Determination of Presumption of Service Connection Concerning Illnesses Discussed in National Academy of Sciences Report on Gulf War and Health, 50856-50869 [E8-19971]
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FOR FURTHER INFORMATION CONTACT:
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BILLING CODE 6720–01–P
DEPARTMENT OF VETERANS
AFFAIRS
Determination of Presumption of
Service Connection Concerning
Illnesses Discussed in National
Academy of Sciences Report on Gulf
War and Health
ACTION:
Department of Veterans Affairs.
Notice.
SUMMARY: As required by law, the
Department of Veterans Affairs (VA)
hereby gives notice that the Secretary of
Veterans Affairs, under the authority
granted by the Persian Gulf War
Veterans Act of 1998, Public Law 105–
277, title XVI, 112 Stat. 2681–742
through 2681–749 (codified in part at 38
U.S.C. 1118), has determined that there
is no basis to establish a presumption of
service connection at this time for any
of the diseases, illnesses, or health
effects discussed in the December 20,
2004, report of the National Academy of
Science, titled ‘‘Gulf War and Health,
Volume 3. Fuels, Combustion Products,
and Propellants’’ based on exposure to
fuels, combustion products, or
propellants during service in the Persian
Gulf during the Persian Gulf War. This
determination does not in any way
preclude VA from granting service
connection for any disease, including
those specifically discussed in this
notice, nor does it change any existing
rights or procedures.
FOR FURTHER INFORMATION CONTACT:
Rhonda F. Ford, Chief, Regulations Staff
(211D), Compensation and Pension
Service, Veterans Benefits
Administration, Department of Veterans
Affairs, 810 Vermont Avenue, NW.,
Washington, DC 20420, (202) 461–9739.
SUPPLEMENTARY INFORMATION:
I. Statutory Requirements
The Persian Gulf War Veterans Act of
1998, Public Law 105–277, title XVI,
112 Stat. 2681–742 through 2681–749
(codified at 38 U.S.C. 1118), and the
Veterans Programs Enhancement Act of
1998, Public Law 105–368, 112 Stat.
3315, directed the Secretary to seek to
enter into an agreement with the
National Academy of Sciences (NAS) to
review and evaluate the available
scientific evidence regarding
associations between illnesses and
exposure to toxic agents, environmental
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or wartime hazards, or preventive
medicines or vaccines to which service
members may have been exposed during
service in the Persian Gulf during the
Gulf War. Congress directed NAS to
identify agents, hazards, medicines, and
vaccines to which service members may
have been exposed during service in the
Persian Gulf during the Gulf War.
Congress mandated that NAS
determine, to the extent possible: (1)
Whether there is a statistical association
between exposure to the agent, hazard,
medicine, or vaccine and the illness,
taking into account the strength of the
scientific evidence and the
appropriateness of the scientific
methodology used to detect the
association; (2) the increased risk of
illness among individuals exposed to
the agent, hazard, medicine, or vaccine;
and (3) whether a plausible biological
mechanism or other evidence of a causal
relationship exists between exposure to
the agent, hazard, medicine, or vaccine
and the illness.
Section 1118 provides that whenever
the Secretary determines, based on
sound medical and scientific evidence,
that a positive association (i.e., the
credible evidence for the association is
equal to or outweighs the credible
evidence against the association) exists
between exposure of humans or animals
to a biological, chemical, or other toxic
agent, environmental or wartime hazard,
or preventive medicine or vaccine
known or presumed to be associated
with service in the Southwest Asia
theater of operations during the Persian
Gulf War and the occurrence of a
diagnosed or undiagnosed illness in
humans or animals, the Secretary will
publish regulations establishing
presumptive service connection for that
illness. If the Secretary determines that
a presumption of service connection is
not warranted, the Secretary is to
publish a notice of that determination,
including an explanation of the
scientific basis for that determination.
The Secretary’s determination must be
based on consideration of the NAS
reports and all other sound medical and
scientific information and analysis
available to the Secretary.
Although section 1118 does not
define ‘‘credible evidence,’’ it does
instruct the Secretary to take into
consideration whether the results (of
any report, information, or analysis) are
statistically significant, are capable or
replication, and withstand peer review.
See 38 U.S.C. 1118(b)(2)B). Simply
comparing the number of studies that
report a significantly increased relative
risk to the number of studies that report
a relative risk that is not significantly
increased is not a valid method for
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determining whether the weight of
evidence overall supports a finding that
there is or is not a positive association
between exposure to an agent, hazard,
or medicine or vaccine and the
subsequent development of the
particular illness. Because of differences
in statistical significance, confidence
levels, control for confounding factors,
and other pertinent characteristics,
some studies are clearly more credible
than others, and the Secretary has given
the more credible studies more weight
in evaluating the overall weight of the
evidence concerning specific illnesses.
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II. Prior National Academy of Sciences
Reports
NAS issued its initial report titled,
Gulf War and Health, Volume 1:
‘‘Depleted Uranium, Sarin,
Pyridostigmine Bromide, Vaccines,’’ on
January 1, 2000. In that report, NAS
limited its analysis to the health effects
of depleted uranium, the chemical
warfare agent sarin, vaccinations against
botulism toxin and anthrax, and
pyridostigmine bromide, which was
used in the Gulf War as a pretreatment
for possible exposure to nerve agents.
On July 6, 2001, VA published a notice
in the Federal Register announcing the
Secretary’s determination that the
available evidence did not warrant a
presumption of service connection for
any disease discussed in that report. See
66 FR 35702 (2001).
NAS issued its second report titled,
‘‘Gulf War and Health, Volume 2:
Insecticides and Solvents,’’ on February
18, 2003. In that report, NAS focused on
the health effects of insecticides and
solvents that were shipped to the
Persian Gulf during the Persian Gulf
War. The pesticides considered by NAS
were organophosphorous compounds
(malathion, diazinon, chlorpyrifos,
dichlorvos, and azamethiphos),
carbamates (carbaryl, propoxur, and
methomyl), pyrethrins and pyrethyroids
(permethrin and d-phenothrin), lindane,
and N,N-diethyl-3-methylbenzamide
(DEET). NAS considered 53 solvents in
eight groups: Aromatic hydrocarbons
(including benzene), halogenated
hydrocarbons (including
tetrachloroethylene and dry-cleaning
solvents), alcohols, glycols, glycol
esters, esters, ketones, and petroleum
distillates. On August 24, 2007, VA
published a notice in the Federal
Register announcing the Secretary’s
determination that the available
evidence did not warrant a presumption
of service connection for any disease
discussed in that report. 72 FR 48734
(2007).
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III. Gulf War and Health, Volume 3.
Fuels, Combustion Products, and
Propellants
NAS issued a third report, titled ‘‘Gulf
War and Health, Volume 3. Fuels,
Combustion Products, and Propellants,’’
on December 20, 2004. In that report,
NAS focused on the health effects of
hydrazines, red fuming nitric acid,
hydrogen sulfide, oil-fire byproducts,
diesel-heater fumes, and fuels (for
example, jet fuel and gasoline).
In its report, NAS classified the
evidence of an association between
exposure to a specific agent and a
specific health outcome into five
categories:
• Sufficient Evidence of a Causal
Association: This category means the
evidence is sufficient to conclude that
there is a causal association between
exposure to a specific agent and a
specific health outcome in humans. The
evidence is supported by experimental
data and fulfills the guidelines for
sufficient evidence of an association.
The evidence must be biologically
plausible and satisfy several of the
guidelines used to assess causality, such
as: Strength of association, doseresponse relationship, consistency of
association, and a temporal relationship.
NAS did not find any health
outcomes that met the criteria for this
category.
• Sufficient Evidence of an
Association: This category means the
evidence is sufficient to conclude that a
consistent association has been
observed between exposure to a specific
agent and a specific health outcome in
human studies in which chance and
bias, including confounding, could be
ruled out with reasonable confidence.
For example, several high-quality
studies report consistent associations,
and the studies are sufficiently free of
bias, including adequate control for
confounding.
NAS found sufficient evidence of an
association between exposure to
combustion products and lung cancer.
• Limited/Suggestive Evidence of an
Association: This category means the
evidence is suggestive of an association
between exposure to a specific agent
and a specific health outcome, but the
body of evidence is limited by the
inability to rule out chance and bias,
including confounding, with
confidence. For example, at least one
high-quality study reports an
association that is sufficiently free of
bias, including adequate control for
confounding. Other corroborating
studies provide support for the
association, but they were not
sufficiently free of bias, including
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confounding. Alternatively, several
studies of lower quality show consistent
associations, and the results are
probably not due to bias, including
confounding.
NAS found limited/suggestive
evidence of an association between
exposure to combustion products and
cancers of the nasal cavity and
nasopharynx; cancers of the oral cavity
and oropharynx; laryngeal cancer;
bladder cancer; low birthweight/
intrauterine growth retardation (with
exposure during pregnancy); preterm
birth (with exposure during pregnancy);
and incident asthma.
NAS found limited/suggestive
evidence of an association between
exposure to hydrazines and lung cancer.
• Inadequate/Insufficient Evidence:
This category means the evidence is of
insufficient quantity, quality, or
consistency to permit a conclusion
regarding the existence of an association
between exposure to a specific agent
and a specific health outcome in
humans.
NAS found inadequate/insufficient
evidence of an association between
exposure to fuels and cancers of the oral
cavity and oropharynx; cancers of the
nasal cavity and nasopharynx;
esophageal cancer; stomach cancer;
colon cancer; rectal cancer; hepatic
cancer; pancreatic cancer; laryngeal
cancer; lung cancer; melanoma;
nonmelanoma skin cancer; female breast
cancer; male breast cancer; female
genital cancers (cervical, endometrial,
uterine, and ovarian cancers); prostatic
cancer; testicular cancer; nervous
system cancers; kidney cancer; bladder
cancer; Hodgkin’s disease; nonHodgkin’s lymphoma; multiple
myeloma; myelodysplastic syndromes;
adverse reproductive or developmental
outcomes (including infertility,
spontaneous abortion, childhood
leukemia, central nervous system (CNS)
tumors, neuroblastoma, and PraderWilli syndrome); peripheral neuropathy;
neurobehavioral effects; Multiple
Chemical Sensitivity symptoms;
nonmalignant respiratory disease;
chronic bronchitis; asthma; emphysema;
dermatitis (irritant and allergic); and
sarcoidosis.
NAS found inadequate/insufficient
evidence of an association between
exposure to combustion products and
esophageal cancer; stomach cancer;
colon cancer; rectal cancer; hepatic
cancer; pancreatic cancer; melanoma;
female breast cancer; male breast cancer;
female genital cancers (cervical,
endometrial, uterine, and ovarian
cancers); prostatic cancer; testicular
cancer; nervous system cancers; ocular
melanoma; kidney cancer; non-
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Hodgkin’s lymphoma; Hodgkin’s
disease; multiple myeloma, leukemia;
myelodysplastic syndromes; preterm
births (based on exposure during a
specific time period during pregnancy,
such as the first trimester); low birth
weight and intrauterine growth
retardation (based on exposure before
gestation or during a specific period
during pregnancy, such as the first
trimester); specific birth defects,
including cardiac effects (with maternal
or paternal exposure before conception
or maternal exposure during early
pregnancy); all childhood cancers
identified, including acute lymphocytic
leukemia, leukemia, neuroblastoma, and
brain cancer; neurobehavioral effects;
post-traumatic stress disorder; nervous
system subgroupings (or individual
nervous system diseases); Multiple
Chemical Sensitivity symptoms; chronic
bronchitis (less than 1 year of exposure);
emphysema; chronic obstructive
pulmonary disease; ischemic heart
disease or myocardial infarction (less
than 2 years of exposure); dermatitis
(irritant and allergic); and sarcoidosis.
NAS found inadequate/insufficient
evidence of an association between
exposure to hydrazines and
hematopoietic and lymphopoietic
cancers; digestive tract cancers;
pancreatic cancer; bladder cancer;
kidney cancer; emphysema; ischemic
heart disease or myocardial infarction;
and hepatic disease.
NAS found inadequate/insufficient
evidence of an association between
exposure to nitric acid and stomach
cancer; melanoma; lymphopoietic
cancers; pancreatic cancer; laryngeal
cancer; lung cancer; bladder cancer;
multiple myeloma; and cardiovascular
diseases.
• Limited/Suggestive Evidence of No
Association: This category means the
evidence is consistent in not showing an
association between exposure to a
specific agent and a specific health
outcome after exposure of any
magnitude. A conclusion of no
association is inevitably limited to the
conditions, magnitudes of exposure, and
length of observation in the available
studies. The possibility of a very small
increase in risk after exposure studied
cannot be excluded.
NAS did not find any health
outcomes that met the criteria for this
category.
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A. Combustion Products
1. Sufficient Evidence of an Association
NAS found sufficient evidence of an
association between combustion
products and lung cancer. NAS found
that there was evidence of associations
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between exposure to ambient air
pollution, engine exhausts, and heating
sources (coal) and lung cancer. Cohort
and case-control studies showed
consistently that risks increased with
increasing ambient air pollution. There
was evidence from both cohort and case
control studies that increasing exposure
to engine exhausts and its components
such as polycyclic aromatic
hydrocarbons (PAHs) increased the risk
of lung cancer.
Based on 82 epidemiological studies,
NAS derived a positive finding of
‘‘sufficient evidence of an association’’
between exposure to combustion
products and lung cancer. The
epidemiological studies included cohort
studies on the health effects of ambient
air pollution on people dwelling in
cities, workers exposed to motor vehicle
exhaust, and case-control studies of
lung cancer patients. The case-control
studies were of lung cancer patients
who were exposed in their occupation,
or in their homes or daily lives to indoor
air pollution from combustion products
from wood, coal, kerosene or gas
burning stoves or heaters over years.
Relevant occupational exposures
included working as a bus, taxi, or truck
driver, or as a miner or railroad worker.
NAS pointed out that lung cancer
from all causes is the leading cause of
cancer death among both men and
women, and that smoking may be
responsible for 80% of lung cancer
cases. Nevertheless, NAS concluded
that ‘‘there was evidence of associations
between exposure to ambient air
pollution, engine exhausts, and heating
sources (coal) and lung cancer.’’ Cohort
and case-control studies showed
consistently that risks increased with
increasing ambient air pollution. There
was evidence from both cohort and
case-control studies that increasing
exposure to engine exhausts and to its
components increased the risk of lung
cancer.
The Secretary has determined that,
although there is sufficient evidence of
an association between combustion
products and lung cancer, VA does not
consider this exposure to be ‘‘associated
with’’ the 1991 Gulf War. Please see
section IV for further detail.
2. Limited/Suggestive Evidence of an
Association
NAS found limited/suggestive
evidence of an association between
exposure to combustion products and
cancers of the nasal cavity and
nasopharynx; cancers of the oral cavity
and oropharynx; laryngeal cancer;
bladder cancer; low birthweight/
intrauterine growth retardation and
exposure during pregnancy; preterm
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birth and exposure during pregnancy;
and incident asthma.
The results of the studies of the
relationship between combustion
products and cancers of the nasal cavity
and nasopharynx were inconsistent, and
indirect methods were used to assess
exposure. However, positive
associations were reported between
combustion products (particularly wood
smoke) and cancer of the nasopharynx.
NAS’s positive finding of ‘‘limited/
suggestive evidence of an association’’
between exposure to combustion
products and cancers of the nasal cavity
and nasopharynx was based on 4
epidemiological case-control studies.
These studies involved patients with
nasal cavity and nasopharynx cancer,
who were exposed regularly to
combustion products, by virtue of their
occupation or in their daily lives, over
many years. Relevant exposures
included exposure to fumes from the
burning of wood and other materials,
use of fuels, and occupational exposures
such as working as a motor vehicle
driver. Although NAS found these
studies showed inconsistent results,
they concluded that positive
associations were reported by studies
conducted in China between
combustion products (particularly wood
smoke) and cancer of the nasopharnyx.
NAS’s positive finding of ‘‘limited/
suggestive evidence of an association’’
between exposure to combustion
products and cancers of the oral cavity
and oropharynx was based on 9
epidemiological case-control studies.
These epidemiological studies were of
oral cavity and oropharynx cancer
patients who were exposed to ambient
air pollution in the cities where they
lived, or who were exposed over many
years due to their occupation or to
indoor pollution in their homes due to
combustion products from wood, coal,
kerosene or gas burning stoves or
heaters. Occupational exposures
included working as a motor vehicle
driver or railroad employee. NAS
concluded that results of several studies
suggested an association between
cancers of the oral cavity and
oropharynx and exposure to combustion
products.
NAS’s positive finding of ‘‘limited/
suggestive evidence of an association’’
between exposure to combustion
products and laryngeal cancer was
based on one epidemiological cohort
study of workers exposed to diesel
exhaust, and 16 epidemiological casecontrol studies of patients with
laryngeal cancer. These studies involved
people who were exposed to
combustion products due to their
occupations as railway workers, motor
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vehicle drivers, or as city commuters
exposed to ambient air pollution. The
studies also included people who used
wood and other fuel burning stoves
regularly. Several studies reported
positive findings, including two studies
regarding exposure to the emissions of
fossil-fuel stoves and one study
regarding exposure to wood-stove
emissions. Several studies reported
small increases in laryngeal-cancer risk
for some exposures; however, overall,
the results were inconsistent. NAS
concluded that the epidemiologic
literature overall provided limited/
suggestive evidence of an association
between exposure to combustion
products and laryngeal cancer.
