DISCLAIMER The following is a staff memorandum or other working document prepared for the members of the Advisory Committee on Human Radiation Experiments. It should not be construed as representing the final conclusions of fact or interpretation of the issues. All staff memoranda are subject to revision based on further information and analysis. For conclusions and recommendations of the Advisory Committee, readers are advised to consult the Final Report to be published in 1995. STAFF MEMORANDUM TO: Advisory Committee on Human Radiation Experiments FROM: Advisory Committee Staff RE: Methodological Review of Agency Data Collection Efforts Initial Report on the National Aeronautics and Space Administration DATE: June 28, 1994 This initial report provides 1) information on NASA history, structure, and records; 2) a description of NASA's search process for locating records on its role in human radiation experiment; 3) information uncovered to date by this search and 4) observations and recommendation for further action by Committee staff. EXECUTIVE SUMMARY 1. NASA History and Records The National Aeronautics and Space Administration was established in 1958 as a civilian space agency under the National Aeronautics and Space Act. As part of the Mercury, Gemini, and Apollo programs, NASA conducted and sponsored research on hazards of human spaceflight, including radiation and weightlessness. NASA was concerned about radiation in space from natural sources -- the Van All belts,1 {1 The Van Allen belts are regions of charged particles (mostly protons and electron) trapped by the Earth's magnetic fields.} solar storms and galactic cosmic rays -- and from proposed space nuclear power and propulsion systems. Since 1961, NASA has been organized around a network of field centers, each with specific authority and missions. The Manned Spaceflight Center in Houston (now the Johnson Space Center) became the principal center for research on space medicine, performing studies in house and through outside medical research centers. Several other NASA centers have also been involved in biomedical, radiological, and environmental research. NASA has provided information on its records management policies. NASA reports that many documents on human radiation experiments were destroyed in accordance with standard records retention schedules, but most results are published. As for the content and structure of NASA's records, a Space Life Science Archive from JSC is located at the Houston Academy of Medicine -- Texas Medical Center Library. The scope and location of archives of policy-level document and documents from other NASA centers remains unclear. 1 2. NASA Search Process Aside from formal ethics documents from 1972 and later, NASA's initial search process focused on technical documents on specific experiments. NASA also conducted database and records searches, as well as interviews with current and former NASA staff. The initial charter of NASA's document search and review organizations focus on this type of information, but NASA has responded promptly to staff requests for specific additional documents. NASA has also begun to search for programmatic and policy level-documents that might shed additional light on the role and purpose of human experimentation in NASA's research agenda. 3. Findings to Date NASA's search has uncovered three types of records: documents on ethics guidelines for human experimentation, information on specific experiments, and programmatic and organizational documents. NASA first formalized its ethics guidelines in 1972 with a NASA Management Instruction (NMI 7100.8) requring written informed consent for human subject research performed by NASA, later (1986) extended to include NASA-funded research. NASA has also provided some records of informal policies that existed before 1972 as well as documents from the development of the 1972 NMI, and staff is reviewing these documents. NASA's search uncovered a number of research projects and reports, including a list of 189 documents from its database search. The most prominent example is a total-body irradiation (TBI) study funded jointly by NASA and the Atomic Energy Commission (AEC) at Oak Ridge from 1964-75. As part of these studies, patients with leukemia and lymphoma were treated with X-rays in a range of doses and dose rates. NASA states that it had no involvement in the clinical details and was only interested in the data. In accordance with its records retention schedules NASA destroyed its files on the Oak Ridge study in 1980, but other documents have emerged from the Department of Energy and from 1981 Congressional hearings chaired by then Representative Albert Gore Jr. NASA has identified several other experiments involving deliberate human radiation exposures, which it believes will be of concern to the Committee. These include experimental techniques to measure bone loss using neutron activation and X-ray absorption, and studies of light-flashes in the eye at particle accelerators. NASA also reported on a number of experiments that it suspects are beyond the scope of the Committee. 