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                    <text>item n Number

°5351

Alltbor

Jenkins, Dale W.

CorperatB Author

United States Environmental Protection Agency (EPA),

D Not Scanned

Report/Article TltlB Project Summary: Biological Monitoring of Toxic Trace
Elements

Journal/Book Title
Year

1981

Month/Day

February

Color

D

Number of Images

°

Descripton Notes

EPA-eoo/sa-so-ogo

Tuesday, March 05, 2002

Page 5351 of 5363

�United States
Environmental Protection
Agency

Environmental Monitoring
Systems Laboratory
Las Vegas NV 89114

Research and Development

EPA-600/S3-80-090

Feb. 1981

Project Summary

Biological Monitoring
of Toxic Trace Elements
Dale W. Jenkins

The contamination of plants,
animals, and humans by toxic trace
elements poses a continuing and
increasing threat to our environment.
Of 20 trace elements that are known
to be toxic, this report identifies 14 as
particularly noxious because of their
widespread production and use, and
subsequent discharge and persistence
in the environment.
These 14
elements of particular concern are
antimony, arsenic, beryllium, boron,
cadmium, chromium, cobalt, copper,
lead, mercury, nickel, selenium, tin,
and vanadium.
Trace elements are known to
accumulate in plants and animals. An
a n a l y s i s of data about their
accumulation, together with a review
of the organisms used for monitoring
environmental gradients of trace
elements, resulted in an extensive list
of potential biological monitoring
organisms.
Volume 1 of the two volumes in this
report treats the problems, needs,
selection, and use of living organisms
for monitoring. The author also
reviews global and national integrated
exposure assessment programs and
environmental and food surveillance
programs. Volume 2 contains
comprehensive data about bioaccumulation and bioconcentration of
these 14 trace elements.
This Project Summary was developed by EPA's Environmental Monitoring Systems Laboratory, Las Vegas,
Nevada, to announce key findings of
the research project that is fully docu-

mented in a separate report of the
same title (see Project Report ordering
information at back).

Trace Element Selection
Before selecting the toxic elements
for study, data were compiled about the
toxic effects on humans, and major
exposure routes and pathways; relative
abundance and concentrations,
production, and use; emissions into the
environment for each trace element;
and, the major sources and pathways of
each trace element into plants and
animals. After the data compilation, the
following selection criteria were used to
identify toxic trace elements:
1. The elements are toxic to humans
and/or their food organisms;
2. The elements are fairly common
and widespread;
3. The exposure to the elements is
sufficient to cause a hazard, or
potential hazard;
4. The elements are persistent in the
environment; and
5. The elements are becoming more
important because of increased
production and/or use.
On the basis of the criteria, the
following 14 trace elements or
metalloids were selected: antimony,
arsenic, beryllium, boron, cadmium,
chromium, cobalt, copper, lead,
mercury, nickel, selenium, tin, and
vanadium.

�Trace Element Toxicity
Certain chemical forms of each of the
14 trace elements that were selected
for evaluation are dangerous to humans
and other biological organisms. A
summary of the toxicity of the element,
its most toxic compounds, food hazards,
and air pollution hazards, and primary
route of entry into humans is presented
in Table 1. When ingested, antimony,
arsenic, beryllium, cadmium,
chromium, lead, mercury, selenium,
and tin are toxic; when injected, most of
the 14 elements are toxic. Some of the
trace elements—arsenic, cadmium,
lead, and mercury—function as
cumulative poisons; others, including
beryllium, chromium, nickel, and
arsenic, are carcinogenic. Cadmium
and lead shorten life and cause

Table 1.

neurological disruptions in experimental animals; at low concentrations,
copper, mercury, boron, tin, cobalt, and
nickel are toxic to certain species and
have been used as biocides for certain
plants and animals.
Of the 14 elements with known degrees of toxicity to humans, only five
presently constituteanimportantthreat
to humans. These are, in order of their
importance, lead, cadmium, mercury,
arsenic, and nickel.

Elements in Earth's Crust

Toxic Trace Elements in the
Environment
Data on abundance, production,
uses, environmental emissions and

The abundance of the selected trace
elements in the earth's crust, in dry soil,
in the ocean, and in freshwater is
s u m m a r i z e d in Table 2. This
information is related to base lines and
b a c k g r o u n d c o n c e n t r a t i o n s per
element in non-polluted areas. Toxic

Toxicity of selected trace elements
Toxicity
to humans

Antimony

dispersion, sources and pathways to
humans are important to establish the
extent of environmental pollution and
the priorities for each trace element.
This information is essential in order to
select appropriate biological monitoring
organisms, the type of monitoring
required, and the number and
geographic distribution of monitoring
sites.

Most toxic
compounds

toxic

Air pollution
hazard

Primary route of entry
into humans

halides and
stibnine

L

low potential hazard

occupational exposure;
therapeutic use; food

As2O3, arsine

Arsenic

Food hazard

hazard

hazard

occupational exposure;
poisoning
occupational inhalation

Beryllium

toxic

all

low

potential hazard

Boron

low

borane

none

unknown

Cadmium

toxic

all

hazard, L

hazard

occupational inhalation;
food

Chromium

S

hexavalent Cr

low

none

occupational inhalation

Cobalt

low

hazard

none

Copper

low

—

none

occupational exposure

Lead

toxic

all, especially
tetraethyl Pb

hazard, L

hazard

occupational exposure

Mercury

toxic

methyl Hg
and alkyl Hg

hazard

hazard

occupational exposure;
food

S

nickel carbonyl

low

hazard

occupational exposure

hazard

none

occupational exposure

L

none

occupational exposure;
food

none

none

occupational exposure

Nickel
Selenium
Tin

Vanadium

toxic

S
low

triethyltin
tetraethyltin

S—Specific compounds toxic or highly toxic, but element moderate to low toxicity.
L—Leaching from container contaminates food.

�Table 2.

Abundance of trace elements in the environment
Igneous rocks,
earth's crust
Ippm)

Antimony
Arsenic
Beryllium
Boron
Cadmium
Chromium
Cobalt
Copper
Lead
Mercury
Nickel
Selenium
Tin

Vanadium

0.2
1.8
2.8

10.0
0.2

100.0
25.0
55.0
12.5
0.08
75.0
0.05
2.0

135.0

Soil (dry)
(ppm)
2.0-10.0
6.0
6.0

10.0
0.06
100.0

0.00033
0.003
0.0000006
4.6

0.00011
0.00005
0.00027
0.003
0.00003
0.0001
0.0054
0.00009
0.003
0.002

8.0

20.0
10.0
0.03
40.0
0.2

10.0
100.0

trace abundance in the earth's crust for
the 14 selected elements ranges from
0.08 to 135.0 ppm and 0.03 to 100.0
ppm in dry soil. Toxic trace abundance
in the ocean ranges from 0.0000006 to
4.6 ppm, and in freshwater from
0.00004 to 0.02 ppm. These estimates
show the relative abundance of toxic
trace elements when compared with
iron (56,300 ppm) in the earth's crust,
and calcium (41,500 ppm) or sodium
(10,500 ppm) in seawater.

Ocean (ppm)

Table 3.

Freshwater
(ppm)
—

0.0004
0.001
0.013
0.08
0.00018
0.0009
0.01
0.005
0.00008
0.01
0.02
0.00004
0.001

Toxic element production and use (1,000 metric tons)
World production
1976

To provide an indication of pollution
or potential pollution for each trace
element, Table 3 presents annual world
productions, annual U.S. consumption,
and estimates of the annual air
pollution emissions in the United
States. More than one million metric
tons of boron, chromium, copper, and
lead are mined annually, and morethan
one million metric tons of copper and
lead are used annually in the United
States. Less than one million metric
tons of the other trace elements are
'mined or used in the United States
annually.

Antimony

75.065

Arsenic

Toxic Element Production and
Use

Beryllium
Boron
Cadmium
Chromium
Cobalt

Plants and animals acquire trace
elements from naturally occurring

U.S. consumption
1976

Human-caused air
pollution in U.S.
1 year

34.581

0.25

39.28

4.196

9.76

10.0

0.519

0.45

2,263.68
18.594
4,203.9
28.228

1 10.23
5.886
284.44
8.287

10.5
0.4

16.46
0.75

Copper

8,083.09

2,206.60

200.0

Lead

4,625.79

1,466.47

234.5

Mercury
Nickel
Selenium

Contamination of Biological
Organisms

environmental sources, such as soil or
water (Table 4), through uptake in plants
and ingestion in animals, as well as
from exposure to environmental contamination.
Normally, plants take up minute
amounts of trace elements through the
roots.The concentrations of a particular
trace element in soil may be augmented
through (1) the deposition of industrial
air pollutants (fallout), (2) the addition of
sewage sludge as a soil amendment, (3)
the application of biocide to control
unwanted weeds or pests, and (4) the
direct application of industrial wastes.
All these influences may cause
elevated element concentrations in
plants. The concentration of trace
elements on plant surfaces also
increases because air pollution fallout
accumulates on leaves and stems
(Table 4).
Terrestrial animals normally ingest
trace elements through food and water.
Additionally, they may be acquired
through breathing contaminated air,

Tin

Vanadium

8.429
872.342
1.364
225.24
25.537

2.241
160.35
0.486

20.0
4.885
0.50

61.934

30.0

4.65

20.0

�Table 4.

Sources and pathways of toxic trace elements to plants
Sb*

As

Be

B

Cd

Cr

Co

Cu

Pb

Hg

Ni

Se

Sn

V

X

X

Uptake by roots
A.

Soil or groundwater

X

X

X

X

X

X

X

X

X

X

X

X

B.

Fallout to soil from air pollution

X

X

X

X

X

X

X

X

X

X

X

X

C.

Sewage sludge soil amendments

X

X

X

X

X

X

X

X

X

X

X

D. Biocides applied to soil and/or seed

X

E.

Surface water contamination

X

F.

Fertilizers

X

X

X

X

X

X

G.

Industrial pollution

X

X

X

X

X

X

X

X

X
X

X

Uptake by leaves and stems
A.

Pollutant fallout from industrial
sources

B.

Pollutant fa/lout from auto emissions

C.

Biocide applications to plants

x

x

D.

Pollution fallout from incineration
of fossil fuels and refuse

x

x

*Key:

Sb = Antimony; As = Arsenic; Be = Beryllium; B = Boron; Cd = Cadmium; Cr = Chromium; Co - Cobalt;
Cu = Copper; Pb ~ Lead; Hg = Mercury; Ni = Nickel; Se - Selenium; Sn = Tin; V = Vanadium.

eating contaminated food, licking fur or
feathers that are contaminated,
receiving therapeutic drugs, or eating
biocides or poison baits. Aquatic
animals are subjected to similar
sources of toxic trace elements when
sewage and industrial effluents are
discharged into aquatic environments
(Table 5).
All of the toxic elements under
consideration are also found in, and
distributed as, air pollutants.

Biological Monitoring
Biological organisms of many types
have been used to measure the
concentrations of trace elements at the
pollutant site; these measurements are
compared with different distances and
with a control. Gradients of trace

e l e m e n t s may be d o w n w i n d ,
downstream, or in a circumferential
zone around a pollution source. The
results of biological monitoring of
e n v i r o n m e n t a l g r a d i e n t s were
compiled from the published literature
for each of the selected trace elements.
Detailed documentation concerning the
organism selected for gradient analysis,
the pollution source, the tissue
analyzed, the concentration gradient in
the organism, and the authority are
presented in this report.
The p r i o r i t i e s for biological
monitoring of toxic trace elements on a
global, regional or national, and local
scale are based on the toxicity of the
element and of its most toxic
compounds, its world production and
use, its emissions intothe environment,
its degree of hazard to humans and
domestic animals, and its hazards when
ingested as trace elements in food
(Table 6, page 6).

Value of Biological Monitoring
If biological organisms are used for
monitoring, they provide important data
about, and actual responses to,
pollutant exposure, instead of
predicting biological responses and
effects from physical and chemical
measurements of the environment.
Using living organisms as monitors is
advantageous because they:
1. Provide early warning and help
researchers to discover and
identify toxic trace element
pollutants in the early stages of
environmental contamination;
2. Identify impact areas and sites of
accumulation, and help researchers to measure the environmental
levels of trace elements from
sources;
3. Define critical pathways' of
pollutants to humans from water,
air, and food;

�Table 5.

Sources and pathways of toxic trace elements to animals
Sb*

As

Be

B

Cd

Cr

Co

Cu

Pb

Hg

Ni

Se

Sn

V

Terrestrial
A . Breathing contaminated a i r

x

B . Eating contaminated plant o r animal
tissue
C.

Drinking contaminated water

D.

x

x

x

x

x

x

x

x

x

x

x

x

x

x
x

x

x

x

x

x

x

x

x

x

x

Licking or preening fur or feathers

E.

x

Receiving therapeutic drugs (domestic
animals)

x

x

x

x

x

x

x

x

x

x

x

x

x

x

x

F. Eating biocides or poison baits

Aquatic
A.

Metal in water

B.

Runoff and fallout

C.

Sewage and industrial waste outfalls

D.

Mine tailings or smelter waste
leachate

E.

Contaminated plants, animals,
or sediment

x

X
X
X

X

X

x

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X
X

x

F. Biocides or runoff
G.

*Key:

Lead shot

Sb = Antimony; As = Arsenic; Be = Beryllium; B = Boron; Cd = Cadmium; Cr = Chromium; Co = Cobalt;
Cu = Copper; Pb = Lead; Hg = Mercury; Ni = Nickel; Se = Selenium; Sn = Tin; V = Vanadium.

4. Establish base lines and integrated
levels of trace elements over
geographic areas;
5. Help show trends and rates of
changes in levels of toxicity over
time;
6. Integrate biological exposure of
toxic trace elements with physical
and chemical measurements in the
environment;
7. Provide continuous monitoring
systems over time, correlated with
many other factors in the
environment; and
8. Help researchers to evaluate the
effectiveness of control measures.

Both plants and animals can serve as
biological monitors for showing
changes in levels of pollution and
environmental contamination, and as
reference points for determining direct
or indirect effects on humans.

Types of Biological Monitoring
Biological monitoring can be
conducted using two fundamentally
different but complementary methods.
The first method is to measure the
accumulation or concentration of toxic

trace elements in selected
biomonitoring organisms. The second
method is to measure impacts or effects
of toxic trace elements on organisms, or
on populations and communities of
organisms. Only the first method, that
is, biological monitoring using
accumulator and concentrator
organisms, is considered here.
Bioaccumulator organisms take up,
accumulate, and store specific
pollutants so that the organism's intake
is g r e a t e r t h a n its o u t p u t .
Bioconcentrator organisms selectively
accumulate and concentrate specific
pollutants by sequestering them into

�Table 6.

Priorities for Biological Monitoring
Environmental monitoring
Global

Regional,
national

Local

Food
surveillance

Antimony

0

0

X

0

Arsenic

X

XX

XX

XX

Beryllium

o

o

X

o

Boron

o

o

o

o

Cadmium

X

XX

XXX

XXX

Chromium

0

0

X

o

Cobalt

0

o

X

X

Copper

o

o

X

X

XXX

XXX

XXX

XX

Mercury

o

XX

XX

XX

Nickel

o

X

XX

X

Selenium

o

X

X

X

Tin

o

o

X

X

Vanadium

0

X

X

0

Lead

o—no biological monitoring (except minimum global base line surveillance)
x—limited surveillance monitoring only of selected sites or foods
xx—surveillance and exposure assessment monitoring of suspected sites and foods
xxx—surveillance and exposure assessment monitoring of all needed sites and foods
in a coordinated program
certain organs or tissues, such as hair,
bone, feathers, and so forth. A summary
of the bioaccumu lation and
bioconcentration of toxic trace
elements for plants and animals is
presented in Table 7. All elements,
except antimony and beryllium, are
concentrated by some biological
organisms present in the environment.

Recommendations for
Biological Monitoring
Recommendations for biological
monitoring of the selected trace toxic
elements are presented in Table 6. Of
those evaluated, there is an urgent,
high-priority, and well-defined need to
monitor lead, primarily because of air
pollution that comes from the
c o m b u s t i o n of l e a d - c o n t a i n i n g

Table 7.

gasoline. The author also recommends
global environmental monitoring for
arsenic and cadmium at a lower priority
than for lead. No global monitoring is
recommended for the remaining 11
elements.
On a regional or national, and a local
basis, biological monitoring for arsenic,
cadmium, lead, mercury, and nickel is
recommended, especially around
mining sites, near smelters, or near
industries using these elements.
Nationally, no monitoring is necessary
for antimony, beryllium, boron,
chromium, cobalt, copper, or tin. All
elements, except boron, require at least
surveillance monitoring at the local
level.

Biomagnification and
Biominification
Biomagnification is the increase in
concentration of trace elements in
organisms with increasing or higher
trophic levels in food chains. This
trophic level magnification indicates
that concentrations of trace elements
are higher in predators than they are in
prey. For biomagnification to occur, the
prey (or food organism) must contain a
trace element in its edible or digested
parts so that the element can be
absorbed and retained by the predator.
Biomagnification has been documented
for all the toxic trace elements that were
selected for this study.
In terrestrial habitats, biomagnification results in increasing levels of trace
elements from soil to plants for

Bioaccumulation and bioconcentration of toxic trace elements
Mollusks,
Mosses,
Mammals,
Crustacea, and
Higher
lichens, and
birds, and fish
lower animals
plants
algae

Antimony
Arsenic
Beryllium
Boron
Cadmium
Chromium
Cobalt
Copper
Lead
Mercury
Nickel
Selenium
Tin

Vanadium
x—Low or limited.

X

X

X

X

XX

xxx

xxx

XX
X

X

X

X

X

XX

xxx

xxx
xxx

xxx
xxx
xxx
xxx
xxx
xxx

XX

X

X

xxx
xxx
xxx
XX

xxx
xxx
xxx
xxx

XX

X

XX
X

xx—Moderate.

X

xxx
xxx
X

xxx
xxx

X

X

xxx

X

xxx
xxx
xxx

xxx

XX

XX

xxx—High to very high.

X
X

�beryllium, boron, cadmium, lead,
mercury, nickel, selenium, tin, and
vanadium. In herbivores, increases take
place for antimony, arsenic, cadmium,
chromium, copper, lead, mercury, and
selenium; only mercury and cadmium
biomagnify in terrestrial carnivores. In
aquatic habitats, levels of trace
elements increase from seawater to
algae for all except beryllium and boron.
In herbivores, increases occur for
antimony, arsenic, cadmium, and
mercury; from prey to carnivores, an
increase occurs for cadmium and
mercury.
Biominification is the decrease in
concentration of trace elements in
organisms with increasing or higher
trophic levels in food chains. This
phenomenon will occur if:
1. The trace element concentration is
low in the edible or digested parts
of prey or food organism,
2. The element has been sequestered
or stored in inedible tissues, such
as bones,

Selecting Suitable Organisms
The procedure for selecting biological
monitoring organisms was accomplished in the following steps. First,
data about concentrations of trace
elements in various species were
compiled, in comparable terms.
Second, the data were evaluated, with
regard to (1) the species that are
suitable for monitoring, that
bioaccumulate and bioconcentrate the
elements, and that retain or store them
in organs or tissues, (2) the usefulness
of various species for monitoring the
environmental gradients of trace
elements, (3) the species' biomagnification and biominification in food chains,
and (4) the species' biotransformation
of trace elements to other forms or
compounds.
This information allowed a tentative
selection of potential monitoring
organisms. Finally, a selection was
made based on several criteria; the
organism must:
• accumulate various elements

4.

The element has been transformed
from a highly absorbed to a poorly
absorbed chemical form, and

5. The retention time of the trace
element is short.
For terrestrial organisms, frequently
all 14 trace elements are biominified in
trace level between soil and plants.
H e r b i v o r e biomin if i c a t i o n is
documented for all trace elements
except beryllium; no change is
documented for cobalt and mercury.
Biominification from prey to carnivore
occurs for antimony, arsenic, cadmium,
lead, and mercury; no change occurs for
chromium. In aquatic habitats,
biominification from sediment or soil
occurs only in freshwater rooted plants
for cadmium, copper, and lead; no
change occurs for mercury. In
herbivores, decreases occur for arsenic,
cobalt, copper, lead, and nickel; in
carnivores, decreases occur for
antimony, arsenic, cadmium, copper,
lead, nickel, and selenium. No change
occurs for mercury in herbivores or
carnivores.

Beryllium—In the only known research
where environmental gradients of
beryllium were measured, Spanish
moss was used. Only three sites
contained over 2 ppm ash weight out of
123 samples.
Boron—Three species of higher plants
have been used successfully to
measure environmental gradients of
boron. No animals, mosses, lichens, or
algae have been tested.
Cadmium—Forty-five species of plants
and animals have been used to
measure environmental gradients of
cadmium pollution. The results show
that several species of plants and
animals appear to be excellent
candidates for biological monitoring.

• be common
• be geographically widespread

3. The absorption of the trace element
in the digestive system of the
predator is low,

measure environmental gradients of
arsenic pollution. Horse and cow hair,
and plants appear to be fairly effective
as monitors.

• be easily collected
• be of adequate size to permit
resampling of tissue
• occur in the impact and unpolluted
area
• show correlation with environmental levels of trace elements.
Also, background data for that species
must be available. Major groups of
organisms were considered with regard
to the choice of potential monitoring
organisms for each trace metal
selected. The tentative selections of
organisms for biological monitoring are
presented in Table 8; these selections
take into account the need for
monitoring in the vicinity of humans; in
urban, industrial, and rural areas, and
in freshwater, estuarine, and marine
environments.
The use of biological organisms for
monitoring environmental gradients of
the select toxic elements is summarized
next.
Antimony—The experience of using
biological monitors for measuring
environmental gradients of antimony is
limited and more studies are needed.
Arsenic—Comparatively few species of
plants and animals have been used to

Chromium—Twenty-one species have
been used to measure environmental
gradients of chromium. Plants appear to
be the most effective biomonitors,
although some animals also show
gradients.
Cobalt— Environmental gradients of
cobalt have been measured using two
species of animals and eight species of
higher plants. Gradients found in
higher plants were most definitive.
Chopper—Environmental gradients of
copper have been monitored using 48
species of animals and plants. Certain
mollusks, and both higher and lower
plants, appear to be suitable for
monitoring environmental gradients of
copper.
Lead—Over 95 species of animals and
plants have been used successfully to
monitor environmental gradients of
lead.
Mercury—Animals, mammals, birds,
amphibians,
fish, mollusks,
crustaceans, insects, and annelid
worms accumulate mercury and have
been used in monitoring environmental
gradients. Few species of higher plants
accumulate mercury.

�Table 8.

Selected organisms for biological monitoring
Human
and
animal
hair

Mammal
organs

Bird
Bird
feathers organs

Mytilus
edulis
or other

Fish

Higher
plants

Mosses
and
lichens

Algae

—

—

Antimony

F

liver, G

—

—

P

P
Arbacia, G

Rose, F

Arsenic

F

kidney, G

G

liver, P

G

E

E

Beryllium

—

P

P

P

—

G

G

—

—

Boron

—

bone, P

—

—

—

coral,
Crustacea, G

E

—

—

Cadmium

F

kidney, G

P

kidney,
liver, E

G

F

E

F

F

Chromium

F

spleen, F

—

—

P

G

E

F

G

Cobalt

—

—

—

—

P

E

F

—

G

Copper

G

liver, G

G

liver, G

P

oyster, E

F

F

F

Lead

F

kidney,
bone, F

E

femur, E

P

E

F

F

F

Mercury

F

fiver, F

F

liver, E
kidney,
liver, G

E

E

G

G

P

Nickel

G

liver, P

—

kidney, G

G

G

F

E

G

Selenium

G

kidney, G

G

liver, G

P

—

F

—

—

Tin

G

kidney, P

—

kidney, G

freshwater, G

—

F

—

G

Vanadium

G

liver, G

—

—

P

tunicates, E

F

F

G

P
G
£
—

£•

= Poor.
= Good.
= Excellent.
= Insufficient data.

Nickel—for measuring environmental
gradients of nickel, mollusks and
crustaceans have shown limited
potential. Higher plants, mosses, and
lichens appear to be excellent
biomonitors.
Selenium—Plants appear to be the best
organisms for measuring environmental gradients of selenium.
Tin—Research reveals that no species
of animal has been used to measure
environmental gradients of tin. Higher
plants have been effective, and certain
species appear to have promise for
biological monitoring.
8

Vanadium—Fish, mollusks, and some
plants have been used as biomonitoring
organisms for vanadium.

Biological Monitoring
Programs in the United States
Under the Federal Environmental
Pesticide Control Act of the United
States, pesticide residues and heavy
metals must be monitored in fish,
shellfish, birds, small mammals,
humans, and food destined for human
consumption. The vehicles for
monitoring are a series of networks,
including the National Freshwater Fish

Monitoring Network, National Ocean
Monitoring Network, National
Estuarine Monitoring Network,
National Pesticide Network for
Monitoring Birds, National Small
M a m m a l s Monitoring Network,
National Human Tissue Monitoring
Network, and the National Food and
Feed Monitoring Network.
The author recommends that the
National Environmental Pesticide
Monitoring Networks. (NEPMN)
program establish and implement
monitoring that will assess the
exposure to metals having a "high
priority." The program proposed for
biological monitoring within the
NEPMN is presented in Table 9.

�Table 9.

Proposed biological monitoring for the National Environmental Pesticide Monitoring Networks (NEPMN)

Organ or tissue

Trace elements*

Number of sites

Monitoring
frequency

Status

hair

Pb, Cd, Hg, As

75 cities

biennial

proposed-new

hair, liver

Pb. Cd. Hg, As

pilot study, then 75 cities

biennial

proposed-new

edible tissue and
dairy products

Pb, Cd, Hg, As,
Se, and Sn

1,200 slaughter houses

bimonthly

USDA program

Pigeon

feather, liver, kidney

Pb, Cd, Hg, As

pilot study, then 75 cities

biennial

proposed-new

Starling

feather, liver, kidney

Pb, Cd, Hg, As

53

biennial

modified-FWS
program

Eagle

feather, liver, kidney

Pb. Cd, Hg, As

dead birds

when available

FWS program

Poultry

edible tissue
and eggs

Pb, Cd, As, Hg,
Se, and Sn

1,200 slaughter houses

bimonthly

USDA program

Food plants

edible parts

Pb, Cd, As, Hg,
Se, and Sn

35 cities

bimonthly

FDA program

Mosses and
//chens, G

whole plant

Pb, Cd, As, Ni

WO air monitoring sites

quarterly

proposed for
EPA -new

Fish (freshwater,
few edible species)

liver, muscle

Hg,As

50

biennial

modified FWS
program

Fish (marine,
few edible species)

muscle, liver

Hg, Pb, Cd

pilot study

biennial

modifed FDA
and NOAA

soft parts

12 trace
elements

pilot study

annual

"Mussel watch"
global-new

edible tissue

Pb, Cd. Hg, As

selected coastal sites

annual

modified FDA,
FWS, NOAA

Species
Human, G
Rat

Cow, pig, sheep

Mytilus edulis, G

Oyster, crab, lobster

G—Part of global surveillance programs of GEMS and "Mussell watch."
*Key: Sb = Antimony; As = Arsenic; Be = Beryllium; B = Boron; Cd = Cadmium; Cr = Chromium; Co = Cobalt; Cu = Copper;
Pb - Lead; Hg = Mercury; Ni = Nickel; Se = Selenium; Sn = Tin; V = Vanadium.

�Dale W. Jenkins is a private consultant residing at 3028 Tanglewood Drive,
Sarasota, FL 33579.
John A. Santolucito is the EPA Project Officer (see below).
The complete report, entitled "Biological Monitoring of Toxic Trace Metals," is
in four parts:
Volume 1. Biological Monitoring and Surveillance (Order No. PB 81 -1034 75;
Cost: $18.50)
Volume 2. Toxic Trace Metals in Plants and Animals of the World. Part I.
(Order No. PB 81-103 483; Cost: $35.00)
Part II. (Order No. PB 81-103 491; Cost: $33.50)
Part I/I. fOrder No. PB 81-103 509; Cost: $21.50)
These reports will be available only from: (prices subject to change)
National Technical Information Service
5285 Port Royal Road
Springfield, VA 22161
Telephone: 703-487-4650
The EPA Project Officer can be contacted at:
Environmental Monitoring Systems Laboratory
U.S. Environmental Protection Agency
P.O. Box 15027
Las Vegas, NV 89114

10

i us GOVERNMENT PRINTING OFFICE: 1961-757-064/0309

�United States
Environmental Protection
Agency

Official Business
Penalty for Private Use, $300

Center for Environmental Research
Information
Cincinnati OH 45268

Postage and
Fees Paid
Environmental
Protection
Agency
EPA-335

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                  <text>&lt;p style="margin-top: -1em; line-height: 1.2em;"&gt;The Alvin L. Young Collection on Agent Orange comprises 120 linear feet and spans the late 1800s to 2005; however, the bulk of the coverage is from the 1960s to the 1980s and there are many undated items. The collection was donated to Special Collections of the National Agricultural Library in 1985 by Dr. Alvin L. Young (1942- ). Dr. Young developed the collection as he conducted extensive research on the military defoliant Agent Orange. The collection is in good condition and includes letters, memoranda, books, reports, press releases, journal and newspaper clippings, field logs and notebooks, newsletters, maps, booklets and pamphlets, photographs, memorabilia, and audiotapes of an interview with Dr. Young.&lt;/p&gt;&#13;
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osssi

D

Author

Kan

Corporatfl Author

Research Section, Agent Orange Projects Office, Depart

9&gt;Han K-

RODOrt/ArtiOlO TltlO Typescript: White Paper: Impact of Abolishing or
Relocating the Research Section, Agent Orange
Projects Office, Department of Medicine and Surgery

Journal/Book Title
Year
Month/Day
Color
Number of Images

D

°

Descriptori Notes

Tuesday, April 02, 2002

Page 5831 of 5840

�&lt;

WHITE PAPER

SUBJ: Impact of Abolishing or Relocating the Research Section, Agent
Orange Projects Office, Department of Medicine and Surgery
I was told on February 26, 1985, by the Director of the Agent Orange
Projects Office that DM&amp;S is considering the options of either closing
down or moving the Research Section of the Agent Orange Projects Office
outside of the Washington area, and that he was asked to prepare a plan to
relocate the Research Section by the close of business the same day.
Consideration of abolishing the Research Section in the near future or
relocating the Section outside of the Washington area should be viewed in
conjunction with the inherent effect of terminating or substantially
delaying the VA's two on-going major epidemiological studies and other
research projects. Such actions will impact negatively on the following:
1. The goal of resolving the Agent Orange issues based on sound
scientific and medical evidence;
2. The congressional and public perceptions of the VA's commitment
to serve veterans; and
3. The efficient management of public funds.
T*

Impact on scientific and medical evidence

The on-going Vietnam Veterans Mortality Study (WMS) is designed to
provide, among other things, answers for 1) whether Vietnam veterans are
at an increased risk of dying early from unexpected causes, 2) whether
they are more likely to commit suicide, and 3) whether they are more
likely to die from cancer, especially soft tissue sarcoma.
The VA's Mortality Study is the largest and most statistically powerful
study of its kind. Neither the on-going CDC epidemiology study nor the
already published Vietnam veterans mortality studies (Air Force Health
Study, New York State, Massachusetts State, Australian mortality study)
can match the size and scope of the VA Mortality Study.
Taking the issue of suicide among Vietnam veterans as an example, our
preliminary data indicate that approximately 5,000 or 10% of the Vietnam
era veterans in the VA Mortality Study, committed suicide. The CDC
epidemiology study will have only approximately 100 suicide deaths
available for analyses. The Research Section is now analyzing the

�suicides with respect to Vietnam service, likelihood of exposure to Agent
Orange, combat experience, length of service, rank, educational level,
age, and many other factors.
With Dr. Gronvall's (DCMD) concurrence, the Research Section and the
Readjustment Counseling Service (10B/RC) have also planned to conduct an
in-depth review of the suicides. This effort is designed to lead to
developing a clinical profile of the suicides which may assist the VA in
preventing suicides in the years to come.
Without the completion of the VA Mortality Study no other studies, either
on-going or planned, can provide such statistically powerful^ (results, and
the questions about Vientam veterans' mortality patterns will be likely to
remain inconclusive and unresolved.
The possibility that exposure to Agent Orange may have increased the risk
of soft tissue sarcoma (STS) has been of genuine concern to Vietnam
veterans, their families and the Congress. The VA/AFIP Soft Tissue
Sarcoma Study is designed to address this major health concern. This
study is also the largest and the most statistically powerful in dealing
with the question of Vietnam service and soft tissue sarcoma. This study
complements the CDC epidemiology study and vice versa.
The two epidemiologic studies now underway have been critically reviewed
and approved by one or more of the following scientific groups: VA
Advisory Committee on Health-Related Effects of Phenoxy Herbicides;
Cabinet Council Agent Orange Working Group, Science Panel; Armed Forces
Epidemiological Board.
The scientific credibility of the study designs and the caliber of the
principal investigators have never been questioned. The scientific
community is anticipating that the results from the studies will resolve
many Agent Orange related health questions as evidenced by numerous
invitations to scientific meetings to present the status of the various
research projects. Examples are American Chemical Society, Society for
Occupational and Environmental Health, International Symposium on Dioxin,
Armed Forces Epidemiological Board.

�Obviously, no single study can provide all the answers. However, the
results of4 the on-going studies being conducted by the Research Section
will provide some of the answers in an unequivocal way.
2. Congressional and public perceptions of the VA's commitment
The VA has repeatedly reported in congressional testimony its strong
commitment to the resolution of the Agent Orange issues and on its
in-house Agent Orange research efforts. Both the Senate and House
Veterans Affairs Committees have requested and are receiving quarterly
reports, as is the GAO, on the status of VA Agent Orange research
activities.
''
The status of in-house Agent Orange research is routinely published in the
"Agent Orange Review" prepared by VA's Office of Public and Consumer
Affairs. The review is published periodically to provide information on
Agent Orange to concerned veterans and their families. Approximately
115,000 Vietnam veterans who came to VA hospitals for Agent Orange
examinations, and other concerned veterans, are on the mailing list.
The creation of the Research Section and the research which is now being
conducted by the section is a reflection of the original and continuing
congressional and service organization's concern and interest in the
health issues. To terminate the research projects would cast serious
doubts on the depth of the VA's original commitment and damage further the
VA's image as the primary advocate of the veterans.
3. Mismanagement of public funds
Approximately 2.2 million dollars have already been spent or obligated on
the studies and research projects to bring them to their current status of
partial and near completion. Funds have been disbursed through contracts
and interagency agreements. If the Research Section were to be abolished,
these studies and projects are likely to remain incomplete, and the
scientific issues which they address will remain unresolved. Therefore,,
an apparent saving by eliminating 5 FTEE frcm the Research Section would
result in the waste of over two million dollars.

�Recommendation
4«

If DM&amp;S is to implement the abolishment of the Research Section/ it should
be carried out on a "phase-out" basis. Results of the mortality study and
the soft tissue sarcoma study are expected to be available by the 3rd
quarter of BY 1986 and reports will be written, reviewed, and published by
the 4th quarter of EY 1986. The VA can then close down the Research
Section by the end of the 4th quarter of EY 1986, without extraordinary
loss of funds and with the satisfaction that the VA has contributed to the
resolution of the Agent Orange controversy based on the scientific
evidence.
Relocation of the Section outside of the Washington area will
substantially delay completion of the studies even if all key professional
staff choose to move and adequate support services can be arranged. Such
a move will also entail significant relocation expenses. However, if the
relocation is only for the duration of completing the two studies some
will choose not.to move and it will be very difficult to recruit competent
scientists with national reputations. Relocation of the Section outside
of the Washington area is not recommended.

HAN K. RANG, D . . .
rPH

Chief, Research Section
Agent Orange Projects Office (1QA7B)

Department of Medicine and Surgery
March 8, 1985

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ROport/ArtiCiO TltlO Memorandum to Members of the Science Panel,
AOWG, from Carl Keller, Chair Pro-Tern, Science
Panel, Agent Orange Working Group, with subject:
Science Panel Meeting, dated November 25,1983.

Journal/Book Title
Year

000

°

Month/Day
Color

D

Number of Images

°

DOSttPiptOfl NdtBS

Memo announces the next meeting of the Science Panel and
distributes the minutes of the November 2,1983 meeting for
approval. Alvin L. Young filed these documents together with
others in a folder labeled, "Agent Orange Working Group
Science Panel, Current Folder."

Tuesday, March 19, 2002

Page 5605 of 5611

�Public Health Service
National Institutes of Health

DEPARTMENT OF HEALTH &amp; HUMAN SERVICES

National Toxicology Proqram

.
.

.

Memorandum

Date

November 25, 1983

From

Carl Keller, Chair Pro Tern, Science Panel, Aaent Oranqe Workinq Group/ f/l/
vw.t

Subject

Science Panel Meetinq

To

Members of the Science Panel, AOW6

There will be a meetinq of the Science Panel on December 5, 1983,
from 9:30 a.m. to 12 noon, in Room 405A, Hubert Humphrey Buildino.
We will finalize plans for review of the international studies of
the association between soft tissue sarcoma and dioxin-contaminated
products requested by Senator Cranston.

I am also enclosinq the

Minutes of the November 2 meetina for your approval.

Attachments.

RECEIVED
NOV 2 81983
Special Hojews hfe.fr (1020

�DEPARTMENT OF HEALTH &amp; H U M A N SERVICES

!""bllc Health Service

National Institutes of Health

Memorandum
Date

November 21, 1983

From

Carl Keller, Chair Pro Tern, Science Panel, Agent Orange Working Group

Subject Minutes of November 2, 1983 Meeting
TO

Members of the Science Panel, AOWG
The Science Panel met at 9:30 a.m., in Room 303-305A of the Hubert Humphrey
Building on November 2, 1983. A list of attendees is appended to these
Minutes. Several informational handouts were distributed including a copy
of the Background document and Dioxin Strategy drafts prepared by EPA on
August 15, and comments from the Veterans Administration on these documents..
Several announcements were made including the postponement of the release of
results from the Ranch Hand Morbidity Study and the cancellation of the Advisory Committee meeting to review these results. Other items discussed
followed the previously prepared agenda.
Members unanimously accepted the report on the Australian Birth Defects
Study prepared by Dr. Mulinare's subcommittee and offered several suggestions for clarification. These included a distinction between confounding,
which must be designed out of a study, and effect modification which can be
analyzed out; a more forceful statement that the Australian Study was intended to be a Vietnam Experience Study; and some explanation of the significance of underascertainment of Birth Defects which may have occurred.
Other comments of an editorial nature should be submitted to the Chair as
soon as possible so that a re-draft can be prepared.
The letters from Senator Cranston and Dick Christian to Dr. Erickson
concerning the CDC protocols were briefly discussed and it was noted
that CDC is preparing a revised draft of the protocols and will respond
to the comments of all reviewers simultaneously in the very near future.
Members of the Science Panel unanimously felt that the proposals for
further study of biopsy material obtained by Dr. Arnold Schecter following
the Binghamton State office building incident would not provide a significant
scientific contribution to issues of concern to the Science Panel. This was
based on the likelihood of unmeasurable multiple and continuing exposure to
a number of potentially toxic substances endured by the subjects involved
which would make a pharmacokinetic study of dioxins unfeasible in this group.
Members of the Science Panel recognized that the request by Senator Cranston
to review international studies of the association between soft tissue sarcoma and dioxin-contaminated products is a substantial undertaking. It was
agreed that a carefully selected subcommittee be assigned this task and the
final effort reviewed by the Panel. Suggested names for this subcommittee
should be submitted to the Chair as soon as possible so that we can begin
this assignment. A copy of a paper on this subject, prepared by Dr. Larry
Hobson in March 1983, is attached to these minutes for your information.
The Science Panel adjourned at noon, November 2, 1983.

�DEPARTMENT OF HEALTH &amp; HUMAN SERVICES

Office of the Secretary

Washington, O.C. 20201

AGENT ORANGE WORKING GROUP/SCIENCE PANEL
Meeting — November 2, 1983 —

9:30 - 12:30

ATTENDEES

Carl Keller
,
.Chair
496-3511
William Triplett
Acting DUSIGA...'
245-6156
Peter E.M. Beach
OVA/DUSIGA
245-2210
Lt. Col. Robert Capell.....Air Force Surgeon General..767-5078
Renate Kimbrough
...CDC
PTS-236-4102
Joe Mulinare.
.CDC....
.PTS-236-4080
Dick Christian
.. ...AAOTP
653-1828
Doug Clark
Cpt. Rob Lipnick
Ed Weiss
-

AADTF
AAOTF
.OGC/HHS

Michael Gough...

.OTA.

.226-2070

OTA
VA/AOPO

., .226-2070
389-5534

VACO/AOPO
EPA

389-5411
382-2897

Hellen Gelband
Al Young

Lawrence B, Hobson..
Donald G. Barnes

653-1829
653-1829
.. 245-1920

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Report/Article TltlB Report of the AOWG Science Subpanel, June 3, 1986,
Appendix I: Methodology and Results of Pilot Tests for
Agent Orange Exposure Among Vietnam Veterans

Journal/Book Title
Year

000

°

Month/Day
Color

D

Number of Images °
Descrtoton Notes

Tuesday, March 26, 2002

Page 5698 of 5743

�REPORT OF THE AOWG SCIENCE SUBPANEL
June 3, 1986

APPENDIX I
METHODOLOGY AND RESULTS OF PILOT TESTS FOR AGENT ORANGE EXPOSURE
AMONG VIETNAM VETERANS

Prepared by
Carl Keller, Ph.D. and Richard Christian, C.R.M.

�SUMMARY OP RESULTS OP PILOT TESTS AMONG VIETNAM VETERANS

Military records were examined by the U.S. Army and Joint Services
Environmental Support Group in order to estimate the amount of
daily troop dispersion and the distribution of encounters with
Agent Orange applications during the period from October 1, 1966
through March 31, 1969, in Corps Tactical Zone III, Vietnam.
Procedures and results of these tests were as follows:
Number of Encounters
Seven Battalions were selected for this test, each consisting of
five companies, making 35 companies in all. The daily locations
for each of these companies were determined from existing military
records and matched against all known Agent Orange applications
during the designated 30-month period of the test. Matching was
done for encounters within three different time-distance combinations, including:
1) Within 500 meters on the day of application ("Wet" Encounters)
2) Within 2 kilometers and within 3 days of application
3) Within 2 kilometers and within 6 days of application.
A summary of the numbers of encounters among the 35 companies and
within each of these time-distance combinations is shown in Table
I. Data are included for ranch hand (Herbs) and perimeter (Services
Herbs) as well as combined (either tape) and for the cumulative
combined, e.g., 5 companies had 14 or more encounters within 2
kilometers and within 6 days of an Agent Orange application. Although
5 out of 35 is 14%, this may be an overestimate of what might be
found among all companies in III Corps since the 7 Battalions were
chosen from among those thought to be the most likely exposed to
ranch hand applications.
Among approximately 5000 veterans known to have been assigned to
these seven Battalions, the number of individuals with various
numbers of encounters were determined as shown in Table II. Since
there are some veterans who were assigned to one of these Battalions
who have not yet been identified, it is estimated that some of the
proportions of men with more than a few encounters will be greater
than indicated in the Table, although how much is unknown.
A more detailed list of procedures and results of the number of
encounters pilot tests follow Table II in this Appendix.

�Troop Dispersion
Six companies, one from each of six of the Battalions used in the
other pilot tests, and six days in 1967 and 1968 were selected at
random. On each of the 36 company-day combinations (six companies
times six days), the recorded location for each element of the
company was plotted on the appropriate topographic map of Vietnam.
The distance between various elements of the same company on the same
day were^ measured from the maps. The maximum distance between any
two elements of the same company on the same day were according to
the following distribution:
NUMBER OF OCCURRENCES
17
1
5
4
5
4

36

DISTANCE IN KILOMETERS
0 (Company all in one location)
&lt;2
2-4
5-9
10-19
20-29
6 (Average)

�RESULTS OF PILOT TESTS FOR NUMBER OF ENCOUNTERS WITH AGENT ORANGE APPLICATIONS
TABLE I

NUMBERS OF COMPANIES WITH VARIOUS NUMBERS OF ENCOUNTERS

# OF ENCOUNTERS

0

1

500 M / 1 DAY
1
*HERBS
33
**SERVICES HERBS 33
2
EITHER TAPE
31
3
4
CUMULATIVE
35
CUMULATIVE %
100% 11%

2

3

4

5

6

7

8

2
6%

1
2
6%

9

10

11

13

14

15

1
1
1
3%

2 KMS / 3 DAYS
24
6
I
1
HERBS
3
7
SERVICES HERBS 17
7
2
1
EITHER TAPE
14
4
4
5
3
3
CUMULATIVE
9
35 21 16 12
6
CUMULATIVE %
100% 60% 46% 34% 26% 17%

2
6%

1
3%

1
3%

1
1
1
3%

2 KMS / 6 DAYS
1
HERBS
21
5
4
1
1
2
4
SERVICES HERBS 17
2
2
2
2
3
1
1
1
14
3
1
4
EITHER TAPE
3
1
1
2
1
1
4
CUMULATIVE
35 21 18 15 14 10 10
9
4
8
6
6
6
6
5
CUMULATIVE %
100% 60% 51% 43% 40% 29% 29% 26% 23% 17% 17% 17% 17% 14% 11

TABLE II

NUMBERS OF INDI VIDUALS WITH VARIOUS NUMBERS OF ENCOUNTERS

# OF ENCOUNTERS 0

9

10

11

12

13

15+

500 M / 1 DAY
EITHER TAPE &lt;4834 104+ 62
CUMULATIVE "5000 166+ 62
CUMULATIVE %
100% 3%+ 1J

2 KMS / 3 DAYS
EITHER TAPE ~4360 268 157 69 47 31 27
I
3
35
41 40 37 37
CUMULATIVE "5000 640 372 215 146 99 68
CUMULATIVE %
100% 13% 7% 4% 3% 2% 1% 1% 1% 1% 1%

2
2
0%

2 KMS / 6 DAYS
4 37
1
EITHER TAPE "4277 252 33 38 154 57 11 72 30
6
28
CUMULATIVE "5000 723 471 438 400 246 189 178 106 76 70 70 42 41 37
CUMULATIVE %
100% 14% 97, 9% 8! 5% 4% 4% 2% 2% 1% 1% 1% 1% 1
*HERBS (refers to Computer Listing of Ranch Hand Applications, Fixed-Winged
and Helicopter)
**SERVICES HERBS (Selected Fixed-Winged, ground applications not listed on
HERBS)

�DEPARTMENT OF THE ARMY
US ARMY ft JOINT SERVICES ENVIRONMENTAL SUPPORT GROUP
1790 K STREET N.W. ROOM 210
WASHINGTON. DC 2OO06

MCPIY TO
ATTENTION TO

April 10, 1986

DAAG-ESG

• ESG PILOT STUDY OF THE MAIN AGENT ORANGE EPIDEMIOLOCAL STUDY

1. The Science Panel, Agent Orange Working Group tasked the Environmental
Support Group to perform a Pilot Study for the Congressionally mandated
Agent Orange Epidemiological study. ESG was given the mission due to the
concerns expressed by the Centers for Disease Control and other scientific agencies that the study had not produced enough qualified heavily
exposed personnel.
2. There are many detailed functions in which ESG will have to perform
for the Agent Orange Epidemiological Pilot Study. Those functions are
listed below.
a. CDC has provided ESG a list of Infantry Battalions that had
the highest likelihood for exposure after being matched against the Ranch
Hand Herbs Tape. ESG selected 6 of the units recommended by CDC and added
one additional Artillery Battalion. ESG will identify the gaps and fill
in the days in which no grid coordinates were previously reported on the 7
battalions for all companies covering the period 1 October 66 to 31 March
69. This will require a new tape (gap fillers) that must be integrated
with the old CDC tape to establish a complete tape with all the tracking
data.
b. When all the daily location data has been accomplished ESG
will computer match the complete grid coordinate locations of each company
by date against the Ranch Hand and Service Herbs Tapes to produce an exposure opportunities score using the below listed criteria.
- 2 kilometers, 3 days
- 2 kilometers, 6 days
c. ESG will produce a listing for each company documenting by
date sequence each herbicide encounter and type of exposure (i.e. Ranch
Hand, Perimeter, Abort, Ground Spray).
d. ESG will review morning reports to insure the veteran was
in the unit and on duty in the field when a spray mission occurred. A
veteran could have been in the hospital or on R &amp; R in Bangkok, Thailand,
when his unit experienced a herbicide encounter and hence would not have
had an exposure opportunity.

�e. Our goal is to identify and qualify every soldier assigned
to each of the 7 battalions that were selected for the study. The qualification criteria used for the Pilot Study are listed below.
- Single tour enlistee
- E5 or below
- The veteran must have been in Vietnam sometime during
or between 1 October 1966 to 31 March 1969 to qualify
as a heavily exposed cohort.
- Served anytime in a tracked unit. Non-exposed personnel
must have served their entire tour in a tracked unit.
3. To date, ESG has completed filling the location gaps on all 7 battalions. Extensive quality control functions were performed on the data and
quality control was initiated on the existing location data that had previously been provided CDC. This information is keypunched and is almost
ready to be matched against the spray mission tapes with respect to the
aforementioned time and distance requirements.
4. ESG has requested approximately 2,500 military personnel files from
the National Archives Records Administration in St. Louis, Missouri. Since
ESG has already qualified 15,900 study subjects, 5,000 will be targeted
for use in the pilot study. Once the records are obtained the records
will be researched and personnel data elements abstracted on each qualified exposed and non-exposed study subject.

RICHARD S. CHRISTIAN, C.R.M.
Director

�</text>
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                    <text>Item D Number

°5601

Author

KuH Bart

D not Scanned

-

Corporate Author
RepOTt/ArtlGlB TltlO Memorandum to the Under Secretary/Chairman, Agent
Orange Working Group from Bart Kull, Special
Assistant to the Under Secretary for Intergovernmental
Affairs, with Subject: Agent Orange Working Group
(AOWG) Membership and Scope and Purpose of
AOWG, dated August 18, 1983

Journal/Book Title
Year

000

°

Month/Day
Color

D

Number of Images

°

DOSOripton Notes

Includes attachments.

Tuesday, March 19, 2002

Page 5601 of 5611

�DEPARTMENT OF HEALTH &amp; HUMAN SERVICES

Office of the Secretary

Washington, D.C. 20201

August 18, 1983

MEMORANDUM TO:

The Under Secretary/Chairman
Agent Orange Working Group

PROM

: Bart Kull &lt;£*,

SUBJECT

: Agent Orange Working Group (AOWG) Membership

Special Assistant to the
Under Secretary for Intergovernmental Affairs
and Scope and Purpose of AOWG.

At the meeting of the AOWG on August 10, 1983, you raised
two issues: (1) the scope and purpose of AOWG; and (2) the
apparently large membership of the AOWG.
As to the first issue, there is attached for your
consideration a decision memorandum presenting alternatives
regarding the clarification of the AOWG's functions*
w

-

"

N

.-'•'-'

."•'••""

'

'•"

. ';

•'

•" '•"

Regarding issue 2,, the precursor of AOWG, the Interagency
Working Group (IWG) was established on December 11, 1979. It
was composed of the the following: ;
. - . '. Members '

-.' •'

' : -: • . " ' . . . ' • . . • " . - . " ' . . . ' •

Department x&gt;f Health and Human Services
Department of Defense
.
Veterans Administration
Observers
Department of Agriculture
Environmental Protection Agency
Department of Labor (OSHA)
Sx-Officio Participant

•

White House Office of Science and Technology Policy

�On July 17, 1981, President Reagan raised the IWG to
Cabinet Council status and renamed it the AOWG. In his
implementing memorandum of August 21, 1981, secretary
Schweiker established the following:
Members
Department of Health and Human Services
Department of Defense
Veterans Administration
Department of Agriculture
Department of Labor
Environmental Protection Agency
ACTION

Office of Management and Budget
White House Office of Science and Technology Policy
White House Office of Policy Development
White House Council of Economic Advisors
Advisor
General Accounting Office
Observer

-

:

Office of Technology Assessment
Most agencies listed have had a pertinent, and at times
vital, input into the Working Group*s functions. Those
agencies involved.in research naturally dominate the meeting
discussion. Others, such as ACTION, Labor, the White House
Office of Science and Technology Policy and Office of Policy
Development attend in order to keep abreast of developments in
research for policy purposes. The Office of Management and
Budget is important inasmuch as it is familiar with potential
research funding needs. The Department of State is useful in
providing members with facilitated access to foreign research
and policy developments. The White House Council of Economic
Advisors has sent a representative only once to my knowledge.
The impression of •overcrowding" at the meetings is often
due to the practice of the more concerned agencies sending one
or more alternates and some observers to each meeting.
You may wish to consider having only the principal from
each agency at the conference table with alternates and
observers seated apart. You may also wish to consider
dropping ACTION, Labor and the White House Council of Economic
Advisors from membership.

�I would recommend writing to each present member agency
head advising them of the present representatives and
requesting they issue, or re-issue, a letter designating one
principal representative and one alternate.
Attachment

�Office of the General
Washington, D.C. 20201

MEMORANDUM
TO

: The Under Secretary
Thru: ES

FROM

: Edwin M. Weiss ffiy
Legal Counsel
Agent Orange Working Group

SUBJECT: Options Available to Clarify the Purpose and
Sonnft of +-h*&gt; ADWfi
Scope nf the AOWG

Purpose
To address the question raised during the August 10, 1983,
meeting on the specific mission of the Agent Orange Working
Group (AOWG).
Background
On December 11, 1979, Stuart Eizenstat, Assistant to President
Carter, requested HHS to take the lead in convening an Interagency Work Group (IWG) to study possible long-term health
effects of phenoxy herbicides and contaminants. The IWG was
to oversee, coordinate and set priorities among federal
government research activities in this area. In designing a
research agenda, the IWG was to take into consideration the
duration of exposure to Agent Orange by Vietnam veterans
(Tab A).
President Reagan announced on July 17, 1981, that the Administration has re-established an expanded IWG as the Agent
Orange Working Group (AOWG) and raised its status to Cabinet
Council leve. In his implementing memorandum of August 21,
1981, Secretary Schweiker stated that the President had been
motivated because he shared the widespread public and
Congressional concern over possible adverse health effects
among Vietnam veterans exposed to Agent Orange and other
substances. (Tab B, p. 1) In the same memorandum the Secretary
reaffirmed the board charter language of December 11, 1979.
(Tab B, p. 2)

�Page 2 — The Under Secretary
Discussion
The charter of IWG, and. now of AOWG, is a broad mandate
which provides in explicit terms the authority to design and
direct all research activities on the health effects of
exposure to phenoxy herbicides and contaminants, with
exposure to Agent Orange by Vietnam veterans as one part of
the total research design. The contaminants mentioned
include that class of chemicals known as the dioxins
produced during the manufacture of these herbicides. The
renaming of the IWG by President Reagan appears to focus the
Work Group's primary responsibility on Agent Orange, but
without a change in the'language of the charter, a lack of
clarity regarding the AOWG's purpose and scope has resulted.
Both the Chair (Pro-Tern) of the Cabinet Council on Human
Resources and the Chair, AOWG, have made previous efforts to
resolve this uncertainty of purpose.
For example, in a report on the activities of AOWG released
to the press on October 21, 1981, the Chair, AOWG, stated
that AOWG "coordinates all Federal Agent Orange research.
It does not undertake any research on its own but rather
acts as the coordinator and monitor." (Tab C, p. 2)
This purpose was affirmed by Secretary Schweiker in a letter
dated April 8, 1982 to the Secretary of Defense in which he
wrote that AOWG "has the responsibility for overseeing,
coordinating and setting priorities among federal research
relating to Agent Orange." (Tab D).
'Nevertheless, the language of the charter is clear that the
AOWG's purpose and scope is to respond to the array of issues
regarding the long-term health effects of phenoxy herbicide
exposure. Selecting only the Agent Orange segment of this
task may subject the AOWG, to criticism for non-performance
of the other elements of its mission.
Options
The following options are available to clarify the purpose
and scope of the AWOG.
. 1. The AOWG charter could remain undisturbed with the
scope and purpose to be defined through authoritative statements at the discretion of either the Chair (Pro-Tern) of the
Cabinet Council on Human Resources or the Chair, AOWG.

�Page 3 — The Under Secretary
2. The AOWG charter could be amended to state that
AOWG is specifically concerned with research related to
Agent Orange exposure in the context of the Vietnam
experience.
Discussion
Option 1 by retaining the broad mandate of the charter,
permits the Chair authority to widen or narrow the scope of
AOWG at its discretion. Inherent in this option is the
possible dilution of AOWG's concentration on Agent Orange as
public pressure mounts on dioxin as a domestic issue. The
potential for duplication and conflict is also present in
Option 1 because HHS has in place a PHS-headed interagency
group, The Committee to Coordinate Environmental and Related
Programs, to consider the health-related effects of dioxin.
Option 2 while limiting the authority and discretion of
the Chair, will make clear that AOWG is, as its name indicates,
concerned with Agent Orange. It will also permit the
charter to reflect the President's purpose in establishing
the AOWG, i.e., that the Administration is giving special
consideration to the concerns of Vietnam veterans.
Recommendation
I recommend that you approve Option 2 which cures the
current ambiguity resulting from the specific purpose inherent
in the name of the Group and the expansive purposes contained
in the charter language. It will send a clear and timely
signal to Vietnam veteran groups and to the Congress by
reaffirming HHS commitment in this area just as CDC is undertaking the Vietnam veterans' study mandated by statute, 95
Stat. 1061; 38 U.S.C. 219 note.
If you select Option 2, I suggest you appoint an ad hoc
committee to draft alternative charter amendments to be
submitted to you for consideration.
Decision

/
Approve Option 1:
Approve Option 2:
Other

:

Date

:

Attachments
Tabs A-D

�^4^^^h ^^^
7&amp;E W H I T E HOUSE
1

/•

^^

WASHINGTON

'~1r!?

/&gt;-.

December 11, 1979

MEMORANDUM FOR SECRETARY OF DEFENSE
SECRETARY OF HEALTH, EDUCATION,
AND WELFARE
ADMINISTRATOR OF VETERANS AFFAIRS
SUBJECT:

Interagency Work Group to Study the
Possible Long-Term Health Effects of
Phenoxy Herbicides and Contaminants

In recent months the public and the Congress have become
concerned about adverse health effects to veterans following their possible exposure to herbicides, particularly
Agent Orange, while serving in Vietnam. Although there are
suggestions of adverse health effects of human exposure to
such herbicides and contaminants, there is currently an
inadequate scientific basis for concluding that health
problems experienced by Vietnam veterans were caused by
previous exposure to herbicides. Moreover, there is
inadequate information on the long-term health effects of
phenoxy herbicides in general.
Individually, each of your agencies has a strong interest in
resolving this issue. Several studies have been initiated
to answer 'questions about the possible health effects of
exposure to herbicides and more generally to the class of
substances called the dioxins. Collectively, the Federal
government needs to have reliable data and criteria on which
to base decisions and policies which affect the entire
country. Although I' am aware that there has already been
extensive interagency cooperation on these issues, I believe
there is a need for formal interagency coordination.
Therefore, I request that you establish an interagency work
group to coordinate agency efforts to determine if there are
long-term health effects following exposure to phenoxy
herbicides and contaminants, with special immediate focus on
exposure of Vietnam veterans to Agent Orange. This interagoncy group should:
1.

Oversee, coordinate, and set priorities among
Federal government research activities designed

�-o r-late exposure to phenoxy herbicides to longrorni"hcalth effects.
t
*"

";

,- ...;..n a research agenda to assure that the
p'-^-rnl government conducts comprehensive
. ::irch on the long-term health effects of
' ^ com^unds, in response to both scientific
r "
a'-'d liolicy needs. The type and duration of
, .' ,r-urn to Agent Orange by Vietnam veterans
1u^i be "considered in the research agenda design
. so that the Veterans Administration will be able
•to establish sound policies for determining
- • • • compensation for veterans exposed to Agent
•:: Vietnam, should a relationship
....... smruicide exposure and long-term adverse
hoaitn'crfects be established. The research
aacnda should build on current agency activities,
including the Department of Defense's Ranch Hand
study. The interagency work group should identify
the appropriate agencies to conduct the recommended
research, either individually or through ;joint
efforts.
3.

Provide technical support to individual agencies
and independent researchers in the formulation,
development, and implementation of research on
the biomedical effects of phenoxy herbicides
and contaminants.

4.

Assure that the protocols and methodology of
ongoing and proposed Federally funded research
studies will produce valid, reliable, timely,
and relevant data, and periodically review the
status of such research.

5.

Assure that all relevant research findings, whether
rsublicly or privately financed, are promptly

made available to the public and the Congress, in .
a comprehensible and comprehensive fashion. The
work group should establish a working relationship
with the Veterans Administration's Advisory
Committee on Health-Related 'Effects of Herbicides
and should promptly provide the Committee all
relevant information as it becomes available.
I am asking Secretary Harris to take the lead in convening
the interagency group and would like to have an initial
report on the progress of the group submitted to me by

�February 15. The
of current agency
progress reports,
other agencies on

initial report should indicate the status
activities, a proposed schedule for public
and any recommendations for inclusion of
the work group.

I have asked the Office of Science and Technology Policy to
be an ex-officio participant on the work group. In addition,
the Department of Agriculture, the Environmental Protection
Agency, and the Occupational Safety and Health Administration
will initially participate on the work group in an observer
status.
.

