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Agent Orange conference calls for U.S. to take responsibility for health problems

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  • Agent Orange conference calls for U.S. to take responsibility for health problems

    Activists and Vietnam War veterans wrapped up a global conference on Agent Orange Wednesday with a plea to the U.S. government and chemical companies to take responsibility for health problems linked to the wartime defoliant.

    "We ... demand that U.S. chemical companies pay compensation equal to their liability. We demand the U.S. government be held responsible for making contributions to overcome the consequences of toxic chemicals," a statement adopted at the end of the meeting read.

    More than 100 activists and from at least six countries including the United States, South Korea, Australia, New Zealand and Canada attended the two-day conference.

    U.S. aircraft sprayed about 21 million gallons of defoliant, mostly Agent Orange, over Vietnam from 1961-71 to destroy forest cover for communist troops.

    Agent Orange contains dioxin, a chemical blamed for health problems ranging from cancer to spina bifida and diabetes. The U.S. government claims there is no scientific evidence directly linking dioxin to the ailments.

    "For the future of mankind, we must prevent the use of Agent Orange from being repeated in any other country in the world," he said.

    Joan Newberry of Santa Fe, N.M., who served as a nurse in the U.S. Air Force during the war, said the conference was a good start to help Agent Orange victims around the world.

    "We hope we can develop international alliances that will strengthen our efforts to seek justice for victims of Agent Orange all over the world," she said.
    **GySgt [J.D.] MACK McKernan {Retired}**
    {VMO-6, Quang Tri} **{Mar69-Mar70}**

  • #2
    Agent Orange (and other defoliants)

    Bull79Dog:

    I have been involved in the defoliant controversy since September, 1971 and my first hospitalization at 23 for some bizzare afflictions. Maybe, just maybe this issue will be addressed if veterans can unite and demand action.

    I suggest every Nam vet read the book 'Vietnam Rain Agents' by Charles Kelley (available at Amazon.com/I have no connection with the book and do not know Mr. Kelley). Kelley does an excellent job of laying out the defoliant scenario. He does get a little emotional in some areas of the book but one can understand why when you finish reading the book.

    The problem that exists is the concentration on only Dioxin & Agent Orange by the VA, our government and the chemical companies. They have never addressed Agent White, Agent Blue or Agent Yellow, how these defoliants were used in mixtures and combinations of one or more of them and studies have never been conducted using Nam vets againsta general population with no exposure (whether civilian, veterans or military). The Ranch Hand study is a farce of epic proportion and of no scientific value at all.

    South Korea has completed a study comparing their vets against a general population group of civilians and military (an outside research team was used and all were blind studies - no one in the research group knew who were Nam vets or a control group member...this has never been done by our government). The results, absolutly startling. All US studies have been beholding to the VA or US government.

    I suggest every Nam vet read the book. I have forwarded copies to my elected representatives in Congress, attached a letter, sent an email telling them to expect the book and have also called their offices in Washington to inform them I expect them to read the book. I plan to follow up and verify if they have done so. Senator Shays (R, CT) and Dodd (D, CT) have already told me they will read the book as I spoke directly with them (they called me).

    We should attempt to get at least a few Nam vets in every state to do the same and to keep shaking the tree until they get a reply of some kind from their Congressional members. I'm willing to pitch in and buy some additional book but cannot afford to purchase the more than 600 we would need to make sure every member receives a copy.

    I would think that through Popasmoke, we could get at least two or three members from each state to help out. I'm willing to compile the list state by state of members who will help and will take care of any communications, paperwork, Congressional lists, addresses, phone numbers. I'm sure I can contact the publisher and get a discount on a large purchase of the books.

    Please let me know what you think of the idea (or anyone here) and suggestions are most welcome. I am in dead earnest and will do whatever is necessary to get the ball rolling but I would appreciate any help offered. The books are $23.00 each but I'm sure purchasing 600 to 700 books we can get the price down.

    S/F Gordon

    Comment


    • #3
      I worked 100 yards from the ramp area where they loaded the Ranch Hand aircraft with that crap. If they got a bit sloppy the wind would bring it to us. It would make my skin itch.

      So far no problems. That was thirty six years ago...

      Comment


      • #4
        Moe1942:

        Moe...consider yourself lucky. No one is saying there are those who have not been affected. Time in theater, amount of exposure, a persons genetic makeup and immune response are all factors to consider.

        If you look at the stats from independent studies though, there is no denying something is terribly wrong with hundreds of thousands of Nam vets that cannot be explained or defined by the medical community.

        Lets hope you remain healthy and live to a ripe old age.

        S/F Gordon

        Comment


        • #5
          Originally posted by GMello
          Moe...consider yourself lucky. No one is saying there are those who have not been affected. Time in theater, amount of exposure, a persons genetic makeup and immune response are all factors to consider.

          If you look at the stats from independent studies though, there is no denying something is terribly wrong with hundreds of thousands of Nam vets that cannot be explained or defined by the medical community.

          Lets hope you remain healthy and live to a ripe old age.

          S/F Gordon


          Thanks, I was there a year and they loaded up everyday. I'm on the agent orange register and get checked regularly by a non VA doc.

          I have given it a lot of thought over the years...