NAS found ‘‘limited/suggestive
evidence of an association’’ between
exposure to combustion products and
bladder cancer. Studies that assessed
the relationship between exposure to
combustion products and bladder
cancer have not been consistently
positive, and no studies assessed
measurements of exposure. One pooled
analysis of occupational exposures
found questionably increased risks in
exhaust-related occupations, and the
risk was increased with higher
exposures to polycyclic aromatic
hydrocarbons (PAHs) and benzopyrene,
which are combustion products. A
slightly increased risk was observed for
diesel exhaust. In a related study,
similar findings were noted with some
exposures to exhausts and PAHs. A
more detailed assessment of PAH
exposures based on expert review of
work-history information found
apparently stable associations with
average and cumulative PAH exposures
and total duration of PAH exposures.
Taken together, the results constituted
limited or suggestive evidence of an
association between combustion
products and bladder cancer, but the
lack of exposure measurements and the
heterogeneity of results precludes
classifying the association as sufficient.
NAS’s positive finding of ‘‘limited/
suggestive evidence of an association’’
between exposure to combustion
products during pregnancy and low
birthweight or intrauterine growth
retardation was based on 8
epidemiological studies of pregnant
women. These women were exposed to
ambient air pollution ‘‘smog’’ in heavily
polluted cities in the Czech Republic
where coal was burned, and in urban
cities located in South Korea, China,
Canada, and the United States.
Two studies found evidence of a
relationship between low birthweight or
intrauterine growth retardation and
combustion-product exposure. Their
analyses controlled for several known
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risk factors, including maternal
smoking. Several other studies reviewed
by NAS provided supportive evidence
of a relationship, but most were unable
to adjust for maternal smoking.
NAS’s positive finding of ‘‘limited/
suggestive evidence of an association’’
between exposure to combustion
products during pregnancy and preterm
birth was based on four epidemiological
studies. The studies that found evidence
of a relationship between preterm birth
and combustion-product exposure were
based primarily on maternal residence
during pregnancy. Most of these studies
controlled for several known risk factors
for preterm birth (such as maternal age,
race, education, and access to prenatal
care), but none of the studies could
completely control for maternal
smoking, which is an important risk
factor for preterm birth.
NAS’s positive finding of ‘‘limited/
suggestive evidence of an association’’
between exposure to combustion
products and asthma was based
primarily on two studies, which
evaluated an association between
asthma and exposure to combustion
products in ambient air pollution. NAS
also relied on a study of veterans of the
1991 Gulf War that found an association
between oil-well fire smoke and asthma,
and a study associating ‘‘biomass
combustion’’ and asthma among people
over 60 years old living in India.
The epidemiological studies found
that new cases of asthma were
associated with combustion-product
exposure in air pollutants. A study of
Gulf War veterans using an objective
exposure-measurement method, found
an association between oil-well fire
smoke and asthma in Gulf War veterans,
but could not distinguish between new
cases arising after the war and
exacerbation of pre-existing conditions.
Although the other key Gulf War study
found no relationship between exposure
and asthma, its definition of asthma was
inadequate. Other studies of biomassfuel combustion and outdoor air
pollution supported a relationship
between combustion exposure and
asthma.
The Secretary has determined that,
although there is limited/suggestive
evidence of an association between
exposure to combustion products and
cancers of the nasal cavity and
nasopharynx; cancers of the oral cavity
and oropharynx; laryngeal cancer;
bladder cancer; low birthweight/
intrauterine growth retardation (with
exposure during pregnancy); preterm
birth (with exposure during pregnancy);
and incident asthma, VA does not
consider this exposure to be ‘‘associated
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with’’ the 1991 Gulf War. Please see
section IV for further detail.
3. Inadequate/Insufficient Evidence
NAS found inadequate/insufficient
evidence between exposure to
combustion products and esophageal
cancer; stomach cancer; colon cancer;
rectal cancer; hepatic cancer; pancreatic
cancer; melanoma; female breast cancer;
male breast cancer; female genital
cancers (cervical, endometrial, uterine,
and ovarian cancers); prostatic cancer;
testicular cancer; nervous system
cancers; ocular melanoma; kidney
cancer; non-Hodgkin’s lymphoma;
Hodgkin’s disease; multiple myeloma,
leukemia; myelodysplastic syndromes;
preterm births (based on exposure
during a specific time period during
pregnancy, such as the first trimester);
low birth weight and intrauterine
growth retardation (based on exposure
before gestation or during a specific
period during pregnancy, such as the
first trimester); specific birth defects,
including cardiac effects (with maternal
or paternal exposure before conception
or maternal exposure during early
pregnancy); all childhood cancers
identified, including acute lymphocytic
leukemia, leukemia, neuroblastoma, and
brain cancer; neurobehavioral effects;
post-traumatic stress disorder; nervous
system subgroupings (or individual
nervous system diseases); Multiple
Chemical Sensitivity symptoms; chronic
bronchitis (less than 1 year of exposure);
emphysema; chronic obstructive
pulmonary disease; ischemic heart
disease or myocardial infarction (less
than 2 years of exposure); dermatitisirritant and allergic; and sarcoidosis.
NAS reviewed five studies of
combustion products and esophageal
cancer, and concluded that no
consistent association was observed in
those studies.
NAS reviewed six studies of
combustion products and stomach
cancer. Two of the studies reported an
increased risk for stomach cancer, but
the method used to assess exposure was
limited and there were no adjustments
for confounders.
Studies of exposure to combustion
products and colon cancer reported
positive associations for exposure to
some combustion products, but not to
others. Further, a number of the positive
findings were limited, due to their large
confidence intervals. NAS found that
the evidence of an association was
inadequate because of the small number
of studies available.
With regard to rectal cancer, NAS
found the studies’ results were
inconsistent, and the number of studies
was small. NAS also noted that any
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positive studies failed to include at least
one high-quality study supported by an
adequate exposure assessment.
NAS noted only one relevant study
that evaluated exposure to combustion
products and hepatic cancer. Although
associations were noted for some
occupations, there were few cases with
relevant exposure, and the study did not
consider all pertinent risk factors.
The four reviewed studies of
combustion-product exposure and
pancreatic cancer generally did not
provide evidence of an association. One
study found an association between
exposure to coal combustion products
and increased risk of pancreatic cancer,
but it did not find a link between nine
other types of combustion products and
pancreatic cancer.
Studies regarding melanoma
addressed exposure to combustion
products but their reliability is limited
because they failed to adjust for
exposure to sunlight, a major risk factor
for melanoma. Overall, the studies did
not report significant findings of
association for most types of exposure.
Two studies found isolated effects of
specific exposures (propane exhaust and
being a traffic administrator,
respectively) that were not among the
major exposures considered by NAS.
NAS reviewed three studies
concerning nonmelanoma skin cancer
and combustion products. The studies
generally did not report statistically
significant findings of an association.
NAS found that for the more common
type of nonmelanoma skin cancer (basal
cell carcinoma), the findings were
largely negative. Two of the studies
stated findings regarding squamous cell
carcinoma, with one finding a
statistically significant association for
one type of exposure (diesel fumes), but
not others, and one study finding no
association.
The two studies involving female
breast cancer and exposure to
combustion products essentially had
negative results.
Of the two reviewed studies regarding
exposure to combustion products and
male breast cancer, one did not find an
association between PAH exposure and
male breast cancer, and the other,
although reporting a positive
association, was limited by its method
of exposure assessment.
NAS reviewed three studies regarding
exposure to fuels or combustion
products and cervical, endometrial,
uterine, or ovarian cancer, and found
that they provided inadequate support
for an association.
NAS reviewed four prostate cancer
studies that measured the relationship
between occupations having potential
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for exposure to combustion products or
PAHs or having more rigorously derived
estimates of exposure to such agents and
prostatic cancer. Although the studies
reported several positive associations,
NAS noted that the results were not
consistently positive. For example, one
study showed results contrary to a doseresponse relationship, while another
study showed an increased risk in
firefighters and railroad workers but not
in other transportation or trucking
workers.
Testicular cancer studies did not
provide enough relevant data to draw
any sort of conclusion about exposure to
fuels or combustion products and
testicular cancer.
Data on combustion products and
brain cancer (nervous system cancers)
were too sparse to determine whether an
association exists.
Three studies of ocular melanoma
reported increased, but imprecise, risks
of ocular melanoma in occupations
related to transportation. The reliability
of these studies is limited by their small
size, lack of statistical significance, and
lack of adequate exposure assessment.
Although some studies of exposure to
combustion products and kidney cancer
suggested a possible association based
on job title, NAS found that the results
were not consistently positive, with
some studies showing no increased risk.
Further, the results of some studies
showing positive associations were
limited by considerations of statistical
significance and other factors.
Studies on non-Hodgkin’s lymphoma
(NHL) had no firmly positive findings.
In the study with the most objective
exposure assessment, there was no
indication of an association with any of
the fuels or their combustion products.
The studies regarding Hodgkin’s
disease (HD) were limited by their small
numbers of cases and the nonspecificity
of their exposure assessments. Further,
the three primary studies reviewed by
NAS showed findings of no association.
NAS reviewed ten studies concerning
multiple myeloma and exposure to
combustion products. Three of the
studies the NAS found to be among the
most sizable or significant reported only
marginally increased risks and are just
barely suggestive of an association.
Other studies showed no association,
and yet other studies are limited due to
imprecise estimates of increased
multiple-myeloma risk in association
with exhaust exposure and concerns
regarding exposure assessments. NAS
concluded that the literature overall
provided insufficient evidence of an
association.
NAS reviewed six studies of leukemia
and exposure to combustion products.
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Four of the studies showed no findings
of a statistically significant increased
risk. In the other two studies, the
apparent associations were related to
separate types of leukemia, and the
authors of the studies noted that any
increase in leukemia risk was difficult
to attribute specifically to exhaust
because of concurrent exposure to fuels
and benzene. The exposure assessments
in all the studies were based on
information from sources of
questionable reliability (personal
interviews or medical records) or had a
low degree of specificity for combustion
products.
NAS reviewed two studies regarding
myelodysplastic syndromes and
exposure to combustion products. One
study found no significant evidence of
an association. The other study found
stable evidence of an association for the
not particularly substance-specific
occupation of machine operator.
Further, the reliability of that study is
limited because the analyses by
researchers were rudimentary and failed
to adjust for possible confounders when
the information was available.
As noted above in section III.A.2,
NAS found limited/suggestive evidence
of an association between exposure to
combustion products during pregnancy
and preterm birth. NAS similarly found
limited/suggestive evidence of an
association between exposure to
combustion products during pregnancy
and low birth weight or intrauterine
growth retardation. However, NAS also
found that there was inadequate/
insufficient evidence of an association
between combustion products exposure
at any specific point during pregnancy
(such as the first trimester) and these
reproductive effects. Although several of
the studies NAS reviewed reported
results for exposure at different stages of
pregnancy, there were no consistent
findings as to whether the risks were
greater with exposure early or late in
pregnancy. Additionally, none of the
studies completely controlled for the
significant risk factor of smoking during
pregnancy.
One study of an association between
maternal exposure to air pollutants and
the risk of birth defects reported
relationships between certain cardiac
defects and increasing exposure to CO
and O3. NAS discussed two studies that
examined the association between
paternal employment as a firefighter and
the risk of cardiac birth defects. One of
the studies found no evidence of an
association, while the other found some
evidence that certain cardiac defects
were associated with paternal
employment as a firefighter. Both
studies had limitations due to size,
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potential confounding and/or
inadequate information about duration
of paternal firefighting. In a study of
maternal or paternal exposures among
residents of Rotorua, New Zealand, a
city with high geothermal exposure to
hydrogen sulfide, no excess birth
defects were reported in comparison
with residents in the rest of New
Zealand.
NAS discussed eleven studies of the
association between combustionproducts exposure and childhood
cancers, including acute lymphocytic
leukemia, leukemia, neuroblastoma, and
brain cancer. All of the studies were
limited by their inability to validate
employment history and by the lack of
details on specific assessments of
exposure to combustion products. The
exposure groups were broad and
included many diverse occupations
where exposure to other chemicals was
noted in addition to combustion
products. Six of the studies found no
association between combustion
products exposure and the studied
childhood cancers. One study reported
general findings of associations for a
variety of childhood cancers, while the
remaining four studies contained mixed
findings, reporting positive associations
for certain types of cancers.
All of the studies on neurobehavioral
effects and combustion-product
exposure suffered from significant
methodological limitations. Several Gulf
War studies reported positive
relationships between self-reported
exposure and self-reported
neuropsychologic, cognitive, or mood
symptoms or multiple unexplained
symptoms, but the lack of objective
measurement of exposure limits the
reliability of those findings. Among two
non-veteran studies reporting positive
findings for certain neurobehavioral
effects, one study did not have a control
group, and the other had serious
limitations, especially in subject
selection.
NAS identified no studies showing an
association between combustionproducts exposure and post-traumatic
stress disorder (PTSD). Although several
studies addressed the prevalence of
PTSD among firefighters, the result is
most likely attributable to the hazardous
nature of the job rather than exposure to
combustion products. Only a few Gulf
War studies have examined whether
self-reported combustion-product
exposure was related to PTSD as an
outcome measure, and none has found
such a relationship. None of the studies
with objectively measured oil-well fire
smoke examined PTSD as an outcome
measure.
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Regarding nervous system disease
subgroupings (or individual nervous
system diseases), NAS excluded studies
involving only overbroad and
nonspecific health outcomes and
focused on individual neurologic
diseases or subgroupings of nervoussystem diseases. Only two identified
studies examined nervous-system
subgroupings in relation to combustionproducts exposure. One study found
exposure-response relationships with
nervous-system subgroupings in a
hospital discharge survey. The
limitation of this study was assignment
of exposure (residence only) and
potential for exposure misclassification.
The other study did not find a
relationship between combustion
product exposure and multiple
sclerosis. No other studies of nervous
system subgroups or the individual
diseases met NAS’s criteria for
inclusion.
Although NAS reviewed several
studies of Multiple Chemical Sensitivity
(MCS) in Gulf War veteran or civilian
samples, those studies provided
relatively little evidence that MCS was
associated with combustion-products
exposure in service. Several studies
involved questionnaires on which
veterans or civilians self-reported that
exposure to certain combustion
products (e.g., tobacco smoke, car
exhaust) are among the factors that can
trigger their symptomatology. However,
NAS noted that most of the studies did
inquire as to the first onset of
symptoms. Further, the studies
generally were limited by methodologic
concerns, including self-reported
exposures and symptoms and the
possibility of recall bias.
Although the studies reviewed by
NAS indicated a probable relationship
between long-term (over 1 year)
exposure to combustion products and
chronic bronchitis, a key unresolved
issue was whether shorter-term
exposures (less than 1 year) can cause
the condition. NAS found inadequate
published data that addressed the effect
of shorter term combustion-product
exposures (less than 1 year) on the risk
of developing chronic bronchitis. Even
if it could be shown that long-term
exposure to combustion products
caused chronic bronchitis, it might be
expected to cease after exposure without
long-term health consequences. NAS
found inadequate published data to
evaluate the natural history of chronic
bronchitis after cessation of exposure to
combustion products.
A study found that mortality due to
emphysema was not considerably
increased among workers exposed to
diesel exhaust. This result was found
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after adjustments for the effects of
smoking were made. Likewise, a study
of veterans exposed to oil-well fires also
did not find a relationship with
emphysema. Other studies that included
emphysema in the analysis were
methodologically inadequate.
NAS did not identify any high-quality
studies that evaluated the effect of
exposure to combustion products on the
risk of chronic obstructive pulmonary
disease (COPD), as defined by objective
evidence of irreversible airflow
obstruction with spirometry. Several
studies of biomass-smoke exposure used
measures of airflow obstruction but had
methodologic limitations that precluded
clear conclusions about the connection
between combustion exposure and
COPD.
There was relatively consistent
epidemiologic evidence of the relation
between ischemic heart disease
(including myocardial infarction) and
long-term exposure to fossil-fuel
combustion products, including motorvehicle exhaust and combustion-derived
fine particulate matter. However, the
increased risk was small in absolute
terms, and there was no adequate
epidemiologic evidence to support the
role of relatively short exposures
(similar to that experienced in the Gulf
War), followed by an exposure-free
period, and then development of
ischemic heart disease events.
Accordingly, NAS found inadequate/
insufficient evidence to determine
whether an association exists between
short-term exposure (less than 2 years)
to combustion products and the
development of ischemic heart disease
after an exposure-free period of months
or years.
Rashes were frequently reported by
Gulf War veterans, but only one study
of Gulf War veterans searched for
relationships between dermatitis and
self-reported exposure during the Gulf
War. No exposure to combustion
products or any other self-reported
exposure was related to dermatitis,
defined as rashes, eczema, or skin
allergies.
