(SIU, 1998: 113). Earlier investigations were merely lackadaisical in their research; the

Special Investigation Unit was truly comatose.

A recent report generated by the VA’s Depleted Uranium Program sheds light on the

misrepresentation of friendly fire vets. The paper, Elevated Urine Uranium Excretion By

Soldiers With Retained Uranium Shrapnel, states that the Department of Defense initially

(presumably in 1992) provided the DU Program with a list of 68 friendly fire veterans.

(Hooper, 1999). The VA contacted 48 individuals, and 33 enrolled in the research

program in 1993.

This disclosure raises a number of questions. If in 1993 the Pentagon had a list of 68

individuals who were likely exposed to DU in friendly fire incidents, why did it tell five

6

consecutive Federal investigations that only 35-36 veterans had been exposed? Since the

Pentagon now admits that approximately 107-113 veterans are in this cohort, why did the

Army Surgeon General’s Office only draw up a list of 68 names? These are questions the

In 1999 the Depleted Uranium Program belatedly examined thirty highly exposed

veterans. Four new veterans retaining depleted uranium fragments were identified.

(AFRRI, 1999). It is therefore possible that other veterans who did not make it onto the

Army Surgeon General’s 1992 ‘short list’ also unknowingly retain depleted uranium

fragments.

The fraudulent accounting of friendly fire veterans casts a shadow of doubt upon all

Pentagon statements about depleted uranium. After all, if, as it now appears, the

Pentagon intentionally misrepresented the number of combat soldiers wounded by

depleted uranium, why should it be considered a reliable source of information about

other depleted uranium exposures? The Pentagon is not solely to blame, however.

Starting with the General Accounting Office, five consecutive federal investigations

acquiescently repeated the fraudulent declarations emanating from the Army Surgeon

General’s Office.

Abrams tanks and Bradley Fighting Vehicles, division maintenance and recovery soldiers

prepped the vehicles and transported them from the battlefield to battalion, corps, and

theater collection points. The number of support personnel who had unprotected

exposures to depleted uranium contamination during this process is unknown, but it is

now acknowledged to be significantly higher than the Pentagon and five successive

Federal investigations previously reported.

During its 1992 investigation, the General Accounting Office interviewed soldiers from

Service and Supply Company) who "had worked in and around DU-contaminated combat

systems without being aware of the characteristics of DU ammunition, the potential risks

from DU contamination, and precautions necessary to prevent DU exposure." (GAO,

may have been exposed to DU during these operations.

The General Accounting Office’s investigation was limited in scope, but it clearly

acknowledged potential exposures among maintenance and recovery personnel. In

7

involving depleted uranium rounds. (OSAGWI, 1998: 84). An unknown number of

support soldiers from each of these divisions removed equipment from the contaminated

vehicles and transported them to battalion, corps, and theater collection points.

When Federal investigations of Gulf War veterans’ illnesses began in earnest in 1994, the

number of potential DU exposures among maintenance and recovery personnel was

vastly underreported. The Defense Science Board and the Institute of Medicine limited

1994: 26. IOM, 1996: 56). To its credit, the Presidential Advisory Committee also

the torpid Senate Special Investigation Unit failed to mention any DU exposures among

support personnel. (SIU, 1998: 113).

The Pentagon finally provided an estimate of the number of support personnel potentially

exposed to depleted uranium in August 1998. In addition to the 27 soldiers from the

Assistance Representatives (LAR) may have been exposed to DU during the recovery

process. (OSAGWI, 1998: 8). Why were these additional soldiers and civilian workers

not reported to any of the five Federal investigations of Gulf War veterans’ illnesses?

Was it an intentional act? Were successive Federal investigations simply lacking the

investigative effort to look beyond Pentagon prevarications? Whatever the reason, it is

clear that the number of support soldiers potentially exposed to depleted uranium is far

greater than the Pentagon and five consecutive Federal investigations previously

reported.

glory of victory atop destroyed tanks and shattered bunkers. Unfortunately, the messages

warning front line soldiers and Marines to stay away from DU-contaminated equipment

were kept in the rear with the commanders. But thousands of miles from the battlefield,

quiet rumblings began among people who were aware of the health hazards to soldiers

and civilians posed by depleted uranium contamination.

Even before the shooting stopped, a colonel at Los Alamos suggested writing war

histories to downplay depleted uranium’s hazards, thereby safeguarding its future use in

munitions (see page 8). (Los Alamos, 1991). Shortly thereafter, a colonel at the Defense

Nuclear Agency wrote that soldiers and civilians were encountering DU contamination

and collecting "toxic war souvenirs." (DNA, 1991). A British Atomic Energy Authority

report warned that civilians might suffer health problems from inhalation of even trace

amounts of depleted uranium dust. (AEA, 1991). While these reports were written,

exhausted soldiers started to return home, some with depleted uranium fragments in their

wounds, others with depleted uranium dust in their lungs. However, news of depleted

uranium exposures was kept from the public, and even from the veterans themselves,

amidst the celebration of a war that the Pentagon hoped would expunge the stigma of

Vietnam.

9

It is difficult to determine the number of people who entered contaminated areas or may

have had contact with contaminated equipment. Approximately 697,000 service

members served in the Southwest Asia theater between August 2, 1990 and July 31,

1991, the period referred to as the ‘Gulf War conflict.’ (PAC, 1996). The number of

American troops deployed to the gulf peaked at approximately 541,000 in February 1991.

(Shield, 1991).

More than 295,000 American soldiers and Marines entered Iraq and Kuwait during the

Operation Desert Storm ground war. On the Army side, Lt. General Franks led the VII

Corps invasion force of 142,000 soldiers, and Lt. General Luck commanded XVIII

Airborne Corps’ 117,000 combat troops. (Schubert, 1995: 177. Shield, 1991: 168). The

troops took part in the ground invasion. (Dunnigan, 1992: 300). Thousands of additional

medical and support personnel followed the combat units into the battlefields.

The hundreds of thousands of American servicemen and women who took part in the

February 1991 ground war may have been exposed to depleted uranium in a variety of

ways. Some breathed smoke from destroyed vehicles, or climbed on them as part of

combat operations. Others rescued American friendly fire survivors and medically

treated them. After the shooting stopped, curious soldiers and Marines climbed on and

entered destroyed equipment to remove equipment, gather souvenirs, and take photos.

Aviation, support, and medical units set up forward base camps in occupied southern Iraq

and liberated Kuwait.

Following the end of hostilities, contaminated American equipment was transported from

the battlefield to King Khalid Military City in Saudi Arabia. Some contaminated Iraqi

equipment was transported to ports in Saudi Arabia for shipment to the US, where Navy

and other personnel may have encountered it. (Fahey, 1998: 196. AEPI, 1995: 85).

Countless numbers of rear echelon Navy, Air Force, Marine Corps and Army personnel

drove from Saudi Arabia and Bahrain to survey the battlefields, gather souvenirs, and

capture the memory on film.

In November 1998, the Office of the Special Assistant released a map, Primary Areas of

DU Expenditure, identifying the areas of Iraq and Kuwait where American aircraft and

tanks shot depleted uranium (see page 10). The map also shows the movement of most

American ground units (some American and Allied forces are not identified) through

these contaminated areas during the ground war. (OSAGWI(a), 1998). The map does

not show post-war movements of American units in contaminated areas of Kuwait and

Iraq, or trace the movements of rear echelon forces who traveled into the battlefield areas

from Saudi Arabia and Bahrain.

Two independent surveys support the premise that large numbers of veterans were

potentially exposed to depleted uranium. Between 1991 and 1995, the Operation Desert

Shield-Desert Storm Association (Texas) surveyed 10,051 Gulf War veterans about a

11

variety of possible exposures. Eighty two percent of the veterans indicated they had

contact with captured Iraqi equipment at some point during their deployment. (Fahey,

1998: 38). A smaller survey of 250 veterans by Veterans Family Health Services (now

National Veterans Services Fund, Connecticut) found that 64% of veterans reported

contact with captured Iraqi equipment. (Ibid.: 38).

Though the veterans’ surveys were not conducted using rigorous scientific procedures,

they do indicate that roughly three quarters of more than 10,000 Gulf War veterans

reported contact with Iraqi equipment. Multiple weapons efficiently destroyed Iraqi

tanks and other equipment, but the 320 tons of depleted uranium dispersed in nearly

1,000,000 small and large caliber rounds destroyed and contaminated thousands of Iraqi

tanks and personnel carriers. (Fahey, 1998: 39). Since no warnings were issued to Gulf

War forces, and no battlefield contamination surveys were conducted, it is possible that

many veterans encountered at least one Iraqi vehicle contaminated by depleted uranium.

If three quarters of the 295,000 soldiers and Marines in the invasion force climbed on or

entered destroyed enemy equipment during and after the war, in excess of 221,000

American troops could have been exposed to depleted uranium.

A Department of Veterans Affairs survey sheds further light on the number of possible

DU exposures. The Department of Veterans Affairs asked veterans participating in the

Revised Gulf War Registry if they were exposed to depleted uranium. Of the first 10,075

veterans on the Registry, 14.2% answered ‘Yes,’ 29.8% answered ‘No,’ and 56%

answered ‘Unknown.’ (VA, 1997(a)).

Applying the percentage of self reported exposures to the number of soldiers and Marines

who participated in the ground invasion would equate to roughly 42,000 DU exposures.

The more telling statistic, however, is the fact that fully one out of every two veterans did

not know if he/she had been exposed to depleted uranium. Many veterans still do not

know what depleted uranium is, how it was used in the Gulf War, and how they might

have been exposed. In recognition of the lack of awareness about depleted uranium

among Gulf War veterans, the VA’s Depleted Uranium Program developed a detailed

DU questionnaire in 1998 that asks questions designed to determine a veterans exposure

in greater detail. (VA, 1998). Unfortunately, the revised questionnaire is not widely used

and is only provided to veterans who specifically request it.

Additional depleted uranium exposures may have taken place among soldiers deployed to

Kuwait after the 1991 ground war. During the July 11-12, 1991 Doha, Kuwait munitions

fire, approximately 660 depleted uranium rounds burned, scattering depleted uranium

dust and debris around the compound and downwind. (OSAGWI, 1998: 100). Soldiers

who later swept the contaminated compound were never told about DU, never provided

Regiment command staff was aware of the hazards. (Ibid.: 27, 78) Approximately 360

DU rounds were collected after the fire and returned to the US for disposal, but the fate of

the other 300 depleted uranium rounds is unknown. (OSAGWI, 1998: 100, 117). It is

likely that the 300 missing DU rounds completely oxidized, and the fine uranium dust

was scattered around the compound and downwind.

12

American soldiers and Marines deployed to Kuwait since 1991 may also have been

exposed to depleted uranium during training operations at the Udairi Training Range in

northern Kuwait. The Udairi range was the scene of a ferocious Desert Storm tank battle,

but all that remains now are the memories and the "skeletons of Soviet-made T-54, T-55,

and T-72 armored vehicles [that] litter the desert floor along with numerous armored

personnel carriers." (Leatherneck, 1998).

The military has never conducted soil sampling or radiological surveys of tanks within

the Udairi Training Range to determine if a depleted uranium hazard persists.

Interestingly, a 1994 survey of tanks in the nearby Udairi "Boneyard" found radioactivity

levels 20 to 24 times above background. The Army survey team concluded there was no

DU hazard to soldiers "as long as there are no ongoing operations within the boneyard."

(CENTCOM, 1994: 17, 20) Yet several miles away, Army and Marine Corps

commanders trained their troops in an area littered with the possibly contaminated

remnants of a large tank battle. In the absence of any data about depleted uranium

contamination and remediation efforts in the Udairi Training Range, it is reasonable to

believe that servicemen and women who trained in this area since 1991 may have been

exposed to depleted uranium.

Federal investigations of depleted uranium and Gulf War illnesses have barely scratched

the surface of widespread depleted uranium exposures. The Defense Science Board

report did not mention any DU exposures beyond friendly fire veterans and support

personnel. (DSB, 1994). The Institute of Medicine was the first investigation to

acknowledge the possibility of broader exposures:

It is possible that there was wider exposure to DU of troops who entered

destroyed enemy vehicles either on duty or as sightseers or of combat-support

troops who were exposed to battle dust after tank battles or to contaminated

smoke from explosion and fire in the destruction of ammunition storage. (IOM,

1996: 56).

Both the Presidential Advisory Committee and the Senate’s Special Investigative Unit

also acknowledged the possibility of large scale depleted uranium exposures, though

neither organization showed any interest in investigating the effects of these exposures on

veterans. (PAC, 1997: 99. SIU, 1998: 114).

By January 1998, it was apparent that the Pentagon had severely underreported the

number of potential DU exposures. In the face of mounting pressure from Gulf War

veterans’ groups, the Office of the Special Assistant discretely made the following

admission in its 1997 Annual Report:

Our investigations into potential health hazards of depleted uranium (DU) point to

serious deficiencies in what our troops understood about the health effects DU

posed on the battlefield. . . Combat troops or those carrying out support functions

generally did not know that DU contaminated equipment, such as enemy vehicles

13

struck by DU rounds, required special handling. . . The failure to properly

disseminate such information to troops at all levels may have resulted in

thousands of unnecessary exposures. (OSAGWI, 1998: 30).

The final statistics are unsettling. Approximately 295,000 ground troops plus tens of

thousands of troops from aviation, support and medical units may have encountered DU

dust and debris on the battlefield. Others serving in the rear could have been exposed to

DU through contact with contaminated American and Iraqi equipment at collection sites

in Saudi Arabia.

***

Just as the number of Vietnam veterans exposed to Agent Orange will never be known,

the number of soldiers exposed to depleted uranium is virtually impossible to determine.

