ABSTRACT In past studies evaluating whether health problems experienced by Vietnam veterans might be linked to wartime use of Agent Orange or other herbicides, a fundamental challenge has been a lack of information about the veterans’ level of exposure to these herbicides. To address that problem, researchers developed a model to assess the opportunity for herbicide exposure among these veterans. Using a geographic information system and a computerized database engine, the model makes it possible to link georeferenced data on herbicide spray paths with information about troop locations and calculate two different proximity-based exposure opportunity metrics. This report presents the conclusions and recommendations of an Institute of Medicine committee that was convened to provide guidance to the Department of Veterans Affairs (VA) about the best use of this herbicide exposure assessment model.
The committee concluded that the model’s approach of using an exposure surrogate based on individuals’ or military units’ proximity in space and time to herbicide spray paths is a reasonable one. It is an important improvement over the cruder yes/no exposure classification based on service in Vietnam that has been used in many past epidemiologic studies of the health of Vietnam veterans. However, the proximity-based exposure metrics inevitably have some unknown amount of misclassification and must be used and interpreted with caution. Sensitivity analyses should be done to determine the effect that the model’s assumptions have on
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Summary
ABSTRACT In past studies evaluating whether health problems
experienced by Vietnam veterans might be linked to wartime use
of Agent Orange or other herbicides, a fundamental challenge has
been a lack of information about the veterans’ level of exposure
to these herbicides. To address that problem, researchers devel-
oped a model to assess the opportunity for herbicide exposure
among these veterans. Using a geographic information system and
a computerized database engine, the model makes it possible to
link georeferenced data on herbicide spray paths with information
about troop locations and calculate two different proximity-based
exposure opportunity metrics. This report presents the conclusions
and recommendations of an Institute of Medicine committee that
was convened to provide guidance to the Department of Veterans
Affairs (VA) about the best use of this herbicide exposure assess-
ment model.
The committee concluded that the model’s approach of using
an exposure surrogate based on individuals’ or military units’
proximity in space and time to herbicide spray paths is a reason-
able one. It is an important improvement over the cruder yes/no
exposure classification based on service in Vietnam that has been
used in many past epidemiologic studies of the health of Vietnam
veterans. However, the proximity-based exposure metrics inevita-
bly have some unknown amount of misclassification and must be
used and interpreted with caution. Sensitivity analyses should be
done to determine the effect that the model’s assumptions have on
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PROXIMITY-BASED HERBICIDE EXPOSURE ASSESSMENT
the exposure assignments it generates, and other proximity-based
approaches with the potential of estimating exposure more accu-
rately should be explored. Moving beyond proximity-based expo-
sure measures would require additional data on herbicide fate and
transport, individual behavior, and pharmacokinetics, and some of
this information is not likely to be available.
To conduct epidemiologic studies using the exposure assess-
ment model requires data on when and where each veteran served
in Vietnam and on the veteran’s health outcomes. It is generally
possible to obtain useful data on individuals’ unit assignments and
unit locations, but the processes of gaining permission for access to
relevant military records and of collecting data for individuals are
likely to be administratively difficult for many researchers as well
as time consuming and costly.
Despite the shortcomings of the exposure assessment model
in its current form and the inherent limitations in the approach,
the committee agreed that the model holds promise for supporting
informative epidemiologic studies of herbicides and health among
Vietnam veterans and that it should be used to conduct studies.
The committee offers criteria that VA should draw on as a basis
for developing a request for proposals, and it recommends that VA
work with the Department of Defense and the National Archives
and Records Administration to facilitate access to and interpreta-
tion of military records for use in the studies.
B
etween 1962 and 1971, several herbicides—most notably the
product known as Agent Orange—were used in Vietnam by U.S.
forces and their allies for defoliation of forest areas, destruction of
crops, and control of vegetation around the perimeters of troop encamp-
ments. Since then, many studies have been conducted to examine whether
health problems experienced by some Vietnam veterans might be linked
to their wartime exposure to any of these herbicides or to a particular
contaminant—2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD)—that was
present in some of them.1
A fundamental and persisting challenge in these studies has been to
determine the amount of herbicide in the environment in Vietnam, identify
military personnel who were exposed to the herbicides, distinguish them
from personnel who were not exposed, and estimate the herbicide or dioxin
dose that exposed individuals received. In an effort to improve exposure
assessment for Vietnam veterans, a group of academic researchers has
1Throughout this report the term “herbicide” encompasses the TCDD contaminant unless
specifically stated otherwise.
