The Monitoring work group is focused on facilitating the collection, analysis and interpretation of information on chemicals, including their sources, uses, exposure, and associated health outcomes. 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

    Thank you for the opportunity to comment. I apologize in advance if my questions are outside the intended scope of the working group’s document, however, I see two general issues that I would invite attention to.

    Firstly, the document describes a concatenation of monitoring and surveillance programs of various types. Really, just looking at the terms and definitions section gives one a good sense of the diversity of what is included. While I most emphatically do not wish that to be taken as a criticism, I wonder if these topics might be categorized in a more cogent and organizing manner.

    Secondly, while the term “biomonitoring” has emerged in the scholarly literature, in clinical practice one usually refers to clinical or diagnostic testing or clinical pathology or laboratory medicine. My point here is not to quibble over terms, but, perhaps, to helpfully highlight that some further consideration might be directed to how the measurements of any of these substances will be, or is being, transitioned into clinical interpretation and practice. It strikes me that the visionary capstone piece of this project eventually has more to do with encouraging the appropriate clinical measurement of these compounds or their biological impact and their correct medical interpretation as part of the comprehensive healthcare of the individuals potentially exposed than the document at present reflects. I do not know how, in a medical context, one deals with many of the questions that may arise relating to exposure assessments based on environmental data and the risk of harm to an individual.

    Needless to say, these comments are an expression of my personal opinion and do not in any way reflect the opinion or policy of the US EPA.

  2. Ernest Grolimund

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

    Thanks for the opportunityto try to help and contribute information and ideas. This is very neccesary.

    Monitoring is very sparse and hard to do. It is also costly and takes a lkng time in emergency situations. Reliance on only monitoring for wood smoke is therefore bad. In many situations 6 hours of woodsmoke at 30 mcg/m3pm2.5 can cause heart attacks and asthama attacks, so victims could die while waiting for the test to be done. A better approach would be to take the design level of ambiant pm and add modeled pm for total pm estimates at the site or sites in any given state. Ie, in Maine the design level is 27 mcg/m3 or about 30 mcg/m3 pm2.5. Maine DEP modeling showed 50 mcg/m3 pm2.5 would be the conc from whole house heating in calm winds. The toal would then be 80 mcg/m3. This is very dangerous but nobody seems to know this. This modeling could be used to prevent problems before they occur if appropriate bans are put in place to prevent worst case pollution from harming health. Spot monitoring checks it from advance portable monitoring in 5 cities in B.C. Canada. Their 5 city ave was 80 mcg/m3 as well. 95% of the houses nearby would have pm violations therefor a ban is neccesary noyt a slow changeout program. Knowledge of the approx pm could be a guide to inspectors and health officers or a check to monitoring.

    Advanced monitoring on occasion could be pegged to the existing pm system to give a better estimate of the pm in a state. Ie, if advanced monitoring showed the ave pm in a city is 45 mcg/m3 and the monitorred pm is 30, you cpould divide 45 by 30 and get a 1.5 multiplier to more accurately establish ave pm values. Maximum pm values could also be determined this way. Right now we have a system that collects the lower values and thus errs on the side of polluting sources not on the side of life and health which judges have expressed is the law.

    The whole method of modeling for large sources is well developed and accepted and should now be apllied to small sources like stoves and boilers and fireplaces. Right now a large incinerator causes less pm than a residential stove!!! And stoves are very common!!! This is leading to citires being engulfed in wood smoke in the last few years in an energy crisis. It must be investigated by DHHS policy and it must be researched with innovative methods but the ATSDR is refusing to do this very cost effective modelling. Wood smoke contains about 180 toxic chemicals that could be tied to pm monitirng by proportion. It seems the ATSDR is only concentrating on 86,000 chemicals from industry alone because it cannot treally cope with this mandate to study indiv chemicals but the result is a toxic emergency and air pollution emergency not being dealt with and millions of victims like me being poisened. This is a failure of the health system that does not have to happen.

    There are other monitors besides expensive pm monitors that can help prevent trouble. Our eyes and noses are good monitors and any smoke that can be seen or smelled should be outlawed like second hand tobacco smoke or “Debris Smoke” mentioned on the CDC website. Fast, cheap, simple, easy.

