STATEMENT OF JAMES BINNS
FORMER CHAIRMAN, RESEARCH ADVISORY COMMITTEE ON
GULF WAR VETERANS ILLNESSES
U.S. HOUSE OF REPRESENTATIVES COMMITTEE ON
VETERANS AFFAIRS
SUBCOMMITTEE ON OVERSIGHT AND INVESTIGATIONS
PERSIAN GULF WAR: AN ASSESSMENT OF HEALTH
OUTCOMES ON THE 25TH ANNIVERSARY
FEBRUARY 23, 2016
With respect to Gulf War veterans’ health, VA
pays no more attention to Congress than it does to science. As described below, Congress has ordered
report after report from the Institute of Medicine (IOM), specifying in law the
work to be done. However, VA has
consistently failed to contract for what Congress actually ordered. The IOM has been a willing accomplice,
changing its own standards of evidence and appointing biased committees to
accommodate VA’s purposes. As a result,
the reports inevitably produce conclusions that deny any connection between
toxic exposures and the shattered health of Gulf War veterans, and promote the
discredited 1990’s VA position that their illness is largely psychiatric.
These same corrupt practices have been employed
to deny the effect of toxic exposures from burn pits on the health of recent
Iraq and Afghanistan veterans.
1.
Public Laws 105-277 and 105-368, enacted in 1998, are the foundation for
the IOM Gulf War and Health reports.
Congress required VA to contract with the IOM to evaluate the health
risks of thirty-three toxic substances and medications to which troops were
exposed in the war. The law required
consideration of animal studies because most studies of the effects of toxic
substances are necessarily done in animals.
But VA did not contract for consideration of
animal studies, and the IOM actually changed its standards of evidence to
exclude animal studies – the exact opposite of what Congress ordered. As a result, these studies – the basic studies that show these
toxic substances are toxic -- have never been considered in any IOM report, and
no IOM report has ever found sufficient evidence that any of the thirty-three
toxic agents are associated with health problems.
The entire IOM Gulf War series of reports is a
house of cards, as detailed in Appendix A.
These same corrupt practices have been employed
to deny the effect of toxic exposures from burn pits on the health of recent
Iraq and Afghanistan veterans. (below,
pp. 12-13)
2. In
2010, in Public Law 111-275, Congress required VA to contract with the IOM for
a “comprehensive review of the best treatments for chronic multisymptom illness
in Gulf War veterans.”
The statute directed that the IOM “shall convene a group of medical
professionals who are experienced in treating [Gulf War veterans] who have been
diagnosed with chronic multisymptom illness or another health condition related
to chemical and environmental exposures . . .”[1]
VA ignored this direction and instead
contracted with the IOM for a literature review of largely psychiatric diseases
by a committee with no experience in treating Gulf War veterans, heavily
weighted with specialists in psychosomatic medicine and stress.[2]
Rather than capturing the valuable treatment experience of Gulf War veterans’
doctors, as Congress intended, the resulting 2013 IOM treatment report was a
restatement of government fictions from the 1990’s, foreshadowing the 2016 IOM
report and the new VA/DoD Clinical Practice Guideline.
3. In
2008, Congress enacted Public Law 110-389 requiring VA to contract with the IOM
“to conduct a comprehensive epidemiological study … [to] identify the incidence
and prevalence of diagnosed neurological diseases, including multiple
sclerosis, Parkinson’s disease, and brain cancers . . .” in 1991 Gulf War
veterans, Post-9/11 Global Operations veterans, and non-deployed comparison
groups.[3]
For seven years, VA refused to contract for the
study, despite repeated urging by the Research Advisory Committee on Gulf War
Veterans Illnesses.[4] In 2015, VA finally contracted with the IOM,
but wrote in the contract that the IOM could only use VA data. The IOM committee declined to proceed with
the study because the VA data was insufficient for a rigorous study.[5]
In the absence of the study ordered by Congress
in 2008, the 2016 report found the evidence insufficient to reach conclusions that
these conditions are associated with Gulf War service.[6]
4. The
membership of IOM Gulf War report committees has usually been biased toward
VA’s discredited position, including the 2016 committee.
See the November 2014 letter to Dr. Victor
Dzau, president of the IOM, attached as Appendix B below (pp. 37-42), objecting
to the makeup of the 2016 Gulf War and Health committee. “[T]he membership is
grossly imbalanced toward the 1990’s government position that Gulf War veterans
have no special health problem — just what happens after every war, related to
psychiatric issues, and not environmental exposures.”
The letter documented that eight the members of
the committee were associated with the 1990’s government position, including
the former 1990’s VA Undersecretary for Health, Dr. Kenneth Kizer, who was the
chief advocate for the position. Eight members were neutral. Subsequent to the letter, one neutral member
resigned and one individual with
current Gulf War research experience was added,
the only person on the committee with such experience.
The last two pages of the letter analyze the
2016 committee membership. (below, pp.
45-46)
The letter predicted that: “Reviving this
discredited fiction will cause veterans’ doctors to prescribe inappropriate
psychiatric medications, and will misdirect research to find effective
treatments down blind alleys — an unconscionable breach of the duty owed to
veterans and expected of the Institute of Medicine. “
Appendix A
VA and IOM Collaboration To Exclude
Consideration Of Animal Studies
Required By Law
Public Laws 105-277 and 105-368 are the
foundation for the Institute of Medicine (IOM) Gulf War and Health
reports. Congress required VA to
contract with the IOM to evaluate the health risks of thirty-three toxic
substances and medications to which troops were exposed in the war. The law required consideration of animal
studies on a par with human studies because most studies of toxic substances
are necessarily done in animals for ethical reasons.
But VA did not contract for
consideration of animal studies, and the IOM actually changed its standards of
evidence to exclude animal studies – the exact opposite of what Congress
ordered. As a result, these studies –
the basic studies that show these toxic substances are toxic -- have never been
considered in any IOM report, and no IOM report has ever found sufficient
evidence that any of the thirty-three listed toxic agents are associated with
health problems.
Consider, for example, the
twenty-three animal studies on pages 160-161 of the 2008 report of the Research
Advisory Committee on Gulf War Veterans Illnesses, showing that low levels of
nerve gas, below the level that causes symptoms at the time of exposure, cause
long-term adverse health effects, contrary to what was believed at the time of the
war. Because of these studies, an update
report on the effects of sarin was ordered from the IOM, but as described
below, VA and IOM staff conspired to ensure that the report would not consider
animal studies in its conclusions, even though new animal studies were the only
reason for ordering the report.
http://www.va.gov/RAC-GWVI/docs/Committee_Documents/GWIandHealthofGWVeterans_RAC-GWVIReport_2008.pdf
The entire IOM Gulf War
series of reports is a house of cards, as detailed below.
These same corrupt practices have been employed
to deny the effect of toxic exposures from burn pits on the health of recent
Iraq and Afghanistan veterans. (below,
pp. 12-13)
* *
*
These 1998 statutes required
the IOM to identify illnesses experienced by Armed Forces members who served in
the war, “including diagnosed illnesses and undiagnosed illnesses” (the term
then used for what is now called “Gulf War Illness”). The statutes then asked, for each of the
thirty-three agents and each illness, “whether a statistical association exists
between exposure to an agent . . . and an increased risk of illness in human or
animal populations.”
Congress required
consideration of studies in animals because most studies of toxic substances
and drugs are necessarily done in animals for ethical reasons. It did not ask for information on how much of
an agent Gulf War troops were exposed to.
It was well known that no such information exists.
These basic animal studies
have never been considered in any IOM report.
The 2016 report discusses some animal studies involving exposures to
combinations of agents, but it acknowledges that “studies examining single
exposures are not considered here” because “[e]arly volumes of the Gulf War and
Health series described animal studies . . . on the association between
exposure to a single toxicant and the health outcomes that may result. . .”
2016 IOM Gulf War and Health
report, Vol. 10, p. 239
But the earlier IOM reports
make clear they did not consider these animal studies in their conclusions. The chairman of the 2016 committee, Dr.
Deborah Cory-Slechta, was a member of the committee for the 2003 IOM Gulf War
report on Insecticides and Solvents, so she is familiar with the procedures
used. While the 2003 report “described”
numerous animal studies, it admitted that “animal studies had a limited role in
the committee’s assessment between exposure and a health outcome. Animal data . . . were not used as part of
the weight-of-evidence . . .”
2003 IOM Gulf War and Health
report, Vol. 2, p. 3
The same admission can be
found in every IOM Gulf War report on the health effects of toxic
substances. Thus, the 2016 report did
not consider these basic animal studies in their conclusions, relying on the
earlier reports, but the earlier reports didn’t consider them either. As a result, since most studies of toxic
exposures are done in animals, no IOM report has ever found sufficient evidence
that any of the thirty-three listed toxic exposures and medications are
associated with adverse health outcomes.
The whole IOM Gulf War series
of reports is a house of cards.
In her preface to the 2016
report, Dr. Cory-Slechta points to the “ever unknowable impact of the various
chemical exposures that occurred. . .”,
because “[o]bjective exposure data gathered during and after the war
have been, and are expected to continue to be, unavailable.” 2016 IOM Gulf War and Health report,
Vol. 10, p. ix
But Congress never asked for
consideration of exposure data. It was well known that data did not exist. What it did ask for was consideration of
animal data. But it has never gotten
it. It has never gotten it because VA
did not contract for the reports that Congress ordered.
The IOM has been a willing
collaborator in this deceit, changing its own standards of evidence to exclude
animal studies – exactly the opposite action from what the law required.
It made this change quietly,
and has deceitfully implied that nothing changed. As presented in the 2003 report, “[t]he
committee used the [standards of evidence] from previous IOM studies because
they have gained wide acceptance over more than a decade by Congress,
government agencies, researchers, and veterans groups.” “The [standards of
evidence] closely resemble those used by . . . IOM committees that have evaluated
. . . herbicides used in Vietnam.” 2003
IOM Gulf War and Health report, Vol. 2, p. 3
(See the similar language on
p. 3 of the 2016 report.)
In fact, however, the
standards were subtly changed from the Agent Orange standards to exclude
consideration of animal studies. Animal
studies are discussed in the Gulf War reports, but when it comes to arriving at
the reports’ conclusions, they are not considered, applying the doctored
standards of evidence (what the IOM calls the “categories of association”).
For sixteen years, VA, DoD,
and IOM staff have manipulated IOM Gulf War reports on the health effects of
veterans’ toxic exposures. As a result,
the reports have consistently found “insufficient evidence” that the exposures
are associated with illness, leading to VA determinations that the illness does
not qualify for benefits as service-connected.
