Challenge to the President, Secretary of VETERANS AFFAIRS, THE CONGRESSIONAL leaders on the senate and
house veterans affairs committees,
all CONGRESSIONAL leaders,
and BOARD of VETERANS’ appeals
on toxic chemical associations to disabling chronic PERSISTENT PERIPHERAL NEUROPATHY (Polyneuropathy)
in our VIETNAM Veterans
The united States campaigning “army of Vietnam” and their widows and orphans deserve
ABSTRACT: Chronic Peripheral neuropathy associated with exposures to the dioxin, TCDD during wartime service by our VIETNAM Veterans.
In order to determine the “validity” of the Secretary of the Department Affairs legal statements and the “validity” of the work of the National Academy of Science Institute of Medicine (NAS/IOM) regarding Chronic Debilitating Peripheral Neuropathy found in Vietnam Veterans a four-year data search was completed.
It was found during this search association to dioxin exposures and peripheral neuropathy was “statistically significant” and demonstrated “a proven increased risk of incidence with an Odds Ratio of at least OR =2.39. P values of association were found at < p - 0.050 and P values of significant differences at p - 0.0042.
In the governments “Gold Standard of Denial,” the Ranch Hand Study statistics were not available for obvious government denial reasons. Evidence did find many associations in the scientific transcripts and statements by Dr. Michalek "... we consistently found a statistically significant increased risk of all indices of Peripheral Neuropathy among Ranch Hand veterans.”
Additionally, during this study, it was found that government processes used in determining associations was not only non determinable as to qualification but what was found bordered on scientific misconduct and lack of intellectual freedom.
16 January 2007
To: Senators, Congresspersons, Government Decision Makers, and Congressional Staff Members
President George Bush
The
White House
1600 Pennsylvania Avenue NW
Washington, DC 20500
Congressman Christopher Shays
Oversight Ranch Hand
1126 Longworth
Building
Washington, DC 20515-0704
Congressman Bob Filner
Incoming Democratic Chairman
House Veterans Affairs Committee
U.S. House of Representatives
2428 Rayburn House Office Building
Washington, DC 20515
Senator Daniel Akaka
Incoming Democratic Chairmen
Senate Veterans Affairs Committee
Senate Office Building
Washington D.C. 20510
For Congressman Buyer
CO Mr. Jeff Phillips
Communications Director
House Veterans Affairs Committee
U.S. House of Representatives
335 Cannon House Office Building
Washington, DC 20515
For Senator Craig
CO Mr. Jeff Schade
Communications Director
Senate Veterans Affairs Committee
412 Russell
Senate Office Building
Washington D.C. 20510
Mr. Jim Nicholson
Secretary - Department of Veterans Affairs
810 Vermont Avenue, NW, Room 1000
Washington, D.C. 20420
Ms. Renee L. Szybala
Director
Compensation & Pension Service
VA Central Office
810 Vermont Avenue,
Washington, D.C. 20420
Mr. William McLemore
Deputy Assistant Secretary
Intergovernmental and International Affairs
Department of Veterans Affairs
810 Vermont Avenue N.W. Suite 915
Washington, DC 20420
Mr. Len Sistek
U.S. House of Representatives
Committee on Veterans Affairs
Oversight and Investigations
Room 333
Cannon House Office Building
Washington, DC 20515
Mr. Chris McNamee
U.S. House of Representatives
Committee on Veterans Affairs
Professional Staff Member
Subcommittee on Disability Assistance
337 Cannon HOB
Washington, DC 20515
Mr. David Abbot
Staff Member
Compensation & Pension Service
VA Central Office
810 Vermont Avenue,
Washington, D.C. 20420
Congressman John Linder
1026 Longworth House Office Building
Washington, DC 20515-1007
Senator Saxby Chambliss
416 Russell Senate Office Building
Washington, DC 20510
Senator Johnny Isacson
Senate Office Building
Washington, DC 20510
Dr. Michelle Catlin, PhD
National Academy of Sciences
500 Fifth Street, NW
Washington, DC 20001
FROM:
Please respond to:
Charles Kelley
2078 Eastwood Drive,
Snellville, GA 30078
Cell: 404-641-6477
Subject: The VERACITY and INTEGRITY of the government CONTROLLED and funded Ranch Hand study and the mortality and morbidity impacts to the Vietnam Veterans and their family via the tainted NAS/IOM and Department of Veterans Affairs decisions.
To Whom It May Concern:
This notice of disagreement and NEW evidentiary scientific and medical data submitted is for all Veterans of the Vietnam Era with diagnosed Chronic and Persistent Polyneuropathy.
{Toxic Chemical Issues and cumulative evidentiary data compiled by Charles Kelley –
“Veterans Agent Orange Lay Expert.
Author “Vietnam’s Rain Agents Orange, White, and Blue (Weapons of Mass Destruction)”}
http://www.2ndbattalion94thartillery.com/book/bookorders.htm
Contents
Veterans' Statements
OVERVIEW
EVIDENCE
The government slippery slope
Summary
conclusions
Veterans' Statements
In toxicity comparison the entire town of Times Beach, Missouri was evacuated because of pooled stock at <2 parts per million.
Isomer Definition: A chemical species with the same number and types of atoms as another chemical species, but possessing different properties.
The Veterans' claims are denied by the DEPARTMENT OF VETERANS AFFAIRS because of “service connection” based on exposure to herbicides in RVN is not warranted for any conditions - other than those for which “VA has found” a positive association exists between the condition and such exposure.
Veterans further state; the statements that deny chronic persistent polyneuropathy made by the Secretary of Veterans Affairs, VA scientists, and NAS/IOM scientists are baseless as they are not experts in either the immunological issues of toxic chemical (dioxin/furan toxic chemicals) nor the resulting many many dioxin created autoimmune forms of neuropathies (autoimmune neuropathy).
Veterans further state the evidence and facts that will be demonstrated and documented qualifies this disorder for inclusion for automatically associated presumptive disorders.