Stuart E. Ei^nstat
Assistant to the President
for Domestic Affairs and Policy

cc:

Secretary of Agriculture
Administrator, Environmental Protection Agency
Assistant Secretary of Labor for Occupational
Safety and Health
Director, Office of Science and Technology Policy

�THE WHITE HOUSE
WASHINGTON

AU621 1981'
MEMORANDUM TOR:

SECRETARY OF DEFENSE
SECRETARY OF AGRICULTURE
SECRETARY OF LABOR
DIRECTOR, OFFICE OF MANAGEMENT AND BUDGET
ASSISTANT TO THE PRESIDENT FOR POLICY
DEVELOPMENT
CHAIRMAN, COUNCIL OF ECONOMIC ADVISERS
DIRECTOR OF ACTION
ADMINISTRATOR, ENVIRONMENTAL PROTECTION AGENCY
ADMINISTRATOR OF VETERANS AFFAIRS
fRfCTOiT, OF/Jq£ OF SCIENCE AND TECHNOLOGY

:Y

-

FROM
SUBJECT

(a

SS5RSTARY" RICHAROlCHWllKER
CHAIRMAN PRO-TEM, CABINET COUNCIL
ON HUMAN RESOURCES

: Agent Orange Working Group

The Administration has reviewed the excellent work of the
Intaragency Work Group to Study tne Possible Long-Term Health
.Effects of Phenoxy Herbicides and Contaminants and believes
that it has Bade significant progress toward fulfilling its
important mandate. By bringing together knowledgeable
scientists from the various Federal departments and agencies
the Work Group has identified ongoing research activities on
phenoxy herbicides and contaminants and begun to develop anJ
organize the means to carry out additional needed scientific
research.
President Reagan shares the widespread public and
congressional concern over possible adverse health effects
among Vietnam veterans exposed to Agent ..Orange and other
substances. The President stated, during his meeting with
national veterans organization leaders at the White House on
July 17, 1581, that the Administration is giving special
consideration to those concerns of Vietnam veterans.
At the White House meeting, the President announced that
the administration had re-established an expanded Working Group
as the. Agent Orange Working Group and raised its status to
Cabinet Council level. The President is personally determined
to assure that the full .resources of the Federal government are

�'
*
•

available to support the Working Group's continuing efforts.
The deiisisr. ta rs-^stablish and expand the membership of the
working i-'jvry and to make it an integral part of the Cabinet
Council on Human Resources reflects the President's commitment
and accords the highest priority to its mission.
As Chairman Pro-Ten of the Cabinet Council on Human .
Resourcest 1 am, accordingly, reaffirming by this memorandum
the Agent Orange Working Group's mandate of December 11, 1579
and providing specific guidance as to how that mandate is to be
carried out in accordance with the Cabinet Council *s decisions.
The Department of Health and Human Services shall continue
to have lead responsibility for overall direction: and
management of the Agent Orange Working Group. The Secretary of
Defense and the Administrator of Veterans Affairs shall
continue to assure that their respective agencies participate
fully in *11 Working Group* activities. The Departments of
Agriculture and Labor and the Environmental Protection Agency,
each or wnicn have until now been observers, shall assume full
membership and their respective agency heads shall assure that
those agencies participate fully in all Work Group activities.
Zn addition, ACTION, the Office of Management and Budget,
and the Council of Economic Advisers, as well as the White
House Office of Science and Technology Policy and the Office of
Policy Development, shall assume membership on the Working
Group and tftc htf&amp;ds of those agencies and offices shall assure
that the resources of their respective -agency or office are
fully available to support it.
Also, the congressional Office of Technology Assessment,
which has been actively involved in all Working Group
activities as an observer, will be invited to continue to participate in that capacity, and the General Accounting
Office, which has been extremely helpful to the Working Group
in the past, will continue to be kept abreast of developments
and invited to advise and assist as appropriate.
The "cjrrinQ Group has initiated research efforts designed
to fino answers to many of the questions surrounding Agent
Orange that have been raised. These 1-efforts include the birth'
defects study being conducted by HHS Centers for Disease
Control, ths Ranch Hand Study being conducted by the Air Force,
the epio'emiological study being planned by the Veterans
Administration pursuant to P.L. 96-151, and the compilation by
HHS1 National Institute of Occupational Safety and Health of a*
national rsgistry of workers exposed to dioxins. Each of these
research, activiti*?. as well as the other important research

�-3-

activities being conducted under the overall guidance of the
Working Crcup, are to be continued without. interruption or
delay .
The Working Group has developed an impressive record of
scientific objectivity, impartiality and integrity and it. is
imperative to the success of the Working Group effort that this
record and the Group's credibility be maintained. In this
regard, i £««!£* progress reports to the Cabinet Council, the
Congress and the public will continue to be made by the Agent
Orange working Group.,
To assure effective leadership of the working Group, I am
hereby appointing James Stockdale, HHS Deputy Under Secretary
for Intergovernmental Affairs, as Chair. Also, I am appointing
Or. Vernon N. Houk of the Center for Environmental Health of
the Centers for Disease Control as Chair of the Working Group's
Science Panel. In addition, I am appointing HHS Legal Counsel
Leslie A. riitt, who* has served as legal -adviser to and staff
director of the Working Group since its inception, to continue
in those capacities. I know and believe you will find that
.these individuals share «y commitment to carrying out this
important mission.
•Please review your representation on the Working Group to
assure that your agency or office is adequately represented by
appropriate technical- experts, scientists .and policy-level
officials. In order to facilitate the Group's effectiveness,
it is of course -important that each agency's total membership
be limited.
The first meeting! of the full Working Group has been *
scheduled for Friday, August 28, 1981 and a meeting of the
Science Panel will be scheduled for shortly thereafter.
Accordingly, please let Mr. Bart Kull, Special Assistant to the
Deputy Under Secretary for Intergovernmental Affairs
.Peter Beach, HHS Director of Veterans
Affairs (24.5*2210), know as soon as possible the name(s)- of
your designated representative(s) so that briefing materials
may be foi-iiicu to them.
Attached for your information is a copy of the memorandum
of the Executive Secretary to the Cabinet Council on Human
Resources establishing the Working Group.
^
Attachment

cc: Comptroller General of the United States
Director, Congressional Office of Technology Assessment
Mr. Robert Carleson

�activities being conducted under the overall guidance of the
Working Group, are to be continued without interruption or
delay.
?
The Working Group has developed an impressive record of
scientific objectivity, impartiality and integrity and it i*
imperative to the success of the Working Group effort that t&amp;ls
record and the Group's credibility be maintained. In this
regard, regular progress reports to the Cabinet Council, the
Congress and the public will continue to be made by the Agent
Orange Working Group.
To assure effective leadership of the Working Group, I
hereby appointing James Stockdale, HHS Deputy Under Secretary
for Intergovernmental Affairs, as Chair. Also, I am appolntlsuj
Dr. Vernon N» Houk of the Center for Environmental Health of
the Centers for Disease Control as Chair of the Working Groups
Science Panel. In addition, I ara appointing HHS Legal Counsel
Leslie A. Platt, who' has served as legal adviser to and staff
director of the Working Group since its inception, to continue
in those capacities. I know and believe you will find that
these individuals share my commitment to carrying out this
Important mission.
'Please review your representation on the Working Group to
assure that your agency or office is adequately represented by
appropriate technical experts, scientists and policy-level
officials. In order to facilitate the Group's effectiveness,
it is of course -important that each agency's total membership
be limited,
The *irst meeting -of the full Working Group has been
scheduled for Friday, August 28, 1981 and a meeting of the
Science ;3anel will be scheduled for shortly thereafter.
Accordingly, please let Mr. Bart Kull, Special Assistant to the
Deputy Under Secretary for Intergovernmental Affairs
(245-6156), or Dr. Peter Beach, HHS Director of Veterans
Affairs (245-2210), know as soon as possible the name(s) of
your designated representative(s) so that briefing materials
may be forwarded to them.
-Attached for your information is a copy of the memorandum
of the Executive Secretary to the Cabinet Council on Human
Resources establishing the Working Group.
Attachment
cc: Comptroller General of the United States
Director, Congressional Office of Technology Assessment
Mr. Robert Carleson
Mr. Edwin Gray

�UJS. DEPARTMENT OF HEALTH AND HUMAN SERVICES

Laura Genero—(202) 245-6343
Richard McGowan— (202) 245-7204
FOR IMMEDIATE RELEASE .
Wednesday, October 21, 1981
HHS Secretary Richard S. Schweiker today made public the
attached Chronology of Activities on Agent Orange.

* I#

�PROM:

TO

Janes S. Stockdale
Deputy Under Secretary for
Intergovernmental Affairs

: The Secretary

;.»

-•- -

^

CHRONOLOGY OF ACTIVITIES RE: AGENT ORANGZ

The first meeting of .the re-established and expanded Agent.
Orange Working Group was held on August 28, 1981. The first
task of the Working Group was to review the status of all
ongoing and planned Federal research and related activities.
Each member agency was directed to provide updated reports
on the status of its current or planned research activities.
A proposed protocol for the design of the Veterans
Administration epidemiological study will be reviewed by the
Working Group's Science Panel.
A number of veterans organizations have been briefed on t%3&gt;
continuing military records search that is being conducted by
the Array Agent Orange Task Force. Preparations are continuiris
for the Air Force Ranch Hand Study. That study involves pilcubjs
and maintenance personnel engaged in the spraying of herbicides
during the Vietnam conflict. Concern was expressed that the
fullest possible participation by Ranch Hand personnel be
obtained for this study df possible health effects related to
exposure to Agent Orange. This is critical because the Rancn •
Hands are a relatively .small group of approximately 1200.
i

,

A public affairs panel was created and will develop plane
for a public meeting of the Working Group to be scheduled lafcar
this.year.
The Working Group also agreed to establish a resource
development panel to assure adequate funding and personnel
resources.
Dr Vernon Houk, Chair of the Working Group's Science Panel,
has plans to review all research.
Dr. Kouk and several other members of the Working Group
visited the Army Agent Orange Task Force Office for a 'briefing
on tne status of the Department of Defense records search.
During the briefing, it became apparent that a potentially

�page 2
existed
*«
• «

v

mr

»^BP-^^

promising new concept/for the identification of people
to Agent Orange in addition to the Air Force Ranch Hand
^ _
personnel or broadly defined unics of ground troops. The -u^.
research panel was briefed on this new information.
The information may provide the basis for a new .approach c&lt;
€inding answers to .some of the serious scientific questions
before t^a working Group. It opens the possibility of
developments regarding
in the next Working Group report.
The Agent Orange Working Group's predecessor, the Interagency Work Group to Study the Possible Long-Tens Health
Effects of Phenoxy Herbicides and Contaminants (IW&lt;3)/ also
undertook a number of activities during the transition period
between April, 1981, when it transmitted its seventh report,
and August, when the expanded Working Group convened.
At the May meeting of the IWG, a status report was givea
the birth defects study being conducted by the Centers for
It was reported that the Office of Management
tDisease Control.
'and Budget had approved the study and preparations for the
study were under way, with completion likely in the summer or
fall of 1983.
•
'
At the same meeting, it was reported that a representative
of the Medical Follow-Up Agency of the National Academy of
Sciences' National Research Council had been briefed on and £t«
reviewed the Defense Department's records search effort and tia&lt;S
concluded it could be difficult to identify a population of
ground troops the nature -and extent of whose exposure to Agens.
Orange could be reliably reconstructed and documented.
At its June meeting, the IWG was honored by a visit toy the
Australian Minister of Veterans Affairs, Senator Anthony
Messner. Senator Messner told the Group of his government"* s
Agent Orange-related.research and urged continuing
between our countries in the area of research. During
meeting, the IWG was assured of the Administration's s
support for Agent Orange research.
As you know, Agent Orange efforts of the various F
bodies include research as follows:
1. .The Agent Orange Working Group coordinates all Federal
.Agent Orange research. It does not undertake
research on its own but rather aces as the
and monitor.

�' Page 3

2.

3.

The Air Force Ranch Hand Study is to be monitored by
an independent advisory committee in addition to the
Agent Orange Working Group. This advisory committeewill meet publicly (probably beginning in November)
and will include scientists from inside and outside
the Federal government.
The Veterans Administration Advisory Committee on
• Health-Related Effects of Herbicides meets
periodically to review all VA herbicide-related
research. The committee includes scientists from
inside and outside the government as well as
representatives of veterans organizations.

4.

The Office of Technology Assessment of the Congress
has established a scientific review panel to review
the proposed protocol for the design of the VA
epidemiological study and will provide the VA with its
conclusions and recommendations regarding the protocol.

5.

There are also a number of State-level Agent Orange
commissions charged with undertaking and/or monitoring
Agent Orange research.

The report notes in conclusion that a number of veterans
organizations, members of the public and Congress have
expressed support for the Administration's actions regarding
Agent Orange and related research.
f

Attachments:
(A) 'Memorandum of August 21, 1981, Re-establishing the Agent:
Orange Working Group, from HHS Secretary Richard S.
Schweiker in his capacity as Chairman Pro-Tern of the
Cabinet Council on Human Resources.
(B)' Opening Remarks of Agent Orange Working Group Chairman
James S. Stockdale at the Working Group's August 28, 1981
meeting.
(C) Report by Dr. Vernon Houk, Chair of the Working Group's'
Science Panel.

�WHITE HOUSE
HI N C T O N

PR
Honorable Caspar W. Weinberger
Secretary of Defense
The Pentagon
Washington, B.C. 20301

Dear Mr. Sec
The Agent Orange Working Group (AOWG) of the Cabinet Council
on Human Resources has the responsibility for overseeing,,
coordinating and setting priorities among Federal research
relating to Agent Orange. In partial fulfillment of izs ,
charter, the AOWG has been assisting the Veterans Rdrr.ir.istration (VA) in implementing an extensive epidemiology study
to determine whether Agent Orange caused long terar. health
effects in exposed veterans. This study was mandate! .ay
Congress in Public Law 96-151. It appeared until r^-sntly
that it would be impossible to identify, with sufficient
reliability, the exposure cohorts for this study.
Within the last six months, Department of Defense (DOD)
representatives to the AOWG working with the staff of the
Army Agent Orange Task Force have succeeded in developing a
model for searching DOD records to identify-exposed a.-d nonexposed Vietnam veteran cohorts. This concept was presented
to the AOWG in December, and after continued refinement by
the^DOD, the concept was endorsed as a reliable method for
identifying the Agent Orange exposure of certain units
serving in Vietnam. We would like to compliment your staff
for developing the solution to this critical problem.
«

The AOWG has recommended that DOD proceed with the search,
retrieval, and establishment of the needed exposed and nonexposed Vietnam veteran cohort lists.
The AOWG recommends that sufficient DOD personnel and computer
support be committed to begin the records search necessary
to provide the Veterans Administration with subjects for the
initial pilot study. After the pilot is completed, additional
DOD staff and computer support will be needed to identify
the 36,000 potential research subjects needed for the full
Agent Orange epidemiology study. The AOWG estimates the
total effort will require a DOD budget of $2 - 3 million
over 1 1/2 years.

�.Page 2 - Caspar W. Weinberger
I now forward to you the request that you review our
recommendation and help to assure the priority, staffing
and other support necessary to enable the DOD to develop
these cohort lists in an expeditious manner.
Sincerely,

Richard S. Schweiker
Chair, Pro-Tern, Cabinet
Council on Human Resources

V»£*x

&lt;%&amp;?i-

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                  <text>&lt;p style="margin-top: -1em; line-height: 1.2em;"&gt;The Alvin L. Young Collection on Agent Orange comprises 120 linear feet and spans the late 1800s to 2005; however, the bulk of the coverage is from the 1960s to the 1980s and there are many undated items. The collection was donated to Special Collections of the National Agricultural Library in 1985 by Dr. Alvin L. Young (1942- ). Dr. Young developed the collection as he conducted extensive research on the military defoliant Agent Orange. The collection is in good condition and includes letters, memoranda, books, reports, press releases, journal and newspaper clippings, field logs and notebooks, newsletters, maps, booklets and pamphlets, photographs, memorabilia, and audiotapes of an interview with Dr. Young.&lt;/p&gt;&#13;
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&lt;p&gt;For more about this collection, &lt;a href="/exhibits/speccoll/exhibits/show/alvin-l--young-collection-on-a"&gt;view the Agent Orange Exhibit.&lt;/a&gt;&lt;/p&gt;</text>
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                    <text>Item D Number

°5598

D Not Scanned

Lathrop, George D.

Epidemiology Division, Data Sciences, Division, USAF S

Report/ArtldO TitlB

Pr

°iect Ranch Hand II: An Epidemiologic Investigation
of Health Effects in Air Force Personnel Following
Exposure to Herbicides, Baseline Mortality Study
Results

Journal/Book Title
Year

1983

Month/Day

June3

Color

°

D

Number of Images

°

DOSCrlptOD NOtQS

Also included are summaries of the baseline mortality study
results (June 30,1983), the baseline morbidity study results
(February 24, 1984), and the mortality update (December 10,
1984. Alvin L. Young filed these documents together with
others in a folder labeled, "Agent Orange Working Group
Science Panel, Current Folder."

Tuesday, March 19, 2002

Page 5598 of 5611

�I

PROJECT RANCH HAND II

AN EPIDEMIOLOGIC INVESTIGATION OF HEALTH
EFFECTS IN AIR FORCE PERSONNEL FOLLOWING
EXPOSURE TO HERBICIDES
BASELINE MORTALITY STUDY RESULTS
30 JUNE 1983

Prepared for:
The Surgeon General
United States Air Force
Washington, D.C. 20314
Approved for public release; distribution unlimited
EPIDEMIOLOGY DIVISION
DATA SCIENCES DIVISION
USAF SCHOOL OF AEROSPACE MEDICINE (AFSC)
BROOKS AIR FORCE BASE, TEXAS 78235

�Unclassified
SECURITY CLASSIFICATION OF THIS PAGE (When DatafEntered)i

REPORT DOCUMENTATION PAGE
1. REPORT NUMBER

«.

Tl T L t

2. GOVT ACCESSION NO

READ INSTRUCTIONS
BEFORE COMPLETING FORM
3. RECIPIENT'S CATALOG NUMBER

5. TYPK OF REPORT A PKRIon C O V K R I n

(«"&lt;/ S

AN EPIDEMIOLOGIC INVESTIGATION OF HEALTH EFFECTS
IN AIR FORCE PERSONNEL FOLLOWING EXPOSURE TO
HERBICIDES: BASELINE MORTALITY STUDY RESULTS

Annual Report,
Initial Report

6. PERFORMING OHG, REPORT NUMBER

7. AUTHORfs)

6. CONTRACT OR GRANT NUMBERS;

9. PERFORMING ORGANIZATION NAME AND ADDRESS

10. PROGRAM ELEMENT, PROJECT, TASK
AREA ft WORK UNIT NUMBERS

George D. Lathrop, Colonel, USAF, MC; Patricia M,
Moynahan; Colonel, USAF, NC; Richard A. Albanesei
M.D.; William H. Wolfe, Lt Colonel, USAF, MC
USAF School of Aerospace Medicine (EK)
Aerospace Medical Division (AFSC)
Brooks Air Force Base, Texas 78235

11. CONTROLLING OFFICE NAME AND ADDRESS
The Surgeon General
United States Air Force
Washington, D.C. 20311*

1Z. REPORT DATE

U. MONITORING AGENCY N'AME ft ADDRESSfff dltterent Irom Controlling Ottice)

15. SECURITY CLASS, (ol thti report)

30 June 1983
13. NUMBER OF PAGES

61

Unclassified
I5«. DECLASSIFI CATION/DOWN GRADING
SCHEDULE

16. DISTRIBUTION STATEMENT (oi this Report)

Approved for public release; distribution unlimited.

17. DISTRIBUTION STATEMENT (of the abstract entered In Block 20. It different from Report)

IB. SUPPLEMENTARY NOTES

19. KEY WORDS (Continue on reverse side H necessary and Identity by block number)

Epidemiologic investigation
Air Force Health Study

Mortality study

RANCH HAND

Matched cohort design
Nonconcurrent prospective design
'0. ABSTRACT (Continue on reverse side if necessary and identify by block number)

In 1979 the United States Air Force (USAF) made the commitment to Congress
and to the White House to conduct an epidemiologic study of the possible
health effects from chemical exposure in Air Force personnel who conducted
aerial herbicide dissemination missions in Vietnam (Operation RANCH HAND).
The purpose of this epidemiologic investigation is to determine whether
long-term health effects exist and can be attributed to occupational exposure
to herbicides. This study uses a matched cohort design in a nonconcurrent
prospective setting, incorporating mortality, morbidity, and follow-up studle;
DD , F O R M73 &lt;|.|« EDITION OF 1 NOV 65 IS OBSOLETE
JAN
WO
Unclassified
7

SECURITY CLASSIFICATION OF THIS PAGE (When Data Entered)

�unclassified
SECURITY CLASSIFICATION OF THIS PAGE(HTi«n Data Entertd)

The purpose of this report is to present the baseline mortality study results.
As of December 31» 1982, 50 Ranch Hand and 250 comparison subjects had died
(certified on/before April 27, 1983). Data analysis showed that the mortality
experience of the Ranch Hand group is nearly identical to that of this comparison group. However, this mortality report can in no way be regarded as conclusively negative since the study population may not yet have reached the latency
period. Subsequent mortality reports will include additional anaylses and will
be updated annually for the next 20 years.

Unclassified
S E C U R I T Y C L A S S I F I C A T I O N OF T U I ' PAGEfWien Dalf

Entered)

�EXECUTIVE SUMMARY
Baseline Mortality Study
The Ranch Hand II epidemiclogic study uses a matched cohort design in a
nonconcurrent prospective setting, incorporating mortality, morbidity, and
follow-up studies. The purpose of this report is to present the baseline
mortality study results.
Since 1979, a detailed population ascertainment process has enumerated a
total of 1269 Ranch Hand personnel who served in Vietnam during the period of
1962-1971. As described in the protocol, this total is believed to comprise,
the entire exposed study population. The eligibility of each Ranch Hander was
verified by a hand review of his personnel record, A comparison group
was formed by identifying all individuals assigned to selected Air Force
organizational units with a mission of flying cargo to, from, and in Vietnam
during the same period. All Ranch Hand and comparison subjects designated as
killed in action were removed from the study population. By a computerized
nearest neighbor selection process, up to 10 comparison individuals were
matched to each Ranch Hander by job category, race, and age to the closest
month of birth. A hand record review of the matched comparison sets revealed
that on the average, 8.2 comparison individuals were fully suitable for study.
From each matched comparison set, five individuals were randomly selected for
the mortality study, yielding a 1:5 design. Every Ranch Hander and his set of
comparisons will be the subjects of annual mortality updates throughout the
entire 20 years of the follow-up study so that emerging mortality patterns or
disease clusters may be detected with maximal sensitivity. Each living Ranch
Hander and his first and willing comparison match were selected to participate
in a comprehensive physical examination and an in-home interview; the results
of this study will be presented in a subsequent report in late 1983.
A mortality determination on 1,247 Ranch Handers and 6,171 comparison
subjects was made, sequentially using the data sources of the Air Force,
Veterans Administration, Social Security Administration, Internal Revenue
Service, and personal contact efforts. As of December 31, 1982, 50 Ranch Hand
and 250 comparison subjects had died (certified on/before April 27, 1983).
Death certificates were obtained on all 300 deceased subjects and were coded
by an Air Force nosologist (ICD, 9th ED). All codings were verified by the
National Center for Health Statistics. Autopsy results are currently being
sought for future analyses.
Statistical analyses of noncause specific death emphasized survival curve
estimates, linear rank procedures, relative risk estimates, and standardized
mortality ratios (SMRs). Cause specific analyses were limited to relative risk
estimates because of small cell sizes. In addition to these approaches, three
other data bases were contrasted to the Ranch Hand population, where possible;
the 1978 US White Male Mortality experience, the 1978 Department of Defense
(DoD) Nondisability Retired Life Table, and the mortality experience of the
West Point Class of 1956.
These additional comparison groups have
substantial comparability or sample size limitations, rendering conclusions to
the weakest order. Analyses with these "external" comparison groups were
accomplished to crudely define the healthy worker effect and to determine if
the Ranch Hand group mortality was drastically out of line with that of other
military populations.

�Data analysis showed that the mortality experience of the Parch Hand
group is nearly identical to that of the comparison group. Analyses showed
that, officers are living longer than enlisted personnel in both Ranch Hand and
comparison groups. This difference between officers and enlisted personnel
was statistically significant in the comparison group whereas it was not in
the Ranch Hand cohort. A contrast of the Ranch Hand and comparison group to
the 1978 DoD Life Table showed significantly less mortality for Ranch Hand
officers, comparison officers and comparison enlisted men, however, there was
not a statistically significant favorable mortality rate for Ranch Hand
enlisted personnel. This pattern of mortality was also seen in a contrast of
the Ranch Hand and comparison groups to the 1978 U.B. white male mortality
experience. That is, highly favorable mortality differentials for Ranch Hand
officers, comparison officers and comparison enlisted personnel were observed,
but not for Ranch Hand enlisted. This trend is consistent with the self
perceptions of differential herbicide exposures reported by many of the Ranch
Hand subjects. The reason(s) for these observations are speculative at
present, but may include the related items of sample size, socioeconomic
differences, access to medical care, and health education and possible
herbicide effects. Cause specific analyses were statistically nonsignificant.
The Ranch Handers showed a relative paucity of overall cancer but an excess of
digestive disorder deaths, both statistically nonsignificant. No soft tissue
sarcoma deaths were detected in either group. Analyses of both the Ranch
Hand and the comparison groups to the 1978 US White male mortality experience
showed highly significant favorable findings. Most of these differences are
speculatively attributed to the healthy worker effect. A contrast of the
Ranch Hand and comparison groups to the 1978 DoD Life Table showed
significantly less mortality for Ranch Hand officers and comparison officers
and enlisted men. The West Point comparison showed nonsignificant SMRs of
0.530 and 0.778 for the Ranch Hand officers and the comparison group officers,
respectively. Overall, the limitations of the statistical power calculations
in most of these analyses were substantial in most analyses due to 1) the low
mortality rate (4%) in the Ranch Hand and comparison groups to date, 2) the
inherently small group of Ranch Handers (as described in the study protocol),
and 3) the observed relative risks which approached unity in most categories.
This baseline mortality report can in no way be regarded as conclusively
negative because this small, young, and relatively healthy cohort may not have
yet reached the latency period wherein attributable fatal disease might be
expected and detected within limited power boundaries of this study. Future
commitments for the annual mortality updates include detailed covariate
analyses for disease risk factors, herbicide exposure, and confounding
industrial chemical exposures. Further, subsequent morbidity reports will
include full spectrum, disease specific analyses, e.g., cancer (fatal,
ongoing, cured) in an effort to enhance study sensitivity to emerging
herbicide effects, if they occur.

ii

�PREFACE

In October 1978, the United States Air Force (USAF) Surgeon General made
the commitment to the Congress and to the White House to conduct an
epidemiologic study of the possible adverse health effects arising from the
herbicide exposure of Air Force personnel who conducted aerial dissemination
missions in Vietnam (Operation Ranch Hand). The purpose of this epidemiologic
investigation is to determine whether long-term adverse health effects exist
and whether they can be attributed to occupational exposure to herbicides and
their contaminants. The study protocol (1) for this effort incorporates a
matched cohort design placed in a nonconcurrent prospective setting. The
study approach includes mortality, morbidity, and follow-up elements linked
tightly in time, in order to produce the most data in the shortest period of
time. The study addresses the question:
Has there been, or are there
currently, or will there be any adverse health effects among former Ranch Hand
personnel caused by repeated occupational exposure to 2,4,5-T containing
herbicides and the contaminant, TCDD? At the request of the Principal Investigators (see Appendix I) the study protocol was extensively and independently
peer reviewed. The review agencies included: The University of Texas School
of Public Health, Houston Texas; the USAF Scientific Advisory Board; the Armed
Forces Epidetniological Board; and the National Research Council of the
National Academy of Sciences. In 1980, the Science Panel of the Agent Orange
Working Group was created as an additional peer review agency. This group,
redesignated as the Advisory Committee on Special Studies Relating to the
Possible Long-Term Health Effects of Phenoxy Herbicides and Contaminants, has
consented to the oversight responsibility of the Ranch Hand study and
continues to monitor the conduct of this epidemiologic investigation (see
Appendix II). The approved and official protocol for this effort is available
to the public through the National Technical Information Services, 5285 Port
Royal Road, Springfield, Virginia 22161.
The Ranch Hand II Study protocol heralds the suboptimal statistical power
of the mortality study. The mortality study was motivated by the desire to
use a full spectrum epidemiologic approach to the herbicide question.
Additionally, the investigators were scientifically obliged to pursue the
mortality study because of previous and emerging studies (some with small
sample sizes) which suggested the possibility of a soft tissue sarcoma
end point (2,3,4). Within the inherent sample size limitation of the Ranch
Hand population, detection of such a rare condition will be missed unless
there is marked case clustering and correspondingly high relative risks.
Also, because of sample size limitations as well as the myriad of
proposed clinical end points, a case-control design was not entertained. The
investigators have attempted to enhance statistical power and analytic
sensitivity where possible by using ] a large comparison group, 2) precise
)
matching procedures, 3) annual mortality updates, A) mortality-morbidity
linkages, 5) a lengthy follow-up study, 6) external comparison groups, and 7)
state-of-the-art statistical methodology. A final assessment of overall
mortality must necessarily await substantially more data and covariate
approaches to identify and isolate unusual emerging mortality patterns, if
they occur.
iii

�This report is primarily directed to individuals with statistical and
epidemiologic backgrounds. It also assumes that the reader has a familiarity
with the herblcide/dioxin issue and a detailed 'knowledge of the protocol of
the Air Force study. In the interest of brevity, the reader is referred to
the protocol published as US Air Force School of Aerospace Medicine Technical
Report 82-44.

iv

�Page
Executive Summary

Preface

.............................

...............................

Table of Contents
Chapter I.

. . .iii

.............................
THE MORTALITY STUDY DESIGN

1 . The Study Population
2. The Mortality Population
Chapter II.

i

..........................
........................
THE MORTALITY DETERMINATION PROCESS

1. Introduction
.......................
.
......
2. United States Air Force Data Sources
..................
3. Veterans Administration Death Beneficiary Identification and Record
Location Subsystem
...........................
1. Other Governmental Data Sources
....................
5. Morbidity Population Tracking
.....................
6. Receipt and Coding of Death Certificates
................
7. Results
...................
.............
Chapter III. RANCH HAND VERSUS COMPARISON GROUP ANALYSES

1. Introduction

v
1
1
2
4

4
4
6
6
6
7
8
9

9

2. Overall Comparisons

9

3. Noncause Specific Occupational Comparisons

15

4.

17

Cause Specific Ranch Hand Versus Comparison Mortality

Chapter IV. NONCAUSE SPECIFIC COMPARISONS WITH
EXTERNAL POPULATIONS

1. Background and Motivation
2. Adjustment Difficulties
A. Adjustment for Calendar Year of Death

20

20
20
20

B. Adjustment for Military Status (Active Duty, Separated, Retired). . 20
C.

Adjustment for Selection

D. Adjustment for Branch of Service

21

21

�3. Comparisons with 1978 DoD Life Tables
.................
4. Comparisons with U.S. 1978 White Male Life Table
.........

21
. . . 24

Chapter V. COMPARISONS WITH THE WEST POINT STUDY GROUP
1 . Background and Motivation ..... .
.................
2. Noncause Specific Comparisons of Ranch Hand and Comparison Subgroups
with the West Point Study Group
....................
3. Cause Specific Comparisons
.......................
Chapter VI. STATISTICAL ASPECTS
1.
2.
3.
4.
5.
6.

28
28
31
34

Purpose
................................
3^
Survival Curve Estimates and Confidence Bands
.............
34
Linear Rank Procedures
.........................
35
Relative Risk Estimation ....... .
............
.... 36
Indirect Standardization
...........
.
............
37
Comparing Observed Life Table Data with a Known Survival Curve. .... 37
Chapter VII. CONCLUSION

1.
2.
3.
4.
5.

28

39

Introduction
..................
. ...... . . . . . 39
Internal Comparison Group . . . . . . . ..... .
..........
42
External Comparisons. . . . .
.........
. . . . . . . . . . . . 42
Power Considerations. . . . ....... . . . . . . . . ....... 42
Consistency Patterns ...... .
...................
43
APPENDICES

I. Ranch Hand II Principal Investigators, Coinvestigators,
Contributors, and Management Personnel
45
II. Advisory Committee on Special Studies Relating to the Possible
Long-Term Health Effects of Phenoxy Herbicides and Contaminants . . 47
III. Matching Results in the Mortality Population
48
IV. Year of Birth, Occupational and Race Specific Mortality
51
V. The Extended E j i gou-McHugh Relative Risk Estimator
..53
VI. Survival Curves and Confidence Bands for Ranch Hand and
Comparison Subgroups
54
REFERENCES

59

VI

�Chapter I
THE MORTALITY STUDY DESIGN

1.

The Study Population

The exposed study population, termed "Ranch Hand", was defined as those
individuals who were formally assigned to the USAF organizations responsible
for the aerial dissemination of herbicides and insecticides in the Republic of
Vietnam from 1962 to 1971. These individuals were identified from historical
data sources at the National Personnel Records Center (NPRC), St. Louis, Missouri and the USAF Human Resources Laboratory, Brooks Air Force Base, Texas. A
total of 1,269 Ranch Hand personnel were eventually identified through this
process. The comparison population was defined as those individuals who were
assigned to a variety of cargo mission organizations throughout Southeast Asia
during the same time period. Cargo mission aircrew members and support personnel were selected because of sufficient population size, similar training
and military background experiences, and psychologic similarities to the Ranch
Hand group. The comparison population was not occupationally exposed to herbicides or insecticides in the Republic of Vietnam. Identification of this
population was completed using the same historical data sources as were used
with the Ranch Hand population; 2*1,971 individuals were so identified. In
preparation for matching the study and comparison populations, all subjects
killed in action (KIA) were removed from the data base. The rationale for
this action is the assumption that combat death in the Ranch Hand group was
not caused by the immediate effects of herbicide exposure; KIA's were removed
from the comparison group for comparability purposes. A KIA analysis will be
performed in a subsequent report.
The Ranch Hand KIA subgroup, numbering 22
individuals, although not matched, was maintained in the data base but was
deleted from the mortality analysis, leaving 12M7 Ranch Hand subjects.
The Ranch Hand population was matched to the comparison population with
an iterative nearest-neighbor computer program (1). Up to 10 comparison subjects were matched to each Ranch Hander by year of birth, race (Black versus
non-Black), and occupational category (officer pilot, navigator and other;
enlisted flight, engineer and other), thus creating matched sets of one study
subject and up to 10 comparison subjects. All subjects are males. The mean
age of the study subjects is *J5 years.
Following the original match, the majority of Ranch Handers had 10
comparisons. The exceptions were the group of non-Black pilots who had a
mean of only 9.5 comparisons per exposed subject due to the extreme ages of
several individuals, and the strata of Black pilots and other Black officers
who only had means of 2.7 and 5.0, respectively. In December 1981, the USAF
Principal Investigators learned that several morbidity study comparison subjects had reported no experience in Southeast Asia, suggesting that
overselection of the comparison population had occurred (1). Manual review of
the comparison subjects' military personnel records revealed that 18 percent
of the 12,193 comparison individuals in the original match were ineligible
for study. The inadvertent inclusion of several non-Southeast Asia organizations resulted in the selection of these inappropriate individuals. These
ineligible subjects were found to be randomly distributed throughout the
matched sets and were removed from the study. Following the removal of the

�ineligible subjects, the study was reduced to a 1:8 design. Also during this
period, five Ranch Hand subjects were identified through personnel record
sources and Veterans Administration Education Benefits and Financial Records.
These five individuals had not been identified earlier because the majority of
their military personnel records had been destroyed in a fire at the NPRC in
St. Louis. Three of these five were newly found Ranch Handers and two were
comparisons subsequently identified as Ranch Handers.
No attempt was made
to match comparisons to these five new Ranch Handers. During the removal of
ineligible subjects, one Ranch Hander, a Black officer pilot, lost his only
comparison and remains unmatched, giving a total of six unmatched Ranch
Handers. All six of these unmatched Ranch Handers are included in the morbidity and mortality studies. They were used in the analyses where appropriate, in order to improve statistical power.
2. The Mortality Population
Five comparisons per exposed subject were considered more than adequate
for mortality analyses; this estimate has recently been verified under a
multiplicative model by Breslow, et al. (5). Up to five comparisons in each
matched set, were identified from the 1:8 cohort as the mortality comparisons. Since the positions of the individuals in the matched sets had already
been randomized in the data file, the selection of the first five positions in
each matched set array for membership in the mortality comparison resulted in
a random selection of the mortality comparison cohort.
If a Ranch Hander
had at least one but no more than five comparisons after removal of the ineligibles, then all of his matched set were used in the mortality component of
this study. The mortality population is, therefore, defined as the 1241
matched Ranch Handers and their randomly chosen mortality comparisons (6171
individuals) and the six unmatched Ranch Handers. Table 1 summarizes the
mortality population by occupational category and race. Here, and elsewhere
in this report, non-Black is defined as Caucasian, Mexican or Oriental.
Table 1
MORTALITY POPULATION SUMMARY BY OCCUPATION AND RACE

Occupation, Race
Officer-Pilot, Non-Black
Officer-Pilot, Black

Ranch Hand

Counts
Comparison

349
6

1740
13

Officer-Navigator, Non-Black
Officer-Navigator, Black

80
2

390
10

Officer-Other, Non-Black
Officer-Other, Black

25
1

123
2

189
15

935
75

528
52_
1247

2628
255
6171

Enlisted-Fit Eng, Non-Black
Enlisted-Fit Eng, Black
Enlisted-Other, Non-Black
Enlisted-Other, Black

�The overall match ratio, 6171/1247=4.95, reflects the lack of suitable
controls in some strata, the subsequent removal of ineligible comparisons and
the addition of five unmatched Ranch Handers. A detailed description of the
matching results is given in Appendix III.
Those Ranch Handers having fewer than five matched mortality controls are
summarized in Table 2.

Table 2
RANCH HAND SUBJECTS WITH LESS THAN FIVE COMPARISON SUBJECTS
Counts
Occupation, Race
Officer-Pilot, Non-Black

Ranch Hand

Comparisons-^

Notes

Officer-Navigator, Non-Black
Officer-Other, Non-Black
Officer-Other, Black
Enlisted-Fit Eng, Non-Black
Enlisted-Other, Non-Black
Enlisted-Other, Black

2

3

1

1

0

1

1
2
1

Officer-Pilot, Black

1

1

1
2
3

1
1
1

2
2
1
2
12
1

0
4
2
0
J»
0

2
1
1
2
1
2

27

Note 1.

Lack of suitable comparison subject or loss due to
ineligibility.
Note 2. New Ranch Hander, no attempt to match.
Note 3. Comparisons per Ranch Hander

1

�Chapter II
THE MORTALITY DETERMINATION PROCESS

1.

Introduction

The mortality status of the Ranch Hand group and their mortality comparisons are, and will continue to be, ascertained using four major data sources:
USAF, Veterans Administration (VA), other Governmental and morbidity population tracking. The mortality determination process using these data sources
is presented in Figure 1.
Figure 1.
RANCH HAND II
MORTALITY DETERMINATION ALGORITHM

RANCH HAND II MORTALITY STUDY
ENTIRE STUDY POPULATION
1
U.S. AIR FORCE
ACTIVE DUTY
^ RETIRED

PERSONNEL CENTER
ACCOUNTING t FIKAHM
CASUALTY BRANCH
WSC FACILITY IHFUR.

BENEFICIARY^
DIED ACTIVE
DIED AF HQSP^

ALL

I
i

DEATH BFJiEFIT

'
SOCIAI SECURITY AOVIS.

CLOSED BY DEATH

INTEMIAL RLTOUE

ACTIVE ACCT.

CLOSED BY DEATH

3E

5
JE

3
X
Ut

ALIVE

f
,__
TRACKING
CONTACT UTTER
LOWS HARRIS

DEAD

EAO - REOtiESf DEATH CERTIFICATE

VETERml'S ADMIN.
(GIRLS, SGI.I)

The entire study population was matched or checked against the first
three sections of this algorithm while only the morbidity population was contacted and tracked. A description of the data sources within the algorithm
follows.
2. United States Air Force Data Sources
The USAF data sources include the USAF Military Personnel Center (MFC)
records, the USAF Accounting and Finance Center records, and the USAF Medical

�Service Center Facility Use Data. The USAF MFC records include the individual's military personnel record and the data accumulated
by the Casualty
Branch of the MFC. Individual military personnel records are created at the
time of induction into the USAF, and reflect a chronological history of the
individual's military career. Epidemiologically, these records are an invaluable data source as they can be used for the development of occupational histories, identification of race, sex, and date of birth as well as for location
of personnel, and for determining vital status. Hard copy records of these
data are maintained at the individual's base of assignment while on active
duty; a computer copy of these records is maintained at the USAF military
personnel center, Randolph AFB, Texas. Following retirement and/or separation from the USAF, these records are forwarded to the National Personnel
Records Center (NPRC), St Louis, Missouri, the record repository for all military personnel records. They are indexed by Social Security Account Number or
Air Force Serial Number at the NPRC. If an individual should die while on
active duty, after retirement, or within 120 days of separation from active
duty, it is the responsibility of the Casualty Branch of the USAF Military
Personnel Center to update the hard copy military personnel record and the MFC
computer data base and to inform the USAF Accounting and Finance Center of
this fact. At the same time, USAF MFC personnel initiate a copy of the USAF
Form 1312, Report of Retired Casualty, or Department of Defense DD Form 1300,
Report of Casualty. The selection of the appropriate form is based on the
current status of the individual concerned. The DD Form 1300 also clarifies
an individual's casualty status which can be either battle or
nonbattle.
Copies of the appropriate death form are sent to appropriate agencies while
the original is placed in the individual's military personnel record.
Since the initial review of military personnel records, a system has been
established with the Casualty Branch of the Military Personnel Center wherein
all active duty and retired death forms are forwarded monthly to the Occupational Epidemiology Section of the USAF School of Aerospace Medicine Epidemiology Division. In this way, the mortality status of all active duty and
retired study subjects is systematically determined on a continuing basis.
The USAF Accounting and Finance Center data base was used as a resource
to update individual Air Force serial numbers to Social Security numbers. The
Social Security number is required for all other aspects of the mortality
algorithm.
The Air Force Medical Service Center (AFMSC) Facility Use Data is a computer data base containing information regarding all active duty and retired
deaths that .occur in Department of Defense (DOD) Medical Facilities. This
data base identified no additional deaths in the mortality population, but did
verify the deaths known to have occurred in DOD hospitals.
In addition to the USAF data bases, the Ranch Hand Association, a reunion
association of approximately 850 Ranch Handers, has contributed to the success
of this study. This group has assisted the Principal Investigators in the
ascertainment of the exposed population, and in the determination of the current location and the mortality status of the group. The association contacts
all of its members yearly through newsletters and provides updated information to the Air Force investigators.

�3. Veterans Administration Death Beneficiary Identification and Record Location Subsystem
The Beneficiary Identification and Record Locator Subsystem (BIRLS) is a
Veterans Administration data base generated by the Veterans Administration for
determination of funeral allowance.
If the family of the deceased informs
the funeral director that the deceased served in the US military, the funeral
director submits the required data to the Veterans Administration. In January
1981, August 1982,and January 1983,the BIRLS data base was searched for Ranch
Hand and comparison deaths. In addition to these searches, the Department for
Veterans Benefits, Veterans Administration, coordinated the gathering of death
certificates from VA regional offices.
4. Other Governmental Data Sources
A.

Internal Revenue Service

Public Law 96-126, Section 502, 28 November 1979, authorized the use
of Internal Revenue Service (IRS) addresses for individuals who had been exposed to occupational hazards in order to determine the status of their
health. The National Institute for Occupational Safety and Health (NIOSH)
coordinated the USAF requests for these IRS addresses. This system is based
on the address shown on individual tax returns and is corrected once a year.
The addresses are verified by NIOSH through use of a post card mailed to the
post office responsible for the individual's mail delivery. NIOSH assumes
that the individual is alive if he files a tax return and if the verification
scheme confirms his address for mail delivery. The IRS assumes an individual
ia dead if the individual is so reported on a joint tax return. The IRS data
base search provides an incomplete mortality determination, however, since
absence of an individual tax return does not necessarily imply death of that
individual.
B. Social Security Administration
The Social Security Administration (SSA) is a source of mortality information based on data maintained by the Office of Remuneration and Earnings.
The basis for this data is employer-reported earnings. The SSA assumes that
an individual is living if there is no indication of death on the individuals
record and earnings are recorded for the last calendar year or retirement,
disability, black lung or supplemental security income payments are being
made. The SSA did inform us that they do not conduct an exhaustive search,
and all deaths are not necessarily reported to SSA. Therefore, this mortality
information may not be complete.
5. Morbidity Population Tracking
Individual tracking techniques apply only to the morbidity population,
defined as those selected and compliant to questionnaire.
The morbidity
population for this effort is defined as all Ranch Handers and their morbidity
comparisons. The morbidity comparisons are, in general, also mortality comparisons. The selection procedure for the morbidity study is presented in
Figure 2.

�Figure 2.
SELECTION PROCEDURE FOR THE QUESTIONNAIRE,
PHYSICAL EXAMINATION, AND FOLLOW-UP STUDY

Living Ranch Hand

Comparison Individuals
Randomly Ordered
Mortality Comparisons

r -A—"^
r~

1

t

i 1 11
+-*

#*

1:1 Morbidity Match
+ Dead
- Unwilling
* Volunteer
** Replacement candidates

In this figure, the first randomly ordered comparison was found to be
dead. The second was contacted but was unwilling to participate and the third
volunteered to participate in the questionnaire component of the morbidity
effort. This contacting process for the morbidity effort was the final step
in the baseline mortality determination. The original contact was made by
certified mail. Each Ranch Hander and a random living comparison were sent
an introductory letter and fact sheet signed by the USAF Surgeon General. A
Louis Harris and Associates (LHA) interviewer then accomplished an in-home
interview.
LHA identified two Ranch Handers and nine comparisons who could not be
located. All eleven unlocatable subjects were assumed living and remain included in the mortality study.
6. Receipt and Coding of Death Certificates
Death certificates were ordered from the vital statistics department of
the appropriate state, trust territory, or foreign country. Death certificates or their equivalent were obtained on all appropriate subjects.
All death certificates were coded by two individuals, trained by the National Center for Health Statistics (NCHS) in underlying and multiple cause
of death coding procedures, using the International Classification of Diseases, Ninth Edition (1977) coding system. Classification of the underlying
cause of death was in accordance with NCHS decision tables. Each coder independently classified the underlying and multiple, causes of death and gave the
coding worksheet, with each corresponding death certificate, to the coding supervisor, a trained nosologist, for reconciliation. Following reconciliation,
one of the coders placed the death code information, by computer terminal, in
the death certificate mortality file via a blind verification program designed
to mimic the NCHS underlying multiple cause of death coding sheet. At the

�conclusion of this initial input of the death codes, a copy of the death certificate was forwarded to NCHS for further validation. The NCHS returned
coded death certificates, which were then compared with the Air Force classification. Discordances were resolved in cooperation with NCHS and entered into
the data base.
7. Results
Chapter II has reviewed the comprehensive, cohesive, sequential
ascertainment process of death in the study populations. This process has
resulted in the identification of 50 dead Ranch Hand subjects and 250 dead
comparison subjects.
Although it is understood that early differential
ascertainment occurred in the Ranch Hand members (because of detailed knowledge of the study group), it is judged that the overall comprehensive
ascertainment process is currently balanced with respect to the two groups.
Table 3 and Appendix IV contain summary counts by age, job, and race
category for all Ranch Handers and their mortality comparisons; these counts
reflect mortality as of 31 December 1982, as known on 27 April 1983. In the
stratified analyses, the term "at risk" is defined as simply the number of
subjects within a specific stratum, and in life table analyses, as the number
of subjects entering a specific age bracket.
The term "rate" is the proportion of those individuals "at risk" who are dead.

Table 3
OCCUPATIONAL AND RACE SPECIFIC MORTALITY

Race

Occupation

Non-Black

Officer-pilot
Officer-navigator
Officer-other
Enlisted-fit eng
Enlisted-other

Black

Officer-pilot
Officer-navigator
Officer-other
Enlisted-fit eng
Enlisted-other
TOTAL

Ranch Hand
At Risk Dead Rate

Comparisons
At Risk Dead Rate

3*»9
80
25
189
528

12
2
1
6
25

.03*
.025
.040
.032
.047

1740
390
123
935
2628

72
13
3
46
97

.041
.033
.024
.049
.037

6

0
0
0
2
2
50

.000
.000
.000
.133
.038
.040

13
10
2
75
255
6171

0
0
0
9
10
250

.000
.000
.000
.120
.039
.041

2
1
15
52
1247

�Chapter III
RANCH HAND VERSUS COMPARISON GROUP ANALYSES

1. Introduction
Overall survival comparisons, without regard to cause of death, were made
via survival curve estimation, linear rank procedures, relative risk estimation and standardized mortality ratios. Survival curves were estimated and
plotted using the method of Kaplan and Meier (6); 95% confidence bands (7) for
each survival curve estimate were also plotted on each graph. Linear rank
testing was carried out using the logrank test and Prentice's censored data
extension of the Wilcoxon test (8). All linear rank tests were carried out
with matched sets merged when Ranch Hands differed by less than one year
relative to date of birth, within each stratum of job and race (9). These
merged matched sets were regarded as separate strata for testing purposes (9,
10, 11). Relative risk estimates and confidence intervals were computed using
an extension of the method of Ejigou and McHugh (12) to variable length,
one-to-many matched sets (see Appendix V). Here, due to the one-to-many
limitation of the algorithm, matched sets were not merged as when testing
procedures were performed. Standardized mortality ratios and associated tests
and plots were carried out as in Gail (13).
These analyses are fully adjusted for the matching variables, age, race
and occupation, but are unadjusted for other variables of interest, such as
length of time in Vietnam or Southeast Asia, herbicide dose, time since exposure, time in active duty military, and other medical or occupational risk
factors. Some of these variables, such as herbicide dose and time since exposure will be adjusted for in the next analyses, after such data become available. In particular, latency analyses cannot be undertaken at this time but
will be included in the next mortality report.
In these analyses, we have used summary statistics for which underlying
modeling assumptions can be tested.
For this reason, we have used the
Breslow-Day (13) approach to SMR calculation, rather than the more traditional
person-years method. A detailed explanation of this choice is given in Chapter VI.
2. Overall Comparisons
Survival time in these analyses was regarded as independent of censorship, if any, and was taken to be age at death. All subjects not certifiably
dead, as of 31 December 1982, at the time of analysis, were considered censored at their age on that date. Contact has been lost with two Ranch Handers
and nine comparisons as described in Chapter II, but these are not assumed
lost to follow-up for the purpose of mortality determination. They are assumed to have been alive on 31 December 1982. With this assumption, no subjects were lost to mortality follow-up before 31 December 1982 in this study.
Ranch Hand and comparison group survival curve estimates and their associated 95% confidence bands are shown in Figure 3 and Appendix VI for the five
groups: pooled, officers, enlisted, flying and ground personnel, as defined
in Table 4. The curves for the pooled groups are shown in Figure 3 with the
95% confidence interval bands deleted in the interest of legibility, but they
are included in the group1 specific curves in Appendix VI.
Review of

�Ranch Hand operations has strongly suggested that Ranch Hand enlisted personnel were more heavily exposed to herbicide than Ranch Hand officers. Further,
there is a perception of possible exposure differential between flying and
ground Ranch Hand personnel. These notions prompted the above groupings and
analyses seen in this and subsequent chapters. Analyses of latency are not
possible at this time due to the as yet incomplete nature of the military
service data base. These analyses will be performed after the hand review of
military tour records has been completed.

Figure 3
SURVIVAL CURVE ESTIMATES FOR POOLED RANCH HANDERS AND COMPARISON SUBJECTS

1
0.9
0.8

Z 0.7
t—i
&gt;
&gt; 0,6
a:

co

0.5

0

« *
0.4

•-•

0.3
0.2

0-1
0

R - RANCH HAND
C - COMPARISON

10

20

30

YEflRS

70

�Table 4
GROUP DEFINITIONS
Group

Definition

Officer
Enlisted

Officer-pilot, navigator, other
Enlisted-flight engineer, other

Flying

Officer-pilot, navigator
Enlisted-flight engineer

Ground

Officer-other
Enlisted-other

Pooled

All occupational categories

Summary counts by group are shown in Table 5. Ignoring the matching,
interaction between officer-enlisted categories and Ranch Hand membership, and
interaction between flying-ground categories and Ranch Hand membership was
evaluated using log-linear models. No statistically significant interactions
were detected.

Table 5
SUMMARY COUNTS BY GROUP

Group

Ranch Hand
At Risk Dead Rate

Comparisons
At Risk Dead Rate

Officer
Enlisted

463
784

15
35

.032
.045

2278
3893

162

.039
.042

Flying
Ground

641
606

22
28

.03**
.046

3163
3008

140
110

.044
.037

Pooled

1247

50

.040

6171

250

.041

88

Linear rank procedures were carried out on the same five groups. The
results, summarized by test statistics and two-sided P-values, are shown in
Table 6. Small P-values, less than .05, indicate significant differences, at
the 5% level, between the two groups. These procedures are designed so that
the statistic will be positive when the Ranch Handers are dying before the
comparison subjects and negative when the comparisons are dying prior to the
Ranch Handers. The null hypothesis is that the actual survival distributions
of Ranch Handers and their matched comparisons are identical. Each statistic
is approximately null distributed as a standard normal random deviate.

11

�Table 6
TEST RESULTS AND P-VALUES FOR OVERALL COMPARISONS

Group

Logrank
(Value) P-Value

Wilcoxon
(Value)
P-Value

Officer
Enlisted

(-0.631)
(0.383)'

.526
.702

(-0.722)
(0.33D

.470
.741

Flying
Ground

(-1.021)
(1.023)

.307
.306

(-1.116)
(0.950)

.264
.342

Pooled

(-0.047)

.962

(-0.123)

.902

There is no significant difference, based on these data, between the
Ranch Handers and their mortality comparison group. This means that, in particular, the mean ages-at-death of the Ranch Handers and their matched comparisons are not significantly different. In some groups, pooled, officer and
flying, the statistics are negative, indicating that the Ranch Handers are
living longer than the comparisons, but the differences are, again, insignificant, as evidenced by the large P-values. The situation is reversed for enlisted and ground personnel. These findings are consistent with the
observation that, within each group, the comparison confidence bands are contained within the Ranch Hand confidence bands. When matched sets are stratified by five year intervals on year of birth, the same procedures give larger
P-values than those in Table 6.
Relative risk estimates, the associated 95$ confidence intervals, twosided P-values for testing the null hypothesis of relative risk equal to unity
and the associated power are given in Table 7.
Here, the power of the test
is defined as the conditional probability of rejecting the null hypothesis at
the 5% level of significance, given that the relative risk is equal to its estimated value.

Table 7
RELATIVE RISKS AND 95$ CONFIDENCE INTERVALS, P-VALUES AND POWER

Group

Relative Risk

95% Confidence Interval P-Value

Power

Officer
Enlisted

0.763
1.065

(.320- 1.207)
(.660- 1.471)

.373
.742

.105
.072

Flying
Ground

0.734
1.232

(.387 - 1.081)
(.694- 1.769)

.211
.337

.197
.195

Pooled

0.964

(.658-

.819

.051

12

1.269)

�The confidence intervals and P-values in Table 7 indicate no significant
difference, at the 5% level, between the mortality of the Ranch Handers and
comparisons in each of the five groups.
Year-of-birth specific mortality rates for each of the five groups are
given in Tables 8 through 12, with the corresponding standardized mortality
ratios (SMR). In each group, the comparisons are the internal standard. The
SMR estimates relative risk in these comparisons if the year-of-birth specific
relative risks are all equal (13). A likelihood ratio test for the hypothesis
of equal year-of-birth specific relative risks was carried out for each comparison; its P-value is denoted by P1 . In addition, the hypothesis that relative risk is unity, given that relative risk is constant across strata, was
tested via a likelihood ratio procedure (13); its P-value is denoted by P2.
The SMR and both P-values are given with each comparison.
Here, and elsewhere in this report, the denominator of the SMR
where n^j is the number of individuals for the ith stratum
population and r^ is the death rate, per person, in the standard
for the ith stratum. In these calculations the data is stratified
birth.

Table 8
POOLED SPECIFIC MORTALITY RATES BY YEAR OF BIRTH
(SMR - .996; P1-.389, P2-.955)

Birth
Year

Ranch Handers
At Risk Dead Rate

Comparison
At Risk Dead
Rate

1905-14

5

2

.1100

1*1

2

.143

1915-19

17

4

.235

96

11

.115

1920-24
1925-29

48
84

3
2

.063
.024

241
501

24
40

.100
.080

1930-31
1935-39

304
207

15
7

.049
.034

1389
1020

67
33

.048
.032

1940-44
1945-54

208
374

5
j_2
50

.024
.032

1096
1814

23
50_
250

.021
.028

13

is
of the jth
population
on year of

�Table 9
OFFICER SPECIFIC MORTALITY RATES BY YEAR OF BIRTH
(SMR - .827; P1-.233, P2-.490)

Ranch Hand Officers
Rate
At Risk Dead

Birth
Year
1910-24
1925-34
1935-39
1940-44
191)5-49

1*1
194

93
90
45

3
4
4
2
2
15

Comparison Officers
At Risk Dead Rate
205
930
458
495
190

.073
.021
.043
.022
.044

17
49
11
6
5
88

.083
.053
.024
.012
.026

Table 10
ENLISTED SPECIFIC MORTALITY RATES BY YEAR OF BIRTH
(SMR = 1.074; P1=.733, P2=.722)

Birth
Year

Enlisted Ranch Handers
At Risk Dead
Rate

1905-14
1915-19
1920-24
1925-29
1930-34
1935-39
1940-44
1945-54

4
9
16
41
153
114
118
329

2
1

3
2
11

3
3
10
35

Enlisted Comparisons
At Risk Dead
Rate

.500
.111
.188
.049
.072
.026
.025
.030

12
54
80
211
749
562
601
1624

2

7
11
22
36
22

17
45

.167
.130
.138
.104
.048
.039
.028
.028

162

Table 11
FLYING SPECIFIC MORTALITY RATES BY YEAR OF BIRTH
(SMR = .769; P1-.678, P2-.238)

Birth
Year
1915-24
1925-34
1935-39
1940-44
1945-49

Flying Ranch Handers
At Risk Dead Rate

44
272
142
120
63

4
8
6
2
2
22

.091
.029
.042
.017
.032

14

Flying Comparisons
At Risk Dead
Rate
220
1316
698
653
276

23
71
22
14
10
140

.105
.054
.032
.021
.036

�Table 12
GROUND SPECIFIC MORTALITY RATES BY YEAR OF BIRTH
(SMR = 1.257; P1-.535, P2=.302)
Birth
Year

Ground Ranch Handera
At Risk Dead Rate

Ground Comparisons
At Risk Dead Rate

1905-14
1915-24
1925-29
1930-34

5
21
31
85

2
3
2
7

.1400
.143
.065
.082

14
117
151
423

2
12
19
17

.143
.103
.126
.040

1935-39
1940-44
1945-54

65
88
311

1
3
1£
28

.015
.034
.032

322
443
1538

11
9
40
110

.034
.020
.026

These SMR comparisons are in agreement with the preceding relative risk
and linear rank analyses; there is no significant difference in mortality,
based on these data, between the Ranch Hand group and the comparison group.
3. Noncause Specific Occupational Comparisons
Within-group comparisons by occupation via SMR's, with P-values for testing constant relative risk across year of birth strata (P1) and for testing
relative risk equal to unity (P2) are given in Tables 13 through 16. The enlisted and ground personnel are the internal standards in these comparisons.
Comparisons via the logrank procedure are given in Table 17.

Table 13
RANCH HAND OFFICERS VERSUS RANCH HAND ENLISTED
MORTALITY BY YEAR OF BIRTH
(SMR «= .544; P1-.280, P2= .087)
Birth
Year
1905-24
1925-34
1935-39
1940-44
1945-54

Ranch Hand Officers
At risk Dead Rate
41
194
93
90
45

3
4
4
2
_2
15

.073
.021
.043
.022
.044

15

Ranch Hand Enlisted
At Risk Dead Rate
29
194
114
118
329

6
13
3
3
lp_
35

.207
.067
.026
.025
.030

�Table 14
RANCH HAND FLYING PERSONNEL VERSUS RANCH HAND GROUND PERSONNEL
MORTALITY BY YEAR OF BIRTH
(SMR - .581; P1-.382, P2-.100)

Birth
Year

Ranch Hand Fliers
At Risk Dead Rate

1905-24
1925-34
1935-39
1940-44
1945-54

44
272
142
120
63

4
8
6
2
_2
22

Ranch Hand Ground
At Risk Dead Rate

.091
.029
.042
.017
.032

26
116
65
88
311

5
9
1
3
1P_
28

.192
.078
.015
.034
.032

Table 15
COMPARISON GROUP OFFICERS VERSUS COMPARISON GROUP ENLISTED

MORTALITY BY YEAR OF BIRTH
(SMR - .697; P1-.640, P2-.015)
Birth
Year
1905-19
1920-24
1925-29
1930-34
1935-39
1940-44
1945-54

Comparison Officers
At Risk Dead Rate
44
161
290
640
458
495
190

4
13
18
31
11

.091
.081
.062
.048
.024
.012
.026

6
5

Comparison Enlisted
At Risk Dead Rate
66
80
211
749
562
601

9
11
22
36
22
17

1624

45
T52

M

.136
.138
.104
.048
.039
.028
.028

Table 16
COMPARISON FLYING PERSONNEL VERSUS COMPARISON GROUND
MORTALITY BY YEAR OF BIRTH
(SMR - .930; P1-.305, P2-.867)

Birth
Year
1905-19
1920-24
1925-29
1930-34
1935-39
1940-44
1945-54

Comparison Fliers
At Risk Dead Rate
45
175
350
966
698
653
276

6
17
21
50
22
14
10
140

.133
.097
.060
.052
.032
.021
.036

16

Comparison Ground
At Risk Dead Rate

65
66
151
423
322
443
1538

7
7
19
17
11
9
40
110

.108
.106
.126
.040
.034
.020
.026

�Table 17
LOGRANK WITHIN GROUP COMPARISONS
Comparison

Logrank P-Value

RH Officer vs RH Enlisted
RH Flyers vs RH Ground
Comparison Officer vs Comp Enlisted
Comparison Flyers vs Comp Ground

-1.468
-1.455
-2.597
-0.363

0.1*12
0.146
0.009
0.717

The SMR and logrank analyses are somewhat in agreement, with both procedures finding significant differences between comparison officers and comparison
enlisted, with the officers living longer.
The two methods
approximately agree on the Ranch Hand fliers versus ground personnel and on
Ranch Hand officer versus enlisted personnel with the logrank result near
significance at the .10 level; the fliers appear to be living longer than the
ground personnel within the Ranch Hand group.
4. Cause Specific Ranch Hand Versus Comparison Mortality
Cause specific mortality, relative risks, two-sided P-values for testing
relative risk equal to unity, power and 95? confidence intervals for relative
risks are summarized in Table 18 for the 1241 matched Ranch Handers and their
mortality comparisons. Mortality data for the six unmatched Ranch Handers
were not used in this analysis. Of the six, one has died of an accident and
the rest are still alive. In some categories, the data were too sparse for
relative risk estimation.
Table 18
CAUSE SPECIFIC MORTALITY AND RELATIVE RISKS
Cause

Dead
Relative
RJH Comparison Risk
95% Conf Int.