    Combine all this modeling and the use of human sense monitoring and grest progress can be made in saving lives, protecting health and reducing global warming. It could save the country $150 billion dollars a year for a comparitive pittance and the Boston ATSDR toxicologist reccomends modeling be done. Trouble id the ATSDR Dep director Sinks is being penny wise and dollar stupid in not doing modeling. This needs to be corrected. He will not listen to an individual limke me but he will listen to Dr Bulbus or other government officials. Not listemning to me and only listenig to state officials allows state negligance in dealing with this issue to continue. Negligance on the part of the ATSDR and EPA and CPSC is also apparaent and the complete failure of gov on this issue is causing citeis to be engilfed in wood smoke. Photos of Denver, Salt Lake City and Shelbourne Falls MA exist proving this is happening and modeling and census data can be combined to estimate ave pm values. I calculated about 45 or 50 mcg/m3 pm2.5 from Maine DEP data and this is checked by the ave design pm value in U.S Cities.

    Please do something about this. Thank You.

  3. Frederic Pfaender

    UNC Chapel Hill SRP

    Well done report that recognizes many of the existing problems and makes realistic recommendations. There are a few issues that should be addressed.

    1. It needs an executive summary

    2. The call for data integration is very important- to do this the issue of sampling and analytical methods should be addressed. In many cases we are comparing apples and oranges and do not recognize that is what we are doing. Effort needs to address how to integrate the measurements as well as the data.

    3. A major effort is underway to integrate medical records. There might be something to learn by looking at what is happening in that area.

    4. What is often lacking in trying to integrate disparate data is a conceptual model of how data and information from different sources, chemicals and exposure media are related. That model needs to be built, validated and accepted or we are just introducing another level of complexity within a system that is already unmanageably complex.

  4. Eileen Senn

    Independent Industrial Hygiene Consultant

    In your view, what are the most important recommendations put forward by the work group?
    Recommendations 1, 2, and 5.

    Do you have suggestions for strengthening the report or any of the recommendations?

    To strengthen recommendation #2, a proposal should be added for NIOSH to repeat the National Occupational Exposure Survey (NOES). The qualitative and semi-quantitative exposure information in NOES, including chemical exposure information, has been valuable to many researchers. It is now outdated because industries, occupations, and exposures have changed much in the past thirty years.

    To strengthen the report, the page 7 narrative on monitoring databases should be enlarged to include occupational health monitoring databases, including:

    OSHA Chemical Exposure Data, Sampling results represent personal, area, and bulk samples for various airborne contaminants. Personal sampling results represent the exposure to the individual who was actually wearing a sampling device. Area samples are taken in a fixed location and results may represent the potential risk from airborne contaminants or physical agents to workers in that area. Bulk samples were taken to verify if certain constituents are present and if so, in what concentration. Bulk samples are used individually or in conjunction with personal or area samples to help interpret the level of worker risk.

    National Occupational Exposure Survey,
    NIOSH conducted the National Occupational Exposure Survey (NOES) from 1981-1983, collecting data on potential occupational exposures to chemical, physical, and biological agents. The survey involved on-site visits to 4,490 establishments in 522 industry types [OMB 1972] employing approximately 1,800,000 workers in 377 occupational categories [Census 1980]. Nearly 13,000 different potential exposure agents and over 100,000 unique trade name products were observed during these on-site visits.

    NIOSH Health Hazard Evaluation (HHE) Reports,
    Employers or employees may request an HHE when there is a concern about a health hazard in the workplace. NIOSH may investigate and collect industrial hygiene sampling and review medical records. Biological monitoring may be conducted. When all the information and data have been analyzed, NIOSH issues a report of its final determination, giving findings and recommendations. The reports contain detailed sampling, medical, and biomonitoring data.

  5. Geoff Calvert


    In the recommendations section, in addition to requesting expansion of EPHT to all 50 states, also consider expanding SENSOR-Pesticides funding to all 50 states. Currently, the program is conducted in 12 states, but only 5 of thsoe states receive federal funding. More info on the SENSOR-Pestcides program is available at:

  6. Elaina Thomas

    An American Citizen Who Cares

    I want to see Recommendation #1 totally enacted – The Clearing House for Chemical Emergencies is a must!!!

