RESOLVE

Action Agenda

The Leadership Council is now finalizing the Action Agenda using comments received during the December 21, 2010 to January 21, 2011 public comment period. While comments are no longer being accepted, both the Draft Action Agenda and the public comments submitted remain available on this website. The final Action Agenda will also be available on this website when it is completed in the spring of 2011.

Next Steps

RESOLVE has submitted the comments received to National Conversation Leadership Council to consider in finalizing the Action Agenda during the spring of 2011. While the Leadership Council will consider comments, they will not respond to comments received. The final Action Agenda will be available on this website. The National Conversation Leadership Council will draw on the results of public input received through the web dialogue and public comments received through this website in finalizing the Action Agenda. Work group reports will be appended to the action agenda.

Note

This report was developed as part of the National Conversation on Public Health and Chemical Exposures. This is a voluntary, independent process involving multiple sectors, which was facilitated by RESOLVE, a neutral non-profit consensus building organization. This DRAFT report is a staff version, prepared from deliberations of the Leadership Council for the purpose of gaining additional public comment. This draft does not reflect a consensus of the Leadership Council. [to be added when consensus is reached: Consensus is defined as each member being able to “live with” the report taken as a whole, rather than as agreement with each recommendation.] Members of the Leadership Council were asked to participate as individuals, rather than on behalf of their organizations or constituencies. Recommendations for action are directed to a wide range of public and private actors, who have full latitude to consider them through the appropriate decision making procedures for implementing changes within their organization. While federal participants were involved with their agencies’ knowledge and provided important insights into the role of the federal government in addressing chemical exposures, their membership on the Leadership Council or work group does not constitute agency endorsement of the recommendations. The Centers for Disease Control and Prevention’s National Center for Environmental Health and the Agency for Toxic Substances and Disease Registry provided funding for the facilitation, member travel, meetings, Web dialogues, community conversations, and other costs associated with the National Conversation. This report does not necessarily reflect the views of the Centers for Disease Control and Prevention, the Agency for Toxic Substances and Disease Registry, RESOLVE, or other organizations involved in the National Conversation.

Please visit the National Conversation on Public Health and Chemical Exposures website for more information on the project.

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66 Comments

  1. Lara Dimick-Santos

    FDA

    Do you intend to include antibiotic contamination and development of resistant bacteria in the coverage of this National Conversion? It is not clear to me from reading this document. I do think it should be included. Should this be more clearly stated?

    http://www.ama-assn.org/ama/pub/news/news/antibiotic-resistance-public-health.shtml

  2. Hazel Ito

    Firstly, I am grateful for the opportunity to participate in commenting on the agenda and in this National Conversation, which is a great initiative – thank you. The following comments are my personal views and are intended most respectfully.

    I was excited to see that the very first day of the agenda is a focus on prevention, however I am curious to know what the defined sources of the problems actually are, according to the authors/panelists. I see the discussions will then be based around policy reform, innovation and science-based decision making. This is all well and good, however I think we need to step back and include a bigger picture of the systems that are behind the problems.

    In my mind, the source of the “problems” is (aside from an overall philosophy of using everyone on the planet to our advantage, whatever the repercussions) largely our agricultural and food production system. Monoculture crops, factory farms, hormone-treated poultry and livestock, GMOs….these are starting to become household terms.

    To many enlightened “consumers”, and I hate referring to myself as one, but that is primarily where my ounce of power lies, these approaches to our food production system are seriously flawed, and leading to numerous problems, with increased use of pesticides being just a part of the picture. If we really want to go to the source of the problem that is where we should begin.

    How can it be that government groups, such as the EPA, USDA and FDA, appear to be accountable to noone but large corporations and the few top dogs in government? I am sure there must be many excellent and well-intentioned people working in these departments, but from a consumer point of view, there seems to be no real voice. For example, when the community expresses concern about the use of Genetically Modified Organisms, instead of paying attention, these departments have allowed through ways to dupe consumers (such as no labels for GMO-foods) or lead them to feel it is simply too hopeless and overwhelming to even think about.

    I am not against technology, or progress, but I do want to be sure that what my family and I are exposed to, what all people are exposed to, is SAFE. Our food production system has dismally failed to apply the “precautionary principle” via the 3 aforementioned government departments. Even recently, methyl iodide was approved by the Department of Pesticide Regulation for use on the strawberry farms of California, despite the fact this chemical is a potent carcinogen, neurotoxin and thyroid toxicant. Why on earth are we adding to the cocktail of chemicals already pervading our environment?

    If prevention is a goal of this National Conversation, then we need to look at how we transition from the broken, existing food production system, of adding more chemicals, hormones and GMOs to try and combat natures responses (insect plagues, superweeds etc) and work WITH nature, and see farming methods to replace the existing ones (permaculture, agroecology). They are out there, and they work beautifully. However they are not suited to a factory, monoculture mentality, so this old way needs to be transitioned to something sustainable. This, to me, is the best way to prevent further exposure to chemicals and improve public health.

  3. Emily Koumans

    It is very scary to be a mom and realize that none of the chemicals in the USA, present in a huge variety of products that infants and children are exposed to, is subject to any testing for safety, carcenogenicity, etc whatsoever. Never mind adults!!!! Chemical exposures to the skin, mucous membranes, and ingestion are frequent for infants and children during their critical growth periods.

    I would suggest that proactively, all new chemicals, even “minor modifications” of existing chemicals, be subject to at least safety testing in mammals. Older chemicals could be added gradually, and not totally “grandfathered” in. Chemicals that are released into the atmosphere or water or are present in any product that humans come into contact with should be included. All chemicals should be presumed UNSAFE, rather than what is the case now, that they are all considered safe until there is proof that there is some problem.

    I appreciate the opportunity to comment.

  4. Michael Bailey

    People First, California, Orange County Chapter

    These are my comments on the Action Agenda Draft Report of December 20, 2010.

    I very strongly agree with and support Recommendationm No. 1.1 for the phasing out and replacement of hazardous chemicals and processes. This must happen as soon as is possible. The health impacts to chemical exposure in terms of athsma, cancers, respiratory problems, developmental and other disabilities, and birth defects are simply too great and growing. Cancers and Austistic disorders are at all time highs and growing. And there are probably one or more links connecting chemical exposure from herbicides and insecticides to diesel fuel to the epidemic of certain health problems like the Autistic Disorders and cancers. As soon as possible, there should be a new synthesis that will provide alternatives with little or no health impacts on humans and little or no hArmful impacts on the environment.

    Recommendation 1.2 is also very much needed. Legislation at federal and also a state levels is necessary to have manufacturers of chemicals provide to the federal and state governments detailed information on what is in the chemicals being produced and what is the impact/potential impact on persons and the environment, and since workers in the chemical industry are the first to be exposed to chemicals and processes what is the impact on chemical plant workers and what is being done to protect them?

    Recommendation 1.3 I also strongly support–providing increased public health protections to vulnerable populations, like seniors, infants and children, pregnant women, persons with disabilities, and people in low income areas that are most likely to be impacted by polluted air, water, and soil.

    It is also important to implement Recommendation 1.9 for a coordinated public health emphasis and infrastructure on chemical exposures throughout the agencies of the federal government that deal with this issue. I think this should also include CMS–the agency that administers and manages MediCaid/MediCare and the Veterans Administration. I also think that a similar approach is needed at the state level and the local level (cities, counties, and special districts) and at the Tribal Government level. There should also be consultation between dand among the different levels of government.

    Effective biomonitoring is also something that is critical and in need of improvement. All medical conditions with environmental links from chemical exposure need to be reportable conditions. And it is important to see what is going on with certain more impacted populations in terms of chemical exposure dand to include people from these populations in chemical exposure studies. Such populations include people with developmental and other disabilities, pregnant women, lower income farm workers, seniors, and people in low income communities that are more likely to be exposed from chemical plants and industrial operations, diesal exposure from freeways and railroad yards and ports, and polluted air, water, and soil. For example, it turns out that Chromium 6 is a cancer causing compound that is found in drinking water and is yet unregulated by federal or state governments. California has some proposed regulations that have not kicked in yet and will be the first state in the country to regulate Chromium 6 in drinking water. Riverside, California, which is a poorer area of the state, has among the highest levels of Chromium 6 tested. While in the San Joaquin Valley, Nitrate contamination has impacted the drinking water and ground water supplies there. In other parts of the state like Los Angeles, Oakland, and Bakersfield, people are adversly impacted by chemical plants,train yards, ports, and freeways and the ensuing diesel particulates and chemical releases. In rural areas, exposure from herbicides, insecticides, and chemical fertalizers is a problem contaminating water, soil, and air. Human studies should also look at families as well as individuals since a pregnant mother may have been living in an agricultural area, or a low income area near industries or trasportation centers and been exposed to chemicals that resulted in a baby born with disabilities and the child of that mother is having greater health problems because of living in a low income or rural area and being exposed to chemicals being released to air and drinking water.

    Recommendation 2.2 is badly needed. Colleges and universities are key in the chemical exposure testing. They have the facilities, equipment, and scientists necessary to do the testing in an objective and detailed way. Once the type of chemical exposure and extent of exposure are identified then universites are critical in developing programs to lessen the impact of exposure on people. So it is clear that colleges and universities have a critical role to play in finding solutions to chemical exposure.

    Recommendation 2.3 is also needed. Major improvements are needed in the reporting process for chemical volumes produced and disposed of, source, useage, and discharge information. The reporting requirement should be more comprehensive and detailed than it is now. It is important to provide this information to agencies that must plan for potential and respond to actual chemical emergencies lke fire departments and county and regional hospital associations.

    Recommendations 2.4 and 2.5 are also necessary. Public health and occupational health tracking as relating to chemical exposure is too limited now. It needs to be expanded, be made more comprehensive, and standardized tracking tools created that would be fully effective up-down-across organizational lines in each agency as well as between and among agencies at federal, state, local, and tribal levels.

    Recommendation 2.7 for developing and using better more effective diagnostic tools and creating better biomarkers is also a necessary step in contolling chemical exposures. These new tools then need to be shared with state, local, and tribal governments.

    Very important is Recommenation 3.3 developing standardized protocals and tools to characterize and identify human exposures to chemicals across product life stages and supply chains and across human life stages. This is a critical health and safety issue that needs addressing as soon as possible.

    Recommendation 3.5 is an important one. There are some gaps here that need to be filled. What is it that makes some people in certain groups more suseptible to medical problems from chemical exposures than others? The disabled, the very young and the elderly are three groups that need special attention paid. It is also of great importance to treat pregnant women as a group and pay special attention to the impacts of chemical exposures on them and their fetisus.

    Recommendation 3.6 I think is also of critical importance especially to the disabled community and the senior community. These are two groups most likely needing to take various prescription and/or over-the counter medications for their illnesses/disabilities and how chemical exposures may interact with the chemicals in the medications that disabled people and seniors need to take and what the impacts on mind and body might be need attention. But this is an area that has not been looked into very much or very well and so there are many gaps that need filling as soon as possible. For other populations as well as seniors and disabled persons, it is also important to look at the interactions of chemical exposures combined with the chemicals generated and taken into the bdy from tobacco products use, alcohol use, and use of illegal drugs.

    Recommendation 3.7 is needed to look at the impacts of indoor chemical pollution especially since most peoples lives are spent inside at home, in the office, in the car or transit. Mold, lead in paint in buildings, on toys, on pottery arev all types of chemical exposures as well as chemicals from second hand tobacco smoke, and fumes from detergents, cleaners, insecticides , and paints/solvants used inside the house or business. All have negative impacts on health that could be short and/or long range impacts.

    Recommendation 3.8 is necessary to improve Public Health Assessments, Cluster investigations and chemical exposure investigations and place a punlic health focus on them that will allow for more effective investigations that will better address the needs of communihty toxic hazards exposures.

    I strongly support Recommendation 4.1 to take immediate action to protect vulnerable populations from chemical exposures. These populations include pregnant women, the disabled, seniors, children, and persons living in low income areas most likely to be exposed. People in these groups need information necessary to allow them to take action to protect themselves from exposure. The information must be available in different languages and in various formats, like Large Print, Braille, Simple language and pictures to explain complex ideas; and websites need to be card reader accessible. For the developmentally disabled community, consideration should be given to doing peer to peer or advocate to advocate training and education through self-advocacy organizations like People First, California and its local chapters. Every state and territory has a People First state office and local chapters.

    Recommendation 4.4 is also important for its emphasis on identiying and defining vulnerability characteristics of communities in structure, function, and susceptibility to chemical exposures. This is another area that needs a lot more attention being paid to it.

    Recommendation 5.5 is a “must” The public has the right to know the information on chemicals produced, used and discharged and disposed of near where they live. People eed to know if their drinking water is polluted and what steps are being taken to clean up the water and air and what is being done to make abandoned brown fields contaminated by chemicals in the soil into usable, valuable realestate again. Peple who participate in studies also should have access to the data on them including reports on what the data mean and what the people can do with it to improve their health.

    Recommendation 6.1 is another of critical importance. Medical school education, continuing education and medical specialty education all need to include in them environmental health, including chemical exposure treatment. This is important for the medical communihty at every level. It is also something important for nurses as well regardless of whether they are school nurses or hospital nurses.

    Recommendation 7.5 is also of critical importance. The education and training of emergency responders must be as effective, efficient, accurate, and up to date as possible and there needs to be provision made for continuing education in this area. It is critical to the health and safety of all fire fighters and police officers responding to chemical emergencies that they know how to respond effectively and be able to protect themselves. Not every fire department is able to afford specialized and equipped HAZMAT units. Those that have HAZMAT units may have regular fire fighters responding first before the special units get there, so good training and education in dealing with chemical emergencies is an absolute must.

    Recommendation 7.7 is also needed for grant funding in dealing with chemical response and testing. It is especially important that funding for planning and testing emphasize that people from impacted communihties be directly involved in the planning and testing processes, including members of the disabled community.

    I think environmental literacy is not very high and education on environmental issues can’t wait until something comes up. Environmental literacy needs to begin in elementary school and continue through life. It also needs to be an inclusive process, not an exclusive one because many of the people who need to be most environmentally aware are those that live in areas without good public education systems and/or they are special education students in special ed programs. In the developmentally disabled community, people seem to respond best to advocate to advocate learning and education. This process of advocate to advocate education could also be done through client self advocacy organizations working with school special education programs to get the word out to special education students.

    Another thing I like is creating Ombudsmen to help make sure access and accountability to information is obtained, abuses eliminated or greatly reduced, and greater public participation and input in the decision making processes ensured.

    Thank you, Michael E. Bailey, People First, California, Orange County Chapter.

  5. Maryanne Vigneaux

    I read the community summary report for LAWRENCE AND NASSAU COUNTY, NEW YORK. I wonder why SUFFOLK COUNTY was not included. There are waste sites in Suffolk county that are within the high cancer incident area comprising Stony Brook, Port Jefferson, Port Jefferson Station, Mt. Sinai and Coram (currently where i live).

    The EPA was / continues to be involved in the decontamination of soil and water caused by the company, Lawrence Aviation in Port Jefferson. I was in contact with Sal Badelimenti (sp) of the EPA after being informed by a librarian who is involved with government documents. The library at Stony Brook University is a depository.

    My interest in chemical waste is the result of having two incidents of breast cancer and knowledge of the cancers of four of my former neighbors who have died from lung, brain and pancreatic cancers. All of us lived on the boundary of Lawrence Aviation from the 1970′s – 1990′s.

    There is so much information that it is essential to go to primary sources. Yet I do believe that many in the public domain read non-critically. We need to make sure that as a result of this conversation that the report is in The Washington Post, The New York Times and other credible sources and reported on media as CNN.

  6. Michel H Nazaire M.D

    IUTLD,PSR ACCP

    Industrial chemicals and toxic sustances are managed in the US by a complex network of governmental agencies..(EPA,FDA…)These chemicals are regulated in commerce,in consumer,in cosmetics products,pesticides.Ther is concerns that this complex system is not adequately health protective:instead of requiring industry or other proponents of specific chemicals,to prove their safety,the public bears the burden of proving that a given environmental exposure is harmful .Advances in pharmacology and medicine(clinical research) have transformed our understanding to a changing world taking on new responsibility,promoting and providing the health of the public:the overwhelming number of chemicals used in manufactures with the potential for environmental contamination and human exposure has driven the direction to toxicity testing.Standardized assessments were developed and incorporated into the premarket review became standard practice accross the pharmaceutical industry requirng evidence of effectiveness based on adequate and well controlled studies…

    The European Union(Reach 2006-2007):Registration,Evaluation,Authorization,and Restriction of chemicals calls for community policy to be based on precautionnary principle;The president’s cancer Panel:Reducing environmental cancer risk..What we can do more,calls for a shift away from our current risk management approach toward one based on the precautionnary principle.These new requirements (providing data and proof of safe use) are expected to improve knowledge and promote the development and use of safer chemicals substances,closing the technology gap by investing in green chemistry science and education..Decion makers have the duty to take preventive action to avoid harm before scientific certainty has been established..For the first time since 1976,there is current legislation in both the House and the Senate:the Safe chemicals Act o 2010 and the Toxic chemicals safety Act 2010 to givethe EPA authority to regulate the use of hazardous chemicals,ensure safer replacement chemicals and require manufacturers to submit informations concerning the safety of chemicals in advance of their entering the market…

    “There is a growing recognition that the cornerstone of our approach to scientific uncertainty must rely on the fundamental principle of Primary Prevention”

  7. Anne Pollock

    I am very pleased to see emphasis placed on reduction at the source by use of safer alternatives. But even more importantly I am very enthused by the emphasis on risk assessments that evaluate chemical exposure risks under conditions of use. What I did not see emphasized is Education targeted at end users, without this emphasis I suggest the desired outcome will be minimal.

  8. Ernest Grolimund

    CAWB, RAWSEP, victims groups, thousands

    On Monitoring: Modeling better as identified by ATSDR. More cost effective. Preventive. Stops toxic pollution from wood smoke for example before it gets in environment and harms health. For wood smoke engulfing cities and country, use advanced portable monitoring used and proven on west coast and in New York combined with regional modeling to fill in gaps of ambiant pm monitring system and avoid fraud by states manipulating numbers to save transportation funding. Pm values lowered by choice of pm monitor locations. Ie on top of mountains , on east shore of lakes, bays, in country instead of in city, et cetera. Check by weighted average of pm conc from equipment combined with census data. In NY large regions estimated to be violating ambiant pm stds. Approx 45 mcg/m3 estimated as an average, 24 hr ambiant pm without wood smoke plus wood smoke pm. Pm doubling in design conditions. Good work isshowing problems that can be solved to protect life and health and save a lot of money. Payback: 30 times cost of monitoring or more!!! Save $150 billion/year in USA plus similar global warming savings. 90% of people dislike smoke in living environments per Maine poll so 90% would approve and like. Restore USA as world leader on pollution, warming. Safe, better alternatives exist so must be used per case law, constitutional law.

