Evidence of toxic herbicide use including Agent Orange at Fort Ord, CA
We request your URGENT assistance in adding Fort Ord to the Veterans Affairs updated and expanded list of stateside DOD installations where the use of Agent Orange and other toxic herbicides are recognized. Fort Ord’s inclusion with this new rule would grant presumption for the adjudication of disability or death benefit claims for the above referenced conditions among those who were exposed.
Making a comment is simple to do. Go here: https://www.regulations.gov/document/VA-2024-VBA-0006-0001 Click on Comment. The deadline in April 12, 2024.
April 5, 2024
Table of Contents
A. Background on herbicides, including Agent Orange and suspected impact on Fort Ord
B. Background on VA Rule § 3.309, proposed changes, and the diseases subject to presumptive service connection for herbicides
C. Summary of evidence for Agent Orange usage at Fort Ord
D. Detailed evidence of Agent Orange usage at Fort Ord:
I. U.S. Army Agronomist report on Poison Oak Control Work at Fort Ord documenting a spray rig crew using between 4 to 8 lbs. of acid per acre of 2,4-D and 2,4,5-T (experimenting with them separately and in mixture) which would mean a representative acre would take roughly 200 gallons of spray material.
II. Citation of a Veteran claim and sworn testimony, including a December 1980 memorandum from the Dept. of the Army indicating that the Pest Control Shop at Fort Ord had monthly records, from January 1973 on, relating to Agent Orange and herbicide use—including references to 2,4,5-T and 2,4-D usage.
III. A citation in The Military Engineer from 1956 indicating that the use of both 2,4-D and 2,4,5-T as brush killers at Fort Ord had been highly successful in preventing poison oak dermatitis and should serve as a “valuable reference in our weed control program.”
IV. Hazardous Waste Minimization Assessment from Fort Ord indicating roughly 80,000 pounds of herbicide use per year, including waste classification of 2,4,5-T specifically.
V. Fort Ord’s Resource Conservation and Recovery Act (RCRA) Closure Plan including a RCRA Part A form where F027 (the EPA hazardous waste number for 2,4,5-T) is listed as stored at estimated 1000 lbs.
VI. Original field plot research on industrial vegetation management report evaluating the effectiveness of herbicides in controlling poison oak at Ord, which sites the use of 2,4,5-T, silvex, and aminotriazole at rates of 1 to 2 pounds per acre in 100 gallons proving to provide immediate but not long-lasting control of the poison oak.
VII. Record of Decision Operable Unit 1 Fritzsche Army Airfield Fort Ord, CA in July 1995 where Table 3 cites 2,3,7,8-Tetrachlorodibenzo-p-Dioxin (TCDD) found after excavation at 3.5 x 10-6 ppm or 3.5 ppt.
E. Summary of advocacy and findings from Cancer and illnesses from Fort Ord, CA military base
F. Lawmaker asks on behalf of those impacted by Fort Ord contamination
G. Source citations
Contributors to this Evidentiary Document
Julie Akey
Founder of Cancer and illnesses from Fort Ord, CA military base. Impacted U.S. Army Veteran and Retired U.S. Diplomat.
Mrs. Akey is a veteran who lived at Fort Ord and who graduated from the Defense Language Institute (Arabic). She is a retired U.S. Foreign Service Officer and was the State Department’s Vice Consul in Spain, Columbia, Ecuador, Guyana, and Nigeria. In 2017, Ms. Akey was diagnosed with Multiple Myeloma. Soon after, she created the Facebook group “Cancer and illnesses from Fort Ord, CA military base” to bring awareness and information to others who have suffered illnesses they believe are associated with contamination at Fort Ord.
Pat Elder, MA,
Research Analyst and Director of Military Poisons pelder@militarypoisons.org https://www.militarypoisons.org/
Mr. Elder is an expert speaker and author who founded the organization, Military Poisons, that focuses primarily on the U.S. military's use of per-and polyfluoroalkyl substances, known as PFAS. Pat has authored 300 articles on the subject and has addressed audiences around the world on the dangers inherent in the military's use of these toxins.
Denise Trabbic-Pointer, MS
Retired Chemical Engineer certified in Hazardous Material Management
Toxics and Remediation Specialist with Sierra Club dtrabbicpointer@gmail.com
Mrs. Trabbic-Pointer is a retired (2019) chemical engineer certified in Hazardous Material Management. As a career environment and occupational health professional, during her 42-year career with DuPont Performance Coatings (later spun-off as Axalta Coating Systems), Ms. Trabbic-Pointer brought awareness to and education of the adverse effects and health impacts of exposure to chemicals in the workplace. Ms. Trabbic-Pointer now volunteers her efforts as a Toxics and Remediation Specialist with the Sierra Club as a technical resource for communities affected by toxic chemicals in air, water and soil.
L. Kyle Horton, MD, MBA
Internal Medicine Physician and Public Policy Advocate
Founder and CEO of On Your Side Action
kyle@onyoursideaction.org https://www.onyoursideaction.org
Dr. Kyle Horton is a former VA physician and trained internist who is now boarded with the National Board of Physicians and Surgeons (NBPAS). She recently founded On Your Side Action, which is an advocacy organization focused on health equity, improving veterans care, and fostering healthier and safer environments. She has years of experience in both clinical practice and assisting veterans with toxic exposures in medical consultation related to their exposures. She has used these experiences to successfully advocate alongside veterans and environmental groups for legislation related to toxic exposures, care of female veterans, opiate safety, and suicide prevention to name a few.
A. Background on herbicides, including Agent Orange and suspected impact on Fort Ord Veterans
In background, Agent Orange is a 50-50 mix of the herbicides 2,4-D and 2,4,5-T; the latter of which was banned in 1979.1 2,4,5-T contains 2,3,7,8-Tetrachlorodibenzodioxin or TCDD, otherwise known as dioxin, which is one of the deadliest substances known.1 Exposure to dioxin can include simple inhalation and exposures can occur from fires, trash, and fuel burning. The half-life of dioxins in the soil is from 60 to 80 years with decades-long persistence as it seeps into the soil and sediments, and migrates into the vegetation and aquatic life, poisoning the food chain.2
According to the VA Public Health, the dioxin TCDD was “an unwanted byproduct of herbicide production.”3 TCDD is the most toxic of the dioxins, and is classified for carcinogenicity by the Environmental Protection Agency.4 The updated Agency for Toxic Substances and Disease Registry information on chlorinated dibenzo-p-dioxins (CDDs) acknowledges that exposure to 2,3,7,8-TCDD increases the risks of several types of cancer in people.5 And in point of fact the World Health Organization (WHO) International Agency for Research on Cancer does qualify 2,3,7,8-TCDD as a human carcinogen.6 Since that 1997 classification by the IARC of TCDD as a group 1 carcinogen based on limited evidence in humans, a subsequent evaluation of epidemiologic evidence in 2004 that was published in Environmental Health Perspectives found in a review of studies including mechanistic, epidemiologic, and industrial cohorts, that the evidence generally supported that 1997 IARC classification.7
The following evidentiary document references specifically the U.S. Army installation at Fort Ord which was declared an EPA Superfund site in 1990.8 Fort Ord was added to the National Priorities List citing over 45 contaminants of concern found in the soil and groundwater, including aquifers that historically served as the drinking water source.9 Expert researchers have found very substantial and compelling evidence that the most toxic components of Agent Orange, including the now banned 2,4,5-T, were used in massive quantities in order to control poison oak over thousands of acres of Fort Ord where troops extensively trained.
