Education and Communication

The Education and Communication work group is focused on ensuring a well-informed public and a competent network of health care providers. To review the group’s membership, charge, and past meeting summaries, visit the National Conversation work group page.

Next Steps
The National Conversation Council will consider public input received through web dialogues and public comment in revising the Action Agenda in the early spring 2011. Work group reports will be appended to the action agenda.



  1. Michael Ottlinger

    I’m going to present my comments in a simple point paper approach.

    Assertion: We have an opportunity to stimulate the discussion of a modern and intellectually superior approach to the education of “health care professionals” of ALL types, traditional as well as more recently incarnated practitioners. Specific ideas for a proposed undergraduate program in “Public Health” follow. Bear in mind that, not all of these subjects need be taught as stand alone courses. Indeed, in the humanities introductory courses are commonly crafted to cover many topics in a lively and integrated manner, and some creative innovations in the teaching of undergraduates interested in science, medicine and public health is sadly overdue.

    “Public Health” education is multidisciplinary and should incorporate
    several heretofore separate scientific disciplines, such as: basic
    chemistry; a basic level of cell and molecular biology, which is
    common to all training pathway; basic physics, certainly including an
    elementary discussion of radiation and radiation effects; basic
    physiology; basic microbiology; basic concepts of pharmacology and
    toxicology; basic epidemiology with some illustrations of how
    diseases have classically been observed to spread through populations
    as well as some good illustrations of epidemiology in the context of
    well reasoned medical or physiological questions.
    Topics can also be added discussing law as it relates to public
    health; a survey of private sector as well as federal, state, and
    local public health agencies with some explanation of their basic
    missions and interrelationships.
    Public health history, economics, social, and management topics can
    also be included.

    Assertion: It is pathetic that we leave public health training, in most cases, to graduate schools.

    We miss getting people involved when they are younger and at the
    initial hire stage of their careers.
    Science, certainly biological science, is presented with an emphasis
    on basic research with almost no exposure to the practice and
    application of these principles, thus deadening what are truly an
    exciting series of topics.
    Important interrelations are missed.
    We miss the opportunity to present to young people at the most
    formative stage of their lives not simply the prospects for a career
    in one narrow area of endeavor, but, rather the opportunities
    afforded by a lifetime of mutually reinforcing and overlapping
    experiences in different applications of public health, such as:
    environmental, occupational, including industrial hygiene, medical,
    health care management, as well as research, basic or applied.
    Applied research is virtually absent from the undergraduate
    Graduate programs will continue, much as MBA training does in
    business, to sharpen skills a well as to foster mid career
    adjustments in the career path.
    We will benefit from channeling people into available job

    Assertion: Currently, US Federal Agencies are weakened by the tendency of employees to join and reside, if not for their entire career, certainly for long stretches of it, within the confines of a single agency. This situation limits the growth experiences of the employees and does not benefit the understanding of the necessary coordinated functioning of these agencies which must face challenges that cross agency lines and technical fields.

    We should emphasize the need for a broader training, if you like, one
    might consider this in comparison to the notion of a well rounded
    liberal arts education. Of course, we still wish our students in
    public health to have substantive exposures to these other subjects
    as well which are so important to their general education as well as
    their understanding of the world and its cultures.
    It would be highly beneficial to encourage more job mobility between
    local, state and federal agencies. At present we have many
    structural barriers to this which we should endeavor to remove.

    Assertion: We should examine the roles of many different public health-related training programs and look for ways in which to synergize or retool them. For instance, industrial hygienists often play a key role in occupational safety and health, including in hospital settings where they interact closely with infection control programs, but, industrial hygienists typically lack training and skills in many of the disciplines listed above. Furthermore, even minimally trained medical aids are capable of performing basic practitioner functions, such as taking temperatures or blood pressures, yet, industrial hygienists, although they could effectively function as physician extenders, have no such skill sets. Taking employment histories or maintaining occupationally-required medical records are similarly related areas.

    Consider the full spectrum of health-related programs available
    ranging from medical assistants to nursing, physician assistants,
    nurse practitioners, physicians, toxicologists, etcetera, and review
    it for potential synergies, continuities of training, as well as
    retooling where obvious gains can be found.

    I’m stopping here because I would not wish to lose the central emphasis of what I am saying by adding so many detailed ideas that the reader might be too distracted. Anything else that I think I could offer is largely derivative of the basic ideas contained in the first assertion.

    Thank you for the opportunity to comment. Naturally, these are my comments alone and do not represent an opinion of position of the US EPA.

  2. Timothy Winter

    LSU Shreveport

    I believe it is healthy to include in the discussioncurboth environmental literacy concurrently with health literacy. I would like to see more emphasis on education with the general public, in particular greater emphasis on prevention, environmental racism still exist.

  3. Randall Brinkhuis


    This is not an official EPA comment, but I noticed that in footnote 4 you attributed the Risk Communication in Action workbook to the National Risk Management Research Library. The “L” in NRMRL actually stands for “Laboratory.”

    But on a personal note I have to say that these reports are quite impressive!

    Randall Brinkhuis

  4. Jaymie Meliker

    Stony Brook University

    A key element of effective communication is awareness that decisions must be made in the face of uncertainty. I did not find the word “uncertainty” in this draft report. I encourage you to consider that education and communication about environmental health risks must improve the public’s and media’s understanding of the uncertainty in the process. Otherwise, this is a very strong report.

  5. Eileen Senn

    Independent Industrial Hygiene Consultant

    In your view, what are the most important recommendations put forward by the work group?
    Recommendations 1, 2, 3, and 11.

    Do you have suggestions for strengthening the report or any of the recommendations?
    The recommendations are heavily skewed towards professional education. More attention is needed to the education of employers and workers.

    Given that the work group was limited to 12 recommendations, are there issues that you think should be prioritized over those addressed in the report?
    I only see 11 recommendations. For number 12, I recommend the committee address the issue of employer and worker chemical education, especially by OSHA and NIOSH.

    Nowhere on their websites does OSHA or NIOSH clearly explain in generic terms how employers should evaluate and control chemical exposures. Each comprehensive chemical standard does so but only for that chemical. OSHA and NIOSH need to add clear and simple information to their websites on assessing and controlling chemical exposures. What is currently on the OSHA website is often too technical and not integrated into an understandable whole. There are no OSHA Topic Pages on substitution, isolation, local exhaust ventilation, or administrative controls. There are topic pages on hazardous and toxic substances, medical screening and surveillance, personal protective equipment, and respiratory protection. The ventilation topic page pertains to ventilation standards intended to avoid fire and explosions, not to protect health. In the area of assessing chemical exposure, there are OSHA Topic Pages on dermal exposure, surface contamination, chemical sampling, direct reading instruments, sampling and analytical methods. But there are none on airborne exposure or qualitative exposure assessment. All these pages need to be integrated under the topic of industrial hygiene measures for assessing and controlling chemical exposures.