Accidental
18
Suicide
3
Homicide
2
Infectious,
Parasitic 0
Malignant
Neoplasm
4
Uncertain
Neoplasm
0
Endocrine
1
Mental Disorder 0
Nervous System 0
Circulatory
16
Respiratory
0
Digestive
5
Genitourinary 0
111 Defined
0
Unknown
_0_

92
14
3

49

250

P-value

Power

.959
1.071
3.333

(.466 - 1.453)
(0 - 2.407)
(0 - 9.297)

.875
.913
.099

.047
.061
.489

.503

(0 - 1.024)

.205

.153

5.000

(0 -18.859)

.102

.562

1.002

(.411 - 1.594)

.994

.050

2.273

(0 - 4.675)

.085

.457

3
39
2
1
1
2
70
4
11
3
2
3_&lt;

17

�The low powers in Table 18 reflect the sparseness of data or the fact that
some of the observed relative risks approach unity. However, two categories do
stand out as deserving further attention: malignant neoplasms and digestive
system deaths.
It should be noted that if matched sets are ignored and relative risk is estimated using the method of Mantel and Haenszel (14), these
results remain essentially unchanged; using this'approach, the relative risk
for malignant neoplasms, for example, is .506 with a P-value of .195 and power
equal to .254. The 95/&amp; confidence interval for relative risk using this approach is .180 to 1.419. The Mantel-Haenszel relative risk for the digestive
system comparison is 2.254, with a P-value of .132 and a power equal to .325;
the 95$ confidence interval for relative risk is .782 to 6.501. The digestive
system deaths are further defined in Table 19.
There has been an increase
in deaths due to liver disease among the Ranch Handers; however, this observed
difference is not statistically significant. These data are also based on
death certificate diagnoses and will be subjected to verification and validation from medical record and autopsy reports.
When all deaths from liver
disease are considered as a whole, a relative risk of 2.50 is found, with a
95% confidence interval of 0 to 5.501. The P value is 0.083. Similarly, the
relative risk for pancreatitis is 2.50 with a 95% confidence interval of 0 to
8.501.; the P value is 0.386. These observations are of interest and will be
pursued in depth in subsequent reports.
Table 19
DIGESTIVE SYSTEM MORTALITY

Deaths
Ranch Hand Comparison

ICD Code (9th Ed)

Pancreatitis (5770)
Alcoholic cirrhosis (5712)
Nonalcoholic cirrhosis (5715)
Nonalcoholic fatty liver (5718)
Chronic liver disease (5728)
Alcoholic liver disease (5711)
Duodenal ulcer (5325)

1
0
3
0
0
1
0_
5

2
3
3
1
1
0
_J_
11

Table 20
SITE SPECIFIC MALIGNANT NEOPLASM MORTALITY

Deaths
Ranch Hand
Comparison

Site ICD Code (9th Ed)

Lip, oral cavity, Pharynx (140-149)
Digestive organs, peritoneum (150-159)
Respiratory, intrathoracic (160-165)
Bone, connective tissue, skin,
breast (170-175)
Genitourinary organs (179-189)
Brain (191-192)
Lymphatic and hematopoietic tissue (200-208)
No site specification (199)

18

0
0
2

4
8
15

0
1
0
0
J_
4

1
3
3
4
J_
39

�The malignant neoplasms are detailed in Table 20, the cell types or the
neoplasms, as recorded on the death certificates, are summarized in Table 21.
Table 21
MORPHOLOGY OF NEOPLASMS
ICD Code
9th Ed.
M800

M801-80*»

M805-808

M8HJ-838

M872-879
M905
M938-948
M959-963
M965-966
M986

Deaths
Ranch Hand
Comparison

Nomenclature

Neoplasms not otherwise specified (NOS)
Brain
Bronchus and Lung
Colon
Intestinal Tract
Epithelial neoplasms (NOS)
Bronchus and Lung
Esophagus
Kidney
Nasopharynx
Pancreas
Unspecified site
Papillary and Squamous Cell
Nasal Sinus
Lip
Tongue
Tonsil
Andenomas and Adenocarcinomas
Appendix
Bronchus and Lung
Colon
Kidney
Stomach
Nevi and Melanomas
Skin (NOS)
Mediastinal
Mesothelioma
Bronchus and Lung
Gliomas
Frontal Lobe
Brain (NOS)
Lymphomas NOS and Diffuse
Lymphomas (NOS)
Hodgkins disease
Hodgkin's (NOS)
Myeloid Leukemias
Acute Myelocytic Leukemia

0
0
0
0

1
3
1
1

1
0
1
0
0
1

8
1
1
1
2
1

0
0
0
0

1
1
1
1

0
0
0
0
0

1
2
1
2
1

0
1

1
0

0

1

0
0

1
1

0

1

0

2

0
4

Epithelial, papillary and adenomas account for 6H% of the comparison neoplasms. Three Ranch Hand neoplasms arose from epithelial cells. There were
no tumors in either group which were classified as soft tissue sarcoma.

19

�Chapter IV
NONCAUSE SPECIFIC COMPARISONS WITH EXTERNAL POPULATIONS

1. Background and Motivation
It is important to know, not only how the Ranch Handers and their matched
comparisons relate to each other, but also how they compare with general military and male United States populations. Pitfalls inherent in these comparisons are well known and are briefly reviewed below for specific comparisons
with 1978 DoD period life tables for nondisability retired military officer
and enlisted personnel (15) and the 1978 U.S. White Male Life Table (16).
Although there are difficulties in the use of these comparisons, their use
does provide an additional indicator of trends in mortality when viewed in the
context of the total analytic process.
2. Adjustment Difficulties
Mortality rates in any military population are strongly dependent upon
1) calendar year of death, 2) military status (active duty, separated, retired), 3) selection and retention, and 4) branch of service. Adjustment for
these effects was not made in these comparisons because published select Air
Force life tables, by calendar year and by status, are not available. In addition, there is also a problem with the statistical method used, since the Gail
and Ware (17) procedure assumes constant relative risk with respect to age;
the selection effect has been shown to diminish sharply with time making this
assumption untenable in these comparisons. The adjustment difficulties (1-4),
and their likely consequences, are detailed below. These difficulties apply
to all of the comparison groups, but these concerns have less effect on the
comparisons of the Ranch Hand group to their matched cohort since these two
groups are generally equivalent, relative to these key factors.
A. Adjustment for Calendar Year of Death
Due to the continuing decrease in overall mortality in the military
(18) and in the United States (19), the referenced external age-specific rates
are appropriate only for the calendar period of the referenced external life
table, that is, 1977-79 for the 1978 period military table used in this analysis. The 1977-79 period rates would, for example, be too low for comparison
with subjects dying in 1970 at the age of 40. These subjects would more properly be compared with the death rate for 40 year olds in a 1970 period life
table or with a death rate for 40 year olds in a cohort military life table
for subjects born in 1930. Calendar time is not taken into account in this
analysis because period life tables covering the three decades from 1950 to
1980, for the the active duty, separated and retired Air Force subpopulations,
are not currently available. This discrepancy is serious because the decline
in death rates in the active duty Air Force during the period 1966 to 1980 has
been very substantial (18).
B. Adjustment for Military Status (Active Duty, Separated, Retired).
The only published military life tables available at this writing are
1978 period tables for DoD nondisability retired officer and enlisted personnel (15) and a series of yearly abridged tables for the active duty Air Force,
the first covering the period 1966-1968 and the last, 1978-1980 (18). With
these data limitations, adjustment for military status is not possible. It is
20

�olear, however, that there are substantial differences between active duty and
retired death rates with the active duty rates being lower than retired rates
(15).
C. Adjustment for Selection
Entry into the military carries with it an effect known as selection, a lengthening of life expectancy due to health prerequisites upon entry
into select status and periodic health checks thereafter. This effect is well
known to insurance actuaries who have observed that, in insured populations,
the effect diminishes as time passes unless there are continued checks on the
state of health of the insured persons (20). If selection is to be adjusted
for in this analysis, it would be necessary to know Air Force death rates as a
function of both age and of time elapsed since entry into the Air Force. It
would also be necessary, therefore, to know enlistment and discharge or retirement dates for all study subjects. It is the lack of these data that
makes this adjustment impossible at this time. The consequences of this lack
of adjustment are not known at this writing.
D. Adjustment for Branch of Service
Age specific active duty Air Force death rates are substantially
lower than the corresponding rates for other services (18). Nonservice specific death rates are therefore too high for appropriate comparison with these
two study groups.
3-

Comparisons with 1978 DoD Life Tables

In Tables 22 and 23, Ranch Hand officers and comparison group officers are
contrasted to a 1978 DoD nondisability retired officer life table (15) and in
Tables 24 and 25, Ranch Hand and comparison group enlisted personnel are compared with a 1978 DoD nondisability retired enlisted life table (15). In
each table, the column labeled "At Risk" lists the number of subjects entering
each five year age interval, the column labeled "Deaths" tabulates the numbers
of deaths in the age intervals and the column labeled "Expected Deaths" gives
the expected numbers of deaths in the age intervals if the study subjects had
experienced the same death rates as those specified by the DoD table. The
value of the test statistic (17) for testing the null hypothesis of equality
is denoted by T; its two-sided P-value is denoted by P. While each table
summarizes the findings with five year age intervals for ease of presentation,
one year age intervals were used for the computation of the statistic T. All
comparisons are conditioned on survival to age 35, since the DoD tables begin
at that age. All comparisons are unadjusted for race since the DoD tables are
not race specific.

21

�Table 22
RANCH HAND OFFICER VERSUS DOD NONDISABILITY
RETIRED OFFICER LIFE TABLE
(T - -3.962, P &lt; .001)
Age

At Risk

Deaths

Expected Deaths

35-39
40-44
45-49
50-54

456
366
288
173

2
1
1
1

4.183
4.244
4.578
3.099

55-59

57

1

2.043

60-64

30

2

.823

65-68

1

£
8

.076
19.046

Table 23
COMPARISON OFFICERS VERSUS DOD NONDISABILITY
RETIRED OFFICER LIFE TABLE
(T - -2.402, P = .016)

Age

At Risk

Deaths

Expected Deaths

35-39
40-44
45-49
50-54

2264
1822
1365
842

12
13
24
12

20.837
20.703
21.920
15.901

55-59
60-64

308
145

9
4

10.265
4.377

65-68

.19

JD

.601

74

94.604

Table 24
ENLISTED RANCH HANDERS VERSUS DOD NONDISABILITY
RETIRED ENLISTED LIFE TABLE
(T = -.239, P = .811)

Age

At Risk

Deaths

35-39

668

6

40-44
45-49
50-54
55-59
60-64

392
287
140
41
20

5
5
5
2
2

65-69

6

0

70-71

1

J_
26

22

Expected Deaths

�10UJ.C

C-J

ENLISTED COMPARISON SUBJECTS VERSUS DOD NONDISABILITY
RETIRED ENLISTED LIFE TABLE
(T = -3.214, P = .001)

Age

At Risk

Deaths

Expected Deaths

35-39
40-44
45-49
50-54
55-59
60-64
65-59
70-74

3299
1945
1437
695
203
103
35
5

21
20
31
14
12
3
1
0
102

33.370
27.681
31.450
20.076
10.980
7.515
2.593
.646
134.311

These findings suggest that, if the effects discussed in section 2 are
assumed to be negligible, Ranch Hand officers and comparison officers and comparison enlisted personnel are living longer than expected relative to their
respective external populations. Enlisted Ranch Hand personnel are not different from DoD enlisted personnel. In the above DoD comparison there is a
suggestion of interaction between officer-enlisted categories and Ranch Hand
versus comparison group membership. If matching and time of death are ignored, the following table can be constructed. The term "rate" is as defined
on page 8 of this report.
Table 26
DEATH AFTER 35 YEARS

Ranch Hand
Alive Dead Rate
Officer
Enlisted

448
642

8
26

Alive

.018
.039

Comparison
Dead
Rate

2190
3197

74
102

.033
.031

Analysis using log-linear models shows a statistically significant interaction with pS 0.05. It appears that Ranch Hand officers have a lower mortality after age 35 than Ranch Hand enlisted or comparison officers or enlisted.
However, the converse situation is noted considering mortality prior to age 35
and is significant with pSO.05. The data for this analysis of mortality prior
to age 35 is set out below.
Table 27
DEATHS BEFORE AGE 35 YEAR

Alive
Officer
Enlisted

456
775

Ranch Hand
Dead
Rate
7
9

&gt;

Alive

.015
.011

2264
3833

23

Comparison
Dead
Rate
14
60

.006
.015

�These interactions will require further detailed analysis and evaluation,
with specific consideration of medical covariables including risk taking,
other life patterns and herbicide.
4.

Comparisons with U.S. 1978 White Male Life Table

Non-Black Ranch Handera and non-Black comparisons are compared in this
section with the population of White males, as represented by the 1978 U.S.
White Male Life Table (16). Two serious and well known problems with the use
of this table are the lack' of adjustments for the calendar year and selection
effects just described; when comparing occupational cohorts with national
populations, the selection effect is known as the "healthy worker" effect. The
pitfalls of these kinds of comparisons are well documented (21, 22, 23). In
Tables 28 and 29, non-Black Ranch Handers and non-Black comparisons are compared, via the method of Gail and Ware (17), with the 1978 U.S. White Male
Life Table (16). In Tables 30 through 33, non-Black officers and enlisted
personnel in both study groups are compared with the same 1978 U.S. White Male
Table.

Table 28
NON-BLACK RANCH HANDERS VERSUS 1978 U.S. WHITE MALE
LIFE TABLE
(T--4.588, P &lt;.001)

Age

At Risk

Deaths

Expected Deaths

21-24
25-29

1171
1169

2
6

9.003
9;783

30-34
35-39

1163
1054

7
7

9.396
9.256

40-44

722

5

10.381

45-49
50-54

549
304

6
5

12.085
8.114

55-59
60-64
65-69
70-71

98
50
7
1

3
4
0
1
W

5.039
2.790
0.669
0.089
76.605

24

�Table 29
NON-BLACK COMPARISONS VERSUS THE 1978 U.S. WHITE MALE
LIFE TABLE
(T = -11.230, P &lt;.001)

Age

At Risk

Deaths

Expected Death

19-19
20-24
25-29
30-34
35-39
40-44
45-49
50-54
55-59
60-64
65-69
70-74

5816
5815
5799
5772
5245
3593
2675
1487
509
248
54
5

1
16
27
23
31
29
50
26
20
7
1
0
231

10.325
55.444
48.592
46.719
46.124
51.041
58.810
40.529
25.210
11:161
3.403
0.601
354.540

Table 30
NON-BLACK RANCH HAND OFFICERS VERSUS 1978 U.S. WHITE MALE
LIFE TABLE
(T «= -4.575, P &lt; .001 )

Age
25-29
30-31
35-39
40-44
45-49
50-54
55-59
60-64
65-68

At Risk

Deaths

151
151
147
362
285
172
57
30
1

3
1
2
1
1
1
1
2
_0
15

25

Expected Deaths
3.794
3.710
4.42Q
5.304
6.370
4.541
3.019
1.302
0.110
32.570

�Table 31
NON-BLACK COMPARISON OFFICERS VERSUS 197$ U.S. WHITE MALE
LIFE TABLE
(T - -7.923, P &lt; .001)

Age

At Risk

Deaths

Expected Deaths

25-29

2253

9

18.880

30-34

2244

5

18;530

35-39

2239

12

22.137

40-44
45-49
50-54
55-59
60-64
65-68

1801
1352
834
308
145
19

13
24
12
9
4
_0

25.841
30.468
23.328
15.157
6.923
0.887

88

162.151

Table 32
NON-BLACK RANCH HAND ENLISTED PERSONNEL VERSUS 1978 U.S. WHITE MALE
LIFE TABLE
(T - -1.753, P - .080)

Age

At Risk

Deaths

21-24
25-29
30-34
35-39
40-44
45-49
50-54
55-59
60-64
65-69
70-71

717
715
712
607
360
264
132
41
20
6
1

2
3
3
5
4
5
4
2
2
0
J_

5.510
5.988
5.686
4.836
5.077
5.716
3.573
2.020
1.488
0.588
0.089

33

40.571

26

Expected Deaths

�Table 33
NON-BLACK COMPARISON ENLISTED PERSONNEL VERSUS THE 1978 U.S. WHITE MALE
LIFE TABLE
(T =-5.923, ? &lt; .001)

Age

At Risk

Deaths

Expected Death

19-19
20-21
25-29
30-34
35-39
40-44
45-49
50-54
55-59
60-64
65-69
70-74

3563
3562
3546
3528
3006
1792
1323
653
201
103
35
5

1
16
18
18
19
16
26
14
11
3
1
0

6.325
33-938
29.713
28.189
23.987
25.200
28.341
17.201
10.053
7.538
2.515
0.601

T4~3

213.601

Given the cautions just described, these findings suggest that the
non-Black Ranch Handers and comparisons are living much longer than expected
relative to the 1978 U.S. White Male Life Table. The ratios of the observed
to the expected deaths described in Tables 28 and 29 reveal that the Ranch
Hand and comparison subjects are experiencing death at only 60 to 6556 of the
rate of the U.S. White male population.
The ratio is 0.461 for the subset
of Ranch Hand officers, 0.543 for comparison officers, 0.813 for enlisted
Ranch Handers, and 0.669 for enlisted comparison subjects. The healthy worker
effect is very likely a major contributor to the undoubtedly real differences
between these study groups and the general population.

27

�Chapter V

'.

COMPARISONS WITH THE WEST POINT STUDY GROUP

1. Background and Motivation
The statistical and epidemiological literature is replete with warnings
against the uncritical use of the SMR and related summary measures for comparing study groups with published vital statistics for national populations or
subpopulations (5), (24), (25). Those cautions are based on the adjustment
difficulties described in Chapter 4, Section 2, and departures from the assumption of constant relative risk across age intervals between the study
group and the external population. These drawbacks can be avoided by not
referencing an external standard at all, by using one of the study groups as
the standard (13). or by using as an external standard a group of military
personnel, born during approximately the same years, with the same mortality
follow-up, as the Ranch Hand and comparison groups.
An external group of sufficient size for meaningful statistical comparisons is not available at this time. Mortality and year of birth data are
available, however, on a small group of West Point graduates, the subjects of
the West Point Follow-up. Study. Although this group is too small for all but
very crude statistical comparisons (1), it is the only known external data
available at this time. The following comparisons are, therefore, primarily
descriptive.
The West Point Study Group consists of W members of the West Point
graduation class of 1956. These men have been followed up since then for
morbidity and mortality. All members of that class were, or still are, officers in the U.S. Armed Forces. The purpose of the West Point study is to
investigate the relationship between blood lipid levels and cardiovascular
disease. Each study subject is physically examined biennially and blood samples are obtained for lipid and lipoprotein analyses at the USAF School of
Aerospace Medicine (26).
2. Noncause Specific Comparisons of Ranch Hand and Comparison
with the West Point Study Group

Subgroups

For the purpose of these mortality comparisons, 15 of the 36 known West
Point deaths occurring on or before 31 December 1982 were deleted, 9 of the 15
were killed in action, one was killed in 1959 in the line of duty and 5 were
killed in automobile crashes prior to 1962. These deletions imitate the deletion of personnel killed in action from the Ranch Hand and comparison groups.
Noncombat or accidental deaths prior to 1962 were deleted because death prior
to 1962 would have precluded membership in the Ranch Hand or comparison
groups. In addition, one West Pointer who is also a Ranch Hander, was deleted; that individual was alive on 31 December 1982.
28

�A summary of the remaining 21 deaths among the 458 West Point subjects
used in these analyses is given by year of birth in Table 34 and by age in
Table 35. In Table 35 the column headed "censored" lists by age, the number
of West Pointers alive on 31 December 1982.
Table 34
WEST POINT DEATHS BY YEAR OF BIRTH

Year of Birth

At Risk

Dead

1930
1931
1932
1933
1934
1935

20
59
90
136
141
12
458

0
2
6
8
4
J_
21

Table 35
WEST POINT DEATHS BY AGE
Age
25-29
30-34
35-39
HO-44
H5-H9
50-52

At Risk

Censored

458
456
451
4 4 8
lji)6
162

Dead

0
0
0
0
276
161
437

2
5
3
2
8
J_
21

In this analysis, non-Black Ranch Hand and comparison officers are compared, without regard to cause of death, with the West Point study group; all
of the West Point subjects are non-Black. Non-Black Ranch Hand Officers were
matched, one-to-one, by year of birth, to West Point subjects. Due to the
relatively small number of Ranch Hand officers and the limited year of birth
range imposed by the age of the Class of 1956, only 283 of the 458 West Point
subjects received a matched Ranch Hander. Matched sets with West Pointers
having the same year of birth were then merged to create six matched sets,
corresponding to the six years of birth, 1930 through 35, of the West Pointers. To compare West Pointers with comparison officers, two non-Black comparison officers were matched to each West Pointer by year of birth. All West
Pointers received two matched comparison individuals. Matched sets with West
Pointers having the same year of birth were merged, giving six. matched sets
containing a total of 916 comparisons.

29

�Logrank teats were carried out on these two matched data sets, and the
results are summarized in Table 36. In these analyses, survival time is age
at death. Censorship is due to survival to 31 December 1982. For those still
alive on 31 December 1982, censoring time is age on that day.

Table 36
STUDY GROUP VERSUS WEST POINT GROUP
LOGRANK COMPARISONS WITH TWO-SIDED P-VALUES

Comparison

P-Value

Ranch Hand officer versus West Point
Comparison officer versus West Point

.218
.528

An SMR analysis, with the West Pointers being the standard, is summarized
in Table 37.
Table 37
SMR COMPARISON OF NON-BLACK RANCH HAND AND COMPARISON
OFFICERS WITH THE WEST POINT STUDY GROUP

(SMR = .530)

Birth
Year

25-31
32
33-34
35-40

(SMR = .778)

Ranch Hand

(SMR = 1)

Comparison

West Point

At Risk

Dead

Rate

At Risk

Dead

Rate

At Risk

Dead

Rate

95
35
60
93

2
1
1
1
8

.021
.029
.017
.043

272
164
257
223

19
7
6
_5
37

.070
.043
.023
.022

79
90
277
12

2
6
12
J_
21

.025
.067
.043
.083

The test for constant relative risk across year of birth strata gives a
P-value of .229. Further, a likelihood ratio test suggests that these SMR's
are not different (P = .392).

�j. Cause Specific Comparisons
The &lt;VHi.se .sponi f \.r. death count,0, for the West Point Study Group are givon

in Table
Table 38
WEST POINT MORTALITY BY CAUSE

Cause

Count

Accidents
Infectious disease
Malignant neoplasms
Circulatory
Digestive
Genitourinary
111 defined

6
1
6
5
1
1
1
21

Cause specific comparisons are carried out with three causes, cancer
(malignant neoplasms), other diseases, and nondisease (accidents, suicides,
homicides and ill-defined), with an adjustment for year of birth by stratification on year of birth. Relative risks are calculated using the method of
Mantel and Haenszel (14). These results, based on the counts in Tables 39 and
40, are shown in Table 41.
Table 39
CAUSE SPECIFIC COMPARISONS
RANCH HAND OFFICERS VERSUS WEST POINT

Ranch Hand
At Risk Dead

West Point
At Risk Dead

Cause

Birth Year

Nondisease

1925-1933
1934-1940

166
117

1
M

305
153

5
1

Cancer

1925-1930
1931
1932
1933
1934
1935-1940

72
23
35
36
24
93

0
0
0
0
0
0

20
59
90
136
141
12

0
1
3
1
1
0

Other diseases

1925-1934
1935-1940

190
93

2
1

446
12

8
1

31

�Table 40
CAUSE SPECIFIC COMPARISON
COMPARISON OFFICERS VERSUS WEST POINT

Birth Year

Cause
Nondisease

Comparisons
Dead
Number

Other diseases

1

11
2
1
2

79
90
136
153

2
2
1

272
164
148
332

2
2
1

79
90
136
153

3
1
1

436
148
109
223

9
1
1

169
136
141
12

1
5
2
1

1929-1931
1932
1933
193^-1937

272
164
148

1929-1931
1932
1933
1934-1937

Cancer

West Point
Dead

Number

1929-1932

332

1933
1934
1935-1937

2

3

1

Table 41
CAUSE SPECIFIC RELATIVE RISKS, P-VALUES
95$ CONFIDENCE INTERVALS FOR LOG RELATIVE RISK

95% Conf Interval
Cause

Comparison

Nondisease

RH vs WP
Comp vs WP

1.072
0.841

(-1.504 - 1.643)
(-1.354 - 1.009)

.931
.775

.051
.059

Cancer

RH vs WP
Comp vs WP

0.690

(-1.634 - .891)

.564

.089

Comp vs WP

0.474
0.779

(-3.540 - 2.047)
(-2.367 - 1.867)

.600
.817

.082
.056

RH vs WP
Comp vs WP

0.539
0.728

(-2.191 - .954)
(-1.940 - .306)

.441
.702

.120
.067

Other diseases RH vs WP
All causes

RR

for Log Rel Risk

32

P-value Power

�While the Ranch Hand versus West Point cancer comparison cannot be assessed using the Mantel-Haenszel procedure, the absence of Ranch Hand cancer
deaths in this analysis is of interest. This finding is consistent with the
apparent but nonsignificantly decreased Ranch Hand cancer mortality noted in
the Ranch Hand versus matched comparison group analysis (Chapter III).

33

�Chapter VI
STATISTICAL ASPECTS

1. Purpose
The purposes of this chapter are 1) to briefly describe each statistical
procedure used in the preceding chapters 2) to state the underlying assumptions of each procedure and 3) discuss the validity of those assumptions in
this study. The procedures used in this analysis were survival curve estimates and confidence bands, linear rank tests, relative risk estimation and
standardized mortality ratios. Points 1-3 are addressed for each procedure in
Sections 2 through 5.
2. Survival Curve Estimation and Confidence Bands
The survival function of a homogeneous population, S(t), is defined as the
probability of surviving t years.
The problem is to estimate S(t) and make
a confidence statement about that estimate based on randomly censored data.
Randomly censored data occur in survival studies since analyses are usually
carried out before all subjects have failed.
In the present application,
failure is defined as death and censorship occurs because most subjects are
still living at the time of analysis. Other causes for censorship in this
kind of epidemiological study are loss to follow-up or death from causes other
than those of interest. Thus far in this study, there have been no subjects
lost to follow-up, and all causes of death are of interest.
The survival function is estimated here by the product limit estimate K(t),
also called the Kaplan-Meier estimate (6). This estimate is derived under the
assumption that, in a life testing experiment with n subjects on test, exactly k subjects, with k less than n, are observed to fail; the other n-k
remaining are observed only until they are censored. The subjects are assumed
drawn randomly from a homogeneous population. Censorship is assumed to be
independent of failure. The Kaplan-Meier estimator is asymptotically unbiased
and reduces to one minus the empirical distribution function in the absence of
censoring.
In the present application, the homogeneous populations are the Ranch
Handers, the comparisons and various subgroups of these two groups.
Death
time is taken as age at death measured to the nearest month; censoring time
is age" on 31 December 1982, measured to the nearest month. Survival time is
age at death or age on 31 December 1982 for those subjects still living.
The process n[K(t)-S(t)] converges weakly to a zero mean Gaussian process,
as n tends to infinity, under random censorship when the underlying survival
function S(t) and the censoring distribution are continuous on a bounded interval (27). This convergence is the theoretical basis for the confidence
band algorithm (7) used in Figures 2 and 3, Chapter III and Appendices VI.

�The independence of death and censorship can be assumed to hold horc
since censorship (survival to December 31, 1982) is not being invoked on individuals because they appear to be at unusually high, or low, risk of death
(28). Direct contact has been lost with two Ranch Handers and nine comparisons as described in Chapter II, but these are assumed to be alive, and hence
censored at their age on 31 December 1982. The reason for this assumption is
that the extensive death ascertainment system is believed to be thorough
enough so that, had any of these subjects died, the death would have been
detected. Hence, while contact has been lost, loss to follow-up for the purpose of mortality determination has not occurred (29).
All other subjects
still alive on 31 December 1982 are censored at their age on that date.
The validity of inferences based on the estimate K(t) and its associated
confidence band depends on the sample size and the observed number of deaths.
The sample sizes and numbers of deaths in every stratum used in these analyses
exceed the minimum requirements for these procedures (7).
The survival curve estimates and confidence bands displayed in Figures 2
and 3 and Appendix VI are not adjusted for year of birth. To do so would have
required stratification on year of birth, creating many small strata with
associated sample size difficulties. Some year-of-birth adjusted plots in the
larger occupational strata will be presented in the next report.
3. Linear Rank Procedures
The hypothesis of interest in this analysis is that the actual survival
distributions of the Ranch Handers and their matched comparisons are identical. The procedures of choice for testing equality of the two unknown survival
distributions based on the matched and censored data in this study are the
censored data extensions of the exponential scores and Wilcoxon tests, due to
Prentice (8). The first of these is widely known as the logrank test. The
test statistics, T, are of the form given by equation 6-23 of (28), where the
summands are calculated on matched sets consisting of survival information on
one Ranch Bander and his matched mortality comparisons. The statistic T, for
either logrank or generalized Wilcoxon summands, is approximately standard
normal under the null hypothesis (9).
tions
other
study
favor

The large sample normal approximation for T will hold when all distribuare continuous and all censoring times are mutually independent of each
and independent of death. These assumptions are well satisfied in this
since the censorship mechanism, survival to time of analysis, does not
one group over the other.

In these procedures, the sampling unit is a matched set, so that these
tests are adjusted for all matching variables. Prior to calculation, matched
sets with Ranch Handers in the same race and job classification having the
same year of birth are merged.

35

�The logrank and extended Wilcoxon tests are locally most powerful when
the logarithm of the survival times are distributed as extreme value or logistic random variates, respectively.
While the efficiency of these procedures peaks at these two underlying distributionsf they have been shown to be
robust against departures ( ) These distributional assumptions, however, are
8.
not viewed as strictly valid in this study since there is good evidence in the
literature that survival time due to certain cancers and other diseases is log
normally distributed (30, 31, 32, 33). A linear rank procedure of the Prentice
form, whose efficiency peaks under the lognormal distributional assumption,
can be constructed" (3*0, but this algorithm is not available at the present
time; it will be included in the next analysis. The effect of this departure
from the assumptions is considered mild. It should also be noted that these
distributional assumptions cannot be checked since these match sets are small
and the observations in the combined samples of all matched sets cannot be assumed to have a common distribution. Therefore, reliance must be placed on
historical data to determine which linear rank procedure to use. The logrank
and Wilcoxon procedures are used here because they are powerful and widely
accepted in epidemiology and statistics.
4. Relative Risk Estimation
Two relative risk estimators are used in this analysis, a generalization
of the Ejigou-McHugh estimator for one to many matched data (12) and the Mantel-Haenszel estimator for stratified data (14). The Ejigou-McHugh estimate
was chosen because it allows full adjustment for the one-to-many year-of-birth
matching in this study, it is asymptotically as efficient as the maximum likelihood estimator and it is noniterative. The Mantel-Haenszel estimate was
chosen because of its ease of calculation, efficiency (35), and general acceptance. It's variance is estimated according to the advice of Anderson et
al. (36). Recent work suggests that the variance of the Mantel-Haenszel statistic might be better estimated by a jack-knife procedure (37); this newer
method will be carried out in the next mortality report.
The Ejigou-McHugh estimator in its published form is suitable only for 1 to R
matched designs in which the number, R, of controls matched to each case is
the same for all cases. Since the number of controls matched to each Ranch
Hander is not the same for all Ranch Handers, the Ejigou-McHugh estimate and
its variance was extended to a one-to-many matched design in which the number
of comparisons is allowed to vary from case to case. Since this extension is
unpublished it is stated in Appendix V for reference.
The extended estimate and its variance reduces to the Ejigou-McHugh estimate and variance when all matched sets contain an equal number of comparisons. It is asymptotically efficient and consistent and is noniterative.
The Ejigou-McHugh estimate and the Mantel-Haenszel estimate are based on
the assumption that relative risk is constant across levels of the matching
variable. Some indication that this assumption holds in this study when the
data is grouped, by stratifying on year of birth, is furnished by likelihood
ratio testing; there is no evidence in this study to suggest that relative

36

�risk is not constant across levels of the matching variables when the event of
interest is death from any cause. Therefore, the Ejigou-McHugh and Mantel-Haenszel estimates are appropriate for these data.
5. Indirect Standardization
With either an external or internal standard, the SMR is a good summary
mortality index for comparing two or more populations, provided the product
model, P.jj=ripj, holds, where PJJ is the probability of death in stratum i of
population j, r^ is a set of standard stratum specific rates and PJ characterizes the mortality of population j, 1=1,2, ..., I, j=1,2, ..., J, (38, 13).
If standard rates are known from some external source and if the product model
holds, the best estimate of pj is proportional to the SMR. If J=2, the product model holds, and if one of the two groups is used as the standard, the SMR
estimates relative risk.
In any case, any SMR summary of mortality data
should be preceded by analytical and graphical tests of fit of the product
model. Because one of the study groups was always used as the standard in
these analyses, the test of fit of the product model was, equivalently, a test
of constancy of relative risk across year of birth strata. The fit of the
model was verified in each analysis. Further, a likelihood ratio test for
equality of population was carried out as described by Gail (13). The results
of both tests are summarized by their P-values in each application. The sample sizes in every application are large enough so that chi-square approximations hold; these analyses are, therefore, valid and appropriate.
The expected number of deaths in the SMR used in these analyses was
calculated as In^rj, where n^j is the number of subjects in the ith stratum
of the jth population. The person-years SMR was not used here for two reasons. First, its validity as an estimator of relative risk is dependent upon
the fit of the proportional hazards model for which an omnibus test is not
currently available.
Secondly, the person-years calculation is typically
carried out from entry into follow-up (5); in this study, follow-up begins at
first entry to Vietnam or Southeast Asia and these entry dates are being verified at this writing.
6. Comparing Observed Life Table Data with a Known Survival Curve
The procedure of Gail and Ware (17) is used in these analyses to compare
Ranch Hand and comparison group survival data with published period life tables. The basic assumptions of this procedure are that death and censorship
are independent competing risks and that the reference curve is a survival
distribution for some external population.
The test is of the form
e
v
wnere
an e are
^°j~ j }/(I j ^ ^»
°j $ j
observed and expected numbers of deaths
in age interval j, and Vj is the variance of OJ-BJ. The statistic is not an
omnibus goodness-of-fit test consistent against all alternatives to the null
hypothesis that the observed sample comes from a known survival distribution.
Rather, it has good power against proportional hazards alternatives or, more
loosely, against alternatives for which the observed survival is better (or
worse) in every interval than predicted by the known survival curve.

37

�The independence of death and censorship assumption is well satisfied in
these data, as discussed in Section 2 of this chapter. The life tables used
in these analyses do not, however, represent the survival distribution of any
population since they are period, not cohort, life tables. The appropriateness of this procedure is, therefore, dependent upon the extent to which these
period life tables approximate the survival distribution of some relevant
reference population. These period tables were used because the more appropriate cohort life tables were not available at the time of analysis.

�Chapter VII
CONCLUSION

1. Introduction
The mortality analyses described in this report have not revealed any
adverse death experience in the herbicide/dioxin exposed cohort. The results
of the analyses, regardless of the source of the comparison data, were consistent: at this time, there is no indication that operation Ranch Hand personnel have experienced any increased mortality or any unusual patterns of death
in time or by cause. They are not dying in increased numbers, at earlier
ages, or by unexpected causes.
The fact that only a relatively small number of Ranch Hand deaths were
available for analysis is reassuring in itself. However, the fact that adverse effects have not yet been detected does not imply that an effect will
not become manifest at a future time or after covariate adjusted analyses. For
this reason, further analyses are intended and mortality in the study population will be ascertained annually for the next 20 years.
A summary of the statistical techniques applied to each source of comparison data is presented in Table 42. It should be noted here that these
analyses have been carried out without knowledge of covariate information,
such as herbicide exposure, industrial chemical exposure, or other risk factors and that these analyses were carried out at a time when approximately
96? of Ranch Handers and their matched comparison subjects were still living.
The data, therefore, must be viewed as preliminary to more definitive analyses, which will be performed over the next 20 years. Table i»3 summarizes the
results of the noncause specific analyses by source of the comparison data,
and Table M presents the results of the cause specific analyses.

39

�Table 42

SUMMARY OF STATISTICAL PROCEDURES USED IN ANALYSIS

Comparison Database

Internal
Comparison
Group

1978
1978 DoD
U.S.
Life
West Point
White Males Tables Class of 1956

Noncause Speoifio Analyses
Logrank &amp;
Wilcoxon Procedures
Ejigou-McHugh
Relative Risk
Mantel-Haenszel
Relative Risk
SMR/Breslow-Day
Product Model
Gail-Ware Procedure

+

+

•«•
+

+

+

+
+

+

Cause Specific Analyses
Ejigou-McHugh
Relative Risk
Mantel-Haenszel
Relative Risk

+
+

+

Procedure usage is indicated by a "+" symbol.

40

�SUMMARY OF NONCAUSE SPECIFIC MORTALITY ANALYSES BY SOURCE
OF COMPARISON DATA

Internal
Comparison
1978 US
Group
White Males^
Ranch Hand Group

RH = C
RH0 = C0
RHE = CE

RHp = Cp
RHG = CG
Comparison Group

RH &lt;«US
RH0 «&lt;US
RHE
SUS

C &lt;«US
C0 &lt;«US

CE &lt;«us

Internal Occupational
Group Specific

«
£
&lt;
«
&lt;«

P
P
P
P
P

1978 DoD
West Point
Life Tables1 Class of 19562
RH0 «&lt;DoD0
RHE = DoDE

CQ &lt;

RH0 - WP0

C0 = WP0

RH0 $ RHE
RHp $ RHG
C0 &lt; CE

valued greater
value equal to
value equal to
value equal to
value equal to

than .10
or less than .10
or less than .05
or less than .01
or less than .001

RH Ranch Hand Group
C Comparison Group
0 Officers
E Enlisted
F Flying
G Ground

1
2

Validity of these comparisons is questionable (see Chapter H)
Statistical inference is limited by small sample size
3 All P value symbols are based upon SMR and Gail-Ware analysis
Table W
SUMMARY OF CAUSE SPECIFIC ANALYSES
BY SOURCE OF COMPARISON DATA

RH Versus
Internal Comparison
No significant difference
in cause specific relative
risks

RH Versus
West Point*
No significant difference
in cause specific relative
risks

* Statistical inference is limited by small sample size

�2. Internal Comparison Group
Based on these early results, there appears to be no significant difference between Ranch Handers and comparisons as regards mortality. This null
finding holds for both cause specific and noncause specific comparisons. One
within group comparison did yield a significant difference, however. The
non-Black comparison officers are living significantly longer than the
non-Black comparison enlisted personnel.
This may reflect the underlying
health care and socioeconomic differences between these two groups. Non-Black
Ranch Hand officers also appear to be living longer than non-Black Ranch Hand
enlisted personnel, but this finding cannot be viewed as significant, with a
P-value of .142 (Table 17).
This lack of significance in the Ranch Hand
analysis might be attributed to the smaller group sizes within the Ranch Hand
cohort in contrast to the comparison cohort.
3. External Comparisons
As outlined in the study protocol, considerable effort was expended in the
selection of the study comparison group. While the chosen comparison group
appeared closest to the Ranch Hand cohort except for herbicide exposure, it
seemed appropriate to also contrast the Ranch Hand mortality experience to
that of additional comparison groups. Three additional comparison data sets
were then selected: mortality data from the West Point Class of 1956, the DoD
Nondisability Retired Officer and Enlisted Life Tables for 1978, and the U.S.
White Male Life Table, also for 1978. These data sets were chosen in a hierarchical fashion with the expectation that, in the absence of a herbicide
effect, the Ranch Handers would have: 1) a mortality pattern comparable to
the West Pointers, 2) a lower mortality than the DoD group due to the healthy
worker effect, and 3) a still lower mortality than the U.S. male cohort due to
healthy worker and military selection effects. These expectations were reassuringly fully realized with respect to overall mortality. Additionally,
interesting officer-enlisted differentials emerged. As discussed below, these
officer-enlisted differentials may have resulted from sample size effects or
from covariable effects, potentially including herbicide exposure.
4. Power Considerations
The power limitations of this study, specifically regarding mortality from
rare conditions, such as soft tissue sarcoma, were fully acknowledged and
described in the protocol (Ref 1, page 67). For example, a fatal disease with
an incidence of .001 would require an approximate risk of 4 for a power of
0.8.
Power calculations, while desirable for planning and study design, are
also revealing at analysis. They are, however, sometimes difficult to carry
out without further assumptions. The powers of the logrank and Wilcoxon tests

�and the likelihood ratio tests in the SMR analyses are not calculable at
this time due to the lack of appropriate methodology. The powers of the tests
for cause specific mortality were calculated at the estimated relative risk.
The values were low because the estimates of relative risk were close to unity
and/or the data were sparse.
The null findings in this report are unlikely to have been observed by
chance had the true group differences been substantial. For example, if the
true overall relative risk were in fact equal to 2, a crude calculation gives
a probability of .0007 of observing a relative risk smaller than the observed
.96*1 (Table 7). This probability is less than .001 if the true relative risk
is 1.5. These findings are, therefore, very likely reflective of a near overall equivalence between Ranch Handers and their matched comparisons. Finally,
these unadjusted findings do not preclude the possibility of the emergence of
significant differences after adjustment for risk factors.
5. Consistency Patterns
When the analysis of each external comparison data base is considered
separately, the restrictions inherent in each source limit the strength of the
inferences which can be made. However, when the results of all internal and
external comparison data bases are considered in context, some patterns of
consistency emerge. While some of these patterns may not have firm statistical underpinnings, they still may provide epidemiologic clues to the dynamics
of the mortality process.
The Ranch Hand officers exhibit a very consistent and predictable pattern
across all analyses. As shown in Table ^43, their mortality is nearly the same
as that of their most equivalent comparison groups (the matched comparison
group officers and the West Point group).
As the comparison groups become
progressively less equivalent to the Ranch Hand group, the relative mortality
of the Ranch Hand officers improves, presumably due to selection comparability
(healthy worker effect, etc.). Their mortality is lower than that of their
enlisted counterparts; however, this difference is not as striking as is the
statistically significant comparable analysis between the matched comparison
officers and the matched enlisted personnel.
Unfortunately, the cross-comparison trends for the enlisted Ranch Handers
are not as clearcut. Their mortality is greater,though not significantly different from their matched comparisons. The enlisted comparison group had a
highly significant underrepresentation of mortality against both the DoD and
US life tables, whereas the Ranch Handers are equivalent to the DoD group and
only marginally better than the 1978 US White males.
The consistent observation that the enlisted Ranch Handers appear to demonstrate less of a difference in relative mortality than do their matched
comparisons is intriguing. This may reflect an actual increase in mortality
due to herbicide exposure or some other factor, or it could be an artifact of
small sample size created by the 1:5 matching or basic comparability problems
as previously described. The inclusion of substantially more subjects in one
group than another can have a profound effect on the significance level of a

�statistical technique. Nevertheless, these observations are of interest, and
will continue to be subjected to detailed analysis throughout the course of
the follow-up study. This trend is consistent with self-perception of herbicide exposure held by many of the Ranch Hand group. Covariate analyses will
be conducted, the herbicide exposure index will be applied to these data, and
the effects of interaction will be assessed to determine whether the Ranch
Hand enlisted findings are real or artifactual.
The next mortality assessment will include analyses by person-year of
follow-up, adjusted for age in an effort to better address the issue of latency. As the number of deaths in the study population increases with the
passage of time, all of the statistical approaches outlined in the protocol
(1) will be applied to the data.

�Appendix I
RANCH HAND II PRINCIPAL INVESTIGATORS
COINVESTIGATORS, CONTRIBUTORS, AND MANAGEMENT PERSONNEL

A. Principal Investigators
George D. Lathrop, MD, MPH, PhD, FACPM
Colonel, USAF.MC
Chief, Epidemiology Division
Patricia M. Moynahan, RN, MS
Colonel, USAF, NC
Chief, Occupational Epidemiology Section
Richard A. Albanese, MD, GM-15
Chief, Biomathematical Modeling Branch
Data Sciences Division
William H. Wolfe, MD, MPH, FACPM
Lt Colonel, USAF,MC
Chief, Epidemiology Services Branch
B. Coinvestigators
Joel E. Michalek, PhD, GS-13
Mathematical Statistician
Data Sciences Division
Richard C. McNee, MS, GM-13
Chief, Advanced Analysis Branch
Data Sciences Division
Alton J. Rahe, MS, GS-13
Mathematical Statistician
Data Sciences Division

�Appendix I (Continued)

C. Contributors
William J. Besich, BS, GS-12
Computer Systems Analyst
Data Sciences Division
Vincent V. Elequin, BS, RRA, GS-11
Medical Record Librarian
Occupational Epidemiology Section
William E. Nixon, BS, GM-13
Computer Systems Analyst
Data Sciences Division
Thomas J. White, MA
Senior Subject Matter Specialist
Data Sciences Division
i
Alvin L. Young, BS, MS, PhD
Major, USAF
Special Assistant in Military Herbicides
D. Management Personnel
Project Director:
Roy L. DeHart-, MD, MPH, MS, FACPM
Colonel, USAF, MC
Commander, USAF School of Aerospace Medicine
Project Resource Manager:
Melvin B. Dobbs
Colonel, USAF, BSC
Director, Systems Acquisition Research, Development
and Acquisition
Aerospace Medical Division
Air Force HQ Systems Command Coordinator:
Ronald D. Burnett
Colonel, USAF, BSC
Command Bioenvironmental Engineer
Office of the Command Surgeon
Air Force Surgeon General Coordinator:
Robert A. Capell
Major, USAF, BSC
Assistant for Bioenvironmental Engineering
Office of the Surgeon General

46

�Appendix II
SCIENCE PANEL

Advisory Committee on Special Studies Relating to the Possible Long-Term
Health Effects of Phenoxy Herbicides and Contaminants.

Dr. G. W. Comstock
Johns Hopkins Research Center
Box 2067
Hagerstown MD 217^0
Dr. John Doull

Professor
Department of Pharmacology and Toxicology
University of Kansas Medical Center
Kansas City KA 66103
Dr. John A. Moore (Chair)
Deputy Director
National Toxicology Program
P.O. Box 12233
Research Triangle Park NC 27709
Dr. Richard Monson
Professor of Epidemiology
Harvard School of Public Health
677 Huntington Avenue
Boston MA 02115
Dr. Norton Nelson

Professor and Chairman
Department of Environmental Medicine
New York University
School of Medicine
New York NY 10016
Dr. Alan Poland
Associate Professor of Oncology
McCardle Laboratory
University of Wisconsin
Madison WI 53706

Dr. Irving Selikoff
Director, Environmental Sciences Laboratory
Mt Sinai School of Medicine
5th Avenue and 100th Street
New York NY 10029

47

�Appendix III
MATCHING RESULTS IN THE MORTALITY POPULATION

The matching results are described here for the mortality population
consisting of 1241 Ranch Hands, their 6171 matched mortality comparisons, and
the six unmatched Ranch Hands. The matching procedure is described in the
Protocol (Ref. 1, pages 23~26).
All study subjects were matched perfectly on job category. Three mismatches occurred on race because the recorded race designations for three
study subjects were found to be incorrect at the LHA interview. These three
subjects were comparisons, two were in the enlisted-other stratum (one was
originally recorded as Black and was discovered to be non-Black, the other was
originally recorded as non-Black and was discovered to be Black), and one was
in the enlisted-flight engineer stratum (he was originally recorded as Black
and was discovered to be non-Black).
Matching on date of birth was carried out by first expressing date of
birth in months from 1 January 1900, to the nearest month; the result is termed month-of-birth. Six discrepancies occurred in matching on month-of-birth
due to erroneous months-of-birth for one Ranch Hand and one comparison. These
were discovered at the LHA interview. The Ranch Hand, in the non-Black enlisted-other stratum, was discovered to be 72 months older than was recorded
prior to the matching. The comparison, in the non-Black officer-pilot stratum, was found to be 15 years younger than was originally recorded. The erroneous Ranch Hand month-of-birth put all five of his matched comparisons 12
months out of range since he was originally perfectly matched to all five
mortality
comparisons. The erroneous comparison month-of-birth put that
comparison 119 months out of range. Given the very small number of mismatches
on age and race relative to the number of subjects, their effect was assumed
negligible.
The matching by month-of-birth, overall, and within each of the ten job
and race categories within the mortality population is summarized in this
Appendix. The column headed "Age Difference" lists absolute differences of
months-of-birth of Ranch Hands and comparisons. The column headed "Number of
Comparisons with RH younger (older)" gives, at each level of age difference,
the number of comparisons within the level of age difference and older
(younger) than the Ranch Hand to whom they are matched. The column headed
"Total Count" gives the total numbers of comparisons having the absolute age
differences with their matched Ranch Hand given in the first column; in
"Total Percent", these counts are expressed as percentages of 6171.
These
are cumulated in the last two columns.

�Appendix III
MATCH SUMMARY FOR THE MORTALITY POPULATION

Strata

Age
Difference

Comparisons with RH
Total
Younger
Older
Count

Cumulative
Total
%
*

Overall

Officer-pilot
Non-Black

Officer-Pilot
Black

OfficerNavigator
Non-Black

0
1-6
7-12
13-18
19-21
25-30
31-36
37-42
13-18
19-51
55-60
72
179
0
1-6
7-12
13-18
19-21
25-30
31-36
37-12
13-18
19-51
55-60
179
0
1-6
7-12
31-36
37-12
13-18
19-51
55
0
1-6
7-12

713
77
10
22
12
16
10
9
13
17
0
0

706
102
36
22
19
11
19
13
7
7
5
1

272
33
20
8
9
13
7
7
11
11
0

259
32
17
12
11
10
18
11
7
7
1

3
3
0
2
1

0
0
1
0
0
0
0

2
1

70
6

71
0

19

1261
1119
179
76
1
1
31
30
29
22
20
21
5
1

1261
5710

69.0
23.5
2.9
1.2
0.7
0.5
0.5
0.5
0.1
0.3
0,1
0.1
0.0

5889
5965
6009
6010
6070
6099
6121
6111
6165
6170
6171

961
531
65
37
20
20
23
25
18
18
21
1

55.2
30.5
3.7
2.1
1.1
1.1
1.3
1.1
1.0
1.0
1.2
0.1

961
1192
1557
1591
1611
1631
1657
1682
1700
1718
1739
1710

89.5
91.6
92.8
93.9
95.2
96.7
97.7
98.7
99.9
100.0

0
3
3
1

0.0
23.1

0.0
23.1
16.2
53.9
69.2
76.9
92.3
100.0

61.5
98.5
100.0

2
1
2
1

7.7
15.1
7.7
15.1
7.7

0
3
6
7
9
10
12
13

210
111
6

61.5
36.9
1.5

210
381
390

23.1

69.0
92.5
95.1
96.7
97.1
97.9
98.1
98.8
99.2
99.5
99.9
100.0
100.0

55.2
85.8

�Appendix III (Continued)
MATCH SUMMARY FOR THE MORTALITY POPULATION

Strata
OfficerNavigator
Black

Number of
Total
Comparisons with RH
Age
Younger Older Count %
Difference

0
1-6
7-12
13-18
19-21
25-30

31-36
Officer-Other
Non-Black

0
1-6
7-12

13-18
19-21*
25

Officer-Other 13-18

1

0
2
0
0
0
0

2
1
1
1
1

38
2
1
1
0

57
8
1
0
1

2

0

Cumulative
Total
%

1
1
1
1
1
1
1

10.0
10.0
10.0
10.0
10.0
10.0
10.0

1
2
6
7
8
9
10

10.0
20.0
60.0
70.0
80.0
90.0
100.0

11
95

11.1
77.2

10
2
1
1

8.1
1.6
0.8
0.8

11
109
119
121
122

11.1
88.6
96.8

2

98.1

123

99.2
100.0

100.0

2

100.0

516
306

55.2
32.7

55.2
87.9

6.7

516
822
885

Black
EnlistedFlight

0
1-6

Engineer
Non-Black

7-12
13-18
19-21
25-30

31-36
37-12
46
EnlistedFlight

Engineer
Black

111
34
11

0
2
2
1
1

7
6
1
0
0

63
30
7
8
3
1
1

26
7

22
5
0
0

10
18
12
3
2

13.3
61.0
16.0

16

0
1-6

Non-Black

7-12
13-18
19-21
25-30
31-36
37-12
13-18
72

0
1-6
7-12

3.2

91,7
97.9
98.6
99.5
99.8
99.9

3
2

116
1
1

91
11

0.7

915
922

0.9

930

0.3

933
931
935

100.0

1.0
2.7

10
58
70
73
75

13.3
77.3
93.3
97.3
100.0

2382

0

1-6
7-12
19-21
55-58

EnlistedOther

EnlistedOther
Black

165
29

90.6

2382

7.9
0.5
0.2
0.5
0.0
0.1
0.0
0.1
0.2

2589

90.6
98.5
99.0
99.1
99.6
99.6

53.7
11.7

10
1
1
0
0
0

2
0
1
1
2
5

207
12
1
12
1
2
1
2
5

19
0

65
1

137
111
1

3

50

0.1
0.1

1.6

2601
2605
2617
2618
2620
2621
2623
2628

99.7
99.7
99.8
100.0

137
251
255

53.7
98.1
100.0

�Appendix IV
YEAR OF BIRTH, OCCUPATIONAL AND RACE SPECIFIC MORTALITY

Birth
Ranch Hand
Job Category, Race Year At Risk Dead

Death
Rate

Officer-Pilot,
Non-Black

.375

1 915-19
1 920-21
1 925-29
1 930-31
1 935-39
1 910-11
1 915-19

8
31
31
113
66
60
10

3
0
0
3
3
1

Comparison
At Risk Dead

1
13
11

Death
Rate

23
8
5
5

.103
.081
.060
.050
.025
.011
.028

TOTAL 319
Officer-Pilot,
Black

2

.027
.015
.017
.050

39
155
232
156
326
351
178

12

.031

1710

72

.011

0
1
3
2

0
0
0
0

3
1
6
0

0
0
0
0

6

0

13

0

9
35
21
13

17
163
105
67
8

3
7
3
0
0

.061
.013
.029

2

0
1
1
0
0

80

2

390

13

.033

1
1

0
0

6
1

0
0

2

0

10

0

1
0
1
3
2
1

0
0
0
0
0
0

2
3
6
11

0
0
0
1
1
0
1
0

1 930-31
1 935-39
1 910-11
1 915-19
TOTAL

Officer-Navigator 1 925-29
Non-Black
1 930-31
1 935-39
1 910-11
1 915-19
TOTAL

Officer-Navigator 1 930-31
Black
1 935-39
TOTAL

Officer-Other,
Non-Black

1 910-11
1 915-19
1 920-21
1 925-29
1 930-31
1 935-39
1 910-11
1 915-19
TOTAL

13
1

.029
.018

.025

12

.077

19
66
1

.010

1

123

0

25
51

.091
.083
.015
.021

�Appendix IV (Continued)

Job Category, Race
Officer-Other,
Black

Birth
Ranch Hand
Year
At Risk Dead

Death
Rate

Comparison
At Risk
Dead

Death
Rate

1940-44
TOTAL

Enlisted-Fit Eng
Non-Black

1
0
0
3
2
0
0

1925-29
1930-34
1935-39
1940-44
TOTAL

Enlisted-Other
Non-Black

1905- 9
1910-14
1915-19
1920-24
1925-29
1930-34
1935-39
1940-44
1945-49
1950-54

1
6
5
3

0
1
0
1

15

2

0
4
8
12
28
76
52
67
270
11

0
2
0
3
2
6
1
2
9
0

25

Enlisted-Other
Black

.333
.200
.049
.049
.041
.033
.056

935

46

.049

1
5
1

.333

10
34
16
15

2

.100
.150
.063
.133

.133

75

9

.120

2
10
48
60
140

0

.167

.500
.250
.071
.079
.019
.030
.033

376
263
340
1333
56

2
5
7
18
14
8
7

36

.200
.104
.117
.129
.037
.030
.021
.027

0

52

52

2628

97

.037

.143

35
40
35

.034

145

2
3
1
4

.057
.075
.029
.028

.038

1
0
0
1
TOTAL

2
4
3
15
10
7
5

.032

Enlisted-Fit Eng
Black

.0*17
.042

6
20
61
304
243
211
90

1.000

255

10

.039

.047

�Appendix V
THE EXTENDED EJIGOU-McHUGH RELATIVE RISK ESTIMATOR

Let R k , k=1,2, ..., K, denote the distinct numbers of comparisons matched
to the cases and let nk denote the number of matched sets with exactly Rk comparisons. A matched set is defined as the case and his matched comparisons.
Let n=ni+n2+ ... +nj( denote the total number of matched sets.
Define Zk«i,T» k-1 .2 ..... K, i-0,1, by
Zk 0 T * tne number of matched sets, among those having exactly Rk
comparisons, in which the case is alive and exactly T of
the R k comparisons have died, T=1,2, ..., Rk
Zk,1 T * the number of matched sets, among those having exactly Rk
comparisons in which the case has died and exactly T of
the Rk comparisons have died, T=0,1,2, ..., Rk-1 .
The extended estimate, \p, is given by
K
1

Rk
I zk,0,Tzk,1 ,T-1/(zk,0,T+zk,1 ,T-l)

K Rk
Z
* TZ2k,0,T/(Rk-T+1)(Zk,0,T+Zk,1,T-l)
k-1 T-1

and its variance is estimated by
K
Rk
Z
Z Zkf0&gt;T/[i|;+(Rk-T+1)/T]
k-1 T-1

Since K is finite, this estimate has the same distributional properties
as the Ejigou-MoHugh estimator; it is asymptotically efficient and unbiased.
The underlying assumptions used in its derivation are that the disease under
study is of low incidence and that relative risk is constant over the levels
of the matching variables. The Ejigou-McHugh estimate and the above extension
are equivalent in asymptotic efficiency to maximum likelihood estimation (12).

53

�Appendix VI
Figure 4
SURVIVAL CURVE ESTIMATE AND 95% CONFIDENCE BANDS
FOR POOLED RANCH HANDERS
C.9 0.3 Ci)

z 0.7 -

14
-

O.G -

CO

C'.V&gt; -

2:
C3

C.4

CT

ce: 0 . 3

C.I .

0I
0

&lt;Q

10

bO

70

RGF.
Figure 5
SURVIVAL CURVE ESTIMATE AND 95% CONFIDENCE BANDS
FOR POOLED COMPARISONS

I
0.9
0.0

§ 0«7
»—i
&gt;
£ 0.6
W Q.&amp;
2 0.4
I—

o
CE
or. ° •3
u.
0.2
0.1

0

0

J_

_.
10

:ji""
fiC-f

54

I

'"0

70

�Figure 6
SURVIVAL CURVE ESTIMATE AND'95% CONFIDENCE BANDS
FOR RANCH HAND OFFICERS

0.9
O.Q
0.7
0.6

9s
0.5

•z.
CJ

0

0.3
0.2
0.1

0

0

10

20

30

60

70

ROE

Figure 7
SURVIVAL CURVE ESTIMATE AND 95% CONFIDENCE BANDS
FOR COMPARISON OFFICERS
I
0-9

o.e
0.7
0.6

z
H-

0.4
0.3

0.1

0

.
IK

30

60

ROE
55

70

�Figure 8
SURVIVAL CURVE ESTIMATE AND 95% CONFIDENCE BANDS
FOR RANCH HAND ENLISTED PERSONNEL

1
0.9
0.8

g 0.7

oc
to 0.5,

z
2 Q.4

Iu

S 0.3
u.
0.2
O.I

0

10

30

60

70

RGE
Figure 9
SURVIVAL CURVE ESTIMATE AND 95% CONFIDENCE BANDS
FOR COMPARISON ENLISTED PERSONNEL

I
0.9
O.Q
g 0.7

o.e
cn
z
S 0.4
0.3
0.2
0.1

0

1—

10

no f.
56

60

70

�Figure 10
SURVIVAL CURVE ESTIMATE AND 95% CONFIDENCE BANDS
FOR RANCH HAND FLYING PERSONNEL

1
0.9
0.0
0.7

&gt; 0.6
or
O.b

z
o
£ 0.3
U_
0.2
0.1

0

10

20

30

E&gt;0

60

70

flGF.

Figure 11
SURVIVAL CURVE ESTIMATE AND 95% CONFIDENCE BANDS
FOR COMPARISON FLYING PERSONNEL

1
0.9
0.0

Z 0.7
U 0.6
W 0-b

CJ

0.3
0.2
0.1

0

10

20

30

bO

57

60

70

�Figure 12
SURVIVAL CURVE ESTIMATE AND 95% CONFIDENCE BANDS
FOR RANCH HAND GROUND PERSONNEL

0.9
0.9
g 0.7
£ 0.5
to

0.5

z
•-• 0.4
ho
£ 0.3
u_
0.2
0.1

10

20

30

60

70

ROE

Figure 13
SURVIVAL CURVE ESTIMATE AND 95% CONFIDENCE BANDS
FOR COMPARISON GROUND PERSONNEL

1
0.9
0.8
Si 0.7
&gt;
£ 0.6
W 0.5
Z

•-&lt; 0.4
o
£ 0.3
u_
0.2
0.1),

0

0

10

30

40

flOE

58

£.0

70

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11. Michalek, J. E. and Mihalko, D. Linear rank procedures for litter matched
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12. Ejigou, A. and McHugh, R. Relative risk estimation under multiple matching. Biometrika 68:85-91 (1981).
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59

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Survival Models and Analysis

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61

�PROJECT RANCH HAND II

AN EPIDEMIOLOGIC INVESTIGATION OF HEALTH
EFFECTS IN AIR FORCE PERSONNEL FOLLOWING
EXPOSURE TO HERBICIDES
BASELINE MORTALITY STUDY RESULTS
30 JUNE 1983

Prepared for:
The Surgeon General
United States Air Force
Washington, D.C. 20314
Approved for public release; distribution unlimited
EPIDEMIOLOGY DIVISION
DATA SCIENCES DIVISION
USAF SCHOOL OF AEROSPACE MEDICINE (AFSC)
BROOKS AIR FORCE BASE, TEXAS 78235

�EXECUTIVE SUMMARY
Baseline Mortality Study
The Ranch Hand II epidemiologic study'uses a matched cohort design in a
nonconcurrent prospective setting, incorporating mortality, morbidity, and
follow-up studies. The purpose of this report is to present the baseline
mortality study results.
, ,&gt;•••
Since 1979, a detailed population ascertainment process has enumerated a
total of 1269 Ranch Hand personnel who served in Vietnam during the period of
1962-1971. As described in the protocol, this total is believed to comprise
the entire exposed study population. The eligibility of each Ranch Bander was
verified by a hand review of his personnel record. A comparison group
was formed by identifying all individuals assigned to selected Air Force
organizational units with a mission of flying cargo to, from, and In Vietnam
during the same period. All Ranch Hand and comparison subjects designated as
killed in action were removed from the study population. By a computerized
nearest neighbor selection process, up to 10 comparison individuals were
matched to each Ranch Hander by job category, race, and age to the closest
month of birth. A hand record review of the matched comparison sets revealed
that on the average, 8.2 comparison individuals were fully suitable for study.
From each matched comparison set, five individuals were randomly selected for
the mortality study, yielding a 1:5 design. Every Ranch Hander and his set of
comparisons will be the subjects of annual mortality updates throughout the
entire 20 years of the follow-up study so that emerging mortality patterns or
disease clusters may be detected with maximal sensitivity. Each living Ranch
Hander and his first and willing comparison match were selected to participate
in a comprehensive physical examination and an in-home interview; the results
of this study will be presented in a subsequent report in late 1983.
A mortality determination on 1,247 Ranch Banders and 6,171 comparison
subjects was made, sequentially using the data sources of the Air Force,
Veterans Administration, Social Security Administration, Internal Revenue
Service, and personal contact efforts. As of December 31, 1982, 50 Ranch Hand
and 250 comparison subjects had died (certified on/before April 27, 1983).
Death certificates were obtained on all 300 deceased subjects and were coded
by an Air Force nosologist (ICD, 9th ED). All codings were verified by the
National Center for Health Statistics. Autopsy results are currently being
sought for future analyses.
Statistical analyses of noncause specific death emphasized survival curve
estimates, linear rank procedures, relative risk estimates, and standardized
mortality ratios (SMRs). Cause specific analyses were limited to relative risk
estimates because of small cell sizes. In addition to these approaches, three
other data bases were contrasted to the Ranch Hand population, where possible;
the 1978 US White Male Mortality experience, the 1978 Department of Defense
(DoD) Nondisability Retired Life Table, and the mortality experience of the
West Point Class of 1956.
These additional comparison groups have
substantial comparability or sample size limitations, rendering conclusions to
the weakest order. Analyses with these "external" comparison groups were
accomplished to crudely define the healthy worker effect and to determine if
the Ranch Hand group mortality was drastically out of line with that of other
military populations.