In recent years, organizers have identified many seriously ill or deceased former service members, dependents, and staff who served, lived, and worked around Fort Ord. Mrs. Julie Peters Akey was herself impacted by the contamination at Fort Ord having lived on the base in 1996 and 1997. She subsequently developed Multiple Myeloma (MM) which is a rare blood cancer affecting plasma cells that is more typically found in much older males with a racial disparity in incidence and earlier age of onset for blacks.10
Given the concerns for her unusual diagnosis and as she learned more about the nature of the contamination at Fort Ord, she started a private Facebook group called “Cancer and illnesses from Fort Ord, CA military base.”11 The group now has over 1,600 members including those who served, lived, and worked around Fort Ord who are concerned about health effects that may be related to the contamination.11 As part of her organizing efforts, she has created a database that includes the cancers and diseases of over 1,250 soldiers and dependents.12 This database includes a substantial number of veterans and dependents suffering from hematologic malignancies, other cancers, and illnesses that VA currently recognizes as presumptive from exposure to Agent Orange.13
Since forming the group, expert researchers have continued to find credible and definitive sources substantiating the heavy use of herbicides at Fort Ord, including the use of Agent Orange. The following document details evidence compiled by April 1, 2024. This evidence is provided to lawmakers in the hopes of action pursuant to an updated VA rule change which would expand the recognition of locations where Agent Orange was used to 18 different DOD installations in 12 states.14 The proposed list extends locations for presumptives for Agent Orange exposure in the U.S., Canada, and India by adding them to the existing locations Vietnam, Cambodia, Johnson, Atoll, Guam, American Samoa, Korea, Laos, and Thailand. The proposed VA rule change is available for public comment through the Federal Register which already reflects comments from those concerned about Agent Orange usage at Fort Ord.15
This designation of presumption for Agent Orange exposure means that VA automatically assumes a veteran who served in that area during the designated timeframe was exposed to the toxin which ensures the veteran access to related healthcare and lowers the burden of proof for veterans to be granted disability benefits. Fort Ord was left off of this list even though expert researchers, including a chemical engineer, have found substantial evidence that Fort Ord used massive amounts of herbicides to control poison oak over thousands of acres. Evidence suggests this use persisted for decades from the 1950s through the 1970s, and documents even note the intent to store 2,4,5-T designated on Ord’s Resource Conservation and Recovery Act (RCRA) Base Closure plan in 1991.16,17Although we have this compelling evidence of AO use at Ord, to date, and to our knowledge, all veteran claims in the Fort Ord Facebook group which were filed for concern of Agent Orange or other related herbicide exposure have been denied. Although Mrs. Akey’s claim for service connection was subsequently approved citing primarily other contaminants in the soil and water, including benzene, TCE, PCE, Dichloroethane, Dicloromethane (DCM), and PFAS. The vast majority of other claims for veterans without a clear occupational toxic exposure risk activity have been denied.
Based on this evidence, we respectfully request your URGENT assistance in adding Fort Ord to the Veterans Affairs updated and expanded list of stateside DOD installations where the use of Agent Orange and other toxic herbicides are recognized. Ord’s inclusion with this new rule would grant presumption for the adjudication of disability or death benefit claims for certain conditions among those who were exposed—the deadline for federal register comments is April 12th, 2024.
B. Background on VA Rule § 3.309, proposed changes, and the diseases subject to presumptive service connection for herbicides
For the 1st time, a VA proposal on February 12, 2024, plans to expand Agent Orange health coverage and presumption for disability or death benefits to veterans with certain conditions who served at 18 DOD installations in 12 states.14 The previously recognized locations as presumptive for Agent Orange exposure included locations in Vietnam, Cambodia, Johnson Atoll, Guam, American Samoa, Korea, Laos, and Thailand.
The proposed rule change to § 3.309 would expand the locations and timeframes for which VA would presume exposure to Agent Orange and other herbicides including locations in the United States, Canada, and India. The DOD has previously recognized toxic herbicide use at a limited number of DOD installations outside of Vietnam.18 This list from 2019 where “tactical herbicides and their chemical components were tested, used, or stored outside of Vietnam” does not include Fort Ord despite the evidence we will present in this document.18
The proposed rule change is part of an effort by the Biden-Harris administration in their “Unity Agenda.” While the PACT Act has addressed and created the largest expansion of veteran care and benefits in generations, it is important to realize that presumptives were not extended by that legislation in a way that benefits many veterans of Fort Ord.19 Also, it is important to realize that the PACT Act screening does not include questions about soil or water contamination at stateside installations outside of Lejeune.20 Because veterans were not made aware of the legacy of contamination at Ord, including for Agent Orange, they would not self-report their exposure in the PACT Act screening nor would they be eligible for the Agent Orange disease registry as it stands.
