This Part II - The Report lays out more details regarding questionable connections between the Institute of Medicine (IOM) release of the Veterans and Ageng Orange: Update 2006 and the Haas vs. Nicholson Court Case now in front of the U.S. Court of Appeals for the Federal Circuit.

The premise is there is no coincidence that the legal arguments of the DVA in Haas vs. Nicholson (which are extremely weak) and the release of the Veterans and Agent Orange: Update 2006 (which excludes important data available to them) mutually support one another entirely. The DVA legal argument is semantic manipulation that is meaningless without the backing of the IOM. The IOM report can only be supportive of the DVA legal arguments if it totally ignores obvious and existing scientific and medical data. Without one, the other fails utterly. If approached as mutually groundless, they may both fall together.

PART II - The Report

A Critical Review of the Agent Orange Update: 2006 and its relationship to the Haas v. Nicholson court case.

There are several potential problems that have come up regarding a possible connection between the VA Brief of July 20, 2007 filed for Haas v. Nicholson and the Veteran and Agent Orange: Update 2006, released by the Institute of Medicine on July 27, 2007. This connection fits together hand in glove too smoothly.

There is currently (September, 2007) a Federal Court case (Haas v. Nicholson) regarding exposure to herbicides of offshore Navy, Marine, Coast Guard, and Air Force personnel who served in the Vietnam War. This group or class of veterans has come to be referred to as Blue Water Sailors, or the Blue Water Navy. It is no accident that certain information present or missing from the Veterans and Agent Orange Update: 2006 is exactly what is needed by the VA attorneys who are involved in the current litigation. Is it possible there was collusion or illegal influence from the VA over the authors of the Update 2006 document?

Who writes the Agent Orange Updates?
From 1962 to 1971, the US military sprayed herbicides throughout Vietnam for several reasons, right or wrong: to reduce the thick jungle canopy that concealed opposition forces; to destroy crops that those forces depended on; and to clear tall grasses and bushes from the perimeters of US base camps, air fields, outlying fire-support bases, and inland waterways.

Because of continuing uncertainty about the long-term health effects of the sprayed herbicides on Vietnam veterans, Congress passed the Agent Orange Act of 1991 (PL 102-4). The legislation requires the Institute of Medicine of the National Academy of Sciences (NAS) to provide the Secretary of Veterans Affairs with a comprehensive evaluation of all available and relevant scientific and medical information regarding the health effects of exposure to Agent Orange and other herbicides used in Vietnam. Mandated updates to the original study were to be conducted every 2 years for 10 years. (This time frame was extended to October 1, 2014 by Public Law 107-103) Veterans and Agent Orange, Update 2006 is the seventh report in this series.

As described on the IOM's own web site :

In accordance with PL 102-4 and PL 107-103, the Committee to Review the Health Effects in Vietnam Veterans of Exposure to Herbicides was asked to “determine (to the extent that available scientific data permit meaningful determinations)” the following regarding associations between specific health outcomes and exposure to TCDD and other chemicals in herbicides:

A) whether a statistical association with herbicide exposure exists, taking into account the strength of the scientific evidence and the appropriateness of the statistical and epidemiological methods used to detect the association; B) the increased risk of disease among those exposed to herbicides during service in the Republic of Vietnam during the Vietnam era; and C) whether there exists a plausible biological mechanism or other evidence of a causal relationship between herbicide exposure and the disease.

The committee notes that both its congressional mandate and its statement of task are phrased in such a way that the target of evaluation is “association,” not “causality,” between exposure and health outcomes. As used technically, the criteria for causation are somewhat more stringent than those for association. This target was not the choice of VAO committees but the consequence of congressional and judicial history.

Congress knew that the Secretary of Veterans Affairs would not have the time, training or expertise to do the required scientific and medical analysis to make decisions related to compensation for Agent Orange illnesses that had begun showing up in the Vietnam veteran community. In the mandate for the IOM to produce these reports, Congress specified that they are to evaluate all available scientific and medical information, and to report this in the Updates. They are not to make policy statements or tell the VA what to do regarding matters of claims adjudication or assignment of compensation. They are to do only medical and scientific data gathering and analysis. Their focus is on science and medicine, not on VA policy. They are to let the VA do as it will with the data.

