text:
Blue Water Navy Vietnam Veterans and Agent Orange Exposure (2011)
Chapter: 3 SELECTED CHEMICALS USED DURING THE VIETNAM WAR
« Previous: 2 HISTORICAL BACKGROUND
Suggested Citation:"3 SELECTED CHEMICALS USED DURING THE VIETNAM WAR." Institute of Medicine. 2011. Blue Water Navy Vietnam Veterans and Agent Orange Exposure. Washington, DC: The National Academies Press. doi: 10.17226/13026.
SELECTED CHEMICALS USED DURING THE VIETNAM WAR
This chapter discusses three groups of chemicals used by the US military in Vietnam. First and in greatest depth, the committee reviews the use of tactical herbicides, such as Agent Orange, which is the focus of this report. Second, some other chemicals used abundantly by the US military during the war—including such nontactical pesticides as malathion, and jet and diesel fuels—are described. Finally, Blue Water Navy and Brown Water Navy personnel were exposed to many chemicals that were needed to operate and maintain their ships. Exposure opportunity varied greatly with a sailor's occupation, the class of ship, and the activity that required the use of the chemical(s). Many of the chemicals used aboard are known to be toxic and can result in both short-term and long-term adverse health effects. Because naval personnel are known to have been exposed to at least some of these chemicals during their tours of duty in Vietnam, the committee found it important to identify and describe a few of the chemicals, their uses, and their long-term health effects.
HERBICIDE USE IN VIETNAM
During the Vietnam War (1962–1975), both the US and the Republic of Vietnam militaries used several herbicides for tactical purposes, specifically to defoliate areas to reduce cover for enemy forces, to improve visibility on the perimeters of military installations, and for a short time to kill enemy crops. Both the US Air Force and the US Army Chemical Corps purchased herbicides and used them in Vietnam. Different tactical herbicides were used at different times during the war (Young, 2009). By far the most widely used herbicide was Agent Orange, followed by Agent White; other tactical herbicides that were
used in Vietnam during the war include Agent Blue, Agent Purple, Agent Pink, and Agent Green. The names of the herbicides were derived from the color-coded bands around the 55-gal (208-L) drums used to ship and store them (Young, 2009). The military use of herbicides has been discussed in several other Institute of Medicine (IOM) reports (IOM, 1994, 2003, 2008) and two books (Buckingham, 1983; Young, 2009), and will not be described in detail here.
The tactical herbicides used in Vietnam were intended to kill a broad spectrum of plants. Agent Orange and Agent White were used against broadleaf plants and woody shrubs and trees, including mangroves. Agent Blue was effective against grasses and grains, such as rice (Young, 2009).
Herbicide Composition
2,4,5-Trichlorophenoxyacetic acid (2,4,5-T) was the main active ingredient of Agent Orange and the herbicides used earlier in the Vietnam War. As a result of the synthesis of 2,4,5-T, it was contaminated with 2,3,7,8-tetrachlorodibenzo-p-dioxin (2,3,7,8-TCDD, also referred to as TCDD). Production of 2,4,5-T ceased in 1979 when the US Environmental Protection Agency (EPA) canceled all registrations for its use (EPA, 1979). The EPA based that decision on its toxicity resulting from its unavoidable TCDD contamination. Of the herbicides used in Vietnam, only those containing 2,4,5-T were contaminated with TCDD. 2,4-dichlorophenoxyacetic acid (2,4-D)—a second active ingredient of Agent Orange, Agent White, and Agent Purple—was and continues to be a widely used herbicide around the world. Its human health and environmental risks were assessed by the EPA in 2005 to support its reregistration. It is permitted for agricultural and residential herbicide use (EPA, 2005).
The magnitude of TCDD contamination in the herbicides used in Vietnam is the subject of controversy. Part of the issue is that the herbicides were not tested for TCDD content when manufactured or used. Assessment of TCDD content is based on the analysis of the herbicide stockpiles that were stored at Johnston Island in the Pacific and the Naval Construction Battalion Center in Gulfport, Mississippi, before their destruction by at-sea incineration in 1977. The TCDD content was known to vary by herbicide and by production run. Some manufacturers were able to reduce the TCDD concentrations in their 2,4,5-T during the 1960s, particularly after 1967 when one manufacturer installed an
activated carbon filter (Piacitelli et al., 2000); other manufacturers also reduced the TCDD contamination of their 2,4,5-T by about 1968 (Young, 2009). Stellman et al. (2003) reports that TCDD concentrations in Agent Orange ranged from 6.2 to 14.3 ppm (average, 13.25 ppm), but other ranges have been estimated on the basis of other herbicide samples, for example, less than 0.05 to 17.0 ppm (NAS, 1974), and the levels reported by Young (2009) in Table 3-1. Agent Purple was likely to have been even more highly contaminated with TCDD than Agent Orange (Stellman et al., 2003), containing up to 45 ppm TCDD. It is also likely that the herbicides used earlier in the war, such as Agent Pink, were more highly contaminated with TCDD. Stellman et al. (2003) calculated that 221 kg of TCDD was sprayed in Vietnam by US forces, and this does not include herbicides used by the Vietnamese forces or herbicides sprayed other than by C-123 aircraft. Young (2009) reported that 105–119 kg of TCDD were sprayed by US forces, based on his lower estimates of TCDD contamination of Agent Orange.
Agent Orange, the most widely used herbicide in Vietnam, was soluble in diesel fuel and organic solvents but not soluble in water. Agent White, in contrast, was soluble in water but not soluble in diesel fuel or organic solvents. Agent Blue was a powder that was mixed with water before application; the formulation contained organic pentavalent arsenic (Young, 2009). According to Young (2009), all the tactical herbicides used in Vietnam were applied in concentrated form and not diluted.
Intentional Release of Herbicides in Vietnam
It has been estimated that over 74 million liters of tactical herbicides were used in Vietnam during 1961–1971, of which Agent Orange made up almost 60% (43 million liters) (see Table 3-1). The amount of Agent Orange sprayed varied by military region: I Corps south of the demilitarized zone–8.52 million liters; II Corps–9.54 million liters; III Corps near Saigon–20.1 million liters, and IV Corps in the Mekong Delta region–4.66 million liters (IOM, 1994). The herbicides were purchased from several US chemical manufacturers and transported via commercial Merchant Marine ships from the United States to military installations in Vietnam. Blue Water Navy and Coast Guard vessels were not used to transport herbicides from the United States to the Republic of Vietnam (Baldini, 2009). The US Air Force's Operation Ranch Hand was the military code name for the US Air Force's spraying of herbicides in Vietnam from 1962 to 1971, when the operation was discontinued.
TABLE 3-1 Major Herbicides Used in Operation Ranch Hand, 1962–1971
Amount Sprayed in Vietnam, liters
Period of Use
TCDD Concentration
65.6 ppm
2,4-D, 2,4,5-T
Up to 45 ppm
Cacodylic acid (4.7%), sodium cacodylate (26.4%)
Orange I, Orange II
2,4-D (50%), 2,4,5-T (50%)
0.05–50 ppm (average, 1.98–2.99 ppm)
2,4-D (39.6%), picloram (10.2%)
SOURCE: Young (2009).
Operation Ranch Hand was responsible for the spraying of more than 95% of all herbicides used in Vietnam; spraying was done from modified C-123 aircraft (Stellman et al., 2003; Young, 2009). Defoliation occurred along waterways, roads, railroads, and other transportation routes to lower the risk of ambush. Extensive spraying was also conducted in the Mekong River delta area around the coastal mangrove swamps, also with the goal of reducing protective cover for the enemy. Operation Ranch Hand peaked in 1967, when 1.7 million acres of Vietnam and Laos were sprayed, 85% for defoliation and 15% for crop destruction.
A small proportion of the herbicides was applied by other means, such as backpacks, spray trucks, helicopters, and boats. The US Army Chemical Corps ground personnel sprayed herbicides from trucks or backpacks around base perimeters; other Army personnel sprayed herbicides from helicopters (Darrow, 1969) and directly from drums along waterways (Marolda, 1994). Members of the Army Chemical Corps reported spraying herbicides, handling spray equipment, being present when others were spraying, getting herbicides on their skin or clothing, and passing through defoliated areas (Kang et al., 2001). The Air Force maintained a record of spraying missions from August 1965 to December 1971 in the Herbicide Reporting System (HERBS) files. From 1968 to 1971, the HERBS files also contained information on the US Army helicopter spraying missions. The US Navy sprayed herbicides along river banks (Darrow, 1969), but the committee was unable to
locate any specific information on Navy herbicide spraying on inland waterways in Vietnam.
Land-Based Application
The Ranch Hand C-123 aircraft had herbicide spray apparatus with nozzles that produced droplets measuring 320–350 m with rapid settling velocity (Young et al., 2004b). A full tank sprayed a swath 80 m wide and 14 km long in 3.5–4 min. The average deposit was 2.9 mL/m2 (3 gal/acre). Virtually all droplets, even those smaller than 100 m, were estimated to intercept the target area within 3 min, and 87% of the Agent Orange would hit vegetation within 1 min; the remaining 13% of the herbicide would not contact vegetation within the designated swath and thus would drift as droplets or volatilize into the gas phase of air (Young, 2009).
The Ranch Hand aircraft sprayed from 50 m above the ground. Environmental conditions for a mission included inversion or neutral atmospheric conditions, that is, wind less than 10 knots (0.005 km/s) at ground level with flight paths oriented into the wind as much as possible, temperature below 29°C (missions were typically flown early in the morning), no rain or predicted rain, and good visibility. Multiple aircraft, up to eight, were used for some spray missions, although 70% of the missions involved three or fewer aircraft (Stellman et al., 2003; Young, 2009). The HERBS file for Operation Ranch Hand contains the most comprehensive data on the herbicide missions flown in Vietnam, including flight date, flight path, turning points and markers for activation and deactivation of spray apparatus, herbicide used, and aircraft type. After review and corrections, 9,141 missions are recorded in the HERBS file, including 1,081 ground missions and 2,108 helicopter missions (Jeanne Stellman, Columbia University, personal communications, October 21 and October 28, 2010). These missions included fighter support aircraft for protection against enemy fire (Young, 2009).
Land-based application via helicopters, trucks, and backpacks was conducted at lower speeds and lower altitudes (for helicopters) for base perimeter defoliation, roadside spraying, and some crop destruction. The Army Chemical Corps was responsible for these applications, which accounted for about 3–4% of the herbicide used in Vietnam. The buffalo turbine mounted on trucks could disperse herbicide at 280 m3/min and cover a swath 75 m wide. Backpack units held 11 L of herbicide.
As noted by both Stellman et al. (2003 and presentation to committee) and Young (2009), the flight paths of the C-123s often included flying over rivers, streams, and delta areas with direct application of Agent Orange or other herbicides to the water surface. An additional method of herbicide application was direct spraying by the Brown Water Navy on riverbanks. Although the committee heard several reports of such spraying and there is a video of it on the Internet (http://www.youtube.com/watch?v=wUZA0GAMmfI), the committee was unable to locate much documentation of the practice (Darrow, 1969) or to determine how much Agent Orange or other herbicides were applied.
Dumping of Herbicides in Coastal Waters
On the basis of the revised HERBS files, Stellman et al. (2003) reported that 42 missions, totaling about 120,000 L of herbicide, are known to have resulted in emergency herbicide dumps. Stellman et al. noted that "aborted missions may not represent the significant source of exposure." Only a few of the 42 missions that dumped herbicides appear to have been near the coast of South Vietnam (Jeanne Stellman, Columbia University, personal communication, November 1, 2010). The Army also verified that some herbicide was jettisoned over water near the Vietnamese coast (Department of the Army, 1981). The committee did not attempt to identify where each aborted or jettisoned missions occurred; this information may be contained in an uncorrected version of the HERBS file, known as the Map Book.
OTHER CHEMICAL-EXPOSURE OPPORTUNITIES
In addition to tactical herbicides, C-123s operating over Vietnam sprayed other pesticides. One of the banes of tropical warfare is malaria. In an effort to control the incidence of malaria in US ground troops in Vietnam, the military initiated Operation Flyswatter (Cecil and Young, 2008). That program, which began in 1967, used modified Ranch Hand C-123 aircraft, also known as Bug Birds, to spray malathion. Unlike the C-123s used for herbicide spraying, the Bug Birds flew alone without escort aircraft and were not camouflaged. Malathion was stored at Bien Hoa Air Base, Cam Ranh Bay Air Base, and Da Nang Air Base. Initially, the pesticide was sprayed over nine major US bases and adjacent sites every 11–14 days. Spraying typically was conducted 1.5 hr after dawn
and 1.5 hr before sunset. Malathion in a 57% concentrate (later 95%) was applied at 0.59 L/hectare. Environmental conditions were similar to those used for herbicide spraying—maximum winds of 10 knots (0.005 km/s), maximum temperature of 30°C, and no rainfall during or for 1 hr after spraying. Aircraft flew at 45 m above the ground at an air speed of 130 knots to cover about 6,000 hectares on one sortie (Cecil and Young, 2008). In all, Operation Flyswatter sprayed more that 1.76 million liters of malathion over about 6 million hectares in South Vietnam (Young et al., 2004a). Cecil and Young (2008) report that that was about half the total insecticides used by all forces during the war. Short-term exposure to high concentrations of malathion has been shown to produce disturbances to various organ systems including the following: gastrointestinal system (vomiting, cramps, diarrhea); respiratory system (difficulty breathing, chest tightness); and central nervous system (watery eyes, blurred vision, salivation, sweating, headaches, dizziness, loss of consciousness, and death) (ATSDR, 2003).
US military personnel in Vietnam also had substantial opportunity for exposure to diesel fuel. Diesel fuel was used not only for operating equipment and vehicles. JP-8 and JP-4, for instance, are types of diesel fuel used for aircraft such as jets and Huey helicopters. The committee heard reports that many of Navy personnel aboard aircraft carriers were frequently sprayed with jet fuel. Naval tankers delivered large amounts of diesel fuel to ground forces. Breathing fuel oils such as diesel fuel may result in short-term adverse effects, such as eye irritation, nausea, and headache; long-term exposure to diesel fuel fumes may result in kidney damage and loss of the blood's ability to clot (ATSDR, 1995).
