Walter Wong, R.E.H.S., M.P.H. December 8 1998

Monterey County Department of Environmental Health

Hello Mr. Wong:

Thank you for your letter of Dec 2 1998. It could be amusing if the subject didn't concern potentially serious threats to human health and endangered species by poisons.

Imagine how much tedious investigation and court time we could avoid if we simply asked suspects if they were guilty.

Prosecutor : "Did you kill your wife Mr. Simpson?"

O.J.Simpson: "No."

Prosecutor : "OK, good enough for us. Case closed."

We could perhaps eliminate the positions of detective and prosecutor. In fact why do we need your office at all, if you trust corporations to tell the truth about environmental toxins?

In reality, the failure to have your staff take samples is irresponsible and inexcusable. While Mr. Lombardo's Golf Club staff may have done a fine job, the job is yours, not his. Allowing the potential polluter to collect samples for toxic testing is not acceptable science by any measure. It makes me wonder if you had training in the concept of "Experimenter Effect" - the skewing of test results by someone, even a well meaning person, who wants a certain outcome.

This is not a rhetorical question. If you understand experimenter effect, your failure to account for it here was a neglection of your duty to adequately protect environmental health. If you do not, I certainly hope you learn this soon and make immediate procedural changes so this never happens again.You should also make it a strict criteria for the next person who holds your position that they can clearly explain the impacts of this phenomena.

a. It appears that only soils were tested, while I expected to see water samples tested. While the soils could possibly show the toxins, it seems more likely to me that the water would reveal pollutants. Perhaps you could explain why the water accompanying the soils from the ponds to the river were not tested.

b. Were you given a map of the sample locations? If not why didn't you request one? If you were, why wasn't I sent one?

c. Are you aware that there is no single test for all pesticide chemicals? That each chemical has to be tested for specifically? Or do you dispute this?

d. Only seven chemicals were tested. Are those the only chemicals used on the course? Do you have a complete list of all the chemicals (pesticides and fertilizers) used on the course? Your staff tells me you do not. If this is correct, how soon will you change your procedures so you do maintain, in your offices, a list of all golf course chemicals used along the Carmel River?

e. Your staff also told us you have no list of any hazardous chemicals that are stored in amounts of less than 100 pounds. Is this correct?

f. Do any of the chemicals used on the golf course have hazardous degradation byproducts? Do your procedures include looking up the hazards of byproducts?

g. Does your office, as opposed to a financially self-interested corporation, test the Carmel River for all potentially harmful chemicals used alongside it? If you lack a complete list of the chemicals used, of course this wouldn't be possible.

3) Finally while it may sound like Andy Rooney, it bothers me that you didn't spell Mr. Boston's name correctly (or even your own title - Director of Environmental "HEATHL" (?).

Reading jaw-breaking polysyllabic chemical names is absolutely a critical ability in your position. Human life and death may hang in the simple misspelling of a chemical's name. My mind is not eased. What other "simple" errors are made in your office?

With all due respect,

David Dilworth, D.B.W., C.F.A. Co-Chair 831/624-6500

Copies Sent to:

US-Fish & Wildlife Service, Region 1

California Dept of Fish and Game, Region 3

Regional Water Quality Control Board, SLO California

Attorney General

Assemblyman Fred Keeley

Supervisor David Potter

Sally Reed, County Administrator

League of Women Voters

Sierra Club

Highway 68 Coalition

Monterey Herald, SUN, Salinas Californian Coast Weekly, Monterey County POST

KION,

KSBW

Mr. Don Boston, VP Rancho Canada Golf Club