We have to rebut this, both with evidence to submit during each of our VA applications and with the inevitable appeals to the Board of Veterans Appeals. If necessary, at this point we have been offered pro bono legal support, but the hope is that years can be saved (and how many do we have left, anyway??) by having enough persuasive evidence in the initial applications.
The law states the VA is supposed to help perfect a veteran's claim. This they won't do except to tell you how to access your own records. The VA is also supposed to give a veteran the benefit of the doubt at every stage. This they won't do thanks to their November 17 and December 14 press releases. Somehow, their folks have, in response to orders from their supervisors, built an imaginary situation where the "heavily contaminated", "extremely hazardous, extremely contaminated" airplanes were not a danger to the crews flying and maintaining them for the decade 1972-1982.
We need scientific help to debate this. We need chemists to explain that the VA's approach is full of errors. We need toxicologists to explain that a contaminated airplane, unpressurized, vibrating, windy and wet inside, could not have failed to expose us over our ten years flying it.
Inhalation, dermal contact and ingestion...we absorbed dioxin from each of these routes. One of the good resources we can start to study is the comprehensive Army manual Technical Guide 312. Much to be learned here, about dermal contact, inhalation, surface contamination...and much to use to fight the VA's voodoo science! A reservation we have about TG 312 is that it addresses office workers, but our time aboard aircraft was much longer, more intense, subjected to greater stresses of flight (both aircraft and crew), and for a decade. Further, the manual deals with contemporary assessments of contaminated facilities, where the only tests on our airplanes were begun in 1994, twelve years after their retirement. This will require a very thoughtful retrospective analysis!
If you are a professional able to offer your review of the VA's materials to help support our claims that we've been exposed, please contact me...you'll have our most sincere thanks!
Here is what the VA put out against us:
Properties of TCDD
TCDD may be inhaled as an aerosol. The reports and literature demonstrated that in the vapor stage, TCDD has an atmospheric lifetime of only about three days. Dried TCDD on interior aircraft surfaces does not aerosolize when exposed to temperatures found inside aircraft during any conceivable use. There is a low probability that dried TCDD would aerosolize during routine crew use and present a risk to health by inhalation. Also, there are no data from the U.S. Air Force or other sources confirming dioxins in air samples taken from post-Vietnam C-123 aircraft.
Routes of exposure
Ingestion as a route of exposure on these aircraft would require that TCDD would need to have entered the mouth through contaminated food or water or by hands contaminated with TCDD. There is a low probability that transfer of TCDD in food or water or from hand-to-mouth could occur among these crew members, especially given that the sampling for TCDD on the aircraft surfaces required use of a solvent (hexane) to displace and dissolve any residue.
Solid TCDD can be extremely stable in the absence of direct sunlight. Once TCDD dries on hard surfaces, such as on an aircraft, it does not readily cross through human skin. Even if the dried material were to come into contact with perspiration or oils on skin, the skin would act as a barrier prohibiting further penetration of TCDD. There is a low probability that TCDD penetrated through the skin of these aircrews.
Scientific review and analysis
The Office of Public Health reviewed the following studies and reports, and will continue to review new findings relevant to this issue as they become available.
Air Force Sampling Reports
"Aircraft Sampling: Westover AFB, MA." Prepared by W.W. Conway, USAF Occupational and Environmental Health Laboratory, Brooks AFB, TX; 1979.
"Memorandum for 645 MedGrp/SGB: Consultative Letter AL/OE-CL-1994-0203, review of Dioxin Sampling results from C-123 Aircraft, Wright-Patterson AFB, OH and Recommendations for Protection of Aircraft restoration Personnel."* (444 KB, PDF) Prepared by WH Weisman and RC Porter, Armstrong Laboratory, Brooks AFB, TX; 1994. "Memorandum for HQ AFMC/SGC: Consultative Letter, AL/OE-CL-1997-0053, Cleanup of Contaminated Aircraft, Aerospace Maintenance and Regeneration Center."* (140 KB, PDF) Prepared by RC Porter, Armstrong Laboratory, Brooks AFB, TX; 1997.