�Data analysis showed that the mortality experience of the Ranch Hand
group is nearly Identical to that of the comparison group. Analyses showed
that officers are living" longer than enlisted personnel in both Ranch Hand and
comparison groups. This difference between officers and enlisted personnel
was statistically significant in the comparison group whereas it was not in
the Ranch Hand cohort. A contrast of the Ranch Hand and comparison group to
the 1978 DoD Life Table showed significantly less mortality for Ranch Hand
officers, comparison officers and comparison enlisted men, however, there was
not a statistically significant favorable mortality rate for Ranch Hand
enlisted personnel. This pattern of mortality was also seen in a contrast of
the Ranch Hand and comparison groups to the 1978 U.S. white male mortality
experience. That is, highly favorable mortality differentials for Ranch Hand
officers, comparison officers and comparison enlisted personnel were observed,
but not for Ranch Hand enlisted. This trend is consistent with the self
perceptions of differential herbicide exposures reported by many of the Ranch
Hand subjects. The reason(s) for these observations are speculative at
present, but may include the related items of sample size, socioeconomic
differences, access to medical care, and health education and possible
herbicide effects. Cause specific analyses were statistically nonsignificant.
The Ranch Handers showed a relative paucity of overall cancer but an excess of
digestive disorder deaths, both statistically nonsignificant. No soft tissue
sarcoma deaths were detected in either group. Analyses of both the Ranch
Hand and the comparison groups to the 1978 US White male mortality experience
showed highly significant favorable findings. Most of these differences are
speculatively attributed to the healthy worker effect. A contrast of the
Ranch Hand and comparison groups to the 1978 DoD Life Table showed
significantly less mortality for Ranch Hand officers and comparison officers
and enlisted men. The West Point comparison showed nonsignificant SMRs of
0.530 and 0.778 for the Ranch Hand officers and the comparison group officers,
respectively. Overall, the limitations of the statistical power calculations
in most of these analyses were substantial in most analyses due to 1) the low
mortality rate (4%) in the Ranch Hand and comparison groups to date, 2) the
inherently small group of Ranch Handers (as described in the study protocol),
and 3) the observed relative risks which approached unity in most categories.
This baseline mortality report can in no way be regarded as conclusively
negative because this small, young, and relatively healthy cohort may not have
yet reached the latency period wherein attributable fatal disease might be
expected and detected within limited power boundaries of this study. Future
commitments for the annual mortality updates include detailed covariate
analyses for disease risk factors, herbicide exposure, and confounding
industrial chemical exposures. Further, subsequent morbidity reports will
include full spectrum, disease specific analyses, e.g., cancer (fatal,
ongoing, cured) in an effort to enhance study sensitivity to emerging
herbicide effects, if they occur.

ii

�AIR FORCEHEALTH STUDY
(PROJECT RANCH HAND II)

AN EPIDEMIOLOGIC INVESTIGATION OF HEALTH
EFFECTS IN AIR FORCE PERSONNEL FOLLOWING
EXPOSURE TO HERBICIDES
BASELINE MORBIDITY STUDY RESULTS
24 FEBRUARY 1984
Prepared for:
The Surgeon General
United States Air Force
Washington, D.C. 20314

George D. Lathrop, Colonel, USAF, MC
William H. Wolfe, Lieutenant Colonel, USAF, MC
Richard A. Albanese, M.D., GM-15
Patricia M. Moynahan, Colonel, USAF, NC

Approved for public release; distribution unlimited.
.£&gt;.

USAF SCHOOL OF A E R O S P A C E MEDICINE
Aerospace Medical Division (AFSC)
Brooks Air Force Base, T e x a s 7 8 2 3 5

�.*
EXECUTIVE SUMMARY
BASELINE MORBIDITY STUDY

The Ranch Hand II epidemiologic study uses a matched cohort design in a
nonconcurrent prospective setting, and .incorporates mortality, morbidity, and
follow-up studies. -The purpose of this report is to present the baseline
morbidity study.
The morbidity study design matched each living Ranch Hander (by age, Job,
and race) to the first living and compliant member of a randomly selected comparison mortality set of 5 individuals, producing a 1:1 contrast. The comparison group was formed from numerous flying organizations which transported
cargo to, from, and within Vietnam, but were not involved in aerial spray
operations of Herbicide Orange. Of the potential study participants, 99.5$
were located. Early in the physical examination phase of the study, it was
discovered that 18$ of the entire comparison group was ineligible to participate because of inappropriate selection. Thereafter, study eligibility was
certified only after a hand-review of personnel records. Next-in-line compliant comparisons entered the study as replacements after fully completing the
questionnaire and physical examination. Statistical analyses of these replacement individuals later showed that they differed from the original comparisons
in a variety of subtle and often opposite ways. As a conservative measure to
avoid possible bias by the inclusion of the replacements in the analyses, a
management decision was made to base the statistical tests in this report primarily upon contrasts of the Ranch Hand group to the original comparison group.
The preponderance of data was obtained from the in-home interviews and the
physical examination, each conducted under contract to the Air Force by Louis
Harris and Associates, Inc., New York NY, and the Kelsey-Seybold Clinic, P.A.,
Houston TX, respectively. All contacts with the participants were carried out
with utmost professionalism and sensitivity. Other morbidity data sources
included reviews of medical records, military personnel documents, and birth
certificates; in-home questionnaires and telephone questionnaires of the study
participant's wives, former wives and, occasionally, their next-of-kin. All
aspects of the study were voluntary. As a contract requirement, data collection personnel were blind as to the exposure status of the participants.
Ninety-seven percent of the Ranch Handers and 93$ of the comparisons participated in the in-home interview. For the physical examination, 87$ of the Ranch
Handers and 76$ of the comparison group participated, a total of 2,272 individuals. This differential attendance at the examination may have introduced a
potential participation bias that, in a military population predominantly engaged in flying duties, is multifactorial and complex. All study phases were
monitored by stringent quality control standards. Statistical analyses of the
data consisted primarily of log-linear models, logistic regression techniques,
generalized linear models, matched covariate analyses, and Kolmogorov-Smirnov,
chi-square, and t tests.
The physical examination and the in-home questionnaire data were analyzed
by major organ system. In terms of general health, more Ranch Handers perceived themselves to be in fair or poor health than did their comparisons. No

�group differences were detected for hematocrit or percent body fat determinations. Unadjusted group differences in sedimentation rate were not observed;
however, significantly more young comparisons had abnormalities in sedimentation rate than did their Ranch Hand counterparts. There were no statistically
significant differences in the occurrence of malignant or benign systemic tumors between the groups. One case of soft tissue sarcoma was found in a comparison member. Significantly more nonmelanotic skin cancer was noted in the
Ranch Hand group, but these - analyses have not yet considered (adjusted for)
sunlight exposure, the prime etiology of these cancers. Such nonmelanotic skin
cancer (predominantly basal cell carcinoma) is the most common neoplasm in the
White population of the United States. Up to the statistical limits of the
study there were no consistent data that showed that the Ranch Handers were
developing uncommon cancers, or cancer in unusual sites, or at an unusual age.
Measures of fertility and reproductive outcome showed mixed results. It is
emphasized that the fertility and reproductive results are preliminary at this
time as they are based largely upon subjective self reports that await full
medical record and birth certificate verification. Four measures of fertility:
number of childless marriages, couples with the desired number of children, the
infertility index and the fertility index, showed no difference between the
Ranch Hand and comparison groups. A semen specimen obtained from those willing
and able to provide one showed no group differences with respect to total sperm
count or percent abnormal sperm. There were no significant findings in conception outcomes for miscarriages, stillbirths, induced abortions, or live births.
For live birth outcomes no differences were observed for prematurity, learning
disability, or infant deaths.
There was no significant disparity between
groups for the classifications of severe or moderate birth defects. By parental history, however, Ranch Hand offspring showed significantly more minor
birth defects (birth marks, etc). Reporte'd neonatal deaths and physical handicaps were also significantly excessive in the Ranch Hand group when contrasted
to the total comparison group. All fertility and reproductive findings in the
Ranch Hand group showed inconsistent relationships to the herbicide exposure
index. Medical records and birth certificates are currently being chronicled
for complete verification of all historical findings. A comprehensive neurological examination showed no consistent abnormalities in the cranial nerves,
peripheral nerves or central nervous system function of the Ranch Handers. As
expected, there was a profound influence of diabetes and alcohol in both groups
upon numerous neurological tests.
Detailed psychologic data were obtained
on
all participants at both the in-home interview and the physical examination. It is emphasized that the majority of psychological data was derived
from self reported responses during interview and has not been fully assessed
for the effect of differential reporting. A variety of subjective deficits
(fatigue, anger, fear, anxiety, etc) were significantly more common in the high
school educated Ranch Handers. Educational level significantly and consistently influenced most subjective test results. In sharp contrast, more objective performance testing by the Halstead-Reitan battery and IQ testing did not
reveal any significant intergroup differences. The roles of overreporting and
the Post Vietnam Stress Syndrome In these analyses have not as yet been
assessed. Liver function tests and clinical history data showed mixed results.
Ranch Handers had some elevated liver enzyme tests and lower cholesterol levels. More Ranch Handers were found to have hepatomegaly and verified histories
of prior hepatic disease than their counterpart comparisons.
Exposure to
alcohol, degreasing chemicals, and industrial chemicals in general, influenced

ii

�the liver test results. Ranch Handers reported significantly more symptoms
resembling porphyria cutanea tarda than the comparisons-, but these data have
not been verified by medical record reviews nor were they substantiated by
laboratory testing or by physical examination. Exposure index analyses were
essentially negative. In the dermatologic evaluation, no cases of c'hloracne
were diagnosed clinically or by biopsy. A thorough questionnaire analysis of
acne showed that the incidence, severity, duration, and anatomic location did
not differ between groups, and suggested that the historical occurrence of
chloracne was highly unlikely in the Ranch Handers. Evaluation of the cardiovascular system showed equal proportions of abnormalities in blood pressures,
electrocardiograms, past electrocardiograms, and heart sounds in both groups.
Ranch Handers are not having premature heart attacks or generalized heart disease. However, the Ranch Handers showed significant deficits in 2 specific
peripheral leg pulses and all leg pulses as a group. These puzzling findings
were highly correlated with age and smoking patterns, and verified past heart
disease. The assessment of the immune system by laboratory testing was compromised by excessive test variability. An independent review committee determined which test data were suitable for statistical analysis. As an unexpected
finding, the test data were significantly influenced by the age and smoking
history of the participant; no group differences were detected after adjustment
for these factors. A hematologic test battery revealed three red cell abnormalities in the Ranch Hand group, but these were difficult to place into a
clinical or epidemiologic context.
Evaluation of renal, pulmonary, and
endocrine functions generally disclosed small and inconsistent proportions of
abnormalities between groups, and were deemed clinically unimportant.
An
unrefined assessment of all summed and weighted organ system abnormalities by
group did not show an aggregation of multisystem disease or malfunction.
Any interpretation of these study data, in whole or in part, must carefully
consider the methodical steps required for a proper inference of causality. It
is specifically pointed out that many group differences were largely based upon
subjective data, and that a subtle effect of differential reporting is suggested but has not been fully evaluated. For objective data, group differences
were generally within normal ranges and were not correlated to the herbicide
exposure index, nor fell within the expected latency periods following Vietnam
service. The proposed clinical end points of dioxin exposure, chloracne, soft
tissue sarcoma, and porphyria cutanea tarda, were not found in the Ranch Hand
group (study power limitations recognized). Overall, substantial credence is
given to the objective study findings, particularly after observing the consistent duplication of the classical effects of risk factors such as age, smoking,
alcohol, etc., in almost all clinical areas. Additional work with these baseline data is still required in the areas of data base refinement, statistical
testing and bias analysis, exposure index refinement, establishment of the
follow-up examination requirements, and collaboration with other dioxin
research studies.
This baseline report concludes that there is insufficient evidence to support a cause and effect relationship between herbicide exposure and adverse
health in the Ranch Hand group at this time. The study has disclosed numerous
medical findings, mostly of a minor or undetermined nature, that require
detailed follow-up. In full context, the baseline study results should be
viewed as reassuring to the Ranch Handers and their families at this time.

iii

�PROJECT RANCH HAND II

AN EPIDEMIOLOGIC INVESTIGATION OF HEALTH
EFFECTS IN AIR FORCE PERSONNEL FOLLOWING
EXPOSURE TO HERBICIDES
MORTALITY UPDATE -1984
10 DECEMBER 84
William H. Wolfe, Colonel, USAF, MC
Joel E. Michalek, PhD
Richard A. Albanese, M.D.
George D. Lathrop, Colonel, USAF, MC
Patricia M. Moynahan, Colonel, USAF, NC

Prepared for:
The Surgeon General
United States Air Force
Washington, D.C. 20314

EPIDEMIOLOGY DIVISION
DATA SCIENCES DIVISION
USAF SCHOOL OF AEROSPACE MEDICINE (AFSC)
BROOKS AIR FORCE BASE, TEXAS 78235

�Project Ranch Hand IT Mortality Update - 1984
EXECUTIVE SUMMARY
HAOKCR&lt;WNI&gt;

The purpose of the Ranch Hand II Study is to determine whether those
Individuals involved in the aerial spraying of herbicides in Vietnam during
the'Ranch Hand operation have experienced any adverse health effects as a
result of their participation in that program. The study evaluates both
mortality (death) and morbidity (disease) In these Individuals 6ver a
20-year period of time after the studies were initiated.
The baseline mortality study was released in June 1983 and the baseline
morbidity study in February 1984. Neither study demonstrated health
effects which could be conclusively attributed to herbicide or dioxln
exposure. The reader is referred to reports of the studies for further
details (1, 12).
METHOD
The present study report describes the second mortality analyses. Deaths
in the 1256 Ranch Hand and 6171 comparison subjects were determined, using
the data sources of the Air Force, Veterans Administration, Social Security
Administration, Internal Revenue Service, and personal contacts. As of 31
December 1983, 54 Ranch Handers and 265 comparison subjects had died.
Death certificates were obtained on all subjects. Autopsies were conducted
on 157 of the individuals who had died. Results have been obtained for 104
of these autopsies to confirm the death certificate findings. Autopsy
reports for the 53 others have been requested, but have not yet been
obtained.
Extensive statistical analyses were accomplished, as detailed in the
report, to compare the death experience in the Ranch Hand population with
the comparison group. In addition, death experience in these groups was
compared to the 1978 U.S. White Male Mortality experience, the 1978
Department of Defense Nondisability Retired Life Table, the mortality
experience of the West Point Class of 1956, the USAF active duty personnel,
and the active U.S. Civil Service population.
RESULTS

As was the case in the first mortality report, the current mortality
analyses did not reveal any statistically significant differences in
mortality between the exposed and comparison groups. The percentages dead
in each major category are summarized below.
Percent Deaths
Ranch Hand
Comparison
Rank
Officers
Enlisted

3.2
4.9

4.0
4.5

Occupation
Flying
Ground

3.6
5.1

4.7
3.9

Note: None of the above differences between the Ranch Hand and Comparison
groups are statistically significant.

�Ranch Hand
Total
Overall

4.3

Comparison
4.3

As was reported In the baseline mortality study, the Ranch Hand officers
had a nonstatlstically significant though slightly lover death rate than
their comparisons, Ranch Hand flyers had a nonstatlstically significant
though slightly lower death rate than comparisons, and Ranch Hand ground
personnel had a slightly higher but nonstatlstlcally significant death rate
than the comparisons.
The herbicide/dioxln exposure index described In the morbidity report was
applied to the data, and no relationship between exposure and mortality
experience was identified.
As was also noted in the baseline mortality study, analyaes consistently
demonstrated significantly better survival in the Ranch Hand officers than
Ranch Hand enlisted members, as was the case with comparison officers and
comparison enlisted personnel. Cause-specific analyses did not demonstrate
any Increased Ranch Hand mortality for accidents, suicide, homicide,
malignancy or circulatory system disease. No unusual patterns of
malignancy were observed in either the Ranch Hand or comparison groups, a
finding which would be expected from the small number of deaths to date.
When compared to the 1978 U.S. White male population, the Ranch Rand
officers, comparison officers, and comparison enlisted are living
significantly longer than expected. Although Ranch Hand enlisted are also
living longer, the difference is not Significant. A similar pattern was
seen in analyses using the DOD retired population. All groups bad a
mortality experience similar to the civil service population. As would be
expected from the fact that individuals In the active duty population who
develop severe chronic disease are medically retired, all groups in this
study had an increased mortality when compared to the Air Fore* population
currently on active duty. Both Ranch Hand and comparison officers had
mortality similar to the West Point group.
I
i
CONCLUSION AND RECOMMENDATION

Continued mortality surveillance is recommended, since the study groups are
still relatively young and healthy. While sufficient time may have elapsed
for some clinically significant conditions to occur, additional time Is
necessary for other conditions, which; nay possibly be attributable to
herbicide exposure, to develop. At this time, however* there Is no
evidence of increased mortality as a result of herbicide exposure in those
individuals who accomplished the Ranch Hand spray operations in Vietnam.

�ABSTRACT OF REPRODUCTIVE OUTCOME
DRAFT REPORT, 17 December 1984

Abstract:
This report was written in response to requests from the
Office of Science and Technology Policy, the Chair - Agent Orange
Working Group and by direction of the Air Force Deputy Surgeon
General.
It was intended as an "interim" analysis of the data
and not as a definitive answer to the birth defects issue.
Since the release of the baseline morbidity report in
February 1984, birth defects and neonatal deaths reported by
study participants during the baseline questionnaire have been
verified by record review. This verification was accomplished by
the review of birth and other medical records, birth certificates
and death certificates. Since not all data can be verified for
at least an additional 24 months, these interim analyses were
based on the v e r i f i c a t i o n of the p o s i t i v e reports only.
Verification of negative responses to the birth defect and
neonatal death questions have not as yet been completed.
The draft report was submitted to the Advisory Committee on
Special Studies Relating to the Possible Long-Term Health Effects
of Phenoxy Herbicides and Contaminants. Their comments have been
received and will be discussed with them in a forthcoming visit
to the Ranch Hand Office. This interim assessment will then be
forwarded to the OSTP through the Chair, AOWG.

b-s

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Report/Article TltlB Typescript: Human Exposure to Phenoxy Herbicides

Journal/Book Title
Year
Month/Day
Color
Number of Images
DeecrlptOU Notes

n

°
Final draft

' Accompanied by letters to Barclay Shepard and
Alvin L. Young from Lavy. Monograph was published in 1987
by the Veterans Administration Central Office, Department of
Medicine and Surgery, Agent Orange Projects Office.

Tuesday, April 02, 2002

Page 5827 of 5840

�T.L. Lavy
2208 Sweetbriar
Fayetteville, AR 72701
December 3, 1984

Dr. Barclay Shephard
Office of Env. Medicine
Veterans Administration
810 Vermont Ave.
Washington, D.C. 20420
Dear Barclay:
I am pleased to send you this final copy of my monograph "Human
Exposure to Phenoxy Herbicides." I hope you are able to get this
published as soon as possible since some of the information is already
becoming outdated.
At times it seemed like this was a never ending task. Recapping
for you - in July 1983 I completed the first draft of the entire
monograph. It was returned to me for revisions about January 1, 1984
after Dr. Shelden Wagner edited it. I made many of the changes
suggested and then returned it to the V.A. around April 1, 1984.
After that time I'm not exactly sure what happened at the V.A.; why it
happened and why it took so long. After finally receiving Alan
Fitzgibbens comments and suggestions I was shocked and disappointed at
the revisions he was demanding. In all of that confusion somehow the
incorrect, unrevised version of Chapter 5 kept getting into your
hands. As I indicated to you following my trip to Florida in
February, major revisions were made, but somehow they didn't get to
you.
A significant step forward occurred when I learned I no longer had
to interact with Mr. Alan Fitzgibbens. I labored extensively over his
reactions, comments, suggestions, and threats. Since my April revision I have put in 96 dedicated hours to completing this monograph.
Conservatively, I can truthfully say that Fitzgibbens diversions have
cost me at least 60 hours of work. Originally I tried hard to attempt
to revise it in the manner he was requesting. After his dismissal I
was able to concentrate on completing my task.
If further revisions are required I will be able to work on it
further at an additional expense to the Veterans Administration.

�Dr. Barclay Shephard
December 3, 1984

Page 2

Please call me if you have any questions or if I can be of
assistance in getting this published.
Truly yours,

.L.avy
Professor
TLL/jlu
cc: Dr. Al Young
Dr. Layne Dresh

�T.L. Lavy
2208 Sweetbriar
Fayetteville, AR 72701
December 3, 1984

Dr. Al Young

1498B

Edwards Place
Boiling Air Force Base
Washington, D.C. 20336
Dear |\1:

Pflease give me your opinion on the following:
1) At one time you indicated that we needed to indicate why I was
selected to write the monograph. I am not sure it is appropriate
or necessary.
2) Is the Table of Contents too detailed? I do not object to drastically cutting the Table of Contents for Chapters 1-5, but for the
Appendix I would like to preserve the entire list of questions as
currently listed in the Table of Contents. Note that I have also
listed them at the beginning of the Appendix. Perhaps this is too
redundant. Should I omit them from the beginning of the Appendix?
3) Especially look at: My interpretations of the controversy Chapter
1, Chapter 5, Appendix A-54. « •••- ,•&gt; , -'
Thanks for your assistance.

T.L. Lavy
Professor
TLL/jlu
Enclosure
P.S. I wish to thank you for your part in getting me geared up to
write the monograph, your suggestions, and encouragement.

�HUMAN EXPOSURE TO PHENOXY HERBICIDES

T.L. Lavy
Professor of Agronomy
University of Arkansas

�PREFACE

The primary intent of this monograph is not to present new information in a manner which will stimulate the scientific community but
rather to communicate with those in other disciplines who have an
interest in or concern for those who have been or believed to have
been exposed to phenoxy compounds or the associated dioxin contaminants.
The goal of this monograph is to provide information to the reader
which will allow him to better evaluate the facts and fiction which
surround the use of phenoxy herbicides employed in crop production.
The reader will have a better understanding of the toxicity associated
with these compounds after considering some of the physical and chemical properties of the phenoxy herbicides, taking an in-depth look at
their fate in the environment, and evaluating animal feeding trials in
which the phenoxys make up a portion of the food supply.
Since the phenoxy herbicides have been used by agriculture for
nearly 40 years, volumes of research projects have been completed.

An

evaluation of animal feeding studies and discussion of industrial
exposure accidents accompanied by over 15 years of historical followup of those humans who have inadvertently been exposed to high levels
of dioxin provide an extraordinary opportunity to view the effects of
phenoxy compounds and their contaminants on man and other animals.
Emphasis is placed on evaluating the kinds and amounts of exposure
received by pesticide applicators. By thoroughly measuring the levels
of exposure being received by this group of workers, who routinely
apply phenoxy herbicide for their means of livlihood, we are examining

�those most likely to receive health threatening levels. Others not
associated with phenoxy spraying would be expected to receive much
less exposure. In this monograph special effort is devoted to differentiating between exposure and dose. Clarity regarding these concepts will provide us a better opportunity to assess the potential
health effects of phenoxy herbicides on the human body.
Personnel involved with the manufacture of the compounds, herbicide applicators, and others in and around the agriculture community, the Vietnamese people and veterans serving the military during
the Vietnam conflict deserve to have the facts on exposure, dose and
risk presented to them in -a manner they can understand.

�TABLE OF CONTENTS

Page
Preface
Table of Contents
Chapter 1:

Phenoxy Herbicides, Their Use, Their Controversies . 1-1

Phenoxy herbicides as weed control chemicals

1-1

Chemical properties of phenoxies

1-4

Commercial uses of phenoxy herbicides in the United States . 1-8
Pastures and rangelands

1-12

Rice production

1-13

Phenoxy herbicide use in rights-of-way management in
the United States

1-13

Other uses

1-14

Selectivity

1-14

How do phenoxy herbicides kill plants?

1-15

Advantages of using phenoxy herbicides

1-15

Controversies associated with phenoxy herbicides

1-16

TCDD and phenoxy herbicides news items

1-17

Chick edema disease

1-18

Findings of Bionetics Research Laboratories

1-18

Claims of Vietnamese health problems

1-19

The incident at Glove, Arizona

1-21

Reindeer in Swedish Lapland

1-22

Alsea II report

1-22

The on-going Missouri horse arena (Times Beach)
Episode

1-23

Seveso, Italy, and other explosions

1-26

References

1-29

�Page
Chapter 2: Factors Influencing Human Exposure to Phenoxy
Compounds

2-1

How long do phenoxy compouds persist in the environment? . . 2-2
Adsorption

2-3

Leaching

2-4

Runoff

2-4

Plant uptake

2-4

Chemical decomposition

2-5

Microbial decomposition

2-5

Volatilization

. . 2-5

Photodecomposition

2-6

Other important factors

2-6

Persistence of phenoxy hericides in soil

2-7

Effects of high rates of aplication or persistence

2-9

Factors affecting phenoxy apors in air

2-11

Vapor pressure

2-11

Particle size

2-13

Protective equipment

2-19

Possibilities of human exposure via phenoxy compounds
in air

2-20

Man's potential for exposure to phenoxy herbicides in
drinking water and other water sources

2-22

Man's exposure to phenoxy herbicides through the food
he eats

2-26

Assessment of human exposure to the phenoxy herbicides . . . 2-32
References
Chapter 3:

2-34

Studies of Human Exposure to Phenoxy Herbicides. . . 3-1

Phenoxys and organophosphates

3-2

�Page
Prohibition of 2,4,5-T sales

3-4

Forestry applicator exposure studies

3-5

Methodology of the 2,4,5-T study

3-6

Application processes

3-9

Climate conditions

3-9

Spray material

3-9

Personnel

3-10

Criteria for obtaining air samples

3-10

Criteria for obtaining dermal exposure samples

3-10

Urine sampling criteria

3-11

Dioxin analyses

3-12

Results of the 2,4,5-T study (Lavy, 1978)

3-12

Methodology of 2,4-D study

3-18

Results of the 2,4-D forestry aerial application study
(Lavy, 1980)

3-23

Air samples

3-23

Patch samples

3-23

Urine samples

3-24

Other phenoxy exposure studies

3-31

Observations, findings, and significance of applicator
exposure studies

3-33

References

3-39

Chapter 4:

Pharmacokinetic Studies of the Phenoxy Herbicides
in Humans and Animals

4-1

Fate of phenoxy herbicides in humans

4-12

Probability of dermal absorption

4-13

Factors affecting man's absorption and excretion rates of

phenoxy compounds

4-16

�Page
Effects of repeated exposures

4-19

Relative toxicities of the phenoxy herbicides and TCDD . . . 4-26
Ranch Hand personnel

4-28

Domestic aerial applicators .

4-29

References

4-32

Chapter 5: Assessment of Harm Due to Phenoxy Herbicide
Exposure

5-1

What research information is needed?

5-1

What does the majority of scientific information tell us
about man's potential for harm from being exposed to
phenoxy herbicides?

5-4

USDA R.C. Nash Study

5-4

Oregon researchers (Newton et a!., 1975)

5-4

J.M. Witt American Chemical Society Symposium, Seattle 1983. 5-5
United Kingdoms:
2,4,5-T

Review of the safety of the herbicide
5-6

Information in medical literature

5-7

Relative risks of spraying 2,4,5-T

5-8

Concluding remarks

5-9

References

5-12

Appendix:

Significance of TCDD in Man's Exposure to Phenoxy
Herbicides

A-l

What is dioxin?

A-4

Is there more than one dioxin?

A-4

Why does TCDD exist?

A-5

How do we learn about TCDD?

A-6

What is being done to learn the significance of man's
exposure to TCDD?

A-6

Is TCDO harmful to humans?

A-7

�Page
Were phenoxy herbicides involved at Times Beach?
Are people being harmed by the TCDD present at Times
Beach?

A-ll
A-ll

Since the discovery that soils removed from the horse arena
and deposited in other Missouri communities still contain
detectable TCDD levels, what is being done?
A-12
What can be done to clean-up or remedy the current TCDD
containing areas?

A-12

How do humans come into contact with TCDD and other dioxins? A-13
Do phenoxy herbicides contain TCDD?

A-17

Is the TCDD present in 2,4,5-T harmful to animals eating
vegetation sprayed with the herbicide?

A-17

What is Agent Orange?

A-18

Why were defoliants used in Vietnam?

A-20

Were defoliants other than Agent Orange used in Vietnam? . . A-20
Were other pesticides used in Vietnam?

A-21

Is Agent Orange as toxic as TCDD?

A-22

How long does TCDD persist in the environment?

A-22

Do green plants take up TCDD from the soil?

A-24

Does TCDD magnify in the food chain?

A-24

Is TCDD in the environment harmful to animals?

A-26

What are the short- and long-term effects of TCDD?

A-27

If TCDD entered a human would it accumulate?

A-30

Why is the Seveso, Italy accident important to the TCDD

exposure questions?

A-31

Since it has been shown that TCDD is widely distributed in
the environment, does that mean that it is present in the
food we eat?
A-33
Can man be harmed from ingesting 2,4-D or 2,4,5-T?

A-34

How toxic is 2,4-D to workers applying this herbicide
in the forest?

A-35

�Should a concerned pesticide applicator individual quit
worrying about exposure to pesticides since the
scientific facts indicate no imminent danger is present? . A-36
If ones chances of being harmed by phenoxy herbicides and
TCDD are so low, why do we keep hearing about the danger
on TV and reading about it in the newspapers?

A-37

Other than in production plants what groups of humans are
exposed to the highest amounts of pesticides?

A-40

Do phenoxy herbicides cause soft tissue sarcomas in man? . . A-40
Were there dangerous components of Agent Orange besides
TCDD?

A-41

What happens if 2,4,5-T, which contains a trace level of
TCDD, comes into contact with a human?

A-41

Were U.S. ground troops in Vietnam "at risk"from Agent
Orange since they could not shower daily?

A-43

Could Agent Orange harm soldiers exposed to it?

A-43

How could one know if he had been exposed to significant
levels of Agent Orange?

A-46

Chloracne has been described as the primary symptom for
men exposed to chlorinated organic compounds, are there
other symptoms that would accompany these symptoms?. . . . A-47
What has happened to the health of those in Vietnam who
mixed and applied Agent Orange?

A-47

Could Agent Orange affect the fertility of males?

A-47

Can birth defects be caused by pregnant women being
exposed to the phenoxy herbicides and TCDD?

A-48

Does human mothers milk contain TCDD?

A-53

How do the teratogenic effects of TCDD and 2,4,5-T compare?. A-53
Were U.S. military personnel who used Agent Orange well
informed about its properties at the time of its use in
Vietnam?

A-54

What evidence do we have which indicates that use of defoliants in South Vietnam has not caused man health
problems?

A-55

�Why do the Veteran's Administration and other government
agencies continue to study Vietnam veteran health problems
if the government is not admitting that Agent Orange
exposure has caused the problems?
A-55

References

A-57

�LIST OF FIGURES

Page
Figure 3-1.

Daily excretion of 2,4-D in urine of batchmanloader. Exposure apparently occurred on days
in addition to the spray days (Days 3 and 9). . . 3-30(F)

Figure 4-1.

Excretion rate of p-aminophenol in urine in
a subject exposed to 1% aniline solution
for 1 h (Baranowska-Dutkiewicz, 1982)

4-16(F)

Average daily excretion of 2,4,5-T in urine
of forest workers applying 2,4,5-T (backpack,
mist blower, and.helicopter methods)(Lavy,
1978)

4-24a(F)

Simulated body burden of 2,4,5-T following
13 repeated daily exposures in units of
the daily dose D 0 (Lavy, 1978)

4-24b(F)

Average daily excretion of 2,4-D in urine
of forestry workers applying 2,4-D by
helicopter (Lavy, 1980)

4-24c(F)

Figure 4-2.

Figure 4-3.

Figure 4-4.

4-26c(F)

Figure 4-5. Simulated body burden of 2,4-D in humans
after a single dermal exposure and after
repeated (daily) dermal exposures. The
body burden is expressed in units of the dose
level applied to the skin (D0) (Lavy, 1980) . . . 4-25(F)

�CHAPTER 1

Phenoxy Herbicides, Their Use, Their Controversies
Phenoxy herbicides as weed control chemicals
Weeds have presented serious problems to human food production for
centuries.

They infest home lawns and gardens and cause, among

others, the human allergies of poison ivy and hay fever.

Commmonly,

weeds invade man's recreation areas and interfere with his fishing,
boating, golf courses, or parks.

Rights-of-way for telephone and

electrical power lines, railways, highway systems in addition to navigational waterways and irrigation systems could be drastically
affected if weed growth was allowed total freedom.
In recent time, we have learned to successfully control many
serious weed problems with chemical control measures.

Among these

chemicals are phenoxy herbicides which are very effective and economical control agents.
The first of the phenoxy herbicides to be discovered was
2,4-dichlorophenoxyacetic

acid (2,4-D) whose synthesis was described

by Pokorny in 1941. Ahlgren et al. (1951) described a series of alkaline reactions which lead to the production of 2,4-D.
Use of 2,4-D as a plant growth regulator was shown in 1942.
Removal of dandelion, plantain and other broadleaved plants from a
bluegrass lawn following an application of 2,4-D was first reported in
1944 (Marth and Mitchell, 1944).

Discovery of this concept of selec-

tivity and its potential for enhancing farm productivity through weed
control was a key motivating factor which prompted scientists in academia and several chemical manufacturers to initiate new research

1-1

�efforts. This series of events has played a vital role in helping the
U.S. build a sound economic foundation.

The American farmer's output

has steadily risen as shown by the fact that one U.S. farm worker fed
16 people in 1950, 26 people in 1960, 47 people in 1970, and in 1978
fed 65 people (Farmline, 1980). The use of organic chemicals for weed
control and other pests has played a major role in this marked
increase in agricultural production. As shown in Table 1.1, the tonnage of phenoxy herbicides used has continued to rise (Bovey and
Young, 1980).
The ability of the formulation chemist to adapt the phenoxy molecule to different field applications has added to the popularity of
the herbicides.
For a pesticide to have an optimum biological effect on its target
it must be permitted an opportunity to make contact with the organism.
Some of the formulations employed to put pure chemical pesticides into
a form facilitating field use include: wettable powders, emulsifiable
concentrates, dusts, granules, water-soluble concentrates, flowables
and aerosols (Van Valkenburg, 1967). The formulation chemist is
interested in achieving several goals. Assuming he has found a compatible mix that will readily pass through the applicating equipment,
he is interested in creating a spray solution with viscosity properties which will allow it to be retained on the foliage of the target
plant, to penetrate the tissues and to translocate within the plant.
Pesticide formulations and surfactants have primarily been designed to
provide a high level of biological activity on plants or other pests.
Most of the research which has been completed on the phenoxy

1-2

�Table 1.1.

Production of 2,4-D and 2,4,5-T (Acid B a s i s ) , United States

1951-1971.

Modified from Bovey and Young (1980).

Produced
2,4-D

Year

2,4,5-T

x 1Q6 kg

x 106 kg

1951

9.4

1.1

1958

14.0

1.7

1959

13.3

2.5

1960

16.5

2.9

1961

19.7

3.1

1962

19.5

3.8

1963

21.0

4.1

1964

24.3

5.2

1965

28.7

5.3

1966

30.9

7.0

1967

35.0

6.6

1968

36.0

7.9

1969

21.4

2.3

1970

19.8

N.A.

1971*

N.A.

N.A.

a

Production data for 2,4-D and 2,4,5-T not a v a i l a b l e after 1970 to

avoid disclosure of i n d i v i d u a l company data.
Source.

The Pesticide Review; 1969, 1970, 1971, 1972, and 1975, U.S.

Department of A g r i c u l t u r e , Agricultural S t a b i l i z a t i o n and Conservation
Service.
1-3

�herbicides has centered around determining how much to use, what
plants are most easily controlled, which are not affected, and how
long they remain active in the soil-plant-water environment.
Extensive information on the effects of phenoxy herbicides on mammals
in animal feeding studies has been gathered.

Extrapolation of these

data from sensitive experimental animals provides much information
which can add to our understanding of their effects on humans.
Prior to 1978 only a few studies have been devoted to measuring
the exposure received by people who apply phenoxy compounds in the
field. As a result, little information is readily'available to the
field applicator about which formulations are most likely to penetrate
skin or those most likely to be present in the air.
Chemical properties of phenoxys
Although all compounds are volatile to some extent, in the case of
pesticides this property may represent a significant mechanism for
permitting the active component to penetrate at a biologically active
concentration to the most susceptible layer of the target organism.

1-4

�Table 1.2. Vapor pressures of esters of some phenoxyacetic acid herbi
cides.

C

3.5 x lO'4
1.1 x 10-3

25

9.6 x 10-6

' 35

2,4-D n-butyl ester

25
35

2,4-D methyl ester

mm Hg

2.6 x lO-5

2,4-D Methyl Amine

38

8.9 x 10-10

2,4,5-T n-propyl ester

25

7.5 x 10-5

35

1.2 x 10-4

Vapor pressure of pesticides determines the maximum vapor concentration at the target site and also governs the rate the compound
may diffuse (Hamaker and Kerlinger, 1967). Volatile compounds with
relatively high vapor pressures, may be more efficacious in their
plant killing properties; thus, coverage within a canopy could be
supplemented as the compound vaporizes.
As shown in Table 1.2, the ester formulations of some of the phenoxy herbicides are markedly more volatile than amine salt formulations. Movement of phytotoxic vapors away from the site of application can damage crops and irritate neighbors, especially in areas
where several different kinds of crops are grown in close proximity.
Formulation of long chain ester herbicides has decreased the volatility of the compound but still facilitates the entry of the herbicide

1-5

�into the plant tissues.
Formulations of the phenoxys include emulsifiable acid, amine
salts, mineral salts and esters. The concentration of these materials
are expressed on the basis of acid equivalents, i.e. that portion that
could be converted to the acid. Since the acid form is only slightly
soluble in water and the emulsifiable concentrate is relatively expensive, only limited amounts of this formulation are used (Klingman and
Ashton, 1982). The most commonly used of the phenoxys are the amine
salts. Characteristically these materials are white crystalline
solids that are readily soluble in water and present essentially no
volatility problem. As a contrast, phenoxy esters are essentially
insoluble in water but dissolve in petroleum oils. Esters made by
using alcohols with one to four carbons are no longer used due to the
high volatility of the phenoxy moiety.

Today more expensive, long

chain alcohols with an ether linkages (-0-) are used in the formulations to lower the volatility hazard (Klingman and Ashton, 1982).
The ester forms are often preferred over the amines since the esters
are much more effective on some species - especially woody plants. It
should be emphasized that the high molecular weight alcohols are now
used to make phenoxy esters with reduced volatility; although these
esters are low volatile they may, under hot, humid conditions, still
volatilize enough to injury highly susceptible plants (Klingman and
Ashton, 1982). Since esters are more phytotoxic, more caution is
required to ascertain that excessive levels are not used, killing
susceptible plants where specificity is desired. Three possible
explanations for the enhanced toxicity to plants from ester for-

1-6

�mulations include: (1) volatility permits absorption of the gases
through leaf stomates, (2) wetting action of the oil-like ester and
the oil carrier may aid penetration and (3) ester forms, with their
low polarity, are compatible with the cuticle and aid penetration
through it (Klingman and Ashton, 1982). Thus, it seems likely that
man's skin surfaces would also be more susceptible to penetration of
the phenoxy compounds when formulated as the ester form.
When the ester and amine formulations are compared with respect to
potential for exposure to man, the more volatile ester formulations are
more likely to be present in the air of man's breathing zone. If skin
contact occurs, the more soluble compounds will be more likely to be
absorbed.

Polar perspiration would aid in solubilizing the amine salt

phenoxy formulations.

However, oily skin surfaces of humans would

tend to solubilize ester formulations of the phenoxy compounds.
Surfactants are classified as cationic, anionic or ionic. In
general, they consist of a hydrophobic and hydrophilic section. This
unique combination of polar and non-polar properties provide surfactants with the ability to emulsify, disperse, spread, wet, or solubilize, thus enhancing herbicidal action through increased foliar
penetration (Foy and Smith, 1967). Freed and Witt (1967), in Table 3,
present data showing that the energy required for plants to absorb
herbicide is reduced in the presence of surfactants.

1-7

�Table 1.3.

Effect of surfactant on absorption energy.

(Freed and Witt,

1967).

E a (kcal/mole)
Without surfactant

Herbicide

With surfactant

Picloram

18.9

-

Dicamba

12.0

10.4

6.5

3.0

2,4-D

Considerable time and study have been devoted to evaluating
enhanced herbicidal action due to surfactants, however, little is
known with regard to any inadvertent exposure man may receive during
application processes or other times he comes into contact with
surfactant-phenoxy herbicide mixtures.

Since Smith and Bayer (1966)

have shown that diuron leaching in a soil column can be increased or
decreased by the kind and rate of surfactant added, several interactions are possible.

Thus, theoretically someday it may be conceivable

that phenoxy herbicides or other pesticides could be optimized for
penetrating plant tissues and minimized for passing man's skin.
Commercial uses of phenoxy herbicides in the United States
Annual and perennial broadleaf weeds in non-cropped areas, as well
as in tolerant crops, are routinely controlled using 2,4-D formulations.

This compound is used extensively in the cornbelt and for

small grain production.

Much of the cropland acreage is treated

with 2,4-D as a postemergence application after the weeds are rapidly

1-8

�growing. Postemergence application rates are routinely 0.5 Ib/acre
or less; at rates above 1 Ib/acre this compound will serve as a
preemergence herbicide, thus killing weeds as they germinate. A
drawback to this means of application is the relatively short residual
life of 2,4-D in the soil.
The forest industry has relied heavily on the use of 2,4,5-T for
vegetation control. Bans on the use of this material for forestry
applications has had a negative impact on timber production. Of the
nearly 500 million acres of commercial forest land in the United
States less than half of this is available for timber production.

In

1972 the U.S. imported 11% of the U.S. consumption of wood (USDA,
1982).
As a consequence of the ban of 2,4,5-T use in forestry and accompanying problems associated with aerial spraying of U.S. forest lands,
vast acreages of potentially excellent production sites became
overgrown by undesirable, much less productive woody vegetation. On
these sites eighteen inch tall, 4-year-old pine seedlings that could
have attained heights of 5 to 7 feet or more are pressed to compete
for sunlight, water, and fertility. Newer, more expensive compounds
and other application means are being used to remedy the problems in
some of these areas. In many cases mechanical means such as chain
saws or machetes have been used in an attempt to eliminate undesirable
species.

In addition to this being an extremely costly and dangerous

task for man, the competitive advantages seldom lasts for more than
one growing season.
Table 1.4 (USDA, 1982) shows aerial application if possible, would

1-9

�be the primary tool for utilizing 2,4,5-T in the South, Rocky
Mountains, and Pacific Coast while in the North individual stem treatment (hand applied) would be the preferred application method.

1-10

�Table 1 4 Estimated annual potential use of 2,4,5-T on commercial
..
forest land by section, application purpose, and application method.
(USOA, 1982).
Purpose and
application
method

North
Present

Potential

• ( A f* Y*rt&lt;*^ _

\ r\L» i Co J

.

South
AppliAppl i cation
cation
Present Potential rate
rate
(Ib ae/
(Ac
(Ib ae/
acre)
acre)

Site preparation
and rehabilitation
Aerial application
1,500
Broadcast ground 1,200
Individual stem 30,000
Total
32,700

40,600
5,400
89,400
135,400

2-3
3-4
1-3

Release and TSI
Aerial application
0
Broadcast ground 1,650
Individual stem 62,200
Total
63,850

32,200
9,300
256,500
298,000

1-2
2
1/4-2

Fuel breaks
Aerial application
Broadcast ground
Individual stem

0
200
0

0
700
10

All purposes
Aeri al appl i cation
1,500
Broadcast ground 3,050
Individual stem 92,200
Total
96,750

72,800
15,400
345,910
434,110

2
2

2-4
2-4
4-6

414,000 1,083,100
42,600
17,000
8,250
31,900
439,250 1,083,100

2
2-4
2-6

0
0
0

0
0
0

614,000 1,594,300
379,100
148,050
97,000
27,550
789,600 2,070,400

4,400
800
0
5,200

2-3
2
2

1-11

—

Pacific Coast

Rocky Mountai ns

Site preparation
and rehabilitation
Aerial application
20
Broadcast ground
0
Individual stem
0
Total
20

585,700
336,500
65,100
987,300

200,000
131,050
19,300
350,350

29,142
1,369
489
31,000

57,184
3,670
3,746
64,600

2-4
3-4
2-3

�North
Purpose and
application
method

Present

South

Potential

Release and TSI
Aerial application
Broadcast ground
Individual stem
Total

220
0
0
220

13,400
2,400
0
15,800

Fuel breaks
Aerial application
Broadcast ground
Individual stem

0
0
0

All purposes
Aerial application
Broadcast ground
Individual stem
Total

240
0
0
130

Appl i cation
Present
rate

Application
Potential rate

231,872
9,519
4,609
246,000

500,330
21,126
15,844
537,300

2
2
1-3

0
0
0

0
800
70

6,000
3,700
400

2-4
2-4
4

17,800
3,200
0
1,000

261,014
11,688
5,168
277,870

563,514
28,496
19,990
612,000

1-2
2
1-2

lae = acid equivalent.
Pastures and range! ands.

Grazi ng lands are a vital natural

resource of the U.S. They are used not only for forage production but
also for watersheds, soil and water conservation, lumber, medicinal
compounds, mining and recreational purposes.

This land is often used

only for grazing since it is too steep, too wet, too shallow, too
cold, too dry, or too acid to be important for growing other crops.
The relatively low cost of the phenoxy herbicides and the wide
spectrum of broadleaved weed control have contributed significantly to
the popularity of this group of chemicals for forage and pasture weed
control.

Pastures are subject to being invaded by many different spe-

cies of woody plants. If an extensive woody plant problem was present
on a minimum acreage ground application, equipment could be used to

1-12

�apply a broadcast treatment.

More commonly, land owners spot treat

woody plants in cultivated pastures as they appear, thus minimizing
the amount of 2,4,5-T required (USDA, 1982).
Rice production.

Rice production has relied heavily on the use of

2,4,5-T for weed control.

The 2.5 million acres of rice the U.S.

located primarily in Arkansas, Louisiana, Texas, Mississippi, and
California.

Broadleaf aquatic weeds have been effectively controlled

by this compound; 28 percent of the rice acres in this four-state area
has relied on the use of 2,4,5-T.

A rate of 1 Ib/acre is commonly

used for weed control, resulting in an annual application of 300,000
pounds 2,4,5-T.

Silvex, another chlorinated phenoxy herbicide, is

also effective in controlling this broad!eaf aquatic weed complex
(USDA, 1982).
In 1983 rice was the only U.S. produced commodity for human consumption that could legally be sprayed with 2,4,5-T during its production.

However, all routine domestic uses of this compound was ceased

in September, 1984.
Phenoxy herbicide use in rights-of-way management in the United
States.

Good vegetation management programs are critical to the

nation as they ensure the safety, security, and reliability of our
rights-of-way systems.

Major rights-of-way types include railroads,

highways, pipelines, and electrical transmission lines.

They supply

our needs for food, fuel, communication, energy, and many other
items.
Estimated rights-of-way acreage in each of the major categories
are listed:

Railroads - 2.4 million acres; highways - 21.7 million

1-13

�acres; pipelines - 2.2 million acres; and electrical utilities - 5
million acres; this makes up 31.3 million acres or nearly 1 percent of
the total U.S. acreage (USDA, 1979). Annual treatment with 2,4,5-T
occurred on more than 680,000 acres annually.
Ground application equipment was usually used when 2,4,5-T was
applied to highways and railway rights-of-way areas while electrical and pipeline utilities relied more heavily on aerial means of
application.
Use of 2,4,5-T resulted in decreased soil erosion since little soil
erosion or compaction occurs due to a lack of site disturbance.

If

bulldozers or other large land clearing devices were required to clear
the vegetation soil erosion would be increased markedly.

Use of

2,4,5-T and other phenoxy compounds for vegetation management has
generally enhanced wildlife activity in treated areas (USDA, 1982).
Other uses.

Other extensive areas of phenoxy herbicide use

include drainage ditches, canals, channels, recreational areas, and
other waterways where brush control is important.
Selectivity
The selectivity of phenoxy herbicides to control broadleaf
plants in the presence of grasses or grain crops is one of the important reasons they phenoxy herbicides have gained in popularity.
Ashton and Harvey (1971) suggested that a herbicide is selective
to a particular crop only within certain limits. These limits are the
result of an interaction between plants, herbicides, and the environment. Significant factors affecting plant responses to a chemical
include: rate of plant growth, shape and characteristics of leaf sur-

1-14

�faces, amount of chemical taken up by the plant, how it moves in the
plant, and deactivation in the plant.
The molecular configuration of the herbicide and its concentration
are important factors governing the ability of the compound to kill
the desired plant.
How do phenoxy herbicides kill plants?
When these compounds kill plants they penetrate into leaves,
stems, or roots; are absorbed into the plant's living protoplasm;
migrate across surrounding tissues to the vascular channels; and
trasnlocate from the point of entry to the actively growing portion
where plant death beings. Ashton and Crafts noted that
Final death of plant tissues may result from contact action;
most characteristic of the 2,4-D light ester or amine formulations on foliage. It may result from extreme hormonelike response giving rise to tumorous tissues, excessive
production of buds or root initials, softening of root cortex
and general degeneration where concentrations are not sufficient to cause direct death, crushing and plugging of
vascular tissues may result in a slower death from lack of
nutrients normally supplied via these tissues (Ashton and
Crafts, 1973).
Although phenoxy compounds are also effective as weed killers
after

they have been applied to the soil, the mode of action asso-

ciated with their removal from the soil-solution complex, translocation through root systems, and subsequent plant killing steps are less
well understood.
Advantages of using phenoxy herbicides
The family of chlorophenoxy herbicides has gained worldwide acceptance for several reasons. Among these reasons are 1) low rates are
effective in killing a wide spectrum of broadleaf plants, 2) they

1-15

�are readily adaptable for many different formulations, 3) they degrade
rapidly in the environment and 4) the vast quantities used and the
advances in technology have allowed the phenoxy compounds to compete
favorably from an economical standpoint.
Controversies associated with the phenoxy herbicides
In view of the positive aspects of the phenoxy compounds, why is
there any controversy?

Confusion abounds and misinformation is common

with regard to this subject.

One of the goals of t h i s book is to pre-

sent facts and allow the reader to place them in their proper perspective.
D u r i n g production of 2,4,5-trichlorophenol which is used to make
some of the chlorophenoxy herbicides an undesirable by product is
formed.
dioxins.

As a group these compounds are commonly referred to as
Often the term d i o x i n , TCOD and 2,3,7,8-tetrachlorodibenzo-

p-dioxin are used interchangeably as synonyms.

Since there are eight

possible locations for chlorine atoms on the d i o x i n molecule there is
the p o s s i b i l i t y of 75 different d i o x i n isomers being formed and 22 of
these could contain 4 chlorine atoms and be labeled as tetrachlorinated d i o x i n s ( H a l p e r i n et al., 1982).

The tetrachlorinated

d i o x i n molecule with c h l o r i n e atoms in the 2,3,7, and 8 positions is
the most toxic of the known d i o x i n members.
Any of the d i o x i n s c o n t a i n i n g four c h l o r i n e atoms can correctly be
called TCDD.

The 1,2,3,4 TCDD is only 1/50,000th as toxic as its

2,3,7,8 relative which appears from animal studies to be the most
toxic of the d i o x i n isomers studied to date (International Agency for
Research on Cancer, 1978). Costly special mass spectrophotometers are

1-16

�required to quantify and differentiate between the different TCDDs.
For further discussion in this monograph the term TCDD will be reservesed specifically for the 2,3,7,8 isomer.
By proper regulation of pressure, temperature and solvent conditions the level of TCDD contamination in 2,4,5-T can be minimized.
In 1964 the Dow Chemical Company became aware of TCDD contamination in
2,4,5-T. At that time they closed their production facilities and
made major modifications in the reaction conditions for synthesis of
trichlorophenol and by late 1965 Dow Chemical had developed technology
that permitted production of 2,4,5-T containing 1 ppm or less TCDD
(Young et al, 1978).
Dioxins also result from sources other than phenoxy herbicides.
Recent research conducted at the University of Amsterdam and in the
U.S. has shown that chlorinated dibenzodioxins, which includes TCDD,
can be formed on combustion in municipal incinerators and by heating
chlorophenols (Rappe et al. 1979).
Pentachlorophenol, a commonly used preservative for wood products,
is contaminated during manufacturing processes with hexa, hepta, octa,
and possible tetra-chlorinated dioxins (Plimmer, 1973, Buser and
Bosshardt, 1976).
TCDD and phenoxy herbicide news items
Following is a list of items concerning the phenoxy and associated
dioxins which have caught public attention during the past 30 years:
Chick Edema Disease, 1955
Bionetics Institute's Report on 2,4,5-T teratogenicity
Use of 2,4,5-T and TCDD in Vietnam

1-17

�Claims of Vietnamese Birth Defects
Swedish Lapland
Globe, Arizona
EPA Alsea II
Missouri Horse Arena
Seveso, Italy Explosion and Other Accidents
On Going Concerns for Veterans
Chick edema disease. Sanger et al. (1958) reported a new
(undiagnosed) disease responsible for killing millions of chickens in
1957.

Only a few similar problems were described until 1969. At that

time soapstock, a by product from refining crude vegetable oil, was
the source of the toxic substance.

Firestone et al (1971) found that

chlorophenols used in antimicrobial water treatment had contaminated
the feed fat. Research stimulated by these findings now allows commercial vegetable oils to be filtered through activated carbon filters
to remove any dioxins which may be formed as a by product from
refining crude vegetable oil (Mounts, 1976).
Findings of bionetics research laboratories. Studies conducted
for the National Cancer Institute by the Bionetics Research
Laboratories in 1969 revealed that rats or mice given relatively large
oral doses of 2,4,5-T during the early stages of pregnancy showed a
higher than average number of deformed offspring (Allen et al., 1977).
This research triggered Dr. Lee A. DuBridge, Science Advisor to the
President and Executive Secretary of the President's Environmental
Quality Council, to state that the "Department of Agriculture will
cancel registration of 2,4,5-T for use on food crops effective January

1-18

�1, 1970, unless by that time the Food and Drug Administration has
found a basis for establishing a safe, legal tolerance in and on
foods" (Bovey and Young, 1980). Immediately after this announcement
of 2,4,5-T registration cancellation, the Department of Defense
suspended the use of Herbicide Orange in Vietnam (Anonymous, 1977;
Bovey and Young, 1980).
Following this announcement and restrictions on 2,4,5-T a close
evaluation was made of the Bionetic's findings, since 2,4,5-T had had
an excellent health record. It had been used in agriculture for over
20 years with no claims of human or other animal problems. Close
scrutiny of the Bionetics Research Laboratory findings showed that the
2,4,5-T used was an old sample from a company no longer producing
2,4,5-T. The compound used contained 27 +8 ppm TCDD. This level was
well in excess of the TCDD levels occurring in 2,4,5-T being produced
by other companies at that time.

In an attempt to reproduce results

to those reported, the Dow Chemical Company conducted a study inconsultation with scientists at the National Institute of Environmental
Health Science Laboratires at Research Triangle, North Carolina. The
only planned deviation in the study was to substitute regular production grade 2,4,5-T.

Results of these studies showed that 2,4,5-T of

regular production grade did not cause birth defects in rats at 24
mg/kg/day administered orally on days 6 through 15 of gestation (Bovey
and Young, 1980).
Claims of Vietnamese health problems. The reports from the
Bionetics Research Laboratories, Dr. Lee DuBridges 1 consequent
actions, the fact that 2,4,5-T used in the U.S. war effort contained

1-19

�low levels of the TCDD contaminant caused concern in Vietnam for the
possibility of increased birth defects due to exposure to 2,4,5-T.
Independent surveys were conducted by Cutting et al. (1970) and
Meselson et al. (1971). In 1971 an Advisory Committee on 2,4,5-T evaluated the two studies mentioned above for U.S. Environmental
Protection Agency (Advisory Committee, 1971). A summary of the evaluation follows:
Summarizing the Vietnam data on human embryotoxicity, it said that
(1) the sample of births surveyed was from year to year a variable but
usually very small fraction of the total number, (2) it was quite
unrepresentative of the geographic and ethnic distributions, (3) the
heavily sprayed and otherwise exposed areas were greatly underrepresented, and (4) the birth records were not trustworthy and, therefore,
the rates of stillbirth, and especially of congenital malformation,
derived from them were equally unreliable. For example, the overall
congenital malformation rate found in South Vietnam, 4.91 per 1000
live births, is about half of what was reported in other studies in
various parts of Asia, and possible a quarter of what might actually
exist at term. A further indication that the newborn children were
not carefully examined is the absence of Down's syndrome in the list
of specific malformations compiled by the Army survey (Cutting et al.,
1970) despite the fact that some Oriental populations have been
reported to have an incidence of this condition not unlike that in
Western populations.
There is, and can be, no precise knowledge of the exposure to
2,4,5-T (and hence, TCDO) experienced by pregnant South Vietnamese

1-20

�women, including what amounts they ingested or absorbed and when this
may have occurred during pregnancy.

Consequently, attempts to accura-

tely relate birth defects or stillbirths to herbicide exposure can not
be made.

The detailed searches reported by Cutting et al. (1970)

almost certainly would have shown any marked increase in the incidence
of birth defects if they had occurred.
The incident at Globe, Arizona. Soon after the U.S. Forest
Service applied 1670 kg Si 1 vex and 54 kg 2,4,5-T in the Kellner-Canyon
Gulch Spray Project near Glove, Arizona reports of harmful effects on
human and other animals were made (Tschirley et al., 1970). These
claims were investigated by the U.S. Forest Service, but many of the
local residents did not agree with the report of the investigation and
in February, 1970 the incident attracted national attention.
Television coverage showed deformities in animals which allegedly had.
been caused by the herbicides. A public hearing was held on February
13, 1970. An account by Time Magazine (Anonymous, 1970) indicated
that the local veterinarian insisted that he had noticed nothing out
of the ordinary in local animals. Local medical doctors could find no
relationship between the spraying and the illnesses. Time also
reported that the investigators holding the public hearing ended up
perplexed. The investigators were accused by some local townspeople
of being imposters, really representatives of chemical companies.
The Office of Science and Education, USDA further investigated the
charges.

Results of this investigation were published by Tschirley et

al. (1970). Roan and Morgan (1972) in a subsequent report of the
investigation concluded:

1-21

�We cannot find any evidence that there was long term exposure
of resident of the Globe, Arizona area to chlorophenoxy herbicides, or significant contamination of water supplies in
this area with 2,4-D, 2,4,5-T, silvex, or metabolites of
these herbicides. Nor have we found contaminants such as
TCOD that may be associated with one or more of the above
technical grade products. Statistics on reproductive mortality and morbidity for the period 1960 through the first
six months of 1970, from one hospital serving this area do
not indicate any trends that are suggestive of adverse
influences on human reproductive function that might be associated with herbicide use during the years 1965, 1966, 1968,
and 1969.
Reindeer in Swedish Lapland. Sudden deaths of reindeer grazing on
2,4,5-T treated vegetation was reported in the Swedish Lapland during
the spring of 1970. Within a week of a heavy snowfall approximately
30 reindeer died without any previous signs of illness; also it was
reported that about 10 reindeer cows aborted their fetuses.
Veterinarian examination of the dead animals revealed empty stomachs.
When food was given to the surviving reindeer the deaths stopped.

To

more fully evaluate the possibility that 2,4,5-T may have been the
culprit, Erne (1973) conducted a controlled experiment by feeding
2,4,5-T to female reindeer.

From results of his study he concluded

that any toxic problems associated with the reindeer deaths were probably not caused by ingestion of 2,4,5-T.
Alsea II Report. The EPA issued an order for the emergency
suspension of 2,4,5-T on the last day of February, 1979. They had
found it to be an imminent threat to human health and had it immediately removed from the market. The public had expressed concern
over miscarriages and other adverse health effects.
In the fall of 1978, the EPA began a search for answers in three
areas - an area where 2,4,5-T was used in the forest in Oregon, and

1-22

�two Oregon areas where it was not used. This study followed an
earlier study of the circumstances in which nine women in the area
suffered miscarriages in which the women could reach no conclusion as
to the cause. Upon the completion of the second study (in February of
1979), known colloquially as "Alsea II", the EPA suspended 2,4,5-T for
forestry, pasture, and right-of-way uses, but not for rice or range,
or for a variety of trivial uses such as industrial or vacant lots.
Witt (1980) in reviewing world-wide assessment of the EPA Alsea II
Report found 18 reports, assessments or reviews on the subject. Every
one of these evaluations found that the EPA data in the reports did
not support the EPA conclusions. The most detailed accounting of
Alsea II was prepared by Wagner et al. (1979).
Following are statements prepared by the Advisory Committee on
Pesticides for the United Kingdom (Kilpatrick, 1980).
In essence we concluded that the data reported were not valid
in either scientific or statistical terms and did not provide
an adequate basis on which to compare abortion rates in women
exposed and not exposed to 2,4,5-T; that evidence of relevant
exposure to 2,4,5-T was lacking; and that a correlation had
not been established between the abortion rates and the usage
of material.
The on-going Missouri horse arena (Times Beach) Episode. Several
of the alledged TCDD "incidents" reported in this chapter have been of
the "suspected" exposure nature. The report of TCDD poisoning in this
episode have been confirmed both by effects on animal health and by
sound analytical determinations.
In 1972, following the spraying of horse arenas with salvage oil
for dust control, 54 of 57 horses exposed to the arena died. In a
report by the Missouri Division of Health and the Center for Disease

1-23

�Control (CDC), Atlanta, Georgia (Anonymous, 1974) extensive investigations were completed.

Symptoms of the illness of the horses were skin

lesions, severe weight loss and heptotoxicity.

Birds, cats, dogs,

insects and rodents were also found dead in the arena.

An exposed

6-year-old girl developed hemorrhagic cystitis (characterized by blood
in the urine).

Other horse arenas sprayed with the similar salvage

oil reported horse deaths occurring.
within a month of each other.

The three arenas were sprayed

According to CDC testing, the original

soil in the arena contained 33,000 ppb of the dioxin.

The problem was

supposedly solved by removing the treated soil from the arenas.
The report of this incident was misquoted by several newspapers
across the country which implied that the herbicide 2,4,5-T was
responsible for the problem (Anonymous, 1974b).
Published facts (Carter et al, 1975, Kimbrough, 1977) reveal that
a factory in southwestern Missouri, while producing hexachlorophene,
had accumulated by-product distillate containing up to 356 ppm TCDD.
Episodes such as this, vividly point out our past inadequacies for
properly disposing of toxic wastes.

Whether the blame should lie with

the manufacturer of the toxin or with the poor judgement of the
licensed vendor for proper disposal is debateable.
Unfortunately the episode is not complete.

The top several inches

of soil from the arenas were excavated and disposed of in several places.

Soil from one arena was dumped along the highway front of the

arena where human exposure would be minimal.
was dumped in a sanitary landfill.

Soil from another stable

Soil from the third arena was used

as landfill for two homes located in Imperial, a small town near St.