In their Brief, the DVA counsels to leave this evidence to the Secretary of Veterans Affairs to decide on. An incredibly knowledgeable Secretary of the VA could easily sift through such scientific and medical evidence for grains of truth. However, the near precognition of Congress to know that no Secretary of the VA would have expertise to accomplish this, and the fact that the now-current Secretary, James Nicholson, has absolutely no expertise to base any such sifting ability on, shows this to be poor counsel. The argument in the Brief then ends with an acknowledgment that things can change, but should be left as they are for now, which supports the contention that there is value to the VA in delay for the sake of delay.

One might, at this point, look closely at the defined task of the IOM. The job of evaluating the association between exposure and health outcomes does not do much for determining such issues as who was actually exposed to toxins and to what level the exposure and dosage was. We can assume that, because this was not the focus of the IOM, this was actually the underlying justification for establishing equal exposure to dioxin for every soldier who served in any part of Vietnam for any length of time. This is the grounds for the ubiquitous nature of the Agent Orange presumptive diseases.

When is data "Medical and Scientific?"
The Institute of Medicine, under the National Academy of Science, has exercised wide latitude in interpreting and following the mandate from Congress of Public Law 102-4. This has been obvious from the very first of their reports in January, 1994. For instance, a large percentage of the studies used in the first Report were animal studies, not human studies. Outcry from the veteran community ultimately brought about a change to that. The first Update the IOM Committee released also failed to mention any data from the Zumwalt Report which, again due to public and veteran outcry, was mentioned in the 1996 Update. It is also important to note that the Zumwalt Report was never "peer reviewed."

The control of the information found in the Agent Orange Updates tends to follow a pattern of 'we'll use it or ignore it, until someone complains loud enough.' In other words, 'We will write whatever suits the purpose of those we prepare the reports for.' In this case, it happened to be the Department of Veterans Affairs. All available medical and scientific aspects must be presented to them so they can make determinations related to compensation, designation of service connection, and so forth. But can the IOM choose not to present data that is relied on by international entities and governments, but very directly impacts the policies of their clients? We contend that withholding such information is actually a policy decision in and of itself, and not at all an option of the IOM in presenting data for the Agent Orange Updates. It deprives the VA, as well as the Vietnam veteran and the American public, of access to the data. The DVA seems quite happy about that, but the veteran community absolutely isn't. Congress should immediately launch a full investigation of this matter on behalf of the American public.

What's in the water?
Starting at least in December of 2002, with the release of a report titled "Examination of the Potential Exposure of Royal Australian Navy (RAN) Personnel to Polychlorinated Dibenzodioxins and Polychlorinated Dibenzofurans Via Drinking Water," and a report presented at an international Agent Orange conference in 2003 titled Co-Distillation of Agent Orange and Other Persistent Organic Pollutants in Evaporative Water Distillation, a very hot topic around many water coolers had been how one believed the IOM and DVA would respond to this new research. It literally shatters the party line the DVA and IOM have been spewing for years. The first three studies from a series of four in-depth Australian Vietnam Veterans Mortality and Cancer Incidence Studies, show dioxin exposure rates of sea going personnel at levels higher than many of the troops on the ground during the Vietnam War, as previous CDC studies have shown. These reports were conducted by well established research institutes by well-credentialed researchers who looked into this obvious inequity. These documents can be reviewed at

Such high risk of exposure was mirrored by the water-borne sailors actually displaying a higher rate of disease consistent with dioxin poisoning than ground troops. Yet Australian, New Zealand, and U.S naval personnel were being denied any compensation for the disabilities and the medical expenses associated with the medical problems of dioxin poisoning. In contrast, ground troops with less exposure and a lower overall incidence of dioxin poisoning symptoms were receiving compensation for their Agent Orange diseases on a presumptive basis. The message these reports carried was about the evaporative water conversion systems which were identical to U.S., Australian and New Zealand ships. These studies show that the heating process used in transforming salt water to fresh water actually intensifies the concentration of dioxin caught within the filters and the storage tanks, making the fresh water supply used for drinking, cooking and showering even more lethal per unit that what it started out as.

In the Veteran and Agent Orange: Update 2006, there was no mention of any issue involving these "Blue Water Navy" Vietnam veterans, which is a class that includes Navy, Marine, Coast Guard, and Air Force personnel. There was no mention of dioxin found in the sea water. Nor was there any mention of dioxin in the waters within Vietnamese estuaries or along the coast which was frequented by naval supply and combat support vessels. Nor was there any mention that water treatment plants aboard ships had been found to both contain and intensify the presence of dioxin.

