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entitled 'Disaster Preparedness: Better Planning Would Improve OSHA's 
Efforts to Protect Workers' Safety and Health in Disasters' which was 
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Report to Congressional Committees: 

United States Government Accountability Office: 

GAO: 

March 2007: 

Disaster Preparedness: 

Better Planning Would Improve OSHA's Efforts to Protect Workers' Safety 
and Health in Disasters: 

GAO-07-193: 

GAO Highlights: 

Highlights of GAO-07-193, a report to congressional committees 

Why GAO Did This Study: 

Concerns about the safety and health of workers involved in the 
response to Hurricane Katrina included their exposure to contaminated 
floodwaters and injuries from working around debris. The Department of 
Labor’s Occupational Safety and Health Administration (OSHA) is 
responsible for coordinating federal efforts to protect the safety and 
health of workers involved in the response to large national disasters. 
Under the Comptroller General’s authority, GAO initiated a number of 
Katrina-related reviews. For this review, GAO examined (1) what is 
known about the number of response and recovery workers deployed to the 
Gulf Coast in response to Hurricane Katrina; (2) the extent to which 
OSHA tracked injuries and illnesses sustained by these workers; and (3) 
how well OSHA met the safety and health needs of workers. To address 
these issues, GAO reviewed reports; analyzed data; interviewed federal, 
state, and local officials; and conducted site visits. 

What GAO Found: 

No one, including OSHA, was responsible for collecting information on 
the total number of response and recovery workers deployed to the Gulf 
Coast in response to Hurricane Katrina and no one collected it, but 10 
federal agencies provided estimates showing that, on October 1, 2005, 
the agencies had about 49,000 federal workers in the Gulf Coast area. 
In addition, six of these agencies estimated that their contractors had 
about 5,100 workers in the area on December 1, 2005, but the other four 
either did not track the number of workers employed by their 
contractors or did not employ contractors. Although OSHA was 
responsible for tracking the injuries and illnesses that federal 
response and recovery workers sustained during the response to 
Hurricane Katrina, the agency’s efforts to collect it were delayed and 
it was unable to collect usable information. According to OSHA, the 
Federal Emergency Management Agency (FEMA) must assign and fund 
specific responsibilities for each disaster. However, FEMA did not 
direct OSHA to collect injury and illness data until more than 3 weeks 
after the hurricane struck. OSHA attempted to collect the data, but the 
information federal agencies provided were incomplete and unreliable. 
OSHA and other agencies did track fatalities. They reported nine worker 
fatalities attributed to work-related accidents: three employees of 
federal contractors and six nonfederal workers or volunteers. OSHA 
provided assistance to many response and recovery workers who responded 
to Hurricane Katrina, but not all workers’ safety and health needs were 
met. OSHA quickly established operations in the Gulf area; intervened 
in thousands of potentially hazardous situations; and assessed air, 
water, soil, and noise hazards at many work sites. However, 
disagreements between OSHA and FEMA about which agency was in charge of 
providing safety and health assistance to federal agencies and workers 
and how it would be provided delayed some of OSHA’s efforts. Also, some 
agencies’ lack of awareness about the role OSHA plays in a disaster 
further hindered its ability to provide assistance. As a result, OSHA 
did not fully meet workers’ safety and health needs, particularly their 
need for training and protective equipment. OSHA also did not 
coordinate with the Department of Health and Human Services to ensure 
that workers had needed mental health services, and OSHA was not 
assigned responsibility for coordinating the needs of nonfederal 
workers, including state and local agency workers; many immigrants; and 
volunteers. 

Figure: Workers at an EPA Hazardous Waste Collection Facility near New 
Orleans, Louisiana: 

[See PDF for Image] 

Source: GAO. 

[End of figure] 

What GAO Recommends: 

GAO is making recommendations to the Secretaries of Labor, Homeland 
Security, and Health and Human Services designed to improve OSHA’s 
efforts during future disasters. Labor agreed with the recommendation 
to establish a system to better track injuries and illnesses but 
disagreed with some of the findings on which the other recommendations 
were based. The other two agencies agreed with the recommendations in 
the report. 

[Hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-07-193]. 

To view the full product, including the scope and methodology, click on 
the link above. For more information, contact Daniel Bertoni at (202) 
512-5988 or bertonid@gao.gov. 

[End of section] 

Contents: 

Letter: 

Results in Brief: 

Background: 

No One Collected Information on the Total Number of Response and 
Recovery Workers Deployed to the Gulf Coast, but 10 Federal Agencies 
Collected Data on Their Workers: 

OSHA Was Unable to Collect Information on Workers' Injuries and 
Illnesses: 

OSHA Provided Assistance to Many Agencies and Workers, but Its Efforts 
to Meet the Safety and Health Needs of All Workers Were Hampered by 
Several Factors: 

Conclusions: 

Recommendations for Executive Action: 

Agency Comments and Our Evaluation: 

Appendix I: Scope and Methodology: 

Appendix II: Data on the Estimated Number of Federal Workers Who 
Responded to Hurricane Katrina and Their Injuries and Illnesses: 

Appendix III: Comments from the Department of Health & Human Services: 

Appendix IV: Comments from the Department of Labor: 

Appendix V: GAO Contact and Staff Acknowledgments: 

Related GAO Products: 

Tables: 

Table 1: Number of Fatalities Reported by OSHA and Other Federal 
Agencies: 

Table 2: Reported Number of Injuries and Illnesses for EPA, August 2005 
to June 2006: 

Table 3: Reported Types of Injuries and Illnesses for EPA, August 2005 
to June 2006: 

Table 4: Reported Number of Injuries and Illnesses for USACE, August 
2005 to June 2006: 

Table 5: Reported Types of Injuries and Illnesses for USACE, August 
2005 to June 2006: 

Table 6: Reported Exposures for the Coast Guard, November 2005 to March 
2006: 

Table 7: Reported Injuries for the Coast Guard, November 2005 to March 
2006: 

Table 8: Reported Health Effects for the Coast Guard, November 2005 to 
March 2006: 

Table 9: Reported Timing of Symptoms for Health Effects for the Coast 
Guard, November 2005 to March 2006: 

Figures: 

Figure 1: Estimated Number of Federal Employees in the Gulf Coast Area 
on the First Day of Each Month, September 2005 to April 2006: 

Figure 2: Animals Such as Snakes and Alligators Presented Hazards to 
Workers in the Gulf Coast Area: 

Figure 3: Selected Quick Cards Developed by OSHA for Hurricane Katrina: 

Figure 4: Selected Fact Sheets Developed by OSHA for Hurricane Katrina: 

Figure 5: Work Zones with Equipment Not Protected from Traffic by 
Safety Cones: 

Figure 6: Workers on a Water Tower without Fall Protection Such As 
Guard Rails or Safety Harnesses: 

Figure 7: Workers on a Roof without Safety Harnesses and with Poorly 
Secured Ladders: 

Figure 8: Airborne Hazards on the Gulf Coast: 

Figure 9: OSHA Field Staff Sampling the Air, Water, and Soil on the 
Gulf Coast by Pinning a Small Personal Monitor to a Worker, Taking 
Water Samples, and Taking Soil Samples: 

Figure 10: Driving Hazards Faced by Workers in the Gulf Coast Area: 

Figure 11: Safety Brochures in English, Spanish, and Vietnamese: 

Abbreviations: 

DOD: Department of Defense: 
EPA: Environmental Protection Agency: 
FEMA: Federal Emergency Management Agency: 
NRP: National Response Plan: 
OSHA: Occupational Safety and Health Administration: 
USACE: U.S. Army Corps of Engineers: 

United States Government Accountability Office: 
Washington, DC 20548: 

March 28, 2007: 

Congressional Committees: 

After Hurricane Katrina hit the Gulf Coast on August 29, 2005, federal 
agencies undertook one of the largest rescue and recovery efforts in 
American history. Several agencies sent workers to the three states 
that suffered the most damage from the hurricane: Alabama, Louisiana, 
and Mississippi. Various reports have raised concerns about the safety 
and health of workers involved in the response to Hurricane Katrina and 
the dangers they faced, from animals such as snakes and alligators to 
floodwaters contaminated by chemicals, oil, corpses, and fecal matter. 
Public health advisories also warned about high temperatures and the 
potential spread of diseases such as West Nile Virus resulting from 
mosquitoes that breed in standing water. In addition, worker advocacy 
groups, public health advisors, and representatives of the Congress 
have raised concerns about the possibility of latent illnesses among 
workers deployed to the Gulf, especially in light of such illnesses 
among workers involved in rescue and recovery efforts at the World 
Trade Center disaster site. Many workers at the site in New York were 
not aware that they had developed debilitating respiratory conditions 
or post-traumatic stress disorders until months or years after they 
left the site. 

The safety and health of workers responding to Hurricane Katrina is 
addressed in a section, or "annex," of the National Response Plan (NRP) 
of December 2004, the federal plan for responding to domestic 
emergencies and disasters. As lead agency for carrying out the 
provisions of the Worker Safety and Health Support Annex (the Annex), 
the Department of Labor's Occupational Safety and Health Administration 
(OSHA) is responsible for coordinating the worker safety and health 
efforts of responders--including federal, state, local and tribal 
governments, and private and nonprofit organizations--in protecting the 
safety and health of their workers when the Annex is implemented. 
OSHA's responsibilities under the Annex include identifying and 
assessing health and safety hazards, providing technical advice and 
support to safety officials, and collecting data on exposures and 
injuries. Given the large numbers of workers who responded to Hurricane 
Katrina and concerns about their health and safety, we addressed the 
following questions: (1) What is known about the number of response and 
recovery workers deployed to the Gulf Coast in response to Hurricane 
Katrina? (2) To what extent did OSHA track injuries and illnesses 
sustained by these workers? (3) How well did OSHA meet the safety and 
health needs of these workers? 

To address these objectives, we reviewed reports and documents related 
to the federal response efforts for Hurricane Katrina and other recent 
disasters; interviewed officials from 10 federal agencies identified by 
FEMA and OSHA as having deployed response and recovery workers to the 
Gulf Coast: OSHA; the Federal Emergency Management Agency (FEMA); the 
Environmental Protection Agency (EPA); the Coast Guard; the Department 
of Defense (DOD); the National Guard; the U.S. Army Corps of Engineers 
(USACE); and the Departments of Agriculture, Health and Human Services, 
and the Interior. We also conducted site visits in Alabama, 
Mississippi, and Louisiana where we interviewed federal officials in 
all three states and selected state and local officials who were part 
of the rescue and recovery efforts. To obtain information on the number 
of response and recovery workers who responded to Hurricane Katrina, we 
contacted the 10 agencies identified by FEMA and OSHA and asked them to 
provide information on the number of workers each agency employed in 
the Gulf Coast. To obtain information on injuries and illnesses 
sustained by these workers, we asked these same agencies for this 
information for their workers. Of the 10 agencies, only four--USACE, 
EPA, the Coast Guard, and the Department of the Interior--had data on 
workers' injuries and illnesses that were sufficiently reliable for us 
to report. We also obtained data on injuries and illnesses related to 
Hurricane Katrina from workers' compensation claims filed by federal 
workers, and information on worker fatalities from OSHA and other 
federal agencies. To assess the reliability of the agencies' data, we 
talked with agency officials about their data quality-control 
procedures and reviewed relevant documentation. We determined the data 
were sufficiently reliable for the purposes of this report. Finally, we 
interviewed workers' rights organizations, including the Mississippi 
Immigrant Rights Alliance, Boat People SOS, the Center to Protect 
Workers' Rights, and the New York Committee for Occupational Safety and 
Health. We conducted our work from October 2005 to December 2006 in 
accordance with generally accepted government auditing standards. For 
additional information, see appendix I. 

Results in Brief: 

No one, including OSHA, was responsible for collecting information on 
the total number of response and recovery workers deployed to the Gulf 
in response to Hurricane Katrina, and no one collected it, but 10 
federal agencies provided estimates showing that, on October 1, 2005 
(the month with the largest total number of federal workers), the 
agencies had about 49,000 federal workers in the Gulf Coast area. In 
addition, six of these agencies estimated that their contractors had 
over 5,100 workers in the area as of December 1, 2005 (the month with 
the largest total number of contractor employees), but three of the 
other four did not track the number of workers employed by their 
contractors, and one did not employ contractors for the response. 

Although OSHA was responsible for tracking injuries and illnesses for 
federal response and recovery workers, including federal contractor 
employees, deployed to the Gulf Coast during the response to Hurricane 
Katrina, the agency was unable to collect usable information from 
federal agencies on their workers' injuries and illnesses. OSHA could 
not track workers' injuries and illnesses because the agency (1) had 
not developed a process for collecting this information prior to the 
disaster, (2) was not directed by FEMA to track this information right 
away, and (3) received incomplete and unreliable data from federal 
agencies once it attempted to collect the information. In the 8 months 
between the time the National Response Plan and the Annex was issued 
and Hurricane Katrina hit the Gulf Coast, OSHA focused its efforts on 
introducing the Annex to agencies that might respond to a disaster and 
did not develop a process for collecting data on workers' injuries and 
illnesses. In addition, OSHA, like all other agencies under the NRP, 
must wait for FEMA to assign it specific responsibilities for each 
disaster and authorize funding for these activities, but FEMA did not 
direct OSHA to collect data on federal workers' injuries and illnesses 
until more than 3 weeks after the hurricane struck. After receiving 
this assignment from FEMA, OSHA tried to obtain the data from the logs 
that OSHA requires agencies to keep at each work site on workers' 
injuries and illnesses. However, not all agencies that deployed workers 
to the Gulf Coast provided these logs to OSHA as requested, and those 
that did provided incomplete and unreliable data. OSHA and other 
agencies also reported nine worker fatalities attributed to work- 
related accidents, including three employees of federal contractors and 
six nonfederal workers or volunteers. 

OSHA provided assistance to many response and recovery workers who 
responded to Hurricane Katrina, but OSHA's efforts to meet all workers' 
safety and health needs were hampered by several factors. OSHA used its 
own funds to quickly establish operations in the Gulf area prior to 
receiving authorization from FEMA in the form of a mission assignment 
implementing the Annex. OSHA developed health and safety plans; 
provided information on common safety hazards to many agencies and 
workers; intervened in thousands of potentially hazardous situations; 
and assessed air, water, soil, and noise hazards at many worksites. 
However, disagreements between OSHA and FEMA about which agency was in 
charge of providing safety and health assistance to federal agencies 
and workers and how and when the Annex would be implemented delayed 
some of OSHA's efforts to provide assistance. Once OSHA began its 
efforts, some agencies' lack of awareness about the role OSHA plays in 
a disaster further hindered its ability to provide assistance. For 
example, many agency officials did not know that, in a disaster, OSHA 
provides technical assistance rather than conducting inspections of 
work sites or that OSHA can provide assistance such as assessing safety 
hazards and recommending the proper protective equipment for workers. 
This lack of understanding contributed to agencies' not requesting 
OSHA's assistance during the response and not inviting OSHA to 
participate in emergency preparedness exercises in the months leading 
up to Hurricane Katrina. In addition, although OSHA provided valuable 
assistance to many agencies and workers, it was not able to ensure that 
all workers' needs for training, protective gear, and mental health 
services were met. The training OSHA provided was delayed for several 
weeks because FEMA did not officially authorize OSHA to carry out its 
responsibilities under the Annex until more than 3 weeks after the 
hurricane, and some agencies did not request training from OSHA because 
they did not realize it was available. OSHA provided some personal 
protective equipment to workers in the Gulf Coast area but had not 
developed a plan for ensuring that workers had needed protective 
equipment as required by the Annex and FEMA, and some workers did not 
have equipment to protect them from hazards. For example, National 
Guard officials told us that some of their federalized workers did not 
have equipment such as rubber boots to protect them from contaminated 
floodwaters. OSHA also had difficulty getting counselors to provide 
mental health services in the locations and during the hours they were 
needed, and it did not coordinate with the Department of Health and 
Human Services to ensure that workers had needed mental health 
services. Finally, coordinating the safety and health needs of 
nonfederal workers--including state and local government workers, many 
immigrants, and volunteers--was not part of OSHA's assigned 
responsibilities for Hurricane Katrina (nor any other federal agency's 
responsibility), and some of their needs were not met. 