1-24

�Louis. As of January, 1983 families in these two homes along with
four other families had been allocated Superfund money for temporary
relocation (Sun, 1983). A considerable expansion in use of Superfund
dollars has more recently been appropriated for relocation, etc. for
families and businesses in Times Beach, Missouri where similar TCDD
materials have been found.
A re-examination of the young girl who had been exposed in one of
the horse arenas conducted 5 years later revealed that the patient had
grown normally. Detailed physical, chemical and neurological examinations were also conducted and found to be normal. The researchers
concluded:
Our experience demonstrates that people exposed to dioxin can
recover completely with no apparent sequels from the toxin.
It remains to be determined whether the exposure to dioxin in
these children will result in abnormal pregnancies or affect
their offspring" (Anonymous, 1974).
An additional 4600 gallons of salvage oil from the hexachlorophene
producing plant was located in the mid 1970's. Six years later, in
1980, the material was degraded using photodegradation techniques.
Up to 100 sites in the state may have been contaminated with the
TCDD twelve years ago. For some of the sites the kind and amount of
TCDD have been well established. The important item, its availability
to man, has not been demonstrated but its water solubility and other
properties indicate it is not readily available for man to receive an
absorbed dose.
Assume 1) that the 2,4,5-T contained 0.1 ppm TCDD (the highest
allowable level) and 2) that 2,4,5-T is applied at a rate of 2 Ib per
acre, 3) that an acre 6 inch slice of soil weighs 2,000,000 Ibs. If

1-25

�the 2,4,5-T was incorporated to a depth of 3 inches then 1,000,000 Ibs
of soil would contain 2 Ibs 2,4,5-T.

If TCDD was present in the

2,4,5-T at a 0.1 ppm level then in 2 Ib of 2,4,5-T 2 x 10~7 Ib TCDD
would be present.

Dispersing this 2 x 10~7 Ib TCDD in the top 3

inches of soil gives a concentration of 0.2 ppt or 2 x 10~4 ppb.
Comparing this amount to the 33,000 ppb TCDD present in the horse
arena 33,000 ppb in horse arena = 165 million
0.002 ppb in normal use
The important findings are:

1) that the dioxin concentration in

soil from the horse arena was 165 million times greater than the concentration of dioxin in a soil normally treated with 2,4,5-T, and 2)
no major health problems to residents of the affected areas have been
reported other than those of the young girl described above.
Seveso, Italy and other explosions.

Since 2,4,5-T has come into

commercial production in 1946, several industrial accidents have
occurred resulting in human exposure to 2,3,7,8 tetrachlorodibenzo-pdioxin and/or other chlorinated dibenzo-p-dioxins.

The most common

method of human exposure occurred during handling of contaminated
intermediate products (e.g. trichlorophenol, TCP).

Young (1978)

reported 23 industrial exposure episodes; eight of these occurred
during an explosion or clean-up after the accident occurred.

At least

740 people have been exposed during these episodes.
Although accidents involving toxic dioxins and subsequent exposure
to humans are highly undesirable they do afford us with an opportunity
to evaluate the health of humans who have received massive TCDD doses.
By detailed investigations of the accidents and extensive .record

1-26

�keeping of the victims scientists have been able to follow the health
patterns of humans who have inadvertently received documented exposure
to the tetrachlorinated dioxins. A combination of any or all trichlorophenol (TCP), pentachlorophenol (PCP), or 2,4,5-T may have been
involved with these exposures.

The most consistent disease exhibited

by the victims was a skin disease called chloracne.

Crow (1979) indi-

cates that men are more likely than women to be afflicted by
chloracne.
The most publicized chemical accident in modern times occurred in
Seveso, Italy. Hundreds of physicians, scientists and veterinarians
have been involved in either on-site inspections, conferences or consultations involving the accident. This accident did not involve
2,4,5-T, but was associated with the production of trichlorophenol.
Details of this TCDD episode follow: The episode of TCDD poisoning
occurred on 10 July 1976 in Seveso, Italy, a small town 40 kilometers
(km) north of Milan (Forth, 1977; Hay, 1977). The source of the TCDO
was a chemical factory that produced trichlorophenol through the alkaline hydrolysis of tetrachlorobenzene. When the temperature in a
steam-heated reaction vessel rapidly increased, a safety disk ruptured
sending a plume of trichlorophenol, TCDD and other products 30 to 50
meters (m) high above the factory. The cloud apparently rose into the
air, cooled and came down over a cone-shaped area about 2 km long and
700 m wide.
It was estimated that 650 to 1700 grams of "TCDD was discharged
into the environment (Reggiani, 1978). The escaped product had a TCDD
concentration of 35,000 ppm (Anonymmous, 1977). Measurements of TCDD

1-27

�on vegetation in the immediate v i c i n i t y ranged from 1 to 50 ppm.
Reggiani (1978) also reported that birds, rabbits and chickens began
to die 2-3 days after the accident.

A few children and some adults

who had been exposed to cloud of TCDD dust complained of nausea and
different kinds of s k i n lesions.

Wagner (1981) reported that f a m i l i e s

were not evacuated from the area u n t i l 17 to 38 days after the explosion.
W i t h i n the next 6 weeks (by late August, 1976) an extensive system
for monitoring the health of people in the v i c i n i t y was established to
cover the acute as well as the long-term effects.

The most complete

analysis of health data was published by Reggiani in 1978.

He conclu-

ded that the Seveso accident did not reveal toxic effects in humans,
which had not been observed in other episodes.

Chloracne, the typical

skin lesion, has occurred in children with tendency to spontaneous and
rapid h e a l i n g . None of the exposed c h i l d r e n showed clinical signs of
pathology other than chloracne d u r i n g these years.

1-28

�Chapter 1
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1970. Globe's mystery.

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1-30

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Reggiani, 6. 1978. The estimation of the TCDD toxic retential in the
light of the Seveso accident. Paper presented at the 20th Congress of
the European Society of Toxicology. Berlin (West), June 25-28, 1978.
Roan, C. C. and D. P. Morgan. 1972. Alleged effects on human health of
the use of herbicides in the area around Globe, Arizona. Mimeo.,
Arizona Community Pesticide Studies Project. Tucson, University of
Arizona, March 6, 1972.
Sanger, V. L., et al. 1958. Alimentary toxemia in chickens. ^ Am.
.
Vet. Med. Assoc. 133:172-76.
Smith, L. W. and 0. E. Bayer.
Soil Sci. 103-328.
Sun, Margorie.
219:367-69.

1983.

1966.

Missouri's costly dioxin lesson.

Science

Tschirley, F. H., W. Binns, C. Cueto, B. C. Eliason, H. E. Heggestad,
G. H. Hepting, P. F. Sand, and R. F. Stephens. 1970. Investigations
of spray project near Glove, Arizona. Investigation conducted
February 1970. Mimeo, U.S. Dep. Agric., Office of Science and
Education. 29 pp.
U.S.D.A. Technical Bulletin Number 1671, 1982.
Economic Assessment £f 2,4,5-T.

The Biological and

Van Valkenburg, J. U. 1967. The physical and colloidal chemical
aspects of pesticidal formulations research: A challenge. In: J. U.
Van Valkenburg (ed.), Pesticide Formulations Research, Washington,
American Chemical Society. Pp. 1-7.

1-31

�Wagner, S. L. and J. M. Witt, et al. Oregon State University.
Environmental Health Services Center, Oct. 25, 1979.
Wagner, S. L. 1981. Clinical Toxicology of Agricultural Chemicals.
Corvallis, Environmental Health Sciences Center, Oregon State
University, Oregon. 309 pp.
Witt, J. M. 1980. A discussion of the suspension of 2,4,5-T and the
EPA Alsea II study. Pp. 47-59.
Witt, J.M. 1980. A discussion of the suspension of 2j4,5-T and the
EPA Alsea II Study. In: Supplement to the 34th Annual Meeting of the
Northeastern Weed Science Society. 34:9-25.
Young, A. L., et al. 1978. The toxicology, environmental fate and
human risk of herbicide orange and its associated dioxin. United
States Air Force OEHL Technical Report 78-92. Brooks Air Force Base,
Texas. 262 pp.

1-32

�CHAPTER 2
Factors I n f l u e n c i n g M a n ' s Exposure to Phenoxy Compounds
Chapter 1 pointed out that the phenoxy compounds have been widely
used for several purposes.

Their use has not been confined to spar-

sely populated forests or prairies:

they have also been used on or in

croplands, rights-of-way, railroads, p u b l i c u t i l i t i e s , and national
parks.
This chapter w i l l attempt to c l a r i f y the fate and d i s t r i b u t i o n of
the phenoxy herbicides in use.

If people are exposed, what factors

determine what their exposure level w i l l be?
The continued development of more sensitive analytical instruments
allow us a new perspective in l o o k i n g for and locating trace levels of
contaminants in our environment.

From one standpoint these new analy-

tic tools should enable us to be "safer" because we can locate and
i d e n t i f y much smaller amounts of toxic compounds than we could 10
years ago.

Because of these advances, we must better understand the

language used to describe the new trace levels.
The term " m i l l i g r a m s per kilogram" (mg/kg) is commonly used to
denote the weight in m i l l i g r a m s of the compound of interest, w h i l e the
kilogram f i g u r e represents the weight of the test organism in
kilograms.

This ratio is useful in extrapolating data from an animal

of one size to another.
Sometimes large numbers w i t h small u n i t s tend to be confusing. We
could call the distance across the crater of a volcano 804,672 m i l l i meters or equally as true we could call the distance one-half m i l e .
Measurement terms commonly encountered when reading about con-

2-1

�taminants in the environment are parts-per-million (ppm) (10~ 6 ), partsper-billion (ppb) (10~9), and parts-per-trill ion (ppt)(10~^). To
gain a better concept of what 1 ppm represents imagine a full railroad
box car that contains 240,000,000 soybeans; if 240 of these soybeans
were somehow different (let's assume they have a different odor), then
the concentration of these different soybeans would be 240 in
240,000,000 or one in every million or 1 ppm. If we were searching
for 1 ppb level, this would be equivalent to finding one of these
soybeans with a different odor in 4.18 full box cars; if we are
looking for a 1 ppt level we must look through all of the soybeans in
4180 box cars (or a train 39.5 miles long).

This example may sound

somewhat absurd but we have sensitive mass spectrometers capable of
identifying and quantifying dioxins down to the ppt range.

The ter-

minology ppm is correctly interchanged with micrograms per gram (ug/g)
or milligrams per kilogram (mg/kg).
The ultimate question remains:
cause harm to a human?

will trace levels of a chemical

This monograph will address several of the

factors necessary before one can make a valid answer.
How long do phenoxy compounds persist in the environment?
Phenoxys are usually applied in postemergence treatment of growing
vegetation and directly to soil as a preemergence treatment to control
weeds during the germination or small seedling stage.

The special

structure of many herbicide molecules gives them excellent specificity
properties, i.e., they will kill a target weed species without harming
the surrounding cash crop.

Under some conditions these very specific

molecules are also easily destroyed.

2-2

Their biologic activity is often

�greatly affected by a very simple change in molecular structure. The
herbicide is ordinarily at its optimal plant-killing capability
(bioactivity) when it is applied in the field.

Almost all environmen-

tal alterations that occur in the phenoxy compounds result in their
loss of bioactivity.
The following discussion is designed to illustrate the persistence
of phenoxy compounds in the environment.

As they degrade or are

removed from the environment, the changes of human exposure to them as
dislodgeable residues from leaf surfaces or through food uptake also
decrease.
Since the soil acts as an intermediary between application of the
phenoxy herbicides and their potential uptake in human food, knowledge
of the factors that affect their fate in soil is important.

Those

factors include adsorption, leaching, runoff, plant uptake, nonbiologic chemical reactions, microbial decomposition, volatilization,
and photodecomposition.
Adsorption.

This factor keys the importance of most of the other

dissipating factors.

If the compound is tightly bound, only a small

fraction of the total applied material is available for the other
modes of dissipation.

For the phenoxy compounds, adsorption to soil

colloids does not tie up a large percentage of the soil-applied
material.

Although both clay and organic components of soil are

effective in binding phenoxys, the bond is not strong when compared to
many other families of pesticides.
reservoir in an equilibrium process.

Adsorption may be thought of as a
One of the primary reasons for

the phenoxys' rapid degradation is the relatively weak bonds between

2-3

�them and soil colloids.
Leaching.

Since the phenoxys are not tightly bound in soil, their

ability to leach throughout soil is relatively high. Comparing their
mobility with other herbicide families, Helling (1971) found them
moderately mobile to mobile. The amount of downward movement in a
soil profile depends on several factors, among which are the compounds' water solubility, a property which varies greatly depending on
the formulation; the amount and intensity of rainfall; and the physical and chemical composition of the soil. Relatively mobile compounds
such as 2,4-D and 2,4,5-T are also able to move upward in soil. This
can happen as a wick action which allows the wetting front to move
downward or upward in a soil profile.
Runoff.

Because of the phenoxys1 low adsorption and relatively

high water solubility, runoff may occur, especially when applied to
very sloping land. Several factors, such as rapid herbicide breakdown, can prevent excessive runoff.

For runoff to be of major impor-

tance, rainfall or irrigation must occur within the first week after
application.
Plant uptake. Although this is the primary reason soil-applied
herbicides are used, it is surprising that seldom is more than 5% of
the herbicide taken up by plants. In silty clay loams, 2% is more
common.

The amount of plant uptake is often related to the amount of

herbicide in the soil solution; thus, any factor limiting this value
will also decrease the amount the plant takes up (Lavy et al., 1968).
Once inside the plant the herbicide may be degraded or it may remain
as an intact molecule. Plants are able to degrade phenoxys by several

2-4

�pathways, as reported by Kearney and Kaufman (1975).
Chemical decomposition.

Several chemical reactions routinely

occur in higher plants as the phenoxy acetic acid compounds degrade.
Among these reactions are side-chain degradation, ring hydroxylation,
and beta oxidation (Kearney and Kaufman, 1975).

These reactions may

become important if other factors do not readily dissipate the compounds.
Microbial decomposition.

This breakdown mode appears to be the

major one for the phenoxy compounds.

Experiments with sterile and

nonsterile soils produce marked differences in the rate of loss of
phenoxy herbicide phytotoxicity.

An interesting phenomenon occurs

when one retreats soil which had earlier been treated with phenoxy
compounds.

The half-life of a phenoxy in previously untreated soil

may be in the vicinity of one to four weeks (Klingman, 1961), but when
the same soil is retreated with a similar compound the half-life may
be 3 to 15 days.

Walker and Smith (1979) conducted a laboratory study

to evaluate rates of 2,4,5-T degradation in soil.

Degradation

approximated first-order kinetics and the half-life varied from four
days at 35°C and 34% moisture to 60 days at 10°C and 2Q% moisture.
Soil microorganisms are quite adaptable.

They live in a variety

of climates and can devise ways to detoxify compounds they have not
encountered before.

We are indeed indebted to this mass of active

biologic material.
Volatilization.
volatile.

Compounds with high vapor pressures are more

Their phytotoxic properties remain with them as they escape

from the soil into the air.

Once the farmer applies herbicides to the

2-5

�soil, he often incorporates his herbicide in it; i.e., turns the soil
over and thus covers the treated layer with an untreated portion,
thereby preserving the phenoxys1 plant-killing properties for their
intended purpose.

Before a properly incorporated herbicide is free to

leave the soil through volatilization, it must first escape the
binding capacity of the adsorptive soil complex.
Loss of a herbicide through volatilization is often underestimated.

EPIC, not a phenoxy but one of the more volatile herbicides,

was lost from a free-liquid surface at a rate of about 5 Ib/A/h
(Ashton and Sheets, 1959). Even herbicides with relatively low vapor
pressures may be lost from a surface in significant quantities over an
extended period, especially if exposed to high temperature.

Soil tem-

peratures as high as 180°F have been measured (Klingman and Ashton,
1982).
Photodecomposition. Photodecomposition commonly degrades many
herbicides.

Like volatilization, it is often thought of as a surface

reaction which can be prevented by proper incorporation techniques.
On soil and leaf surfaces it represents a major avenue of loss.
Pesticide transformation in sunlight plays an increasingly significant role in our environment (Crosby, 1976). The photo-oxidation of
phenoxy acid herbicides results in rapid deactivation and low persistence.

This process also limits the phenoxys1 usefulness since

they degrade so easily.
Other important factors
Adequate moisture and a temperature range of 20°C to 35°C greatly
enhance the dissipation of most soil-borne phenoxy compounds.

2-6

The

�chemistry of 2,4-D and 2,4,5-T is very similar in many respects.
Studies have shown that 2,4-D is somewhat more rapidly biodegradable,
but the two herbicides' mobility factors are quite similar. Another
difference is that no TCDD affiliation has been shown for 2,4-D.
Because of their striking number of similarities, 2,4-D and 2,4,5-T
will be exemplified interchangeably herein.
One study showed that shortly after 2,4-D was sprayed on growing
vegetation, the leaves contained residues of 200 to 500 ppm, but 10
weeks later this decreased to 20 to 50 ppm (Ramel, 1977). In a
British review of U.S. research, 2,4-D was shown to be nonpersistent
in plant tissues (Turner, 1977). When 2,4-D was applied to cucumbers
in a sublethal dose, more than 75% of the herbicide disappeared within
13 days. Thus, if people are to be exposed to dislodgeable residues
on sprayed leaf surfaces to any appreciable extent, they must make
contact with the treated plants shortly after application.
Photodegradation, rainfall washoff, volatilization, and plant
uptake all play roles as these 2,4-D losses from leaf surfaces occur.
Persistence of phenoxy herbicides in soil
Initial levels of 2,4,5-T in soils are usually low and disappear
relatively rapidly. In field studies, DeRose and Newman (1947) found
that 2,4,5-T at 10 pounds per acre persisted 93 days after application. The investigators concluded that persistence was determined by
soil microbial activity since 2,4,5-T persisted longer in autoclaved
soil than in nonautoclaved soil. Other factors affecting disappearance of 2,4,5-T in soil include soil temperature, leaching, and
soil organic matter. Generally, those conditions that favor microbial

2-7

�activity will favor more rapid decomposition of 2,4,5-T.
In 1954, Warren (1954) studied the leaching and rate of breakdown
of several phenoxy herbicides in a fine sand and silt loam, using
crabgrass as a bioassay species.

He found that 2,4-D ester, 2,4,5-T

amine, and si 1 vex amine moved readily in sandy soil but moved little
in mineral soils or mucks. Esters of si 1 vex and 2,4,5-T were
resistant to leaching in all soils, with some movement in sand only.
The amine formulation decomposed in the soil faster than the ester
formulation.

Silvex tended to be more persistent than 2,4-D and

2,4,5-T.
More recent research, using gas chromatographic analytical techniques, has generally confirmed the results of earlier investigators.
Altom and Stritzke (1973) reported that the average half-life of the
diethanolamine salts of 2,4-D, dichlorprop, silvex, and 2,4,5-T were
4, 10, 17, and 20 days, respectively, in three soils. Except for
2,4-D, the rate of disappearance of the other phenoxys was faster in
soil from Oklahoma grasslands than in soil from forests. Lutz and
others (1973) studied the movement and persistence of picloram and
2,4,5-T (2 and 4 Ib/acre) on a North Carolina watershed that averaged
a 27-percent slope. Approximately 60 percent of the picloram and 90
percent of the 2,4,5-T disappeared in 15 days. Most of the 2,4,5-T
was found in the top 3 inches of soil, with no movement of 2,4,5-T
beyond 12 inches downslope. In Texas, Bovey and Baur (1972) applied
an ester of 2,4,5-T at 0.5 and 1 pound per acre to soils at five locations. Soils were sampled to a depth of 3 feet. Similar results were
obtained at other geographical locations (Norris et al. 1977).

2-8

�Plumb et al. (1977) and others reported on the persistence characteristics of 2,4,5-T applied at 3 pounds per acre to a chamise site in
southern California. Residue levels immediately after application
were not determined, but based on residues present 14 days after
application (0.9 ppm), 2,4,5-T showed a half-life of about 19 days for
the period 14 to 29 days after application. The rate of degradation
changes with time, however. Approximately 1 year after application,
the residue level was about 0.05 ppm.
Morris et al. (1977) determined 2,4,5-T residues in forest floor
and soil after two successive annual applications of herbicide at 2
pounds per acre (ae) applied as the isooctyl ester in diesel oil by
helicopter in March. The study area was a cool, moist site in western
Oregon. The rate of decline in 2,4,5-T levels in forest floor after
the first application at this site was slower than at the hot, dry
site in southern California (Plumb et al., 1977), which may reflect
the importance of volatilization and photodecomposition on the loss of
phenoxy herbicides from exposed soil surfaces.

The rate of loss of

2,4,5-T was quite rapid the first 30 days after the second application, which indicates good adaptation of the microorganisms after the
first application. One year after application, residue levels in
forest floor were about 0.75 .percent of the amount of herb-icide originally applied. These data show the strong tendency of forest sites
to dissipate 2,4,5-T. Residues were largely confined to the top 6
inches of soil.
Effects of high rates of application or persistence
Some people are concerned that residues of 2,4-D and 2,4,5-T left

2-9

�in soils in Vietnam might destroy subsequent crops. Early work by
Craft (1949) DeRose and Newman (1944), and many others indicated that
2,4-D and 2,4,5-T, when applied even at high rates, usually do not
persist from one growing season to another, due largely to microbial
decomposition of the herbicides. Work by Bovey and others (1968) in
Puerto Rico indicated that corn, sorghum, wheat, rice, soybeans, and
cotton could be grown in soils without reduction in fresh weight of
the crops 3 months after the application of a 1:1 mixture of the nbutyl esters of 2,4-D + 2,4,5-T at 24 pounds per acre. Similar
results were obtained for a 2:2:1 mixture of 2,4-D + 2,4,5-T +
picloram at 15 pounds per acre (except for soybeans, which required 6
months for the phytotoxic effect to disappear). The longer residual
effect on soybeans is prob-ably due to picloram, because of its
greater persistence in soils.
Blackman et al. (1974) reported on recent studies in Vietnam,
which indicate that sensitive crops can be safely grown 4 to 6 months
after single applications of the jv-butyl esters of 2,4-D and 2,4,5-T
at rates up to 12 pounds per acre. The authors indicate that the
dosage of herbicides in their experiments was considerably higher than
would occur in spraying forests or mangroves since their materials
were applied directly to bare soil and were not intercepted by herbaceous and woody vegetation.

Young and others (1974) incorporated a

50:50 mixture of the ji-butyl ester of 2,4-D and 2,4,5-T into a soil
trench in Utah at the rate of 1,000, 2,000, and 4,000 pounds per acre.
After 440 days, 89 percent of the herbicide was degraded at the
1,000-lb rate, 85 percent was degraded at the 2,000-lb rate, and 83

2-10

�percent was degraded at the 4,000-lb rate. The rate of loss of the
herbicide was rapid considering the low temperatures that prevailed
for 7 months d u r i n g the experiments.
In another study, Young and others (1974) reported on the effect
of massive doses of 2,4-D and 2,4,5-T sprayed on an area at Eg!in Air
Force Base in Florida. About 92 acres received 1,900 pounds per acre
2,4-D

and 2,4,5-T in 1962 to 1964; a second area received 1,200 pounds

per acre in 1964 to 1966; and a third area received 340 pounds per
acre of 2,4-D and 2,4,5-T from 1966 to 1970.

Chemical analyses of

soil cores collected in 1970 from the treated areas showed a maximum
concentration, 8.7 ppb of either herbicide, i n d i c a t i n g that the herbicide had essentially disappeared.
Factors affecting phenoxy vapors in air
A human's absorbed dose of any compound w i l l be due to i n h a l a t i o n
of airborne materials, ingestion of food or water, and absorption
through the skin. Tobacco use many contribute to the ingested portion.

Human applicator exposure studies w i l l be addressed in detail

in Chapter 3.
Some of the factors that affect the amount of i n h a l a t i o n are the
compound's vapor pressure, the particle size produced d u r i n g application, and the amount of protective equipment used.
Vapor pressure
The vapor pressure of the phenoxy compounds is markedly affected
by the chemical make-up of their formulation.

Since the esters are

more toxic to plants than acid or salt formulations, this is the preferred form for many of the use areas.

2-11

These more phytotoxic forms

�have a higher vapor pressure and are thus more v o l a t i l e . This property of v o l a t i l i t y nearly eliminated the use of the phenoxy compounds in agricultural areas where crop rotations are common since
broadleaf plants, be they weed or cash crop, are indiscriminately
k i l l e d by this family of compounds.

Formulation chemists have greatly

widened the scope of their use by l i n k i n g longer chain esters w i t h the
active plant k i l l i n g component. This lower vapor pressure, less volat i l e material, allows the compound to be used in the near proximity to
susceptible crops.

Thus, when correctly applied placed in the f i e l d ,

it is expected that they w i l l not move in the vapor state but w i l l
remain on the target area. The necessity of decreasing the vapor
pressure of the phenoxys to allow their acceptance in the agricultural
community has at the same time, markedly reduced the levels of the
phenoxy vapors in the air that man breathes.

A factor that has led

man to be wary of pesticides in general, and the phenoxys specifically
is the fact that the human nose is sensitive to low levels of these
chemicals and/or their carriers.
Another factor contributing to man's concern over the use of phenoxys is the fact that v i s i b l e symptoms of extremely low levels of
airborne phenoxys are sometimes shown by off-site broadleaf green
plants.

Some chemicals that are not acutely toxic to plants or a n i -

mals may contaminate an area without anyone suspecting their presence,
however, even the presence of trace levels of phenoxy herbicides becomes quite obvious.

Phytotoxic symptoms such as leaf c u r l i n g or

t w i s t i n g for sensitive species such as cotton, tomato, potato, grapes,
peas, beans, and many broadleaf weeds readily reveal the presence of

2-12

�these compounds.
In an analytical laboratory this property of vapor pressure among
the esters of the phenoxys can be seen quite easily.

In a gas chroma-

tographic determination of a mixture of the compounds, the more volat i l e short chained esters are eluted before the high molecular weight
long-chained materials.

Use of formulations containing these low

volatile esters and even lower vapor pressure amines greatly lowers
the probabilities of phenoxy vapors becoming airborne.
Particle size
Once the herbicide has been formulated in a manner that its vapor
pressure does not s i g n i f i c a n t l y contribute to it being present in the
air there is still another factor that can cause it to be airborne and
that is particle size of the spray material. Larger particles would
be expected to f a l l faster and smaller particles to remain suspended
for a longer time period.
A modification of Stokes Law (Hansen, 1965) which can be used to
calculate how far a compound may d r i f t is:
D =

4

1.49 _2 V - H
10

104
D = 1.49

2

V

'H

where: D = drift in feet, H = height above ground in feet, V =
crosswind velocity in mi/h, r = droplet diameter in m
The drift of spray droplets in a 5 mi/h crosswind from a height of
100 feet would be as shown in Table 2-1. The drift distances
resulting from other crosswind velocities or other release heights can
be determined by applying an appropriate factor to the distances given
or by calculation using the modified Stokes' equation. Thus, droplet

�size is the critical factor determining spray drift since halving the
droplet diameter results in a fourfold increase of drift distance.
A spray droplet is also subject to evaporation while falling. A
very small droplet can evaporate completely before reaching the ground
or a leaf surface (USDA, 1982).

Assuming an air temperature of 86°F,

Table 2-1. Theoretical drift of spray droplets released 100 feet above
ground in a 5-mi/h crosswind (USDA, 1982).

Droplet size,

Theoretical

diameter (urn)

d r i f t (feet)

50

298.0

100

74.0

200

19.0

400

4.6

600

2.0

800

1.2

1,000

.7

1,500

.

.3

relative humidity of 50 percent, and still air, the approximate lifetime and distance of fall for water droplets would be as shown in
Table 2-2. The tabulation shows that water droplets less than 100 urn
in diameter would probably never reach the ground or a leaf surface
when applied from a height of 10 feet, which is nearly a minimum for
aerial application.

2-14

�The lifetimes and fall distances for herbicide spray droplets
would vary from the figures given above. The kind of carrier (oil or
water), vapor pressure of the carrier and the herbicide, and the kind
of emulsion (oil in water or water in oil) would all influence droplet
lifetime. Air turbulence causes major deviations from calculated
fallout rates.
Table 2-2. Lifetime and fall distance of water droplets in air at 86
F and 50% relative humidity (USDA, 1982).

Droplet size,

Fall

diameter

Lifetime

distance

(urn)

(seconds)

(inches)

200

56.0

1,678

100

14.0

151

80

9.5

36

50

3.5

11

40

2.4

2

20

.6

&lt;1

10

.2

&lt;1

2

.1

&lt;1

a6°F, 50 pet relative humidity, still air.

Most of the application equipment in use today produces a range of
droplet sizes. The greater the volume of spray solution found in

�small droplets (less than 100 urn), the greater the drift; however,
there is an upper range of droplet sizes beyond which biological
effect of a herbicide is reduced.

Thus, herbicide applications should

have the goal of achieving a range of droplet sizes that minimizes
drift without unduly sacrificing biological effectiveness.
Under field conditions the effective fall distance is the vertical
distance moved relative to the surrounding air. In turbulent air this
may be several times the height at which the spray is released.
Knowledge of the in-flight behavior of selected droplet sizes and of
the micrometereological factors should allow us to make significant
improvements in predicting drift potential from agricultural spray
operations (Seymour, 1967).
Since it has been established that use of larger droplet sizes
will reduce the amount of particle potentially available to drift let
us examine means of selecting the desirable particle size. Stewart
and Gratkowski (1976) present five factors of importance.

(1)

Increasing airspeed results in smaller droplets because of the greater
shear forces imposed on the spray solution as it leaves the nozzle.
(2) Pressure in the spray system also affects droplet size. Higher
pressure increases turbulence in the nozzle, which in turn increases
shear forces at the nozzle orifice, resulting in smaller droplets
being formed. (3) Orifice diameter of nozzles is directly related to
droplet size. A larger orifice will reduce shear forces caused by
turbulence in the nozzle, and produce larger droplets.

(4) The kind

of nozzle also affects droplet size. Nozzles producing narrow,
cylindrical patterns form fewer small drops; thus, they are better for

2-16

�reducing drift.

(5) Nozzle orientation is a major factor affecting

droplet size. The smallest range of droplet sizes and the lowest
volume of spray solution in small droplets is obtained when nozzles
are oriented parallel to the airstream and discharge downwind to the
direction of airflow.
Equipment is available that will provide droplet sizes of 300 to
400 vmd (volume median diameter in m) with 70 to 90 percent recovery
in a 500-foot width; 400 to 600 vmd with 85 to 95 percent recovery;
800 to 1000 vmd with 95 to 98 percent recovery; and 800 to 1000 vmd
with 99 or more percent recovery (Akeson et al., 1978).
Temperature and relative humidity influence drift through evaporation, which reduces droplet size and results in more drift.

In prac-

tice, many States impose limitations to herbicide application based
upon these two factors. Limitations are also imposed in terms of
maximum permissible windspeed at the time of application. A maximum
windspeed of 5 mi/h is common, although up to 10 mi/h is permitted in
areas where there is less hazard to sensitive vegetation.
A critical atmospheric factor is the temperature gradient with
height, specifically the occurrence of warm air overhead, usually
referred to as an inversion condition (Akeson et al., 1978). An
inversion limits vertical air circulation and acts to concentrate
fumes and small particles in a cloud under the inversion ceiling,
relatively close to the ground. The material thus entrapped may be
transported long distances in amounts sufficient to cause damage to
sensitive crops.
Spray solutions can be modified to reduce the number of small

2-17

�droplets and thereby reduce drift. The principles involved are the
increase of viscosity or of surface tension, each of which tends to
reduce the number of small droplets. The types of preparations
available to reduce drift may be classified as invert emulsions,
thickeners, particulating agents, and foaming agents (Gratkowski,
1973).
Although many variables affect spray drift, it is clear that elimination of small droplets, especially those less than 100 m in
diameter, is the fundamental solution to the drift problem; however,
the biological effectiveness of the phenoxy herbicides decreases as
droplet size increases and droplet density decreases. For example,
McKinlay et al (1972) found that increasing droplet size from 100
to 200 urn, with volume kept constant, required three times as much
active ingredient, and when size was increased to 400 urn, six times as
much herbicide was needed to give equivalent biological effects.
There are two factors that tend to make smaller droplets more effective. First, the leaf area contacted by a given volume of spray solution is greater when droplets are smaller. That may enhance
absorption. Second, high herbicide concentrations localized in larger
droplets may so damage the underlying cells that translocation to
other tissues is reduced.

In practice, the lower effectiveness of

larger droplets can be offset by increasing herbicide concentration of
the spray solution or by increasing the total volume. Both increase
costs.
Drift can be reduced when conventional application equipment is
used, by taking advantage of the best combination of nozzle type and

2-18

�orientation, orifice size, pressure, and spray mixture. In addition,
modern engineering developments permit reduction of droplets below 100
m diameter to near zero. The microfoil boom, for example, has nozzles
placed in a boom shaped like an airfoil, which minimizes turbulence at
the point where droplets are formed. Primary droplets from microfoil
nozzles are about twice the size of the orifice.

Smaller satellite

droplets are formed from thin filaments of spray between the primary
droplets, but proper nozzle orientation will result in the capture of
small droplets by large droplets in the smooth air behind each nozzle.
The microfoil boom provides many of the desirable qualities in
droplet size. However, the microfoil boom is expensive to buy and is
subject to clogging and other problems if it is not properly maintained. Nevertheless, it provides the best drift control available at
this time. Other application systems are in the process of development (Stewart, Gratkowski, 1976).
Protective equipment
Although much can and has been done to limit the number of
respirable particles it is not always possible or practical to eliminate all of them. Many kinds of masks and filters have been devised
to remove respirable size pesticide particles.
Although it may be recommended that a mask be worn the human element plays an important role in determining whether it actually will
be. If the compound of concern is known to be highly hazardous the
worker is more likely to use the protective mask.

Since most woody

vegetation growth occurs during the warm and hot months of the year
that is also when much of the phenoxy herbicide use occurs. Both the

2-19

�heat and the humidity add to the discomfort of man using the protective devices. When men engage in strenuous physical activity in the
hot summer months such as during phenoxy herbicide application masks
are seldom used. Many of these workers have been using phenoxy herbicides for over 25 years with no known ill effects. In spite of the
fact the label on the phenoxy herbicides container indicates that
masks be used, they seldom are.
Possibilities of human exposure via phenoxy components in air
Most dependable inhalation data are achieved by trapping exposure
levels via air. Bamesberger and Adams (1966) indicated that 2,4,5-T
was found infrequently and in low concentrations in air-sampling studies in Washington state. In high use areas, however, one might
expect concentrations similar to 2,4-D as reported by Adams and others
(1974). Average concentrations of ester of 2,4-D in air in Washington
during the spraying season was 0.1 ug/m3. Assuming that a person
would inhale 30 cubic meters of air per day, the exposure would be
0.003 mg per day. The threshold limit values in air adopted by the
American Conference of Government and Industrial Hygienists in 1977
were 10 mg/m3 for 2,4-D or 2,4,5-T.
The highest concentration of phenoxy herbicides in the air probably occurs during application. Russian workers (Fetison, 1966)
reported concentrations of the sodium salt of 2,4-D up to 22.4 mg/m3
after spraying. Akesson, 1978 (communication to USDA, 1982) however,
has shown a maximum of 20 ug/m3 of herbicides downwind from typical
aerial .application sprays. TCDD has not been measured in the air in
spray areas, but possible levels can be calculated based on an assumed

2-20

�2,4,5-T:TCDD ratio of l-.lxlO'7 and the levels of herbicide above (this
assumes TCDD to be present at 0.1 ppm level).
In a national air monitoring pesticide program there were 2,479
samples taken in 14 to 16 different states (Kutz :et al.).

The

sampling sites for 1970 and 1972 were selected for being potentially
areas with a high concentration of pesticides.

The analytical method

had a sensitivity of 1-10 nanograms per cubic meter.- It is evident
that most samples were analyzed at the lower limit of the method's
capability.

There is no established concentration in the air for

2,4-D that is considered to be safe or unsafe for the general population.

The TLV of 2,4-D for a normal working eight-hour day without

adverse effect is 10 nig/m^
Table 2-3.

Three-Year Summary of 2,4-D in Ambient Air in U.S.A. in

Nanograms3 per Cubic Meter from 1970-1972 (Kutz et al. 1976).

Total 3-yr Average
Percent positive samples

5.64

Average values

1.54

Average values of positive samples

18.33

Maximum values

68.17

a

A nanogram is 1 x 10~9 grams = 1 x 10~6 mg, 68.17 nanograms =

0.000,068,17 mg.

Table 2-3 shows that the maximum value found was 68.17 nanograms
which is 0.00006817 mg. This amounts to a safety factor of 146,700

�before reaching the TLV value considered to be a safe exposure for a
40-hour working week.

Again it should be remembered that over the

three-year period covered by this report 2,4-D occurred in the air on
the average only 5.64% of the time and the sites were potentially the
worst possible situations.

Thus, practically speaking, the general

public is not exposed to 2,4-D in the air.
Man's potential for exposure to phenoxy herbicides in drinking water
and other water sources
As discussed under photodecomposition of phenoxy herbicides in
soil, UV light is effective in degrading many herbicides including the
phenoxy compounds.

Microbial action and other chemical reactions may

also occur to rid water of trace levels of herbicide.
The Water Resources Division (WRD) of the U.S. Geological Survey
reported a study on 12 pesticides occurring in 11 western streams
(Brown and Nishloka, 1967).

The three herbicides 2,4-D, 2,4,5-T and

silvex were included but none was found.

The sensitivity of the

method was given as 100 parts trillion (ppt) for 2,4-D and 5 ppt for
2,4,5-T and silvex.

The survey was made over approximately one year.

The WRD reported on the incidence of pesticides in selected
western streams (Mangold and Schulze, 1969).
three-year period, 1966-1968.
over 15 western states.

This report covered a

Samples were taken from 20 locations

The highest amount of 2,4-D found was 0.35

g/liter (0.35 ppb) in James River at Huron, S.D. (According to this
report, the Committee on Water Quality Criteria has established a
standard of 100 ug/liter (100 ppb, 0.1 ppm or 0.1 tug/liter) for all
the phenoxy herbicides.)

There were 321 samples analyzed for 2,4-D.

2-22

�Eighty-seven percent of the samples tested had no 2,4-D.

Of the 41

samples containing 2,4-D, 29, or 70%, had less than 0.15 parts per
billion (ppb).

Table 3 gives a detailed breakdown of the quantities

of 2,4-D found in these samples that occurred only 13% of the time.
Table 2-4.

Occurrence of 2,4-D in ppb in selected Western streams over

a three-year period (Mangold and Schulze, 1969).

0.01-

ppb

0.06-

0.11-

0.16-

0.21-

0.26-

0.31-

0.05

0.10

0.15

0.20

0.25

0.30

0.35

13

13

6

2

3

2

2

No. of

occurrences3
a

Remember that this is only in the samples containing 2,4-D and 87% of

the samples had none.

A monitoring program on water has also been conducted by the Federal
Water Quality Administration of the U.S. Department of Interior
(Lictenberg et al., 1970).

In their five-year survey of water in the

major river systems in the U.S.A., no mention is made of the phenoxy
herbicides.

Analyses were not made for them presumably because based

on the earlier studies (Brown and Nishloka, 1967; Mangold et al.,
1969) they were thought not to be of sufficient concern to warrant
analysis.
The U.S. government has established an acceptable level of 0.1 ppm
2,4-D as a contaminant in what they call community water systems.
This information was published in the Federal Reg-ister (Anonymous,

�1975) in 1975. A tolerance of 0.1 ppm of 2,4-D in potable water has
also been established by EPA. EPA published in 1980 a list of 64
toxic pollutants classified under the Clean Water Act. As would be
expected from the foregoing, 2,4-D is not included on this list.
Since residues of phenoxy herbicides tend to remain in upper soil
layers, they are rapidly degraded. It is unlikely that ground water
would be polluted from current registered uses of phenoxy herbicides,
and thus exposure is considered to be zero.
Surveys by the U.S. Geological Survey program of the surface
waters of major rivers in the Western United States over a period of
years indicated that the highest concentration of a phenoxy herbicide
was 0.97 ppb of 2,4-D. Researchers have found that even in streams
adjacent to aerial spraying operations in the forest, concentrations
of 2,4-D, 2,4,5-T, or other herbicides seldom exceed 0.01 ppm. After
application, concentrations of the herbicide rapidly diminish by dilution. The preponderance of streamwater samples from operational monitoring programs in forest land has not contained detectasble residues
of 2,4,5-T. Even when ditchbanks were sprayed directly, so that spray
fell into the stream, the maximum 2,4,5-T found after applications at
2 pounds per acre was 0.04 ppm. Herbicide could be found only in the
treated area, but none could be found one mile downstream.
Therefore, considering that only small and intermittent portions
of the total land area are treated, the risk of exposure of the
general population in the United States to significant levels of the
phenoxy herbicides in water is remote. The greatest potential for

2-24

�exposure occurs if domestic water is taken from very small streams in,
or immediately downstream from, treated areas. An extensive research
base shows:

(1) Such exposure would be infrequent because most small

watersheds are never treated and those that are treated seldom yield
water contaminated with herbicides; and (2) when contamination does
occur, it is low (less than 0.1 ppm, usually less than 0.01 ppm
2,4,5-T) and remains for only one hour to a few days.
Sugarbeets, soybeans and dwarf corn crops were irrigated with phenoxy treated water at concentrations of 0.02, 1.1 and 5.5 ppm in 2
acre in. of water by both furrow irrigation and sprinkler irrigation
(Bruns et al., 1973). These levels added to the water were much
higher than those found in monitoring studies. At the two highest
concentrations 2,4-D residues were detected in roots only. Sugarbeet
roots contained 0.01 ppm or less. The concentrations of the residues
in the crops even from this height concentration treated irrigation
water, were many times below the tolerance in effect in 1972 for certain food and forages for human and livestock consumption (Bovey and
Young, 1980).
Averitt (1967) studied the persistence of 2,4-D amine in a bayou in
Louisiana after application for control of water hyacinth.
Application of 2,4-D was made as a coarse wet stream at 4.48 kg/ha by
wetting the leaves with little or no runoff into the water.
An evaluation of the persistence of 2,4-D amine in a bayou for
water hyacinth control in Louisiana was made (Averett, 1967). He
applied 2,4-D as a coarse wet stream with little run-off occurring
from the leaves.

2-25

�Water samples taken below depths of 13.5 in one location indicated
residues of 153, 37, 727, 38, 12, and 0.6 ppb for 1 hr, 24 hrs, 1, 2,
3, and 20 weeks, respectively, after application. Residues at a
deeper depth were similar. The high concentration of 2,4-D after 1 hr
is attributed to direct spraying of the water and/or "roll-off" of
spray droplets from hyacinth leaves. The increased concentration at 1
week compared to the level at 24 hr was attributed to loss of chemical
from the plants into the water. Three weeks after treatment the 2,4-D
levels diminished considerably to 12 ppb. The body of water was relatively stagnant with somme flow from upstream, however, the banks of
the bayou upstream had been treated so an influx of water should have
also contained 2,4-D. Small plastic lined boxes, 60 x 120 x 30 cm
deep, filled with lake or bayou water and supporting stands of water
hyacinths were treated with rates of 4.5 or 5.6 kg/ha of 2,4-D amine.
Loss of 2,4-D from the boxes was similar to loss in tha natural bayou.
The 2,4-D had essentially disappeared in 27 days (4 and 15 ppb for 4.5
and 5.6 kg/ha application). Two lagoons chosen for study gave similar
results to earlier studies.
Man's exposure to phenoxy herbicides through the food he eats
Evaluation of market basket surveys provide us with the best criteria for quantifying the levels man is ingesting. For definition
purposes a "market basket" represents the amount of food consumed by a
16-19 year old male in a basic two-week diet. This amount represents
almost twice the food intake for the average individual.
Pesticide residue studies of our food has been conducted by the
U.S. Food and Drug Administration since 1964.

2-26

Seventeen classes of

�food are sampled: dairy products; meat; shellfish, fish; eggs and
poultry; grain and cereals; potatoes; leaf and stem vegetables; beans;
vine and ear vegetables; root vegetables; garden fruits large and
small; oils; fats and shortening; tree nuts; infant and junior foods.
There are 82 individual food items in these "market baskets".

Thirty

markets are sampled in 28 different cities.
In a report by Corneliussen (1972) which covers the period from
June 1969 to April 1970, 2,4-D was analyzed using a test method with a
sensitivity of 0.02 ppm.

Some trace residues were reported which were

below the sensitivity level of analysis.
estimates.

Such low values are only

Chlorophenoxy acids were found four times during this

reporting period.

However, 2,4-D is listed as occurring only twice

with the highest value being 0.125 ppm in the June, 1969 to April,
1970 reporting period.

For earlier periods they report phenoxy her-

bicides were found seven times in 1967-1968, eight times in 1966-1967,
and 13 times in 1965-1966.
Shown in a series of reports (Corneliussen, 1972; Oohnson et al.,
1976; Manske et al., 1975; Manske et al., 1974)

covering the period

of June, 1970 through July, 1973 2,4-D was present only infrequently
(once or twice in all the yearly samples) and in low amounts (about
0.01 ppm). From August, 1973 through July, 1975, no 2,4-D was found
in any of the samples (Johnson et al., 1977; Manske et al., 1977).
summary report (Duggan et al., 1969)

/\

f 0r the period July 1963 to July

1970 indicates the maximum possible amount of 2,4-D a person might
have ingested during this six-year period (1964-1970) is given.

These

amounts are well below the daily intake quantity regarded as safe by

�the FAO-WHO Expert Committee and even further below the
"no-effect-level" established by the World Health Organization. An
expert group on pesticide residues working for FAO-WHO has established
an acceptable daily intake of 2,4-D for humans of 0.3 mg/kg
(Anonymous, 1972).
day.

For

a 132 Ib person this would amount to 18 mg per

Taking a maximum daily intake of 0.005 mg as calculated from

market basket surveys would give a 3600 safety factor before the
acceptable daily intake was even reached. This same international
group (Anonymous, 1972) has also accepted 31 mg/kg/day of body
weight in the rat as being a dose level that causes no toxicological
effect.

The use of this figure of course would result in an even

larger safety factor.

When considering this point, it should be noted

that the Environmental Protection Agency (EPA) has issued a number of
tolerances for 2,4-D.
2,4-D

These tolerances are permissible residues of

in our food and water that EPA considers would not be harmful to

human health.
Following are printed notices EPA has presented as guidelines.
This was taken from the Code of Federal Regulations Title 40
Protection of Environmental Parts 100 to 399 revised as of July 1,
1979 p. 489 Section 180.142 2,4-D:

tolerances for residues,

(a)

Tolerances are established for residues of the herbicide plant regulator and fungicide 2,4-D (2,4-dichlorophenoxyacetic acid) in or on raw
agricultural commodities as follows:
5 parts per million in or on apples, citrus fruits, pears and
quinces.
2,4-D

The tolerance on citrus fruits also includes residues of

(2,4-dichlorophenoxyacetic acid) from the preharvest application

�of 2,4-D isopropyl ester and 2,4-D butoxyethyl ester and from the
postharvest application of 2,4-D alkanolamine salts to citrus fruits,
and from the postharvest application of the 2,4-D isopropyl ester to
lemons.
0.2 part per million in or on potatoes,
(b) Tolerances are established for residues of 2,4-D
(2,4-dichlorophenoxyacetic acid) at:
1000 parts per million in or on grasses (pasture and rangeland):
300 parts per million in or on grass hay:
20 parts per million in or on the forage of barley, oats, rye, and
wheat, corn fodder and forage, rice straw, sorghum fodder and forage,
and sugar cane forage:
2 parts per million in or on sugarcane:
0.5 part per million in or on the grain of barley, oats, rye, and
wheat, corn grain and fresh corn including sweet corn (kernels plus
cob with husks removed), cranberries, grapes, and sorghum:
0.1 part per million in or on blueberries and rice from application of 2,4-D in acid form, or in the form several salts or esters.
The FDA, according to Pesticide and Toxic Chemical News
(Anonymous, 1979), list 2,4-D as being found twice in its food monitoring programs in fiscal 1978 and zero in fiscal 1979.

To put this

in perspective the insecticides malathion and captan were found 329
and 305 times; and 141 and 185 respectively in the same time period.
Thus, it may be concluded that from a health standpoint there is
essentially no 2,4-D in our food supply.
Measurable amounts of 2,4,5-T were found only in.two food samples

2-29

�in FDA market basket surveys in 1966-67 and in one sample in 1967-68.
No 2,4,5-T has been found in food since 1968 in the FDA studies.
total of over 2,000 samples was collected and analyzed.

The highest

2,4,5-T concentration in the 1966-67 samples was 0.19 ppm.
residues of silvex were found.

A

Only two

These occurred in dairy products

collected in 1965-66 and were 0.018 ppm and 0.029 ppm (Environmental
Protection Agency, 1978).

Therefore, based on FDA market basket sur-

veys, the amount of phenoxy herbicides in food is virtually undetectable.
The most direct exposure of humans to 2,4,5-T through food products is probably via plants; however, research has shown that phenoxy
residues in forage and agronomic crops usually disappear rapidly.
Since most weeds in crops are treated in early spring, residues disappear by harvest time.

Devine (1970) analyzed 27 samples of rough rice

fromm Texas, Arkansas, and Louisiana for residues of 2,4,5-T at intervals from 50 to 84 days after application of 2,4,5-T for weed control.
No detectable residues (0.01 ppm) were found.

Rice straw contained

residues that varied from &lt;0.01 ppm to 1 ppm. In the case of pasture
and rangeland plants, which may intercept relatively high amounts of
phenoxy herbicides (up to 200 ppm), residues can be avoided in meat
and milk products by deferring grazing for milk cows on the treated
area a few days to a few weeks and removing meat animals from treated
pastures 2 weeks before slaughter.

These restrictions appear on

current product labels.
W i l l the meat from slaughtered animals which had been bean fed
2,4-D or 2,4,5-T for four weeks contain residues? Negligible levels

2-30

�(less than 0.1 ppm in muscle and fat) were found when no withdrawal
time was employed.

If the animals were fed a regular diet for 1 week

after the 2,4-D or 2,4,5-T feeding occurred, no detectable phenoxys
were found in fat or muscle tissue (Leng, 1972).
Even when w i l d l i f e species or livestock graze on pastures immediately after spraying, only small amounts of phenoxy herbicide may
appear in meat or m i l k .

They disappear after a few days due to rapid

loss of the herbicides from forage and by normally rapid excretion
from the grazing animal.

Klingman et al. (1966), in actual field

grazing trials w i t h cattle, found 0.01 ppm to 0.09 ppm of 2,4-D in
m i l k the first 2 days after spraying 2,4-D at 2 pounds per acre, and
lower amounts thereafter.

No residues of 2,4,5-T were found in m i l k

from cows put into pastures 4 days after spraying. Bjerke et al.
(1972) found no residues of 2,4-D, 2,4,5-T, or MCPA, or their
corresponding phenols, greater than 0.05 ppm in m i l k from cows exposed
to 30, 300, or 1,000 pm 2,4,5-T in their feed level.
silvex were found only at the 1,000 ppm feeding level.

Residues of
Clark et al.

(1975) concluded that residues of phenoxy herbicides or phenolic metabolites in meat of sheep or cattle are unlikely under normal patterns
of 2,4,5-T use.
In field studies, Newton and N o r r i s (1968) found that b l a c k t a i l
deer did not accummulate large amounts of 2,4,5-T when they grazed
browse that had been treated with 2 pounds per acre. Concentrations
in tissue rarely reached detectable levels, and the ruminant was able
to degrade and e l i m i n a t e the herbicide, soon after ingestion.
Obviously, game animals may graze in treated areas immediately after

2-31

�spraying, but in most cases spray areas are substantially smaller than
the home range of large game animals, and thus exposure is not continuous. Game animals are likely to constitute a vanishing small proportion of the average human diet in the United States, but they may
be an important component in the diet of a few individuals.
Fish and other aquatic organisms are also important components of
the diet of humans.

The occurrence of significant amounts of phenoxy

herbicides in the FDA market basket survey in fish products was not
indicated. Research shows that most fish do not accumulate large
amounts of the phenoxy herbicides «1 ppm), even when the herbicide is
applied directly to water surrounding the fish. The degradation rate
of phenoxys in surface water is quite rapid. Fish also have the capability of eliminating and degrading the phenoxys.
None of these reports show food to be a major source of human
exposure.
Assessment of human exposure to the phenoxy herbicides
Man's potential exposure to phenoxy herbicides through the air he
breathes, water he drinks or food he eats has been shown to be minimal. Levels that his skin may absorb by coming into casual contact
with sprayed vegetation would probably be low since these compounds
degrade rapidly on both leaf surfaces and soil.
Although much of phenoxy applied to vegetation may find its way to
the soil or run-off into water the degradation rate is so rapid that
no buildup occurs. Thus, all of avenues for human exposure examined
so far have indicated that humans are receiving non-existant to minimal levels. In the next chapter an in-depth look into exposure levels

2-32

�received by those who apply herbicides for their livelihood will be
made.
It is important to differentiate between man's exposure and his
absorbed dose. It was pointed out that humans may be exposed via
inhalation, dermal depositions or ingestion. An important item which
dictates the degree of risk man encounters is his absorbed dose or how
much of the chemical actually enters the body fluids. The rate and
amount excreted from the body is also important.
The absorbed dose resulting from inhalation must take into consideration how much was present in the air a man breathes in and also
how much is in the air he exhaled. The difference would conceivably
be the absorbed dose unless a fraction of this was expelled as sputum. Absorbed dose resulting from dermal exposure is that amount
penetrating man's dermal membranes. Herbicide contacting the skin
does not necessarily penetrate the surface. In the case of water
soluble phenoxy compounds a considerable amount can be washed off
using soap and water if this is done soon after contact.

In the case

these compounds are ingested, the opportunities for absorption are
much greater. Thus, man or any other organism can not be injured
merely by being exposed to a toxin.

2-33

�CHAPTER 2
References

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Akesson, N. B. and W. E. Yates. 1978.
application handbook.

Wildlands aerial herbicide

Altom, J. D. and J. F. Stritzke. 1973. Degradation of dicamba,
picloram and four phenoxy herbicides in soils. Weed Sci. 21:556-60.
American Conference of Government and Industrial Hygienists. 1977.
Threshold limit values for chemical substances and physical agents in
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Anonymous. 1975. Part IV. Environmental Protection Agency, Water
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Averitt, W. K. 1967. An evaluation of the persistence of 2,4-D amine
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2-34

�Bovey, R. VI. and J. R. Baur. 1972. Persistence of 2,4,5-T in
grasslands of Texas. Bull. Environ. Contam. Toxicol. 8:229-33.
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residues in sugarbeets, soybeans, and corn irrigated with 2,4-D or
silvex treated water. United States Department of Agriculture, Agric.
Res. Ser., Technical Bulletin No. 1476. 32 pp.
Clark, D. E., et al. 1975. Residues of chlorophenoxy acid herbicides
and their phenolic metabolites in tissues of sheep and cattle. J^.
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19:141-58.

1949.

Toxicity of 2,4-D in California soils.

Hilgardin

Crockett, A. B. 1974. Pesticide residue levels in soils and crops,
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DeRose, H. R. and A. S. Newman. 1947. The comparison of the persistence of certain plant growth regulators when applied to soil.
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Devine, J. M. 1970. Report on 2,4,5-T residues in rough rice and
rice straw. Syracuse Univ. Res. Conf. Jan. 26, 1970.
Duggan, R. E., G. Q. Lipscombe, E. L. Cox, R. E. Heatwole and R. C.
Kling. Residues in food and feed - pesticide residue levels in foods
in the United States from July 1, 1963, to June 30, 1969. Pesticides
Monitoring J. 5:73-212.
Fetisov, M. I. 1966. Occupational hygiene in the application of herbicide of the 2,4-D group. Gig. Sanit. 31:383-86.
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Hansen, J. R. A bi-fluid spray system for application of invert
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No. 207. Hercules Powder Co., 1965.

�Helling, C.S. 1971. Pesticide mobility in soils. Proc. Soil Sci.
Soc. Am. 35:732-748.
Johnson, J. E. 1971. The public health implications of widespread
use of the phenoxy herbicides and picloram. BioScience 21:899-905.
Johnson, R. D. and D. D. Manske. 1976. Pesticide residues in total
diet samples. IX. Pesticides Monitoring J. 9:157-69.
Johnson, R. D. and D. D. Manske. 1977. Pesticide and other chemical
residues in total diet samples. Pesticides Monitoring J. 11:116-131.
Kearney, P. C. and D. D. Kaufman.
Marcel Dekker. Vol. I. 500 pp.

1975. Herbicides. New York,

Klingman, 0. L., C. H. Gordon, 6. Yip, and H. P. Burchfield. 1966.
Residues in the forage and in milk from cows grazing forage treated
with esters of 2,4-D. weeds 14:164-67.
Klingman, G. C. 1961. Weed Control as a Science.
Wiley and Sons. P. 130.
Klingman, Glenn C. and Floyd M. Ashton.
York, John Wiley and Sons. P. 449.

New York, John

1982. Weed Science.

New

Kutz, F. W., A. R. Yobs and H. S. C. Yank. 1976. National pesticide
monitoring programs. In: Robert E. Lee, Jr., (ed.), Air Pollution
from Pesticides and Agriculture Processes, Boca Raton, Florida. CRC
Press.
Lavy, T. L, 1968. Micromovement mechanisms of s-triazines in soil.
Soil Sci. Soc. Amer. Proc. 32:377-80.
Leng, M. L. 1972. Residues in milk and meat and safety to livestock
from a use of phenoxy herbicides in pasture and rangeland. Down to
Earth 28:12-20.
Lictenberg, J. J., J. W. Eichelberger, R. C. Dressman and J. E.
Longbittom. 1970. Pesticides in surface waters of the United States;
A five-year summary, 1964-1968. Pesticides Monitoring J. 4:71-86.
Lutz, J. F., G. E. Byers and T. J. Sheets. 1973. The persistence and
movement of picloram and 2,4,5-T in soils. vL Environ. Qua!.
2:485-88.
Manigold, D. B. and J. A. Schulze. 1969. Pesticides in water pesticides in selected western streams - A progress report.
Pesticides Monitoring J. 3:124-35.
Manske, D. D. and P. E. Corneliussen. 1974. Pesticide residues in
total diet samples. VII. Pesticides Monitoring J. 8:110-24.

�Manske, D. D. and R. D. Johnson. 1977. Pesticides and other chemical
residues in total diet samples. X. 1977. Pesticides Monitoring J.
10:134-48.
Manske, D. D. and R. D. Johnson. 1975. Pesticide residues in total
diet samples. VIII. Pesticides Monitoring J. 9:94-105.
McKinlay, K. S., S. A. Brant, P. Morse, and R. Ashford. 1972.
Droplet size and phytotoxicity of herbicides. Weed Sci. 20:450-52.
Newton, M. and L. A. Norris. 1968. Herbicide residues in blacktail
deer from forests treated with 2,4,5-T and atrazine. In: Proc. West.
Soc. Weed Sci., pp. 32-34.
Norris, L. A., M. L. Montgomery and E. R. Johnson.
sistence of 2,4,5-T in a Pacific Northwest forest.
25:417-22.

1977. The perWeed Sci.

Plumb, T. R., L. A. Norris, and M. L. Montgomery. 1977. Persistence
of 2,4-D and 2,4,5-T in chaparral soil and vegetation. Bull. Environ.
Contam. Toxicol. 17:1-8.
Ramel, C. 1977. Chlorinated Phenoxy Acids and Their Dioxins-Mode of
Action, Health Risks and Environmental Effects. Ecological
Bulletins/NFR27. Stockholm, Royal Swedish Academy of Sciences.
Seymour, K. 6. 1969. Evaluation of Spray Drift Potential in
Pesticidal Formulations Research. In: Advances in Chemistry Series 86,
Washington, American Chemical Society.
Smith, G. E. and B. G. Isom. 1967. Investigation of effects of large
scale applications of 2,4-D on aquatic fauna and water quality.
Pesticides Monitoring Ji. 1:16-21.
Stewart, R. E. and H. Gratkowski. 1976. Aerial application equipment
for herbicide drift control reduction. U.S. Dep. Agric. For. Serv.
Gen. Tech. Rep. PNW-54 Pac. Northwest For. Range Exp. Stn. Portland,
Oregon.
Turner, D. J. 1977. The Safety of the Herbicides 2,4-D and 2,4,5-T.
Forestry. Forestry Commission Bulletin 57. London, H. M. Stationery
Office.
U.S.D.A. Technical Bulletin Number 1671, 1982.
Economic Assessment of 2.4,5-T.

The Biological and

U.S. Environmental Protection Agency. 1978. 43 Federal Register
Excerpts from Position Document-1 2,4,5-T Working Group 17128,
17139-17141.
Walker, Allan and Allan E. Smith. 1979. Persistence of 2,4,5-T in a
heavy clay soil. Pesticide Sci. 10:151-57.

2-37

�Warren, G. F. 1954. Rate of leaching and breakdown of several herbicides in different soils. North Central Weed Control Conf. 11:5-6.
Wiersma, G. B., H. Tai, and P. F. Sand. 1972. Pesticide residue
levels in soils, FY 1969 National Soils Monitoring Program.
II.
Pesticides Monitoring J. 6:194-228.
Young, A. 1., E. L. Arnold, and A. M. Wachinski. 1974. Field studies
on the soil persistence and movement of 2,4-D, 2,4,5-T and TCDD.
Abstr. No. 226, Weed Sci. Soc. Am.
Young, A. I , C. E. Thalken, W. E. Ward, and W. J. Cairney. 1974.
.
The ecological consequences of massive quantities of 2,4-D and 2,4,5-T
herbicides. Summary of a five-year field study. Abstr. No. 164, Weed
Sci. Soc. Am.

2-38

�CHAPTER 4

Pharmacokinetic Studies of the Phenoxy
Herbicides in Humans and Animals
Toxicity can be defined as the ability of a material to cause
injury by other than physical (mechanical) means.

It can be deter-

mined by administering known doses of a test substance to laboratory
animals.
A relatively simple test for acute (single dose) toxicity is the
determination of a substances' acute oral median lethal dose LDsg.
Such an LDso (mg/kg) is defined as the single dosage of milligrams per
kilogram body weight required to kill 50&amp; of a test population of animals when given by mouth.

The lower the number, the greater the toxi-

city.
Most commonly used pesticides have some degree of toxicity.
Table 4-1 provides information on toxicity, terminology, LDso's and
estimates for probable lethal dose for a 150 Ib man if exposed to a
toxic material.

The toxicity ratings in this table will be used to

evaluate pesticide toxicity presented in Table 4-2.
exposed to concentrated pesticides.

Humans are seldom

Batchmen mixing chemicals for a

spray operation or those in manufacturing plants are most likely to
contact the concentrates.

Some accidents and suicides have occurred.

4-1

�Table 4-1.
dose.

Ratings of toxicity, LDso, and estimates of man's lethal

(Cleason, et al. 1957).
Probable lethal dose for

Toxicity rating 2

LDso (mg/kg) 1

_

150 Ib man3

Extremely toxic

less than 5

a taste (less than 7 drops)

Very toxic

5-49

7 drops to 1 teaspoonfull

Moderately toxic

50-499

1 teaspoon to 1 ounce

Slightly toxic

500-4,999

1 ounce to 1 pint (1 pound)

Almost non-toxic

5,000-14,999

1 pint to 1 quart

Non-toxic

15,000 and above

more than 1 quart

^Toxicity rating is from Clinical Toxicology of Commercial Products by
Cleason, M.N. , Gosselin, R.E. and Hodge, H.D., and published by
Williams and Wilkins Co., Baltimore, MD, 1957.
^These doses refer to a 100% concentrate.