During the Agent Orange debate, stories were collected, doses were estimated, and maps

were drawn, but in the end Congress ordered the Department of Veterans Affairs to

presume that every veteran who served in Vietnam was exposed to Agent Orange for

benefits purposes. With depleted uranium, stories have been collected, doses estimated,

and maps drawn, but the debate over how many soldiers may have been exposed to

depleted uranium continues unabated.

It is clear that large numbers of Gulf War veterans – everyone from combat soldiers and

Marines to support personnel to souvenir hunters – were potentially exposed to depleted

uranium. On top of that, Doha fire veterans and soldiers and Marines who have trained at

the Udairi Training Range since 1991 may also have been exposed. For seven years after

the war, the Pentagon concealed the extent of potential depleted uranium exposures from

a series of inattentive investigative committees. At this point in time, the available

evidence indicates that tens or even hundreds of thousands of Gulf War veterans may

have been exposed to depleted uranium.

14

To determine how much depleted uranium veterans were exposed to we could review the

results of bioassays conducted right after the war. But there are no results to review

because not one soldier, sailor, airman or Marine was tested until two years after the war.

We could examine battlefield contamination surveys completed after the cessation of

hostilities. But there are no surveys to examine because the Army and Marine Corps

never identified or delimited areas contaminated by depleted uranium.

We could check the air filters of the respirators worn during maintenance and recovery

operations. But there are no air filters to check because soldiers did not wear respiratory

protection while working with DU-contaminated equipment.

We could analyze the air monitoring samples collected during and after the Doha fire.

But there are no samples to analyze because no air monitoring was conducted either

during the fire or a week later when soldiers swept the dusty compound with brooms.

We could evaluate soil and wipe samples gathered from the Udairi Training Range to

determine ongoing exposures to US troops deployed to Kuwait. But there are no soil or

wipe samples from the Udairi Training Range to evaluate.

We could interpret the findings of the epidemiological study of Gulf War veterans

exposed to depleted uranium. But there are no findings to interpret because no

epidemiological study has been conducted.

We could assess the validity of Army dose reconstructions. But these estimates apply

only to soldiers in or near a vehicle at the time it is hit by a DU round, to the exclusion of

the thousands of personnel who had subsequent contact with DU dust and debris. So that

leaves us with the undesirable task of estimating how much depleted uranium thousands

of men and women might have been exposed to during days and weeks of unprotected

operations in contaminated areas.

An important part of assessing veterans’ exposures is listening to the experiences of the

veterans themselves. The Department of Defense, the General Accounting Office, and

other groups have each interviewed veterans in an attempt to understand the duration and

intensity of possible DU exposures. The following stories illustrate the difficulty of

estimating doses for the range of scenarios in which veterans might have been exposed to

depleted uranium.

shrapnel in my head, neck, and shoulder. After we were treated, I drove the Bradley back

to camp. Everything was covered in dust. I slept in my sleeping bag, which was covered

in dust and had been hit by shrapnel. I wore the same clothes for days and was never told

15

about DU. I wasn’t told I was exposed to DU until a year after the war, and I wasn’t

tested until 1993." (Fahey, 2000).

APC’s, trucks, bunkers – anything in our path. After everything was over, we went back

through the areas we had shot up and climbed all over the vehicles we had destroyed. We

wanted to see the damage our tanks had done, and we were looking for souvenirs. I knew

we were shooting DU rounds, but we were never told to stay away from the vehicles that

were hit by DU rounds. We were dipping [chewing tobacco], smoking, and eating

without having washed our hands. Right after the war we saw lots of guys from other

units climbing on the vehicles that we had shot with DU rounds." (Fahey, 1998: 107,

115).

Lt. Colonel, Battle Damage and Assessment Team Co-Leader: "Ltc. [redacted] said

that 27 or 28 major components were missing from the first four Bradleys he entered. So,

he knows that maintenance soldiers had been in there scrounging parts . . . [He] said that

had intentionally destroyed, entered the vehicles when they retrieved them . . .

Apparently the senior NCO from the other six-man BDAT team, MSG [redacted]

sometimes took a more cavalier attitude towards the hazards . . . On one occasion he

entered an Abrams tank which he knew was DU-contaminated, without any protective

measures. When one of the hatches slammed shut a lot of dust was stirred up."

and personal items, the maintenance personnel stripped off usable parts and highly

sensitive equipment. The maintenance sergeant in charge of the recovery operation told

us that he had no prior knowledge of the potential for DU contamination in these

vehicles." (GAO, 1993: 15).

Abrams tanks fired DU ammunition. This maintenance sergeant told us that after the

vehicle was repaired, he had stayed in it, along with other personnel, for several days

until the ground war was over." (GAO, 1993: 16).

"A11 is an M1A1 tank. It received 1 impact on the left rear . . . The tank has external

measurable contamination on the skirts, left fuel cell housing, and the bottom of the tank

. . . The wheels on Bohica (A1) were taken from this tank and the undamaged wheels on

Bohica were placed on A11. The engine from this vehicle was reportably [sic] damaged.

Location of the engine is unknown. CPT [redacted] indicated that 4 individuals received

shrapnel injuries and were evacuated back to Germany. He also stated that numerous

individuals were exposed to smoke during resulting fire . . . After checking the tank [the

DU Team] recommended that each individual involved in [this] DU incident receive an

appropriate medical evaluation." (AMCCOM, 1991: 5.K.).

16

into Kuwait to get a truckload of souvenirs. We drove through battle areas, including the

Highway of Death, just after the fighting ended, when everything was still very chaotic.

People from lots of different units were climbing all over destroyed tanks, personnel

carriers, and whatever else was lying around. We climbed on Iraqi tanks and put our

fingers in the neat round holes that I now know were where the DU penetrators hit. We

collected a truck full of helmets, gas masks, shell casings, and other souvenirs." (Fahey,

1998: 109).

involved in leveling ‘Camp Freedom’ north of Kuwait City, which apparently had been

garrisoned by the Iraqis. They frequently bulldozed or cleared bunkers and other former

Iraqi positions, and moved or cleared away some Iraqi equipment. Like many other

soldiers in his unit, [the] Sgt. crawled inside destroyed Iraqi armor and vehicles. Some

guys took souvenirs, but most of these were confiscated upon their departure."

(OSAGWI, 1998: End Note 268).

Vehicle Assessment Report – Depleted Uranium Contamination, 14 May 1991: "14

April 1991. The DU team . . . flew by Huey helicopter from KKMC to southern Iraq to

assess the damage to the tank and provide technical assistance. Upon arrival the tank

crew was observed removing all ammunition and structural members from the main

ammunition compartment. DU and HE rounds were laying on the ground beside the

tank. Crew members were working on top of the tank, in the main ammunition

compartment, and on the ground surrounding the tank. . . The DU team took radiological

measurements to determine contamination levels. Contamination was found on the

ground beside the tank, 47,000 dpm, on the front surface of the tank, on the top of the

ammunition compartment, and in the ammunition compartment. All crewmembers were

asked to vacate the tank. The DU team then surveyed all unit members exposed to or

involved in the handling of munitions. Several crewmembers hands were found

contaminated, one crewmembers coveralls were also contaminated. . . One individual had

radiological contamination in an open wound. . . The DU team advised the battalion

commander to have all individuals take showers and wash their clothes as soon as

possible." (AMCCOM, 1991: 5.J.).

"The explosions [at Doha] spread DU penetrators, both whole and in pieces, throughout

the north compound. The fires produced billowing black and white clouds of smoke that

rose hundreds of feet into the air, and drifted predominantly slowly to the east south-east

across portions of both compounds towards Kuwait City. . . I estimate I personally

handled over two dozen rods or pieces of rods. Most of them had a black sooty and/or

powdery coating over them. . . There would be as many as 50 soldiers ‘on line’ sweeping

down a cleared area of very small debris, sand, and dust. Again, as with the UXO

clearing, these soldiers carried and drank water continuously throughout their cleaning

efforts. . . At no time did anyone provide protective suits, surgical gloves, respirators, or

surgical masks for personnel to wear during clearing or cleaning operations." (OSAGWI,

1998: End Note 202).

17

bodies as we moved up through Kuwait. Nobody ever told us to stay away from the

vehicles that might have been contaminated with depleted uranium. When we went back

the second time (Feb.-Mar. 1992), we went through areas where there were tanks and

other vehicles that had been destroyed in Desert Storm. Lost of people were climbing on

those vehicles. Nobody told us those vehicles might be contaminated." (Fahey, 1998).

about 21 Jan. They were travelling along a hard surfaced road that paralleled the berm

when they came under attack from 2 A-10s. . . In the aftermath of the attack the berm and

ground around the convoy was peppered with hundreds of DU projectiles. . . [He] picked

one up as evidence of the attack and still has it to this day (NOTE: we made

arrangements for its proper retrieval and disposal)." (OSAGWI, 1998: End Note 183).

indicated that his people frequently also had to enter the tanks/Bradleys to download

munitions. Initially, they did not know the equipment was contaminated and did not take

any precautions. . . He indicated that the outside of the vehicles were not particularly

dirty/dusty. However, the insides had ¼ to ½ inch of fine ‘dust.’ He could not say

whether or not the dust was from the fires or from the desert. He said that the hatches of

the vehicles were always open when they received the vehicles. He indicated that the

dust was stirred up as his personnel walked [and] climbed through the vehicles."

(OSAGWI, 1998: End Note 97).

RECORD…SUBJECT: Exposure to Low Level Depleted Uranium (DU)

radiation…During deployment to Southwest Asia in support of Operation Desert Storm,

the following individual was exposed to low level Depleted Uranium (DU) radiation.

This contamination exposure was due to required entry into tracked vehicles that were

destroyed either by fire or by impact from depleted uranium (DU) anti-tank ammunition.

. . The approximate time period of exposure ranged between 10 minutes to two hours per

vehicle. A total of 27 vehicles were entered." (Fahey, 1998: 131).

Kuwait in a bus and three or four trucks. The purpose of our trip was to check out the

battle areas. One of the places we went to was the Highway of Death. We took pictures

and climbed in a lot of the vehicles. We gathered souvenirs. We were like little children

out on a playground. We had no knowledge of depleted uranium or that there might be

contamination on the vehicles." (Fahey, 1998: 110).

18

incident that worries him is when an A-10 loaded with DU and HEI rounds crashed on

their runway, he and his men had to fight the fire before pushing the hulk out of the way.

They were heavily exposed to the smoke." (OSAGWI, 1998: End Note 138).

burn slowly after being hit by the firing pin – this resulted in rounds being stuck in the

gun barrel [of an A-10]. . . No protective gear was worn when these were being

dislodged. No prior training with DU rounds. Some rounds were broken open, crushed,

cracked after the misfire. He cannot estimate how much DU dust there was. . . He is

concerned about his exposure to DU, based on handling the misfired rounds and cleaning

out the barrels." (OSAGWI, 1998: End Note 139).

the branches who had first been triaged in the field. We would stabilize them before they

were flown out to hospitals in Germany and England. We had lots of patients who had

shrapnel wounds, but we were never aware that some of those wounds might have been

caused by depleted uranium, or that their wounds and clothes may have been

contaminated with uranium dust. We were never provided with any guidance about

depleted uranium contamination or the use of depleted uranium ammunition. We were

never informed that any of our patients had gone through decon (decontamination). We

never received one order requesting any testing for people who had potential exposures to

DU. We may have been exposed to DU from injured personnel, but none of us were ever

tested for DU exposure. I didn’t even learn about the use of depleted uranium

ammunition in Desert Storm until after I returned home." (Fahey, 1998).

bivouacked in kill zones in Kuwait that contained a lot of destroyed Iraqi vehicles. We

were never told about depleted uranium or that some of these vehicles may have been

contaminated. Guys were climbing all over destroyed tanks and checking them out. As a

corpsman, I was never told about depleted uranium ammunition or how to treat Marines

that might be wounded by DU." (Fahey, 1998).

had been hit with DU were ‘off limits.’ I was in dozens of tanks looking for souvenirs. I

remember picking up a gas mask lying on the floor of an Iraqi tank that was covered with

a fine powder and I brushed it off and put it on to pose for a picture a friend took. I

brought that mask home with me. I brought back helmet liners like everyone else did,

and some uniforms I found. I might have a couple of DU shell casings too." (Fahey,

2000).

19

concluded, I made numerous trips into Kuwait in support of the helicopters. During my

many trips, I took the opportunity to explore the destroyed tanks and vehicles in the Mile

of Death. At no time was I told that there might be any hazards other than live munitions

in the area. I have videotapes that document the exposures. I estimate that I spent a total

of 6 hours in contaminated areas exploring destroyed tanks and other equipment."

(Fahey, 2000).

guidance fax’d to them that instructed them to seal the tank and move downwind. It

never addressed what to do about ammunition on board. . . He said that [redacted] is a

retired LAR who has been real sick. Apparently [he] had more dealings with DU

contaminated equipment (downloading munitions) than any other LAR." (OSAGWI,

1998: End Note 89).

In-Theater Civilian, AMCCOM Radiation Control Team: "Many soldiers were

contaminated when they boarded to download munitions. They salvaged anything they

could salvage and wore no protective clothing or mask in the process. He said none of

the transporters knew of the hazard except for in the few cases when radioactive warning

stickers had been placed on contaminated systems. . . He reiterated that prior to his arrival

there was no fence and control at KKMC [King Khalid Military City, Saudi Arabia]. He

said they had no clue about contamination. People not even related to the site were

coming in to tour the battle damaged equipment." (OSAGWI, 1998: End Note 110).

In-Theater Civilian, AMCCOM Radiation Control Team: "[He] said that initially

there were a lot of people in and out of the equipment at KKMC including BDAT,

curiosity seekers and people seeking parts. . . Later on, he returned after the 11 July fire

at Doha. . . [He] saw young enlisteds out sweeping the area with brooms (after the UXOs

and debris had been cleared). [He] said he told [redacted] "That’s not something they

should be doing."" (OSAGWI, 1998: End Note 105).