    Use human senses of sight and smell as monitors following CDC guide. “If you see or smell wood smoke there is a problem”!!!! Cheap. All people can be used as monitors. Check if neccesary. But do not ignore. Do not dismiss. Do not require $50,000 monitors that are not available. This stops enforcement. Allows pollution. Right now, wood smoke toxics are the largest source of toxics and they get in food and water systems as well as lungs. EPA and ATSDR refusing to do monitoring for cost reasons. People can’t do monitoring for cost reasons. So model large classes of wood burning equipment. If worst case design pm violates ambiant pm stds or new wildfire smoke guidelines, ban by class. IE old stoves, outdoor wood boilers, indoor wood boilers, old fireplaces, for starters. Check NSPS std for meeting pm stds and wildfire smoke guidelines. Make guidelines into stds that have to be enforced so states cannot refuse to enforce. Have Surgeon General make statement like tobacco smoke statement. “There is no safe level of tobacco smoke”. EPA says wood smoke is 12 times as carcinogenic and 4-8 times more toxic for heat attacks and astham attacks. So have Surgeon General say: ‘ Most woodburning equipment creates smoke that is not safe at any level like tobacco smoke, so no visible smoke or detectable smell can be allowed’. Republican libertarian tendencies must be overcome in this case because life and health are threatened as well as safety and welfare. Wood smoke cause moves, decreased tax revenues , increased taxes , cost to communities from health problems, $8,000/burner/year acc to Austr Health Authorities.

    Precedant exists for large sources. Small sources now creating more pm regionally. Egregius, gross, notorius, obvious pollution by eyes and noses and modeling and monitoring and advanced monitoring, satelite monitoring, etc. Precedant exists to have President state carbon black soot from pm causes warming like CO2 and it is a threat to life, health, safety, welfare, like CO2.

    Stop talking! Start doing! Get emergency action by President. Show pictures of Denver, Salt Lake City, Shelbourne Falls-MA, Oakland-ME engulfed in woodsmoke. Show NYSERDA regional modeling of woodsmoke combined with ambiant pm showing large regional impact.

    Call me. Let me help for free. see http://www.coalitionagainstwoodburning.com . http://www.RAWSEP.org . http://www.burningissues.org . Involve victims , not just stakeholders. There are a hundred million or so victims not being ehlped or represented as only business is allowed to come to the table. For example, I was not invited. EDF, ALA not fully representing us. They have been reported compromised by business contributions like government politicians. When called on, peole likke me can and will volunteer with genius engineering talent like me or genius doctos advice in RAWSEP or genius legal briefs from Burning Issues. We have been at the forefront for breakthrugh modeling, monitoring, and networking with national and international scientists. What we lack in phd’s, we make for in imagination, drive and caring for the environment. Right now, government is ignoring the victims and the negligance is causing a disaster with cities engulfed in wood smoke.

    Wood smoke is the mother lode for toxics, more than any other source. Mercury, dioxin, heavy metals pm soot, 180 or more toxics the Ag for Toxic Substances has to adress and control. ATSDR must monitor and check work by EPA and Congress. When politicians make scientific and legal mistakes governent must step in and stop it. The blind obedience of crazy orders from Congress has to stop. If not you, then who? Stop passing buck and saying itis not the ATSDR responsibility or CPSC responsibility. It is a mutaul responsibility and checking is the hallmark of good science and management.

    All the victims I have contacted (Thousands) say this National Conversatipon is a great idea. But you really have to listen and not go through the motions. We appreciate the ATSDR commitment to study wood smoke more with the EPA. We appreciate the recognition of modeling of all kinds and its reccommended increased use. But there has been an emergency going on for about 3-4 years affecting 30% of the population. Fast emergency action is needed over slow deliberate scientific investigations. Thank you for listening and allowing me to try to help God and Country.

    Please respond. Tell me what you are going to do. Ask questions, et cetera.

  9. Claire L. Barnett

    Healthy Schools Network, Inc.

    From a children’s environmental health perspective, this is a much improved report — thank you. It has great potential to drive public health prevention efforts.

    However, the document still does not go far enough in identifying children’s unique vulnerabilities, placements, and exposures, and preventive public health programs designed to address their unique situations.

    Children in child care or in K-12 schools are still developing; they cannot identify or articulate exposures or health effects, nor can they remove themselves from harm’s way. While child care center and K-12 school personnel can and do avail themselves of NIOSH, OSHA, labor grants and occupational health services (COSH groups) to provide some measure of health protection, families of children who have the same or similar exposures have no such access, even though children outnumber personnel and may have the same or similar exposures. Examples:

    See attached for complete comment.

    Attachments:
    File: CDC_Conversation_comments-HSN_Jan2011.pdf

  10. Kenneth Daniels

    New York City Department of Education

    I thank you for this forum and the oportunity to identify a major deficiency in our scientific awareness in our High Schools in New York City and … elsewhere

    I teach High School Chemistry for the New York City Department of Educatiion. Over the last decade, I observe an accelerating trend in the reduction of schools offering Chemistry to students. The concept of Chemistry being a difficult subject and not essential for high school graduation encourages students to avoid it, even in the shools that still provide the service.

    I also wonder how aware are we of the national decline of science skills in high school and college students.

    Without the knowledge and a consuming zeal in our student body about chemiistry and environmental challenges in our community, our effectiveness will be severely restricted.

    Dr. Kenneth I. Daniels, Chemistry Teacher, NYC

  11. HASSAN ABDULHUSSEIN

    MINISTRY OF HEALTH

    IN THE DEVELOPING COUNTRY ,BECAUSE OF THE LOW STANDARD OF HYGIENE, LOW STANDARD OF THE BASIC INFRASTRUCTURE ,THE ENVIRONMENTAL EPOSURE TO DIFFERENT TYPES OF ENVIRONMENTAL POLLUTANTS , MOSTLY ,TOSE DUE TO BURNING THE PLASTIC MATERIALS,USING THE ELECTRICITY GENERATRORS FOR PERSONAL USES, THIS TOPIC IS VERY IMPORTANT TO BE DISCUSSED SPECIALLY WHEN WE THINK ABOUT CO2 PRODUCTION THE EFFECT ON CLIMATE

  12. Daniela Kunz

    To Whom This May Concern January 6th, 2011

    It has been my mission to keep especially children safe from chemical toxins in food, water and products of all sorts, especially so also in the school setting. I have come to witness personally on what has been going on in the school of my youngest son for the past 2 years and vaguely also got to know on what happens in the school of my 15 year High School son, to some degree.

    Last incident, which happened also about a year ago in the schools was, that Central Office of our School District sent out Maintenance Workers to the schools to paint hallways, doorframes and the likes, all while classes were in full session, exposing by that all the children for the whole school day for many days in a row. I have stepped up and voiced my grave concern in this all, especially so because my youngest son has severe chemical allergies and it all posed a serious risk to his health, not to mention on what else paint fumes DO not only in children, but also in adults. Back then when the first incident happened in the school of my youngest son, I did have a meeting with the principal and also alerted the Superintendent of Schools on it all and requested that these kind of doing will not happen anymore and postponed to when classes were not in session.

    Just yesterday I had to sign out yet again my youngest son from school, as some maintenance workers initiated painting the hallways, now, after Christmas break, and with classes in full swing! I was appalled to say the least that yet again these kind of things were happening! I took action immediately and talked to the principal, who should have been the one responsible to stop these doings in their tracks and postpone them to when children were not in the building for a number of days. My intervention must have conveyed the message for the school of my youngest son at least, then the principal did go ahead and rescheduled the works for the summer, when children would not be around to be exposed to such hazards. I am still awaiting a response from the Superintendent and his assistant on this all.

    I also want to make sure that the practice of having school children handle chemicals to clean the tables after their lunch periods will be not applied anymore, but that the students will merely continue to swipe the floors and maybe wipe the tables with rags that have been dampened only with plain water instead. On every chemicals containing bottle it says: “Keep out of reach of children”, so why in the world those very same chemicals, of which ingredients are not being even regulated nor are they safe in any manner, are given into the hands of chilren, who then spray them not only onto the table, but also into the faces of other peers or onto the food of adjacent students’ food (witnessed all of the above for the past 2 years and intervened on numerous occasions!!!), I do NOT think that this practice is safe either!

    Further, a great concern has been the latest news on the products containing Triclosan. From disinfecting handsoaps, to hand sanitizers, toiletries and such, and more chemicals that are hidden under the seemingly innocuous word “Fragrance” alone, under which 600 non regulated hazardous chemicals can be disguised as “safe”, I request that all schools switch their soap containers or hand sanitizers to safe alternatives that are proven to be safe. I have found only 2 such products that actually do measure up to safety standards. You may check out toxicity grade of prducts under following website: http://www.cosmeticsdatabase.com It is important to know also, that products that have the very eye catching claim “Green Cleaning”, “Natural”, “Organic”, does not mean at all that those products are safe – since even in those, and despite they are being sold in Health Food Stores, still contain a myriad of highly toxic substances. It is crucial to do the research and to thoroughly inform institutions where children are spending their days, on what alternatives they have to make sure to not keep around children and what to use instead.

    I demand that there be given out a very concise guideline for schools or facilities alike in particular, because children have not the direct parental protection available there and then and are merely at the mercy of other grown ups, and their actions or the lack of them, and that in these specific guidelines it will be made very clear that putting first the health and safety of all the children is of utmost importance and that they will be held accountable should they not adhere to the new safety standards. A safe list of products must be given out too, as to make it possible for such institutions to be equipped with the needed knowledge and solution. Facilities must be checked out periodically as to make sure that guidelines are being followed.

    Also, last but not least, chemical substances in foods that are being served onto lunchtrays in the form of “Junk Food in disguise” or the unhealthy sweet treats that are loaded with chemicals too and brought in by some parents themselves for parties at schools or such facilities must go too. While you might think that food has nothing to do with chemicals – unfortunately food if not Organic and Processed they are loaded with a myriad of very hazardous substances. There is mounting evidence and correlation to health issues in people, especially so the most vulnerable ones, our children. Processed food is loaded with haphazard chemical substances and they put unsuspecting children at risk, which has been well researched and documented through medical scientists and other professionals as such. I do agree that parents have the responsibility to do their part, and unfortunately all too many are not aware on the dangers or do not care, but I do NOT accept it that schools will continue to look on and not do what is doable to ensure the safety of the student body or children who are placed in the care of people/facilities. If we do not define a plan to follow, nobody else will. I am not willing to look on how others neglect their responsibility and by this endanger our children through it all, knowingly nonetheless in most of the cases.

    I am just a mom who is highly proactive in providing a safe environment to her children at home and have gone above and beyond as to ensure that also out of the home my children are as safe as possible. By going to the school of my youngest son each and every day, to bring him his homecooked all organic food and to monitor that no chemicals will be sprayed onto him in the lunchroom when other students are cleaning up the tables, I had the privilege to get to witness to what all the other children are being exposed to. It is time – Overdue. It is time to bring about tangible and positive changes, for the safety of our children and our environment!

    Thank you for giving me the opportunity to bring forth all this. I hope it will help to make an impact and that it will prompt you to take action and follow with guidelines to be enforced in all schools or institutions as such, be those private or public, all accross America.

    Sincerely,

    Daniela Kunz

  13. Nancy Swan

    Children's Environmental Protection Alliance

    After reading the draft of recommendations for public comment, I fear failure to use “develop an agenda with clear, achievable, recommendations for action that will provide a plan for oversight and effective enforcement . . .” will doom these recommendations to failure.

    “. . .vision is that chemicals are used and managed in ways that are safe and healthy for all people. The project’s goal is to develop an action agenda with clear, achievable recommendations that can help government agencies and other organizations strengthen their efforts to protect the public from harmful chemical exposures.” The problem we have now is that industry volunteers information for chemical monitoring. That is like having criminals volunteer that they have been breaking the law. Our chemical industry needs to be policed. An individual who harms a child with chemicals he knows is harmful can be charged with criminal misconduct. An industry that sells or applies pesticides where children are present (schools), knowingly exposing and harming them, can only be held civilly accountable.

    To validate the application of these recommendations, I suggest discussion about how the The Draft Action Agenda would have protected me and the school children at Long Beach Middle School, Long Beach Mississippi. http://www.mssc.state.ms.us/Images/Opinions/Conv1034.pdf

    I was seriously and permanently injured by toxic chemicals (including isocyanate, benzene, toluene) from a foam roof application to the school where I was teaching in 1985. http://www.nancyswan.com/toxic-justice-a-true-story Although workers are required protective clothing and hazard information, bystanders are not. This type of roofing continues to be highly marketed to schools as inexpensive and “green” alternative. allgreenandlean.com/roof_casestudies.html greenteamroofing.com/foam.html

    For at least two weeks prior to the roofing application at my school, the chemicals had been stored in tankers and chemical barrels in trucks on school property, less than twenty feet from the cafeteria. The applicator lied that the tankers contained only water and that the chemicals being applied were non toxic. School officials ignored complaints of injury to the point that the children were ridiculed and refused permission to call their parents. Over a thousand middle school children and teachers were exposed for three days, all windows were open because the weather was hot and humid, and we had no air conditioning.

    To this day, the community and the exposed were never told the name of the chemicals. No local, state, nor government agency had authorization to investigate. No one was held accountable to the communty, nor the injured. Please read story on Toxic Justice, Chapter 1 http://www.nancyswan.com/toxic-justice-a-true-story/chapter-1

  14. Nancy Swan

    Children's Environmental Protection Alliance

    I posted the comment below as a National Conversation webdialogue participant on 1/6/11 6:32 PM, Respond Effectively to Chemical Exposures. I failed to include the weblink to the thousands of news articles about chemical exposures at school during the last year which I have posted on my website. http://www.nancyswan.com/interests/healthy-schools-healthy-children/news. Please add this to my comment.

    In addition, previous commitments prevented me from posting an additional comment under “New Ideas.” The Action Agenda can have a greater impact on government officials, politians, and the public by using compelling stories told by those who have experienced the failures of our government to protect the public from chemical exposure and injury. I told relevant parts of my story of being toxically injured while teaching at the three Community Conversations I hosted in Mobile Alabama. Story and Chapter 1 of my soon to be published book Toxic Justice is posted on my website http://www.nancyswan.com/toxic-justice-a-true-story

    I am a trained public speaker and know that a story is the best way to capture attention and to incite discussion and inspire change. I could not help but notice the sparse number of people responding the the request for comment on such an important document, a huge shift in chemical policy. If you would like for me to speak to help the support the Action Agenda, please do not hesitate to call me at home (251) 633-6728, cell (251) 366- 1707 or write me at 582 Summerlake Drive E. Mobile, AL 36608

    Comment on the National Conversation webdialogue: No government agency will investigate nor respond to chemical exposures and chemical injuries that occur at schools. The recommendations in the draft edition seem to skirt around protection of children from chemical exposures and injuries at public and private schools

    I was seriously and permanently injured by toxic chemicals from a foam roofing application while teaching in coastal Mississippi. One thousand 10 to 13 year old school children were exposed and dozens were also seriously injured. The weather was hot (90%) and humid, and with no air conditioning, and all windows were open. No warning was given to personnel nor parents of students about the dangers of the chemicals to be applied. Teachers and students were notified via intercom that the tankers contained only water, and the chemicals being applied were “non toxic,” when in fact they contained some of the most toxic chemicals manufactured. No agency would respond, claiming they had no authorization nor directive to do so. No medical responders were called. Injured and suffering children were prevented from calling parents to remove them from school. The community was never informed about the name and hazards of the chemicals applied. No was was ever held accountable. See story and Chapter 1 of Toxic Justice http://www.nancyswan.com/toxic-j…

    Despite injuries to school children and teachers from this product, nothing has changed in 25 years. Foam roofing continues to be aggressively marketed to school officials as an inexpensive and “green” solution. http://greenteamroofing.com/foam.html

    Almost a thousand chemical exposures at schools in the US were reported in the news over the past year. Parents were angered and confused about who to contact for accurate information. Only a tiny fraction of the news accounts told the name of the toxin or hazardous substance. Often school officials announced the school “safe” without testing with the appropriate equipment or without contacting environmental governmental agencies.

    I fear that most if not all the recommendations that will be adopted will rely on voluntary monitoring, weak incentives, efforts and not action, no oversight and no effective enforcement.

    Knowingly harming a child or personnel by using a toxic substance at a school, failure to protect school children from chemical exposure and injury, refusing medical care to those chemically injured at schools, and cover up of a school toxic incident should be criminal.

    How would any or all of the recommendations on this topic: Respond effectively to Chemical Exposure protect school children?

    How would any or all of the recommendations have prevented or helped the toxic incident at my school and others experiencing injuries from exposure to chemicals used in renovation and repair?

    Attachments:
    [img]http://resolv.org/site-nationalconversation/files/2011/02/Court exhibit 11, MIRI spraying on school, enlarged.jpg[/img]
    [img]http://resolv.org/site-nationalconversation/files/2011/02/Court exhibit 11, MIRI spraying on school, enlarged1.jpg[/img]
    [img]http://resolv.org/site-nationalconversation/files/2011/02/Discarded barrels 2 001.jpg[/img]

  15. Lisa Nagy

    The Preventive and Environmental Health Alliance

    My name is Lisa Lavine Nagy M. D. I am appreciative that my time spent over the past 18 months has yielded some positive results on the Scientific Understanding work group. I would say that the items have been boiled down a bit too much so that the details we had outlined are now not to be found and therefore exact positive actions are not enumerated as well in this final product. In order for next steps to be taken they need to be spelled out. It is hard to convey both background and a plan in a single paragraph. I therefore feel additions should be made which refer to the work group recommendations related to each leadership council recommendation. This way we will get away from being milk toast and towards being more inspired.