CHEMICALS USED ABOARD US NAVY SHIPS
Blue Water Navy and Brown Water Navy personnel were exposed to many chemicals during their shipboard deployments. Exposure may have occurred by ingestion, inhalation, or dermal contact.
Some common chemicals found aboard surface vessels and their potential associated adverse health effects are presented in Table 3-2. The table is not meant to be comprehensive but rather represents some of the chemicals to which naval personnel might have been exposed while serving on ships in the Blue Water Navy during the Vietnam War. In
TABLE 3-2 Examples of Adverse Health Effects Associated with Chemical Exposure
Use Category
Adverse Health Effecta
Polychlorinated biphenylsb
Trichloroethylenec
Mercuryd
Explosives, disinfectants, batteries
Benzenee
Component of jet and other fuels, combustion product, cigarette smoke
Phosgenec
Asbestosb
Insulation, cement pipe, sealants, plasters
Cancer, pulmonary disease, asbestosis
Hydraulic fluidsc
Machinery lubricants
Leadb
Paint, cable and wire, plastics, pastes, caulks
Hydrazinef
Electroplating, soldering, boiler water
aLong-term adverse health effects from Haz-Map Database, National Library of Medicine.
bNavy Occupational Safety and Health Program Manual for Forces Afloat. Volume I. SOH and Major Hazard-Specific Programs (Department of the Navy, 2002).
cTrichloroethylene factsheet. Available at: http://www.nmcphc.med.navy.mil/downloads/ep/factsheets/tce.pdf (accessed January 19, 2011).
dNavy Occupational Safety and Health Program Manual for Forces Afloat. Volume II. Surface Ship Safety Standards (Department of the Navy, 2007).
eBenzene factsheet: Available at: http://www.nmcphc.med.navy.mil/downloads/ep/factsheets/benzene.pdf (accessed January 19, 2011).
fNavy MIL-H-24776: Hydrazine Test Kit, Naval Shipboard. 1992. Available at: http://engineers.ihs.com/document/abstract/NCSWDAAAAAAAAAAA (accessed January 19, 2011).
determining long-term adverse health effects of chemicals like those shown in Table 3-2, it is generally presumed that a person was exposed to a single chemical. However, in practice, personnel aboard naval vessels were exposed to a complex mixture of environmental contaminants. Those exposures could occur concurrently or sequentially. The importance of understanding the exposures is twofold. First, the
long-term adverse health effects of some of the chemicals are similar to those associated with exposure to dioxins, such as some cancers (for example, TCDD and benzene with leukemia) and peripheral neuropathy (for example, TCDD and mercury). A cancer induced by a shipboard chemical exposure cannot be differentiated from a similar cancer produced by TCDD, particularly given the multitude of chemical exposures that most people experience and the long latent period of most cancers. Second, chemicals in a mixture may antagonize or synergize each other's effects. For example, exposure to one chemical may make a person more susceptible or more resistant to the effect of a second chemical. If exposure to two chemicals is concurrent, it may result in an additive, synergistic, or antagonistic effect. It is noteworthy that sailors on naval vessels were exposed not only to a mixture of chemicals as a result of their occupations and the ventilation systems but to chemicals in cigarette smoke, which render smokers (as well as nonsmokers exposed to secondhand smoke) more susceptible to other chemicals (Hoffmann and Hoffmann, 1997; Goud and Kaplan, 1999). The chemical composition of a mixture may change as components degrade or interact with each other, or as a result of different manufacturing conditions (for example, TCDD concentrations varied from batch to batch during production of Agent Orange). All those factors may affect the chemical mixtures to which sailors were exposed aboard naval vessels and thus affect their susceptibility to TCDD and other chemical exposures.
Several factors influence the potential for exposure to chemicals both onboard ships and shoreside. Among them are the class and mission of a ship, the ventilation system on the ship, and the use of multiple chemicals. Events such as shipboard transformer fires can also expose crewmembers to chemicals such as PCBs. Still et al. (2003) assessed PCB exposures on Navy surface ships and submarines, some dating to the Vietnam War. Although PCBs were not detected in any air samples taken on the surface ships, they were detected at 3,600 ppm in felt gasket material collected in the ventilation duct extraction system.
Many chemicals are used aboard ships in numerous occupational activities. In general, larger ships will have more chemicals onboard than smaller ships because there are more occupational activities on larger ships. For example, an aircraft carrier is essentially a floating industrial community, and the number of chemicals found onboard would be much higher than on a destroyer. An aircraft carrier would have chemicals onboard associated with the flying and maintenance of jet aircraft, whereas a destroyer or ammunition ship would not have such chemicals
onboard. However, many of the chemicals would be comparable onboard all classes of ships. For example, a degreaser used by machinists onboard aircraft carriers could also be used by machinists onboard destroyers or frigates.
Navy enlisted classifications (NECs) for naval surface ships include a wide array of occupations, from aerographer and construction electrician to hull maintenance technician, machinist's mate, and yeoman. However, it is difficult to identify all the chemicals to which a person with a given NEC might be exposed during occupational activity; furthermore, there is the possibility that other naval personnel may inadvertently be exposed to some chemicals even if they are not working directly with them, mainly because of the ventilation system onboard Navy ships.
Navy shipboard living and working conditions differ considerably from those found shoreside. Shipboard environments are influenced by ventilation systems that run throughout the entire ship. The systems have the potential to spread airborne materials collected at one site to other sites throughout the ship if not properly designed and maintained. The potential spread of occupationally produced airborne materials could have a serious influence on the health of shipboard personnel. If the ventilation system is isolating individual work activities, personnel in the area would potentially be exposed only to the chemicals used in that area. However, if the ventilation system is not functioning properly, vapors and other airborne materials from other work areas could also be present; this can result in mixing of chemicals from different work areas with resultant exposures to complex mixtures by personnel onboard the ship.
Shoreside personnel conducting work similar to that found onboard ships may be using the same industrial chemicals but work under different environmental conditions. The activities often have different types of ventilation systems, both mechanical and natural. A shoreside welder may work in an area that has both local exhaust ventilation and natural ventilation, which is provided by open windows and doors. A shipboard welder typically does not have the luxury of an open window. If welding is conducted on deck, there is ample natural ventilation, but if the work is conducted below deck, natural ventilation is not available, so the shipboard welder is potentially exposed to a greater variety and higher concentrations of chemicals if not properly protected.
Furthermore, there is considerable variation in environmental conditions for shoreside Navy personnel and, unlike shipboard naval personnel, they
are less likely to spend both work time and leisure time in the same environment.
Naval ships and shore activities undergo numerous types of evaluations and inspections that establish actual or potential hazardous situations. Before the inception of specific Occupational Safety and Health Administration (OSHA) or EPA inspections, the naval medical department conducted comparable inspections; a ship the size of an aircraft carrier has a fully complemented medical department, including environmental-health personnel, who in earlier days provided comparable industrial-hygiene support. The Navy has conducted safety and occupational health programs for many years. Those programs gained special prominence after passage of the Occupational Safety and Health Act (OSHAct) in 1970. The primary thrust of the OSHAct was directed at private-sector employers; however, Section 19 of the OSHAct and several later presidential executive orders directed federal agencies to establish and maintain occupational safety and health programs. Requirements for such programs are contained in Title 29 of the Code of Federal Regulations, Part 1960 (29 CFR 1960). OPNAVINST 5100.19 series addresses the shipboard environment. Inspections would have been conducted by a ship's medical personnel, Navy hospital personnel, Navy Environmental Preventive Medicine Units or the equivalent, type commands, fleet commands, the Naval Safety Center (which was established in 1968), the Board of Inspection and Survey, or the systems commands (for example, NavSea and NavAir).
ATSDR (Agency for Toxic Substances and Disease Registry). 1995. Public health statement for fuel oils. http://www.atsdr.cdc.gov/phs/phs.asp?id=514&tid=91 (accessed February 15, 2011).
ATSDR. 2003. Public health statement for malathion. http://www.atsdr.cdc.gov/phs/phs.asp?id=520&tid=92 (accessed February 15, 2011).
Baldini, D. 2009. Memorandum for record: Joint Services Records Research Center statement on research findings regarding Navy and Coast Guard ships during the Vietnam era. Alexandria, VA: Department of the Army, U.S. Army and Joint Services Records Research Center. May 1.
Brent, R. E., D. E. Rollins, D. P. Duffy, and M. C. Gregory. 1985. Standardized treatment of severe methanol poisoning with ethanol and hemodialysis. Western Journal of Medicine 142(3):337-340.
Buckingham, W. A. 1983. Operation Ranch Hand: Herbicides in Southeast Asia. Air University Review, July-August. 12 pgs. http://www.airpower.maxwell.af.mil/airchronicles/aureview/1983/jul-aug/buckingham.html (accessed October 18, 2010).
Cecil, P. F., and A. L. Young. 2008. Operation FLYSWATTER: A war within a war. Environmental Science and Pollution Research 15(1): 3-7.
Darrow, R. A. 1969. Report of trip to Republic of Vietnam, 15 August-2 September 1969. Department of the Army.
Department of the Army. 1981. Table, all MACV fixed wing aircraft herbicide incidents, 15 October 1981. Alexandria, VA: Department of the Army, Office of the Adjutant General.
Department of the Navy. 2002. Navy Occupational Safety and Health Program manual for forces afloat. Volume I. SOH and Major Hazard-Specific Programs. OPNAV Instruction 5100.19E. Washington, DC: Office of the Chief of Naval Operations.
Department of the Navy. 2007. Navy Occupational Safety and Health Program manual for forces afloat. Volume II. Surface Ship Safety Standards. OPNAV Instruction 5100.19E. Washington, DC: Office of the Chief of Naval Operations.
EPA (Environmental Protection Agency). 1979. Decision and emergency order suspending registration for the forest, rights-of-way, and pasture uses of 2,4,5-trichlorophenoxyacetic acid (2,4,5-T). Washington, DC: Office of Pesticide Programs.
EPA. 2005. Reregistration eligibility decision for 2,4-D. Washington, DC: Office of Pesticide Programs.
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Hoffmann, D. , and I. Hoffmann. 1997. The changing cigarette 1950-1995. Journal of Toxicology and Environmental Health 50:307-364.
IOM (Institute of Medicine). 1994. Veterans and Agent Orange: Health effects of herbicides used in Vietnam. Washington, DC: National Academy Press.
IOM. 2003. Characterizing exposure of veterans to Agent Orange and other herbicides used in Vietnam. Washington, DC: The National Academies Press.
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Somers, E. 1987. Modulation of response: Environmental factors. In Methods for Assessing the Effects of Mixtures of Chemicals, edited by V. B. Vouk, G. C. Butler, A. C. Upton, D. V. Parke and S. C. Asher. Chichester, UK: Scientific Committee on Problems of the Environment (SCOPE 30). http://globalecology.stanford.edu/SCOPE/SCOPE_30/SCOPE_30.html (accessed December 14, 2010).
Stellman, J. M., S. D. Stellman, R. Christian, T. Weber, and C. Tomasallo. 2003. The extent and patterns of usage of Agent Orange and other herbicides in Vietnam. Nature 422(6933):681-687.
Still, K. R., D. P. Arfsten, W. W. Jederberg, L. V. Kane, and B. J. Larcom. 2003. Estimation of the health risks associated with polychlorinated biphenyl (PCB) concentrations found onboard older U.S. Navy vessels. Applied Occupational and Environmental Hygiene 18(10):737-758.
Young, A. L. 2009. The history, use, disposition and environmental fate of Agent Orange: New York, NY: Springer.
Young, A. L., P. E. Cecil, and J. F. Guilmartin. 2004a. Assessing possible exposures of ground troops to Agent Orange during the Vietnam war: The use of contemporary military records. Environmental Science and Pollution Research 11(6):349-358.
Young, A. L., J. P. Giesy, P. D. Jones, and M. Newton. 2004b. Environmental fate and bioavailability of Agent Orange and its associated dioxin during the Vietnam War. [Review] [82 refs]. Environmental Science & Pollution Research 11(6):359-370.
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Next: 4 FATE AND TRANSPORT OF HERBICIDES USED IN VIETNAM »
Blue Water Navy Vietnam Veterans and Agent Orange Exposure Get This Book
Over 3 million U.S. military personnel were sent to Southeast Asia to fight in the Vietnam War. Since the end of the Vietnam War, veterans have reported numerous health effects. Herbicides used in Vietnam, in particular Agent Orange have been associated with a variety of cancers and other long term health problems from Parkinson's disease and type 2 diabetes to heart disease. Prior to 1997 laws safeguarded all service men and women deployed to Vietnam including members of the Blue Navy. Since then, the Department of Veteran Affairs (VA) has established that Vietnam veterans are automatically eligible for disability benefits should they develop any disease associated with Agent Orange exposure, however, veterans who served on deep sea vessels in Vietnam are not included. These "Blue Water Navy" veterans must prove they were exposed to Agent Orange before they can claim benefits. At the request of the VA, the Institute of Medicine (IOM) examined whether Blue Water Navy veterans had similar exposures to Agent Orange as other Vietnam veterans.
Blue Water Navy Vietnam Veterans and Agent Orange Exposure comprehensively examines whether Vietnam veterans in the Blue Water Navy experienced exposures to herbicides and their contaminants by reviewing historical reports, relevant legislation, key personnel insights, and chemical analysis to resolve current debate on this issue.
Front Matter i–xvi
SUMMARY 1–14
1 INTRODUCTION 15–28
2 HISTORICAL BACKGROUND 29–46
3 SELECTED CHEMICALS USED DURING THE VIETNAM WAR 47–60
4 FATE AND TRANSPORT OF HERBICIDES USED IN VIETNAM 61–86
5 EXPOSURE ROUTES AND MECHANISMS 87–108
6 LONG-TERM ADVERSE HEALTH EFFECTS 109–126
7 SUMMARY AND CONCLUSIONS 127–134
APPENDIX: CODISTILLATION DURING POTABLE WATER TREATMENT: ANALYSIS OF THE AUSTRALIAN STUDY 135–142