OVERVIEW
The BVA and the Secretary of the Department of Veterans Affairs is “inconsistent” in statements of fact of the requirements for the Veteran to prove his service connection including that many studies have shown association of neuropathies that meet the VA’s own requirements of such studies. (See 38 C.F.R 1.17 “Evaluation of studies relating to health effects of dioxin and radiation exposures.”)
The VA/board mandates positive association on exposures to “herbicides" plural). Then mandates the Veteran prove “dioxin, TCCD” (singular) associations.
Veterans disagree with the VA and/or Board that all such medical associations in claims in wartime service in a toxic chemicals (plural) environment must be addressed/associated to the one single by-product of the manufacturing process of (2, 4, 5 trichlorophenoxyacetic acid; 545.4 Kg/m3) {2,4, 5-T} producing the dioxin, TCDD with that being impure Dioxin (2, 3, 7, 8-tetrachlorodibenzo-p- Dioxin) {2,4,5-T}.
Veterans state that the dioxin, TCDD is a “single toxicant” of a “single component” that made up the SINGLE Herbicide with the nomenclature of “Agent Orange.”
Board and its members need to be cognizant and knowledgeable to the scientific facts there is no such thing as “a dioxin.” There are over 200 dioxins that are part of a family of “co-planer” toxicants, which includes dibenzofurans and polychlorinated biphenyls (PCB’s) and are rarely found alone, if at all, with just a single dioxin isomer.
Facts are - that in science and toxicology the most carcinogenic of all the dioxins, dibenzofurans, and polychlorinated biphenyls (PCB’s) IS (2, 3, 7, 8-tetrachlorodibenzo-p- Dioxin) {2,4,5-T} found in Agent Orange.
Science compares the carcinogenic severity of other dioxins, dibenzofurans, and polychlorinated biphenyls (PCB’s) to the dioxin, TCDD that “IS” quantified and qualified as the worst. The key words are “carcinogenic severity of other carcinogens in this family of toxic chemicals.” Therefore, it is logical the Veteran would not only be exposed to the single toxicant of one component but many toxicants of the many components that made up the “Herbicides” (plural).
Veterans are in disagreement with the present acute and subacute transient peripheral neuropathy conclusions by the Department of Veterans Affairs as well as the NAS/IOM contracted by the same government agency the Veteran is now seeking disability compensation from on the issues of Peripheral Neuropathy and those issues normally associated with this nerve disorder.
Present Department of Veterans Affairs and government contracted Institute of Medicine (IOM) position on Peripheral Neuropathy is government biased and scientifically flawed.
EVIDENCE
It is imperative that those Congresspersons/Senators/Government decision makers know and understand the history of this nerve disorder, its associations to toxic chemicals, and the wide variety of opinions and biases against the nations Veterans when VA using the power it has in 38 C.F.R paragraph 1.17. This 38 C.F.R. allows the Secretary to provide “guidelines for establishment of service connection” then minimize the effects and costs of this disorder and make many baseless, presumptuous, and erroneous decisions.
On May 23, 1991, the Veterans' Advisory Committee on Environmental Hazards (VACEH) considered the relationship between exposure to dioxin and the development of this condition. The Committee concluded that there is a "significant statistical association" between “peripheral neuropathy” and exposure to dioxin. The Committee qualified this opinion, stating that the association could be said to exist in the absence of exposure to chemical substances known to cause this disorder. Committee members indicated that other risk factors that must be considered are age and whether the individual suffers from other known causes of peripheral neuropathy such as diabetes, alcoholism, or Guillain-Barre syndrome. The Committee also advised that the disorder must become manifest within “ten years” of the last known dioxin exposure.
The VACEH’s statements confirm a found significant statistical association between “peripheral neuropathy” and exposure to dioxins.
The VACEH committee, in restating the medically obvious to even the 1st year medical student, stated that associations to other disorders such as alcoholism, Guillain-Barre, or diabetes also may cause peripheral neuropathy. This statement no matter how medically inept and not even germane to the subject of the stated found associations directly to Peripheral Neuropathy and dioxin exposures cannot be used as a qualifying statement against the Veterans.
Guillain-Barr syndrome - Guillain-Barre syndrome may be an autoimmune disorder in which the body produces antibodies that damage the myelin sheath that surrounds peripheral nerves. The myelin sheath is a fatty substance that surrounds axons. Veterans would also add variants of the Guillain-Barre syndrome as there a variants of this disorder that do not meet the ICD diagnostics in its entirety. This seems to be true in the axonal variant of Guillain-Barre. Ischemic sensory axonal peripheral neourpathy seems to be the most common diagnosis in our disabled Veterans with the accompanying manifestations.
We now know with the state of medicine and science as it is now that exposures to dioxin does in fact create antibody problems as well as cytokine problems that direct autoimmunity in many different ways and levels. To say this disorder could not produce what is called autoimmune neuropathy would be not only spurious at best but very unscientific (See Evidence Section Immune system).
We now have diabetes associated to the exposures as an automatic inclusive government compensated disability disorder. The state of the scientific evidence (See Evidence Section Immune system) now has concluded that it is at least as likely as not the Guillain-Barr syndrome or similar immune system damages should also be included as a form of peripheral nervous system damages as an autoimmune disorder.
The VACEH clearly stated as part of their function (supposedly on behalf of the Veterans) the found "significant statistical association" between “peripheral neuropathy” and exposure to dioxin. Then qualified that with a non-proven and non-justified ten year time limit.
To qualify the development time of any disorder associated to dioxins, including peripheral neuropathy, then one must understand not only the valid medical etiology (pathology) of how dioxin creates the found statistical association of Peripheral Neuropathy. In addition, all the pathological roads must be identified as in many cases there is more than one pathological pathway of causations. In addition, the discussion must now turn to threshold or ingestion rate in order to quantify a time limit. In addition, the discussion of form of ingestion must be considered. Different forms of Ingestions have different rates of body absorption. None of these are known today much less in 1991. Therefore, unless these VACEH scientists wrote on scrolls and walked on water the qualifying and the other inept statements other than the found statistical association to Peripheral Neuropathy and dioxin is nothing more than VA/government scientific misconduct.