    To support employers’ chemical assessment and control efforts, OSHA and NIOSH should create databases of assessment tools, best practice controls, and substitutes. Different sets of controls are applicable to different processes, therefore OSHA and NIOSH should produce narratives descriptions and checklists of best practice controls for industrial unit operations such as degreasing, production facilities such as cement plants, and construction work such as cutting wood products. Classic industrial hygiene books, such as Recognition of Health Hazards in Industry , are places to start.

    There are many sources of information on engineering controls for chemical contaminants. OSHA’s existing ventilation standards are a start. NIOSH has issued many control technology publications. Particularly useful are the 31 Hazard Control documents issued from 1996 to 2001. Note that ACGIH publications, and American National Standards Institute (ANSI) and American Society of Heating, Refrigerating and Air-Conditioning Engineers (ASHRAE) ventilation standards are copyrighted and expensive. If OSHA creates ventilation checklists, it will make this important information on controlling chemical exposures much more widely available.

    To assist employers and employees in interpreting air sampling results, OSHA should compile a guidance document, including a non-mandatory list of the lowest published Occupational Exposure Limits (OELs). There are many sources for these OELs , including California’s PELs. The list should be updated annually.

    OSHA should also collaborate with specific industries to develop eTools like the one on engineering controls in Secondary Lead Smelting. Also very useful model are the OSHA Small Entity Compliance Guide Fact Sheets produced when the Methylene Chloride Standard was promulgated For chemical exposures, there are OSHA eTools on respirators, silica, and battery manufacture and Expert Advisors on asbestos and lead. More of these eTools should be created. The first priority should be one on assessing and controlling chemical exposures.
    [file] to Education and Communication Group.doc[/file]

  6. Frederic Pfaender

    UNC Chapel Hill SRP

    This seems to be the most far reaching and in many places confused of the reports. I suspect this is the result of way to few educators on the committee. Some specific comments:

    1. Rec 1 and in general. Our ability to educate the public is in question. Our public education system is widely acknowledged as a disaster area. We don’t know how to educate the public. New approachs and technologies are needed. Rather than involving federal agencies we need marketing and television folks to help us develop and deliver the multidimensional message. The report addresses the content but is weak on delivery. That is ok since no one really knows how to do it well.

    2. We have some proven mechanisms for educating health professionals- most require continuing education to keep licenses and certification valid. A well established but not discussed mechanism already in place. They are absolutely correct that Environmental Health is not a major part of public health training. In most health departments environmental health is not a focus, often not even part of the health department. Rec 10 wants to have program to encourage new people to enter the environmental health field. The problem is that is most cases the wages are so low that recruiting talented and commited folks is close to impossible and will be until the wage issue is addressed.

    3. Rec 2- the process to build trust recommended suggests little knowledge of the research process. Transparency and trust are the major tenants of the peer review process. The recommendations will make the research process so cumbersome that far less research will be done which I believe is counter to what the committee hoped to achieve.

    4. Rec 3 is similar to what is proposed by several other work groups. Clearly there is a need for some sort of information clearinghouse where professionals and the public can access information without a degree in cumputer science. The real issue is who does it and who pays for it. Each of the work groups seems to have different views of how that might be done.

    5. Rec 4 needs to acknowledge that input is needed from all levels, not just federal environmental agencies. The educational establishment has wrestled with many of these issues (largely unsuccessfully) for a generation and can help.

    6. Rec 8 and 9 really belong in other work groups-

  7. Shar Turner


    I am Sick and tired off researching the CDC & EPA for help! You know MCS is real but to chicken to make a stand! COMPLETE THE RESEARCH! Make a Stand! Tell the doctors all over the world it real!!

    My mom went to 17 doctors before a doctor told her she had MCS! I saw a lot of pain, she even wished she was dead! Finely the doctor was able to teach her about all of the problems and symptoms that came with MCS along with help from a shrink and she is doing better (not 100% but better).

    All of the pain physically and mentally could have been avoided if only the government would have posted what they already know! It would have put presser on the 16 other doctors to at least put the pieces of the puzzle together and suggest her to just stay away from chemical even if it meant losing her job, car, or home. Had these doctors had something to go by she probably would not have suffered so bad mentally.

    My mom is on disability. Had her doctors knew about MCS the government would not be spend taxpayers money taking care of her for the rest of her life, instead she would have removed herself from all chemical at home, from the new car smell, and talked to her boss about relocating her in the office away from people that smoke and used heavy perfume.

    Please see the attached study, I hope it can help with the government showing recognition to MCS.

    Attached PDF: Biological definition of multiple chemical sensitivity from Redox state and cytokine
    profiling and not from polymorphisms of xenobiotic-metabolizing enzymes
    [file] Tested -ScienceDirect.pdf[/file]

  8. Katherine Kirkland

    Association of Occupational and Environmental Clinics

    Dear Work Group Members,

    Thank you for the opportunity to review and comment on this document. On behalf of the Association of Occupational and Environmental Clinics (AOEC) we would like to thank the Education and Communication Work Group for your efforts. We particularly appreciate your focus on health care professionals and the need for them to be both better educated on occupational and environmental issues and on communicating that knowledge to community members.

    Our members include many of the academic centers in the U.S. that train the physicians, nurses, toxicologists, industrial hygienists and other professionals in occupational and environmental health. In addition we represent the Pediatric Environmental Health Specialty Unit (PEHSU) network. AOEC members share a strong conviction that the challenges presented by occupational and environmental conditions must be met with a multi-disciplinary, public health approach of prevention.

    While we recognize that your charge was to address environmental health issues, in most cases there is no way to easily separate environmental issues from occupational health issues. For example, the Deepwater Horizon oil spill has affected not only the environment, but also workers, their families, and residents of the affected areas.

    The tasks outlined in lines 61-66 articulate the importance of enhancing the understanding, knowledge, and skills of health care professionals. Box 1, beginning at line 406, mentions several important groups as “examples”, however, noticeably absent are professional groups that focus on both occupational and environmental health training. Recommendation 5, beginning at line 931, proposes support for faculty positions in academic health centers (see lines 959-960), and recommendation 7, beginning at line 1027, proposes that experts develop specialty-specific clinical practice guidelines for addressing chemical exposures.

    In considering these recommendations, it is important to note that an established structure exists within some academic health centers in occupational and environmental medicine and nursing training programs. In addition, there are professional organizations that represent practicing physicians, nurses, toxicologists, industrial hygienists, and related health professionals who focus on occupational as well as environmental health. The AOEC is a network that includes both academic specialists and practicing clinicians, and represents a major source of education and communication in occupational and environmental health. We therefore urge the Work Group to cite the AOEC network as a resource for the special understanding, knowledge, and skills in occupational and environmental health needed by all health care professionals.