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SUMMARY
developed an herbicide exposure assessment model. This report presents
the conclusions and recommendations of the Institute of Medicine (IOM)
study committee that was convened to provide guidance to the Department
of Veterans Affairs (VA) on the use of this model.
The committee found that assignment of exposure based on proximity
to herbicide spraying offers the possibility of important improvement in
the classification of exposure over most earlier approaches, although there
are inherent limitations in the model. Using the model to assess herbicide
exposure in epidemiologic studies may permit observation of associations
between herbicide exposure and health effects in the Vietnam veteran popu-
lation that were not identifiable in previous studies. The committee recom-
mends further sensitivity analyses to provide a better understanding of
the model’s strengths, limitations, and uncertainties and also recommends
exploration of opportunities to refine the model’s estimation of exposure.
STUDY BACKGROUND
U.S. military personnel were present in Vietnam throughout the 1962–
1971 period when herbicides were in use for defoliation and crop destruc-
tion. Among the several different herbicides used, Agent Orange and Agent
White were the principal defoliants and Agent Blue was widely used for
crop destruction.2 Available data indicate that 95 percent of the herbicide
used in Vietnam was applied by fixed-wing aircraft as part of Operation
Ranch Hand. Herbicides were also applied by helicopters and with ground-
spraying apparatus. Records for Operation Ranch Hand are considered to
be relatively more complete than those for other herbicide use.
In 1991, Congress requested that IOM committees periodically review
the scientific evidence to assess whether associations may exist between
exposure to the herbicides (or the TCDD contaminant) used in Vietnam
and health outcomes. Congress originally sought from the IOM reviews
an assessment of the increased risk that Vietnam veterans would have for
conditions found to be associated with herbicide exposure. None of the
review committees have been able to make quantitative assessments, in
part, because credible direct or proxy measurements of Vietnam veterans’
herbicide exposure have not been available.
The first of the IOM’s biennial reviews included a recommendation
that this problem be addressed by an attempt to develop an exposure
reconstruction model that could be considered valid for use in epidemio-
logic studies of veterans. VA responded to this recommendation by com-
2 Agent Orange was a combination of 2,4-dichlorophenoxyacetic acid (2,4-D) and 2,4,5-
trichlorophenoxyacetic acid (2,4,5-T). Agent White was a combination of 2,4-D and picloram.
Agent Blue was cacodylic acid and sodium cacodylate. TCDD was a contaminant of 2,4,5-T.
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PROXIMITY-BASED HERBICIDE EXPOSURE ASSESSMENT
missioning the IOM to assess the scientific issues that a research proposal
would need to address, to oversee the selection of a contractor to conduct
the work, to monitor progress during the course of the contract, and to
evaluate the product produced by the contractor. The contract for the work
was awarded in 1998 to researchers at the Columbia University Mailman
School of Public Health (Jeanne Mager Stellman, Ph.D., principal investiga-
tor), who produced the proximity-based exposure assessment model that is
the focus of this report.
STUDY CHARGE
The Committee on Making Best Use of the Agent Orange Exposure
Reconstruction Model was convened in 2007 to advise VA on the best
ways to employ the herbicide exposure assessment model in the evaluation
of the long-term health effects of veterans’ wartime exposure to herbicides.
VA requested that the committee consider several factors: the relevant IOM
recommendations for evaluating such a model; approaches for evaluating
the exposure model using existing data on health outcomes associated with
herbicide or dioxin exposure among Vietnam veterans; the availability,
quality, and usefulness of existing information on Vietnam veterans, includ-
ing data on troop locations and health outcomes for diseases commonly
associated with herbicide exposure as well as those not currently linked to
such exposures; and how such information might be used in epidemiologic
studies using the exposure assessment model. The committee was also asked
to consider the role of epidemiologic studies of Vietnam veterans conducted
using the new model in informing the IOM’s biennial evaluation of evidence
on the association between herbicide exposure and health outcomes. VA’s
interests included advice on planning future research using the model, guid-
ing researchers to the potentially most fruitful areas of study, and alerting
researchers to the challenges in doing studies using the model.