  7. Cindy Mathews

    Private Citizen

    In my view, all the recommendations sound like very good ideas, but I think that Recommendation #1 is most important. A Clearing House for Chemical Emergencies would be key in preventing a disaster from being worse than it has to be. If this were already in place, many lives could have been saved already — in my community and many others like it. This is really a must!!

  8. Linda Jacobson

    Several years ago, I realized that if I was exposed to plug-in or continuous spray air fresheners, my Hashimoto’s disease went into flare-up, within 2 days (that’s how soon my blood was tested after the exposure). In each case, my thyroid numbers went back to normal, gradually, over the course of a month. These exposures could be indirect and minimal (e.g.., sitting in a hall outside the office suite that used the products for 10 minutes). At the same time, I had many symptoms of a flare-up of ulcerative colitis. However, since I no longer bleed even in the worst flare-up, this can only be verified by an invasive procedure, and I have not done so.
    Since then, I have tried contacting the Colorado Public Health Dept., CDC, EPA, NIH, and the local office of the ATSDR, all of whom referred me in a round robin to nowhere.
    This is of particular concern, because several local hospitals and clinics use these air fresheners. If I am in a serious traffic accident near one of these hospitals, the additional compromises these products put on my body could mean the difference between life and death.
    Although I have notified these establishments, I have had mixed success. One hospital wrote that, since these products were legal, there was no reason to stop using them. An endoscopy center across the hall from my orthopedic doctor told me they “had” to use them.
    These kinds of situations need to be addressed by:
    a. Providing an easy to access, well-publicised database where individuals and doctors can report such anomalies.
    b. Educating hospitals and clinics about what they need to do to be accessible to ALL patients.

  9. Joseph Carey

    Call me

    Please seek complaints about pesticide treatments that temporarily and permanently poison the living environments to the extent that the occupants become ill and must vacate their home or workplace and avoid contact with poisoned possessions from within in order to return to the health they enjoyed prior to the treatment.

    My research indicates that pesticide treatments gone wrong in the home and in industry might very well be a silent epidemic of human illness, destroyed health and personal dysfunction.

    I may be contacted for an in depth presentation of this matter.

    Reference data:
    On 11/12/09 my land, home and garage were treated with liquid and powder pesticide poisons to eliminate termites and carpenter ants. As an unexpected consequence all treated living environments and areas, including possessions within my home, became toxic and detrimental to my health and well being.

    I cannot breathe the air in these environments or come in contact with possessions that were exposed to the pesticide fluids, vapors and powders employed without getting seriously ill. My neighbors may also be affected.

    Away from the poisoned environment I enjoy the good health I had prior to the treatment. Consequently I cannot go home or come in contact with anything from my house and 9 months later it is the same with no solution in sight.

    Joseph J. Carey

    Ps. My background includes being a Corporate Quality and Regulatory Affairs Director, Chief Engineer, Product Design Engineer, Technical Consultant and Radiation Safety Professional for Medical and Industrial Electronic Manufacturing Corporations.

  10. Diane Hanna


    I read the draft & I could not find any information noting past exposure to chemicals. I have attached Mr. Eckel, EPA’s published report. Said report speaks for itself. From that report, I reviewed, on-line, all of the known and unknown toxic sites in Philadelphia, Pennsylvania. The CDC & the ASTDR have no idea the number of people who are now ill with auto-immune disorders, i.e., multiple sclerosis, parkinsons, lupus, etc. (because these disorders are not communicable diseases) despite the monitoring air data in the 1990’s (copy attached) which revealed “the highest in the nation” of a combination of chemicals (lead, arsenic, cadmium, etc.) released specifically in the Philadelphia area.

    The EPA did some demolition at some sites, but did not remove the piles of chemicals, which are as big as (one to two city blocks long). Instead, they are covered with tarps, fenced in “non-securely” & posted a sign “Danger, Hazardous Chemicals”.

    A full investigation of all known and unknown to state and federal agencies needs to be addressed as well as the latency period of exposure to those chemicals emitted into the air and noted on the attached air monitoring document again in Phila., PA in the 1990s.

    Please let me know if you have any questions and I would be more than happy to speak with you.

    Thank you, Diane Hanna 215-891-1505
    [file] article — unrecognized lead smelting sites.pdf[/file]
    [file] Monitoring data-EPA 3-27-1995.pdf[/file]

  11. Nancy Evans

    PLEASE NOTE: These comments were prepared in collaboration with Cindy Sage, Sage Associates, Santa Barbara, CA.

