James Roth
[Dr. James Roth was the twenty-second witness called by the defence.
He testified on Thursday, April 21, 1988.]
Dr. James Roth, the laboratory manager of Alpha Analytical Laboratories,
testified as to the results of tests done on the numbered samples removed
from Auschwitz and Birkenau by Fred A. Leuchter. Roth had obtained his
doctorate from Cornell University in analytical chemistry.
Roth testified that he received samples from Fred Leuchter in his capacity
as an Analytical Chemist at Alpha Analytical Laboratories. Roth directly
supervised the tests performed on the samples and the preparation of the
test report. The purpose of the tests was to determine total iron content
and total cyanide content in the samples. The identification numbers assigned
to the samples were those designated by Leuchter. (33-9274 to 9276)
Total Iron Content
Iron tests were conducted on three of the samples, namely, samples 9,
29 and 32. Results of the tests for total iron content were essentially
the same for all three samples. Sample 9 contained 7,580 mg/km; sample
29 contained 6,280 mg/km and sample 32 contained 6,170 mg/km. (33-9276,
9291, 9292)
Iron was normally present in brick and mortar and the quantities found
in the brick samples tested were fully within the acceptable ranges for
brick type. Red bricks were red because of the iron, although even white
bricks had these levels of iron present. (33-9306)
Total Cyanide Content
Cyanide was analyzed in a total of 32 samples of which 31 were brick
material and one was a gasket material. The minimum trace level for cyanide
was one milligram per kilogram of material. Tests results which did not
detect cyanide were designated on the report as "ND," meaning
"not detected." (33-9276 to 9278)
Roth testified that the test results indicated the following: sample
1 showed no detection; sample 2 showed no detection; sample 3 showed no
detection; sample 4 showed no detection; sample 5 showed no detection;
sample 5 duplicate test showed no detection; sample 6 showed no detection;
sample 7 showed no detection; sample 7 spike recovery test indicated 119
percent; sample 8 showed no detection; sample 8 duplicate showed 1.9 milligrams
per kilogram; sample 9 showed 6.7 milligrams per kilogram; sample 10 showed
no detection; sample 11 showed no detection; sample 12 showed no detection;
sample 13 showed no detection; sample 14 showed no detection; sample 15
showed 2.3 milligrams per kilogram; sample 16 showed 1.4 milligrams per
kilogram; sample 16 spike recovery test indicated 96 percent; sample 17
showed no detection; sample 18 showed no detection; sample 18 spike recovery
test indicated 100 percent; sample 19 showed no detection; sample 19 spike
recovery test indicated 120 percent; sample 20 showed no detection; sample
20 duplicate showed 1.4 milligrams per kilogram; sample 21 showed 4.4 milligrams
per kilogram; sample 22 showed 1.7 milligrams per kilogram; sample 23 showed
no detection; sample 24 showed no detection; sample 25 showed 3.8 milligrams
per kilogram; sample 25 duplicate showed 1.9 milligrams per kilogram; sample
26 showed 1.3 milligrams per kilogram; sample 26 spike recovery test indicated
140 percent; sample 27 showed 1.4 milligrams per kilogram; sample 28 showed
1.3 milligrams per kilogram; sample 29 showed 7.9 milligrams per kilogram;
sample 30 showed 1.1 milligrams per kilogram; sample 30 duplicate showed
no detection; sample 31 showed no detection; sample 32 showed 1,050 milligrams
per kilogram. (33-9278 to 9287) A bar graph of the sample results which
Roth had examined and determined to accurately represent the test results
was entered as Exhibit 154. (33-9288)
The tests were performed by taking a representative sample of the material
that was received by the laboratory, placing it in a flask that could be
sealed, adding a low concentration of acidic solution, specifically sulphuric
acid, then warming the sample in that solution while in the process passing
gas through it. Air passed through the solution and the acidic environment
volatilized the cyanide and formed hydrogen cyanide gas. This gas was then
passed through a solution of sodium hydroxide. Any hydrogen cyanide would
react with the sodium hydroxide to form sodium cyanide. After a period
of time required to assume complete removal of any cyanide in the sample,
the solution was analysed colour metrically for the presence of cyanide.