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Joe DiGenova believes it's critical Durham, FBI grill Obama over Trump spying
August 30, 2019 | Frieda Powers | Print Article
Joe diGenova wants to know when former President Barack Obama will be questioned by U.S. Attorney John Durham and the FBI.
The former U.S. attorney for the District of Columbia believes an interview of Obama "must" be conducted, telling a Fox News panel that it will be necessary in order to complete an ongoing investigation into the origins of the Russia probe.
(Video: Fox News)
Along with his wife and partner, Victoria Toensing, diGenova spoke with Fox News host Sean Hannity on Thursday about the release of the Department of Justice report on the investigation of former FBI Director James Comey.
"Today we learned what we already knew, that Comey is a liar and he violated the law," diGenova said on "Hannity" Thursday, reacting to the report released by Inspector General Michael Horowitz.
While Attorney General Bill Barr will not be prosecuting Comey over the findings, and the fired FBI chief gloated over what he saw as an exoneration, the report found that he "violated Department or FBI policy, or the terms of Comey's FBI Employment Agreement."
Comey's curious reaction doesn't mesh with 'reality' of scathing IG report that just dropped https://t.co/xxUmeAysyd pic.twitter.com/YRBvKneL9S
— Conservative News (@BIZPACReview) August 29, 2019
"As described in this report, we conclude that Comey's retention, handling, and dissemination of certain Memos violated Department and FBI policies, and his FBI Employment Agreement," the report concluded.
Though Comey seemed to have escaped prosecution for now, many felt Attorney General William Barr may be holding off in order to prosecute him for alleged FISA abuse.
In a separate investigation, a report by Horowitz is anticipated on alleged Foreign Intelligence Surveillance Act abuses in obtaining warrants against former Trump campaign aide Carter Page.
"We know that the FISA warrants, all four of them, were illegally obtained," diGenova said Thursday, reiterating the bombshell of sorts he revealed earlier in the week.
But he went on to point to the bigger issue in the IG's investigation.
"But when all is said and done, when you get to the end of the road, the issue is Susan Rice's January 20, 2017 email for the record where she outlines in great detail how President Obama knew about, authorized and obstructed people to operate 'by the book' in a counterintelligence operation against candidate Trump, president-elect Trump and President Trump," diGenova said.
"I want to know when is Barack Obama going to be interviewed by John Durham and the FBI," he demanded.
"Do you believe that will happen?" Hannity asked.
"I believe it will. I believe it must," diGenova responded.
"In fact, there is no way you can finish this investigation without interviewing the former president of the United States because his National Security Adviser said 'bingo,' he was at the head of it," he added.
Former prosecutor Andrew McCarthy implicated Obama last week in the administration's use of the government's law enforcement and intelligence apparatus against Trump.
"What I'm saying is that unlike criminal investigations, counter intelligence investigations are done for the president. The only reason to do them is to inform the president with the information he needs to protect the United States from foreign threats," McCarthy told Hannity.
Fmr US attorney implicates Obama in Trump spying https://t.co/FKt0pq4t6C
"If things were working properly the president should have been alerted about it and informed about it – it was a very important investigation," McCarthy added. "If they actually believed what they were telling the court, that it was a possibility that Donald Trump was actually a plant of the Kremlin, it would have been derelict on their part not to keep the president informed."
Back in June, Trump took a shot at Obama in a tweet, quoting Fox News host Tucker Carlson.
"Someone should call Obama up. The Obama Administration spied on a rival presidential campaign using Federal Agencies. I mean, that seems like a headline to me?" @TuckerCarlson It will all start coming out, and the Witch Hunt will end. Presidential Harassment!
— Donald J. Trump (@realDonaldTrump) June 12, 2019
Hannity addressed the question of Obama's involvement in his monologue Thursday, asking why the former president would have even begun a counter intelligence investigation of his successor.
Watch Hannity's remarks, beginning at the 7:43 minute mark, in the Fox News video below:
Frieda Powers
Senior Staff Writer
Originally from New York, Powers graduated from New York University and eventually made her way to sunny South Florida where she has been writing for the BizPacReview team since 2015.
Latest posts by Frieda Powers (see all)
Canadian reporter sneaks off to Florida to escape lockdown, is triggered by too much freedom - January 24, 2022
Pfizer announces new Omicron vax will be ready by March despite Fauci proclaiming 'no need' - January 11, 2022
Man who told Biden 'let's go Brandon' makes no apologies, corrects the record where he stands on Trump - December 28, 2021