When personal histories are gathered to estimate hazardous exposures, there is a

possibility of recall bias. However, the consistency of the experiences reported by Gulf

War veterans who served in different branches, in various locations, and at different

times indicates recall bias is probably insignificant.

As the veterans’ stories show, it is difficult to estimate the amount of depleted uranium

veterans may have inhaled, ingested, or absorbed through wound contamination. Some

veterans may have entered dozens of contaminated vehicles while others encountered

none. Some veterans may have inhaled significant amounts of DU oxides while others

had no exposure. At this point in time, we will probably never know the extent to which

Gulf War veterans were exposed to depleted uranium.

20

For the purposes of this discussion, a depleted uranium exposure may be defined as any

case in which a person was wounded by DU fragments and/or operated in close proximity

to depleted uranium dust or debris without the benefit of protective equipment. The

routes of exposure include injection, inhalation, ingestion, or absorption through wounds.

The routes of exposure mediate uptake and, along with metabolic characteristics of the

exposed person, determine the dose of the agent that reaches the target tissues in the

body. (IOM, 1994: 252).

The quantity, size, and form of aerosols created by an impact can vary considerably. The

Army Environmental Policy Institute notes that "tests designed to characterize the

aerosols created when a DU penetrator strikes a combat target found significant

differences in particle characteristics of the different types of rounds and different types

of targets." (AEPI, 1995: 93). Consequently, test data may be of limited use for

evaluating the health and environmental consequences of depleted uranium. (Ibid.: 93).

Nevertheless, U.S. Army test data shows that between 10 and 70 percent of the mass of a

depleted uranium penetrator oxidizes on impact. (Fahey, 1998: 179. AEPI, 1995: 78).

The impact of one 120mm M829A2 round fired by an Abrams tank against a hard target

would therefore create roughly 1–3 kg (2–7 lb) of depleted uranium dust, depending on

such variables as the type and terminal velocity of the round and the density of the target.

Army testing also found that "[t]he DU oxide aerosol formed during the impact of DU

into armor has a high percentage of respirable size particles (50 to 96%), and an

appreciable percentage of those respirable particles are readily soluble in lung fluids (17

to 48%)." (ARDEC, 1991).

After the Pentagon reluctantly admitted that thousands of veterans may have been

exposed to depleted uranium, the Office of the Special Assistant categorized DU

exposures into three theoretical levels. Level I veterans received the highest exposures,

we are told, and Level III veterans the lowest. (OSAGWI, 1998). However the Office of

the Special Assistant failed to justify the differences in exposures with any data or

research.

In a critique of OSAGWI’s DU report, the Presidential Special Oversight Board called

the exposure estimates "incomplete and misleading":

The interim DU report does not provide evidence showing that Level I exposures

are greater than Level II exposures or that Level II exposures are greater than

Level III. The report states, "Based on existing research, this entire group [Level

III] probably received minimal exposures" (p. 78), but the research supporting

this claim is not provided or discussed. (PSOB, 1999: 1.b.1)

The Special Oversight Board also pointed out that the Office of the Special Assistant

provided "misleading" estimates of potential exposures to soluble DU: "The [OSAGWI]

DU report indicates that soldiers in the worst case scenario could have inhaled 9 mg of

21

soluble DU; however, CHPPM’s study shows they could potentially inhale up to 25 mg

of soluble DU." (Ibid.: 1.b.3).

The Pentagon has produced a total of one exposure estimate that applies only to soldiers

inside vehicles at the time they are penetrated by depleted uranium rounds. The U.S.

Army Center for Health Promotion and Preventative Medicine (CHPPM) developed this

estimate based on a single live fire test in which tungsten alloy and depleted uranium

rounds were shot through a DU-armored tank. (BRL, 1989). CHPPM estimated a single

DU impact could result in an inhalation exposure of 12 mg (average) to 26 mg

(maximum); the estimate doubled to 24 mg (average) and 52 mg (maximum) if the tank

was hit by two DU rounds. (OSAGWI, 1998: 161). CHPPM also estimated intake by

hand-to-mouth transfer would be 16 mg of DU from a single impact and 32 mg from two

hits. (Ibid.: 161). CHPPM was unable to accurately estimate intakes of DU

contamination of wounds because of gaps in the available data on transfer of

contamination from surfaces to wounds. (Ibid.: 162).

A recent General Accounting Office inquiry confirmed the Oversight Board’s finding and

concluded that the Pentagon’s only exposure estimate is "unreliable because of

questionable assumptions used in the analysis." (GAO, 2000: 12). In response to

increasing pressure for realistic dose estimates, the Army plans to conduct new live-fire

testing and analysis. The results of this testing are not expected until sometime in 2001.

(Ibid.: 14).

The Army’s existing dose estimate, faulty though it may be, does indicate that soldiers in

vehicles hit by depleted uranium rounds could inhale or ingest unhealthy amounts of

depleted uranium, in addition to being wounded by or suffering wound contamination

from DU. In contrast to CHPPM’s estimation that a soldier in a tank might inhale 26 to

52 mg of DU aerosol in 15 minutes, the Nuclear Regulatory Commission established an

inhalation limit of 0.19 mg/day for the general public. (BRL, 1989: 18). The inhalation

limit for occupational workers is 2 mg/day. (RAND, 1999: 39). However, since the

Army conservatively treats soldiers as members of the general public with respect to

radiation exposure, dose estimates should only be evaluated in comparison to general

public exposure limits. (TACOM, 1998: 6).

After a vehicle is hit by a depleted uranium round, some of the aerosol drifts downwind.

A 1987 Army test showed that the impact’s smoke cloud would result in the highest

estimated intake of 0.3 mg at a distance of 10 meters. (BRL, 1989: 18). At 100 meters,

the maximum estimated intake outside the cloud path was 0.009 mg. (Ibid.: 21). This

data would seem to indicate there is little danger to troops outside a struck vehicle.

However, other Army test results show the hazards of depleted uranium persist long after

the impact.

In June 1995 at the Nevada Test Site, the Army’s Depleted Uranium Project fired 120mm

and 25mm DU rounds against Soviet armored equipment. Like the tests on which

CHPPM’s findings were based, the value of the data obtained by these tests is apparently

limited by technical difficulties, but several key findings were identified:

22

vehicles by DU penetrator impact. The concentration of airborne DU aerosol

decreases with time, but measurable concentrations of respirable particles remain

suspended hours later.

resuspended during routine personnel re-entry activities, and that the resuspended

aerosols contain particles of respirable sizes. (OSAGWI, 1998: 157).

These findings are especially relevant to the thousands of servicemen and women who

climbed on and entered contaminated equipment during recovery, maintenance, and

touring operations.

The Army Environmental Policy Institute has acknowledged the importance of obtaining

reliable information about DU resuspension:

The resuspension potential for the test cases is not comparable with that on the

battlefield. During a battle, multiple vehicles can provide a source for DU

particles (fires and impacts) or can mechanically resuspend DU by their

movements. Thus, without a firm grounding in aerosol mechanics theory, test

results are only valid for the testing conditions and cannot be generalized over

diverse environmental conditions (soil composition, vegetation, weather, etc.).

The Army needs to generate models that are sufficiently robust to provide

defensible estimates of the aerosol and particulate concentrations of DU on the

battlefield. (AEPI, 1995: 95).

A 1999 article in the journal Science and Global Security estimated that soldiers inside a

vehicle could inhale 50 or more milligrams of depleted uranium. (Fetter/von Hippel,

1999: 141). Using mathematical calculations, the authors determined that soldiers

downwind of vehicles struck by DU penetrators could inhale 0.08 to 0.3 mg. (Ibid.: 138).

In addition, the authors theorized that soldiers working inside contaminated vehicles

could be overexposed to resuspended depleted uranium dust. "This emphasizes the

importance of proper education, use of protective equipment, and preventing unprotected

individuals from entering contaminated vehicles or areas." (Ibid.: 142).

The concentrations of depleted uranium in and around destroyed equipment were not

widely measured after the Gulf War, though some contaminated equipment was noted to

pose a public health risk. One T-72 tank hit by two depleted uranium penetrators was

rejected for shipment to the United States because of "general external contamination"

and "general DU splatter and welded DU throughout the inside of the crew

compartment." (Fahey, 1998: 196). The Radiological Survey Report on this tank notes:

Tank could not be placed on public display without substantial risk to health and

safety of the public or members of the military. The primary health risks include

DU oxide respiration and radiological exposure through alpha and beta inspiration

23

and injection. The health hazards potential involved in the retrograde of this tank

outweigh the benefits. Tank was covered with a tarp. (Ibid.: 196).

Similarly, six Bradley Fighting Vehicles hit in friendly fire incidents were wrapped in

tarps and entombed in Saudi Arabia "due to levels of contamination and additional

mitigating factors." (AMCCOM, 1991: 4.O.). Fourteen Abrams tanks and nine

Bradley’s contaminated by DU impacts or fires were wrapped in tarps and shipped to the

Defense Consolidation Facility in Snelling, South Carolina, where a $4 million building

was constructed to decontaminate them. (AEPI, 1995: 87).

Despite the many uncertainties about the amounts of DU oxides veterans may have

inhaled, in 1999 the RAND Corporation released a Pentagon-funded report asserting that

in all cases, Gulf War veterans could not have inhaled enough depleted uranium to cause

any health problems. RAND co-author Dr. Naomi Harley recently stated that "it’s really

impossible to breathe in enough depleted uranium to do you any serious harm." (DoD,

2000). Dr. Harley’s statement might be true in cases where veterans had brief contact

with a single contaminated tank, but it may ring false in other cases where veterans

entered dozens of vehicles and removed parts or souvenirs. Nine years after the war,

there are simply too many uncertainties to draw any firm conclusions about the duration

and intensity of Gulf War depleted uranium exposures.

At approximately 10:20 am on July 11, 1991, a fire started inside a vehicle located in the

motor pool and ammunition storage area of the U.S. Army base at Doha, Kuwait. After

attempts to extinguish the fire failed, a series of explosions spread the blaze to nearby

vehicles and ammunition stockpiles. Explosions rocked the compound for six hours, and

the fires burned until 10:45 am on July 12. (CENTCOM, 1991). In the end, 102 vehicles

were damaged or destroyed, and more than two dozen buildings sustained damage.

Among the estimated $14 million in munitions damaged or destroyed in the fire were 660

120mm DU sabot rounds. (OSAGWI, 1998: 100).

rounds were beginning to cook off" two hours after the fire started. (SUPCOM, 1991:

Cavalry Regiment had been notified "to treat the area as though it were a chemical hazard

area; i.e. stay upwind and wear protective mask in the vicinity." (Ibid.: DCG #10).

Inexplicably, the soldiers at Doha were never informed about the hazard of burning

depleted uranium or instructed to wear respiratory protection.

Five hours after the fire started, the Operations Officer ordered an "Alpha Damage

Assessment" to "figure out total complacent area to be cordoned off." (SUPCOM, 1991:

34). Six hours later, "a team with equipment to conduct downwind monitoring for

‘Alpha’ radiation" was dispatched to Doha. (Ibid.: 44). However, for reasons that

remain unclear, no air monitoring of Doha fire smoke was apparently conducted. The

24

fate of the air monitoring effort is difficult to ascertain, in part because a huge section of

the SUPCOM logs are inexplicably ‘missing.’ (OSAGWI, 1998: End Note 206).

U.S. Army burn tests show that during severe fire conditions, depleted uranium rounds

may "slow cook" and completely oxidize into powder. (BNL, 1985. OSAGWI, 1998:

31). Burning depleted uranium produces aerosols of a different size and form than the

dust formed by impacts:

Small percentage of respirable-size dust particles (0.07% to 0.6%); those

respirable-size particles that are formed are essentially very insoluble in lung

fluids and, therefore, if inhaled, pose primarily a radiological, as opposed to a

chemical, toxicological hazard. This translates into upwards of 25 grams (<1

ounce) of DU particulates in respirable size being formed by a fire during the

heating of a DU penetrator tank munition. (ARDEC, 1991).

Approximately 111 of the DU tank rounds destroyed by the fire were located inside

destroyed Abrams tanks. The other 549 rounds were stored in ammunition storage

containers. These containers "exploded in fires that were of such sustained intensity that

steel howitzers and other equipment had melted, making it likely that many DU rounds

had been damaged by oxidation." (OSAGWI, 1998: 102). During post-fire clean up

operations, only approximately 250 DU penetrators from the containers were accounted

for, leaving the fate of approximately 300 rounds (1,450 kg/3,200 lb. of DU) unknown.

(Ibid.: 117).

The intensity and duration of the Doha fire dispersed depleted uranium around the

compound and downwind. "Hundreds of . . . troops may have received short-term

exposure to smoke from burning DU munitions stored in tanks or conexes. It is probable

that some DU particles were entrained in smoke that drifted over the soldiers who had

evacuated to the southern tip of the base." (OSAGWI, 1998: 27). The amount of

depleted uranium these soldiers might have inhaled is unknown and difficult to accurately

determine.

While fires still burned on the morning of July 12, someone at Doha requested twenty

empty 55 gallon drums for EOD teams to put depleted uranium fragments in.

Regiment command staff demonstrated their commitment to the health and safety of the

clean up crews:

As sections of the concrete pad were cleared of unexploded ordnance and DU,

regular troops were brought in to do a final cleanup using brooms and other hand

tools. These soldiers could have inhaled or ingested residual DU stirred up by

sweeping, and could also have picked up DU fragments. (OSAGWI, 1998: 78).

There is no record of any air monitoring being conducted while unprotected soldiers

swept the compound clean, and none of the Doha veterans were offered medical testing

until 1998.

