As you know from reading earlier postings, VA in 2012 introduced their policy-driven and wrong-headed redefinition of "exposure" only to bar C-123 veterans from Agent Orange exposure benefits. Because the various laws specify that a non-Vietnam War veteran need only prove exposure to military herbicides for a successful claim, VA focused on creating a phony way to deny the exposure. To make it go away with semantics, even though we'd had a decade of that exposure flying the contaminated C-123 warplanes.
VA opposed us by redefining the word. They put forward the incorrect and unscientific pretense that "Exposure=Contamination Field+Bioavailability." No proof of biological impact of the substance on the body (like caffeine in coffee increasing blood pressure) the VA pretends to mean equals no exposure.
This is scientifically wrong. The most authoritative source is the CDC/Agency for Toxic Substances and Disease Registry, which defines exposure as the simple contact (or ingestion or inhalation) of a contaminant with the body. Remember, the laws and regulations make clear veterans need only establish the fact of exposure...that is what the VA seeks to make impossible by creating their own in-house use for that word.
Now, a highly respected professional society, the International Society of Exposure Science, has published their official ISEA glossary. There, exposure is defined as "contact between an agent and a target." No mention of bioavailability! Not here, nor elsewhere in science is bioavailability required to acknowledge exposure, because in fact, bioavailability flows from exposure.
And this flows from experts with the US EPA, the American Chemistry Council, and Lawrence Berkley National Laboratory. Dr.Valerie Zartarian with the EPA published the glossary in the Journal of Exposure Science and Environmental Epidemiology in September 2004.
It must be clear to everyone, including VA's Veterans Health Administration and their
Post-Deployment Health Section, that VA has undertaken a policy-driven redefinition of fundamental scientific terms and done so solely to prevent C-123 exposure claims. Post-Deployment Health has even barred C-123 veterans claiming exposure from receiving Agent Orange Registry health exams. (source: W. Carter telecon with Deputy Director VHA Post-Deployment Health)
Nowhere else in science or medicine is "exposure" redefined as the VA has done. Now, the authority of the premier professional scientific organization addressing exposure issues, and the publication by an EPA scientist here of the glossary as a juried article, means VA's approach has been trashed.
VA will still deny claims, which is the VBA's fundamental mission. The Secretary promised the Senate that all C-123 claims were to be considered individually. Perhaps so, but these claims are all 100% denied regardless of proof submitted, and denied at the direction of VA's Compensation and Pension Service which tells raters that "regulations do not permit" C-123 claims to be honored.
However, VHA's Post-Deployment Health, which directed Compensation and Pension Services to accept their warped manipulation of the word exposure, now stands exposed themselves for their obvious falsehoods.