DR. WAYNE DWERNYCHUK
OPINION: ON THE EXPOSURE TO
AGENT RANGE/DIOXIN RESIDUE IN C-123 AIRCRAFT
REGARDING: Major Wesley T. Carter (USAF)(note: opinion responds to VA Denial of Agent Orange Benefits to Carter, 25 Sept 2012)
I have reviewed Jeanne Stellman’s letter as well as that of Thomas Sinks (ATSDR), the two letters I have in my possession that support a highprobability of exposure to dioxin in C-123 aircraft. I have ‘absolutely’ noargument regarding the conclusions drawn by either Dr. Stellman or Dr. Sinks.I am in total agreement with their conclusions regarding the definite existenceof a potential for TCDD exposure to flight crews in the decommissioned C-123aircraft.
In the ‘denial’ letter from the US Department of Veterans Affairs (DVA), there isreference to two other letters of support issued by Drs. Berman and Goeppner... these I have not seen. However, with regard to each of the letters of supportsubmitted, apart from Dr. Sinks, the DVA states in their denial letter thatbecause those individuals presenting letters of support are not ‘medical’doctors, only ‘PH.Ds’., they are not qualified to make judgments regarding thedrawing of conclusions between a Veteran’s exposure and his/her disabilities. Iwould argue that medical doctors are not scientists who are experienced in thescientific method and knowledgeable with respect to intricate study design,implementation, analyses, and data interpretation. Scientists spendconsiderably more time examining details of exposure potential/logistics, forexample, than a medical doctor. The medical doctor examines the ‘end result’,the disability ... the manner in which the disability evolved, related to exposurelogistics, in concert with exposure mechanisms inherent to the particularcontaminant in question (e.g. cellular interaction of the contaminant), is notwithin the purview of a medical doctor’s training and/or experience.
In the denial letter, the DVA quotes highly supportive conclusions attributed toDrs. Stellman, Berman, and Goeppner. In each case, the scientific conclusionsof ...exposure in decommissioned C-123 aircraft were analogous to that of in-country Viet Nam Veterans (Stellman) ... the veteran may have been exposed toexcessive levels of dioxins (Berman) ... and that the denial of this claim was notscientifically accurate and credible (Goeppner), was rejected by the DVA on thebasis of a lack of connection between exposure and disability (because theseindividuals were Ph.Ds.). This conclusion, from my perspective, is totallywithout warrant. These individuals, through their respective vast experiences, understand the ramifications of historical and operational exposures to dioxinand what may culminate from such exposures.
Also in the DVA denial letter, reference is made to the conclusions of Dr. Sinks,these being that information is insufficient to determine if the exposure levelsto Veterans was low or high, or the actual risk of health complications due tothis exposure ... and ... that precise measurement of contaminantconcentration will not necessarily be predictive of negative healthconsequences). The DVA responded by stating that “... there is no conclusiveevidence that TCDD exposure causes adverse health effects”. This statement Ifind blatantly disingenuous. The DVA employs the ‘presumptive exposure’criteria in compensating US Viet Nam Veterans who had ‘boots on the ground’in Viet Nam. In the instances where compensation is provided, given that theVeteran has fulfilled all necessary criteria, there is no “ ... evidence that TCDDexposure causes adverse health effects” ... only presumption of exposure forthese Veterans, and the resulting health complication that may have ensued.
As Dr. Sinks states, the concentration of dioxin does not necessarily translateto ‘no effect’ at a low dose, or an automatic ‘effect’ at a high dose. Mammalianorganisms, including humans, may differ in their physiological responses tovarious levels of a contaminant. Different people may respond differently tospecific contaminant levels with varying time frames, such that more time maybe necessary before a health effect is expressed following exposure. Given thatactual experimentation on humans has not been undertaken to scientificallydocument, over time, exposure and expression of health effects in a controlledexperimental design/environment, only surrogate data are used to drawscientific conclusions. On this basis, latitude is normally given to suchconclusions which inherently accommodate unavoidable scientific error.
The DVA concludes with a summation of Major Carter’s application by stating:
“The Veteran did not serve in Vietnam and has not served in any other area thatwould allow for presumption of Agent Orange exposure or direct occupationalexposure to be accepted. Medical studies showed that it was unlikely the humanbody was able to absorb any dioxins from residual Agent Orange on aircraftsurfaces, or that any exposure would lead to adverse health effects.”Therejection of presumptive Agent Orange exposure in the C-123 aircraft, I feel, iswithout warrant. As Dr. Sinks stated, there is a lack of specific data on therelative levels of exposure in the aircraft and that an actual prediction of health complication may not be possible even with precise data, this, of course,governed by the variability in physiological functions in those exposed. In thesecond statement reference is made by the DVA that it was ‘unlikely’ dioxinswere absorbed by the Veterans or that exposure would culminate in healtheffects. Given that no direct studies on human contamination were done in atimely fashion over the course of C-123 use, and dioxins were, in fact, presentin these aircraft, I find it inconceivable that credence is not given to thecircumstance of sufficient exposure contributing to health repercussions as likely to as not.
A US DVA document states “There is a low probability that TCDDpenetrated through the skin of these aircrew.” (Scientific Review of AgentOrange in C-123 Aircraft). Low probability or not, there was some probability... no directed studies were done to actually determine the ‘level of probability’that did exist at the time of aircraft use. In addition, as Dr. Sinks indicated,even a precise measurement of dioxin may not enable a predictive scenario ofnegative health results. Given the many unanswered scientific questionsregarding the mechanisms related to dioxin exposure and specific healthconsequences, and the lack of corroborating in-situ exposure data from actualaircraft while in use, it would seem most reasonable and logical to accept the‘as likely as not’ phrase (related to whether or not exposure occurred) toultimately provide suffering Veterans with compensation related to their serviceand, in my mind, unquestionable exposure.
Dr. Berman summed the situation up succinctly by stating “... it is my opinionthat the personnel assigned to the C-123K Provider, particularly the mostexperienced crew, were more likely as not to have been exposed to excessivelevels of dioxins.” The operative phrase is more likely as not to have beenexposed. This summation is the crux of the matter and should be accepted bythe DVA ... this in conjunction with the undetermined levels of dioxin that mayhave entered a given Veteran’s body from the environment of the C-123aircraft, and the uncertainty of what specific levels of the contaminant wouldactually precipitate a given health consequence.
It is clear to me that the US DVA should re-assess their position on MajorCarter’s application, and perhaps others who are in similar circumstances.
I attach here my CV for your files.
Yours sincerely,
Dr. Wayne Dwernychuk
(October 3, 2012)
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