    I refer especially to 3.5, 3.6, and 3.7. In 3.5 (individual susceptability) I think that the essence has been lost in that what the country needs is a (non toxic) hospital facility and then satellites facilities dedicated to research and treatment of the environmentally ill individuals. All diesease that have a possible route in exposure to chemcials, mold, or radiation should be apprioach in a logical way as to treatment based on investigation and work up in an environemtnal Medicine Unit. Without such units we will never progress. We must bring the 50 years of knowledge of environmental physicians and researchers to the public through rigourous study with government funding. Right now only the wealthy, well educated doctors and very fortunate individuals get this treatment that can obviate the development of neurologic, immune or endocrine diseases – to name a few. We need to make it available to all that become ill, to lower health care costs for chronic diseases by allowing thourough investigations at the outset and preventing those diseases from progressing. We must look first to those obviously poisoned by chemicals (and toxic molds) and who now have chemical intolerance to garner data and then move to the averagre person with information learned.

    I also would have liked to see more specific information included on the exact ways we will work to elucidate the health effects of mold exposure and other indoor air contaminants. Half of those made chemically intolerant get it from mold exposure – it is very common in the US. It is a common cause of depression as well – and likely autism. We must open up lines of communication between the public and our government and they are saying help us now to deal with these controversial yet devestating exposures. Insurance, Medicine and pharmaceutical industry all have vested reasons why it is easier to sweep this subject under the rug. We need our government to represent us not private industry in an effort to elucidate the true medical conditons that arise from poor indoor air quality. The American Acadmey has been speaking ot for decades about BPA andnow it is about to be outlawed. Likewise the same Academy speaks out loudly on the health effects of mold and we expect this recommendation to make things happen swiftly to address the inadaquacies in research, diability coverage, medical treatment and general acknowledgment of this truley horrific exposure afflicting many tens of millions.

    In summary please include the entirety of the recommendations we worked so hard on with their references as well so that at least that much is used as a jumping off point. Otherwise little action will occur. I have worked on the hill in my youth, I am from Washington, and I have recovered from what appeared to Lou Gehrig’s type symptoms form mold exposure, and I am have attended Cornell Medical School, you need to head the reccomendations of people like myself who have become environmentally ill. Academics and legislators have no idea of the true import of these problems and hopefully they will learn from people like myself and those brillaint docs who have come before me — what steps need to be taken. It may be an uphill battle but we must start the hike and now! Thank you for reading my post. Sincerely, Lisa Nagy President of The Preventive and Environmental Health Alliance

    Attachments:
    [file]http://resolv.org/site-nationalconversation/files/2011/02/Bio Brief.doc[/file]

  16. Ernest Grolimund

    RAWSEP, CAWB

    Great Action Agenda!

    1) Prevention: Federal Agancies should work with citizen victims of toxic chemicals where ever they arise from and not focus on industry, business, as stakeholders. The proposed Voluntary Environmental Corps could do this by getting young lawyers to help victims get action from non responsive government agaencies as identified. Without access to lawyers, people are being abused and physically injured in great numbers. Ie wood smoke has injured about 50 million citizens in the USA. I personally am hopeful that the CDC can do something about this like they have for tobacco smoke, but the action for tobacco has been slow and painful and difficult.

    Modeling or computer estimating is a proven tool for preventing air pollution for large sources. It should be used to prevent pollution from new small sources as well which in total emit much more pm into the air. 4 times more in LA just from fireplaces. The modeling must also be used retroactively to assess permitting of old equipment, 90% of the problem, especially old stoves. Right now, ATSDR is insisting on monitoring by individuals before they will consider looking at individual sites, like the Jackson County owb. Monitoring each stove is un economical and impractical and the monitoring is expensive and un available most of the time and too slow and dangerous. With modeling you can assess whole classes of equipment and regulate economically. An EPA OIG hotline person says he personally agrees modeling could stop and prevent large amounts of threats to life and health. The Maine DEP and EPA did some modeling that was judged good by the EPA. Perhaps a quick review by the CPSVC and ATSDR modelors and a little fine tuning of inputs could get stop millions of toxic chemical threats very quickly and economically. But the will to do it or order to do it has to come from up high.

    Monitoring right now is difficult and expensive for individual sites, but old science human senses can be used for cheap and time tested monitoring at least on an initial screening. But with time for monitoring being hours to heart attacks and asthma attacks, tables of known values and qualitative human senses may have to be used for fast instant decisions by local first responders. The existing pm monitoring system that works for oil and gas combustion fails to pick up wood smike pm that is commonly raising city levels to 80 mcg/m3 levels instantaneously and pm levels are shown to sometimes be 4-5 times the ambiant pm levels from one side of a city to another. EPA policy gets minimum pm but safety pronciples dictate getting the highest. Portable pm monitoring can largely solve that as shown by Brauer and Larson.

    A good example of policy that worked from modeling is the Washington State outdoor wood boiler law. There is a ban on outdoor wood boilers there until they can be proven safe. Other states have followed suit but many others have instituted different laws that are not working, and violate other laws and constitutional rights, et cetera. Maine is a prome example of bad owb law. Much of the same problem exists with old stoves and indoor wood bilers but nothing has been done about that equipment.

    The states were forced to act because of poor EPA regulation and a fast changing pm std. Better federal regulation could have prevented a lot of these problems. Other Depts checking the EPA could have helped but most other agancies passed the buck to the EPA. Checking and oversight is always a good idea in scientific fields, but business often cuts corners. The problems in Management go all the way to the Whitehouse according to EPA sources. BUsh was anti regulation and pro business so his administration cut regulatuion and investigsation. Obama is pro regulation and the Depts get whip sawed between administrations.

    Prevention could also be enhanced cheaply by making guidelines standards that have to be enforced. Right now, states do not enforce guidelines. It is a joke. Benzene is commonly reported to be 4 times the guideline in cities and other chemicals have not been checked.

    2) Promoting Health… after exposures. I like alot of the ideas here. Enforcement of environmental laws is very bad, so think of the good that could come just by getting better enforcement or regulation. Or eliminating the need for enforcement when the probability of violations becomes so high that banning polluting activity comes to mind. Ie wood burning that violates pm stds by modeling.

    Faith in government is almost non existant as wood smoke victims see cities engulfed in wood smoke from journalists photos. Pictures do not lie. In this case, the CDC is correctly saying any visible smoke is a health problem and the journalists are correctly showing how much a problem we have. But the EPA is very lax in enforcing laws and amending stds and regulatory means to match CDC health policy. The CDC gets a A grade here but the EPA gets an F grade for failing to enforce the law and ammend the law according tothe constitution.

    Victims absolutely cannot advocate for theselves. They are routinely ignored and brushed off by government who pass the buck and use all kinds of excuses to cut costs. Paper laws and enforcement are the norm right now, as correctly written. Victims are overjoyed to read this but wary that paer studies do not become reality on the ground fast or ever in most cases.

    Safer Alternatives is properly mentioned. An example could be requiring all wood burning equipment except perhaps pellet stoves to be replaced by gas stoves that can still save people 50% on their heating bills without threatening life,health, safety, and welfare. A new wood smoke pm std must be developed quickly from EPA wild fire smoke guidelines. But dioxin levels from all equipment must be checked as well as 180 other toxics. Victims like myself really like the emphasis placed on this.

    Victims groups like RAWSEP and The Clean Air Revival and The International Coalition Against Wood Burning Pollution like the emphasis placed on listening to them for this is greattly lacking now and we have been able to bring cetrtain issues to the forefront as the action plan says.

    We have advocated for TOX FAQs expansion because right now pm is not even on the TOX FAQs, let alone different stds for different types of pm such as the especially dangerous wood smoke pm.

    We dram of having an ombudsman because we are ignored but have to comment that the EPA OIG ombudsman program is not working. The ombudsman should be lawyers who cannot be pushed around and can fight to get laws enforced. The EPA ombudsman program is another paper program. Supposedly there but not really there, just like the CID of the EPA. The negligance at all levels of government is why we have cities engulfed in visible and invisible wood smoke and smelly air toxic chemicals from wood smoke.

    Finally, many of the victims are well educated engineers, med techs, and other responsible and accomplished people who could and are volunteering much time to try to stop the chemical emergencies from wood smoke going on all across thecountry. We would be excellent volunteers until the fraud and suppression of science and evidence starts being forced on us. RAWSEP and other groups desperately need grant money for environmental justice and law suits to make our government s start enforcing the laws and to get rid of the old grandfather rules for wood burning that mustbe ammended. Federal money could go towards bringing suits against cities and sates and we would have to be content to just try to negotiate with the federal government. This is good as most of the enforcement problems are state and more importantly local problems.

    3) Healthy choices must be identified. I have tried to do this above for wood smoke. OLd equipment is bad and needs to be baned or replaced immediately. Changeout programs allow life and health threatening pollution to exist 20 years which is unconstitutional, threatening life and health and more against DHHS policy that says al,l of these threats must be stopped and prevented.

    4) Understanding Chemicals. Obviously neccesary. But costly. Much knowledge exists about wood smoke dangers for example but little is done. Expensive monitoring could be avoided if smells are recognized as an indicator of threats to life and health. That practical understanding seems to be missing and could be restored in seconds. Just do a TOX FAQs on wood smoke from existing knowlewdge without spending millions andinclude smell as an indicator of danger.

    5) Respond to chemical emergecies. Victims of widespread chemical emergecies from wood smoke in particular agree that there is a big problem that needs to be fixed. The EPA and CDC and ATSDR are starting to recognize this but action is very slow and delayed and negligant. I hate to have to be that critical but I must for real emergencies do exist right now that are being ignored. Perhaps the biggest problem not identified by the Action Agenda is the “INTERFERANCE BY POLITICIANS” not allowing first responders to do their jobs. Most respnders are not professionals like doctors but in one case in my city I have seen a professional doctor ignord by unprofessional politicians with injuries resulting. This interferance exists at all levels, local, state, and federal on a sliding scale. There is less interferance at the federal level but when it comes from Presidents and Congress the effects are much worse.

    In summary, I am glad to see so much effort being placed on fixing the entire system from bottom to top in every way. I agree with most of what is being done and have been told the National Conversation is sympathetic to woodsmoke toxic chemical emergencies. I would like to especially praise Atty Ruhl of the EPA for trying to call attention to my issue by calling the EPA Administrsators office and informing an advisor of the emergency going on with wood smoke. That ideally is what we want from all government oficials. Fast ACTION.

  17. Alan Bookman

    NJDEP

    I was a member of the Education and Communication Workgroup. I think the Action Agenda contains many important items, but I do think the richness and number of the ideas is overwhelming and diminishes the possibility that the report will lead to the positive changes that are desired. I would ask that further work be done to possibly combine some of the items, to reduce the number of items that are presented.

    Also, I would move the secondary action items to an appendix.

  18. Jenilynn Bohm

    Red Lake DNR

    I am concerned about the risk assessment process for human exposure from agriculture lands. Both the household use and agricultural exposure should be considered within cumulative risk. The two scenarios are not isolated. Throughout farming country, homes, towns, cities, and reservations are surrounded by agriculture. The current methods to determine exposure don’t take into consideration the patchwork quilt that the farming community comprises. Homes and towns are often scattered between and surrounded by fields. Quite often, their primary exposure is not from household use, but aerial drift and run-off from pesticide applicatons. Cancer is also a major concern for most of these communities. To properly address the environmental risk of humans, the area in which they live, as well the home that they live in both need to be addressed to represent a more appropriate measure of cumulative risk. Unfortunately I was not able to participate in the web dialogue, but I would appreciate a response to my comment.

  19. Corinna Brown

    Hi;
    My comment involves chemicals use in childrens perms,relaxers,shampoos and conditioners,not to mention dish washing liquids,laundrey detergents,toothpaste and Straterra(meds for adhd).Sodium Laureth Sulfate is in just about every product on the market.In straterra the first side affect is Suiside in big black bold print,this is meds. the doctor wanted me to give to my daughter,I just couldn’t do it after gaining knowledge of how painful it is causing major headaches,stomach pains,depression,zombie like movements and yellowing of the eyes.From my research, Sodium Laureth Sulfate according to the American College of Toxicology both SLS and SLES can cause malformation in childrens eyes,other research has indicated SlS may be damaging to the immune system. SLS has the potential to cause cataracts through skin absorption even without direct contact with the eyes.Skin layers may separate and inflame due to its’ protein denaturing to poor quality hair, corroded hair follicles and inhibited hair growth contributing to hair loss.Skin contact can cause SLS to be absorbed into the blood circulation and can then concentrate in organs such as heart,liver or brain.This is potentially dangerous since SLS is a mutagen,capable of changing the information in the genetic material of your cells and organs.There are other potentially dangerous chemicals such as Diethanolamine(DEA),Monoethamolamine(MEA),and Triethanolamine(TEA),these are hormone disrupting chemicals and are known to form cancer causing nitrates and nitrosamines.Also propylene glycol- a chemical a colorless,viscous hygroscopic liquid,used chiefly as a lubricant,as an antifreeze and as asolvent for fats,oils,waxes and resins.Propylene-containing the propylene group-n 2) also propene, a colorless flammable gas.These are just some of the dangerous chemicals used in hair care products and its been approved by the FDA to be marketed,this is dangerous to my health as well as my children.These products should not be sold to me or anyone else, the perms are human bombs once you use it. This is my hair before I used the childs perm.

    Attachment:
    [img]http://resolv.org/site-nationalconversation/files/2011/02/cc pic 006.jpg[/img]

  20. Renee Dufault

    United Tribes Technical College

    After searching the Draft Action Agenda document I found the word “diet” once and the word “nutrition” once. This is a sad state of affairs and explains the continued slow progress being made by the U.S. government public health agencies with respect to environmental disease prevention and creating a healthier environment in which to live.

    You cannot have a conversation about preventive medicine or environmental health, or exposure prevention without comprehending how diet ultimately determines how the body will respond to toxic substance exposure.

    Suggest you bone up on the basics and read the peer reviewed journal article published in Behavioral and Brain Functions – Dufault et al (2009) Mercury exposure, nutritional deficiencies and metabolic disruptions may affect learning in children. This document provides a model that can be used to explain what the human body needs to combat heavy metal exposures. See Dufault’s power point presentation for the Feb. 9, 2010 teleconference sponsored by the American Association of Intellectual and Developmental Disabilities. http://www.aamr.org/ehi/content_3919.cfm?navID=306 Click on the materials button.

    Look for the next model to be published by Dufault et al on Organo Phosphate exposure.

    The American diet needs serious modification. Pregnant women and parents must have access to information so they can eat appropriately while occupying space on our current planet without creating conditions that lead to neurodevelopmental disorders.

    We live on a polluted planet. Give the people some information that will help them prevent neurodevelopmental disorders.

    Renee Dufault, CDR (retired PHS officer) 808-345-6864
    [file]http://resolv.org/site-nationalconversation/files/2011/02/Dufault et al BBF.pdf[/file]

  21. Renee Dufault

    Food Ingredient and Health Research Institute

    After searching the Draft Action Agenda document I found the word “diet” once and the word “nutrition” once. This is a sad state of affairs and explains the continued slow progress being made by the U.S. government public health agencies with respect to environmental disease prevention and creating a healthier environment in which to live.

    You cannot have a conversation about preventive medicine or environmental health, or exposure prevention without comprehending how diet ultimately determines how the body will respond to toxic substance exposure.

    Suggest you bone up on the basics and read the peer reviewed journal article published in Behavioral and Brain Functions – Dufault et al (2009) Mercury exposure, nutritional deficiencies and metabolic disruptions may affect learning in children. This document provides a model that can be used to explain what the human body needs to combat heavy metal exposures. See Dufault’s power point presentation for the Feb. 9, 2010 teleconference sponsored by the American Association of Intellectual and Developmental Disabilities. http://www.aamr.org/ehi/content_3919.cfm?navID=306 Click on the materials button.

    Look for the next model to be published by Dufault et al on Organo Phosphate exposure.

    The American diet needs serious modification. Pregnant women and parents must have access to information so they can eat appropriately while occupying space on our current planet without creating conditions that lead to neurodevelopmental disorders.

    We live on a polluted planet. Give the people some information that will help them prevent neurodevelopmental disorders.

    Renee Dufault

    Executive Director, Food Ingredient and Health Research Institute http://www.fihri.org
    [file]http://resolv.org/site-nationalconversation/files/2011/02/Dufault et al BBF1.pdf[/file]

  22. Larysa Dyrszka

    Pediatrician

    As a physician who has looked at gas drilling from the health perspective, I would like to call your attention to this process and request that your Leadership Council advocate a study of this issue.

    Drilling for gas using the method called high volume hydraulic fracturing (HVHF) has caused air and water contamination, with adverse human health effects.

    Human health can be adversely impacted during many parts of HVHF gas drilling process:

    there can be impacts on the drinking water supply due to exceptionally large amounts of water withdrawn for each well (5-7 million gallons per well), most of which is not recovered
    in transport there can be spills, explosions, traffic accidents, road and bridge failures
    during drilling, when aquifers become contaminated due to lack of adequate casing or due to casing failure resulting from cementing problems such as shrinkage allowing the toxic mix to connect to aquifers following a path of least resistance; casings, because they are man-made, will always fail, sooner or later
    during fracking, when natural faults can be breached, there can be communication with aquifers and result in water contamination
    also during fracking, and returned with the waste or communicating via natural faults–radon finds its way to the surface; also methane can be forced to come up from the deep layers during gas drilling
    chemical spillage and contamination of groundwater or aquifers can occur–at the drill site, from holding ponds or during transport
    air pollution and ozone production resulting from transport, venting, processing and pipeline loss are not cumulatively measured at this point; however, it is predicted by scientists (Colorado School of Public Health) and now being assessed by the EPA, that the impacts of air pollution from gas production will be the most significant impact on human health
    disposal of waste which contains the chemicals used plus what is brought to the surface from a mile below, like brine, heavy metals, radioactive materials and hydrocarbons is a problem because disposal has not been adequately addresse
    noise pollution during transport, drilling, processing, possibly resulting in vibro-acoustic disease
    psychological stress on humans during the entire process due to potential loss of home, potential loss of water, potential health impacts, possible displacement, increased crime and potential for life-threatening accidents and explosions.
    Due to the exemptions from major parts of the Clean Air, Clean Water, Safe Drinking Water and other federal acts that would protect the population, there is inadequate oversight of this industry as it concerns human health due to federal exemptions. There is only one federal study in progress–the EPA hydrofracturing study which may be quite limited in its look at human health.

