To:   Commissioner John Grady and all concerned Commissioners


subject:  Level of Exposures of many toxic chemicals of our Vietnam veterans

Copy to:

Congressional Members, Congressional Staff, and VA staff:,,,,,,,


IOM members:,,


In our discussion on Tuesday evening, September 5, you suggested that Vietnam Veterans did not get that much exposure.  I do not know where you got your information but I would just about bet from someone in the government/VA or an agency contracted by the government.

My first question would have been and should be your question to the IOM - Exposures to what?  At what level of exposure  is the IOM anticipating associations or non-associations.  If the NAS/IOM is going to be judge and jury then the positive and the negative decisions or levels must have a clear defined definition of what constitutes positive and what constitutes negative.  Otherwise we have a moving legal target that changes with the evidentiary findings or what someone subjectively believes as a positive or a negative.  If the NAS/IOM is unclear as the rest of the world's scientists on levels then obviously there has to be a qualifying condition statement/preface based on something viable - not just an opinion.

I would also ask the IOM if they are only judging/considering to associate the levels of dioxin and other toxic chemicals the Veteran was exposed while in Vietnam during his service in that theater?  Every scientists in the world has concluded that dioxins must be looked at in the context of cumulative lead exposures or similar.

Considering that our Nations Environmental Protection Agency (EPA) has concluded the level of dioxin in our Nations environment, confirmed by sediment data, peaked in the early 70's.  Then began a gradual decline from 1987 to 95 with levels falling from 55 to 25 ppt TEQ lipid.  Of course this is due to the government band on the usage of many of these toxic chemicals in the late 70's.  While still manufactured here the use was for export only.

Clearly any base line achieved in Vietnam during military service must be considered an additive accumulation to what ever the rest of the nation was exposed.  This fact certainly must be considered in any compensation judgments.  Without the Veterans additional exposure at the hands of our own government his or her levels and/or the length of "in body" dioxins and the length of metabolism in the Veteran's body since 1962; the Veteran is now suspect as to his death or disability may not have presented itself at all.  There are many factors to consider and personally I think the IOM is concentrating on only looking at what dosage in Vietnam and that as discussed is not factual when discussing a cumulative body toxic chemical.

Is the IOM acting as both judge and jury for our Nation's Veterans and their families by only considering the one byproduct of the one part of the Agent Orange Herbicide and that being the one single toxic chemical dioxin, TCDD only?

There were other dioxins, closely related furans, as well as hexachlorobenzene and rust inhibitors (nitrosamines) in Agent White under the guise of a proprietary Dow Product called "Picloram."

Human metabolism of hexachlorobenzene becomes pentachlorphenol in a person's system.  This is not a good thing to have along with the dioxin, TCDD.


As recently as mid 2005 the EPA's Dr. Linda Birnbaum put out its data on exposures to Dioxin (ONLY), Body Burden Levels in Background Populations and Epidemiological Cohorts.


Number one on the list by Body Burden measured in ng/kg whole body, 25% lipid was the Seveso, Italy dioxin, TCDD disaster and this was further broken into three established contaminated areas:

The highest in Zone R was approximately 250 ng/kg with the median at about 60 ng/kg.


The high in Ranch Hand was 1000 ng/kg with the median about 75 ng/kg.


Now let's look at the facts of these data points.


Seveso, Italy ----  Because of our national disaster the Seveso, Italy study was almost immediate with blood samples taken and stored.   Reports come out at ten, 15 and 20 year intervals.  In addition, by this time the protocol and test methodology of sampling either blood and/or adipose tissue for residual dioxin was proofed and a correlation in the medical world was established.  Although blood samples, in my opinion, do not represent the actual stored and attached residual factors.


Remembering that dioxins like fat cells (lipid) and readily store themselves there, one also might not be aware that myelin matter (nerve tissue) is about 80% fat with the remainder in proteins.  This includes the spinal cord tissue and brain tissue.


For one to conclude that he can take a sample of adipose tissue from the abdomen and test it for residual dioxins and then not conclude that the same dioxins can store themselves in the central nervous system, is a story I am eager to hear, even if it comes from the IOM.