Despite the name of the committee, it is important to note that the
herbicide exposure assessment model that was reviewed is not an exposure
reconstruction model. To the committee, “exposure reconstruction” sug-
gests the possibility of arriving at a retrospective estimate of the quantity
of herbicide that individuals or groups were exposed to, or even the dose
they might have received. Instead, the model produces metrics based on
proximity to herbicide spraying that are only surrogates for exposure.
Furthermore, the committee was not charged with conducting analyses
using the exposure assessment model or with conducting an assessment of
the scientific evidence on associations between any specific health effects
and exposure to herbicides used in Vietnam.
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SUMMARY
AN EXPOSURE ASSESSMENT HIERARCHY
The committee viewed the Stellman team’s exposure assessment model
in the context of an exposure assessment hierarchy for herbicide spraying
in Vietnam (see Figure 3-1). At the simplest level, “exposure” is defined
based on a veteran’s presence or absence in Vietnam during the period of
herbicide spraying. Measures of exposure at the second level are based on
information on the location, timing, and volume of herbicide spraying com-
bined with information on the location in space and time of individuals or
military units. At the third level, proximity-based exposure metrics might
be refined by the incorporation of more detailed data or models for the
fate and transport of herbicides in the environment, such as spray drift
models, estimates of the proportion of the sprayed herbicide that reached
the ground, or consideration of secondary transport of the herbicides or the
TCDD contaminant in the environment. The fourth level of the hierarchy
would require data on individual-level interactions with the environment
(e.g., dermal exposure to soil, consumption of local food) to better estimate
personal exposures and permit examination of differences among units
or individuals present at the same places and times. At the fifth and most
highly refined level, information on pharmacokinetics would be needed to
estimate the doses of a toxic compound that individuals receive.
The Stellman team’s model operates primarily at the second level of
this hierarchy, relating the location of military units in time and space
to the timing, location, and volume of herbicide spraying. Understand-
ing this aspect of the model is necessary in order to accurately evaluate
its strengths and weaknesses and to advise future researchers about its
appropriate use.
A TOOL FOR HERBICIDE EXPOSURE ASSESSMENT
The Stellman team developed a geographic information system (GIS)
and the Herbicide Exposure Assessment–Vietnam (HEA-V), which is a
computerized database engine that facilitates the linking of disparate geo-
referenced data as well as the calculation of two exposure opportunity
metrics at the spatial scale of approximately 1 square kilometer.
The “hits” metric is based on an individual’s or a unit’s presence at a
given location within a specified distance from a spray path at the time of
a spray mission. Hits are calculated for each cell in the GIS grid that lies
within 0.5, 1, 2, or 5 kilometers of a spray path. The other metric is the
Exposure Opportunity Index (EOI), which factors in both direct exposure
and an estimate of indirect exposure to residual herbicide from spray-
ing that occurred before an individual’s or a unit’s entry into a location.
The EOI calculations incorporate data on the quantity of herbicide sprayed,
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PROXIMITY-BASED HERBICIDE EXPOSURE ASSESSMENT
the distance from the spray path, the time since spraying, and an environ-
mental half-life. Hits and EOIs can be calculated for a specific location or
for military units or individual military personnel when their location his-
tories are provided.
CONSIDERATIONS IN ASSESSING HERBICIDE EXPOSURE IN
VIETNAM FOR EPIDEMIOLOGIC STUDIES
The committee’s assessment was guided by four primary considerations.
First, it was essential to be clear about the nature of the exposure assess-
ment model and what it does and does not claim to do. The committee
approached the model as a means of generating a quantitative representa-
tion of opportunity for herbicide exposure, acknowledging that it could not
provide sophisticated estimates of individual dose or exposure levels.
Second, the committee gave careful consideration to the information
needed to use the model. This included gaining an understanding of the
strengths and limitations of data on herbicide spraying, troop locations, and
health outcomes. Issues of access to and usability of these data were also
important. Although attention in the past has often focused on TCDD, the
spraying database includes information on all herbicides for which records
were available, and the committee made its assessment from this broader
perspective.
Third, the committee considered whether the model “works,” that is,
whether it locates spraying and troops accurately (opportunity for expo-
sure) and whether doing so is related to actual exposure (through com-
parisons with other sources of information on exposure, such as blood
levels or environmental samples). Because environmental epidemiology
often advances through successive approximations of exposure and not
necessarily by applying the standard of absolute accuracy, the utility of the
model is defined in part by the methods it improves upon.