Of equal importance, these dishonest reports have also misled
researchers seeking to understand the causes of Gulf War illness in order to
identify treatments to improve veterans’ health and preventive measures to
protect future US forces.
In recent years, the same
techniques have been applied to IOM reports on the health effects of toxic
substances released by burn pits on recent Iraq and Afghanistan veterans.
The balance of this Appendix
will review in detail these corrupt practices.
1. The governing statute expressly requires
consideration of animal studies.
In PL 105-277 and PL 105-368,
Congress in 1998 directed the Department of Veterans Affairs to contract with
the National Academy of Sciences (NAS, the parent organization of the Institute
of Medicine, IOM), to review the scientific literature regarding substances to
which troops were exposed in the 1991 Gulf War to determine if these substances
are associated with an increased risk of illness. These reports were to be used by the
Secretary of Veterans Affairs in determining whether the illness should be
presumed service-connected for the purpose of veterans’ benefits.
The law directed the NAS
(IOM) to identify the “biological, chemical, or other toxic agents,
environmental or wartime hazards, or preventive medicines or vaccines” to which
members of the Armed Forces may have been exposed during the war. 38 USC Sec. 1117, note Sec. 1603 (c). [attached to this Appendix below at p. 14] The law listed thirty-three specific “toxic
agents, environmental or wartime hazards, or preventive medicines or vaccines
associated with Gulf War service” to be considered, including various
pesticides; pyridostigmine bromide, a drug used as a nerve agent prophylaxis;
low-level nerve agents; other chemicals, metals, sources of radiation; and
infectious diseases. 38 USC Sec. 1117,
note Sec. 1603 (a), (d). [below, pp. 15-16] The law further required the NAS (IOM) to
identify illnesses, “including diagnosed illnesses and undiagnosed illnesses,”
experienced by Armed Forces members who served in the war. 38 USC Sec. 1117, note Sec. 1603 (c) [below, p. 14]
“For each agent, hazard, or
medicine or vaccine and illness identified,” the law provided that:
“The National Academy of
Sciences shall determine …
(A) whether a statistical
association exists between exposure to the agent … and the illness . . .
(B) the increased risk of the
illness among human or animal populations
exposed to the agent … and
(C) whether a plausible
biological mechanism or other evidence of a causal relationship exists …”
38 USC Sec. 1117, note Sec.
1603 (e) [below, p. 16, emphasis added]
The statute went on to
provide that the Secretary of Veterans Affairs should consider both human and
animal studies in determining whether a presumption of service connection is
warranted. He was to consider “the
exposure in humans or animals” to an agent and “the occurrence of a diagnosed
or undiagnosed illness in humans or animals.”
38 USC Sec. 1118
(b)(1)(B) [below, p. 21, emphasis
added]
Congress thus expressly
required consideration of animal as well as human studies by both the National
Academy of Sciences (the Institute of Medicine) and the Secretary of Veterans
Affairs. This statutory requirement
reflects the fact that most studies on the biological effects of hazardous
substances are necessarily done in animals, for ethical reasons. Consider, for example, the twenty-three studies
on the long-term effects of low level sarin exposure, or the eighteen studies
evaluating the combined effects of pyridostigmine bromide, pesticides and
insect repellant listed on pages 160-161 and 170-171 of the 2008 Research
Advisory Committee on Gulf War Veterans Illnesses report, all of which were
done in animals. http://www.va.gov/RAC-GWVI/docs/Committee_Documents/GWIandHealthofGWVeterans_RAC-GWVIReport_2008.pdf
When the first IOM report was
conducted under the law, however, animal studies were omitted from the standard
for determining whether an association exists between an exposure and a health
effect. The report states:
“For its evaluation and
categorization of the degree of association between each exposure and a human
health effect, however, the [IOM] committee only used evidence from human
studies.”
Gulf War and Health, Volume
1, (2000), p. 72 [below, p. 23]
Considering only human
studies, and not the much larger relevant literature on animal studies, the IOM
committees have never found sufficient evidence of an association for the
exposures and illnesses experienced by Gulf War veterans. Following the reports of the IOM, the
Secretary of Veterans Affairs has made no determinations of service-connection
for these exposures and illnesses for veterans’ benefits.
(VA asserts that it covers
Gulf War veterans on other grounds for their “undiagnosed illnesses,” but VA
statistics show that over 80% of such veterans’ claims are denied. http://www.scribd.com/doc/241661207/Binns-Parting-Thoughts-093014)
This pattern has been
followed in all IOM Gulf War reports to date.
More recently, it has been applied to IOM reports on the effects of toxic
exposures fromburn pits on the health of recent Iraq and Afghanistan veterans.
2. The exclusion of animal studies was
deliberate.
A close examination of what
occurred makes clear that the exclusion of animal studies was not an
oversight. It was deliberate.
To express conclusions as to
whether an association between an exposure and an illness exists, the first IOM
Gulf report defined five standards of evidence, which it called the “Categories
of Association.” Gulf War and Health,
Vol. 1, pp. 83-84. [below, pp. 25-26]
The same categories have been used in all subsequent IOM Gulf War exposure
reports:
- Sufficient Evidence of a Causal Relationship
- Sufficient Evidence of an Association
- Limited/Suggestive Evidence of an Association
- Inadequate/Insufficient Evidence to Determine
Whether an Association Does or Does Not Exist
- Limited/Suggestive Evidence of No
Association.
Each substance was ranked
according to these categories. How a
substance is ranked becomes the all-important conclusion of the report as to
whether an association exists between an exposure and illness.
Where did these categories
come from? The report explained: “The
committee used the established categories of association from previous IOM
studies, because they have gained wide acceptance for more than a decade by
Congress, government agencies, researchers, and veteran groups.” “The categories closely resemble those used by
several IOM committees that evaluated …. herbicides used in Vietnam …” Gulf War and Health, Volume I, p. 83. [below, p. 25]
IOM Gulf War reports have
repeatedly emphasized over the years that their methodology is based on the IOM
Agent Orange reports. However, it is
revealing to compare a category of association used in the Agent Orange reports
with the same category used in the Gulf War reports.
Agent Orange:
“Sufficient Evidence of an
Association. Evidence is sufficient to
conclude that there is a positive association.
That is, a positive association has been observed between herbicides and
the outcome in studies in which chance,
bias, and confounding could be ruled out …”
Veterans and Agent Orange:
1996 Update, p. 97 [below, p. 27,
emphasis added]
Gulf War:
“Sufficient Evidence of an
Association. Evidence is sufficient to
conclude that there is a positive association.
That is, a positive association has been observed between an exposure to
a specific agent and a health outcome in human
studies in which chance, bias, and confounding could be ruled out . . .”
Gulf War and Health: Volume
I, p. 83 [below, p. 25, emphasis added]
The Gulf War category does
indeed “closely resemble” the Agent Orange category -- with a conspicuous
exception. The word “human” has been
inserted in the Gulf War category. This
addition obviously did not occur by accident.
It was deliberate, as was the misleading language that these were the
“established categories of association from previous IOM reports.”
Thus, not only have the IOM
Gulf War studies been conducted in violation of the direction Congress provided
in the statute; this violation has been deliberate, with intent to conceal.
As to why it was done, one
can speculate based on the knowledge that the Agent Orange language, just a few
years earlier, had produced an IOM report that found that Agent Orange exposure
was associated with cancer (after two decades of government denial of any
health consequence). This finding led to
a presumption of service connection for thousands of Vietnam veterans with
cancer.
It should be noted that the
IOM Gulf War reports state that animal studies were considered for purposes of
“biological plausibility”: “For its evaluation and categorization of the degree
of association between each exposure and a human health effect, … the committee
only used evidence from human studies.
Nevertheless, the committee did use nonhuman studies as the basis for judgments
about biological plausibility, which is one of the criteria for establishing
causation.” Gulf War and Health, Volume
1, p. 72 [below, p. 25]
The terms of the Gulf War
categories of association make clear, however, that biological plausibility and
causation only relate to the highest category of evidence, “sufficient evidence
of a causal relationship,” and are not considered unless there has been a
previous finding of “sufficient evidence
of association”:
“Sufficient Evidence of a
Causal Relationship. Evidence is
sufficient to conclude that a causal relationship exists between the exposure
to a specific agent and a health outcome in humans. The evidence fills the criteria for
sufficient evidence of association (below) and satisfies several of the
criteria used to assess causality: strength of association, dose-response
relationship, consistency of association, temporal relationship, specificity of
association, and biological plausibility.”
“Sufficient Evidence of an
Association. Evidence is sufficient to conclude that there
is a positive association. That is, a
positive association has been observed between an exposure to a specific
agent and a health outcome in human studies in which chance, bias, and
confounding could be ruled out with reasonable confidence.” Gulf War and Health, Volume 1, p. 83. [below,
p. 25, emphasis added]
Thus, only if there has
already been a finding of “sufficient evidence of association” do the issues of
causality and biological plausibility arise, and a finding of “sufficient
evidence of association” depends solely on human studies. Unless an association is found based on human
studies, biological plausibility -- and animal studies -- are not considered.
It is notable that the
statute does not require evidence of a “casual relationship” to trigger a
presumption of service connection. It
only requires evidence of a “positive association”:
“[T]he Secretary shall
prescribe regulations providing
that a presumption of service
connection is warranted [if the Secretary makes a]
determination based on sound
medical and scientific evidence that a
positive association exists between--
(i) the exposure of humans or
animals to a biological, chemical,
or other toxic agent, environmental or
wartime hazard, or preventive
medicine or vaccine known or presumed to be
associated with service
in the Southwest Asia theater of operations
during the Persian Gulf
War; and
(ii) the occurrence of a diagnosed or
undiagnosed illness in
humans or animals.”
38 USC Sec. 1118 (b)(1) [emphasis added, below
pp. 20-21]
In short, in direct
contravention of the law, the methodology established for the IOM Gulf War
reports deliberately excluded animal studies from consideration as to whether
an association exists between an exposure and an illness, the only question
that matters in the determination of veterans’ benefits.
3. VA and IOM staff privately collaborated to
produce these results.
As to how this was done, the
history of one of the IOM Gulf War reports provides an indication. The 2004 IOM Updated Literature Review of
Sarin is the most egregious example of the distortion of science produced by excluding
animal studies from the evidence considered in these reports’ conclusions. In late 2002, a number of new studies on
sarin nerve gas, sponsored by the Department of Defense, revealed that contrary
to previous belief, low level exposures (below the level required to produce
symptoms at the time of exposure) produced long-term effects on the nervous and
immune systems. Naturally, these
studies were done in animals, not humans.