"Dioxin and Herbicide Characterization of UC-123K Aircraft – Phase I." Prepared for Director of Operations, 505 Aircraft Sustainment Squadron and Hazardous Waste Program Manager, 75CEG/CEVC, Hill AFB, UT (prepared by Select Engineering Services, Layton, UT); 2009.
Peer-Reviewed Literature
Properties of TCDD
TCDD may be inhaled as an aerosol. The reports and literature demonstrated that in the vapor stage, TCDD has an atmospheric lifetime of only about three days. Dried TCDD on interior aircraft surfaces does not aerosolize when exposed to temperatures found inside aircraft during any conceivable use. There is a low probability that dried TCDD would aerosolize during routine crew use and present a risk to health by inhalation. Also, there are no data from the U.S. Air Force or other sources confirming dioxins in air samples taken from post-Vietnam C-123 aircraft.
Routes of exposure
Ingestion as a route of exposure on these aircraft would require that TCDD would need to have entered the mouth through contaminated food or water or by hands contaminated with TCDD. There is a low probability that transfer of TCDD in food or water or from hand-to-mouth could occur among these crew members, especially given that the sampling for TCDD on the aircraft surfaces required use of a solvent (hexane) to displace and dissolve any residue.
Solid TCDD can be extremely stable in the absence of direct sunlight. Once TCDD dries on hard surfaces, such as on an aircraft, it does not readily cross through human skin. Even if the dried material were to come into contact with perspiration or oils on skin, the skin would act as a barrier prohibiting further penetration of TCDD. There is a low probability that TCDD penetrated through the skin of these aircrews.
Scientific review and analysis
The Office of Public Health reviewed the following studies and reports, and will continue to review new findings relevant to this issue as they become available.
Air Force Sampling Reports
"Aircraft Sampling: Westover AFB, MA." Prepared by W.W. Conway, USAF Occupational and Environmental Health Laboratory, Brooks AFB, TX; 1979.
"Memorandum for 645 MedGrp/SGB: Consultative Letter AL/OE-CL-1994-0203, review of Dioxin Sampling results from C-123 Aircraft, Wright-Patterson AFB, OH and Recommendations for Protection of Aircraft restoration Personnel."* (444 KB, PDF) Prepared by WH Weisman and RC Porter, Armstrong Laboratory, Brooks AFB, TX; 1994. "Memorandum for HQ AFMC/SGC: Consultative Letter, AL/OE-CL-1997-0053, Cleanup of Contaminated Aircraft, Aerospace Maintenance and Regeneration Center."* (140 KB, PDF) Prepared by RC Porter, Armstrong Laboratory, Brooks AFB, TX; 1997.
"Dioxin and Herbicide Characterization of UC-123K Aircraft – Phase I." Prepared for Director of Operations, 505 Aircraft Sustainment Squadron and Hazardous Waste Program Manager, 75CEG/CEVC, Hill AFB, UT (prepared by Select Engineering Services, Layton, UT); 2009.
Peer-Reviewed Literature
Scientific Review: Agent Orange Residue in C-123 Aircraft - Public Health 12/14/11 10:45 AM
Buffler PA, Ginevan ME, Mandel JS, Watkins DK. The Air Force health study: an
epidemiologic retrospective.* Ann Epidemiol 2011; 21:673-87.
Diliberto JJ, Jackson JA, Birnbaum LS. Comparison of 2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD) disposition following pulmonary, oral, dermal, and parenteral exposures to rats.* Toxicol Appl Pharmacol 1996; 138:158-68.
Karch NJ, Watkins DK, Young AL, Ginevan ME. Environmental fate of TCDD and Agent Orange and bioavailability to troops in Vietnam. Organohalogen Compounds 2004; 66:3689-94.