It is quite far-fetched to think that a review and report of these documents does not fall under the mandates of the IOM. It is equally far fetched to believe that these documents were available in the research world for such a short time that the IOM had not had a chance to become familiar with them. It is even more far fetched to believe that the government of both New Zealand and Australia would not be presently compensating their naval veterans based on these reports, if there were any reasonable doubt as to their validity. In the world of science and medicine, empirical evidence and practical application trumps academic concepts like peer review any day of the week.

As already implied, the types and kinds of documents the IOM considers important enough to review appear to rise and fall with the political interests of the day. In this instance, it would have been very inconvenient for the Department of Veterans Affairs to have the IOM address the issue of dioxin found offshore of Vietnam in the Update:2006 while the VA, who they essentially work for (or do work for) was in an important law suit challenging this exact topic. The suit has challenged the legitimacy and existence of water-borne dioxin ingestion capable of exposing water-borne personnel to the dangers of dioxin poisoning. In fact, this precise issue was addressed by the VA Brief filed July 20 with the U.S. Court of Appeals for the Federal Circuit.

The July 20 Brief is heavily skewed in that direction with the DVA attorneys fumbling with concepts like exposure, spray location, illness and others, and the Brief relies heavily upon the very information so glaringly missing from the IOM Report. We find this as no mere coincidence. Even though the relevant data was available for nearly four years before the Update: 2006 release, it is discounted because "it is not part of the record, [and] was not relied upon by the Secretary," according to the DVA Brief. That's typically what happens when data is not made available. It is not passed on and not referenced by follow-on reports. In plane language, it remains hidden. And if the IOM didn't help them understand the data, it appears the DVA believes it can ignore the results of the data. We're here to proclaim, "Not so!"

Trying to Sneak One Past
We already know the IOM is directed to keep its focus on "medical and scientific analysis" and not to stray into the field of VA policy. They have had since 1992 to get that distinction clearly made. No one would expect the IOM, after 14 years of practice and 6 prior Updates, to make, or even attempt to make, a statement addressing VA policy. And yet, that is exactly what happened, according to the Chairman of the Committee charged with writing the Update 2006. When asked why the committee did not include the obviously important medical and scientific studies done by the Australians, the Chairperson of the Committee provides this following eyebrow raising statement, among others, in an email after Update:2006 was released:

"You will be disappointed that there is no recommendation with respect to the "foot on the soil of Vietnam" issue, and we were quite disappointed also. Such a statement came very close to making it in[to the Update 2006], but the ruling from on high was that remarks of that sort exceeded the committee's charge by extending into VA policy issues."

The immediate tense of her statement implies that "the ruling" was a very specific ruling which occurred during the creation of the Update:2006 dealing with a very specific set of words, and was not just a blanket statement that actually reflects IOM policy as it has stood since its formation.

We take serious issue with that statement on several levels. How can the Chairperson of the committee responsible for the drafting and publication of a study "be disappointed" that something didn't appear in the report they wrote? She makes it sound as if the wording she had sent off to the printers was not the same wording that appeared in the finished copies of the final Report. Alternatively, it might reflect a scenario where the IOM committee, after attempting to sneak in a statement which violated its Congressional mandate, had to watch while an overseer with an eraser struck those words as the report was ready to go out the door. Who would ever expect the IOM committee to come up with a statement that "extended into VA policy issues?" They've had 14 years of practice in sticking to their mandate. Why would they attempt to break that rule now? That makes no sense whatsoever except as a weak cover story.

Nor does it make any sense that a "ruling from on high" kept such an unlikely statement out of the report. We don't even need to know what the statement was before we question the very attempt to extract any wording. Who rules "from on high" who would legitimately have access to the final draft of the committee report? And who has enough power to actually disappoint the Committee Chair that the committee's remarks, as unlikely as they might have been, were apparently edited out of their report? There's something very strange with what went on, and our efforts to understand what that was begins to indicate something resembling a cover-up. Could it have been the VA, the agency that the IOM committee produces its work for, that ruled "from on high"? It had to have been from some place higher than the position of the Chairman of the committee that wrote the report. How about the customer? How much higher can one go?

The Australian Studies and Other Research
But that still leaves open the question of why the Australian reports and other critical information regarding the "Blue Water Navy" problem of the presence of dioxin in the water offshore Vietnam does not appear in Upate:2006 as mere data without any editorial statements attached to it. Those details were not even mentioned in the IOM's Update: 2006. A normal assumption would be that the IOM as in previous Updates would continuously review the research released by medical and scientific Institution and labs and stand ready to put their full attention to any work that meets the mandate. The data would be given and perhaps some comments regarding its medical and scientific basis might be made. In fact, nothing could be further from the truth.