A previous IOM report on
sarin in 2000 had found insufficient evidence of an association between
low-level sarin and long-term health effects based on scientific knowledge as
of that date. On January 24, 2003,
then-VA Secretary Anthony Principi wrote the president of the Institute of
Medicine: “Recently, a number of new studies have been published on the effects
of Sarin on laboratory animals.” He
asked the IOM to report back “on whether this new research affects earlier
conclusions of IOM . . . about possible long-term health consequences of exposure to
low levels of Sarin.” [attached, p. 29]
In 2004, the IOM delivered
its report. The Updated Literature Review of Sarin discussed the new animal
studies in its text. However, true to
form, the report did not consider animal studies in the all-important
categories of association, even though the new animal studies were the only
reason for doing the report.
“As with previous committees,
this committee used animal data for making assessments of biological
plausibility … rather than as part of the weight of evidence to determine the
likelihood that an exposure to a specific agent might cause a long-term
outcome.” Updated Literature Review of
Sarin (2004), p. 18 [below, p. 30] Accordingly, the report found insufficient
evidence of an association.
To understand this bizarre
outcome, it is revealing that following Secretary Principi’s letter, an IOM
proposal was prepared which became the basis for a contract between the IOM and
VA.
The proposal for the sarin
update was sent to VA on March 11, 2003, with a cover letter from Susanne
Stoiber, executive director of the IOM, to Dr. Mark Brown, director of the VA
Environmental Agents Service, part of the Office of Public Health. The cover letter stated: “This proposal
follows a request from Secretary Anthony J. Principi and discussions with
yourself requesting an update of the health effects of the chemical warfare
agent sarin.” [below, p. 31]
The proposal contained the
following “Statement of Task”: [below, p. 34]
“The
committee will conduct a review of the peer-reviewed literature published since
earlier IOM reports on health effects associated with exposure to sarin and
related compounds. Relevant
epidemiologic studies will be considered.
With regard to the toxicological literature, the committee will
generally use review articles to present a broad overview of the toxicology of
sarin and to make assessments of biologic plausibility regarding the compound
of study and health effects; individual toxicology research papers will be
evaluated as warranted.
The
committee will make determinations on the strength of the evidence for
associations between sarin and human health effects. If published peer-reviewed information is
available on the dose of sarin exposure in Gulf War veterans, the committee may
address the potential health risks posed to the veterans . . . “
In other words, the Statement
of Task established that the update report would use the same “categories of
association” as the earlier Gulf War reports.
The “determinations on the strength of the evidence” would be made on
the basis of the “associations between sarin and human health
effects”. “With regard to the
toxicological literature” (which included the new animal studies), its use
would be confined to the assessment of “biological plausibility” to which
animal studies had previously been relegated.
Thus, the update report would exclude animal studies from its key
conclusions, even though animal studies were the only reason for doing the
report.
Moreover, the Statement of
Task set up another fundamental constraint for the report. The IOM committee would be permitted to
address the potential health risks posed to the veterans “[i]f published
peer-reviewed information is available on the dose of sarin exposure in Gulf
War veterans.” As anyone familiar with
Gulf War research would know, including Dr. Brown and his IOM counterparts,
there is no published peer-reviewed information available on the dose of sarin
exposure in Gulf War veterans, for the reason that no such information was
collected during the war. As noted in
the previous 2000 IOM report on sarin, “as discussed throughout this report,
there is a paucity of data regarding the actual agents and doses to which
individual veterans were exposed.” Gulf
War and Health, Volume 1, p. 84. [below,
p. 26] In order for the IOM committee to
address the health risks posed to veterans, it had to meet a condition that was
impossible to meet.
These constraints in the
Statement of Task were not contained in the letter from Secretary Principi
requesting the report. (To the contrary,
they appear to contradict it.) They must
have come from the “conversations with yourself” referred to in Ms. Stoiber’s
letter to Dr. Brown. Thus, conversations
between VA and IOM staff determined the outcome of the report before the IOM
committee to prepare the report was ever appointed.
In summary, VA and the IOM
have not complied with the law requiring the IOM Gulf War reports, restricting
the scientific evidence required to be considered. This action has been deliberate. Conversations between VA and IOM staff have shaped
the methodology of the reports so as to predetermine their outcome. Dr. Brown and Ms. Stoiber are long gone, and
their successors are more careful regarding what they put in writing, but the
corrupted Categories of Asssociation and all the IOM reports based on them
still stand.
4. The
IOM has recently applied this same corrupt standard to the health of recent
Iraq and Afghanistan veterans, denying the adverse effects of toxic substances
released by burn pits.
In 2007 on-site military
officers with environmental health responsibilities reported dangerous health
effects of toxic exposures from burn pits on U.S. bases in Iraq and
Afghanistan, particularly Joint Base Balad (JBB). A draft executive summary of
a study, dated December 2007, showed dioxin levels at 51 times acceptable
levels, particulate exposure at 50 times acceptable levels, volatile compounds
at two times acceptable levels, and cancer risk from exposure to dioxins at two
times acceptable levels for people at Balad for a year and at eight times
acceptable levels for people at the base for more than a year.
DoD Washington said the draft
summary contained "incorrect data" due to a “software error” and was
"prematurely distributed.”
Officials in Washington in the DoD Office of Force Health Protection and
Readiness denied any lasting health effects:
"While exposure to burn pit smoke may cause temporary coughing and
redness or stinging of the eyes, extensive environmental monitoring indicates
that smoke exposures not interfering with breathing or requiring medical
treatment at the time of exposure usually do not cause any lasting health
effects or medical follow-up." http://www.armytimes.com/article/20081027/NEWS/810270315/Burn-pit-at-Balad-raises-health-concerns
An IOM report was ordered by
VA to study the subject. "[T]he
Institute of Medicine has embarked on a comprehensive study with noted experts
in environmental and occupational health to study the issue." "Is
Burn Pit Smoke Hazardous To Your Health?”, Force Health Protection and
Readiness magazine, vol. 5, issue 2, 2010, page 11.
Following the pattern
established in the IOM Gulf War reports, the IOM burn pit report first pointed
out the known health risks of the exposures: "Chemicals in all three major
classes of chemicals detected at JBB . . . have been associated with long-term
health effects. A wide array of health effects have been observed in
humans and animals after exposure to the specific pollutants detected at JBB .
. . The health-effects data on the other pollutants detected include:
neurological effects, liver toxicity and reduced liver function, cancer,
respiratory toxicity and morbidity, kidney toxicity and reduced kidney
function, blook effects, cardiovascular toxicity and morbidity, reproductive
and developmental toxicity." http://books.nap.edu/openbook.php?record_id=13209&page=5
But then, when it came to
arriving at conclusions, the IOM committee applied the Categories of
Association that allowed only for consideration of human studies. It stated that it was "[f]ollowing the
methods and criteria used by other IOM committees that have prepared reports
for the Gulf War and Health Series and the Veterans and Agent Orange Series . .
.") http://books.nap.edu/openbook.php?record_id=13209&page=6).
There were no published
studies of service members exposed to burn pits, so the committee relied on
studies of groups like firefighters and incinerator workers. Accordingly,
as reported on VA's website, the committee found only "limited but
suggestive evidence of a link between exposure to combustion products and
reduced lung function" and "inadequate or insufficient evidence of a
relation to combustion products and cancer, respiratory diseases, circulatory
diseases, neurological diseases, and adverse reproductive and developmental
outcomes." It did not find the “sufficient evidence of an association”
required for service connection.
Thus, rigging IOM reports by
corrupting the Categories of Association has been extended to a new generation
of veterans, as well as continuing for Gulf War veterans.
ATTACHMENTS TO APPENDIX A
TITLE 38--VETERANS' BENEFITS,
PART II--GENERAL BENEFITS
CHAPTER 11--COMPENSATION FOR
SERVICE-CONNECTED DISABILITY OR DEATH,
SUBCHAPTER II--WARTIME DISABILITY COMPENSATION
Sec. 1117. Compensation for disabilities
occurring in Persian Gulf War veterans
* * *
Agreement With National
Academy of Sciences Regarding Toxic Drugs and
Illnesses Associated With
Gulf War
Pub. L. 105-277, div. C, title XVI, Sec.
1603-1605, Oct. 21, 1998,
112 Stat. 2681-745 to 2681-748,
as amended by Pub. L. 107-103, title II,
Sec. 202(d)(2), Dec. 27,
2001, 115 Stat. 989, provided that:
``SEC. 1603. AGREEMENT WITH
NATIONAL ACADEMY OF SCIENCES.
``(a) Purpose.--The purpose of this section
is to provide for the
National Academy of Sciences,
an independent nonprofit scientific
organization with appropriate
expertise, to review and evaluate the
available scientific evidence
regarding associations between illnesses
and exposure to toxic agents,
environmental or wartime hazards, or
preventive medicines or
vaccines associated with Gulf War service.
``(b) Agreement.--The Secretary of Veterans
Affairs shall seek to
enter into an agreement with
the National Academy of Sciences for the
Academy to perform the activities
covered by this section. The Secretary
shall seek to enter into the
agreement not later than two months after
the date of enactment of this
Act [Oct. 21, 1998].
``(c) Identification of Agents and
Illnesses.--(1) Under the
agreement under subsection
(b), the National Academy of Sciences shall--
``(A) identify the biological,
chemical, or other toxic agents,
environmental or wartime hazards, or
preventive medicines or
vaccines to which members of the Armed
Forces who served in the
Southwest Asia theater of operations during
the Persian Gulf War may
have been exposed by reason of such
service; and
``(B) identify the illnesses (including
diagnosed illnesses and
undiagnosed illnesses) that are manifest in
such members.
``(2) In identifying illnesses under
paragraph (1)(B), the Academy
shall review and summarize
the relevant scientific evidence regarding
illnesses among the members
described in paragraph (1)(A) and among
other appropriate populations
of individuals, including mortality,
symptoms, and adverse
reproductive health outcomes among such members
and individuals.
``(d) Initial Consideration of Specific
Agents.--(1) In identifying
under subsection (c) the
agents, hazards, or preventive medicines or
vaccines to which members of
the Armed Forces may have been exposed for
purposes of the first report
under subsection (i), the National Academy
of Sciences shall consider,
within the first six months after the date
of enactment of this Act [Oct.
21, 1998], the following:
``(A) The following organophosphorous
pesticides:
``(i) Chlorpyrifos.