    The entire process of gas production should be evaluated with a view on human health specifically and this has not been done. I would recommend that this be undertaken so that appropriate measures can be taken to secure human health. Thus far, no physician who has looked at this process of gas extraction has said that it is safe. On the contrary, the more we physicians look at the process, the more convinced we are that the process, as currently practiced, is unsafe.
    [file]http://resolv.org/site-nationalconversation/files/2011/02/Health Witter White Paper.pdf[/file]
    File: Health-1-Colborn_.pdf
    [file]http://resolv.org/site-nationalconversation/files/2011/02/HEALTH EPA_Comments_Submitted_by_Eric_London_MD.pdf[/file]

  23. Samar Chatterjee

    SAFE Foundation

    Currently, there is little effective use of the tools and techniques of Effective Public Participation (Chapter 5) in developing and ensuring effective implementation of the Preventive Strategies for Health Impacts of Exposure resulting from new Chemicals. The testingof new chemicals should be put thru a more rigorous evaluation protocol based on an empowered public participation program
    File: NANOTECHNOLOGY-PAPER-1.doc

  24. MARK RUSSELL

    RECYCLER/ARTIST/WRITTER/SPIRITUAL/CARES

    PREVENTATIVE MEDICINE FOR THE US 200,000,000,000 LB. CHEMICAL INDUSTRY

    The biggest Outcome of the Chemical Conversation 2011 is that we need to do

    · Preventative Medicine for the United State’s 100,000,000 Ton Per Year Industry.

    Whether it is to Regulate the 44,000,000-Ton’s of Sulfur that the US Produces every year or the Pesticides that go on our Crops. The Conversation went as far as the Medical and Pharmaceutical Industries and Regulating their Chemical Waste Streams.

    · 99% of all the Answer have already been Invented
    · All we have to do is some Research
    · We have the Finest Universities in the World that Could Assist.

    In 1898 we made Cancer a Science and only 2—5% of all Cancers were Curable.

    · Today we can cure over 95% of all Cancers if we Catch them in Stage (1 or 2).

    In 1967 we had the 1st. MRI and 1969 years latter we Landed on the Moon.

    There are (2) Basic Ways to Cure the Problems of Chemical Pollution.

    1) Make New Laws with Harsh Punishments and Cash Penalties.
    2) Teach Industries and the Cities the Answers to their Problems and Everyone Profits. Teach the Chemical Industry how to Recycle their Waste Stream and Save the Cost of Law Suits, Damaged Communities, and Make Profits.

    “MANY HAVE VISION AND FEW CAN SEE” Helen Keller

    I personally like Option (2)

    GOAL

    TO TEACH & EMPOWER INDUSTRY—-CITIES—-STATES—-MEDICAL—-SCHOOLS—MILITARY HOW TO RECYCLE THEIR CHEMICAL WASTES & POLLUTION AND HOW TO MAKE PROFITS & NEW JOBS.

    The Real Estate Industry set up a Licensing Process that a Real Estate Licensee Agent must know 100,000 Basic Things about Real Estate to get His or Her License. Like —Grant Deed, Sales Agent, Anchor Bolts, Metes and Bounds, Sections, Broker, Trustee, Judiciary, Escrow, Lease, & Etc. I feel that we could Design Education and Testing with the Purpose of Educating the Chemical Industry in the Following:

    · Educate Industry as to the Possible Consequences to their Employees, Themselves, and their Families caused by Chemical Pollution.
    · Educated Industry/Cities,/States/Etc. on the Legal Consequences for their Employee’s or a Community that Gets Cancer or Sicknesses linked to their Chemicals and the Cost Benefits for Preventative Measures.
    · Educate Industry as to the Different ways of Dealing with Chemicals—Real Video/Books/Audio’s/Tests
    · Educate Industry as to the Alternatives Options—Real Life Examples
    · Educate Industry as to the Solutions to their Problems with New Jobs, Less Chemical Pollution, and Profits for the Business, Communities, and the World.
    · Educate Industry How to Recycle their Chemicals with Real Life Examples of Industries that are doing it Right Now.
    · Educate Industry as to the Markets for their Chemicals and for their Own Re-use.
    · Educate Industry as to Different Subset Answer to the Chemical Pollution.

    In Real Estate you are given a test of Knowledge to get a License. The same should hold true for Business or Communities that deal in Chemicals. Education and Testing would be a very good Delivery System to Teach How to Recycle, Profit, and Save Lives and the Environment.

    Let me give you an example.

    POSSIBLE QUESTIONS:

    1) Name (5) ways to Recycle Sulfur
    a) Fertilizer (54% of all Sulfur goes into Fertilizers)
    b) Battery Acid
    c) Matches
    d) Vulcanization of Rubber
    e) Chemical Industry

    2) How many Ton of Sulfur did the US Produce last Year?
    a) 44,000,000 Ton

    3) How much is 44,000,000 Ton
    a) 88,000,000,000,000 lbs.

    4) Name (3) Industries that are now Recycling Sulfur
    A) Copper Mines
    B) Steel Mines
    C) Oil Refineries

    5) Name (7) places to get information on Sulfur Market
    a) Trade Journals
    b) Internet
    c) Chemical Industry of America
    d) Universities
    e) Encyclopedias
    f) Trade Organizations
    g) US Dept. of Trade

    6) Name (5) way to Protect the Farm Workers from Pesticides
    a) Give your Workers Dust Masks
    b) Set up Shower Facilities so that the Workers can Shower before leaving
    c) Leave Uniforms at Work and Leave in different clothes when leaving the Farm.
    d) Don’t have your workers in the fields for (3) days after Spaying of Chemicals.
    e) Have your Workers Drink (16) Cups of Water Daily—Flush their systems.

    7) Name (1) Ways to prevent Pharmacological Manufactures from Polluting our Water Systems?
    a) Don’t let any Sewage leave the Facility
    1) Install 5,000 Gallon Underground Sewage Tanks

    8) Name (1) Ways for the Hospitals not to pollute our Water Systems with Medical Waste?
    a) Install 10,000 Gallon Underground Sewage Tanks?

    9) What is the Liability if you give (1) of your Workers Cancer?
    a) Million-dollar Liability.

    10) Name (3) ways to Recycle CO2
    a) Use in Oil fields
    b) Use to Grow Kelp
    c) Freeze

    The point of the Education and Testing Standard is to Teach Industry—Schools—Cities—States—Sewage—Coal Burning Electrical—Military—Chemical and Mines
    the Solutions so that we all Benefit as a Whole.

    · If we Build in More Regulations to business this will only cause more Hardships.
    · By Teaching the Solutions we Empower Industry with Real Solutions and Ways to make Profits.
    · Less Pollution
    · Less Law Suits
    · Better Health for Yourself—Your Workers—Your Community and the World.
    · Less Chemical Pollution.

    I feel that we could Create New Industries across the US to Recycle our Chemicals.

    · For every Problem we have a New Industry to Cure the Problem.
    · 99% of all the Problems have already Been Developed with Proven Solutions that Make Profits & Jobs.
    · We could Create Millions of New Paying Jobs to Recycle the Chemicals and Make Large Profit.
    · We could Develop a Industry to Solve Chemical Pollution and to Sell that Technology, Solutions and Equipment around the World
    · 99% of all the Answers to Chemical Pollution have been Developed.
    · Recycling is the 10th Largest Industry in the US.

    “GIVE A MAN A FISH HE’LL STARVE

    TEACH A MAN TO FISH HE’LL LIVE A LIFFETIME”

    We are Our Own Biggest Enemies and We are the Solution.

    MR.

  25. Edward Lorenz

    Pine River Superfund Citizen Task Force

    As the chair of the Health Committee of the Pine River Superfund Citizen Task Force, the officially recognized community advisory group for Superfund sites in the Pine River watershed in mid-Michigan, I want to submit the following comment to the Draft Action Agenda of the National Conversation on Public Health and Chemical Exposures.

    In general our organization is very much support the work you have done and specifically want to endorse inclusion of the following ideas from the drafts from earlier this year in your final version:

    1. We strongly agree that there are likely to be many additional, unmeasured chemicals that have entered the environment. In our community, for example, in 2004 EPA found our drinking water supply was contaminated with a byproduct of DDT manufacturing, pCBSA. This compound has been subject to minimal testing, yet we are drinking it daily until a new water supply can be found. We are sure many other communities face similar chemical exposures. A more robust system must be found to test promptly such chemicals.

    2. Because people in communities such as ours are exposed to multiple chemicals, that collectively are likely to be a unique cocktail of exposures, a process needs to be developed to do prompt local exposure estimates. Local and state governments need adequate financial support when the community contains contaminated sites to fund locally relevant testing.

    3. As the Scientific Understanding Work Group proposed, we support use of the model developed in the European Union (EU) for assessing exposures. The EU countries are some of the most advanced in the world, certainly comparable to the U.S.; rather than reinventing “a wheel,” we should move forward quickly to utilize all empirically developed methods and standards, from whatever country or international organization. We should not waste time reinventing wheels.

    4. As the Scientific Understanding Work Group observed the current Public Health Assessment process used by ATSDR is nearly useless in guiding further action. We have found such assessments have been quite perceptive in suggesting possible concerns, yet the assessments are so short and generalized that they are nearly useless in moving from perception to remedial action. All other comments of the Work Group related to these assessments, such as subjecting them to peer review should be implemented.

    5. As the Scientific Understanding Work Group proposed it MUST be a priority to “develop scientific criteria for the application of the precautionary approach . . .” It is time we move beyond the current risk assessment process, which too often excuses inaction because of uncertainty. Our children and their descendants should expect we will not treat them as guinea pigs for substances and processes we CAN utilize, when we do not yet know the consequences of their use.

    6. As the Scientific Understanding Work Group, we fully endorse the wisdom of favoring permanent treatment of contaminants rather than so-called institutional controls. Our community, as others linked to our polluter, has experienced the utter failure of past state-of-the-art remedies that left contaminants in place with “containment systems.” At all three of “our” Superfund sites, institutional controls failed to keep contaminants from migrating, especially into the drinking water aquifer. At the Hardeman County site in Tennessee, the pump and treat system utterly failed, when dense contaminants fouled wells. In each case, the failure to guide containment plans with the precautionary principle meant that when the initial containment failed it took many years for the cumbersome EPA remedy review process to produce a new plan. Throughout this process, residents with actual exposures, as in our drinking of pCBSA, were told to wait a few years while decisions were made and funding found for a new effort at remediation. Still, EPA favors containment not permanent treatment.

    We hope it is obvious from the above, that we fully support the wording in the Draft Action Agenda. Our final comment, however, would be that you should not ‘water-down’ the August 2010 draft. Once the draft is finalized, we also urge you to work to assure your Action Agenda is implement by the federal government and state partners. We are fully prepared to support you in this work.

    Edward C. Lorenz, Ph.D.
    Chair, Health Committee
    Pine River Superfund Citizen Task Force
    P.O. Box 172
    St. Louis, MI 48880
    (989) 463-7203 [office]
    (989) 463-6170 [home]
    lorenz@alma.edu

  26. Derek Swick

    American Petroleum Institute

    Recommendation 2.3(a) addresses the Toxic Substances Control Act (TSCA) Inventory Update Rule (IUR). The document recommends that the IUR be improved by 1) increasing the frequency of reporting from every five to every one or two years; 2) requiring greater substantiation of claims that information is “not readily obtainable”; and 3) providing clear guidance as to those circumstances under which a claim of “not readily obtainable” would be accepted. EPA recently proposed modifications to the IUR that addressed these subjects, and API recommends that the National Conversation include review of the comments on those modifications in the draft action agenda and not only a simple reference to the IUR proposal. [See TSCA Inventory Update Reporting Modifications Proposed Rule; 75 Federal Register 49656, August 13, 2010; EPA-HQ-OPPT-2009-0187.]

    Regarding the IUR and other data collection requirements, API believes that regulations that impose reporting burden must be justified by a clearly demonstrated need for the information. We support EPA’s risk management efforts and think they are most effectively accomplished when EPA sets priorities and gathers data that it needs for specific purposes and programs. API supports the five-year reporting cycle because it is appropriate to meet identified data needs and the statutory intent of TSCA. We think the five-year reporting interval optimizes value, i.e., there is a reasonable balance of the effort required and accomplishing the purpose of the IUR.

    API disagrees with the recommendation that EPA require greater substantiation of claims that information is “not readily obtainable.” The IUR already imposes significant reporting burden on companies and requiring this additional substantiation would increase the level of effort required without accompanying benefit. We do not believe that requiring substantiation for entering “not readily obtainable” would increase the amount of useful data reported.

    Also, regarding the use of “not readily obtainable” on the IUR form, we note that EPA’s August 13, 2010 proposed rule would replace the “readily obtainable” reporting standard used for reporting processing and use information with a “known to or reasonably ascertainable by” reporting standard. API opposes use of the standard “known to or reasonably ascertainable by” for processing and use information. API believes that EPA should limit IUR reporting to information that is in the possession of the submitter, which even the current “readily obtainable” standard exceeds. Requiring companies to report information that they do not possess is likely to result in submission of poor quality information.

    Regarding the recommendation to provide clear guidance as to those circumstances under which a claim of “not readily obtainable” would be accepted, API agrees. Whether the standard is “readily obtainable,” “known to or reasonably ascertainable by,” or something else, it is important the EPA clearly define the standard, including what actions reporters are expected to take to obtain the information internally and/or from other parties.

    Finally, the TSCA recommendation 2.3(a) is misplaced under Recommendation 2.3, because Recommendation 2.3 concerns the Toxics Release Inventory (TRI). The TSCA IUR is not part of the TRI program—the two programs are managed by different EPA offices, pursuant to two different statutes. It is easy to miss TSCA recommendation 2.3(a) because it is buried within a TRI recommendation.

  27. Angela Monti Fox

    Citizen of the United States

    Commentary on Chapter 1, Improving Public Health through Prevention From Angela Monti Fox, LCSW

    I wish to comment on the current Draft Action Agenda document, particularly Chapter 1, that proposes a basic reduction in adverse effects on human health and the environment by placing some limitations on toxic chemical exposure. It is difficult to understand how this would be accomplished without directly approaching the current assault on human health and the environment by the oil and gas industry’s use of many and various toxic chemicals in high volume hydraulic fracturing (HVHF) to extract natural gas.

    While the recommendations in Chapter 1 have some inherent validity (Recommendation 1.1, “Federal, state,..Promote the substitutions of hazardous chemicals with less toxic alternatives…” Recommendation 1.2, “Reform the Toxic Substances Control Act…..” and Recommendation 1. 3 , All branches of government …improve child health protection..etc” , address Recommendation 1.6, “Federal agencies …ensure ..compliance ..And enforcement of …environmental health regulations, laws and policies.” were they to be enacted, they would have little impact while the oil and gas industry remains exempt from fundamental Federal laws. I refer here to the fact that the oil and gas industry is exempt from The Clean Air Act (1963, 1966, 1970 and The Clean Water Act (1972)and The Comprehensive Environmental Response, Compensation, and Liability Act of 1960 (CERCLA), commonly known as the Super Fund Law, that explicitly holds the culpable entity financially responsible for any toxic contamination it has caused. The enactment of these laws recognized that Clean Air and Clear Water are fundamental human rights and warranted protection.

    Due to the exemption from this law, we see that the oil and gas industry has been given free reign and has had no concern for the environment or for the ordinary people whose lives it ruins and destroys. We have clear evidence from the 2010 disaster in the Gulf, that without a doubt and without any need for further scientific proof, this event has caused irreparable damage to human life, wild life and the existing ecosystem. Yet, the proposed document to be sent to the Center for Disease Control (CDC ) with a 2011 date, proposes that more “scientific proof”, as well as more and better laws and more and better functioning governmental agencies, are needed to accomplish the espoused goals.

    To reflect on the Gulf oil disaster as an example, we see that although the current presidential administration forced the British Petroleum Oil Company (BP) to provide compensation for the harm caused, the public was not aware that this was an exception to the rule. The public must be made aware that the Super Fund Law was enacted specifically to hold entities responsible financially for damage caused to individuals and property for the release of toxic waste into the environment. Yet, this became a partisan political issue. Perhaps only because recent legislation made the industry financially exempt! (See: Halliburton Loophole: http://www.nytimes.com/2009/11/03/opinion/03tue3.html)

    It is clear to many that the Gulf oil disaster proved without doubt that the industry does not police itself, because it does not have to. In addition, the day-to-day coverage of the event should have proved to the public that neither the industry nor the government, nor the private sector had any technical knowledge as to how to provide a remedy as the damage continued to occur. We can take from this lesson, that a major disaster caused by the cumulative or singular event of hydraulic fracturing will not be remedied either. The industry does not concern itself with how to prevent a disaster nor to remedy it as it occurs precisely because the law as it stands is on the industry’s side. We are foolish to think that a true rehabilitation of any population can occur. Therefore, it is my belief that there is a need for a total preventive approach to all populations.

    To the question that more science may be needed before any action is taken, time delays are not on the environments side and delay with have irreparable consequences. There is already significant scientific and anecdotal evidence that current nationwide hydraulic fracturing is toxic. This is true in spite of the fact that the oil and gas industry is not obligated to state the name or nature of the chemicals it is using in this process. Its claim that the toxic formulae being used is a secret over which the industry has protective rights is further evidence of their ruthless disregard for public health and the environment. We have as a model for regulating such formula already in the laws that enable the Food and Drug Administration to monitor our food intake and many other products available for human consumption. Yet this draft document makes no mention of applying similar standards through law to the products being used in the extraction of natural gas.

    Relevant commentary on the draft document has been made regarding the dissemination of information about hazards to human health. While Chapter 1 is relevant in its emphasis on the use of local communities, organizations, universities and current digital resources to disseminate accurate and truthful information regarding the destructive impacts of unbridled disbursement of toxic chemicals on human health, it does not address the fact that the oil and gas industry is spending hundreds of thousands of dollars, if not millions, in advertising on television, radio and print media to falsely promote natural gas as a clean energy product.

    This campaign goes beyond anything that is currently being done on the grass roots or federal government level to inform and educate the public. The oil and gas industry has communication dominance aimed blatantly at fooling the American people into thinking that natural gas is the clean energy solution to our energy dependence on foreign oil.

    One has to wonder what it will take to compete with the industry’s command of the national conversation and what will work in informing and influencing the public as to the truth. This topic is not addressed in Chapter 1 of the proposed Action Agenda.

