Why I am calling for a Local Health Emergency in San Francisco

The term emergency can be applied to any situation where urgent and immediate action is required to mitigate or prevent an adverse situation that threatens public health, property and the environment. California abides by two sets of laws governing the decision to declare or proclaim a public health emergency in order to exercise extraordinary powers to respond to an emergency.

Biomonitoring detects pollution in people. As a method for measuring toxic chemicals in human tissues, HBM is a proven tool for studying harmful environmental chemicals to confirm exposures and validate public health policies. Population biomonitoring was first applied to environmental public health in the U.S. Environmental Protection Agency’s regulatory reduction of lead in gasoline on Jan. 1, 1986.

“HBM is the only way to identify and quantify human exposure and risk, elucidate the mechanism of toxic effects and ultimately decide if measures have to be taken to reduce exposure. Risk assessment and risk management without HBM leads to wrong estimates and inadequate measures.” — “Human Biomonitoring: State of the Art,” Jurgen Angerer et al. Int J Hyg Environ Health May 2007.

Biomonitoring for measuring and detecting toxic chemicals in human tissue was enacted by the EPA in 1967 when the National Human Monitoring Program (NHMP) used an exposure-based assessment to detect pesticides in fatty tissue.

HBM was used to reduce human exposures to lead, PCBs and the pesticide DDT. The modern era of HBM began in 1993 when the National Human Exposure Assessment Survey addressed human exposures to multiple chemicals including metals, pesticides and volatile organic compounds using aggregate analysis. See “ An Overview of the National Human Exposure Assessment Survey”: https://cfpub.epa.tov/si/si_public_record_report.cfm?dirEntryld=61422&Lab=NERL.

The Hunters Point Community Biomonitoring Program has mounting evidence supported by urinary screenings and geospatial mappings of a community-wide toxic exposure caused by airborne shipyard soil and landfill hazards.

The National Research Council 1991 report “Human Exposure Assessment for Airborne Pollutants” concludes: “Monitoring the environment by identifying and measuring concentrations of chemicals in media — e.g. air, water and soil — is not by itself an adequate basis for assessing human exposures. HBM offers an improved understanding of potential health risks through the detection of ‘biomarkers’ of exposure that indicate the progressive response to exposures in the human body that lead to disease … before disease occurs.”

“If it hadn’t been for these dial painters, thousands of workers might well have been in great danger.” — U.S. Atomic Bomb Commission

The earliest example of workplace medical monitoring is the tragic story of the Radium Girls — female factory workers who contracted radiation poisoning from painting watch dials with luminous paint that contained radium in the early 1920s. Over 30 deaths were documented in women as young as 20 after the Radium Dial Co. faced an increased military demand for watches during the World War I era.

To maximize profit, they hired girls as young as 11 to paint numbers onto watch faces in assembly line fashion, instructing them to “lip-dip” the paint brushes to speed up the process. The “ghost girls” glowed in the dark as radium accumulated in their bones and teeth.

By 1926 it became obvious radium was causing a spectrum of disease, including necrosis of the jaw, fractures, hemorrhage and stillbirths. Cancer rates skyrocketed and by 1936 over $90,000 in medical settlements had been paid by the U.S. Radium Corp.

X-rays of the women showed their jaws and bones “riddled with holes like honeycombs.” As they began to die, doctors paid by U.S. Radium defamed them by publicly announcing their deaths were due to syphilis.

In 1934 the lethal effects of radiation were sensationalized when Madame Marie Curie, the Nobel Prize-winning scientist who discovered radium, died of aplastic anemia. The first “Radium Girl,” even 87 years after her death, Madame Curie’s remains are dangerously radioactive and are expected to remain so for the 1,500-year half-life of radium 226.

Human biomonitoring was used to seek justice for the wrongful deaths of the Radium Girls that included x-rays and autopsy examination. Amelia “Mollie” Maggia was the first to die. She was 24 years old. Mollie suffered from jaw pain and tooth loss before a dentist pulled out a decayed segment of her jaw. On Oct. 15, 1927, her body was exhumed.

“At 3:30 p.m., Berry walked up to the grave with Dr. Matland and a cohort of New York doctors who would lead in conducting the autopsy. There were 13 officials gathered to witness Mollie’s exhumation. Mollie’s body could provide corroborative evidence for the dial painters’ fight in court. Despite the dim fall day, the coffin seemed to glow with an unnatural light — the inside of the coffin was aglow with the soft luminescence of radium.” Burning Bones helped prove that women were poisoned by glowing paint: https://www.popsci.com/autopsy-dying-radium-poisoning/.

History repeats itself, and the September 2018 discovery of a radium dial in a newly developed residential neighborhood on a federal Superfund site in southeast San Francisco prompted the second collaborative effort in a decade to institute a human biomonitoring program at the Hunters Point Naval Shipyard.