    Thank you for your consideration.

    Katherine H. Kirkland, MPH
    Executive Director

  9. Laura Weinberg

    Great Neck Breast Cancer Coalition

    The most important recommendations put forward by the work group include setting up a K-12 appropriate school curicuulum on environmental health and exposure to toxins, as well as the dire need to educate the medical profession on all aspects of environmental health. Medical School in our country at this point only requires 0 – 3 hours on environmental health. The majority of medical professionals are clueless regarding how to offer advice on prevention of exposure to toxic chemicals, or to recognize illnesses caused by a toxic exposure.

    The Education and Communication Work Group was very thorough in its analysis and recommendations of expanding education and knowledge of environmental health throughout the public, private and medical sectors of our country.

    Our coalition hopes to hear that these recommendations have been accepted and realized in the near future.

    Sincerely yours,

    Laura Weinberg
    President, Great Neck Breast Cancer Coalition

  10. Ernest Grolimund

    Coalition Against Wood Burning, Residents Against Wood Smoke Emmissons of Particulates

    Educate Congress. Find a way to lobby the congress by utilizing the emergency lines of communication. In other words advise congress and the president that a toxic emergency exists regarding 200 or so key chemicals that are beoming a threat to life, health, safety, welfare.

    For example, wood smoke containing 180 or so chemicals is now engulfing houses and cities as shown by photos, hot spot monitoring, modeling, and the science has become clear in the last few years. But the scientists cannot work up the chain of command because everthing is designed to work from the top down. But you waste the genius of 150 million people who can monitor and observe the problem and tell you all about it and how to solve the problem, too.

    In other words, let us, the public, educate you, when it is appropriate. That is what this conversation is all about. Then you educate the congress.

    DHHS policy says you have to investigate public health problems whenever there is a health nuisance or health problem and the problem has to be prevented. But the ATSDR has told me it can’t do anything about wood smoke chemicals and noxious fumes and dangerous pm, unless the state toxicologist wants it. But what happens if the state toxicologist is negligant or ignorant about wood smoke or is prevented from doing anything by a negligant Governor or legislature? And this is happening all over. The politicians do not understand the science like the ATSDR and need to be educated but the ATSDR is not allowed to “lobby” congress. So, “inform” them of the disaster. Tell them cities are being engulfed. Tremendous violations of pm stds are occuring and the wood smoke is 12 times more carcinogenic. Tell them it is like tobacco smoke on steroids, More carcinogenic and greater in conc and presence. Educate the Surgeon General and get that office involved like was done for tobaco smoke. If you can’t lobby congress, lobby the president.

    FIND A WAY!!!

    We are taliking about large amounts of dioxin and 32 volatile aromatic hydrocarbons attached to pm which has to be regulated. Has to be controlled. No discretion to not enforce. Most of the chemicals you are concerned with, are in wood smoke in great amounts. Remember lead? from the lead paint issue? It is there too. Mercury? Cumalative wood smoke is a source larger than coal power plants.

    Ken Schere, chief EPA modeler says Maine DEP modeling is correct in showing an old stove heating a house causes 80 mcg/m3 pm2.5, 24 hr ave. Fireplaces are worse. You don’t really have to check the modeling but it would be cheap if you did. Outdoor and indoor wood boilers are worse still because the politicians did not consider Habers Rule of Toxicology. The DEP and EPA did not understand the toxicology of large doses for small times. In other words you need to “educate” the environmental scientists about the toxicology. That is your department. But you have to educate congress when it tells the country to do something dangerous and illegal regarding toxics.

    Now it is my time to educate you about something critical that the EPA exposure expert educated me on. Wood smoke pm is not ambiant pm from many sources. Therefor it is inappropriate to compare themodelingconcentrations to ambiant pm stds. If good science shows that wood smoke pm is more toxic and an ATSDR quotes a Dr Brown as saying that is so, then the new safe dose must be used to compare wood smoke too and concentration is not even the right parameter. Dose is. The proper dose is about 108 mcg/m3,hrs fro 17 mcg/m3 x 6 hrs. The ambiant pm std dose of 35 mcg/m3 x 24 hrs or 840 mcg/m3,hrs is not correct. A regional ATSDR toxicologist was samrt enough to say almost the same thing. So you can essentially create a new tox profile of a kind by utilizing the Brown perr reviewed dose. Save money. Do a lot of good.

    Compare the existing modeled pm numbers to the new dose and give out guidelines if you can’t give out stds. Use the modeling to adress millions of pieces of equipment at the same time saving a lot of money. Doing health assessments for every outdoor wood boiler is not necessary. Save money. Save time. Then compare the new dose to action that should be taken following the CDCguidline to protect your family from debris smoke which basicaly says if you can see or smell smoke, there is a health problem and health problems must be prevented by DHHS policy that is explained in the Essential Functions of the DHHS.

    Ernest Grolimund, retired engineer, wood smoke victim, and activist.

  11. Susan Hurd

    I strongly encourage that the education communication work group develop a subcommittee that will educate and train other government organizations, including working with the ADA, HUD, EPA, higher education, health dept, etc on multiple chemical sensitivity, MCS accessibility accommodations needs. THere is way too much ignorance out there. Where wheel chair disability accommodations were say 30 plus years ago is where I believe MCS disability accommodations still are. I do believe out of all of the disability populations that are the most at risk population with the least representation and advocacy to take place. MCS persons develop hyper sensitivity and adverse neurological/immunological responses. THe EPA does acknowledge that neurotoxic chemicals will give many adverse neurological and immunological responses just as one with MCS contends with, though they do not outwardly acknowledge that these are all symptoms that go along with MCS and chemical sensitivities to lesser degrees.

    4% of the US population is now disabled with MCS, which is 12 million people. 40% are now chemically sensitive to various degrees. 72% of all asthmatics are chemically sensitive to various degrees. Many others are adversely affected by chemical exposures triggering headaches, migraines, digestive problems, difficulty concentration and other neuro-cognitive impairments existing when in toxic buildings or exposed to toxic chemicals. Many more suffer from learning disabilities, ADD/ADHD, behavioral and mood disorders worsening with chemical exposures, but improve with avoidance.

    Fragrances are now toxic chemicals that can consist of 2,000 to 4,000 chemical ingredients listed under the seemingly benign word “Fragrance”. THese chemicals can bio-hazardous, neuro-toxic and carcinogenic. 60% of what touches the skin is absorbed into the blood stream. The olfactory system is directly wired to the brain and has the most permeable blood oxygen brain barrier. THis is exactly why people who inhale drugs like cocaine or toxic glues will get the fastest and most intense high since it by passes the blood stream and goes right to the brain. A child’s brain is not fully developed and is very permeable, making them also the more vulnerable to toxic chemicals touched or breathed in. THis is also why we have mandates on children’s art supplies by made non-toxic and that children’s wooden playground equipment is stained with less toxic water based stains. Yet, a child can live in a home or go to a school and be exposed to highly toxic stains, paints and other toxic building materials, toxic pesticides, lawn chemicals etc. More consistency in connecting the dots is needed with keeping things Green, safe and less toxic and also in educating the public and agencies.