          Comment


          • #6
            Agent Orange site

            This looked interesting. Haven't taken time to go through it carefully.
            Order of the Silver Rose
            QUALIFYING DISEASES
            ******************************



            Please get a full yearly physical with CAT Scan!


            THE FOLLOWING DISEASES
            QUALIFY A VETERAN
            FOR THE SILVER ROSE AWARD




            All of the diseases on the VA's list of conditions linked to the herbicide exposure appear in the left-hand column. If there is a requirement that the disease appear within a certain period of time, the period of time appears in the right-hand column.



            DISEASES RECOGNIZED BY THE VA AS CONNECTED TO AGENT ORANGE EXPOSURE LENGTH OF TIME REQUIREMENTS: WHEN SYMPTOMS OF THE DISEASE HAVE TO APPEAR AND RESULT IN A DISABILITY (AT LEAST 10 PERCENT DISABLING) IN ORDER TO QUALIFY FOR BENEFITS.
            TYPES OF CANCER / TIME REQUIREMENT
            Cancer of the Bronchus No time requirement (veteran qualifies no matter when the disease first appears.)
            Cancer of the Larnyx No time requirement (veteran qualifies no matter when the disease first appears.)
            Lung Cancer No time requirement (veteran qualifies no matter when the disease first appears.)
            Cancer of the Trachea No time requirement (veteran qualifies no matter when the disease first appears.)
            Prostate Cancer No time requirement (veteran qualifies no matter when the disease first appears.)
            Hodgkin's Disease No time requirement (veteran qualifies no matter when the disease first appears.)
            Chronic Lymphatic Leukemia No time requirement (veteran qualifies no matter when the disease first appears.)
            Multiple Myeloma No time requirement (veteran qualifies no matter when the disease first appears.)
            Non-Hodgkin's Lymphoma No time requirement (veteran qualifies no matter when the disease first appears.)
            TYPES OF SOFT TISSUE SARCOMA TIME REQUIREMENT
            Adult Fibrosarcoma
            Alveolar Soft Part Sarcoma
            Angiosarcoma
            Clear Cell Sarcoma of Aponeuroses
            Clear Cell Sarcoma of Tendons
            Congenital Fibrosarcoma
            Dermatofibrosarcoma Protuberans
            Ectomesenchymoma
            Epithelioid Malignant Leiomyosarcoma
            Epithelioid Malignant Schwannoma
            Epithelioid Sarcoma
            Extraskeltal Ewing's Sarcoma
            Hemangiosarcoma
            Infantile Fibrosarcoma
            Leiomyosarcoma
            Liposarcoma
            Lymphangiosarcoma
            Malignant Fibrous Histiocytoma
            Malignant ganglioneuroma
            Malignant Giant Cell Tumor of the Tendon
            Sheath
            Malignant Glandular Schwannoma
            Malignant Glomus Tumor
            Malignant granular cell tumor
            Malignant Hemangiopericytoma
            Malignant Mesenchymoma
            Malignant Schwannoma with Rhabdomyoblastic differentiation
            Prolifertationg (systemic)Angiendotheliomatosis
            Rhabdomyosarcoma
            Synovial Sarcoma No Time Requirement
            (veteran qualifies no matter when sarcoma first appears)


            DISEASES OTHER THAN CANCER TIME REQUIREMENT
            Peripheral Neuropathy (acute or subacute)

            Within months of exposure to agent orange in Vietnam and cured within 2 years after symptoms first appear
            (Note: this time requirement is written so narrowly it appears to be impossible for any Vietnam veteran to qualify)
            Chloracne Within one year of the last day the veteran served in Vietnam.
            Porphyria Cutanea Tarda Within one year of the last day the veteran served in Vietnam.
            Diabetes

            Complications:


            Skin Conditions:
            diabetic dermopathy
            necrobiosis lipoidica
            diabeticorum
            diabetic blisters
            eruptive xanthomatosis

            Gum Disease:
            Oral Infection
            Fungal Infection
            Poor Healing
            Dry Mouth

            Eye Disease:
            Blindness
            Retinopathy
            Glaucoma
            Cataracts

            Kidney Disease

            Transplantation:
            Kidney
            Pancreas

            Neuropathy:
            Charcot’s joint
            Cranial neuropathy
            Autonomic neuropathy
            Compression mononeuropathy
            Femoral neuropathy
            Thoracic or lumbar radiculopathy
            Unilateral foot drop

            Cardiovascular Health:
            Heart Attack
            Stroke
            No Time Requirement
            (veteran qualifies no matter when Diabetes first appears)
            DISABILITIES IN CHILDREN OF VIETNAM VETERANS TIME REQUIREMENT
            Spina Bifida Child must have been conceived after veteran first arrived in Vietnam.
            BIRTH DEFECTS IN CHILDREN OF FEMALE VIETNAM VETERANS TIME REQUIREMENT
            Once final rules are issued, the birth defects that qualify for benefits will be listed on NVLSP's website and here. http://www.nvlsp.org
            Child must have been conceived after veteran first arrived in Vietnam.
            Deborah

            Comment


            • #7
              OK I'll bite

              Just what is "The Silver Rose Award?"
              /s/ray

              Raymond J. Norton
              1513 Bordeaux Place
              Norfolk, VA 23509-1313

              (757) 623-1644

              Comment


              • #8
                Beats me. Something I found on veterans' spouses chat board.