25

complete the clean up were provided with respiratory and other protection:

When the entire North Compound and the sandy strip between the North and

South Compounds had been cleared, third-country nationals were hired to

perform the final sweeping of the motor pool pads. These individuals were

provided with dust masks, gloves, cotton overalls, and other personal protective

equipment, although the levels of radiation detected fell below the Army’s criteria

for donning M17 or similar gas-mask type respirators. (OSAGWI, 1998: 117).

We will probably never know why American soldiers were not informed about the DU

hazard at Doha, or provided with respiratory protection. The many uncertainties about

depleted uranium exposures during and after the Doha fire complicate efforts to develop

reliable dose estimates.

The results of soil and air sampling conducted after the war shed little light on the

ongoing hazard depleted uranium may pose to deployed American forces. Amazingly, in

1993 the Kuwaiti government declared that "Kuwait is free of radiation hazards resulting

from depleted uranium used in military activity during the Gulf War." (American

Embassy Kuwait, 1993). According to an American Embassy message:

Defense Minister Sheikh Ali Al-Sabah told the Parliament that a number of Iraqi

tanks had been found to be contaminated with depleted uranium as was a downed

Iraqi plane. All were removed. The Minister also stated that the Ministry of

Defense has surveyed all areas that were likely to be contaminated, but had found

no other sign of uranium contamination. (Ibid.).

Much of the contaminated equipment in Kuwait was transported to an area in the western

desert now called the Udairi "Boneyard." However, an area just to the north of the

Boneyard, known as the Udairi Training Range, was left intact after the war to provide

American soldiers and Marines with a realistic training environment. "The Udairi

Training Area is strewn with former Iraqi armament. Skeletons of Soviet-made T-54, T-

55, and T-72 armored vehicles litter the desert floor along with numerous armored

personnel carriers." (Leatherneck, 1998: 20).

Even though the Kuwaiti government declared its lands free of depleted uranium, the

U.S. Army investigated the matter in November 1994. A radiological survey in the

Boneyard showed that "a number of tanks exhibited activity levels 20 to 24 times above

background." (CENTCOM, 1994: 17). Inexplicably, the Army team failed to venture

into the Training Range where soldiers and Marines practice their combat skills. (Ibid.).

The Army survey team determined there was "no DU exposure hazard to military

26

there are no ongoing operations within the boneyard." (CENTCOM, 1994: 20, emphasis

added). In addition, the final report made the following recommendation:

Conduct further evaluation of any potential radiation exposure from the damaged

Iraqi tanks . . . if reclamation or other work is anticipated to be done in the

boneyard or if these tanks are to be moved from the boneyard. High volume air

sampling should be considered to determine if any airborne radioactive hazard

exists for personnel downwind from the boneyard during boneyard operations.

Radiation protection procedures should always be considered as part of any

worker Safety and Health Plan prior to beginning such work within the boneyard.

(Ibid.: 20).

If contaminated equipment in the boneyard presents a health hazard, it is plausible that

contaminated equipment in the training range could also constitute a danger.

A 1995 report, Estimating the Concentration of Uranium in Some Environmental

Samples in Kuwait After the 1991 Gulf War, concluded that "no significant contamination

of the Kuwait soil, water or atmosphere by depleted uranium was found." (Bou-Rabee,

1995). The twelve soil samples (none apparently gathered from the Udairi Training

Range) collected in the summer and winter indicated that "slightly higher uranium

concentration in solid dry fall-out and lower for the isotopic ratio (for summer air

particulate matter) can be explained by the relatively small contribution of depleted

uranium dispersed after the Gulf War." (Ibid.). Though depleted uranium was detected,

it was apparently sufficiently diluted to pose little threat to the Kuwait people.

In 1998 – five years after the Kuwaiti government declared its lands free of any depleted

uranium – the U.S. Army undertook a second round of soil sampling. A total of 22

surface soil samples were collected "from areas occupied or to be occupied by U.S.

forces." (CHPPM, 1998: 1). Unbelievably, the Army once again failed to take any soil

or wipe samples from the Udairi Training Range (see page 27). Only one soil sample

(collected from the Boneyard) showed elevated levels of depleted uranium.

The soil, wipe, and air sampling conducted between 1993 and 1998 indicate that there is

little ongoing hazard from depleted uranium except on or around contaminated

equipment. In a classic example of the ‘Don’t Look, Don’t Find’ philosophy, the Army

gathered soil and wipe samples from every area of Kuwait except the Udairi Training

Range where soldiers and Marines train amidst destroyed tanks and equipment. At this

point in time, the thousands of soldiers and Marines who have trained at Udairi may have

inhaled, ingested, or sufficiently dispersed the depleted uranium contamination to pose

little ongoing threat, but testing has neither confirmed nor denied this.

28

The complete absence of depleted uranium training, protection, and testing during and

after the Gulf War makes it difficult to accurately estimate veterans’ exposure levels.

Theoretical calculations can not replicate the conditions on a battlefield; Army testing can

not recreate every possible exposure scenario. The key to determining the extent of

depleted uranium exposures lies in the experiences of the veterans themselves, but even

this approach has its limits. At this point in time, it is in the best interests of the veterans

and consistent with known facts and historical precedent to presume veterans were

exposed to sufficient amounts of depleted uranium to cause health problems.

The duration of the possible exposure scenarios described by veterans ranges from a few

minutes to several months. The first combat units returned home in March 1991, and

American troops occupied portions of southern Iraq through April 1991. (AMCCOM,

1991: 5.J.). American forces set up permanent bases in Kuwait and continued to move

between Saudi Arabia, Iraq and Kuwait in the months after the war. The last U.S. ground

June 13, 1991. (OSAGWI, 1998: 98. PAC, 1996: 2). Hundreds of thousands of veterans

operated in areas where depleted uranium was released during the ground war. Many of

these veterans report they climbed on and entered multiple destroyed Iraqi vehicles

during and after the war.

The maximum duration of exposure for Gulf War conflict veterans is approximately four

months, however, exposures to internal organs can take place for many years following

an intake of depleted uranium. It is also possible that veterans and their families may

have been exposed to depleted uranium through contact with contaminated equipment

and souvenirs.

operations at Doha, Kuwait, an active U.S. Army installation to this day. During the

provided respiratory protection during clean up operations. Soldiers, sailors and Marines

deployed to Kuwait since 1991 have operated out of the Doha base. Combat units have

trained amidst destroyed Iraqi equipment at the Udairi Training Range.

The intensity of veterans’ exposures is difficult to determine. Friendly fire survivors and

support personnel could have received some of the highest DU exposures, but many other

veterans could have also been over-exposed in a range of possible exposure scenarios.

The only reason we are debating this point nine years after the war is because the

Pentagon repeatedly misled veterans and Federal investigations about the extent of

exposures to DU. At this point in time, it is virtually impossible to determine the

duration and intensity of Gulf War and post-conflict depleted uranium exposures.

There is an historic and legal precedent for granting a presumption of exposure to

depleted uranium. For more than fifteen years after the end of the Vietnam War, veterans

and the government argued over the extent of exposures to Agent Orange and other

29

herbicides. Ranch Hand and Chemical Corps veterans were suspected of having the

highest exposures to herbicides, and most other troops were believed to have had minimal

or no exposure. Surveys of Vietnam veterans who were not part of the Ranch Hand or

Chemical Corps groups indicate that only 25 to 55 percent self-reported an exposure to

herbicides. (IOM, 1998: 147).

However, in recognition of the many uncertainties about the duration and intensity of

Agent Orange exposures, Congress passed legislation granting a presumption of exposure

to herbicides for all Vietnam veterans:

For the purposes of this subsection, a veteran who, during active military, naval,

or air service, served in the Republic of Vietnam during the Vietnam era and has a

disease referred to in paragraph (1)(B) of this subsection shall be presumed to

have been exposed during such service to an herbicide agent containing dioxin or

2,4-dichlorophenoxyacetic acid, and may be presumed to have been exposed

during such service to any other chemical compound in an herbicide agent, unless

there is affirmative evidence to establish that the veteran was not exposed to any

such agent during that service. (PL 102-4: (2)).

Implicit within this presumption is the unwritten premise that veterans were exposed to

sufficient amounts of herbicides to deliver a dose to target organs large enough to cause

short-term (e.g., chloracne) and long-term (e.g., lung cancer, non-Hodgkins lymphoma)

health problems. Even though only half the veterans surveyed indicated they might have

been exposed to Agent Orange, Congress and the Department of Veterans Affairs

resolved the uncertainties about the duration and intensity of exposures in favor of the

veterans.

Gulf War veterans deserve the same level of consideration bestowed upon Vietnam

veterans. It is unfair to place the burden of proof upon the veteran to show that he or she

entered a given number of destroyed tanks, swept the Doha compound for a certain

amount of time, or trained in the Udairi Training Range for a set period. To do so would

be to penalize the veterans for the transgressions of their superior officers, who failed to

provide training, respiratory protection, or medical testing. When the benefit of the doubt

is resolved in favor of the veterans, the Institute of Medicine and the Department of

Veterans Affairs should presume that Gulf War veterans were not only exposed to

depleted uranium but also exposed to sufficient quantities to cause adverse health

problems. This presumption is consistent with the benefit of the doubt afforded to

Vietnam veterans.

The presumption of exposure to depleted uranium need not be unnecessarily extended to

those who served far from the battlefields. Certainly a sailor on a submarine in the Red

Sea or an air crewman flying high above Iraq from a base in Turkey are unlikely to have

been exposed to DU dust. However, given what we know today, it is justifiable and

prudent to extend a presumption of exposure to depleted uranium to all soldiers, sailors,

airmen, Marines and civilian contractors who served in or traveled to Saudi Arabia,

Kuwait and Iraq during the Gulf War conflict (August 2, 1990 to July 31, 1991). Further,

30

all soldiers and civilians present at the Doha fire and/or clean up, and all military and

civilian personnel who visited the Udairi Training Range from 1991 to the present,

should be included under the umbrella of presumptive exposures. In light of the

incomplete and misleading nature of Pentagon exposure estimates and the many

uncertainties about the extent of DU exposures, extending a presumption of exposure to

Gulf War veterans is right and just.

31

June 1995

The Institute of Medicine (IOM) has been tasked to summarize the strength of the

scientific literature concerning the association between exposure to a variety of biologic

and chemical agents during Gulf War service and a set of diseases or conditions

suspected to be associated with each exposure. (IOM, 2000). To investigate depleted

uranium and other suspected causes of veterans’ illnesses, the IOM created the

Committee on Health Effects Associated with Exposures During the Gulf War. The

committee’s recommendations will likely become the basis for Department of Veterans

Affairs determinations of the conditions for which veterans and their families can receive

service-connected disability and death benefits.

For each disease identified by the committee as possibly related to depleted uranium, the

committee will determine, to the extent that scientific data permit meaningful

determinations,

1. whether a statistical association with depleted uranium exists, taking into account the

strength of the scientific evidence and the appropriateness of the statistical and

epidemiological methods used to detect the association;

2. the increased risk of each disease among those exposed to depleted uranium during

Gulf War service; and

3. whether there exists a plausible biologic mechanism or other evidence of a causal

relationship between depleted uranium exposure and the disease.

When conducting a similar investigation of Agent Orange, the Institute of Medicine

reviewed not only peer-reviewed published literature, but also regulatory information,

information posted on the Internet, and other relevant documents. The IOM further noted

that its investigation of Agent Orange was greatly enhanced by "the input received both

in written and oral form from veterans and other interested persons at public hearings and

in written submissions." (IOM, 1998: 125). The IOM’s present investigation should

similarly review all relevant information and literature about depleted uranium and

depleted uranium exposures. There are many technical reports containing valuable

information about the health and environmental effects of depleted uranium which

deserve review even though they are not peer-reviewed, published medical research

reports.

Though the health effects of depleted uranium have not been extensively studied, there is

considerable literature on the effects of internal exposure to uranium compounds in

32

humans and animals. Human and animal studies have found links between uranium

compounds and systemic effects (e.g. respiratory, renal), immunological effects,

neurological problems, reproductive effects, developmental effects, genotoxic effects,

and cancer. (ATSDR, 1999). The Institute of Medicine is tasked with the weighty

responsibility of determining which of the known health outcomes may be related to Gulf

War depleted uranium exposures.

The Institute of Medicine must necessarily focus on a pragmatic question: What is the

nature of the relevant evidence for or against a statistical association between exposure

and the health outcome? The evidentiary basis for such a determination will inevitably

involve a review of epidemiological studies of populations with the same or similar

exposures. Since there has been relatively little study of populations exposed to depleted

uranium, a review of studies of populations exposed to natural uranium or other metals

with a similar toxicity will be necessary.

To determine whether an association exists, epidemiologists estimate the magnitude of an

appropriate quantitative measure (such as the relative risk or the odds ratio) that describes

the relationship between exposure and disease in defined populations or groups.

Determining whether an observed statistical association between exposure and a health

outcome is "real" requires additional scrutiny because there may be alternative

explanations for the outcome. These include error in the design, conduct, or analysis of

the investigation; bias, or a systematic tendency to distort the measure of association so

that it may not represent the true relation between exposure and outcome; confounding, or

distortion of the measure of association because another factor related to both exposure

and outcome has not been recognized or taken into account in the analysis; and chance,

the effect of random variation, which produces spurious associations that can, with a

known probability, sometimes depart widely from the true relation. (IOM, 1998: 127).

As with its investigation of Agent Orange, the Institute of Medicine is likely to evaluate

epidemiological studies on populations with occupational exposures to uranium. The

findings of these studies are equivocal about the causes of increased diseases, but error

and bias may have affected the outcomes. The Washington Post recently reported about

health problems among workers at the uranium processing plant in Paducah, Kentucky:

The mortality study of about 11,000 former workers at the plant was conducted by

the Oak Ridge Institute for Science and Education. Although the research

essentially was completed in 1994, funding for the study was dropped before it

could be peer reviewed and published in a scientific journal. The draft report,

obtained by the Washington Post, shows higher rates of death for all causes

among former workers. . . The study also shows higher rates of cancers of the

lung (19 percent) and bone (82 percent) among white male workers compared

with the general population. (Warrick, 1999).