    The word Green needs to have a consistent definition and regulated which though is something for the policy workgroups to pay attention, it is also something for education workgroups to pay attention to. There is no regulated, standardized meaning for Green. WE assume it means less toxic, safe, healthier for people and the environment, yet this is not taking place. A playground may have toxic shredded reclyced tires in use and being called Green. Educated affluent parents are blinded and assume its ok for their children to play on since its being called Green and therefore misleading the public at large. Tires emit high amounts of toxic VOCs. CHildren , especially toddlers are putting these toxic tire shreds in their mouths are toddlers put whatever they can in their mouths. The tires are getting onto clothes, skin and breathed in by all children. COntractors are getting new Green building grants and calling their housing Green when in reality they still are using toxic formaldehyde ladden particle for wall structures and sub-flooring instead of Bamboo flooring also is being promoted as Green and therefore consumers assuming its less toxic. Bamboo however is processed often with formaldehyde and one needs to do their homework. Vinyl siding also can be highly toxic and carcinogenic. It does not let a home breathe as wood does and other natural materials like plaster,clay, tile. Vinyl siding can trap moisture in a home then causing mold and mildew problems and leading to toxic quality problems. A great amount of education is needed in what constitutes as Green and regulating Green building funding to be truly built Green, less toxic with good air quality.

    Fragrances also need a great more education on how toxic they can. They are promoted as aromatherapy. They are promoted as inviting, appealing, sexy, welcoming. Fragrances are toxic, and are getting away with murder, literly due to powerful Fragrance lobbies. Old outdated laws do not require fragrances to list all ingredients including bio-harzardous, neurotoxic, carcinogenic ingredients and toxic ingredients like formaldehyde. Again, 60% that touches the skin is absorbed into the blood stream and the olfactory system is most permeable and wired to the brain. Automated fragrances installed in public bathrooms prevents acessibility to those disabled with MCS and with asthma that will have immediate adverse reactions. STores like the GAP and Bed and BAth that now pump fragrances into the stores also preventing accessibility. THis is therefore a violation of the ADA laws since MCS and asthma are both recognized disabilities. Air fresheners do use numbing agents to deaden the sense of the smell and therefore not smelling bad odors, while allowing one to only smell the toxic fragrances. Many perfumes and personal fragrance products used in soaps, deodorants, hair products, laundry soaps trigger adverse reactions. For example the Bounce Dryer sheets have formaldehyde ingredients which help prevent wrinkles and static, they use chemical adhesives so the toxic chemicals will stick to clothing to keep out wrinkles and static. THey also use toxic fragrances which also then cling to clothing and also then leave trace residues behind on chairs, desks, as well as when one hugs another then it cleans to their clothing. Medical research has been submitted to the medical communities, including hospitals in how toxic BOunce is and that it is known to be directly related to trigger pancreatic cancer. It is also highly neurotoxic. THis is on one level a policy regulation issue but the public needs to be educated on how toxic these products and also they are very reactive to those disabled with MCS and other medical conditions that cause chemical sensitivities to less degrees.

    THose with MCS are likened to the canary birds used in the coal mines. The canary birds would be the first to detect toxic gases, get sick and die. They miners lives depended on paying attention to what happened to the canary bird, which was a warning for them to get out of the mines fast before noxious gases killed them as well. THose with MCS are hyper sensitive and we are the first to detect toxicity, get sick and be a warning to others. If a person with MCS can tolerate being a home or other building, then the odds that it is pretty Green, safe and less toxic. Green practices are healthier us all, not just those with MCS. It is very important to protect those with MCS, and other illnesses triggered by chemical exposures, because we are like the canaries warning the rest who are not as aware and sensitive.

    I am happy to share more of knowledge. I am a great teacher and speaker, with formal BA in Mass Communications and public speaking training. I also taught environmental education prior to getting neurological Lyme disease which then weakened my immune and nervous systems triggering disabling MCS and severe allergies. I am a sucess story. I have learned how to advocate for myself with great amount of perservance and patience. I also am a holistic psychotherapist, MA, CAGS, LMHC, specializing in health psychology. I do treat persons with chemical sensitivities, MCS and other chronic auto-immune/neuro-immune disorders that have a mental health component. THOse with MCS can be healthy, productive citizens working PT or FT if they are provided with necessary MCS accommodations. They also can be very sick and disabled and bed ridden if they are living in toxic homes or working in toxic buildings, which then becomes very costly. It is so much cheaper to provide Green homes and work places, etc, which then keeps us all healthy. For this to really take place on a greater level it does mean more education and sensivity awareness. I witness so many being blocked with getting MCS disability support and accommodations they need due to ignorance, lack of education and sensivity. THere is serious discrimination taking place for the MCS population. MCS education and sensitivity awareness needs to start at the top with major DC gov organizations and then work down through other organizations and to the public at large.

  12. Tee Guidotti

    The National Conversation does not seem to be moving forward. It seems to be re-entrenching the past agenda. The way forward, in my opinion, is to 1) create trust and if necessary non-political oversight in regulatory agencies, not community groups, because the latter do not have the sustainability, technical capacity, or objectivity to be the arbiter in such issues, 2) scrap the existing TSCA apparatus and replace it with something resembling REACH, 3) mainstream tox substances issues with competition for priority with other public health issues rather than keeping them as “carve outs”, to be dealt with case-by-case by expensive and adjudication-rich processes, 4) articulate something like Roosevelt’s “Four Freedoms” for living in a safe environment, recognizing that a toxic-free world is not possible.

  13. Rosemary Ahtuangaruak

    Inupiat Community of the Arctic Slope

    This process is very important and I wish it had happened three years ago. I pray the information is used to improve policies and the enforcement of these policies are so needed right now with the devastation in the Gulf of Mexico. We have a hard time to gain access to information and to participate in ways to affect decisions that cause impacts to our health. The nation energy needs create exposures to us. Risks for failures affect our daily lives.

    This document took months and years of expertise from the participants to build a good way to improve education and communication to help limit the exposure to health. Prevention is the key and precautionary principal helps to prevent worse effects. Protecting the next generations are the reasons we work so hard to protect the health of the people and the lands and waters we depend on for healthy living. World developments with air currents have come to the Arctic and working to look at what we can do to help reduce chemical exposures for our people are why we work on these issues. Thank you to all the participants in the process willing to look at the information to contribute to help with the education and communication working group and the additional groups that worked on the whole project.