                Was going to crop out the title, but decided against it as they deserve credit for for assembling the info. Haven't had time to check it thoroughly, but that updated list seemed worthy of reposting.
                Deborah

                Comment


                • #9
                  Silver Rose Award

                  Found this on the web site: SILVER ROSE AWARD~! Hope this helps~! MACK

                  Honoring the Victims of Agent Orange

                  The Silver Rose Award consists of a Certificate, Award Card, Poster and Medal (shown immediately below) with an Orange and White neck-drape Ribbon.

                  Contact Us: fuzzyfrog@intouchmi.com Put "AO Flag" in subject line.

                  Direct all information and questions regarding The Order of The Silver Rose to ....

                  GARY CHENETT
                  National Director
                  PH: 810-714-2748
                  Email: fuzzyfrog@2fords.net

                  Or To

                  NANCY REKOWSKI
                  National Commander
                  PH: 814-965-5760
                  Email: nancyrekowski@hotmail.com

                  Over 3,000 Silver Rose Awards have been awarded to date.
                  Last edited by Bull79Dog; 02-24-2007, 17:23. Reason: AWARD spelt wront
                  **GySgt [J.D.] MACK McKernan {Retired}**
                  {VMO-6, Quang Tri} **{Mar69-Mar70}**

                  Comment


                  • #10
                    Interesting

                    Thanks. I hadn't seen the site, only the list I posted from the spouses' chat board.

                    Never heard of it before, but must admire the Lady who started it. Her Dad would be proud.
                    Deborah

                    Comment


                    • #11
                      Gordon,

                      Good idea about book. I am checking w/ local libraries to see if they have copies, if not I will ask them to "requisition" copies.

                      Maybe that Silver Rose organization can assist in this?
                      Deborah

                      Comment


                      • #12
                        AO spraying; areas and quantities

                        Must find K-paige's identity, many kudos for the links she has accumulated;
                        http://vietnamresearch.com/agento/spray.htmlAO spraying; areas and quantities
                        Deborah

                        Comment


                        • #13
                          Kelley's Book

                          Finally got it! Had library order it, came in and I know I must have my own.
                          Very good. Am amazed he had the stamina to finish it. My own health problems due to poisonings crop up from time to time and make it difficult to do anything requiring higher cognitve functioning.

                          Think it was this thread that I read about it. "Vietnam's Rain Agents Orange, White, and Blue and Agents of Mass Destruction" by Charles Kelley.

                          Thanks, Kelley, for having the fortitude, stamina, and courage to write it down. I know all about the fear of retaliation, thank you for your bravery long after your term to serve had passed. Our politicians must feel uncomfortable around you, with good reason.

                          "IT'S DIFFICULT TO GET A MAN TO UNDERSTAND SOMETHING, IF
                          HIS SALARY DEPENDS UPON HIM NOT UNDERSTANDING."
                          UPTON SINCLAIR
                          Deborah

                          Comment


                          • #14
                            I must point out that Kelley's premise that civilians have more rights to sue over toxic tort is true in theory, but in reality, it is very, very hard. Now if someone goes permanently horizontal, vegetable or worm fodder, and it can be proven causality was poison, that is a horse of a different color.

                            I live in the Chemical Corridor, and it is virtually impossible to find an attorney to take a case like that unless exposure was due to a train derailment or massive spill, can you spell C L A S S A C T I O N? I know because I tried to find an attorney, including the ones featured prominently in the news for handling toxic tort cases.

                            Must face it, regular citizens aren't treated any better than you guys, the dilemma is that y'all are promised care that you never receive.

                            Kelley's book is excellent and you can be sure any toxic tort attorney worth their weight will have a copy. Excellent book, excellent. Needs to be read w/ highlighter in hand or notepad.
                            Deborah

                            Comment


                            • #15
                              Conflicts of Interest in Chem and Mold Research

                              http://ntp.niehs.nih.gov/files/MoldC...forwwwFNL1.pdf.

                              NTP on mold, see above

                              February 28, 2007

                              David A. Schwartz, M.D.
                              Director
                              National Toxicology Program
                              National Institute of Environmental Health Sciences
                              P.O. Box 12233
                              Research Triangle Park, NC 27709
                              Fax: 919.541.2260

                              Dear Dr. Schwartz,

                              We are writing to express significant concerns with the
                              National Toxicology Program's (NTP) Center for the
                              Evaluation of Risks to Human Reproduction (CERHR)
                              management and review process for evaluating the
                              reproductive and developmental effects of chemicals. It has
                              recently come to our attention that CERHR is managed by a
                              private consulting firm, Sciences International (SI), a
                              company with historic ties to the tobacco industry and a
                              client base that appears to include manufacturers of
                              substances that might be subject to CERHR review, including
                              the chemical up for review on March 5, 2007, bisphenol A
                              (BPA). We think that the public would be very surprised to
                              learn that industry consultants are managing critical
                              public health agencies.

                              The ties between SI and industry raise important ethical
                              issues that we describe in detail below. The fundamental
                              question raised by the BPA case is whether or not
                              government health assessments should be managed by private
                              consulting firms with ties to the industry that
                              manufactures the chemicals under review. We are very
                              concerned that this relationship may influence the outcome
                              of the BPA assessment.