Many pesticides are con-

tained in solvents which dilute the active ingredient.
the solvent may be more toxic than the pesticide.)

4-2

(In some cases

�Table 4-2. Relative Toxicity of Some Pesticides to Mammals.
(Virginia Pest Management Guide, 1980).
Trade
Common name

LDso1

name

Toxicity rating

(mg/kg)
Herbicides
Alachlor

Lasso

1,800

slightly toxic

Ami no triazole

Amitrole-T

5,000

almost non-toxic

ASPIRIN (for
comparison

750

slightly toxic

Atrazine

Aatrex

3,080

slightly toxic

Bromacil

Hyvar-X

5,200

almost non-toxic

4,659-5,431

Butyl ate

slightly toxic
slightly toxic

Chloramben

Ami ben

3,500

Cyanazine

Bladex

334

Dalapon

Dowpon

Dicamba

Banvel-D

1,028

slightly toxic

Dinitramine

Cobex

3,700

slightly toxic

Dinoseb

DNBP

Diquat

7,570-9,330

moderately toxic
almost non-toxic

58

moderately toxic

Diquat

230

moderately toxic

Diuron

Karmex

3,400

slightly toxic

Fluometuron

Cotoran

1,550

slightly toxic

Glyphosate

Round-up

4,320

slightly toxic

Linuron

Lorox

1,500

slightly toxic

MSMA

MSMA

1,800

slightly toxic

Metolachlor

Dual

4,286

slightly toxic

Metribuzin

Sencor

1,090-1,206

slightly toxic

4-3

�Table 4-2 (cont.)

Trade
Common name

name

LD501

Toxicity rating

(mg/kg)
Monuron

Telvar

2,300-3,700

Oxadiazon

Ronstar

30,000

Paraquat

Paraquat

Pencil me thai in

Prowl

3,380

slightly toxic

Picloram

Tordon

8,200

almost non-toxic

Profluralin

Tolban

2,200

slightly toxic

Propachlor

Ramrod

710

slightly toxic

Si 1 vex

Weed-B-Gon

1,070

slightly toxic

Simazine

Princep

5,000

almost non-toxic

Sodium Chlorate

Tumbleaf

5,000

almost non-toxic

3,320

slightly toxic

120

slightly toxic
non-toxic
moderately toxic

Table salt (for
comparison)
Terbacil

Sinbar

5,000-7,500

Trifluralin

Tref Ian

3,700

2,4-0

2,4-D

2,4-DB

2,4-DB

2,4,5-T

2,4,5-T

Hexazinone

Velpar

16,900

non-toxic

Acephate

Orthene

866-945

slightly toxic

Aldicarb

Temik

1.0

extremely toxic

Azinphosmethyl

Guthion

13

very toxic

300-1,000
1,960
300

almost non-toxic
slightly toxic
moderately toxic
slightly toxic
moderately toxic

Insecticides

4-4

�Table 4-2 (cont.)

Trade
Common name

name

LDSQ!

Toxicity rating

(mg/kg)

Carbaryl

Sevin

Carbofuran

Furadan

Chlordane

Ortho-Klor

850
10
335

slightly toxic
very toxic
moderately toxic

Belt
Chlordimeform

Fundal,

170-220

moderately toxic

97-276

moderately toxic

Galecron
Chlorpyrifos

Dursban,

D erne ton

Systox

12

DDT

Diazinon

113-118

very toxic
moderately toxic

108

moderately toxic

80

moderately toxic

215

AG 500

moderately toxic

Spectracide
Dichlorvos

Vapona,
DDVP

Dimethoate

Cygon,
DeFend

Disulfoton

Di-Syston

12

Ethylene dibromide

Dowfume

108-70

moderately toxic

Fenthion

Baytex,

313

moderately toxic

88

moderately toxic

very toxic

Tiguvon Entex
Lindane

Malathion

Cythion

1,375

s l i g h t l y toxic

Methiacarb

Mesurol

130-135

moderately toxic

4-5

�Table 4-2 (cont.)

Trade
Common name

name

LD501

Toxicity rating

(mg/kg)
Methomyl

17-24

very toxic

14

Lannate,

very toxic

Nudrin
Methyl Parathion

Penncap-M

480

(Microencapsulated MP)

moderately toxic

Parathion

13

very toxic

Pentachlorophenol

27

very toxic

Phorate

Thimet

2.3
200

Pyrethrum
Ronnel

Korlan,

extremely toxic
moderately toxic

906-3,025

slightly toxic

Trolene, Ronnel
132

moderately toxic

14,000

almost non-toxic

64

almost non-toxic

9,000

almost non-toxic

Rotenone
Tetradifon

Ted ion

Fungicides
Benomyl

Ben!ate

Captan

Captan

Fensulfothion

Dasanit

2-10

extremely toxic

Dichlone

Dichlone

1,300

slightly toxic

Captafol

Difolantan

Oxydisulfoton

Disyston

Perbam

Ferbam

Carbofuran

Furadan

Maneb

Maneb

6,200

almost non-toxic

3.5

extremely toxic

17,000
11
6,750

4-6

non-toxic
very toxic
almost non-toxic

�Table 4-2 (cont.)
Trade
Common name

name

LD5Q1

Toxicity rating

Captan

Orthocide

9,000

almost non-toxic

Thiram

Thiram

Zineb

Zineb

780

5,200

slightly toxic
almost non-toxic

(mg/kg) - The dosage of milligrams per kilogram of body weight
required to kill 50% of test animals when given a single dosage by
mouth.

From:

Herbicide Handbook of the Weed Science Society of

America, 4th Edition, 1979.

A list of several pesticides grouped as families of herbicides,
insecticides, or fungicides is presented in Table 4-2. This table
suggests that as a family, the toxicity of herbicides presents a minimal risk to human health.

Phenoxy herbicides have been specifically

designed to kill broadleaf weeds; as such it is not surprising that
they have relatively low capability to cause harm to animals (Vaccaro,
1983).

Insecticides as a family have a higher potential for harming

higher animals.

It is interesting to look at information from the

Poison Control Center on reported cases of poisoning.

In 1979, there

were over 144,000 reported cases of poisoning with 70 fatalities.

4-7

�None of the 70 fatalities were due to herbicides. Of the 144,000
reported cases, 5% were attributed to all pesticides and 0.2% to herbicides.
The LDso values as listed in Table 4-2 represent acute doses or
the amount that an animal can tolerate if all was administered in one
dose. These values from test animals are of real assistance when
addressing poisoning or attempted suicide cases in humans.

Since men

are seldom used as guinea pigs in our society to study potential longterm (chronic) effects of repeated exposure to low levels of pesticides, animal feeding experiments are conducted.

In these studies

several different concentrations of pesticides are routinely incorporated into all of the food ingested by the test animal. The duration of feeding periods may range from 1 week to more than a year for
many of the tests. The studies are required to include concentrations
that are sufficiently high to at least cause injury to some of the
test animals. No observed effect levels (NOELs) are determined by
citing the highest pesticide level at which no harmful effects are
detected on the test animals.
It is relatively easy for the results of this type of study to be
misinterpreted since often the information is not presented in a
manner that one can easily understand regarding how much of the chemical was required to cause the effect. Information derived from studies of this kind are of importance to man as he seeks to make
judgements regarding any exposure to pesticides that he may receive.
Conducting a well designed research study is not as difficult as
effectively communicating the findings to an interested audience of

4-8

�varying backgrounds.
Results from the applicator exposure studies have shown that a
portion of the phenoxy herbicides as they are being applied as vegetation control do not reach their target. In fact, at times humans may
be inadvertent receptors resulting in an "absorbed dose." The goal of
this chapter is to investigate the fate of the phenoxy compounds after
they have contacted humans, entering the body by penetrating the skin
(the most common route) via the food and water consumed or in the air
breathed.

The most commonly used phenoxy compounds 2,4-D and 2,4,5-T

will be discussed. Since the LDso for 2,4-D ana 2,4,5-T is "upwards
of 300 mg/kg" for several animal species (CAST, 1978) it is highly
likely that these compounds have some biological activity for humans
also. The mere fact that a compound has some moderately toxic properties does not make it dangerous unless one receives an absorbed dose
and even then the amount of the dose is the important factor.
A philosopher of the Middle Ages, Paracelsus, said "All substances are poison; there is none which is not a poison. The right dose
differentiates a poison and a remedy." If the full understanding of
the meaning of dose could be clearly commmunicated an informed U.S.
public would have less trouble sleeping at night. The user needs to
be aware of the toxicity of the compound he is using. As shown in
Table 4-2 pesticides vary greatly in their toxicity to man and other
animals.
The phenoxy compounds have an excellent human health record when
considering their widespread use and the lack of complaints or health
problems arising from pesticide applicators, the most exposed group.

4-9

�What protective mechanism(s) does man possess which allows him to
be in contact with these compounds, sometimes over an extended period,
without them causing him noticeable physical harm?

To gain a better

understanding of how his body is able to excrete or rid itself of
these compounds an evaluation of animal feeding studies with the phenoxy compounds is in order.
An indication of the extent of animal toxicological testing with
the phenoxy compounds is obtained from Diaz-Col en et al. (1977) who
indicate that more than 870 such studies have been completed in the
past 25 years.

In one study residues of the 2,4-D and its breakdown

products were determined in muscle, fat, liver and kidney of cattle
and sheep fed up to 2000 mg 2,4-D per kg in their feed.

Muscle and

fat contained the lowest levels while kidneys and liver contained the
highest residue level.

Withdrawal from treatment for one week

resulted in a significant reduction in tissue residue levels.

With

the exception of the kidneys, 2,4-D residues averages less than I
mg/kg in the tissue analyzed.

The kidney tissue level averaged 7.82

mg/kg with 0.37 mg/kg present after a 7-day withdrawal period. No
2,4-D was detected in fat or muscle of any animals at a detection
limit of 0.05 mg/kg.

(Lack of build-up of the phenoxy herbicides in

fatty tissues of animals is common; this is in sharp contrast to some
of the more persistent chlorinated insecticides which are stored in
fatty tissues of mammals.)

All treated animals in this study showed

some loss of apetite, weight loss or poor weight gain depending on the
level 2,4-D present in the feed.

During the 7-day withdrawal period,

feed consumption in all groups returned to normal (Clark et al.,

4-10

�1975).

Cattle, which were fed 50 or 100 mg/kg/day phenoxy herbicide

(2,4,5-T or Silvex) for as long as 1 year, suffered no ill effects.
Livestock can safely eat vegetation freshly treated with phenoxy herbicides, however, milk or meat fromm these animals could contain trace
levels of residue.

It is recommended that 2 weeks elapse between phe-

noxy treatment of vegetation and slaughter of animals grazing the
treated area (Leng, 1972).
One of the short-comings of some animal testing data as described
by the Advisory Panel on Toxic Substances (Beljan et al., 1981) states
"One of the common failings of animal toxicity assessments is the use
of test doses that are much higher than those that may be encountered
by humans.

Such massive doses are intended to shorten the time for a

response or, in the case of a carcinogenicity test, to increase the
probable incidence of tumors within a sample of animals."

However,

much valuable information can be obtained from animal studies when
realistic rates are selected proper
A two-year study by Smith et al, (1978) of chronic toxicity and
incidence of cancer among rats inge ting diets containing 2,4,5-T
revealed few toxicological symptoms (loss of body weight and slight
changes in the size or shape of kidneys, livers, and lungs) even at
the highest does level (30 mg 2,4,5-T/kg body weight/day).

This study

also showed no incidence of cancer response in rats even when administration of 2,4,5-T extended over most of their life span at a
dosage high enough to induce other toxicity.

As for the effects of

2,4,5-T on reproduction, they found in studying three generations of
rats that dose levels of 2,4,5-T high enough to cause signs of toxi-

4-11

�city had no effect on the reproductive capacity of rats, except for a
tendency to reduce s u r v i v a l of the young at dose levels of 10 and 30
mg/kg/day.
Numerous studies on the fate of 2,4-dichlorophenoxy-acetic acid
(2,4-D) and related herbicides in animals have shown that these chemicals are absorbed and excreted unchanged in the u r i n e w i t h i n a week
after administration (Leng, 1977).

Pharmacokinetic studies with

2,4,5-T in rats and dogs (Piper et al., 1973) supported these f i n d i n g s
(Pharmacokinetic studies show us how a chemical is treated by the body
and how rapidly it is excreted).
Repeated doses of 2,4-D or 2,4,5-T in animals do not cause toxic
symptoms since they continually eliminate it.

This process is protec-

tive since it does not allow the concentration to build-up. The
study of how animals eliminate foreign chemicals and the rate of elimination is important in understanding the fate of phenoxy compounds
in humans.
Fate of phenoxy herbicides in man
In an experiment to determine the fate of ingested 2,4,5-T in man,
f i v e male volunteers (from 31 to 58 years of age) were each given a
single dose of 5 mg/kg of body wt of 2,4,5-T (which contained less
than 0.05 ppm of TCDO).

Blood concentration of 2,4,5-T reached a

maximum in 7 hours, and then declined for the f o l l o w i n g 5 days.
W i t h i n 5 days, 89% of the ingested 2,4,5-T was excreted unchanged in
the u r i n e (Gehring et al., 1973). From these results the investigators predicted that an i n d i v i d u a l ingesting d a i l y doses of 2,4,5-T
would have attained his highest level after 3 days.

4-12

�In related research showing 2,4-D excretion Sauerhoff (1977)
showed that 2,4-D was also absorbed almost entirely and eliminated
from the body in the urine - 95% within 4 days.

With repeated doses,

a plateau is reached and the body excretes 2,4-D as rapidly as it
enters.
This research provides evidence of the fate of phenoxy herbicides that are orally ingested by humans; but, as shown in Chapter 3,
forest crew members applying phenoxy herbicides appeared to receive
their highest dose when these compounds penetrated their bare skin
areas.

Personnel associated with the "Operation Ranch Hand" program,

which involved use of the phenoxy herbicides as defoliants in Vietnam
would probably also have received the majority of their exposure by
skin absorption.

Studies by Sauerhoff et a!., 1976 show that

regardless of the path of entry, rapid urinary elimination of 2,4,5-T
occurred in rats.
Probability of dermal absorption
Is it feasible that significant levels of an organic chemical
could pass through man's skin? Baranowska-Dutkiewicz (1982) indicates
that under industrial conditions the skin is the main route of aniline
absorption.

To obtain a measure of the absorbed dose of aniline

occurring in 30 or 60 minute exposure a 24-h urine sample was analyzed
for p-aminopheriol.

They cited other research which showed that ben-

zene, styrene, xylene and carbon disulphide were even more readily
absorbed by human skin.

Hosier et al. (1980) analyzed blood plasma

and urine to provide indicators for the amount of 10% lindane cream
absorbed by human skin in a 12-hr exposure study.

4-13

Jakobson et al.

�(1982) indicates that uptake of organic solvents through the skin may
pose a risk during occupational handling of these compounds.

Warnings

are given that considerable uptake may occur when certain solvents
contact human skin. Durham et al. (1972) indicates that although
absorption by the respiratory route is faster than through the skin,
the opportunities for dermal exposure are often much greater.
Studies of the dermal absorption of 2,4-D applied to human
forearms revealed that 6% of the applied amount was recovered in urine
collected during the week after exposure (Feldman and Mai bach, 1974).
The findings of the applicator exposure studies presented in Chapter 3
which showed dermal absorption of phenoxys to be the major route of
entry into the body are compatable with the results of the research
above.
Although the odor near an application site often times is quite
pronounced, it is interesting that in both of the detailed phenoxy
applicator exposure studies reported here and also in other studies
the amount of the compound in the air was minimal on a weight basis
compared to the dermally absorbed dose.
Young et al. (1981) applied the propylene glycol butyl ether
esters (PGBE) of 2,4,5-T to the shaved skin of rats. This is the same
formulation of 2,4,5-T used in the 2,4,5-T applicator exposure studies
described in detail in Chapter 3.
When this 2,4,5-T was absorbed through the skin only 2,4,5-T could
be detected in the urine. The authors concluded that the application
of PGBE ester to the skin of rats resulted in 2,4,5-T itself in the
body. Therefore, exposure to esters of 2,4,5-T can be regarded as

4-14

�toxicologically equivalent to the 2,4,5-T itself.

Six days after

application to the skin they recovered approximately 97% of the
2,4,5-T in the urine.

Samples of either blood or urine from exposed

individuals should provide a measure of the absorbed dose since the
phenoxy compound must enter the blood stream before it is excreted in
urine.

Total urine collection allows the researcher to recover almost

all of the phenoxy herbicide that was absorbed.
Young et al. (1981) also observed that adsorption through skin
was much slower than absorption of ingested 2,4,5-T.

The low rate of

absorption of the ester through the skin suggests that removal of the
ester from the skin by washing after exposure could substantially
reduce the dose of 2,4,5-T received by this route.

The relatively

slow dermal absorption and excretion rate agrees with human data
derived from the 2,4,5-T exposure study presented in Chapter 3.
The extraordinary ability of man's body to rid himself of foreign
substances and other toxins is vividly demonstrated as one scans the
literature.

Although the prudent man will protect himself from unne-

cessary exposure to toxins in the environment, it should be reassuring
to him to learn that he has several built in safety devices. Perhaps
in this age when the media almost monthly reveals to us the toxic
effects of one of our foods or some other chemical product that we
come into contact with it is reassuring to know that our kidneys or
other body systems are attempting, on a full-time basis to remove both
known and unknown toxins that we encounter.

4-15

�Factors affecting man's absorption and excretion rates of phenoxy
compounds
One of the more perplexing questions with regard to interpreting
results from pesticide applicator exposure data is why the correlation is so low between the amount of pesticide deposited on patches and
that excreted in urine. Data presented earlier in this chapter i n d i cates that phenoxy herbicides are nearly quantitatively excreted in
m a n ' s urine and that dermal absorption is the major avenue of entry
into his body.

Thus, i n t u i t i o n suggests that levels derived from

quantitatively measuring the herbicide deposited on m a n ' s skin and the
amount excreted in his urine would be h i g h l y correlated.

In both the

2,4,5-T and the 2,4-D applicator exposure studies (Lavy et a!., 1980;
Lavy et al., 1982) poor correlation for these two measurements was
found.

What are some of the potential reasons for these findings?

Figure 4-1 depicts the typical excretion rate of p-aminophenol for
an i n d i v i d u a l dermally exposed for 1-hr to l i q u i d a n i l i n e
(Baranowska-Dutkiewicz, 1982).

When a single dermal exposure occurs

over a 1-hr period for a rapidly absorbed compound a smooth uniform
excretion pattern occurs.

Figure 3-1 on page

illustrated the

excretion pattern of 2,4-D by one of the more heavily exposed crewmembers in the 2,4-D exposure study who probably did not receive all of
his exposure on the day the spray was applied (Lavy, 1980).

Since

patches were attached to the worker's clothing only on the application
day, and urine was collected over a 6-day period it is not surprising
to f i n d poor correlation between patch data and urinary excretion data
if exposure was not l i m i t e d to the day of application. As discovered

4-16

�Figure 4-1.

Excretion rate of p-aminophenol in urine in a subject
exposed to 1% aniline solution for 1 h
(Baranowska-Dutkiewicz, 1982).

�8

£
LxJ
en

6
5

o:

g
h- 3
LJ
CC

O p
X ^
Ld

I

8

10

12
14
HOURS

16

18

20

22

24

�in post-study interviews for some workers, the opportunity for cont i n u i n g exposure occurred as they cleaned equipment.

Contaminated

clothes could also provide prolonged exposure.
Another fact that could be contributing to the low correlation
between patch and urine data is the physical location of the patches
on the test subject.

In the 2,4,5-T study (Lavy, 1978) 6-10 x 10 cm

paper backed gauze patches were attached to clothing of the worker at
the f o l l o w i n g locations:

chest, back, upper arms, and upper thighs.

In the 2,4-D study the denim patches were attached to worker's
clothing near their bare skin areas.

The calculations for predicting

dermal exposure to humans are dependent on knowing:

a) the area of

patches retaining the chemical, b) the total weight of the pesticide
deposited on the patch, c) the area of bare skin of the crewmember
( t h i s is obtained by viewing photographs of the crewmember in his work
clothes and using a human area formula developed by Durham and Wolfe
(1962)).

Use of patches and consequent interpretation of data derived

from their use is based on assumptions that pesticides 1) are uniformly deposited across all parts of the body; 2) that patches capture
and retain the same amount of pesticide that the skin retains ( t h i s
could hardly be true if a man were perspiring and he was wearing dry
patches) and 3) that all portions of a m a n ' s skin are equally
penetrable by the pesticide in use.
Data presented by Lavy et al. (1980b) showed that the range in
weight of 2,4,5-T on s i m i l a r sized patches on the same i n d i v i d u a l
ranged from 20 to 8760 micrograms.

The anatomical site of application

has been shown to affect the percutaneous absorption of compounds in

4-17

�humans (Maibach et al., 1971). The interaction between skin and the
specific pesticide will also be important. Some will adhere strongly
to the skin while others will more readily pass through.
When all of these factors are taken into consideration it is not
surprising that low correlations exists between patch and urinary
excretion data in phenoxy exposure studies.
Gehring et al. (1973) developed an equation to predict a per day
excretion curve for humans given a single dose of phenoxy herbicide.
Nash (1983) has expanded on this work and devised an equation which
allows one to make an estimate of the absorbed dose which occurred on
the day of exposure. He indicates that by knowing the elapsed time
between the exposure day and the day a 24-hr urine sample was taken,
his equation can provide a good estimate of the extent of absorption
which occurred.

If functional use of the above approaches could be

made it would save the field research crews considerable time and the
crew participants inconvenience (as contrasted to collecting every
drop of urine over a 6-day period). Unfortunately as shown in Figure
3-1 on page

, actual field exposure received by some workers does

not occur all on the same day. Thus, if the researcher is looking for
measurement of the total phenoxy exposure occurring to all crewmembers
who work as a part of the field application process he will continuously monitor the phenoxy content of urine from humans during all
of the time exposure is potentially occurring and for at least 5 days
following the last potential exposure.

Even though the exposure to

humans applying the phenoxy herbicides was not all limited to the
actual application day it was shown in Chapter 3 that even for the

4-18

�i n d i v i d u a l s m i x i n g the concentrate and receiving m u l t i p l e exposures,
natural human body processes are capable of keeping the level of the
phenoxy herbicides which penetrate the body well below harmful levels.
It is vital that we not overlook the primary f i n d i n g s of this
monograph - namely although man experiences some exposure to the phenoxy compounds the detection of this exposure is made possible only
through advances in analytical equipment which allow pesticide detection capabilities in the parts per b i l l i o n range.

The backpack appli-

cators and mixers (those receiving the highest absorbed dose) (Lavy,
1978) did not feel i l l or e x h i b i t any symptoms.

The absorbed dose for

these highest occupationally exposed i n d i v i d u a l s is 300-fold below the
no-effect level.

Putting this into another context - if one were

dependent on surveys and results from questionnaires of workers who
mix and apply the phenoxy herbicides, basically we would come to the
conclusion that no exposure was occurring.

These compounds have been

used extensively for over 30 years with no known i l l effects due to
their use when used in accordance to the directions provided.

Thus,

other than through the use of analytical equipment capable of
detecting trace levels of pesticide residues, the only evidence that
exposure is occurring is by v i s u a l l y observing that sometimes workers
get the spray materials on their skin and that a characteristic odor
is often present at spray operation sites.
Effects of repeated exposures
Questions such as the f o l l o w i n g have not been addressed f u l l y :
Do repeated exposure to the phenoxy herbicides pose a threat to the
health of people who work as pesticide applicators for several months

4-19

�a year? How high a concentration of the phenoxy herbicides will build
up in such applicators?
The exposure data presented have addressed the question:
exposure does a human receive during a one-time exposure?

How much

Researchers

are aware that normally field workers do not apply phenoxy herbicides
just one time a year.

However, to obtain good replicated data it

is

important that each of the crewmembers enter the study on an equal
exposure basis.

If some had been spraying continuously for a week

prior to the study, others two days, and others intermitently for 3 or
4 days it would be nearly impossible to attain meaningful replicated
data.

If the study had been designed to measure the exposure

occurring during and after 4 sequential spray days, how would one
handle the data collected following a weather pattern which allowed 2
days of application before a 3-day rainstorm prevented continuation of
the research? The logistic problems associated with carrying out the
research would be greatly increased and the replications would be
destroyed unless all workers were at the same location experiencing
the identical work conditions for the same period of time. Another
reason for selecting a single exposure day was the fact that single
dose exposure data could be extrapolated to produce the same results
that would have been attained if an individual had been exposed
repeatedly.
Taking a scientific approach to answering the repeated exposure
question Ramsey et al. (1978) made a pharmacokinetic analysis of the
2,4,5-T exposure study reported in Chapter 3 (Lavy, 1978).

They indi-

cate that the total amount of 2,4,5-T excreted in the urine following

4-20

�exposure represents a minimum estimate of the amount of 2,4,5-T
absorbed, since excretion may not be complete at termination of the
experiment.

However, calculation of the absorbed dose of 2,4,5-T

based on pharmacokinetic analysis of urinary excretion data is not
dependent on total excretion and can provide a realistic estimate of
the absorbed dose.
Ramsey et al. (1978) estimated the amount of 2,4,5-T by the
workers using knowledge of 2,4,5-T in humans from controlled experiments Gehring et al. (1973). Experiments in laboratory animals have
shown that 2,4,5-T is excreted in the urine at the.same rate
regardless of how it enters the body. In other words intravenously
and orally administered 2,4,5-T are excreted in the urine at the same
rate. Since urinary excretion of 2,4,5-T is independent of the route
of exposure (Young et al., 1981; Sauerhoff et al., 1977; Piper et al.,
1973) these authors used the data of Gehring et al. (1973) to calculate the dose of 2,4,5-T absorbed by forest workers, even though most
of it was absorbed through the skin.
Ramsey et al. (1978) took this information and prepared the
following model for urinary excretion.

S(t)

k0i

B(t)

kie

E(t)

This is a schematic diagram of the pharmacokinetic model for the
absorption of 2,4,5-T or its PGBE ester in humans, followed by urinary
excretion of 2,4,5-T acid. S(t) = amount of 2,4,5-T in the body at
time t. E(t) = amount of 2,4,5-T excreted in urine at time t, and
and k^e = first order rate constants for absorption and excretion of

4-21

�2,4,5-T, respectively. B(t) = amount in body at time t.
They took urinary excretion data from Lavy (1978) and employed the
model. They indicated
The amount of 2,4,5-T in the pre-exposure samples fluctuated
widely with no apparent pattern, therefore no background
corrections were applied. The workers employed as mixers may
have been exposed on the day previous to the application date
(since the formulations are usually mixed the day before the
actual application), but for purposes of pharmacokinetic analysis they were considered to be exposed only at the date of
application. The duration of the application procedures
ranged from 55 minutes to approximately 4 hours (average 138
minutes). Since this is a short time span relative to the
total duration of the experiments (up to seven days), the
calculated dose was considered to be a single application to
the skin at time zero.
Values listed in Table 4-3 represent the percentage of the total
absorbed dose of 2,4,5-T which was excreted on each of first seven
days following exposure.

4-22

�Table 4-3. Cumulative fraction of the dermally absorbed dose of 2,4,5-T
excreted in the urine (Ramsey et a"!., 1978).

Days following

Cumulative fraction of

exposure

dose excreted

1

0.1956

2

0.4819

3

0.6974

4

0.8326

5

0..9105

6

0.9532

7

0.9760

Ramsey et al. (1978) commented:
The pattern of the daily amount of 2,4,5-T excreted in the
urine following exposure is characterized by a maximum on day
2, followed by a steady log-linear decline thereafter.
However, an examination of the data shows that, in many
cases, there is a significant increase in the amount of
2,4,5-T excreted after the second day following exposure.
These data are inconsistent with the excretion pattern
expected from a single exposure (Gehring et al., 1973), and
thus, probably indicates subsequent exposure to 2,4,5-T or to
its ester after the actual application date. The speculation
that such exposure might arise from the use of contaminated
clothing or footgear should be verified by further experiments and observations. In each case, these increased
amounts of urinary 2,4,5-T have the effect of increasing the
calculated dose, and therefore result in maximized estimates
of the dose absorbed on the application date.
Since the data reported by Lavy (1978) indicate clearly that
the respiratory route of exposure to 2,4,5-T is virtually
negligible, the major portion of the absorbed dose of 2,4,5-T
was the result of dermal exposure to ESTERON 245 herbicide
formulations. Methods used to calculate the absorbed dose
will reflect the total amounts of 2,4,5-T absorbed by all

4-23

�possible routes.
Figure 4-2 is a composite of the urine excretion curves from the
21 workers in the 2,4,5-T exposure study. The above detailed
interpretation by Ramsey et al. (1978) evaluated each of the worker's
excretion data individually. It is interesting that a relatively
smooth pattern exists when the whole group is evaluated on a composite
basis. This is in contrast to the rather marked variability from
individual to individual.
The question of maximum attainable body burden is specifically
addressed by Ramsey et al. (197$).
The pharmacokinetic model describing the absorption and
excretion of 2,4,5-T in humans can also be used to predict
the accumulated body burden of 2,4,5-T that would result from
repeated daily exposures. The results of this mathematical
simulation are shown by the solid line in Figure 4-3. These
simulated data predict that the maximum accumulated body burden of 2,4,5-T resulting from repeated daily exposures would
be 1.4x the daily dose (D0). In other words, if a worker
absorbed a dose of 0.05 mg/kg each day, the maximum body burden attained would be 0.07 mg/kg and this maximum would be
reached after approximately 7 daily exposures. However, if
the 2,4,5-T remaining to be absorbed were removed 6 hr after
each exposure (e.g., by washing or changing clothing), the
predicted accumulated body burden would be represented by the
dotted line in Figure 4-3. In this case, the maximum body
burden would be 0.3x the daily dose D0, and this maximum
would be reached after approximately 3 daily exposures.
In summary, the amount of 2,4,5-T absorbed by forest workers
during the application of ESTERON® 245 has been shown to be
generally less than 0.1 mg 2,4,5-T per kg of body weight.
Since this dose level is far below the no effect level of 20
mg/kg for fetotoxic or teratogenic effects cited by EPA
(1978), we conclude that under these conditions the absorption of 2,4,5-T presents a negligible toxic hazard to forest
workers.
A composite of the urinary excretion of 2,4-D forestry workers is
presented in Figure 4-4. Ramsey et al. (1980) attempted to use this
information on their pharmacokinetic model:

4-24

�Figure 4-2. Average daily excretion of 2,4,5-T in urine of forest
workers applying 2,4,5-T (backpack, mist blower, and
helicopter methods)(Lavy, 1978).

�MILLIGRAMS 2,4,5-T EXCRETED IN URINE
Avg. of 21 workers

0.900

0.600

I

ro
EU

1
0.300

I

I

5

7

DAYS

*

9

II
SPRAY DATE

�Figure 4-3.

Simulated body burden of 2,4,5-T following 13 repeated
daily exposures in units of the daily dose D0 (Lavy,
1978).

�1.0
0.9
0.8
0.7
IN3
-p.

tr

Body

Multiple Exposures

0.6

Burden 05
of 2,4-D 04
(Do)

03

0.2
O.I
0

Single Exposure

6

8
10
12
14
16
No. of Exposures = No. of Days

�Figure 4-4.

Average daily excretion of 2,4-D in urine of forestry
workers applying 2,4-D by helicopter (Lavy, 1980).

�MILLIGRAMS 2,4-D EXCRETED IN URINE
0.150

-p&gt;
ro
o

Avg. of 18 workers

0.100

.050

I

6

8

DAYS

10

12

I

14

* SPRAY DATE

�In contrast to the 2,4,5-T study cited above, the levels of
urinary 2,4-D in the present study could not be measured for
a sufficient length of time (because the exposure levels were
so low that the concentration of urinary 2,4-D was often
below the analytical detection limit) to allow direct determination of the first order rate constant for the dermal
absorption of 2,4-D esters in these workers. However,
because of the close similarity between the pharmacokinetic
profiles of 2,4-D and 2,4,5-T, the rate of dermal absorption
of 2,4-D esters in humans may be similar to that for 2,4,5-T
esters. This assumption is supported by the observation that
the half-life values for the dermal absorption of the PGBE
esters of 2,4-D and 2,4,5-T in rats are similar, approximately 20 hours and 24 hours, respectively (Young et al.,
1981).
In order to calculate the pharmacokinetic fate of dermally
absorbed 2,4-D in humans, numerical values for the rate
constants of absorption and elimination are required. Based
on the considerations above, the dermal absorption rate
constant of 2,4-D esters in humans was assigned the same
value as that for 2,4,5-T esters (half-life = 18 hours)
(Ramsey et al., 1980).
The urinary excretion rate constant of 2,4-D and conjugates was
assigned the value previously determined in a human study (half-life =
11 hours) (Sauerhoff et al., 1977).

These values then allowed the

calculation of the amount of dermally absorbed 2,4-D that is excreted
in the urine at any time following exposure (Ramsey et al., 1979).
This calculation reveals that approximately 99% of a dermally absorbed
dose of 2,4-D esters would be excreted in the urine as 2,4-D during
the exposure day and for 5 days thereafter.
These values for the rate constants were also used to obtain a
computer simulation of the body concentration of 2,4-D that would
result from repeated daily dermal exposure to 2,4-D esters.

The

results of prediction are shown in Figure 4-5 in which the body burden
of 2,4-D is given in units of the dose that has been absorbed thru the
skin.

This simulation shows that the maximum body burden attained

4-25

�Figure 4-5.

Simulated body burden of 2,4-D in humans after a single
dermal exposure and after repeated (daily) dermal exposures. The body burden is expressed in units of the dose
level applied to the skin (D0) (Lavy, 1980).

�2.8
2.4
2

Body
-°
Burden
of2,4,5-T
^

PO

en

(Do)

Continuously exposed
— Washed off after 6 hours

�would be approximately 0.7 times the daily dose.

In other words, if a

dose of 0.050 mg 2,4-D per kg were absorbed through the skin each day
the maximum concentration attained in the body after repeated daily
exposures would be only 0.035 mg/kg.

This bioaccumulation factor is

less than might be expected (as calculated based on 1 dose per day)
because the absorption rate constant in the pharmacokinetic model is
less than the elimination rate constant (i.e., a flip-flop model).
Although the primary emphasis of this monograph is devoted to
human exposure to phenoxy herbicides an additional point of concern
when 2,4,5-T, is discussed, is that of the trace contaminant
2,3,7,8-tetrachloro-2-dibenzo-dioxin (TCDD).
Relative toxicities of the phenoxy herbicides and TCDD
Considerable confusion exists in the minds of most people with
respect to the relative dangers of 2,4,5-T and the 2,3,7,8 isomer of
TCDO.

In a 2,4,5-T formulation it

is not possible for a person, ani-

mal, or plant to receive a lethal dose of TCDD before receiving a much
much larger and correspondingly lethal dose of 2,4,5-T.

The following

discussion provides an explanation why people who come into contact
with 2,4,5-T are not harmed by the more toxic TCDD.
Fisher (1977) reported that the average amount of TCDD in 2,4,5-T
is about 0.01 ppm. To compare the toxicities of the two compounds,
assume that the NOEL of 2,4,5-T for humans is 20 mg/kg and for TCDD is
0.001 mg/kg (Tschirley, 1979).

Dividing the 2,4,5-T NOEL by 0.001

(the TCDD NOEL) gives a value of 20,000.
20,000 times greater than that of 2,4,5-T.

The toxicity of TCDD is thus
Since 2,4,5-T is more con-

centrated than TCDD by a factor of 100 million, however, the effective

4-26

�toxicity can be calculated by d i v i d i n g 100 m i l l i o n by 20,000, which
shows that in a 2,4,5-T mixture containing 0.01 ppm of TCDD the
2,4,5-T toxicity is potentially 5,000 times greater than that of TCDD.
This same sequence of calculations w i l l be used for evaluating the
effective toxicity of 2,4,5-T and TCDD in Agent Orange assuming that
Agent Orange contained an average of 2 ppm (Young et al., 1978). For
Agent Orange containing 2 ppm TCDD the calculations would be as
follows:

the composition of Agent Orange is essentially a 50-50 mix-

ture of 2,4-D and 2,4,5-T (Young et al., 1978); the no-effect-level
for 2,4-D is 24 mg/kg ( H a l l , 1980) and the no-effect level for 2,4,5-T
is 20 mg/kg (EPA, 1978); since Agent Orange is a 50-50 mixture of
these compounds an average no-effect-level of 22 mg/kg will be used.
The herbicide: TCDD ratio would be 1,000,000: or 500,000:1; calcul a t i n g a new toxicity relationship based on the 22 mg/kg no-effectlevel for the herbicide and the 0.001 mg/kg level for TCDD reveals
that pure TCDD is 22,000 times as toxic as the herbicides in Agent
Orange.

Since, there is 500,000 times more herbicide present in Agent

Orange the relative toxicity of the mixture was:
Relative.
toxicity

1,000.000 concentration of herbicide in Agent Orange
2 ' concentration of TCDD in Agent Orange
22 mg/kg HerbicidelOEL
0.001 mg/kg TCDD NOEL

9? 7

"*'

Thus, because of the large preponderance of the herbicides in the m i x ture (99.9998% Herbicide and 0.0002% TCDD) the relative toxicity from
the herbicides would be 22.7 times greater than the effects from the
TCDD.
Values for NOEL'S are based on chronic (long-term) feeding trials;

4-27

�some personnel in Vietnam may have had only occasional exposure to low
levels of Agent Orange while others may have been exposed for longer
periods to higher concentrations.

Regardless of the source or dura-

tion of exposure, pharmacokinetic studies have shown that the phenoxy
compounds are rapidly excreted from the body, and do not build-up to
harmful levels. In rat studies TCDD has been shown to be primarily
excreted in the feces with 50% eliminated the first day (Piper et al.,
1973; Allen et al., 1976).
The following studies present information of vital importance to
our evaluation of two groups of people who have had some phenoxy exposure.
If the assumptions used in the above calculations are valid and if
Vietnam veterans have experienced health effects that can be attributed to their exposure to Agent Orange these data indicate that the
defoliants themselves were more to blame than TCDD.
Ranch Hand personnel
The group of U.S. military personnel directly involved with
transporting, mixing, and applying the herbicides used as defoliants
in South Vietnam was referred to as "Ranch Hands." This group of
Vietnam veterans probably received more exposure to Agent Orange than
any other group since they handled the concentrated materials.
Mechanics and pilots associated with spray missions may also have
received an absorbed dose of the herbicides. By studying the health
and mortality records of the Ranch Hands and workers in the U.S. who
have been, involved in the commercial application of the phenoxy herbicides for 10 years or more we have a large data base from which to

4-28

�draw valid comparisons.
A follow-up study on the death rate of ranch hands has been
conducted by the Air Force.

Of the 1170 individuals who participated

in the study (this represents 97% of the total number involved in the
spray operation in South Vietnam) no statistically significant difference in the peacetime death rate have found between this group and
the comparison group, which was made up of similarly aged American men
who served in the armed forces but not in South Vietnam. Both groups
/

appear to have experienced s i g n i f i c a n t l y less mortality than a similarly aged U.S. white male population ( A i r Force, 1982).
Domestic aerial applicators.

In 1979 the National Agricultural

Aviation Association conducted a study to evaluate the effects of
exposure on aerial pesticide applicators.

It was designed to deter-

mine if continuous or long-term exposure to pesticides had resulted in
increased incidences of miscarriage and s t i l l b i r t h in the applicators'
families.

The study was based on the assumptions that absolute safety

exists, i.e., lack of hazard cannot be determined w i t h regard to any
chemical in its interactions with Homo sapiens or lower species; there
is a dose/response relationship with regard to any chemical and its
adverse or beneficial effects since i n d i v i d u a l s or populations
receiving higher doses (exposures) w i l l show more effect than comparable i n d i v i d u a l s or populations w i t h lower doses or exposures; and
i n d i v i d u a l s or populations who apply pesticides are more exposed as a
result of their occupation than the general population.
F a m i l i e s of National Agricultural A v i a t i o n Association members and
a s i m i l a r p o p u l a t i o n of s i b l i n g s who had had no occupational exposure

4-29

�to pesticides were compared. Questionnaires were developed and
distributed to members all across the nation.
The results listed in Table 4-4 show that no significant differenTable 4-4. Comparisons among live births, miscarriages and
stillbirths between the two basic populations. (Modified from WAA,
1980.)

Non-Agricultural

Agricultural

Aviation

Aviation
Families

Families

(no.)
Live Births

(%)

(no.)

(*)

373

(92)

360

(88)

29

( 8)

47

(12)

Miscarriages &amp;
Stillbirths

ces in live births and miscarriages were found among the "exposed
families" and the unexposed families.
Information on birth defects as related to parents occupation
is quite rare. The occurrence of birth defects has neither
substantially decreased or increased since pesticides were
introduced suggesting that few if any widespread and powerful
new teratogens were introduced (WAA, 1980).
In studies where hundreds of pesticide applicators have been compound to non-pesticide users no evidence has been found which would
indicate that the use of phenoxy herbicides has harmed man. Using
present day methods of statistical evaluation there is no evidence of

4-30

�CHAPTER 4
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Administration Advisory Committee on Health-Related Effects of
Herbicides. Washington, November 30, 1982.
Allen, J. R. et al. 1975. Tissue distribution, excretion and biological effect of MC tetrachlorodibenzo-£-dioxin in rats. Food Cosmet.
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Durham, W. F., H. R. Wolfe, and J. W. Elliott. 1972. Absorption and
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1962.

Bull. WHO. 26:75-91.

EPA. 1978. Rebuttable presumption against registration and continued
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,
Fisher, J. R. 1977. Letter-p-G12 In Final E1S Vol. 1. Vegetation
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�Gehring, P. J., C. 0. Kramer, V. A. Schwetz, J. Q. Rose, and V. K.
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Hall, J. F. 1980. In: T. L. Lavy Project Completion Report to
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Hosier, J., C. Tschanz, C. E. Hignite, and D. L. Azarnoff. 1980.
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epicutaneous exposure anesthetized guinea pigs. Toxicol. Appl.
Pharmacol. 63:181-87.
Lavy, T. L., S. J. Shepard, and J. D. Mattice. 1980. Exposure
measurements to applicators spraying (2,4,5-trichlorophenoxy)acetic
acid. J. Agric. Food Chem. 28:626-30.
Lavy, T. L., J. D. Walstad, R. R. Flynn, and J. D. Mattice. 1982.
(2,4-dichlorophenoxy)acetic acid exposure received by aerial application crews during forest spray operations. J. Agric. Food Chem.
30:375-81.
~
Lavy, T. L. 1978. Project completion report to National Forest
Products Assn. Measurement of 2,4,5-T Exposure of Forest Workers.
Washington.
Lavy, T. L. 1980. Project completion report to National Forest
Products Assn. Determination of 2,4-D Exposure Received by Forestry
Applicators. Washington.
Lavy, T. L., 0. S. Shepard, and D. C. Bouchard. 1980b. Field worker
exposure and helicopter spray pattern of 2,4,5-T. Bull. Environ.
Contam. Toxicol. 24:90-96.
Leng, M. L. 1972. Residues in milk and meat and safety to livestock
from a use of phenoxy herbicides in pasture and rangeland. Down to
Earth 28:12-20.
Leng, M. L. 1977. Comparative metabolism of phenoxy herbicides in
animals in fate of pesticides in large animals. In: 6. W. Ivy and H.
W. Dorough (eds.), New York, Academic Press. Pp. 53-76.
Maibach, H. I., R. J. Feldmann, T. H. Mil by, and W. F. Serat. 1971.
Arch. Environ. Health 23:208-11.
Nash, R. G. 1983. Agricultural applicators' exposure to pesticides.
American Industrial Hygiene Conference Proceedings 1982, Cincinnati.
Pp. 23.

4-33

�Piper, W. N., et al. 1973. In: E. H. Blair (ed.), Chlorodioxins—
Origins and Fate Ados. Chem. Ser. 120:85-91. Excretion and tissue
distribution of 2,3,7,8-tetrachlorodibenzo-jD-dioxin in the rat.
Piper, W. N., J. Q. Rose, M. L. Leng, and P. J. Gehring. 1973. The
fate of 2,4,5-trichlorophenoxyacetic acid (2,4,5-T) following oral
administration to rats and dogs. Toxicol. Appl. Pharmacol.
26:339-51.
Ramsey, J. C., T. L. Lavy, and W. H. Braun. 1978. Exposure of forest
workers to 2,4,5-T: Calculated Dose Levels in Lavy 1978 Project
completion report to National Forest Products Assn. Washington.
Ramsey, J. C., F. A. Smith, T. L. Lavy, C. N. Park, and W. H. Braun.
1980. Dose levels of 2,4-D in forest workers. In: T. L. Lavy. 1980
Project Completion Report to National Forest Products Association.
Washington.
Sauerholf, M. W., W. H, Braun, G. E. Blau, and P. J. Gehring. 1976.
The dose-dependent pharmacokinetic profile of 2,4,5-trichlorophenoxy
acetic acid following intravenous administration in rats. Toxicol.
Appl. Pharmacol. 36:491-501.
Sauerhoff, M. U., et al. 1977. The fate of 2,4-dichlorophenoxyacetic
acid (2,4-D) following oral administration toman. Toxicology 8:3-11.
Smith, F.A., B.A. Schwetz, and K.D. Nitschke. 1976.
of 2,3,7,8-tetrachlorodibenzo-p-dioxin in CF-1 mice.
Pharmacol. 38:517-523.

Teratogenicity
Toxicol. Appl.

Tschirley, F. H. (ed.). 1979. Scientific dispute resolution conference on 2,4,5-T. Sponsored by the American Farm Bureau
Federation, Richmond, Nu Vue Printing Company. Pp. 101.
Vaccaro, J. 1983. The toxicity of silviculture herbicides in herbicide safety workshop, Southern Forest Products Assn. New Orleans,
Louisiana.
Virginia pest management guide 1, 1980. Chemical control of insects,
plant diseases and weeds. Virginia Polytechnic Institute and State
University. Pp. 317.
Weed Science Society of America.
Weed Science Society of America.

1979. Herbicide Handbook, 4th. ed.,
Champaign. Pp. 479.

World of Agricultural Aviation (WAA). 1980. Investigation of the
possible effects of pesticide exposures on reproductive mortality and
morbidity. 7:12-30.
Young, A. L., J. A. Calcagni, C. K. Thalken, J. W. Trembloy. 1978.
The Toxicology, Environmental Fate, and Human Risk of_ Herbicide Orange
and Its Associated Dioxin. USAF OEHL Technical Report 78-92.
Aerospace Medical Division (AFSC) Brooks Air Force Base, Texas. Pp.
247.
4-34

�Young, J. D., J. C. Ramsey, and W. H. Braun. 1981. Pharmacokinetics
of 2,4,5-T P6BE ester applied dermally to rats. Journal of Toxicology
in Environ. Health 8:401-08.

4-35

�CHAPTER 5

Assessment of Harm Due To Phenoxy Herbicide Exposure
What research information is needed?
The complex nature of the issues surrounding phenoxy herbicides
and the TCDO contaminants in 2,4,5-T requires that the concerned
interested citizen use common sense as he tries to sort out the facts
and keep an open mind to new ideas and new research information.
Seemingly, a countless number of studies and volumes of writings
have already been devoted to learning about the phenoxy herbicides and
their effects on man. Should more be done? As long as pertinent
questions remain, scientists have an obligation to attempt to answer
them. However, it is prudent to conduct only the studies for which
there has been no clear cut answer and those that would appear to have
attainable answers. Some areas where additional research would be
beneficial include:
a) Determination of the bioavailability of TCDD from soil. Use
of different solvent systems and other factors which could potentially
enhance bioavai1 ability or degradation of TCDD should be fully
investigated. Work conducted to date indicates that the low water
solubility of the compound makes it nearly inert in a soil environment. The Center for Disease Control (CDC) has indicated that 1 ppb
TCDD in soil represents a threshold value for man's safety.
Definitive new studies should be conducted which clearly demonstrate
this threshold value. These new data could strengthen the CDC position.
The TCDD bioavailability issue is important due to the toxicity of
the compound, the widespread dispersal of TCDD tainted oil in
5-1

�Missouri, and the fact that several sources of TCDD in the environment
have been documented.

These sources include: fly ash from municipal

incinerators (01ie, 1977); home fireplace soot, commercial sludge fertilizer and diesel truck mufflers (Bumb et al., 1980).
b) Origin and fate of dioxins in the environment. It has been
shown that production of herbicides and other commercial chlorinated
phenoxy compounds is not the only source of TCDD. If major sources
of these toxic compounds exist in our environment we need to become
more aware of them and take the proper precautions.
c) Assessing the bioaccumulation of TCDD in animals living in the
areas of known TCDD contamination. Experiments could be patterned
after those of Newton and Snyder (1978) who sacrificed a few test animals which have had most opportunity for TCDD exposure.

By analyzing

livers of animals living in the Times Beach area it should be possible
to determine if a TCDD build-up is occurring. Animals living in or
near this TCDD contaminated area should accumulate higher levels than
humans.
d) A systematic collection and analytical scheme should be initiated which would allow the procurring of fat samples from human
cadavors, some known to have had high exposure to phenoxy herbicides
and others with no known exposure.

Comparison of the extent of build-

up of TCDD in human adipose tissue, if any, could then be made.

These

studies would be similar to, but much more extensive than those
reported by Kutz (1981).
e) Improved methods for accurately determining rates of degradation of toxic compounds in our environment. Errors in evaluating

5-2

�or calculating disappearance rates of chemicals highly toxic to man
could result in decisions harmful to his health.
f) Determining source of the toxic components of a pesticide.
In the case of mammalian toxicity to pesticides, the effects of
the active ingredient should be separated from those of the carrier or
other additives. Some organic solvents may possess more toxic qualities than the "active" compound.

It is important to be able to iden-

tify the source of any toxic effect observed.
g) Soft tissue sarcoma. Reports by Hardell (1981), but unsupported by several researchers, attempt to link phenoxy exposure and
soft tissue sarcomas in humans. This possibility should be fully evaluated before the issue is put to rest. If a valid correlation exists
this issue should be widely publicized and steps taken to remedy the
situation,
h) Continuing in-depth assessment of the health characteristics of
personnel in the Ranch Hand operation and commercial pesticide applicators. Evaluation of health records of these exposed groups offer
valuable opportunities to assemble meaningful health hazard information due to the large numbers of personnel involved and the fact
that this was the most highly exposed group in Vietnam.
i) Adequate testing of compounds being developed to replace the
herbicide 2,4,5-T. An extensive amount of time and effort had been
devoted to researching nearly all aspects of 2,4,5-T; it is possible
that more environmentally troublesome compounds which have been
studied far less extensively may be being used as a substitute for the
readily decomposable, much-studied 2,4,5-T molecule.

5-3

�What does the majority of scientific information tell us about man's
potential for harm from being exposed to phenoxy herbicides?
A large preponderance of the scientific publications concerning
the possible effects of the phenoxy herbicides and the low levels of
TCDD present show that these compounds do not pose a threat to man's
health.

Following are a few examples of research, in addition to the

author's studies on human exposure to phenoxy herbicides in the field
which supports the safety of the phenoxy compounds.
USDA R.C. Nash Study
In a study by R.C. Nash of the United States Department of
Agriculture, it was calculated that if a 175 Ib farmer applied 2,4-D
30 days a year for 30 years he would receive and excrete less than one
gram (about the weight of one-half of a dime).

To put this into

perspective this is several hundred times less than the acceptable
daily intake (ADI) for a person over that time period (Nash, 1983).
(The ADI is the amount of a chemical, based on all the known facts,
which can be consumed every day for an individual's entire lifetime
with no harm occurring.

These values are expressed on a mg chemical

per kilogram body weight basis.

The ADI is based on the no effect

level in the most sensitive animal species or, if the data are
available, in man.)
Oregon researchers (Newton et a!., 1975)
The registered uses of 2,4,5-T in the forest were effective and
did not present a significant threat to the quality of the environment.

Data from experimental animals indicate that immediately after

spraying 2,4,5-T at an accepted treatment rate, a 100 Ib human could
absorb all the TCDD on 1 acre of forest and suffer no toxic effect.
5-4

�TCDD is so tightly bound by vegetation and soil that the probability
of significant intake by humans is remote. It is calculated that a 1
Ib/acre application of 2,4,5-T containing 0.1 ppm TCDD applied
directly to the soil could result in a maximum of 0.1 parts per
trillion TCDD in soil. TCDD does not appear in the seeds of plants
grown in soil containing even large amounts of TCDD. Isensee et al.
(1971), after applying TCDD to a Lakeland sandy loam and growing oats
(Avena sativa) and soybeans (Glycine max), concluded that soil uptake
of TCDD by plants is highly unlikely.
J.M. Witt American Chemical Society Symposium, Seattle 1983
To evaluate man's risks from another approach, a comparison of the
health effects of 2,4-D has been made with aspirin.
A man swallowing 2 tablets of aspirin every 4 hours has a safety
factor of 25; i.e. if he consumed 50 tablets in that time period,
death is expected.

By comparison, Witt indicates an individual who

was directly under a spray boom applying 2 Ib of 2,4-D per acre has a
safety factor of 625. He would need to be sprayed 625 times on the
same day before he could receive sufficient 2,4-D to cause death.
Data on birth defects for these compounds show a similar pattern.
Following is a calculation for the risk of birth defects to the
offspring of pregnant female sprayed with 2,4-D as prepared by Witt
(1984).
1) A female standing directly under a spray plane applying 2 Ib
2,4-D per acre would receive an exposure level of 20 mg 2,4-D per
square foot of body area.
2) 5% of the exposure would be absorbed through her skin.
3) the half-life of 2,4-D: on plants, litter or soil 2 weeks to 2
5-5

�months; in water - 1 week; in mammals 1 day.
4)

pregnant females have approximately a 20 sq ft.

skin surface.

The 2,4-D risk of birth defects for a pregnant female who was
sprayed with a spray-mix of 2 Ib/acre (=20 mg/ft 2 ); 50% of her skin
would be exposed (10 ft 2 ); weight 110 Ibs (=50 kg).
Calculations:
20 mg/ft 2 x 10 ft 2
(exposure level) (50% of skin area exposed)
50 kg (body weight)
200 mg = 4 mg/kg on bare skin areas x 0.05 percent absorbed
50 kg
= 0 . 2 mg/kg absorbed dose
20 mg/kg/dayl = No effect 1e,ve1 = 100 = margin of safety
0.2 mg/kg
= absorbed dose
These data indicate the pregnant female could be sprayed 100 times
daily before she would receive an absorbed dose of 2,4-D which is
equivalent to the amount of the "no effect level" for birth defects.
It is highly unlikely that anyone would be sprayed 100 times in one
day.

United Kingdoms;

Review of the safety of the herbicide 2.4.5-T

Following are conclusions from a comprehensive evaluation of the
phenoxy-TCDD question by a major research team in the United Kingdom:
(Kilpatrick et al., 1980)
Given the acute toxic effects of TCDD any significant exposure to this chemical would have been reflected in the health
of operators. Against this background of data on exposure to
2,4,5-T and bearing in mind the low levels of TCDD present in
l$ince Witt (personal communication) believes the no effect level for
2,4-D is between 20 and 25 mg/kg/day he has chosen to use the more
conservative value for these calculations.

5-6

�is

M three surveys

„„
,B

,Molved 1100&gt; a,

1970,

1975 Md "76,

^

revealecj any

disorders.
ted

,in9dom for «.r

§i

to t,

^

.

use of 2.4.5-.

wy TCDO

eo.

of 2&gt;4&gt;5 . T

1983)

iysle«1 c

o TO

n

1980;

TS , sen,nwe ^cator of

° ; ::1- ^ ""

reactions to

reactions are rare,

TCOO

exposure has

1

- - - ,»» -- -• - - *
5-7

�Relative risks of spraying 2.4,5-T
An oncogenicity (tumor causing) study reported by Kociba in 1978
showed that TCDO caused cancer in rats.

Assuming the effective rate

of 0.1 ug/kg body weight per day is comparable to that of humans, it
is possible to calculate a risk factor for workers applying 2,4,5-T
containing (assuming worst case) 0.1 ppm TCDD.
Leng (1978) discussed the "one hit"

model which assumes that pro-

bability of tumor production is random and proportional to the total
chemical contact.
Under worst-case conditions for a female applicator weighing
60 kg applying 2,4,5-T containing 0.1 ppm TCDD, 5 days per
week, 4 months per year, for 30 years, the average lifetime
dose of TCDD would be one millionth of a microgram per
kilogram of body weight per day (1 x 10~&amp; ug/kg/day). Based
on a 99% upper confidence limit for the incidence of tumors
in female rats given 0.1 ug/kg/day for 2 years in the Kociba
study, and adjustment for differences in body surface area
(more conservative than relative body weights), and in
lifespan (70 vs 2 years) for humans compared to rats, she
would have a calculated potential risk of 3.05 x 10"5.
Male applicators exposed in the same way would have a risk only
half as large since male rats in Kociba's study had a lower incidence
of tumors.

Table 5-1 indicates that cancer risk to a male smoker is

6000 times greater than to a backpack sprayer applying 2,4,5-T. The
relative risk of a worker developing tumors from exposure to the TCDD
in 2,4,5-T is far less than for people who drink water in Miami or New
Orleans, or even fly cross-country once a year.

5-8

�Table 5-1.

Relative Annual Risk of Cancer Per Million People from

Exposure to Various Causative Agents (Adapted from Wilson, I960 and
Leng, 1978).
R i s k x 106
per year
TCDD from Application of 2,4,5-T
Female backpack sprayer

•

Male backpack sprayer

0.4
0.2

Eating and Drinking
One diet soda per day (saccharin)

10

Average U.S. consumption of saccharin

2

Peanut butter, 4 tablespoons per day (aflatoxin)

40

Milk, 1 pint per day or cheese equiv. (aflatoxin)

10

Drinking water in Miami or New Orleans

1.2

Steak, 1/2 Ib charcoal-broiled, 1 per week

0.4

Alcohol, light drinker (1 beer per day)

20

Alcohol in smokers vs. non-smoker

50

Tobacco
Smoker

1200

Being in room with a smoker

10

Concluding remarks
The two largest data bases available for evaluating man's exposure to the phenoxy compounds are 1) the health records of hundreds of
pesticide applicators, and 2) the health records of the Ranch Hand

5-9

�personnel who were active in the transport, mixing and application of
Agent Orange in Vietnam. By continuing to monitor the health of these
groups we are studying those individuals who have received the highest
dose of phenoxy herbicides. If adverse health effects are caused by
exposure to these chemicals the evidence should become apparent when
the health records of these groups are compared to those of a nonexposed population.
The amount of phenoxy herbicide present in man's air, food and
water has been shown to be very low. Field workers who mix and apply
these compounds receive a higher absorbed dose than others in our
society with the possible exception of workers in phenoxy manufacturing plants. Some workers at these plants using chlorinated phenoxy
compounds where explosions have occurred have received higher doses.
Although the dose of herbicides received by those transporting,
mixing, or applying these chemicals have not appeared to reach health
threatening levels, those interested in reducing their exposure levels
may easily do so by following simple suggestions listed in Chapter 3.
It is recognized that some who have served in Vietnam have later suffered health problems. While probing literature in preparation for
this monograph no scientific evidence has been found which would link
those health problems to phenoxy or TCDD exposure. To answer
questions on health related problems other avenues should be pursued.
The ultimate answers to these problems are probably more complex than
attributing them to phenoxy herbicide exposure.
After reviewing hundreds of research articles on the pros and cons
of 2,4,5-T, scientific evidence strongly supports the safety of this

5-10

�compound to man and the environment. Findings from agriculture show
that in over 30 years of use no known health problems have been found
when this herbicide is used according to label instructions.

5-11

�Bibliography
Bradley, E. 1983. Landmark court decision rules in favor of 2,4-D
and 2,4,5-T herbicides. In: News Release, National Coalition for a
Reasonable 2,4-D Policy.
Bumb, R.R., W.B. Crummett, S.S. Cutie, J.R. Gledhill, R.H. Hummel,
R.O. Kagel, L.L. Lamparski, E.V. Luoma, D.L. Miller, T.J. Nestrick,
L.A. Shadoff, R.H. Stehl, and J.S. Woods. 1980. Trace Chemistries of
Fire: A source of Chlorinated Dioxins. Science 210:385-390.
Hardell, L. 1981. Relation of soft-tissue sarcoma, malignant
lymphoma and colon cancer to phenoxy acids, chlorophenols and other
agents. Scand. J. Work Environ. Health 7:119-130.
Holmstedt, B.
Seveso.

1980. Arch. Toxicol. 44:211-230.

Prolegomena to

Homberger, E., et al. 1979. Ann. occup. Hyg. 22:327-370.
accident; its nature, extent and consequences.

The Seveso

Kilpatrick, R. 1980. Further review of the safety for use in the
U.K. of the herbicide 2,4,5-T. Advisory Committee on Pesticides.
London.
Kociba, R.J., D.G. Keyes, J.E. Beyer, R.M. Carreon, C.E. Wade, D.A.
Kittenber, R.P. Kalnins, L.E. Frauson, C.N. Park, S.D. Barnard, R.A.
Hummel, and C.G. Humiston. 1978. Results of a two-year chronic toxicity and oncogenicity study of 2,3,7,8-tetrachlorodibenzo-p-dioxin in
rats. Toxicol. Appl. Pharmacol. 46:279.
Kutz, F.W. 1981. Chemical exposure monitoring in the EPA office of
pesticides and toxic substances. Presented at the Veterans
Administration Advisory Committee on Health Effects of Herbicides.
Nov. 19, 1981.
Leng, M.L. 1978. 2,4,5-T/TCDD controversy-Current status.
North Central Weed Control Conference 33:164-168.

Proc.

Nash, R.C. 1983. Background Information: from G.W. Bostrom, E.G.
National Coalition for a Reasonable 2,4-D Policy.
Newton, M. and S.P. Snyder. 1978. Exposure of Forest Herbivores to
2,3,7,8-Tetrachlorodibenzo-p-dioxin (TCDD) in Areas Sprayed with
2,4,5-T. Bull. Environ. Contam. Toxicology 20:743-750.
Newton, M. and A. Norris. 1975. A discussion on herbicides.
Statement on 2,4,5-T and TCDD. Reproduced from Journal of Forestry
73:410-412.
Olie, K.P.L.

1977. Vermeulen 0. Hutzinger, Chemosphere.

5-12

6:455.

�APPENDIX

Significance of TCDD in Man's Exposure to Phenoxy Herbicides
Due to the interest in this subject area and widespread national
attention focused on it,

many questions arise.

Although some items

may be somewhat redundant with earlier discussions, they are presented
here for convenience.
Following is an index of questions addressed in this appendix:
Page A-4

What is dioxin?

Page A-4

Is there more than one dioxin?

Page A-5

Why does TCDD exist?

Page A-6

How do we learn about TCDD?

Page A-6

What is being done to learn the significance of man's

exposure to TCDD?
Page A-7

Is TCDD harmful to humans?