    The comments for the project should look at including the at risk groups and include tribes in the generalize discussions that occur throughout the document. The document has a good generalized discussion that does reference tribes and at risk groups but needs to be included in the process stronger. We thank you for taking a look at our comments and for all the work every one put into the process. Our region has dire need for the information and we hope the process helps the Gulf of Mexico. We have risks for chemicals come here from all over and we need to help educate others and work to improve the process to reduce risks.


    @ Susan Hurd, Beautiful!
    All doctors should be educated on Multiple Chemical Sensitivity!
    MCS drove me into Post Traumatic Stress Disorder because I was fighting the worse battle of my life all by myself. My doctors had absolutely no clue.
    It’s been 4 years now sense I got sick and I still cry at night over the fear and pain & suffering I suffered before I was diagnosed. I believe if the doctors had given me a questioner in regards to MCS I would still have a life worth living. I too would have removed myself from the environment that was making me sick a year & four months earlier.

  15. Shar Turner

    Most government data states, “Most of the complainants report relief soon after leaving the building” This is not true. health care professionals need to know that:
    [If you have 5 or more of the symptoms, and/or had been suffering in the environment over one (1) year, there is a great chance of only 50% to no recovery]

    To many people suffer psychologically from the run around given to them from their own doctor telling them “you should be better by now” or “maybe it’s in your head”, no matter how strong or successful that person is without the right answer pretty soon that person will start to think “maybe I do have a mental problem”, start to doubt themselves, grow weak and end up another lost life all because the doctor was not properly educated.

    It’s bad enough that your health has failed you, but to think you mind is failing you as well …. makes life not worth living.

    Please see the attached studies on SBS:
    SBS1 & SBS2
    File: SBS1.pdf
    File: SBS2.pdf

  16. Leslie Israel

    Occupational Medicine Residency Directors

    [file] Comments to Education and Communication Work Group 09-14-101.pdf[/file]

  17. Tracy Morrow


    Over the past 25 years residential and commercial builders started to heavily rely on the “Exhaust Fan” to ventilate homes and commercial buildings.

    I have MCS and Hyperosmia (an increased ability to smell). Over the past 4 year no matter where I go if the bath room has an exhaust fan running I smell and my body reacts to the odor, bacteria, toxins, and/or gases that come from the drain pipes. If I am in a home or commercial building with windows for fresh air I don’t smell it.

    I am not a scientist but I think when you are in a closed room such as a bathroom, and the fresh air isn’t being pumped into the room fast enough the exhaust fan pulls the gases and/or toxic chemical producing bacteria from the drain pipes up into the air of the bathroom! This is dangerous to the public’s health!

    Again…I am no scientist but I think it should be a Federal Law that all bathrooms private or public with three (3) or more fixtures (toilet, sink, tub, and shower) should be required to have a window that can be OPENED and a exhaust fan should be secondary. There is nothing better than replacing smelly air with fresh air and believe me when I tell you I smell and my body reacts to what’s growing in the drain pipes!

  18. Alice Freund

    Mt. Sinai Irving J. Selikoff Center for Occupational and Environmental Medicine

    Comments on the National Conversation on Public Health and Chemical Exposures Draft Report on Education and Communication

    Mount Sinai Irving J. Selikoff Center for Occupational and Environmental Medicine

    Thank you for the opportunity to add our suggestions. We would like to make the following suggestions:

    On page 14 it is stated: The education and communication infrastructure could be greatly enhanced if agency Web sites featured: (1) cross-references to other government and non-government Web sites addressing relevant chemical exposures; (2) updated lists of relevant scientific journals or peer-reviewed papers; and (3) lists of relevant resources other than government studies or peer-reviewed papers (e.g., policy documents). A common Web-based source of information on regulatory status, safety standards, exposure limits, and health effects for specific contaminants would be invaluable. Basic information should be presented in lay and user-friendly formats, and could be linked to more detailed data housed in various agencies.

    And on page 15 the draft states:

    Achieving these outcomes will likely require that …(4) government information discloses both the ‘knowns’ and the ‘unknowns’ in existing scientific knowledge about chemical exposures and public health;

    We would like to see the following added to this section: It would be extremely valuable to health professionals who have to communicate risk from chemicals to have easily discernable information on what health outcomes and populations have been adequately tested and what is still needed on a given chemical or substance. The agencies that have reviewed the toxicity literature to developed health based guidelines (USEPA IRIS reference doses, ATSDR minimum risk levels, for example) should summarize what is known and unknown about toxicity in the form of a checklist or matrix of acute and chronic health outcomes or systems studied, such as cancer, endocrine system, neurodevelopment, etc that should be studied for each chemical. They should also include the types of populations which have been considered, since studies on a particular population (say workers) may not be generalized easily to other groups (say children). Their database should include an entry for each of these health outcomes and populations (adequate studies, very few studies, not studied, not relevant, based on similar structure to another chemical, etc), as judged by the agency that issues a guidance or risk level based on these studies. The agencies review the literature, so no more resources are required. Many of the toxicity studies are already standardized. It is just making their review, and what is unknown (ie data gaps), more transparent. Perhaps this table could even give the exact references of the studies.

    Recommendation #3 states :D evelop, perhaps under the auspices of the National Library of Medicine’s existing Toxicology and Environmental Health Information Program, a comprehensive online portal for information on health and chemical exposure.

    We suggest adding:
    Agencies that use information on health and chemical exposures to develop risk information, such as USEPA and ATSDR, should tabulate the health outcome studies and types of populations that were included and the health outcomes that had not yet been adequately studied at the time of their analysis, in the form of a checklist so that missing data is readily discerned, and the strength of the evidence for recommendations is clear. A standard list of possible acute and chronic health outcomes and types of populations to study should be developed and next to each it should be stated whether there were an adequate number of studies, very few studies, not studied, not relevant, studies on chemicals with similar structures, etc for each chemical under consideration. This list should also be kept updated by the TEHIP.

    The original e-mail submission is attached.
    [file] Conversation.doc[/file]

  19. Jennifer McKinnis

    "MCS" Beacon of Hope Foundation

    We have attached our summary regarding the issues you proposed. Thank you so much for this opportunity to share the collaborative views of our particular community.

    Sincerely, your friends in Hope & Health,
    Peggy, Julia, and Jennifer

    “Applied Knowledge is Power ~ Prevention is Key. . .” Peggy Troiano
    [file] Conversation on Public Health ~ 20102.pdf[/file]

  20. John Tregidga


    Education is a slippery slope, as there is so much confusing information and politics tied to this so call “green revolution”.

    With the EPA only monitoring 6 of the 1400 toxic substances found in modern societies and not monitoring combined chemicals in the built environment, most of us are doomed to soak in a sea of toxic substances, never knowing that something as simple as our anti-bacterial soap combined with the fluoride and cholorine in our modern hot showers is adding toxins to our bodies system.