Given all of these factors, to date, most veterans impacted by Fort Ord’s contamination are still unable to get claims approval unless their occupation leads to their approval through a recognized occupational toxic exposure risk activity (TERA).21 The intent of the PACT Act and these changes, however, was clearly to help veterans who had faced stateside contamination like that for which we have evidence at the heavily contaminated Fort Ord. According to VA Under Secretary for Health Shereef Elnahal, M.D., “We can also care for Veterans who never deployed but were exposed to toxins or hazards while training or on active duty here at home – by working with chemicals, pesticides, lead, asbestos, certain paints, nuclear weapons, x-rays, and more. We want to bring all of these Veterans to VA for the care they’ve earned and deserve.”21
To honor the promise of this nation and the intent of the PACT Act passage by congress, we need your help to recognize the extensive contamination at Fort Ord. Briefly explained, the rule change and presumption of exposure means that VA automatically assumes that veterans who served in certain locations were exposed to certain toxins. A designation of presumption for a condition lowers the burden of proof required for a veteran to receive disability benefits, helping veterans get the benefits they deserve as quickly as possible. This expansion of presumptives under the rule change § 3.309 by adding Fort Ord would mean that VA recognizes toxic herbicides, including Agent Orange, were used at Fort Ord and would mean that veterans with certain conditions that are highly associated with exposure to these herbicides would be covered for VA benefits. Through April 12th, the VA is accepting public comments on the proposed expansion of presumptive areas of exposure from herbicides, and many Fort Ord veterans have chosen to comment.15
For reference, the diseases recognized by VA as associated with exposure to certain herbicide agents are delineated as follows: AL amyloidosis, Chloracne or other acneform disease consistent with chloracne, Type 2 diabetes (also known as Type II diabetes mellitus or adult-onset diabetes), Hodgkin's disease, Ischemic heart disease (including, but not limited to, acute, subacute, and old myocardial infarction; atherosclerotic cardiovascular disease including coronary artery disease (including coronary spasm) and coronary bypass surgery; and stable, unstable and Prinzmetal's angina), all chronic B-cell leukemias (including, but not limited to, hairy-cell leukemia and chronic lymphocytic leukemia), Multiple myeloma, non-Hodgkin's lymphoma, Parkinson's disease, early-onset peripheral neuropathy, porphyria cutanea tarda, prostate cancer, respiratory cancers (cancer of the lung, bronchus, larynx, or trachea), soft-tissue sarcoma (other than osteosarcoma, chondrosarcoma, Kaposi's sarcoma, or mesothelioma).13 The term “soft-tissue sarcoma” includes the following: “Adult fibrosarcoma, Dermatofibrosarcoma protuberans, Malignant fibrous histiocytoma, Liposarcoma, Leiomyosarcoma, Epithelioid leiomyosarcoma (malignant leiomyoblastoma), Rhabdomyosarcoma, Ectomesenchymoma, Angiosarcoma (hemangiosarcoma and lymphangiosarcoma), Proliferating (systemic) angioendotheliomatosis, Malignant glomus tumor, Malignant hemangiopericytoma, Synovial sarcoma (malignant synovioma), Malignant giant cell tumor of tendon sheath, Malignant schwannoma, including malignant schwannoma with rhabdomyoblastic differentiation (malignant Triton tumor), glandular and epithelioid malignant schwannomas, Malignant mesenchymoma, Malignant granular cell tumor, Alveolar soft part sarcoma, Epithelioid sarcoma, Clear cell sarcoma of tendons and aponeuroses, Extraskeletal Ewing's sarcoma, Congenital and infantile fibrosarcoma, and Malignant ganglioneuroma.”13
When reviewing those conditions and comparing to the database of the Facebook group “Cancer and illnesses from Fort Ord, CA military base, you will find similarities in the patterns of conditions being found.12 ASAP action by lawmakers would ensure DOD recognition of the compelling evidence of Agent Orange usage at Ord and that impacted Fort Ord veterans would be eligible for presumptive coverage for their benefits.
We request your URGENT assistance in adding Fort Ord to the Veterans Affairs updated and expanded list of stateside DOD installations where the use of Agent Orange and other toxic herbicides are recognized under § 3.309. Ord’s inclusion with this new rule would grant presumption for the adjudication of disability or death benefit claims for the above referenced conditions among those who were exposed.
C. Summary of evidence for Agent Orange usage at Fort Ord
To date, researcher Pat Elder and retired chemical engineer Denise Trabbic-Pointer have found seven different primary sources of evidence for heavy herbicide usage, including the active components of Agent Orange. This evidence was first reported by Mr. Elder on March 31, 2024.
Photo - Toxicodendron diversilobum - Pacific Poison Oak.
I. U.S. Army Agronomist report on Poison Oak Control Work at Fort Ord documenting a spray rig crew using between 4 to 8 lbs. of acid per acre of 2,4-D and 2,4,5-T (experimenting with them separately and in mixture) which would mean a representative acre would take roughly 200 gallons of spray material.16
Floyd L. Otter who was a Management Agronomist for the U.S. Army working at Fort Ord reports on records on the usage of herbicides to control poison oak at Fort Ord. He documents the impact on training from the number of troops who reported to sick call with poison oak dermatitis. He compares the reduction of cases from the control period, which was in 1950 before the herbicide use, and explains, “By August 1, 1951 only 691 acres of an estimated 9,000 needing treatment had been sprayed. Of course, the more heavily used areas were treated first.” He continues by clarifying the extent of the need and the herbicidal usage approach which proved effective. Specifically cited are the use of 2,4-D and 2,4,5-T; the latter of which is the banned known and carcinogenic component of Agent Orange. From Mr. Otter, “Daily records were kept so that we can go back to any area and know when and how it was treated. The records show that the requirement of herbicide usually ran between 4 and 8 pounds of acid per acre, or one to two gallons of liquid herbicide. The report reads, “The spray rig when a full crew was available, would put out 1500 to 2000 gallons per 8-hour day. A representative acre therefore would take 200 gallons of spray material (of which 1} gallons would be 2,4-D - 2,4,5-T mixture, and 8 gallons diesel oil) and one man-day of labor.”16
II. Citation of a Veteran claim and sworn testimony, including a December 1980 memorandum from the Dept. of the Army indicating that the Pest Control Shop at Fort Ord had monthly records, from January 1973 on, relating to Agent Orange and herbicide use—including references to 2,4,5-T and 2,4-D usage. 22
Citation NR: 1235530 with a decision date of 10/15/2012 which was an appeal from the Department of Veterans Affairs Regional Office in Portland, OR includes a letter from the Army dated in December 1980 noting that the Pest Control Shop at Fort Ord had monthly records dating back to January 1973 of all herbicides used, and that 2,4,5-T and 2,4-D usage was included in the records.22 The veteran was unfortunately denied his claim for Type II DM and chronic lymphocytic leukemia (CLL) secondary to herbicide exposure.23
III. A citation in The Military Engineer from 1956 indicating that the use of both 2,4-D and 2,4,5-T as brush killers at Fort Ord had been highly successful in preventing poison oak dermatitis and should serve as a “valuable reference in our weed control program.”24
Discussions in the journal from Sam E. Alden, Major, Corps of Engineers and Post Engineer, reference that the information from Mr. Neil about brush control at Fort Ord will serve as “a very valuable reference in our weed control program.” The description of the poison oak control efforts at Fort Ord reads, “In training areas, such as Fort Ord, where poison oak has been extremely troublesome to military personnel., a well-organized chemical war has been waged against this woody plant pest. A drastic reduction in trainee dermatitis casualties has been the reward. Here both 2,4-D—2,4,5-T brush killer, and “Ammate” weed and brush killer have been used in the chemical campaign.”24