We are recommending that the Secretaries of the Departments of Labor 
and Homeland Security direct the Administrators of OSHA and FEMA to 
improve their ability to meet workers' safety and health needs in the 
event of a future disaster in several areas, including clearly defining 
the criteria to be used in deciding when OSHA will be responsible for 
carrying out its duties under the Annex to the NRP; clarifying OSHA's 
and FEMA's roles under the Annex; and proactively working to provide 
information to other federal, state, and local agencies about the role 
that OSHA plays in a major disaster and the assistance it can provide. 
We are also recommending that the Secretary of Labor direct OSHA to 
establish a process for collecting data on injuries and illnesses 
sustained by workers who respond to disasters and develop, implement, 
and monitor an incident personal protective equipment program as 
defined in the Annex. Finally, we are recommending that the Secretaries 
of the Departments of Labor and Health and Human Services develop a 
plan for coordinating and providing mental health services in the event 
of a future disaster. In responding to a draft of this report, 
officials with the Departments of Health and Human Services and 
Homeland Security agreed with our recommendations and provided 
technical comments that we incorporated as appropriate. The Department 
of Health and Human Services provided general written comments. (See 
app. III for a copy of its comments.) The Department of Labor agreed 
with one of our recommendations and, while it did not comment on the 
other recommendations, stated generally that we did not give the agency 
enough credit for the actions it took during its response to Hurricane 
Katrina and disagreed with some of the findings. (See app. IV for a 
copy of the agency's comments and our response.) The Departments of 
Labor and the Interior; the Coast Guard; and the National Guard also 
provided technical comments, which we incorporated as appropriate. 
Although they were provided with a draft for comment, DOD did not 
respond to our request for comments. Officials with EPA, USACE, and the 
Department of Agriculture told us that they had no comments. 

Background: 

The Role of OSHA in Occupational Safety and Health: 

The Occupational Safety and Health Act of 1970 authorizes OSHA to set 
occupational safety and health standards, rules, and regulations and to 
enforce their compliance. OSHA uses two approaches--enforcement and 
compliance assistance. 

Enforcement is carried out primarily by using compliance officers to 
inspect employer work sites. Employers whose work sites fail to meet 
federal safety and health standards face sanctions, such as paying 
penalties for violations of safety and health standards. In this 
enforcement capacity, OSHA targets employers for inspection using 
injury and illness rates for industries and specific work sites. OSHA 
also conducts inspections when employers report fatalities or serious 
injuries and when workers file complaints alleging that a violation of 
a safety or health standard exists that threatens physical harm or that 
an imminent danger exists at their work sites. 

Cooperative programs, in contrast, use a variety of incentives to 
encourage employers to work with OSHA to reduce hazards and institute 
practices that foster safer and healthier working conditions. Such 
incentives include free consultations, recognition for exemplary safety 
and health systems, and exemption from routine inspections. 

OSHA has direct enforcement responsibility for federal workers in all 
states and for private sector workers in about half the states. In the 
remaining states, OSHA has granted approval for the states to conduct 
their own enforcement of private sector, state, and local government 
work sites.[Footnote 1] None of the three states most affected by 
Hurricane Katrina conducts its own worker safety and health program; 
OSHA provides direct oversight for workers in these states. 

OSHA is organized by regional and area offices. The three states most 
affected by Hurricane Katrina are located in OSHA's Region 4 
(Mississippi and Alabama) and Region 6 (Louisiana). Its area offices in 
these states are located in Jackson, Mississippi; Mobile, Alabama; and 
Baton Rouge, Louisiana.  

Federal and private sector employers are required by OSHA to maintain 
records documenting certain work-related injuries and illnesses: those 
that result in death, 1 or more days away from work, restricted work, 
loss of consciousness, or a significant injury or illness diagnosed by 
a physician. Each employer's work site is required to record illness 
and injury data on a form known as an "OSHA 300 log." While employers 
are not required to submit these logs to OSHA, they must be available 
for inspection upon request. Federal agencies are required to submit 
summary information to OSHA about their safety and health programs on 
an annual basis, but these reports generally do not contain information 
on specific injuries and illnesses sustained by their workers. 

The Role of OSHA in a Disaster: 

Based on lessons learned during the response to the World Trade Center 
disaster, OSHA now uses its statutory enforcement discretion during a 
disaster to exempt selected employers from normal enforcement 
operations and provide technical assistance and consultation in 
combination with traditional enforcement as required by the 
incident.[Footnote 2] At the World Trade Center, OSHA made this 
decision based on the recognition that a rescue effort should not be 
hampered, that enforcement takes time and can affect the speed of the 
correction of safety and health hazards, and that its goal was 
protection, not citation. The Assistant Secretary of OSHA, in 
conjunction with regional administrators, makes the decision when to 
exercise its enforcement discretion and move to a technical assistance 
role, and when to return to traditional enforcement.  

While federal, state, and local agencies as well as private sector 
employers are responsible for ensuring the safety and health of their 
workers, OSHA is responsible for coordinating with other federal 
cooperating agencies to provide safety and health technical assistance 
to response and recovery workers involved in the response to a 
disaster. The federal cooperating agencies are DOD; the Departments of 
Energy, Health and Human Services, and Homeland Security; and EPA. 

As the lead coordinating agency for the Worker Safety and Health 
Support Annex (the Annex), OSHA's coordination responsibilities 
include: 

1. providing occupational safety and health technical advice and 
support to safety officials at the Joint Field Office, a temporary 
federal facility established at the site of a disaster to coordinate 
federal assistance to affected jurisdictions; 

2. developing and implementing site-specific occupational safety and 
health plans and ensuring that the plans are coordinated and consistent 
among multiple sites; 

3. identifying and assessing health and safety hazards and 
characterizing the incident environment, to include continued 
monitoring of incident safety on a 24-hours-a-day, 7-days-a-week basis; 

4. monitoring responder personal exposure on a 24-hours-a-day, 7-days- 
a-week basis, including monitoring for chemical and biological 
contaminants, noise, heat or cold, and ionizing radiation; 

5. monitoring the medical condition of responders and, in conjunction 
with the Department of Health and Human Services, evaluating the need 
for longer term monitoring; 

6. assessing responder safety and health resource needs and identifying 
sources for those assets; 

7. developing, implementing, and monitoring an incident personal 
protective equipment program--including the selection, use, and 
decontamination of the equipment; implementation of a respiratory 
protection fit-test program--and distribution of equipment; 

8. collecting and managing data on exposures, accidents, and injuries 
to facilitate consistent formatting and data sharing among response 
organizations; 

9. communicating with labor unions, contractors, and other 
organizations regarding responder safety and health issues; 

10. coordinating and providing incident-specific responder training; 

11. providing psychological first aid during and after incident 
response and recovery activities; and: 

12. identifying, in coordination with the Department of Health and 
Human Services, appropriate immunization and prophylaxis for responders 
and recovery workers. 

Even though OSHA has been assigned responsibility for coordinating the 
activities in the Annex, during an actual disaster, FEMA must issue a 
"mission assignment" that authorizes OSHA to receive reimbursement for 
carrying out some or all of these activities, depending on the needs of 
the disaster and which groups are covered during each response effort. 
Without a mission assignment, services provided by an agency cannot be 
reimbursed by FEMA.[Footnote 3] For Hurricane Katrina, FEMA issued 
mission assignments to OSHA tasking it with 11 of the 12 activities 
listed in the Annex for federal agencies and their workers, including 
federal contractor employees. The only activity in the Annex for which 
OSHA was not assigned responsibility for Hurricane Katrina was 
monitoring the medical conditions of responders, including assessing 
the need for long-term medical monitoring because, according to FEMA, 
it does not have the authority under the Stafford Act to pay for the 
collection and management of data for long-term studies or 
analysis.[Footnote 4] FEMA also did not assign responsibility to OSHA, 
or any other federal agency, for coordinating the safety and health of 
nonfederal workers, except workers employed by federal contractors. 
State and local agency employees, private sector employees other than 
those employed by federal contractors, and volunteers were not covered 
under the Annex.[Footnote 5] OSHA had difficulty addressing the needs 
of nonfederal workers not covered under its mission assignment, but was 
able to provide some assistance to these workers using its own funds. 

No One Collected Information on the Total Number of Response and 
Recovery Workers Deployed to the Gulf Coast, but 10 Federal Agencies 
Collected Data on Their Workers: 

No one, including OSHA, was assigned responsibility for collecting data 
on the total number of response and recovery workers deployed to the 
Gulf and no one collected it, but 10 federal agencies were able to 
provide estimates of the number of federal workers they deployed to the 
Gulf for specific points in time. However, only six of them tracked the 
number of workers employed by their contractors.[Footnote 6] According 
to FEMA and OSHA, 10 federal agencies deployed response and recovery 
workers to the Gulf in response to Hurricane Katrina: the Departments 
of Agriculture, the Interior, and Health and Human Services; the Coast 
Guard; DOD; EPA; FEMA; OSHA; USACE; and the National Guard. We asked 
officials from these 10 agencies to provide us with the total number of 
response and recovery workers they had in the Gulf Coast from August 
2005 through April 2006. Agency officials said they did not collect 
data in a way that would enable them to provide us with unduplicated 
counts of workers who rotated in and out of the Gulf Coast area. All 10 
agencies, however, told us they could provide us with estimates of the 
number of workers they had in the Gulf Coast area at any specific point 
in time. Therefore, we asked them to provide us with information on the 
number of workers they employed in the three states on the first of 
each month for the period from September 2005 to April 2006. 

As shown in figure 1, the agencies estimated that they had about 31,000 
federal employees in the Gulf Coast area on September 1, 2005. That 
number increased to approximately 49,000 workers on October 1, 2005, 
and dropped to about 8,500 workers on April 1, 2006. 

Figure 1: Estimated Number of Federal Employees in the Gulf Coast Area 
on the First Day of Each Month, September 2005 to April 2006: 

[See PDF for image] 

Source: Data obtained from selected federal agencies. 

[End of figure] 

The National Guard reported having the largest number of federal 
employees--about 31,000--in the Gulf Coast area on October 1, 2005, and 
FEMA reported the second largest number--about 4,800 workers. The Coast 
Guard reported the third largest number of federal employees in 
October--approximately 3,100 workers. OSHA reported that it had 84 
staff in the Gulf Coast area on the first of October and November 2005. 

Of these 10 federal agencies, only six of the agencies that employed 
contractors in the Gulf area--EPA, OSHA, FEMA, and the Departments of 
Agriculture, Health and Human Services, and the Interior could provide 
data on the number of employees their contractors employed. These 
agencies estimated that their contractors had over 5,100 workers in the 
Gulf Coast area on December 1, 2005, the month with the largest total 
number. FEMA and EPA reported the most contractor employees: FEMA 
estimated that it had approximately 3,800 contractor employees at one 
point, and EPA estimated that its contractors had about 1,200 workers 
in the Gulf area. The other agencies reported much smaller numbers of 
contractor employees, ranging from 1 worker to 150. USACE and Coast 
Guard officials told us they could provide us with information on the 
number of contracts they issued, but they did not know the number of 
workers employed under each of these contracts. Officials with DOD told 
us that, although DOD employed contractors in the Gulf area, they did 
not track the number of workers employed by their contractors. National 
Guard officials told us that they did not employ any contractors. 

OSHA Was Unable to Collect Information on Workers' Injuries and 
Illnesses: 

Although OSHA was directed by FEMA to collect information from federal 
agencies on injuries and illnesses sustained by federal workers during 
the response to Hurricane Katrina, the agency was unable to collect 
useable information from all of the agencies that deployed workers to 
the Gulf. Four federal agencies provided some information to us on 
their workers who were injured or became ill, and OSHA and other 
agencies provided information on worker fatalities that occurred during 
the response. 

Several Factors Hindered OSHA's Efforts to Collect Data on Injuries and 
Illnesses: 

Although the Annex assigned responsibility to OSHA for collecting data 
on workers' injuries and illnesses during disasters, and FEMA directed 
OSHA to collect this information from federal agencies for Hurricane 
Katrina, several factors hindered OSHA's efforts to collect these data 
as required. OSHA did not establish a process for gathering these data 
between the time the Annex was issued in December 2004 and when 
Hurricane Katrina hit the Gulf Coast in late August 2005. According to 
OSHA officials, during this 8-month period, they focused their efforts 
on introducing federal, state, and local agencies to OSHA's new role 
under the Annex in a disaster rather than developing a process for 
collecting data on workers' injuries and illnesses during a response. 

The second factor that hindered OSHA's ability to collect data on 
workers' injuries and illnesses was that fact that FEMA did not issue a 
mission assignment directing OSHA to collect these data for federal 
agencies' workers until more than 3 weeks after the hurricane hit the 
Gulf. FEMA instructed OSHA to track workers' injuries and illnesses 
across all federal agencies that deployed workers to the Gulf in the 
mission assignment it issued to OSHA on September 21, 2005, more than 3 
weeks after the hurricane struck on August 29, 2005. 

Third, OSHA tried to collect data on injuries and illnesses for federal 
workers in the Gulf Coast area from the logs that OSHA requires 
agencies to maintain at each worksite on workers' injuries and 
illnesses but received incomplete or unreliable data from federal 
agencies. In November 2005, OSHA asked federal agencies and their 
contractors to submit their injury and illness logs for worksites 
located in the Gulf area to OSHA headquarters on a monthly basis. 
However, according to OSHA officials, because they did not request 
agencies to provide their injury and illness logs to OSHA until five or 
six weeks after the hurricane hit, and because agencies are normally 
not required to send their logs to OSHA, not all agencies submitted 
their logs. In addition, many of the agencies could not separate data 
for workers assigned to the Gulf Coast area temporarily since employers 
are not required to establish separate logs for temporary worksites 
expected to be in operation for one year or less. Some agencies 
provided their logs to OSHA, but the data they provided were incomplete 
and unreliable, according to OSHA officials. For example, one agency's 
logs included information on accidents involving heavy equipment but 
did not contain information on the related injuries to workers. OSHA 
officials cited several reasons for the poor quality of the data, 
including the fact that the agencies may have placed a low priority on 
recording injuries and illnesses while responding to a disaster. 

In technical comments on the draft report, OSHA officials stated that 
neither their efforts to educate the federal community about the Annex 
nor the more than 3-week delay in receiving its mission assignment 
prevented them from developing a system for collecting injury and 
illness data. 