NAS identified three epidemiologic
studies on the relationship between
occupational or residential exposure to
fires and sarcoidosis, all of which had
significant methodologic limitations.
One study had numerous limitations,
such as inadequate description of how
the cases without biopsy confirmation
were diagnosed and the lack of control
for employment history (besides
farming), recall bias, and lack of
measurement of pollutant
concentrations. The authors noted that
sarcoidosis could be associated with a
component of wood-burning or wood-
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handling, namely contact with smoke,
ash, wood particles, or wood molds.
Another study was limited by the lack
of specific exposure assessment and of
analysis of duration or frequency of
exposure to combustion products. There
was no control for potential
confounders, such as race or familiar
aggregation of sarcoidosis. In addition,
there was no way to determine the role
of combustion products or exposure to
other toxicants, allergens, or infectious
agents. The third study was limited by
the small sample, the low statistical
power, the lack of a risk estimate for
firefighters versus police officers, the
lack of exposure assessment for
combustion products, and the lack of
assessment of coexposures to other
chemicals in the workplace.
Based on the information and analysis
in the NAS report, the Secretary has
determined that there is insufficient
credible evidence to conclude that there
is a positive association between
exposure to combustion products and
esophageal cancer; stomach cancer;
colon cancer; rectal cancer; hepatic
cancer; pancreatic cancer; melanoma;
nonmelanoma skin cancer; female breast
cancer; male breast cancer; female
genital cancers (cervical, endometrial,
uterine, and ovarian cancers); prostatic
cancer; testicular cancer; nervous
system cancers; ocular melanoma;
kidney cancer; non-Hodgkin’s
lymphoma; Hodgkin’s disease; multiple
myeloma, leukemia; myelodysplastic
syndromes; preterm births (based on
exposure during any specific time
period during pregnancy, such as the
first trimester); low birth weight and
intrauterine growth retardation (based
on exposure before gestation or during
any specific period during pregnancy,
such as the first trimester); specific birth
defects, including cardiac effects (with
maternal or paternal exposure before
conception or maternal exposure during
early pregnancy; all childhood cancers
identified, including acute lymphocytic
leukemia, leukemia, neuroblastoma, and
brain cancer; neurobehavioral effects;
post-traumatic stress disorder; nervous
system disease subgroupings (or
individual nervous system diseases);
MCS symptoms; chronic bronchitis (less
than 1 year of exposure); emphysema;
chronic obstructive pulmonary disease;
ischemic heart disease or myocardial
infarction (less than 2 years of
exposure); dermatitis-irritant and
allergic; and sarcoidosis. Further, as
explained in section IV of this notice,
VA does not consider the combustionproducts exposures underlying the NAS
findings to be exposures ‘‘associated
with’’ the 1991 Gulf War. Therefore, a
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presumption of service connection is
not warranted for any such illness based
upon exposure to combustion products
during service in the Gulf War.
B. Hydrazines
1. Limited/Suggestive Evidence of an
Association
NAS found limited/suggestive
evidence of an association between
exposure to hydrazines
(monomethylhydrazine ‘‘MMH,’’ and
unsymmetrical (1,1-)dimethylhydrazine
‘‘UDMH’’) used as rocket propellants,
and lung cancer. This conclusion was
based primarily on one high-quality
study, as discussed below.
An occupational study of a U.S.
cohort of aerospace workers engaged in
testing rockets using hydrazine fuel
demonstrated an association between
hydrazine exposure and risk of lung
cancer. Several sources of potential
confounding, including sex and
radiation exposure, were controlled by
study design. Other potentially
confounding variables were controlled
in multivariate analysis, including age,
pay type, and time since hire or transfer.
Although the smoking status of most
workers was unknown, there was
indirect evidence that smoking did not
confound the results.
Two other studies of lung cancer were
limited by small sample size and
inadequate study power. In addition,
another study was limited by its failure
to control for coexposure to other
carcinogenic substances, including
asbestos and PAHs. The lack of internal
control subjects and the lack of
information on smoking constitute
major limitations for both studies.
Consequently, there was inadequate
evidence to evaluate the consistency of
the association between hydrazine and
lung cancer beyond the study of the U.S.
cohort.
NAS stated in its report that U.S.
military personnel could have been
exposed to UMDH during Operation
Desert Storm if UMDH was used as a
rocket fuel in Scud missiles launched by
Iraq and the U.S. military personnel
were in the vicinity of the Scud missiles
when they disintegrated. However, NAS
stated that hydrazines were apparently
not used in Scud missiles during the
1991 Gulf War even though Iraq had
apparently experimented with UDMH as
a rocket fuel. NAS further stated that it
was not aware of any other potential use
of hydrazines that could have resulted
in exposure of U.S. service personnel.
Based on information and analysis in
the NAS report and from DoD, VA does
not consider exposure to hydrazines to
be exposures ‘‘associated with’’ the 1991
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Gulf War. Please see section IV for
further detail. Therefore, a presumption
of service connection is not warranted
for lung cancer based upon exposure to
hydrazine during service in the 1991
Gulf War.
2. Inadequate/Insufficient Evidence
NAS found inadequate/insufficient
evidence between hydrazines and
hematopoietic and lymphopoietic
cancers; digestive tract cancers;
pancreatic cancer; bladder cancer;
kidney cancer; emphysema; ischemic
heart disease or myocardial infarction;
and hepatic disease.
NAS noted that relatively few studies
existed concerning the health effects of
hydrazine exposure, and that lung
cancer was the only health outcome
represented in all three cohort studies
reviewed by the committee. NAS further
noted that individual findings in those
studies also reported somewhat
increased mortality from cancer at sites
other than the lung (hematopoietic and
lymphopoietic, bladder and kidney,
digestive tract, and pancreas) and from
two noncancer conditions (emphysema
and ischemic heart disease). NAS
concluded, however, that the few
available studies do not provide
adequate or consistent evidence of an
association between exposure to
hydrazines and any of those other
health outcomes.
Based on the information and analysis
in the NAS report, the Secretary has
determined that there is insufficient
credible evidence to conclude that there
is a positive association between
exposure to hydrazines and
hematopoietic and lymphopoietic
cancers; digestive tract cancers;
pancreatic cancer; bladder cancer;
kidney cancer; emphysema; ischemic
heart disease or myocardial infarction;
and hepatic disease. Further, as
explained in section IV of this notice,
VA does not consider exposure to
hydrazines to be exposures ‘‘associated
with’’ the 1991 Gulf War. Therefore, a
presumption of service connection is
not warranted for any such illness based
upon exposure to hydrazine during
service in the 1991 Gulf War.
C. Fuels—Inadequate/Insufficient
Evidence
NAS found inadequate/insufficient
evidence of an association between
exposure to fuels and cancers of the oral
cavity and oropharynx; cancers of the
nasal cavity and nasopharynx;
esophageal cancer; stomach cancer;
colon cancer; rectal cancer; hepatic
cancer; pancreatic cancer; laryngeal
cancer; lung cancer; melanoma;
nonmelanoma skin cancer; female breast
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cancer; male breast cancer; female
genital cancers (cervical, endometrial,
uterine, and ovarian cancers); prostatic
cancer; testicular cancer; nervous
system cancers; kidney cancer; bladder
cancer; Hodgkin’s disease; nonHodgkin’s lymphoma; multiple
myeloma; myelodysplastic syndromes;
adverse reproductive or developmental
outcomes (including infertility,
spontaneous abortion, childhood
leukemia, CNS tumors, neuroblastoma,
and Prader-Willi syndrome); peripheral
neuropathy; neurobehavioral effects;
MCS symptoms; nonmalignant
respiratory disease; chronic bronchitis;
asthma; emphysema; dermatitis-irritant
and allergic; and sarcoidosis.
NAS reviewed five studies regarding
cancer of the oral cavity and oropharynx
and fuels. NAS found that the three
occupational cohort studies it reviewed
each had limited statistical power and
were therefore uninformative. NAS
further concluded that the two casecontrol studies it reviewed failed to
report any consistent relationship
between fuel exposure and cancers of
the oral cavity and oropharynx.
NAS found little information
available on exposure to fuels and
cancers of the nasal cavity and
nasopharynx, and that the two studies it
reviewed failed to provide convincingly
positive findings.
NAS found that studies of an
association between fuel exposure and
esophageal cancer were few and results
were inconsistent and inadequate to
support an association. Some of the
studies were unreliable because they
analyzed esophageal cancer and
stomach cancers together, and NAS
therefore could not determine which
specific cancer type may have been
associated with fuel exposure. Other
studies showed no evidence of
association.
NAS also found that studies of an
association between fuel exposure and
stomach cancer were inconsistent and
inadequate to support an association. As
noted above, some of the studies were
unreliable because they analyzed
esophageal cancer and stomach cancers
together in relation to fuel exposure and
NAS could not determine which
specific cancer type may have been
associated with fuel exposure. Other
studies showed no evidence of
association.
NAS found that the studies
concerning fuel exposure and colon
cancer provided no consistent evidence
of an association. Although some
studies showed increased risk of colon
cancer, the increases were modest and
the confidence intervals in several
instances included the null. Three
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studies analyzed colon cancer and rectal
cancer together and, therefore, NAS
could not determine whether exposure
to fuels may have been associated with
a specific type of cancer.
NAS found that the studies reporting
positive associations between fuels and
rectal cancer were not consistent and
the number of studies was small.
Furthermore, the positive studies failed
to include at least one high-quality
study supported by an adequate
exposure assessment. Some studies
found no evidence of association
between fuel exposure and rectal
cancer.
NAS noted only one relevant study
that evaluated exposure to fuels and
hepatic cancer in which there were few
cases with relevant exposure, and the
study did not consider all pertinent risk
factors.
NAS found only two relevant studies
on the risk of pancreatic cancer posed
by fuel exposure. One study found no
association. The other study reported an
association, but the results were
imprecise, due in part to a large
confidence interval that included the
null.
NAS found that the results regarding
exposure to fuels and laryngeal cancer
were inconsistent. Two studies
reviewed by NAS reported a modest
increase in the risk of laryngeal cancer
associated with exposure to fuels, but
the reliability of those findings is
limited because the exposures in both
studies were self-reported. Another
study reported an increased, but
imprecise, risk of laryngeal cancer in
vehicle mechanics, but found no
increase in garage and gasoline-station
workers.
NAS found the results of studies of
fuel exposure and lung cancer risk were
inconsistent. One study reported an
association between kerosene and
crude-oil exposure and squamous-cell
lung cancer, between diesel-fuel
exposure and nonadenocarcinoma, and
between heating-oil exposure and oatcell lung cancer. Two studies did not
find an association in workers most
likely to have been exposed to fuels.
The studies examined by NAS
addressing melanoma and exposure to
fuels were not adjusted for sun
exposure, a major risk factor for
melanoma, and the workers—
particularly the exploration, drilling,
and pipeline workers—may have
received considerable sun exposure
while performing their jobs. But the one
case-control study with fairly reliable
exposure analysis did not support an
association in workers likely to have
been exposed to fuels.
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Of the available epidemiologic studies
regarding nonmelanoma skin cancer
that met NAS’s criteria, one study
reported one borderline association
between fuel exposure and squamouscell carcinoma. The other two reports
reviewed by NAS had methodologic
limitations and did not provide reliable
evidence of an association. For the more
common type of nonmelanoma skin
cancer (basal cell carcinoma), the
findings were largely negative.
NAS reviewed three studies
concerning fuel exposure and female
breast cancer. One study found no
increased risk of breast cancer, while
the other two found only an
insignificant increase in risk.
NAS found no studies assessing the
possible relationship of male breast
cancer to fuel exposure alone. NAS
reviewed one study that reported a
positive finding regarding combined
exposure to fuels and combustion
products and male breast cancer. NAS
found, however, that the method used to
assess exposure in that study was
limited.
NAS reviewed three studies
concerning fuel exposure and female
genital cancers. The studies failed to
provide any significant evidence of an
association between exposure to fuels
and cervical, endometrial, uterine, or
ovarian cancer.
NAS reviewed several studies
regarding an association between fuel
exposure and prostatic cancer. Only one
of those studies reported a positive
association between a fuel-related
exposure and prostatic cancer. That
study found an association between
exposure to diesel fuel and prostate
cancer, but did not find significant
evidence of an association for other
types of fuel exposure. The other reports
reviewed by NAS were negative for any
association.
Only one study addressed the
association between fuel exposure and
testicular cancer, and it found no
evidence of an association. NAS
concluded that there was not enough
relevant data to draw any sort of
conclusion about exposure to fuels and
testicular cancer.
Several studies reported sporadic
associations between fuel exposure and
nervous system cancers (brain cancer),
but the results were limited by several
factors, including wide confidence
intervals that include the null. In some
studies, the increased risk was found
only among workers likely to have
lesser fuel exposure, while no increased
risk was seen among workers likely to
have greater fuel exposure. None of the
studies could be considered a highquality study supported by an adequate
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exposure assessment. Additionally,
some studies found no evidence of
association.
No key study that was positive for an
association between exposure to fuels
and kidney cancer was identified. NAS
found the uniformly negative results of
a study of a comprehensive sample of
renal cell carcinoma cases in the
petroleum industry with excellent
exposure assessment to be compelling.
NAS reviewed several studies
concerning fuel exposure and bladder
cancer. Several of the studies found no
evidence or no significant evidence of
an association. Other studies provided
evidence of a relationship between fuel
exposure and bladder cancer, but the
relationship was not consistently
increased in any study with a detailed
and specific exposure assessment. The
positive findings in some studies were
further limited by the methods used to
estimate exposure and the difficulty in
segregating fuel exposure from
combustion-product exposure in some
instances.
Regarding Hodgkin’s disease, the
studies were limited by their small
numbers of cases and the nonspecificity
of their exposure assessments. Of the
five studies reviewed by NAS, two
found no evidence of an association
between fuel exposure and Hodgkin’s
disease, one found an insignificant
increase only among males. The other
two studies showed evidence of an
association, but were limited by wide
confidence intervals and the lack of any
relationship to a specific job or duration
of employment.
Studies on non-Hodgkin’s lymphoma
had no firmly positive findings. The
most well conducted studies showed no
evidence of association.
NAS found no consistent relationship
between exposure to fuels and multiple
myeloma in the studies reviewed. Most
studies reported no association.
NAS reviewed two studies that
showed evidence of an association
between myelodysplastic syndrome and
exposure to petroleum-related
substances. However, a significantly
larger study using similar methods and
procedures failed to produce consistent
results. The larger study reported only
a modest increased risk, with
confidence intervals including the null,
and did not find any evidence of a doseresponse relationship with duration or
intensity of exposure.
NAS determined that it was difficult
overall to reach conclusions on the
epidemiologic studies of adverse
reproductive outcomes and exposure to
fuels. The assessment of findings was
limited by the small number of studies
available on each health outcome, the
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possibility of recall bias, and the lack of
specificity of exposure to the agents of
concern in this report. NAS found no
adequate studies regarding the
relationship between fuel exposure and
female infertility. NAS found one study
concerning fuel exposure and male
fertility, and that study showed no effect
on sperm measures among persons
exposed to jet fuels. NAS found only
one study on fuel exposure and
spontaneous abortion. The study
showed a significant increase in
spontaneous abortion among women
living in an area where water used for
drinking, cooking, and bathing was
contaminated by nearby oil fields,
however, the finding was potentially
limited by recall bias and methods of
estimating exposure. NAS identified one
study showing an increased risk of
childhood leukemia in the offspring of
men exposed to petroleum for 1,000
days or more before conception, and one
study showing an increased risk of
childhood leukemia based on maternal
exposure to fuels during pregnancy. The
latter study was potentially limited by
recall bias, interviewer bias, controlselection procedures, and lack of
validation for other risk factors. NAS
noted that three other occupational
studies showed no relationship between
parental employment in a field
involving fuel exposure and childhood
leukemia. With respect to childhood
cancers of the central nervous system,
NAS identified one study showing no
increase in neuroblastoma based on
maternal exposure to fuels during
pregnancy, but moderate increases
based on paternal exposures. The study
authors were unable to distinguish
between paternal exposures occurring
before or after conception. Another
study showed an increased risk of
neuroblastoma based on maternal or
paternal exposures, although the study
authors noted several limitations on the
interpretation of the data, including
bias, chance, and self-reporting of
exposure information. NAS noted that
two studies showed a possible
association between parental exposure
to hydrocarbons and the occurrence of
Prader-Willi Syndrome in offspring,
although neither study collected
information on potential confounders. A
third study found no association
between exposure to hydrocarbons and
Prader-Willi Syndrome in offspring. In
view of the minimal and indeterminate
data, NAS concluded that there was
inadequate/insufficient evidence of an
association between parental fuel
exposure and adverse reproductive or
developmental outcomes.
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Regarding neuropathy, NAS reviewed
two studies, in which certain
neurological symptoms were more
prevalent among subjects with higher
exposures to jet fuels, while other
neurological symptoms were either not
increased or were more prevalent among
controls. NAS concluded that, although
certain symptomatic differences were
apparently related to exposure, there
were no objective measures to support
a relationship between jet-fuel exposure
and neuropathy. The limitations of the
studies included small samples and the
lack of internal nonexposed groups of
controls.