``(ii) Diazinon.
``(iii) Dichlorvos.
``(iv) Malathion.
``(B) The following carbamate pesticides:
``(i) Proxpur.
``(ii) Carbaryl.
``(iii) Methomyl.
``(C) The carbamate pyridostigmine
bromide used as nerve agent
prophylaxis.
``(D) The following chlorinated
hydrocarbon and other pesticides
and repellents:
``(i) Lindane.
``(ii) Pyrethrins.
``(iii) Permethrins.
``(iv) Rodenticides (bait).
``(v) Repellent (DEET).
``(E) The following low-level nerve
agents and precursor
compounds at exposure levels below those which
produce immediately
apparent incapacitating symptoms:
``(i) Sarin.
``(ii) Tabun.
``(F) The following synthetic chemical
compounds:
``(i) Mustard agents at levels
below those which cause
immediate blistering.
``(ii) Volatile organic compounds.
``(iii) Hydrazine.
``(iv) Red fuming nitric acid.
``(v) Solvents.
``(vi) Uranium.
``(G) The following ionizing radiation:
``(i) Depleted uranium.
``(ii) Microwave radiation.
``(iii) Radio frequency radiation.
``(H) The following environmental
particulates and pollutants:
``(i) Hydrogen sulfide.
``(ii) Oil fire byproducts.
``(iii) Diesel heater fumes.
``(iv) Sand micro-particles.
``(I) Diseases endemic to the region
(including the following):
``(i) Leishmaniasis.
``(ii) Sandfly fever.
``(iii) Pathogenic escherechia
coli.
``(iv) Shigellosis.
``(J) Time compressed administration of
multiple live,
`attenuated', and toxoid vaccines.
``(2) The consideration of agents, hazards,
and medicines and
vaccines under paragraph (1)
shall not preclude the Academy from
identifying other agents,
hazards, or medicines or vaccines to which
members of the Armed Forces
may have been exposed for purposes of any
report under subsection (i).
``(3) Not later than six months after the
date of enactment of this
Act [Oct. 21, 1998], the
Academy shall submit to the designated
congressional committees a
report specifying the agents, hazards, and
medicines and vaccines
considered under paragraph (1).
``(e) Determinations of Associations
Between Agents and Illnesses.--
(1) For each agent, hazard,
or medicine or vaccine and illness
identified under subsection
(c), the National Academy of Sciences shall
determine, to the extent that
available scientific data permit
meaningful determinations--
``(A) whether a statistical association
exists between exposure
to the agent, hazard, or medicine or
vaccine and the illness, taking
into account the strength of the scientific
evidence and the
appropriateness of the scientific
methodology used to detect the
association;
``(B) the increased risk of the illness
among human or animal
populations exposed to the agent, hazard,
or medicine or vaccine;
and
``(C) whether a plausible biological mechanism or other evidence
of a causal relationship exists between
exposure to the agent,
hazard, or medicine or vaccine and the
illness.
``(2) The Academy shall include in its
reports under subsection (i)
a full discussion of the
scientific evidence and reasoning that led to
its conclusions under this
subsection.
``(f) Review of Potential Treatment Models
for Certain Illnesses.--
Under the agreement under
subsection (b), the National Academy of
Sciences shall separately
review, for each chronic undiagnosed illness
identified under subsection
(c)(1)(B) and for any other chronic illness
that the Academy determines
to warrant such review, the available
scientific data in order to
identify empirically valid models of
treatment for such illnesses
which employ successful treatment
modalities for populations
with similar symptoms.
``(g) Recommendations for Additional
Scientific Studies.--(1) Under
the agreement under
subsection (b), the National Academy of Sciences
shall make any
recommendations that it considers appropriate for
additional scientific studies
(including studies relating to treatment
models) to resolve areas of
continuing scientific uncertainty relating
to the health consequences of
exposure to toxic agents, environmental or
wartime hazards, or
preventive medicines or vaccines associated with
Gulf War service.
``(2) In making recommendations for
additional studies, the Academy
shall consider the available
scientific data, the value and relevance of
the information that could
result from such studies, and the cost and
feasibility of carrying out
such studies.
``(h) Subsequent Reviews.--(1) Under the
agreement under subsection
(b), the National Academy of
Sciences shall conduct on a periodic and
ongoing basis additional
reviews of the evidence and data relating to
its activities under this
section.
``(2) As part of each review under this
subsection, the Academy
shall--
``(A) conduct as comprehensive a review
as is practicable of the
evidence referred to in subsection (c) and
the data referred to in
subsections (e), (f), and (g) that became
available since the last
review of such evidence and data under this
section; and
``(B) make determinations under the
subsections referred to in
subparagraph (A) on the basis of the
results of such review and all
other reviews previously conducted for
purposes of this section.
``(i) Reports.--(1) Under the agreement
under subsection (b), the
National Academy of Sciences
shall submit to the committees and
officials referred to in
paragraph (5) periodic written reports
regarding the Academy's
activities under the agreement.
``(2) The first report under paragraph (1)
shall be submitted not
later than 18 months after
the date of enactment of this Act [Oct. 21,
1998]. That report shall
include--
``(A) the determinations and discussion
referred to in
subsection (e);
``(B) the results of the review of
models of treatment under
subsection (f); and
``(C) any recommendations of the
Academy under subsection (g).
``(3) Reports shall be submitted under this
subsection at least once
every two years, as measured
from the date of the report under paragraph
(2).
``(4) In any report under this subsection
(other than the report
under paragraph (2)), the
Academy may specify an absence of meaningful
developments in the
scientific or medical community with respect to the
activities of the Academy
under this section during the 2-year period
ending on the date of such
report.
``(5) Reports under this subsection shall
be submitted to the
following:
``(A) The designated congressional committees.
``(B) The Secretary of Veterans
Affairs.
``(C) The Secretary of Defense.
``(j) Sunset.--This section shall cease to
be effective on October
1, 2010.
``(k) Alternative Contract Scientific
Organization.--(1) If the
Secretary is unable within
the time period set forth in subsection (b)
to enter into an agreement
with the National Academy of Sciences for the
purposes of this section on
terms acceptable to the Secretary, the
Secretary shall seek to enter
into an agreement for purposes of this
section with another
appropriate scientific organization that is not
part of the Government,
operates as a not-for-profit entity, and has
expertise and objectivity
comparable to that of the National Academy of
Sciences.
``(2) If the Secretary enters into an
agreement with another
organization under this
subsection, any reference in this section and
section 1118 of title 38,
United States Code (as added by section
1602(a)), to the National
Academy of Sciences shall be treated as a
reference to such other
organization.
``SEC. 1604. REPEAL OF
INCONSISTENT PROVISIONS OF LAW.
``In the event of the enactment, before,
on, or after the date of
the enactment of this Act
[Oct. 21, 1998], of section 101 of the
Veterans Programs Enhancement
Act of 1998 [Pub. L. 105-368, 112 Stat.
3317], or any similar
provision of law enacted during the second session
of the 105th Congress
requiring an agreement with the National Academy
of Sciences regarding an
evaluation of health consequences of service in
Southwest Asia during the
Persian Gulf War, such section 101 (or other
provision of law) shall be
treated as if never enacted, and shall have
no force or effect.
``SEC. 1605. DEFINITIONS.
``In this title [enacting section 1118 of
this title, amending this
section and section 1113 of
this title, and enacting this note and
provisions set out as a note
under section 101 of this title]:
``(1) The term `toxic agent,
environmental or wartime hazard, or
preventive medicine or vaccine associated
with Gulf War service'
means a biological, chemical, or other
toxic agent, environmental or
wartime hazard, or preventive medicine or
vaccine that is known or
presumed to be associated with service in
the Armed Forces in the
Southwest Asia theater of operations during
the Persian Gulf War,
whether such association arises as a result
of single, repeated, or
sustained exposure and whether such
association arises through
exposure singularly or in combination.
``(2) The term `designated
congressional committees' means the
following:
``(A) The Committees on Veterans'
Affairs and Armed Services
of the Senate.
``(B) The Committees on Veterans'
Affairs and National
Security [now Armed Services] of the
House of Representatives.
``(3) The term `Persian Gulf War' has
the meaning given that
term in section 101(33) of title 38, United
States Code.''
[Pub. L. 105-368, title I, Sec. 101, Nov.
11, 1998, 112 Stat. 3317,
enacted provisions similar to
those in sections 1603 and 1605 of Pub. L.
105-277, set out above. See
section 1604 of Pub. L. 105-277, set out
above.]
From the U.S. Code Online via
GPO Access
[www.gpoaccess.gov]
[Laws in effect as of January
3, 2007]
[CITE: 38USC1118]
TITLE 38--VETERANS' BENEFITS
PART II--GENERAL
BENEFITS
CHAPTER 11--COMPENSATION FOR
SERVICE-CONNECTED DISABILITY OR DEATH
SUBCHAPTER II--WARTIME DISABILITY
COMPENSATION
Sec. 1118. Presumptions of
service connection for illnesses
associated with service in the Persian
Gulf during the Persian
Gulf War
(a)(1) For purposes of section 1110 of this
title, and subject to
section 1113 of this title,
each illness, if any, described in paragraph
(2) shall be considered to
have been incurred in or aggravated by
service referred to in that
paragraph, notwithstanding that there is no
record of evidence of such
illness during the period of such service.
(2) An illness referred to in paragraph (1)
is any diagnosed or
undiagnosed illness that--
(A) the Secretary determines in
regulations prescribed under
this section to warrant a presumption of
service connection by
reason of having a positive association
with exposure to a
biological, chemical, or other toxic agent,
environmental or wartime
hazard, or preventive medicine or vaccine
known or presumed to be
associated with service in the Armed Forces
in the Southwest Asia
theater of operations during the Persian
Gulf War; and
(B) becomes manifest within the period,
if any, prescribed in
such regulations in a veteran who served on
active duty in that
theater of operations during that war and
by reason of such service
was exposed to such agent, hazard, or
medicine or vaccine.
(3) For purposes of this subsection, a
veteran who served on active
duty in the Southwest Asia
theater of operations during the Persian Gulf
War and has an illness
described in paragraph (2) shall be presumed to
have been exposed by reason
of such service to the agent, hazard, or
medicine or vaccine
associated with the illness in the regulations
prescribed under this section
unless there is conclusive evidence to
establish that the veteran
was not exposed to the agent, hazard, or
medicine or vaccine by reason
of such service.