In a mission assignment, FEMA tasked OSHA to collect these data in 
order to facilitate consistent formatting and data sharing among 
response organizations. OSHA could then use the data to track emerging 
trends in the types of injuries and illnesses sustained by workers so 
that appropriate measures, such as providing specific safety training 
and information on hazards, could be taken to address emerging safety 
issues and prevent or reduce injuries and illnesses. Although OSHA was 
unable to use injury and illness data to track emerging trends, it did 
identify some injuries and illnesses that occurred during the response 
through the information it obtained from other federal agencies at the 
Interagency Safety Committee meetings held at the Joint Field Office in 
each state. 

Available Data from Four Agencies Show Over 3,000 Injuries and 
Illnesses: 

Because OSHA could not provide data on injuries and illnesses, we asked 
the 10 agencies that deployed workers to the Gulf Coast area for these 
data. However, although agency officials told us they collected 
information on the injuries and illnesses for their workers on the 
injury and illness logs required by OSHA, most of them could not 
separate out this information for workers sent to the Gulf Coast. Four 
of the 10 agencies--EPA, USACE, the Coast Guard, and the Department of 
the Interior--collected information on the injuries and illnesses their 
workers sustained in the Gulf Coast area using their own data systems. 
The four reported that their workers sustained over 3,000 injuries and 
illnesses from the end of August 2005 through June 2006 including minor 
injuries that would not have been recordable on the OSHA logs. The most 
frequently cited injuries were bites from insects such as mosquitoes 
and dogs; sunburn; exposure to floodwater; heat stress; and exposures 
to chemicals, infectious or biological agents, mold, and carbon 
monoxide. (See app. II for additional information on the injury and 
illness data provided by these four agencies.) The data were not 
comparable across the four agencies because each one collected 
different types of information and categorized it differently. For 
example, EPA used nonstandard, detailed descriptions of the illness or 
injury, such as "tripped on wire and bruised knee," while the Coast 
Guard described the health effects of injuries or exposures using 
consistent and concise categories, such as "infected skin" and "skin 
laceration." 

The Department of Labor's Office of Workers' Compensation Program, 
another source of data on injuries and illnesses, reported that federal 
workers filed 770 claims related to Hurricanes Katrina and Rita from 
August 2005 through June 2006.[Footnote 7] While data on the number of 
claims were reliable, the information on the nature and causes of the 
injuries and illnesses was not reliable. Therefore, we could not use it 
to identify the types of injuries and illnesses sustained by federal 
workers in the Gulf Coast area. 

Eleven Worker Fatalities Related to Hurricane Katrina Reported: 

OSHA and other agency officials identified 11 fatalities of workers 
involved in response and recovery work for Hurricane Katrina from 
September 2005 through June 2006, 9 of which occurred as a result of 
work-related accidents.[Footnote 8] No worker fatalities directly 
related to the response were reported in Alabama. In Louisiana and 
Mississippi, three federal agency contractor employees died in work- 
related accidents, including two employees of FEMA subcontractors and 
an employee of a USACE subcontractor. (See app. II for additional 
information.) 

OSHA Provided Assistance to Many Agencies and Workers, but Its Efforts 
to Meet the Safety and Health Needs of All Workers Were Hampered by 
Several Factors: 

Although FEMA did not issue a mission assignment to OSHA implementing 
the Annex until more than 3 weeks after Hurricane Katrina struck the 
Gulf Coast, OSHA was able to establish several of its operations within 
hours of the hurricane. FEMA officials told us that all of the NRP's 
annexes take effect when the NRP is implemented, but OSHA officials 
said they must first receive a mission assignment from FEMA to receive 
funding and begin the work as described in the Annex. OSHA used its own 
staff and budget to establish operations and provide assistance to 
utility workers in the Gulf Coast before to receiving authorization 
from FEMA. OSHA staff developed health and safety plans, provided 
information on safety and health hazards to many workers, and 
intervened in thousands of potentially hazardous situations. OSHA staff 
also assessed air, water, soil, and noise hazards at many worksites. 
However, OSHA waited to provide assistance that involved substantial 
funding--such as deploying worker safety and health trainers and 
purchasing protective gear for other federal agencies--until FEMA 
formally authorized OSHA to receive reimbursement for these activities 
through mission assignments. Disagreements between OSHA and FEMA 
delayed issuance of the mission assignment that implemented the Annex, 
which delayed OSHA's efforts to provide assistance to workers. In 
addition, lack of awareness by other agencies about OSHA's role in a 
disaster further hindered its efforts. Because of these and other 
factors, the agency was unable to ensure that all workers' needs for 
safety and health assistance were met, including obtaining needed 
training, protective gear, and mental health services, and OSHA had 
difficulty addressing the needs of nonfederal workers not covered under 
its mission assignments. 

OSHA Established Operations Quickly, Developed Health and Safety Plans, 
Provided Valuable Information, Intervened in Hazardous Situations, and 
Sampled Work Sites: 

OSHA Quickly Established Operations in the Gulf: 

OSHA effectively used its existing relationships with private companies 
and another federal agency to quickly establish its operations in the 
Gulf Coast area and provide safety and health assistance to workers. 
Through these relationships, OSHA quickly set up staging areas for its 
staff, obtained needed equipment, and provided safety and health 
information to workers early in the response. For example, when OSHA 
had difficulty finding housing for its staff in New Orleans, it 
contacted a chemical company that is part of one of OSHA's cooperative 
programs, and the company gave OSHA space in its parking lot for 
recreational vehicles that OSHA used to house several of its field 
staff. OSHA also obtained support from the Mine Safety and Health 
Administration, another agency within the Department of Labor, for 
almost 3 months after the hurricane. The agency provided OSHA with two 
large trailers equipped with satellite communications that it uses for 
mine rescue operations. OSHA used the trailers as mobile command post 
centers to communicate with other agencies at a time when communication 
in the area was very difficult. The agency also gave OSHA generators to 
power electricity and plumbing. 

OSHA also capitalized on relationships with utility companies 
established during previous responses to hurricanes in the three 
affected states to target its safety and health assistance. Utility 
companies are among the first responders on the scene of hurricanes, 
restoring power and communications in the affected areas. OSHA 
accompanied the utility companies to staging areas each morning to 
brief workers on safety and distribute printed safety information. OSHA 
also advised utility workers on using the proper safety equipment. For 
example, although utility workers were trained on how to safely handle 
downed power lines, some were not aware that they needed to wear boots 
with steel shanks to prevent puncture wounds from debris containing 
nails and other sharp objects or that floodwater and drainage pipes 
could contain alligators, snakes, or other animals. Figure 2 shows some 
of the wildlife encountered by Hurricane Katrina response workers. 

Figure 2: Animals Such as Snakes and Alligators Presented Hazards to 
Workers in the Gulf Coast Area: 

[See PDF for image] 

Source: EPA. 

[End of figure] 

OSHA Developed a Health and Safety Plan for the Entire Response and 
Helped Other Federal Agencies Develop Their Own Plans: 

OSHA developed a health and safety plan for the federal response to 
Hurricane Katrina that included all responders and hazards commonly 
encountered. The plan included information on how to: 

* monitor exposures; 

* provide adequate supplies of protective gear that was: 

- appropriate for the hazard, 

- fitted to the employee, and: 

- inspected, repaired or replaced as necessary; 

* provide training on safety and health hazards that was: 

- conducted before deployment, 

- applicable to general conditions, 

- customized for different sites, and: 

- customized for specific tasks; 

* develop decontamination procedures; and: 

* provide psychological first aid and other mental health services. 

OSHA also assisted other federal agencies in developing similar plans 
for their workers and ensured that all of the plans were coordinated 
and consistent across the response. 

OSHA Provided Information on Common Hazards on Its Web Site and in 
Public Places on the Gulf Coast: 

OSHA also provided information about hazards on its Web site and 
directly to workers at public places such as hardware stores where they 
purchased materials. For example, OSHA developed 58 small, laminated 
"quick cards" and 1-page fact sheets in English and Spanish with 
information about hazards and how to address them, such as how to 
safely handle traffic in work zones, how to operate a chain saw safely, 
how to work safely with electricity, how to prevent falls, and how to 
use ladders safely. See figures 3 and 4 for selected quick cards and 
fact sheets distributed by OSHA. 

Figure 3: Selected Quick Cards Developed by OSHA for Hurricane Katrina: 

[See PDF for image] 

Source: OSHA. 

[End of figure] 

Figure 4: Selected Fact Sheets Developed by OSHA for Hurricane Katrina: 

[See PDF for image] 

Source: OSHA. 

[End of figure] 

OSHA also provided pre-recorded public service announcements on its Web 
site with information on safe work practices that could be aired by 
local radio stations and stores. According to OSHA officials, one large 
national hardware chain played the public service announcements over 
its loudspeaker system in stores in the Gulf area as a safety and 
health reminder for its customers. 

OSHA Intervened at Work Sites by Correcting Potential Hazards: 

From the beginning of the response in August 2005 through June 2006, 
OSHA's field staff intervened in more than 15,000 potentially hazardous 
situations at work sites throughout the Gulf--6,800 in Louisiana and 
8,320 in Alabama and Mississippi.[Footnote 9] OSHA targeted these 
visits based on information it received from other federal agencies and 
utility companies about work sites with large numbers of workers or 
potential hazards. As shown in figures 5, 6, and 7, OSHA staff 
intervened in many different types of hazardous situations, including 
work zones containing equipment not protected from traffic by safety 
cones and individuals working on water towers and roofs without proper 
fall protection such as safety harnesses and guard rails. 

Figure 5: Work Zones with Equipment Not Protected from Traffic by 
Safety Cones: 

[See PDF for image] 

Source: OSHA. 

[End of figure] 

Figure 6: Workers on a Water Tower without Fall Protection Such As 
Guard Rails or Safety Harnesses: 

[See PDF for image] 

Source: OSHA. 

[End of figure] 

Figure 7: Workers on a Roof without Safety Harnesses and with Poorly 
Secured Ladders: 

[See PDF for image] 

Source: OSHA. 

[End of figure] 

OSHA staff offered advice on safety and health measures and followed up 
to make sure hazards were corrected. For example, an OSHA official in 
Louisiana stopped work at a site until unprotected workers in an aerial 
lift 50 feet above the ground received safety harnesses and orange 
cones were placed around the lift to protect against traffic. On the 
few occasions when an employer did not follow OSHA's recommendations, 
or if there were repeat problems with an employer, OSHA would elevate 
its concerns to company management or to the federal agency that 
contracted with the company and this usually brought abut the needed 
changes, according to OSHA officials. For example, OSHA staff told a 
supervisor at one worksite that workers repairing a bridge needed 
safety harnesses to protect them from falls, but the workers did not 
have the equipment when OSHA visited the next day. OSHA staff then 
called the owner of the company, who promptly provided the safety 
equipment and made sure the workers used it. 

Other federal agencies asked OSHA to intervene in hazardous situations. 
For example, EPA asked OSHA to monitor the health of workers at the 
site of an oil spill where more than a million gallons of crude oil 
leaked from an above-ground storage tank. FEMA asked OSHA to provide a 
hazardous materials specialist to accompany its staff to jails and 
Department of Justice buildings in New Orleans and assess what 
protective gear was needed to enter and inspect buildings and to a 
local hospital to assess general safety and health hazards. FEMA also 
asked OSHA to conduct air-monitoring tests and assess hazards at local 
courts and other public buildings in the area, and OSHA staff advised 
FEMA on how to properly ventilate temporary housing trailers 
contaminated with formaldehyde gas emitted by construction materials 
such as plywood and rugs. 

Officials with OSHA and other federal agencies told us that the 
technical assistance OSHA provided during the response was well 
received and was more effective in protecting workers than if the 
agency had been operating in an enforcement mode. The officials noted 
that enforcement actions can take months to complete due to the legal 
requirements of an investigation, the amount of documentation required, 
and the due process provided to employers to appeal citations. By 
providing technical assistance and immediately addressing hazardous 
situations, OSHA officials said they were able to assist many more 
workers and correct more hazardous situations during the response than 
if they had been operating in an enforcement mode. OSHA typically 
conducts about 1,500 inspections each year in the three affected 
states--about 430 in Alabama, about 530 in Louisiana, and about 500 in 
Mississippi--but intervened in over 15,000 potentially hazardous 
situations during approximately 11 months of the response. 

OSHA Sampled Air, Water, Soil, and Noise Levels at Many Work Sites: 

In addition to providing safety and health technical assistance, OSHA 
also took more than 6,000 samples at work sites throughout the Gulf 
Coast area to assess air, water, soil, and noise hazards. As shown in 
figure 8, workers in the Gulf Coast area faced many airborne hazards. 

Figure 8: Airborne Hazards on the Gulf Coast: 

[See PDF for image] 

Source: OSHA. 

[End of figure] 

EPA was responsible for sampling the general environment--such as the 
air, water, and soil--in order to assess the dangers to the public, 
while OSHA was responsible for sampling worksites for hazardous 
substances harmful to workers. For example, OSHA field staff pinned 
small personal monitors on workers' clothing to sample for potential 
exposure to hazardous chemicals and substances, and sampled water and 
soil at worksites (see fig. 9). 

Figure 9: OSHA Field Staff Sampling the Air, Water, and Soil on the 
Gulf Coast by Pinning a Small Personal Monitor to a Worker, Taking 
Water Samples, and Taking Soil Samples: 

[See PDF for image] 

Source: OSHA. 

[End of figure] 

OSHA field staff also monitored unoccupied buildings for carbon 
monoxide that may have accumulated from the use of generators before 
the building was vacated and to determine whether the siding and 
shingles contained asbestos. OSHA officials told us they posted the 
results of the samples taken on the agency's Web site and said they are 
developing a data management system for future disasters that will 
provide faster access to sampling results. 

Disagreements with FEMA and Lack of Awareness of OSHA's Role Hindered 
OSHA's Efforts to Assist Other Agencies: 

OSHA and FEMA disagreed about how and when to implement the Annex and 
about each agency's responsibilities in the rescue and recovery effort. 
As a result, some of OSHA's efforts to provide assistance were delayed. 
Additionally, before Hurricane Katrina, OSHA provided limited 
information to federal, state, and local agencies about the Annex, and 
many agencies did not understand the services OSHA can provide or that 
OSHA provides technical assistance, not enforcement, in a disaster. 
This may have contributed to agencies not inviting OSHA to participate 
in emergency preparedness exercises held prior to Hurricane Katrina or 
asking for OSHA's help during the response and recovery efforts once 
the storm hit. 

OSHA and FEMA Disagreed about Implementation of the Annex and about 
Each Other's Roles and Responsibilities: 

FEMA did not issue a mission assignment to OSHA implementing the Annex 
until September 21, 2005--more than 3 weeks after the hurricane hit the 
Gulf Coast. Before Hurricane Katrina, FEMA and OSHA had not developed 
criteria or procedures for implementing the Annex in a 
disaster.[Footnote 10] FEMA officials told us that all of the NRP's 
annexes take effect when the NRP is implemented; however, OSHA said it 
must first receive a mission assignment from FEMA to receive funding 
and begin its work as described in the Annex. OSHA used its own staff 
and budget to establish operations and provide assistance to workers in 
the Gulf before receiving authorization for reimbursement from FEMA. 
However, OSHA delayed activities that involved substantial funding, 
such as deploying worker safety and health trainers and purchasing 
protective gear for other federal agencies, until FEMA formally 
authorized funding through mission assignments, assuring that such 
activities would be reimbursed. However, although FEMA and OSHA were 
developing procedures for their operations in future disasters, as of 
December 2006, these procedures did not contain criteria that clearly 
defined when and how OSHA will carry out its responsibilities under the 
Annex or the type or magnitude of disasters in which OSHA will be 
involved. 