As a Veteran and representing many others, we have a right to know how we are being judged and at what level this same judge/jury must find in favor of either the U.S. government or of those who are victims of the same entity.  There is a huge difference in any legal system, i.e., criminal proof versus civil proof.  Bearing in mind that the courts found in favor of the Veterans and it is the "advertised philosophy of the U.S. Government" that all the Veterans and/or their widows must have a "significant correlation" or an "increased risk of incidence."


It is important to have a baseline established before exposures are recorded as in a controlled experiment.  A "cause and effect" failure analysis demanding that some dose rate be established to a segment of society 40 years after the fact is outrageous.


The IOM seems to think as long as it says "yes, we think it can cause this or that but we do not know how to apply it to the Vietnam Veteran" seems to be some sort of disclaimer to protect itself from fraud or the credo TO DO NO HARM.  It seems legitimate that the IOM sees itself as protected by the Feres Doctrine which protects the DoD from using Veterans in human experiments such as SHAD and Project 112 BCW testing.  Had Germany invoked something like our Feres Doctrine then there may never have been the Nuremberg trials and executions for crimes against humanity.


You may also note the court verdict was a significant correlation OR, not AND, an increased risk of incidence.  If one looks at the Risk and Odds Ratios of many of the world's mortality studies in dioxin exposures and accidents, these increased ratios would be found in many diseases and disorders.  Yet it seems the professionals at the IOM you mentioned do not consider the rest of the world's scientists as their equal in science and mathematics.


With Risk and Odds Ratios the real difference seems to be that one of the formulas for calculation includes a linear dose slope, assuming there can be proven there is one with dioxins and that it is not proven in all medical manifestations.  In fact it seems for some disorders the opposite is true.  I would conclude this is a pretty arrogant philosophy with no proof of this seemingly elevated scientific stature other than being judge and jury for 4.2 million Veterans who were damaged by the indiscriminate spraying of herbicides in Vietnam.


I would like to point out that one of the doctors on the President's Gulf War Counsel suggested that at any time, given rough exertion, dioxins can break away from fat cells and reenter the blood stream.  Another concluding factor on time constraints is that dioxin does not cause an antigenic response so there should not be some artificial time mandate such as the one agreed to by the V.A. and IOM which is a one year window.  Since it started out as a 10 year window and ends up as a one year window this should tell any intelligent person it is a budget issue and nothing more.  One need only to look at the Seveso studies and conclude how can all these medical problems not be applied to our Veterans.


Now lets look at the differences of Ranch Hand and Seveso.


Seveso had a central distribution point so one could consider this as looking at a dose response considering the levels found in the different areas.


IOM seems to believe and it is my opinion the VA demands, a linear dose response to be a fictional government mandate.  This study, as well as other studies, demonstrates there is no linear dose response to certain cancers such as esophageal, gastro and thyroid atrophy.  I was able to find two studies of low level exposures documented with the same quantitative exposure response.  These studies clearly indicate there is no threshold below a no zero cancer risk.  Even doubling the background from 5 to 10 found an increased lifetime risk between 12.1% and 13%.  In addition, studies demonstrate there is little mathematical risk difference from a specific cancer site vs. "all cancer sites."  My matrix would show it is especially true of adenocarcinoma which seems to be a cancer of the organ linings as opposed to the inside or outside of the organ.


Once again I find the IOM and VA resistant to this mathematical quantitative analysis.  That is to say, it is due to budgetary constraints.


Let's look at the Ranch Hand figures and the false conclusions they demonstrate.


Seveso had a central contamination point so the data as I've indicated is fairly reliable as to some form of dose response or lack of dose response.


Ranch Hand has no such data point.


Ranch Hand data is not representative of the normal combat or firebase Vietnam Veteran and far from it.


Early on the I Corps Marines were noted for having more medical issues than any other area of service.  This was put off to the combat philosophy of "the Corps vs. the Army".  While that may have been part of it, one only need look at the concentration of Agents Orange, White and Blue and, the Super Agent Orange/Agent Orange Two which was a totally different formula used for two years during 1967-69.




Take three firebases along the DMZ which were part of the McNamara line: Cam Lo, Camp Carroll and Rockpile.