    The National Conversation on Public Health and Chemical Exposures needs to acknowledge that non-chemical environmental agents such as radiation, particularly non-ionizing radiation, called electromagnetic fields (EMF) can intensify the toxic effects of chemical exposures.

    A substantial body of evidence suggests that electromagnetic radiation (EMF) can potentiate the effects of chemical toxins and therefore needs to be considered in monitoring environmental exposure and in achieving a more complete understanding of chemicals and their health effects. For example, nursing staff and other healthcare workers may experience multiple, harmful exposures (chemicals, heavy metals, other toxicants) in combination with EMF exposures as wireless technologies proliferate in the healthcare environment. In a meta-analysis of 65 studies, Juutilainen et al (2006) reported that the combined effects of toxic agents and ELF magnetic fields enhanced toxic effects as compared to the toxic chemical exposure alone. Overall results showed that 91% of the in vivo studies and 68% of the in vitro studies had worse outcomes (were positive for changes indicating synergistic damage) with ELF exposure in combination with toxic agents. The percentage of 65 studies with positive effects was highest when the EMF exposure preceded the chemical exposure.

    Juutilainen J, Kumlin T, Naarala J. (2006). Do extremely low frequency magnetic fields enhance the effects of environmental carcinogens? A meta- analysis of experimental studies. International Journal of Radiation Biology 82:1-12.

    The Monitoring Working Group report defines exposure [lines 153-154] as “the amount of a chemical, physical or biological contaminant at the outer boundary of the body available for exchange or intake via inhalation, ingestion, or skin or eye contact (EPA, 2008).”

    Exposure assessment is defined [lines 156-158] as “the process of finding out how people come into contact with a hazardous substance, how often and for how long they are in contact with the substance, and how much of the substance they are in contact with (ATSDR, 2009).”

    EMF is a physical contaminant that can be measured. Unless the electromagnetic environment is also monitored/assessed in a manner similar to the chemical environment, the environmental assessment is incomplete.

  12. Barbara Rubin

    To Whom it May Concern,

    I only received word last night of this project and that comments were due by five o’clock this afternoon. As there remains only one hour now before I can send you comments, please forgive this generic submission. Some of theses issues are crucial to the American health care system already stretched to the point of collapse as nearly a third of American adults (to age 64) and a quarter of our children are demonstrating chronic health conditions and disabilities. Our soaring rate of developmental disabilities which now affects one in six children according to Dr. Phillip Landrigan of the Mt. Sinai Hospital Center in NYC, is a good measure of our need for better management of chemicals.

    I am a clinician and special educator who was disabled with permanent central nervous system and metabolic damage at the age of 45, by toxic chemicals used in a school setting. I became a whistle-blower through calling in the EPA to investigate misuse of pesticides and began a decade of learning about your areas of study. I hope my discoveries regarding the large gaps in public policy will be of use. Please let me know if I can offer further detail of these major points to you after your deadline. My mild aphasia and acquired ADD as a result of pesticide poisoning does not make this an efficient process.

    1.Education: Citizens are generally referred to as consumers in this country. This has allowed us to become confused regarding a citizen’s right to safe drinking water, an unadulterated food supply, and clean air in our enclosed living and working spaces. Instead we are approached only in our role as good customers for the industry best able to advertise a quick answer to any of our needs. As we see in the larger economic picture, buying cheaper and more readily obtained products and services (e.g. construction, pest control, laundry services) can result in a far more costly cascade of events such the lost productivity and school attendance of children and adults suffering with asthma; reduction in achievements by children suffering losses of intellectual potential from lead, mercury, neuro-toxic pesticides; loss of a strong consumer base as disabled workers and those following the downward spiral to that end point (one third of the workforce) cannot use their discretionary income for anything but health care services. Citizens need to become more familiar with chemicals and that can only be done by altering a public policy which endorses ignorance. In fact, we are not permitted in may locales to know in advance when toxic chemicals will be introduced into our lives by employers, landlords and school administrators. Congress has yet to release the School Environment Protection Act from committee which would have mandated my advance notice of pesticide applications and possibly saved my health and career when such notice was denied me. Vendors selling toxic products are ignorant of their ingredients and hazards while proprietary formulas are permitted, eradicating freedom of choice on the basis of health related standards. Education in all subjects is, well, subject to public policy as follows.