Fourth, with the nature of the model and its metrics clearly in mind,
the committee considered the potential contributions and pitfalls of using it
in epidemiologic studies. Of particular interest in these deliberations were
the potential to study Vietnam veterans directly, the degree to which expo-
sure classification might be improved if the model were to be used, and the
appropriate interpretation of the results of any such studies.
ASSESSMENT OF THE MODEL AND ITS EXPOSURE METRICS
The committee considered it necessary to assess the strengths and
weaknesses of the Stellman team’s approach to herbicide exposure assess-
ment before commenting on the best use of the model. This initial assessment
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SUMMARY
focused on (1) the basic data inputs on geography and herbicide spraying,
(2) the exposure metrics of hits and EOI, and (3) the assumptions regarding
the effects of distance from spraying in time and space that are incorporated
into the calculation of the EOI.
Infrastructure for Proximity-Based Exposure Measures
The committee concluded that the Stellman team’s approach of using
an exposure surrogate based on individuals’ or military units’ proximity in
space and time to herbicide spray paths is a reasonable exposure assess-
ment strategy. This approach is an important improvement over the cruder
exposure classification based on service in Vietnam that has been used in
many past studies of the health of Vietnam veterans.
The databases and GIS were found to provide a useful infrastruc-
ture for estimating proximity-based surrogates of exposure to herbicides
in Vietnam. However, data on spraying by fixed-wing aircraft are more
complete than the data for spraying by ground equipment or helicopters.
As a result, the model is currently better suited to examining proximity to
fixed-wing spraying. Even so, it is important for the potential contribution
of herbicide exposures from helicopter and ground spraying to be taken
into consideration in planning and interpreting studies, recognizing that
sources of exposure other than from fixed-wing aircraft could introduce
misclassification in the rank-order of exposure assignment.
In addition, given the significant uncertainties in the levels of TCDD
contamination in the herbicides used in Vietnam, proximity-based exposure
models may be better suited to studies of the health effects of herbicides for
which the active ingredients were consistent over time, such as 2,4-D and
2,4,5-T, rather than TCDD. Should researchers want to distinguish between
proximity to Agent Orange and proximity to Agent White or Agent Blue,
for example, it is possible to generate separate exposure opportunity values
for each agent using the Stellman team’s model.
The committee concluded that the proximity-based exposure metrics
of hits and EOI have value in that they move in a favorable direction along
the exposure assessment hierarchy described above. However, the methods
by which the hits and EOI scores are calculated have the potential for
exposure misclassification of unknown magnitude, and so these metrics
must be used with caution. Other proximity-based approaches to estimating
exposure may be more accurate and should be explored using the existing
GIS. Moving beyond proximity-based measures would require additional
data on meteorologic conditions, herbicide fate and transport, individual
behavior, and pharmacokinetics.
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PROXIMITY-BASED HERBICIDE EXPOSURE ASSESSMENT
Testing and Refining Herbicide Exposure Assessment
The Committee concluded that factors influencing the environmental
fate and transport of the herbicides that were not incorporated into the cur-
rent version of the Stellman team’s model (e.g., width of the spray swath,
concentration of contaminants, primary and secondary drift, soil condi-
tions, initial and remaining canopy, and photodegradation) are likely to
have affected exposure to herbicides and their contaminants. Incorporating
these phenomena into an exposure model could possibly reduce exposure
misclassification, but it would require additional data that may or may
not be available. Furthermore, the resolution of the Universal Transverse
Mercator (UTM) system used in the military records and the approxi-
mately 1-square-kilometer resolution of the Stellman team’s GIS grid map
of Vietnam limits to some extent the benefits of adding fine-scale fate and
transport modeling.
The committee emphasizes that, regardless of the exposure model used,
sensitivity analyses are necessary to determine the impact of the model’s
assumptions on the exposure assignments it generates. In addition, the
committee concluded that it is not feasible to validate the exposure scores
produced by the Stellman team’s model—or any other proximity-based
model—by comparisons with biomarkers or soil samples because of the
passage of time and the unavailability of archived environmental or bio-
logical samples.
AVAILABILITY AND ACCESSIBILITY OF DATA ON VETERANS
The Stellman team’s herbicide exposure assessment model starts from
a data infrastructure that focuses on the timing, location, and content
of herbicide spraying in Vietnam and the software tools for calculating
exposure metrics. To generate exposure metrics that can be used in epide-
miologic studies, this infrastructure must be supplemented with data on
when and where military personnel served in Vietnam and on their health
outcomes.