33

Several factors could have skewed the results of this study (such as the inclusion of

individuals with extremely high exposures), but its existence demonstrates a possible

connection between occupational exposure to uranium and illness that was never fully

explored. "They hesitate to proceed to intensive studies [at Paducah] because of the

union’s use of this for hazard pay," notes a recently released Department of Energy

memorandum. (Warrick, 1999(a)).

In August 1999, following the press reports in the Washington Post, Secretary of Energy

Bill Richardson announced new studies of worker health at uranium plants in Paducah,

Portsmouth, Ohio and Oak Ridge, Tennessee. "We are initiating a comprehensive study

of worker medical history since the 1950s and we are instituting an immediate medical

surveillance program for current workers," said Richardson. (DOE, 1999) The Institute

of Medicine must bear in mind the possibility that error or bias may have influenced the

outcome of previous Federal or corporate epidemiological studies of worker and civilian

populations exposed to uranium.

An epidemiological study’s precision or statistical power is linked to the extent of the

exposure and the accuracy of its measurement. (IOM, 1998: 142). The absence of

reliable data about the degree of Gulf War depleted uranium exposures (duration and

intensity) will necessarily complicate comparison of epidemiological studies on exposed

populations to veterans. Nevertheless, uranium and depleted uranium exposure has been

found to be associated with health outcomes, and literature documenting these

associations will provide the committee with useful information.

Error and Bias in the RAND DU Report. The Pentagon promotes the 1999 RAND

review of literature on uranium as evidence that depleted uranium could not possibly be

affecting the health of Gulf War veterans. Though the Pentagon-funded RAND report

reviewed a substantial portion of the available literature on uranium’s health effects,

error and bias may have affected its interpretation of the applicability of the literature to

veterans’ health.

In 1999, the Pentagon’s Office of the Special Assistant touted the RAND report as proof

of no association between depleted uranium and veterans’ health: "At the low exposure

levels experienced by Gulf War veterans, the scientific literature available today does not

indicate negative health effects due to the chemical toxicity of depleted uranium."

(OSAGWI, 1999, emphasis added) C. Ross Anthony, coordinator of the RAND report,

echoed the Pentagon’s declaration: "At the levels of exposure that I’m aware of, and

unless there is something that I’m not aware of, the scientific literature does not find that

there is a negative health effect." (OSAGWI, 1999(a)).

Such definitive statements of disassociation are, in reality, indefensible in light of the

unreliability of Army exposure estimates and the virtual absence of any other data on the

exposure levels experienced by Gulf War veterans. It is possible, therefore, that RAND’s

34

reliance upon "incomplete and misleading" exposure estimates may have adversely

affected the design, conduct, or analysis of the investigation (error).

The RAND report may also be flawed due to a conflict of interest among the authors.

Specifically, one of the five authors, Arlene Hudson, "assisted with important

background drafting and research" of the RAND report while simultaneously working for

the Pentagon’s Office of the Special Assistant for Gulf War Illnesses. (RAND, 1999:

120). In addition to promoting the continued use of depleted uranium munitions, Ms.

Hudson’s superiors at the Office of the Special Assistant have publicized exposure

estimates they knew to be incomplete and misleading. The presence of an OSAGWI staff

person on the RAND review team represents a clear conflict of interest. Given

OSAGWI’s past actions, it is reasonable to believe that OSAGWI’s influence of the

RAND report could have resulted in a systematic tendency to distort the measure of

association so that it may not represent the true relation between exposure and outcome

(bias).

In July 1999 testimony to the Presidential Special Oversight Board, RAND co-author

Naomi Harley demonstrated a fundamental lack of knowledge about depleted uranium:

"I don't know if anybody knows why it doesn't cross the blood/brain barrier as well.

That's research. But it doesn't. So you have not seen any neurological effects from

uranium." (PSOB, 1999(a)). In contrast to Dr. Harley’s strident assertion, depleted

uranium research that RAND claimed to review clearly shows that not only does depleted

uranium cross the blood/brain barrier, it has also caused neurological effects in human

and animal studies. (Pellmar et al., 1999. Pellmar et al., 1999(b). McDiarmid et al.,

2000). Dr. Harley’s ignorance of depleted uranium research that RAND supposedly

reviewed may have adversely affected the design, conduct, or analysis of the

investigation (error).

RAND’s presentation of information about veterans’ exposure levels provides further

evidence of possible error and bias. RAND describes an inhalation dose of 2 mg as

"unreasonable," and states an ingestion of 1 mg is "unlikely." (RAND, 1999: 39, 49).

However, the Army has estimated that soldiers inside a vehicle struck by a two DU

rounds could inhale 52 mg and ingest 32 mg of DU, significantly higher than the amounts

RAND asserts are likely to occur.

In describing military studies of DU in rats, RAND states "the lowest dose to which rats

were exposed is reported greater than the highest possible DU levels observed in Persian

Gulf veterans." (RAND, 1999: 67). However, a scientific report that RAND claimed to

have reviewed reports that urinary uranium levels in the lose-dose rats were comparable

to the levels seen in soldiers retaining DU fragments. (Pellmar et al., 1999(b)). This

could be a subtle difference in wording and presentation, or it could be just another

example of pervasive flaws in the analysis of the investigation that may distort the true

relation between exposure and outcome (error and bias).

The Pentagon hired the RAND Corporation to write a report about depleted uranium, and

then it conveniently placed a staff person from its Gulf War illness investigation amongst

35

the authors. In the course of RAND’s review, systematic error and bias may have

obscured possible relationships between depleted uranium exposures and veterans’

current and future health problems. The RAND DU report is hardly the independent

analysis that the Pentagon claims. The myriad problems with the RAND depleted

uranium report significantly limit its applicability to the study of Gulf War veterans’

illnesses.

This question, which is pertinent if there is evidence of a positive association between

exposure and a health outcome, concerns the likely magnitude of the association in Gulf

War veterans exposed to depleted uranium. The most desirable evidence in answering

this type of question involves knowledge of the rate of occurrence of the disease in those

Gulf War veterans who were actually exposed to depleted uranium, the rate in those

veterans who were not exposed (the "background" rate of the disease in the population of

Gulf War veterans), and the degree to which any other differences between exposed and

unexposed groups of veterans influence the difference in rates.

Where exposure levels among Gulf War veterans have not been adequately determined,

which is the case for all veterans except the few dozen examined by the VA, this question

becomes difficult to answer. Further complicating this assessment is the possibility that

cancers and other diseases with long latency periods have not yet manifested in Gulf War

veterans to a statistically significant degree.

Biologic plausibility is the extent to which a statistical association is consistent with

existing biological or medical knowledge. (IOM, 1998: 128). The likelihood that an

exposure-health outcome relationship reflects a true association in humans depends on

evidence of the relationship in cellular, animal, and human studies.

For Gulf War veterans, the routes of exposure that may result in health outcomes are

injection, inhalation, ingestion, and wound contamination. Of these exposures, injection

of fragments and inhalation of oxides appear to be the most hazardous to human health,

though the clinical significance of each type of exposure remains uncertain due to the

lack of research on depleted uranium.

The VA’s Depleted Uranium Program reports that some of the veterans who retain

depleted uranium fragments were excreting elevated levels of urinary uranium 7 years

after first exposure (range 0.01-30.7 µg/g creatinine vs. 0.01-0.05 µg/g creatinine in a

36

non-exposed group). (McDiarmid et. al., 2000). This finding suggests that the depleted

uranium fragments are dissolving and entering the bloodstream, resulting in chronic

systemic exposure. Interestingly, several friendly fire veterans who do not retain DU

fragments have urinary uranium values well above the highest non-exposed persons’

value. One member of this group may have DU residue from some removed shrapnel,

but the source of the elevated urinary uranium levels in the other veterans is unknown.

(Ibid.).

The Armed Forces Radiobiology Research Institute studied the distribution of dissolving

depleted uranium originating from fragments implanted in Sprague Dawley rats.

Researchers determined that depleted uranium deposits in the greatest amounts in the

kidney and bone (tibia and skull), though many other tissues (muscle, spleen, liver, heart,

lung, teeth, brain, lymph nodes, and testicles) "contained significant concentrations of

uranium." (Pellmar et. al., 1999). "The accumulations in brain, lymph nodes, and

testicles suggest the potential for unanticipated physiological consequences of exposure

to uranium through this route." (Ibid.).

The toxicity of inhaled depleted uranium depends largely upon the size and solubility of

the oxides. The quantity, size, and solubility of oxides created by an impact may vary

considerably, but the aerosol is generally understood to contain a high percentage of

respirable size particles (50 to 96%), with most of the respirable size particles being

insoluble in lung fluid (52 to 83%). (ARDEC, 1991). Respirable-size insoluble particles

may deposit in various lung compartments and remain there for years. (ATSDR, 1999:

8). Insoluble depleted uranium in lung tissue may lead to increased incidence of

respiratory disorders, while the soluble particles are less toxic to the lungs but more toxic

systemically due to easier absorption from the lungs into the blood and transportation to

distal organs. (ATSDR, 1999: 26).

An ingestion exposure could occur through intake of contaminated food or water or

through hand-to-mouth contact. In addition, some of the larger inhaled particles will be

cleared from the lungs by mucociliary action, swallowed, and eventually reach the

gastrointestinal (GI) tract. (RAND, 1999: 40). In general, the water-soluble compounds

are more toxic by the oral route because of the greater ease of absorption in the

gastrointestinal tract. (ATSDR, 1999: 92).

Depleted uranium particles created by impacts or fires may also contaminate wounds.

Once in a wound, depleted uranium particles could directly enter the bloodstream. There

is insufficient data available on the transfer of contamination from air and surfaces to

wounds to estimate intakes from this route of exposure. (OSAGWI, 1998: 162).

Once inside the body, depleted uranium presents both radiological and chemical toxicity

hazards. Current scientific and medical knowledge suggests depleted uranium’s chemical

toxicity is of greater concern than its high-energy but poorly penetrating alpha radiation.

(McDiarmid et. al., 2000). There is considerable controversy, however, over the health

effects of low, chronic doses of internal radiation. In addition, the potential for health

effects from an acute exposure to low or medium levels of uranium or depleted uranium

37

is uncertain. Further study is needed to understand the characteristics of DU oxides, the

health effects of internalized depleted uranium, and the extrapolation of study findings

from animals to humans.

can be excreted. Animal and human studies show that uranium is damaging to the

kidney, exerting its toxic effect by chemical action mostly in the proximal tubules.

(ATSDR, 1999: 74). The Health Physics Society estimates that the thresholds for

transient and permanent kidney damage in humans are 8 and 40 mg of inhaled soluble

uranium aerosol, respectively. (RAND, 1999: 33).

Animal data clearly demonstrates renal damage from uranium, but evidence of damage in

humans is less consistent. Delayed effects were observed in a male worker exposed to a

high concentration of uranium tetrafluoride for 5 minutes in a closed room. (ATSDR,

1999: 75). Nephrotoxic effects began 68 days after exposure and persisted through day

1,065 but gradually diminished. Renal effects were not observed, however, among a

group of workers who accidentally inhaled an estimated 0.47 to 24 mg of uranium.

(Ibid.).

Human and animal studies demonstrate that the kidney can regenerate damaged tubular

epithelium, thereby minimizing adverse clinical outcomes. (RAND, 1999: 34).

However, "workers who have previously been exposed to uranium may be at greater risk

in the event of subsequent kidney disease than unexposed workers." (AMCCOM, 1990:

D(2); 1-10).

Kidney problems have not been identified in statistically significant levels among 29

friendly fire veterans in the DU Program. This finding may prompt a re-evaluation of the

kidney as the target organ for uranium’s first effects. "It may be at these relatively lower

exposure concentrations, the kidney is not the critical organ and that another, possibly the

neurological or reproductive system, is the ‘sentinel’ organ system, the system first

perturbed biochemically." (McDiarmid et al., 2000). This finding is supported by

AFRRI research showing DU-implanted rats showed physiological changes in the brain

without exhibiting any signs of kidney toxicity. (Pellmar et al., 1999(b)).

Despite these findings, some Gulf War veterans have reported acute and delayed kidney

permanent kidney damage after working inside contaminated American vehicles for a

period of several weeks. (Fahey, 1998: 126). Another Marine Corps veteran similarly

suffered kidney damage shortly after returning home from Operation Desert Storm.

(Ibid.: 103).

38

Respiratory Disease. The potential for respiratory problems depends upon the size,

solubility, and amount of depleted uranium dust inhaled. Since most of the aerosols

created by a DU impact are respirable in size, there is a potential for adverse clinical

outcomes. In acute exposures, respiratory disease may be limited to lung tissue damage,

eventually leading to emphysema or pulmonary fibrosis. (ATSDR, 1999: 65). Several

epidemiological studies have reported respiratory diseases in uranium mine and mill

workers, who were also exposed to significant amounts of dust and other lung irritants,

but not in uranium processing workers, who were not exposed to these potential

aggravants. (Ibid.: 66).

It has been suggested that inhalation of the exceptionally fine sand dust of the Central and

Eastern Saudi Arabian peninsula could have caused respiratory problems among Gulf

War veterans. (Korenyi-Both, 1997). It is possible that inhalation of fine sand along

with depleted uranium oxides, oil well fire smoke, and low levels of chemical warfare

agents could be contributing to respiratory ailments among Gulf War veterans.

Despite the fact that Congress ordered the Department of Defense to research the effects

of inhaled depleted uranium on Gulf War veterans in 1993, no inhalation research has

even started. (PL 103-160: II.E.(271)). The lack of research on inhaled depleted

uranium, combined with the absence of any reliable inhalation dose estimates,

complicates an evaluation of the role of DU in veterans’ respiratory problems.