(33-9280)
This process was repeated with each of the samples, with duplicates
on certain selected samples and with spot samples in which known amounts
of cyanide were added to check recovery. Cyanide spike recovery tests performed
on several of the samples all indicated that the analyses and the techniques
and methods by which the samples were analyzed were valid. (33-9281 to
9287)
Prussian Blue (ferro-ferri-cyanide)
Roth was shown Exhibit 144, a colour photograph of the blue staining
on the wall of Delousing Facility No. 1 at Birkenau from which sample 32
had been removed. He indicated that the blue colour was what was commonly
referred to as "Prussian blue." (33-9289) The chemical definition
of Prussian blue was ferro-ferri-cyanide. (33-9297) Prussian blue was an
iron cyanide produced by a reaction between iron and the hydrogen cyanide.
It was a very stable compound which stayed around a long time. If hydrogen
cyanide came into contact with bricks or mortar containing iron, it was
fully conceivable that a reaction of the iron and hydrogen cyanide would
take place, leaving behind the Prussian blue. (33-9290) In porous materials
such as brick and mortar, the Prussian blue could go fairly deep as long
as the surface stayed open, but as the Prussian blue formed, it was possible
that it would seal the porous material and stop the penetration. If all
surface iron was converted to Prussian blue, the reaction would effectively
stop for lack of exposed iron. (33-9291)
Roth testified that the iron/cyanide reaction capabilities of samples
9 and 29 were no different from that of sample 32. If samples 9 and 29
had been exposed continually everyday for two years to 300 parts per million
of hydrogen cyanide, Roth testified that he would expect to see the formation
of the iron cyanide compounds; the so called "Prussian blue"
material, in detectable amounts. The reaction of the two substances was
an accumulative reaction; the reaction continued with each exposure. One
way for this reaction not to occur would be a lack of water. These reactions,
in many cases, required water or vapour in order to occur. However, in
rooms of normal temperatures and normal humidity, there would be plenty
of moisture present for this type of reaction to take place. (33-9293,
9294)
Prussian blue did not normally disappear unless it was physically removed.
To be removed from a porous material like a brick it would have to be removed
by sandblasting or grinding down the surface or by the application of a
strong acid such as high levels of sulphuric, nitric or hydrochloric acid.
It would be more difficult to remove from porous surfaces because of the
fact that the formation would have taken on depth. (33-9297, 9298) This
ended the examination-in-chief of Roth, and his cross-examination commenced.
Roth testified that he did not take the samples or have any control
over the sample taking. He agreed that cyanide radicals could exist in
forms other than Prussian blue and that the absence of Prussian blue did
not necessarily mean that cyanide radicals were absent. To Pearson's suggestion
that a good control sample would have been one where Prussian blue was
not present in order to determine if any cyanide radicals were present
there, Roth pointed out that there were many samples where no cyanide was
detected. (33-9301, 9302)
Roth testified that in order to have Prussian blue, iron must be present
and accessible to the cyanide. (33-9301) He agreed that the presence of
Prussian blue almost guaranteed that the ferri-cyanide complex was present.
(33-9302) How deep Prussian blue would penetrate was totally dependent
on many factors, such as the porosity of material and what moisture existed
in the area. (33-9303) Asked if a building was blown up with dynamite and
the surface blown off, the Prussian blue might thereby be removed, Roth
replied that if just the surface was removed and the rest of the material
was left, the answer would be yes. The Crown stated this was not what was
suggested; the suggestion was that in an explosion the surface of the brick
would come off. Roth replied that normally bricks would break up. "Now,
if that's removal of the surface, yes." (33-9304)
Roth refused to answer a question dealing with the amount of hydrogen
cyanide required to kill insects as opposed to human beings as he felt
this was not his area of expertise. (33-9304) He agreed that he would not
want to be around 300 parts per million of hydrogen cyanide. (33-9305)
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