Regarding neurobehavioral effects,
NAS found that several studies of Gulf
War veterans found a relationship
between the veterans’ self-reported fuel
exposure and their self-reported
neuropsychologic, cognitive, or nonspecific symptoms, but that these
studies provided weak evidence of any
relationship, due to recall bias. NAS
also discussed a study of increased
neurologic and cognitive abnormalities
among persons who engaged in ‘‘petrolsniffing,’’ but found those results
inconclusive because the effects were
most likely due to exposure to lead
rather than the fuels themselves.
NAS found that studies of MCS in
Gulf War veteran or civilian samples
generally provided relatively little
evidence that MCS was associated with
fuel exposure in service. Several studies
involved questionnaires on which
veterans or civilians self-reported that
exposure to fuels are among the factors
that can trigger their symptomatology.
The studies generally were limited by
methodologic concerns, including selfreported exposures and symptoms and
the possibility of recall bias. Further,
NAS noted that most of the studies did
not address the factors relating to the
first onset of symptoms as distinguished
from subsequent recurrence of
symptoms. The only study addressing
first onset was an occupational study
that incorporated objective exposure
measurement and found a relationship
between symptoms of MCS and fuel
exposure. However, because the study
was limited by the small sample and
lack of a matched control group of
workers, NAS found that it did not meet
the criteria for a primary study that
could support an association.
Regarding respiratory diseases, the
studies generally did not report specific
respiratory disease outcomes and
exposure assessment, so it was difficult
to reach a conclusion as to a
relationship between respiratory disease
outcomes and exposure to fuels.
However, NAS noted that most of the
studies it reviewed showed
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standardized mortality ratios of 1.0 or
less in study populations, showing no
increased risk of death due to
nonmalignant respiratory disease,
asthma, chronic bronchitis, or
emphysema in populations exposed to
fuels.
Regarding irritant contact dermatitis,
many fuels (for example, gasoline and
kerosene) were generally acknowledged
skin irritants, as indicated by the studies
reviewed by NAS. Irritant contact
dermatitis was evident soon after
exposure but usually disappeared soon
after removal of the irritant. There are
few epidemiologic studies, however, of
exposure to fuels and irritant and
allergic contact dermatitis. Accordingly,
NAS concluded that there was
inadequate/insufficient evidence of an
association between fuel exposure and
chronic irritant and allergic contact
dermatitis after cessation of exposure.
The NAS report does not identify any
studies concerning the possible
relationship between exposure to fuels
and sarcoidosis. However, NAS
concluded, presumably based on the
absence of relevant studies, that there is
inadequate/insufficient evidence of an
association between fuel exposure and
sarcoidosis.
Based on the information and analysis
in the NAS report, the Secretary has
determined that there is insufficient
credible evidence to conclude that there
is a positive association between
exposure to fuels and cancers of the oral
cavity and oropharynx; cancers of the
nasal cavity and nasopharynx;
esophageal cancer; stomach cancer;
colon cancer; rectal cancer; hepatic
cancer; pancreatic cancer; laryngeal
cancer; lung cancer; melanoma;
nonmelanoma skin cancer; female breast
cancer; male breast cancer; female
genital cancers (cervical, endometrial,
uterine, and ovarian cancers); prostatic
cancer; testicular cancer; nervous
system cancers; kidney cancer; bladder
cancer; Hodgkin’s disease; nonHodgkin’s lymphoma; multiple
myeloma; myelodysplastic syndromes;
adverse reproductive or developmental
outcomes (including infertility,
spontaneous abortion, childhood
leukemia, CNS tumors, neuroblastoma,
and Prader-Willi syndrome); peripheral
neuropathy; neurobehavioral effects;
Multiple Chemical Sensitivity
symptoms; nonmalignant respiratory
disease; chronic bronchitis; asthma;
emphysema; dermatitis-irritant and
allergic; and sarcoidosis. Therefore, a
presumption of service connection is
not warranted for any such illness based
upon exposure to fuels during service in
the 1991 Gulf War.
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D. Nitric Acid—Inadequate/Insufficient
Evidence
NAS found inadequate/insufficient
evidence between nitric acid and
stomach cancer; melanoma;
lymphopoietic cancers; pancreatic
cancer; laryngeal cancer; lung cancer;
bladder cancer; multiple myeloma; and
cardiovascular diseases.
Generally, on the basis of NAS’s
review of the epidemiologic evidence,
no available studies directly examined
the association between exposure to
nitric acid and long-term human health
effects. Most studies were able only to
investigate the health effects of nitric
acid in combination with other strong
inorganic acids, such as sulfuric acid, or
other known carcinogens such as
asbestos: that is, an independent
assessment of nitric acid exposure was
impossible because workers were
exposed simultaneously to such
mixtures. As a result, the health effects
associated with exposure to nitric acid
alone cannot be assessed.
It appears that NAS stated
conclusions with respect to nitric acid
and nine disease categories because
certain studies state findings with
respect to those disease categories in
populations that potentially were
exposed to a group of carcinogens that
may have included nitric acid. As
explained above, however, NAS
concluded that the existing data are not
sufficiently specific to nitric acid and,
therefore, do not provide reliable
evidence of an association between
exposure to nitric acid and the
occurrence of any disease.
Based on the information and analysis
in the NAS report, the Secretary has
determined that there is insufficient
credible evidence to conclude that there
is a positive association between
exposure to nitric acid and stomach
cancer; melanoma; lymphopoietic
cancers; pancreatic cancer; laryngeal
cancer; lung cancer; bladder cancer;
multiple myeloma; and cardiovascular
diseases. Therefore, a presumption of
service connection is not warranted for
any such illness based upon exposure to
nitric acid during service in the 1991
Gulf War.
IV. VA Response to the National
Academy of Sciences Report
In order to facilitate action on the
2004 update report from NAS, VA
established the 2005 Gulf War Health
Effects Task Force to consider and
develop recommendations for the
Secretary of Veterans Affairs. The Task
Force consisted of top Departmental
officials, specifically the Under
Secretaries for Health and Benefits, the
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General Counsel, and the Assistant
Secretary for Policy and Planning. The
review provided the basis for the
Secretary’s determination regarding
health outcomes related to service in the
Gulf War.
A. 1991 Gulf War Hazard Exposure Data
Although the statutes necessarily
contemplate that NAS would evaluate
non-veteran studies concerning the
health effects of various exposures, they
also require NAS to attempt to relate its
findings to the actual experiences of
Gulf War veterans.
For example, Public Law 105–277,
§ 1603(e)(1)(B) directs NAS to evaluate
and summarize ‘‘the increased risk of
the illness among human or animal
populations’’ including but not limited
to Gulf War veterans. Public Law 105–
368, § 101(c)(1)(C) directs NAS to
‘‘identify the illnesses * * * for which
there is scientific evidence of a higher
prevalence among populations of Gulf
War veterans when compared with
other appropriate populations of
individuals.’’ The statute goes on to
require that for each illness NAS finds
to be more prevalent in Gulf War
veterans or to be associated with a
possible Gulf War hazardous exposure,
NAS ‘‘shall determine (to the extent
available scientific evidence permits)
whether there is scientific evidence of
an association of that illness with Gulf
War service or exposure during Gulf
War service to one or more agents,
hazards, or medicines or vaccines.’’
Public Law 105–368, § 101(e)(1).
Public Law 105–368, § 101(e)(1)(E),
(F) directs NAS to consider ‘‘in any case
where information about exposure
levels is available, whether the evidence
indicates that the levels of exposure of
the studied populations were of the
same magnitude as the estimated likely
exposures of Gulf War veterans; and
* * * whether there is an increased risk
of illness among Gulf War veterans in
comparison with appropriate peer
groups.’’
Congress further provided that ‘‘[i]n
conducting the review and evaluation
* * * [NAS] shall * * * assess the
latency period, if any, between service
or exposure to any potential risk factor
(including an agent, hazard, or medicine
or vaccine [reviewed]) * * * and the
manifestation of such illness.’’ Public
Law No. 105–368, § 101(c)(3).
Determinations concerning the
increased risk of illness among Gulf War
veterans, as well as the latency periods
for manifestation of illness, necessarily
require consideration of the degree and
the duration of exposure to the relevant
environmental hazards. Findings based
on non-veterans dwelling in cities or
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typical civilian occupational studies
may not necessarily support findings
specific to Gulf War service because of
differences in the magnitude and
duration of exposure between these
groups.
NAS concluded in its report that it
was essentially unable to respond to
Congress’ charge to relate their
literature-based health findings to the
actual exposure magnitude and duration
for Gulf War veterans. NAS explained:
To estimate the magnitude of risk of a
particular health outcome among Gulf War
veterans, the committee would need to
compare the rates of disease or other health
effects in veterans exposed to the putative
agents with the rates in those who were not
exposed. That would require information
about the specific agents to which individual
veterans were exposed and about their doses.
However, there is a paucity of data regarding
the agents and doses to which individual
Gulf War veterans were exposed. * * *
Because of the lack of various kinds of data
on veterans, the committee could not
extrapolate from the exposures in the studies
it reviewed to the exposures of Gulf War
veterans. Therefore, it could not determine
the likelihood of increased risk of adverse
health outcomes among Gulf War veterans
due to exposure to the agents examined in
this report.
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‘‘Gulf War and Health, Volume 3. Fuels,
Combustion Products, and Propellants,’’
pp.16–17 (December 20, 2004).
NAS further noted that the studies it
reviewed often ‘‘included people whose
exposures had been over a lifetime
(such as to air pollution in their
communities) or included workers
employed in a particular industry over
many years.’’ NAS stated: ‘‘In contrast,
the exposures of veterans in the Persian
Gulf were of relatively short duration
with varying intensity. Therefore, the
exposures experienced during the Gulf
War might only approximate the
exposures described in the occupational
and environmental literature reviewed
in this report.’’ ‘‘Gulf War and Health,
Volume 3. Fuels, Combustion Products,
and Propellants,’’ p. 17 (December 20,
2004).
As such, NAS was unable to relate
their health findings to the actual
exposures experienced by Gulf War
veterans. However, some relevant data
is available.
1. Gulf War Exposure to Combustion
Products
In its September 2000 report,
‘‘Environmental Exposure Report: Oil
Well Fires’’ the Department of Defense
(DoD) summarized its investigations on
exposure of Gulf War veterans to oilwell-fire smoke and related combustion
products during the 1991 Gulf War. The
report describes how from January
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through late February 1991, retreating
Iraqi forces set fire to more than 600
Kuwaiti oil-wells, creating huge
columns of smoke. These fires were
brought under control within 9 months.
The report concludes that, although
the oil-well fires produced smoke
plumes, the actual exposure to
combustion products of U.S. service
members in that region was generally
unremarkable. Furthermore, unlike
many Gulf War environmental hazards
of concern, the results of extensive
monitoring efforts by various agencies
for air pollutants and combustion
products from the 1991 Gulf oil-well
fires are available to support the report’s
conclusions about such exposure. The
report also concludes that some
individual veterans who were near the
oil-well fires could have been exposed
to high levels of large particulates,
primarily as material deposited directly
to skin or clothing rather than through
inhalation.
According to the report,
For about eight months immediately after
the ground war, U.S. and international
organizations conducted comprehensive air
monitoring to characterize the contaminants
of concern and, by measuring their relative
concentrations in the atmosphere, lay the
groundwork for assessing their likely shortand long-term impacts to human health and
the environment. * * * Ground-level and
airborne-based monitoring platforms
collected numerous samples. The U.S. Army
Environmental Hygiene Agency conducted
the most comprehensive monitoring program,
including taking more than 4,000 samples.
In general, the monitoring results were
consistent among the various organizations
involved. * * * the maximum observed
concentrations of air contaminants, other
than particulate matter, were similar to levels
found in U.S. suburbs and generally lower
than those found in large urban areas.
Overall, * * * monitoring data show the
pollutant concentrations present in the
environment, particularly in areas where U.S.
troops and civilians were located, fell below
NIOSH [National Institute for Occupational
Safety and Health], OSHA [Occupational
Safety and Health Administration], or ACGIH
[American Conference of Government
Industrial Hygienists] recommended
exposure limits for hazardous substances in
the workplace.
The DoD report states:
At the time of the destruction, the medical
and environmental community feared
exposure to the fires would result in
catastrophic acute and chronic health effects.
However, the fires’ high combustion
efficiency, the nature and amount of the
smoke’s contaminants, the lofting effect
created by solar heating, and the local wind
and weather conditions combined to reduce
the fires’ impact on military and civilian
populations.
Results of air monitoring studies indicated,
except for particulate matter, air
contaminants were below levels established
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to protect the health of the general
population. However, there were self-reports
by a number of veterans who complained of
acute symptoms they allege were a result of
their proximity to the burning oil wells.
The DoD report points out that
exposures to the fires by U.S. service
members were quite short compared to
civilians dwelling in U.S. cities exposed
to urban ‘‘smog’’ and indoor air
pollution, or workers exposed to engine
exhaust: ‘‘Fortunately, the time period
during which military and civilian
populations were subjected to the fires’
pollution was relatively short.’’
Nevertheless, some 1991 Gulf War
troops apparently reported various
short-term adverse health symptoms
that could have been related to
exposures to oil fire smoke. The report
characterized these as follows: ‘‘Several
troops reported significant short-term
exposures to oil fire smoke, soot, and
unburned oil, usually after having been
totally enveloped in oil-well-fire fallout.
At times troops reported being soaked
with unburned oil.’’ ‘‘Several
monitoring sites observed high levels of
airborne particulates, sand, and soot.
Analysis of samples, however, indicated
the particles were mostly sand-based
materials typical for this region of the
world. In the particulate matter samples,
PAH and toxic metal concentrations
were low.’’ Finally, ‘‘[w]hile smoke
plumes occasionally touched the
ground, enveloping nearby personnel,
few were in those areas for extended
periods of time.’’
DoD’s finding that the oil-well fires
did not result in significant unique
exposures has been confirmed by
several other sources. The Presidential
Advisory Committee on Gulf War
Veterans’ Illnesses noted that, while the
oil well fires were burning, numerous
U.S. and international agencies
performed extensive air monitoring;
these groups included a U.S.
Interagency Air Assessment team
comprised of scientists from the
Environmental Protection Agency, the
National Oceanographic and
Atmospheric Administration, and the
Department of Health and Human
Services; and a group of scientists from
twelve countries engaged in a datacollection effort overseen by the World
Meteorological Organization. The
Presidential Advisory Committee stated
that ‘‘[a]ll groups found that levels of
nitrogen oxides, carbon monoxide,
sulfur dioxide, hydrogen sulfide, other
pollutant gases, and [PAHs] were lower
than anticipated and did not exceed
those seen in urban air in a typical U.S.
industrial city.’’ Presidential Advisory
Committee on Gulf War Veterans’
Illnesses: Final Report (Washington, DC:
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U.S. Government Printing Office,
December 1996). The Presidential
Advisory Committee further noted that
biological samples taken from persons
deployed in the vicinity of the oil-well
fires generally revealed lower levels of
volatile organic compounds (VOCs),
polycyclic aromatic carbons, and lead
than in reference populations located
elsewhere, except in the case of
firefighters, who had significantly
elevated levels of VOCs in comparison
to the reference population.
NAS’s finding linking oil-well-fire
smoke and lung cancer was based
primarily on studies of workers exposed
to engine exhaust on the job and to
civilians exposed to ‘‘smog’’ and indoor
air pollution from heaters and stoves in
the cities in which they dwelled. Health
effects from these relatively long-term
exposures may not be relevant to effects
from short-term but intense exposures
experienced by some veterans of the
1991 Gulf War who became heavily
covered with fallout from oil well fires.
Apart from the oil-well fires, exposure
to combustion products could also have
occurred through more routine
operations that involve burning fuels.
The 1996 Final Report of the
Presidential Advisory Committee stated
that ‘‘[o]perating the vehicles and
machinery used in the Gulf War
involved exposure to petroleum-based
material,’’ and that ‘‘[p]etroleum fuels
also were used for burning wastes and
trash, dust suppression, and fueling
stoves and tent heaters. The Presidential
Advisory Committee stated that ‘‘none
of these uses is unique to the Gulf War,’’
but that such uses probably led to
increased petroleum vapor and
combustion product exposures. With
respect to the use of heaters, the
Committee noted that ‘‘[b]urning leaded
fuels indoors without proper
ventilation—e.g., heaters in tents—
could have caused increased lead
exposure,’’ and that ‘‘[k]erosene heaters,
widely used in the United States, also
could have been significant sources of
exposure to nitric oxides, sulfur
dioxide, inorganic combustion gases,
carbon monoxide, and particles when
used with inadequate ventilation.’’
2. Gulf War Exposure to Hydrazine
Rocket Propellants
In January 2005, VA’s Under
Secretary for Health formally requested
DoD’s Assistant Secretary of Defense for
Health Affairs to provide all available
information about possible exposures of
U.S. service members to hydrazine
rocket fuels during the 1991 Gulf War.