(4)
For purposes of this section, signs or symptoms that may be a
manifestation of an
undiagnosed illness include the signs and symptoms
listed in section 1117(g) of
this title.
(b)(1)(A) Whenever the Secretary makes a
determination described in
subparagraph (B), the
Secretary shall prescribe regulations providing
that a presumption of service
connection is warranted for the illness
covered by that determination
for purposes of this section.
(B) A determination referred to in
subparagraph (A) is a
determination based on sound
medical and scientific evidence that a
positive association exists
between--
(i) the exposure of humans or animals
to a biological, chemical,
or other toxic agent, environmental or
wartime hazard, or preventive
medicine or vaccine known or presumed to be
associated with service
in the Southwest Asia theater of operations
during the Persian Gulf
War; and
(ii) the occurrence of a diagnosed or
undiagnosed illness in
humans or animals.
(2)(A) In making determinations for
purposes of paragraph (1), the
Secretary shall take into
account--
(i) the reports submitted to the
Secretary by the National
Academy of Sciences under section 1603 of
the Persian Gulf War
Veterans Act of 1998; and
(ii) all other sound medical and
scientific information and
analyses available to the Secretary.
(B) In evaluating any report, information,
or analysis for purposes
of making such
determinations, the Secretary shall take into
consideration whether the
results are statistically significant, are
capable of replication, and
withstand peer review.
(3) An association between the occurrence
of an illness in humans or
animals and exposure to an
agent, hazard, or medicine or vaccine shall
be considered to be positive
for purposes of this subsection if the
credible evidence for the
association is equal to or outweighs the
credible evidence against the
association.
(c)(1) Not later than 60 days after the
date on which the Secretary
receives a report from the
National Academy of Sciences under section
1603 of the Persian Gulf War
Veterans Act of 1998, the Secretary shall
determine whether or not a
presumption of service connection is
warranted for each illness,
if any, covered by the report.
(2) If the Secretary determines under this
subsection that a
presumption of service
connection is warranted, the Secretary shall, not
later than 60 days after
making the determination, issue proposed
regulations setting forth the
Secretary's determination.
(3)(A) If the Secretary determines under
this subsection that a
presumption of service
connection is not warranted, the Secretary shall,
not later than 60 days after
making the determination, publish in the
Federal Register a notice of
the determination. The notice shall include
an explanation of the
scientific basis for the determination.
(B) If an illness already presumed to be
service connected under
this section is subject to a
determination under subparagraph (A), the
Secretary shall, not later
than 60 days after publication of the notice
under that subparagraph,
issue proposed regulations removing the
presumption of service
connection for the illness.
(4) Not later than 90 days after the date
on which the Secretary
issues any proposed
regulations under this subsection, the Secretary
shall issue final
regulations. Such regulations shall be effective on
the date of issuance.
(d) Whenever the presumption of service
connection for an illness
under this section is removed
under subsection (c)--
(1) a veteran who was awarded
compensation for the illness on
the basis of the presumption before the effective
date of the
removal of the presumption shall continue
to be entitled to receive
compensation on that basis; and
(2) a survivor of a veteran who was
awarded dependency and
indemnity compensation for the death of a
veteran resulting from the
illness on the basis of the presumption
before that date shall
continue to be entitled to receive
dependency and indemnity
compensation on that basis.
(e) Subsections (b) through (d) shall cease
to be effective on
September 30, 2011.
(Added Pub. L. 105-277, div.
C, title XVI, Sec. 1602(a)(1), Oct. 21,
1998, 112 Stat. 2681-742;
amended Pub. L. 107-103, title II,
Sec. 202(b)(2), (d)(1), Dec.
27, 2001, 115 Stat. 989.)
References in Text
Section 1603 of the Persian Gulf War
Veterans Act of 1998, referred
to in subsecs. (b)(2)(A)(i)
and (c)(1), is section 1603 of Pub. L. 105-
277, which is set out in a
note under section 1117 of this title.
Amendments
2001--Subsec. (a)(4). Pub. L. 107-103, Sec.
202(b)(2), added par.
(4).
Subsec. (e). Pub. L. 107-103, Sec.
202(d)(1), substituted ``on
September 30, 2011'' for ``10
years after the first day of the fiscal
year in which the National
Academy of Sciences submits to the Secretary
the first report under
section 1603 of the Persian Gulf War Veterans Act
of 1998''.
Effective Date of 2001
Amendment
Amendment by section 202(b)(2) of Pub. L.
107-103 effective Mar. 1,
2002, see section 202(c) of
Pub. L. 107-103, set out as a note under
section 1117 of this title.
Gulf War and Health, Vol. 1,
p. 72 [emphasis added]
studies often focus on one
agent at a time, they more easily enable the study of chemical mixtures and
their potential interactions.
Research
on health effects of toxic substance includes animal studies that characterize
absorption, distribution, metabolism, elimination, and excretion. Animal
studies may examine acute (short-term) exposures or chronic (long-term)
exposures. Animal research may focus on the mechanism of action (i.e., how the
toxin exerts its deleterious effects at the cellular and molecular levels).
Mechanism-of-action (or mechanistic) studies encompass a range of laboratory
approaches with whole animals and in vitro systems using tissues or cells from
humans or animals. Also, structure–activity relationships, in which comparisons
are made between the molecular structure and chemical and physical properties
of a potential toxin versus a known toxin, are an important source of
hypotheses about mechanism of action.
In
carrying out its charge, the committee used animal and other nonhuman studies
in several ways, particularly as a marker for health effects that might be
important for humans. If an agent, for example, was absorbed and deposited in
specific tissues or organs (e.g., uranium deposition in bone and kidney), the
committee looked especially closely for possible abnormalities at these sites
in human studies.
One of
the problems with animal studies, however, is the difficulty of finding animal
models to study symptoms that relate to uniquely human attributes, such as
cognition, purposive behavior, and the perception of pain. With the exception
of fatigue, many symptoms reported by veterans (e.g., headache, muscle or joint
pain) are difficult to study in standard neurotoxicological tests in animals
(OTA, 1990).
For its
evaluation and categorization of the degree of association between each
exposure and a human health effect, however, the committee only used evidence
from human studies.
Nevertheless, the committee did use nonhuman studies as the basis for judgments
about biologic plausibility, which is one of the criteria for establishing
causation (see below).
Human Studies
Epidemiologic Studies
Epidemiology concerns itself
with the relationship of various factors and conditions that determine the
frequency and distribution of an infectious process, a disease, or a
physiological state in human populations (Lilienfeld, 1978). Its focus on populations
distinguishes it from other medical disciplines. Epidemiologic studies
characterize the relationship between the agent, the environment, and the host
and are useful for generating and testing hypotheses with respect to the
association between exposure to an agent and health or disease. The following
section describes the major types of epidemiologic studies considered by the
committee.
Gulf War and Health, Vol. 2,
p. 13 [emphasis added]
general use in the United
States (PAC, 1996) at that time. However, EPA has since placed restrictions on
some of the insecticides used during the Gulf War.
USE OF SOLVENTS IN THE GULF WAR
To determine the specific
solvents used in the Gulf War the committee gathered information from several
sources, including veterans, OSAGWI (2000), and DOD’s Defense Logistics Agency.
As a result of its research, the committee ultimately identified 53 solvents
for review (Appendix D).
There is
little information to characterize the use of solvents in the Gulf War. Wartime
uses of solvents (such as vehicle maintenance and repair, cleaning, and
degreasing) probably paralleled stateside military or civilian uses of
solvents, but operating conditions in the Gulf War (such as ventilation and the
use of masks) may have varied widely from stateside working conditions.
The most
thoroughly documented solvent exposure involved spray-painting with
chemical-agent-resistant coating (CARC) (OSAGWI, 2000). Thousands of military
vehicles deployed to the Gulf War were painted with tan CARC to provide
camouflage protection for the desert environment and a surface that was easily
decontaminated. Not all military personnel involved in CARC painting were
trained in spray-painting operations, and some might not have had all the
necessary personal protective equipment (OSAGWI, 2000).
Personnel
engaged in CARC painting were exposed to solvents in the CARC formulations,
paint thinners, and cleaning products. As noted in the OSAGWI report, some of
the solvents used to clean painting equipment might have been purchased locally
and therefore not identified.
COMPLEXITIES IN ADDRESSING GULF WAR HEALTH ISSUES
Investigations of the health
effects of past wars often focused on narrowly defined hazards or health
outcomes, such as infectious diseases (for example, typhoid and malaria) during
the Civil War, specific chemical hazards (for example, mustard gas and Agent
Orange) in World War I and Vietnam, and combat injuries. Discussion of the possible
health effects of the Gulf War, however, involves many complex issues, such as
exposure to multiple agents, lack of exposure information, nonspecific
illnesses that lack defined diagnoses or treatment protocols, and the
experience of war itself. The committee was not charged with addressing
those issues, but it presents them here to acknowledge the difficulties
faced by veterans and their families, researchers, policy-makers, and others in
trying to understand Gulf War veterans’ health.
Multiple Exposures and Chemical Interactions
Military personnel were
potentially exposed to numerous agents during the Gulf War. The number of
agents and the combination of agents to which the veterans may have been
exposed make it difficult to determine whether any one agent or combination of
agents is the cause of the veterans’ illnesses. These include preventive
measures (such as use of pyridostigmine bromide, vaccines, and insecticides),
hazards of the natural environment
Gulf War and Health, Vol. 1,
p. 83 [emphasis added]
mittee evaluated the strength
of the evidence for or against associations between health effects and exposure
to the agents being studied.
Categories of Association
The committee used five
previously established categories to classify the evidence for association
between exposure to a specific agent and a health outcome. The categories
closely resemble those used by several IOM committees that evaluated
vaccine safety (IOM, 1991, 1994a), herbicides used in Vietnam (IOM,
1994b, 1996, 1999), and indoor pollutants related to asthma (IOM, 2000).
Although the categories imply a statistical association, the committee had
sufficient epidemiologic evidence to examine statistical associations for only
one of the agents under study (i.e., depleted uranium), there was very limited
epidemiologic evidence for the other agents examined (i.e., sarin,
pyridostigmine bromide, and anthrax and botulinum toxoid vaccines). Thus, the
committee based its conclusions on the strength and coherence of the data in
the available studies. In many cases, these data distinguished differences
between transient and long-term health outcomes related to the dose of the
agent. Based on the literature, it became incumbent on the committee to
similarly specify the differences between dose levels and the nature of the
health outcomes. This approach led the committee to reach conclusions about
long- and short-term health effects, as well as health outcomes related to the
dose of the putative agents. The final conclusions expressed in Chapters 4–7 represent the committee’s collective judgment.