    To comment on Recommendation l.6. that Federal agencies…ensure ….compliance..and enforcement of ..environmental health regulations, laws and policies.
    While this recommendation calls on various governmental agencies, DOE, DOD, EPA, OSHA, ATSDR and FOH to ensure effective compliance of industrial and federal facilities, to provide independent monitoring, to protect workers, to give priority to vulnerable populations, etc., it fails to address the idea (1) that all industries must be in compliance with no exceptions and (2)sufficient federal funds must be mandated to adequately staff these entities so that they can do their job effectively.

    Why not address the current exemptions of oil and gas industry from major Federal legislation, that would force them to comply with The Clean Air Act, The Clean Water Act, and force financial responsibility as the Super Fund law states? The job of these agencies, when properly staffed would then have real meaning.

    Recommendation l.7 Federal Agencies work in consultation with private sector in developing scientific criteria…to protect human health and the environment.”
    This recommendation is not sound. We know that engagement with private industry so heavily invested in this currently profitable endeavor of natural gas extraction and off shore oil drilling does not produce accurate and scientifically sound information that is contrary to their financial interest. If the federal government and its financially endowed institutions were to be engaged with the private sector, that private sector would have to be independent entities that have no financial or political interest in the oil and gas industry and be already bound in their principles and ethics to the advancement of human health.

    Commentary on the Draft Action Agenda has suggested that primary prevention at all levels for all populations must become the norm. This should not just be suggested by policies but enacted into law and all entities engaged in the process of harvesting the earth’s natural resources must be in compliance with a “do no harm” ethic, with no exceptions. The idea of prioritizing “vulnerable populations” as suggested by the current draft document would become a moot point if the entire population were to be protected.
    To the point stated in the first paragraph of this commentary, it would be worthwhile to consider reinstatement of the federal laws that protected Clean Air and Clean Water and perhaps even as a constitutional amendment protecting Clean Water and Air as a basic human right..
    References: Some websites do have reliable sources of information on environmental health consequences of “fracking”. The Collaborative on Health and Environment held an informative panel discussion moderated by Elise Miller on November 9, 2010. http://www.healthandenvironment.org/partnership_calls/8138
    Dr. Theo Colborn of The Endocrine Disruption Exchange (TEDX.org) and Professor Anthony Ingraffea from Cornell University brought up key issues. 11/9/10: MP3 recording available:
    http://www.endocrinedisruption.com/about.people.php

  28. David Marker

    Westat

    Chapter 2 has adopted 6 of the 8 recommendations made by the monitoring group. I am disappointed that I don’t see any mention of recommendations 2 or 8 that we made.

    #2 was to make monitoring more comprehensive and suitable for assessing total human chemical exposure. I’m not sure if additional monitoring is called for anywhere in Chapter 2, even though the recognition of the large gaps in our knowledge was a basic finding of the Monitoring Working Group. Routine monitoring of a range of microenvironments is vital to understanding exposure and identifying how to reduce future exposure. Data on exposure at work is often 30 years old, data on microenvironments such as child care centers is extremely limited.

    #8 concerned balancing public access to data with confidentiality protection. The clearinghouse mentioned in 8c might be considered part of recommendation 2.8, but it isn’t clear. The important concern about data not be available in order to protect privacy can have major impacts on local and national understanding of chemical exposure. Our recommendations concerning a NAS report and local access to their data are important and reasonable. Hopefully they can get incorporated in the final recommendations in some form.

  29. Ashley Whitlow

    State Health

    Comments to the National Conversation on Public Health and Chemical Exposures draft ‘Action Agenda’:

    1. Page 22, 24, and 37: Agree, but this would take considerable inter-agency cooperation and a uniform definition of terms, as well as new uniform methodology and training to implement a more stream-lined risk assessment process throughout all public health and environmental health agencies.
    Page 22
    “Timely revision of guidance documents on risk assessment… Training of risk assessment staff as needed in order to implement the rivised methodologies, including guidance on working effectively and compassionately with exposed communities…”
    Page 24
    “Developing a single system or portal to track all potentially harmful chemical substances would greatly assist in identifying and addressing the presence of harmful chemicals…”
    Page 37
    “The federal govenment then should create such a s National Registry of significant databases on chemicals and other contaminants and develop a knowledge-based search engine to access data across multiple agencies’ and organizations’ databases…”

    2. Page 27: If a network resource is to be beneficial, it should include input from all states and territories.
    Page 27
    “The Association of Public Health Laboratories (APHL) is working with CSTE and ASTHO to develop a laboratory network called the National Biomonitoring System to create guidelines for state and local participation within a period of five years…”

    3. Page 31: Creating a more specific set of health indicators would help with ATSDR (and state/local health) Health Outcome Data beyond the county level.
    Page 31
    “Creating a standardized national set of health and hazard indicators withhigher geographic resolution than state and county would help localities and federal agencies identify those communities with disproportionately lower environmental health status in order to empower communities to implement targeted interventions.”

    4. Page 32, Ch. 2 Conclusion: Agree, there is a disconnect between physician’s offices and environmental health issues/awareness. Who would be responsible for biomonitoring and follow-up? Where would funding come from for biomonitoring?
    Page 32
    “In order to improve monitoring of chemcial exposures and their effects on public health, then Leadership Council recommends expanding both health outcomes surveillance an dbiomonitoring capacity… Finally, additional diagnostic tools and biomarkers should be develped to expand healthcare providers’ capacity to diagnose and treat harmful chemical exposures and the public helath community’s ability to target interventions where human exposures have been confirmed.”

    5. Page 39, Recommendation 3.8 and Page 40, Ch.3 Conclusion: Agree, ATSDR must receive new methodology for investigating public health, as well as more funding and staff training to implement this recommendation.
    Page 39
    “In recent years there has been increasing public concern about the role ATSDR plays in protecting public health and conducting environmental health assessments in identified communities. Community groups across the country have criticized the limitations of some investigations and studies conducted by ATSDR, NCEH, state health agencies and others in addressing community concerns. The major scientific issue with these investigations is the limited capacity of the methods used to evaluate the public health impacts of community-wide exposures to toxic substances. Research is needed to identify new methods to address exposure…”
    Page 40
    “… Finally, ATSDR staff and cooperative agreement partners in state health departments should receive training and support in implementing thes best practices. Congress should allocate funds to ATSDR to establish this body and ensure the agency and the investigative body should have the capacity and resources to effectively implement this recommendation.”

    6. Page 48, Ch. 4 Conclusion: Agree, but also need to launch a public campaign to make more citizens aware of the government resources they have available to them once public health workers receive training in this capacity (Ch. 5 addresses this, as well).
    Page 48
    “Significant changes to current policies and procedurea are needed to promote health and wellness in environmentally-burdened communities… Finally, to effectively address communities’ environmental health problems and allow them to advocate on their own behalf, it is important to provide resources for strengthening the capacity of tribes, communities, and those who work in parternership with them – government employees, academics, volunteers, and industry representatives.”

    7. Page 56, Ch. 5 Conclusion: Agree, but inter-agency policy needs to provide environmental public health workers with the proper tools and training for better public participation in environmental health issues.
    Page 56
    “Empowering the public to make choices that protect their health depends on improved information, enhanced models of communication, effective means to participate in environmental health decision-making; and the availability of healthy choices. The Leadership Council suggest standardizing, consolidating, and improving the quality of information available on chemicals and chemical exposures, as well as rendering it more easily accessible to the public. It also is critically important to build environmental health literacy among the public and to foster a commitment to life-long learing of environmental health issues. These efforts also will help ensure a ‘pipeline’ of future public health and health professionals, to be discussed in greater detail in the next chapter.”

    8. Overall comment of document: Implementation of better scientific research and methodology is needed to revise and improve risk assessment in the public health arena. Then, provide updated and uniform tools, guidelines, and training to all public health workers within all environmental health agencies to better assess chemical exposures and meet the public’s need for improved quality of life surrounding environmental health issues.

  30. Lynn Henning

    2010 Goldman Environmental Prize

    Thank you for allowing my comments.

    I am a family farmer in Michigan, my concern is CAFO’s. My in-laws have been diagnosed with hydrogen sulfide poisoning. My husband had to have quadruple by-pass at 53 because of emissions. There are 168 chemicals in animal waste in 2001 USEPA report. We are surrounded by 12 CAFOs within a ten mile radius. We have over 60 lagoons with over 400 million gallons of waste being applied untreated on fields, mixed with chemicals and pesticides and antibiotics.

    We must eliminate subsidies to CAFOs, we must eliminate the liquid lagoon systems. All animal waste must be treated before land application. We must go back to a pasture based system as the best available technology. Our resources cannot stand the water usage, fuel usage, environmental damage, or public health damage that CAFOs cause.

    Our local website: http://www.nocafos.org shows over ten years of damage to our community.

    I have over ten years of scientific documentation, please contact me.

    Respectfully submitted,
    Lynn Henning
    2010 Goldman Environmental Prize
    Michigan CAFO Water Sentinel
    Lynn.henning@sierraclub.org
    517-605-7740

  31. William Hunn

    As a concerned voter in the United States I want to demand you MOVE RECOMMENDATION 7.5 TO THE TOP!!!!! IT IS THE ONLY RECOMMENDATION THAT COULD BE ENACTED BY JUST EXTENDING POISON CONTROL THAT IS ALREADY IN PLACE

  32. Constance Biemiller Thomas

    Let us not bury Recommendation 7.5!!!!! This is too important and our Chemical Emergencies Work Group was so very excited about the prospects of this recommendation. We know that we need to expand Poison Control to include a National Clearing House for Chemical Emergencies. Lets make this happen!!!!!!!!!!!!!!!!!!!!!!!!!!! My community was poisoned and we had no one to turn to for leadership or information as to the chemical that was harming us. WE BEG ALL THOSE IN LEADERSHIP TO SEE THE NEED HERE AND THE IMMEDIATE IMPACT THIS WOULD HAVE FOR MILLIONS!!!!!!!!!!!!!!!! DO NOT LET THIS MOMENT PASS!!!!!!!!!! MOVE 7.5 TO THE TOP OF THE LIST!!!!!

  33. Owen David

    New Hampshire Radon Program

    Please include radon gas in the agenda.

    Thanks.

    Owen David MPH
    Radon Program Specilist
    New Hampshire Dept. of Environmental Services
    Radon Program

  34. R. William Field

    University of Iowa, College of Public Health

    Radon health risks should be considered within the agenda. Radon is likely the leading environmental cause of cancer mortality in the United States. Over the past 50 years, over a million people have died because of residential radon exposure. Radon is naturally occurring outdoors, but not indoors. Builders continue to choose to build homes in a manner that traps radon, rather than building homes radon resistant. The recommendations from the President’s Cancer Panel on this issue should be included within the agenda, see: http://deainfo.nci.nih.gov/advisory/pcp/annualReports/pcp08-09rpt/PCP_Report_08-09_508.pdf.
    File: PCP_Report_08-09_508.pdf

  35. Donna Drake

    I request that recommedation 7.5 be moved to the top!!!!!

  36. Brian Toal

    CT Dept of Public Health

    ATSDR’s mandate should be expanded to include non-site specific activities.Many of the most important environmental health exposures are not related to contaminated hazardous waste sites. These exposures include :natural contaminants found in ground water ( Ur,As ,others) ,fish contamination ( both recreationally caught and store bought) , indoor air pollution ( homes ,schools,offices) ambient air pollution and consumer/commercial products ( i.e. Chinese drywall, BPA, asbestos in art products,mercury in rubber flooring …). Many of these issues require applied research/investigation at the state and local level and directed public education at the state/local level .There is no other federal agency that is dealing with these exposures through capacity building of state health departments. ATSDR is well positioned to undertake these activities with their existing scientific expertise and their existing relationships with states and regions.

    I am not sure where this belongs in the report ? Maybe in the Prevention section

  37. Peter Hendrick

    American Association of Radon Scientists and Technologists, Inc.

    The National Conversation on Public Health and Chemical Exposures needs to consider radon gas, a source of ionizing radiation in this program.

    Radon is a colorless and odorless radioactive gas that is produced by the radioactive decay of radium. The EPA estimates that out of a total of is that out of 146,400 lung cancer deaths in 1995, 21,100 (14 percent) were related to radon exposure. Epidemiological studies support this estimate. Radon is the second leading cause of lung cancer after cigarette smoking. Radon exposure is the primary cause of lung cancer in individuals who have never smoked.

    For purposes of this discussion, radon, a naturally occuring gas that produces ionizing radiation, needs to be treated as a toxic chemical by the Centers for Disease Control and Prevention (CDC) and the Agency for Toxic Substances and Disease Registry (ATSDR).
    [file]http://resolv.org/site-nationalconversation/files/2011/02/2009_World Health Org_Radon_Handbook.pdf[/file]

  38. Daniel Steck

    St. John's University

    Reducing residential radon exposure should be high on your agenda. Radon’s death toll is high and, in many cases, preventable. Preventing radon-related lung cancer mortality using current technology and practices is more cost-effective in both existing houses and new construction than most alternative policies like treating the disease.

  39. Preston Rea

    AARST, NEHA

    I am concerned that Radon Gas has not been included as an exposure that has profound health consequences. Radon is a known carcinogen that recieves very little attention from Government and Public Health groups. Please include Radon Gas in the National Conversation on Public Health and Chemical Exposures.

  40. Martin Smith

    US Inspcet, LLC.

    I sincerely hope that radon will be placed on the agenda. Yes, for most Americans it’s “Out of sight and out of mind”, BUT…it is the second leading cause of lung cancer in the United States, AND…the leading cause of lung cancer for non-smokers. It is so important to raise awareness about this silent killer.

    Yes, radon kills. EPA estimates 21,000/year.

    I am continually surprised by the number of citizens that are unaware about the dangers of radon. Not just the general public, but state health officials! Cancer Organizations! Elected Polititions! It’s really a shame.

    Increased awareness means more action/testing, and more action/testing means more reductions in exposure through radon remediation.

    And that means we are saving lives. That’s what it is all about…saving lives.

    Thank you for your time and consideration,
    Martin Smith

  41. Kim Moore

    Thank you for hearing me,

    There are so many great comments here that cover the many inadiqucies in the draft agenda that anything I could say would be redunant. Therefore I want to make it as simple as possible..

    As American citizens we realize we are being poisoned. We realize that these corporations prevent our people from having the protection of our government agencies. We also understand that the time has come to unravel the grip these corportations have on us.

    From our skies to our soils and everything in between please stop the use of these poisons.

    America is Watching!

    P.S. I especially agree with

    Comment #20
    Renee Dufault
    United Tribes Technical College

    Comment #12
    Daniela Kunz

    Comment #4
    Michael Bailey
    People First, California, Orange County Chapter

    and

    Comment #38
    Barbara Rubin

    Thank You

  42. Calvin Murphy

    AARST/Allied Radon Services, Inc

    Radon is the leading cause of lung cancer among non-smokers claiming in excess of 20,000 lives annually. We know how to prevent these needless deaths. Test for radon and fix structures with elevated radon levels. We know how to reduce elevated radon levels in buildings. We just have get them tested and fixed.

    Please see that radon testing and mitigation is included in your plan.

  43. Allen Kent

    As a concerned voter in the United States I want you MOVE RECOMMENDATION 7.5 TO THE TOP!!!!! IT IS THE ONLY RECOMMENDATION THAT COULD BE ENACTED BY JUST EXTENDING POISON CONTROL THAT IS ALREADY IN PLACE!

  44. Gloria Linnertz

    Cancer Survivors Against Radon

    Please accept my comments and suggestions for change in public health policy and concern for the citizens of our nation. With approximately 22,000 people dying in our nation each year with nothing being done to prevent this tragedy, please hear my cry to include radon gas in your action plan to save lives. You may not even be aware of what radon gas is, what it can do or if it is in your home or not. It is a radioactive gas that is a class A carcinogen meaning that it causes cancer–lung cancer–in humans. The only way to know if this silent killer is present in dwellings such as homes, schools, and workplaces is to test for it.

    You ask for suggestions to be made for change. Make the public aware of the fact that radon gas can be present in homes, schools and workplaces. Distribute material on this silent killer just as is done for other toxic substances such as lead. Hold classes to educate the economically disadvantaged on the ease of testing and put pressure on the federal government such as EPA, CDC, Housing and Urban Development Agency and corporate giants such as the National Homebuilders Association and well as politicans and physicans to take a stand on this by ensuring that public housing is safe from high levels of radon gas and that that new homes are built to the standards for reducing radon levels. Don’t allow your agency or other agencies to keep this dirty secret to themselves. Share the facts shown by the World Health Organization and the President’s Cancer Panel with the public and educate them on how to test for radon and where to go to get professional mitigation is the level is elevated. Do this through mailings, media, and news events.

    Take a stand and help prevent the needless deaths of thousands and thousands and thousands of people each year. Do what is right. Don’t be afraid.
    [file]http://resolv.org/site-nationalconversation/files/2011/02/appendix F.doc[/file]
    [file]http://resolv.org/site-nationalconversation/files/2011/02/radon cancer table by bill field.pdf[/file]
    [file]http://resolv.org/site-nationalconversation/files/2011/02/Bill Field Presidents cancer panel slide show.pdf[/file]

  45. Larainne Koehler

    Radon is an air toxic; one of the largest environmental cancer risks; a significant problem in indoor air;a burden on low income communities which do not have resources to mitigate this risk. Radon fits in multiple categories covered in this agenda, yet it appears to be overlooked. This agenda should be amended to include the need to address this important chemical public health exposure.

    See for example the President’s Cancer Panel Report for recommendations
    http://deainfo.nci.nih.gov/advisory/pcp/annualReports/pcp08-09rpt/PCP_Report_08-09_508.pdf

  46. Julio Gonzales

    Vietnam Veterans

    It is time to continue the research on ALL of the CHEMICALS used during the VIETNAM WAR not just AGENT ORANGE!

    Vietnam Veterans continue to pay EVERYDAY for the exposure of these CHEMICALS.

    Lets not forget those of us who served our Country during a troubled time.

  47. Bill Goebel

    Heartland Chapter of American Assoc. of Radon Scientists & Technologists

    I have 2 customers who have lung cancer and have never smoked. They have mitigated their homes but the damage is already done for them but there are so many others who have not heard about radon. The 20,000 plus people nationwide who have died from radon-induced lung cancer should be a major reason to have this issue brought to light. My state has some of the highest incidence of radon in homes with 50-70% having too high levels.