DoD’s response in an April 8, 2005,
letter from the Assistant Secretary of
Defense was that the best available
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information indicated it was unlikely
there was any exposure to hydrazine
among U.S. military personnel in the
Gulf. U.S. missiles and other munitions
did not employ hydrazine during the
Gulf War. Also, investigations indicated
Iraq had not switched to hydrazine as a
propellant for Scud missiles.
Accordingly, there was no basis upon
which to conclude that U.S. veterans of
the Gulf War were exposed to hydrazine
from either U.S. or Iraqi missiles.
A very small number of personnel
working with the U.S. Air Force F–16
aircraft might have had minimal
exposure to hydrazine. F–16 aircraft are
equipped with a sealed tank (bottle) of
hydrazine as an emergency propellant to
be employed in the event of engine stall.
When employed, the hydrazine is
consumed. F–16 squadrons deployed
with spare bottles during the Gulf War.
If used, the bottles would have been
returned to the U.S., Europe, or Turkey
to be refilled and shipped back. The Air
Force has long been keenly aware of the
potential health hazards of hydrazine,
so refilling operations are conducted in
a manner consistent with the strictest of
occupational health standards.
DoD’s August 1999 report,
‘‘Information Paper: Inhibited Red
Fuming Nitric Acid,’’ concluded that
the rocket fuel used by Iraqi forces in
Scuds and several smaller missiles
during the 1991 Gulf War was a type of
kerosene and red fuming nitric acid
(also known as IRFNA). DoD states that
apparently Iraq had experimented with
hydrazine rocket fuels including
UDMH, however, it concluded that
these fuels were not used during that
conflict:
The missile fuel that Iraq used in its older
Soviet systems was a specially refined
kerosene-like substance (called kerosene in
the literature). Some improved missiles used
UDMH in combination with IRFNA. The
Soviet Union used UDMH in their Scuds, but
we have no evidence that Iraq used UDMH.
Therefore, it is unlikely that any U.S.
service members were exposed to
hydrazine rocket fuels during the 1991
Gulf War.
B. VA Determination on Combustion
Products and Hydrazines
Based upon the evidence currently
available, VA has determined that a
presumption of service connection is
not warranted at this time for any
disease based upon an association with
exposure to combustion products or
hydrazines during service in the Gulf
War. This determination is based on the
conclusion that current evidence does
not establish that service in the Gulf
War entailed exposures to combustion
products that were unique to Gulf War
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service when compared to other military
and civilian populations and that could
be expected to produce the increased
risk of adverse health effects based on
the findings set forth in the NAS report.
The best evidence currently available
indicates that hydrazines were used in
limited circumstances during the Gulf
War and that hydrazine exposure
generally would not have occurred.
With respect to combustion products,
although the 1991 oil well fires were the
product of a unique event, the best
evidence currently available indicates
that they did not result in combustionproducts exposures that were unique in
kind or degree when compared to
exposures incurred generally by other
military and civilian populations as the
result of ambient air pollution, vehicle
exhaust, and other means. Currently
available evidence further indicates that
other potential means of exposure to
combustion products, such as through
proximity to vehicles, aircraft, or the use
of fuel-based heaters, did not differ
significantly in the Gulf War from
similar exposures occurring in other
military and civilian populations
generally.
In the absence of unique exposures
associated with Gulf War service that
could be correlated to the increased
risks of health effects discussed in the
NAS report, a generally applicable
presumption of service connection is
not warranted based on exposure to
combustion products or hydrazines in
the Gulf War. The governing statute
requires VA to establish presumptions
when the Secretary determines that an
illness is associated with exposure to
substances or hazards ‘‘known or
presumed to be associated with service
in the Southwest Asia Theater of
operations during the Persian Gulf
War.’’ 38 U.S.C. 1118(b)(1)(B)(i).
VA has determined that hydrazines
were used during the 1991 Gulf War
only under extremely limited
conditions, and, therefore, hydrazines
are not substances or hazards
‘‘associated with’’ service in the 1991
Gulf War. Consequently, VA need not
establish a presumption of service
connection for any disease identified in
the NAS report as associated with such
exposure.
VA has determined that combustion
products, the prevalence and use of
which in the Gulf War did not differ
significantly from the prevalence and
use of such substances in other military
and civilian populations, are not
substances or hazards ‘‘associated with’’
service in the 1991 Gulf War, because
they are not unique to such service.
Consequently, VA need not establish
presumptions of service connection for
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any of the eight diseases that NAS
associated with exposure to combustion
products in its report.
This approach is similar to that taken
in our notice concerning the 2002 NAS
report on insecticides and solvents.
Public Law 105–277 specifically
directed NAS to consider combustion
products, fuels, and propellants among
the substances to which veterans may
have been exposed in their service in
the 1991 Gulf War. The statute does not
specifically identify these agents as
substances ‘‘associated with’’ such
service. Although Congress directed
NAS to consider them in its reports, the
language and structure of the statute
indicates that Congress delegated to VA
the responsibility for determining, based
on NAS reports and other available
information, whether such substances
were ‘‘associated with’’ Gulf War service
for the purpose of establishing
presumptions under the statute.
We conclude that the statutory phrase
‘‘associated with service in the Armed
Forces in the Southwest Asia theater of
operations during the Persian Gulf War’’
is most reasonably construed to refer to
a relationship between the substance or
hazard and the specific circumstance of
service in the Southwest Asia theater of
operations during the Persian Gulf War,
as distinguished from features of
military or civilian life in general that
are not unique to service in the Gulf
War. The phrase ‘‘associated with’’
clearly connotes a direct relationship,
and the requirement that the substance
or hazard be associated with service at
a particular time and place indicates an
intent to distinguish between substances
and hazards associated with general
military or civilian life and those unique
to service at the specified time and
place. If civilian and military
populations are commonly exposed to a
substance, we believe it would be
unreasonable to conclude that the
substance is ‘‘associated with’’ service
in the Persian Gulf during the Gulf War
merely because it was present during
such service. We do not believe that
Congress intended VA to establish
presumptions for the known health
effects of all substances common to
military or civilian life. Rather, the
requirement that the substance be
‘‘associated with’’ Gulf War service
makes clear that VA’s task is to focus on
the unique exposure environment in the
Persian Gulf during the Persian Gulf
War.
This reading of the statutory language
comports with the clear purpose of both
Public Law 105–277 and Public Law
105–368. Both statutes reflect the
Government’s commitment to
addressing the unique health issues
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presented by Gulf War veterans, by
establishing a process for identifying
diseases and illnesses that may be
associated with Gulf War Service. It is
by now well known that many Gulf War
veterans have reported a variety of
similar symptoms that cannot presently
be identified with a known diagnosis or
cause and that were not considered
‘‘diseases’’ for the purposes of the
statutes generally authorizing VA to pay
compensation for service-connected
disability or death due to disease or
injury. Congress responded initially to
that situation by authorizing VA to pay
compensation for ‘‘undiagnosed illness’’
in such veterans. The process
established by Public Law 105–277 and
Public Law 105–368 reflects a further
effort to bridge the existing gaps in
medical and scientific knowledge and to
ensure that Gulf War veterans may
obtain compensation for diagnosed or
undiagnosed illnesses that may have
been caused by the unique exposures or
hazards of service during the Gulf War.
Establishing presumptions of service
connection for illnesses associated with
exposures or hazards specifically related
to Gulf War service obviously would
further that objective. In contrast,
establishing presumptions of service
connection for the exclusive benefit of
Gulf War veterans based solely on the
well-known health effects of exposures
shared in common with the general
veteran population would not
significantly further the purposes of
those statutes. Moreover, establishing
such presumptions would create
significant inequities in the veterans’
benefits system that Congress could not
have intended.
Public Law 105–277 requires VA to
establish presumptions of service
connection, when the statutory
requirements are met, exclusively for
veterans who served in the Southwest
Asia theater of operations during the
Persian Gulf War. If the statute were
construed to require presumptions
based on exposure in the Persian Gulf
War to substances to which other
veterans serving at other times and
places are commonly exposed at similar
levels, it would raise significant
concerns of fairness and reasonableness.
For example, veterans exposed or
presumably exposed to combustion
products during the Gulf War might be
entitled to presumptive service
connection for certain diseases
associated with such exposure, while
veterans who served stateside and had
equal or greater combustion product
exposure would not be entitled to
presumptive service connection for
those diseases. The fact that most
PO 00000
Frm 00113
Fmt 4703
Sfmt 4703
service members, and most civilians,
routinely incur some degree of
background exposure to the substances
NAS considered further underscores the
arbitrariness that would attach to
establishing presumptions for a limited
class of veterans based on such common
exposures. Apart from the fact that it is
generally unnecessary to establish
presumptions of service connection for
health effects that are well documented
in the medical literature, establishing
presumptions applicable only to a small
percentage of the veteran population
potentially exposed to the relevant
substances would have significant
adverse effects on the veterans benefits
system. Providing by statute and
regulation for the disparate treatment of
similarly situated veterans would
substantially undermine confidence in
the objectivity and fairness of the
veterans benefits system. Additionally,
establishing different adjudicative rules
for the claims of similarly situated
veterans without any reasoned basis for
the distinction would undoubtedly
cause confusion to the VA personnel
responsible for deciding claims, as well
as to veterans and their representatives
in presenting and supporting their
claims.
We do not believe that Congress
intended VA to establish presumptions
unique to Gulf War veterans based on
the well-known health effects of
exposures common to military and
civilian life outside the Gulf War theater
of operations. As explained above, the
language and purpose of Public Law
105–277 and Public Law 105–368
indicate that Congress did not intend
such a result, and we believe it is
reasonable to presume that Congress did
not intend arbitrary or unfair
distinctions. We note that statutes
generally must be construed to avoid
serious constitutional concerns. See
Edward J. DeBartolo Corp. v. Florida
Gulf Coast Building & Construction
Trades Council, 485 U.S. 568, 575
(1988). We cannot say it is beyond
Congress’ power to establish
presumptions exclusively for Gulf War
veterans based on exposures not known
to differ significantly from service
outside the Gulf War. However, the
apparent unfairness, in our view, of that
result supports the conclusion that
Congress did not intend such a result.
We recognize that Public Law 105–
277 and Public Law 105–368 both
required NAS to consider the health
effects of exposure to fuels, combustion
products, and propellants as part of its
investigations of illnesses potentially
associated with Gulf War service.
However, the direction to consider those
substances does not compel the
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conclusion that those substances,
considered in isolation, are themselves
agents ‘‘known or presumed to be
associated with service in the Southwest
Asia theater of operations during the
Persian Gulf War’’ for purposes of VA’s
duty to establish presumptions of
service connection. Section 1603 of
Public Law 105–277 describes the scope
of NAS’ inquiry. Section 1603(c)(1)
directs NAS to ‘‘identify the biological,
chemical, or other toxic agents,
environmental or wartime hazards, or
preventive medicines or vaccines to
which members of the Armed Forces
who served in the Southwest Asia
Theater of operations during the Persian
Gulf War may have been exposed by
reason of such service.’’ Section 1603(d)
of that statute provides that, in
identifying substances to which Gulf
War veterans ‘‘may have been exposed,’’
NAS will consider, among other things,
oil fire byproducts. In contrast, section
1602 of Public Law 105–277 does not
direct the Secretary to establish
presumptions of service connection for
the health effects of every substance to
which Gulf War veterans ‘‘may have
been exposed,’’ but requires
presumptions only for the health effects
of exposure to substances known or
presumed to be ‘‘associated with’’
service in the Gulf War. Congress used
different language in section 1602 and
1603 of Public Law 105–277, and we
must conclude that the different
language was intended to have different
meanings. See Bank of America
National Trust & Savings Ass’n v. 203
N. LaSalle St. Partnership, 526 U.S. 434,
450 (1999); Russello v. United States,
464 U.S. 16, 23 (1983). Congress
reasonably defined the scope of NAS’
inquiry broadly, to include
consideration of all substances to which
veterans may have been exposed during
the Gulf War, irrespective of whether
the exposures were unique to Gulf War
service or common to all service. In
defining VA’s regulation-writing
obligations, however, Congress
reasonably required VA to establish
presumptions of service connection
only for the health effects of substances
that are ‘‘associated with’’ Gulf War
service. As noted above, that limitation
furthers Congress’ purpose of
establishing presumptions for the
unique health concerns of Gulf War
veterans and also avoids the inequity of
establishing presumptions exclusively
for Gulf War veterans based on
exposures that are common to most
veterans.
Our conclusion that the hydrazines
and combustion products in question, in
isolation, cannot at this time be
VerDate Aug<31>2005
17:36 Aug 27, 2008
Jkt 214001
determined to be ‘‘associated with’’ Gulf
War service is not intended to suggest
that they are irrelevant to further
investigations of Gulf War veterans’
health or that they may not in any
circumstance form the basis for
presumptions of service connection
under Public Law 105–277. In the event
future evidence links any illnesses to a
combination of exposures associated
with Gulf War service, whether or not
including exposure to fuels, combustion
products, and propellants, VA may
establish presumptions of service
connections for such illnesses pursuant
to Public Law 105–277.
This determination also in no way
prevents veterans from obtaining service
connection for the health effects
discussed in the NAS report where the
potential for above-normal exposures
was present in service. Under
established current procedures, VA
develops and considers evidence
concerning events or aspects of service
that may contribute to the incurrence of
an illness. Accordingly, if a veteran’s
occupation in service, such as a
firefighter or mechanic, entailed abovenormal exposure to combustion
products, VA will give due
consideration to that unique exposure in
determining whether service connection
is warranted for a health effect known
to be associated with such exposure.
Similarly, if a veteran served in a role
that may have involved exposure to
hydrazines, VA will evaluate that factor
in determining whether service
connection is warranted for a disease
associated with such exposure. These
standards apply to claims by veterans of
any period of service, and are not
dependent upon any presumption of
service connection. A presumption of
service connection is not needed for the
purpose of establishing a link between
exposure to combustion products or
hydrazines and any disease identified in
the NAS report as associated with such
exposures, because those health effects
are generally well known and, in any
event, the NAS report itself provides
significant additional evidence of such
an association. Accordingly, the
determination not to establish a
generally applicable presumption based
on the NAS report will not preclude the
grant of benefits to any individual
whose service entailed the type of
exposure NAS found to be associated
with an increased risk of disease
incurrence.
V. Conclusion
After careful review of the findings of
the 2004 NAS report, ‘‘Gulf War &
Health Vol. 3: Fuels, Combustion
Products, and Propellants,’’ and other
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Fmt 4703
Sfmt 4703
50869
pertinent information including reports
from DoD on potential exposure of U.S.
service members, the Secretary has
determined that the scientific evidence
presented in the 2004 NAS report and
other information available to the
Secretary indicates that no new
presumption of service connection is
warranted for any of the illnesses
described in the 2004 NAS report.
Approved: August 21, 2008.
James B. Peake,
Secretary of Veterans Affairs.
[FR Doc. E8–19971 Filed 8–27–08; 8:45 am]
BILLING CODE 8320–01–P
DEPARTMENT OF VETERANS
AFFAIRS
Voluntary Service National Advisory
Committee; Notice of Meeting
The Department of Veterans Affairs
(VA) gives notice under Public Law 92–
463 (Federal Advisory Committee Act)
that the Executive Committee to the
Department of Veterans Affairs
Voluntary Service (VAVS) National
Advisory Committee (NAC) will meet
October 6–7, 2008, at the Marriott West
Chase, Houston, Texas. The sessions
will begin at 8 a.m. each day and end
at 4:30 p.m. on October 6 and at noon
on October 7. The meeting is open to the
public.
The NAC consists of 63 national
organizations and advises the Secretary,
through the Under Secretary for Health,
on the coordination and promotion of
volunteer activities within VA health
care facilities. The Executive Committee
consists of 18 representatives from the
NAC member organizations.
On October 6, agenda topics will
include: NAC goals and objectives,
minutes of April 2008 NAC meeting,
Veterans Health Administration update,
VAVS update on the Voluntary Service
program’s activities since the 2008 NAC
annual meeting, Parke Board update,
evaluations of the 2008 NAC annual
meeting and plans for the 2009 NAC
annual meeting (to include workshops
and plenary sessions). On October 7,
agenda topics will include:
Recommendations from the 2008 NAC
annual meeting, subcommittee reports,
standard operating procedure revisions,
2010 NAC annual meeting planning,
and new business.
No time will be allocated at this
meeting for receiving presentations from
the public. However, interested persons
may either attend or file statements with
the Committee. Written statements may
be filed either before the meeting or
within 10 days after the meeting and
addressed to: Ms. Laura Balun,
E:\FR\FM\28AUN1.SGM
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Agencies
[Federal Register Volume 73, Number 168 (Thursday, August 28, 2008)]
[Notices]
[Pages 50856-50869]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: E8-19971]
=======================================================================
-----------------------------------------------------------------------
DEPARTMENT OF VETERANS AFFAIRS
Determination of Presumption of Service Connection Concerning
Illnesses Discussed in National Academy of Sciences Report on Gulf War
and Health
AGENCY: Department of Veterans Affairs.
