May 9, 2002

To Whom It May Concern:

I was asked to function as a TA regarding health issues at Fort Ord. In preparation for my evaluation and for suggestions I reviewed more than twenty pounds of records, some of them consisting of the ones mentioned in the contract I signed on 5/4/02. Additional records were reviewed and are incorporated in my opinion.

I saw it as my first task to review reports which address the potential toxicity of materials above ground, in the ground, and in the water table below Fort Ord. Such an assessment would of course give one an idea as to whether or not Fort Ord is indeed toxic.

My second task was to assess the potential health effects of the toxicity and to comment on what if anything has been done to address these health effects.

I saw it as my third task to make suggestions as to how potential health effects can be addressed.

Multiple documents were reviewed and all show that potentially toxic chemicals have been and are still being found on Fort Ord grounds. It should be stressed that many of these potentially toxic compounds are known toxic metals. In addition, there is some evidence that depleted uranium was found.

Fort Ord was evaluated many times and in my opinion the toxicity present is well documented. It should be stressed that Fort Ord has been declared a Super Fund site by the EPA.

The Army suggested that the site be detoxified by burning the vegetation (mostly chaparral) and that ordnance be exploded. The Army contends that this type of cleanup would basically result in elimination of all potentially toxic compounds some of which would be evaporated into the air. The Army contends that it can direct the smoke high enough into the air to not bother local residents. The Army did not comment on the fact that smoke will pollute the air elsewhere if not locally.

The Army has looked at one single chemical compound or one single metal at a time and contends that they will not be generated in toxic amounts.

The Army did not consider the fact that a mix of toxic compounds can have unexpected health effects.

Regulatory agencies have suggested exposure limits for many potentially toxic chemicals.

It should be stressed that exposure limits apply to healthy adult males who are working an eight to twelve hour workday. Exposure limits are therefore not applicable to females, children, and nor to acutely or chronically ill individuals.

Exposure limits are suggestions only and not binding since even the regulatory agencies admit that some adult males are sensitive to exposure below the allowed limit.

None of the suggested exposure limits apply to mixes of chemicals. The problem of predicting the potentially toxic effects of mixes is addressed in a textbook which is referenced below.

It is quite accepted in the literature that mixes of chemicals can dramatically increase the toxic effects which one would have expected from just considering one chemical at a time.

A basic tenet of toxicology is the consideration of dose-effect. While there are exceptions, it is generally true that the higher the dose the more toxic a given compound can be.

It is often assumed that a chemical can have no toxic effects if it is present below the regulatory exposure limits. This is obviously not true if one considers females, children, and acutely or chronically ill adults.

If one considers the potential toxic effects of mixes, a given patient could become ill even if the individual compounds in a mix are present at levels which are less than the official exposure limit. In view of the above, a statement that the absence of toxic levels of a given chemical mix could not possibly be toxic to human beings is blatantly wrong.

In order to assess the dose-effect relationship, one also has to look at the effect. If the effect has all the hallmarks of toxicity, one must reach the conclusion that the dose was toxic.

Toxic exposure and it’s effects can be shown to effect brain function, immune function, lung function, and many other body organs and systems.

I have enclosed a protocol paper of mine which suggests measurements needed to document toxic effects of chemicals.

It should be noted at this time that I am not aware of any studies done on human beings living or working near Fort Ord. While a newspaper article mentioned that students on the nearby campus reported ill effects, no documentation of these ill effects have to my knowledge been done.

I am also not aware of any epidemiological studies which would study nearby populations and possibly compare them with a non-exposed population.

In view of the above no statement can be made at this time as to what if any health effects resulted from exposure to toxic chemicals at Fort Ord.

After reviewing more than twenty pounds of documents, I had to conclude that no health study of any kind has been done by any representative of the Army or any other agency.

Studies of the health of the surrounding population, including the students at the college, have apparently been suggested many times, yet, none have been done. Worse, I am not aware of any planned studies of potential or real health effects in the surrounding population.

No health studies have been done right before and after a burn.

The incidence of cancer including leukemia in the nearby population has not been determined and compared with a control population, nor has the incidence of birth defects and miscarriages.

It is strange that no studies were done nor are they planned, apparently because the Army thinks that the toxic compounds are individually present in amounts too small to have any health effects.

Blood can be sampled and solvent panels can be done. These would tell us whether or not the students and nearby populations have unusual amounts of solvents in their blood.

A representative sample of the student population could be compared with a matched sample from the University of Santa Cruz students who live on campus. These could be matched by sex, age, and other criteria so that the two populations become as similar as at all possible.

The two student populations should also be examined by a knowledgeable physician and should fill in questionnaires regarding their health.

Rather simple and inexpensive tests are available to study brain function, immune function, pulmonary function, and others.

Brain function and pulmonary function can be measured on site with portable instrumentation. Blood samples can be taken on site and then sent to appropriate laboratories.

When the Army plans to burn and explode potentially toxic compounds at Fort Ord, a sample of the surrounding population could be examined in the above fashion before and after the burn and explosion.

An epidemiologist would ideally work with the physician in charge of the above evaluations.

An epidemiologist would definitely be needed to sample enough of the population so as to be able to conclude whether or not there are clusters of cancer, leukemia, and other diseases in the nearby population. Populations would have to be compared with a controlled population elsewhere.

The evaluation outlined above could also benefit from studies already done in the Boston area at another toxic site.

Fort Ord is a toxic site which deserves to be a Super Fund site.

No health studies have been done at all. No individual evaluation of health effects have been documented nor any epidemiological study.

Epidemiological and health evaluations are mandatory. I will be glad to provide a detailed protocol.

Gunnar Heuser, M.D.

GH:cr

P.S. Statements and suggestions made in this report will be addressed in more detail and also be documented upon request.