It is impossible to know when the last dioxin exposures occurred in the Vietnam Veteran no matter where he/she resided after the war. It is well known that most of the world’s population including the United States is exposed to some level of dioxins and/or dioxin like isomers. Especially industrialized nations that continue to pollute the environment.
The questions have always been; what types of harm do these ingestions cause, what form of ingestions are at risk, what rate of ingestions are at risk, or what cumulative body threshold over time is required to cause some form of damage to organs and/or body operating systems.
The Environmental Protection Agency (EPA) in its reassessments of dioxins clearly stated that dioxin ingestions must be thought of as “cumulative lead ingestions.” Having many subclinical long-term effects before the damage is discovered or manifestations began.
These medical conditions must be considered and described as related to degenerating conditions suffered later in life which VA and NAS/IOM with no evidence to the contrary continually deny.
Therefore, the government/VA stance on any “time limit” to manifestations of any disorder is totally without merit or scientific precedence regarding an unknown toxic chemical or a group of unknown toxic chemicals that can have a cumulative effect not only in body accumulation but damages that occur because of constant duration of exposures.
Congresspersons/Senators/Government decision makers must know or become aware that these dioxins and dioxin like furans remain in the body attached to more lipid cells (fat) and only degrade in toxicity at a rate of seven to ten years of half-life. It should also be noted that our central nervous system cells are about 70% - 80% lipids (fat) and the rest is protein.
In dioxins reassessment reports, EPA identified 18 major U.S. Dioxin Sources. It might be well for the Congresspersons/Senators/Government decision makers to make note that one of the identified sources of major dioxin contamination was the toxic chemical 2,4, -D. Those that are familiar with the Vietnam Veterans Toxic Chemical Legacy may recall that 2,4-D was not only used as a separate herbicide with the nomenclature Agent White but also used as a 50/50 mixture within the herbicide with the nomenclature Agent Orange.
Clearly pointing out that the most widely used dioxins containing herbicide chemical was Agent White and not Agent Orange. Agent White was the code name for a mixture of an approximate ratio of 4:1 of 2, 4-D (2, 4-dichlorophenoxyacetic acid; 239.7 kg/m3) and Picloram (4-amino-3, 5, 6-trichloropicolinic acid; 64.7 kg/m3), used from 1965 to 1971.
The toxic chemical 2,4-D is also noted for attachment to more lipid cells as a repository.
Further stated by the Veteran the Herbicide with the nomenclature Agent White (2,4-D) also had other dioxin isomers as well as closely related furans, which was also used separately, and as a 50/50 mixture with Agent Orange.
Dr. Daniel Teitelbaum, MD.; one of the world’s foremost toxicology experts in 1989 in a letter to Admiral Zumwalt during the 1989 Herbicide assessments stated: (X)
{In the context of evaluating Agent Orange but as documented after reviewing Dow Chemicals own documentation, his concern also was for Agent White (2,4-D):}
{Agent White was the code name for a mixture of an approximate ratio of 4:1 of 2, 4-D (2, 4-dichlorophenoxyacetic acid; 239.7 kg/m3) and Picloram (4-amino-3, 5, 6-trichloropicolinic acid; 64.7 kg/m3).}
“What I do think...may bear on the Agent Orange issue, is the fact that in review of Dow’s 2,4-D documentation I found that there are significant concentrations of potentially carcinogenic materials present in 2,4-D which have never been made known to the EPA, FDA, or to any other agency. Thus, in addition to the problem of the TCDD which, more likely than not, was present in the 2,4,5-T component of Agent Orange, the finding of other dioxins and closely related furans and xanthones in the 2,4-D formulation….”
Picloram is a conveniently Dow proprietary chemical formula that contained not only nitrosamines but also a form of benzene toxic chemical known as hexachlorobenzene. Which would almost guarantee this formula would have other dioxins and dioxin like isomers.
For example:
Any of the hexachlorodibenzofuran isomers
Any of the tetrachlorodibenzofuran isomers
Any of the tetrachlorodibenzofuran –p-dioxin
Any of the pentachlorodibenzofuran isomers
Any of the pentachlorodibenzo – p-dioxin isomers
It should be noted here, as you have seen on TV the lawyer commercials, the benzene family of toxic chemicals are also noted for causing blood disorders, including leukemia’s.
One can readily see that the government mandated to a “cause and effect” of the one dioxin isomer, TCDD to one medical disorder or a group of medical disorders from mixed dioxin compound isomers or dioxin like isomers in the form of furans and/or polychlorinated biphenyls (PCB’s) is outside the realm and ability of science as we know it at this present time and has mandated “undue hardship on the Veterans of this nation” that served in the government created toxic chemicals (plural) environment.
VA and U.S. Government, studies have solely concentrated on the worst dioxin that being 2, 3, 7, 8-tetrachlorodibenzo-p- Dioxin found in 2, 4, 5-T or Agent Orange. Clearly, there are other dioxins, xanthones, and closely related dioxin like furan isomers that have never been looked at, identified, nor even a VA/government concern for over 40 years.
It is further stated by the Veteran the Herbicide with the nomenclature Agent Blue cacodylic acid (dimethyl arsenic acid) symptoms include: (X)
Acute exposure may lead to:
Garlic type odor of breath and feces, and metallic taste in the mouth.
Adverse GI effects predominate with vomiting, abdominal pain and rice-water, or bloody diarrhea.
GI effects may also include inflammation, vesicle formation, and eventual sloughing of the mucosa in the mouth, pharynx, and esophagus.
Central nervous system effects that are common include: headache, dizziness, drowsiness, and confusion.
Symptoms may progress to include muscle weakness, spasms, hypothermia, lethargy, delirium, coma, and convulsions.