ACTION: Notice.
-----------------------------------------------------------------------
SUMMARY: As required by law, the Department of Veterans Affairs (VA)
hereby gives notice that the Secretary of Veterans Affairs, under the
authority granted by the Persian Gulf War Veterans Act of 1998, Public
Law 105-277, title XVI, 112 Stat. 2681-742 through 2681-749 (codified
in part at 38 U.S.C. 1118), has determined that there is no basis to
establish a presumption of service connection at this time for any of
the diseases, illnesses, or health effects discussed in the December
20, 2004, report of the National Academy of Science, titled ``Gulf War
and Health, Volume 3. Fuels, Combustion Products, and Propellants''
based on exposure to fuels, combustion products, or propellants during
service in the Persian Gulf during the Persian Gulf War. This
determination does not in any way preclude VA from granting service
connection for any disease, including those specifically discussed in
this notice, nor does it change any existing rights or procedures.
FOR FURTHER INFORMATION CONTACT: Rhonda F. Ford, Chief, Regulations
Staff (211D), Compensation and Pension Service, Veterans Benefits
Administration, Department of Veterans Affairs, 810 Vermont Avenue,
NW., Washington, DC 20420, (202) 461-9739.
SUPPLEMENTARY INFORMATION:
I. Statutory Requirements
The Persian Gulf War Veterans Act of 1998, Public Law 105-277,
title XVI, 112 Stat. 2681-742 through 2681-749 (codified at 38 U.S.C.
1118), and the Veterans Programs Enhancement Act of 1998, Public Law
105-368, 112 Stat. 3315, directed the Secretary to seek to enter into
an agreement with the National Academy of Sciences (NAS) to review and
evaluate the available scientific evidence regarding associations
between illnesses and exposure to toxic agents, environmental or
wartime hazards, or preventive medicines or vaccines to which service
members may have been exposed during service in the Persian Gulf during
the Gulf War. Congress directed NAS to identify agents, hazards,
medicines, and vaccines to which service members may have been exposed
during service in the Persian Gulf during the Gulf War.
Congress mandated that NAS determine, to the extent possible: (1)
Whether there is a statistical association between exposure to the
agent, hazard, medicine, or vaccine and the illness, taking into
account the strength of the scientific evidence and the appropriateness
of the scientific methodology used to detect the association; (2) the
increased risk of illness among individuals exposed to the agent,
hazard, medicine, or vaccine; and (3) whether a plausible biological
mechanism or other evidence of a causal relationship exists between
exposure to the agent, hazard, medicine, or vaccine and the illness.
Section 1118 provides that whenever the Secretary determines, based
on sound medical and scientific evidence, that a positive association
(i.e., the credible evidence for the association is equal to or
outweighs the credible evidence against the association) exists between
exposure of humans or animals to a biological, chemical, or other toxic
agent, environmental or wartime hazard, or preventive medicine or
vaccine known or presumed to be associated with service in the
Southwest Asia theater of operations during the Persian Gulf War and
the occurrence of a diagnosed or undiagnosed illness in humans or
animals, the Secretary will publish regulations establishing
presumptive service connection for that illness. If the Secretary
determines that a presumption of service connection is not warranted,
the Secretary is to publish a notice of that determination, including
an explanation of the scientific basis for that determination. The
Secretary's determination must be based on consideration of the NAS
reports and all other sound medical and scientific information and
analysis available to the Secretary.
Although section 1118 does not define ``credible evidence,'' it
does instruct the Secretary to take into consideration whether the
results (of any report, information, or analysis) are statistically
significant, are capable or replication, and withstand peer review. See
38 U.S.C. 1118(b)(2)B). Simply comparing the number of studies that
report a significantly increased relative risk to the number of studies
that report a relative risk that is not significantly increased is not
a valid method for
[[Page 50857]]
determining whether the weight of evidence overall supports a finding
that there is or is not a positive association between exposure to an
agent, hazard, or medicine or vaccine and the subsequent development of
the particular illness. Because of differences in statistical
significance, confidence levels, control for confounding factors, and
other pertinent characteristics, some studies are clearly more credible
than others, and the Secretary has given the more credible studies more
weight in evaluating the overall weight of the evidence concerning
specific illnesses.
II. Prior National Academy of Sciences Reports
NAS issued its initial report titled, Gulf War and Health, Volume
1: ``Depleted Uranium, Sarin, Pyridostigmine Bromide, Vaccines,'' on
January 1, 2000. In that report, NAS limited its analysis to the health
effects of depleted uranium, the chemical warfare agent sarin,
vaccinations against botulism toxin and anthrax, and pyridostigmine
bromide, which was used in the Gulf War as a pretreatment for possible
exposure to nerve agents. On July 6, 2001, VA published a notice in the
Federal Register announcing the Secretary's determination that the
available evidence did not warrant a presumption of service connection
for any disease discussed in that report. See 66 FR 35702 (2001).
NAS issued its second report titled, ``Gulf War and Health, Volume
2: Insecticides and Solvents,'' on February 18, 2003. In that report,
NAS focused on the health effects of insecticides and solvents that
were shipped to the Persian Gulf during the Persian Gulf War. The
pesticides considered by NAS were organophosphorous compounds
(malathion, diazinon, chlorpyrifos, dichlorvos, and azamethiphos),
carbamates (carbaryl, propoxur, and methomyl), pyrethrins and
pyrethyroids (permethrin and d-phenothrin), lindane, and N,N-diethyl-3-
methylbenzamide (DEET). NAS considered 53 solvents in eight groups:
Aromatic hydrocarbons (including benzene), halogenated hydrocarbons
(including tetrachloroethylene and dry-cleaning solvents), alcohols,
glycols, glycol esters, esters, ketones, and petroleum distillates. On
August 24, 2007, VA published a notice in the Federal Register
announcing the Secretary's determination that the available evidence
did not warrant a presumption of service connection for any disease
discussed in that report. 72 FR 48734 (2007).
III. Gulf War and Health, Volume 3. Fuels, Combustion Products, and
Propellants
NAS issued a third report, titled ``Gulf War and Health, Volume 3.
Fuels, Combustion Products, and Propellants,'' on December 20, 2004. In
that report, NAS focused on the health effects of hydrazines, red
fuming nitric acid, hydrogen sulfide, oil-fire byproducts, diesel-
heater fumes, and fuels (for example, jet fuel and gasoline).
In its report, NAS classified the evidence of an association
between exposure to a specific agent and a specific health outcome into
five categories:
Sufficient Evidence of a Causal Association: This category
means the evidence is sufficient to conclude that there is a causal
association between exposure to a specific agent and a specific health
outcome in humans. The evidence is supported by experimental data and
fulfills the guidelines for sufficient evidence of an association. The
evidence must be biologically plausible and satisfy several of the
guidelines used to assess causality, such as: Strength of association,
dose-response relationship, consistency of association, and a temporal
relationship.
NAS did not find any health outcomes that met the criteria for this
category.
Sufficient Evidence of an Association: This category means
the evidence is sufficient to conclude that a consistent association
has been observed between exposure to a specific agent and a specific
health outcome in human studies in which chance and bias, including
confounding, could be ruled out with reasonable confidence. For
example, several high-quality studies report consistent associations,
and the studies are sufficiently free of bias, including adequate
control for confounding.
NAS found sufficient evidence of an association between exposure to
combustion products and lung cancer.
Limited/Suggestive Evidence of an Association: This
category means the evidence is suggestive of an association between
exposure to a specific agent and a specific health outcome, but the
body of evidence is limited by the inability to rule out chance and
bias, including confounding, with confidence. For example, at least one
high-quality study reports an association that is sufficiently free of
bias, including adequate control for confounding. Other corroborating
studies provide support for the association, but they were not
sufficiently free of bias, including confounding. Alternatively,
several studies of lower quality show consistent associations, and the
results are probably not due to bias, including confounding.
NAS found limited/suggestive evidence of an association between
exposure to combustion products and cancers of the nasal cavity and
nasopharynx; cancers of the oral cavity and oropharynx; laryngeal
cancer; bladder cancer; low birthweight/intrauterine growth retardation
(with exposure during pregnancy); preterm birth (with exposure during
pregnancy); and incident asthma.
NAS found limited/suggestive evidence of an association between
exposure to hydrazines and lung cancer.
Inadequate/Insufficient Evidence: This category means the
evidence is of insufficient quantity, quality, or consistency to permit
a conclusion regarding the existence of an association between exposure
to a specific agent and a specific health outcome in humans.
NAS found inadequate/insufficient evidence of an association
between exposure to fuels and cancers of the oral cavity and
oropharynx; cancers of the nasal cavity and nasopharynx; esophageal
cancer; stomach cancer; colon cancer; rectal cancer; hepatic cancer;
pancreatic cancer; laryngeal cancer; lung cancer; melanoma; nonmelanoma
skin cancer; female breast cancer; male breast cancer; female genital
cancers (cervical, endometrial, uterine, and ovarian cancers);
prostatic cancer; testicular cancer; nervous system cancers; kidney
cancer; bladder cancer; Hodgkin's disease; non-Hodgkin's lymphoma;
multiple myeloma; myelodysplastic syndromes; adverse reproductive or
developmental outcomes (including infertility, spontaneous abortion,
childhood leukemia, central nervous system (CNS) tumors, neuroblastoma,
and Prader-Willi syndrome); peripheral neuropathy; neurobehavioral
effects; Multiple Chemical Sensitivity symptoms; nonmalignant
respiratory disease; chronic bronchitis; asthma; emphysema; dermatitis
(irritant and allergic); and sarcoidosis.
NAS found inadequate/insufficient evidence of an association
between exposure to combustion products and esophageal cancer; stomach
cancer; colon cancer; rectal cancer; hepatic cancer; pancreatic cancer;
melanoma; female breast cancer; male breast cancer; female genital
cancers (cervical, endometrial, uterine, and ovarian cancers);
prostatic cancer; testicular cancer; nervous system cancers; ocular
melanoma; kidney cancer; non-
[[Page 50858]]
Hodgkin's lymphoma; Hodgkin's disease; multiple myeloma, leukemia;
myelodysplastic syndromes; preterm births (based on exposure during a
specific time period during pregnancy, such as the first trimester);
low birth weight and intrauterine growth retardation (based on exposure
before gestation or during a specific period during pregnancy, such as
the first trimester); specific birth defects, including cardiac effects
(with maternal or paternal exposure before conception or maternal
exposure during early pregnancy); all childhood cancers identified,
including acute lymphocytic leukemia, leukemia, neuroblastoma, and
brain cancer; neurobehavioral effects; post-traumatic stress disorder;
nervous system subgroupings (or individual nervous system diseases);
Multiple Chemical Sensitivity symptoms; chronic bronchitis (less than 1
year of exposure); emphysema; chronic obstructive pulmonary disease;
ischemic heart disease or myocardial infarction (less than 2 years of
exposure); dermatitis (irritant and allergic); and sarcoidosis.
NAS found inadequate/insufficient evidence of an association
between exposure to hydrazines and hematopoietic and lymphopoietic
cancers; digestive tract cancers; pancreatic cancer; bladder cancer;
kidney cancer; emphysema; ischemic heart disease or myocardial
infarction; and hepatic disease.
NAS found inadequate/insufficient evidence of an association
between exposure to nitric acid and stomach cancer; melanoma;
lymphopoietic cancers; pancreatic cancer; laryngeal cancer; lung
cancer; bladder cancer; multiple myeloma; and cardiovascular diseases.
Limited/Suggestive Evidence of No Association: This
category means the evidence is consistent in not showing an association
between exposure to a specific agent and a specific health outcome
after exposure of any magnitude. A conclusion of no association is
inevitably limited to the conditions, magnitudes of exposure, and
length of observation in the available studies. The possibility of a
very small increase in risk after exposure studied cannot be excluded.
NAS did not find any health outcomes that met the criteria for this
category.
A. Combustion Products
1. Sufficient Evidence of an Association
NAS found sufficient evidence of an association between combustion
products and lung cancer. NAS found that there was evidence of
associations between exposure to ambient air pollution, engine
exhausts, and heating sources (coal) and lung cancer. Cohort and case-
control studies showed consistently that risks increased with
increasing ambient air pollution. There was evidence from both cohort
and case control studies that increasing exposure to engine exhausts
and its components such as polycyclic aromatic hydrocarbons (PAHs)
increased the risk of lung cancer.
Based on 82 epidemiological studies, NAS derived a positive finding
of ``sufficient evidence of an association'' between exposure to
combustion products and lung cancer. The epidemiological studies
included cohort studies on the health effects of ambient air pollution
on people dwelling in cities, workers exposed to motor vehicle exhaust,
and case-control studies of lung cancer patients. The case-control
studies were of lung cancer patients who were exposed in their
occupation, or in their homes or daily lives to indoor air pollution
from combustion products from wood, coal, kerosene or gas burning
stoves or heaters over years. Relevant occupational exposures included
working as a bus, taxi, or truck driver, or as a miner or railroad
worker.
NAS pointed out that lung cancer from all causes is the leading
cause of cancer death among both men and women, and that smoking may be
responsible for 80% of lung cancer cases. Nevertheless, NAS concluded
that ``there was evidence of associations between exposure to ambient
air pollution, engine exhausts, and heating sources (coal) and lung
cancer.'' Cohort and case-control studies showed consistently that
risks increased with increasing ambient air pollution. There was
evidence from both cohort and case-control studies that increasing
exposure to engine exhausts and to its components increased the risk of
lung cancer.
The Secretary has determined that, although there is sufficient
evidence of an association between combustion products and lung cancer,
VA does not consider this exposure to be ``associated with'' the 1991
Gulf War. Please see section IV for further detail.
2. Limited/Suggestive Evidence of an Association
NAS found limited/suggestive evidence of an association between
exposure to combustion products and cancers of the nasal cavity and
nasopharynx; cancers of the oral cavity and oropharynx; laryngeal
cancer; bladder cancer; low birthweight/intrauterine growth retardation
and exposure during pregnancy; preterm birth and exposure during
pregnancy; and incident asthma.
The results of the studies of the relationship between combustion
products and cancers of the nasal cavity and nasopharynx were
inconsistent, and indirect methods were used to assess exposure.
However, positive associations were reported between combustion
products (particularly wood smoke) and cancer of the nasopharynx.
NAS's positive finding of ``limited/suggestive evidence of an
association'' between exposure to combustion products and cancers of
the nasal cavity and nasopharynx was based on 4 epidemiological case-
control studies. These studies involved patients with nasal cavity and
nasopharynx cancer, who were exposed regularly to combustion products,
by virtue of their occupation or in their daily lives, over many years.
Relevant exposures included exposure to fumes from the burning of wood
and other materials, use of fuels, and occupational exposures such as
working as a motor vehicle driver. Although NAS found these studies
showed inconsistent results, they concluded that positive associations
were reported by studies conducted in China between combustion products
(particularly wood smoke) and cancer of the nasopharnyx.
NAS's positive finding of ``limited/suggestive evidence of an
association'' between exposure to combustion products and cancers of
the oral cavity and oropharynx was based on 9 epidemiological case-
control studies. These epidemiological studies were of oral cavity and
oropharynx cancer patients who were exposed to ambient air pollution in
the cities where they lived, or who were exposed over many years due to
their occupation or to indoor pollution in their homes due to
combustion products from wood, coal, kerosene or gas burning stoves or
heaters. Occupational exposures included working as a motor vehicle
driver or railroad employee. NAS concluded that results of several
studies suggested an association between cancers of the oral cavity and
oropharynx and exposure to combustion products.
NAS's positive finding of ``limited/suggestive evidence of an
association'' between exposure to combustion products and laryngeal
cancer was based on one epidemiological cohort study of workers exposed
to diesel exhaust, and 16 epidemiological case-control studies of
patients with laryngeal cancer. These studies involved people who were
exposed to combustion products due to their occupations as railway
workers, motor
[[Page 50859]]
vehicle drivers, or as city commuters exposed to ambient air pollution.
The studies also included people who used wood and other fuel burning
stoves regularly. Several studies reported positive findings, including
two studies regarding exposure to the emissions of fossil-fuel stoves
and one study regarding exposure to wood-stove emissions. Several
studies reported small increases in laryngeal-cancer risk for some
exposures; however, overall, the results were inconsistent. NAS
concluded that the epidemiologic literature overall provided limited/
suggestive evidence of an association between exposure to combustion
products and laryngeal cancer.
NAS found ``limited/suggestive evidence of an association'' between
exposure to combustion products and bladder cancer. Studies that
assessed the relationship between exposure to combustion products and
bladder cancer have not been consistently positive, and no studies
assessed measurements of exposure. One pooled analysis of occupational
exposures found questionably increased risks in exhaust-related
occupations, and the risk was increased with higher exposures to
polycyclic aromatic hydrocarbons (PAHs) and benzopyrene, which are
combustion products. A slightly increased risk was observed for diesel
exhaust. In a related study, similar findings were noted with some
exposures to exhausts and PAHs. A more detailed assessment of PAH
exposures based on expert review of work-history information found
apparently stable associations with average and cumulative PAH
exposures and total duration of PAH exposures. Taken together, the
results constituted limited or suggestive evidence of an association
between combustion products and bladder cancer, but the lack of
exposure measurements and the heterogeneity of results precludes
classifying the association as sufficient.
