                                                                                                    Page
     Forward ......................................................III
I. Introduction ................................................. 1
II. Background ................................................... 3
      A. Codes, declarations, and laws governing human
          experimentation ......................................... 3
      B. Mustard gas and lewisite ................................. 5
      C. Seventh-Day Adventists ................................... 5
      D. Dugway Proving Ground .................................... 6
      E. Radiation exposure ...................................... 7
      F. Hallucinogens ............................................ 9
      G. Investigational drugs ................................... 10
III. Findings and conclusions .................................... 15
      A. For at least 50 years, DOD has intentionally
          exposed military personnel to potentially
          dangerous substances, often in secret ................... 15
      B. DOD has repeatedly failed to comply with required
          ethical standards when using human subjects in
          military research during war or threat of war ........... 18
      C. DOD incorrectly claims that since their goal was
          treatment, the use of investigational drugs in
          the Persian Gulf War was not research ................... 24
      D. DOD used investigational drugs in the Persian Gulf
          War in ways that were not effective ..................... 25
      E. DOD did not know whether pyridostigmine bromide
          would be safe for use by U.S. troops in the
          Persian Gulf War ........................................ 28
      F. When U.S. troops were sent to the Persian Gulf
          in 1994, DOD still did not have proof that
          pyridostigmine bromide was safe for use as an
          antidote enhancer ....................................... 31
      G. Pyridostigmine may be more dangerous in combination
          with pesticides and other exposures ..................... 32
      H. The safety of the botulism vaccine was not
          established prior to the Persian Gulf War ............... 34
      I. Records of anthrax vaccinations are not suitable
          to evaluate safety ...................................... 35
      J. Army regulations exempt informed consent for
          volunteers in some types of military research ........... 35
      K. DOD and DVA have repeatedly failed to provide
          information and medical followup to those who
          participate in military research or are ordered
          to take investigational drugs ........................... 36
      L. The Federal Government has failed to support
          scientific studies that provide information about
          the reproductive problems experienced by veterans
          who were intentionally exposed to potentially
          dangerous substances .................................... 37
      M. The Federal Government has failed to support
          scientific studies that provide timely information
          for compensation decisions regarding military
          personnel who were harmed by various exposures .......... 38
      N. Participation in military research is rarely
          included in military medical records, making it
          impossible to support a veteran's claim for service
          connected disabilities from military research ........... 39
      O. DOD has demonstrated a pattern of misrepresenting the danger
          of various military exposures that continues today ...... 40
IV. Recommendations .............................................. 42
      A. Congress should deny the DOD request for a blanket
          waiver to use investigational drugs in case of war
          or threat of war ........................................ 42
      B. FDA should reject any applications from DOD that
          do not include data on women, and long-term
          followup data ........................................... 42
      C. Congress should authorize a centralized database
          for all federally funded experiments that utilize
          human subjects .......................................... 43
      D. Congress should mandate all Federal agencies to
          declassify most documents on research involving
          human subjects .......................................... 43
      E. Congress should reestablish a National Commission
          for the Protection of Human Subjects .................... 43
      F. VA and DOD should implement regular site visits
          to review Institutional Review Boards ................... 44
      G. The Feres Doctrine should not be applied for
          military personnel who are harmed by inappropriate
          human experimentation when informed consent has not
          been given .............................................. 44
Appendix
   Survey of 150 Persian Gulf War Veterans ........................ 46