From: To: Cc: Subject: Date: Attachments: Alvin Young Sampsel, James, VBAVACO; Dick, Wendi; Peterson, Michael (VHACO) (SES EQV); Irons, Terra Pharr, Michael, VBAVACO; Exemption Points to Consider RE: Stellman et al ltr Monday, December 17, 2012 6:01:34 PM Points to consider in response to the Stellman letter to Secretary Hickey12 16 12.docx 17 December Wendi, After our conference call last Wednesday, I started developing some talking points or points to consider in addressing the letter from Undersecretary Hickey to Dr. Jeanne Stellman. In summary, I would just suggest that  Dr. Stellman distorts the science and history with impunity thinking that the VA Team is simply not at her level of competence or understanding (what a nice way for me to say it!). In my "Points to Consider", I played her game of assessing risks, although my actual position is that you cannot take hexane wipe samples and convert the total extractable quantity as a human "dose", as she does, and then determine unrealistic screening levels. One cannot even talk about the process as a meaningful expression of "exposure." I have used a few of these points in my revision. I also addressed the issue of dust by explaining how "air flow" occurred in the C-123s. In my paper I also focus on the Air Force Health Study that has equal application to exposure to Agents White and Blue (picloram and cacodylic acid), neutralizing her issue of a presumption of 'herbicide' exposure. I have attached the "Points to Consider"  to give you my thoughts of the Stellman Letter.  I have received calls from a couple of "very knowledgeable scientists" who read Stellman's letter on the Internet and said they were going to write to BG Hickey with their views on correcting the misinformation by Dr. Stellman. This certainly gives you an idea how unpopular Jeanne Stellman is with the main stream scientific community on the issue of risks and Agent Orange and dioxin. I'll have some comments later about the scientists/physicians that signed onto the Stellman letter. Regards, Al Young Points to consider in response to the Stellman et al. letter to Secretary Hickey on C-123 exposures: 1. Any potential exposures for the C-123 veterans are small-area, limited-time exposures. That is, an office or industrial worker is typically assumed to be exposed for 250 days per year, 8 hours per day, for 10 to 30 years. Flight crews would be exposed a small fraction of this time, both in terms of days per year and years of exposure (typically 1 year). 2. The letter to Secretary Hickey by Dr. Stellman and others makes the statement that “The Army office worker exposure scenario provides for far less opportunity for dermal contact than would have been likely for C-123 crew and maintenance personnel.” This statement is wrong. Flight crews are in fixed locations when the aircraft is underway. Belted into a seat, there is very limited area for skin contact. 3. The contact area of the interior of a C-123 is estimated in Appendix H of the report “Hill Air Force Base, Utah Final Dioxin and Herbicide Characterization of UC-123K AircraftPhase I.” The interior areas accessible to human contact, including the ceiling are 2,660 square feet. In contrast, an office building or industrial facility will have an available surface area of tens of thousands of square feet. 4. The problem is that with such a small area, all of the material may be easily removed by human activities over time, such as cleaning in regions of frequent contact. Thus, long term exposures are practically impossible. 5. The letter to Secretary Hickey states “We also think it important to note, as you do in your letter, ‘the 1991 Agent Orange Act ... provides a presumption of herbicide exposure’ (emphasis added). This means exposure to 2,4,5-T, 2,4-D, picloram and dimethyl arsenic acid (another carcinogen), not just the notorious Agent Orange contaminant, TCDD (dioxin), are covered by the Act.” However, the long series of Veterans and Agent Orange reports is focused on identifying diseases that are “dioxin associated.” That is, the focus of the compensation program is, and always has been on dioxin. 6. As far as dermal exposure is concerned, the fact remains that the wipe samples taken in all the aircraft are done with wipes wetted with hexane. While hexane saturated wipes are efficient at removing dioxin from surfaces, the amount removed would be far greater than any amount removed by human contact. 7. The aircraft known as “Patches”, which showed the highest levels of dioxin, had been transported to Wright-Patterson AFB, OH for display in a museum and had been transported with the spray booms and tank used for spraying. It is unclear how representative this aircraft is of C-123’s used by post-Vietnam flight crews (see point 9 below). In part, this concern derives from the nickname “Patches,” which is due to the exceptional number of bullet holes that the aircraft received. It is reasonable to assume that some of these punctures reached the herbicide tank or spray line. This likely resulted in a greater level of contamination from loss of Agent Orange. We also note that “Patches” was in service relatively early in the spray program and may have sprayed substantial volumes of the early, high dioxin herbicides like Agent Purple. This would also tend to increase contamination levels. 8. The three interior “Patches” samples showed a dioxin level of about 6.36 ng/100 cm2 or 636 ng/m2. The letter to Secretary Hickey would lead us to believe that this suggests a risk some 200 times the risk of the screening value. However, the comparison is inappropriate in that the assumptions underlying the screening level do not apply to the flight crews in the C-123s currently seeking compensation. Any exceedance above the screening level is not likely ever to have occurred for the C-123 flight crews after the Vietnam War. 9. Moreover, the concentrations are based on removals by solvent-soaked wipes, not human skin. The exposure period is much less than 250 days per year, 8 hours per day, for 10 years that the screening value assumes, and lastly, inherent in the screening level is the assumption that the office workers are actively moving through a large building with surface concentrations at the screening level. None of these assumptions apply to the flight crews. 10. Subsequent sampling of four C-123’s at Hill Air Force Base showed average contamination levels in dioxin TEQ in ng/m2 of 14.6 (9 samples), 18.2 (7 samples), 2 (7 samples), and 2.95 (9 samples). These are below the reentry screening level determined for “Patches,” and in two aircraft they are below the screening level derived for office workers in the 2009 Technical Guide. The letter to Secretary Hickey suggests that since these planes have not been used for herbicide spraying for almost 40 years, historical concentrations were likely higher. This may be true, but even if one were to assume historical concentrations were 10 fold higher, 2 of the four planes would be below the “Patches” reentry level, and the highest concentration plane would be 3.5 times less than the levels recorded for “Patches.” Thus, even if the levels in the past were higher as indicated, it does not establish a case for high risk from dioxin because the assumptions underlying the screening level are not met. 11. Finally, the C-123 has a cruising speed of 186 MPH. Given that C-123’s are not tightly sealed, the air exchange rates in a C-123 will be very high which would dilute any exposures from dusts or vapors to the point that inhalation exposures are practically impossible. Documents cited Hill Air Force Base, Utah Final Dioxin and Herbicide Characterization of UC-123K AircraftPhase I. July 2009. U.S. ARMY CENTER FOR HEALTH PROMOTION AND PREVENTIVE MEDICINE. Technical Guide 312. Health Risk Assessment Methods and Screening Levels for Evaluating Office Worker Exposures to Contaminants on Indoor Surfaces Using Surface Wipe Data. June 2009 C123 Characteristics: http://airheritage.org/our-aircraft/c-123k-provider/