4. Observations and Recommendations NASA appears to have conducted a through initial search and review of specific experiments, and has responded promptly to additional documents requests. Staff needs to work with NASA to clarify the Committee's information needs and to refine document search strategies. Staff has identified five immediate priorities and three longer-term priorities for additional document research and review. The highest priority is to follow-up on the NASA/AEC/Oak Ridge TBI experiments and use these and other documents to review a broader range of TBI experiments. Other immediate priorities include reviewing the information NASA has already provided and working with NASA to refine search strategies for ethics and other policy and programmatic documents. Staff requests further guidance from the Committee on proposed long-term priorities. 2 I. INFORMATION SOURCES On May 24, NASA provided the Committee with written information on its document search. This information describes the search process and what NASA has uncovered regarding human radiation experiments funded or performed by NASA and on NASA' ethics policies for human experimentation. NASA briefed Committee staff on June 8 on the results of its search to date, and is continuing to provide additional documents in response to requests from Committee staff. NASA has also provided several books on its history, including the history of its biomedical research programs. Staff requested follow-up information on June 13, and NASA responded by providing three additional boxes of materials on June 21 and an additional folder on June 24. II. HISTORY/ORGANIZATION OF NASA A. General The National Aeronautics and Space Administration was created in 1958 in response to the 1957 Sputnik launch, in an effort to catch up with the Soviet Union in the space race. Formed out of the National Advisory Committee on Aeronautics (NACA, founded in 1915) and selected programs of the Department of Defense, NASA was intended to be a purely civilian agency, separate from the U.S. military and intelligence-related space programs. Animated by President Kennedy's May 1961 goal to send a man to the Moon and back by the end of the 1960s, NASA focused the bulk of its effort on human spaceflight, beginning with the Mercury, Gemini, and Apollo projects. NASA grew rapidly during its early years and faced the simultaneous challenges of building an organizational structure and carrying out an ambitious program of human spaceflight. In 1961, NASA Administrator James Webb undertook a major reorganization that defined NASA's structure through 1970. This reorganization matched NASA's structure to its missions rather than to functional categories of research and development. One effect was to clarify and expand the role of NASA's field centers, giving them clearly defined missions within NASA's overall agenda and expanding their autonomy and policy-making authority. As a result, NASA performs most of its research at these centers or funds it extramurally through the centers. B. Biomedical, Radiological, and Environmental Research Unlike in aeronautics and rocketry, NASA did not inherit any substantial capabilities in biology and medicine. In its early years, therefore, NASA relied heavily on outside and Air Force expertise in aviation medicine as it developed an organizational structure and programs in those fields. Because life sciences were not a major consideration in NASA's 1961 reorganization, life sciences programs were split among NASA's main program offices and field centers. The Manned Space Flight Center in Houston, Texas (now the Johnson Space Center or JSC) has been responsible for astronaut training and selection, and has performed or sponsored research involving astronauts and other human subjects. The Ames Research Center (ARC) in Palo Alto, California also has a major life sciences program, but deals mostly with animals subjects; other NASA centers have played smaller roles in life sciences research. The Goddard Space Flight Center (GFSC) in Greenbelt, Maryland has principal responsibility for research on the atmosphere and the space environment. 3 Currently, life sciences research is administered by the Office of Life and Microgravity Sciences and Applications, headed by Associate Administrator Harry C. Holloway, M.D., who is also responsible for NASA's review of its records on human radiation experiments. NASA's principal concern in life sciences was to ensure the health and safety of astronauts in the stressful and poorly understood environment of spaceflight. Understanding and protecting against the hazards of weightlessness and of exposure to solar and cosmic radiation posed two of the greatest challenges. The discovery by the first Explorer satellite of the Van Allen radiation belts in 1958 and satellite measurements of charged particles from a solar storm in 1960 raised radiation risks to the top of NASA's agenda. At NASA's request, the National Academy of Sciences (NAS) in 1961 convened a series of studies on astronaut safety and protection, which were carried out by the Man in Space Committee of the Academy's Space Sciences Board. This Committee's Working Group on Radiation, chaired by Dr. Wright Langham of the Los Alamos Laboratory, concluded that heavy charge particles -- protons, alpha particles, and heavier nuclei -- posed the greatest unknown hazard in human spaceflight. 2 {These particles are the main source of radiation in the Van Allen radiation belts, the solar wind, solar storms, and cosmic rays. Radiation from these sources is more penetrating than alpha and beta radiation from radioactive nuclei and deposit their energy in a much more concentrated way than gamma rays, so they can cause more severe localized damage to internal organs and tissues.