Date: Friday, October 24, 2003 6:29 AM
Subject: Some comments on your paper
 
I reviewed your paper about dioxin toxicity late in 2002. At your request I have re-examined the paper and prepared a short comment on it.
 
Your presentation of the scientific data -- both the toxicology data and the epidemiology information -- is clear and accurate. You did not pick and choose among the data and information to find "evidence" for a "conclusion" that you had already drawn. Instead, you present the data fairly and then inform the reader about your interpretation of it.
 
I agree with your interpretation. The data do not support the claims that dioxin has caused demonstrable health effects (with the exception of chloracne and other effects among some workers and Seveso citizens who were subjected to acutely toxic exposures as a result of chemical plant accidents). You also make clear that there are great difficulties -- and unmeasurable errors -- in extrapolating from toxicology results obtained at doses that are three and four orders of magnitude greater than human environmental exposures to make predictions of human risk.
 
I expect that any scientist who reads your paper and considers the data that you examine would agree that your presentation of the data is fair and balanced unless that scientist is bound to a policy that insists that the data are to be "mined" to find support for a policy that insists dioxin is a major risk to human health. A scientist or anyone else who accepts that policy position can say that your presentation and interpretation of the data are flawed, but general statements without specific examples are of no value. Your interpretation of the data are contradictory to U.S. policy, but it does not contradict any interpretation that is based on science rather than science policy.
 
Your paper should be published. Your critics should welcome publication. The purpose of scientific publication is to subject data and interpretations to the review of the widest circle of scientists and interested readers. If there are errors in your presentation or flaws in your reasoning, publication is the surest method to ferret them out. I expect, however, that publication will reveal that your science is good and that your interpretations of the data are reasonable and scientifically based but inconsistent with policy.
 
Sincerely,
Michael Gough
 
"For the information of anyone who might read this, I am the author of Dioxin, Agent Orange [Plenum: New York, 1986] and a couple dozen papers about dioxin risks. I chaired the DHHS committee that advises the United States Air Force about its health study of the Air Force personnel who sprayed 90 percent of the Agent Orange used in Vietnam from 1985-1990, and I rejoined the committee as a member at the request of HHS Secretary Shalala in 2000. I was a government expert on the EPA's Science Advisory Board Committee that reviewed EPA's dioxin risk assessment in 1995. During and after my employment at the congressional Office of Technology Assessment, I testified before Congress about dioxin and Agent Orange about two dozen times."