                              These concerns are heightened by the Conflict of Interest
                              policy document we received from Michael Shelby, the
                              director of CERHR. In contrast to the CERHR policy for
                              panel members who must disclose all potential conflicts of
                              interest, the CERHR policy for consultants, sent to us by
                              Mr. Shelby, states plainly that, "No specific restrictions
                              are placed on the contractor." [1] This seems to mean that
                              contractors with serious conflicts of interest would not
                              have to disclose them and, in fact, could oversee analyses
                              that could dramatically affect the future health and
                              wellbeing of the American public. We would very much
                              appreciate your clarification of this policy. Further, we
                              request that prior to the March 5, 2007 meeting, SI and its
                              employees disclose all potential conflicts of interest
                              relative to BPA. Absent such disclosure, the integrity of
                              the entire BPA review process will be in question.

                              In 1998, NTP established the Center for the Evaluation of
                              Risks to Human Reproduction (CERHR) to "serve as an
                              environmental health resource to the public and to
                              regulatory and health agencies," and to
                              provide "scientifically-based, uniform assessments of the
                              potential for adverse effects on reproduction and
                              development caused by agents to which humans may be
                              exposed" via "rigorous evaluations of the scientific
                              literature by independent panels of scientists." [2]

                              CERHR's mission is vital because five to ten percent of
                              couples experience fertility problems, up to five percent
                              of babies have birth defects, and a growing body of
                              scientific evidence shows that exposures to industrial
                              chemicals can impact reproduction and development. [3]

                              Environmental Working Group (EWG) was shocked to learn,
                              therefore, that CERHR — a government agency under the
                              auspices of the National Institutes of Health — is actually
                              being run by a private consulting firm known as Sciences
                              International (SI). To quote the SI website:

                              "The most significant project at our firm is the management
                              of the National Toxicology Program's Center for the
                              Evaluation of Risks to Human Reproduction, one of the
                              premiere institutions for evaluation of reproductive and
                              developmental health issues." [4]
                              This relationship is even more troubling because there are
                              serious conflicts of interest and ethical concerns
                              surrounding this contractor that involve apparent financial
                              ties with the chemical industry and non-disclosure of these
                              relationships.

                              On March 5, 2007 a CERHR expert panel is scheduled to
                              evaluate the reproductive hazards presented by bisphenol A
                              (BPA). This expert panel will be basing their decision on a
                              300-page document describing the hazards of BPA that was
                              prepared by Sciences International. BPA is a heavily used
                              industrial chemical that is integral to production of hard
                              plastics and is found in the liners of metal food cans and
                              in hard plastic containers. More than 200 animal studies
                              show that BPA is toxic at very low doses. [5] The Centers
                              for Disease Control has found BPA in 95 percent of people
                              tested at levels that raise health concerns sufficient to
                              warrant this major review by CERHR. [6] And the peer—
                              reviewed science suggests that BPA may be contributing to
                              increases in many adverse health conditions in the human
                              population including breast cancer, prostate cancer and
                              insulin resistance. [7-12]

                              Several ethical concerns surround SI's role in this
                              process, including the company's financial ties to the
                              chemical industry and their failure to disclose key
                              information in the BPA review that may affect the expert
                              panel's assessment of the chemical. These concerns are
                              discussed further below.

                              SI conflicts of interest. SI appears to have a close
                              working relationship with, and financial ties to, companies
                              that manufacture the chemicals SI is charged with reviewing
                              for CERHR. To our knowledge, SI has not disclosed these
                              ties. As one example, in 2004, Anthony Scialli, the SI
                              employee named as the lead SI manager of CERHR, co-authored
                              a scientific paper with an employee of Dow Chemical Company
                              on the critical issue of how animal test results can be
                              applied to human health risk. [13]. Dow is a major producer
                              of BPA. [14] The study was funded by the European Chemical
                              Industry Council. There appears to be no way for the public
                              to determine whether or not any SI clients are
                              manufacturers or major users of BPA or any other chemical
                              that may be reviewed by CERHR. SI notes on its website that
                              its clientele comprise "approximately 50% public sector and
                              50% private sector clients." [15] Yet while SI lists the
                              names of many of its public sector clients, SI's private
                              sector clients are identified only as "various companies,
                              trade organizations, and law firms." [16]

                              Scientists must sign conflict of interest forms before they
                              may serve on a CERHR panel. [17] But CERHR's Director
                              Michael Shelby indicates that "no specific restrictions are
                              placed on the contractor."[1] This policy is in stark
                              contrast to the disclosure procedures applied to CERHR
                              panel members, and is completely unacceptable. To earn the
                              public trust, SI must disclose all financial and research
                              ties that it has with any company or other entity that
                              might have even a potential conflict of interest with the
                              work carries out in its managing duty at the CERHR.

                              SI failure to investigate study funding sources. In its
                              review document on BPA, SI fails to disclose industry
                              funding sources and author affiliations for major studies
                              cited in the document. For example, on page 177 in the
                              document, SI states "[financial] support not indicated" for
                              several important studies finding no adverse effects from
                              BPA at low levels of exposure. [18] But, in fact, both
                              studies are authored by scientists who routinely perform
                              work for the chemical industry trade organizations: CEFIC-
                              the European Chemical Industry Council and SPI-the Society
                              of the Plastics Industry, both of which have member
                              companies who manufacture or use BPA. [19] A simple request
                              to these scientists would likely have revealed the source
                              of funding.