In March 2009, a research collaboration led by community scientists and academic researchers submitted a proposal to the National Institute of Environmental Health Sciences for $2.5 million in community exposure funds to conduct human biomonitoring and simultaneous air monitoring in Bayview Hunters Point.

While the proposal was not funded, the team persisted and ultimately paved the way for the January 2019 launch of the Hunters Point Community Biomonitoring Program and its public benefit non-profit.

HP Biomonitoring conducts urinary screenings on residents and workers within the one-mile perimeter of the shipyard that detail dangerous clusters of toxic exposures and associated diseases. Using a urinary screening test capable of detecting up to 35 chemical “toxicants,” HP Biomonitoring is detecting patterns of exposure specific to the shipyard’s known contaminants, including radioactive agents of disease. Additionally, HP Biomonitoring’s trailblazing work is establishing cause and effect relationships between toxic chemicals and diseases.

The HP Biomonitoring “ROC” cluster — radionuclides of concern — combines the findings of urinary screenings with geospatial mapping of radioactive biomarkers detected at the residence and/or worksite. The cluster of radioactive biomarkers in the mapping tracks eastward along the historic entrance at Third and Palou toward the chemical and radiation contaminated Parcel E shoreline.

HP Biomonitoring’s South Basin Cluster maps the statistically unlikely detection of four elements found in toxic concentrations in “neighbors” centered around the shipyard’s contaminated South Basin region and Palou street entry. The four elements detected are arsenic, gadolinium, manganese and vanadium. In 16 screenings three or four of the elements have been detected in concentrations above allowable levels.

Manganese has been detected with 100 percent frequency in screenings conducted on residents of both Hunters Point and Treasure Island. Manganese has a 100 percent detection frequency in shipyard soils owing to its use in steel production and its natural presence in the serpentinite bedrock of the region. Ninety percent of manganese used globally is in the conversion of iron to steel.

By contrast, manganese was detected only 19 percent of the time in 357 urinary screenings conducted by Biomonitoring California.

By typing the location into the search bar, EJSCREEN colorfully displays 11 environmental indicators. Risk of exposure to diesel particulates, ozone, lead-based paint and proximity to Superfund sites and hazardous waste are mapped. Air toxics, cancer risk and respiratory hazard index are calculated along with the EJ (environmental justice) index that incorporates social factors including population size, income levels and percent people of color, under age 5 and over 65.

HP Biomonitoring has mapped a cluster of cancers linked to airborne radiation and chemical exposures by the Atomic Bomb Survivor Data Base, the VA Environmental Health Registry and the World Trade Center Health Program.

Eight types of cancers detected in shipyard residents and workers are assigned a pin color mapping the residence or work site. The color code for pin assignments is red for breast cancer, green for thyroid cancer, yellow for brain and nervous system, blue for cancer of the airways and lung, white for leukemia/lymphoma. The black pin is reserved for deaths in dogs due to radiation induced canine fibrosarcoma. The mapping closely corresponds to the HP Biomonitoring ROC cluster.

Shipyard soil elements documented to be present by the U.S. Navy and EPA are being detected in a remarkably similar profile in urinary screenings conducted on Hunters Point residents and workers independent of age, gender, race, ethnicity and education level. The common pattern of elements being detected combined with geospatial mapping identify the Hunters Point Naval Shipyard to be the source of exposure and airborne transmission to be the route of exposure.

The Navy conducted biomonitoring on tissue samples of clams and fish collected along the sediments and shoreline of the base and published the findings in the Parcel F Feasibility Study. The Navy used toxins detected in its biomonitoring to guide remediation of the contaminated shoreline. The contaminants detected by the Navy using biomonitoring were copper, lead, mercury and PCBs. Radionuclides of concern were not tested for, even though cesium-137, radium-226, cobalt-60 and strontium-90 are documented to be present in Parcel E-2 soils that drain into South Basin Area X.

The Hunters Point Community Biomonitoring Program has mounting evidence supported by urinary screenings and geospatial mappings of a community-wide toxic exposure caused by airborne shipyard soil and landfill hazards.

“The Navy denies the findings of advanced human biomonitoring capable of detecting 35 chemical toxins conducted by a licensed medical professional and analyzed by a certified laboratory using mass spectrometry … yet expects the public to accept the Navy’s restricted biomonitoring research conducted on fish and shellfish that relied on sample sizes as small as six, excluded radionuclides documented to be present in shoreline soils and limited the number of chemicals analyzed to four!” — Ahimsa Porter Sumchai, MD PD, medical director and principal investigator, Hunters Point Community Biomonitoring Program, speaking at Greenaction’s Earth Day 2021 rally outside San Francisco City Hall.