IV. Hazardous Waste Minimization Assessment from Fort Ord indicating roughly 80,000 pounds of herbicide use per year including waste classification of 2,4,5-T specifically.25
From the Defense Technical Information Center, the Hazardous Waste Minimization Assessment for Fort Ord presents in Table 26 total waste generation and “Quantities of Materials Used by Miscellaneous Sources,” which references 80,000 pounds of herbicides used per year. In these documents, Agent Orange is characterized as a phenoxy pesticide and in Table 50 of that document is the Waste Classification Pesticides, including those containing 2,4,5-T, with a reference to the use of 2,000 lbs. The trade names under that waste classification include Brush-Rhap, Dacamine, Ded-Weedon, Esteron, Farmco Fence Rider, Forron, Inverton 245, Line Rider, Super D Weedone, Tormona, Transamine, U 46, Veon 245, Weedar, and Weedone.25
V. Fort Ord’s Resource Conservation and Recovery Act (RCRA) Closure Plan including a RCRA Part A form where F027 (the EPA hazardous waste number for 2,4,5-T) is listed as stored at estimated 1000 lbs.17
The Final Closure Plan for Fort Ord for the Defense Reutilization Marketing Office indicates the storage of hazardous waste that falls under the EPA waste number F027, which includes, “discarded unused formulations containing tri-, tetra-, or pentachlorophenol or discarded unused formulations containing compounds derived from these chlorophenols. (This listing does not include formulations containing Hexachlorophene synthesized from prepurified 2,4,5-trichlorophenol as the sole component.)”26 This listing of all the hazardous wastes that were or could be generated at Fort Ord, and particularly during the facility closure activities, cites the hazardous waste F027 as a waste that could be generated and stored on the DRMO storage unit at less than 1,000 pounds. This means the Army intended to store, prior to discarding, up to 1000 pounds of Agent Orange waste at the permitted storage unit. To further substantiate this concern, Table 7 of the “Draft” Final Closure Plan for the DRMO Container Storage Unit includes analytical results that indicate 4,4-DDE and 4,4-DDT were present in soil and sediments underlying that storage unit—further confirmation of Agent Orange storage prior to disposal.17
VI. Original field plot research on industrial vegetation management report evaluating the effectiveness of herbicides in controlling poison oak at Ord, which sites the use of 2,4,5-T, silvex, and aminotriazole at rates of 1 to 2 pounds per acre in 100 gallons, as proving to provide immediate but not long-lasting control of the poison oak. 27
There is a citation for an assessment of the effectiveness of several herbicides in controlling poison oak at Fort Ord from 1965 to 1969. The article appears in a “Right-of-Way Ecological Effects Bibliography” from the Electric Power Research Institute and recaps the author’s general experiences in controlling poison oak with herbicides. The document references the usage of 2,4,5-T; 2,4-D; silvex, and aminotriazole at rates of 1 to 2 pounds per acre in 100 gallons as giving immediate but not long-lasting control of the poison oak at Fort Ord.27
VII. Record of Decision Operable Unit 1 Fritzsche Army Airfield Fort Ord, CA in July 1995 where Table 3 cites 2,3,7,8-Tetrachlorodibenzo-p-Dioxin (TCDD) found after excavation at 3.5 x 10-6 ppm or 3.5 ppt. 28
From the Sacramento Corps of Engineers, the Record of Decision Operable Unit 1 at Fritzsche Army Airfield in Fort Ord, there is a report of “Chemicals Detected in the Soil Prior to and After Excavation and Preliminary Remediation Goals.” Table 3 in that document cites 2,3,7,8-Tetrachlorodibenzo-p-Dioxin (TCDD) found after excavation at 3.5 x 10-6 ppm or 3.5 ppt. This finding is above the remediation goal of 1.2 ppt.28
C. Detailed evidence of Agent Orange usage at Fort Ord
I. U.S. Army Agronomist report on Poison Oak Control Work Control at Fort Ord documenting a spray rig crew using between 4 to 8 lbs. of acid per acre of 2,4-D and 2,4,5-T (experimenting with them separately and in mixture) which would mean a representative acre would take roughly 200 gallons of spray material.16
The report documents a spray rig crew using between 4 to 8 lbs. of acid per acre of 2,4-D and 2,4,5-T (experimenting with them separately and in mixture) which would mean a representative acre would take roughly 200 gallons of spray material. The report reads as follows, “Poison oak poisoning, for some mysterious reason is often considered a slightly humorous disease. At Fort Ord, however, the Medical Officer gives it the more dignified name of poison oak dermatitis, and his reports on the extent of this poisoning among trainees do not make humorous reading to the training officers nor to the taxpayers.
Previous to starting the 1951 control program as many as 339 men in one month reported on sick call with poison oak dermatitis and as many as 34 cases in one month had to be hospitalized for an average of 7 clays per case. This does not include the cases not serious enough to require a doctor. It can readily be seen that this shrub not only causes lost time and hospital costs but the interruption of the regular training sequences is even more costly. A man who loses one week from poison oak poisoning may have to be dropped from his unit and be held over several weeks to complete his training with another unit.
This loss, contrary to· common opinion, is almost constant throughout the year with no consistent seasonal variation. Nearly 27,000 acres at Fort Ord are used for training. The most intensively used areas are thickly infested with .poison oak. They are used almost daily for marching, bivouacing, and infantry problems of all kinds, night and day.
One solution suggested for this poison oak problem is that Selective Service induct all poison oak susceptible men into the Navy instead of the Army. Until some such simple solution is found, however, it seems necessary to attack the poison oak.
I will briefly review three phases of the program:
Effect of one season's work on the number of poisoning cases.
Methods and costs.
Results insofar as they are obtainable at this early date.
Credit should go to the Sixth Army at San Francisco for recognizing the problem and providing funds for last year and for the coming season, and also for furnishing a machine called a Bushwacker, new to the west, for clearing the brushy areas. I am indebted to the Medical Officer at Fort Ord for the data on poisoning cases, and to the Post for authorization to hire an experienced weed control man to supervise the work.
The U.S. Department of Agriculture's Blister Rust people deserve special mention. Mr. H. R. Offord, M. V. Benedict and Art London besides giving us complete plans and advice based on their Ribes control experience, loaned us equipment and trained our men in the use of it. Dr. Oliver Leonard of the University of California at Davis has advised us on chemicals and put out dozens of test plots on the reservation. The State Extension Service, State Department of Agriculture, and the field men of several chemical companies have also been very helpful.
The control work seems to have given surprisingly quick results. To get the best possible comparative·figures the period August l to December 31, 1950 was taken as representative of the period before intensive control work had been done, and the corresponding five months of 1951 were taken as representative of the results after an appreciable area had been treated. Actually, by August 1, 1951 only 691 acres of an estimated 9000 needing treatment had been sprayed. Of course, the more heavily used areas were treated first. '
Comparison of the two five-month periods shows that poison oak sick call cases, even with an increase in post strength, decreased 53%, the rate of incidence of poison oak cases per 1000 men decreased 57%, and the daily non~effective rate per 1000 men decreased 68%. Additional information is shown in Table 1.