} This panel recommended further research to measure the flux of these particles and to study their effects on animal tissues, but did not call for direct human experimentation. A second NASA panel, the Space Radiation Safety Panel of the Life Sciences Committee, convened in 1964 and produced its final report entitled Radiobiological Factors in Manned Space Flight in 1967. This study noted the need to understand the different effects of terrestrial and extra-terrestrial radiation sources, as well as the effects of the long exposures at relatively low dose rates astronauts would experience (with proper shielding) during extended human space missions. The study also called for further research and cited the need for more data on human radiobiological effects, to be gathered through "every ethical means." In 1961, NASA established a working relationship with the Atomic Energy Commission on studies of space radiation and radiobiology, which led to a series of joint projects. These projects included the use of AEC particle accelerators to simulate the space radiation environment for ground-based experiments and AEC experiments flown aboard NASA missions. A 1964 interagency agreement formalized this relationships and identified "approximately a dozen"3 {Testimony of Dr. Nathaniel Barr, Hearings on the Human Total Body Irradiation (TBI) Program at Oak Ridge before the Subcommittee on Investigations and Oversight of the House Committee on Science and Technology (September 23, 1981), p. 127.} joint tasks. Task 9 involved the study of total-body irradiation of humans in a research project carried out by the Oak Ridge Medical Division.4 {Technically, this was the Medical Division of the Oak Ridge Institute for Nuclear Studies (ORINS), as it was known before 1966, or of Oak Ridge Associated Universities (ORAU), as it was known after 1966} These joint tasks were initially administered through NASA headquarters. 4 III. NASA RECORDS: OVERVIEW A. Location and Organization NASA provided contact information on the location of retired documents in Federal Record Centers from each of its space centers responsible for biological and environmental research. Under a 1985 agreement, the Johnson Space Center transfers records to the Houston Academy of Medicine -- Texas Medical Center Library for a Space Life Sciences Archive. Staff has requested further information on the organization of NASA's archive and holdings in Federal record Centers and the National Archives on the disposition of documents from NASA Headquarters and other NASA Centers. B. Document retention/Destruction Policies and Practices NASA provided a copy of its current (1991) records retention policy (NMI 1440.6D, attached), which implements the pertinent legislation on records retention, and the section of the NASA Records Retention Handbook NHB-1441.1A (1974) describing records retention schedules for research projects. According to these regulations, records of major research projects may be transferred to Federal Record Centers after 2 years, and may be disposed of 13 years later, after consultation with the National Archive and Records Administration on permanent retention. For smaller projects the limits are 2 years and 4 years, respectively.5 {5 "Major" projects include particular space mission such as Appolo or Explorer. NASA's life sciences projects ten to be in the "smaller" category. Regulations now require that test subject medical records and radiation records be retained for 30 and 75 years, respectively.} This makes it difficult to obtain documents other than final published reports on NASA's human radiation experiments, although NASA is searching in the National Archives for such records. In the most prominent case -- the Oak Ridge total-body irradiation (TBI) experiments (see below) -- NASA claims that it destroyed most or all relevant documents in 1980 in accordance with these records retention procedures and this may be true for the other experiments NASA HAS IDENTIFIED. IV. DESCRIPTION OF NASA SEARCH A. Guidelines/Logic NASA's initial search aimed at locating records of individual experiments and identifying documents on guidelines for experimentation involving human subjects. The Directors of each of NASA's field installations have been asked to locate and safeguard all records relating to human radiation experimentation, and notify the search team of what they uncover. In addition, NASA has searched its own and other electronic databases, paper records of its predecessor NACA going back to 1940 and books and review articles. This search identified 189 relevant publication, which NASA has classified into nine types (Attachment I). NASA's search has begun to focus on headquarters level and policy-relevant documents that would provide a programmatic guide to the extent and purposes of NASA's biomedical and radiological research. 