FEMA and OSHA also disagreed about which agency was in charge of worker 
safety and health for the response and recovery efforts and which 
workers should be covered. The agency in charge assumed the role of 
Safety Coordinator at the Joint Field Office in each state, where the 
federal agencies met to coordinate their response and recovery efforts. 
Because of their disagreement about leadership, FEMA and OSHA each 
fulfilled the role of Safety Coordinator for different periods of time 
in Louisiana, Alabama, and Mississippi, and other federal agencies did 
not know which agency was consistently and officially in charge. In 
addition, some FEMA officials viewed the role of the Safety Coordinator 
as providing support only to FEMA employees and personnel at FEMA- 
managed facilities. In contrast, OSHA officials saw the role of the 
Safety Coordinator as supporting all federal workers, including federal 
contractor employees involved in the response. For example, both FEMA 
and OSHA officials in Mississippi identified a need for driver training 
because of the large number of motor vehicle accidents. FEMA's Safety 
Coordinator in Mississippi sought the driver training for FEMA staff 
only, while, under its mission assignment, OSHA had already worked with 
the National Institute of Environmental Health Sciences to develop a 
similar program that was available to all federal responders. 

In addition, under the Annex, OSHA is responsible for coordinating with 
the Department of Health and Human Services to monitor the medical 
conditions of responders and evaluate the need for long-term medical 
monitoring. However, FEMA did not direct OSHA to coordinate this 
activity in the mission assignments issued for Hurricane Katrina 
because, according to FEMA officials, they do not have the authority 
under the Stafford Act to pay for the collection and management of data 
for long-term studies or analysis. Although it is not clear whether 
there is a need for this type of monitoring for response and recovery 
workers involved in the response to Hurricane Katrina, the fact that 
some workers at the World Trade Center disaster did not exhibit 
symptoms of illnesses until months or years after they left the site, 
and others developed acute conditions at the site that later worsened 
or became chronic, highlights the importance of considering these 
issues for rescue and recovery workers who responded to Hurricane 
Katrina or for those involved in future disasters. 

FEMA and OSHA are in the process of developing new procedures for 
future disasters. However, the procedures do not specify the type or 
magnitude of disaster in which OSHA will be involved, and they include 
FEMA's definition of the scope of the Safety Coordinator as providing 
safety and health support only to FEMA employees and personnel at FEMA- 
managed facilities, not OSHA's definition that covers all responders, 
including federal contractor employees at all facilities. As a result, 
OSHA may have difficulty providing assistance to all workers involved 
in future response efforts. The new procedures also do not resolve the 
issue of how OSHA will be able to monitor the medical condition of 
responders or evaluate the need for long-term medical monitoring in 
future disasters as described in the Annex, given that FEMA does not 
believe it can authorize such activities or reimburse them under the 
Stafford Act. 

Many Agency Officials Were Not Aware of OSHA's Role in a Large 
Disaster: 

OSHA officials told us they did not have enough time to conduct 
extensive outreach to other federal agencies in the months between the 
issuance of the NRP in December 2004 and the end of August 2005 when 
Hurricane Katrina hit the Gulf Coast. They said they planned to inform 
other federal agencies about the Annex and OSHA's new role in large 
disasters through a committee comprised of the key federal agencies 
that have a role in the Annex in responding to disasters. OSHA was in 
the process of developing this committee when Hurricane Katrina hit, 
but these efforts were suspended during the response.[Footnote 11] 

OSHA's efforts to inform state and local agencies about its role under 
the Annex were limited to making presentations and staffing information 
booths at training sessions conducted by the Department of Homeland 
Security after the NRP and Annex became effective in April 2005. The 
sessions were offered in seven cities to state and local emergency and 
health officials from fire departments, police departments, and local 
hospitals. The Department of Homeland Security chose to visit cities it 
considered likely targets in future terrorist attacks: the District of 
Columbia, Chicago, New York, Los Angeles, Seattle, Miami, and Houston. 
According to OSHA and FEMA officials, the presentations were attended 
by individuals from federal, state, and local agencies; trade groups; 
and support personnel. OSHA officials also said they provided 
information about the Annex at meetings and conferences held by 
organizations such as the National Governors' Association. These 
presentations, however, were not targeted to the key state and local 
agencies involved in disaster response efforts, such as state emergency 
management agencies. 

Officials from several federal, state, and local agencies told us that 
they did not understand OSHA's role in a disaster response, including 
providing information on potential hazards, recommending proper 
protective gear, and testing for hazardous substances at work sites. 
They also did not know that, in a disaster, OSHA switches from 
enforcing regulations by conducting inspections of work sites to 
providing technical assistance. National Guard and EPA officials we 
interviewed told us they did not know OSHA's role in disaster response. 
Representatives from state police and fire departments in Louisiana, 
the state highway patrol in Alabama, and the Federal Law Enforcement 
Officers Association--an organization that represents officers from 
more than 50 different federal law enforcement agencies--said they did 
not know that OSHA provides technical assistance in a disaster or that 
they could have asked for OSHA's help. 

OSHA Was Not Invited to Participate in Emergency Preparedness Exercises 
Held Prior to Katrina: 

Because many federal, state, and local agency officials did not 
understand the assistance OSHA could provide in a disaster or its role 
under the Annex, OSHA was not invited to participate in many of the 
emergency preparedness exercises the agencies held prior to Hurricane 
Katrina. Moreover, in the few exercises to which OSHA was invited, the 
Annex was never implemented. For example, OSHA attended a national 
emergency preparedness exercise conducted by FEMA in June 2005 that 
simulated a response to a large, destructive hurricane, but the 
exercise did not include implementing the safety and health Annex. OSHA 
headquarters officials told us they thought the Annex was not 
implemented during these exercises because other agency officials did 
not fully understand the assistance OSHA can provide in a disaster or 
its new role under the Annex. OSHA's participation in state and local 
emergency preparedness exercises held prior to Hurricane Katrina was 
also limited. Two of OSHA Area Office Directors in the affected states 
told us they had difficulty getting invited to participate in state and 
local emergency preparedness exercises, and often when they were 
invited, they did not play an active role in the exercise. For example, 
the Director of OSHA's Mobile Area Office told us he attended regional 
training exercises on his own initiative. It took him a year to 
convince the sponsoring agencies that OSHA provides assistance in a 
disaster, at which point they incorporated OSHA into an exercise 
involving a chemical spill from a railroad car, but OSHA's services 
were not used during the exercise. 

Since its response to Hurricane Katrina, OSHA officials say the agency 
has been invited to participate in more emergency response exercises 
where the Annex is implemented and the agency plays an active role. 
OSHA officials also told us they plan to participate in an exercise 
sponsored by EPA in 2007 that will simulate a large chemical spill. 
OSHA's regional and area office directors told us they continue to look 
for opportunities to participate in regional, state, and local 
emergency preparedness exercises. 

OSHA Was Only Partially Successful in Providing Training, Distributing 
Protective Gear, Serving Nonfederal Workers, and Providing Mental 
Health Services: 

Some of OSHA's Training Was Delayed, and Some Agencies Did Not Request 
Needed Training from OSHA Because They Did Not Realize It Was 
Available: 

Because OSHA and FEMA disagreed about the process for issuing the 
mission assignment authorizing OSHA to receive reimbursement for its 
safety and health training to workers, FEMA did not issue it until more 
than 3 weeks after the hurricane hit the Gulf Coast. As a result, OSHA 
and its cooperating agency, the National Institute of Environmental 
Health Sciences, reported that trainers who were ready to begin work in 
the aftermath of the storm were not deployed to Mississippi until 
October 2005 or to Louisiana until November 2005. In addition, some 
agencies did not ask OSHA to provide training because they did not 
realize that OSHA offered this type of training. For example, EPA 
regional officials told us that, although their response managers noted 
a need for driver safety training in October 2005 because of the large 
number of motor vehicle accidents that occurred in the Gulf Coast area 
during the initial response efforts, it was not provided until March 
2006 because it took them several months to determine that OSHA could 
provide this training. Workers faced many hazardous driving conditions 
during the response to Hurricane Katrina, including missing road signs 
or signs pointing the wrong direction, debris-strewn streets, 
intersections without working traffic signals, and lack of street 
lights--which made nighttime driving especially hazardous. (See fig. 
10.) 

Figure 10: Driving Hazards Faced by Workers in the Gulf Coast Area: 

[See PDF for image] 

Source: OSHA. 

[End of figure] 

OSHA Distributed Some Protective Equipment to Workers but Was Not 
Prepared to Establish a Protective Equipment Program, As Required: 

FEMA authorized OSHA to receive reimbursement for establishing a 
personal protective equipment program as described in the Annex for 
other federal agencies that included the selection, ad hoc 
distribution, fit, use, and decontamination of equipment for the 
response to Hurricane Katrina. While OSHA field staff distributed ear 
plugs, eye goggles, respirators, and safety vests to workers throughout 
the Gulf from supplies they had on hand for the use of OSHA staff, the 
agency was unprepared to establish a program that included procuring 
and distributing needed equipment on an ad hoc basis to other agencies 
as required by its mission assignment from FEMA. In its lessons learned 
from the World Trade Center disaster, OSHA recognized the need to 
ensure an adequate supply of personal protective equipment before a 
future incident and to develop a program to ensure for the storage, 
transportation, and distribution of this equipment through FEMA and 
other federal agencies. However, OSHA did not have such a program in 
place prior to Katrina, and OSHA and FEMA disagreed on how to obtain 
personal protective equipment: OSHA ordered equipment from its 
Cincinnati Technology Center, while FEMA ordered equipment from its 
contractor. In addition, OSHA had not made prior arrangements for 
storing the equipment during the response. OSHA and FEMA resolved their 
disagreements about suppliers and OSHA arranged to store equipment in 
its area offices and FEMA-managed facilities near the Joint Field 
Offices in Louisiana and Mississippi, but these difficulties delayed 
the provision of some equipment to workers and highlighted the need to 
establish a personal protection equipment program in advance of a 
disaster. 

Some federal agency officials reported needing advice on proper 
protective gear, and other officials reported a shortage of equipment. 
For example, National Guard officials in Louisiana told us they would 
have liked information from OSHA on the hazards workers were facing, 
recommendations on how to protect workers, and assistance in obtaining 
protective equipment such as rubber boots needed to protect workers 
from contaminated floodwaters. USACE officials told us they had 
difficulty obtaining sufficient supplies of protective equipment such 
as gloves and reflective vests. 

OSHA officials told us the agency has not yet fully addressed what the 
personal protective equipment program, as defined in the Annex, should 
entail. Issues to be addressed include obtaining agreement with FEMA on 
how such equipment should be purchased and where it will be stored, how 
the equipment will be distributed at disasters, and which workers will 
be entitled to receive the equipment. 

The Need for Mental Health Services Exceeded the Assistance OSHA 
Provided: 

FEMA tasked OSHA with coordinating with the Department of Health and 
Human Services to ensure that mental health assistance was provided to 
workers during the response to Hurricane Katrina.[Footnote 12] However, 
OSHA did not coordinate with them to ensure that all workers in the 
Gulf area who needed mental health services received them, and OSHA had 
difficulty obtaining these services. OSHA and FEMA officials told us it 
was difficult to get mental health counselors to go to the base camps 
where workers lived during the response and to get counselors to 
provide services during off-hours to workers who did not have standard 
work schedules. They also said it was difficult to obtain mental health 
services for non-FEMA employees because while FEMA believed its 
contract with a unit of the Department of Health and Human Services, 
Federal Occupational Health , to provide counseling would cover all 
federal workers responding to Hurricane Katrina, the contractor 
interpreted the contract to only cover FEMA workers. In addition, 
instead of sending counselors to work sites throughout the Gulf, the 
contractor provided a toll-free number for workers to call. This was 
not an effective way to provide services because phone service in the 
Gulf was widely disrupted, and OSHA and FEMA officials said they 
thought on-site counseling was a better way to help workers. Although 
the contractor eventually provided services to non-FEMA employees by 
sending counselors to work sites and base camps in the Gulf area and 
distributing literature about available services, these efforts did not 
begin until late December 2005--too late to address the needs of 
response workers who were most in need of these services and the needs 
of many recovery workers involved early in the response. 

According to a FEMA official, the agency recently began an effort to 
review its contracts to ensure that non-FEMA employees are explicitly 
covered in the event of a future disaster response. However, OSHA 
headquarters officials told us that, in their opinion, ensuring that 
mental health services are available to workers in a disaster response 
should not be part of OSHA's responsibilities under the Annex because 
the agency does not have the resources needed; this responsibility 
should be placed with a federal agency that has subject matter 
expertise and access to appropriate mental health resources, such as 
the agencies within the Department of Health and Human Services. OSHA 
officials we interviewed said they are coordinating with FEMA and the 
Department of Health and Human Services to improve the delivery of 
psychological first aid and informational materials during future 
disasters. Such efforts include distributing pamphlets to workers and 
their families throughout the Gulf area; consulting with other agencies 
to learn what types of mental health assistance are most appropriate 
for workers who respond to disasters; developing pamphlets on mental 
health issues for employers, employees, and their families; and 
distributing these pamphlets to OSHA area offices and other federal 
agencies to use during future disaster responses. 

Although OSHA Provided Some Information and Training to Nonfederal 
Workers in the Gulf, the Safety and Health Needs of Some Workers Were 
Not Met: 

Although OSHA staff intervened to assist any worker when they observed 
unsafe work practices, some of the safety and health needs of 
nonfederal workers not covered by OSHA's mission assignments for 
Hurricane Katrina--state and local government employees, immigrants, 
and volunteers--involved in the response were not met.[Footnote 13] 
OSHA officials in Alabama, Louisiana, and Mississippi said it was 
difficult to address the needs of these populations. The mission 
assignment FEMA issued to OSHA only covered federal workers and federal 
contractor employees. OSHA's efforts, therefore, were focused on those 
workers, and no other federal agency had responsibility for meeting the 
safety and health needs of nonfederal workers. OSHA had limited access 
to state and local workers because the states did not request the 
agency's assistance. OSHA also had difficulty addressing the needs of 
immigrant workers because of language barriers, low literacy levels 
among some immigrants, the transience of many employers that hire 
immigrant workers, and immigrants' fear of deportation and the federal 
government. In addition, OSHA had no authority to compel volunteer 
workers in the Gulf to follow safe work practices. 