In February 2000, the Army Medical Research and Material Command solicited research

proposals for studies on the biological effects of depleted uranium and other heavy metals

used in munitions. The announcement requested proposals for the study of pulmonary,

hepatic, renal, and nervous systems from particulate and solubilized forms of depleted

uranium. (AMRMC, 2000) The findings of this research, which will take several years

to complete, will undoubtedly shed further light on the possible relationship between

depleted uranium and respiratory diseases and other ailments.

Immunological Effects. Recent research from the Armed Forces Radiobiology Research

Institute found uranium concentrations in lymph nodes of DU exposed rats significantly

higher than those observed in tissues collected from control animals. This finding is

confirmed by other animal studies showing immune system damage following chronic

uranium exposure. "Impaired immune function resulting from the chronic accumulation

of uranium in the lymphatic system as well as in bones and spleen might be a possible

consequence of prolonged exposure to DU fragments." (Pellmar et. al., 1999).

Another study on rats exposed to uranium dust showed a rise in the number of

eosinophils in the blood. (ATSDR, 1999: 82). An abnormal increase in the number of

eosinophils in the blood is characteristic of allergic states and various parasitic infections.

Interestingly, the DU Program found elevated eosinophils in the highest exposed veterans

at a rate that approached a statistical significance. (McDiarmid et. al., 2000).

39

One study of uranium industry workers did not find evidence of immune system effects

associated with inhalation of uranium. (RAND, 1999: 32). Nevertheless, the findings of

research on rats and veterans warrant further investigation of the possible association

between depleted uranium and immune system damage.

Neurological Problems. In 1997 the VA tested the neurocognitive functioning in 29

friendly fire veterans. The findings suggested a statistical relationship between the high

urinary uranium values and poor performance on automated tests assessing performance

efficiency and accuracy. (McDiarmid et al., 2000). Since traditional neurocognitive tests

did not show the same statistical result, the clinical significance of this finding is unclear.

In a parallel study, the Armed Forces Radiobiology Research Institute found that depleted

uranium crossed the blood-brain barrier and deposited in the hippocampus of implanted

rats. AFRRI research found that in rats with medium and high DU exposures, uranium

concentrations in the motor cortex, frontal cortex, midbrain, and vermis were statistically

greater from those in tantalum controls. Uranium concentrations in the cerebellum were

only significant in the high-dose group. (Pellmar et al., 1999). Changes in the

electrophysiological potentials in the hippocampus of animals exposed to varying

quantities of DU pellets suggest that behavioral and/or neurological deficits could be a

consequence of prolonged exposures in injured soldiers. (Pellmar et al., 1999(b)). The

changes that occurred with exposure in the low dose animals were not statistically

different from those that occurred with exposure in the high dose group.

For inhalation exposures, normal mental function was acutely disrupted in three workers

accidentally exposed to a cloud of soluble uranium compounds. (Pellmar et al., 1999(b)).

Another study linked the handling of a uranium bar and a subsequent increase in stool

uranium with foot cramps, leg pain, and abnormal gait. (Ibid.). A retrospective study

found more deaths than expected from central and peripheral nervous system diseases in

employees in a nuclear fuels fabrication plant, though the employees were also exposed

to other radiological and chemical agents in addition to uranium. (ATSDR, 1999: 83).

Reproductive Effects. In 1997 the Depleted Uranium Program tested the semen of 17

DU-exposed veterans and 5 non-exposed cohorts. Elevated levels of uranium in semen

were found in 5 out of the 17 exposed veterans; the controls showed no signs of uranium

in semen. (McDiarmid et al., 2000). This is consistent with AFRRI’s finding of a dosedependent

increase of uranium in the testicles of implanted rats. (Pellmar et al., 1999).

"The biologic plausibility of uranium’s entry into semen from the prostate and other

organs and these preliminary findings suggest that the evaluation of uranium in semen be

considered in future medical follow-up." (Ibid.).

A statistically significant relationship between high concentrations of the reproductive

hormone prolactin and high urinary uranium was observed in the exposed veterans.

Several of the veterans’ values required medical evaluation, but many prolactin values

40

were at the high end of normal without any apparent clinical effects. (McDiarmid et al.,

2000). Evaluation of semen characteristics showed no apparent uranium effect.

The findings of uranium and abnormal prolactin levels in veterans’ semen occur in the

context of no known birth defects in the approximately 20 pregnancies fathered by DUexposed

veterans since 1991. (McDiarmid et al., 2000). However, this finding must also

be placed in the context that the veterans studied are less than a third of the friendly fire

veterans, and only a small fraction of the overall numbers of veterans potentially exposed

to depleted uranium.

Inhalation studies do not show a clear link to reproductive effects. Three studies of

uranium mine workers found more first-born female children than expected, suggesting

chromosomal damage, but the miners were also exposed to a variety of chemical toxins.

(ATSDR, 1999: 84). Male mice fed uranium in drinking water for 64 days showed a

decrease in the rate of impregnation of untreated females, though these effects were not

dose dependent. (Pellmar et al., 1999). Chronic ingestion studies of animals show

evidence of testicular damage. (ATSDR, 1999: 134. Pellmar et al., 1999).

The RAND report states: "to the extent that reproductive health issues related to uranium

have been investigated to date, there have not been findings that would suggest a

relationship between levels of exposure that could have occurred in the Persian Gulf and

those that are associated with adverse outcomes in animal experiments." (RAND, 1999:

67, emphasis added). Though there is no reliable data on the levels of exposure that

occurred in the Gulf War, RAND notes that further studies are underway, "particularly

evaluating the impact of uranium on male reproductive health." (Ibid.).

Sadly, studies on the reproductive effects of uranium often focus almost exclusively on

male workers and male rats. On the modern battlefield, women often operate alongside

men, making them equally susceptible to exposure to depleted uranium and other toxins.

The legacy of the use of depleted uranium in the Gulf and Kosovo wars includes probable

exposures among civilian women, children, and men. There is sufficient evidence to

justify future studies of the reproductive effects of depleted uranium on both men and

women.

Developmental Effects. The Armed Forces Radiobiology Research Institute studied the

effects of depleted uranium on fetal development in Sprague Dawley rats. Female rats

were impregnated after being implanted with varying levels of depleted uranium and/or

tantalum pellets. The study found that uranium accumulates in the placenta and fetus of

DU-implanted rats. Preliminary evidence of decreased litter size in animals implanted

with high levels of depleted uranium was also observed. (McClain, 1999).

There is a lack of information concerning maternal toxicity, embryotoxicity, fetotoxicity,

and teratogenicity of uranium in mammals. Several studies of mice that ingested high

levels of uranium show a variety of effects including reduced fetal body weight and

41

length, and an increased incidence of malformations and developmental variations.

(Domingo, 1993: 707. ATSDR, 1999: 206).

The animal studies examining developmental effects involved relatively high doses of

depleted uranium and uranium. It is not clear whether low and medium doses will cause

similar effects, or if the findings of animal studies can be extrapolated to humans.

Genotoxic Effects. Because uranium is predominantly an alpha-emitting element,

current theories on gene mutation and chromosomal aberrations suggest a concern for

genotoxicity (damage to cells) from uranium’s radioactivity. (ATSDR, 1999: 207).

AFRRI research on Sprague Dawley rats implanted with depleted uranium pellets found

that urine with a high DU content is mutagenic. (Miller, 1998). Even the lowest number

of implanted DU pellets resulted in mutagenic urine as the pellet exposure time increased.

A parallel AFRRI in vitro study found that depleted uranium transforms human cells to

the tumorigenic phenotype, indicating that "the risk of cancer induction from internalized

DU exposure may be comparable to other biologically reactive and carcinogenic heavymetal

compounds." (Miller, 1998(b)). The transformed cells produced tumors when

injected into mice; they also induce genetic instability, and reduce production of the Rb

tumor-suppressor protein. "Based on these in vitro results, the carcinogenic potential of

internalized DU remains a concern and warrants additional studies with experimental

animals." (Ibid.).

The 1997 test results of 29 of the friendly fire veterans showed frequencies of

chromosomal aberrations similar to those seen in external control populations.

(McDiarmid et al., 2000). An increase in sister chromatid exchange (SCE) among the

friendly fire veterans who do not retain DU fragments was not statistically significant.

"These endpoints, however, deserve repeating in future assessments to examine any

effect of additional years of chronic exposure to retained DU." (Ibid.).

Cancer. If an agent is carcinogenic, it may increase the chance of cancer occurring, or it

may accelerate development of the cancer so that it occurs at a younger age than it

otherwise would have. The agent may also influence the likelihood that the cancer

results in death or may shorten the time between occurrence of the disease and death

caused by that disease. (IOM, 1998: 410).

The effect of the timing of the exposure on the subsequent risk of disease is known as

latency. The timing of exposure often plays an important role in determining when and

by how much the eventual disease risk is increased (or decreased) by the exposure. For

exposures of short duration, time since exposure is in many cases easy to define.

However, even brief inhalation exposures can produce protracted exposure of many

organs in the body. (IOM, 1998: 408). Cancers associated with internalized uranium

may not develop until 20 to 30 years after initial exposure. (Xia, 1998: 2038).

42

Current research indicates that depleted uranium’s carcinogenicity may be comparable

with other heavy metals known to induce cancer, such as nickel and lead. An in vitro

study found that depleted uranium transformed human cells to the tumorigenic

phenotype; these cells produced tumors when injected into mice. (Miller, 1998(b)).

Based on this finding, the Armed Forces Radiobiology Research Institute states there is

strong evidence to support a detailed study of depleted uranium’s potential to cause

cancer. (McClain, 1999).

One study on mice examined the potential for carcinogenicity by administration of

uranium by parenteral (intravenous or intramuscular) routes. The parenteral route is

analogous to the condition in which uranium compounds enter cuts, wounds, abrasions,

and ulcers in large quantities. Following the administration of uranium, significant

numbers of sarcomas were found in the experimental mice. Investigators were unable to

ascertain whether uranium’s chemical toxicity or radioactivity caused the tumors.

However, their observations indicate that localized uranium deposits in tissues of rats

created a high concentration of uranium in the surrounding areas, and the prolonged

action of the uranium on cells in the immediate vicinity causes tumors. (ATSDR, 1999:

211).

While there is evidence of increased lung cancer rates among workers exposed to

uranium dust, the scientific community has been unable to link the increases to a specific

cause because in many cases the workers were also exposed to cigarette smoke, radon,

radium, thorium, and silica and other dusts. (ATSDR, 1999: 211).

Radon is most often blamed for lung cancers in uranium miners, but there is evidence

inhalation of uranium could also be responsible. In a study of 120 uranium miners who

died from primary cancer of the lungs, squamous cell metaplasia progressed over time

and developed into neoplasia (tumors) of the lungs in 15-20 years. However, a study that

reviewed efforts to test uranium miners concluded that radon progeny exposure may not

cause any type of lung tumor other than the so-called small-cell (oat cell) carcinoma. The

incidence of oat cell cancer of the lungs has decreased over the last 20 years and currently

accounts for slightly more than 22% of developing neoplasia in uranium miners.

(ATSDR, 1999: 87). Another study determined that total radon exposure was not related

to an excess of lung cancers in underground uranium miners from the Grants, New

Mexico area. (Ibid.).

A study of miners in northern Ontario with previous inhalation exposure to uranium dust

and a diagnosis of lung cancer found a linear relationship between uranium dose and

incidence of lung cancer. (ATSDR, 1999: 88). A study of 3,699 Canadian uranium

workers found a statistically significant association between inhalation exposure to

uranium dust and the development of lung cancer, though radon was present in the mines

in greater amounts than airborne uranium. (Ibid.: 89). A study of 16 Navajo uranium

miners who developed lung cancer concluded the cancers were attributable to radon and

its decay products; uranium exposure and cigarette smoking were ruled out as causes.

(Ibid.: 89).

43

A study of lung cancer rates near the Fernald Materials Processing Center in Hamilton

County, Ohio shows "substantially increased lung cancer death rates in Hamilton county

[compared to the rest of Ohio] over the whole time period [1968-1988], and rates in all

four [neighboring] counties that appear to be rising more rapidly than the statewide

average." (Xia, 1998: 2035). When the Fernald plant was an operating uranium refinery

producing uranium metal, uranium dust may have been released into nearby communities

due to inadequate filtration and ventilation systems. (Ibid.: 2027). The Fernald site is

now so contaminated that it has been declared a federal Superfund site. (Wolbarst,

1999). "Since a 20-30 year lag between uranium dust inhalation and death from lung

cancer is consistent with known disease etiology, [o]ur results suggest continued

monitoring of cancer rates in the area." (Xia, 1998: 2038).

The Washington Post discovered an unpublished report on 11,000 Oak Ridge workers

which showed higher rates of cancers of the lung (19 percent) and bone (82 percent)

among white male workers compared with the general population. (Warrick, 1999(b)).

Other published studies of uranium mills and metal processing plant workers have either

found no excess cancer or attributed excess lung cancers to other known carcinogens

(radon, cigarette smoke) rather than to uranium. (RAND, 1999: 35).

A study of the communities surrounding the Starmet (formerly Nuclear Metals) plant in

Concord, Massachusetts where depleted uranium ammunition was manufactured showed

statistically significant increases in multiple myeloma in males and thyroid cancer in

males and females. (MDPH/BEHA, 1997: 14). No significant increases in lung or bone

cancer were identified.

Development of lymphatic malignancies (other than leukemia) has been associated with

inhalation exposure to uranium and its decay products. In a study of 2,002 uranium

millers, 6 deaths from lymphatic malignancies occurred when 2.6 were expected. The

latency period was 20 years. Another study of uranium mill workers found a slight

increase in deaths from tumors of the lymphatic and hematopoietic tissue. The authors

suggested the increase might be due to irradiation of the lymph nodes by thorium-230, a

decay product of uranium-234 and a member of the uranium-238 decay chain. (ATSDR,

1999: 90).