Renal injury manifests as proteinuria, hematuria, glycosuria, oliguria, and shows up in the urine. In severe poisoning cases, acute tubular necrosis results.
Cardiovascular effects include shock, cyanosis, and cardiac arrhythmia.
Elevated liver enzymes and jaundice may manifest causing liver damage.
Injury to blood-forming tissues may cause anemia, leucopenia, and thrombocytopenia.
Chronic exposure may lead to:
Muscle weakness, fatigue, anorexia, weight loss.
Hyperpigmentation, hyperkeratosis.
Peripheral neuropathy, paresthesia, paresis, and ataxia.
Inability to coordinate voluntary muscular movements.
Subcutaneous edema in face, eyelids, and ankles.
Stomatitis, white striations across the nails (Mees lines) and sometimes loss of nails or hair.
Liver toxicity as indicated by hepatomegaly, jaundice, and cirrhosis.
Renal toxicity leading to oliguria, proteinuria, and hematuria.
EKG abnormalities and peripheral vascular disease.
Hematologic abnormalities.
Cancer.
Carcinogenicity has not been tested adequately, but it should be noted that other inorganic arsenic compounds have been found associated with liver, lung, skin, and “stomach cancers.”
In 1969 when the US State Department got involved in analyzing and minimizing the effects that were being seen in our Vietnam Veterans. The US State Department clearly indicated in a report by ______ that Agent Orange was of very little concern. However, Agent Blue with its arsenic acid base “was a real concern.” (X)
These toxic chemical effects and possible outcomes cannot be just government ignored because Agent Blue was not as widely used as Agent White or Agent Orange. There were very few areas of Vietnam where only Agent White and Agent Orange were used and not Agent Blue.
Congresspersons/Senators/Government decision makers must recognize this clear difference between Vietnam Veterans and other increased risks of working with these isomers, and the normal genotype population. The Vietnam Veteran in general is not going to meet the normal genotype population in background exposure levels. Not only in dioxin isomers but also exposures to other toxic chemicals at the exact same time.
A study published in Industrial Health on Dioxin; Exposure-Response Analysis and Risk Assessment the following statements were made. (X)
Abstract:
…In 1997, dioxin was found to be a human carcinogen by the International Agency for Research on Cancer (IARC), based on four other studies of industrial workers exposed to high levels. Recently there has been interest in estimating human cancer risk at “low-level environmental exposures.” Here we review quantitative exposure – response analysis and risk assessment for low level environmental levels… In the US the background risk of cancer death by 75 is 12%, so doubling the background levels of dioxin exposure risk to somewhere between 12.1 and 13.0%. Our results agree broadly with results from a German cohort, which is the only other cohort for which a quantitative risk assessment has been conducted. (X)
This study also found that “all cancer sites” were elevated not just the ones the government/VA has reluctantly stated are associated. Additional statements were made that dioxins may be the first manmade “all site” cancer-producing carcinogen. In addition, those cohort individuals that were exposed to pentachlorophenol (PCP) were excluded from this study. (X)
Pentachlorophenol is also a major product of the metabolism of hexachlorobenzene in mammals.
Chronic toxicity: Much research on PCP has been performed with poorly characterized technical material, and the chronic toxicity observed may depend in large measure on the proportion of chlorodibenzo-p-dioxins present in the mixture [69]. In a 90-day feeding trial in rats, 30 mg/kg/day produced depressed red blood cell and hemoglobin levels as well as liver degeneration, and even lower doses resulted in irregular blood chemistry and enzyme levels, along with increased liver and kidney weights [69,71]. Pure PCP, and technical PCP without dioxin contamination, produced only slight enlargement of livers and kidneys [69]. Purified PCP also did not produce toxic effects such as liver damage and immune system alterations, which had previously been reported for the technical product [69,71]. In humans, the most common exposure to PCP is inhalation in the workplace. Abdominal pain, nausea, fever, and respiratory irritation, as well as eye, skin, and throat irritation, may result from such exposure [70], while very high levels may cause obstruction of the circulatory system in the lungs and cause heart failure [70]. Survivors of toxic exposures may suffer permanent visual and central nervous system damage [70]. Persons regularly exposed to PCP tend to tolerate higher levels of PCP vapors than persons having little contact with these vapors [70,71].
While cancer is not the subject of the Veterans denial, cancer risk does play a part in the rebuttal of denial. It is clinically impossible to have a cancer causing toxicant that can only produce cancer and not autoimmune derivates of a cancer such as Peripheral Neuropathy. This will be shown in the dysregulation of B and T cells in the immune system found associated and the variances found in the cytokines of the immune system. (See Evidence Section) Many subclinical autoimmune disorders are associated with peripheral neuropathies.
Veteran will also demonstrate the association to many such immune disorders that will cause many forms of neuropathy. Including Veterans evidence will show that EPA and NAS now agree – “The NAS committee agreed with EPA's conclusion that dioxins are probably toxic to the human immune system,….”
Congresspersons/Senators/Government decision makers must remember that dioxins create at least three immune system damages in Immunotoxicology and combination of damages that the outcomes are multiple in outcomes and severity.
Dioxin created:
Immunodeficiency or suppression
Alteration of the host defense mechanism against antigens and carcinogens (one theory is that the immune system detects cells altered by antigens or other carcinogenic trigger and destroys these cells. Thus, an impaired immune system may not detect and destroy a newly forming cancer.)
Hypersensitivity or allergy to the chemical antagonist. Because of dioxin’s ability to be both an immunosuppression and a carcinogen, as early as 1978 immunologists were suggesting that "agents such as TCDD.. .may be far more dangerous than those possessing only one of these properties."95
Some immunotoxicologists argue that one molecule of a carcinogenic agent, like dioxin in the right place and at the right time can create a multitude of outcomes and severity in immune system damages.