Page A-ll Were phenoxy herbicides involved at Times Beach?
Page A-ll Are people being harmed by the TCDD present at Times Beach?
Page A-12 Since the discovery that soils removed from the horse arena
and deposited in other Missouri communities still contain
detectable TCDD levels, what is being done?
Page A-12 What can be done to clean-up or remedy the current TCDD
containing areas?
Page A-13 HOW do humarrscome into contact with TCDD and other dioxins?
Page A-17 Do phenoxy herbicides contain TCDD?
Page A-17 Is the TCDD present in 2,4,5-T harmful to animals eating
vegetation sprayed with the herbicide?
Page A-18 What is Agent Orange?

A-l

�Page A-20 Why were defoliants used in Vietnam?
Page A-20 Were defoliants other than Agent Orange used in Vietnam?
Page A-21 Were other pesticides used in Vietnam?
Page A-22 Is Agent Orange as toxic as TCDD?
Page A-22 How long does TCDD persist in the environment?
Page A-24 Do green plants take up TCDD from the soil?
Page A-24 Does TCDD magnify in the food chain?
Page A-26

Is TCDD in the environment harmful to animals?

Page A-27

What are the short- and long-term effects of TCDD?

Page A-30 If TCDD entered a human would it accumulate?
Page A-31 Why is the Seveso, Italy accident important to the TCDD
exposure questions?
Page A-33 Since it has been shown that TCDD is widely distributed in
the environment, does that mean that it is present in the
food we eat?
Page A-34 Can man be harmed from ingesting 2,4-D or 2,4,5-T?
Page A-35 How toxic is 2,4-D to workers applying this herbicide
in the forest?
Page A-36 Should a concerned pesticide applicator individual quit
worrying about exposure to pesticides since the scientific
facts indicate no imminent danger is present?
Page A-37 If ones chances of being harmed by phenoxy herbicides and
TCDD are so low, why do we keep hearing about the danger on
TV and reading about it in the newspapers?
Page A-40 Other than in production plants what groups of humans are
exposed to the highest amounts of pesticides?

A-2

�Page A-40 Do phenoxy herbicides cause soft tissue sarcomas in man?
Page A-41 Were there dangerous components of Agent Orange besides
TCDD?
Page A-41 What happens if 2,4,5-T, which contains a trace level of
TCDD, comes into contact with a human?
Page A-43 Were U.S. ground troops in Vietnam "at risk from Agent
Orange since they could not shower daily?
Page A-44 Could Agent Orange harm soldiers exposed to it?
Page A-46 How could one know if he had been exposed to significant
levels of Agent Orange?
Page A-47 Chloracne has been described as the primary symptom for
men exposed to chlorinated organic compounds, are there
other symptoms that would accompany these symptoms?
Page A-47 What has happened to the health of those in Vietnam who
mixed and applied Agent Orange?

Page A-47 Could Agent Orange affect the fertility of males?
Page A-48 Can birth defects be caused by pregnant women being
exposed to the phenoxy herbicides and TCDD?
Page A-53 Does human mothers milk contain TCDD?
Page A-63 How do the teratogenic effects of TCDD and 2,4,5-T compare?
Page A-54 Were U.S. military personnel who used Agent Orange well
informed about its properties at the time of its use in
Vietnam?
Page A-55 What evidence do we have which indicates that use of defoliants in South Vietnam has not caused man health
problems?

A-3

�Page A-55 Why do the Veteran's Administration and other government
agencies continue to study Vietnam veteran health problems
if the government is not admitting that Agent Orange
exposure has caused the problems?
What is dioxin? Dioxin is a general term which describes an organic
molecule essentially composed of two benzene rings joined by a double
oxygen bond.

When a chlorine atom is attached to any or all numbered

positions of it,
-2-dioxin.
tions.

the molecule is referred to as a chlorinated dibenzo

Chlorine atoms may be attached in the 2, 3, 7, and 8 posi-

The molecule shown in Figure 1.1 is commonly referred to as

dioxin or TCDO.
Is there more than one dioxin? As many as 75 different dioxin
molecules can be formed by substituting different chloride atoms at
the numbered positions given (Kociba et al., 1982).

Types of chlori-

nated dibenzo-p-dioxins that can be found in the environment include:
tetra, hexa, hepta, and octa.

Several of these chlorinated dibenzo-p-

dioxins are biologically active.

The most active one known is the

2,3,7,8 tetra chloro dibenzo-£-dioxin.

It is the most toxic of the 22

tetrachlorinated dioxins; this toxic molecule will be referred to
herein as TCDD.

Table A-l lists some of the properties of TCDD.

A-4

�Table A-l.

Some TCDD Physical Properties (Bovey and Young, 1980).

Molecular weight

322

Melting point, °C

303-305

Decomposition point, °C

980-1000

Solubility in

ppm

Orange herbicide

580

benzene

570

chloroform

370

acetone

110

methanol

10

water

0.0002

TCDD is quite soluble in fats and very insoluble in water.

In the

direct presence of sunlight and a hydrogen donor it is degraded
readily on leaves, water or soil surfaces.

It has a low vapor

pressure (1 x 10~7 Ton) and tends not to vaporize in the atmosphere
thus its vapors can not be carried away by the wind.

It is strongly

bound to soil, consequently is very resistant to leaching and to
entering the groundwater (Reggiani, 1981).
Why does TCDD exist?

TCDD is formed as a low-level unwanted by-

product during the manufacture of trichlorophenol from
1,2,4,5-tetrachloro-benzene (Sparschu et al., 1971).

The production

of trichlorophenol is the initial step in producing hexachlorophene
and trichlorophenol, common antibacterial agents that have been incor-

A-5

�porated into a number of soaps and cosmetics (Rawls et al., 1976).
Trichlorophenol is also used in the production of 2,4,5-T.
How do we learn about TCDD? Information on the effects of TCDO exposure comes from at least three different sources. Industrial accidents have resulted in severe human exposure.

Use of synthetic

compounds containing TCDD, particularly the herbicide 2,4,5-T has initiated studies on humans and animals exposure exposed to the compound
(Rose et al., 1972). Furthermore, several laboratory investigations
have been completed during the past 10 years in an attempt to determine the toxic effects of TCDD (Zabik and Zabik, 1980).
What is being done to learn the significance of man's exposure to
TCDD? Dr. Frederick Kutz from the Field Studies Branch of the
Exposure Evaluation Division of the Office of Toxic Substances in the
U.S. Environmental Protection Agency offers some information on the
philosophy and scope of their programs:
The major orientation of the monitoring programs in the
Office of Pesticides and Toxic Substances is toward the
assessment of human exposure. Therefore, biological monitoring of human tissues and fluids assumes primary importance. Environmental components, such as air, drinking
water, food, etc., which are intimately associated with human
life, are considered secondarily. This prioritization scheme
focuses monitoring programs on the protection of public
health. Current ambient chemical monitoring responsibilities
within OPTS include monitoring soils, raw agricultural crops,
estuarine and marine organisms, water, human tissue, and air.
Many of the programs have operated in cooperation with other
Federal agencies, i.e., the National Center for Health .
Statistics, the U.S. Geological Survey, and the National
Oceanic and Atmospheric Administration. These agencies
collect selected specimens for chemical residue analysis by
EPA-directed laboratories. Samples of the above human and
environmental media are collected on a periodic basis from
locations defined by statistically representative designs
(Kutz, 1981).
In addition to the EPA, scientists in several other governmental
agencies including FDA, USDA, and CDC and others are studying TCDD.
A-6

�Related research is also being conducted by universities and chemical
companies. An in-depth discussion of an applicator exposure study to
2,4,5-T containing trace levels of TCDD was presented in Chapter 3.
Is TCDD harmful to humans? It is a widely accepted fact that TCDD is one
of the most toxic low molecular weight synthetic molecules known to
man. As a result of its toxicity and occassional presence in the
environment TCDD has emerged as a compound for which there is great
public concern.
Since humans and test animals do not always have the same
tolerance or sensitivity to a chemical it is difficult to establish a
sound basis for exact comparisons. The question is: What is the
relative toxicity of TCDD to humans and other mammals? In view of the
extreme toxicity of TCDD this question becomes quite alarming when one
reviews the facts on thalidomide. The lowest dose of thalidomide to
produce teratogenic effects in mammals are: 30, 50, 100, and 350
mg/kg/day for mouse, rat, dog and hamster respectively. For humans
this value is 0.5 mg/kg/day.

Thus, humans are 60 to 700 times more

sensitive to thalidomide than were the animals used to test.it. This
relationship is not necessarily true of all compounds, however. In
fact, it appears that humans are less sensitive to TCDD than several
other animal species. For TCDD a wide range in mammal toxicity exists
as expressed as an acute and 1059 (Table A-2).

A-7

�Table A-2.

Acute oral LDso of TCDD.

Single-dose
1050

Literature
citation

(Micrograms per kilogram body weight)
Guinea pig
Rabbit

0.6-2.0

Schwetz et al., 1973

115

Schwetz et al., 1973

Rat

22-45

Greig et al., 1973

Dog

100-200

Greig et al., 1973

25-50

Greig et al., 1973

Chicken
Bullfrog
Hamster

over 1000
1157-5051

Beatty et al., 1976
Olson et al., 1980;
Henck et al., 1981

Since humans are not routinely used to test compounds as toxic
as TCDD there is little information available other than information
which arises after an accident or some other "happening." Literature
describes in the early 1970's a "happening" known as the Missouri
Horse Arena Incident; today it has been extended and now includes
Times Beach, Missouri. Following the spraying in 1971 of three horse
arenas in Lincoln County, Missouri, with salvage oil contaminated with
TCDD, a by-product of hexachlorophene production, a number of people
who worked or played in the arenas developed medical disorders (Beale
et al., 1977; Kimbrough et al., 1977; Lobes et al., 1972; Young et
al., 1978). For a more detailed accounting of this "happening" see

A-8

�Chapter 1.

The most serious health effects were shown by a six-year-

old girl who developed hemorrhagic cystitis and focal pyelonephritis.
The urinary tract symptoms were preceded by headache, epistaxis,
diarrhea and a general malaise.
after a few days.

Her urinary tract symptoms cleared

An examination three months later revealed she was

normal except for punctate hemorrhages of the bladder seen on
cystoscopy.

The father of the child had developed headaches and

nausea while working in the arena.

Her mother reported severe

headache, nausea, diarrhea and abdominal pains, and arthralgia. A
ten-year-old sister developed easy fatigability, epistaxis, headaches,
abdominal pain, and diarrhea.
lesions (Reggiani, 1978).

All developed at least mild acne

Follow-up studies on the mother and two

children performed five years later were normal (Beale et al., 1977).
The symptoms for all of the humans were relatively mild with the most
severe being the hemorrhagic cystitis and focal pyelonephritis seen in
the six-year-old girl.
several years later.

The symptoms had cleared on re-examination
Exposure, at least to the children must have

been significant in that they regularly played in the soil of the arenas.

These symptoms can be contrasted with fatalities observed for

horses and other animals.

In total 62 horses, hundreds of birds, many

cats, and a few dogs died (Carter et al., 1975).
Thus, the answer to our original question "Are dioxins toxic to
humans?"

is yes; but in contrast to thalidomide, humans appear to be

much less sensitive to TCOD than are many test animals.

This fact

does not detract from the extreme toxicity of the TCDO molecule but
does suggest that well designed experiments using sensitive test ani-

A-9

�mals can perhaps provide meaningful information for humans.
Center for Disease Control (CDC) has indicated that soils containing 1 ppb could theoretically cause health problems. Since the
Center for Disease Control was forced to make a quick decision before
all of the scientific data could be thoroughly evaluated it is
possible that they have set limits on TCDD concentrations that are too
conservative. Soil particles strongly bind TCDD. This reduces the
uptake of this compound by the body of test animals according to
experiments conducted by Poiger and Schlatter (1980). They also
showed that the longer TCDD remains in contact with soil the less
available it becomes for uptake.

Since humans ingest little TCDD,

they have little direct external body exposure to it. Cast (1983)
states that implications by Burke (1983) that "dioxin, described by a
respected health research as a "doomsday chemical" that can be harmful
to humans in microscopic amounts as low as one part per billion" can
be equated to the effect of one part of dioxin per billion of soil is
without substance.
As mentioned several times earlier, it is easy to confuse
"exposure" and "absorbed dose." Chemical tests for amounts of TCDD in
soil provides a measure of potential exposure but does little to provide a meaningful answer to how much does man absorb. As suggested by
CAST, 1983 examination of the liver of wild animals inhabiting the
high exposure areas can provide much information from which man can
better evaluate the level of risk present.
Agencies faced with njany human health decisions have difficult
decisions to make.

If they are to error, they should error on the

A-10

�side of safety.

As responsible servants they are also expected to

make decisions based on all of the best scientific information
available.

Due to the worldwide impact these decisions may have these

agencies should be permitted the luxury of continually reweighing the
facts and the opportunity to alter their recommendations - be they for
more stringency or less stringency.
Were phenoxy herbicides involved at Times Beach?

No, the TCDD by-

product occurred during the synthesis of hexachlorophene a bactericidal agent.
Are people being harmed by the TCDD present at Times Beach?

The TCDD

being found at Times Beach is present in soil which was contaminated
with oil containing TCDD more than 10 years ago.

The low water solu-

bility (0.2 ppb) and adsorbing properties of TCDD prevents detectable
levels from moving into man's food supply via growing plants.
a grease or oil

Without

solubilizer the TCDD present today has little oppor-

tunity to move through the skin of man or other animals.

Bovey and

Young (1980) have discussed that in highly TCDD contaminated soils the
burrowing animals, beach mice and hispid cotton rat,
TCDD level in their liver.
10 to 1500 ppt TCDD.

had the highest

Liver from healthy animals contained from

No current health problems attributable to TCDD

in the Times Beach area have been reported.

Only by carefully

extracting the TCDD with special organic solvents and then using the
best analytical gas chromatograph-mass spectrometry instrumentation is
it possible to identify TCDD.
The normal health patterns of humans who have lived in these contaminated areas for the past 12 years in conjunction with the low

A-ll

�bioavailability of TCDD strongly suggests that TCDD is not available
in the environment at levels harmful to plants, humans or other animals.
Since the discovery that soils removed from the horse arena and deposited in other Missouri communities still contain detectable TCDD
levels, what is being done? Following the Center for Disease Control's
announcement that TCDD of 1 ppb and above constitutes a danger to man,
EPA has indicated that dollars in its "Superfund" will be used to
purchase the areas and relocate the people involved.

As of May, 1983

residents of two areas of Times Beach and Imperial, MO had been cited
by EPA as communities qualifying for use of the Superfund for relocation purposes.
What can be done to clean-up or remedy the current TCDD containing
areas?

Five possible options are available as listed in Table A-3.

A-12

�Table A-3.

Possible waste stabilizing and permanent clean-up possibil-

ities for Imperial, Missouri (Garmon, 1983).

Option

Years

(est.)
Construction of a grout curtain (This involves

Millions

(est.)

3-4

$29

digging a ditch around the contaminated area and
filling it with a clay-like substance in order
to prevent migration of the toxic material.)
Removal of dirt and placement in an on-site vault

3-4

$9-11

Removal of dirt and placement in an off-site
landfill or storage facility

4
8

Incineration of dirt
Detoxification of dirt via application of

$5-8
$29+

11

$58-77

chemicals (Use of a sodium hydroxide and
polyethylene glycol mixture to dechlorinate remove the chlorine atoms from - the dioxin
now is being tested.

Estimates of time and

cost include that needed for further development of this technique.)

How do humans come into contact with TCDD and other dioxins?

In addi-

tion to trace levels in the phenoxy herbicide 2,4,5-T, Agent Orange
and by-products of trichlorophenol production other sources are present.
Dr. Kutz of the EPA reports some of their investigations:

A-13

�Because of the growing concern for the possibility of human
exposure to toxic substances as a result of combustion, a
study to provide statistically valid estimates of the level
of organic emissions from combustion sources was begun.
Among the main categories of concern are coal/refuse-derived
fuel combustion, refuse combustion, and residential wood combustion. The compounds of interest are included in a broad
category of substances termed "Polycyclic Organic Matter"
(POM). These include polychlorinated biphenyls (PCBs),
polychlorodibenzo dioxins (PCDDs), polychlorodibenzo furans
(PCDFs), phenols, pyrenes, other polynuclear aromatic hydrocarbons (PAHs), and other organic compounds. In order to
make a statistically valid estimate of national emissions, it
is important to have information on emissions variabil-ity
within any one facility. Therefore, a pilot study at two
facili-ties was conducted in order to describe emissions
variability. This variability was used to design the
national study. One of the facilities sampled in the pilot
burned 85% coal and 15% refuse-derived fuel (RDF), whereas
the other burned raw municipal refuse. These facilities were
sampled for 9 and 10 days, respectively, and samples of fuel,
ambient air; water, bottom ash, fly ash, and flue gas were
taken (Kutz, 1981).
Results of these gas chromatography-high resolution mass spectremetry analyses are presented in Table A-4.

A-14

Research by Reggiani

�Table A-4. Residues of dioxins and furans observed in flue gas of a
municipal waste combustion facility.! (Kutz, 1981).
Mean^

Mean^ quantities

concentrations

emitted

(ng/cubic m)

Isomer groups

(ug/hr)

Tri-CDD 3

13

1,100

CDF4

300

26,000

Tetra-CDD

6.3

540

2,3,7,8-TCDD

0.4

34

90

7,600

Hexa-CDD

16

1,400

-CDF

62

5,200

-CDF

Hepta-CDD

7.6

640

-CDF

7.5

640

Octa-CDD

2.5

220

0.6

52

-CDF

corrected for recoveries.
2

Mean of 3 data points.
refers to chlorodibenzo dioxins.
refers to chlorodibenzo furans.

(1981) indicates that various polychlorinated dioxins, sometimes
including TCDD, may be formed during various combustion processes,

A-15

�such as municipal incinerators, fossil-fueled power plants, internal
combustion engines, home fireplaces and cigarette smoke.
Knowledge that the toxic TCDO is introduced into man's environment
through several sources does not necessarily make this a safer world
in which to live but it does allow us to redirect the thinking of some
of our environmental concerns.

Since the presence and significance of

TCDD as a contaminant in herbicides at levels from 1 to 70 ppm was
found by Higginbotham (1968) the concentrations have been markedly
reduced.

Today's production methods routinely produce 2,4,5-T con-

taining less than 0.1 ppm which is the legal level.
Another source of exposure could be through the use of cosmetics
that have as one of their ingredients compounds derived from trichlorophenol (Rawls et al., 1976). Although no research has been reported
on the absorbed dose of TCDD arising from these uses one can infer
that due to the lipophyllic nature of TCDD its percutaneous absorption
would be expected when present in creams applied to the skin.
A report by Schmittle et al., 1958 indicates that human and animal
exposure to TCDD has also occurred from the improper disposal of
distillate residues of chlorinated benzenes which are used as a
starting material in the production of a variety of chemical products.
They indicate that perhaps the most extensive occurrence of animal
exposure to the dioxins (including dichloro-, trichloro-, tetrachloro-,
pentachloro-, hexachloro-, heptachloro-, and octachlorodibenzodioxin) occurred in the United States in 1957.

At that time, in

order to increase the caloric content of poultry rations, feed manufacturers were using a wide variety of low cost fats. These fats were

A-16

�collected from various sources and pooled. Some of the fats were contaminated with oily residues containing dioxins. These mixtures were
sold to the feed manufacturers and incorporated in poultry feeds. As
a result of the ingestion of these contaminated fats, millions of
chickens died. Hundreds of thousands of the surviving contaminated
chickens were processed for human consumption before the origin of the
problem was discovered and steps initiated to prevent the use of this
food. There are no data which suggests that humans were affected by
consuming adulterded poultry products (Allen et a!., 1978).
It is not surprising that there are no accounts of humans becoming
ill from eating TCDD contaminated chicken because the high toxicity of
the compound would probably kill the chicken.

Thus, there is a built

in safety factor since humans seldom eat meat from animals that they
or the slaughter house has not killed.
Do phenoxy herbicides contain TCDD? 2,4,5-T and si 1 vex contain trace
levels of the contaminant TCDD. Although it has not been feasible to
eliminate this contaminant entirely, present production methods are
able to reduce the dioxin level routinely to less than 0.01 ppm in
commercial 2,4,5-T with occasional batch containing as much as 0.05
ppm (McQueen, 1977). The legal limit for TCDD in 2,4,5-T is 0.1 ppm.
Is the TCDD present in 2,4,5-T harmful to animals which eat vegetation
sprayed with the herbicide? As previously stated, TCDD is present in
2,4,5-T in only trace amounts but the extremely toxicity of even small
amounts of TCDD has also been stated. The quotation from CAST (1978)
will be used to answer the question:
The amount of TCDD distributed in the United States in
2,4,5-T and silvex is probably no more than 1 ounce (28 g)
annually. This material is distributed over approximately 5

A-17

�million acres at the rate of 5 micrograms per acre. The most
sensitive species known is the guinea pig, which has an LDso
of 0.6 microgram per kilogram (Johnson, 1971). If we assume
that we have a grazing animal about the size of a sheep or
deer (175 Ib or 80 kg) and the sensitivity of a guinea pig,
this animal would have to consume, without excretion, all of
the treated vegetation on more than 9 acres of land to get a
lethal dose. If the animal had the sensitivity of a rat, it
would have to consume, without excretion, all of the treated
vegetation on more than 400 acres.
There are no cases where livestock has been injured due to
ingesting forage treated with 2,,4,5-T containing trace levels of
TCOD.

Perhaps the fact that phenoxy compounds (Lavy, 1980a) and TCDD

(Jensen et al., 1981) are rapidly excreted from animals allow these
chemicals to be absorbed without apparent harmful effects.
What is Agent Orange?

Herbicide Orange, later Agent Orange, was a

label given by the U.S. military forces to a 50:50 mixture of the nbutyl esters of 2,4-dichlorophenoxyacetic acid (2,4-D) and
2,4,5-trichlorophenoxy-acetic acid (2,4,5-T).

One gallon of Herbicide

Orange theoretically contained 4.21 Ib of the active ingredient of
2,4-D and 4.41 Ib of the active ingredient of 2,4,5-T.

Orange was

formulated to contain a 50:50 mixture of the n-butyl esters of 2,4-D
and 2,4,5-T.

The percentages of the formulation typically are shown

in Table A-5.

A-18

�Table A-5. Chemical composition of Agent Orange (Shepard, 1980)
Materi al

%

n-butyl ester of 2,4-D

49.49

free acid of 2,4-D

0.13

n-butyl ester of 2,4,5-T

48.75

Free acid of 2,4,5-T

1.00

inert ingredients (e.g.,

0.62

butyl alcohol and ester moieties)

Agent Orange also included amounts (from 0.02 to 15 ppm, or a weighted
mean of 1.98 ppm) of the contaminant
2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD).

According to Young et al.

(1978), about 25 million kilograms (55,940,150 Ib) of 2,4-D and 20
million kilograms (44,232,600 Ib) of 2,4,5-T - for a total of 166 kg
(368 Ib) of TCDD - were distributed over approximately 1.4 million
hectares (3.5 million acres) of South Vietnam from January 1962 to
February 1971.

It is significant to note that almost 40% of the

entire amount of TCDD that was released in South Vietnam - or 64 kg
(143

Ib) was contained in Agents Green, Pink, and Purple, which

materials were used on about 36.4 thousand hectares (90 thousand
acres) from 1962 thru 1964. During this time few American troops were
assigned to South Vietnam.
The name Herbicide Orange was a code name by the military for
herbicide combination given.

Later the phrase "Agent Orange" was

A-19

the

�coined. Barrels containing this plant defoliant were painted with an
orange stripe to differentiate it from other compounds being used in
Vietnam.
Why were defoliants used in Vietnam?
The use of chemicals (herbicides) to control vegetation has
been one of the most controversial subjects arising from the
Vietnam conflict. The U.S. Air Force applied most of these
herbicides in jungle areas to clear vegetation from the perimeters of military bases and camps, along lines of communication, and in enemy staging areas. The objective was to
provide defoliated zones that would reduce ambushes and
disrupt enemy tactics (Young, 1981).
Ninety percent of all Herbicide Orange was used to defoliate
forests; it was especially effective in defoliating mangrove forests.
Eight percent of Herbicide Orange was used in the destruction of
broadleaf crops (beans, peanuts, ramie, and root or tuber crops). The
remaining 2 percent was used around base perimeters, cache sites,
waterways, and comunication lines (Shepard, 1980). The use of defoliants in Vietnam saved hundreds of U.S. military lives.
Were defoliants other than Agent Orange used in Vietnam?
Several others were employed; their code names are White, Blue,
Purple, Pink and Green. The latter three which all contained 2,4,5-T
were used in (Table A-6).

A-20

�Table A-6.

Number of gallons of military herbicide procured by the

U.S. Department of Defense and disseminated in South Vietnam during
January, 1962 - October, 1971 (Young et al., 1978).

Period of

Code name

Herbicide

Quantity

Orange

2,4-D; 2,4,5-T

10,646,000

1965-1970*

White

2,4-D; Picloram

5,633,000

1965-1971**

Blue

Cacodylic Acid

1,150,000

1962-1971**

Purple

2,4-D; 2,4,5-T

145,000

1962-1965

Pink

2,4,5-T

123,000

1962-1965

Green

2,4,5-T

8,200

1962-1965

Total

use

17,705,200

*Last fixed-wing mission of Orange 16 April 1970; last helicopter
mission of Orange 6 June 1970.
**Last fixed-wing mission 9 January 1971; all herbicides under U.S.
control stopped 31 October 1971.

Were other pesticides used in Vietnam?
The control of malaria and other mosquito-borne diseases in
South Vietnam necessitated an extensive aerial insecticide
application program in order to control these vector insects.
From 1966 through 1972, three C-123 aircraft were used to
spray Malathion, an organo-phosphate insecticide. These
aircraft could be distinguished from the herbicide-spraying
aircraft because they were not camouflaged. These aircraft
routinely sprayed insecticide adjacent to military operations
were in progress, or installations, as well as in areas where
military operations were in progress, or about to commence."
(Shepard, 1980).
A-21

�Is Agent Orange as toxic as TCDD?

As indicated above, TCDD was present

in Agent Orange at an average concentration of nearly 2 ppm.

This

translates to a 50:50 mixture of 2,4-D and 2,4,5-T; the final mixture
contained 99.9998% phenoxy herbicide and 0.0002% TCDD.

Information

taken from Cast (1978) states
The evidence shows that TCDD is from 5,000 to 500,000 times
more toxic to mammals than 2,4,5-T, depending on species.
Under current standards set by the Environmental Protection
Agency, the content of TCDD in commercial 2,4,5-T must be
less than 1 part in 10 million parts of 2,4,5-T. In practice
the content is about 1 part in 100 million (Fisher, 1977).
On this basis, a single toxic dose of TCDD would be contained
in from 200 to 20,000 toxic doses of 2,4,5-T, depending upon
the test species. Thus, the current level of TCDD in 2,4,5-T
does not contribute significantly to the toxicity of herbicidal preparations of 2,4,5-T.
A more detailed calculation of the relative toxicity of TCDD and
the phenoxy herbicides in the mixture is presented in Chapter 4.
How long does TCDD persist in the environment? Crosby and Wong (1977)
analyzed the persistence of TCDD in actual herbicide formulations on
leaves, soil, or glass plates.

When leaves were exposed to natural

sunlight, most of the TCDD was lost from the leaves in less than 6
hours.

This loss was due principally to "photochemical

dechlorination."

The herbicide formulation provides a hydrogen donor,

which allows rapid photolysis to occur.
excellent source of hydrogen donors.
markedly decreased.

Since Agent Orange has an

TCDD persistence should be

Thus, despite the known persistence of pure

TCDD, it is not stable in thin films of formulated herbicide when
exposed to outdoor light.
Plant uptake of TCDD from soils does not appear to be significant.
Soybean and oat plants took up only trace amounts of TCDD in the first

A-22

�10 to 14 days after exposure to sandy soil containing 200,000 times
the amount of TCDO contained in an application rate of 2 pounds per
acre 2,4,5-T (with 0.1 ppm TCDD).

There was no detectable TCDD in the

grain or beans at maturity, probably because of normal dilution by
plant growth, volatilization, or photodecomposition on the leaf surface, or as a result of metabolism.

TCDD is not translocated from the

point of application on the leaf surface (Isensee, 1971).

In five

soils with widely varying properties, TCDD was found to be immobile
even when subjected to leaching (Helling et al., 1973).

The possibi-

lity of TCDD entering ground water is remote (Tschirley, 1971).
TCDD is incorporated into soil, it disappears slowly.

If

It seems unli-

kely, however, that TCDD would be incorporated in soils under most
conditions of use since it does not leach into the soil.

TCDD is not

produced from breakdown products of 2,4,5-T in soils or in sunlight
(Kearney et al., 1972).
TCDD is nearly insoluble in water - 0.2 ppb.

For this reason, it

would be expected to remain on the surface of plants and soil at the
application site.

Because it is immobile in soils, Kearney et al.

(1973) also concluded that there would be "no ground water contamination problems."
Recent studies on half life determinations of TCDD in soils indicate that 10-12 years are required for 50% of this compound to
degrade.

This very persistent molecule has earlier been shown to be

quite toxic.

Other factors of importance in assessing its hazard to

humans is how much is present? how bioavailable is it? and ultimately
how much is absorbed by humans?

A-23

�Do green plants take up TCDD from the soil? Isensee et al. (1971)
determined the uptake of TCDD from a Lakeland sandy loam soil using
two crop species.

Oats (Avena sativa) and soybeans (Glycine max)

accumulated less than 0.15% of the TCDD applied to the soil. In a
similar study Cuppelo et al. (1976) using sorghum (Sorghum bicolor)
found that the amount of TCDD taken up from a Ulysses sandy loam soil
was approximately one millionth of one percent of the amount of TCDD
in the soil. One of the major contributing factors for the low %
uptake is the low 0.2 ppb water solubility of TCDD. As a general
rule, in the case of herbicides, those with low water solubilities
tend also to be more tightly adsorbed to soil colloids thus further
decreasing their potential for plant uptake.
In U.S. Air Force Experimental plots at Eglin AFB, Florida where
massive quantities of 2,4,5-T were applied to soil, TCDD concentrations
were 150, 160, 700, and 44 ppt at soil depths of 0-2.5 cm, 2.5-5 cm,
5-10 cm and 10-15 cm, respectively. In an ecological survey conducted
over a 5-year period in that area more than 123 different plant species were present.

No TCDD was found in any of the plant species ana-

lyzed (Young et al., 1975). Due to the extremely low levels of TCDD
present in most soil and its low water solubility, TCDD plant uptake
from soil is virtually nil thus escaping detection sensitive gas chromatographic determinations with capabilities for detecting TCDD in the
low ppt range.
Does TCDD magnify in the food chain? The term bioaccumulation means
the uptake of a chemical and some storage of it by an organism. Since
TCDD is present in such low levels in the environment ingestion, inha-

A-24

�lation or dermal absorption is minimal (Norris et al., 1977). An EPA
study monitoring fat from beef animals indicated that bioaccumulation
of TCDD in grazing animals could occur, but levels were not high
enough to be regularly detected by instruments with a 10 ppt sensitivity.
The results of these various tests indicate that, if TCDD is present in the environment in a form that is available to organisms, then
bioaccumulation will occur if organisms are exposed. This concept is
supported, both from an examination of the physical-chemical properties of TCDD, as well as by studies of its behavior in animals exposed
through feeding studies or in laboratory model aquatic ecosystems.
The degree to which bioaccumulation of TCDD occurs in the field
depends not only on the physical-chemical properties of the compound,
but also on the persistence and availability of TCDD in the environment. Mechanisms of degradation and dilution that operate in the
natural environment reduce the opportunities for organisms to be
exposed, and thereby reduce the degree to which bioaccumulation might
occur.
A wide-scale monitoring of water, sediment, fish, beef, and human
milk from areas in the Midwestern United STates where 2,4,5-T has been
applied also showed no detectable TCDD residues at minimum detection
levels that averaged 10 ppt. These monitoring efforts indicate that
substantial bioaccumulation of TCDD (sufficient to produce residue
levels in excess of 10 ppt TCDD in the majority of the population) is
not occurring in animals in or near areas treated with 2,4,5-T in
current operational programs (USDA, 1982).

A-25

�Is TCDD in the environment harmful to animals? As shown in Table A-2
several animal studies have been completed to evaluate the toxicity
of the TCDD molecule. Thus guinea pigs are quite sensitive to the
molecule while hamsters may be as much as 8000 times less sensitive.
The question to be answered is - is there enough TCOD in the environment to harm animals?
Several animal studies have completed but the only formal study
designed to test the accumulation of TCDD in animals in the wild
Newton et al. (1978), could detect no TCDD in tissues of mountain
beaver at the end of 45 to 60 days of feeding on 2,4,5-T treated vegetation.

The area had been sprayed with 2 Ib 2,4,5-T per acre at the

beginning of the feeding period.
Shadoff et al. (1971) analyzed animals for accumulation of TCDD
from regions in Midwestern United States where 2,4,5-T is commonly
used.

They did not detect any TCDD in samples of fish, water, mud and

human milk from Arkansas and Texas. Their detection limit was 10

PPt.
Jensen et al., 1981 fed artificially exaggerated levels of 24 ppt
TCDD to seven beef cattle for 28 days. No adverse effects were
observed in the animals during the 50 weeks of the feeding study.
They consumed approximately 0.02 ug/kg in 4 weeks. Beef fat which
contained the highest level of TCDD, contained 61 to 95 ppt. These
levels dissipated when the cattle were put on non-treated feed.
These data represent residues obtained following an artificially
exaggerated TCDD ingestion rate when compared to the intake that might
be obtained grazing grass sprayed with 2,4,5-T. Typically, the ini-

A-26

�tial deposit of 2,4,5-T on grass is 100 ppm for each pound of herbicide applied per acre (Morton et al., 1967). Since 2,4,5-T
presently contains &lt;0.05 ppm of TCDD, the treated grass could have a
maximum initial TCDD level of 5 ppt. This residue decreases with
time, having a half life on grass somewhere between the 4-h value
found on excised leaf surfaces (Crosby and Wong, 1977) and a value of
1 week in a field experiment where grass was sprayed with a 2,4,5-T
formulation (Getzendaner and Hummel, 1975). Assuming these halflives, the TCDD level would decline to between &lt;0.001 and 0.3 ppt in 1
month. TCDD residue levels obtained in the Jensen study in which a
continuous 24-ppt diet level was fed should not be confused with the
greatly reduced potential for TCDD residues in normal herbicide use.
The results of the Jensen feeding study provide a foundation of
ruminant animal data supporting the conclusion that residues of TCDD
would be detected in beef fat if range animals had been exposed to
measurable levels of TCDD. However, no TCDD has been found at levels
above the detection limit in beef samples taken from areas which would
maximize exposure to TCDD through treatment with 2,4,5-T, except for 3
samples out of 89 from treatment areas (Shadoff et al., 1977) which
came from an area in Missouri where highly TCDD contaminated soil from
Missouri Horse Arena incident had been deposited (Pesticide Chemical
News, 1976). Rabbits force fed with TCDD contained in soil or organic
solvents absorbed higher levels from the organic solvents than from
the soil which tightly binds TCDD (Bonaccorsi et al., 1983).
What are the short- and long-term effects of TCDD? We could answer
this question quite simply and correctly by indicating we do not yet

A-27

�have all of the answers.

However, this same answer could be given for

most all compounds that have biological activity. Since some information is available, portions of this will be discussed. Much of this
information is based on animal feeding studies. These effects could be
more severe or less severe in man since TCDD has been shown to be to
some extent species-specific, however indications are that man is less
sensitive to TCDD than are several other animal species (Stevens,
1981).
TCDD appears to be excreted primarily in the feces of the rat
(Piper et al., 1973) and is assumed to be associated with unabsorbed
compound. Calculated half-lives of 10-30 days were markedly longer
than those from the phenoxy herbicides. The extreme toxicity as exhibited by the very low LDso's (Table 5-2) for TCDD in combination with
a relatively long residence time in animals provide this compound with
an enhanced potential for causing harmful effects in animals.
Due to the extreme toxicity of this compound man should take precautions to insure that he is not being exposing himself to dangerous
levels. Whether it is possible for him to expose himself to health
threatening levels in the environment is debateable. Nevertheless, he
also owes it to himself to make a rational attempt to become as well
informed as possible to the actual levels of exposure he can conceivably be expected to receive.
Workers involved in accidental exposure to TCDD as a contaminant
of trichlorophenol or in factories synthesizing the compound have
reported a number of adverse health reactions (May, 1973; Poland et
al., 1971). Besides chloracne, which is the best known and most sen-

A-28

�sitive sign of exposure to TCDD, other reported toxic manifestations
include conjunctivitis or blepharoconjuctivitis, hepatotoxicity,
gastrointestinal and kidney disturbances, anorexia, weight loss, fatigue, hyperpigmentation, hirsutism, porphyria cutanea tardia, neuromuscular problems, and psychological changes.

However, it has not

been established with certainty that all these clinical symptoms were
related to TCDD exposure.
In their section on "Public Health Hazards" the National Research
Council of Canada (NRCC, 1978) indicates that exposure to high concentrations of phenoxy herbicides as residues in food or water is
relatively unlikely, the primary risk to human health may be expected
to be from occupational exposure during manufacture and application.
Bleiberg et al. (1964) and Poland et al. (1971) reported surveys of
workers in a plant producing 2,4-D, 2,4,5-T, and the di- and trichlorophenols. Chloracne was found in 13 of 73 employees examined and,
in the earlier survey, several cases of porphyria and uroporphyrinuria
were described.. These effects were observed before and just after
major steps were taken to decrease the TCDD content of the products
produced in this plant. These are signs of TCDD poisoning although
the exact nature of the chemicals to which the workers were exposed is
unknown. In another study no differences were observed in 220 men
exposed to 2-8 mg 2,4,5-T/day for 1 to 960+ days (Johnson, 1971). The
control group contained 4600 men. "The workmen were given extensive
physical examinations including a battery of at least 20 laboratory
tests." No chromosomal effects were reported.
sures were not specified.

A-29

Their level of expo-

�Based on dose response studies in animals and limited epidemiologic data at this time there is no conclusive evidence that TCDD is
mutangenic, teratogenic, or carcinogenic to man (Bovey and Young,
1980).
If TCDD enters a human would it accumulate? In animal studies in
which l^C-labeled TCDD was given orally to rats the largest accumulation occurred in liver and fat. These tissues contained 10 to 50
times as much as other body tissues.

This fact does not answer the

question of accumulation. TCDD is eliminated primarily through the
feces for guinea pigs, rats, and mice. The total excreted through
this route was 94, 99, and 74%, respectively for the above animals.
Urinary excretion accounted for the difference.

The half life for

elimination was 30, 31, and 17 days respectively for guinea pigs,
rats, and mice (Neal et al., 1982).
Dr. Frederick Kutz (1981) of the EPA has analyzed human adipose
tissue for TCDD content.

His statements follow.

Several investigators have indicated that minute quantities
of 2,3,7,8-TCDD are present (in the low parts per trillion
range) in specimens of adipose tissue collected from members
of the general population. We also have conducted a very
limited number of analyses of this type. As control specimens for some analytical studies done by the EPA Dioxin
Monitoring Program in early 1980, six specimens of human adipose tissue were collected from residents of an urban Ohio
county. These specimens were exised during post-mortem examinations from individuals with m) recorded or known exposure
to 2,4,5-T or silvex. The source of TCDD in these specimens
was not phenoxy herbicides. Subsequently, the samples were
analyzed in duplicate following the EPA Dioxin Monitoring
Program protocol. Instrumental determinations were conducted
at two independent laboratories.
The results demonstrated that all specimens contained
residues of 2,3,7,8-TCDD. Levels ranged between 5 and 12
parts per trillion, with a detection limit below 5 ppt. It
should be emphasized that all studies conducted to date,
including this one, have been accomplished utilizing small

A-30

�sample sizes and deliberate specimen selection criteria.
Consequently, these data cannot be construed as being representative of the general population.
Why is the Seveso. Italy accident important to the TCDD exposure
questions? By evaluating health problems suffered by humans which
have been exposed to high levels of TCDD, we will be in a better posv
tion to attempt to quantify exposure to the Vietnam veteran and
Vietnamese living in the defoliated areas.
Stevens (1981) provides a quantitative approach to the animal
deaths and human health factors.
About noon on July 10, 1976, a factory north of Milan which
produced trichlorophenol had an explosion which released
boiling reagents into the atmosphere. Most of the cloud
settled on a 110 hectare (1 ha = 2.47 acres) area in the town
of Seveso where it deposited about 2 kg of TCDD. This area
was designated Zone A and a larger, more distant area of 269
ha which received only 20 g of TCDD was designated Zone 8.
The 733 residents of Zone A were evacuated 2 weeks after the
explosion. The 4800 residents of Zone B were not evacuated
but were prohibited from raising or using produce from either
Zone B or the surrounding 1430 ha Zone R. These amounts of
TCDD would produce average concentrations of 1800 and 7 ug of
TCDD per square metre in Zones A and B respectively.
Analyses carried out days to weeks after the explosion showed
a very spotty distribution with a range in Zone A from 5447
ug per square meter to not detectable (Pocchiari, Silano &amp;
Zampieri, 1979). Actual concentrations on vegetation and
soil shortly after the explosion were undoubtedly higher than
these recorded values. Birds began dying in Zone A a few
days after the explosion. Birds preen their feathers regularly. The surface area of the feathers is many times that
of the skin surface so even a small bird must have at least
0.1 m2 of feather surface. 2 If the feathers held the average
concentration of 1800 ugnr , then 180 ug would be present on
a bird weighing only 30 to 100 g. Thus the bird could ingest
1000 ugkg'1, about ten times the acute LD5Q for birds (Young
et al., 1978). Rabbits which ate fresh vegetation from local
fields died next. A 1 kg rabbit consuming vegetation from an
area of one square meter would take in at least 1800 ug, over
ten times the 1059 for rabbits. More cats than dogs died
since cats both groom frequently and eat birds. Later a
number of sheep.and cattle died; most livestock in Zone A was
destroyed. In Zone B, however, birds and rabbits would consume TCDD in the order of 7 ugkg-1 (below the actue toxic
dose) and here few of these animals were found dead.

A-31

�The early toxic effects in man were not due to TCDD but
to other chemicals, for example sodium hydroxide. Chloracne
has been the only prominent effect found to be caused by
TCDD; 193 cases have been diagnosed with 50 cases in residents of Zone A. The diagnosis in the 143 cases outsize Zone
A is confused because these were found by screening 49,000
people for an incidence of 0.3% and this percentage is
reported to be the incidence of chloracne in more northern
industrial Italian cities not involved in the accident.
However, in Zone A the incidence of chloracne was 7%: 23
times this base rate. In addition, about 10% of the Zone A
population showed either minor clinical signs of polyneuropathy or laboratory evidence of slowed nerve conduction
times. Transient changes in liver enzymes were noted in a
few cases. There have been no deaths, no serious disease, no
immunological changes, no birth defects, no increase in spontaneous abortions; and no chromosomal changes attributable to
TCDD (Pocchiari et al., 1979). Cases of chloracne outside
Zone A were probably due to external contact with transported
TCDD. The overall pattern indicates that the mean concentration of TCDD in Zone A was below the minimum toxic dose
but the spotty distribution produced minimal signs and symptoms in about 10%. Since most clinical findings were in
children under age 12, 30 kg will approximate the average
weight. To reach the MTD of TCDD of 0.1 ugkg"^ would require
an intake of 3 ug. The mean concentration of TCDD was 1800
ugm~2 which must have been considerably lower than the level
needed to provide the MTD. It will therefore be assumed that
the 10% affected were exposed to about three times this mean
value or 5400 ugm~2. The intake transfer factor for Seveso
would then be 5400/3 or 1:1800.
TCDD is most toxic for guinea pigs and least for dogs. The
acute toxicity for chickens, mice, rats, cats and monkeys are
all within a proportional order of magnitude, and chronic
toxicity in man, monkeys and rats is not very different
(Young et al., 1978). Hence the reason that human toxicity
was low in Missouri and Seveso while animal toxicity was
high, related not to innate differences in sensitivity but to
a very much lower intake of the environmental TCDD. Humans
wear shoes and clothing, they do not groom with their mouths,
they wash themselves and their food and they do not eat vegetation in bulk. These features account for the intake
transfer factors of 1:2300 calculated from a single individual for whom accurate measurements of environmental TCDD and
of the duration and type of exposure were known, and of
1:1800 calculated from the signs and symptoms of about 75
individuals with less accurate TCDD measurements and of their
exposure. The agreement is good and the average value of
1:2050 will be used for the intake transfer factor.
In the Seveso accident TCDD was released in a village at rates per
acre that were millions of times greater than those that occur from

A-32

�2,4,5-T treatments (Reggiani, 1978).

Beljan et al. (1981) discussing

the Seveso accident states
Thus far, one of the most extensive "human experiments" is
being conducted on the residents of Seveso, Italy. The whole
story may not be known for another five years; but preliminarily, it appears that the dermatological effects were
reversible; there has been no progression of neurological
damage; differences in immune response between exposed and
nonexposed persons have not been significant; and there has
been no notable increase in infectious diseases. There may
never be an entirely clear picture from Seveso of the effect
of TCDO on reproduction or the fetus, because it is suspected
that a number of women elected to have therapeutic abortions.
No major pathology, however, was reported by the area
physicians.
May (1982) reported an accident involving TCDD which occurred in
the United Kingdom in 1968. During the manufacture of 2,4,5 trichlorophenol (TCP) an accident led to the release of crude TCP containing a higher than normal concentration of 2,3,7,8-TCDD.

A total

of 79 cases of chloracne was reported, but there was no clinical evidence of other dioxin-related diseases.
responded favorably to simple treatments.

The majority of the cases
Ten years later, symptoms

had disappeared completely from half the cases under observation while
in the remainder symptoms were insignificant.
Since it has been shown that TCDD is widely distributed in the
environment, does that mean that it is present in the food we eat? If
normally present it is below our level of detection as shown by
several food surveys.

In a study designed to favor the conditions for

a positive identification of TCDD the following action was taken.
Beef fat containing residues of ronnel and its

metabolite

2,4,5-trichlorophenol at 46.0 and 2.8 ppm, respectively, was examined
before and after cooking for presence of 2,3,7,8-tetrachlorodibenzo-

A-33

�p-dioxin.

Fat samples fortified at 2000 ppm with

2,4,5-trichlorophenol or its sodium salt were cooked at 500°F for
periods of 6 to 22 hr.

No tetra-dioxin was found in any of the

samples, using a method with a sensitivity limit of 0.05 ppm (Watts et
al., 1973).
Can man be harmed from absorbing or ingesting 2,4-D or 2,4,5-T?
Berwick (1970) reports an incident where a man accidentally ingested a
110 mg/kg dose of 2,4-D (isooctyl ester).

Besides depression and

irritation of the central nervous system, the victim suffered from
myopathy, 61 irrigation, nephroprethy and toxicity to the liver.
individual recovered fully.

This

Several other cases give us additional

information on man's susceptibility to phenoxy herbicides. Symptoms
of poisoning occur at an oral dose of around 3 to 4 grams (Hayes,
1963).

In an experiment conducted on himself, a man consumed 500 mg

of purified 2,4-D each day for 21 days without ill
1951).

effects (Assouly,

In another case, 18 intravenous doses - the last 12 of which

were 800 milligrams or more - were delivered to a patient over the
course of 33 days for the treatment of coccidioidomycosis; there were
no side effects even after the 18th dose of 2,000 mg. The last injection of 3,600 mg produced illness - but, by the end of 48 hours, the
subject had completely recovered (Beljan et al., 1981).
Some information on phenoxy toxicity to man has been gained by
evaluating data gathered from suicide victims.

The lethal oral dose

for 2,4-D as based on findings from a 23-yr-old male is slightly over
80 mg/kg; a man weighing 80 kg would thus require at least 6.4 grams
of the material to kill him.

Nielsen et al. (1965) reports this

A-34

�suicide with an estimated 6.5 g of 2,4-D.
death was 18 hours.

The time from ingestion to

This 80 mg/kg dose was received all at one time.

If low doses are received over a long time period man's body effectively rids itself of phenoxy compounds.
Rats, when fed levels of 2,4-D at or above the NOEL for teratogenicity, developed peripheral neuropathy (impaired functioning of outermost joints of forearms and hindlimbs (Squibb et al., 1983).

In all

cases grip strength of the rats returned to normal 6 weeks after daily
dosing ended.
Peripheral neuropathy was reported for two individuals who had
significant dermal contact with 2,4-D (Berkley et al., 1963; Todd,
1962).

No evidence has been shown that indicates that chronic expo-

sure to 2,4-D in man will cause peripheral neuropathy.
How toxic is 2,4-D to workers applying this herbicide in the forest?
Using the above information on acute poisoning in the suicide case
let us now make a calculation from data on applicator exposure to
2,4-D provided in Chapter 3 (Lavy et al., 1982).

The group of workers

receiving the highest dose were the pilots and the batchmen, both of
whom received 0.0198 mg/kg.

If we assume similar toxicity between the

dose received orally by the suicide victim and that received as a consequence of dermal absorption by the field workers the following
calculation can be made.

The 80 kg suicide victim's level of

ingestion was 80 mg/kg; the group with the highest absorbed dose in
the 2,4-D applicator exposure study (Lavy et al., 1982) was 0.0198
mg/kg.

The calculation:

A-35

�Lethal acute dose

80 mg/kg

= 4040

One time applicator exposure dose 0.0198 mg/kg
reveals that the workers could have absorbed 4040 times more 2,4-D
than they did before they would have received a lethal dose. Thus, a
4040 fold margin of safety was involved for the most highly exposed
workers in the study.

In reality the margin of safety would be much

higher since the approximately 0.0198 mg/kg was the total absorbed
dose of 2,4-D occurring over the 5-day observation period. As
discussed previously, absorption through the skin in a relatively slow
process, thus the body has the ability to excrete it at a faster rate
than it can enter through the skin. This rapid elimination of the
phenoxy compounds does not allow them to build-up in the body. The
fact that over 9556 of the absorbed phenoxy dose is excreted from the
worker's bodies within 6 days probably accounts for the fact that many
aerial applicators have made a career of applying phenoxy herbicides
with no apparent detrimental health effects. Recent applicator exposure studies from New Zealand indicate that calculated results when
compared to epidemological data show that chemical applicators are at
no greater risk from teratogenic or carcinogenic hazard that the
general population (Ferry et a!., 1982).
Should a concerned pesticide applicator quit worrying about exposure
to pesticides since the scientific facts indicate no imminent danger
is present? All pesticides have biological activity; as such they
should be handled with due caution as prescribed on the label. Nonapplicators receive much, much less exposure than others in our
society. Education, protective clothing, and a desire to work in a

A-36

�safe manner are prerequisites for concerned pesticide applicators who
wish to limit their absorbed dose of the pesticide.
To put into perspective the potential dermal exposure received by
workers applying 2,4,5-T by backpack sprayers at a 2 Ib/acre rate compared to the TCDD levels discussed in other examples in this monograph
(see Table A-7).
Table A-7. Comparisons of TCDD levels as reported in different studies.
Commodity

Concentration reported
(ppb).

Soil from Missouri horse arenas

33,000

Soil from near Seveso explosion site
Soil from Times Beach, Missouri

5,500
300

CDC expressed concern level

1

Soil concentration present when top
3 inches is treated with 2#/acre
2,4,5-T (containing 0.04 ppm TCDD)

0.00008

Present on humans applying 2,4,5-T
(containing 0.04 ppm TCDD) at a rate
of 1.6 Ibs/acre in the forest

0.00005

If one's chances of being harmed by phenoxy herbicides and TCDD are
so low, why do we keep hearing about the danger on TV and reading
about it in the newspapers?

Several different answers are possible:

A-37

�1) The issues being discussed are complex; assuming the news story
writer heeds all of the facts available to him, it would not be a
simple task to convey the message to a broad audience.
Results of an extensive literature search and discussions with
scores of concerned laymen reveals that the U.S. public has heard
little factual information pertaining to the man's exposure to phenoxy
herbicides and TCDD. The objectives of the news media and of reporters of scientific data are often at opposite poles. The journalist
does not provide details on the millions of cars traveling the highways each day. But a car which crashes, bursts into flame, and kills
three people makes front page news. Likewise, the public is seldom
told of the major role that pesticides play in allowing the U.S.
farmer to achieve production levels which provide us an opportunity to
ship our abundant food supplies to millions of starving people around
the world. But if a child inadvertently drinks concentrated gasoline
or insecticide and dies this story makes news. The scientist on the
other hand collects data to determine how safe cars are, or how to
make them safer; he seeks to find new means to feed people; he tests
to determine the danger levels of cars or pesticides; realistically,
these facts do not make good front page stories.
Evidence overwhelmingly supports the concept that phenoxys and
TCDO when in a concentrated form, can harm man and animals. The news
media responds to this side of a complex story. The evidence also
convincingly shows that man can not, through his occupational use of
the herbicides or through his food supply, attain a dose of the phenoxy herbicides or TCDD approaching a health threatening level. The

A-38

�scientist bases his endorsement on the current use of these materials
after assessing the issues and interpreting them to the best of his
ability.
2) The public hears news stories; most do not pursue scientific
literature. The audience is more accustomed and perhaps more receptive to listening to catastrophic happenings than to statements such
as "these pesticide levels do not constitute a threat to man's
health."
3) It is much easier to speculate that something bad may happen in the
future than it is to prove unequivocally that 20, 40, or 80 years from
now a compound will not present a danger to man or his grandchildren.
4) Politically, it is more efficacious to vote on the side of safety
than it is to invest the time and determination to search out the
facts. The masses informed by the media represent more votes than
those reading the scientific journals.
5) Some Vietnam veterans have health related problems; for many individuals it will not be possible to arrive at the exact source of the
problem due to complex world in which we live. In fairness to this
group of individuals only factual scientifically validated information should be offered as the cause.
6) As discussed previously, on a per gram basis, the toxicity of the
phenoxy herbicides is much, much less than that of TCDD. This
monograph has presented information which shows that phenoxy herbicides are not a major source of TCDD in our environment today.
Dioxin (TCDD) will continue to be of keen interest to man due to its
extreme toxicity and its persistence in the environment.

A-39

�Other than in production plants what groups of humans are exposed to
the highest amounts of pesticides?

Commercial pesticide applicators

and mixers receive doses that are hundreds to hundreds of thousands
times greater than others in the vicinity.
Do phenoxy herbicides cause soft tissue sarcomas in man?

Reports from

Sweden (Harden, 1981) suggest that man's exposure to phenoxy herbicides used in forestry and agriculture results in an increased rate
of soft tissue sarcomas.

Many researchers have been critical of the

work charging that he failed to accurately separate other potential
tumor causing factors.
Workers are unlikely to recall with any accuracy the chemicals being used some years in the past and it seems somewhat
simplistic to differentiate between workers exposed to phenoxy acetic acid herbicides and those not exposed to this
group of herbicides (Kilpatrick, 1980).
Estimates of the level of exposure occuring or length of time involved
are obscure.

The fact that several different sarcoma types were found

also make the findings suspect.
A study in the Netherlands was conducted by the State Occupational
Health Service to evaluate claims by newspapers that personnel
involved with 2,4,5-T work in a forested community were encountering a
higher prevalance of tumors.

A total of 54 of their most highly

exposed personnel were selected from a group of 400 workers who had
had some exposure.

This 54 man group was matched with 54 non-exposed

workers (matched by sex, age and residence).

Acne and liver dysfunc-

tion data were used as the criteria for evaluating the workers. No
differences in acne or urinary porphyrin patterns were shown for the
forestry workers exposed to 2,4,5-T and the non-exposed group (Van

A-40

�Houdt et al.t 1983).
The question of soft-tissue sarcoma is important and must not be
avoided.

Current research has failed to show a cause and effect

relationship between exposure to phenoxy herbicides and soft tissue
sarcomas. This subject is receiving continuing attention by research
being conducted by the National Institute for Occupational Safety and
Health (NIOSH).
Were there dangerous components of Agent Orange besides TCDD? This
herbicide was a 50-50 mixture of the n-butyl esters of 2,4-D and
2,4,5-T. The 2,4,5-T component contained a trace level of TCDD. In
normal use patterns such as these employed in U.S. agriculture and in
South Vietnam defoliation efforts levels harmful to man would not be
encountered.

As discussed earlier (see page

) 2,4,5-T represents

more of a health hazard to man than does TCDD which is present as a
trace component.
What happens if 2.4,5-T, which contains a trace level of TCPD, comes
into contact with a human? An in-depth discussion of an applicator
exposure study where 2,4,5-T was applied by helicopter crews, mist
blower crews and backpack spray crews was presented in Chapter 3.
Nearly all crewmembers were exposed.

None became ill. These results

agree with findings discussed by Kilpatrick (1980). Dermal absorption
was cited as the primary entry mechanism into the body.

Excretion in

urine over a 6-day period accounts for over 95% of the absorbed dose.
Individuals who mixed the concentrate received the highest absorbed
dose. The most highly exposed group, the mixers, could have received
an absorbed dose 300 times greater than their actual dose before they

A-41

�would have attained a no-adverse-effect dosage for teratogenicity.
Another way of expressing this fact is that a safety factor or "A
Margin of Safety" of 300 was present.

The 20 mg/kg no-adverse-effect

dosage for 2,4,5-T teratogenicity as established by the working group
in EPA Position Document 1 is a conservative value when employed for
other human health effects.

Since the developing fetus is quite sen-

sitive to toxins this value of 20 mg/kg represents a realistic level
for evaluating exposure of females of childbearing age.

Thus, the

results from the monitored human applicator exposure studies to the
phenoxy herbicides showed that the dose the workers received was well
below any level which could harm their health.
Of the personnel exposed to Agent Orange in Vietnam, only members
of Ranch Hand operations could have received exposure levels as high
as the field crews discussed here.

Ground troops walking through

vegetation sprayed with Agent Orange probably received much lower
exposure than the Ranch Hand personnel based on evaluation of the
following limited study.

A worker walking through a field, which 2

hours earlier had been treated with an ester formulation of 2 Ib/acre
2,4,5-T was outfitted with 6 gauze patches attached to his clothing
allow to measurement of the extent of dislodgeable 2,4,5-T residues
occurring.

Analysis of the patches revealed no detectable 2,4,5-T in

spite of the fact that the worker walked through chest-high to
15-feet-tall sprayed vegetation.

The gas chromatographic technique

could have detected levels as low as 10 micrograms.
Calculations presented in Chapter 4 indicate that 2,4,5-T, a
pesticide relatively non-toxic to man, represents a greater threat to

A-42

�man's health than does the highly toxic TCDD - due to the trace amount
of TCDD present in 2,4,5-T.

As also shown in Chapter 4 some of our

commonly used insecticides have toxicity properties that are 60 times
greater than 2,4,5-T.

Aerial application of some insecticides,

classified as very toxic, can be accomplished in a manner that does
not appear to pose a health threat to the crewmembers applying them.
Were U.S. ground troops in Vietnam "at risk" from Agent Orange since
they could not shower daily?

Records of 2,4,5-T excretion in urine

from commercial applicator exposure studies indicate that although the
backpack crewmembers sprayed only 1 day per test some of them received
an absorbed dose 1 or 2 additional days during the 6 days following
the application day.

Observations of the spray operation and

crewmember habits suggest that not all of these people changed
clothing and bathed daily.

Contaminated boots, gloves, or other

clothing probably contributed to additional exposure they received 3,
4, or 5 days after the application was completed.

As presented in the

Lavy (1978) National Forest Product Association report the mixers
received the highest exposure, 0.069 mg/kg while the backpack
sprayers received 0.048 mg/kg and the flagger received 0.003 mg/kg.
An observer in the forest who was sprayed 2 or 3 times with 2,4-D
received 0.00056 mg/kg.

Following are the margins of safety* for each:

Mixers

299

Backpack sprayers

417

Flagmen

6,666

Observer (sprayed

5,333

with helicopter 2 or 3 times)

A-43

�NOTE: The actual margin of safety is probably much higher than these
values since the NOEL values were obtained from sensitive test animals
who daily consumed these compounds in their food; most crewmembers are
not exposed daily.
These data indicate that workers in the Ranch Hand Operation would
have been exposed much more heavily than ground troops; thus, if health
problems were to arise due to Agent Orange exposure it should be
expressed in health records from the Ranch Hand personnel.
If U.S. military ground troops who were exposed to Agent Orange
did not take daily showers, they too had the potential for continuing
exposure from exposed skin or clothing. Even though the exposure for
ground troops may have been prolonged due to the clothes they were
wearing these levels would not build up in their bodies since the phenoxy herbicides are readily excreted in urine.
The maximum exposure levels that the ground troops could have
received were less than that received by crewmembers of backpack
spray crews in the U.S. who did not receive health threatening exposure application levels. A survey of long-term health studies of
aerial applicators of phenoxy compounds has not revealed any health
associated problems (WAA, 1980).
Could Agent Orange harm soldiers exposed to it? Information obtained
by calculating the trace levels of TCDD in 2,4,5-T and interpreting
the human symptomology exhibited by the large TCDD exposed population
in Seveso, Italy suggest that humans exposed to 2,4,5-T or Agent
Orange have not encountered either serious acute or any chronic health
threatening doses of TCDD. Stevens (1981) uses the TCDD exposure fin-

A-44

�dings derived from the Missouri Horse Arena Incident and the Seveso,
Italy accident to assess the hazards to humans in Vietnam:
Agent Orange is an oily liquid composed of equal volumes of
the ji-butyl esters of 2,4-D and 2,4,5-T. TCDD, present in
Agent Orange in an average concentration of 2 ppm, is extremely insol-uble in water but readily soluble in Agent Orange.
The herbicide was delivered as a coarse spray with droplets
of 320-350 urn diameter (Young et a!., 1978). While gases
readily enter the lungs, only droplets which are less than 10
urn can enter (Walton, 1971), thus Agent Orange could not be
absorbed from the lungs. Each gallon of Agent Orange contained 10.7 Ibs (4.9 kg) of total herbicide (Young et al.,
1978). One acre is 3660 m2 so the spraying rate of three
gallons per acre converts to metric mass units of 4.1 gm~2.
Since the mean TCDO concentration in Agent Orange was 2 ppm,
the delivered amount of TCDD would be 8 ugm"2. The average
concentration of TCDD in Zone B in Seveso, where the people
were not evacuated, was 7 ugm"2 (Pocchiari et al., 1979).
The conditions for destruction of TCDD in Vietnam were almost
ideal. TCDD is very stable in the dark but is photodechlorinated in position eight. The resulting 2,3,7-TriCDD is
10,000 times less toxic (McConnell &amp; Moore, 1979).
Photodechlorination requires light, an organic hydrogen donor
(Agent Orange works well) and the reaction proceeds three
times faster at 30°C, the mean annual daytime temperature in
Saigon, than at 23°C (Liberti et al., 1978). When Agent
Orange is applied to leaves in full sunlight, the half-life
of the contaminant TCDD is only 2 h (Crosby &amp; Wong, 1977).
Grass receives less light and some TCDD reaches the soil; the
half-life of TCDD applied to turf is about 6 days (Young et
al., 1978). Since spraying was done in early morning (Young
et al., 1978), a single day of full sun would decrease the
TCDD on the leaves from 8 to 0.3 ugrrr2. About 90% of Agent
Orange was sprayed on forests and only 6% of that reached the
forest floor (Young et al., 1978) to yield 0.5 ugnr2 of TCDD.
Hence under forest cover, troops passing through, even under
direct spraying, would receive less than 1 ugrrr2 in their
environment. For the 10% not sprayed on forests, the early
morning concentration of 8 ugrrr2 would be less than half of
that by evening. For most soldiers who had any exposure to
Agent Orange, that exposure would consist of walking through
vegetation which contained no more than 1 ugm"2 of TCDD.
Using the transfer factor of 1:2050, the soldier would take
in 5 x 10~4 ug of TCDD. For a 70 kg soldier this represents
7 x 10"" ugkg~* or 1/14,000 of the minimum toxic dose of 0.1
ugkg'-"-. If soldiers were exposed to direct spraying from
airplanes the intake would still be only 1/1750 of the MTD.
Even if a soldier were exposed to 8 ugm"2
each day of his
one year tour in Vietnam and each day was treated as a new
exposure, his cumulative intake would be only 1.4 ug or 0.02
ugkg"1 of TCDD.
A-45

�Since it would take about 5 years of daily close
with Agent Orange to reach toxic levels of TCDD,
illnesses in Vietnamese (Tung et al., 1971, 1973)
Americans (Bogan, 1979) were due to Agent Orange
merit" (Stevens, 1981).

contact
claims that
and
are without

Stevens' description above of the prospects for significant TCDD
exposure of U.S. military personnel in Vietnam were made with no
reference to the fact that a portion of the TCDD absorbed during the
exposure period would also be excreted.