NAS's positive finding of ``limited/suggestive evidence of an
association'' between exposure to combustion products during pregnancy
and low birthweight or intrauterine growth retardation was based on 8
epidemiological studies of pregnant women. These women were exposed to
ambient air pollution ``smog'' in heavily polluted cities in the Czech
Republic where coal was burned, and in urban cities located in South
Korea, China, Canada, and the United States.
Two studies found evidence of a relationship between low
birthweight or intrauterine growth retardation and combustion-product
exposure. Their analyses controlled for several known risk factors,
including maternal smoking. Several other studies reviewed by NAS
provided supportive evidence of a relationship, but most were unable to
adjust for maternal smoking.
NAS's positive finding of ``limited/suggestive evidence of an
association'' between exposure to combustion products during pregnancy
and preterm birth was based on four epidemiological studies. The
studies that found evidence of a relationship between preterm birth and
combustion-product exposure were based primarily on maternal residence
during pregnancy. Most of these studies controlled for several known
risk factors for preterm birth (such as maternal age, race, education,
and access to prenatal care), but none of the studies could completely
control for maternal smoking, which is an important risk factor for
preterm birth.
NAS's positive finding of ``limited/suggestive evidence of an
association'' between exposure to combustion products and asthma was
based primarily on two studies, which evaluated an association between
asthma and exposure to combustion products in ambient air pollution.
NAS also relied on a study of veterans of the 1991 Gulf War that found
an association between oil-well fire smoke and asthma, and a study
associating ``biomass combustion'' and asthma among people over 60
years old living in India.
The epidemiological studies found that new cases of asthma were
associated with combustion-product exposure in air pollutants. A study
of Gulf War veterans using an objective exposure-measurement method,
found an association between oil-well fire smoke and asthma in Gulf War
veterans, but could not distinguish between new cases arising after the
war and exacerbation of pre-existing conditions. Although the other key
Gulf War study found no relationship between exposure and asthma, its
definition of asthma was inadequate. Other studies of biomass-fuel
combustion and outdoor air pollution supported a relationship between
combustion exposure and asthma.
The Secretary has determined that, although there is limited/
suggestive evidence of an association between exposure to combustion
products and cancers of the nasal cavity and nasopharynx; cancers of
the oral cavity and oropharynx; laryngeal cancer; bladder cancer; low
birthweight/intrauterine growth retardation (with exposure during
pregnancy); preterm birth (with exposure during pregnancy); and
incident asthma, VA does not consider this exposure to be ``associated
with'' the 1991 Gulf War. Please see section IV for further detail.
3. Inadequate/Insufficient Evidence
NAS found inadequate/insufficient evidence between exposure to
combustion products and esophageal cancer; stomach cancer; colon
cancer; rectal cancer; hepatic cancer; pancreatic cancer; melanoma;
female breast cancer; male breast cancer; female genital cancers
(cervical, endometrial, uterine, and ovarian cancers); prostatic
cancer; testicular cancer; nervous system cancers; ocular melanoma;
kidney cancer; non-Hodgkin's lymphoma; Hodgkin's disease; multiple
myeloma, leukemia; myelodysplastic syndromes; preterm births (based on
exposure during a specific time period during pregnancy, such as the
first trimester); low birth weight and intrauterine growth retardation
(based on exposure before gestation or during a specific period during
pregnancy, such as the first trimester); specific birth defects,
including cardiac effects (with maternal or paternal exposure before
conception or maternal exposure during early pregnancy); all childhood
cancers identified, including acute lymphocytic leukemia, leukemia,
neuroblastoma, and brain cancer; neurobehavioral effects; post-
traumatic stress disorder; nervous system subgroupings (or individual
nervous system diseases); Multiple Chemical Sensitivity symptoms;
chronic bronchitis (less than 1 year of exposure); emphysema; chronic
obstructive pulmonary disease; ischemic heart disease or myocardial
infarction (less than 2 years of exposure); dermatitis-irritant and
allergic; and sarcoidosis.
NAS reviewed five studies of combustion products and esophageal
cancer, and concluded that no consistent association was observed in
those studies.
NAS reviewed six studies of combustion products and stomach cancer.
Two of the studies reported an increased risk for stomach cancer, but
the method used to assess exposure was limited and there were no
adjustments for confounders.
Studies of exposure to combustion products and colon cancer
reported positive associations for exposure to some combustion
products, but not to others. Further, a number of the positive findings
were limited, due to their large confidence intervals. NAS found that
the evidence of an association was inadequate because of the small
number of studies available.
With regard to rectal cancer, NAS found the studies' results were
inconsistent, and the number of studies was small. NAS also noted that
any
[[Page 50860]]
positive studies failed to include at least one high-quality study
supported by an adequate exposure assessment.
NAS noted only one relevant study that evaluated exposure to
combustion products and hepatic cancer. Although associations were
noted for some occupations, there were few cases with relevant
exposure, and the study did not consider all pertinent risk factors.
The four reviewed studies of combustion-product exposure and
pancreatic cancer generally did not provide evidence of an association.
One study found an association between exposure to coal combustion
products and increased risk of pancreatic cancer, but it did not find a
link between nine other types of combustion products and pancreatic
cancer.
Studies regarding melanoma addressed exposure to combustion
products but their reliability is limited because they failed to adjust
for exposure to sunlight, a major risk factor for melanoma. Overall,
the studies did not report significant findings of association for most
types of exposure. Two studies found isolated effects of specific
exposures (propane exhaust and being a traffic administrator,
respectively) that were not among the major exposures considered by
NAS.
NAS reviewed three studies concerning nonmelanoma skin cancer and
combustion products. The studies generally did not report statistically
significant findings of an association. NAS found that for the more
common type of nonmelanoma skin cancer (basal cell carcinoma), the
findings were largely negative. Two of the studies stated findings
regarding squamous cell carcinoma, with one finding a statistically
significant association for one type of exposure (diesel fumes), but
not others, and one study finding no association.
The two studies involving female breast cancer and exposure to
combustion products essentially had negative results.
Of the two reviewed studies regarding exposure to combustion
products and male breast cancer, one did not find an association
between PAH exposure and male breast cancer, and the other, although
reporting a positive association, was limited by its method of exposure
assessment.
NAS reviewed three studies regarding exposure to fuels or
combustion products and cervical, endometrial, uterine, or ovarian
cancer, and found that they provided inadequate support for an
association.
NAS reviewed four prostate cancer studies that measured the
relationship between occupations having potential for exposure to
combustion products or PAHs or having more rigorously derived estimates
of exposure to such agents and prostatic cancer. Although the studies
reported several positive associations, NAS noted that the results were
not consistently positive. For example, one study showed results
contrary to a dose-response relationship, while another study showed an
increased risk in firefighters and railroad workers but not in other
transportation or trucking workers.
Testicular cancer studies did not provide enough relevant data to
draw any sort of conclusion about exposure to fuels or combustion
products and testicular cancer.
Data on combustion products and brain cancer (nervous system
cancers) were too sparse to determine whether an association exists.
Three studies of ocular melanoma reported increased, but imprecise,
risks of ocular melanoma in occupations related to transportation. The
reliability of these studies is limited by their small size, lack of
statistical significance, and lack of adequate exposure assessment.
Although some studies of exposure to combustion products and kidney
cancer suggested a possible association based on job title, NAS found
that the results were not consistently positive, with some studies
showing no increased risk. Further, the results of some studies showing
positive associations were limited by considerations of statistical
significance and other factors.
Studies on non-Hodgkin's lymphoma (NHL) had no firmly positive
findings. In the study with the most objective exposure assessment,
there was no indication of an association with any of the fuels or
their combustion products.
The studies regarding Hodgkin's disease (HD) were limited by their
small numbers of cases and the nonspecificity of their exposure
assessments. Further, the three primary studies reviewed by NAS showed
findings of no association.
NAS reviewed ten studies concerning multiple myeloma and exposure
to combustion products. Three of the studies the NAS found to be among
the most sizable or significant reported only marginally increased
risks and are just barely suggestive of an association. Other studies
showed no association, and yet other studies are limited due to
imprecise estimates of increased multiple-myeloma risk in association
with exhaust exposure and concerns regarding exposure assessments. NAS
concluded that the literature overall provided insufficient evidence of
an association.
NAS reviewed six studies of leukemia and exposure to combustion
products. Four of the studies showed no findings of a statistically
significant increased risk. In the other two studies, the apparent
associations were related to separate types of leukemia, and the
authors of the studies noted that any increase in leukemia risk was
difficult to attribute specifically to exhaust because of concurrent
exposure to fuels and benzene. The exposure assessments in all the
studies were based on information from sources of questionable
reliability (personal interviews or medical records) or had a low
degree of specificity for combustion products.
NAS reviewed two studies regarding myelodysplastic syndromes and
exposure to combustion products. One study found no significant
evidence of an association. The other study found stable evidence of an
association for the not particularly substance-specific occupation of
machine operator. Further, the reliability of that study is limited
because the analyses by researchers were rudimentary and failed to
adjust for possible confounders when the information was available.
As noted above in section III.A.2, NAS found limited/suggestive
evidence of an association between exposure to combustion products
during pregnancy and preterm birth. NAS similarly found limited/
suggestive evidence of an association between exposure to combustion
products during pregnancy and low birth weight or intrauterine growth
retardation. However, NAS also found that there was inadequate/
insufficient evidence of an association between combustion products
exposure at any specific point during pregnancy (such as the first
trimester) and these reproductive effects. Although several of the
studies NAS reviewed reported results for exposure at different stages
of pregnancy, there were no consistent findings as to whether the risks
were greater with exposure early or late in pregnancy. Additionally,
none of the studies completely controlled for the significant risk
factor of smoking during pregnancy.
One study of an association between maternal exposure to air
pollutants and the risk of birth defects reported relationships between
certain cardiac defects and increasing exposure to CO and O3. NAS
discussed two studies that examined the association between paternal
employment as a firefighter and the risk of cardiac birth defects. One
of the studies found no evidence of an association, while the other
found some evidence that certain cardiac defects were associated with
paternal employment as a firefighter. Both studies had limitations due
to size,
[[Page 50861]]
potential confounding and/or inadequate information about duration of
paternal firefighting. In a study of maternal or paternal exposures
among residents of Rotorua, New Zealand, a city with high geothermal
exposure to hydrogen sulfide, no excess birth defects were reported in
comparison with residents in the rest of New Zealand.
NAS discussed eleven studies of the association between combustion-
products exposure and childhood cancers, including acute lymphocytic
leukemia, leukemia, neuroblastoma, and brain cancer. All of the studies
were limited by their inability to validate employment history and by
the lack of details on specific assessments of exposure to combustion
products. The exposure groups were broad and included many diverse
occupations where exposure to other chemicals was noted in addition to
combustion products. Six of the studies found no association between
combustion products exposure and the studied childhood cancers. One
study reported general findings of associations for a variety of
childhood cancers, while the remaining four studies contained mixed
findings, reporting positive associations for certain types of cancers.
All of the studies on neurobehavioral effects and combustion-
product exposure suffered from significant methodological limitations.
Several Gulf War studies reported positive relationships between self-
reported exposure and self-reported neuropsychologic, cognitive, or
mood symptoms or multiple unexplained symptoms, but the lack of
objective measurement of exposure limits the reliability of those
findings. Among two non-veteran studies reporting positive findings for
certain neurobehavioral effects, one study did not have a control
group, and the other had serious limitations, especially in subject
selection.
NAS identified no studies showing an association between
combustion-products exposure and post-traumatic stress disorder (PTSD).
Although several studies addressed the prevalence of PTSD among
firefighters, the result is most likely attributable to the hazardous
nature of the job rather than exposure to combustion products. Only a
few Gulf War studies have examined whether self-reported combustion-
product exposure was related to PTSD as an outcome measure, and none
has found such a relationship. None of the studies with objectively
measured oil-well fire smoke examined PTSD as an outcome measure.
Regarding nervous system disease subgroupings (or individual
nervous system diseases), NAS excluded studies involving only overbroad
and nonspecific health outcomes and focused on individual neurologic
diseases or subgroupings of nervous-system diseases. Only two
identified studies examined nervous-system subgroupings in relation to
combustion-products exposure. One study found exposure-response
relationships with nervous-system subgroupings in a hospital discharge
survey. The limitation of this study was assignment of exposure
(residence only) and potential for exposure misclassification. The
other study did not find a relationship between combustion product
exposure and multiple sclerosis. No other studies of nervous system
subgroups or the individual diseases met NAS's criteria for inclusion.
Although NAS reviewed several studies of Multiple Chemical
Sensitivity (MCS) in Gulf War veteran or civilian samples, those
studies provided relatively little evidence that MCS was associated
with combustion-products exposure in service. Several studies involved
questionnaires on which veterans or civilians self-reported that
exposure to certain combustion products (e.g., tobacco smoke, car
exhaust) are among the factors that can trigger their symptomatology.
However, NAS noted that most of the studies did inquire as to the first
onset of symptoms. Further, the studies generally were limited by
methodologic concerns, including self-reported exposures and symptoms
and the possibility of recall bias.
Although the studies reviewed by NAS indicated a probable
relationship between long-term (over 1 year) exposure to combustion
products and chronic bronchitis, a key unresolved issue was whether
shorter-term exposures (less than 1 year) can cause the condition. NAS
found inadequate published data that addressed the effect of shorter
term combustion-product exposures (less than 1 year) on the risk of
developing chronic bronchitis. Even if it could be shown that long-term
exposure to combustion products caused chronic bronchitis, it might be
expected to cease after exposure without long-term health consequences.
NAS found inadequate published data to evaluate the natural history of
chronic bronchitis after cessation of exposure to combustion products.
A study found that mortality due to emphysema was not considerably
increased among workers exposed to diesel exhaust. This result was
found after adjustments for the effects of smoking were made. Likewise,
a study of veterans exposed to oil-well fires also did not find a
relationship with emphysema. Other studies that included emphysema in
the analysis were methodologically inadequate.
NAS did not identify any high-quality studies that evaluated the
effect of exposure to combustion products on the risk of chronic
obstructive pulmonary disease (COPD), as defined by objective evidence
of irreversible airflow obstruction with spirometry. Several studies of
biomass-smoke exposure used measures of airflow obstruction but had
methodologic limitations that precluded clear conclusions about the
connection between combustion exposure and COPD.
There was relatively consistent epidemiologic evidence of the
relation between ischemic heart disease (including myocardial
infarction) and long-term exposure to fossil-fuel combustion products,
including motor-vehicle exhaust and combustion-derived fine particulate
matter. However, the increased risk was small in absolute terms, and
there was no adequate epidemiologic evidence to support the role of
relatively short exposures (similar to that experienced in the Gulf
War), followed by an exposure-free period, and then development of
ischemic heart disease events. Accordingly, NAS found inadequate/
insufficient evidence to determine whether an association exists
between short-term exposure (less than 2 years) to combustion products
and the development of ischemic heart disease after an exposure-free
period of months or years.
Rashes were frequently reported by Gulf War veterans, but only one
study of Gulf War veterans searched for relationships between
dermatitis and self-reported exposure during the Gulf War. No exposure
to combustion products or any other self-reported exposure was related
to dermatitis, defined as rashes, eczema, or skin allergies.
NAS identified three epidemiologic studies on the relationship
between occupational or residential exposure to fires and sarcoidosis,
all of which had significant methodologic limitations. One study had
numerous limitations, such as inadequate description of how the cases
without biopsy confirmation were diagnosed and the lack of control for
employment history (besides farming), recall bias, and lack of
measurement of pollutant concentrations. The authors noted that
sarcoidosis could be associated with a component of wood-burning or
wood-
[[Page 50862]]
handling, namely contact with smoke, ash, wood particles, or wood
molds. Another study was limited by the lack of specific exposure
assessment and of analysis of duration or frequency of exposure to
combustion products. There was no control for potential confounders,
such as race or familiar aggregation of sarcoidosis. In addition, there
was no way to determine the role of combustion products or exposure to
other toxicants, allergens, or infectious agents. The third study was
limited by the small sample, the low statistical power, the lack of a
risk estimate for firefighters versus police officers, the lack of
exposure assessment for combustion products, and the lack of assessment
of coexposures to other chemicals in the workplace.