The Environmental Protection Agency (EPA) as recently as 2005 stated general exposure levels in its dioxin reassessments, which began in 1992. (X) While the mid-90’s levels of exposures is about half of what it was in the 1980’s it is still at 25 parts per trillion Toxic Equivalent (TEQ) lipid. The Vietnam Veteran was at his/her most vulnerable for additional cumulative damages in the 1980’s at approximately 55 parts per trillion Toxic Equivalent (TEQ) lipids. So even on long-term damages, there can be no time limit from initial massive multiple toxic chemical exposures resulting from the Veterans wartime service in the parts per trillion range or the parts per million ranges. Chronic exposures resulting in constant/continuous exposures must be considered; not some “initial estimated dose” of one toxic chemical isomer of many toxic chemical isomers involved experienced during only the time spent in Vietnam.
Vietnam Veterans are outside this generic qualification of background exposures. As anyone can see it might be the additional 20 or 30 years of dioxins accumulation that is the causation dose or reaches the cumulative body threshold. However, if not for Service in Vietnam in a toxic chemicals (plural) environment that increased his or her increased baseline at an early age then the mortality and disability manifestations caused by the dioxin, TCDD may not have taken place or had any effect on early mortality or early disability the Veteran now develops.
It was known that Peripheral Neuropathies and Chronic Fatigue Syndrome (the old medical term of Neurasthenic syndrome) were associated to toxic chemical pesticide and herbicide exposures as far back as the late 1940’s. (See Evidence Section)
An announcement on 3 December 2006:
What are the possible health effects of Dioxin exposures?
At high enough levels, dioxins can cause cancer in humans. They can also damage the nervous system, weaken the immune system, and alter menstrual cycles.
Dioxins have caused cardiovascular and respiratory problems, skin disease, birth defects, and other conditions in laboratory animals.
(X) SOURCES: National Institute of Environmental Health Sciences, federal Agency for Toxic Substances and Disease Registry
In addition, recently a new medical finding located in dorsal root ganglionitis (inflammation in the spinal cord) - recently discovered in a two-week autopsy, with the cause of death listed as Chronic Fatigue Syndrome. This becomes a “clear physical manifestation” of the disorder in the Central Nervous System.
This new finding seems to confirm what many scientists have been saying for decades now regarding toxic chemical Peripheral Nervous System (PNS) issues and that is before any PNS issues manifest a Central Nervous System (CNS) subclinical event/causation has taken place and precedes any PNS manifestations.
While there seems to be, a running battle between psychiatrists and medical doctors as to the cause of this disorder. It seems there is a medical physiological issue associated to our toxic chemical exposures in our damaged immune systems that create this nerve damage or inflammation as well as the chronic fatigue issues found in 1984 of degenerating neurological issues by our own governments studies of those that sprayed the toxic chemicals. (X)
The “Government Bias” has always been that toxic chemical etiolgy must be found directly to an antigenic response by the body to the toxicant that caused the peripheral neuropathy. This is also a flawed assumption. Flawed by the assumptions that exposure to multiple toxic chemicals event would force the body to a direct response to the dioxin, TCDD, or any other toxicant. With a half-life in the body of a decade or longer thereby demanding the exposures to the various toxic chemicals must be considered as simultaneous or parallel multiple exposures as opposed to a serial single toxicant exposure. This clearly demonstrates that any time limit put on a Veteran for diagnoses is a false conclusion by the government/VA/NAS-IOM in any disorder.
Dioxin exposures create many systemic body damages such as in the immune system that will not meet some mandated International Classification of Diseases (ICD) but rather an undefined toxic chemicals (plural) syndrome of organ and/or body system damages in neurological, endocrine, hematological, immunological, gastrological, cardiovascular, urology, or any combination of each. Each one separately can be the cause of chronic and persistent neuropathies of many types and varieties and even combination of different neuropathies (autonomic, sensory, motor).
The Veterans' Advisory Committee on Environmental Hazards did not qualify the association to “acute or subacute transient peripheral neuropathy” but clearly stated "significant statistical association" between peripheral neuropathy and exposure to dioxin did exist as early as 1991 clearly meeting the requirements in 38 C.F.R. 1.17.
While the Veterans' Advisory Committee on Environmental Hazards did put a flawed time limit of 10 years on the manifestation of the nerve damages, it did not indicate any time of resolution of the disorder. Primarily because of the conditions in which the nerve damage is being caused by is more than likely not going to be curable such as in autoimmune peripheral neuropathy or even some of the smoldering cancer conditions or undiagnosed toxic chemical caused cancers. Thus, this also eliminated the slow progression of the real disorders and long-term development from being compensated or service connected.
This particular disorder has an even more obvious government/VA bias and undue hardship on the Veteran in that our government put a time limit on not only the manifestation to one year but also the damage to the nerve myelin matter would repair itself within two years after removal from the toxic chemicals or resolve itself.
While that may be true for the Department of Defense testing program on Vietnam Veterans in the use of Dapsone for the harsh type of malaria that was found in Vietnam. It is not true of dioxin associated Peripheral Neuropathies. Dapsone is noted for causing peripheral neuropathy and hematological disorders directly as in a direct antigenic response to the chemicals in Dapsone (a leprosy treatment medication). This is especially true in hematological issues, which is the most common adverse effect and is seen in patients with or without G6PD deficiency. {Glucose 6-phosphate dehydrogenase (G6PD) deficiency is an enzyme deficiency of the red blood cells. G6PD deficiency leads to an abnormal rupture (breakage) of the red blood cells called hemolytic anemia (abnormally low red blood cell count)}. Almost all patients demonstrate the inter-related changes of a loss of 1-2 g of hemoglobin, an increase in the reticulocytes (2-12%), a shortened red cell life span and a rise in methemoglobin. G6PD deficient patients have greater responses.
Once a medical diagnosis is reached that, the patient is having these difficulties with red blood cells or Peripheral Neuropathy and muscle weakness the recommend medical treatment is to remove the patient from the Dapsone. Normally Recovery on withdrawal is “usually substantially complete.” The mechanism of recovery is reported by axonal regeneration.