Some state and local agency officials reported that they could have 
benefited from additional assistance from OSHA, including information 
about potential hazards and protective equipment for their workers. For 
example, Louisiana state troopers involved in recovering bodies were 
provided with boots and gloves, but officials said they would have 
liked additional information on potential hazards and guidelines on 
appropriate protective gear such as waders and on proper 
decontamination procedures. Similarly, many state and local agencies 
reported that they did not have waders to protect workers from 
contaminated flood waters. An official with the New Orleans Police 
Department told us the only staff who had waders to use during rescue 
efforts were fishermen and hunters who owned their own waders. However, 
because the governors of the three states most affected by Hurricane 
Katrina did not request OSHA's assistance, the mission assignments 
issued to OSHA by FEMA did not cover state or local workers, they only 
covered federal workers. As a result, OSHA's efforts were focused on 
providing assistance to federal agencies and workers. 

Several advocacy groups have issued reports highlighting the worker 
safety and health issues among immigrant workers in the Gulf Coast area 
who lacked information on hazards, training, and protective equipment. 
For example, a study by the Advancement Project, the National 
Immigration Law Center, and the New Orleans Worker Justice Coalition 
concluded that, in their opinion, the level of health and safety 
training and equipment provided to many workers in the Gulf area, 
including immigrants, fell well below federal standards.[Footnote 14] 

OSHA trained its staff on the cultural aspects of working with 
immigrant populations, hired some bilingual field staff, and built 
relationships with immigrant advocacy groups. For example, OSHA's 
Mississippi Area Office hired several Hispanic staff to provide 
training to immigrant workers and participated in several local 
cultural events and job fairs to improve workers' awareness of OSHA's 
role in protecting workers. In addition, OSHA officials in Alabama, 
Louisiana, and Mississippi developed worker safety literature in 
Spanish and Vietnamese, two languages frequently used by non-English 
speaking workers in the Gulf Coast area, and distributed the literature 
at cultural events sponsored by immigrant groups. The unit that 
conducted most of OSHA's training in the Gulf area through an 
interagency agreement, the National Institute of Environmental Health 
Sciences, developed brochures in Spanish and Vietnamese.[Footnote 15] 
(See fig. 11.) 

Figure 11: Safety Brochures in English, Spanish, and Vietnamese: 

[See PDF for image] 

Source: National Institute for Environmental Health Sciences. 

[End of figure] 

OSHA officials told us they issued five public service announcements in 
Spanish and translated 26 safety and health technical assistance 
documents into Spanish and 3 into Vietnamese. They also said they 
worked closely with the Mexican Consulate offices in Houston, Texas and 
Atlanta, Georgia to address concerns about the safety of Hispanic 
workers involved in the response. For example, according to OSHA, the 
consulate in Houston arranged several events in New Orleans designed to 
give the Hispanic community a chance to raise concerns and meet with 
OSHA staff. In addition, OSHA officials said they worked with local 
Catholic churches to reach Hispanic workers in the New Orleans area. 

OSHA also raised concerns about the safety and health of volunteers who 
arrived in the Gulf Coast area to assist in the recovery efforts, 
including concerns about the lack of training and protective equipment 
among the volunteers. For example, OSHA staff encountered several 
volunteers working on roofs without the proper training or proper fall 
protection. OSHA staff intervened when they encountered such situations 
and, according to agency officials in the Gulf area, provided on-site 
training and protective equipment to volunteer workers when it was 
available. 

Conclusions: 

Although OSHA did not have a lot of time to prepare for its new role in 
a disaster between the time the NRP became effective and when Hurricane 
Katrina struck the Gulf Coast, the agency moved quickly to provide 
assistance to workers who were part of the early response effort and 
those involved in recovery work. In preparing for future disasters, 
however, it is important for OSHA to note the areas in which its 
efforts in responding to Hurricane Katrina could have been improved. 
Without the ability to collect data on injuries and illnesses sustained 
by workers involved in disaster recovery efforts, OSHA cannot fulfill 
its role as defined in the Annex to identify trends and use this 
information to prevent further injuries and illnesses by informing 
workers and their employers about potential safety and health hazards. 
Furthermore, unless OSHA and FEMA clearly define their roles, the type 
and magnitude of the disasters in which OSHA will be involved, and how 
and when the Annex will be implemented, there may continue to be delays 
in providing critical assistance and information needed to protect 
workers in future disasters. As a result, workers may sustain injuries 
and illnesses that could have been prevented. In addition, if OSHA and 
FEMA do not resolve the issue of who is responsible for assessing the 
need and paying for long-term medical monitoring of workers involved in 
a response effort, these needs may not be met in future disasters. 

Because OSHA has not taken a proactive role in educating many federal, 
state, and local agencies and their workers about the role the agency 
plays in large disasters, some of the agencies do not know about the 
assistance OSHA can provide or how to request it. Similarly, by not 
seeking opportunities to participate in emergency preparedness 
exercises held by federal, state, and local agencies, OSHA has not been 
able to demonstrate the assistance it can provide or how the agencies 
can obtain its services during a disaster. As a result, without 
knowledge of OSHA's role, it is unlikely that state and local agencies 
will request OSHA's assistance in future disasters, hampering the 
agency's ability to meet the safety and health needs of nonfederal 
workers, many of whom are first responders. Further, because OSHA was 
not prepared to establish a program for providing information on what 
protective equipment is needed or how to use it during future disasters 
or for ensuring that agencies obtain adequate supplies of equipment, 
workers may not be properly protected from potential hazards. Finally, 
some workers' needs for mental health services in future disasters may 
not be not met, and the full extent of workers' unmet mental health 
needs will not be known because OSHA has not coordinated with the 
Department of Health and Human Services to determine how it will assess 
the need for mental health services or ensure that these services are 
provided to rescue and recovery workers. 

Recommendations for Executive Action: 

In order to improve the ability to meet workers' safety and health 
needs in the event of a future disaster, the Secretaries of the 
Departments of Labor and Homeland Security should direct the 
Administrators of OSHA and FEMA to: 

* clearly define the criteria to be used in deciding when OSHA will be 
responsible for carrying out its duties under the Worker Safety and 
Health Support Annex to the National Response Plan, including the types 
and magnitude of disasters in which OSHA will be involved, and: 

* clearly define OSHA's and FEMA's roles under the Worker Safety and 
Health Support Annex, including resolving the issue of how the need for 
long-term medical monitoring of workers involved in the response to 
future disasters will be met; and: 

* proactively work to provide information to federal, state, and local 
agencies about OSHA's role in a disaster and the assistance it can 
provide under the Worker Safety and Health Support Annex, including 
seeking opportunities for OSHA to participate in emergency preparedness 
exercises at federal, state, and local levels. 

In addition, the Secretary of the Department of Labor should direct 
OSHA to: 

* establish a process for collecting data on injuries and illnesses 
sustained by workers who respond to disasters as defined in the Worker 
Safety and Health Support Annex to the National Response Plan, such as 
requiring employers to record injuries and illnesses on logs maintained 
at each disaster work site and periodically submit them to OSHA during 
the response; 

* use the information collected on injuries and illnesses to identify 
safety and health hazards and analyze injury and illness trends; and: 

* develop, implement, and monitor an incident personal protective 
equipment program as defined in the Worker Safety and Health Support 
Annex. 

In order to improve the ability to meet workers' needs for mental 
health services in the event of a future disaster, the Secretaries of 
the Departments of Labor and Health and Human Services should: 

* develop a plan for coordinating and providing mental health services 
to response and recovery workers as described in the Worker Safety and 
Health Support Annex to the National Response Plan. 

Agency Comments and Our Evaluation: 

We provided a draft of this report to the Secretaries of the 
Departments of Agriculture, Health and Human Services, Homeland 
Security, the Interior, and Labor; EPA; the Coast Guard; DOD; the 
National Guard; and USACE for comment. We received written comments 
from the Departments of Health and Human Services and Labor, which are 
reproduced, along with our response in appendixes III and IV. Both 
agencies also provided technical comments, which we incorporated in the 
report as appropriate. 

The Department of Health and Human Services agreed with our 
recommendations. The Department of Labor agreed with our recommendation 
for OSHA to establish a process for collecting data on injuries and 
illnesses sustained by workers who respond to disasters as defined in 
the Annex, although it noted several challenges in doing so. Although 
the agency did not comment on the other recommendations, it disagreed 
with our findings in several areas and provided additional information 
on the actions it took to provide assistance to agencies and workers. 
Officials with the Department of Homeland Security stated in oral 
comments that they agreed with our findings and recommendations and 
provided written technical comments, which we incorporated as 
appropriate. The Department of the Interior, the Coast Guard, and the 
National Guard also provided technical comments, which we incorporated 
as appropriate. DOD did not respond to our request for comments. 
Officials with EPA, USACE, and the Department of Agriculture told us 
that they had no comments on the report. 

We will make copies of this report available upon request. In addition, 
the report is available at no charge on GAO's Web site at 
http://www.gao.gov. 

If you have any questions about the report, please contact me at (202) 
512-5988 or at Hbertonid@gao.govH. Contact points for our Offices of 
Congressional Relations and Public Affairs may be found on the last 
page of this report. Key contributors to the report are listed in 
appendix V. 

Signed by: 

Daniel Bertoni: 
Director, Education, Workforce and Income Security Issues: 

List of Congressional Committees: 

The Honorable Edward M. Kennedy: 
Chairman: 
The Honorable Michael B. Enzi: 
Ranking Minority Member: 
Committee on Health, Education, Labor, and Pensions: 
United States Senate: 

The Honorable Joseph Lieberman: 
Chairman: 
Committee on Homeland Security and Governmental Affairs: 
United States Senate: 

The Honorable Tom Harkin: 
Chairman: 
Subcommittee on Labor, Health and Human Services, Education and Related 
Agencies: 
Committee on Appropriations: 
United States Senate: 

The Honorable Patty Murray: 
Chairman: 
Subcommittee on Employment and Workplace Safety: 
Committee on Health, Education, Labor, and Pensions: 
United States Senate: 

The Honorable George Miller: 
Chairman: 
Committee on Education and Labor: 
House of Representatives: 

The Honorable Tom Davis: 
Ranking Minority Member: 
Committee on Oversight and Government Reform: 
House of Representatives: 

The Honorable James T. Walsh: 
Ranking Minority Member: 
Subcommittee on Labor, Health and Human Services, Education and Related 
Agencies: 
Committee on Appropriations: 
House of Representatives: 

The Honorable Henry Cuellar: 
Chairman: 
The Honorable Charles W. Dent: 
Ranking Minority Member: 
Subcommittee on Emergency Communications, Preparedness, and Response: 
Committee on Homeland Security: 
House of Representatives: 

[End of section] 

Appendix I: Scope and Methodology: 

We met with OSHA national, regional, and area office officials to 
obtain a general understanding of their specific roles and 
responsibilities under the National Response Plan (NRP) and the Worker 
Safety and Health Support Annex (the Annex). We documented the steps 
OSHA took to ensure the safety and health of workers in the Gulf Coast 
area during the response to Hurricane Katrina; the extent of the 
agency's coordination with other federal, state, and local government 
officials; and the lessons learned that included any new initiatives 
that had been implemented or were being considered. 

We also met with officials from federal agencies that, according to 
OSHA and FEMA officials, deployed federal workers and contractor 
employees to the Gulf Coast in response to Hurricane Katrina: OSHA; 
FEMA; EPA; the Coast Guard; DOD; the National Guard; USACE; and the 
Departments of Agriculture, Health and Human Services, and the 
Interior. As a part of our interviews, we asked about them the extent 
of their involvement with OSHA, lessons learned, and specific 
initiatives being implemented or planned to address the challenges 
faced by their workers during Hurricane Katrina. In addition, we 
interviewed representatives of several workers' rights groups to obtain 
their perspectives on the role OSHA played in protecting the safety and 
health of workers involved in the response to Hurricane Katrina, 
including the safety and health of the immigrant population. These 
groups included Boat People SOS, the Mississippi Immigrants Rights 
Alliance, the Center to Protect Workers' Rights, and the New York 
Committee for Occupational Safety and Health. We also reviewed several 
studies on emergency preparation, response, and recovery efforts 
conducted prior to and during Hurricane Katrina. 

We conducted our work from October 2005 to December 2006 in accordance 
with generally accepted auditing standards. 

Analysis of Agency Documents: 

We reviewed provisions of the NRP and the Annex to identify the 
specific roles and responsibilities of OSHA in an incident of national 
disaster or a catastrophic event. We also reviewed state emergency 
management plans in Alabama and Louisiana to determine whether these 
state plans had provisions for ensuring the safety and health of rescue 
and recovery workers. Mississippi did not have a current state 
emergency management plan. 

Site Visits: 

To provide some perspectives on the extent of OSHA effectiveness for 
ensuring safety and health of workers at the state and local levels, we 
conducted site visits in Alabama, Louisiana, and Mississippi, the 
states that suffered the most damage from Hurricane Katrina. We spoke 
with OSHA regional and area officials as well as federal officials from 
FEMA, EPA, and USACE. We also interviewed many state and local response 
and recovery workers, including state police in Louisiana and 
Mississippi; local law enforcement in New Orleans, Louisiana and 
Jackson, Mississippi; firefighters in New Orleans, Louisiana; the 
Louisiana Department of Wildlife and Fisheries; the Louisiana 
Department of Environmental Quality; and a county emergency management 
official in Mississippi. In addition, in March 2006, we attended a 
conference sponsored by the National Institute of Environmental Health 
Sciences that discussed the various lessons learned and challenges 
federal agencies encountered during the responses to Hurricanes Katrina 
and Rita. 

Data from Federal Agencies on Injuries and Illnesses: 

Because OSHA was unable to collect useable data on the number of 
injuries and illnesses sustained by federal workers in the Gulf Coast 
area, we asked the 10 agencies that sent rescue and recovery workers to 
the Gulf Coast to provide this information. Although agency officials 
told us that they tracked illnesses and injuries on the work site logs 
that OSHA requires them to maintain, they were not able to separate out 
this information for all workers deployed to the Gulf Coast because 
injuries and illnesses are recorded at the work sites where workers are 
permanently assigned, not the work sites to which they were temporarily 
assigned during the response. 

We asked these agencies whether they maintained their own data on 
workers who were injured or became ill as a result of their work in the 
Gulf area. Four of the 10 agencies--EPA, USACE, the Coast Guard, and 
the Department of the Interior--provided data on injuries and illnesses 
for workers deployed to the Gulf Coast that were sufficiently reliable 
for us to report. However, each of these agencies used different 
methods to report this information. In an effort to summarize the 
injury and illness data reported by the agencies, we developed a coding 
scheme for classifying and combining the data on injuries and illnesses 
provided by EPA and USACE into more consistent and concise categories. 
For example, we classified an injury described in USACE's data as 
"contractor chain saw operator suffered laceration," as a "laceration," 
and an injury described in EPA's data as "employee lost his footing and 
fell onto the deck landing," as a "trip/fall." We determined that the 
codes used by the Coast Guard were sufficiently reliable in coding 
scheme to use to report the number and types of injuries and illnesses 
sustained by their workers. We received the data from the Department of 
the Interior too late to include it in its entirety but provided a 
brief summary of the types of injuries and illnesses sustained by its 
workers in the Gulf Coast area (see app. II). 

In addition, to determine the number and types of injuries and 
illnesses sustained by their workers, we looked at the nature and 
causes of the injuries and illnesses reported by the four agencies and, 
where possible, the number of injuries and illnesses reported for each 
month. Because some incidents reported by EPA and USACE contained more 
than one injury or illness, we used more than one code to report on the 
type of injury or illness sustained. For example, we classified an 
injury reported by EPA where an employee had "pulled and strain neck 
and back from a motor vehicle accident," as a "motor vehicle accident" 
and a "pain/strain." As a result, the total number of injuries and 
illness reported by the agencies may differ from the numbers we 
reported. 