The committee endeavored to express its judgments as clearly and precisely as
the available data allowed. The committee used the established categories of
association from previous IOM studies, because they have gained wide acceptance
for more than a decade by Congress, government agencies, researchers, and
veteran groups.
- Sufficient Evidence of a Causal Relationship.
Evidence is sufficient to conclude that a causal relationship exists between
the exposure to a specific agent and a health outcome in humans. The evidence
fulfills the criteria for sufficient evidence of an association (below) and
satisfies several of the criteria used to assess causality: strength of
association, dose–response relationship, consistency of association, temporal
relationship, specificity of association, and biological plausibility.
- Sufficient Evidence of an Association.
Evidence is sufficient to conclude that there is a positive association. That
is, a positive association has been observed between an exposure to a specific
agent and a health outcome in human studies in which chance, bias, and
confounding could be ruled out with reasonable confidence.
- Limited/Suggestive Evidence of an
Association. Evidence is suggestive of an association between exposure to a
specific agent and a health outcome in humans, but is limited because chance,
bias, and confounding could not be ruled out with confidence.
Gulf War and Health, Vol. 1,
p. 84 [emphasis added]
- Inadequate/Insufficient Evidence to Determine
Whether an Association Does or Does Not Exist. The available studies are of
insufficient quality, consistency, or statistical power to permit a conclusion
regarding the presence or absence of an association between an exposure to a
specific agent and a health outcome in humans.
- Limited/Suggestive Evidence of No
Association. There are several adequate studies, covering the full range of
levels of exposure that humans are known to encounter, that are mutually
consistent in not showing a positive association between exposure to a specific
agent and a health outcome at any level of exposure. A conclusion of no
association is inevitably limited to the conditions, levels of exposure, and
length of observation covered by the available studies. In addition, the
possibility of a very small elevation in risk at the levels of exposure studied
can never be excluded.
These five categories cover
different degrees or levels of association, with the highest level being
sufficient evidence of a causal relationship between exposure to a specific
agent and a health outcome. The criteria for each category incorporate key
points discussed earlier in this chapter. A recurring theme is that an
association is more likely to be valid if it is possible to reduce or eliminate
common sources of error in making inferences: chance, bias, and confounding.
Accordingly, the criteria for each category express varying degrees of
confidence based upon the extent to which it has been possible to exclude these
sources of error. To infer a causal relationship from a body of evidence, the
committee relied on long-standing criteria for assessing causation in
epidemiology (Hill, 1971; Evans, 1976).
COMMENTS ON INCREASED RISK OF ADVERSE HEALTH OUTCOMES AMONG GULF
WAR VETERANS
As discussed in the beginning
of this chapter, the committee reviewed the available scientific evidence in
the peer-reviewed literature in order to draw conclusions about associations
between the agents of interest and adverse health effects in all populations.
The committee placed its conclusions in categories that reflect the strength of
the evidence for an association between exposure to the agent and health
outcomes. The committee could not measure the likelihood that Gulf War
veterans’ health problems are associated with or caused by these agents. To
address this issue, the committee would need to compare the rates of health
effects in Gulf War veterans exposed to the putative agents with the rates of
those who were not exposed, which would require information about the agents to
which individual veterans were exposed and their doses. However, as
discussed throughout this report, there is a paucity of data regarding the
actual agents and doses to which individual Gulf War veterans were exposed.
Further, to answer questions about increased risk of illnesses in Gulf War
veterans, it would also be important to know the degree to which any other
differences be-
Veterans and Agent Orange:
Update 1996, p. 97 [emphasis added]
Summary Of The Evidence
Categories of Association
The
categories of association used by the committee were those used in VAO.
Consistent with the charge to the Secretary of Veterans Affairs in P.L. 102-4,
the distinctions between the categories are based on "statistical
association," not on causality. Thus, standard criteria used in
epidemiology for assessing causality (Hill, 1971) do not strictly apply. The
distinctions between the categories reflect the committee's judgment that a
statistical association would be found in a large, well-designed epidemiologic
study of the outcome in question in which exposure to herbicides or dioxin was
sufficiently high, well-characterized, and appropriately measured. The
categories of association are:
- Sufficient Evidence of an Association
Evidence is sufficient to conclude that there is a positive association. That
is, a positive association has been observed between herbicides and the outcome
in studies in which chance, bias, and confounding could be ruled out
with reasonable confidence. For example, if several small studies that are free
from bias and confounding show an association that is consistent in magnitude
and direction, there may be sufficient evidence for an association.
- Limited/Suggestive Evidence of an Association
Evidence is suggestive of an association between herbicides and the outcome but
is limited because chance, bias, and confounding could not be ruled out with
confidence. For example, at least one high-quality study shows a positive
association but the results of other studies are inconsistent.
- Inadequate/Insufficient Evidence to Determine
Whether an Association Exists The available studies are of insufficient
quality, consistency, or statistical power to permit a conclusion regarding the
presence or absence of an association. For example, studies fail to control for
confounding, have inadequate exposure assessment, or fail to address latency.
- Limited/Suggestive Evidence of No
Association There are several adequate studies, cover the full range of levels
of exposure that human beings are known to encounter, that are mutually
consistent in not showing a positive association between exposure to herbicides
and the outcome at any level of exposure. A conclusion of "no
association" is inevitably limited to the conditions, level of exposure,
and length of observation covered by the available studies. In addition, the
possibility of a very small elevation in risk at the levels of exposure studied
can never be excluded.
Gulf War and Health, Vol. 1,
p. 72 [emphasis added]
studies often focus on one
agent at a time, they more easily enable the study of chemical mixtures and
their potential interactions.
Research
on health effects of toxic substance includes animal studies that characterize
absorption, distribution, metabolism, elimination, and excretion. Animal
studies may examine acute (short-term) exposures or chronic (long-term)
exposures. Animal research may focus on the mechanism of action (i.e., how the
toxin exerts its deleterious effects at the cellular and molecular levels).
Mechanism-of-action (or mechanistic) studies encompass a range of laboratory
approaches with whole animals and in vitro systems using tissues or cells from
humans or animals. Also, structure–activity relationships, in which comparisons
are made between the molecular structure and chemical and physical properties
of a potential toxin versus a known toxin, are an important source of
hypotheses about mechanism of action.
In
carrying out its charge, the committee used animal and other nonhuman studies
in several ways, particularly as a marker for health effects that might be
important for humans. If an agent, for example, was absorbed and deposited in
specific tissues or organs (e.g., uranium deposition in bone and kidney), the
committee looked especially closely for possible abnormalities at these sites
in human studies.
One of
the problems with animal studies, however, is the difficulty of finding animal
models to study symptoms that relate to uniquely human attributes, such as
cognition, purposive behavior, and the perception of pain. With the exception
of fatigue, many symptoms reported by veterans (e.g., headache, muscle or joint
pain) are difficult to study in standard neurotoxicological tests in animals
(OTA, 1990).
For its
evaluation and categorization of the degree of association between each
exposure and a human health effect, however, the committee only used evidence
from human studies. Nevertheless,
the committee did use nonhuman studies as the basis for judgments about
biologic plausibility, which is one of the criteria for establishing
causation (see below).
Human Studies
Epidemiologic Studies
Epidemiology concerns itself
with the relationship of various factors and conditions that determine the
frequency and distribution of an infectious process, a disease, or a
physiological state in human populations (Lilienfeld, 1978). Its focus on
populations distinguishes it from other medical disciplines. Epidemiologic
studies characterize the relationship between the agent, the environment, and
the host and are useful for generating and testing hypotheses with respect to
the association between exposure to an agent and health or disease. The
following section describes the major types of epidemiologic studies considered
by the committee.
Updated
Literature Review of Sarin (2004), p. 20 [emphasis added]
OP insecticide data in its
conclusion, the committee reviewed the OP epidemiology literature. The
committee responsible for GW2 (IOM, 2003a) reviewed the literature on OP
compounds. The present committee reviewed relevant epidemiology studies
published since the preparation of that report.
Animal
studies had a small role in the committee’s assessment of association between
putative agents and health outcomes. As with previous committees, this
committee used animal data for making assessments of biologic plausibility in
support of the epidemiologic data rather than as part of the weight of evidence
to determine the likelihood that an exposure to a specific agent might cause a
long-term outcome.
The
committee classified the evidence of an association between exposure to sarin
and cyclosarin and a specific health outcome into five categories (Box 1-1). The
categories closely resemble those used by previous committees that evaluated
the effects of chemicals related to the Gulf War (IOM, 2000a, 2003a) and those
used by several IOM committees that have evaluated vaccine safety (IOM, 1991,
1994a), herbicides used in Vietnam (IOM, 1994b, 1996, 1999, 2001, 2003b), and
indoor pollutants related to asthma (IOM, 2000b). The committee’s conclusions,
presented in Chapter 4, represent its collective judgment.
The committee
endeavored to express its judgment as clearly and precisely as the available
data allowed, and it used the established categories of association from
previous IOM studies because they have gained wide acceptance over more
BOX 1-1
Categories of Evidence
Sufficient Evidence of a
Causal Relationship
Evidence
from available studies is sufficient to conclude that a causal relationship
exists between exposure to a specific agent and a specific health outcome in
humans, and the evidence is supported by experimental data. The evidence
fulfills the guidelines for sufficient evidence of an association (below) and
satisfies several of the guidelines used to assess causality: strength of
association, dose–response relationship, consistency of association, biologic
plausibility, and a temporal relationship.
Sufficient Evidence of an
Association
Evidence
from available studies is sufficient to conclude that there is a positive
association. A consistent positive association has been observed between
exposure to a specific agent and a specific health outcome in human studies
in which chance1 and bias, including confounding, could be
ruled out with reasonable confidence. For example, several high-quality
studies report consistent positive associations, and the studies are
sufficiently free of bias, including adequate control for confounding.
|
Appendix B
Letter to IOM President Regarding Imbalanced Membership
of 2016 Report Committee
November
28, 2014
Dr. Victor J. Dzau, M.D.
President
Institute of Medicine
500 Fifth St., NW
Washington, DC
20001
Dear Dr. Dzau,
As former
members of the VA Research Advisory Committee on Gulf War Veterans Illnesses,
we are gravely concerned by the makeup of the committee that IOM staff has
chosen for the upcoming review of Gulf War health literature. The membership is grossly imbalanced toward
the 1990’s government position that Gulf War veterans have no special health
problem — just what happens after every war, related to psychiatric issues, and
not environmental exposures.