redpajama_set_name: RedPajamaCommonCrawl


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Bollier's endorsement of Niermann leads senate president to remove her from committee leadership
Jay Senter - July 19, 2018 7:09 am
Sen. Barbara Bollier was removed as vice chair of the Senate Public Health and Welfare Committee after endorsing a Democrat in the Congressional race.
Republican Sen. Barbara Bollier, whose stances on Medicaid expansion, gun control and other issues have aggravated more conservative members of her party for years, was removed as vice chair of the Senate Public Health and Welfare Committee following her endorsement of a Democrat in the local Congressional race.
Bollier announced Wednesday she was supporting teacher Tom Niermann's bid for Congress, saying she did not believe incumbent Republican Kevin Yoder had represented the views of the district and that as a constituent she had been frustrated by his lack of town halls. She also said she would support Democratic Sen. Laura Kelly in her bid for governor should Kelly win her party's nomination.
Those moves prompted swift rebuke from Republican statehouse leaders. Senate President Susan Wagle and Majority Leader Jim Denning, whose district abuts Bollier's, issued a statement condemning her for crossing party lines.
"After Senator Bollier's embarrassing endorsements, I have no choice but to remove her from her leadership position, effective immediately," Wagle said.
Denning said he was committed to fostering an environment where "the caucus reflects Kansas values and the will of the voters who elected the Republican membership" and called Bollier's decision a "profound and personal disappointment to me."
Following Wagle and Denning's response, Niermann's campaign issued a statement saying she was "removed from her leadership positions today for speaking truth to power."
"Senator Bollier has a long record of standing up for what is right, regardless of what her party leaders demand of her," Niermann said. "She listens to her community, and works to improve their lives – standing up to the NRA, protecting our healthcare, and fully funding our public schools. Her commitment to community over party is the kind of leadership sorely missing in Washington, especially from Kevin Yoder."
For her part, Bollier told the Topeka Capital-Journal she would consider leaving the Republican party, and that she may look to join the new Party of the Center or become an independent.
Bollier's support of Niermann wasn't the only big endorsement news in the Kansas 3rd Congressional District race. President Donald Trump authored a tweet Wednesday afternoon thanking Rep. Yoder for his work on the Homeland Security appropriations subcommittee for securing money for border security and saying Yoder had his "full and total endorsement!":
Thank you to Congressman Kevin Yoder! He secured $5 BILLION for Border Security. Now we need Congress to support. Kevin has been strong on Crime, the Border, the 2nd Amendment, and he loves our Military and Vets. @RepKevinYoder has my full and total endorsement!
Previous articleBriefly noted: Briarwood students raise money for Water.org
Next articlePrairie Village mayoral candidates share views on rising property values, teardown-rebuilds, public financing incentives
MainStream Coalition taps Roeland Park councilman Michael Poppa as next executive director
At MainStream event in OP, Gov. Kelly stresses distinction between politics and partisanship
Former state Democratic Party leader to run for Bollier's seat in the Kansas Senate
Rose endorses Moran for Senate, Yoder for Congress
Jay Senter - June 24, 2010


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text:
Cambs Times > Things to do
Take a step back to the Sixties with a night of music at The Peterborough Cresset
Kath Sansom
Herman's Hermits - Credit: Archant
The ultimate 60's extravaganza is visiting venues across the UK on its 50th anniversary tour and for one night six legendary names take to the stage in Peterborough for an unforgettable night.
Ivy League Silver Suits - Credit: Archant
Herman's Hermits, The Swinging Blue Jeans, Dave Berry, The Union Gap uk, The Ivy League and Alan Mosca from Freddie and The Dreamers will be at the Cresset with a nostalgic night packed with hits such as I'm Into Something Good, Something Is Happening, No Milk Today, Mrs Brown You've Got A Lovely Daughter, Wonderful World, My Sentimental Friend, Hippy Hippy Shake and Tossing And Turning.
Herman's Hermits throughout the mid-60's music scene proved to be a dominating force worldwide. From 1964 the band chalked up over 23 top 20 singles, 10 hit albums and three 3 major movies.
The Swinging Blue Jeans have a history that spans back to the 1960's. Over the years their hit singles Hippy Hippy Shake, You're No Good, Good Golly Miss Molly and Don't Make Me Over have been the bedrock of the bands memorable live performances.
Dave Berry's heart has always remained in the 60's, when his top 10 singles, The Crying Game, Memphis Tennessee, Mama, Little Things and My Baby Left Me led to highly successful concert appearances at the most prestigious venues throughout the United Kingdom.
Gap will be playing Peterborough - Credit: Archant
The Union Gapuk will perform such classics as Young Girl which hit the number one spot in the UK & number two in the USA.
The Ivy League Perry Ford introduced Dave Buckley into the band during the 60's to add his unique falsetto voice creating The Ivy League sound. When most 60's bands had faded away, Dave later joined by Jon Brennan and Mike Brice have kept The Ivy League going from strength to strength maintaining their popularity to the present day.
They have built the show into one of the finest musical/comedy acts in the country .
Hosted by Alan Mosca from Freddie & The Dreamers the tour will be at the Peterborough Cresset on Friday November 7 at 7.30pm. Tickets are £26.50.
The Swinging Blue Jeans - Credit: Archant


text:
Q: cookie configuration on magento 1.9.2.0 I'm working on Magento 1.9.2.0. and I have a cookie problem on its config.
I found many topics the right way to config cookie but when
config 1: i put the domain path without dot(.) (domaine.com) login on device does not work.
config 2: if i put the dot, login on PC does not work.(.domaine.com)
Now, we have a multistore website. when you loggin (with config 1), the name in customer account changes randomly,
and config2 does not work(no one can log in).
Anyone can help me!