The methods and equipment used for control work were selected after considerable study of methods used elsewhere. At Camp Adair, Oregon, for example, the Army, assisted by the U.S. Department of Agriculture's Blister Rust Control people carried out an eradication program up 17,000 acres in 1942•3 using bulldozers, hand-grubbing and borax. Costs ran up to $400 per acre with an average of $18.00. Fort Ord has done extensive hand grubbing, diesel oil spraying and 2,4-D spraying in past years. Airplane spraying was considered but most of the poison oak is found under live oak trees which were needed as cover for the training work. It was felt, also, that airplane spraying might be hazardous to the lettuce and artichoke fields near the base.
The methods and equipment developed over a period of several years for Ribea control were therefore adopted. A spray rig consisting of a Bean ''Royal 20" pump, Wisconsin VF-4 gasoline motor and a 500-gallon tank was purchased and mounted on a 22-Ton 4-Wheel drive army truck. This rig works normally about 15 acres to a setting, using 1000 feet of 11 mainline hose and eight 3/8 inch lateral hoses, each 400 feet long. All couplings are of the type that can be quickly coupled and uncoupled under pressure. The rig requires 10 men for full operation. Each nozzle man works a lane 33 feet wide laid out with white string.
Chemicals used included 2,4-D and 2,5-T Esters (Ed. Note – this is a typo! There is no such 2,5-T ester. It is 2,4,5-T) alone and in various combinations, 2,4-D amine, and ammonium sulphamate. Diesel oil and a spreader sticker were used. Acid concentrations were between 3000 and 5000 p.p.m.
Daily records were kept so that we can go back to any area and know when and how it was treated. The records show that the requirement of herbicide usually ran between 4 and 8 pounds of acid per acre, or one to two gallons of liquid herbicide. The spray rig when a full crew was available, would put out 1500 to 2000 gallons per 8 hour day.
A representative acre therefore would take 200 gallons of spray material (of which 1} gallons would be 2,4-D - 2,4,5-T mixture, and 8 gallons diesel oil) and one man-day of labor. These materials cost about $14.00 and the labor $11.00, or $25.00 per acre to which must be added .all costs of equipment operation, depreciation, miscellaneous supplies, and office overhead.
During the season, April 2 to October 12, 875 acres were treated. As to the amount of kill obtained very little can be determined at this early date. The areas treated in 1949 and 1950 with straight 2,4-D and water re-sprouted heavily, The season of treatment seems to be very important. The winter work using the "dormant" spray method with 2,4-D and diesel oil was a failure. Our standard treatment applied before May 15th gave top kill but there was heavy sprouting in the open areas where leafing-out was late. The areas treated from May 15 to October 12 all appear dead at this time, but we expect some regrowth.
In conclusion, we are fairly well satisfied with the methods used last year, and with the results as far as they can be ascertained at this time. The 57% reduction in poison oak cases shows quicker results than were expected. We are interested in any improvement that can be made in equipment or materials or any way in which costs can be lowered or quicker kill obtained.”16
II. Citation of a Veteran claim and sworn testimony, including a December 1980 memorandum from the Dept. of the Army indicating that the Pest Control Shop at Fort Ord had monthly records, from January 1973 on, relating to Agent Orange and herbicide use—including references to 2,4,5-T and 2,4-D usage. 22, 23
Citation NR: 1235530 with a decision date of 10/15/2012 which was an appeal from the Department of Veterans Affairs Regional Office in Portland, OR includes a letter from the Army dated in December 1980 noting that the Pest Control Shop at Fort Ord had monthly records dating back to January 1973 of all herbicides used, and that 2,4,5-T and 2,4-D usage was included in the records.22
The veteran was unfortunately denied his claim for Type II DM and chronic lymphocytic leukemia (CLL) secondary to herbicide exposure.23
III. A citation in The Military Engineer from Jan.-Feb. 1956 indicating that the use of both 2,4-D and 2,4,5-T as brush killers at Fort Ord had been highly successful in preventing poison oak dermatitis and should serve as a “valuable reference in our weed control program.”24
Discussions in the journal from Sam E. Alden, Major, Corps of Engineers and Post Engineer, reference a report from a Mr. Neil about brush control at Fort Ord, and explains that brush control program will serve as “a very valuable reference in our weed control program.”
The description of the poison oak control efforts at Fort Ord reads, “In training areas, such as Fort Ord, where poison oak has been extremely troublesome to military personnel., a well-organized chemical war has been waged against this woody plant pest.
A drastic reduction in trainee dermatitis casualties has been the reward. Here both 2,4-D—2,4,5-T brush killer, and “Ammate” weed and brush killer have been used in the chemical campaign.”24
IV. Hazardous Waste Minimization Assessment from Fort Ord indicating roughly 80,000 pounds of herbicide use per year including waste classification of 2,4,5-T specifically.25
From the Defense Technical Information Center, the Hazardous Waste Minimization Assessment for Fort Ord presents in Table 26 total waste generation and “Quantities of Materials Used by Miscellaneous Sources,” which references 80,000 pounds of herbicides used per year.25
Hazardous Waste Minimization Assessment - Fort Ord, CA July 5, 1991
In these documents, Agent Orange is characterized as a phenoxy pesticide which would include Table 50 of that document which is Waste Classification Pesticides including those containing 2,4,5-T references the use of 2,000 lbs. The trade names under that waste classification include Brush-Rhap, Dacamine, Ded-Weedon, Esteron, Farmco Fence Rider, Forron, Inverton 245, Line Rider, Super D Weedone, Tormona, Transamine, U 46, Veon 245, Weedar, and Weedone.25
TABLE 50
V. Fort Ord’s Resource Conservation and Recovery Act (RCRA) Closure Plan including a RCRA Part A form where F027 (the EPA hazardous waste number for 2,4,5-T) is listed as stored at estimated 1000 lbs.17
The following is from a Hazardous Waste Permit Part A application pursuant to Fort Ord’s Resource Conservation and Recovery Act (RCRA) Closure Plan, which lists all the hazardous wastes that were or could be generated at Fort Ord, and particularly during facility closure activities. As indicated in the following screenshots from the application, F027 waste, was one of the waste codes that could be generated and stored on the DRMO storage unit site at less than 1,000 pounds.17
The wastes covered by Hazardous Waste Number F027 include “Discarded unused formulations containing tri-, tetra-, or pentachlorophenol or discarded unused formulations containing compounds derived from these chlorophenols. (This listing does not include formulations containing Hexachlorophene synthesized from prepurified 2,4,5-trichlorophenol as the sole component.)”26
This means the Army intended to store, prior to discarding, up to 1000 pounds of F027 Agent Orange waste at the permitted storage unit (DRMO) for the period defined in their hazardous waste permit (typically one year). Evidence does not tell us how much Agent Orange waste they temporarily stored at the DRMO storage unit and ultimately disposed of, but we do know that the active ingredients in Agent Orange were stored on the hazardous waste storage unit.