Data on Federal and State Workers' Compensation Claims: 

Because the data on injuries and illnesses provided by the federal 
agencies on their workers were limited, we obtained information on 
workers' compensation claims filed by federal workers from the 
Department of Labor's Office of Workers' Compensation Programs in order 
to obtain more information about injuries and illnesses sustained by 
federal workers involved in the response. The Office of Workers' 
Compensation Programs provided us with data on 770 claims related to 
Hurricanes Katrina and Rita filed from August 2005 through June 
2006.[Footnote 16] However, we found that the data provided to us on 
claims filed by federal workers were not sufficiently reliable to use 
in reporting the types of injuries and illnesses sustained by federal 
workers involved in the response. 

[End of section] 

Appendix II: Data on the Estimated Number of Federal Workers Who 
Responded to Hurricane Katrina and Their Injuries and Illnesses: 

Officials with OSHA and FEMA told us the following federal agencies 
sent workers to Alabama, Louisiana, and Mississippi--the three states 
that sustained the most damage from Hurricane Katrina--to perform 
rescues and conduct recovery work such as clearing debris: 

1. the Department of Agriculture; 

2. the Department of the Interior; 

3. the Coast Guard; 

4. FEMA; 

5. EPA; 

6. the Department of Health and Human Services, including the Centers 
for Disease Control and Prevention, the National Institutes of Health, 
the Food and Drug Administration, the Office of Force Readiness and 
Deployment, and the Substance Abuse and Mental Health Services 
Administration; 

7. OSHA; 

8. USACE; 

9. DOD, including the Air Force, Army, Navy, and Marine Corps; and: 

10. the National Guard. 

In early May 2006, we asked these agencies to provide us with the 
number of employees and contract employees they employed in the three 
states to assist with rescue and recovery work related to Hurricane 
Katrina from the beginning of the response through April 1, 2006. Many 
agency officials told us that they could not provide the total number 
of workers for the entire period because they did not collect data in a 
way that would enable them to provide us with unduplicated counts of 
workers who rotated in and out of the Gulf Coast area. However, many 
said they could provide us with estimates of the total number of 
workers for specific points in time so we requested such data from all 
10 agencies. 

We asked them to provide the total number of full-time equivalent 
workers they employed in Alabama, Louisiana, and Mississippi on the 
first day of each month from September 1, 2005, through April 1, 2006. 
We also asked them to exclude employees of other agencies that were 
temporarily assigned to them or volunteers who were not government 
employees or contractors. All of the agencies submitted estimates for 
their federal employees working in the Gulf area, although some 
agencies were not able to provide information on all personnel deployed 
to the Gulf Coast.[Footnote 17] Only 6 of the 10 agencies tracked 
information on the number of workers employed by their contractors in 
these three states to work on response and recovery work related to 
Hurricane Katrina: the Departments of Agriculture, the Interior, Health 
and Human Services, EPA, OSHA, and FEMA. Although officials with three 
of the other four agencies--the Department of Defense, USACE, and the 
Coast Guard--said they employed contractors in the Gulf, they did not 
track the number of workers employed by their contractors. Officials 
from the National Guard told us they did not employ contractors in the 
Gulf Coast area. 

We obtained data from OSHA and the other agencies on 11 response and 
recovery workers who died in the Gulf, 9 of whom were killed in work- 
related accidents. OSHA provided information on 10 fatalities, 9 of 
which were work-related, and USACE on 2 fatalities, one of which was 
work-related.[Footnote 18] All of the other agencies said that none of 
their workers was killed during the response to Hurricane Katrina. (See 
table 1 for additional information on these fatalities.) 

Table 1: Number of Fatalities Reported by OSHA and Other Federal 
Agencies: 

State: Louisiana; 
Description of incident: A worker was struck by a bulldozer at a debris 
site; 
Employer: Employee of a federal subcontractor for USACE; 
Work-related?: Yes. 

State: Louisiana; 
Description of incident: A worker was crushed during the installation 
of a parked trailer that was accidentally released and ran over him; 
Employer: Employee of a federal subcontractor for FEMA; 
Work-related?: Yes. 

State: Louisiana; 
Description of incident: A worker who was attempting to reinstall 
electrical services to a residence was electrocuted; 
Employer: Nonfederal employee or volunteer; 
Work-related?: Yes. 

State: Louisiana; 
Description of incident: A worker suffered a massive heart attack while 
sitting in a company truck; 
Employer: Nonfederal employee or volunteer; 
Work-related?: No. 

State: Louisiana; 
Description of incident: A maintenance worker fell 18 feet to his death 
after receiving an electric shock; 
Employer: Nonfederal employee or volunteer; 
Work-related?: Yes. 

State: Mississippi; 
Description of incident: A worker operating a tractor to clear debris 
died when the tractor overturned into a ditch with 5˝ feet of water, 
pinning the operator under the tractor; 
Employer: Employee of a federal subcontractor for FEMA; 
Work-related?: Yes. 

State: Mississippi; 
Description of incident: A worker was killed when a 75 foot pole fell 
from a forklift and struck him; 
Employer: Nonfederal employee or volunteer; 
Work-related?: Yes. 

State: Mississippi; 
Description of incident: A worker fell 40 feet to the floor of a 
warehouse; 
Employer: Nonfederal employee or volunteer; 
Work-related?: Yes. 

State: Mississippi; 
Description of incident: Two workers on a casino barge were overcome by 
hydrogen sulfide fumes and drowned; 
Employer: Nonfederal employees or volunteers; 
Work-related?: Yes. 

State: Mississippi; 
Description of incident: Employee died on the way to work as the result 
of a car accident; 
Employer: Employee of a federal subcontractor for USACE; 
Work-related?: No. 

Source: GAO analysis of OSHA and USACE data. 

[End of table] 

Because OSHA was unable to collect data on the number of injuries and 
illnesses sustained by federal workers in the Gulf Coast area, we asked 
the 10 agencies that sent workers to the Gulf Coast area to provide 
this information. Although agency officials told us that they tracked 
illnesses and injuries on the worksite logs that OSHA requires them to 
maintain, they were not able to separate out this information for all 
workers deployed to the Gulf Coast because injuries and illnesses are 
recorded at the worksites where workers are permanently assigned, not 
the worksites to which they were temporarily assigned during the 
response. 

We asked these agencies whether they maintained their own data on 
workers who were injured or became ill as a result of their work in the 
Gulf Coast area. Four of the 10 agencies--EPA, USACE, the Coast Guard, 
and the Department of the Interior--provided data on injuries and 
illnesses for workers in the Gulf area that were sufficiently reliable 
for us to report. However, each agency used different descriptions of 
the injuries and illnesses to report the information collected. In an 
effort to summarize the data reported by the agencies, we developed our 
own categories to use in classifying and collapsing the descriptions of 
injuries and illnesses provided by EPA and USACE into more consistent 
and easily understood categories. For example, for an injury described 
in USACE's data as "contractor chain saw operator suffered laceration," 
we reclassified it as a "laceration;" and for an injury described in 
EPA's data as "employee lost his footing and fell onto the deck 
landing," we reclassified it as a "trip/fall." We determined that the 
descriptions and categories used by the Coast Guard were sufficiently 
clear to use in reporting the number and types of injuries and 
illnesses sustained by their workers. We received the data from the 
Department of the Interior too late to reclassify it and report it in 
its entirety, but we provided a brief summary of the types of injuries 
and illnesses sustained by its workers deployed to the Gulf Coast on 
page 58. 

To determine the number and types of injuries and illnesses sustained 
by their workers deployed to the Gulf Coast, we looked at the nature 
and causes of the injuries and illnesses reported by the agencies and, 
where possible, the number of injuries and illnesses reported for each 
month. Because some incidents reported by EPA and USACE contained more 
than one injury and/or illness, we used more than one code to report on 
the type of injury and illness sustained. For example, where EPA 
reported that an employee had pulled and strain neck and back from a 
motor vehicle accident, we classified it as "motor vehicle accident" 
and "pain/strain." As a result, the total number of injuries and 
illness reported by these agencies may differ from the types of 
injuries and illnesses reported for that same time frame. 

EPA reported information on the number of injuries and illnesses 
sustained by their federal workers and contractor employees. (See table 
2.) 

Table 2: Reported Number of Injuries and Illnesses for EPA, August 2005 
to June 2006: 

Month: August; 
Region 4: 0; 
Region 6: 0; 
Total: 0. 

Month: September; 
Region 4: 0; 
Region 6: 7; 
Total: 7. 

Month: October; 
Region 4: 1; 
Region 6: 22; 
Total: 23. 

Month: November; 
Region 4: 1; 
Region 6: 32; 
Total: 33. 

Month: December; 
Region 4: 0; 
Region 6: 14; 
Total: 14. 

Month: January; 
Region 4: 0; 
Region 6: 13; 
Total: 13. 

Month: February; 
Region 4: 0; 
Region 6: 12; 
Total: 12. 

Month: March; 
Region 4: 0; 
Region 6: 7; 
Total: 7. 

Month: April; 
Region 4: 0; 
Region 6: 5; 
Total: 5. 

Month: May; 
Region 4: 0; 
Region 6: 8; 
Total: 8. 

Month: June; 
Region 4: 0; 
Region 6: 2; 
Total: 2. 

Month: Total; 
Region 4: 2; 
Region 6: 122; 
Total: 124. 

Source: GAO analysis of EPA data. 

Note: These numbers represent data on EPA agency personnel, employees 
of their contractors, and employees of the Tennessee Valley Authority. 
At OSHA's request, EPA collected data on all types and causes of 
hurricane response-related injuries and illnesses. However, according 
to EPA, the totals do not include some minor injuries and illnesses. 

[End of table] 

EPA also provided information on the types of injuries and illnesses 
these workers sustained. (See table 3.) 

Table 3: Reported Types of Injuries and Illnesses for EPA, August 2005 
to June 2006: 

Type of Injury or Illness: Cut/scrape/bruise; 
Region 4: 0; 
Region 6: 43; 
Total: 43. 

Type of Injury or Illness: Skin condition; 
Region 4: 0; 
Region 6: 16; 
Total: 16. 

Type of Injury or Illness: Pain/strain; 
Region 4: 0; 
Region 6: 13; 
Total: 13. 

Type of Injury or Illness: Animal/insect bite; 
Region 4: 0; 
Region 6: 12; 
Total: 12. 

Type of Injury or Illness: Sprain/fracture; 
Region 4: 1; 
Region 6: 10; 
Total: 11. 

Type of Injury or Illness: Irritation; 
Region 4: 0; 
Region 6: 9; 
Total: 9. 

Type of Injury or Illness: Chemical Splash; 
Region 4: 0; 
Region 6: 6; 
Total: 6. 

Type of Injury or Illness: Trip/fall; 
Region 4: 0; 
Region 6: 4; 
Total: 4. 

Type of Injury or Illness: Medical condition; 
Region 4: 0; 
Region 6: 3; 
Total: 3. 

Type of Injury or Illness: Chemical exposure; 
Region 4: 0; 
Region 6: 3; 
Total: 3. 

Type of Injury or Illness: Infection; 
Region 4: 0; 
Region 6: 2; 
Total: 2. 

Type of Injury or Illness: Exhaustion/dehydration/heat stress; 
Region 4: 0; 
Region 6: 2; 
Total: 2. 

Type of Injury or Illness: Smoke exposure; 
Region 4: 0; 
Region 6: 1; 
Total: 1. 

Type of Injury or Illness: Nausea; 
Region 4: 0; 
Region 6: 1; 
Total: 1. 

Type of Injury or Illness: Burn; 
Region 4: 0; 
Region 6: 1; 
Total: 1. 

Type of Injury or Illness: Viral infection; 
Region 4: 0; 
Region 6: 1; 
Total: 1. 

Type of Injury or Illness: Motor vehicle accident; 
Region 4: 0; 
Region 6: 1; 
Total: 1. 

Type of Injury or Illness: Seizure; 
Region 4: 0; 
Region 6: 1; 
Total: 1. 

Type of Injury or Illness: Acute appendectomy; 
Region 4: 0; 
Region 6: 1; 
Total: 1. 

Type of Injury or Illness: Rupture; 
Region 4: 1; 
Region 6: 0; 
Total: 1. 

Type of Injury or Illness: Total; 
Region 4: 2; 
Region 6: 130; 
Total: 132. 

Source: GAO analysis of EPA data. 

USACE reported information on the number of injuries and illnesses 
sustained by their federal workers and contractor employees. (See table 
4.) 

[End of table] 

Table 4: Reported Number of Injuries and Illnesses for USACE, August 
2005 to June 2006: 

Month: August; 
Total: 0. 

Month: September; 
Total: 64. 

Month: October; 
Total: 99. 

Month: November; 
Total: 49. 

Month: December; 
Total: 40. 

Month: January; 
Total: 95. 

Month: February; 
Total: 70. 

Month: March; 
Total: 75. 

Month: April; 
Total: 46. 

Month: May; 
Total: 17. 

Month: June; 
Total: 7. 

Month: Total; 
Total: 562. 

Source: GAO analysis of USACE data. 

[End of table] 

USACE also reported information on the types of injuries and illnesses 
sustained by these workers. (See table 5.) 

Table 5: Reported Types of Injuries and Illnesses for USACE, August 
2005 to June 2006: 

Injury/Illness Category: Motor vehicle accident; 
Total: 247. 

Injury/Illness Category: Motor vehicle rollover; 
Total: 90. 

Injury/Illness Category: Property damage; 
Total: 62. 

Injury/Illness Category: Struck by object; 
Total: 48. 

Injury/Illness Category: Trip/fall; 
Total: 25. 

Injury/Illness Category: Cut/scrape/bruise; 
Total: 24. 

Injury/Illness Category: Animal/Insect bites; 
Total: 13. 

Injury/Illness Category: Laceration; 
Total: 11. 

Injury/Illness Category: All other injuries; 
Total: 11. 

Injury/Illness Category: Pain/strain; 
Total: 8. 

Injury/Illness Category: Fire; 
Total: 7. 

Injury/Illness Category: Sprain/fracture; 
Total: 6. 

Injury/Illness Category: Broken limb; 
Total: 5. 

Injury/Illness Category: Limb caught in object; 
Total: 4. 

Injury/Illness Category: Skin conditions; 
Total: 3. 

Injury/Illness Category: Operational stress; 
Total: 3. 

Injury/Illness Category: Unknown; 
Total: 3. 

Injury/Illness Category: Burn; 
Total: 2. 

Injury/Illness Category: Contusion; 
Total: 2. 

Injury/Illness Category: Medical conditions; 
Total: 2. 

Injury/Illness Category: Fatality; 
Total: 2. 

Injury/Illness Category: Violence; 
Total: 2. 

Injury/Illness Category: Muscle spasm; 
Total: 1. 

Injury/Illness Category: Heat exposure; 
Total: 1. 

Injury/Illness Category: Gastrointestinal; 
Total: 1. 

Total: 583. 

Source: GAO analysis of USACE data. 