Reviving
this discredited fiction will cause veterans’ doctors to prescribe
inappropriate psychiatric medications, and will misdirect research to find
effective treatments down blind alleys — an unconscionable breach of the duty
owed to veterans and expected of the Institute of Medicine.
Science
has conclusively demonstrated that this government position has no scientific
validity. Just four years ago, an IOM
committee chaired by Dr. Stephen Hauser, former president of the American
Neurological Association, reviewed the scientific literature and concluded that
the chronic multisymptom illness suffered by an estimated 250,000 Gulf War
veterans (over one-third of the 697,000 who deployed) is a physical illness
associated with Gulf War service, a “diagnostic entity” that “cannot be
reliably ascribed to any known psychiatric disorder,” and that “it is likely
that Gulf War illness results from an interplay of genetic and environmental
factors.” http://books.nap.edu/openbook.php?record_id=12835,
pages 262, 210, 204, 109, 261
These
conclusions reinforced the similar findings and recommendations of our former
committee’s 452-page 2008 report. Our committee went further to identify the
specific environmental exposures responsible, including pesticides,
pyridostigmine bromide pills given to troops as a prophylaxis against nerve
gas, and possibly low level nerve gas released by the destruction of Iraqi
facilities, oil well fires, and multiple vaccinations. In April 2014, our committee published an update
report which concluded that “[s]cientific research published since … 2008 …
supports and further substantiates the conclusions of the 2008 report.” http://www.va.gov/RAC-GWVI/RACReport2014Final.pdf,
page 5
Yet, as
the attached analysis shows, fully half the individuals selected for the new
committee are predisposed toward the discredited 1990’s government position,
either because they promoted it themselves, or because they are professionally
oriented to view such problems as psychiatric and/or unrelated to environmental
exposures. The rest of the committee are neutral figures with a background in
other neurological conditions like Alzheimer’s disease and traumatic brain
injuries. No member of the committee has
been actively engaged in Gulf War health research in the past decade.
Given that
the committee is charged with producing a consensus report, it is wholly
foreseeable that its conclusions will end up between the group predisposed to
1990’s fictions and those who are neutral but unfamiliar with the subject. Compared to the 2010 IOM report, it will be
a reversal toward the discredited 1990’s position.
For three
years, VA has been engaged in a surreptitious campaign to revive the 1990’s
government position. Since no scientific
support for the position exists, VA staff has resorted to manipulating Gulf War
research and reports. The Research
Advisory Committee has documented this manipulation in forty-six pages of
findings and recommendations in June 2012 and in a draft section of its April
2014 report which had to be removed because VA eliminated the committee’s
oversight authority. http://www.va.gov/RAC-GWVI/docs/Committee_Documents/CommitteeDocJune2012.pdf
In
September, VA’s Director of Epidemiology, Dr. Robert Bossarte, and his staff
presented findings of two new VA studies to the Research Advisory
Committee. One showed that diagnoses
given to Gulf War veterans in VA hospitals over a ten-year period were no
different than those given to veterans of the same era who did not deploy. The other, a large survey, showed that rates
of PTSD and depression were dramatically higher than previously reported by
Gulf War veterans.
To an
inexperienced observer, it might seem that the research on Gulf War veterans’
health was changing. However, Research
Advisory Committee members quickly pointed out that Dr. Bossarte and his staff
were not telling the whole story. http://www.va.gov/RAC-GWVI/RAC_Recommendation092314.pdf
The
diagnoses study presentation failed to mention that VA had no diagnostic code
for Gulf War illness or chronic multisymptom illness, that VA doctors at this
time were trained to consider the illness as psychosomatic, and that veterans
who served during the period of greatest toxic exposures were inexplicably
excluded from the study. Similarly, the
survey presentation did not disclose that the survey was overweighted with
mental health questions to the extent that the Committee had repeatedly
recommended against sending it out, http://www.va.gov/RAC-GWVI/docs/Committee_Documents/CommitteeDocJune2012.pdf, Appendix F, and that the survey’s principal
investigator had testified to Congress that his superiors lied to then-VA Chief
of Staff John Gingrich to induce him to release the survey. https://veterans.house.gov/witness-testimony/dr-steven-s-coughlin The presentation did not mention that people
suffering from chronic health problems often become depressed after 23 years,
but it is not the cause of their illness.
Dr.
Bossarte and his staff will be presenting to the new IOM committee on December
3. Very likely they will be presenting
their new research findings. But no one
on the IOM committee will know that they are not being told the whole story,
because there are no members with the necessary background. Thus, misleading VA studies will be presented
to an imbalanced IOM committee, which will include the findings in its new
report, and science will be “revised”.
The motivation behind VA’s manipulation of science is clear:
to hold down benefits costs and claims wait times. In April, Military Times reported that VA
Undersecretary for Benefits Allison Hickey was concerned that even using the
term “Gulf War illness” “might imply a causal link between service in the Gulf and
poor health which could necessitate legislation for disability compensation for
veterans who served in the Gulf.” http://archive.militarytimes.com/article/20140422/BENEFITS04/304220036/Top-VA-official-questions-use-term-Gulf-War-illness-
She also recently testified to Congress that VA would meet
its 2015 claims processing target of 125 days unless she had to add a
quarter million new claims to her inventory overnight, as happened in 2010 when
Agent Orange coverage was expanded: “That will kill us.” http://www.veterans.senate.gov/hearings/va-claims-system-review-of-vas-transformation-progress
[1:38:50 mark]
While VA says that it provides care and benefits to veterans
suffering from Gulf War illness under the category “undiagnosed illnesses,” http://www.publichealth.va.gov/exposures/gulfwar/medically-unexplained-illness.asp,
the reality is otherwise. A 2014 VA
report to Congress revealed that only 11,216 Gulf War-related claims have been
approved, while 80 percent are denied.
VA’s September 2014 press release that “nearly 800,000 Gulf
War era Veterans are receiving compensation benefits for service-connected
issues” is grossly misleading.
http://www.91outcomes.com/2014/09/va-press-release-va-secretary-mcdonald.html VA counts every veteran in the area from 1990
to the present as “Gulf War era,” not just those who served in 1990-91.
We are appalled that the government has been able to
influence the workings of the Institute of Medicine, the most revered
institution in American medical science, to further its shameful campaign to
manipulate science to deny veterans care and benefits. Regrettably, however, we are not surprised,
as this has been more common than not where Gulf War veterans’ health has been
concerned. For example:
1. For fourteen
years, in response to a law passed by Congress in 1998, VA has ordered and the
IOM has prepared reports on the health effects of thirty-three toxic substances
to which Gulf War veterans were exposed.
The law repeatedly specified that the reports must consider studies in
both humans and in animals. For fourteen years, however, these IOM reports have
considered only human studies. To do
this, VA and the IOM not only have had to disregard the law; they also had to
manipulate the standard established in the IOM reports on Agent Orange,
inserting the word “human” in the standard.
As a result, since most research studies of toxic substances are
necessarily done in animals, these IOM Gulf War reports have never found
sufficient evidence of an association between these substances and Gulf War
veterans’ health problems. In turn, VA
has never recognized any toxic exposure as a reason for granting these ill
veterans care and benefits. https://veterans.house.gov/witness-testimony/james-h-binns-0
2. The most egregious
of these IOM Gulf War reports was the Updated Literature Review of Sarin, in
which animal studies were not considered even though new animal studies were
the only reason that then-Secretary Principi ordered the report. The outcome of the report was predetermined
before the VA-IOM contract was ever signed, by understandings between VA and
IOM staff discussed in a cover letter from the then executive director of the
IOM to the then head of the VA Environmental Agents Service. https://veterans.house.gov/witness-testimony/james-h-binns-0
3. The Research
Advisory Committee recommended in 2008 that these IOM reports be redone in
accordance with the law. http://www.va.gov/RAC-GWVI/docs/Committee_Documents/GWIandHealthofGWVeterans_RAC-GWVIReport_2008.pdf,
pages 53-55, 57. However, they have not
been redone. Worse, the manipulated
standard is now being employed in VA-ordered IOM studies of the health of
post-9/11 veterans. The 2011 IOM report
on the long-term health effects of burn pits used to incinerate waste in Iraq
and Afghanistan used the manipulated Gulf War standard (limited to human
studies), not the Agent Orange standard.
As a consequence, the IOM burn pits committee found “inadequate/insufficient
evidence of an association between exposure to combustion products and cancer,
respiratory disease, circulatory disease, neurologic disease, and adverse
reproductive and developmental outcomes.”
http://books.nap.edu/openbook.php?record_id=13209&page=6
4. In 2006, the IOM
did a general Gulf War literature review for VA, similar to the current
task. Most of the report was a
straightforward summary of the research, but IOM’s press release and press
conference focused on one conclusion that echoed the familiar government theme
that there is “no unique Gulf War syndrome.”
Technically, this only means that others have similar symptoms, but the
press release and conference spun the message to imply that Gulf War veterans
have no major health problem. http://www.nbcnews.com/id/14801666/ns/health-health_care/t/study-gulf-war-syndrome-doesnt-exist/#.VHLDjUuBNH8
5. The 2013 IOM
treatments report was a recent glaring example of VA and IOM collaboration to
disregard the law and promote the 1990’s government position. A 2010 law required VA to contract with the
IOM for a comprehensive review of the best treatments for ill Gulf War veterans
by a group of doctors experienced in treating Gulf War veterans “diagnosed with
chronic multisymptom illness or another health condition related to chemical
and environmental exposures that may have occurred during [their] service.”
Instead,
VA contracted for a literature review of treatments for all “populations with a
similar constellation of symptoms,” and the IOM appointed a committee with no
experience in treating Gulf War veterans but extensive experience in
psychiatric and psychosomatic medicine -- though the 2010 IOM report had just
concluded that the illness “cannot be ascribed to any known psychiatric
disorder.” Analysishttps://veterans.house.gov/sites/republicans.veterans.house.gov/files/Binns%2C%20ExhibitBtestimony.pdf
The
individuals selected to give background briefings to the committee were largely
familiar advocates for the 1990’s position, who told the committee the problem
was psychiatric. http://www.va.gov/RAC-GWVI/docs/Committee_Documents/CommitteeDocJune2012.pdf,
pages 24-30. Half the illnesses whose
therapies were reviewed were psychiatric.
The report revived 1990’s themes that that “[t]hroughout modern history,
many soldiers returning from combat have experienced postcombat illnesses. . .
that cannot now be attributed to any diagnosable pathophysiologic entity or
disease,” and that “[c]linicians should
approach [chronic multisymptom illness] with ‘a person-centered model of care .