5 B. Experiment Definition NASA used the definition of human radiation experiments contained in Executive Order 12891. This includes NASA-funded studies involving the deliberate exposure of human subjects to ionizing radiation or radioisotopes for the purposes of determining the biological effects of that radiation. NASA searched for but did not find any instances of environmental releases of radioisotopes. Because of uncertainties about the definition of human radiation experiments, however, NASA states that it conducted a broad search, which identified a number of experiments that NASA believes are probably beyond the concern of the Committee. NASA is working with the Committee and staff to clarify this uncertainty, and prepared a draft taxonomy of experiments, which is shared with the Advisory Committee's Subcommittees on Cold War Data Collection and Scope and Priorities (Attachment 2). C. Search Organization/Staffing Dr. Harry C. Holloway, Associate Administrator for Life and Microgravity Sciences and Applications, has taken overall responsibility for directing the search. Dr. Earl W. Ferguson, Director of the Aerospace Medicine and Occupational Health Division, is coordinating the search at the headquarters level, and Dr. Donald E. Robbins, Acting Director of Space and Life Sciences at JSC, is leading the search of NASA's records. Dr. Janice Stoklosa has coordinated NASA's search efforts with Committee staff. NASA has established three bodies as part of its search for and review of human radiation experiments. The main search organization is the Human Radiation Research Search Team, which is searching for information on specific experiments. Its initial charter did not include searching for ethical regulations or policy level documents. The Human Radiation Research Internal Review Committee oversees this search effort and includes NASA's General Counsel and Inspector General. Over 50 current and former NASA employees and contractors have been involved in the search. NASA is also establishing its own external review committee to aid in the review and revision of its human experimentation policies. D. Use of Historians, Offical Histories, Published Literature, and Interviews Historians at NASA Headquarters and at JSC have helped guide NASA's search, and NASA has provided Committee staff with a number of published histories. Several of the principals in NASA's biomedical and radiological research have been with NASA from the early 1960s. Members of NASA's search team have drawn on the experience of these principals -- and of 16 others who have since retired -- to guide their research efforts. This continuity of experience has been a major asset in NASA's search to date. E. Classification NASA has a separate division responsible for classified programs, which have included collaborative human spaceflight projects with the Air Force and programs on nuclear space propulsion and power systems. However, NASA states that is has not uncovered any classified documents dealing with human radiation experiments, and that it does not believe any classified documents of this type exist. 6 F. Interagency Coordination NASA participates in the Interagency Working Group on Human Research Using Ionizing Radiation and shares the information it uncovers with other participating agencies. NASA also discovered that it had sent 200 boxes of records on project NERVA (Nuclear Engine for Rocket Vehicle Application) to Oak Ridge, but did not find any reference to human radiation exposures in the file descriptions. G. Search Results to Date The search results fall into three categories: (1) documents reflecting NASA's ethical policies for human experimentation, 2) documents on specific experiments, and 3) documents on NASA's programs and organization. Staff is continuing to review the third category of documents and some information from those documents is included in the historical survey above. 1. Ethics The Committee staff has received from NASA documents which reflect NASA policies and procedures on human research generally since 1972. As discussed in the Ethics follow-up in briefing book #3, NASA issued a Management Instruction (NMI) governing human research in 1972 requiring written informed consent in research conducted by NASA; a 1986 revised NMI extended this policy to NASA contractors and grantees. Staff has also received policies and a handbook from Johnson Space Center implementing these NMI's, one of which indicates that the Center established a human research review committee in 1975. Further, in 1969 NASA established a Medical Isotopes Subcommittee to advise the Manned Space Center Radiation Safety Committee on evaluations of proposals to use radioisotopes for research, diagnosis or therapy in the Manned Spacecraft Center Programs. Staff is currently closely reviewing the ethics policy documents received from NASA for follow-up. In the interim, staff has also requested other formal or informal policies governing human research prior to 1972 in place at NASA and/or its field centers, any implementing policies from the other centers beside Johnson Space Center, and any interpretive and development documents associated with any NASA or center policy on human research. 2. Specific experiments NASA's search has identified a number of experiments involving the deliberate exposure of humans to ionizing radiation or to radioactive materials. NASA has divided its list into experiments that it believes are clearly within the charter of the Advisory Committee and those it believes are outside that charter, while recognizing that the scope of the Committee's interests remains to be fully determined. The first list contains four items: (1) Total Body Irradiation: NASA and AEC cosponsored a retrospective and a prospective study of TBI experiment carried out at Oak Ridge from 1964-75 (see Tab O of this 7 briefing book for an overview of the information on these and other TBI experiments currently available to the Committee). The Oak Ridge studies were the subject of Congressional hearings held in 1981 before the