Firing ranges are commonly contaminated with lead from munitions, nevertheless the authorities did not conduct comprehensive lead testing or soil remediation before moving migrants to the site in September 2020.

Evidence collected by migrants moved to the site also indicated that authorities have also failed to clear all unexploded mortar projectiles and live small arms ammunition, which could injure or kill if disturbed or handled.

“Putting thousands of migrant adults and children, along with aid workers, on top of a former firing range without taking the necessary steps to guarantee they would not be exposed to toxic lead is unconscionable,” said Belkis Wille, senior crisis and conflict researcher at Human Rights Watch. “The Greek authorities should promptly conduct a comprehensive site assessment of soil lead levels and release the results.”

In November and early December, Human Rights Watch interviewed four people living in the camp, two aid workers, one Greek migration ministry employee working in the camp, and four medical and environmental experts, and reviewed academic research on the risk of soil lead contamination at shooting ranges and medical research on the health risks of lead poisoning.

Human Rights Watch did not have access to conduct on-site research, but analyzed photos and videos of the site and satellite imagery to confirm the firing range location.

The Asylum and Migration Ministry began major construction work at the end of November at the site, called Mavrovouni camp, that could disturb any lead contaminated soil, further exposing residents and workers. The work to improve access to electricity and water and reduce the risk of flooding began despite warnings from Human Rights Watch of the potential of increased risk of lead poisoning.

In early September, large fires broke out inside the Moria camp, the Reception and Identification Center on Lesbos that was housing 12,767 migrants, mostly women and child migrants. Within days, authorities constructed Mavrovouni (also known as new Kara Tepe) as a temporary camp and told people that they would begin construction of a new permanent camp for use by June 2021.

According to the media, Migration and Asylum Minister Notis Mitarachi, has recently indicated the new camp will only be ready by Autumn 2021. Currently 7,517 people, mostly from Afghanistan and Syria, are staying at Mavrovouni, which started functioning as a military firing range in 1926 and was in use until the camp was constructed in September 2020, Mitarachi said.

In response to letters from Human Rights Watch, Migration and Asylum Minister Notis Mitarachi stated in a November 19 letter that the camp had “no lead contamination,” but provided no evidence for the basis of that assertion. He said the government has agreed to conduct soil testing with the European Commission within one month, but has not revealed the nature of the testing, the areas to be tested, or the methodology.

A Hellenic army representative called Human Rights Watch on December 1, stating his intention to respond to a letter received on November 4 from Human Rights Watch, raising urgent concerns. But no response has been received.

On December 6, General Secretary for Asylum Seekers’ Reception Manos Logothetis, called Human Rights Watch to dispute the risk of lead contamination at the camp. He confirmed that no soil testing for lead had taken place prior to moving people to the camp, but said that authorities are awaiting the results of soil testing conducted recently in collaboration with the Institute of Geology and Mineral Exploration (IGME).

“No one just shows up without a plan,” Dr. Gordon Binkhorst, vice president of global programs at Pure Earth, told Human Rights Watch. “Sharing of a well-founded work plan beforehand is key to transparency and ensuring confidence in the findings.” Greek authorities should allow independent experts to comment on investigative work plans, audit the soil testing process and collect split samples for independent testing.

“The authorities should share documentation of work completed and a comprehensive site investigation work plan based on a review of the site history, contaminants of concern, a conceptual site model of how such contaminants are released to and migrated in the environment, and a comprehensive testing plan that evaluates the degree and extent of contamination in the environment, and potential exposure routes,” Dr. Binkhorst said.

Firing ranges are well-recognized as sites with lead contamination because of bullets, shot, and casings that contain lead and end up in the ground. Lead in the soil from bullet residue can readily become airborne, especially under dry and windy conditions, which often exist on Lesbos. Lead is a heavy metal that is highly toxic to humans when ingested or inhaled, particularly by children and during pregnancy. It degrades very slowly, so sites can remain dangerous for decades.

The World Health Organization maintains that there is no known safe level of lead exposure. Elevated levels can impair the body’s neurological, biological, and cognitive functions, leading to learning barriers or disabilities; behavioral problems; impaired growth; anemia; brain, liver, kidney, nerve, and stomach damage; coma and convulsions; and even death. Lead also increases the risk of miscarriage and can be transmitted through both the placenta and breast milk.

Small children and women of reproductive age are at particular risk. According to Greek authorities, on November 19, 2,552 out of 7,517 people in the camp were children, 997 of them under age 5, and 1,668 were women – 118 of whom have said they are five or more months pregnant.