    If nothing else, a comprehensive database should be maintained and updated with valid information. Right now there is a start at:

  21. Michael E. Bailey

    People First, California, Orange County Chapter

    This group and their report is of fundamental importance to getting the public prepared to deal with a chemical emergency and to understand the risks involved in manufacturing, transporting, storing, using and recycling or disposing of chemicals.

    Scientific education in the K-12 public school system has follen in recent years. Textbooks have not been kept up to date by state or local education departments, middle and high school labs are old and some don’t meet requirements for safely storing and using chemicals, and necessary funding continues falling. This puts scientific illiteracy on the increase at a time when basic information about chemicals is needed now more than ever before. We need to raise money aimed specifically at improving science education in the K-12 school system. This can be done by placing a sales tax on chemicals like insecticides and fertalizers and/or tobacco products and aim the proceeds directly to K-12 science education. There also needs to be more incentives created to get students in teacher colleges to choose to go into scientific education as a career.

    Also, some people have greater communications challenges than others and this must be taken into account. The disabled community has multiple communications challenges including, vision, hearing, perception, thinking. These challenges can be effectively addressed and overcome but to do so will require a multimedia effort and some time. Steps to take include (1) presenting the information in simple form as possible using simple words and symbals to communicate complex ideas and information; (2) presenting the information in large print and Braile formats; (3) presenting information in audio recording format; (4) having websites card reader accessible; (5) have persons trained to communicate in American Sign Language to present information to deaf communihty organizations; (6) know who the target audiance is and if members have primary languages other than English be able to present the information in the person’s primary language. And persons communicating with the deaf community should also recieve training in how to use the California Relay Service for the Deaf in the communications process.

    Thank you.

    Michael E. Bailey, People First, California, Orange County Chapter, 25801 Marguerite Parkway, No. 103, Mission Viejo, CA 92692.

  22. Stephanie Wozniak

    My general comment after briefly reviewing all of the draft reports and hearing that our nation has been officially declared the “fattest” nation on earth is this: clearly I believe the overwhelming presence of persistent, bio-accumulative, toxic, carcinogenic, mutagenic, reproductive system damaging and endocrine disruptive chemicals in our food supply, air, water and homes has made us not only the fattest, but also the most depressed, medicated, lethargic, apathetic and generally unhealthy people who are most likely to become extinct by our own actions and arrogance.

    I would like to say that without a doubt one of the most important decisions our nations leaders and scientists and industry leaders can make is to stop poisoning the population and the environment with wood preservatives and other known dangerous pesticides.

    Please see attachment for complete fax submission and work group specific comments.
    [file] Wozniak – Education and Communication.pdf[/file]

  23. Nsedu Witherspoon

    Children's Environmental Health Network

    Education and Communication report:
    The Network supports the mention of children and their unique needs in this report, however, the report can a better job of assuring that children are appropriately included and considered. Specific comments follow.

    The Network strongly supports statements such as:
    “The work group adopts a broad definition of environment to include home, workplace, school, neighborhood, and community environments, both ambient and built” (p. 3) (while we urge the inclusion of child care settings)
    “groups that merit special attention . . . include those who are . . (2) especially susceptible (e.g., pregnant women, children, elders, people with chronic illness); (3) vulnerable to being involuntarily exposed to harmful chemicals due to conditions in their home, school, work environment, or community; . . . . . (7) concerned about the issues (e.g., patient groups, parents, environmental justice groups); (p. 13)

    Areas where children should be specifically mentioned include:

    *In its recommendations 4 and 5, “Develop 21st century environmental and occupational health education for K-16+ through agency collaboration. (p. 20) and “Incorporate environmental and occupational health competencies into formal health professional education,” ( p. 21) pediatric environmental health should be specifically mentioned. Requiring environmental health education and competencies does not guarantee that children’s unique susceptibilities and vulnerabilities will be included.

    *The report’s definition of “the public” does not include children, parents or caregivers (p. 4)

    *On p. 5, the report states: “Based on the research literature and the work group‘s experience, in the emergent situations described above the public often wants to know: (1) if and to what chemicals they have been exposed.”

    The Network believes a more accurate statement would be: “Based on the research literature and the work group‘s experience, in the emergent situations described above the public often wants to know: (1) if and to what chemicals they and their loved ones have been exposed.”

    Since children cannot identify risks, remove themselves from harm, describe exposures or events, or link symptoms to exposures, they must rely on their parents and other caregivers to protect them.

    An important resource for protecting children is Executive Order 13045 on children’s environmental health and safety and the interagency task force it created.

  24. Diane VanDe Hei

    Association of Metropolitan Water Agencies

    Attached please find the comments of the Association of Metropolitan Water Agencies. Thank you for the opportunity to comment.
    [file] Conversation_Education comments.pdf[/file]

  25. Lisa Ragain

    Aqua Vitae

    [file] Conversation Com.pdf[/file]

  26. Barbara Rubin


    This is primary to any educational effort. The public will not accept information from sources which are inaccurate, biased, steeped in conflicts of interest or are presumed so, based upon historical events. There is no question that the public trust has been violated on multiple occasions in the past decade, in highly publicized events surrounding toxics. In 1999, West Nile Virus entered the US through New York City. Aerial applications of malathion were made as the public was given false reassurances of malathion safety. A bi-partisan congressional hearing took place the following spring revealing the delayed publication of an MMR report on Florida illnesses from malathion and the ‘misplacement’ of citizen reports of illness by the NYC Department of Health during the crisis. Physicians were inadequately counseled as to bio-monitoring for the problem and when pyrethroids (Scourge, Anvil) were substituted for malathion, no bio-monitoring was possible since no labs had permits in the state of NY to assess pyrethroid metabolites in bodily fluids. New Yorkers were assured of safe air quality in post 9/11 New York City even before test results were taken and residents/respondents in that area are critically ill today. Information was withheld regarding lead in the water supply for the District of Columbia for nearly a year by public officials before that story was broken.

    In more personal terms, citizens researching their need for vaccinations cite more recent erosions of trust. When the swine flu epidemic occurred, the numbers were presented to us as overwhelming evidence of widespread infection of a specific form. Then we learned that no differential diagnosis went into the process of collecting this data. Unless hospitalized, flu patients were not differentially diagnosed in their infection being swine flu as opposed to other forms of influenza, also known to take a high toll in morbidity and mortality in our country every year. Conflicting recommendations of Canadian vaccine science discouraged dual vaccinations for swine and traditional flu while the FDA encouraged it. Next, we learned that women need about half the antigen as men due to differential levels of immune system activity. In such a case, the public cannot trust a system which wastes a quarter of all antigen made on dosages for female patients and will correctly worry that too high a dosage of vaccine antigen may increase risks for autoimmune disease. In the meantime, shortages might have been alleviated by reducing dosages for women.

