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NEED TO ADD GRAPHICS FROM REPORT

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.

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 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.

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Niccolo Macchiavelli
Advice to Raffaello Girolami when he went as Ambassodor to the Emperor
October 1522

Friendly Fire Veterans. Most of the Gulf War’s friendly fire incidents occurred 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.

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 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 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 Pentagon and the Army Surgeon General’s Office simply refuse to answer.^*

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.

Maintenance and Recovery Soldiers. After depleted uranium rounds disabled 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 two Army units (the 24^th Infantry Division-Mechanized and the 144^th National Guard 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, 1993: 3). The General Accounting Office stated that 27 soldiers from the 144^th Service and Supply Company and an unknown number of soldiers from the 24^th Infantry Division 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 addition to the 24^th Infantry Division, the 1^st Infantry Division, 1^st Armored Division, 2^nd Armored Division, and the 3^rd Armored Division also experienced friendly fire incidents 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 their discussion of support personnel to the 27 support soldiers from the 144^th.. (DSB, 1994: 26. IOM, 1996: 56). To its credit, the Presidential Advisory Committee also mentioned "about two dozen" support soldiers from the 24^th Infantry Division in addition to 27 soldiers from the 144^th. (PAC, 1997: 99). Amazingly, the 1998 final report from 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 144^th, the Pentagon estimated that between 88 and 156 soldiers and civilian Logistics 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.

Everybody Else. In the aftermath of the Gulf War, thousands of soldiers basked in the 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.

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 1^st Marine Expeditionary Force invaded Kuwait with more than 36,000 Marines from the 1^st and 2^nd Marine Divisions. (Shield, 1991: MC31). Approximately 50,000 coalition 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 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, CT) 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 (DVA) survey sheds further light on the number of possible DU exposures. The DVA 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 with respirators, and never medically tested, even though the 11^th Armored Cavalry 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.

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:

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:

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.

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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.

Specialist, 3^rd Armored Division: "Our Bradley was hit with two rounds, and I took 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 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).

Specialist, 2^nd Armored Division: "We had 52 tanks on line. We engaged Iraqi tanks, 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 he knows that the 24^th Infantry Division direct support guys who retrieved the tanks they 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." (OSAGWI, 1998: End Note 87 found online at www.gulflink.osd.mil/du/).

Sergeant, 24^th Infantry Division (Mechanized): "After unloading all the ammunition 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).

Sergeant, 24^th Infantry Division (Mechanized): "He said that he was unaware that 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).

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

Sergeant, 123^rd Medical Detachment (Army Reserve): "Our commander sent us up 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).

Sergeant, 58^th Combat Engineers: "[The Sgt.] said that he and other in the unit were 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.).

Lt. Colonel, Regimental Engineer Staff Officer, 11^th Armored Cavalry Regiment: "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).

Sergeant, 1^st Marine Division: "We came across a lot of destroyed vehicles and dead 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).

Captain, 1^st Force Recon Company, 1^st MEF: "The second incident took place on or 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).

Sergeant First Class, 144^th Service and Supply Company (New Jersey): "He 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).

Captain, 144^th Service and Supply Company (New Jersey): "MEMORANDUM FOR 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).

Specialist, 649^th Military Police Company (California): "About 50 of us drove up to 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).

U.S. Air Force

Senior Master Sergeant, 4410^th Provisional Operational Support Wing: "The 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).

Master Sergeant, 354^th EMS: "Several incidents. Bad lots of ammo – the round would 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).

Captain (RN), 23^rd Aero Staging Facility: "We received military personnel from all 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).

Corpsman, 1^st Marine Division (Served February-March 1992 in Kuwait): "We 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).

Logistics Assistance Representative, 101^st Airborne: "I was never told Iraqi tanks that 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).

Technical Representative, 3^rd Marine Air Wing: "After the ground war had 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).

Logistics Assistance Representative (LAR), 1^st Armored Division: "They had prewar 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.

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 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 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:

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:

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:

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).

A log kept by the 22^nd Support Command (SUPCOM) notes that "depleted uranium rounds were beginning to cook off" two hours after the fire started. (SUPCOM, 1991: 14). Four hours after the first explosions, SUPCOM logs state that the 11^th Armored 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 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:

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. (SUPCOM, 1991: 129). During the week after the fire, the 11^th Armored Cavalry Regiment command staff demonstrated their commitment to the health and safety of the clean up crews:

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.

In contrast to the way the 11^th ACR treated its soldiers, workers hired two months later to complete the clean up were provided with respiratory and other protection:

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:

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 personnel working outside the boneyard but still within its immediate vicinity as long as there are no ongoing operations within the boneyard." (CENTCOM, 1994: 20, emphasis added). In addition, the final report made the following recommendation:

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 25). 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.

Presumption of Exposure

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 combat unit, the 1st Brigade of the Army’s 3rd Armored Division, left the Persian Gulf on 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.

The 11th Armored Cavalry Regiment relieved the final Gulf War combat unit and set up operations at Doha, Kuwait, an active U.S. Army installation to this day. During the Doha fire, 11th ACR soldiers were never warned about burning depleted uranium or 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 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:

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, 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.

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U.S. Army Environmental Policy Institute
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 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:

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 DU 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 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 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 DU.

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 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 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.

Kidney Effects. The kidney helps the body remove wastes from the blood so that they 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 problems. One veteran from the 144th Service and Supply Company suffered apparently 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).

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).

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 dose-dependent 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 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 DU-exposed 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 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 heavy-metal 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 expe