In addition to the warnings and adverse effects reported above, additional adverse reactions include: nausea, vomiting, abdominal pains, pancreatitis, vertigo, blurred vision, tinnitus, insomnia, fever, headache, psychosis, photo toxicity, pulmonary eosinophilia, tachycardia, albuminuria, the nephrotic syndrome, hypoalbuminemia without proteinuria, renal papillary necrosis, male infertility, drug-induced Lupus erythematosus, and an infectious mononucleosis-like syndrome. In general, with the exception of the complications of severe anoxia from over dosage (retinal and optic nerve damage, etc.) these adverse reactions have regressed off drug.
This is an example of how the one year or ten year rule would fit the diagnosed VA scenario and even the scenario that in most cases the medical issues caused by the direct taking of the Dapsone (a direct antigenic response) should resolve in most patients, once removed. This would also fit the scenario of a poisons such a snake bite, or ingesting a poisonous plant, or even an untreated tick bite.
This scenario does not fit the secondary Ah receptor toxic chemical damages done by the dioxin, TCDD or many toxicants of similar dioxin like isomer properties the Veteran was exposed.
Our own Environmental Protection Agency has clearly stated as well as other studies that dioxins in and by themselves do not cause an antigenic body response such as a poisonous plant, spider, snake, or even some types of tick bite. Once again, the taking of Dapsone may produce an antigenic response. In these examples once the toxicant is eliminated by the body, which varies in time and methodology the body damage is then over, and the body as stated will repair itself "to some level."
Common and medical scientific sense mandates that there can be no antigenic response for the dioxins since the dioxins are in the body 40 years after the exposures. This would also mandate that since there is no antigenic response there could be no time limit of resolution. This would also mandate that only a C & P for the damages or the doctor’s opinion with diagnostics that the damages being done are getting better or resolving. That is not up to VA or the IOM for the individual veteran.
This would have to conclude that somehow our government/VA/NAS-IOM has magically defined the following:
Therefore, someone somewhere has determined that direct contact with the dioxin, TCDD at some level will create some level of “direct peripheral nerve damage only” that does not involve a central nervous system involvement or any cell DNA or mitochondria cell DNA modifications and they know how it does it and what the ingestion rate must be and/or the total body threshold is; regardless of method of ingestions.
Congresspersons/Senators/Government decision makers, Veteran finds the VA decisions on peripheral neuropathy disorder to be only transient and resolution of disorder baseless, presumptuous, and erroneous and not scientific as it applies to the toxicants in question.
On July 1, 1991, Secretary of Veterans Affairs Derwinski announced that VA will propose rules granting service-connected disability status to certain veterans with peripheral neuropathy. Proposed rule implementing the Secretary's decision was published for public comment in the Federal Register in January 1992. (See 57 Fed. Reg. 2236, January 21, 1992). It was anticipated that the final rule would be published in 1993. However, in July 1993, when the National Academy of Sciences (NAS) released its comprehensive report, entitled Veterans and Agent Orange - Health Effects of Herbicides Used in Vietnam, peripheral neuropathy was not included in the category "sufficient evidence of an association" or even "limited/suggestive evidence of an association." Rather, the NAS reviewers concluded that there is "inadequate or insufficient evidence to determine whether an association exists between exposure to herbicides (2,4-D; 2,4,5-T and its contaminant TCDD; cacodylic acid; and picloram) and disorders of the peripheral nervous system." The NAS report added, "Although many case reports suggest that an acute or subacute peripheral neuropathy can develop with exposure to TCDD and related chemicals, reports with comparison groups do not offer clear evidence that TCDD exposure is associated with chronic peripheral neuropathy. The most rigorously conducted studies argue against a relationship between TCDD or herbicides and chronic neuropathy."
Acute is used to mean immediate effect; as opposed to chronic that means an effect not appearing immediately.
VA asked the NAS, in its follow-up report, to consider the relationship between exposure to herbicides and the subsequent development of the acute and subacute effects of peripheral neuropathy (as compared to the chronic effects, which were focused on in the initial report).
In January 1994, VA published a notice in the Federal Register that Secretary Brown has determined that a presumption of service connection based on exposure to herbicides used in Vietnam is not warranted for a long list of conditions identified in the NAS report. Peripheral neuropathy was included in this list. (See 59 Fed. Reg. 341, January 4, 1994).
What did the NAS 1996 update conclude about peripheral neuropathy?
When the NAS reviewers separately reviewed chronic persistent peripheral neuropathy and acute and subacute transient peripheral neuropathy, they found that there was still inadequate or insufficient evidence to determine whether an association exists between exposure to herbicides and chronic persistent peripheral neuropathy. On the other hand, they reported that there is some evidence to suggest, “neuropathy of acute or subacute onset may be associated with herbicide exposure.” They included acute and subacute transient peripheral neuropathy among those conditions they placed in their second category “limited/suggestive evidence of an association.” (Chronic persistent peripheral neuropathy remained in category three, “inadequate/insufficient evidence to determine whether an association exists.”)
What was VA’s response to the NAS 1996 finding about acute and subacute transient peripheral neuropathy?
After careful review of the report, Secretary Brown decided that VA should add acute and subacute peripheral neuropathy (when manifested within one year of exposure) to the list of conditions recognized for presumption of service connection for Vietnam veterans based on exposure to herbicides. President Clinton announced this, along with other, decisions, at the White House, on May 28, 1996. The proposed rule was published for public comment in the Federal Register in August 1996. (See 61 Fed. Reg. 41368, August 8, 1996). The final rule was published in the Federal Register in November 1996. (See 61 Fed. Reg. 57587, November 7, 1996).
What did subsequent NAS updates conclude about peripheral neuropathy?
With regard to chronic persistent peripheral neuropathy, the 1998 report stated, “No new information has appeared in the intervening two years that alters this (the 1996) conclusion.”