Despite the fact that the RAN Study and the Co-Distillation Study have been available for the Institute of Medicine to review, retest, or otherwise substantiate for at least four years, they essentially said, 'It's not up to us to validate this data. So we won't acknowledge its existence until it is handed to us on a silver platter.' It's a bit of an uppity attitude, but how many times has that occurred when the IOM has searched through the numerous reports and studies that have come out over the past 14 years? If it happened this once, how can we be sure it didn't happen previously? We contend that behavior of this sort runs the risk of denuding the IOM of any scientific integrity whatsoever. Even then, I would expect them, as good scientists, to have the data verified anyway, even if by third party.

What was there to gain by excluding this important data? To this point, it appears fairly obvious. They can support the delay and other games wherein the DVA is protecting the U.S. Chemical Industry, and they can stand silently by to allow the DVA to proclaim it has no knowledge of this information "to rely on." Although there is a minor concession given to the existence of Australian reports, it is focused on the types of cancers seen rather than a scientific analysis of the full data set itself. There was a severe failure of the system at this point. We're led back to this assumption by the Congressional mandate and the clearly stated requirement of the IOM to provide comprehensive evaluation of scientific and medical information: Comprehensive for all data, not only the ones that its customer finds acceptable.

In addition to ignoring good data, we also find the IOM Update: 2006 still using the highly discredited Ranch Hand Study as a reference. This controversial study is reported to be flawed to the core by admissions of key researchers who actually worked on that study. Numbers and results were changed. The entire report is suspect. The raw data contains just enough validity to make the VA want to discontinue the study and destroy the evidence. Why does the IOM continue to refer to that study? The answer is simple. It may be false data, but it serves the purpose of suppressing more correct data which supports the policy of the DVA (even though the IOM is by mandate not allowed to consider the policy side of the DVA). There is simply too much evidence to ignore that a concerted effort is underway to limit public knowledge of the real scientific findings from that Agent Orange research. Use of the Air Force Ranch Hand Study, after an admission of fraud in the research data and in the core of the methodology used to create it by the scientists who put that Report together is inexcusable. Referring to that as a source document at this date is absurd.

IOM Committee Chair Dr. Mary Paxton acknowledged in a telephone conversation that the Royal Australian Navy (RAN) Report as well as several other Australian reports were reviewed during the evaluation of material for inclusion in the Agent Orange update. The data was in front of them. But Dr. Paxton says these scientific studies still needed to be "peer reviewed" before the Committee could incorporate them into their conclusions. She had previously mentioned this to me in an email communiqué back in February, 2006, yet the IOM has apparently made no attempt to further verify what that study data shows. Once again, we encounter the 'silver platter' requirement. Only a portion of data used in the Veterans and Agent Orange Updates has ever been "peer reviewed."

These Australian studies represent detailed, highly scientific documents that very objectively conclude that the presumption of exposure to Agent Orange and other dioxins during the Vietnam War needs to be given to water-borne military personnel - in some cases, even more so than presumption given to land based military personnel. They represent well documented, reproducible studies concluding that military personnel who served in waters offshore from Vietnam exhibited disease entirely consistent with contamination by dioxin and showing a means for that contamination to have traveled.

Peer Reviewed
Peer Review is an interesting but rarely mystical process. Each institution may have its own precise definition as to what "peer review" actually is, but they all have very similar components and follow similar procedures. The IOM is very clear in their definition of peer review and posts it for all to see on the NAS/IOM website. It appears to contain a lot of "formal show" (aka fluff), a great way to cover their tails, and a good way to delay anything that needs it. A system like this has several denial and acceptance points, and upon re-examination of an outcome, they're not all that easy to spot.

One way this system can be summarized is: they are essentially indicating that they can independently pass judgment on their own work, but the work of others is held to a "higher standard". That might stem from either not having the in-house expertise to deal with complicated issues, or might show the need to have some outside agency to do this kind of work because they are too busy reviewing and giving peer review status to their own reports.