                              SI's failure to identify the source of funding for these
                              studies is more than just an oversight. A distinct pattern
                              in BPA test results, relative to funding source, has been
                              documented in the peer-reviewed literature, most notably in
                              a 2005 review published in the National Institutes of
                              Health journal Environmental Health Perspectives. This
                              analysis examined more than 100 peer-reviewed studies on
                              BPA and found a stunning relationship between funding
                              source and study outcome: 100% of industry-sponsored
                              studies found no adverse effects of BPA at low doses,
                              compared to just 4% of independent studies. [20] Given the
                              severe bias for industry-funded studies to find BPA "safe,"
                              funding sources for studies are a key piece of information
                              the CERHR expert panel should review in making
                              determinations on study utility. Without this information,
                              CERHR assessments are incomplete.

                              The CERHR expert panel must have thorough information on
                              study funding sources for the panel in order to make
                              informed decisions on study utility. SI has failed to
                              provide this.

                              SI failure to disclose key study limitations. In its review
                              of BPA studies, SI scientists fail to document known,
                              glaring design deficiencies that make it nearly impossible
                              for certain studies to detect BPA toxicity. Without this
                              information, in some cases the expert panel has issued
                              glowing endorsements of seriously flawed studies, including
                              a study [21] deemed by the expert panel to be "exceptional"
                              and "very useful," when in fact the researchers in this
                              study used resistant animals and animal feed that is known
                              to mask the toxicity of chemicals like BPA. To quote the SI
                              document: "This exceptional study is very useful for the
                              evaluation process, and will carry significant weight in
                              the evaluation of structural, histogenic, and fertility
                              endpoints." [22]

                              In another example, the expert panel found a study "very
                              useful in the evaluation" when, in fact, the National
                              Toxicology Program (NTP) had noted issues with the study
                              design that cast the findings into doubt, including the
                              quality of the feed, concerns with animal weight, and data
                              strongly suggesting that the particular experimental
                              animals used would be insensitive to BPA's effects. [20,
                              23, 24] SI did not note these concerns in its review.

                              The CERHR expert panel is asked to review the usefulness
                              and quality of literally hundreds of studies summarized in
                              the SI review. The panel members cannot feasibly review
                              each study individually, and therefore must rely heavily on
                              SI interpretations. Therefore, it is critical for SI to
                              thoroughly and accurate document study findings and
                              deficiencies. Their failure to do so in the case of these
                              key studies can inject critical bias into the review
                              process and severely inhibit the expert panel's ability to
                              make sound decisions.

                              SI's history as industry consultant. SI's history of
                              compromised ethics leads to deep concerns about its role in
                              managing CERHR chemical assessments. In September, 2006 the
                              journal Environmental Science & Technology (ES&T) detailed
                              SI's dealings with the tobacco giant RJ Reynolds and its
                              efforts to prevent the Environmental Protection Agency
                              (EPA) from tightening its regulation of a toxic pesticide.
                              [25] ES&T wrote that:

                              In December 1998, the U.S. EPA proposed several risk-
                              mitigation measures to protect workers handling phosphine —
                              a chemical for fumigating grain and other commodities. The
                              proposals included creating a buffer zone around fumigation
                              sites and notifying residents living within 750 feet. EPA
                              also proposed lowering the exposure threshold of phosphine
                              from 0.3 parts per million (ppm) to 0.03 ppm. Court
                              documents show that, to fend off regulations, RJ Reynolds
                              Tobacco Co. (RJRT) funded the Phosphine Coalition, which
                              successfully fought against the proposed changes. A
                              centerpiece of its strategy was hiring the consulting firm
                              Sciences International to lobby EPA and to write a study on
                              phosphine's toxicity.

                              The study was finally published in Risk Analysis in 2004.
                              Five people appear as authors on the paper: Betty Anderson
                              and two of her employees at Sciences International, and
                              Joel Seckar and Paul R. Harp, who are listed as members of
                              the Phosphine Coalition of Washington, D.C. The Phospine
                              Coalition does not have a street address, and the paper
                              does not note that Harp and Seckar are employed by RJRT.

                              In April 1999, officials with Sciences International met
                              with EPA staff to try to persuade the agency to halt the
                              proposed changes to phosphine regulations. A month later,
                              Anderson, Sciences International's executive director, sent
                              a memo to Seckar stating, "I believe that the approach with
                              the greatest likelihood of affecting EPA's position is to
                              prepare and publish in a peer-reviewed journal a scientific
                              paper or article that describes the current science on the
                              toxicity of phosphine." She continues, "Since I am
                              currently Editor-in-Chief of the international journal Risk
                              Analysis, perhaps the peer-review process could be
                              expedited, if we decide that it is the journal of choice."

                              At the end of 1999, RJ Reynolds released a report
                              highlighting the company's accomplishments. "R&D led the
                              Phosphine Coalition in addressing the scientific issues
                              involved when the Environmental Protection Agency (EPA)
                              proposed a new phosphine exposure standard," reads a
                              passage. Further along, the document states, "The efforts
                              of the Coalition saved RJRT many millions of dollars."
                              Clearly, serious questions are raised when a company with
                              this history is charged with running a government program
                              vital to the protecting public health.