    Then we also had to deal with the methylmercury issue in flu vaccine vials. Apparently it was incorporated as a preservative in the mass dosage vials but not in individual dose vials which were hard to find. In a country where refrigeration is available and the full number of vials was expected to be used up almost immediately following production and distribution, the inclusion of this ingredient raises many questions of trust. Certainly when a formulation absent mercury is available, most reasonably well informed individuals would reject the one with this toxic additive. Again, this has nothing to do with autism debates or other complex issues but a straightforward issue of public trust that unwanted material will not be forced upon us when the risk is not necessary to take. We don’t want to be poisoned because industry can make a larger profit (short-term anyway). The Canadian government has largely banned cosmetic lawn pesticides as ineffective and harmful. They are being sued for lost profits. Fear of industry retribution for restraint of trade is not sufficient reason to increase risk. Our congress has the constitutional right to legislate business if deemed necessary. That should not be a consideration in your deliberations.

    It is not too much to expect that the facts deemed important by the public or regulatory agency will be offered ‘up front’. Once the facts finally become available to us in some newspaper expose′, we aren’t merely informed by that news brief but come to believe our primary information sources in the health field are unreliable due to aforementioned conflicts of interest. Among the oxymorons the public is given is about ‘safe levels of poisons’. Language is a precise tool. If something is a poison, then there are no truly safe levels while safe materials (e.g. water) can develop toxic effects at a particular amount. Still, water is not a registered chemical poison. The process by which we eliminate chemicals which are not compatible with human physiology from our bodies, incites some degree of oxidative stress and interferes with catalysts needed in normal functions (e.g. endocrine disruptors, cholinesterase inhibitors). That too, is a toxic response by definition of a poison and the subject of concern doesn’t acknowledge other sources of similar toxicity encountered daily which magnify the effects (additive or synergistic relationships).

    Above all, the consignment of those with overt toxicity responses to exposures deemed to be ‘safe’ (misleading term), alienates the sizable segment of the population so dismissed. One cannot trust a source which calls you ‘abnormal’ when you were just fine prior to an exposure. Since half of patients are not responsive to the bulk of medications manufactured due to genetic diversity, it is pointless to discuss such diversity as one would genetic defects. Any loss of tolerance to toxic substances is likely a byproduct of exposures which have been presumed ‘low’, yet never measured. I have personally measured large amounts of toxic substances in residences one would never expect including: methylene chloride, formaldehyde, petroleum hydrocarbons, banned and current use pesticides such as chlorpyrifos, cypermethrin, chlordane, lindane and others. Never did I expect to see such results indicating that our environmental groups and government agencies have no idea what is actually lurking in the corners of this country. Why don’t we know about such things? Interestingly, the city council in NYC tried to ban citizens from doing environmental testing of air/dust etc. without a police permit. Evidently, the private testing going on after the West Nile Virus outbreak and then post 9/11 leads to too much information. Since the NYC governments weren’t truthful with the public on either occasion, the public needs to know it can do it’s own relatively low cost assessments. Independent laboratories are essential for this purpose and once the public can make it’s own determinations about their own indoor air quality, we will see increased industry and governmental responsiveness to the realities. Industry will diversity as citizens spend less money on products which pollute their homes – in lieu of government regulation perhaps.

    Trust is very basic to the concerns of this committee if the public is to be reasonable in processing information about this subject. The public often dismisses real hazards fearing threats of job losses if we reduce uses for certain pesticides or remove formaldehyde from construction materials. The public may also enlarge their view of hazards through a presumption that they’ve been downplayed for profit.

    It works both ways. The solution may be in easily accessed pools of data that individuals can obtain via phone or by internet, and which can be viewed as sources without distortion or conflict of interest. Perhaps ratings applied by independent ‘watchdog’ groups on such press releases can be added to increase public confidence in the information found there listing those remaining questions related to the issue which have yet to be conveyed.

    Different Views of Risk:

    This argument is completely specious unless it is only a concept applied under circumstances which require toxic chemicals to be introduced into a setting. We must always begin with the question of whether or not any risk is required for a particular context; not how large a risk to take in every context. Let’s take examples from our schools.

    After the Seton Hall dormitory fire in NYS, where the combustibility and gases emitted from burning polyurethane foam furnishings contributed to the fatalities, the refurbished residence did not purchase similar furniture. It was deemed an unnecessary risk. The fire-fighters of America are all urging that we now dispense with brominated flame retardants in furniture to reduce toxic emissions as they fight fires—as if their jobs weren’t sufficiently dangerous. Were you aware that dryer sheets like Bounce have warnings on the boxes saying not to use it on baby clothing because it increases flammability of the material? Yet they don’t mention hazards from inhalation of the softening agents. Those are petrochemicals which coat the rayon cloth and are then released from the sheet by the heat of the dryer to treat the clothing. Just what is the difference between risks worth assuming and those which any physician would tell an asthmatic patient to refrain from taking? At what point is the public considered ‘disturbed’ for their unhealthy life style? Much blame is centered on that for rising health care costs. At the same time, citizens are being called alarmists or ‘disturbed’ for inquiring into the particular hazards cited in lifestyle choices. How do we differentiate risks from lifestyle choices which are voluntary like smoking and those which are involuntary due to ignorance (eg microwaving popcorn with diacetyl, which asthmatics have long known was a problem). Consent to risk is not something which should be assumed. The public has no need to consent to it through mandated ignorance and irresponsible advertising (e.g. Lysol spray shown on TV used as a room spray when the label says surfaces only – air can’t be disinfected in such a manner).

    Shouldn’t risks be labeled alongside of the ingredients in some form of quantification like warnings on pesticide labels (caution, warning, danger)? If industry chooses not to re-tool itself based upon their own R&D studies showing hazards, then they can decide if it is needed through consumer choice.

    The House Committee on Agriculture has refused to release the School Environment Protection Act (SEPA) for a floor vote for over a decade now. In the interim, a number of pesticides long used in school buildings have been banned when the degree of harm became impossible to ignore any longer. The SEPA bill proposes eliminating neuro-toxic and endocrine disrupting pesticides from use in schools and to have a graded approach to selecting pesticides for use. These would require selection of least to most toxic, with notification of staff and parents before the latter category are applied. That would allow individuals to have choice about the degree of risk they feel is warranted to take for themselves and their children.

    One has to wonder why anybody dealing with chemicals on farms has the authority to determine which among those same chemicals are appropriate for indoor settings. There are no differential assessments of these products in each context and agricultural workers have a high incidence of injuries. Why isn’t there a default position that we would never choose to use poisons around children unless absolutely essential – in which case further measures would be taken to minimize exposure such as notice, signage, and careful review of re-entry strategies for school children and their peculiar conditions. Asthma is the largest cause of missed school days in the country and contributes to adult losses in productivity as well. Risk cannot be properly assessed because the chemicals haven’t been properly assessed. How that could be accomplished when approval for marketing these chemicals does not require studies on the entire product but just the active one? Where are the post application measurements which tell us how much residue generally remains airborne from these aerosolized chemicals over ensuing days, weeks and months? There are none although if you take measurements, you will likely find measurable levels of DDT and chlordane banned in the sixties and eighties, respectively despite widespread objections to their removal from the marketplace.