[End of table] 

The Coast Guard provided information on injuries and illnesses 
sustained by their workers and contractor employees from November 2005 
though March 2006 in several different categories. According to Coast 
Guard officials, about 5 percent of the data it received on illnesses 
and injuries that occurred during this period had not been entered into 
its injury and illness tracking system. It reported data on the number 
of types of exposures their federal workers and contractor employees 
experienced during the response. (See table 6.) 

Table 6: Reported Exposures for the Coast Guard, November 2005 to March 
2006: 

Type of Exposure: Animal vector (e.g., bites from insects such as 
mosquitoes or animals such as snakes and dogs); 
Total: 1,171. 

Type of Exposure: Sunburn; 
Total: 1,002. 

Type of Exposure: Floodwater; 
Total: 737. 

Type of Exposure: Heat stress; 
Total: 727. 

Type of Exposure: Chemicals; 
Total: 684. 

Type of Exposure: Infectious agents or biological agents; 
Total: 659. 

Type of Exposure: Mold exposure; 
Total: 562. 

Type of Exposure: Carbon monoxide; 
Total: 246. 

Total number of exposures; 
Total: 5,788. 

Source: GAO analysis of Coast Guard data. 

[End of table] 

The Coast Guard also reported the number of injuries sustained by their 
federal workers and contractor employees. (See table 7.) 

Table 7: Reported Injuries for the Coast Guard, November 2005 to March 
2006: 

Injuries: Penetrating injury; 
Total: 419. 

Injuries: Slips, trips, falls; 
Total: 136. 

Total number of injuries; 
Total: 555. 

Source: GAO analysis of Coast Guard data. 

[End of table] 

In addition, the Coast Guard provided data on the health effects of the 
injuries and illnesses sustained by their federal workers and 
contractor employees. (See table 8.) 

Table 8: Reported Health Effects for the Coast Guard, November 2005 to 
March 2006: 

Health Effects: Sinus infections; 
Totals: 299. 

Health Effects: Diarrhea; 
Totals: 196. 

Health Effects: Skin rash; 
Totals: 179. 

Health Effects: Dehydration; 
Totals: 174. 

Health Effects: Other (e.g., cough, fatigue, flu, headache); 
Totals: 157. 

Health Effects: Joint pain; 
Totals: 151. 

Health Effects: Loss of appetite; 
Totals: 139. 

Health Effects: Muscle strain; 
Totals: 138. 

Health Effects: Depression; 
Totals: 134. 

Health Effects: Nausea; 
Totals: 132. 

Health Effects: Difficulty concentrating; 
Totals: 128. 

Health Effects: Skin lacerations; 
Totals: 87. 

Health Effects: Cramps; 
Totals: 61. 

Health Effects: Vomiting; 
Totals: 50. 

Health Effects: Skin puncture; 
Totals: 50. 

Health Effects: Infected skin; 
Totals: 45. 

Health Effects: Confusion; 
Totals: 38. 

Health Effects: Excessive weight loss; 
Totals: 22. 

Health Effects: Total number of health effects; 
Totals: 2,180. 

No known long-term health effects; 
Totals: 1,295. 

Source: GAO analysis of Coast Guard data. 

[End of table] 

The Coast Guard noted which symptoms occurred during workers' 
deployment and which occurred post-deployment. (See table 9.) 

Table 9: Reported Timing of Symptoms for Health Effects for the Coast 
Guard, November 2005 to March 2006: 

Symptoms During and Post Deployment to the Gulf Coast Area: Symptoms 
while deployed; 
Total: 729. 

Symptoms During and Post Deployment to the Gulf Coast Area: Symptoms 
post deployment; 
Total: 506. 

Source: GAO analysis of Coast Guard data. 

[End of table] 

Finally, the Department of the Interior reported that 90 workers 
sustained injuries or illnesses during the response to Hurricane 
Katrina from August 2005 through April 2006. They included injuries 
such as falls, slips and trips; strains from lifting; dermatitis from 
exposure to poison ivy; and reactions from exposures to toxins, dust, 
gas or chemicals. 

We took several steps to assess the reliability and reasonableness of 
the data the agencies provided. To assess the reliability of the 
agencies' data, we talked with agency officials about their data 
quality control procedures and reviewed relevant documentation. For 
example, we asked about the types of procedures and systems they had in 
place to ensure that the data were collected and reported consistently. 
We found the data were sufficiently reliable for the purposes of this 
report. 

[End of section] 

Appendix III: Comments from the Department of Health & Human Services: 

Department Of Health & Human Services: 
Office of the Assistant Secretary for Legislation: 
Washington, D.C. 20201: 

Feb 17 2007: 

Robert E. Robertson: 
Director: 
Education, Workforce, and Income Security Issues: 
U.S. Government Accountability Office: 
Washington, DC 20548: 

Dear Mr. Robertson: 

Enclosed are the Department's comments on the U.S. Government 
Accountability Office's (GAO) draft report entitled, 'Disaster 
Preparedness: Better Planning Would Improve OSHA's Efforts to Protect 
Workers' Safety and Health in Future Disasters" (GAO-07-193), before 
its publication. 

The Department has provided several technical comments. 

The Department appreciates the opportunity to review and comment on 
this draft. 

Sincerely, 

Signed by: 

Vincent J. Ventimiglia: 
Assistant Secretary for Legislation: 

Comments Of The Department Of Health And Human Services On The 
Government Accountability Office (GAO) Draft Entitled: Disaster 
Preparedness: Better Planning Would Improve Osha's Efforts To Protect 
Workers' Safety And Health In Future Disasters" GAO 07-193: 

General Comments: 

* The fundamental issue that this report brings to the forefront is the 
vital importance of ensuring that disaster planning and response 
includes a focus on worker safety and health. 

* The World Trade Center and Hurricane Katrina/Rita events were 
disasters on an unprecedented scale. The types of hazards and 
environmental risks confronted in such disasters are complex and 
unique. In these events, the physical injuries to relief workers can be 
counted, but the impacts on health are often not revealed until much 
later. The National Institute of Environmental Health Sciences (NIEHS), 
a component of the National Institutes of Health, through its research 
centers and other partners, is beginning to obtain information on the 
relationships between exposures during disaster remediation activities 
and later morbidity. There is a clear public health and research value 
that underscores the GAO recommendation to clarify the roles of federal 
agencies regarding medical monitoring for response workers. 

[End of section] 

Appendix IV: Comments from the Department of Labor and GAO's Response: 

Note: GAO comments supplementing those in the report text appear at the 
end of this appendix. 

U.S. Department of Labor: 
Assistant Secretary for Occupational Safety and Health: 
Washington, D.C. 20210: 

Mar 9 2007: 

Mr. Robert E. Robertson: 
Director, Education, Workforce and Income Security Issues: 
United States Government Accountability Office: 
441 G Street NW, Room 5930: 
Washington, DC 20548: 

Dear Mr. Robertson: 

The Occupational Safety and Health Administration (OSHA) has received 
the Government Accountability Office's (GAO's) draft report to 
congressional committees entitled Disaster Preparedness: Better 
Planning Would Improve OSHA's Efforts to Protect Workers' Safety and 
Health in Future Disasters, and appreciates the opportunity for advance 
review and comment. 

This GAO report represents many months of investigation over a wide 
geographic area about newly-created procedures for responding to 
domestic emergencies and disasters. While GAO accurately captured some 
of OSHA's actions, the report fails to fairly and adequately reflect 
OSHA's efforts to prevent occupational injuries and illnesses and work- 
related fatalities in the Hurricane Katrina response operations. 
Further, it should be noted that OSHA has resolved many of the issues 
noted in the GAO study, which focuses on activities through December 
2005, and continues to make progress on others. 

During OSHA's 12-month involvement in the Hurricane Katrina response, 
the Agency undertook the following tasks aimed at preventing 
occupational injuries and illnesses and work-related fatalities: 

* Distributed over 4,000 pieces of personal protective equipment on an 
ad hoc basis; 

* Developed a sampling plan and took approximately 10,000 samples to 
evaluate potential exposures; 

* Distributed approximately 200,000 OSHA compliance assistance 
products; 

* Interacted with approximately 16,000 federal and private sector work 
crews; 

* Conducted interventions that covered more than 50,000 workers; and: 

* Removed more than 20,000 workers from serious hazards. 

As the report accurately points out, OSHA did not wait for the storm to 
make landfall before taking action to respond to the anticipated 
aftermath of the hurricane. For example, OSHA's regional and area 
offices in Alabama, Georgia, Mississippi, and Louisiana contacted local 
utilities to assist with occupational safety and health issues they 
would encounter after the hurricane. This action was undertaken based 
on lessons learned from earlier hurricane seasons that indicated 
utility crews are some of the first responders after storms hit, and 
often face life-threatening hazards when trying to get systems back up 
and working. OSHA took another proactive step on September 2, 2006, 
days before the Federal Emergency Management Agency (FEMA) completed 
the mission assignment, by activating its own National Emergency 
Management Plan, enabling it to focus the resources of the entire 
Agency on response operations.[Footnote 19] 

Once FEMA completed the mission assignment, thereby providing OSHA with 
access to additional funds, the Agency continued to take action and 
deployed over 50 safety and health professionals to the affected 
region.[Footnote 20] The additional professionals aided in the 
management and coordination of safety and health assistance to federal 
agencies and others, as outlined in the mission assignment. As part of 
its assignment, OSHA's responsibilities included: 

* Deploying staff to national level coordination centers including the 
Health & Human Services (HHS) Secretary's Operation Center; 

* Developing an overall Health and Safety Plan that guided those 
designing plans for individual worksites; 

* Cooperating with HHS to develop and reproduce psychological first aid 
materials to help responders, their families, and their home offices 
deal with the stresses associated with this work; and: 

* Providing training to responders, delivered by OSHA staff in the 
field, and through an agreement, by which the National Institute of 
Environmental Health Sciences (NIEHS) trained an additional 3,500 
responders in specialized classes. OSHA also sponsored construction 
safety conferences for contractors engaged in hurricane recovery work. 

In addition to its management and coordination responsibilities, OSHA's 
staff traveled throughout the disaster area providing technical 
assistance directly to employers and employees. When OSHA teams 
identified a dangerous situation, they approached work crews and 
managers to make them aware of hazards and to provide on-site training. 
To support its field work, OSHA staff developed an array of compliance 
assistance products, including quick reference materials for people 
working in hazardous environments. 

The details above offer a sampling of the vast and varied occupational 
safety and health assistance OSHA provided during the Katrina response. 
As with any domestic emergency or disaster, OSHA enters the situation 
with the goal of preventing occupational injuries and illnesses and 
work-related fatalities. This goal is carried-out though a variety of 
means, including coordinating occupational safety and health assistance 
for responders, delivering safety and health technical assistance in 
the field, and developing quick reference materials to keep safety and 
health at the forefront of responders' minds. 

After a review of GAO's draft report, OSHA submits several 
clarifications to better enable prospective readers to understand the 
Agency's responsibilities by which to measure its response. 

Number of Responders Deployed: GAO's report notes that no one collected 
information on the number of workers deployed to the disaster area. 
OSHA would like to clarify that it was not responsible for tracking the 
number of workers responding to Hurricane Katrina in the Gulf Coast 
region. 

Annex vs. Mission Assignment Language: The report focuses on the 
language in the National Response Plan (NRP) Worker Safety and Health 
Support Annex (WSHSA), rather than on the mission assignment for the 
Katrina response. The language in the mission assignment is what 
directed OSHA's activities in response to Hurricane Katrina, and should 
be the basis by which the Agency's response is evaluated. 

Training: OSHA repeatedly noted the availability of training through 
the interagency Safety Committees in Joint Field Offices (JFO's) in 
both Louisiana and Mississippi. Under tasking from OSHA, NIEHS, an 
Annex cooperating agency, made presentations at these meetings 
informing the federal response community of the training resources 
available under the Annex. OSHA made a consistent effort to stress the 
need for and availability of training in the affected region. However, 
there was a greater response to these efforts in Mississippi than in 
Louisiana. In total, approximately 3,750 people were trained through 
the resources made available through the Annex. 

Personal Protective Equipment (PPE): There are several issues of 
concern in the sections of the report dealing with OSHA's 
responsibilities for PPE. 

Availability of PPE: The mission assignment states: "Procure and 
provide essential PPE to responders and recovery workers on an ad-hoc 
basis." The mission assignment did not call for OSHA to be responsible 
for purchasing and distributing all the PPE needed by workers in the 
disaster zone, which under law is the responsibility of the agency or 
entity that employs the workers. OSHA's mission was to provide PPE on 
an ad-hoc basis. OSHA successfully did this by distributing over 4,000 
pieces of PPE. Through ongoing daily briefings, we offered assistance 
to federal agencies concerning PPE programs and respirator fit testing. 
At no time during the response did federal agencies or their 
contractors indicate that they could not acquire needed PPE. 

PPE Program: The current WSHSA language did not anticipate a PPE 
program on such a colossal scale as the one experienced in the Katrina 
response. The Annex was focused on a more compact site. Moreover, a 
general plan broad enough to encompass the many environments and 
operations in the Katrina response would not have had value for a 
specific worksite. Rather, in meeting the mission assignment, OSHA 
developed and distributed to federal agencies a response-wide Health 
and Safety Plan (HASP). This included guidance to those who were 
developing worksite-specific HASPS for what they should include in 
their plan to address PPE needs. Through JFO interagency safety and 
health committee meetings, the development of agency HASPS and their 
content was covered. On the need to include PPE in worksite specific 
HASPS, the guidance read: 

"Personal Protective Equipment (PPE) The use of PPE must be properly 
assessed. Equipment must be properly selected for the hazard, and 
properly fitted for the employee. Employees must be trained in the 
equipment's uses and limitations, as well as proper donning and doffing 
techniques. Equipment must be inspected before each use and repaired or 
replaced as needed. PPE shall be maintained and stored in a clean and 
sanitary manner. Employers shall maintain adequate supplies for timely 
replacement of lost, worn, or broken PPE." 

PPE Distribution: As tasked under the mission assignment, OSHA provided 
PPE on an ad hoc basis when it encountered workers who lacked it or 
whose PPE was broken or ineffective. 

Source of PPE: The report makes an issue of whether PPE was purchased 
through FEMA's vendor or through OSHA's Cincinnati Technical Center 
(CTC). There may have been discussion about how PPE would be acquired, 
but it had no impact on whether PPE was available for the responders. 

Need for Mental Health Services: The report states, "OSHA did not 
coordinate with them [HHS]." This statement is not accurate. Within one 
week of receiving a mission assignment, OSHA sent its Director of 
Occupational Medicine, a physician, to Louisiana to address the need 
for mental health services and determine how best to deliver them. 
Further, OSHA staffed a desk at the HHS Secretary's Operations Center 
to address worker safety and health issues, providing an industrial 
hygienist and an occupational physician daily to support this function. 

OSHA continually reached out to HHS, FEMA, and other agencies to meet 
its obligations under the mission assignment. Through regular 
discussions with FEMA and HHS, it was decided that the mission 
assignment from FEMA to Federal Occupational Health (FOH), a service 
unit within FUN, addressed the need for on-site mental health services. 
This included the need for assistance materials for deployed personnel, 
their supervisors, and families, concerning psychological resiliency 
during disaster response and recovery. Under the mission assignment, 
OSHA coordinated with FEMA and HHS to develop these materials and make 
them available to federal agencies. 