                              SI involved in all aspects of running CERHR

                              It is clear that SI is deeply involved in all aspects of
                              CERHR, from selecting expert panel members, setting the
                              agenda for panel meetings, preparing the literature
                              reviews, and helping to draft the panel's reports. The
                              intimate and unusual relationship between the firm and
                              CERHR is extensively documented. For example:

                              CERHR's website describes the agency's structure as
                              follows: "Under the direction of Michael Shelby, Ph.D.,
                              Director, CERHR at NIEHS, scientific and support staff at
                              NIEHS and Sciences International, Inc. operate the Center
                              for the Evaluation of Risks to Human Reproduction (CERHR).
                              The Principal Investigator, Anthony Scialli, M.D., leads
                              the scientific and support staff at Sciences International,
                              Inc." [26]
                              The website of Sciences International states that: "The
                              most significant project at our firm is the management of
                              the National Toxicology Program's Center for the Evaluation
                              of Risks to Human Reproduction, one of the premiere
                              institutions for evaluation of reproductive and
                              developmental health issues." [27]
                              Although Dr. Scialli is the Vice President of SI, on
                              CERHR's on-line "contact" page his affiliation is listed
                              simply as "NTP Center for the Evaluation of Risks to Human
                              Reproduction." [28]
                              The Federal Register notice describing the creation of
                              CERHR explains that: "Scientists representing NTP agencies
                              and Sciences International, Inc., the contractor who will
                              support the Center, will constitute a core committee which
                              will provide the initial review for [panel member]
                              nominations, select the expert panel membership and
                              establish the meeting agenda." [29]
                              Expert panel and chemical nominations are sent directly to
                              the SI offices. Some CERHR workshop sessions take place
                              there as well. [30, 31]
                              For its work — and influence — SI gets paid heftily. The
                              firm's current contract, which runs from June 2003 through
                              June 2008, is worth $5,241,109. [32]

                              It is not uncommon for federal agencies to contract out
                              certain pieces of work to consulting firms or other
                              contractors. However, we are unaware of any other instance
                              in which nearly all of the functions of a pubic health
                              agency have been outsourced to a private entity. Please
                              provide us with details on when this has been done
                              previously and what the bidding parameters were.

                              It is also unclear whether the SI contract was put out to
                              bid. If it was put out for competitive bid, please provide
                              us with the bid notice and parameters. If it was a no bid
                              contract, please explain the rationale for this decision.

                              The arrangement between CERHR and SI raises serious ethical
                              questions that demand immediate disclosure of financial and
                              research ties to chemical manufacturers and other
                              industries that make or use substances under review by the
                              CERHR. These disclosures must apply both to individual SI
                              staff as well as the greater institution. Questions about
                              the objectivity and adequacy of this review process and the
                              reviewers must be resolved before a final decision on BPA
                              is reached.

                              It is also critical that CERHR incorporate into its final
                              decision on BPA critical input from an NIEHS-sponsored
                              expert workshop convened in November 2006. Forty-two
                              leading scientists on the effects of BPA at low doses
                              reviewed existing literature on the issue (see attached
                              list). The experts are producing a series of papers
                              addressing the very issues being reviewed by CERHR, but
                              expect to have only two of them completed by the March 5th
                              meeting. It is our understanding that these experts are
                              seeing a pattern of adverse effects at low levels of
                              exposure similar to those measured in humans by the Centers
                              for Disease Control and Prevention [33]. We are concerned
                              that CERHR is poised to make a decision on BPA prior to the
                              review of this important information.

                              Regulators, policy makers, and the general public
                              desperately need the "readily accessible, scientifically
                              authoritative" evaluations of potential reproductive and
                              developmental toxins that CERHR is supposed to be
                              providing. [34] But these evaluations will only serve to
                              help protect human and environmental health if they are
                              truly objective and trustworthy. Given that bisphenol A is
                              found in consumer products as diverse as baby bottles, food-
                              can linings and dental sealants, this is a question that
                              the public has a right — and a need — to know.

                              Sincerely,

                              Richard Wiles
                              Executive Director
                              Environmental Working Group