Cam Lo: AO  80,375 gallons, AW  8,660 gallons, AB 12,785 gallons


Camp Carroll: AO 78,200 gallons, AW 5,400 gallons, AB 5,050 gallons


Rockpile: AO 110,050 gallons, AW 15,050 gallons, AB 7,650 gallons


When one looks at the herbicide tapes, the specified target areas such as Cam Lo, Camp Carroll, or Rockpile are designated within a 4.8 mile radius of what is covered.  The three areas I am discussing were only five miles apart for overlapping fields of artillery support.  All of these were just off the DMZ within 5 miles of concentrated spraying.


According to the government, the drift rate was 11.2 miles.  Soldiers and their environment at these bases were totally saturated by all of the toxic chemicals and this is just from Ranch Hand operations and does not include the direct firebase spraying by tanker truck, helicopter, or by hand sprayers of both Agents Orange and White.  Spraying by hand was done by soldiers not trained in the use of toxic chemicals.  They were simply told to go spray the perimeter and the areas outside security wire.  I have seen reports of Agent Blue being tank sprayed.  And let's not forget that contamination by these toxic chemicals were also in the water that was used for drinking and cooking.


Thus we have a very different scenario than that of the Seveso population exposures.


During the hill fights and the battles along QL9 including Khe Sanh from about summer, 1966 to mid 1968, the dead bodies along QL9 were a problem.  Some areas were even told to boil their drinking water and this was done in used Agent Orange and Agent White drums that had been cut in half.  These same drums were used to store water for bathing and clothes washing.  The level of contamination from this action cannot be calculated but it certainly should not be dismissed.


In Seveso exposed individuals were told immediately whereas Vietnam Veterans were not told until 1989, twenty plus years after the exposure!  Concentrated spray areas along the DMZ were often bulldozed by Seabees who would then burn the defoliated brush piles.  What level of exposure did this cause?  It is incalculable.


Ranch Hand personnel, or those exposed to toxic chemicals who worked the flight line at Da Nang and showered each day or night in water from deep wells, their level of exposure would be different to those along the DMZ, Cam Lo, Camp Carroll, Rockpile, etc.  Ranch Handers' exposure was primarily skin exposure only and this was the most benign form of dioxin contamination.  And the reason is simply that dioxin absorption thru the skin is limited and slow while dioxins absorbed in the intestinal tract and lungs is faster and much more deadly. Even in exposure methods the outcomes maybe as different as apples and oranges.


Concluding that Ranch Hand, portrayed as the worst case analysis, is indeed the best case analysis and should not ever be used as some sort of gold standard.


One issue you are probably not aware of was the internal combustion atomized dioxin aerosol created.  This was because the Military used the 55 gallon drums to store and transport fuel in.  Agent Orange readily mixed with fuel and burned with the fuel.   Slow moving re-supply convoys every two days along QL9 were nothing but dioxin aerosol dispensers.


Of course in mid 1969 Fort Detrick, MD because of the above discovery issued an emergency directive to MACV on how to decontaminate the drums before use as storage.  Unfortunately, this directive came too late for those already exposed in this method.


To compare Seveso exposure levels with Ranch Hand and then say that Vietnam Veterans did not get much contamination is simply absurd.  And one more factor to consider is this: the Seveso sampling was almost immediate in comparison to Ranch Hand which didn't even start until 1980 or, 18 years after first exposure.


As I understand it, the dioxin half-life in the body is estimated to be between seven and ten years depending on fat content.  So by the time Ranch Hand samples were taken who really knows what the Ranch Handers had in their system since there is so little data to show how and at what rate the dioxins are eliminated from the body other than metabolism which is very very slow.


The Ranch Hand tissue and blood samples were not even started until 1980 as our own government using the VA distanced itself from any damages done by any of the many herbicides used. Clearly this was 18 years after the first exposures.  The dioxin half life in the body is estimated to be between seven and ten years depending on fat content as I understand it.  By the time Ranch Hand samples were taken who really knows what these Ranch Handers had in their system since there is little data to show how and at what rate the dioxins are eliminated from the body.  If fat content is the deciding factor then everyone will be different to the rate.


In 2000 the Hatfield Corporation which is an environmental damage study company reported Quang Tri Province, the most northern province, fish, fowl, and beef were still at 65 parts per trillion of dioxin.  Now that is 32 years after my guys and my Marines left that area. 