. . that helps patients understand that the word psychosomatic is not
pejorative.’” https://veterans.house.gov/sites/republicans.veterans.house.gov/files/Binns%2C%20ExhibitBtestimony.pdf
6. The person who
identified the individuals to be invited to brief the treatment committee was
the chief scientist of the VA Office of Public Health, according to
Congressional testimony by a senior VA epidemiologist who worked for him. https://veterans.house.gov/witness-testimony/dr-steven-s-coughlin
7. One of the
psychiatric-oriented briefers was a member of the IOM Board on the Health of
Select Populations, the IOM board that oversees veterans’ studies. Dr. Kurt Kroenke, an Army doctor and
psychiatric-oriented Gulf War researcher in the 1990’s, is a leading figure in
somatic medicine. He co-chaired the
“Conceptual Issues in Somatoform and Similar Disorders” project that laid the
groundwork for the controversial expansion of the definition of somatoform
disorders in the recently revised Diagnostic and Statistical Manual of Mental
Disorders (DSM-5) of the American Psychiatric Association. http://www.ncbi.nlm.nih.gov/pubmed/17600162 http://dxrevisionwatch.com/dsm-5-drafts/dsm-5-ssd-work-group/ He has co-authored publications with two
members of the IOM treatment committee and two members of the new IOM committee
that begins work December 3.
8. Two other members
of the IOM Board of the Health of Select Populations were also leading
proponents of the government position on Gulf War health in the 1990’s. Dr. Francis Murphy held the position
equivalent to chief scientist in VA’s Office of Public Health, and Dr. Greg
Gray was a Navy doctor who published numerous papers in 1996-2001 that
dismissed the idea that Gulf War veterans have any special health
problems. Conversely, as of June 2013,
no one on the IOM Board of the Health of Select Populations represented current
scientific understanding of Gulf War illness.
http://www.scribd.com/doc/150949964/WHITE-PAPER-IOM-CMI-Panel-Membership-Analysis.
It is currently undisclosed who serves
on this board, as its membership has been removed from the IOM website,
although the membership of all other IOM boards continues to be listed. http://www.iom.edu/About-IOM/Leadership-Staff/Boards.aspx
In summary, there has been a long-term corrupt relationship
between the government and the Institute of Medicine to deny the true state of
Gulf War veterans’ health, of which the makeup of the new committee is only the
latest example.
We are confident that neither you nor VA Secretary McDonald,
as newcomers to Washington and to your respective institutions, is aware of
this problem. At one point, none of us
would have believed it possible either.
But it is a cancer that threatens to destroy the integrity and reputations
of both organizations. And it makes a
mockery of the mission of the IOM “to provide unbiased and authoritative advice
to decision makers and the public.” http://www.iom.edu/About-IOM.aspx
We urge
you to conduct a thorough investigation of this problem and to fix it. The most effective and rapid approach is for
the IOM to handle this itself. If it
does not, however, we will work with veterans’ organizations to show Congress
the need to conduct an investigation and enact legislative solutions.
As part of
putting IOM on solid ground going forward, we urge you to replace the eight
provisional members predisposed to the government’s scientifically discredited
1990’s position with individuals representing current scientific knowledge of
Gulf War research and the health effects of neurotoxic exposures. We also urge you to replace those members of
the Board on the Health of Select Populations identified with this position,
with individuals representing current scientific knowledge regarding veterans’
health and environmental exposures.
Respectfully,
James
Binns
Former
Chairman, Research Advisory Committee on Gulf War Veterans Illnesses
Beatrice
A. Golomb, MD, PhD
Professor
of Medicine, University of California San Diego
Current Member, Research
Advisory Committee; former Committee Scientific Director
Rev. Joel C. Graves, DMin,
CPT U.S. Army (Ret.)
Former Member, Research
Advisory Committee
Marguerite L. Knox, MN,
ARNP-FNP/ACNP
COL, South Carolina Army
National Guard
Former Member, Research
Advisory Committee
William J. Meggs, MD, PhD
Professor and Chief, Division
of Toxicology, Brody School of Medicine, East Carolina University
Former Member, Research
Advisory Committee
cc: Institute of Medicine Council
Analysis
of the Provisional Committee Membership
November,
2014
The
provisional committee is grossly imbalanced in favor of the 1990’s government
position that Gulf War veterans have no special health problem—just what
happens after every war, related to psychiatric issues, and not environmental
exposures.
The
following committee members are predisposed toward this position, either
because they personally supported it, or because they are professionally
oriented to view these kinds of health problems as psychiatric and unrelated to
environmental exposures.
Dr. Kenneth Kizer, as VA
Undersecretary for Health, 1994-1999, was the chief promulgator of this
position, including this 1997 Congressional testimony: “The overall frequency
of unexplained symptoms among Gulf War veterans appears to be about the same as
in a general medical practice.” http://www.va.gov/OCA/testimony/hvac/sh/hvac61.asp
Dr. Howard Kipen, a
member of the VA Persian Gulf Expert Scientific Committee, 1993-1997, has
published “Military deployment to the Gulf War as a risk factor for psychiatric
illness among U.S. troops” (2005) http://bjp.rcpsych.org/content/188/5/453.long
and that “[c]oncerns . . . of a unique Gulf War syndrome, remind us that
military personnel returning from wars have regularly described disabling
symptoms” (co-authored with Dr. Kroenke).
Unexplained Symptoms after
Terrorism and War: An Expert Consensus Statement. Journal of Occupational and
Environmental Medicine 45(10):1040-8, 2003
Dr. Herman Gibb runs a private
consulting firm. The NIH reportedly
terminated its contract with his previous firm, while he was president, on
grounds that his firm was working for three chemical companies at the same time
it was reviewing their chemicals for the government. http://www.washingtonpost.com/wp-dyn/content/article/2007/04/13/AR2007041301979.html
Dr. Nancy Woods is an expert on
midlife and aging women’s health; her background relevant to Gulf War illness
was as a member of the IOM committee that authored a 1996 report, “The Health
Consequences of Service During the Persian Gulf War,” which concluded: “Men and
women served side by side in conditions that increased the stresses of serving
in these grim surroundings . . . Studies of Gulf War veterans suggest that
these veterans suffer from a variety of recognized diseases, . . . not the
existence of a new disease. ” http://books.nap.edu/openbook.php?record_id=5272&page=R6
Dr. Javier Escobar is
a professor of psychiatry at the Robert Wood Johnson Medical School, where his work
“focuses on the somatic presentations of psychiatric disorders in primary care .
. . as director of the ‘Medically Unexplained Physical Symptoms Research Center.’”
http://www.physicianfacultyscholars.org/nac/escobar.html With Dr. Kroenke he was a member of the “Conceptual
Issues in Somatoform and Similar Disorders” project that laid the groundwork
for the controversial expansion of the definition of somatoform disorders in
the recently revised Diagnostic and Statistical Manual of Mental Disorders
(DSM-5) of the American Psychiatric Association, and was a member of the task
force that wrote DSM-5. http://www.ncbi.nlm.nih.gov/pubmed/17600162 http://dxrevisionwatch.com/dsm-5-drafts/dsm-5-ssd-work-group/ http://www.dsm5.org/MeetUs/Pages/TaskForceMembers.aspx He was a member of the 2013 IOM treatment
report committee.
Dr. Scott Fishman is board certified
in psychiatry and pain medicine. His
research includes a focus on “psychiatric issues of chronic illness and pain.” http://www.ucdmc.ucdavis.edu/publish/facultybio/search/faculty/508
Dr. Alberto
Caban-Martinez studies musculoskeletal pain in workers related to their
occupational risk factors. http://www.cabanmartinezlab.com/#!about/c46c He has studied “The prevalence of Somatic
Disfunctions in a Multi-Center Outpatient Osteopathic Medicine Clinic” http://nhsn.med.miami.edu/documents/cv/a_cabanmartinez_cv_09.pdf
and has published that “[c]onstruction workers struggle with a high prevalence
of mental distress, and this is associated with their pain and injuries.” J Occup Environ Med 2013 Oct;55(10):1197-204
Dr. Deborah Cory-Slecta, the
committee chair, has not done Gulf War health research herself but stated in
2013, in connection with service on another IOM Gulf War committee, that she
does not believe Gulf War illness research has produced adequate data to show
what caused the illness. http://www.forbes.com/sites/rebeccaruiz/2014/03/12/experts-cant-decide-on-definition-for-gulf-war-illness/ She also served on the 2003 IOM Gulf War
committee that concluded there was insufficient evidence to show an association
between any illness affecting Gulf War veterans and exposure to pesticides,
applying the manipulated standard that excluded animal studies. http://www.nap.edu/openbook.php?record_id=10628&page=R5
The other
half of the committee are neutral, people who have not been engaged in Gulf War
health research themselves, but who have a background in studying other
neurological conditions and expertise in relevant subjects like neuroimaging,
neuropsychology, and neuroepidemiology.
They include Dr. Robert Brown, Dr. Ellen Eisen, Dr. Mary Fox, Dr.
Clifford Jack, Dr. Joel Kramer, Dr. Francine Laden, Dr. James Noble, and Dr.
Anbesaw Selassie.
Conspicuously
absent from the committee are any doctors or scientists who have studied Gulf
War health in the past decade, who have studied or treated other groups
subjected to neurotoxic exposures like farmers or pesticide applicators, or who
have studied the effects of Gulf War exposures in animals.
[1] Veterans Benefits Act of 2010, Sec. 805,
http://library.clerk.house.gov/reference-files/PPL_111_275_VeteransBenefitsAct_2010.pdf
[2]
http://www.scribd.com/doc/150949964/WHITE-PAPER-IOM-CMI-Panel-Membership-Analysis
[3] Public Law 110-389, Section 804
[5]
http://iom.nationalacademies.org/Reports/2015/Considerations-for-Designing-Epidemiologic-Study-for-Multiple-Sclerosis-and-other-Neurological-disorders-Veterans.aspx
[6] 2016
IOM Gulf War and Health report, pp. 102,145,149.
Mr. Hardie, how do I help in this fight? I am a gulf war veteran and since coming home, have suffered fatigue, bone and joint pain, severe headaches, irritable bowel syndrome for 25 years. I've gone to the VA and was told I didn't meet criteria to obtain any veterans benefits. I just saw an article today, that led me to you. Again, what can I do to assist in this fight for not just myself but other gulf war vets.
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