  48. Cindy Barg

    Fracking for natural gas, Chemtrails, Oil Spills, Toxic Chemical Dispersants, Toxic Waste Dumping, Poisonous Insecticides, leaking pipelines…the list goes on and on as do these unethical practices and events.

    The battle for green energy and alternative fuels is on…we need your help to save this planet from total destruction and fast!!

    You all know it, now do something about it!!

    You like trees don’t you?

    You like nature don’t you?

    Politics should not be controlled by major industry, it’s time to get back to reality before the damage is irreversible.

    We have just one chance to reverse decisions, to reverse policies but time is not on our side.

  49. Carol Carver

    Starting at the beginning of Chapter 1, second paragraph is a summary that should include hampered by….”insufficient communication of what is of concern, to the public” together with other issues listed. Public access to info is listed on p. 18 but should be a part of this initial summary also. On p.15 on the featured recommendation could be added ” and dessimination of info to the public to help engage market forces.”

    p,17 add in paragraph beginning with “furthermore”….Should be paid for by industry.

    p.18, use of abbreviation PBT without explanation

    p. 18 and 19 recommendations and narrative refer to “exposure to children”–should include pregnant women and fetuses. P. 19 narrative describes children as “uniquely vulnerable” but does not explain why they are. AS I READ THE ENTIRE DOCUMENT I ASKED MYSELF IF IT WOULD BE UNDERSTANDABLE TO LEGISLATORS OR THEIR AIDES, hence this request for explanation. with this in mind through out the document I’d suggest one more edit to make sure the first agency and chemical abbreviations are used, they are completely written out. Maybe the doc includes and I missed it, a list defining all the abbreviations.

    p.22 under priority actions, for sake of impressing readers that you are not going to re-invent the wheel, a number “6″ could be added to include use of information already compiled through European/ REACH process–document refers to this later on p.23 but I think it should be listed as a priority action.

    I LOVE recommendation I.9 p.23

    p. 27 ASTHO abbreiviation is used I think for the first time and not defined

    p.35 I assume the OECD listed is a European organisation, based on the “s” spelling of org–it would strenghten the document to clearly point out that this is collaboration with a European effort already under way.

    p.37 Recommendation 3.4 should be the FIRST recommendation, not an “additional” one

    p.49 first paragraphs used the word “actors”. I would substitute “resources”. “Actors” seems like a weak almost derogatory noun.

    Thank you for such a monumental undertaking. I wish it could be implemented in warp speed. Blessings on this effort.

  50. Richard Sedlak

    American Cleaning Institute

    Overall, while comprehensive in scope, the Action Agenda contains too many recommendations such that the likelihood of action on any single recommendation is probably very low. Therefore, the American Cleaning Institute® (ACI) recommends that the Leadership Council further consolidate the recommendations and prioritize them based on the benefits of moving forward on each specific recommendation. Absent this, there is less likelihood that the “conversation” could move on to “action.” Instead, the “conversation” will continue, and continue in a wide array of other forums that wouldn’t have the focus of this current effort.

    Recommendation 1.1

    The text supporting Recommendation 1.1 cites consideration of hazards, uses and releases and risks in assessing chemical alternatives. However, the recommendation statement itself only references hazard perspectives: “Federal, state, tribal and local government agencies should promote the substitution of hazardous chemicals with less toxic alternatives through use of policy incentives, investment in research and development, and enhanced efforts to develop effective hazard screening methods.” This recommendation overlooks other considerations in alternatives assessment. Therefore, the recommendation would be improved by revising it to state:

    “Federal, state, tribal and local government agencies should promote the substitution of (delete: hazardous) chemicals with (delete: less toxic) alternatives [insert: that pose lower risks] through use of policy incentives, investment in research and development, and enhanced efforts to develop effective hazard [insert: and risk] screening methods.”

    Recommendation 1.5

    Recommendation 1.5 is a good recommendation (NIOSH and OSHA should improve worker protection from chemical exposures by strengthening health-based exposure recommendations, improving hazard communication, and encouraging adoption of a chemicals management systems approach to purchasing, using, and disposing of chemicals.) However, within the text of the supporting information for this recommendation is the statement: “Full disclosure of a product’s chemicals composition, without confidentially exemptions, should be required.” Consistent with the recommendation, existing hazard communication requirements already mandate disclosure of a workplace product’s hazard and the chemicals in such products that contribute to that hazard. Disclosure of all the ingredients, including non-hazardous ingredients, does not enhance hazard communication or protection. In addition, it is important that the principle of protecting innovations be respected in the Action Agenda and the right to protect confidential business information be maintained. Therefore, this sentence should be removed from the draft Action Agenda.

    Recommendation 2.2

    Recommendation 2.2 is good recommendation (CDC/ATSDR, EPA, OSHA, state and local governments and academia should expand biomonitoring capacity and use population-based biomonitoring data as a tool to set priority strategies to reduce harmful levels of environmental chemicals identified in people.) However, the following statement in the supporting text for this recommendation presents a detail regarding how to proceed to take action on the recommendation that could create a bottleneck to progress, namely: “Necessary changes include . . . developing new laboratory methods and expanding capacity to measure locally the more than 3,000 chemicals used in high volume in the U.S. . . .” This detail, calling for new laboratory methods and capacity to measure all high volume chemicals in the U.S., apparently presumes there could be “harmful levels” in the environment for many of them. This poses the prospect of significant resources being diverted from work on chemicals that have higher probability to cause harm to what could be a wide range of chemicals that pose no harm. The better course of action would be to examine approaches currently used by CDC and others to prioritize chemicals for biomonitoring, including the development of methods and capacity to measure for them, assess if there are any deficiencies in the prioritization approaches, and, if necessary, change the approaches. However, the more fundamental change would be to recognize that prioritization of the work is critical to making progress. Therefore, ACI recommends that the phrase be modified to: “. . . developing new laboratory methods and expanding capacity to measure locally the (delete: more than) [insert: priority chemicals among the] 3,000 chemicals used in high volume in the U.S.”

    Recommendation 5.2

    While the recommendation that improvements could be made in how information on chemicals is made available is good, the supporting text for the recommendation presents erroneous statements about the status of requirements for labeling and fails to recognize some of the efforts to improve the situation.

    The statement that “. . . labels are often incomplete, misleading, or unnecessarily complex . . .” is contrary to the present state of the market, where products are labeled in compliance with their applicable regulations, including FTC, CPSC, OSHA, and FDA labeling regulations. Labels that are incomplete, misleading, or unnecessarily complex to the point that they are misleading when compared to the requirements of the law are in violation and should be addressed by enforcement of existing regulations. As such, this phrase is not relevant to the recommendation and should be deleted.

    Further, the statement “For many products, there is no requirement to make any chemical ingredient information available” is misleading. There are federal requirements that mandate circumstances under which information on ingredients must be provided, such as under the FHSA regulations enforced by CPSC and the Hazard Communication Standard of OSHA. These two systems require hazardous ingredients to be identified in products determined to be hazardous. This sentence should be deleted or, at a minimum, revised to reflect the existing law.

    The text also identifies a few initiatives that could serve as “models for a national effort.” The examples provided appear to be works in progress. At a minimum, models that are already up and running should be cited. For example, ACI is supporting the “Consumer Product Ingredient Communication Initiative,” which is an ingredient communication initiative providing consumers with information about the ingredients in products in four major categories: air care, automotive care, cleaning, and polishes and floor maintenance products (http://www.cleaninginstitute.org/ingredientcentral/). This initiative provides meaningful information on ingredients to consumers in a consistent, easy-to-understand manner. The intent is to help consumers make informed decisions about the products they use in and around their homes. Participation has been high. For example, within a short time after its launch at the beginning of 2010, 99% of the cleaning products purchased from ACI’s members were compliant with the initiative. Given that it is an existing, effective program, ACI recommends it be noted by a new sentence right after the sentence identifying the California, Michigan, and DfE programs under development, as follows: “There are also existing industry initiatives, such as the “Consumer Product Ingredient Communication Initiative.”

    The following sentences are very unclear:
    “Another important aspect of this approach is requiring that all consumer products and articles list the chemicals that remain in the product in sufficient quantities on the label. This change could fit within the framework of the Fair Packaging and Labeling Act, which states: ‘Packages and their labels should enable consumers to obtain accurate information as to the quantity of the contents and should facilitate value comparisons.’”

    Do these sentences refer to residual amounts of a product that remains in a product container after use? If so, it is inappropriate to suggest the FPLA could be used as a basis for requiring labeling for this situation. The “quantity of contents” being referred to in the Act is the quantity at point of purchase. Further, studies have shown that the residuals amounts of many consumer products remaining in containers do not impair post-consumer recycling or waste management.

    Finally, referring to the sentence:

    “Efforts should be undertaken to amend consumer protection legislation to require dissemination of information to consumers on the chemicals that could present potential hazards in consumer products.”

    The current consumer protection laws, such as those under the FHSA, lead to consumers having access to comprehensible, actionable information to properly handle and use consumer products. Built on a requirement that products be assessed by considering both the hazards of the ingredients and the finished product and the exposure during use, consumers receive warnings of hazards and recommended precautions that they should take in order to avoid the likelihood they or their families would be harmed. Calling for the addition of information to labels that detracts from critical warnings and precautionary statements opens the door to labels that are less comprehensible, less actionable, and, therefore, less protective. This sentence should be deleted.

  51. Michael Walls

    American Chemistry Council

    [file]http://resolv.org/site-nationalconversation/files/2011/02/ACC National Conversation Comments 1 20 2011.pdf[/file]
    [file]http://resolv.org/site-nationalconversation/files/2011/02/National Conversation Comments_092710 FINAL.pdf[/file]

  52. Mary Lamielle

    National Center for Environmental Health Strategies

    January 21, 2011

    Dear Ms. Witherspoon, Dr. Anderson, and Members of the Leadership Council:

    Thank you for the opportunity to provide comment on the Leadership Council’s draft Action Agenda for the National Conversation on Public Health and Chemical Exposures dated December 20, 2010. I am commenting on behalf of the National Center for Environmental Health Strategies. I was a member of the National Conversation’s Education Work Group. I also organized a Community Conversation and provided public comment at the Leadership Council meetings on October 5 and December 15, 2010. I attended the meeting on December 15. I was unable to attend the October 5 meeting in person due to the use of pesticides throughout the hotel where the meeting took place.

    Recommendation 3.5 Improve understanding of individual susceptibility to chemical exposures.
    Although I enthusiastically support the goals of the National Conversation, I was shocked and dismayed to find that the Individual Susceptibility Task Group’s research recommendations on chemical sensitivities/intolerances had been gutted by the Leadership Council. I urge members of the Leadership Council to restore the language of the Individual Susceptibility Task Group or the language following edits performed by staff prior to revision by the Leadership Council. Section 3.5 recommendations that were deleted by the Leadership Council include: (1) research on the mechanism by which people develop intolerances or sensitivities following chemical exposures, (2) development of an Environmental Medical Unit for the clinical investigation of chemical intolerance, and (3) population-based studies of chemical intolerance among exposed groups using a validated questionnaire such as the Quick Environmental Exposure and Sensitivity Inventory (QEESI).

    As I indicated during the public comment period at the December 15 Leadership Council Meeting, there is no one on the Leadership Council, the group charged with writing the Action Agenda, knowledgeable about or with expertise on chemical sensitivities/intolerances. Familiarity is not expertise. No one on the Leadership Council actively participated in any of the federally sponsored government or professional meetings over the last eighteen years. This is clearly an area where a ‘little knowledge is a dangerous thing.’ If this is not done, more questions will be raised about the lack of transparency in this process because some members of the Leadership Council have indicated that these edits did not take place at meetings of the entire group yet no one has taken ownership of the edits.
    The Leadership Council’s responsibility is to act in the best interest of the public and those individuals already harmed by chemical exposures. Those populations with chemical intolerances resulting from toxic exposures are significant in number. Research to illuminate the connection between exposure and disease process through an environmental medical unit is critical.

    When the staff version is reinstated, I would recommend that the “interdisciplinary group” include “representatives of affected communities and patient groups” as noted in the original recommendations of the Individual Susceptibility Task Group and consistent with the multidirectional perspective endorsed by the Education Work Group.

    I also wish to comment on Recommendation 3.7 as follows.

    Recommendation 3.7: Identify adverse health effects from indoor air pollutants, including mold and mycotoxins, and improve scientific knowledge of these effects with a focus on the linkage to neurologic, mental health, endocrine and immunologic diseases.
    “People with chemical sensitivities/intolerances and/or those previously harmed by chemical exposures” should be specifically identified as populations of concern in the initial sentence of this section: “Given growing concern over prenatal exposures and exposures to children, the physically compromised, the elderly, people with chemical sensitivities/intolerances and those previously harmed by chemical exposures,…”

    According to the “Indoor Environmental Quality Project Report” published by the National Institute of Building Sciences with funding from the U. S. Access Board (www.access-board.gov/research/ieq), people with chemical sensitivities are disabled by exposure to indoor contaminants. The report identified two dozen recommendations for improving indoor environmental quality. These specific research recommendations should be considered by the Leadership Council. I would also recommend research on toxic ingredients in fragranced and scented products including cleaning and maintenance products which contribute significantly to indoor pollution. Such research would further support promulgation of the CDC Fragrance Free Policy across federal agencies and for public buildings.

    I would recommend that this section support the creation of an Interagency Committee on Chemical Sensitivities/Intolerances comprised of federal representatives from research, regulatory, and disability agencies together with physicians, indoor air experts, patient advocates, and others to review what has been done to address this issue, identify the policy and research gaps, and develop a plan of action to address these public health problems in a timely and professional manner that involves impacted populations and responds to their needs.

    I would offer several general comments:
    The terms “vulnerable”, “vulnerable and susceptible”, “at risk” and “affected communities” are used repeatedly throughout the document. I recommend that the term “vulnerable” be defined to include “people with chemical sensitivities/intolerances” and “those previously harmed by chemical exposures” and be expanded to include these groups when the term is used in the report.

    Whenever the phrases “marginalized communities” or “affected communities” are used, they should be changed to read “marginalized communities and populations” (Page 8 or 71; 14 of 71; 58 of 71; 59 of 71; 62 of 71) or “affected communities and populations” (30 of 71). “Communities” suggest groups that have a common geography but exposed or impacted populations can have other things in common aside from geographic location.

    “Access to information” (page 47 of 71):

    The discussion on “access to information” does not do justice to the many ways that internet-based information fails to reach the public and particularly those who may have some of the most critical need for information on public health and chemical exposures. The report fails to acknowledge limitations due to economics, literacy, language barriers, and the ability to use computers, including those with health problems who are not well enough to spend time on computers, or those with chemical and electrical sensitivities/intolerances who do not tolerate computers due to out gassing volatile chemicals and/or electromagnetic exposures.

    General Comments on the Process:

    The National Conversation has worked against recommendations to address those who have been significantly damaged by toxic exposures but whose health problems have not been addressed by the federal research agencies. While there has been a pretense of inclusion with token representatives on two of the work groups, failure to include anyone with expertise on the Leadership Council doomed this process as a possible means of addressing issues which have been ignored or neglected by the federal government for decades. I know in my own experience with the Education Work Group that my recommendations regarding people with chemical sensitivities/intolerances were repeatedly rejected by the Work Group leader as well as one or two individual members. Again, lack of understanding and a biased paradigm have led to rejection of a public health problem that should be a central issue of the entire project.

    Those disabled by low level exposures lead lives of quiet desperation. They feel hopeless and will be angered that the same federal government charged with protecting the public health has again left out recommendations that promise any elucidation of this complex problem. We played your game including organizing a community conversation, but none of those comments ever made it to the summary offered to the Leadership Council.

    I hope that the three specific research recommendations in section 3.5 make it back into the Leadership Council’s Action Agenda so that what happens next is a push to fund specific research in this area and not the need to find out why one more process worked against reasonable research recommendations to illuminate the nature of chemical sensitivities/intolerances and determine ways to protect the public and address the health of people already sick from toxic exposures.

    Please feel free to contact me at marylamielle@ncehs.org or (856)429-5358 for further discussion.

    Sincerely,

    Mary Lamielle, Executive Director
    National Center for Environmental Health Strategies

    Staff Version Before Revision by Leadership Council:
    Recommendation 3.5: Improve understanding of individual susceptibility to chemical exposures.

    A better understanding of variations in individual susceptibility, including of children, the aged, and the health compromised and those who develop intolerances following well documented exposures to chemicals, may yield targets for prevention and treatment. The results of improved data collection and research, for example through working with targeted groups such as veterans suffering from Gulf War Illness, have the potential to benefit those with more common conditions such as asthma, autoimmune diseases, and neuropsychological disturbances that may share the same underlying mechanism. Information is needed on the prevalence and incidence of chemical intolerance in exposed and unexposed groups and individuals, along with identification of individual risk factors for susceptibility. This could include assessing symptoms and intolerances pre- and post-illness and at baseline and at serial points following exposures. Researchers should foster collaboration toward interdisciplinary research, including epidemiological, clinical, and animal studies, on individual susceptibility among relevant governmental agencies. Agencies such as the CDC should investigate the feasibility of incorporating a scalable, validated and reportable statistical instrument into exposure and community investigations. A interdisciplinary group comprised of scientists from federal agencies, the public and practitioners experienced in the practice of “exposure medicine” should develop and implement a research agenda on chemical intolerance that includes the impact of all forms of exposure including consumer product selection, and vanguard research facilities should be based in hospitals and clinics for the systematic investigation of individual differences in response to chemical and mold exposures.

    Original recommendations of Individual Susceptibility subgroup:

    Recommendation 7. Improve understanding of individual susceptibility to chemical exposures.

    Recommended actions: Improve the understanding of individual susceptibility and chemical intolerance through improved data collection and research. Specific recommended actions include:

    In the next year:

    1) Investigate the feasibility of incorporating a scalable, validated and reportable statistical tool, such as the published Quick Environmental Exposure and Sensitivity Inventory (QEESI) instrument into Centers for Disease Control and Prevention (CDC)/Agency for Toxic Substances and Disease Registry (ATSDR) exposure and community investigations (Miller & Prihoda, 1999)[1].

    2) Create an interdisciplinary group to develop and implement research on chemical intolerance. This could include CDC/ATSDR, U.S. Environmental Protection Agency (EPA), National Institutes of Health (NIH)/National Institute of Environmental Health Sciences (NIEHS), National Institute for Occupational Safety and Health (NIOSH), U.S. Food and Drug Administration (FDA), the public, and practitioners, as a first step toward establishing an NIH office/department/branch focusing on environmental medicine.