Based on the information and analysis in the NAS report, the
Secretary has determined that there is insufficient credible evidence
to conclude that there is a positive association between exposure to
combustion products and esophageal cancer; stomach cancer; colon
cancer; rectal cancer; hepatic cancer; pancreatic cancer; melanoma;
nonmelanoma skin cancer; female breast cancer; male breast cancer;
female genital cancers (cervical, endometrial, uterine, and ovarian
cancers); prostatic cancer; testicular cancer; nervous system cancers;
ocular melanoma; kidney cancer; non-Hodgkin's lymphoma; Hodgkin's
disease; multiple myeloma, leukemia; myelodysplastic syndromes; preterm
births (based on exposure during any specific time period during
pregnancy, such as the first trimester); low birth weight and
intrauterine growth retardation (based on exposure before gestation or
during any specific period during pregnancy, such as the first
trimester); specific birth defects, including cardiac effects (with
maternal or paternal exposure before conception or maternal exposure
during early pregnancy; all childhood cancers identified, including
acute lymphocytic leukemia, leukemia, neuroblastoma, and brain cancer;
neurobehavioral effects; post-traumatic stress disorder; nervous system
disease subgroupings (or individual nervous system diseases); MCS
symptoms; chronic bronchitis (less than 1 year of exposure); emphysema;
chronic obstructive pulmonary disease; ischemic heart disease or
myocardial infarction (less than 2 years of exposure); dermatitis-
irritant and allergic; and sarcoidosis. Further, as explained in
section IV of this notice, VA does not consider the combustion-products
exposures underlying the NAS findings to be exposures ``associated
with'' the 1991 Gulf War. Therefore, a presumption of service
connection is not warranted for any such illness based upon exposure to
combustion products during service in the Gulf War.
B. Hydrazines
1. Limited/Suggestive Evidence of an Association
NAS found limited/suggestive evidence of an association between
exposure to hydrazines (monomethylhydrazine ``MMH,'' and unsymmetrical
(1,1-)dimethylhydrazine ``UDMH'') used as rocket propellants, and lung
cancer. This conclusion was based primarily on one high-quality study,
as discussed below.
An occupational study of a U.S. cohort of aerospace workers engaged
in testing rockets using hydrazine fuel demonstrated an association
between hydrazine exposure and risk of lung cancer. Several sources of
potential confounding, including sex and radiation exposure, were
controlled by study design. Other potentially confounding variables
were controlled in multivariate analysis, including age, pay type, and
time since hire or transfer. Although the smoking status of most
workers was unknown, there was indirect evidence that smoking did not
confound the results.
Two other studies of lung cancer were limited by small sample size
and inadequate study power. In addition, another study was limited by
its failure to control for coexposure to other carcinogenic substances,
including asbestos and PAHs. The lack of internal control subjects and
the lack of information on smoking constitute major limitations for
both studies. Consequently, there was inadequate evidence to evaluate
the consistency of the association between hydrazine and lung cancer
beyond the study of the U.S. cohort.
NAS stated in its report that U.S. military personnel could have
been exposed to UMDH during Operation Desert Storm if UMDH was used as
a rocket fuel in Scud missiles launched by Iraq and the U.S. military
personnel were in the vicinity of the Scud missiles when they
disintegrated. However, NAS stated that hydrazines were apparently not
used in Scud missiles during the 1991 Gulf War even though Iraq had
apparently experimented with UDMH as a rocket fuel. NAS further stated
that it was not aware of any other potential use of hydrazines that
could have resulted in exposure of U.S. service personnel.
Based on information and analysis in the NAS report and from DoD,
VA does not consider exposure to hydrazines to be exposures
``associated with'' the 1991 Gulf War. Please see section IV for
further detail. Therefore, a presumption of service connection is not
warranted for lung cancer based upon exposure to hydrazine during
service in the 1991 Gulf War.
2. Inadequate/Insufficient Evidence
NAS found inadequate/insufficient evidence between hydrazines and
hematopoietic and lymphopoietic cancers; digestive tract cancers;
pancreatic cancer; bladder cancer; kidney cancer; emphysema; ischemic
heart disease or myocardial infarction; and hepatic disease.
NAS noted that relatively few studies existed concerning the health
effects of hydrazine exposure, and that lung cancer was the only health
outcome represented in all three cohort studies reviewed by the
committee. NAS further noted that individual findings in those studies
also reported somewhat increased mortality from cancer at sites other
than the lung (hematopoietic and lymphopoietic, bladder and kidney,
digestive tract, and pancreas) and from two noncancer conditions
(emphysema and ischemic heart disease). NAS concluded, however, that
the few available studies do not provide adequate or consistent
evidence of an association between exposure to hydrazines and any of
those other health outcomes.
Based on the information and analysis in the NAS report, the
Secretary has determined that there is insufficient credible evidence
to conclude that there is a positive association between exposure to
hydrazines and hematopoietic and lymphopoietic cancers; digestive tract
cancers; pancreatic cancer; bladder cancer; kidney cancer; emphysema;
ischemic heart disease or myocardial infarction; and hepatic disease.
Further, as explained in section IV of this notice, VA does not
consider exposure to hydrazines to be exposures ``associated with'' the
1991 Gulf War. Therefore, a presumption of service connection is not
warranted for any such illness based upon exposure to hydrazine during
service in the 1991 Gulf War.
C. Fuels--Inadequate/Insufficient Evidence
NAS found inadequate/insufficient evidence of an association
between exposure to fuels and cancers of the oral cavity and
oropharynx; cancers of the nasal cavity and nasopharynx; esophageal
cancer; stomach cancer; colon cancer; rectal cancer; hepatic cancer;
pancreatic cancer; laryngeal cancer; lung cancer; melanoma; nonmelanoma
skin cancer; female breast
[[Page 50863]]
cancer; male breast cancer; female genital cancers (cervical,
endometrial, uterine, and ovarian cancers); prostatic cancer;
testicular cancer; nervous system cancers; kidney cancer; bladder
cancer; Hodgkin's disease; non-Hodgkin's lymphoma; multiple myeloma;
myelodysplastic syndromes; adverse reproductive or developmental
outcomes (including infertility, spontaneous abortion, childhood
leukemia, CNS tumors, neuroblastoma, and Prader-Willi syndrome);
peripheral neuropathy; neurobehavioral effects; MCS symptoms;
nonmalignant respiratory disease; chronic bronchitis; asthma;
emphysema; dermatitis-irritant and allergic; and sarcoidosis.
NAS reviewed five studies regarding cancer of the oral cavity and
oropharynx and fuels. NAS found that the three occupational cohort
studies it reviewed each had limited statistical power and were
therefore uninformative. NAS further concluded that the two case-
control studies it reviewed failed to report any consistent
relationship between fuel exposure and cancers of the oral cavity and
oropharynx.
NAS found little information available on exposure to fuels and
cancers of the nasal cavity and nasopharynx, and that the two studies
it reviewed failed to provide convincingly positive findings.
NAS found that studies of an association between fuel exposure and
esophageal cancer were few and results were inconsistent and inadequate
to support an association. Some of the studies were unreliable because
they analyzed esophageal cancer and stomach cancers together, and NAS
therefore could not determine which specific cancer type may have been
associated with fuel exposure. Other studies showed no evidence of
association.
NAS also found that studies of an association between fuel exposure
and stomach cancer were inconsistent and inadequate to support an
association. As noted above, some of the studies were unreliable
because they analyzed esophageal cancer and stomach cancers together in
relation to fuel exposure and NAS could not determine which specific
cancer type may have been associated with fuel exposure. Other studies
showed no evidence of association.
NAS found that the studies concerning fuel exposure and colon
cancer provided no consistent evidence of an association. Although some
studies showed increased risk of colon cancer, the increases were
modest and the confidence intervals in several instances included the
null. Three studies analyzed colon cancer and rectal cancer together
and, therefore, NAS could not determine whether exposure to fuels may
have been associated with a specific type of cancer.
NAS found that the studies reporting positive associations between
fuels and rectal cancer were not consistent and the number of studies
was small. Furthermore, the positive studies failed to include at least
one high-quality study supported by an adequate exposure assessment.
Some studies found no evidence of association between fuel exposure and
rectal cancer.
NAS noted only one relevant study that evaluated exposure to fuels
and hepatic cancer in which there were few cases with relevant
exposure, and the study did not consider all pertinent risk factors.
NAS found only two relevant studies on the risk of pancreatic
cancer posed by fuel exposure. One study found no association. The
other study reported an association, but the results were imprecise,
due in part to a large confidence interval that included the null.
NAS found that the results regarding exposure to fuels and
laryngeal cancer were inconsistent. Two studies reviewed by NAS
reported a modest increase in the risk of laryngeal cancer associated
with exposure to fuels, but the reliability of those findings is
limited because the exposures in both studies were self-reported.
Another study reported an increased, but imprecise, risk of laryngeal
cancer in vehicle mechanics, but found no increase in garage and
gasoline-station workers.
NAS found the results of studies of fuel exposure and lung cancer
risk were inconsistent. One study reported an association between
kerosene and crude-oil exposure and squamous-cell lung cancer, between
diesel-fuel exposure and nonadenocarcinoma, and between heating-oil
exposure and oat-cell lung cancer. Two studies did not find an
association in workers most likely to have been exposed to fuels.
The studies examined by NAS addressing melanoma and exposure to
fuels were not adjusted for sun exposure, a major risk factor for
melanoma, and the workers--particularly the exploration, drilling, and
pipeline workers--may have received considerable sun exposure while
performing their jobs. But the one case-control study with fairly
reliable exposure analysis did not support an association in workers
likely to have been exposed to fuels.
Of the available epidemiologic studies regarding nonmelanoma skin
cancer that met NAS's criteria, one study reported one borderline
association between fuel exposure and squamous-cell carcinoma. The
other two reports reviewed by NAS had methodologic limitations and did
not provide reliable evidence of an association. For the more common
type of nonmelanoma skin cancer (basal cell carcinoma), the findings
were largely negative.
NAS reviewed three studies concerning fuel exposure and female
breast cancer. One study found no increased risk of breast cancer,
while the other two found only an insignificant increase in risk.
NAS found no studies assessing the possible relationship of male
breast cancer to fuel exposure alone. NAS reviewed one study that
reported a positive finding regarding combined exposure to fuels and
combustion products and male breast cancer. NAS found, however, that
the method used to assess exposure in that study was limited.
NAS reviewed three studies concerning fuel exposure and female
genital cancers. The studies failed to provide any significant evidence
of an association between exposure to fuels and cervical, endometrial,
uterine, or ovarian cancer.
NAS reviewed several studies regarding an association between fuel
exposure and prostatic cancer. Only one of those studies reported a
positive association between a fuel-related exposure and prostatic
cancer. That study found an association between exposure to diesel fuel
and prostate cancer, but did not find significant evidence of an
association for other types of fuel exposure. The other reports
reviewed by NAS were negative for any association.
Only one study addressed the association between fuel exposure and
testicular cancer, and it found no evidence of an association. NAS
concluded that there was not enough relevant data to draw any sort of
conclusion about exposure to fuels and testicular cancer.
Several studies reported sporadic associations between fuel
exposure and nervous system cancers (brain cancer), but the results
were limited by several factors, including wide confidence intervals
that include the null. In some studies, the increased risk was found
only among workers likely to have lesser fuel exposure, while no
increased risk was seen among workers likely to have greater fuel
exposure. None of the studies could be considered a high-quality study
supported by an adequate
[[Page 50864]]
exposure assessment. Additionally, some studies found no evidence of
association.
No key study that was positive for an association between exposure
to fuels and kidney cancer was identified. NAS found the uniformly
negative results of a study of a comprehensive sample of renal cell
carcinoma cases in the petroleum industry with excellent exposure
assessment to be compelling.
NAS reviewed several studies concerning fuel exposure and bladder
cancer. Several of the studies found no evidence or no significant
evidence of an association. Other studies provided evidence of a
relationship between fuel exposure and bladder cancer, but the
relationship was not consistently increased in any study with a
detailed and specific exposure assessment. The positive findings in
some studies were further limited by the methods used to estimate
exposure and the difficulty in segregating fuel exposure from
combustion-product exposure in some instances.
Regarding Hodgkin's disease, the studies were limited by their
small numbers of cases and the nonspecificity of their exposure
assessments. Of the five studies reviewed by NAS, two found no evidence
of an association between fuel exposure and Hodgkin's disease, one
found an insignificant increase only among males. The other two studies
showed evidence of an association, but were limited by wide confidence
intervals and the lack of any relationship to a specific job or
duration of employment.
Studies on non-Hodgkin's lymphoma had no firmly positive findings.
The most well conducted studies showed no evidence of association.
NAS found no consistent relationship between exposure to fuels and
multiple myeloma in the studies reviewed. Most studies reported no
association.
NAS reviewed two studies that showed evidence of an association
between myelodysplastic syndrome and exposure to petroleum-related
substances. However, a significantly larger study using similar methods
and procedures failed to produce consistent results. The larger study
reported only a modest increased risk, with confidence intervals
including the null, and did not find any evidence of a dose-response
relationship with duration or intensity of exposure.
NAS determined that it was difficult overall to reach conclusions
on the epidemiologic studies of adverse reproductive outcomes and
exposure to fuels. The assessment of findings was limited by the small
number of studies available on each health outcome, the possibility of
recall bias, and the lack of specificity of exposure to the agents of
concern in this report. NAS found no adequate studies regarding the
relationship between fuel exposure and female infertility. NAS found
one study concerning fuel exposure and male fertility, and that study
showed no effect on sperm measures among persons exposed to jet fuels.
NAS found only one study on fuel exposure and spontaneous abortion. The
study showed a significant increase in spontaneous abortion among women
living in an area where water used for drinking, cooking, and bathing
was contaminated by nearby oil fields, however, the finding was
potentially limited by recall bias and methods of estimating exposure.
NAS identified one study showing an increased risk of childhood
leukemia in the offspring of men exposed to petroleum for 1,000 days or
more before conception, and one study showing an increased risk of
childhood leukemia based on maternal exposure to fuels during
pregnancy. The latter study was potentially limited by recall bias,
interviewer bias, control-selection procedures, and lack of validation
for other risk factors. NAS noted that three other occupational studies
showed no relationship between parental employment in a field involving
fuel exposure and childhood leukemia. With respect to childhood cancers
of the central nervous system, NAS identified one study showing no
increase in neuroblastoma based on maternal exposure to fuels during
pregnancy, but moderate increases based on paternal exposures. The
study authors were unable to distinguish between paternal exposures
occurring before or after conception. Another study showed an increased
risk of neuroblastoma based on maternal or paternal exposures, although
the study authors noted several limitations on the interpretation of
the data, including bias, chance, and self-reporting of exposure
information. NAS noted that two studies showed a possible association
between parental exposure to hydrocarbons and the occurrence of Prader-
Willi Syndrome in offspring, although neither study collected
information on potential confounders. A third study found no
association between exposure to hydrocarbons and Prader-Willi Syndrome
in offspring. In view of the minimal and indeterminate data, NAS
concluded that there was inadequate/insufficient evidence of an
association between parental fuel exposure and adverse reproductive or
developmental outcomes.
Regarding neuropathy, NAS reviewed two studies, in which certain
neurological symptoms were more prevalent among subjects with higher
exposures to jet fuels, while other neurological symptoms were either
not increased or were more prevalent among controls. NAS concluded
that, although certain symptomatic differences were apparently related
to exposure, there were no objective measures to support a relationship
between jet-fuel exposure and neuropathy. The limitations of the
studies included small samples and the lack of internal nonexposed
groups of controls.
Regarding neurobehavioral effects, NAS found that several studies
of Gulf War veterans found a relationship between the veterans' self-
reported fuel exposure and their self-reported neuropsychologic,
cognitive, or non-specific symptoms, but that these studies provided
weak evidence of any relationship, due to recall bias. NAS also
discussed a study of increased neurologic and cognitive abnormalities
among persons who engaged in ``petrol-sniffing,'' but found those
results inconclusive because the effects were most likely due to
exposure to lead rather than the fuels themselves.
NAS found that studies of MCS in Gulf War veteran or civilian
samples generally provided relatively little evidence that MCS was
associated with fuel exposure in service. Several studies involved
questionnaires on which veterans or civilians self-reported that
exposure to fuels are among the factors that can trigger their
symptomatology. The studies generally were limited by methodologic
concerns, including self-reported exposures and symptoms and the
possibility of recall bias. Further, NAS noted that most of the studies
did not address the factors relating to the first onset of symptoms as
distinguished from subsequent recurrence of symptoms. The only study
addressing first onset was an occupational study that incorporated
objective exposure measurement and found a relationship between
symptoms of MCS and fuel exposure. However, because the study was
limited by the small sample and lack of a matched control group of
workers, NAS found that it did not meet the criteria for a primary
study that could support an association.
Regarding respiratory diseases, the studies generally did not
report specific respiratory disease outcomes and exposure assessment,
so it was difficult to reach a conclusion as to a relationship between
respiratory disease outcomes and exposure to fuels. However, NAS noted
that most of the studies it reviewed showed
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standardized mortality ratios of 1.0 or less in study populations,
showing no increased risk of death due to nonmalignant respiratory
disease, asthma, chronic bronchitis, or emphysema in populations
exposed to fuels.
Regarding irritant contact dermatitis, many fuels (for example,
gasoline and kerosene) were generally acknowledged skin irritants, as
indicated by the studies reviewed by NAS. Irritant contact dermatitis
was evident soon after exposure but usually disappeared soon after
removal of the irritant. There are few epidemiologic studies, however,
of exposure to fuels and irritant and allergic contact dermatitis.
Accordingly, NAS concluded that there was inadequate/insufficient
evidence of an association between fuel exposure and chronic irritant
and allergic contact dermatitis after cessation of exposure.