Working with the Joint Services Records Research Center at the Depart-
ment of Defense (DoD) and with records held by the National Archives and
Records Administration (NARA), the Stellman team has assembled loca-
tion data for many of the military units that moved infrequently during the
time they served in Vietnam (i.e., stable units) as well as for some combat
units, which moved frequently. Conducting a person-based study requires
the further step of identifying the individuals who served in these units and
gaining access to their military records. However, access to this information
is constrained by privacy laws and is especially challenging for researchers
who are not affiliated with DoD or VA.
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SUMMARY
The committee concluded that it is generally possible to obtain useful
data on individuals’ unit assignments and unit locations. Locations for
most stationary units have already been catalogued, and it appears feasible
to gather adequate location information for mobile troops. However, the
processes of gaining permission for access to relevant military records and
of collecting data for individuals are likely to be administratively difficult
for many researchers, as well as time consuming and costly. Assistance
from experts in the location and interpretation of Vietnam-era military
records is likely to be essential for the effective collection of data from these
sources.
Epidemiologic studies will also require assembling mortality or mor-
bidity data for Vietnam veterans. With appropriate identifying informa-
tion, mortality data for Vietnam veterans are readily and reliably available
through the National Death Index and the Social Security Administration’s
Death Master File. Mortality data can also be obtained from VA’s Benefi-
ciary Identification and Record Locator Subsystem (BIRLS), but access to
this database is more limited.
Obtaining morbidity data presents greater challenges. VA has several
databases that could contribute information about the health status of some
veterans, but only about 20 percent of Vietnam veterans are receiving care
from the VA, and access to VA data is typically restricted to VA researchers.
However, as more Vietnam veterans reach age 65 and become eligible for
Medicare, it will be possible to use Medicare records to conduct morbidity
studies. Researchers could also explore other resources such as state cancer
registries and hospital discharge datasets.
The committee notes that the Air Force Ranch Hand personnel and
Army Chemical Corps personnel are two groups of veterans that are not
suitable study populations when the Stellman team’s model is to be used,
even though their exposures to herbicides are likely to be among the high-
est of all veterans. Most of their herbicide exposures were a direct result
of duties that required handling or applying herbicides. By contrast, the
model is designed to assess the exposure opportunity that would result from
unintended proximity to herbicide spraying.
EPIDEMIOLOGIC STUDIES USING THE
HERBICIDE EXPOSURE ASSESSMENT MODEL
Despite recognizing shortcomings in the exposure assessment model in
its current form and inherent limitations in the proximity-based approach,
the committee concluded that the assessment model holds promise for
contributing to informative epidemiologic studies of herbicides and health
among Vietnam veterans and that it should be used to conduct such
studies.
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0 PROXIMITY-BASED HERBICIDE EXPOSURE ASSESSMENT
Two key considerations led to this conclusion. First, the exposure
assessment model is applicable to the population of ultimate interest,
namely Vietnam veterans. No other group has the confluence of exposures
and exposure circumstances experienced by the Vietnam veterans, so given
an adequate model, there is inherent value in asking the question in this
group.
Second, many previous studies of this population have been severely
limited with respect to exposure assessment. A more accurate, if still imper-
fect, method should increase the specificity of exposure classification and
may permit observation of associations between herbicide exposure and
health effects in the Vietnam veteran population that were not identifiable
in previous studies.
The committee also concluded that the ongoing work by VA investiga-
tors is constructive in characterizing the logistical challenges and magnitude
of effort needed to apply the Stellman team’s herbicide exposure assessment
model. However, the committee views this work as too limited and insuf-
ficiently accessible to the broader research community to constitute, in
isolation, the best use of the model.
Two types of study design were judged to be the most promising for
application of the model. One approach is a cohort study that would start
from military units and identify individual veterans who served in those
units. Units might be selectively sampled based on their exposure potential.
The other approach suggested by the committee is to build on large cohorts
already assembled and pursue nested case-control studies of outcomes of
interest within those cohorts. Either approach would require assembling
location histories for individual study subjects.
Efforts to validate the model solely by examining existing data on
health outcomes associated with herbicide exposure are of limited value. If
positive, such studies would add support to the model’s potential value, but
if negative, the model’s value is not disproved because the levels of exposure
may be lower than would cause adverse health effects or the study’s power
may be insufficient to address the question adequately.