Excess risk of leukemia mortality was observed in communities surrounding uranium

processing facilities in Andujar and Ciudad Rodrigo, Spain. (Lopez-Abente et al., 1999).

One study identified an excess of leukemia deaths among American uranium workers but

was unable to determine if there was an association with radiation. (RAND, 1999: 36).

Because depleted uranium is known to deposit in bone, there is a potential for increased

risk of bone cancer. However, the available human studies do not suggest a connection

between the development of bone sarcomas and exposure to uranium. (ATSDR, 1999:

90). Nevertheless, one of the Gulf War friendly fire veterans wounded by depleted

uranium recently developed a tumor in his left humerus (the long bone of the upper arm

extending from the shoulder to the elbow), which was surgically removed. (Fahey,

44

2000). The development of bone tumors or cancers among Gulf War veterans exposed to

depleted uranium should be investigated.

Credible scientific evidence suggests that internal exposure to depleted uranium may

result in cancer. However, the absence of reliable exposure data for Gulf War veterans

complicates efforts to estimate whether excess cancers are expected. Many cancers are

known to have a 20-30 year latency period. Since only 9 years have elapsed since

Operation Desert Storm, cancers may not have manifested in veterans or civilian

contractors to a statistically significant degree. Exposure to depleted uranium could

result in an increase of cancers among veterans, or it could be a contributing cause to

such an increase. Only time will tell.

Children’s Susceptibility. Children are not small adults. Children’s unique physiology

and behavior can influence the extent of their exposure. Children may be more or less

susceptible than adults to health effects, and the relationship may change with

developmental age. (ATSDR, 1999: 212).

Vulnerability often depends on developmental stage. There are critical periods of

structural and functional development during both pre-natal and post-natal life and a

particular structure or function will be most sensitive to disruption during its critical

period(s). Damage may not be evident until a later stage of development. (ATSDR,

1999: 212).

Absorption of uranium may be different in children because of the immaturity of their

gastrointestinal tract; the gastrointestinal absorption of lead is greatest in infants and

young children. (ATSDR, 1999: 212). Infants have an immature blood-brain barrier and

probably an immature blood-testis barrier. (Ibid.). In animal studies depleted uranium

was shown to cross the blood-brain barrier and deposit in the testicles. (Pellmar et al.,

1999).

There may be differences in excretion of chemicals, particularly in the newborn whose

kidneys have not fully developed. Children and adults may differ in their capacity to

repair damage from chemical insults. Children also have a longer remaining lifetime in

which to express damage from chemicals; this potential is particularly relevant to cancer.

(ATSDR, 1999: 213).

Information on the absorption, distribution, metabolism, and excretion of uranium in

children is very limited. Since the skeletons of children are growing (higher rate of bone

formation), it is possible that a higher fraction of circulating uranium will be deposited in

bone than in adults. The fractional absorption of uranium by ingestion was higher in

newborn swine and rats than in adult animals. (ATSDR, 1999: 214).

The Armed Forces Radiobiology Research Institute studied the effects of depleted

uranium on fetal development in Sprague Dawley rats. Female rats were impregnated

after being implanted with varying levels of depleted uranium and/or tantalum pellets.

45

The study found that uranium accumulates in the placenta and fetus of DU-implanted

rats. Preliminary evidence of decreased litter size in animals implanted with high levels

of depleted uranium was also observed. (McClain, 1999).

There is a lack of information concerning maternal toxicity, embryotoxicity, fetotoxicity,

and teratogenicity of uranium in mammals. Several studies of mice that ingested high

levels of uranium show a variety of effects including reduced fetal body weight and

length, and an increased incidence of malformations and developmental variations.

(Domingo, 1993: 707. ATSDR, 1999: 206).

No studies have apparently examined uranium in breast milk. Based on the chemical

properties of uranium, it seems unlikely that there would be preferential distribution from

the blood to a woman’s breasts. However, it is not known if maternal bone stores of

uranium (like those of calcium and lead) are mobilized during pregnancy and lactation.

(ATSDR, 1999: 214).

Undiagnosed Illnesses. Gulf War illnesses (a.k.a. Gulf War Syndrome) is a generic term

for the array of health problems affecting tens of thousands of veterans from the United

States, United Kingdom, Canada, and other countries. Current scientific and medical

knowledge suggests that veterans’ diagnosed and undiagnosed health problems are the

result of the combined effects of several chemical and biologic exposures, rather than

being a unified illness with a single cause.

As of February 2000, approximately 132,749 Gulf War veterans have participated in the

2000. DoD, 2000(a)). As of February 1999, about 80.1 percent of the Gulf War veterans

on the combined VA registry had symptoms diagnosed by VA physicians, leaving

approximately 19.9 percent with undiagnosed symptoms. (VA, 2000). Among the most

commonly reported symptoms are fatigue, skin rash, headache, muscle and joint pain,

memory loss, and shortness of breath. (VA, 1998(a)).

Neither the Department of Veterans Affairs nor the Department of Defense have

scientifically studied the possible relationship between exposure to depleted uranium and

the undiagnosed illnesses affecting 20% of sick veterans. Nonetheless, OSAGWI’s

August 1998 DU report summarily ruled out depleted uranium as a cause of undiagnosed

illnesses:

The report’s bottom line conclusion, based on a comprehensive review of

available data and a science-based methodology, is that exposures to DU’s heavy

metal (chemical) toxicity or low-level radiation are not a cause of the undiagnosed

illnesses afflicting some Gulf War veterans. (OSAGWI, 1998: 44).

46

In a glaring oversight, OSAGWI’s report failed to discuss any possible link between DU

exposure and the diagnosed conditions affecting fully four out of every five sick veterans.

As with many statements about depleted uranium made by the Office of the Special

Assistant, scant evidence was provided to support the report’s conclusion. To its credit,

the Presidential Special Oversight Board recognized the flaws in OSAGWI’s

proclamation. In a surprisingly frank critique of OSAGWI’s DU report, the Oversight

Board determined that "[t]he interim Depleted Uranium (DU) exposure report does not

demonstrate adequate support for its bottom line conclusion." (PSOB, 1999).

Specifically, the Oversight Board noted that most of the individuals who were potentially

exposed have not been clinically evaluated; exposure assessments are incomplete and

misleading; toxicity assessments are incomplete; and research used to support key

statements and conclusions is preliminary. (Ibid.).

In response to the Oversight Board’s critique, OSAGWI adopted a less definitive but

equally deceptive conclusion:

Based on the data developed to date, the Office of the Special Assistant believes

that while DU can pose a chemical toxicity and radiological hazard under specific

conditions, the available evidence does not support claims that DU caused or is

causing the undiagnosed illnesses some Gulf War veterans are experiencing.

(OSAGWI, 1998: 10).

While this position grants the Pentagon more latitude in its policy, it still does not address

the possible role of depleted uranium in veterans’ diagnosed conditions, or in the future

development of latent health problems.

After displaying early promise as a body of true reform and requisite oversight, the

Presidential Special Oversight Board started to mimic the Pentagon’s proclivity to

narrowly view depleted uranium through the prism of undiagnosed illnesses. In its

August 1999 Interim Report, the Oversight Board mysteriously overlooked the role of

depleted uranium in veterans’ current and future diagnosable conditions, stating only that

"exposure to DU is unlikely to be the cause of the unexplained illnesses affecting Gulf

War veterans." (PSOB, 1999(a): 26). By ignoring the role of DU in causing veterans’

diagnosed illnesses, the Presidential Special Oversight Board has apparently become an

obsequious accomplice to Pentagon efforts to downplay the possible harmful effects

related to the use of depleted uranium munitions.

The Office of the Special Assistant and the Presidential Special Oversight Board are

missing the point. If a veteran suffers respiratory problems, or develops cancer in ten

years, or develops neurocognitive problems due to exposure to depleted uranium or other

toxins in the Gulf War, the government has a responsibility to be there to help the veteran

and the veteran’s family. In any case where there is doubt as to the origin of the

condition or the degree of its impairment, the benefit of the doubt must be resolved in

favor of the veterans. They deserve nothing less, and they ask nothing more.

47

Depleted uranium is created when natural uranium is processed and enriched for use in

nuclear reactors and weapons, or when spent nuclear fuel is recycled. The nuclear fuel

process creates dangerous contaminants including plutonium, neptunium, and

technecium. When spent nuclear fuel is recycled, some quantity of plutonium and other

transuranics remain in the waste product called depleted uranium.

The Department of Energy has been aware of the presence of plutonium and other

transuranics in depleted uranium since at least the early 1960’s. Some depleted uranium

was sampled and found to have minimal amounts of plutonium; other DU had levels of

plutonium hundreds of times above established limits. (UCNC, 1963. DOE, 1985).

The Department of Energy and the Department of Defense are currently investigating the

amounts of plutonium and other transuranics in the depleted uranium ammunition and

tank armor produced over the last thirty years. Some of the DU munitions are known to

contain plutonium: the uncertainty revolves around whether the levels of plutonium

contamination are high enough to outweigh the risks posed by depleted uranium alone.

The burden of proof is on the Department of Defense to prove whether the DU

ammunition shot by American armed forces in the United States, Iraq, Kuwait, Saudi

Arabia, Japan, Puerto Rico, Bosnia, Kosovo or Serbia contained high levels or merely

trace amounts of plutonium and other transuranics. This uncertainty further complicates

efforts to assess the health impacts on veterans and civilians exposed to contamination

created by depleted uranium munitions.

48

"Little Gidding"

July 1990. Just six months before the Gulf War, the U.S. Army released the Kinetic

Energy Penetrator Long Term Strategy Study, a comprehensive report comparing the use

of tungsten alloy and depleted uranium in armor-piercing ammunition. This report

predicted that the large amounts of DU oxides created during combat could be inhaled by

soldiers and civilians. Soldiers in ground combat units were identified as potentially

receiving the highest exposures, and the expected health outcomes included cancers and

kidney problems. The report further warned that public knowledge of the health and

environmental effects of depleted uranium could lead to efforts to ban the use of DU in

munitions. Looking back on the ten years since the release of this report, it is remarkable

how many of the Army’s predictions have come true.

Appendix D of the 1990 Army report, titled Kinetic Energy Penetrator Environmental

and Health Considerations, states:

[A]erosol DU exposures to soldiers on the battlefield could be significant with

potential radiological and toxicological effects. These health impacts may be

impossible to reliably quantify even with additional detailed studies. It is not our

intention to overstate this issue given other combat risks, nor to imply that the

health of soldiers will definitely be compromised. We are simply highlighting the

potential for levels of exposure to military personnel during combat that would be

unacceptable during peacetime conditions. (AMCCOM, 1990: D(1), 4-5).

The Army assessed the dangers to its soldiers and determined that "under combat

conditions, the MEI’s [most exposed individuals] are probably the ground troops that reenter

a battlefield following the exchange of armor-piercing munitions, either on foot or

on motorized transports." (Ibid.: D(2), 3-4).

While the immediate risks of combat were noted to be of greater concern than the

delayed effects of exposure to depleted uranium, the Army acknowledged that depleted

uranium is a "low level alpha radiation emitter which is linked to cancer when exposures

are internal, [and] chemical toxicity causing kidney damage." (AMCCOM, 1990: D(1),

2-2).

The Army’s prescience did little to affect the behavior of Gulf War commanders. The

Department of Defense now admits that field commanders did not train or warn

servicemen and women about the hazards of depleted uranium on the battlefield. (CBS,

49

1999). Not one soldier, sailor, airman, or Marine with a known or suspected exposure to

depleted uranium was medically tested following the war.

The 1990 report also noted that "assuming U.S. regulatory standards and health physics

practices are followed, it is likely that some form of remedial action will be required in a

DU post-combat environment. Remedial actions may consist of retrieval of penetrator

fragments and decontamination of impact sites such as tanks, rocks, trees, buildings, etc."

(AMCCOM, 1990: D(1), 4-6).

The American equipment contaminated by depleted uranium was cleaned up; some

contaminated vehicles were buried in Saudi Arabia and the remainder were shipped to

South Carolina for decontamination and disposal. In Kuwait, contaminated equipment

was either transported to the Boneyard or left in the Udairi Training Range. Apparently,

the government of Iraq has not conducted any battlefield remediation of contaminated

equipment. Similarly, clean up of depleted uranium in Kosovo and Serbia has apparently

been hampered by NATO delays in the release of the locations and amounts of depleted

uranium contamination.

In its darkest but most insightful vision, the report predicted that "following combat, the

condition of the battlefield and the long-term health risks to natives and combat veterans

may become issues in the acceptability of the continued use of DU kinetic energy

penetrators for military applications." (AMCCOM, 1990: D(2), 3-4). Prior to the Gulf

War, there was no effort to ban the use of depleted uranium munitions. Nine years later,

many individuals, community groups, non-profit organizations and political parties in the

United States, England, Canada, the Netherlands, Belgium, Germany, Switzerland, Italy,

Japan and other nations are working to end the use of depleted uranium in munitions and

commercial products.

The more we learn about the use of depleted uranium in the Gulf War, the more accurate

the 1990 predictions become. All our exploration has merely brought us back to where

we started, but the story is not over. The Institute of Medicine is empowered to write the

next chapter about the possible health effects on Gulf War veterans, but the controversy

over the use of depleted uranium in munitions is likely to escalate in the years to come.

Additional research and investigation will help decision makers to formulate sound

training, force protection, health care and clean up policies, but this may be too little, too

late for Gulf War veterans, who have been left twisting in the wind by the Pentagon.