Table 7 of the "Draft" Final Closure Plan for the DRMO Container Storage Unit includes analytical results that indicate 4,4-DDE and 4,4-DDT were present in soil and sediments underlying the DRMO storage unit. This further confirms that AO was stored on the DRMO prior to disposal.30
TABLE 7
Dioxin is bioaccumulative and has a half-life in soil from 60 to 80 years, and at the same time, it persists for a long time in the environment, seeps into the soil and sediments, and migrates into vegetation and aquatic life, leading to bioaccumulation in the soil and food chain.29
VI. Original field plot research on industrial vegetation management report evaluating the effectiveness of herbicides in controlling poison oak at Ord, which sites the use of 2,4,5-T, silvex, and aminotriazole at rates of 1 to 2 pounds per acre in 100 gallons proving to provide immediate but not long-lasting control of the poison oak. 27
A citation for an assessment of the effectiveness of several herbicides in controlling poison oak at Fort Ord from 1965 to 1969. The article appears in a “Right-of-Way Ecological Effects Bibliography” from the Electric Power Research Institute and recaps the author’s general experiences in controlling poison oak with herbicides listed including 2,4,5-T; 2,4-D; silvex, and aminotriazole at rates of 1 to 2 pounds per acre in 100 gallons as giving immediate but not long-lasting control.27
VII. Record of Decision Operable Unit 1 Fritzsche Army Airfield Fort Ord, CA in July 1995 where Table 3 cites 2,3,7,8-Tetrachlorodibenzo-p-Dioxin (TCDD) found after excavation at 3.5 x 10-6 ppm or 3.5 ppt.28
From the Sacramento Corps of Engineers, the Record of Decision Operable Unit 1 at Fritzsche Army Airfield in Fort Ord, there is a report of “Chemicals Detected in the Soil Prior to and After Excavation and Preliminary Remediation Goals.” Table 3 in that document cites 2,3,7,8-Tetrachlorodibenzo-p-Dioxin (TCDD) found after excavation at 3.5 x 10-6 ppm or 3.5 ppt. This finding is above the remediation goal of 1.2 ppt.28
E. Summary of advocacy and findings from Cancer and illnesses from Fort Ord, CA military base
Ms. Akey lived on base in 1996 and 1997, and was subsequently diagnosed, at an atypically young age, with Multiple Myeloma (MM). Ms. Akey’s claim was approved as 100% service connected by citing contaminants in the soil and likely affecting the groundwater--primarily hinging on evidence of TCE, PCE, Dichloroethane, benzene, PFAS, and Dicloromethane (DCM). Prior to gathering the compelling evidence for the herbicide use, VA denied Ms. Akey’s claim for service connection for her MM based on Agent Orange exposure.
Given her ongoing concerns with her own condition and others impacted, she has continued to grow the network of a Facebook group “Cancer and illnesses from Fort Ord, CA military base.”11 That group has continued to grow and now includes over 1,600 members. As part of her organizing efforts, she has created a database that includes the cancers and diseases of over 1,250 soldiers and dependents.12 This database includes a substantial number of veterans and dependents suffering from hematologic malignancies, other cancers, and illnesses that VA currently recognizes as presumptive from exposure to Agent Orange.13 Although we have this compelling evidence of AO use at Ord, to date, all veteran claims in the group filed for concern of AO have been denied and the vast majority of other claims for veterans without a clear occupational toxic exposure risk activity have been denied.
Beginning in 2021, group leaders organized the impacted community around a series of asks focused on better understanding of the impact of the contamination on their health and facilitating action to get appropriate healthcare and benefits to those suffering. They created a petition at that time asking for a number of actions in a whole of government approach to addressing the impacts of the contamination that included: providing healthcare and benefits for those impacted by Fort Ord contamination akin to those granted to those who were impacted at Camp Lejeune, the creation of a health registry, reassessment of health effects by ATSDR, creation of a medical monitoring program, and periodic reassessment to add conditions to the presumptive list pursuant to new evidence by ATSDR or gained through the health registry.31
The community of folks concerned with Fort Ord previously drafted a petition calling for “Fairness for the Patriots and Patriots Poisoned at Fort Ord, US Army Base—that petition has gathered over 27,000 signatures of individuals who stand with Fort Ord.31
Media outreach has continued to reach more folks and in 2022, the AP published a nationally featured story about the contamination at Fort Ord entitled, “What Lies Beneath: Vets worry polluted base made them ill.”32 Later, they would follow-up with a more thorough investigative report on the concerns with the contamination at Fort Ord. The investigative reporting was featured nationally as a “Best of the Week” and is archived as, “Toxic Chemicals Lie Beneath Fort Ord.”33
In that reporting, you will find reference to a flawed previous ATSDR study conducted in 1996, which concluded that there was “no apparent public health hazard” posed by the contamination at Fort Ord.34In review of the quality of the study and after consultation with experts, Ms. Akey corresponded with ATSDR on her concerns. Also, leaders had a series of meetings and follow-up with Representatives Jimmy Panetta and Katie Porter who subsequently corresponded with ATSDR to request an updated study. ATSDR would agree to conduct an updated study and health assessment although details were initially unclear. In February 2023, the Agency published more information on what assessments would be completed as part of the updated study.35
In review of that documentation, Ms. Akey consulted with Ms. Trabbic-Pointer who is a chemical engineer with a BS and MS in Hazardous Materials Management and a career EHS professional. Ms. Trabbic-Pointer has 42 years of experience with DuPont and a spin-off company, Axalta Coating Systems. Using her expertise, they crafted a detailed series of requests to ATSDR with the express goal of providing those impacted by the Fort Ord contamination with a more accurate and comprehensive health assessment of their risks from exposure. Concerns raised included but were not limited to: failure to consider and review volatilization of indoor air from chlorinated chemicals, not assessing cumulative exposures to chlorinated chemicals, failure to consider synergistic effects including of PFAS with previous known carcinogenic chemicals like TCE, and consequentially ignoring evidence of an expanding TCE plume due to a faulty extraction well and pump and treat system. Major inadequacies in the initial Fort Ord Public Health Assessment that they identified include failure to: consider key routes of exposure, include certain highly toxic contaminants of concern, assess certain base locations and times of ongoing contamination, and study very consequential potential health effects including immune toxicity and from endocrine disruption in particular.
Despite the many inadequacies addressed in their detailed request, ATSDR essentially denied every request. Even considering this denial, our expert leaders continue to advocate, including recently meeting with the new Director of NCEH/ATSDR. Unfortunately, per his expressed concerns, the updated budget to ATSDR was cut and so there is little reason to believe that ATSDR will commit to any further action at Ord in the future, although there was a new allotment made of $5M for PFAS-related outreach and work.