Studies of veterans based on the exposure assessment model should
include analyses to assess how sensitive an estimated association between
the exposure opportunity metric and specific health outcomes is to different
parameters and sources of uncertainty in the exposure assessment measure.
Sensitivity analyses that summarize the variability in the model’s exposure
metrics under different assumptions underlying the exposure opportunity
model will provide ranges and distributions of exposure opportunity metrics
(hits or EOI) that may be included in statistical estimates, such as rate ratios
and logistic regression parameters. In this way, researchers can offer a range
or distribution of the estimated risks associated with the exposure and so
illuminate the underlying uncertainty in the assumptions of the model.
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SUMMARY
In order for other researchers to benefit from such analyses as well as
any refinements or extensions of the model, the committee encourages those
who conduct studies applying the exposure assessment model not only to
address meaningful epidemiologic questions but also to follow the example
set by the Stellman team in contributing publicly accessible building blocks
for reanalyses and refinements by others. Work that investigators—including
VA researchers—carry out to determine unit locations and calculations used
to arrive at exposure indices should be documented and made available,
ideally through the Internet, to enable others to repeat the analyses. Any
extension or refinement of the model and associated sensitivity analyses
should also be documented so that others can evaluate and build upon the
work.
RECOMMENDATIONS
The committee’s conclusions from its consideration of the Stellman
team’s herbicide exposure assessment model led it to make the following
recommendations:
1. VA should sponsor epidemiologic studies of Vietnam veterans that
take into account the criteria below regarding the appropriate
characteristics of informative research on herbicide exposure and
health outcomes in this population. VA should draw on the criteria
as the basis for developing a request for proposals.
Specifically, to make the best use of the exposure assessment model,
epidemiologic studies of Vietnam veterans should have the follow-
ing characteristics:
a. The study population should be broadly representative of Viet-
nam veterans, with care taken to include sufficient numbers of
study participants with relatively higher exposure.
b. A broad range of health outcomes should be considered, not
just those that are suspected of being related to herbicide expo-
sure. Where feasible, morbidity should be studied in addition
to mortality.
c. The health data should be as complete and up-to-date as
possible.
d. The study should have sufficient statistical power to address
the range of health outcomes of concern.
e. To isolate the effects of herbicide exposure, potential con-
founding factors need to be carefully addressed in the study
design or the analytic approach.
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PROXIMITY-BASED HERBICIDE EXPOSURE ASSESSMENT
f. Analyses should be conducted to evaluate how sensitive the
estimated associations between exposure opportunity and
health outcomes are to the uncertainty in the exposure oppor-
tunity metrics and to varying approaches to estimating her-
bicide exposure, possibly including alternative approaches to
exposure assignment as discussed in Chapter 3.
g. Opportunities to conduct research using the exposure assess-
ment model should be open to investigators beyond the VA sys-
tem to allow for the benefits of engaging the broader research
community and to enhance public acceptance and credibility.
2. In support of the recommended epidemiologic studies, VA should
work with DoD and NARA to
facilitate health research uses of military records that are sub-
•
ject to access barriers arising from privacy laws, and
arrange for assistance from DoD and NARA staff with appro-
•
priate expertise to aid researchers in the location and interpre-
tation of military records for health research uses.
RESEARCH OPPORTUNITIES
From its review of the Stellman team’s model, the committee also iden-
tified two areas where it urges further investigation.
First, efforts should be made to improve and refine the Stellman team’s
model by exploring alternative formulations of the proximity-based expo-
sure metrics and by incorporating alternative or additional model param-
eters that account for more aspects of herbicide fate and transport in the
environment. Further development of the model will require an assessment
of the additional data needed and the availability of these data.
Second, the sensitivity of the Stellman team’s model’s results to changes
in parameter values should be assessed systematically. The committee spe-
cifically urges attention to the effects of potential inaccuracies in the data on
the location of herbicide application or troop presence. It is also important
to investigate, especially with any attempt to add refinements to the existing
model, the effect of assumptions on factors such as spray swath, the con-
centration of the TCDD contamination, primary and secondary drift, soil
conditions, initial and remaining canopy, and photodegradation of sprayed
herbicide. Although the committee concluded, based on the information it
reviewed, that direct validation of the accuracy of exposure assignment is
not feasible, it encourages efforts to quantify the degree of accuracy and
incorporate those estimates into the sensitivity analysis.