With regard to acute and subacute transient peripheral neuropathy, the 1998 update reported, “The committee is aware of no new publications that bear on this issue. If TCDD were associated with the development of transient acute and subacute peripheral neuropathy, the disorder would become evident shortly after exposure. The committee knows of no evidence that new cases developing long after service in Vietnam are associated with herbicide exposure.”
In update 2000: For chronic persistent peripheral neuropathy, there is only inadequate or insufficient evidence to determine whether an association exists between exposure to dioxin or the herbicides studied in this report. NAS found that there was limited/suggestive evidence of an association between exposure to the herbicides considered in this report and acute or subacute transient peripheral neuropathy. The evidence regarding association was drawn from occupation and other studies in which subjects were exposed to a variety of herbicides and herbicides components. Information available to NAS continued to support this conclusion.
Congresspersons/Senators/Government decision makers you should remember the statements made above by VA and NAS/IOM and the statements originally made by the committee that decided our fate from 1979 to 1991 (VACEH) and their findings that there is a "significant statistical association" between “peripheral neuropathy” and exposure to dioxin shown in the Evidence Section. Then as you go through the Veterans evidence bear in mind what other studies have found - even in the government exoneration tool the Ranch Hand study. I think you will agree that in order for NAS/IOM to make the above statements that a large bias seems to be evident in the scientific world of those that are contracted and controlled by our government.
Veterans will clearly show the neurological condition, chronic polyneuropathy, is associated to exposures to dioxins as well as the associated Chronic Fatigue Syndrome (formerly diagnosed as Neurasthenic Syndrome) as a stand alone disorder and should be “automatically associated” for all Vietnam Veterans with that diagnosis that served in geographical Vietnam as well as those Veterans that were exposed around the world to the same “government created toxic chemical formulas and doses.”
The Chronic Fatigue Issues that go with this nerve disorder also found in exposure victims even in our own government studies that “is just as likely as not” associated to Central Nervous System damage associated with Chronic Fatigue Immune Dysfunction Syndrome, or sometimes called Myalgic Encephalopathy.
A recent new finding seems to confirm what many scientists have been saying for decades now regarding PNS issues and that is before any PNS issues manifest a CNS subclinical event/causation has taken place and precedes any PNS manifestations.
This seems to be located in dorsal root ganglionitis (inflammation in the spinal cord) - recently discovered in a two-week autopsy, with the cause of death listed as Chronic Fatigue Syndrome. This becomes a “clear physical manifestation” of the neurological disorder.
“Evidence reveals that Dow Chemical, a manufacturer of Agent Orange was aware as early as 1964 that TCDD was a byproduct of the manufacturing process. According to Dow’s then medical director, Dr. Benjamin Holder, extreme exposure to dioxins could result in "general organ toxicity" as well as "psychopathological" and "other systemic" problems.” (19)
{Psychopathological - The manifestation of mental or behavioral disorders.
Many toxicologists believe that not only do these toxic chemical herbicides (plural) cause peripheral neuropathy (PN) but also central nervous system (CNS) issues.
It should also be noted that in 1969 the United States “State Department” got involved in the controversy of the use of herbicides. Their scientific conclusion was that Agent Orange posed little threat to humans but that Agent Blue was of major concern with its form of arsenic acid. (12) (13)
This description of our toxic chemical exposures matches no other toxic chemical hazard other than the possibility of the Love Canal, New York environmental disaster, which contained many of the same forms of toxic chemicals (plural) that Vietnam Veterans were exposed. However, once again the dose rate for Vietnam Veterans is much higher than even in the Love Canal disaster.
Toxicologists state the CNS damage in the form of nervous system lesions or other issues precludes a PN involvement. (2) The EPA, in their 1992-1996 dioxin reassessments categorically stated that the brain may be particularly vulnerable to accumulating dioxin into its fat content. Nervous system tissue itself, with its high lipid content, can also act as a repository for dioxin. Dioxin accumulates in the body fat and once in the body, even at very minuscule amounts, interferes with cell development. (3)
It is also note worthy that the main toxic chemical in Agent White 2,4-D, is also noted for this seeking of a more lipid environment as a repository.
Dioxin exposure causes damage to the peripheral and central nervous systems. The association between dioxin and damage to the nervous system is reflected in a finding by the Veterans' Advisory Committee on Environmental Hazards, which recommended that the VA compensate Vietnam veterans for peripheral neuropathies as “service related.”
Already discussed in the formal presentation are the VA’s constraints that were put on this “obvious toxic chemical caused disorder” to the point that no (zero) Veteran would qualify.
Effects on the central nervous system occur before gross pathological damage can be demonstrated in the peripheral nerves. The neuropsychiatric and neuropsychological symptoms of central nervous include depression, anxiety, reduced cognitive function, poor coordination, etc. (2)
One severe consequence of central nervous system damage by dioxin is higher
rates of suicide (shown in dioxin-exposed Vietnam veterans, chemical production
workers, and forestry workers). Another severe consequence is excess
deaths from accidents (also significantly elevated in dioxin-exposed chemical
production workers and Vietnam veterans). These accidents could be caused
by neurological malfunction, or also represent disguised suicide to a certain
extent. (2)
Other effects on the central nervous system found in exposed Vietnam veterans and chemical production workers include depression, anxiety, loss of libido, and other neuropsychiatric and neuropsychological effects. Effects on the central nervous system also have been demonstrated in a dose-related manner in Vietnam veterans and chemical production workers, providing firm epidemiological evidence that dioxin caused these effects. (2)
In addition, the same range of neuropsychiatric and neuropsychological effects
seen in dioxin-exposed populations have been demonstrated for exposure to other
neurotoxic substances, such as solvents. This demonstrates a similar
biological mechanism between the neuropsychiatric and neuropsychological effects
caused by dioxin and other substances.
(2)
Peripheral Nerve and Cerebrovascular Abnormalities
The following studies document clinically diagnosed neurological and
cerebrovascular effects among several populations exposed to dioxin.