                              Cc: Mike Leavitt, Secretary, U.S. Department of Health and
                              Human Services
                              John Howard, M.D., M.P.H., J.D., LL.M., Director, National
                              Institutes of Occupational Safety and Health, Centers for
                              Disease Control, U.S. Department of Health and Human
                              Services
                              Andrew C. von Eschenbach, M.D., Commissioner, U.S. Food and
                              Drug Administration
                              William Slikker, Jr., Ph.D., Director, National Center for
                              Toxicological Research, U.S. Food and Drug Administration
                              Michael Shelby, Ph.D., Center for the Evaluation of Risks
                              to Human Reproduction, National Toxicology Program
                              Representative Henry Waxman, Chair, Committee on Oversight
                              and Government Reform
                              Representative Tom Davis, Ranking, Committee on Oversight
                              and Government Reform
                              Representative John Dingell, Chair, Committee on Energy and
                              Commerce
                              Representative Joe Barton, Ranking, Committee on Energy and
                              Commerce
                              Senator Barbara Boxer, Chair, Committee on Environment and
                              Public Works
                              Senator James Inhofe, Ranking, Committee on Environment and
                              Public Works
                              Robert E. Chapin, Ph.D., Chair, CERHR Expert Panel on BPA,
                              Pfizer, Inc.
                              Jane Adams, Ph.D., CERHR Expert Panel on BPA, University of
                              Massachusetts
                              Kim Boekelheide, M.D., Ph.D., CERHR Expert Panel on BPA,
                              Brown University
                              Michael A. Gallo, Ph.D., CERHR Expert Panel on BPA, UMDNJ —
                              Robert Wood Johnson Medical School
                              L. Earl Gray, Jr., Ph.D., CERHR Expert Panel on BPA, U.S.
                              Environmental Protection Agency
                              Simon W. Hayward, Ph.D., CERHR Expert Panel on BPA,
                              Vanderbilt University Medical Center
                              Peter S.J. Lees, Ph.D., CERHR Expert Panel on BPA, Johns
                              Hopkins University
                              Barry S. McIntyre, Ph.D., CERHR Expert Panel on BPA,
                              Schering Plough Research Institute
                              Michael J. McPhaul, Ph.D., CERHR Expert Panel on BPA,
                              University of Texas Southwestern Medical Center
                              Kenneth M. Portier, Ph.D., CERHR Expert Panel on BPA,
                              American Cancer Society
                              Teresa M. Schnorr, Ph.D., CERHR Expert Panel on BPA,
                              National Institute for Occupational Safety and Health
                              Sherry G. Selevan, Ph.D., CERHR Expert Panel on BPA, U.S.
                              Public Health Service (Ret.)
                              John G. Vandenbergh, Ph.D., CERHR Expert Panel on BPA,
                              North Carolina State University
                              Kendall B. Wallace, Ph.D., CERHR Expert Panel on BPA,
                              University of Minnesota
                              Susan R. Woskie, Ph.D., CERHR Expert Panel on BPA,
                              University of Massachusetts


                              References

                              [1] Personal communication with Michael Shelby. Received
                              summary of CERHR's conflict of interest policy on February
                              23, 2007 prepared by Shelby in response to EWG's request
                              for official copies of this policy on February 16, 2007.

                              [2] Center for the Evaluation of Risks to Human
                              Reproduction (CERHR). 2007. "About CERHR."
                              http://cerhr.niehs.nih.gov/aboutCERHR/index.html. Accessed
                              on February 13, 2007.

                              [3] Center for the Evaluation of Risks to Human
                              Reproduction (CERHR). 2007. "About CERHR."
                              http://cerhr.niehs.nih.gov/aboutCERHR/index.html. Accessed
                              on February 13, 2007.

                              [4] Sciences International. 2007. "Reproductive and
                              Environmental Health Practice Area."
                              http://www.sciences.com/practice-are...roductive.html.
                              Accessed on February 13, 2007.

                              [5] The Endocrine Disruptor Exchange. Accessed on February
                              23, 2007.
                              http://www.endocrinedisruption.org/products/bisphenol_a

                              [6] Calafat AM, Kuklenyik Z, Reidy JA, Caudill SP, Ekong J,
                              Needham L. 2005. Urinary concentrations of Bisphenol A and
                              4-Nonylphenol in a human reference population.
                              Environmental Health Perspectives 113:391-395.

                              [7] Munoz-de-Toro M, Markey CM, Wadia PR, Luque EH, Rubin
                              BS, Sonnenschein C, Soto AM. 2005. Perinatal exposure to
                              bisphenol-A alters peripubertal mammary gland development
                              in mice. Endocrinology 146(9):4138-47.

                              [8] Markey CM, Luque EH, Munoz-de-Toro M, Sonnenschein C,
                              Soto AM. 2001. In utero exposure to Bisphenol A alters the
                              development and tissue organization of the mouse mammary
                              gland. Biology of Reproduction 65(4):1215-23.

                              [9] Timms BG, Howdeshell KL, Barton L, Bradley S, Richter
                              CA, vom Saal FS. 2005. Estrogenic chemicals in plastic and
                              oral contraceptives disrupt development of the fetal mouse
                              prostate and urethra. Proc Natl Acad Sci 102(19):7014-9.

                              [10] Ho SM, Tang WY, Belmonte de Frausto J, Prins GS. 2006.
                              Developmental exposure to esradiol and bisphenol A
                              increases susceptibility to prostate carcinogenesis and
                              epigenetically regulates phsophodiesterase type 4 variant
                              4. Cancer Research 66(11):5624-32.

                              [11] Alonso-Magdalena P, Morimoto S, Ripoll C, Fuentes E,
                              Nadal A. 2006. The estrogenic effect of Bisphenol A
                              disrupts pancreatic §-cell function in vivo and induces
                              insulin resistance. Environmental Health Perspectives 114
                              (1):106-112.

                              [12] Vandenberg LN, Maffini MV, Wadia PR, Sonnenschein C,
                              Rubin BS, Soto AM. 2007. Exposure to environmentally
                              relevant doses of the xenoestrogen bisphenol-A alters
                              development of the fetal mouse mammary gland. Endocrinology
                              148(1):116-27.

                              [13] Carney EW, Scialli AR, Watson RE, DeSesso JM. 2004.
                              Mechanisms regulating toxicant disposition to the embryo
                              during early pregnancy: An interspecies comparison. Birth
                              Defects Res C Embryo Today. 72(4):345-60. Abstract
                              available at: http://www3.interscience.wiley.com/cgi-
                              bin/abstract/109867213/ABSTRACT

                              [14] US Environmental Protection Agency (USEPA). 2002.
                              Inventory Update Reporting. http://www.epa.gov/oppt/iur/

                              [15] Sciences International. 2007. "Clients."
                              http://www.sciences.com/clients/index.html. Accessed on
                              February 13, 2007.