In recent months though, the evidence we have assimilated on the herbicide use, including of Agent Orange, has led leadership to a clear conclusion that the contamination at Fort Ord needs and merit immediate redress.
We are asking for your immediate ACTION to add Fort Ord under the updated and expanded list of stateside DOD installations where the use of Agent Orange and other toxic herbicides is recognized for presumption of service connection for certain conditions. Given the very direct and compelling evidence for dioxin use, as well as the decades of science behind the toxic effects of these herbicides, we believe a study is no longer needed--rather that the addition of Fort Ord to the proposed expanded list for presumption is the EVIDENCE-BASED action that is merited.
F. Lawmaker Asks on Behalf of those impacted by Fort Ord Contamination
As previously described, a VA proposal on February 12, 2024, plans to expand Agent Orange health coverage and presumption for disability or death benefits to veterans with certain conditions who served at 18 DOD installations in 12 states.3 Unfortunately, Fort Ord was left off the list. Since previous corresponding with federal lawmakers, expert researchers, including a chemical engineer, have found substantial, compelling evidence that Fort Ord used massive amounts of herbicides to control poison oak over thousands of acres. We believe this use persisted for decades from the 1950s through the 1970s, and have noted the intent to store 2,4,5-T designated on Ord’s Resource Conservation and Recovery Act (RCRA) Closure plan in 1991.
Based on this evidence, we respectfully request your URGENT assistance in adding Fort Ord to the Veterans Affairs updated and expanded list of stateside DOD installations where the use of Agent Orange and other toxic herbicides are recognized. Ord’s inclusion with this updated rule § 3.309 would grant presumption for the adjudication of disability or death benefit claims for certain conditions among those who were exposed.
Furthermore, we ask your consideration for the many seriously ill or deceased former service members, dependents, and staff who served, lived, and worked around Fort Ord, which was among the worst of the worst locations for contamination by virtue of its designation on the EPA’s Superfund National Priorities List. Fort Ord featured a burn pit on top of the inadequately assessed groundwater contamination, which seeped into the drinking water aquifers. The groundwater contamination included extremely toxic and carcinogenic contaminants, namely: TCE, benzene, PCE, Dichloroethane, Dichloromethane, and PFAS (to name a few). In view of the previously inadequate study of the health effects at Fort Ord and the ATSDR’s clear expression that they are unwilling to provide the kind of comprehensive health information those impacted deserve, we continue to ask for definitive and health protective action by lawmakers to stand up for Fort Ord.
We must stop the cycle of delay, deny, and hope they die when it comes to those who have served, lived on, or worked at these DOD Superfund sites.
To stop this abusive cycle, we are respectfully requesting parity with the same healthcare and benefits guaranteed to those exposed at Camp Lejeune. This includes a specific request for veterans benefits coverage as well as hospital and medical services coverage equivalent to those guaranteed in the Honoring America’s Veterans and Caring for Camp Lejeune Families Act of 2012. And because this is now a pattern across different service branches and including many other DOD sites, we are demanding proactive policies that protect those exposed at all the other Lejeunes that may be identified. We respectfully request the following further federal actions:
❖ Creating a Health Registry similar to the Airborne Hazards and Open Burn Pit Registry that allows for growing the body of knowledge of potential conditions related to contamination at Fort Ord and other DOD Superfund sites.
❖ Requiring periodic reviews of the registry with public comment periods coinciding with ATSDR reporting to Congress on emerging epidemiological evidence that would substantiate adding conditions to the presumptive list for VA benefits coverage.
❖ Establishing a Medical Monitoring Program for those impacted that will be guided by information learned through the Registry.
❖ Add DOD Superfund site information to the VA Exposure Education Application with links to clinical guidance on key contaminants of concern found at Lejeune and which are now repeatedly being identified, including specifically those that are known or probable human carcinogens.
The above requests for action have been endorsed by over 27,000 individuals who stand with those impacted by the contamination at Fort Ord.
G. Source Citations
1. NIH. History of the Controversy of the Use of Herbicides. Available at: https://www.ncbi.nlm.nih.gov/books/NBK236351/#:~:text=The%20military%20use%20of%202,of%20the%20entire%20herbicide%20operation.
2. NIH. A Review of Soil Contaminated with Dioxins and Biodegradation Technologies: Current Status and Future Prospects. https://www.ncbi.nlm.nih.gov/pmc/articles/PMC9227754/
3. U.S. Department of Veterans Affairs Public Health. Facts About Herbicides. Available at: https://www.epa.gov/sites/default/files/2016-09/documents/2-3-7-8-tetrachlorodibenzo-p-dioxin.pdf
4. Environmental Protection Agency (EPA). Info on 2,3,7,8-Tetrachlorodibenzo-p-Dioxin (2,3,7,8,-TCDD). Available at: https://www.epa.gov/sites/default/files/2016-09/documents/2-3-7-8-tetrachlorodibenzo-p-dioxin.pdf
5. Agency for Toxic Substances and Disease Registry Division of Toxicology and Environmental Medicine. ToxFAQs Chlorinated Dibenzo-p-Dioxins (CDDs). Available at: https://www.atsdr.cdc.gov/toxfaqs/tfacts104.pdf
6. World Health Organization (WHO) International Agency for Research on Caner (IARC). Monographs on the Evaluation of Carcinogenic Risks to Humans Volume 69 Polychlorinated Dibenzo-para-Dioxins and Polychlorinated Dibenzofurans. Available at: https://publications.iarc.fr/Book-And-Report-Series/Iarc-Monographs-On-The-Identification-Of-Carcinogenic-Hazards-To-Humans/Polychlorinated-Dibenzo--Em-Para-Em--Dioxins-And-Polychlorinated-Dibenzofurans-1997
7. Steenland et al. Environmental Health Perspect. 2004. Dioxin revisited: developments since the 1997 IARC classification of dioxin as a human carcinogen. Available at: https://pubmed.ncbi.nlm.nih.gov/15345337/
8. U.S. Environmental Protection Agency (EPA) Superfund Site report for Fort Ord. Available at: https://cumulis.epa.gov/supercpad/CurSites/csitinfo.cfm?id=0902783&msspp=med
9. U.S. Environmental Protection Agency (EPA) Superfund Contaminant List for Fort Ord. Available at: https://cumulis.epa.gov/supercpad/SiteProfiles/index.cfm?fuseaction=second.contams&id=0902783&fbclid=IwAR0EsetwJ2BIfWD7PLJoQ6CIuas-LojWYTvRmsXznVohhrqZ28waTInTVCY
10. Waxman et al. Blood. 2010. Racial disparities in incidence and outcoume in multiple myeloma: a population-based study. Available at: https://ashpublications.org/blood/article/116/25/5501/28669/Racial-disparities-in-incidence-and-outcome-in