Assuming the other con-

siderations to be valid, then an even greater margin of safety could
be projected. There is another important but difficult fact to evaluate regarding the U.S. spraying program in Vietnam. Many soldiers
were accustomed to seeing U.S. planes routinely spray jungle and base
perimeter areas; for many it would have been impossible to distinguish
between the spraying of malthion, an insecticide, or one of the
several defoliants.
How could one know if he had been exposed to significant levels of
Agent Orange?

From the studies on humans accidently exposed to large

doses of TCDD in Seveso, Italy in 1976 the most common symptom was the
development of chloracne.

However, not all of the exposed population

developed chloracne.
This particular skin disease is, in fact, regarded as the clinical
marker for TCDD exposure.

Systemic disorders in man from exposures to

TCDD are not likely to occur if chloracne is not present.

Such symp-

toms as impaired liver function, nephropathy, GI irritation, myopathy
and neuropathy, including depression and irritation of the central
nervous system, have been reported after exposure to large amounts of
TCDD in industrial accidents; however, these symptoms have not been

A-46

�progressive, and they have always cleared with time (Beljan, et al.,
1981).
In the Seveso exposed population evidence of chloracne was present
2 weeks after exposure,however some cases took as long as 7 weeks to
develop. A total of 175 cases (Pocchiari, 1978) was reported; this
accounted for 0.6 to 1.256 of the population exposed.
It is highly unlikely that U.S. military personnel in Vietnam were
exposed to TCDO levels high enough to cause chloracne, however, if it
did occur evidence of chloracne should have developed within 2 to 7
weeks of the time exposure occurred.
Chloracne has been described as the primary symptom for men exposed to
chlorinated organic compounds, are there other symptoms that would
accompany these symptoms?

Chloracne development commonly follows

industrial accidents involving man's exposure to TCDD. Evaluation of
health records of 174 humans, who developed chloracne after the explosion or occupational exposure to some form of dioxin since 1960,
revealed no obvious effects of other systemic disorders (Crow, 1981).
What has happened to the health of those in Vietnam who mixed and
applied Agent Orange? These individuals are a part of the Ranch Hand
group where ongoing tests are being conducted.

To date this group has

not reported health related problems due to their job assignment. If
one could accurately extrapolate from exposure data on humans who mix
and apply phenoxy herbicides as a vocation in the U.S., no deleterious
health effects would be expected.
Could Agent Orange affect the fertility of males? Male mice were fed
a replication of substances similar to Agent Orange (Lamb et al.,

A-47

�1980). In previous studies some female mice when exposed to 2,4,5-T
at high doses during pregnancy delivered offspring with cleft palate,
cystic kidney or retarded growth; no other laboratory animals had
shown this effect. Although the dose levels in this study of male
mice were sufficient to affect the liver and the thymus, and to reduce
growth rates, there was no alteration in the concentration or motility
of sperm or in the proportion of abnormal sperm; no significant
decrease in fertility was shown and the development of the offspring
of treated males appeared to be normal.
Can birth defects be caused by pregnant women being exposed to the
phenoxy herbicides and TCDD? The human event most sensitive to harm
is that of possible birth defects in the developins fetus of pregnant
women.

The level of any compound required to cause this effect in

test animals is much less than the levels required to show other
health problems (Hunter et al., 1981). Much of this section has also
been taken from Hunter et al., 1981.
Experiments with test animals can be used to determine a
"no-effect" level (NEL), which describes a definite amount of applied
chemical at which no risk exists and birth defects do not occur.

The

level for the most sensitive test species can then be extrapolated to
human exposure.

The likelihood of contacting this level of exposure

during field use of the chemical will determine its hazard.
The NEL's1 for 2,4-D, 2,4,5-T and TCDD are 24 mg/kg/day, 20

^•Although the term NEL, "No effect level", is used here there remains
a dose-response curve for teratogenicity at levels below the NEL's
listed. For phenoxy compounds teratogenicity is not a problem
because the chemical clears the body so rapidly.
A-48

�mg/kg/day and 0.03 ug/kg/day respectively.

(Figures for 2,4,5-T and

TCDO are in accordance with the U.S. Environmental Protection Agency.)
To attain this much exposure a 60 kg pregnant woman would have to
ingest 1.6 g/day of 2,4-D, 1.2 g/day of 2,4,5-T or 1.8 ug/day of TCDD
(equivalent to 19 g/day of 2,4,5-T containing the maximum permissible
level of TCDD) during the critical period of fetal development
(Australian Consultative Council, 1978).

To help evaluate the possi-

bility of this much exposure occurring consider 1) pesticide applicators are among the most highly exposed group of humans, and 2)
applicator exposure to 2,4,5-T as discussed in Chapter 3 revealed that
the most exposed crewmembers received less than 0.1 mg/kg/d (Lavy,
1978).
Exposure could occur by either:
a.

direct contact with the sprays; or

b.

residues of chemical in food or water.

a.

skin absorption and inhalation of sprays
Calculations of direct spraying onto 1 square metre of a woman's

skin (approximately 2/3 of total area) and allowing for a 10% absorption rate (based on EPA data) would give safety factors of 40 for
2,4,5-T; 600 for TCOD and 60 for 2,4-D.
Thus the NEL will be reached for each of these three chemicals by
a woman standing in an open paddock, with two-thirds of her skin
exposed, while a low-flying aircraft spraying 2,4-D or 2,4,5-T at the
normal rate makes between 40 and 600 passes directly over her each day
for many consecutive days during the sensitive period of fetal development.

Also the woman makes no attempt to wipe or wash the spray

A-49

�off for many days.
It is highly unlikely that the above scenario could occur;
however, it is desirable to err on the safe side, but there are limits
beyond which it becomes unrealistic.
Assuming 100% of absorption of inhaled chemical, a 10 minute exposure would give safety factors of 15,000; 225,000; and 31,000 for
2,4,5-T, TCDD and 2,4-D respectively (Australian Consultative Council,
1978).
b.

residues in food and water
Table A-8 shows the amounts of spray or foodstuffs which must be

ingested by a 60 kg woman in order to obtain the "no-effect" level.

A-50

�Table A-8. Amounts of food or spray mix to be ingested per day to
reach the NEL of 2,4-D, 2,4,5-T, and TCDD with respect to a 60 kg
pregnant woman, as determined from experiments with laboratory animals
(Modified from Australian Consultative Council, 1978).

Source

2,4-D

2,4,5-T

TCDD

Spray mix 3

.45 1

0.6 1

9.0 1

Water b

72,000

60,000 1

900,000 1

Milk c

14,500

12,000 1

180,000 1

Meatd

7,200

6,000 kg

90,000 kg

a

2,4,5-T is diluted approximately 400-fold for conventional spraying.
^Assuming the 2,4,5-T concentration is at the maximum recommended
residue level of 0.02 ppm.
c
Assuming residue level of 0.1 ppm in milk.
d
Assuming residue level of 0.2 ppm in meat.
NOTE: With respect to the residue levels assumed for water, milk, and
meat, these levels are virtually never obtained with normal field use.
The calculations involved in determining the values in Table A-8
represent an exaggeration since:
1. The 0.02 ppm maximum recommended residue level for 2,4,5-T in
water is based on potential run-off, or direct application to surface waters in catchment areas; not to the residue occurring in
normal field use which, in the bulk of instances, is below the

A-51

�level of detection; and
2. The residue levels chosen for milk and meat are taken from experimental work in which animals were deliberately fed 2,4,5-T at much
higher levels than would be expected to occur through the
ingestion of treated pasture.

Under normal agricultural use resi-

dues of 2,4j5-T in meat and milk are extremely unlikely to occur.
In addition to the facts mentioned above, the use patterns of
2,4,5-T are such that potential accumulation of the herbicides would
be unlikely. They are used only in areas where weed pressure is high
and very few individual areas would be treated more often than once in
any year.
As with 2,4,5-T general residue surveys have shown that 2,4-D is
rarely found in food, and when found the levels are well below the
maximum permissible residue levels. The latter values have been set
to cover relatively unusual circumstances.
Domestic users of 2,4-D and 2,4,5-T can be assured that provided
the label recommendations are followed, no harmful effects will be
caused to any unborn child, unlike other well documented risks associated with cigarette smoking and alcohol (Chlorinated Dioxin Task
Force, 1978; U.S. Dept. of Health Educ. and Wei., 1978).
Studies were designed to determine whether paternal exposure to
TCDD or other dioxins might be associated with adverse pregnancy outcomes. Wives of husbands potentially exposed were compared to a group
whose husbands had no known exposure to any dioxin. During the study
in groups over 2700 conceptions and 2400 live birth resulted; overall
no statistically significant associations were found between any expo-

A-52

�sure and pregnancy outcomes (Townsend et al., 1982).
Does human mother's milk contain TCDD?

This question is of interest

since if mother's milk did contain TCDD, a large proportion of her
infants nourishment could contain the toxin.

If a nursing mother's

body .contained TCDD the fat content of the milk would most likely contain some TCDD.

Before TCDD could be found in human mother's milk

it

must be present in her body at a concentration detectable by modern
methodology.

Techniques are now available which permit the scientist

to be able to detect TCDD at, or below, the 1 ppt level.

In studies

reported by Shadoff (1980) of 4 correctly analyzed human milk samples
none contained levels of TCDD above the 1 ppt detection limit.

This

finding is not surprising since man's food supply seldom contain
detectable levels of TCDD.
Another report in 1980 states "All 103 mothers' milk samples from
the 2,4,5-T spray area were negative for dioxin, EPA noted this week.
The Agency said the samples were taken from 2,4,5-T spray areas in
California, Oregon and Washington in 1977.

Samples were also

collected in control areas of California and Alaska not sprayed with
dioxin-containing pesticides, the agency said.

It noted that the

samples were checked on equipment capable of measuring residues down
to 1 to 4 parts per trillion" (Pesticide and Toxic Chemical News,
1980).
How do the teratogenic effects of TCDD and 2,4,5-T compare?
much more toxic compound than 2,4,5-T.

TCDD is a

Cranmer (1978) has calculated

that TCDD is 10,000 times more teratogenic than 2,4,5-T.

However,

since 2,4,5-T is present at levels which are 10,000,000 times greater

A-53

�than TCDD, the TCDD would be required to bioaccumulate by at least
1000 times before it would equal the toxic effect that the larger
amount of 2,4,5-T possesses. As discussed earlier the low application
rates of 2,4,5-T (approximately 2 Ib/acre) coupled with its short
half-life (20-40 days) in the environment make it impossible for the
agricultural use of 2,4,5-T to represent a threat to man's health.
Were U.S. military personnel who used Agent Orange informed about
its properties at the time of its use in Vietnam? Facts regarding how
to handle these herbicides were printed in a Department of Army information manual in 1969 (Irish et al., 1969). The publication indicated
that spillage onto skin or clothing should be removed promptly to
avoid possible irritation through prolonged skin contact.

This same

report also stated "These chemicals present no hazard to man or animals in areas subjected to defoliation at the time of or following
spray application."
Results from experiments conducted later, which were designed to
measure the amount of 2,4,5-T and 2,4-D exposure received by field
workers routinely mixing and applying these chemicals, appear to
substantiate the statements presented by Irish et al. in 1969.
Results from the most highly exposed 2,4-D and 2,4,5-T applicators
revealed that the amount of exposure occurring did not result in
absorbed doses approaching health threatening levels (Lavy et al.,
1980; Lavy et al., 1982; Nash et al., 1982; Nigg, 1983).

A-54

�What evidence do we have which indicates that use of defoliants In
South Vietnam has not caused man health problems?
Ground troops would have been exposed to that material which
penetrated the canopy.

Using phenoxy herbicides similar to Agent

Orange Tschirley (1969) found that about 6% of the material applied
actually reached ground level. The percentage falling to the ground
was lower in areas where forest canopy was the thickest. From studies
on commercial applicator exposure studies we have learned that those
standing under aircraft which was applying phenoxy herbicides do not
receive nearly as much exposure as those who mix and prepare the concentrated materials (Lavy et al., 1980; Lavy et al., 1982).
Personnel in Vietnam who routinely mixed the concentrates and
applied the defoliants to the jungle (the Ranch Hand personnel) would
have received a much higher absorbed dose than ground troops. Ongoing
monitoring of the health effects of this group has not indicated an
increased incidence in death rate or in health problems. Possibly one
of the reasons that a man is not injured when exposed to the phenoxy
compounds is that his absorbed dose of phenoxy compounds is rapidly
and nearly quantitatively excreted in his urine, thus, no build-up
occurs in his body.

Since these materials are not stored in fatty

tissues of humans any health problems arising from their use should
occur near the time of exposure.
Why do the Veteran's Administration and other government agencies
continue to study Vietnam veteran health problems if the government is
not admitting that Agent Orange exposure has caused the problems? As
responsible interested agencies, the VA, CDC et al. are continuing to

A-55

�search for possible scientific evidence which could link Agent Orange
exposure to the health effects being reported.

The search for new

facts should not be interpreted to mean that these agencies believe
there is a positive relation between exposure to Agent Orange and consequent health problems; it is their duty to explore all of the factors which could contribute to the health problems reported.

A-56

�APPENDIX
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Lavy, T. L., J. S. Shepard, and J. D. Mattice. 1980a. Exposure
measurements of applicators spraying (2,4,5-trichlorophenoxy) acetic
acid the forest, vh Agric. Food Chem. 28:626-30.
Lavy, T. L., J. S. Shepard, and D. C. Bouchard. 1980b. Field worker
exposure and helicopter spray pattern of 2,4,5-T. Bull. Environ.
Contain. Toxicol. 24:90-96.
Lavy, T. L., et al. 1982. (2,4-dichlorophenoxy)acetic acid exposure
received by aerial application crews during forest spray operations.
J_. Agric. Food Chem. 30:375-81.
Liberti, A., D. Bracco, I. Allegrini, A. Cecinato, and M. Possanzini.
1978.
Solar and ultroyiolet photodecomposition of 2,3,7,8tetrachlorodibenzo-p-dioxin in the environment. Sci. Total Environ.
10:97-104.
Lobes, L.A., R.E. Koehler, W.F. Barthel, R.A. Feldman, and J.V.
Bennett. 1972. Administrative report to the director of the Center
for Disease Control (CDC) on toxic illness, Lincoln County, Missouri,
CDC No. EPI-72-13-2, U.S. Public Health Service, CDC, Atlanta,
Georgia.
May, G. 1973. Chloracne from the accidental production
tetrachlorodibenzo-p-dioxin. Br. J_. Ind. Med. 30:276-83.
May, G. 1982. Tetrachlorodibenzodioxin: a survey of subjects ten
years after exposure. Br. J_. Ind. Med. 39:128-35.
McConnell, E. E. and J. A. Moore. 1979. Toxico pathology
characteristics of the halogenated aromatics. Ann. NY Acad. Sci.
320:138-50.

A-60

�McQueen, E. 6., et al. 1977. 2,4,5-T and Human Birth Defects. Report
Prepared in the Discussion of Public Health Dept. of Health, New
Zealand.
Morton, H. L., E. D. Robison, and R. E. Meyer.

1967.

Weeds 15:268.

Nash, R. 6,, P. C. Kearney, J. C. Maitlen, C. R. Sell, and S. N.
Fertig. 1982. Agricultural applicator exposure to
2,4-dichlorophenoxy acetic acid. ACS Symposium Series 182, American
Chemical Society.
National Research Council Canada.
effects on environmental quality.

1978. Phenoxy herbicides - Their
NRCC No. 16075, Ottawa, Canada.

Neal, R. A., J. R. Olson, T. A. Jasiewicz, and L. E. Geiger. 1982.
The toxicokinetics of 2,3,7,8-tetrachlorodibenzo-p-dioxin in mammalian
systems. Drug Metab. Rev. 13:355-85.
Neil sen, K., B. Kaempe, and J. Jensen-Holm. 1965. Fatal poisoning in
man by 2,4-dichlorophenoxyacetic acid (2,4-D): Determination of the
agent in forensic materials. Acta. Pharmocol. Toxicol. 22:224-34.
Newton, M. and S. P. Snyder. 1978. Exposure of forest herbivores to
2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD) in areas sprayed with
2,4,5-T. Bull. Environ. Contam. Toxicol.
Nigg, H. N. and 0. H. Stamper. 1983. Exposure of Florida airboat
aquatic weed applicators to 2,4-dichlorophenoxy acetic acid (2,4-D).
Chemosphere 12:209-15.
Norris, L. A., M. L. Montgomery, and E. R. Johnson. 1977. The
persistence of 2,4,5-T in a Pacific Northwest Forest. Weed Sci.
25:417-22.
Olson, J. R., M. A. Holscher, and R. A. Neal.
Pharmacol. 55:67.
Pesticide Chemical News.

1980.

Toxicol. Appl.

1976. Washington, June 23, 1976.

Pesticide and Toxic Chemical News.
Volume No. 8, Jan. 16, 1980.

1980.

P. 17.

Mothers milk samples.

Piper, W. N., J. L. Rose, and P. J. Gehring. 1973. Excretion and
tissue distribution of 2,3,7,8-tetrachlorodibenzo-p-dioxin in the rat.
Environ. Health Perspect. 5:241-44.
Pocchiari, F., B. Silano, and A. Zampieri. 1979. Human health
effects from accidental release of tetrachlorodibenzol-p-dioxin (TCDD)
at Seveso, Italy. Ann. NY Acad. Sci. 320:311-20.
Poiger, H. and C. H. Schlatter.

1979.

A-61

Nature 281:706.

�Poiger, H. and C. Schlatter. 1980. Influence of solvents and
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Toxicol. 18:477-81.
Poland, A. P., D. Smith, G. Wetter, and P. Possick. 1971. A health
survey of workers in a 2,4-D and 2,4,5-T plant. Arch. Environ. Health
22:316-27.
Rawls, R. 1. and D. A. 0'Sullivan. 1976. Italy seeks answers
following toxic release. Chem. Eng. News. Aug. 23, 1976. Pp. 27-35.
Reggiani, G. 1981. Toxicology of 2,3,7,8-tetrachlorodibenzo-p-dioxin
(TCDD): Short review of it's formulation occurrence toxicology and
kinetics, discussing human health effects, safety measures, and
disposal. Regulatory Toxicol. Pharmacol. 1:211-43.
Reggiani, G. 1978. Medical problems raised by TCDD contamination in
Seveso, Italy. Arch. Toxicol. 40:161-88.
Rose, H. R. and S. P. R. Rose. 1972. Chemical spraying as reported
by refugees from South Vietnam. Science 177:710-12.
Schmittle, S. C., A. M. Edwards, and D. Morris. 1958. A disorder of
chickens probably due to a toxic feed—preliminary report. J_. Am.
Vet. Med. Assoc. 143:216-19.
Schwetz, B. A., J. M. Norris, G. L. Sparschu, V. K. Rowe, P. J.
Gehring, J. L. Emerson, and C. G. Gerbig. 1973. Environ. Health
Perspect. Exp. 5:87.
Shadoff, L. A., R. A. Hummel, L. Lampachki, and J. H. Danidson. 1977.
A search for 2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD) in an
environment exposed annually to 2,4,5-trichlorophenoxyacetic acid
esther (2,4,5-T) herbicides. Bui 1. Environ. Contam. Toxicol.
18:478-85.
Shadoff, L. A. 1980. The determination of 2,3,7,8-tetrachlorodibenzop-dioxin in Human Milk. Am. Chem. Soc.
Shepard, B. M. 1980. Proceedings from the Second Continuing Education
Conference on Herbicide Orange. Washington, May 1980.
Smith, F. A., F. J. Murray, J. A. John, K. D. Nitschke, R. J. Kociba,
and B. A. Schwetz. 1981. Three-generation reproduction study of rats
ingesting 2,4,5-trichlorophenoxyacetic acid in the diet. Food Cosmet.
Toxicol. 19:41-45.
Sparschu, G. L., F. L. Dunn, and V. K. Rowe. 1971. Study of the
teratogenicity of 2,3,7,8-tetrachlorodibenzo-p-dioxin in the rat food.
Food Cosmet. Toxicol. 9:405-12.
Squibb, R.E., H.A. Talson, and C.L. Mitchell. 1983. Neuro-behavioral
assessment of 2,4-dichlorophenoxyacetic acid (2,4-D) in rats.
Neurobeh. Toxicol. Teratol. 5:331-335.
A-62

�Stevens, Kingsley M. 1981. Agent Orange toxicity: A quantitative
perspective. Human Toxicol. 1:31-39.
Terry, D. 6., L. R. Gazeley, and I. R. Edwards. 1982. 2,4,5-T
absorption in chemical applications. Proc. Univ. Otago Med. Sch.
60:31-32.
Todd, R.L. 1962. A case of 2,4-D intoxication. J. Iowa Med. Sco.
52:663-664.
Townsend, J. C., K. M. Bodner, P. F. D. Vanpeenen, R. D. Olson, and
R. R. Cook. 1982. Survey of reproductive events of wives of
employees exposed to chlorinated dioxins. Am. J. Epidemiol.
115:695-713.
Tshirley, F. H. 1969. Research Report - Response of tropical and
subtropical woody plants to chemical treatment. Agric. Res. Service,
U.S. Dept. of Agriculture, ARPA Order No. 424.
Tshirley, F. H. 1971. Report on status of knowledge regarding
2,4,5-T. Submitted by USDA to EPA. March 5, 1971. 2,4,5-T Advisory

Commi ttee.
U.S.D.A. 1982. The biologic and economic assessment of 2,4,5-T.
Technical Bulletin 1671 U.S.D.A.
U.S. Dept. of Health, Education, and Welfare. 1978. Smoking and
Health - A Report to the Surgeon General - Pregnancy and Infant
Health. Publication Number PHS 79-50066.
Van Houdt, J.J., L.G. Fransman, and J.J.T.W.A. 1983. Epidemiological
case control study in personnel exposed to 2,4,5-T. Chemosphere
12:575.
Walton, W.H. (ed.).
Greshan Press.

1971. Inhaled particles.

Old working, surrey.

Watts, R. R. and R. W. Storherr. 1973. Negative finding of
2,3,7,8-tetrachlorodibenzo-p-dioxin in cooked fat containing actual
and fortified residues of ronnel and/or 2,4,5-T trichlorophenol. J^.
Assoc. Off. Anal. Chem. 56:1026-27.
Wipf, H. K., E. Homberger, N. Neuner, and F. Schenker. 1978. Field
trials on photodegradation of TCDD on vegetation after spraying with
vegetable oil. In: Dipxin: Toxicological and Chemical Aspects. New
York, Spectrum. Pp. 201-17.
World of Agricultural Aviation (WAA). 1980. Investigation of the
possible effects of pesticide exposures on reproductive mortality and
morbidity. 7:12-30.
Young, A. L., C. E. Thai ken, and W. E. Ward. 1975. Studies of the
ecological impact of repetitive aerial applications of herbicides on
the ecosystem of test area C-52A, Eg!in Air Force Base, Florida
Technical Report AFATL-TR-75-142 Air Force Armament Lab. Pp. 127.

�Young, A. L., et al. 1978. The Toxicology Environmental Fate and
Human Risk of Herbicide Orange and Its Associated Dioxins. USAF
Occupational and Environmental Health Laboratory Technical Report
Number TR-78-92, Final Report Brooks Air Force Base, Texas.
Young, A. L. 1981. Agent Orange at the Cross-roads of Science and
Social Concern. Air Command and Staff College Student Research
Report, Maxwell Air Force Base, Alabama.
Zabik, M. E. and M. J. Zabik. 1980. Dioxin levels in raw and cooked
liver, loin steaks, round, and patties from beef fed technical grade
pentachlorophenol. Bull. Environ. Contam. Toxicol. 24:344-49.

A-6J.

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°5241
Leng, Marguerite L.

Corporate Author
RBpOrt/ArtiClB Title

Letter to

Federal Register Section, Technical Services
Division, Office of Pesticide Programs, EPA from
Marguerite L. Leng, July 7, 1978

Journal/Book Title
Year

000

°

Month/Day
Color

D

Number of Images

°

DBSCrlptOn NOtBS

Letter has subject line 2,4,5-T Rebuttable Presumption
Against Registration OPP 30000/26. Leng is responding to
the RPAR and encloses two of her papers. First is
"Comparative Metabolism of Phenoxy Herbicides in Animals"
in Fate of Pesticides in Large Animals, 1977 (not scanned),
and the second is a draft of "Government Requirements for
Pesticide Residue Analyses and Monitoring Studies" Chapter
11 in Pesticide Residue Analysis, January 31, 1977.

Friday, March 01, 2002

Page 5241 of 5263

�l&gt;1*r*

1714 Sylvan Lane
Midland, Michigan 48640
July 7, 1978

Federal Register Section
Technical Services Division (WH-569)

Office of Pesticide Programs, EPA
Room 401, East Tower
401 M Street SW

Washington, D. C.
Subject:

20460

2,4,5-T Rebuttable Presumption.Against Registration
OPP 30000/26

This response to the 2,4,5-T RPAR is prompted by my dedication as a
scientist who is continually seeking knowledge about the effects of
chemicals on man and his environment. I am submitting it as an individual who is an active member in the Division of Pesticide Chemistry of
the American Chemical Society, rather than as a person who is currently
employed by Dow Chemical, one of the principals in the continuing debate
on the safety of this useful herbicide.
Enclosed are pertinent excerpts of two documents dealing with studies on
phenoxy herbicides in humans, and with the reliability of data on
residues of 2,4,5-T and its trace contaminant TCDD in foods and environmental samples.
The first paper summarizes three studies with phenoxy herbicides in
humans. It includes a discussion about the fallacy of using data from
studies at highly exaggerated dosage levels to predict what might
happen at levels likely to be encountered from recommended uses of
2,4,5-T. (This paper was cited as reference 79 in EPA's 2,4,5-T Position
Document No. 1, but only as a basis for calculating highly exaggerated
residues for 2,4,5-T in meat and milk.)
The second enclosure is from my draft chapter on government requirements
for pesticide residue data and monitoring studies, scheduled for publication in 1978. As indicated in this excerpt, many of the allegations
of hazard from use of 2,4,5-T are based on data from studies which do
not meet even minimum requirements for such investigations.
Sincerely,

/

'

Marguerite L. Leng, Ph.D.

abc

cc to attached list.

�M. L. Leng letter dated 7/7/78
2,4,5-T Rebuttable Presumption Against Registration
OPP 30000/26

Copies to:
Federal Register Section
Technical Services Division (WH-569)
Office of Pesticide Programs, EPA
Room 401, East Tower
401 M Street SW
Washington, D. C. 20460

Dr. Gerald G. Still, Chairman
Division of Pesticide Chemistry
American Chemical Society
USDA, ARS
West Building 005
Beltsville, MD 20705

Mr. Edwin L. Johnson
Deputy Assistant Administrator
(WH-566)
Office of Pesticide Programs, EPA
401 M Street, SW
Waterside Mall, East Tower
Washington, D. C. 20460

Dr. Philip C. Kearney
Chairman, Technical Advisory Group
National Agricultural Pesticide
Impact Assessment Program
USDA, Office of Environmental
Activities
Office of the Secretary
14th and Independence Ave., SW
Washington, D. C. 20250

Dr. William A. Wells
Acting Administrator
Special Pesticide Reviews Div.
(WH-566)
U.S. Environmental Protection Agency
Office of Toxic Substances
401 M Street, SW
Waterside Mall, East Tower
Washington, D. C. 20460

Representative James G. Martin
(North Carolina)
115 Cannon House Office Building
Washington, D. C. 20515

Mr. Douglas M. Costle
Administrator (A-100)
Environmental Protection Agency
Room 1200
Waterside Mall, West Tower
401 M Street SW
Washington, D. C. 20460

Harvey L. Warnick
Office of Special Pesticide
Review (WH-566)
Environmental Protection Agency
Waterside Mall, East Tower
401 M Street SW
Washington, D. C. 20460

Dr. Anna Harrison, President

American Chemical Society
Carr Laboratory
Mount Holyoke College
South Hadley, Massachusetts

01075

�GOVERNMENT REQUIREMENTS FOR PESTICIDE RESIDUE ANALYSES
AND MONITORING STUDIES

by
Marguerite L. Leng
Government Registration
Dow Chemical U.S.A.
Midland, Michigan

Chapter 11 in
PESTICIDE RESIDUE ANALYSIS
edited by
H. Anson Moye

No. 43 in Wiley Interscience Series of
Monographs on Analytical Chemistry and Its Applications

Philip Ebving and James D. Winefordner, Editors

January 31/ 1977

�TABLE OF CONTENTS
1.

INTRODUCTION

2.

REGULATION OF PESTICIDES

2.1 Government Agencies
2.2 Laws Regulating Pesticides
2.2.1

The Federal Insecticide/ Fungicide, and
Rodenticide Act
2.2.2 The Federal Food, Drug, and Cosmetic Act
2.2.3 Implementation of Laws on Pesticide Residues

2.2.4
3.

History of Tolerances for 2,4-D in Food Crops

RESIDUE DATA REQUIREMENTS

3.1 Analytical Methodology
3.1.1

Validation of the Method

3.1.2

Extraction Efficiency

3.1.3
3.1.4

Total Residue Including Metabolites
Regulatory Method

3.2 Residue Studies in Plants
3.2.1
3.2.2
3.2.3
3.2.4
3.2.5
3.2.6
3.2.7
3.3

Field Experiments
Sampling
Residues in Crops
Residues in Crop Byproducts
Crop Groupings for Residue Data
Negligible or Low Level Residues
Temporary Tolerances

Residue Studies in Animals
3.3.1
3.3.2
3.3.3

Residues from Treated Plants
Residues from Treatment of Animals
Residues from Treatment of Agricultural Premises

3.4 Miscellaneous Residue Studies
3.4.1 Aquatic Sites
3.4.2 Stored Commodities
3.4.3
3.4.4
3.4.5
3.4.6
3.4.7

Food Handling Establishments
Seed Crops and Seeds
Postharvest Treatments
Minor Changes in Use or Formulation
Imported Foods

3.4.8

Environmental Studies

�3.5

Reporting of Residue Data
3.5.1
3.5.2

3.5.3
3.5.4
4.

Identification of Report
Residue Summary

Body of Report
Tables and Figures

MONITORING STUDIES

4.1 National Pesticides Monitoring Program
4.1.1

Working Group and Monitoring Panel

4.1.2

Pesticides Monitoring Journal

4.1.3

Pesticides in National Monitoring Program

4.2 National Food and Feed Monitoring Program
4.2.1 Surveillance of Unprocessed Food and Feed
4.2.2 Surveillance of Meat and Poultry
4.2.3 Total Diet Studies on Market Basket Samples
4.3

Pesticide Residues in Environmental Samples
4.3.1

Monitoring Studies in Fish/ Wildlife and Estuaries

4.3.2 Monitoring for Pesticides in Soil/ Water and Air
—— 4.4 Monitoring in Humans
-—— 4.5 Special Monitoring Programs
5.

INTERPRETATION OF RESIDUE DATA

*—"— 5.1 Variability among Samples
5.2

Sensitivity vs Limit of Detection

—— 5.3

Interpretation of Monitoring Data

—— 5.4

Confirmation of Residue Identity

— "• 5.5

Statistical Evaluation of Results

6.

CONCLUSION

7.

ACKNOWLEDGEMENT

8.

REFERENCES

�-4-

1.

INTRODUCTION

Requirements for analysis of pesticide residues have increased
vastly since the 1950's when regulations were first implemented to require tolerances (maximum residue limits) for these
useful chemicals in food crops intended for human and animal
consumption.

The evolution of changes in such requirements

can be traced in reviews published between 1955 and 1971 by
Gunther and Blinn

(1), Pogelman (2), Harris (3), Vorhes (4),

Frehse (5), Harris and Cummings (6), and Bevenue and Kawano (7).

In 1968/ the U.S. Food and Drug Administration issued FDA
Guidelines for Chemistry and Residue Data Requirements of
Pesticide Petitions (8).

These official guidelines described

the studies needed at that time for obtaining analytical data
suitable for establishment of tolerances for pesticides in food
and feed crops and their byproducts, as well as in meat, milk,
poultry and eggs.

During the early 1970's bills were passed in the U.S. House
and Senate proposing major revisions in the Federal Insecticide,
Fungicide/ and Rodenticide Act (FIFRA), resulting in passage
of the Federal Environmental Pesticide Control Act (FEPCA)
on October 8, 1972.

Detailed regulations for implementation

of Section 3 on Registration of Pesticides were finalized
by publication in the Federal Register on July 3, 1975 (9).

�-5-

At that time certain sections were "Reserved" for later issuance,
Registration Procedures were published as regulations on
September 9, 1975 (11).

A preliminary draft of sections on

Petitions for Tolerances (12) was made available by EPA in 1975
for comment by outside experts, but a revised version has not
been issued as of this writing.

Review of the draft indicated

that requirements for residue data by the Environmental Protection Agency (EPA) under FIPRA as amended will be similar but
more extensive than those outlined by FDA under the Food, Drug
(
and Cosmetic Act in' 1968 (8) .

Proposed guidelines for studies to meet Section 3 Regulations
were published in the Federal Register on June 25, 1975 along
with extensive appendices outlining how the studies should be
conducted (10).

Final guidelines are scheduled for publication

in 1977 incorporating revisions based on comments by other
government agencies, industry, and any interested parties.

This chapter presents a brief outline of how certain government agencies control.pesticides, of the laws under which they
operate, of regulations implemented to carry out this task,
and of how tolerances were established for the herbicide 2,4dichlorophenoxyacetic acid (2,4-D) over a period of 25 years
under these laws and regulations.

It also provides a detailed

description of current requirements for residue data based on

�proposed EPA Guidelines, based in part on personal experience
during more than ten years of compiling data in petitions
for tolerances, including many volumes on residue studies
with 2,4-D. Finally, it discusses monitoring studies for
pesticide residues in raw agricultural commodities, total
diet samples, and environmental samples, as well as pitfalls
in interpretation of "positive" findings.

�-78-

4.

MONITORING STUDIES

During the 1960's, concern grew about potential long-term
effects of persistent pesticides in the environment.

This

concern was fed in part by reports of finding residues of
DDT in samples such as pelicans, walruses, and even soil far
removed from where the insecticide had been used. The
impact of such reports has continued long after many of
the results of early studies have been refuted by more
specific analytical data. Positive findings originally
attributed to DDT have often been shown to be due to the
presence of PCB's (polychlorinated biphenyls) (48). More
recently, environmental and laboratory contamination by
phthalate esters has been shown to cause responses frequently
mistaken for DDT residues (49). Thus, it is imperative
that analytical methods used in monitoring for pesticides
are specific for the chemicals being sought and that positive
findings are confirmed by secondary methods based on different
principles of analysis.

4.1

NATIONAL PESTICIDES MONITORING PROGRAM

The National Pesticide Monitfsring Program (NPMP) was initially
designed on the basis of the minimum monitoring needed to
establish baseline levels of pesticideSvin substrates of food
and feed, humans, soil, water, air, wildlirX, fish and estuaries,

�-98-

Variables such as wihdjrain, temperature, snow, and inversion are unpredictable and sfr®nl.d be recorded during the
sampling period.

4-4

MONITORING IN HUMANS

Concern about potential long-term effects of persistent
chemicals led to the National Human Monitoring Program for
Pesticides.

In 1967, the Division of Pesticide Community

Studies initiated a program in which adipose tissue (fat)
was to be collected from postmortem and surgical specimens
(50).

The design provided for sampling which would yield

valid data concerning pesticide incidence variation with
geographic distribution, and with age, sex, and race variation of the donors.

The sampling population was drawn from sources in cities of
25,000 or more population (1960 figures) distributed among
the four census regions (Northeast, North Central, South,
and West), without regard for the donor's occupation.

The

total number of collection points (or pathologists) was
39 and each was to provide a minimum of 50 samples per year,
for an annual total of at least 1950 random samples.

For

each collection point, the sample quota was further broken
down by age and sex:

14 years and under, male and female;

15 through 49 years, male and female; and 50 years and over,
male and female.

Since the program objective was to reflect

�-99-

the incidences in the normal (man-on-the-street) general
population, samples were excluded from cases of known or
suspected acute pesticide poisoning or chronic debilitating
illness, and from patients who had been institutionalized
for long periods.

Analyses of human adipose tissue were initially limited to
the measurement of certain chlorinated hydrocarbons due to
sensitivity limitations of available analytical methodology.
The program originally included only DDT and its metabolites,
dieldrin, heptachlor epoxide, and the isomers of BHC. As
refinements of methodology progressed, additional pesticide
chemicals or metabolites were added such as oxichlordane
and mirex. Other pollutants such as PCB's (polychlorinated
biphenyls) were added as they became identifiable.

4.5

SPECIAL MONITORING PROGRAMS

Special programs are instituted as problems arise or are
suspected.

Many of these are a result of industrial pollution

or accidental contamination rather than from direct use of
pesticides.

One such example was a monitoring program for

mercury, or more specifically methyl mercury, in fish and
bottom sediments in the Great Lakes attributed to dumping
of wastes from giant electrolytic processes.

A more localized

�-100-

problem was contamination of cattle and poultry in Michigan
beginning in 1973 from ingestion of feed containing polybrominated biphenyls (PBB's).

Intensified programs are also put into operation when emergency
use of cancelled pesticides is authorized.

During recent

years, EPA has taken stepwise action against DDT, mirex,
aldrin and dieldrin, heptachlor and chlordane, and other
chlorinated hydrocarbons are expected to follow.

However,

in the absence of adequate substitutes, EPA occasionally
approves limited use of DDT to prevent spread of a specific
pest.

Similarly, EPA issued a permit in 1976 for aerial

application of mirex to control fire ants on six million
acres in Georgia, Mississippi, Louisiana, and Arkansas.
Scientists from APHIS will monitor water, soil, sediment,
invertebrates (crabs and crayfish), and vertebrates (mostly
birds) to determine the fate of residues in the non-target
environment.

Such monitoring programs using specific method-

ology should provide more reliable information on the persistence
of these useful pesticides in the environment.

Expansion of special programs is anticipated as EPA continues
to review data for other pesticides on their list of candidates for Rebuttable Presumption Against Registration (RPAR).
Several chlorinated phenols and phenoxy herbicides are included

�-101-

in the list, due in part to the presence of dioxin contaminants.
The most widely publicized of these is the herbicide 2,4,5trichlorophenoxyacetic acid (2,4,5-T), originally implicated
as a teratogen in screening studies at high doses in susceptible
strains of mice.

The 2,4,5-T used in the first teratogenic

studies by Bionetics (60) contained about 30 ppm of the
highly toxic 2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD).
This dioxin is formed during the manufacture of 2,4,5-trichlorophenol from tetrachlorobenzene at high temperatures
under alkaline conditions. Current specifications are for
less than 0.1 ppm TCDD in 2,4,5-T and other pesticides
derived from 2,4,5-trichlorophenol, such as the herbicide
silvex (2,4,5-trichlorophenoxypropionic acid) and the fungicide
hexachlorophene (2,2'-methylene bis(3,4,6-trichlorophenol)).

Cancellation proceedings against 2,4,5-T were withdrawn by
EPA in June 1974 pending results of extensive monitoring studies
for TCDD.

Analytical methods have been developed capable of

detecting residues down to 10 parts per trillion (0.00001 ppm)
or less in milk, fat, .and environmental samples (61, 62).
However, caution is needed in attributing positive responses at
this level to the actual presence of TCDD residues due to
interferences from unrelated substances in the same samples.

The TCDD monitoring program initially called for sampling
of many substrates including human milk, fat, and liver.

�-102-

Substrates most likely to contain residues were samples
taken from range cattle maintained in areas with a confirmed
history of repeated treatment with 2,4,5-T for many years,
and slaughtered without the usual fattening period in a
feed lot.

Samples of fat from these animals were distributed

to several cooperating laboratories including EPA and The
Dow Chemical Company. Preliminary results were erroneously
reported in 1975 to indicate "positive" results for about
50% of the initial 34 fat samples analyzed, but the findings
were not consistent among the laboratories conducting the
analyses.

As reported by Dr. Ralph T. Ross, Chairman of

the EPA Dioxin Project in June 1976 (63), only one of the
85 beef fat samples analyzed showed a positive TCDD level
at 60 ppt, and two samples appeared to have TCDD levels
at 20 ppt. He also stated that the analytical method is
not valid below 10 ppt.

The method used in the above analyses involves use of gas
chromatographic separation to remove interfering substances,
in combination with high resolution mass spectrometry for
quantitation.

This method has also been used to analyze other

monitoring samples collected by Dow. As reported by Shadoff
in 1975 (64), no residues of TCDD were detected in samples
of fish, water and mud from two locations in Arkansas and
Texas that have a long history of treatment with 2,4,5-T

�-103-

containing considerably more than the current limit of 0.1 ppm
TCDD.

Thus, it seems unlikely that continued use of 2,4,5-T

would result in significant residues of TCDD in the environment.
Addendum, July 1978
Reports of the study by Shadoff et al. (above) and of two studies on
surveillance samples of milk and beef fat were published in 1977 and 1978.
Summaries of these studies are quoted below.
Summary -' As part of a broad study to determine whether 2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD) is accumulating in the environment due to
approved uses of 2,4,5-trichlorophenoxyacetic acid (2,4,5-T) based herbicides,
samples of fish, water, mud and human milk were collected from areas in
Arkansas and Texas where 2,4,5-T herbicides are used and were analyzed for
TCDD. No TCDD was detected by a GC-MS procedure with a detection limit
which averaged less than 10 ppt.
2/
Conclusion •=* Surveillance samples of milk from the states of Oklahoma,
Arkansas, and Missouri were collected from cows grazing on pasture or
rangeland treated with normal applications of 2,4,5-T. These samples and
control samples were analyzed for TCDD by GC/MS. A detection limit of 1 ppt
was achieved. With this sensitivity the control samples were indistinguishable from those from treated areas. Hence, TCDD was not found.

3/
Summary — Specimens of fat taken from steers which had grazed on rangeland previously treated with 2,4,5-T herbicides were analyzed for the
presence of 2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD). A cleanup procedure
resulting in a 500-fold concentration was followed by a gas chromatographymass spectrometry detection technique. The limit of detection of TCDD
(2.5 times peak to peak noise) was found to be in the 30-60 picogram range
(3-6 ppt in beef fat using 10 gram samples).
None of the sixteen samples comprising two of the three studies showed any
response for TCDD. In the third study, in which the animals were confined
to a fenced pasture sprayed in its entirety with a 2,4,5-T herbicide, samples
from three of the seven animals gave a positive response at the extremely low
level of 3 to 4 ppt TCDD. which is'at the detection limit.

— Shadoff, L.A., Hummel, R.A., Lamparski, L., and Davidson, J.H. A Search for
2,3,7,8-Tetrachlorodibenzo-p-dioxin (TCDD) in an Environment Exposed Annually
to 2,4,5-Trichlorophenoxyacetic Acid Ester (2,4,5-T) Herbicides.
Bull. Environ. Contam. Toxicology 18_, 478-485, 1977.
2/
— Mahle, N.H., Higgins, H.S., and Getzendaner, M.E. Search for the Presence
of 2,3,7,8-Tetrachlorodibenzo-p-dioxin in Bovine Milk. Bull. Environ.
Contam. Toxicology 18., 123-130, 1977.

-^Kocher, C.W., Mahle, N.H., Hummel, R.A., Shadoff, L.A., and Getzendaner, M.E.
A Search for the Presence of 2,3,7,8-Tetrachlorodibenzo-p-dioxin in Beef Fat.
Bull. Environ. Contam, Toxicology, ]J9, 229-236, 1978.

�-104-

5.

INTERPRETATION OF RESIDUE DATA

Several basic principles should be applied in the interpretation of positive responses obtained in pesticide residue
analyses.

For example, a nanogram quantity of a pesticide in

a solvent may cause a measurable peak in a gas chromatogram.
However, the same quantity may not be distinguishable when
superimposed on the "noisy" background obtained from extracts
of a substrate.

Similarly a small peak from a treated sample

should not be compared directly to a large peak from a sample
spiked at a considerably higher level.

Recovery studies

should include complete analyses of several control samples
fortified at the claimed sensitivity of the method.

Any

"positive" responses below that should be reported as "less
than" or "traces".

A response below the limit of detection

should be reported as "none-detected" since it is not possible
to demonstrate a zero residue.

For example, a residue of
only 0.01 ppm DDT still represents 1013 molecules per gram
of foodstuff (65).

Above all, confirmation of residue identity

is needed before instrument responses can be translated into
positive values.

5.1

VARIABILITY AMONG SAMPLES

The inherent biological variation among individuals of the
same species can cause differences in response during
analysis which might be interpreted as positive residue

�-105-

values unless numerous samples were analyzed.

For example,

in a recent study reported by Clark et al, (66), residues of
several chlorinated hydrocarbon insecticides in fat of groups
of feedlot cattle were compared to the residues in the
feed given to them for 112 days prior to slaughter.

Both

feed and fat samples contained detectable levels of lindane,
dieldrin, DDT, DDE, and DDD. Except for dieldrin, each
insecticide was found at higher levels in fat than in feed.
However, the levels were consistently low except for DDT
and its degradation products in fat. Average values for
lindane were 0.002 ppm in feed and ranged from 0.014 ppm
to 0.032 ppm in fat of five groups of ten calves each given
various levels of ammonium salts in addition to the feed.
Average levels found for DDT were 0.083 ppm in feed and
ranged from 0.324 ± 0.256 ppm in fat from Group II to
0.518 ± 0.104 ppm in Group IV.

If only average values for

DDT are compared, a significant difference appears to exist
between Groups II and IV. However, overlap of values for
individuals in the two groups shows that they are not different (i.e., 0.324 +0.256 = 0.580 which is higher than
0.518 - 0.104 = 0.414) .'

5.2

SENSITIVITY VS LIMIT OF DETECTION

As discussed recently by the Federal Working Group on Pest
Management, the terms sensitivity and limit of detection do

�-106-

not have the same meaning (52).

Sensitivity depends on the

response of an instrument such as a gas chromatograph under
a specific set of conditions.

However, as the instrument

sensitivity is adjusted to a maximum, the baseline "noise"
level generally increases too.

The response due to a pesti-

cide residue can be considered significant only if the peak
height at the maximum usable sensitivity is twice the peakto-peak height of the noise on the chart.

Operation of the

instrument at less than maximum sensitivity may be preferable,
particularly for comparative analyses in different laboratories,
For example, FDA analysts set instruments to give 50% of
full scale recorder deflection on injection of one nanogram
of heptachlor epoxide or two nanograms of parathion to assure
that each laboratory operates at the same sensitivity.

On the other hand, the limit o_f detection of an analytical
method may be defined as the concentration of pesticide
above which a given sample of material can be said, with
a high degree of confidence, to actually contain the chemical
analyzed.

This limit of detection depends upon a number of

factors in addition to the instrument sensitivity, including
sample size, adequacy of extraction and cleanup, size of
aliquot injected, and knowledge and experience of the
analyst.

Deviations in peaks or baselines caused by inade-

quate cleanup are more evident when the instrument is
operated at maximum sensitivity.

These deviations may

�-107-

cast doubt on the validity of the peaks of interest in
assigning positive values for specific residues.

Sutherland has reviewed the analytical limit of detectability
for residues (67) . For all practical purposes, the response
of control samples to a specified analytical method is the
sole determinant of the limit of detectability.

However,

these control samples must be taken from plants or animals
exactly comparable to the treated samples.

They must be

sampled at the same time, from identical varieties of the
same degree of maturity, and must have been treated in all
respects the same as the treated samples except that the
chemical to be determined must not have been used on them.
Furthermore, the samples must be independent and normally
distributed according to statistical definitions.

The responses

given by, or apparent residues found in these control samples
will usually follow a bell-shaped distribution curve.
average of all samples analyzed will be the true mean.

The
An

old rule-of-thumb was that any uncorrected residue value
greater than twice the average control represented a real
residue (65) . However, this is not necessarily so depending
on the spread of the frequency distribution around the mean
for that substrate.

Hahn has recently discussed the conse-

quences of incorrectly assuming that distribution is normal
about the mean (68).

�-108-

Even greater care must be taken in interpreting data for
extremely low residues of highly toxic chemicals in the
environment.

This was demonstrated following collaborative

studies on TCDD conducted as part of the EPA Dioxin Implementation Plan in 1976.

Agreement was reached among

scientists from EPA, USDA, Harvard, University of Utah
and Dow that it takes a response of 2.5 times background
noise to indicate a positive finding.

Furthermore, it takes

a response of 10 times background noise before quantitative
values at low parts per trillion can be assigned.

5.3

INTERPRETATION OF MONITORING DATA

Unfortunately, analysts conducting monitoring studies do
not have the benefit of comparisons to control samples
because samples reliably free from pesticides are usually
not available.

In such cases, the limit of detection is

based on the analytical variability for each pesticide on
each substrate, generally by carrying through the entire
method at least six replicate samples containing levels near
the estimated limit of detection of the pesticide (52).
Under these conditions, the limit of detection is considered
equal to two standard deviations (approximately 95% confidence
level) calculated from the replicated results.

The identity

of any peak larger than this should be subject to confirmation

�-109-

as discussed in Section 5.4, but practical limitations
preclude confirmation of most "positive" values.

Although variability among analyses of six replicates may
be adequate for samples of certain species of plants or
animal tissues, it may not be adequate to establish a
reliable baseline for samples of soil or water from widely
divergent geographical locations subjected to contamination
by a great variety of chemicals.

Unfortunately, some chemists

do not recognize such limitations and interpret any positive
response similar to that produced by a pesticide as proof
that a residue is present.

Furthermore, reports of moni-

toring studies tend to emphasize the frequency of positive
responses without regard to the significance of the "residues"
found.

One such report issued in 1973 was entitled Pesticides in
Selected Western Streams —

1968-1971 (69).

It gave results

of analyses by the U.S. Geological Survey for nine chlorinated
hydrocarbon insecticides and three phenoxy herbicides in
water from twenty locations in fourteen states.

The authors

reported "total occurrence (of phenoxy residues) reached a
peak of 106 during 1968-69 and declined sharply to 54 during
1970-71.

This decrease of about 50% was due to 'reduced

occurrences of 2,4-D and 2,4,5-T1."

Examination of the

lengthy data tables revealed that traces of phenoxy herbicides

�-110-

amounting to less than 0.0005 ppm (0.5 part per billion)
appeared to be present in about 16% of the samples for 2,4-D
and 2,4,5-T and 7% of the samples for silvex. Furthermore,
four-fifths of the positive findings were at levels below
0.1 part per billion (ppb). The detected limits were listed
at 0.005 yg/liter for silvex and 2,4,5-T and 0.02 yg/liter
for 2,4-D (i.e., a sensitivity of 5 to 20 parts per trillion).
Recoveries of 80 to 100% were claimed for validation studies
but the spiking levels were not specified and may not have
approached the claimed sensitivity.

Furthermore, confirmatory

analyses for phenoxy compounds were" not mentioned although
other methods or other columns were discussed for confirmation
of the insecticides found.

The report also stated that 64% of the silvex occurrences were
at one station in Nevada and 47% of the 2,4,5-T occurrences
were in two associated sites in Arkansas and Oklahoma.

In

view of the localization of positive findings, it is possible
that the parts per trillion residues "found" may have been
due to the presence of interfering substances in samples
from these locations rather than to actual residues of silvex
or 2,4,5-T in the water.

Unfortunately, the report has been

cited as evidence of widespread contamination of water by
these controversial herbicides in Western States.

�-111Another example is a paper in the September 1974 issue of
Bulletin of Environmental Contamination and Toxicology (70).
A total of 13 authors summarize studies on the distribution
of pesticides in randomly selected soil samples taken from
diverse environments in five west Alabama counties.

Pesti-

cide residues were found in all samples examined/ even soil
samples from areas where records indicated that no pesticides
had been applied directly.

The pesticides included eleven

chlorinated hydrocarbon insecticides, six nonchlorinated
insecticides, and two herbicides (atrazine and 2,4,5-T).
They reported finding 2,4,5-T in 24% of the samples of top
soil analyzed.

Examination of the data revealed that 37

samples of top soil contained no detectable residues (sensitivity not specified) and only one sample containing more
than 0.1 ppm 2,4,5-T.

The samples were analyzed twice by

GLC using two columns.

No analytical data were provided

to indicate reliability for the eight samples reported as
"positive" at &lt;0.1 ppm.

Unfortunately, such data are used

as evidence of persistence of pesticides in the environment.

The above examples also demonstrate the pitfalls in drawing
conclusions from reports which emphasize the maximum residue
found or the percent "positive" samples without adequate
allowance for variations in background "noise".

This becomes

even more important in special monitoring programs for highly

�-112-

toxic chemicals at extremely low levels.

An example dis-

cussed previously was the premature release of preliminary
data from, analyses for TCDD at levels around 10 parts per
trillion in beef fat which could be construed by some as
sufficient evidence that 2,4,5-T and related pesticides
should be banned (63).

5.4

CONFIRMATION OF RESIDUE IDENTITY

Residue analyses without confirmatory tests provide only
qualitative information.

It is not safe to assume that a

response similar to that produced by a known pesticide means
the pesticide is actually present.

Many instances have been

noted in which one material masquerades as another in any
one test (e.g. PCB's, phthalate esters, etc.).

The certainty

of identification is increased when the behavior of the
unknown and the standard is the same in a number of tests.

Subscribers to Pesticides Monitoring Journal received a
June 1975 issue entitled Guidelines on Analytical Methodology
for Pesticide Residue Monitoring (52).

The following specific

guidelines on confirmation of residue identity were listed:

Residues reported should be confirmed by tests such
as TLC, element specific GCf p-value determinations,
derivatization, ultraviolet photolysis, etc., in addition
to EC-GC.

�-113-

PCB's or other suspected complex interfering substances must be separated and confirmed.

Combinations of confirmatory tests that measure the
same physical property parameters as tests that measure
the same parameters as the initial analysis, although
they may help to support the identification, are not
the best means of doing so.

If sufficient material

is available/ excellent identifications can be made
by infrared spectrometry, particularly with the use
of microcell techniques or Attenuated Total Reflectance.

Mass spectrometry (MS) or combined GC-MS is recommended
for identifying or confirming identity of important
residues not adequately identified by other techniques.

The methods used for confirming residue identity should
always be described in the report of residue results.

Although some laboratories may not have time to confirm every
residue tentatively identified by &lt;3C, confirmatory analyses
should be conducted at intervals such as one in every five
samples when the same residues are apparently present throughout the group.

When insufficient sample is available, con-

firmatory analyses may be conducted on a pool of several
cleaned up sample extracts.

�-114-

5.5

STATISTICAL EVALUATION OF RESULTS

The Federal Working Group on Pest Management also differentiates between accuracy and precision of pesticide residue
analyses (52).

Accuracy involves statistical measurements

that relate to the differences between the test results and
the true result when the latter is known or assumed, and
may be expressed as the mean error or relative error.

Preci-

sion involves statistical measurements that relate to the
variation among test results themselves —

i.e., the scatter

or dispersion of a series of test results without assumption
of any prior information as to the true result.

Precision

may be expressed in terms of the variance, standard deviation,
relative standard deviation, range, etc.

Values from single

or duplicate injections of extracts from duplicate samples
are more meaningful than values from multiple injections
from single samples.

These should be differentiated in

evaluating differences among groups of data.

As noted in Section 3.1.1, pesticide residue methods are
often subjected to collaborative studies through the Association of Official Analytical Chemists (AOAC).

These studies

evaluate specificity, repeatability, and reproducibility
of independent analyses for various samples.

Repeatabi1ity

is a measure of how well an analyst can expect to agree with

�-115-

himself from day to day, whereas reproducib i 1i ty is how well
analyses in one laboratory are likely to agree with results
from other laboratories.

The Statistical Manual of the

AOAC presents excellent information on formulating and
statistically analyzing collaborative studies (71).

�-116-

6.

CONCLUSION

The regulation of pesticides involves .a complex maze of
rules implemented by various government agencies in their
everchanging interpretation of laws enacted and amended by
the U.S. congress to control the use of such chemicals.

Two

basic elements in these laws are that all pesticide products
must be registered and that tolerances must be set for safe
residue limits of all pesticides used in food or feed crops.
Requirements for residue data in support of these tolerances
are discussed in Section 3.

Monitoring studies are conducted

by groups within several government agencies to assure that
excessive residues are not present in foods or accumulating
in the environment, as discussed in Section 4.

The importance

of careful interpretation of residue data is discussed in
Section 5 of this chapter.

Concern about the significance of monitoring data was expressed at a 1973 hearing on EPA studies of specific chemicals
in estuarine and freshwater environments.

At that time the

agency's Hazardous Materials Advisory Committee was told that
virtually all measurements of DDT in the environment were
suspect due to interferences in the analyses (72) . Early
data did not distinguish between DDT and residues of PCB's
used extensively in transformer fluids, etc. (48, 52).

�-117-

Furthermore, phthalate esters used widely as plasticizers
accompany DDT through virtually all clean-up procedures
according to D. G. Crosby of the University of California (49),
Crosby also reported that interferences have been a major
factor in chemical analyses for arsenic residues, and for
mercury and phenoxy herbicides such as 2,4-D and 2,4,5-T.

Responsibilities in the use and misuse of scientific data
were discussed during a symposium of the American Association
for the Advancement of Science (AAAS) at their national meeting in New York in 1975.

It was concluded that responsi-

bility for proper reporting of data lies with individual
scientists/ scientific societies, and publishers. One of
the speakers, Dr. Richard W. Roberts, director of the National
Bureau of Standards, estimated that at least half of the
data reported in scientific literature are unusable, often
because too little information has been provided for inde. pendent evaluations (73) . Dr. Mary L. Good, a director
of the American Chemical Society, cited four areas in need
of responsible attention:

determination of permissible

levels of potentially dangerous materials in the biosphere,
lack of information on error limits and credibility of
published data, overmassage or excessive manipulation of
raw data by computer techniques, and evaluation and use
of computerized data banks. Also, care must be taken to

�-118-

delineate between those parts of reports that are factual
and can be repeated by other workers and those reflecting
interpretation of the data (74).

Dr. Bernard L. Oser entitled his presentation Exaggerated
Conclusions Based on Inadequate Data (75).

He defined

scientific data as observations and findings generally
expressed in numerical or descriptive terms and stated
that, even when correctly reported/ "data" are not necessarily
equatable with "facts".

Implicit in the term "facts" are

the accuracy and reproducibility of findings and the competence and integrity of those responsible for the design,
execution, and interpretation of the studies.

Data are

often statistically manipulated or "staticulated", such as
by use of average values without expressing the range or
distribution around the mean.

Scientists may also draw

false or misleading conclusions from their own data or from
that of others.

This may take the form of overestimating

the importance of uncorroborated findings, or as one writer
expressed it, extrapolation of unproven speculations.

Thus,

problems arise from misuse of scientific data as well as
from use of unscientific data.

Emphasis in this chapter has been on the care needed in conducting analyses for pesticide residues at sub-part-per-million

�•119-

levels in a variety of substrates, of the need for adequate
reporting of such residue data, and of pitfalls in interpretation of data at levels below the validated sensitivity
of the method.

More specificity is needed rather than

"picogram" measurements as often pushed by the scientific
community.

Premature or unwise interpretation of data can

lead to precipitous action by regulatory agencies who have
to respond to public pressures from individuals or groups
of persons.

Unfortunately, most pressure comes from lawyers

and politicians who do not comprehend the limitations of
pesticide residue analyses, particularly when the identity
of the residues "found" has not been adequately confirmed.

�-121-

8.

1.

REFERENCES

F. A. Gunther and R. C. Blinn, Analysis of Insecticides
*

and Acaricides-.

Vol. VI in'Chemical Analysis Series,

Interscience, New York-London, 1955.

2.

R. W. Fogelman, J. Agr. Food Chem. £, 410 (1956).

3.

T. H. Harris, J. Agr. Food Chem. 4,, 413 (1956).

4.

F. A. Vorhes, Jr., J. Agr. Food Chem. £, 415 (1956).

5. H. Frehse, Residue Reviews J5, 1 (1964) .

6. T. H. Harris and J. G. Cummings, Residue Reviews j&gt;, 104
(1964).

7. A. Bevenue and Y. Kawano, Residue Reviews 35, 103 (1971) .

8.

FDA Guidelines for Chemistry and Residue Data Requirements
of Pesticide Petitions, Bureau of Science, Food and Drug
Administration, Dept. of Health, Education, and Welfare,
Washington, D.C. 20204, March 1968.

�-128-

47. Handbook for Authors of Papers in the Journals of the
American chemical Society, American Chemical Society
Publications, Washington, D.C. (1967).

48. J. H. Ruzicka, "Methods and Problems in Analyzing for
Pesticide Residues in the Environment" in Environmental
Pollution by Pesticides, ed. by C. A. Edwards, Plenum
Press, New York, 1973.

49. D. G. Crosby - Statement before EPA's Hazardous Materials
Advisory committee, Pesticide Chemical News 1 (45), 6
(October 17, 1973).

50. National Pesticides Monitoring Program (Revised), Pest.
Monit. J. 5, 35 (1971).

51. Federal Working Group on Pest Management, Guidelines on
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Protecting the Public and the Environment from Pesticide
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F. A. Gunther, Adv. Pest. Control Research 5, 222 (1962).

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D. E. Clark, H. E. Smalley, H. R. Crookshank, and F. M.
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*(No.) CRF is Title (No.) of the Code of Federal Regulations,
(No.) FR is Volume (No.) of the Federal Register.

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                  <text>&lt;p style="margin-top: -1em; line-height: 1.2em;"&gt;The Alvin L. Young Collection on Agent Orange comprises 120 linear feet and spans the late 1800s to 2005; however, the bulk of the coverage is from the 1960s to the 1980s and there are many undated items. The collection was donated to Special Collections of the National Agricultural Library in 1985 by Dr. Alvin L. Young (1942- ). Dr. Young developed the collection as he conducted extensive research on the military defoliant Agent Orange. The collection is in good condition and includes letters, memoranda, books, reports, press releases, journal and newspaper clippings, field logs and notebooks, newsletters, maps, booklets and pamphlets, photographs, memorabilia, and audiotapes of an interview with Dr. Young.&lt;/p&gt;&#13;
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