The IOM web site clearly sets out how the Peer Review process is accomplished for reports generated in-house. If an IOM Committee creates a report, there is a very unambiguous path for obtaining "peer review" status. It merely calls for the right people to read the document and come to some agreement as to its probable validity. It rests on the non-esoteric principle of scientific method: data is data, regardless of whether it supports or refutes your customer's policy.

Peer review is highly structured and proceeds according to the policies of IOM and the National Research Council (NRC) through the Report Review Committees (RRC). Formal reviewer slates are discussed before the IOM leadership group and submitted for approval to the NRC RRC. Reviews are solicited by the RRC or the IOM equivalent office, not by the study staff. Reviews are provided to the study staff by the review office and are blinded. The study staff must respond to each review - either making the change if appropriate or providing a rationale for not doing so. Each review has a coordinator who must be satisfied and certify that the study staff has done so. In addition, in many cases the NRC RRC appoints a monitor, whose job is to certify that the NRC process of peer review has taken place adequately.

Every two years, when IOM committee members create a report for their client,( the Department of Veterans Affairs), that report must be peer reviewed through a series of the Report Review Committees. This review procedure is given to internal documents before they are released to the public, and hopefully to their client as a valuation of their work. And they claim here to have the perrsonnel (mostly comprised of outside volunteers) expertise to do this.

Any of the reports that IOM creates must be evidence-based and when not possible then noted as expert opinion. When replication is not possible, there is a provision where the IOM can review the written conclusion of experiments by a panel of experts, who can wield the "Peer Reviewed" stamp when all things make sense - without the empirical evidence of retesting. At least, that's what can happen to their own papers. We've recently seen major instances where this was not extended to external source papers. During our searches, we did not find direct reference to the treatment of external reports. It may be there, but we haven't found it yet.

The IOM can perform a peer review on a report when they aren't able to actually duplicate the experiment. This type of peer review is based solely on a detailed review and analysis of the "concepts" done by their own experts in that field. The RAN report had been around for almost 5 years, so they can't say that the issues were so new they couldn't respond to them in time, as indicated by the VA Brief of July 20th. We submit that those reports could have been peer reviewed within the process of the IOM Review committees. That is how they would have handled their own material and the research and documentation internally. They simply chose not to do that.

The missing peer review status excuse is untenable, even assuming the IOM really requires it and couldn't get the process completed in house or elsewhere in time for the 2006 update. The IOM use of that lame excuse indicates two possibilities, which might include an extremely bloated arrogance of the American research community (or just the IOM), and/or ignorance of those who design and oversee reviewed studies at other institutions. If all the other data sources used by the IOM since 1994 would have required a peer reviewed status, there would scarcely have been any pages to the Agent Orange Updates to this point in time. That's why all indications point to other reasons for withholding this information.

Words, Meanings, and Court Room Semantics
When discussing things like toxins and their interaction with living things, especially leading to a disability, a very precise set of terms and definitions is typically used. Some of those terms might include:

But not even the IOM reports present things in such a precise manner, unlike some other scientific and medical review procedures. The pronouncements of the IOM on matters related to data for the VA to use are very quantitatively imprecise, leaving the "administration" of their findings to a great level of ambiguity. For an agency like the Department of Veterans Affairs, this works quite well, as the DVA passes on to the Regional Offices that ambiguity in their instructions for rulings of veteran compensation. This seems to be the major factor in the colossal backlog of unadjudicated claims veterans are now facing.

There are precise sets of words that define various stages of the toxin and animal interaction, as referred to by the DVA in the Haas v. Nicholson case. The DVA fumbled badly in its presentation of location of service, area of herbicide use, and exposure to the contaminant. They need to understand that people who served in areas where herbicides were used may not have been exposed while others outside that area might have been exposed. These terms and concepts have been thrown around rather loosely, so here are some definitions to help create a shared understanding of the semantics.

Location is a defined physical area. It is used to identify an area where toxins exists or might exist or were intended to exist. In an analysis of toxic exposure or contamination, location might be a rough starting point, but in itself has little or no relationship to where the toxin ultimately winds up and therefore does not address who is exposed or what is contaminated. Location as used in the July 20 DVA Brief is absolutely devoid of any relationship to dioxin illness, which should be the focus of the case. Specifically, there is a man, Jonathan Haas, who is displaying symptoms of dioxin poisoning.

Contamination deals with the media which a toxin gets into, such as air, mist, water, food, soil, clothing, and such. When the biological system (Jonathan Haas) comes in contact with the contaminated agent (air, mist, water), he receives some dose of the toxic agent, depending on the length of exposure, the amount of contaminant absorbed or ingested, the number of times the exposure occurs, etc.