A: Actually, it was the cache. header template was not regenerated while reloading page.
After reseting cookies configuration, it works but still has connexion pb on mobile device.

redpajama_set_name: RedPajamaStackExchange


Read the tentative Memorandum of Agreement (MOA) regarding the Non-Tenure Track Faculty at Rutgers. This MOA is subject to membership approval by voting. We use an electronic ballot system that allows members to vote througn an online secure mechanism.


text:
Read, Listen & Learn
ENVIRONMENT REPORT- January 4, 2002: Mystery Squid - 2002-01-03
This is the VOA Special English ENVIRONMENT REPORT.
Scientists have discovered a strange new kind of squid deep in the world's oceans.
Scientists reported seeing the sea creatures in the Pacific, Atlantic and Indian oceans and in the Gulf of Mexico. They say they have never seen anything like the mystery squid before.
Evidence of the squid comes from pictures and video images taken by eight independent scientists in four countries. The scientists took the pictures from inside deep-water submarines. The deepest sighting was made almost five kilometers below the surface of the ocean, in the western Atlantic near the coast of Brazil.
The mystery squid is about seven meters long. Most squids have two long tentacles and eight shorter arms. The new squid, however, has ten arms that are extremely long, about six meters. Its arms are longer than those of any known squid species.
The squid's arms are held in an unusual position. They spread out a short distance from the body, then bend down sharply. The rest of the arms flow behind the squid as it swims.
Scientists also say the squid's arms are sticky. The scientists discovered this when a squid became stuck to the submarine while they were filming. Scientists believe the squid may use its long, sticky arms to trap food.
The mystery squid also has two huge fins that stick out from its small head. The fins look like two giant elephant ears that appear to help the animal swim through the water.
Scientists have not captured the animal. So they could not tell how much the squid weighs. However, they say it has a very small body, unlike that of the giant squid.
Michael Vecchione [VECK-ee-own] is a scientist at the National Oceanic and Atmospheric Administration. He wrote about the mystery squid in Science magazine. He said the discovery shows how little researchers know about life deep in the world's oceans.
Areas of deep water make up more than ninety percent of the living space on Earth. However, scientists do not know much about deep sea areas. That is because these areas are difficult, dangerous and costly to explore. The mystery squids were discovered accidentally by scientists or oil company workers looking for something else at the bottom of the ocean.
This VOA Special English ENVIRONMENT REPORT was written by Cynthia Kirk.


Barren Hannah was desperate for a child and in her desperate prayer she promises to give the gift she has received right on back to God. Samuel is born and Hannah does indeed follow through on her vow.
All children are of course gifts from God and it does a person good to both realise this and act on it for these good gifts are always kept longer and remain far fresher to us, when they are dedicated right on back to Him. Please note tonight that any gift selfishly consumed by us will in the end corrupt us and I tell you, this is especially true if we eat our children, consume them in our own desires and make them the cherished idols of our hearts. If you are doing this, you had best watch out, for cannibalised children always give the very worst of stomach aches.
So following the blessed example of the Holy Family, give back your gift to God! Dedicate them to the Lord. This dedication means a letting go of and a laying hold of.
As to letting go, you must remember that this child is not yours. It shall grow and shall become and in the all of its becoming the child shall decide on so many things for itself, including whether or not they shall follow the Lord. You must have faith in letting the child of your care be found by the God that you love.
As to laying hold, well, you must lay hold of Your God and of yourself. It is imperative that you grow in grace and in the knowledge of the Lord Jesus Christ. As the child becomes and as the child decides, You must lay hold of God on its behalf. You must also lay hold of yourself, for you must become a model of godliness before them, a mentor of graciousness and hope, a mother of love prayer and care, a father of manly courage, wisdom, perseverance and provision. The child will become and will make its own decisions, you are not responsible for this. However, you are greatly responsible for laying hold of both God Himself and you yourself.
Whatever you do tonight, do not eat your children.
Pray: O Lord we cast down our idols, even of they are our most dearly beloved children. So help us to leave them with Your good discipline and Your love and Your care, yes, this we do tonight with both hope and faith in Your goodness. Now O Lord, we lay hold of Your goodness and lay hold of ourselves to walk with You, as models and mentors of the Christ like life before the gifts You have so graciously granted us. Amen and amen.


Donald R. Nielsen was Professors of Water Science, Department of Water Science and Engineering, Davis; James W. Biggar was Professors of Water Science, Department of Water Science and Engineering, Davis; Koon T. Erh was Postgraduate Research Water Scientist, Department of Water Science and Engineering, Davis.
Hilgardia 42(7):215-259. DOI:10.3733/hilg.v42n07p215. November 1973.
Infiltration and redistribution of water following an irrigation was studied, and the work was replicated at 20 locations on a 150 hectare plot of land. Hydraulic conductivity was measured as a function of soil-water content at 30.5 cm depth intervals to a depth of 182.9 in twenty 6.5-meter-square plots randomly established over a 150-hectare field. Tensiometers installed at 30.5, 61.0, 91.4, 121.9, 152.4, and 182.9 cm were used to measure hydraulic gradients. Soil-water contents were ascertained from soil-water characteristics obtained from six soil cores taken from each of the above depths for each plot. Variations in soil-water content were found to be normally distributed with depth and with horizontal distance throughout the field, while values of the hydraulic conductivity were found to be log-normally distributed. The correlation between hydraulic conductivity during steady-state infiltration and the clay fraction was significant at the 1 per cent level. Several equations for predicting water movement and retention under field conditions are examined.
Beckett P. H. T., Webster R. Soil variability: A review. Soils and Fertilizers. 1971. 34:1-15.
Cramer H. The elements of probability theory and some of its application. 1955. New York: J. Wiley and Sons, Inc. 281p.
Johnson N. L., Leone F. C. Statistics and experimental design in engineering and the physical science. 1964. I: New York: John Wiley and Sons, Inc.
Millington R. J., Quirk J. P. Transport in porous media. Intl. Congr. Soil Sci., Trans. 7th (Madison, Wis.). 1960. 13:97-106.
Ogata Gen, Richards L. A. Water content changes following irrigation of bare-field soils and its effect on soil moisture investigations. Soil Sci. Soc. Amer. Proc. 1957. 18:344-47.
Shaw R. H., Nielsen D. R., Runkles J. R. Evaluation of some soil moisture characteristics of Iowa soils. Iowa Agricultural Expt. Sta. Res. 1959.