Imminent and proximate threat supporting the declaration of a local emergency: California Health and Safety Code, Section 101080

“In reality, contamination levels are three times higher than the Navy reported and 60 percent higher than the Navy’s own safety guidelines. [Principal plaintiff] Andre Patterson has been diagnosed with three tumors on his back, he has rashes and has lost several of his teeth.” — Attorney Stanley Goff, Courthousenews.com, “Residents of Treasure Island File Class Action Over Radiation Pollution”

On April 2, 2021, HP Biomonitoring conducted a comprehensive medical, historical and site evaluation along with urinary toxicology screening on a 12-year resident of Treasure Island Naval Station who presented in the immediate aftermath of exposure to a solid waste disposal area (SWDA) located on the western shoreline of the island.

The resident is a disabled senior who lives in subsidized housing with her daughter and small dog. In late March she walked — with cane assistance — along the island perimeter approaching the Westside SWDA, where she experienced eye itching, watering, particle sensations and redness that spread to include her face and neck and caused her lips to swell.

These are symptoms the Veterans Administration Airborne Hazards and Open Burn Pit Registry describe as burn pit exposures. Burn pits are open-air uncontrolled areas used by the military as a means to dispose of metal, rubber, chemicals, munitions, unexploded ordinance and medical waste.

Treasure Island is the site of military burn pits used to incinerate radioactive and chemical waste. A California Department of Public Health website documents the existence of two burn pits on Treasure Island in the region where the resident was exposed.

Urinary screening on a 20-year TI resident exposed to the military burn pit at Westside SWDA detects elevations in heavy metals and radioactive biomarkers including aluminum, cadmium, cesium, gadolinium, nickel, rubidium, thallium and manganese.

“We are fighting this toxic genocide all the way to the top of the government ladder,” says Attorney Charles Bonner of Bonner & Bonner Attorneys and Mediators at Law in their fight for justice with the Hunters Point Community Lawsuit.

A federal lawsuit filed by 400 police officers stationed in Building 606 beginning in 1996 on the Hunters Point Shipyard radiation and chemical contaminated Parcel E alleges exposure to hazardous materials led to chronic disabling health conditions and wrongful deaths.

Declaration of Local Public Health Emergency: Hunters Point Naval Shipyard and Treasure Island Naval Station

Comparing EPA EJSCREEN environmental indicators for Hunters Point and Treasure Island reveals the majority of variables for both sites exceed the 90th percentile for the US population. Treasure Island’s dangerously high EJ variables approach the 100th percentile for PM 2.5, Diesel PM, Air Toxics Cancer Risk, Respiratory Hazard Index, lead paint exposure and Superfund proximity.

The State of California Emergency Plan (SEP) authorized by the Emergency Services Act defines a series of Emergency Support Functions, one of which is the Public Health and Medical Emergency Support Function (CA-ESF 8).

California has two sets of laws that support a political declaration or proclamation in order to exercise extraordinary powers to respond to imminent and proximate threats to human health and safety. The most comprehensive is the Emergency Services Act, that can be applied to any circumstance in which conditions of extreme peril to the safety of persons and property exist that are beyond the control of the services, personnel, equipment and facilities of the locale and require the combined forces of the region to respond.

The second set of laws is contained in the California Health and Safety Code. This regulation was enacted to facilitate immediate response to hazardous materials and spills and was expanded to include any “imminent and proximate threat of the introduction of any contagious, infectious or communicable disease, chemical agent, noncommunicable biologic agent, toxin or radioactive agent.”

Under such circumstances the local health officer or designee may declare a Local Health Emergency under Section 101080 of the Health and Safety Code. Therefore, as a licensed medical practitioner operating a medical facility within the jurisdiction facing imminent and proximate threat, as a former physician with the San Francisco Department of Public Health, as a former attending physician for the Veterans Administration Environmental Registry, Stanford Fellowship trained and Board Certified in Emergency Medicine and in the absence of principled, compassionate and independent leadership exercised by the local health officer — as designee, I hereby declare a Local Health Emergency under Section 101080 of the California Health and Safety Code at Naval Stations Hunters Point and Treasure Island.

SF Bay View Health and Environmental Science Editor Ahimsa Porter Sumchai, MD, PD, founder and principal investigator for the Hunters Point Community Biomonitoring Program, founding chair of the Hunters Point Naval Shipyard Restoration Advisory Board’s Radiological Subcommittee and contributor to the 2005 Draft Historical Radiological Assessment, can be reached at AhimsaPorterSumchaiMD@Comcast.net. Dr. Sumchai is medical director of Golden State MD Health & Wellness, a UCSF and Stanford trained author and researcher, and a member of the UCSF Medical Alumni Association Board of Directors.

Originally published at https://sfbayview.com on May 5, 2021.



Founder, Director, PI - HP Biomonitoring/ Founding Chair- Radiological Committee Hunters Point Shipyard RAB 2001, Former Attending MD VA Toxic Registry & SFDPH

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Ahimsa Porter Sumchai MD

Founder, Director, PI - HP Biomonitoring/ Founding Chair- Radiological Committee Hunters Point Shipyard RAB 2001, Former Attending MD VA Toxic Registry & SFDPH