(2)
These gross abnormalities of the peripheral and central
nervous system serve to indicate extreme endpoints of the effects of dioxin.
More subtle effects on the central nervous system occur before clinically
demonstrable peripheral nerve damage.
Peripheral Nerve and Cerebrovascular Abnormalities
Gold Standard Government study Ranch Hand
The Air Force Ranch Hand study in the scientific transcripts stated a found dioxin response to chronic polyneuropathy.
“Data showed a significant increase in the index of polyneuropathy. Another run through the data showed it correlated significantly with dioxin.” (4)
“A significant and adverse relationship between peripheral neuropathy and dioxin body burden was found.” (5)
Other studies of Vietnam Veterans
The Korean Agent Orange Impact studies in a totally blind honest study released in 2003, found dioxin related to peripheral neuropathy at a p-value of 0.039. The study also found a p-value of difference between Vietnam Veterans and non-Vietnam Veterans with peripheral neuropathy of a p-value of difference of 0.0042. An odds ratio (OR) was found of 2.39. (21)
The Korean Agent Orange Impact studies also found cerebrovascular issues as follows: Brain Atrophy except cerebellum a p-value of 0.0165, Brain Infarction a p-value of 0.0013. In the spinal chord areas, the study found Radiculopathy including herniated intervertebral disc a p-value of <0.0001, Radiculopathy a p-value of 0.0002 was found with an odds ratio (OR) of 3.98, Myelopathy a p-value of 0.0851, and in Spondylosis a p-value of 0.1311 was found. (21)
In a second Korean impact study evaluating the immune system the statement was made: “Based on the results of two epidemiological studies, Peripheral Nerve Disease is the most prevalent disease followed by Lung Cancer, Beurger’s Disease, Larynx Cancer, non-Hodgkin’s Lymphoma, and Chloracne associated with Agent Orange Exposures. Based on the results of two epidemiological studies of probably associated with Agent Orange exposure, Hypertension was the most prevalent disease followed by Diabetes Mellitus, Seborrheic Dermatitis, Central Nervous Diseases, Liver Diseases, Cancer, Hyperlipidemia, Cerbrovascular Disease, Ischemic Heart Disease, and other skin disorders such as Chronic Urticaria and Psoriasis Vulgaris.”(16)
Seveso, Italy
Seveso, Italy Residents in the 15-year mortality/morbidity dioxin only accident study found a “three-fold increase” in peripheral neuropathy obviously at least 15 years after the accident. (23)
In all these studies they were decades after exposures and nothing had resolved itself as the VA and NAS/IOM have unscientifically and with great bias have mandated will happen within two years of removing ones self from the exposures.
The list of found associations to peripheral nerve damage and dioxin or dioxin like isomers goes on and on in medical history back to the late 1940's. It would be redundant to include those in this Veterans challenge. However if those Senators, Congresspersons, Government decision makers, and Congressional Staff Members decide to at least look at a path to justice for the nations government created disabled veterans then these accounts and facts can certainly be presented as a separate paper. Just ask!
Veterans will give one more example:
In a dioxin like train spill, 49 Monsanto workers were sent in to clean up the spill. Within 12 years, 45 of the workers had raging peripheral neuropathy and two workers had committed suicide. It is unknown what happen to the other two. (X)
How can the VA/NAS-IOM continue to deny such found relationships by the governments own gold standard study and many other studies? Simply put - congress has given the Government entities such as VA and NAS/IOM that much "corrupt power" over Veterans and the mandated yearly budget control, including the questionable use of the Board of Veterans Appeals.
“The most severe neuropsychological consequence of dioxin exposure is excessive suicides, which has been demonstrated among exposed Vietnam Veterans, chemical production workers in the U.S. and European countries, forestry workers, and railroad workers. Another severe consequence is the excessive death rate from accidents found among the dioxin-exposed chemical production workers and Vietnam Veterans, representing either motor neuron malfunction or suicide in disguise.
“In 1977, the Working Group of the International Agency for Research on Cancer (IARC) found that neurological and behavioral changes were among the most frequently reported effects in studies of exposures to 2,4,5-T (IARC, 1977a). (X)
IARC identified 6 out of 7 different populations occupationally exposed to chlorinated phenolic compounds where neuropsychological symptoms such as neurasthenic or depressive syndromes were established (IARC, 1977b).v (X)
IARC noted that PNS damage was also found in the same 6 dioxin-exposed populations, including polyneuropathies, lower extremity weakness, and sensorial impairments (sight, hearing, smell, taste). (X)
In 1986, the IARC clearly restated it’s finding that dioxin had been found to be associated with peripheral neuropathies and personality changes (IARC, 1986). (2)
Veterans need not know the etiology of such manifestations as to why they are becoming neurological disabled from dioxin exposures.
Peripheral Neuropathy by the best scientific minds in our nation go ischemic in about 33% of the cases. Veterans cannot even get this noted medical diagnostic doubt from our government so called friendly agencies.
Peripheral Neuropathic disorders have many many causations associated to include:
Of course most know of the insulin issues associated with a diabetic involvement.
It should be noted here that in the only honest testing and evaluation done in the "Veterans Opinion" of Vietnam Veterans and dioxin levels the p-value found on "neuropathy and diabetes" in Veterans was only remarkable to 0.2157. This is hardly significant in any scientific value. Yet, this same study found both diabetes and peripheral neuropathy significant at p<0.5 with respective odds ratios of OR = 2.69 and OR = 2.39. (X)
The four levels of exposures did not show a significant trend in linear effect with the possibilty of a slight trend in diabetes involvement. Absent the tolerance values assigned this may be an accumulation of tolerances error.
These findings "were significant" after adjusting for potential confounders in:
age
smoking
alcohol
body mass index
education
martial status
health insurance
How much more do the government caused disabled Veterans of this nation need to prove in order to be compensated in disability for a disorder that has been proven and proven and then re-proven to be associated with the dioxin exposures.
What is it that the VA and the NAS/IOM need besides some honesty and integrity?