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The 13 tribes of Israel. (Yes, 13. I didn't miscount.)
Hope you're not triskaidekaphobic. In case you are, the bible usually says 12.
The Hebrews whom the LORD rescued from Egypt during the Exodus, consisted of the descendants of Jacob ben Isaac—whom a man, probably an angel, renamed Israel after their wrestling match. Ge 32.28 Hence they're regularly called benéi Yišraél/"children of Israel." Ex 1.1
Since Israel had 12 sons (through four different women), and all the "children of Israel" are descended from the sons, they're also known as "the 12 tribes of Israel," each tribe named for each son. In English, the sons are
Sons of Leah: Reuben, Simeon, Levi, Judah, Issachar, Zebulun. Ge 35.23
Sons of Rachel: Joseph, Benjamin. Ge 35.24
Sons of Bilhah: Dan, Naphtali. Ge 35.25
Sons of Zilpah: Gad, Asher. Ge 35.26
They're listed in various orders, but Reuben tends to come first, 'cause he was firstborn. However, Israel reassigned the birthright, the patriarchal obligations of the eldest son, to his favorite son, Joseph.
Hence Joseph received twice the inheritance of his brothers—and became represented by two tribes, named for Joseph's sons Manasseh and Ephraim. (Manasseh is sometimes referred to as a "half tribe," Js 13.29 but not because Manasseh was half of Joseph; it's because half of Manasseh's land lies east of the Jordan river, and half west.) And since Jacob put the younger son, Ephraim, first, Ge 48.17-20 precedence passed to that tribe. The Prophets regularly refer to northern Israel as "Ephraim" for that reason. Is 7.9, 11.13, Jr 31.20, Ho 5.3, 7.8, Zc 9.13
So… this actually produces 13 tribes (which I'll list alphabetically): Asher, Benjamin, Dan, Ephraim, Gad, Issachar, Judah, Levi, Manasseh, Naphtali, Reuben, Simeon, and Zebulun. Not 12. Why aren't they called 13 tribes? Two reasons.
First and foremost: The writers of the bible, and probably God too, really like the number 12. The ancient Sumerians divided the year into 12 months, marked 'em with the zodiac (whatever constellation is highest in the sky at night), and throughout middle eastern culture this became the number of completeness, fulfillment, unity, and perfection. Thirteen? Not so much. Not that it's unlucky; that superstition came from the Romans. But they liked 12 way better.
And the LORD turned the entire tribe of Levi into a special priestly caste. He gave them "no inheritance"—that is, no land apart from 48 cities. Js 21 Instead of land, Moses explained, the LORD was their inheritance, Js 13.33 meaning whenever people brought food and animals to the LORD, the Levites, in their capacity as the LORD's priests, got to eat 'em Dt 18.1 and therefore didn't really need any land for farming and ranching.
So geographically, there are only 12 tribes: Twelve tracts of land, designated for 12 families descended from Israel. The Levite cities were scattered all over these tribes, and really anybody could live in the cities, not just Levites. (Particularly the larger cities, like Hebron, Shechem, or Ramoth-Gilead.)
Where the 12 tribes were meant to be situated, according to Joshua. Historically, they didn't ultimately end up there. Dan, fr'instance, gave up trying to fight the Philistines and moved to the north part of Naphtali. The Bible Study Site
Geographic tribes.
People start to get really bored with the book of Joshua right about where the conquered land gets divvied up between the tribes. Three tribes already had land by this point: Reuben, Gad, and half of Manasseh, had claimed land east of the Jordan. Nu 32, Js 13.15-32 Judah pretty much got everything south of Jerusalem, Js 15 and Ephraim and Manasseh took the land north of that. Js 16-17 The other, smaller tribes were sorted out by lot, Js 14.2 and if you wanna read the passages on that, go right ahead. I included a map though.
Asher's boundaries. Js 19.24-31
Benjamin's boundaries. Js 18.11-20
Dan's boundaries. Js 19.40-48
Issachar's boundaries. Js 19.17-23
Naphtali's boundaries. Js 19.2-39
Simeon's boundaries. Js 19.1-9
Zebulun's boundaries. Js 19.10-16
Problem is, these tribes were supposed to finish driving out the other inhabitants so they could take the rest of the land allocated to them. This, they failed to do. Jg 1 Dan, despite their famous tribesman Samson, never was able to drive out the Philistines who occupied their territory, and in frustration they scouted the northern part of Naphtali's territory, drove out the Sidonians who loved there, and took that territory over. Jg 18.27-31 Ephraim moved into Dan's former tribal area.
When the tribes split into northern Israel ("Ephraim") and southern Israel ("Judah") round the year 930BC, the split was basically three tribes in the south—Judah, Benjamin, and Simeon—versus the other tribes. Now yeah, most folks figure northern Israel consists of 10 tribes, 'cause the prophet Ahijah told northern Israel's king Jeroboam ben Nevat he was getting 10 tribes. 1Ki 11.31 Thing is, only the tribe of Judah fully followed southern Israel's king Rehoboam ben Solomon. 1Ki 12.20 Benjamin sorta did, 1Ki 12.21-24 but it's debatable how solid their loyalty was. Simeon, which was wholly surrounded by Judah, never even got a mention. Only once were they described as siding with Judah—but then again, at the time, so was Ephraim and Manasseh. 2Ch 15.9
Every so often you'll hear people refer to the "lost tribes of Israel." When the Assyrians conquered northern Israel in 722BC, they deported much of their population and scattered them round their empire, never to return. Much later, when the tribes of southern Israel were permitted by the Persians in 520BC to return from their own deportation by the neo-Babylonians in 587, we only read in Ezra of people from three tribes—Judah, Benjamin, and Levi—returning to southern Israel. Ez 1.5 So… what happened to the other 10 tribes? Bible doesn't say, so people figure the other tribes were just gone. Lost to history.
Not that there aren't hundreds of theories. Every once in a while, anthropologists discover a clan of people whose religion and traditions sound remarkably like that of ancient Israel, so people leap to the conclusion these folks must be one of the "lost tribes," miraculously still intact (more or less; mostly less) after 25 centuries.
And of course there are all the Christian myths about where they went. In England and the United States, there's a really popular belief that the Saxons are descended from the "lost tribes." (Supposedly "Isaacson" got shortened to "Saxon." Linguistically impossible, but when people are stupid enough, they'll believe anything.) So if you wanna claim the English, or their Anglo descendants in the Americas, are secretly God's chosen people, there ya go. Why the people who believe this, still have various prejudices about Jews, is beyond me, but whatever.
But it's not wholly accurate to say the "lost tribes" are actually lost. 'Cause they weren't. Not entirely. The Assyrians deported most of the people of northern Israel. In Sargon of Assyria's Annals, he recorded he exiled only 27,290 of the inhabitants of Samaria. Everybody else?—all the inhabitants of all the other cities? Still there. Living under Assyrian rule till the neo-Babylonians conquered Assyria. The neo-Babylonians didn't deport everyone either. 2Ki 25.12 Just the folks they considered a important… or a problem.
It's why we find members of the "missing tribes" in the bible:
Ephraim was still around after the exiles returned from Babylon. Zc 7.1, 9.9, 10.7
The apocryphal book of Tobit is about people from the tribe of Naphtali. Tb 1.1 NRSV
One of the prophets whom Jesus's parents met in temple was Anna, from the "missing" tribe of Asher. Lk 2.36
Jesus lived in the tribes of Zebulun and Naphtali. Mt 4.13
Revelation includes a vision of 144,000 people from 11 tribes: Asher, Benjamin, Gad, Issachar, Judah, Levi, Manasseh, Naphtali, Reuben, Simeon, and Zebulun. Rv 7.5-8 ("Joseph" gets included in verse 8, which likely includes people from Ephraim; Dan isn't mentioned at all. Doesn't necessarily mean Dan is extinct though.)
A numerologist's dream.
Thirteen tribes aside, the tribes of Israel were consistently referred to as 12, and if you like the number 12, you're gonna love the bible. There are 12s all over it. Just about everything in ancient Israel was centered on twelveness.
Moses set up 12 pillars. Ex 24.4
Twelve jewels in the head priest's ephod, Ex 28.21 deliberately for the sake of each tribe.
Twelve loaves of showbread. Lv 24.5
Twelve spies sent to scope out Canaan before the invasion, Nu 13 one from every tribe but Levi.
Twelve stones set up in memory of crossing the Jordan. Js 4.9
Solomon had 12 officers, 1Ki 4.7 likely from each tribe but Levi.
Solomon's "bronze sea" was designed with 12 bronze oxen holding it up. 1Ki 7.25
Solomon's throne had 12 lions on the steps to it. 1Ki 10.20
Elijah's altar consisted of 12 stones. 1Ki 18.31
Lastly Jesus had 12 apostles, whom he expected to seat on 12 thrones to rule the 12 tribes. Mt 19.28 Even though the apostles obviously didn't come from every tribe, what with Peter and Andrew, and James and John, being siblings; plus three of 'em were Jesus's cousins.
And of course 12 is all over Revelation.
12,000 apiece from the 12 tribes are sealed. Rv 7.5-8
The woman clothed with the sun has a crown of 12 stars. Rv 12.1
New Jerusalem has 12 pearly gates, Rv 21.2, 21 12 foundations, Rv 21.14 and is 12,000 stadia high, wide, and deep. Rv 21.16
The tree of life produces 12 kinds of fruit. Rv 22.2
What can I tell you? Hebrews and Christians—and apparently God too—really like the number. So it's all over the bible, and in order to conform to it, the 13 tribes of Israel have been rejiggered into 12.


Bill gives Nora some pills and tells her he didn't mean to kill Sam Selmar - he just wanted his job back. He says he doesn't even remember hitting Selmar, then adds that, when he saw his boss lying on the floor, all he could think of were the cop shows he'd seen on TV, so he wiped his fingerprints from the crowbar and left out the back of the warehouse. He tells his mother that John shouldn't have run away as he was innocent - he says the police won't put John in jail because he didn't do anything. Bill then tells Mrs. Todd to keep quiet, saying, "If we don't say anything, it'll work out."
At the Palmers', Beryl takes a 'phone call from Fiona's solicitor, saying his client will probably get bail. David tells his wife that Fiona was stupid to get mixed up in everything, and should have just told John to buzz-off. He adds that John probably spun Fiona a yarn to get her to take him in.
At Dural, Angela is very chirpy, as Gordon is fine about her calling-off the engagement, and he has agreed to help John. She tells Wayne that it's time she came clean to Gordon about herself and about Wayne ripping him off, saying she wants Wayne to get what's coming to him. Angela goes to see Gordon in his study. Mr. Hamilton says he's pleased Angela is standing by John, and is proud of her. Angela then tells her father that, while he and Patricia were overseas the previous year, she got involved with a married man. He left his wife, but Angela then dumped him a week later. Angela says she's telling her father now, before Wayne gets in. Then she says, "That's not all..." Out in the hall, Wayne has just told Patricia about his embezzling. He says he was going to pay it back from his trust fund, but Patricia doesn't believe him. Angela tells her father that Wayne has been stealing money from the company, by taking a cut of the proceeds from selling horses. She says that Wayne knew about her secret and had threatened her with it. Gordon says he's ashamed of both his children. He goes and shouts for Wayne. When Wayne enters the study, he tries to get round his father by saying, "Look, I can explain. It was more like a loan." Gordon says that if Wayne wasn't his son, he'd call the police. Gordon tells Wayne that he can have his trust fund money, and he can stay in the house, but he doesn't want any more to do with his son. Wayne goes and tells Patricia what happened. He says that maybe Angela did him a favour, as he's now got his trust fund money. Patricia tells Angela that what Wayne did was stupid. Angela asks if Wayne told Patricia about his sister's affair with a married man, but Patricia reveals she had already heard it on the grapevine several months ago. Angela is upset that that she's hurt Gordon, but Patricia says the shocks may do him good, as Angela and Wayne have both been on pedestals. In his study, Gordon makes a telephone call - he's changed his mind about helping John.
John has called Susan, and Susan reveals this fact to Bill, who wants to know if John said anything else. He acts nervously, even though Susan is patently on his side. Nora, who is close-by, looks disturbed. She hears Susan talking about John 'phoning just before the wedding to tell her Bill was the murderer.
David is getting ready to go and see John's solicitor.
Nora asks Bill why he didn't tell her John rang before the wedding, then tells her son that he shouldn't have married Susan. Bill tells his mother that they'll be OK if she keeps to her story. There's a knock at the front door. It's Fiona, who is out on bail. She charges in and tells Nora that she hopes she can live with herself. When Fiona's gone, Bill tells Nora that Fiona is just bluffing.
Angela argues with Gordon about not helping John, then storms out of the house. Patricia tells Gordon it doesn't seem fair. Gordon says he agreed to help because Angela was doing something unselfish for a change, then adds that he doesn't know what to think about Angela or Wayne any more. Patricia wants Gordon to help John, but Gordon just says, "John's got family - let them help."
Fiona goes to the Palmers'. Beryl tells her that David has gone to see John. Fiona says that David will hear the truth, then.
Angela goes to see Jill. She says she still wants to help John, but doesn't have any money. Jill asks her if she has anything she can sell. Angela says she has her car. Jill says Angela could alternatively get a job, to which Ms. Hamilton replies, "You're joking!" But Angela does then say she'd do anything to help John.
David storms into his house and yells about the crazy yarn John has just spun him. Fiona tells him it's the truth. David says, "You were there, were you, when Sam Selmar was killed?!" He won't believe Bill did it, but adds that he doesn't like having to face the fact that his son is a coward. Beryl tells her husband that if John can look her in the eye and say Bill did it, she'll believe him.
Bill's ready to go to work, but Mrs. Todd can't understand how her son can go back to the warehouse. Bill tells his mother to shut up. She retorts, "What will you do? Hit me?" Nora tells Bill it's over - he must tell Susan and go to the police. Mrs. Todd tells Bill she loves him.
Having had a good sleep, Susan wakes up and Bill tells her there's no news on John. Bill has been gathering together the papers etc. to run the household. He wants to take Susan through them so that she can keep the place going if necessary. After he's done this, he tells his wife he loves her, and adds that she's the best thing that has ever happened to him. He then says, "I'm sorry Susie - I killed Sam Selmar." Susan looks shocked.
A car pulls up outside the police station. Inside, Susan looks upset and Bill tells her he that wants to go in on his own. Susan says, "I love you." They hug, and Susan sobs. Bill tells Susan not to hang around. He gets out of the car. Susan sits and cries, then drives off as Bill stands by the police station door, watching.