    3) Assemble an Environmental Medical Unit (EMU) planning group that includes physicians experienced in the practice of “exposure medicine,” as a prelude to implementing an EMU.

    4) Encourage federal agency support of investigations that include the impact of individual choices (e.g., consumer product selection, diet, etc.) on personal exposures and individuals’ health.

    In the medium term (next two to three years), recommended actions include: 1) prepare EMU design and engineering specifications, operations manual, and clinical research protocols; 2) estimate project costs for construction, staffing, and operation of EMU including direct research cost estimates per patient/day; and 3) identify private and public sources of support for sustained EMU operations including funding for EMU-based research.

    Longer term actions include the construction and staffing of a prototype EMU, followed by EMU-based research.

    Current status of issues under consideration: Chemical intolerance is disabling for 2-6% of the U.S. population and results in major medical costs and loss of productivity (Caress & Steinemann, 2004; Kreutzer, Neutra & Lashuay, 1999). Approximately 15-30% of Americans report adverse reactions to particular chemical exposures. Groups of individuals in more than a dozen industrialized nations report experiencing multisystem symptoms and new-onset intolerances to structurally diverse chemicals following an identifiable exposure event. However, little is known about prevalence, incidence following exposure events, and individual risk factors for chemical intolerance.

    Interdisciplinary research that integrates exposure science and medicine is lacking. There are no appropriate research facilities in the U.S. for the controlled investigation of physiological responses to low-level chemical exposures. Known as EMUs, these research facilities have been a priority recommendation from multiple professional and scientific meetings for more than a decade and are considered critical to advancing our understanding of individual susceptibility (Ashford & Miller, 1998; Association of Occupational and Environmental Clinics, 1992; Miller et al., 1997; National Research Council, 1992). An EMU is an inpatient hospital facility designed to reduce exposures by all routes, in order to allow patients to achieve a “clean” baseline, or “unmasked state.” Researchers can determine the extent to which illness improves with avoidance of potential environmental triggers, and conduct double-blind, placebo-controlled challenges using every day, low-level exposures in the absence of background chemical “noise.”

    Desired outcomes and implementation:

    • A better understanding of individual susceptibility, e.g., children, the aged, and the health compromised, and how it could improve our understanding of community susceptibility.

    • A unifying explanation/theory/mechanism of disease, TILT is the distillation of world-wide observations of exposed groups and individuals who develop intolerances following well-documented exposures (Ashford & Miller, 1998). TILT provides a framework for basic and translational research on individual susceptibility which may yield targets for prevention and treatment. These results, obtained through working with chemically-intolerant individuals, including priority groups such as veterans suffering from Gulf War Illness, have the potential to benefit groups with more common conditions such as asthma, autoimmune diseases, and neuropsychological disturbances that may share the same underlying mechanism.

    Establish prevalence and incidence of chemical intolerance in exposed and unexposed groups and individuals and pre- and post-illness by assessing symptoms and intolerances at baseline and at serial points following exposures. Identify individual risk factors for susceptibility. Foster collaboration toward interdisciplinary research, including epidemiological, clinical, and animal studies, on individual susceptibility among relevant governmental agencies. Plan, create, and sustain vanguard research facilities based in hospitals and clinics for the systematic investigation of individual differences in response to chemical and mold exposures.

    Professional evaluation and tracking of this endeavor is necessary and should follow an accepted framework, e.g., CDC’s Framework for Program Evaluation in Public Health (1999), with emphasis on stakeholder involvement at every phase.

    Throughout the process, key stakeholders should be involved in an open dialogue to ensure that research programs are translational, leading to research projects with clinical relevance. This should include representatives of affected communities and patient groups, experienced occupational and environmental medicine and other medical practitioners, academic researchers, and various governmental agencies including CDC/ATSDR, NIH/NIEHS/NIOSH, EPA, FDA, health insurance companies, and others as relevant.

  53. Cindy Lynn Richard

    Occupational and environmental health professional

    Regarding draft recommendation 1.5:

    Standardization or uniformity of hazard communication information for the purposes of completeness, consistency, ease of accessibility, transparency, and comprehension would be far better served by the combined approach to labels and warnings (Safety Data Sheets and Bulletins) articulated in the new ANSI guidance on labels and warnings [ANSI Z400.1/Z129.1-2010] than by United Nations’ Globally Harmonized System of Classification and Labeling of Chemicals (GHS). While the GHS’s use of standard language facilitates translation into many languages at a more affordable cost, it does not communicate hazards in manner that even experienced professionals find easily assessable in emergency situations. Also, this system does not address risk; only hazard.

    We currently rely on multiple tools for communicating hazards and risks, which address the level of detail and urgency necessary to the situation. Department of Transportation (DOT) placards in combination with the ANSI style Safety Data Sheets provide consistent and complete emergency response information. Both ANSI’s guidance and OSHA’s proposed updates to the Hazard Communication Standard provide information through labels, SDSs and the use of additional communication materials [FR 74: 50280]. ANSI’s 2010 guidance document provides for greater consistency in organization and content between various manufacturers. OSHA’s proposed updates include additional measures to communicate warnings more effectively; such as (1) pictograms, (2) hazard statements for each hazard class and category, and (3) training for workers regarding new warning symbols and revised Safety Data Sheets. These materials (DOT, ANSI and OSHA) are more intelligible and provide opportunities to address risk in addition to hazard. Therefore, emergency responders, workers, employers, and consumers can make better decisions regarding exposure and risk utilizing these tools over the GHS approach.

    References:
    ANSI Z400.1/Z129.1-2010 Revision, redesignation and consolidation of ANSI Z400.1-2004 and ANSI Z129.1-2006. American national Standard for Hazardous Workplace Chemicals – Hazard Evaluation and Safety Data Sheet and Precautionary Labeling Preparation. American National Standards Institute. Approved 28 May 2010.
    Occupational Safety and Health Administration. Hazard Communication: Proposed Rule. Federal Register, volume 74, number 188, Wednesday, 30 September 2009: 50280-50328.

  54. Trudy Smith

    Spruce Environmental Technologies, Inc.

    Radon is the number 1 environmental health risk in the U.S. killing over 21,000 people every year. It is the number 1 environmental cause of mortality and needs to be a top priority in any discussion on public health exposures especially for citizens in their homes.

  55. Tom Krohmer

    Environmental Technologist

    The Operating Procedure of Modern Medicine and Health Care
    By The Tom Krohmer, Environmental Technologist
    aka
    The Toxic Reverend
    http://twitter.com/toxicreverend

    Abstract:

    A Congressional Report in the May of 2000 shows that less than 6%
    of the known 1,400 chemicals that threaten human health are tracked
    with regard to chronic illnesses and cancers (8) as reported in a
    Los Angeles Times newspaper story (9).

    As an Environmental Technologist I can not imagine a health care
    system that could be viable when it ignores toxic chemical exposures

    This review also cites resources and suggests solutions to the political
    interferences that influences the scientific integrity of several
    government agencies, private and public universities, corporations
    and our entire health care system.

    Main text:

    The paradigm of singular cause and effect with respect to chronic illnesses
    is outdated. Unfortunately, the training of health care professionals has not
    caught up with such research.

    Specifically, doctors are not given enough training in the nutritional aspects
    of good health. And even less with regard to the impact toxic chemical exposures.
    The various responses of a patient immune system to infectious agents can be
    influenced by both nutritional factors and toxic chemical exposures.

    As an example, “Multiple Combination’s” that applies to The Toxic Lotto,
    with regard to chemical exposures, infectious agents, radiation exposures
    and genetic as well as epigenetic responses, that can be modified with

    Nutrition for the Epigenome.

    How ever, the nature of some infectious agents like mycoplasma’s, have not been taught

    to docters for a couple of decades. But mycoplasma’s have been studied and genetically

    modified as a “Non-Lethal Biological Weapon” that is also known as an “Incapacitating Agent”.

    Some of the information about this was discussed during an International radio interview

    that was also broadcast to over 500 American cities with over 15 million listeners, on

    September 18, 2010. A link to the Coast To Coast AM Talk Radio Show that was titled

    “Toxic Effects” is posted with an overview at my blog of September 18, 2010 at:

    http://toxicreverend.blogspot.com/2010_09_01_archive.html

    The audio of the Coast To Coast Toxic Effects show is also archived at

    http://www.coasttocoastam.com/show/2010/09/18

    Physicians are not given adequate training in nutrition nor toxicology to
    really address either issue. And even when a patient is referred to a toxicologist,
    it is usually for evaluation of singular exposures and the cumulative effects of
    multiple exposures are not considered as causing a variance in the tolerable
    levels. More over, a patients response to chemical exposures can vary according
    to their nutritional health “combinations”.

    This perspective of “cross training” is also applicable to other aspects of
    improving the health care system.

    For instance, the Chief Executive Officer of the majority of pharmaceutical
    companies have no real medical training and are most often only have a
    background in finances.

    This is also true of many of the managers in the Food and Drug Administration
    that over see the work of the FDA’s scientists and researchers. The “political
    influences” on decisions made by government agencies have been well documented
    as a “corrupting force” on the decisions rules and regulations of the EPA, FDA and
    far too many other government agencies to list, here. But this issue alone is so
    obvious and important that I am citing the combined work of over fifty Nobel
    Laureates, with Academy of Science Award Winners and thousands of the worlds
    best scientists that have all signed onto the Union of Concerned Scientists
    “Integrity In Science” program.
    http://www.ucsusa.org/scientific_integrity/

    The basic overview given is (and I quote);

    Political interference in federal government science is weakening our nation’s
    ability to respond to the complex challenges we face. Because policy makers
    depend on impartial research to make informed decisions, we are mobilizing
    scientists and citizens alike to push for reforms that will enable our leaders to
    fully protect our health, safety, and environment.

    The Union of Concerned Scientists have also posted the
    The A to Z Guide of Political Interference in Science
    http://www.ucsusa.org/scientific_integrity/abuses_of_science/a-to-z-guide-to-political.html

    As well as “Agency-specific Solutions”
    http://www.ucsusa.org/scientific_integrity/solutions/agency-specific_solutions/

    Additionally, a report by the National Research Council and the Institute
    of Medicine and commissioned by Sen. Herb Kohl (1), said the agency
    is hamstrung by limited resources and gaps in research-gathering and
    information-sharing.

    “The report sheds light on the reasons that, despite FDA’s commitment to
    keeping our food supply safe, we still see hundreds of thousands of cases
    of serious illness each year caused by food-borne contamination. It’s a
    useful guide on how we can improve and modernize our food safety system.
    While some of the recommendations are already under way at FDA, this
    report provides clear goals we can all work toward,” said Kohl, who is the
    chairman of the Senate Agriculture Appropriations Subcommittee, which
    has jurisdiction over funding for the FDA.

    How ever, the report (1) does not appear to address the “political influences”
    of what has been termed “the revolving door” from large corporations and
    their executives into many of the high ranking administration offices of our
    government, in Washington DC. From the National Institute of Health to the
    Food and Drug Administration and beyond. In fact, there are some aspects
    of the report (1) that cause it appear to be more of a “White Wash” of the
    real causes and conditions of “The Revolving Door”.

    “The revolving door” is easily shown with an Internet http://www.google.com search
    term, “revolving door Washington DC drugs chemical companies”.
    For one explicit example that concerns current events, there is the situation
    of the nine current and former FDA medical device reviewers alleging that
    the agency managers improperly overruled their opinions with regard to the
    safety of medical X-ray devices (2). Of which is also applicable to air port
    scanning devices and the consequent “money trail” (3). As well as the
    “Money Trail” of Who is Who in the toxic chemical war of our health (4) that
    allowed industries to influence the collapse of the overhaul of the 34-year-old
    Toxic Substances Control Act (TSCA) to make it easier for EPA to take
    dangerous chemicals off the market and ensure that the substitutes are safe (5).

    The FDA whistleblowers point to multiple occasions in which managers overruled
    their rejections of medical scanners, without properly documenting the reason,
    as required by FDA regulations. At least three of the whistleblowers have left
    the agency in the last year, saying their contracts were terminated after they
    sent letters of complaint to Congress, the administration and other outside groups.

    One of those whistleblowers, Dr. Julian Nicholas, said he has never been interviewed
    by the inspector general’s office. Nicholas, an Oxford-trained intestinal specialist, said
    that his contract as a medical reviewer was terminated after he repeatedly opposed
    approving a CT scanner for routine colon cancer screening. Nicholas said that he
    objected to exposing otherwise healthy patients to the cancer risks of routine radiation
    scans.

    Dr. Julian Nicholas has been quoted as saying;
    “It’s hard for me to believe this was a bona fide investigation when they haven’t even
    contacted the people who reported these violations,” said Nicholas, now a practicing
    gastroenterologist at the Scripps Clinic in San Diego. “Such a huge amount of money
    is at stake and so many people are affected, that for the (office of inspector general)
    not to conduct a credible investigation is criminal in itself (2)”.

    How such “political influences” that corrupt our government agencies are well
    explained in a short Youtube video (6) by a couple of ex-FOX News Investigative
    Journalists that were “forced out” of their jobs after attempting to expose corruption
    in the FDA decision making process with respect to the bovine growth hormone,
    (or BGH) that is injected into cows and the impacts on human health. The
    documentation that exposes this alleged “cover-up” is also posted by the same
    journalists at their web page about it (7). The Youtube Video by Steve Wilson
    and his wife gives a simplistic overview of the multiple government agencies,
    university professors, lawyers, news organizations and others, that participated
    in the “disinformation” of BGH by the Monsanto Corporation (7).

    There are too many other examples to list
    and cite in this manner. But the same “techniques” have been used with other
    drugs and chemicals that directly effect the overall health care system.

    It is not my intention to pick out one example of the “Reckless Operation of
    a Corporation” (7). There are far too many example both in and out of the
    health care industry to cite. As well as the “Confidentiality Agreements” (7) that
    are also used in other similar scenarios, contracts as well as out of court settlements.
    A rather long list of “reckless operation of corporations” that have resulted in
    “Negligent Homicides” is documented in a censored report titled:
    Skeletons in the Courthouse: April 2002 by the Coalition for Consumer Rights
    I do have a copy of that PDF report posted as a free download at:
    the Toxic Revelations subpage:

    American Roulette – Red Collar Crime
    “Forget the revolver. We use products and services”
    (work in progress)
    http://sites.google.com/site/toxicrevelations/red-collar-crime—american-roulette

    Multi-Agency Specific Solution:

    Presently, the has been legislation under consideration that will weaken the
    “Whistleblower Protection Laws”. While this is being ignored in the major news
    media, the Whistleblower Protection Enhancement Act (S. 372) has more
    than just the potential to make a bad situation even worse. The Project on
    Government Oversight (10) has been following the legislation (11) that has
    been slightly reported in some news agencies and explained simply (12).

    Other countries do have another solution for this:

    Example:

    In China, two men sentenced to death
    in milk scandal
    By Maureen Fan, Washington Post / January 23, 2009
    http://www.boston.com/news/world/asia/articles/2009/01/23/in_china_two_men_sentenced_to_death_in_milk_scandal/

    China executed the former head of its
    State Food and Drug Administration
    on Tuesday, the official Xinhua News Agency
    reported. Jul 10, 2007
    Zheng sentenced to death in May for
    taking bribes to OK substandard drugs
    http://www.msnbc.msn.com/id/19686498/ – 48k

    Just for the record, I am against the death penalty.
    But you do have appreciate the contrast of how we
    rarely ever prosecute such things in the U.S.A.
    It is more like we prostitute rather than prosecute
    such criminals. I’ll get deeper into that perspective
    at the American Roulette page that is linked in below.

    The district attorney that convicted Jeffrey Dahmer also convicted ten
    corporations of negligent homicide (162). While I have been investigating
    why this is so rarely done, I have found another disturbing fact.

    Increasingly, non-prosecution and deferred prosecution agreements
    have become the settlements of choice for prosecutors and corporate
    defense attorneys.

    And yet this trend to not criminally prosecute corporate criminals
    to conviction is the subject of little serious scrutiny by corporate
    crime defense lawyers, reporters, and law school professors.

    The basic concept to stopping the political influences from corrupting
    our political system and government agencies must be based on “accountability”.
    There is need for legislation to impose mandatory criminal charges and
    sentencing of corporate executives for the “Reckless Operation of a
    Corporation”.

    Please note this article titled;

    Crime Without Conviction: The Rise of Deferred and Non Prosecution Agreements
    By Russell Mokhiber Editor of Corporate Crime Reporter December 28, 2005 and posted at
    http://www.corporatecrimereporter.com/deferredreport.htm

    Reference material:

    1: Report calls for FDA overhaul
    Kohl committee investigating ways to make foods safer
    By McClatchy News Service, Journal Sentinel staff June 9, 2010
    http://www.jsonline.com/news/95922174.html

    2: Feds Dismiss Misconduct Claims At The FDA
    CBS News November 9, 2010
    http://dfw.cbslocal.com/2010/11/09/feds-dismiss-misconduct-claims-at-the-fda/

    3: Money Trail of Airport Body Scanners
    Source:
    Government gropers at airports a ruse for body scanners coming to schools and malls
    By Doug Hagmann Monday, November 15, 2010
    http://canadafreepress.com/index.php/article/29959

    4: “Money Trail” of Who is Who in the toxic chemical war of our health
    Source:
    Chemical ‘Warfare’: Who’s Who and What’s at Stake
    By Sheila Kaplan, Politics Daily November 2010
    http://www.politicsdaily.com/2010/10/13/chemical-warfare-whos-who-and-whats-at-stake/?a_dgi=aolshare_twitter

    5: Reform of Toxic Chemicals Law Collapses as Industry Flexes Its Muscles
    By Sheila Kaplan, Politics Daily November 2010
    http://www.politicsdaily.com/2010/10/13/reform-of-toxic-chemicals-law-collapses-as-industry-flexes-its-m/?a_dgi=aolshare_facebook

    6: FOX News Whistle blowers. UNBELIEVABLE!
    Youtube Video by Steve Wilson
    http://www.youtube.com/watch?v=trWcqxrQgcc

    7: Documentation
    BGH Bulletin
    http://www.foxbghsuit.com/

    8; Testimony on Children’s Health and the Environment
    by Richard J. Jackson, M.D., M.P.H.
    Director, National Center for Environmental Health
    Centers for Disease Control and Prevention
    U.S. Department of Health and Human Services – posted at >
    http://www.hhs.gov/asl/testify/t000502a.html

    9: U.S. Lags in Toxicity Data
    Wednesday, May 3, 2000
    Los Angeles Times, By SUNNY KAPLAN
    is archived at
    http://web.archive.org/web/20050426200055/www.angelfire.com/nm/redcollarcrime/lack.html

    10:WikiLeaks Misconceptions Derail Progress, Threaten Reform
    Project on Government Oversight December 20, 2010 blog
    http://pogoblog.typepad.com/pogo/2010/12/wikileaks-misconceptions-derail-progress-threaten-reform.html

    11: Text of S. 372 [111th]: Whistleblower Protection Enhancement Act of 2010
    December 22, 2010
    http://www.govtrack.us/congress/billtext.xpd?bill=s111-372

    12: Kill the Bill, by Julia Davis, The Examiner news service December 15, 2010
    http://www.examiner.com/homeland-security-in-los-angeles/kill-the-bill

    162: Criminal charges can hit bottom line
    For corporations, a criminal conviction may mean small fines,
    but larger consequences for business
    By CRIS BARRISH AND STEVEN CHURC 06/28/2003
    Copied from The News Journal Staff reporters 06/28/2003
    Archived copy at
    http://web.archive.org/web/20080426105537/www.angelfire.com/nm/redcollarcrime/criminC.html
    File: OperatingProceedureofHealthCare.pdf

  56. Jack Hughes

    Southern Regional Radon Training Center, Auburn University

    Given the degree of public health risk posed by exposure to radon and its decay products, and the fact that the National Center for Healthy Housing included radon mitigation as a recommended housing intervention in its report “Housing Interventions and Health: Review of the Evidence,” it would seem appropriate for this topic to be part of this agenda.