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An intact 60mm mortar projectile that a migrant living in Mavrovouni found after moving to the camp. The mortar can explode if moved.  © 2020 Private 

Camp residents shared 17 photographs of items they said they had found in the ground around their tents, including an intact 60mm mortar projectile and a tail fin assembly for another 60mm mortar projectile, cartridge casings for rifle bullets, fired 12-gauge shotgun cartridges, and live pistol, rifle, machine gun, and shotgun ammunition. Intact munitions, such as 60mm mortar projectiles and small arms ammunition, pose an immediate explosive hazard and should be removed urgently from the area.

“We try to stop our children from going to play up the hill because we know there might be bullets and other things the army didn’t clear that could be dangerous,” one camp resident said. Munitions containing lead can be extremely dangerous when swallowed by children or contaminate the soil, a medical expert told Human Rights Watch.

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Children playing in the gravel between the tents in Mavrovouni. Playing on the ground increases children’s likelihood of ingesting or inhaling lead in dust and dirt.  © 2020 Private 

The authorities should conduct a thorough and transparent assessment of lead levels in the soil and dust, as well as other possible pathways to exposure, and make the results publicly available. Any work that might increase exposure should be paused until after the soil has been tested or until people have been removed from the camp and housed in adequate facilities, Human Rights Watch said.

If lead is present in the soil, authorities should provide free blood testing and treatment for camp residents, aid workers, police, and others who might have been exposed, prioritizing young children and women of reproductive age, and immediately move exposed residents to a safe location and remediate the contaminated areas.

“The Greek government could be putting at risk families with young children, aid workers, and its own employees because it’s determined to hold asylum seekers on the island,” Wille said. “If this is where the government is trying to force asylum seekers to live on Lesbos, then all the more reason to transfer people to the mainland.”

Tents on a Firing Range

The Mavrovouni site sits on a large plot of military-owned land, some of which was used as a military firing range since 1926. The Asylum and Migration Ministry said that it covered the site with “new levels of soil” before the camp was opened.

Human Rights Watch reviewed satellite imagery from before and after construction began on the camp on September 11, 2020. Imagery from before shows a firing range on part of the site next to Mavrovouni Hill. By September 28, more than 200 tents had been set up directly on the former firing range itself, with more tents on adjacent areas.

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Satellite imagery recorded on September 28, 2020 shows at least 200 tents on the former firing range. Satellite imagery  © 2020 Maxar Technologies. Source: Google Earth. 

Satellite imagery from June, before Moria camp was destroyed by fire, shows some basic clearance of vegetation cover within a rectangular strip that included the firing range, as well as a small section at the base of Mavrovouni Hill. From the imagery, it is impossible to determine the depth of the soil removal and whether the remediation of lead impacted soil was completed in accordance with prevailing standards and guidelines, or if it was just a superficial scraping of topsoil.

Human Rights Watch was unable to determine what soil removal activities took place between June and September, when the camp opened, or of other activities to decontaminate the ground or where soil removed was disposed of. Given the speed of camp construction, it is very unlikely that authorities could have carried out remediation of lead-impacted soil before setting up the tents. Greek authorities have indicated that new soil was placed prior to construction of the camp, with no location indicated.

Satellite imagery analysis, combined with a review of photos and videos of the firing range that were posted online in the spring, shows that the military was shooting from the southwest toward targets in the northeast, at the foot of Mavrovouni Hill. This suggests that soil on the hillside might also be contaminated by lead.

Imagery recorded between September 14 and 16, shows at least 300 tents just south of the hill without any prior signs of soil clearance, with another at least 170 added in the following days. Imagery from late November shows further ground preparation southeast of the hill, and the construction of four large structures.

Medical and environmental experts interviewed said it was risky to conduct further work in the camp without first conducting soil samples. “Disturbing this area will mobilize the lead in the soil and make it more vulnerable to dispersion from periodic rainfall, flooding, and wind erosion,” said Jack Caravanos, professor of global environmental health at New York University. Dr. Caravanos has visited and assessed dozens of lead-contaminated sites throughout the world and expressed dismay over how this site was chosen without proper environmental investigation.

A European Commission official who is involved in migration policy with Greece said that the Greek Defense Ministry claimed that “no pieces of lead were observed on the ground” during construction or other work. Because lead dust is usually not visible, this claim raises concerns about the seriousness of the Greek government’s assessment.

A source close to the police said that the government had considered turning the firing range into a camp site as early as 2015. At the time, authorities rejected the proposal for several reasons, the source said, including because it had been a firing range. It is unclear why the government ignored these concerns in 2020. A migration ministry employee working on the camp who spoke on the condition of anonymity said that in September, before Mavrovouni was selected, the government met with a few larger nongovernmental organizations, and discussed at least two or three alternative locations.