If you're ready for a new career opportunity, consider applying for school-based therapy jobs.
School travel therapy jobs let you change up the environment each year, so there's less change of tedium and burnout, and simply working in schools comes with great benefits. If you're excited by the benefits of school-based therapy jobs, check out the positions you can apply for via Med Travelers.
Whether you're an OT or a speech pathologist, school-based therapy jobs offer a lot of flexibility. You can choose where you want to work and live — school systems across the country need qualified therapy professionals — and you can choose to work in elementary, middle or high schools.
The work itself is also more flexible than what you might experience in a clinical setting, and it can present an enjoyable challenge.
Megan Drumm, M.S. CCC-SLP, works at Stoughton Public Schools. She says, "a student could walk through my door with any type of disability, and I get to service them if they have an IEP. It keeps me constantly doing research for best practices and evidence-based therapy techniques and tools for a variety of disabilities and therapy areas."
A school environment lets you work with kids outside of the immediate needs of a therapy session. "I also really love it because I get the opportunity to go in to classrooms and run whole class lessons," says Drumm. "It helps my students carry over their skills into the classroom, and since I can teach an entire classroom how to use strategies I am teaching my students, they don't feel singled out and are more likely to use the strategies on a daily basis."
School travel therapy jobs offer extra benefits, because you can live in exciting locations that lend to exploration during the summer months, when you're off. Therapy clinicians can even take temporary school-based jobs for the remaining of a school year when positions are available, setting themselves up in a prime area for adventure during the summer. Check out some of the best and cheapest places to travel during the summer and match your starting point with an end-of-school-year therapy job.
Whether you're on the job for a semester or sticking with your school travel therapy job all year, another perk is getting to see the results of your work.
Drumm says she loves working with teachers and students to reinforce strategies that work and understand what treatments aren't seeing results. "I also love working in schools," she says, "Because I get to see my students outside of my office and get to know them in other areas of their life. I can see them as the basketball star or the gymnast at recess, the beautiful singer during chorus, the incredible artist or the leader during student council meetings. I can then play to their strengths and promote generalization."
A final reason to seek a school travel therapy job is that the positions pay very well and you can take advantage of included housing while you're on assignment. That tends to be true for PT, OT and speech pathologists who opt for travel positions over traditional permanent jobs.


OMTEX CLASSES: Practical 8 Title: Geogebra: Regular six-sided polygon.
Practical 8 Title: Geogebra: Regular six-sided polygon.
Title: Geogebra: Regular six-sided polygon.
Construct a regular polygon with six sides using the Polygon tool.
Tools/Software: Computer with Geogebra Software installed.
1) Start the Geogebra Software.
3) Select the Circle with Centre through point tool and draw a circle with centre as O and passing through A.
4) Similarly draw circle with centre as point A and point D passing through O.
6) Select the Polygon tool, and click on the vertices from E in anticlockwise direction to get a closed polygon.
8) Hide the circles by right clicking it and turn off the show object option.
10) Save the construction with a suitable file name.
Result: An Hexagon with the same side length is drawn.


This incredible residence is set on a spectacular flat 2.08 acre lot on one of the most prestigious streets in Villanova, Radnor Township. Features include gracious sun-filled rooms with stunning architectural designs and a wonderful open flow, beautifully restored original millwork, moldings and hardwood floors, views of the private terraces, pool and gloriously landscaped grounds, renovated gourmet kitchen with breakfast room, spacious adjacent Family room with fireplace and vaulted ceiling, breathtaking formal Living Room with soaring ceilings, elegant Dining Room with classic built-ins, luxurious Master Suite and 4 additional bedrooms with 2 renovated baths. Move right in and enjoy this lovely home and stunning property while being only 5 minutes away from renowned schools, trains, shopping and downtown Wayne, 30 minutes to the airport and Center City Philadelphia and 90 minutes from New York City.


As it is said in an English proverb "A healthy mind lives in a healthy body." Thus below is the list of 20 healthy foods one should know about and they are also categories under different items.
Cheddar is unfathomably nutritious, and a solitary cut of it contains about an indistinguishable supplements from some drain. It is likewise a standout amongst the most scrumptious nourishments you can eat.
The entire drain is high in vitamins, minerals, quality creature protein and sound fats. It is a standout amongst other wellsprings of calcium.
Yogurt is produced using milk that is aged by adding live microbes to it. It has a large number of similar wellbeing impacts as the drain, aside from with the additional advantages of the neighborly probiotic microbes.
Grains have become ominous feedback starting late, for the most part on account of them being an unthinkable sustenance on the savagely standard paleo thin down.
Regardless, it is a misunderstanding to tie all grains together. There are an extensive variety of sorts of grains, and some of them are especially solid.
Basically, recall that they are still very high in carbs, so they are not recommended on a low carb tally calories.
Rice is a standout healthy food amongst the most settled oat grains and is starting at now a staple sustenance for most of the people on the planet. Dim hued (whole grain) rice is truly nutritious, with a decent measure of fiber, vitamin B1, and magnesium.
Oats are phenomenally solid. They are stacked with supplements, and besides contain earth-shattering strands called beta-glucans, seemed to have different points of interest.
Quinoa has ended up being phenomenally outstanding among prosperity aware individuals starting late. It is a scrumptious grain that is high in supplements like fiber and magnesium. It is also an eminent wellspring of plant-based protein.
Fish and differing seafood have a tendency to be phenomenally solid and nutritious.
They are particularly well off in omega-3 unsaturated fats and iodine, two supplements that an extensive number people don't get enough of.
Studies demonstrate that individuals who eat the most sustenances from the ocean (particularly guide) incline toward live more and have a lower risk of different sufferings, including coronary infection, dementia and hopeless.
Salmon is a sort of smooth fish that is inconceivably observable because of its phenomenal taste and a high measure of supplements, including protein and Omega-3 unsaturated fats. It moreover contains some vitamin D.
Sardines are basically nothing, smooth fish that are among the most nutritious sustenances you can eat. They contain significant measures of the greater bit of supplements required by the human body.
Shellfish isn't eaten reliably, which is a disgrace since it contains a more prominent number of supplements than for the most part every other sustenance. It positions like organ meats as for supplement thickness. Palatable shellfish solidifies mollusks, mollusks, and shellfishes.
Shrimp is a kind of creature found in the ocean. It has a tendency to be low in fat and calories, in any case high in protein. It is in addition stacked with different supplements, including selenium and vitamin B12.
Trout is another kind of heavenly smooth fish, like salmon.
Fish is to an extraordinary degree comprehended in Western nations and has a tendency to be low in fat and calories, yet high in protein. It is impeccable individuals who need to add more protein to their eating regimens while keeping calories low.
Calorie for calorie, vegetables are among the world's most pulled in wellsprings of supplements.
There is a wide outline open, and it is best to eat a wide mix of sorts of vegetables continually.
Asparagus is a typical vegetable. It contains vitamin K.
Toll peppers associate in two or three tints, including red, yellow and green. They are crunchy and taste sweet, and are an exceptional wellspring of tribulation modifying development specialists and vitamin C.
Broccoli is a cruciferous vegetable that tastes mind blowing both horrible and cooked. It is a splendid wellspring of fiber, vitamin K, and vitamin C, and contains a not too awful assign of protein remained from different vegetables.
The carrot is a striking root vegetable. It is to a marvelous degree delightful and crunchy and stacked with supplements like fiber and vitamin K. Carrots are moreover high in carotene tumor murdering development masters, which have specific inclinations.
Cauliflower is an exceptionally versatile cruciferous vegetable. It can be utilized to make a broad assortment of solid conditions, what're more tastes to an unprecedented degree unthinkable in control.
The cucumber is one of the world's most acclaimed vegetables. It is low in both carbs and calories and consolidates everything considered of water. In any case, it contains obvious supplements in little aggregates, including vitamin K.
Garlic is astoundingly strong. It contains allicin, a bioactive compound with striking normal impacts, including overhauled safe motivation behind the control.
Kale has been astoundingly undeniable beginning late, everything considered. It is uncommonly high in vitamin K, vitamin C, fiber and undeniable diverse supplements. It is flawless to add an eminent pulverize to servings of mixed greens and conditions.


This Bulk Fuel Hauler is headquartered in Carson City, MI and provides fuel distribution services to the Northeast region, specifically jet fuel and gasoline. The fleet consists of (32) Freightliner, Peterbilt, Kenworth, Sterling and Mack conventional & sleeper T/A truck tractors ranging in age from 2003 to 2017. In addition, the fleet utilizes (47) Fruehauf, Heil, Polar, Custom and Brenner aluminum fuel tanker trailers. The trailers are arranged with 2 to 6-axles with capacities ranging from 9,200 to 13,800 gallons.
The fleet can be inspected at 652 N. Williams St., Carson City, MI and 3730 Wyoming Ave., Dearborn, MI. The live & webcast auction sale will be theater-style and will take place at the Ingham County Fairgrounds, 700 E. Ash St., Mason, MI.
Removal begins after the last item is sold and lasts for one hour (or until 5PM).
Removal will continue the next morning and on all weekdays from 8AM to 5PM.
Last day for removal is March 23, 2018.
Small, carryout items, should be removed immediately after the auction or the day after the auction.
Anyone, either a buyer or rigger, who uses a powered vehicle to remove anything from the auction site, will need a certificate of insurance.
For more information regarding removal. please visit Myron Bowling Auctioneers.
For complete terms and conditions. please visit Myron Bowling Auctioneers.