Did not get that much Commissioner Grady?????  I think my guys and my Marines can qualify for enough dioxin to be associated to any disorder found in other studies; except by the IOM.  And that does not include the other toxic chemicals and the taking of Dapsone along with all the other toxic chemical contaminations that other studies would not include.


Here is where I also find the EPA's assumption that the water would not be much higher than 65 ppt since the finding was in fish, fowl, and beef and was approximately the same.   To me this would indicate a parallel event such as the uptake of contaminated water not some serial food chain event.  If that is the case, then who knows what our water contamination level was in 1966 - 1969.


The EPA suggests and probably factual that the dioxins bond to the sediment and such in the water.   But you must remember some I Corps guys in the field got water where they could and just used a cloth over the canteen to keep from getting too much sediment in their mouth.


You also must remember every time we filled our potable water "water buffalos" from the local water areas the contamination in those became worse and worse and worse as the dioxin laden sediment built up.


In summary I believe the Ranch Hand report as well as CDC studies are inaccurate and biased.  I have covered some of the disparity of the Ranch Hand report and I submit that government collusion between various departments has been done in order to minimize the monetary cost of damages done to Vietnam Veterans and their families.  In my opinion the CDC studies were insufficient, biased, and grossly inadequate.  They were manipulated by the White House and the Veterans Administration.  I suggest you review House Report 101-672: "The Agent Orange cover-up: a case of flawed science and political manipulation." (35)


I have just covered some of the disparity of the Ranch Hand report and there is much more in government collusion that should be covered yet the IOM uses this totally bogus 140 million dollar wasted taxpayer funding so called study.


In fact, you could write a book about what Ranch Hand found and did not report; which of course I did do just that!


Now lets be clear here on the scientific biases associated with the Veterans of the Nation.


The VACEH operating from 1979 to 1991 had scientists who had represented the chemical companies as well as had already publicly stated their professional position of dioxins caused no harm and these scientists made it sound like dioxin was as good for you as Orange Juice.


Dr. Vernon Houk, Director of the Center for Environmental Health and Injury control, the department within the CDC responsible for conducting the Agent Orange study certainly had a conflict.


Unfortunately for our Veterans and their soon to be widows Dr. Houk had endorsed the lessening of the dioxin dumping standard in the State of Georgia at a rate 500 times more lenient than EPA recommended guidelines.


{See Letter from Dr. Vernon N. Houk to Leonard Ledbetteber, Commissioner Georgia Department of Natural Resources.)




Mr. Grady, members of the Commission , I believe you will find that Vietnam Veterans have never been given a fair and unbiased assessment of the tremendously negative effects that dioxin contamination has caused to their health and the health of their children.  This is due to political interference over the course of many decades by a government trying to cover-up the disaster that was caused in a military conflict and continues in Vietnam to this day as evidenced in the Hatfield Studies of 2000.  In 1990 former Senator Daschle disclosed compelling evidence of additional political interference in the Air Force Ranch Hand study. 


In fact, Mr. Grady, you correctly pointed out how you did not understand the mustard gas issues and why it took over 60 years for our own government to admit its failure to try and find any Veterans that were left to compensate.  This, sir, is the very same government and the very same Veterans Administration that was involved with the denials of mustard gas associations and exposures that is involved with the Ranch Hand studies.  The big difference between mustard gas and toxic chemicals is the generational damage that was done in  the Vietnam Veterans' DNA. And sadly, we have no idea how long a time and how many future generations will be affected by the toxic chemicals that damaged a generation of this country's finest men and women, the Vietnam Veterans.  I implore you sir not to turn your back and become indifferent to these Veterans who suffer with so many health related problems caused by the chemical agents used in that war.


Early interventions instead of denials may have saved lives or disability but we will never know the impacts of the government denials then and now as they continue.


If you need any questions or concerns answered or additional data or proof I am at the ready anytime and will meet anywhere to discuss these issues at my own expense in an attempt to give you our Veterans, widows, and orphans side of this national disaster created by the Johnson Administration and denied by every administration since then.


Charles Kelley

DMZ 67-68