Agency Unawareness of OSHA's Role in a Large Disaster: OSHA does not 
believe the report accurately reflects the awareness of the Worker 
Safety and Health Support Annex among the federal agencies prior to 
Hurricane Katrina. All federal agencies signed off on the NRP, 
including the Worker Safety and Health Support Annex. In addition, 
several of the agencies most involved in Katrina response operations 
(FEMA, USACE, EPA, HHS, etc.) are cooperating agencies to the Support 
Annex. While not all of the employees of these federal agencies may 
have known about the Support Annex or the full extent of the resources 
available through it, the Support Annex was generally recognized among 
the federal agencies, and agencies were advocating for its 
implementation. Further, once OSHA was activated to implement the 
Annex, OSHA personnel staffed the JFOs, established contacts with state 
and federal agencies, held individual briefings with federal and state 
entities concerning OSHA's role in Katrina response and recovery, and 
attended numerous daily meetings that were also attended by federal and 
state agencies. 

What may not be completely understood throughout the federal community 
was how to implement the Support Annex and to access its resources. 
This was largely due to the fact that the Worker Safety and Health 
Support Annex is the only support annex that requires a mission 
assignment to both provide financial resources to an Agency and be 
implemented. All other support annexes are administrative and process- 
oriented rather than focused on providing operational support at 
disaster sites. Since most resources are provided by Emergency Support 
Functions, it was not clear among the federal agencies how to activate 
the resources available through the Support Annex. 

Enforcement: OSHA continued to investigate fatalities, complaints, and 
referrals throughout its response efforts. OSHA did not "suspend" 
enforcement during the response to Katrina. Rather, the agency delayed 
planned inspection activities as appropriate to the unique 
circumstances. Normal enforcement operations continued nationwide 
except in the specific areas devastated by the storm. Furthermore, 
OSHA's inspections levels for FY2006 continued at the levels planned 
for the year. Despite responding to and assisting the recovery of one 
of the nations worst natural disasters, OSHA's regular staff in 
Louisiana conducted 616 inspections for fiscal year 2006, exceeding 
their inspection goal by nine percent. 

OSHA resumed full enforcement in the areas affected by the stones as 
response operations ended. As of January 25, 2006, normal enforcement 
operations for planned inspections resumed throughout Florida and 
Alabama, in Mississippi north of Interstate 10, and in Louisiana 
outside of the seven parishes in and around New Orleans. On June 28, 
2006, normal operations for planned inspections resumed throughout 
Mississippi. OSHA resumed normal operation for planned inspections 
throughout Louisiana on September 15, 2006. 

Recordkeeping: OSHA agrees with GAO's recommendation that recognizes 
the benefits of collecting data on injuries and illnesses sustained by 
workers who respond to disasters as envisioned by the Worker Safety and 
Health Support Annex. OSHA's existing injury and illness recordkeeping 
forms (OSHA Forms 300 and 301) and definitions are a good platform on 
which to build. These forms and definitions provide two major benefits: 
1) they are already well known and understood, as all federal agencies 
currently use these forms, as required by 29 CFR Part 1960 Subpart 1 
(effective January 1, 2005); and 2) the forms provide the detailed 
information needed to evaluate trends and identify problem areas. 

However, as evidenced in this report, emergency and/or disaster 
conditions present unique challenges not anticipated by OSHA's current 
recordkeeping rule. These challenges include: 

* The need for real time data collection and dissemination; 

* The need to identify responsibilities of federal, state, and local 
government agencies for reporting during a response; 

* The need to clarify contractual obligations to report injuries and 
illnesses in a disaster response; and: 

* Prioritization of the use of limited man-power. 

Again, OSHA appreciates the opportunity for advance review and comment 
on this draft report. 

Sincerely, 

Signed by: 

Edwin G. Foulke, Jr. 

GAO's Response to OSHA's Comments: 

1. We disagree that our report does not fairly and adequately capture 
the actions OSHA took to prevent occupational injuries and illnesses 
and work-related fatalities in the Hurricane Katrina response 
operations. The information on pages 15 through 27of the report details 
many of these activities, but the purpose of the report was to provide 
a broader picture of OSHA's overall effectiveness. While the magnitude 
of the activities accomplished by OSHA's field staff was noteworthy, 
the agency's overall effectiveness was hampered by its lack of 
preparation for implementing its responsibilities under the Annex at 
the national level. This was also noted by the Department of Homeland 
Security's National Preparedness Task Force, which stated in its 
technical comments that, "As a signatory agency, Department of Labor 
should have anticipated and put in place mechanisms to ensure the 
success of OSHA in meeting their Workforce Safety responsibilities." In 
addition, our work focused on OSHA's activities through December 2006, 
not December 2005. 

2. Although OSHA provides more detailed information about its action 
during the response to Hurricane Katrina, our report mentions many of 
these same activities. For example, on page 33 of the report, we stated 
that OSHA distributed personal protective equipment to many agencies 
and workers; on pages 25 to 27, we noted that OSHA sampled many 
worksites for hazards; on pages 19 and 20, we provided examples of the 
quick cards and fact sheets OSHA developed and distributed throughout 
the Gulf; and on page 21, we discussed the thousands of interventions 
that the agency's staff conducted. 

3. We agree that OSHA, nor any other federal agency, was responsible 
for collecting information on the number of workers deployed to the 
Gulf area in response to Hurricane Katrina. In the absence of such 
information, we attempted to collect it ourselves but, as noted in the 
report, were not entirely successful because many of the agencies we 
contacted did not have systems in place for tracking the number of 
workers deployed. 

4. We noted on page 9 of the report that the mission assignment FEMA 
issued to OSHA implementing the Annex for Hurricane Katrina included 
all of the activities listed in the Annex except long-term medical 
monitoring. We measured the effectiveness of OSHA's performance only 
against those activities included in its mission assignment. 

5. Despite OSHA's efforts, as noted on page 32 of the report, other 
agency officials told us that there still were gaps in the training 
provided to workers involved in the response effort and additional 
information was needed about available training. 

6. While we agree that establishing a personal protective equipment 
program for a disaster response is a difficult and complex task, we 
continue to believe that the underlying issue is the need for OSHA to 
define how it will implement and monitor such a program as specified in 
the Annex. The issues that OSHA raises need to be addressed in 
developing an incident personal protective equipment program for future 
disasters, including developing a process for deciding what providing 
equipment on an "ad-hoc" basis means, what types of equipment will be 
provided, who will provide it, which workers will receive it, and where 
will it be stored. 

7. We disagree with OSHA's comment that our statement about its lack of 
coordination with the Department of Health and Human Services is 
inaccurate. Our statement is based on OSHA's lack of coordination 
before the disaster in order to ensure that the cooperating agencies 
were adequately prepared to meet the mental health needs of workers. 
Furthermore, in technical comments on the report, the Department of 
Homeland Security's National Preparedness Task Force also noted this 
lack of coordination. It stated that OSHA did not seek assistance from 
cooperating agencies that have provided mental health services during 
major events in the past, such as the Department of Health and Human 
Services' Substance Abuse and Mental Health Services Administration. 

8. We disagree with OSHA's assertion that the report does not 
accurately reflect the awareness of the Annex among federal agencies 
before Hurricane Katrina. As noted in the report, many of the agency 
officials we interviewed who were in charge of day-to-day operations in 
the Gulf area were not aware of OSHA's role or the services it could 
provide. We continue to believe that OSHA needs to provide information 
to federal, state, and local agencies about its role in a disaster, 
including seeking opportunities to participate in emergency 
preparedness exercises at all levels of government. Because so many 
responders are associated with nonfederal agencies, it is particularly 
important for OSHA to reach out to state and local agencies to provide 
this information. 

9. We used the word "suspend" to describe the fact that, in its press 
releases, OSHA noted that it had "exempted" large areas of the three 
affected states from its normal enforcement operations for specific 
periods and limited its inspections to cases involving fatalities, 
catastrophic accidents, or complaints, as noted on page 7 of the 
report. We changed the wording of the report in response to OSHA's 
technical comments and no longer use the term "suspend." However, we 
believe that this is an accurate reflection of the change in OSHA's 
activities during a disaster. 

10. The challenges OSHA recognizes in its comments regarding the use of 
its standard recordkeeping forms (OSHA forms 300 and 301) to collect 
data on injuries and illnesses sustained by workers during a disaster 
correctly identify some of the drawbacks involved in using the forms 
for this purpose. OSHA's comments also emphasize the need for it to 
develop a process for collecting needed data that overcomes the 
challenges identified. We disagree, however, that the forms are a good 
platform on which to build such a process. They do not contain detailed 
information on injuries, and employers are not required to include many 
of the more minor injuries and illnesses sustained by workers, such as 
those requiring only first aid. In addition, the use of the logs could 
cause confusion among federal agencies about whether the standard rules 
for recording injuries and illnesses are to be applied. For example, 
federal agencies are not normally required to submit their injury and 
illness logs to OSHA, but OSHA will need to obtain this information on 
a timely basis during a disaster response in order to monitor injuries 
and illnesses and identify trends. 

[End of section] 

Appendix V: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

Daniel Bertoni, (202) 512-5988 or Hbertonid@gao.govH: 

Acknowledgments: 

Revae E. Moran, Assistant Director, and Karen A. Brown, Analyst in 
Charge, managed all aspects of the assignment. Amanda M. Mackison, 
Claudine L. Pauselli, and Linda W. Stokes made significant 
contributions to the report. In addition, James D. Ashley, Lise Levie, 
Sheila R. McCoy, Jean L. McSween, David Perkins, and Tovah Rom provided 
key technical and legal assistance. 

[End of section] 

Related GAO Products: 

September 11: HHS Has Screened Additional Federal Responders for World 
Trade Center Health Effects, but Plans for Awarding Funds for Treatment 
Are Incomplete. HGAO-06-1092TH. Washington, D.C.: September 8, 2006. 

Catastrophic Disasters: Enhanced Leadership, Capabilities, and 
Accountability Controls Will Improve the Effectiveness of the Nation's 
Preparedness, Response, and Recovery System. HGAO-06-618H. Washington, 
D.C.: September 6, 2006. 

Coast Guard: Observations on the Preparation, Response, and Recovery 
Missions Related to Hurricane Katrina. HGAO-06-903H. Washington, D.C.: 
July 31, 2006. 

Hurricane Katrina: Better Plans and Exercises Needed to Guide the 
Military's Response to Catastrophic Natural Disasters.HGAO-06-643H. 
Washington, D.C.: May 15, 2006. 

Hurricane Katrina: Status of the Health Care System in New Orleans and 
Difficult Decisions Related to Efforts to Rebuild It Approximately 6 
Months After Hurricane Katrina. HGAO-06-576RH. Washington, D.C.: March 
28, 2006. 

GAO's Preliminary Observations Regarding Preparedness and Response to 
Hurricane Katrina and Rita. HGAO-06-365RH. Washington, D.C.: February 
1, 2006. 

Hurricanes Katrina and Rita: Provision of Charitable Assistance. HGAO- 
06-297TH. Washington, D.C.: December 13, 2005. 

September 11: Monitoring of World Trade Center Health Effects Has 
Progressed, but Not for Federal Responders. HGAO-05-1020TH. Washington, 
D.C.: September 10, 2005. 

FOOTNOTES 

[1] At present, 22 states have been approved by OSHA to operate their 
own enforcement programs covering all private sector workers and state 
and local public sector workers, and 4 have been approved to cover 
state and local public sector workers only. 

[2] OSHA retains the ability to enforce regulations and issue citations 
even when it is in a technical assistance role and may cite employers 
that do not comply with the suggestions of OSHA staff or if there is an 
employee complaint or a fatality. 

[3] Reimbursement is provided under the Robert T. Stafford Disaster 
Relief and Emergency Assistance Act (the Stafford Act) 42 U.S.C. § 
5147. 

[4] In the mission assignment FEMA issued to OSHA implementing the 
Annex for Hurricane Katrina, FEMA stated that it did not have authority 
under the Stafford Act to pay for the collection and management of data 
for long-term studies or analysis. 

[5] In order for state and local agency workers in a state to be 
covered by the Stafford Act in a disaster, the governor of the affected 
state must specifically request services from FEMA. For Hurricane 
Katrina, none of the governors of the three states requested assistance 
with safety and health issues. 

[6] National Guard officials told us the agency did not employ any 
contractor personnel during the response to Hurricane Katrina. 

[7] Officials with the Office of Workers' Compensation Programs told us 
they could not use their computer database to distinguish claims for 
injuries or illnesses related to Hurricane Katrina from those related 
to Hurricane Rita, a hurricane that caused extensive damage in Texas 
and Louisiana in September 2005. 

[8] Some of the fatalities reported involved workers that were not 
covered under OSHA's mission assignment, such as volunteers or private 
sector employees. 

[9] OSHA refers to these visits to work sites by its field staff in 
which potentially hazardous situations were identified and corrected as 
"interventions." 

[10] A majority of the disaster response efforts FEMA oversees involve 
small, regional disasters, such as flooding in a single county. FEMA 
oversees 50 to 60 such disasters annually. 

[11] The Annex assigns responsibility to OSHA for establishing a Worker 
Safety and Health Support Annex Coordination Committee. This committee-
-comprised of officials from DOD, the Department of Energy, the 
Department of Health and Human Services, the National Institute for 
Occupational Safety and Health, the National Institute of Environmental 
Health Sciences, the Coast Guard, and EPA--is responsible for 
coordinating the assets needed to protect worker safety and health at 
all levels of government during a disaster. 

[12] Specifically, OSHA was tasked with providing short-term 
psychological first aid during and after incident response and recovery 
activities. Psychological first aid is an approach to help children, 
adolescents, adults and families in the immediate aftermath of disaster 
and terrorism. It is designed to reduce the initial distress caused by 
traumatic events and to foster short-and long-term adaptive functioning 
and coping. 

[13] Some immigrants may have been employed by federal contractors and, 
therefore, covered under OSHA's mission assignments, but many of these 
workers were not employed by federal contractors. 

[14] The Advancement Project, the National Immigration Law Center, and 
the New Orleans Worker Justice Coalition, And Injustice For All: 
Workers' Lives in the Reconstruction of New Orleans, (2006). 

[15] The National Institute of Environmental Health Sciences is part of 
the Department of Health and Human Services' National Institutes of 
Health. 

[16] Officials with the Office of Workers' Compensation Programs told 
us they could not separate claims related to Hurricane Katrina from 
claims related to Hurricane Rita using the information recorded in 
their database. 

[17] DOD, for example, did not track the number of active duty Navy 
personnel who assisted with rescue and recovery efforts in the Gulf 
because the Navy base was damaged by the hurricane and they were not 
able to report this information. 

[18] Both OSHA and USACE provided us with information on one of the 
fatalities. 

[19] OSHA's National Emergency Management Plan (HEMP) clarifies 
procedures and policy for OSHA's national office and regional offices 
during responses to nationally significant incidents. 

[20] FEMA utilizes mission assignments to specify the tasks the 
department or agency is to perform during a specific incident. FEMA's 
mission assignment identifies the specific tasks the department is to 
perform to support the inter-agency efforts for a specific incident. 

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