Subcommittee on Investigations and Oversight of the House Committee on Science and Technology, chaired by then Representative Albert Gore, Jr. Andrew J. Stofan, then Acting Associate Administrator for the Office of Space Science, testified for NASA, along with a number of former AEC, and Oak Ridge officials (see Mr. Stofan's testimony and an internal Oak Ridge memo in Attachment 3). NASA wanted to use information on accidental and therapeutic radiation exposures to help establish single-dose and lifetime radiation exposure limits for astronauts. The TBI studies were used to help establish single-dose limits based on understanding the dose- response relationship for the onset of early radiation effects such as nausea and anorexia that could affect the ability of astronauts to perform their missions effectively. From 1964 to 1975, NASA provided $2.2 million (8%) of the $26 million (the remainder of the funding came from the AEC) for two TBI studies at Oak Ridge, a prospective one and a retrospective one. In the retrospective study, researchers at the Oak Ridge Medical Division collected and analyzed data from Oak Ridge and 45 other institutios on clinical and accidential TBI exposures. This led to numerous publications, including the final Oak Ridge report in 1975 (Attachment 4 to Tab O). At the same time, NASA supported a prospective study to collect useful data from leukemia and lymphoma patients undergoing TBI treatments at the Oak Ridge Medical Division. NASA maintains that it played no role in selecting patients for treatment or in overseeing the course of treatment. Oak Ridge had built a Medium Exposure Total Body Irradiator (METBI) in 1960, which is used to treat patients with certain types of leukemia and lymphoma. In 1965, Oak Ridge approached NASA about a proposed prospective study using a new Low Exposure Total Body Irradiator (LETBI), which provided uniform whole body dose rates of 1.5 rad/hour, comparable to the dose rate to astronauts during solar storms. The LETBI began operations in 1967, with NASA providing $65,000 for equipment to monitor patients while they underwent extended radiation exposures. These TBI facilities were closed in 1974. The 1981 Gore hearings provide a basic source of information to date on these experiments, in addition to reports by Dr. Lushbaugh at Oak Ridge, who was principal investigator for these studies, and files from Oak Ridge that the Department of Energy has uncovered. At those hearings, NASA testified that it had destroyed its files associated with these experiments in 1980, according to standard document retention schedules. Staff has received some of the interagency files for these studies among documents from Oak Ridge provided by DOE, and hopes to uncover more information from this and other sources. (2) Total Body Calcium Measurements. From 1971-77 NASA funded a project with the AEC to develop a technique to measure total body calcium using fast neutron reactions with Calcium-40. These neutrons react with Calcium-40 to produce Argon-37, which the subjects then exhale. Studies on rats had indicated a 3% accuracy in measuring total body calcium. NASA was particularly concerned with bone loss from weightlessness. 8 The experiments were performed at the University of Washington Department of Radiology and the Battelle Pacific Northwest Laboratory, and research protocols were subject to review by the University of Washington's Radiation Safety Committee and Biomedical Sciences Review Committee. According to NASA's summary, approximately 16 subjects6 {The subjects included 10 "normal" adults and 6 patients with "bone wasting disease."} were exposed three times each for four minutes at a time to 10 millirad of 14 MeV neutrons. (3) X-ray Absorptimetry. Between 1968 and 1982, the AEC, and later NASA, funded researchers at the University of Wisconsin to study a proposed technique for measuring bone mineral content using the absorption of X-rays from a variety of radioisotope sources on both animal and human subjects. (4) Light Flash Experiments. To test theories about light flashes observed by astronauts, investigators at particle accelerators in Berkeley and Brookhaven exposed their eyes to beams of protons, neutrons, and pions. The investigators undertook these experiments on their own initiative and estimated their exposures at 2.6 to 8.5 millirem. These researchers sought and received permission from review boards to subject themselves to this radiation. NASA second list included a number or other experiments performed on astronauts and other human volunteers that involved the use of radioisotopes and ionizing radiation for tests on astronauts and bed-rest experiments in which subjects were confined to bed for extended periods of time to simulate the effects of weightlessness. The Committee might be interested in some of these experiments: * NASA-funded bed-rest studies that used radioisotope tracers as indicators of metabolic function. According to Mr. Stofan's testimony at the 1981 Gore hearings, some of these studies used California state prisoners as volunteer subjects. * NASA is conducting a longitudinal study of astronaut health using data on occupational radiation exposures. * NASA's document search ;also identified two additional papers on neutron irradiation, and two papers on experimental skin and cancer treatments using particle beams. * The NASA Specialized Center of Research and Technology (NSCORT) conducted a retrospective study