In the case of Jonathan Haas, not only was he exposed at the time he visually saw the spray mist he reports, but very probably hundreds of additional times for extended periods when he came into contact with contaminated agents he encountered which were not visible. His exposures occurred whenever a contaminated agent entered his system, by ingestion, inhalation, skin absorption, etc.

His illness occurred as a result of how his body reacted to the toxin. Illness can be very subtle and can work very slowly or even lay dormant at an undetectable level for many years before any clinically detectable symptoms appear. That seems to be the way dioxin works. As the illness progresses, the body can become disabled with diseases like diabetes, any of the acknowledged "presumptive diseases" plus many others.

There is a well-defined series of steps that occur before a body presents itself for treatment of any specific disease:

What is missing from this sequence is often an entirely unknown or unpredictable factor: Identifiable locations where the contaminated media move over time. When a toxin is released, it can be carried to many different physical locations. In the case of Agent Orange spray applications, it most certainly was. The location of the release point is just one of many locations where exposure can occur and may not be, and often isn't the location where actual exposure occurs. The VA argument wants to put location in the category of definable steps in the progression of contamination, when in fact it is the least known variable in the sequence.

Additionally, most dioxin-related damage occurs long after exposure. These factors make "proving" dioxin caused the damage difficult. However, the U.S. government has little incentive to correctly identify dioxin releases as the cause of any disease because they and the entire American Chemical Industry they have sworn to protect from liability then become responsible to those servicemen who have been harmed. None of this absolves the government of ethical and appropriate public health actions that include acknowledging that dioxin moves through the environment, via contaminated air, water, soil, and other media leading to the exposures of many servicemen in locations far from the intended spray targets.

The VA, as indicated by their July 20 Brief, is suddenly hung up on definitions and distinctions between "exposure" and "being in the [geographical] location of an Agent Orange spray area." It appears that they believe the semantic games of the courtroom can show how to override reality. In doing so, they create the appearance of Agent Orange application following very straight, linear boundaries on the ground directly beneath the plane that sprayed it. They present a singular scenario where applications strictly adhered to the lines drawn on a map to show where each droplet from every mission landed. They mistakenly and naively conclude that being in a spray area always results in exposure, and being outside a spray area never results in exposure. Mother Nature and the Laws of Physics, to say nothing of common sense, just happen to clearly show otherwise. This process can be a very complicated chain of events.

Let's get more precise here. Let's define Vietnam veteran exposure as "being subjected to the conditions for actual or possible contamination by a lethal chemical." So, military personnel who were exposed were "subjected to the conditions for actual or possible contamination by a lethal chemical." That says nothing about their physical location. They could have been exposed because they were standing directly under the planes that released the chemical; or they could have been exposed because the wind shifted and spray mist drifted 10's or 100's of kilometers from the target site. Or they could have been exposed because they drank from a contaminated stream when the monsoons washed chemically laden particulate residue into the stream water, but out of and away from the direct path of the spray pattern. This scenario of wide and unknown dispersion is logical, and this is a good reason why the entire contingent of land-based personnel is given the presumption of exposure to Agent Orange. There's just no way to tell who was exposed to Agent Orange at what degree, and that is the basis of the use of presumption. But it is not logical to assume the wind and water were not contaminated and did not leave the initial location of application.

Now we follow the stream water for a minute. It led into a river. There were military personnel on the river. Even though they were far from an actual geographical spray area, they still could have been exposed to Agent Orange, most probably by the water, but by many other means as well. If they drank the river water, even if they tried to filter it, they were "exposed" to Agent Orange. In the minds of the representatives of the Veterans Administration, any water-borne Agent Orange magically stopped as soon as that water flowed past the last bit of continental land mass. They say that ships, even within tens or hundreds of feet of where the water entered into the South China Sea, were not exposed because they weren't subjected to actual or possible contamination by a lethal chemical. This is not so. Organisms that were not located directly in the path of a spray area had at least as likely a chance of exposure as those out of the spray area. It is quite a simple matter to show good reason for the high probability of this scenario once a few basic definitions are understood.

There is verified evidence that the process of co-distillation, which converts sea water into fresh water, captures and augments dioxin, and allows it to enter into the fresh water system aboard ships. The data are there. The handling of the data, which requires timely review without external influence by the Department of Veterans Affairs, does not appear to be.

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