11. Cancer and Illnesses from Fort Ord, CA military base. Private Facebook Group, 1,600 Members.
12. Database of Impacted Veterans, Civilians, and Dependents who served, worked, or lived at Fort Ord. https://static1.squarespace.com/static/6005a180c8cd610112a8a795/t/65d4bd987a294d133fe7d226/1708440984923/Akey+ATSDR+Spreadsheet+no+initials.xlsx
13. National Archives Code of Federal Regulations . § 3.309 Disease subject to presumptive service connection. Diseases associated with exposure to certain herbicide agents. Available at: https://www.ecfr.gov/current/title-38/chapter-I/part-3/subpart-A/subject-group-ECFR39056aee4e9ff13/section-3.309?fbclid=IwAR1dkw-wCE8K0ZAtRXK4AgPhSqRCR0-MU4Pm7Qu77XJphOvzTXo-87PRqPQ_aem_AdzqnESBYP2wAEn7rCQo7J5pb3hg78g4wfnxnwviyUIr572TSjoCJ6TdRL5asJL0BSABvziv-Tt4q8I8HOnw68ja
14. U.S. Department of Veterans Affairs. VA proposes rule to extend presumed areas of exposure to Agent Orange and other herbicides, making it easier for exposed Veterans to receive their earned benefits. Available at: https://news.va.gov/press-room/va-presumes-exposure-agent-orange-herbicides/
15. U.S. Department of Veterans Affairs. Updating VA Adjudication for Disability or Death Benefit Claims Related to Exposure to Certain Herbicide Agents. Available at: https://www.federalregister.gov/documents/2024/02/12/2024-02590/updating-va-adjudication-regulations-for-disability-or-death-benefit-claims-related-to-exposure-to
16. Poison Oak Control Work at Fort Ord, California from Floyd L. Otter, Management Agronomist for US Army, Fort Ord, California. Available at: https://ucanr.edu/repository/fileaccess.cfm?article=164771&p=LKIILR
17. U.S. Environmental Protection Agency. Fort Ord Hazardous Waste Permit Application Part A. November 1996 with revision March 1997. Available at: https://docs.fortordcleanup.com/ar_pdfs/AR-BW-0188/Appendices/Appendix_B.pdf
18. U.S. Department of Veterans Affairs Public Health. Herbicide Tests and Storage in the U.S. Available at: https://www.publichealth.va.gov/exposures/agentorange/locations/tests-storage/usa.asp
19. U.S. Department of Veterans Affairs. The PACT Act and your VA benefits. Available at: https://www.va.gov/resources/the-pact-act-and-your-va-benefits/
20. U.S. Department of Veterans Affairs. PACT Act Toxic Exposure Screening and your VA benefits. Available at: https://www.va.gov/lovell-federal-health-care-va/programs/pact-act-toxic-exposure-screening-and-your-va-benefits/#:~:text=A%20toxic%20exposure%20screening%20supports,toxins%20during%20your%20military%20service.
21. U.S. Department of Veterans Affairs. VA Expands health care eligibility to all Veterans exposed to toxins and other hazards during military service. 2024. Available at: https://www.va.gov/southern-nevada-health-care/news-releases/va-expands-health-care-eligibility-to-all-veterans-exposed-to-toxins-and-other-hazards-during-military/
22. U.S. Department of Veterans Affairs. Citation Nr: 1235530. Decision date: 10/15/2012. Available at: https://www.va.gov/vetapp12/files5/1235530.txt?fbclid=IwAR2NOr9xldhtkvY3Vn-VFyXoZuwBsQAWkSRBkkRyhY2eyzPEy9klDot270o
23. U.S. Department of Veterans Affairs. Citation Nr: 0802291. Decision 1/22/08. Available at. https://www.va.gov/vetapp08/files1/0802291.txt
24. Alden et al. The Military Engineer. Vol 48 No. 321 (Jan-Feb 1956). P 33-35. Discussions on Chemical Control of Weeds. Available at: https://www.jstor.org/stable/44603883
25. Defense Technical Information Center. Hazardous Waste Minimization Assessment: Fort Ord, CA. May 1991. Available at: https://apps.dtic.mil/sti/citations/ADA238101
26. U.S. Environmental Protection Agency. Hazardous Waste Numbers as cited in Federal Register § 261.31 Hazardous wastes from non-specific sources. Available at: https://www.ecfr.gov/current/title-40/chapter-I/subchapter-I/part-261#261.31
27. Price, L.G. U.S. Dept. of Defense. Industrial Vegetation Management. 2(1) 15-17. 1970. Alb; A5b. Available at: https://www.osti.gov/biblio/6269398
28. U.S. Department of the Army Sacramento Corps of Engineers. Record of Decision Operable Unit 1 Fritzsche Army Airfield Fort Ord, CA from July 25, 1995. Available at: https://docs.fortordcleanup.com/ar_pdfs/AR-OU1-362//ou1-362.pdf
29. Nhung et al. A Review of Soil Contaminated with Dioxins and Biodegradation Technologies: Current Status and Future Prospects. Toxics 2022, 10(6), 278; https://doi.org/10.3390/toxics10060278
30. U.S. Environmental Protection Agency. RCRA Base Closure Plan for DRMO Storage Unit Tables. Available at: https://docs.fortordcleanup.com/ar_pdfs/AR-BW-0188//Tables.pdf
31. Akey and leaders Cancer and illnesses from Fort Ord, CA military base. Change.org petition. Fairness for the Families and Patriots Poisoned at Fort Ord, US Army Base. Started June 1, 2021. Available at: https://www.change.org/p/fairness-for-the-families-and-patriots-poisoned-at-fort-ord-us-army-base
32. Mendoza et al. Associated Press. What Lies Beneath: Vets worry polluted base made them ill. February 23, 2022. Available at: https://apnews.com/article/us-army-fort-ord-chemical-exposure-cancer-c1078dd520322f2a4130e2f7077b7892
33. Dearen et al. Associated Press. AP Investigation: Toxic Chemicals Lie Beneath Fort Ord. March 4, 2022 Available at: https://www.ap.org/news-highlights/best-of-the-week/2022/toxic-waste-lies-beneath-fort-ord/
34. Agency for Toxic Substances and Disease Registry (ATSDR). Public Health Assessment for Fort Ord, Marina, Monterey County, California July 15, 1996. Available at: https://www.documentcloud.org/documents/21177635-fort-ord-1996-public-health-assessment
35. Agency for Toxic Substances and Disease Registry (ATSDR). ATSDR to Re-Evaluate 1985-1994 Drinking Water Exposures at Fort Ord. February 2023. Available at: https://fortordcleanup.com/wp-content/uploads/2023/07/ATSDR-Ft-ord-intro-factsheet-02102023_cleared_formatted.pdf