Comment on AN01-Proposed Rule-Scott D. Daniels

The Proposed Rule represents an ideological shift in disease categorization. This paradigm shift should be represented formally by 1) Amending the definition of causality in 38 U.S.C. 1116(b) to allow consideration of disease spectra and 2) Altering the currently proposed rule to reflect a presumed service connection for all diseases characterized by clonal hyperproliferation of B-cell derived plasma cells and production of abnormal amounts of immunoglobulins. Otherwise, the Secretary’s conclusion should be challenged, since it does not reflect the current criteria for causality that are enumerated in 38 U.S.C. 1116(b) (i.e. there is no direct evidence for causality), and it arbitrarily awards presumptive service connection to AL Amyloidosis without provision for other, equally qualified diseases characterized by clonal hyperproliferation of B-cell derived plasma cells and production of abnormal amounts of immunoglobulins, but which are without direct evidence of association with Agent Orange exposure.