Keenan RE, Paustenbach DJ, Wenning RJ, Parsons AH. Pathology reevaluation of the Kociba et al. (1978) bioassay of 2,3,7,8-TCDD: implications for risk assessment.* J Toxicol Environ Health 1991; 34:279-96.
Michaud JM, Huntley SL, Sherer RA, Gray MN, Paustenbach DJ. PCB and dioxin re-entry criteria for building surfaces and air.* J Expo Anal Environ Epidemiol 1994; 4:197-227. Newton M, Norris LA. Potential exposure of humans to 2,4,5-T and TCDD in the Oregon coast ranges.* Fundam Appl Toxicol 1981; 1:339-46.
Weber LW, Zesch A, Rozman K. Penetration, distribution and kinetics of 2,3,7,8- tetrachlorodibenzo-p-dioxin in human skin in vitro.* Arch Toxicol 1991; 65:421-8.
Young AL, Giesy JP, Jones PD, Newton M. Environmental fate and bioavailability of Agent Orange and its associated dioxin during the Vietnam War.* Environ Sci Pollut Res Int 2004;11:359-70.
Risk Assessment Reports
Doull J. Acceptable levels of dioxin contamination in an office building following transformer fire. Washington, DC: National Academy Press, 1988.
Kim NK, Hawley J. Risk assessment: Binghamton State Office Building.* (285 KB, PDF) Albany, NY: New York State Department of Health, 1982.
University of California [Davis]. Department of Environmental Toxicology. Risk Science Program (RSP). Intermedia transfer factors for contaminants found at hazardous waste sites: 2,3,7,8-Tetrachlorodibenzo-p-dioxin (TCDD).* (118 KB, PDF) Sacramento, CA: Department of Toxic Substances Control, 1994.
Diliberto JJ, Jackson JA, Birnbaum LS. Comparison of 2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD) disposition following pulmonary, oral, dermal, and parenteral exposures to rats.* Toxicol Appl Pharmacol 1996; 138:158-68.
Karch NJ, Watkins DK, Young AL, Ginevan ME. Environmental fate of TCDD and Agent Orange and bioavailability to troops in Vietnam. Organohalogen Compounds 2004; 66:3689-94.
Keenan RE, Paustenbach DJ, Wenning RJ, Parsons AH. Pathology reevaluation of the Kociba et al. (1978) bioassay of 2,3,7,8-TCDD: implications for risk assessment.* J Toxicol Environ Health 1991; 34:279-96.
Michaud JM, Huntley SL, Sherer RA, Gray MN, Paustenbach DJ. PCB and dioxin re-entry criteria for building surfaces and air.* J Expo Anal Environ Epidemiol 1994; 4:197-227. Newton M, Norris LA. Potential exposure of humans to 2,4,5-T and TCDD in the Oregon coast ranges.* Fundam Appl Toxicol 1981; 1:339-46.
Weber LW, Zesch A, Rozman K. Penetration, distribution and kinetics of 2,3,7,8- tetrachlorodibenzo-p-dioxin in human skin in vitro.* Arch Toxicol 1991; 65:421-8.
Young AL, Giesy JP, Jones PD, Newton M. Environmental fate and bioavailability of Agent Orange and its associated dioxin during the Vietnam War.* Environ Sci Pollut Res Int 2004;11:359-70.
Risk Assessment Reports
Doull J. Acceptable levels of dioxin contamination in an office building following transformer fire. Washington, DC: National Academy Press, 1988.
Kim NK, Hawley J. Risk assessment: Binghamton State Office Building.* (285 KB, PDF) Albany, NY: New York State Department of Health, 1982.
University of California [Davis]. Department of Environmental Toxicology. Risk Science Program (RSP). Intermedia transfer factors for contaminants found at hazardous waste sites: 2,3,7,8-Tetrachlorodibenzo-p-dioxin (TCDD).* (118 KB, PDF) Sacramento, CA: Department of Toxic Substances Control, 1994.