50

1. The Institute of Medicine should investigate the effects that exposures to

War veterans’ current and future health. Specifically, the Institute of Medicine

should examine veterans’ susceptibility to cancers, immune system damage,

neurological effects, reproductive problems, respiratory disease, kidney damage and

other health problems resulting from exposure to combinations of depleted uranium,

oil well fire smoke, low levels of chemical warfare agents, experimental drugs and

vaccines, pesticides and other toxins known to be present in the gulf. Keeping in

mind the devastating effects that cancer can have on veterans and their families, the

Institute of Medicine should evaluate the likelihood of future increases in cancers

without waiting for veterans to develop cancers in statistically significant numbers.

2. The Department of Veterans Affairs should conduct an epidemiological study of

exposures to depleted uranium. The Depleted Uranium Program at the Baltimore,

MD VA Medical Center appears best suited to undertake such an endeavor. Areas of

inquiry should include:

damage due to inhalation or ingestion of depleted uranium, and the significance of

these injuries on the long-term health of veterans;

these findings on developmental effects in veterans’ children;

fragments and exposure via inhalation, ingestion, or wound contamination;

immunotoxicity, neurotoxicity, and reproductive effects to female and male

veterans; and

3. In accordance with historical precedent and resolving the many doubts about

problems for all veterans who served in or traveled to contaminated areas. The

presumption of exposure should be extended to all veterans who:

conflict (August 2, 1990 to July 31, 1991);

munitions fire, and/or participated in clean up efforts; or

area is certified to be free of depleted uranium hazards.

51

4. Future depleted uranium research should investigate health effects resulting

from all possible routes of exposure. Research to date has failed to examine health

effects from inhalation, ingestion, and wound contamination. Reliable dose estimates

should be developed for exposure through inhalation, ingestion, and wound

contamination in a range of realistic exposure scenarios.

5. Future depleted uranium research should investigate the health effects of

protracted internal exposure to varying levels of depleted uranium. The shortand

long-term effects of low, medium, and high exposures to depleted uranium

should be determined.

6. Congress should request a report from the Secretary of Defense on the status of

depleted uranium training in the armed forces. Since the the Army and Marine

Corps do not know if troops deployed to Kosovo have received any training or

warnings about the hazards of DU, it is likely that troops deployed to Kuwait, South

Korea, and other hot spots also have not been trained or properly equipped.

7. Following future conflicts in which veterans are exposed to depleted uranium

recommendations for research and treatment. If we have learned anything from

the last nine years of the Gulf War illness debate, it is that the Pentagon can not be

trusted to objectively investigate toxic exposures or to accurately report about the

efficacy of experimental drugs and vaccines.

8. An international organization, such as the World Health Organization, should

reports of increased rates of cancers and birth defects in Iraq. There is

undoubtedly a large pool of Iraqi war veterans who inhaled depleted uranium oxides

or were wounded by depleted uranium fragments that could be studied. In addition,

Iraqi children with known or suspected exposures to depleted uranium (e.g., from

playing on destroyed vehicles, collecting DU penetrators) should be studied to

determine the possible role of depleted uranium in the etiology of increased diseases.

This research could shed further light on the relationship between depleted uranium

exposure and American veterans’ illnesses.

9. The United States of America should accept responsibility for identifying,

uranium has been released. The Department of Defense should further issue

immediate warnings to civilian populations, relief agencies, and the United Nations

when American armed forces use depleted uranium in training or combat operations

on foreign soil.

10. The United States Congress should task the General Accounting Office to

determine the life-cycle cost for depleted uranium. The expenses of creating

depleted uranium through mining, enriching, and processing uranium should be added

52

to the costs of manufacturing, testing, purchasing and using DU ammunition. The

aggregate cost should also include the expenses of safety training and protective

clothing for soldiers, medical monitoring of soldiers and civilians for exposure, health

care for exposed veterans and civilians, restricted use of contaminated lands, clean up

of contaminated soil and water, disposal of DU contamination, and military public

relations efforts to deny depleted uranium’s effects. In this way taxpayers can decide

if the bang is worth the bucks.

53

During the 1999 war between NATO air forces and Yugoslav ground troops, American

A-10 aircraft fired 37,550 rounds of all typed 30mm ammunition. (USAF, 2000).

Assuming each A-10 carried a standard combat mix of 5 DU rounds with 1 high

explosive incendiary (HEI) round, approximately 31,300 depleted uranium rounds were

shot. Each 30mm round contains a depleted uranium penetrator weighing 0.302 kg or

0.66 lb. (Fahey, 1998: 198). Therefore, US forces released approximately 9,453 kg (9.5

metric tons) or 20,658 lb. (10.3 tons) of depleted uranium during the war.

Following the end of NATO’s bombing campaign, the United Nations Environment

Programme (UNEP) and the United Nations Centre for Human Settlements (Habitat)

(UNCHS) formed the Balkans Task Force (BTF) to assess the impacts of the war.

(UNEP/UNCHS, 1999). Within the Balkans Task Force, an inter-agency ‘Desk

Assessment Group’ was assembled to investigate the use of depleted uranium munitions.

The Desk Assessment Group’s investigation was hindered by NATO’s refusal to confirm

the quantities and locations of depleted uranium expenditure. (UNEP/UNCHS, 1999:

61). Consequently, the group was reduced to conducting a review of published literature

and making assessments based on hypothetical exposure scenarios.

The Desk Assessment Group noted that people in the immediate vicinity of a DU attack

could be heavily exposed to DU by inhalation. This is confirmed by US Air Force testing

showing that "findings of past air sampling efforts revealed contamination was localized

to within 300 to 400 feet (90 to 120 m) of the [A-10] target area." (Nellis, 1998: 3-9).

Claims that the release of depleted uranium in Kosovo resulted in vastly increased rates

of radioactivity in the air in Bulgaria or Greece are highly improbable.

Following the release of the Balkans Task Force report in October 1999, Secretary

General of the United Nations Kofi Annan wrote to NATO requesting details about the

use of depleted uranium during Operation Allied Force. Five months later, NATO

responded that A-10’s shot depleted uranium during approximately 100 missions. "At

this moment it is impossible to state accurately every location where DU ammunition was

used," states Lord George Robertson, NATO Secretary General, in the letter to Kofi

Annan. (NATO, 2000).

A NATO map released with the letter to Kofi Annan identifies 28 locations in Kosovo

where A-10’s are believed to have released depleted uranium (see page 54). (NATO,

2000). However, it is likely that A-10’s also shot depleted uranium at Yugoslav forces in

Serbia, though no locations outside the borders of Kosovo are identified on the NATO

map. The Balkans Task Force apparently did not make much of an effort to look for or

find depleted uranium, but Christian Science Monitor journalist Scott Peterson found

depleted uranium in Djakovica, Kosovo and reported its discovery in Vranje and

Bujanovac, Serbia. (Peterson, 1999).

55

The Balkans Task Force convened a meeting of experts on March 20, 2000 in Geneva,

Switzerland to discuss the NATO letter and map. Those gathered at the meeting agreed

to give the following recommendations:

1. Inform any organizations concerned about the recommendations of the BTF

Desk Study on DU. With the given information, the earlier recommendations,

based on precautionary principles are still valid.

2. The expert group concluded that for several reasons it would be useful to

continue the investigations on the health and environmental impacts of DU in

Kosovo. However, the information obtained so far will not allow appropriate

preparations into a necessary field study.

3. A follow-up of the BTF Desk Study should be organized with good interagency

co-operation and should be conducted in a way as to safeguard

independent and reliable results. Success in the study requires smooth

collaboration with military organizations and UN organizations in Kosovo.

4. A field mission should be carefully prepared and would require considerable

resources and commitment from several UN agencies.

5. Based on the nature of the potential DU-contamination, the field mission

should be organized as soon as possible in order to achieve reliable results.

6. A field mission should start from measuring the places indicated as targeted

areas during the NATO operation. Consequently, the need for further assessment

of health and other investigations would then be assessed.

7. Though the urgency of the issue and organizations' willingness was made clear,

a political decision from UN headquarters on the future steps would be necessary.

(UNEP, 2000).

In accordance with the recommendations made in the Balkans Task Force’s 1999 report,

measures should be taken to prevent access and clean up contaminated material at places

where contamination is confirmed. (UNEP/UNCHS, 1999: 76). Local authorities and

civilian populations should be informed of the possible risks and appropriate

precautionary measures. (UNEP, 2000(a)). Finally, "appropriately designed health

examination programmes should be established" in areas where civilians may have

encountered DU contamination. (UNEP/UNCHS, 1999: 77).

Since NATO declared that it fought the war in Kosovo to protect civilian populations

from internal and external harm, it is reasonable to expect NATO, and specifically the

United States, to accept responsibility for cleaning up depleted uranium contamination.

The steps for such an effort have already been established at Nellis Air Force Range in

Nevada, where A-10 pilots practice their skills.

56

Contaminated tanks in the storage area at the Nellis range "are properly labeled with

clearly visible warning signs indicating ‘Caution: Radioactive Material.’" (Nellis, 1998:

3-9). Some tanks are decontaminated and returned to target service, but the tanks that

cannot be decontaminated "will ultimately be disposed of either as low-level waste in

accordance with 10 CFR Part 20 . . . or shipped to a licensed facility for treatment,

smelting, and recycling. These tanks and debris would be loaded into sealed shipping

containers on site and transported to the landfill or recycling facility by truck or rail, as

appropriate, by a licensed contractor" (Ibid.).

Out on the firing range, "trained technicians will manually remove visible DU rounds and

fragments from the target area." (Nellis, 1998: 3-8). "Every five years, surface and

subsurface DU rounds and fragments will be removed . . . Tilled soil and upturned

materials will be inspected by EOD personnel and fed into a hopper for sorting . . . These

operations will remove the DU source material on the surface, as well as those expected

to be in the upper subsurface." (Ibid.: 3-9).

Approximately 25% of the rounds shot by an A-10 hit their target. The physical form of

the DU on the Nellis range varies from oxidized particulates mixed with sand, to

fragments and intact penetrators within an approximately 300 to 400 foot (90-120 m)

radius of the tank targets. (Nellis, 1998: 2-4). In general, the amount of contamination

decreases as the distance from the target increases. "DU penetrators have been seen for

many feet beyond the 300 to 400 foot radius and, due to overshot, are expected to be

present and isolated in the soil for possibly over 1,000 feet (300 m) past the targets."

(Ibid.).

At Kirtland Air Force Base in New Mexico, where depleted uranium ammunition is also

tested, areas with the potential for increased soil contamination "are not accessible to the

general public." (FR, 1999: 64(240)). "Depleted uranium fragments are collected after

tests and additional measures are taken to remove any contamination from the soil."

(Ibid.).

The end of the air war over NATO brought the return of tens of thousands of ethnic

Albanian people to Kosovo. Relief agencies and military forces from the United States,

Russia, England, France, Holland, Germany, Italy, Canada and other nations

accompanied the refugees back into Kosovo. When the movement of people back into

Kosovo began, the British National Radiological Board issued a depleted uranium

advisory to British citizens which warned them to avoid entering areas where DU was

suspected of having been used. (NRPB, 1999).

In contrast to the action of the British government, the United States did not even warn or

train the soldiers and Marines sent into Kosovo on peacekeeping operations. The General

Accounting Office recently stated that "Army and Marine Corps officials in Washington,

DC and Europe were unable to tell us whether Army and Marine Corps troops who

recently deployed to Kosovo had received DU training prior to or during the

deployment." (GAO, 2000: 19). This is emblematic of the Pentagon’s approach to DU

57

training: public affairs keeps saying training is taking place, but they can seldom provide

any supporting evidence.

It is unclear whether any soldiers or Marines in Kosovo have been medically tested

following known or suspected exposures to depleted uranium. The Army’s Office of the

Surgeon General refused to comment when asked whether any soldiers have been tested

Unlike their American counterparts, Dutch soldiers in Kosovo have not only been trained

about DU, but also tested following a known exposure incident. In a letter to the Dutch

Soldiers Trade Union, the Dutch Ministry of Defence confirmed that six soldiers from the

Explosive Device Removal Service were tested after finding and keeping one 30mm DU

penetrator. (DMD, 2000). No elevated uranium concentration was found in the urine of

any of the six soldiers. The Dutch Ministry of Defence should be commended for caring

enough about its soldiers to medically test them following an exposure to DU. Someday,

perhaps, the U.S. Department of Defense will show as much concern for the health and

well being of its fighting forces as its counterpart in the Netherlands.

The United States Department of Defense has clearly demonstrated the impossibility of

using depleted uranium munitions in a responsible manner. The Pentagon fails to warn

civilian populations in Iraq, Kuwait, Bosnia, Kosovo, and Serbia about the release of

depleted uranium. Relief agencies and United Nations inquiries receive vague

information long after DU is released. The Pentagon oversees cleanup of depleted

uranium at selected locations in the United States, but refuses to accept responsibility for

DU shot on many domestic and foreign lands. American fighting forces receive scant

training about DU’s hazards, and no testing of active duty forces is apparently taking

place. Marine Corps pilots "accidentally" fire DU rounds in Japan and Vieques, Puerto

Rico. If the Pentagon can not take responsibility for health and environmental

consequences associated with the use of depleted uranium munitions, then perhaps they

should not be allowed to use it. Unfortunately, elected U.S. representatives with the

courage and fortitude to confront the Pentagon about its reckless use of DU munitions are

as rare as a snowstorm in July.

Depleted uranium penetrators are now in the arsenals of many nations who purchase

weapons from the United States, Russia, China, and Pakistan, though some nations

including Canada and Germany have foresworn the use of depleted uranium. In the

Middle East, virtually every nation except Iraq has depleted uranium ammunition in its

arsenal. In the future, large numbers of soldiers and civilians may be exposed to depleted

uranium, and nations already impoverished by war may face the additional burden of

long-term health care for exposed populations living on contaminated lands. Depleted

uranium is a weapon whose time has come, and gone.

did not respond to this request.

58

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