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Home » Top Picks » Macy's Inc. (M) average volume reaches $18.3...
Macy's Inc. (M) average volume reaches $18.36M: Are the Stars Lining Up for Investors?
Witnessing the stock's movement on the chart, on December 28, 2021, Macy's Inc. (NYSE: M) set off with pace as it heaved 0.93% to $26.05. During the day, the stock rose to $26.76 and sunk to $25.53 before settling in for the price of $25.81 at the close. Taking a more long-term approach, M posted a 52-week range of $10.74-$37.95.
The Consumer Cyclical sector firm's twelve-monthly sales growth has been -7.70% for the last half of the decade. Meanwhile, its Annual Earning per share during the time was -43.80%. Nevertheless, stock's Earnings Per Share (EPS) this year is -836.30%. This publicly-traded company's shares outstanding now amounts to $313.80 million, simultaneously with a float of $288.28 million. The organization now has a market capitalization sitting at $7.71 billion. At the time of writing, stock's 50-day Moving Average stood at $28.30, while the 200-day Moving Average is $21.36.
It is quite necessary to find out the efficiency of the corporate organization, which has 75711 number of employees on its payroll. It has generated 239,027 per worker during the last fiscal year. Meanwhile, its income per employee was -52,093. The stock had 38.71 Receivables turnover and 0.87 Total Asset turnover. For the Profitability, stocks gross margin was +26.81, operating margin was -5.28 and Pretax Margin of -26.47.
Macy's Inc. (M) Ownership Facts and Figures
Nothing is more important than checking the behaviour of major investors towards the stock of the Department Stores industry. Macy's Inc.'s current insider ownership accounts for 0.20%, in contrast to 98.20% institutional ownership. According to the most recent insider trade that took place on Nov 24, this organization's EVP, Chief Financial Officer sold 2,397 shares at the rate of 31.82, making the entire transaction reach 76,267 in total value, affecting insider ownership by 3,549. Preceding that transaction, on Nov 22, Company's SVP and Controller sold 452 for 34.70, making the whole transaction's value amount to 15,682. This particular insider is now the holder of 4,382 in total.
Macy's Inc. (M) Earnings and Revenue Records
As on 10/30/2021, Multinational firm has announced its last quarter scores, in which it reported $1.23 earnings per share (EPS) for the period topping the consensus outlook (set at $0.31) by $0.92. This company achieved a net margin of -21.79 while generating a return on equity of -88.33. Wall Street market experts anticipate that the next fiscal year will bring earnings of 0.48 per share during the current fiscal year.
Macy's Inc.'s EPS decrease for this current 12-month fiscal period is -836.30% and is forecasted to reach 4.05 in the upcoming year. Considering the longer run, market analysts have predicted that Company's EPS will decrease by -11.82% through the next 5 years, which can be compared against the -43.80% growth it accomplished over the previous five years trading on the market.
Macy's Inc. (NYSE: M) Trading Performance Indicators
Let's observe the current performance indicators for Macy's Inc. (M). It's Quick Ratio in the last reported quarter now stands at 0.20. The Stock has managed to achieve an average true range (ATR) of 1.66. Alongside those numbers, its PE Ratio stands at $9.71, and its Beta score is 2.07. Another valuable indicator worth pondering is a publicly-traded company's price to sales ratio for trailing twelve months, which is currently 0.33. Similarly, its price to free cash flow for trailing twelve months is now 8.36.
In the same vein, M's Diluted EPS (Earnings per Share) trailing twelve months is recorded 2.68, a figure that is expected to reach 1.95 in the next quarter, and analysts are predicting that it will be 4.05 at the market close of one year from today.
Technical Analysis of Macy's Inc. (M)
Going through the that latest performance of [Macy's Inc., M]. Its last 5-days volume of 13.3 million was inferior to the volume of 18.27 million it revealed a year ago. During the previous 9 days, stock's Stochastic %D was recorded 76.50% While, its Average True Range was 1.37.
Raw Stochastic average of Macy's Inc. (M) in the period of the previous 100 days is set at 41.15%, which indicates a major fall in contrast to 59.20% during the last 2-weeks. If we go through the volatility metrics of the stock, In the past 14-days, Company's historic volatility was 49.24% that was lower than 64.66% volatility it exhibited in the past 100-days period.


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Home/Blog Home/Financial News/Fiduciary Rule Delay
Fiduciary Rule Delay
May 15, 2017 Sean Arnold Fiduciary Financial News
As anybody reading this should be aware, the DOL has issued a delay of the applicability date of its Fiduciary Rule which was slated to take effect on April 10, 2017. The DOL has pushed the applicability date out 60 days, until June 9, 2017. The DOL has indicated that it is highly unlikely to issue any further extension.
The DOL did provide some additional relief in the form of some new transitional exemptions.
Under ERISA, it is considered a prohibited transaction to receive a fee for providing fiduciary investment advice that creates a conflict of interest. This has been the rule since ERISA became effective in 1975 and, will continue to be the rule after June 9, 2017.
What Happens on June 9?
On June 9, the definition of the term "Fiduciary Investment Advice" changes. Specifically, the following activities will be considered to be fiduciary acts on June 9 and thereafter:
Making a recommendation to an ERISA Plan, participant or IRA owner on:
The selection of investments.
Specific investment strategies.
Purchases of insurance or annuities.
The hiring of a specific investment manager.
Whether to take a distribution (and in what form: lump-sum, rollover, transfer)
Up until this point, investment advice was only considered to be fiduciary in nature if it satisfied five very specific criteria:
The advice provided as to the value of securities or other property.
The advice was provided on a regular basis.
The advice was provided pursuant to a mutual agreement.
The advice serves as the primary basis for investment decisions.
The advice provided is individualized.
If all five criteria were not met, the advice was not considered to be fiduciary in nature. Clearly, the new definition of fiduciary investment advice casts a much wider net.
You Will Probably Be a Fiduciary
If you were providing investment related services to qualified retirement plans, participants or IRA owners prior to June 9, 2017, whether you considered yourself to be a fiduciary or not, you will likely be considered to be a fiduciary on June 9, if you continue to provide those services.
Many fiduciary advisors use a level-fee compensation structure to avoid potential conflicts of interest in dealing with plans and participants. This continues to be a viable strategy with the new definition. But, you will need to understand how the new rules impact any activities involving distribution and rollover advice being provided. Even absent a relationship to a plan or its participants; the provision of advice relative to taking a distribution, in any form, will be considered fiduciary investment advice.
Wait, IRAs Are Not Subject to ERISA
Recommendations to ERISA plans and participants will continue to be subject to ERISA's prudent man rule and duty of loyalty. Breaches of fiduciary duty will be enforceable as ERISA claims, enforceable by the Department of Labor's Employee Benefit Security Administration (EBSA). However, IRAs fall outside of ERISA and, up until now, outside of the DOL's jurisdiction. The new definition of fiduciary investment advice and, more importantly, the types of activities that give rise to a prohibited transaction give the DOL rulemaking authority over IRAs, to an extent.
Pursuant to an inter-departmental coordination agreement, the DOL has all rulemaking authority as it relates to prohibited transactions under section 4975 of the Internal Revenue Code. However, IRS retains enforcement responsibilities as it pertains to compliance for non-ERISA arrangements (IRAs). So, we find ourselves now with a rule that subjects investment advice providers to potential prohibited transactions as a result of apparent conflicts of interest that are created by decades old compensation arrangements.
How Can Prohibited Transactions Be Avoided?
The easiest way to avoid any conflict of interest while providing fiduciary investment advice is to eliminate any conflicts of interest. Unfortunately, that which is so easy to say is near impossible to accomplish.
Certainly, moving to a level-fee arrangement for investment advisory services helps eliminate many issues, but a number still remain. To help deal with these remaining conflicts of interest, DOL provides the Best Interest Contract Exemption (BICE).
The BICE allows an investment advice provider to offer advice that may inherently carry specific conflicts of interest, provided that prior to, or at the time of, providing the advice, the advice provider and the customer enter into an agreement with an enforceable contract that spells out specific conditions, namely:
The advice provider acknowledges fiduciary status.
Adheres to Impartial Conduct Standards that requires a firm to:
Provide prudent investment advice.
Charge only reasonable compensation.
Make no misleading statements about investments, compensation or any potential conflict of interest.
The firm implements policies and procedures that are reasonably designed to prevent violations of the impartial conduct standards,
Refrain from awarding financial incentives to advisors to act contrary to the customer's best interest.
Fairly discloses fees, compensation and material conflicts of interest.
Any investment advice provider planning to make use of the BICE would need to notify DOL of their intention, prior to doing so. In addition, there is an obligation to retain certain records associated with the advice provided.
One of the more unappealing aspects of the BICE is the fact that it creates a private right of action for IRA owners. Without an enforceable contract, DOL would have promulgated a ruling without much real enforceability outside of ERISA. However, many in the industry see the potential for class-action litigation to be a tough pill to swallow.
What About Those New "Transitional Exemptions?"
To help the industry deal with the new definition of fiduciary investment advice, DOL has provided some additional transitional exemptive relief. This transitional relief is available through December 31, 2017. For advice related to registered securities (not insurance), DOL provides us with a new best interest contract transition exemption ("Transitional BICE").
In order to satisfy the Transitional BICE, a fiduciary investment provider will need to comply with the three requirements of the Impartial Conduct Standards as described above.
The Presidential Memorandum of February 3, 2017
On February 3, President Trump issued a memorandum to the DOL to review its Fiduciary rule to ensure that the rule is "consistent with the policies of" his administration. Given the scope and the required time to complete such a review, the transitional exemptions help the industry become comfortable with a new definition of fiduciary investment advice. What final exemptive relief we end up with by year-end is anybody's guess.
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