of cataracts in patients who had previously been irradiated for the treatment of uveal (retinal) melanomas. H. Contractor/Grantee Records NASA requested information from some contractors and grantees, who referred NASA to published reports and articles. NAS reports that the contractors and grantees claim that all other records of the experiments in question had been destroyed or lost. 9 I. Evaluation of Calls Referred to NASA by DOE Helpline, and Other Inquiries. At the time of its initial report to the Committee, NASA had received 6 referrals of calls from DOE's helpline, 3 Freedom of Information Act requests, and 4 other direct inquiries (Attachment 4). These referrals contained incomplete information, and NASA is following up on the helpline calls, but Committee staff has received no further information on this follow-up. NASA has investigated two of the direct inquiries: * A complaint that NASA released radioactive barium over Alabama in 1961-62. NASA confirms that it has released chemical tracers to study the upper atmosphere, but denies that it used radioactive isotopes. * A call from someone who claimed to have been an experimental subject injected with Radio-iodinated serum albumin as part of NASA's bed-rest studies. NASA has not located records on this particular subject. V. STAFF OBSERVATIONS ABOUT THE NASA SEARCH Staff has found NASA to be forthcoming in providing specific documents and in its initial responses to more general information requests. NASA is working with the Committee and staff to develop a taxonomy of human radiation experiments and clarify the scope of the Committee's interests. However, staff does not yet have a clear picture of the organization of NASA's records. NASA has provided ethics documents from 1972 and after, when it established formal guidelines, and has begun to search for earlier ethics documents. Staff is reviewing ethics documents NASA provided on June 21, and would like to obtain several other types of documents to the extent that they are available, particularly regarding research funded by NASA but performed by others, for example by Oak Ridge. NASA has begun to search for policy and programmatic documents that might explain the background and purposes of the research it funded. Some of this information may be easy to obtain, for example from annual reports or budget documents. Staff may need to engage in discussions with NASA historians and archivists to understand what other information may be available. Staff has identified several types of documents that, if available, could shed some light on NASA involvement in human radiation experiments. These include: (1) documentation of NASA/AEC discussions 1961-64, when the two agencies developed a working relationship and formalized a joint program of radiation research; (2) information on NASA's nuclear powered spacecraft programs NERVA and Rover, which may refer to concerns over radiation hazards to astronauts; and (3) information on NASA/Air Force collaborations on human spaceflight, including the Air Force's Blue Gemini and Manned Orbiting Laboratory programs, which may include discussions of the radiation hazards of extended human spaceflight. VI. STAFF RECOMMENDATIONS AND PLANS The recommendations for further staff work are divided into immediate priorities, which staff expects to work on in the next several weeks, and longer-term priorities, which staff expects to follow-up on later. 10 Immediate priorities: (1) Focus on the NASA/AEC/Oak Ridge TBI experiments in connection with the broader range of TBI experiments. Staff working on the NASA document search are also studying the TBI records This effort involves reviewing documents NASA has already provided and collaborating with other staff teams to identify likely sources of information. This may involve additional requests for documents from other agencies and non-federal entities (medical research centers). (2) Review other documents NASA provided to staff on June 21 and June 24. These include additional information on ethics policies, several documents on NASA's organization and life sciences programs, and some information on NASA records. (3) Work with NASA to discuss strategies for obtaining other records on NASA programs and policies, particularly a) the NASA/AEC collaboration on radiation research, b) NASA's space nuclear power and propulsion programs, and c) NASA/Air Force collaboration on extended human spaceflight. (4) Work with NASA to clarify priorities and discuss strategies for obtaining additional documents on ethics policies, particularly for research performed by NASA contractors and grantees. (5) Continue to discuss the taxonomy of experiments. This will involved working with other staff and with the relevant Advisory Committee Subcommittee to clarify the range of Committee concerns. Longer-term priorities: 6) Request and review annual reports and budget documents, particularly for biomedical and radiological research programs but also for other programs that might have need the information to be obtained through such research. 7) Request and review more detailed documentation on the other experiments NASA has identified. This would include published papers and reports as well as nay available NASA records. Staff awaits guidance from the Committee on its priorities for follow-up. 8) Follow up on ethics discussions. This may involve additional document requests and interviews with current and former NASA personnel.