  57. Lindsey Realmuto

    Association of State and Territorial Health Officials (ASTHO)

    ** Please see attached for complete comment **

    The Association of State and Territorial Health Officials (ASTHO) has been involved in the National Conversation on Public Health and Chemical Exposures since its launch in June 2009 through involvement on workgroup and partner conference calls, dissemination and analysis of a state needs assessment, and nomination of state health agency representatives and our Executive Director, Dr. Paul Jarris, to serve on the Leadership Council. ASTHO applauds the National Conversation workgroups and Leadership Council for their efforts to strengthen the chemical safety system in order to protect the public from harmful chemical exposures. The National Conversation draft Action Agenda provides a clear and achievable roadmap for government agencies and other organizations to achieve this goal. After careful review, ASTHO would like to submit the following comments on the draft Action Agenda on behalf of the State Environmental Health Directors (SEHD).

    • Section 1: The Action Agenda should quantify the economic benefits from prevention focused public health interventions versus reactive public health interventions
    • Recommendation 1.9 should be moved up to Recommendation 1.4 because it is the umbrella under which other prevention recommendations fit.
    • Section 2: As discussed in ASTHO’s Chemical Exposures: State Ideas for Safeguarding Health and mentioned in the National Conversation WebDialogue , the Action Agenda should address the need for better monitoring and understanding of the health effects from large, acute exposures. State agencies could benefit from a NHANES-type data collection system for chemical emergencies, large chemical spills, and/or explosions. At these types of exposure sites, there are many environmental samples taken, but little or no matching human data to complement the environmental data. State representatives have identified a need for a validated method for sampling chemicals commonly found in humans at acute exposure sites and increased clinical samples from those subject to acute exposures. An expansion of CDC’s Laboratory Response Network could be of great assistance. Information should be gathered, not only from members of the public known to have been exposed, but also the emergency responders at the site. States should develop a working relationship with the American College of Emergency Physicians so the two groups can share data.
    • Recommendation 2.6 (b) – The general public should be able to provide insight and feedback to state level public health monitoring planning, not just local level monitoring.
    • Recommendation 3.2 – The Action Agenda should explicitly state that the federal government should consult with tribal, state, and local governments as well as academia, to develop a targeted set of toxicological, epidemiologic, clinical, chemical use, chemical transport and exposure data.
    • Recommendations 3.8 and 4.2 are very similar. The two recommendations should either be combined into one single recommendation or greater clarification should be provided on how the two fit together.
    o In addition, state health agencies believe that ATSDR’s mandate should be expanded to include non-site related work. Currently, ATSDR cooperative agreement programs are not evaluated for work completed on non-site specific chemical safety activities. Examples of non-site related activities that ATSDR technical assistance and funding could support include:
     Fish advisories
     Indoor Air Quality
     Indoor mercury spills
     Indoor pesticide usage
     Consumer and art products (i.e. asbestos, Hg, BPA, PBDEs, etc.)
     Vermiculite in attic insulation
     Wind turbine complaints
     Radiation
     Food contamination
     Private well water with natural contaminants (Ur, As, Cr+6)

    Thank you for the opportunity to provide feedback on this very important initiative.

    Sincerely,

    Paul E. Jarris, MD, MBA
    Executive Director
    ASTHO

    cc: Clifford Mitchell, MS, MD, MPH, Chair, SEHD Group
    Assistant Director for Environmental Health and Food Protection
    Maryland Department of Health and Mental Hygiene
    File: ASTHOActionAgendaComments_Final.pdf

  58. Lauren Gerard

    Let me preface my comments by stating that I am one of the growing number of persons in the U.S. and around the world who has chronic Multiple Chemical Sensitivities, so most of my comments will be coming from that purview.

    • I like the original concept presented in Chapter One, suggesting that a precautionary approach be taken with respect to chemical usage, harm and risk. However, as I read through the draft, I felt that the actual position that was being presented was more business as usual; meaning continued chemical development and usage, coupled with the development of numerous committees to review and report on a specific aspect of chemical use and exposure. There are already numerous consumer groups, such as the Environmental Working Group, who are effectively investigating and reporting the negative effects of chemicals on the health and welfare of the general population. It seems to me that they are doing what the government should have been doing decades ago, and that the government should provide funding and support to groups like this who are taking a strong proactive stance. I find that they are doing a much better job of helping the average person protect himself than the government.

    • There are repeated references to sensitive populations, which is a valid aspect of chemical exposure that requires strong and forthright attention…..something that has been drastically lacking for decades. However, there is little recognition of the effects of everyday exposure to common chemicals that are drastically affecting the physical and mental health and welfare of the general population. This tremendous oversight is a travesty, to say the least, as everyday exposures are affecting the ability of children to grow healthy and productive, and for the older population to remain healthy and productive. In a time where medical care has become a critical issue for most, it is beyond comprehension that everyday chemicals can continue to be so freely utilized, unfettered, compromising numerous aspects of the mental and physical welfare of the general population. How will any government deal with and support the needs of a compromised society in the future? It is already a difficult and costly situation, which will only get worse within the next decade.

    • There appears to be no established mechanism for reporting MCS or related illnesses. Typical statistics suggest that between 3% and 9% of the population is chronically ill due to everyday chemicals, but there is apparently no official record reported by the CDC or ASTDR. If those statistics are accurate, that means that within the U.S., somewhere between 9 and 27 million people are ill due to everyday chemical exposures. If these numbers were presented for any other illness, this would be considered an epidemic. The CDC/ASTDR must develop a reporting system for this growing aspect of disease.

    • The general medical community is severely ignorant of the condition known as Multiple Chemical Sensitivity or Environmental Illness. There are several other names which have also been developed, but they all refer to the same illness. The medical community, including doctors, educators and researchers all need to be educated about this illness, what to look for, how to recognize it and how to work with a patient. A perfume allergy is not an allergy, but is in fact a chemical intolerance, and to let it be treated with conventional medical protocol is not protecting the individual from an illness that can continue to worsen, despite this protocol, if exposure is not eliminated. Doctors do not have the knowledge to advise their patients that avoidance can help to greatly reduce or eliminate symptoms. Instead, medications, which are themselves another form of chemical exposure, are administered, with the potential to create additional health issues, which will be treated with yet another medication. The chemical cycle grows, the body burden is increased and costly and painful illness develops.

    • This report does not include medications as the enormous chemical exposure they become in this country. The public is being inundated with chemicals on two fronts: those that they absorb from their surrounding environments (inside and outside) as well as those that come in the form of prescriptions. The body was not designed to process the tremendous chemical load that is being forced upon it these days, and when prescriptions are utilized to treat a symptom, not the root problem, the health of the body is further compromised.

    • There appears to be very little understanding of how the body processes everyday chemical exposures and how the build up of long term and multiple chemical exposures damage the body. There needs to be a substantial push towards this type of research.

    • Chemical companies should not be given free reign to monitor and report on chemicals and their potential health hazards. This has been the norm for the pharmaceutical industry for decades, and that practice is constantly being exposed for testing standards that benefit the financial gains of the company as opposed to the health and welfare of the patient. If the government is going to allow the continued development and ubiquitous use of chemicals, the findings of the chemical company should be thoroughly reviewed. Caution should be strongly utilized before allowing new chemicals to be introduced into the marketplace.

  59. Patsy Brooks

    US EPA Region 4

    It doesn’t appear that radon has been included. Addressing the health risk from radon, lung cancer, should be a natural part of any public health discussion and strategy. It should be considered when discussing prevention, risk, risk assessment, children’s health, homes, schools, buildings, healthy housing, and any number of other possibilities. The science has been debated and the results are in from many many credible sources. Radon is the leading cause of lung cancer among non-smokers, and the second leading cause of lung cancer overall. This effort cannot be considered complete without including radon.

  60. Lauren Gerard

    Chapter Two suggests increased biomonitoring, but seems to fall short as to what action could or should be taken when an area is determined to be dealing with excessive exposures that are causing widespread illness. Often, since it is difficult to ascertain scientific proof that a specific chemical(s) is causing illness, attitudes are less proactive than more. Corporate financial interests often outweigh public welfare. How is this going to change? There are many areas in this country that would like to see this attitude follow through in recognizing chemically induced illness and getting the help and resources necessary to deal with it. Gathering data is only a worthy endeavor if it results in real action.

    Discussions about risk assessment are interesting. It is my understanding that the government has evaluated risk for numerous chemicals in the past and set acceptable ‘safe’ levels. Over the past several decades, evidence has been mounting that many of those acceptable levels are infact harmful. Additionally, when you multiple the acceptable level of one chemical with exposure to many others, which is an indeterminable concept, how can risk management work effectively to develop a true acceptable level of any given chemical? I suspect that as in the past, precautionary measures will not be that stringent and will favor the chemcical manufacturer, not the consumer.

    The overall thought of this report seems to be that chemical usage is acceptable and here to stay, and focuses how it can best be managed. Very little thought is given to tempering chemical usage. Additionally, educating the general public about the effects of everyday chemical exposures, suitable alternatives and measures that can be taken to protect themselves does not seem to be a high priority.

    The U.S. government needs to work with other countries to stem the use of toxic chemicals in the many products used in home and work envirionments. Toxic illness, and those illnesses resulting from toxis exposures, is a global concern and must be addressed on a global level.

  61. Lucy Hindman

    I feel that it is urgent that Recommendation 7.5 be moved to the top of the list of considerations. This is very important to the health of all Americans.

  62. Don Hindman

    Please move Recommendation 7.5 to the top of the list for consideration. It is so important for all Americans to be safe from poisons that threaten our health and well being.

  63. Don Hindman

    Please move Recommendation 7.5 to the top of the list for consideration. It is so important for all Americans to be safe from poisons that threaten our health and well being..

  64. Jay Watson

    Local Hazardous Waste Management Program, Seattle, King County, Suburban & Other Cities

    Jay Watson, Ph.D.
    Program Administrator
    Local Hazardous Waste Management Program in King County, Seattle WA.

    Thank you for providing the opportunity to comment on the National Conversation on Public Health and Chemical Exposures. The Local Hazardous Waste Management Program in King County (LHWMP) is a regional partnership comprised of local government agencies, including King County Water and Land Resources Division, King County Solid Waste Division, Seattle Public Utilities, Public Health – Seattle & King County, and the 37 suburban cities of King County, Washington. LHWMP’s mission is to protect and enhance public health and environmental quality in King County by reducing the threat posed by the production, use, storage, and disposal of hazardous materials (www.lhwmp.org/home/AboutUs/planupdate.aspx).

    Overall, LHWMP applauds the recommendations described in this report to enhance environmental and public health practice. The agenda items are consistent with several of LHWMP’s primary goals, including:

    • Reduce the production of hazardous materials and products.
    • Reduce the use of, and exposure to, hazardous materials and products
    • Reduce public and environmental exposure to the most hazardous materials.
    • Reduce the exposure of vulnerable and traditionally underserved populations to toxic and other hazardous materials.

    Comments on the Action Agenda are provided below.

    LHWMP supports efforts aimed at reforming the long-outdated Toxic Substances Control Act and other regulatory efforts that serve to put the precautionary principle into practice. TSCA should be revised to eliminate data gaps for chemicals in commerce. Industry should be required to provide essential health and safety information on all chemicals, including information on the inherent hazards of these chemicals and their mixtures, exposure data, and life cycle information (i.e., production volume, uses, potential environmental fate and transport, and end-of life disposition).

    Concerted efforts should also be made to promote the field of green chemistry, in order to facilitate design of chemical products and processes that eliminate the use or generation of hazardous chemicals. Companies that use or generate hazardous substances should be required to incorporate prevention principles into their decision-making processes. In addition, resources should be provided to academic chemistry departments to ensure that green chemistry principles are taught at both the undergraduate and graduate levels.

    We support the recommendations to promote the substitution of hazardous chemicals with less toxic alternatives. Emphasis should be placed on developing rigorous science-based hazard screening systems that can be used by the public to compare and contrast chemicals and products. Promising systems for identifying safer chemical alternatives are the EPA’s Design for the Environment program (www.epa.gov/dfe/), Clean Production Action’s Green Screen (www.cleanproduction.org), and the Washington State Department of Ecology’s Quick Chemical Assessment Test (QCAT).

    LHWMP concurs that children represent a particularly sensitive population and we support efforts to account for their chemical vulnerability when developing policies and practices. New toxicological findings for hazardous substances like lead, pesticides, and plasticizers have served to highlight the importance of minimizing hazardous exposures to children.

    LHWMP concurs that worker chemical exposure standards should be based on current science. However, many sole proprietors of businesses receive no regulatory oversight or assistance because they are frequently not under the jurisdiction of state or federal OSHA programs and are largely ineligible for agency-provided free-of-charge consultation services. Minority populations who own and operate businesses require particular assistance with reducing chemical exposures. In King County, approximately 85% of dry cleaning businesses are Korean-owned and 65% of the businesses still use perchloroethylene, which is a hazardous chemical and pervasive environmental contaminant. In addition, approximately 50% of nail salons in King County are owned and operated by Vietnamese individuals (mostly women), who are exposed routinely to solvents, adhesives, dusts, and other hazardous substances.

    LHWMP supports the expansion of biomonitoring programs, environmental public health tracking, and state-based occupational health surveillance. In Washington State, the Department of Health is currently building capacity to conduct biomonitoring of the local population (http://www.doh.wa.gov/ehsphl/Biomonitoring.htm). However, it is not clear whether this effort has sufficient long-term funding to create a sustainable program. One significant challenge is providing the findings to study participants, particularly when the health consequences of exposure to the detected levels are unclear (examples include polychlorinated biphenyl ethers, perfluorinated compounds, and bisphenol A). Consequently, significant resources should be directed to the development of coherent messaging, including formal usability testing of protocols and documents.

    LHWMP also supports long-term expansion of CDC’s Environmental Public Health Tracking program, to ensure that relevant environmental and health data are captured in a database that may be queried by researchers and the public, while maintaining patient confidentiality. Linkages should be provided between these data and the biomonitoring results described above. Also integrated into this system should be comprehensive occupational health surveillance data (for biomarkers and health outcomes) as well as industrial hygiene data for workplace chemical exposures.

    Additional efforts should be directed towards inventorying the chemicals commonly used by business and government entities. Currently, there is no systematic means to identify or quantify low volume chemicals and estimate the risks associated with using those chemicals. LHWMP is currently working with the local fire department to develop a system to catalog the chemicals used at a particular location, with an ancillary module designed to identify safer chemical alternatives.

    LHWMP supports the efforts described to promote health & wellness in communities disproportionately affected by environmental exposures. Like many communities, King County, Washington has been growing in diversity in recent years. More than a quarter of the county’s population is minority or foreign-born and about four percent of the county’s residents do not speak English well or at all. Of the 15 largest counties in the U.S., Seattle/King County is home to some of the most pronounced health inequalities, as measured by the ratio of health, access, and poverty disparities by income and race/ethnicity (www.kingcounty.gov/healthservices/health/partnerships/cppw/~/media/health/publichealth/documents/cppw/HEALDisparities.ashx). For example, the diabetes prevalence and mortality rates for African-Americans in King County are among the largest in the nation, and the inequities are increasing as rates continue to decline for whites but not others http://www.kingcounty.gov/healthservices/health/partnerships/cppw/~/media/health/publichealth/documents/cppw/HealthNeedHEAL.ashx).

    A final overarching need is the development of a consolidated database of sampling and analytical methods. Comparing environmental data generated by different environmental agencies is currently fraught with difficulties, reflecting sometimes subtle differences in methodology. As emerging contaminants like pharmaceuticals and personal care products are being identified in environmental media, it is essential that equivalent methods are employed to allow critical comparisons of data.

  65. Jamie Fleece

    The Silicones Environmental, Health and Safety Council of North America (SEHSC)

    ** Please see attached for complete comment **

    Dear Sir or Madam,

    The Silicones Environmental, Health and Safety Council of North America (SEHSC) appreciates the opportunity to provide comments on the National Conversation on Public Health and Chemical Exposures Draft Action Agenda, dated December 20, 2010.

    Please feel free to contact me with any questions regarding our submission.

    Thank you,
    Jamie Fleece
    [file]http://resolv.org/site-nationalconversation/files/2011/02/SEHSC Comments on Public Health & Chemical Exposures Draft Action Plan.pdf[/file]

  66. Kathleen Curtis

    Clean New York

    Thank you for the opportunity to comment on this largely ambitious, progressive and inspiring Action Agenda.
    [file]http://resolv.org/site-nationalconversation/files/2011/02/National Conversation Action Agenda Comments1.doc[/file]