    When contemplating risk ,there needs to be a context presented which shows that some degree of risk is required. Then it becomes logical to weigh the nature of those risks as mentioned in this draft article. Then we can consider the degree of benefit to be gained from a chemical (as with the use of benzene in fuels so transportation vehicles can exist) for the population as a whole and not just to sellers of benzene. The conflict of interests are staggering when you leave context out of the risk assessment process. The public can’t possibly agree upon risk when risk is imposed without justifiable cause, other than the fact that an industry wants to sell more of their product than the country requires. The public can’t possibly participate in selection of acceptable risks while being misled about ‘essential needs’. Why discuss pesticides as a cure for asthma provoked by roach carcasses, when pesticides cause asthma? A vacuum can remove roach carcasses after they are repelled or killed by least toxic means. Risk is being presented in an unacceptable manner to the public as if it is a requirement. When triclosan was introduced into every product, now threatening the health of all Americans, just what need was being met? How important was it to add an antimicrobial to toothbrushes when it is recommended they be replaced on a regular basis? A large part of risk reduction is in ascertaining when there is a need for toxic chemicals and then differentiating among them. Most of those are in construction although better choices can be made there as well for most settings. In this vein, most of us are unaware of when risks are being undertaken at all. We don’t know that a visit to a park just sprayed with defoliants isn’t a healthy exercise at all. We will be more willing to accept risk when we can be assured it is being assessed properly.

    Scientific Illiteracy:

    There is a vast confusion about this in the minds of the public because of the stranglehold that industry holds over regulatory agencies The public looks at scientific facts as something you arrive at through a democratic process of counting the number of studies on each side of a question (despite there being many positions in between) with the majority ‘ruling’ the day. Every study ends with further questions worthy of analysis but it does not mean the findings are in dispute. Good studies can be judged as to their validity through peer review. Good studies will be successfully replicated for reliability determinations. Once deemed valid by one’s peers and reliable through one or two reproductions and expansions, just how many more studies must be funded over how many decades for those conclusions to be deemed ‘factual’ for policy making?

    The basics of how inquiries become part of the body of scientific knowledge is important not just for the public to learn but for the scientific community to agree upon so that timely decisions can be made about chemicals and turned into policy. The ‘unknown’ isn’t necessarily unknown but may just not be available for study or viewing by the public. We only knew of the extent to which Avandia affected cardiac function because public funding of medicare and medicaid allowed records to be reviewed of what happened to patients taking that drug. The manufacturer had no duty apparently to reveal all they knew about it or to even run certain studies for unexpected outcomes. Nonetheless, the mortality and morbidity of Avandia users doesn’t change.

    A good study, unless refuted, must be accounted for in terms of actions taken to ameliorate the hazards it identifies. All the media reports is that there is debate or uncertainty about the toxicity of pesticides when the toxic functions of those products constitutes the basis for their sale. Only the degree of harm to non-targeted organisms is debated and those variables aren’t being studied in any systematic manner by regulators. For pesticides that would include the manner of application (delivery devices aren’t regulated); cognitive performance changes in exposed populations; cognitive deficits in lab animals instead of just mortality rates; altered environmental conditions affecting toxicity determinations etc. The availability of good alternatives make the risks entirely unnecessary to assume but that is for another topic but brings us to comparison values – X is less toxic than Y. That last places the onus of safety testing upon the makers to use as a way to have their product added to the list of least toxic products.

    We also have to realize that studies are not subject to industry rating according to defense cases in the courts where only Daubert approved scientists can introduce evidence. Many toxicologists whose income is derived from court appearances aren’t going to permit many studies into evidence which might be in opposition to their positions. Yet, they can’t all be consigned to the category of ‘bad science’. However, we do have a problem of ‘no science’ in that many tests of patients and their environments are not ordered because there are no facilities to investigate them. So, while pyrethroid pesticides are the bulk of those in use today in every area of our lives, there are no labs which assess metabolites in blood or urine for exposed parties. Very few environmental labs test for them as well because they aren’t part of the regulatory system demands.

    Illiteracy happens where there are no books to be read. Even if you know how to read. That brings us to:

    Access Barriers:

    Most individuals now know the value of label reading except that labels aren’t educational in their absence of solid information to consumers. Most learn from reading labels and seeking information about words which lack meaning to them. Labels are excellent media for communication but we waste them. Any recommendation for transparency of the process of dealing with toxics requires an end to the obstruction of the flow of information to the public. Even regulatory agencies may remain in the dark about many constituents of products which aren’t regulated or, if in their possession, are restrained from sharing the MSDS information on them when FOIA’d by consumers citizens who were Similarly, if government studies are to be held to a high standard, the same standards must apply to studies put before the government to review prior to the marketing of a product.

    There should be no product on the market which is lacking in facilities to assess appropriate biomarkers for exposure. Only that way can we determine a range of concentrations associated with adverse effects. Shamefully, that is tantamount to human testing in product research and development but until the US adopts the REACH or similar EU process, we are the lab rats for post-marketing data collection on adverse effects of chemicals. As mentioned above, there are no medical labs to test for metabolites of the most common chemicals used in the country – pyrethroid pesticides and DEET which are all recommended or mandated for use in much of the country. In 2002, some three thousand individuals were tested by the CDC and 70 percent had these biomarkers in their urine. Why are such tests inaccessible today? Since products are safety tested after marketing in the US, then the experiment conducted on consumers must have parameters which allow data to be accumulated by treating physicians seeing such symptoms associated with this. The biomarkers are also a clue that the methods of application of these chemicals are inappropriate. How can they be applied without absorption by human occupants?

    Medical histories will remain incomplete as long as there is no mandated release of information regarding chemicals in the environment from proprietary labeling. Also, lack of advance notice to individuals present in a setting where chemicals are employed is a major access barrier (see discussion of SEPA laws above).

    Lastly, our justice system is providing an almost insurmountable barrier to information access. When harm is demonstrated in a court proceeding, there is a record of the science which went towards proving it. What about all the sealed settlement agreements which serve as the cost of doing business in many industries? A view towards making public the applicable science which enters into legal proceedings should not be ‘sealed’. It is not a reflection upon the participants in a suit but of demonstrable evidence towards safety issues affecting us all. Litigation of this sort is a barrier to access of information about the real harm done to individuals by toxic chemicals. That needs to be addressed. Otherwise, lawyers continue to ‘try’ and settle the same cases over and over again at a profit to them – but a loss to society.