                              [16] Sciences International. 2007. "Clients."
                              http://www.sciences.com/clients/index.html. Accessed on
                              February 13, 2007.

                              [17] Center for the Evaluation of Risks to Human
                              Reproduction (CERHR). 2007. CERHR Expert Panel Guidelines.
                              http://cerhr.niehs.nih.gov/aboutCERHR/guidelines.pdf.

                              [18] Center for the Evaluation of Risks to Human
                              Reproduction (CERHR). 2006. Draft NTP-CERHR report on the
                              reproductive and developmental toxicity of bisphenol A.
                              December 2006.
                              http://cerhr.niehs.nih.gov/chemicals/bisphenol/pubcomm-
                              bisphenol.html

                              [19] Frederick S. vom Saal. 2007. Comments on the report of
                              the expert panel on bisphenol A.
                              http://cerhr.niehs.nih.gov/chemicals/bisphenol/pubcomm/
                              vomsaal_response_BPA_Report.pdf

                              [20] vom Saal FS, Hughes C. 2005. An extensive new
                              literature concerning low-dose effects of bisphenol A shows
                              the need for a new risk assessment. Environ Health
                              Perspect. 113(8):926-33.

                              [21] Tyl RW, Myers CB, Marr MC, Thomas BF, Keimowitz AR,
                              Brine DR, Veselica MM, Fail PA, Chang TY, Seely JC, Joiner
                              RL, Butala JH, Dimond SS, Cagen SZ, Shiotsuka RN, Stropp
                              GD, and Waechter JM. 2002. Three-Generation Reproductive
                              Toxicity Study of Dietary Bisphenol A in CD Sprague-Dawley
                              Rats. Toxicol. Sci. 68: 121-146.

                              [22] Center for the Evaluation of Risks to Human
                              Reproduction (CERHR). 2006. Draft NTP-CERHR report on the
                              reproductive and developmental toxicity of bisphenol A.
                              December 2006.
                              http://cerhr.niehs.nih.gov/chemicals/bisphenol/pubcomm-
                              bisphenol.html

                              [23] National Toxicology Program (NTP). 2001. National
                              Toxicology Program's Report of the Endocrine Disruptors Low
                              Dose Peer Review. Research Triangle Park, NC:National
                              Toxicology Program.
                              http://ntp.niehs.nih.gov/ntp/htdocs/...DosePeerFinalR
                              pt.pdf

                              [24] Ashby J, Tinwell H, Haseman J. 1999. Lack of effects
                              for low dose levels of bisphenol A (BPA) and
                              diethylstilbestrol (DES) on the prostate gland of CF1 mice
                              exposed in utero. Regul Toxicol Pharmacol 30:156—166.

                              [25] Environmental Science & Technology Policy News. 2006.
                              Journals feel pressure to adopt disclosure rules. After an
                              inquiry by ES&T, three leading science societies say they
                              will now examine conflict-of-interest policies. September
                              20, 2006. http://pubs.acs.org/subscribe/journals/esthag-
                              w/2006/sep/policy/pt_disclosure.html

                              [26] Center for the Evaluation of Risks to Human
                              Reproduction (CERHR). 2007. "About CERHR."
                              http://cerhr.niehs.nih.gov/aboutCERHR/index.html. Accessed
                              on February 13, 2007.

                              [27] Sciences International. 2007. "Reproductive and
                              Environmental Health Practice Area."
                              http://www.sciences.com/practice-are...roductive.html.
                              Accessed on February 13, 2007.

                              [28] Center for the Evaluation of Risks to Human
                              Reproduction (CERHR). 2007. "Contact CERHR."
                              http://cerhr.niehs.nih.gov/contactus/index.html. Accessed
                              on February 13, 2007.

                              [29] Federal Register. December 14, 1998. Volume 63 (239):
                              68782. DOCID:fr14de98-73

                              [30] Federal Register. August 5, 1999. Volume 64 (150):
                              42707-42708. DOCID:fr05au99-108

                              [31] National Institute of Environmental Health Sciences.
                              1999. Center set up to evaluate evidence of chemical
                              threats to human reproduction. Press Jan. 6, 1999.
                              http://cerhr.niehs.nih.gov/news/press/pr1_6_99.html

                              [32] Office of Acquisitions, National Institute of
                              Environmental Health Sciences. Active Research and
                              Development Contracts as of Oct 12, 2006.
                              http://www.niehs.nih.gov/omamb/rcb/randdext.htm

                              [33] Calafat AM, Kuklenyik Z, Reidy JA, Caudill SP, Ekong
                              J, Needham L. 2005. Urinary concentrations of Bisphenol A
                              and 4-Nonylphenol in a human reference population.
                              Environmental Health Perspectives 113:391-395.

                              [34] Center for the Evaluation of Risks to Human
                              Reproduction (CERHR). 2007. "About CERHR."
                              http://cerhr.niehs.nih.gov/aboutCERHR/index.html. Accessed
                              on February 13, 2007.
                              Deborah

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