    2.Public Policy:
    a) Full disclosure of ingredients in all products: Since patents protect industry formulas and exact proportions of ingredients are not released to the general public, mandates of full disclosure for 100% of a product’s contents is essential. Capitalism is a trickle up policy by which consumers control the marketplace according to demand. One cannot demand the best quality products when secrecy makes knowledge of what constitutes “best” from the process.
    b) Full disclosure (non-punitive) of all applications of toxic chemicals. Staff and parents need to know when schools are receiving insecticidal treatments. Communities ought to be able to go to the clerk’s office and know what is in use in farm fields so they can decide if living in a particular location is a good choice for themselves and their children. The EPA does not receive notice of farmer’s use of herbicides and pesticides which do not require a license to obtain. Numerous studies show drift is a serious issue for many miles in farming communities and has been seen to cause changes in central nervous system functions.

    c) Oversight of chemical use has long been a source of conflict of interest. The department of agriculture is intensely involved with a very specialized industry. Their involvement in the management and enforcement of pesticide laws (FIFRA) in our residential and non-farming industry practices is entirely inappropriate. People are not crops and the use of agricultural chemicals indoors completely alters their actions and efficacy as well as endangering a large group of non-targeted living beings. In schools, hospitals, and nursing homes that means our most vulnerable populations are exposed to chemicals which are not only going to act upon them differentially than healthy adult males (current reference group) but also interact with medications being taken (particularly cholinergically active medications) for a wide variety of normal developmental and abnormal health conditions. A body of scientists and citizens ought to be reviewing the use of industrial chemicals in non-industry settings. SEPA has not passed because the House Agriculture committee will never approve such measures. Notice of applications and restrictions in the class of chemicals applied in schools is counter to the wishes of agribusiness.

    3. Bio-monitoring: Recognition of chemically induced illness is very poor for a variety of reasons. This can only be overcome by increasing the ease of bio-monitoring for components in indoor air and of blood/urine metabolites for commonly encountered chemicals. As of this moment, there are no laboratories in the US which assess metabolites of the most commonly used pesticides in this country – pyrethroids and DEET. The fact that older use pesticides became regulated (and a number banned) as bio-monitoring for them became more accessible, one can only suppose such an absence of testing for pesticides, hormones and certain solvents are intentional. The CDC looked at 3,000 individuals in 2002 and found 70% of them positive for metabolites of current use pesticides. Yet they were unable to provide me with any lab facilities capable of measuring it in the population today.

    4. Enforcement: I have received two death threats in the past 13 months and had my residences and car sprayed with pesticides. Not one agency in this nation actually gets involved in crimes using common chemicals including Homeland Security, the EPA, FEMA or the CDC despite all groups being notified. They referred me to the local police who referred me back to them. Someone must take responsibility and quickly for investigating the misuse of chemicals for gain (I am a litigant and advocate for safer use of chemicals). I may not live to see my litigation to completion and have no recourse whatsoever.

    Barbara Rubin
    44489 Town Center Way 117
    Palm Desert, Ca 92260

  13. Kate Flannery


    It would be ideal if you could develop a system of incentives for private industry to begin the process of researching and adopting safer alternatives to dangerous chemicals.

    Re Rec. #5 – The public should also have greater awareness of the chemicals used in processing’s impact on air and water.

  14. Tracy Morrow

    Architects and Builder Monitoring

    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 in an exhaust fan only bathrooms!

  15. Claire Barnett

    Healthy Schools Network, Inc.

    In general, all the work group reports fail to adequately address children’s environmental health. The reports must do a better job by:

    • Making a priority of protecting vulnerable populations of children, the elderly, and others.
    • Recognizing children’s unique vulnerabilities and exposures, including the facts that children cannot identify risks, remove themselves from harm, describe exposures or events, or link symptoms to exposures.
    • Acknowledging the existence and relevance of Executive Order 13045 on children’s environmental health and safety.
    • Building on “workers/workplace” exposures as a starting point, and adding children’s exposures when they are away from home in schools and child care settings—their “workplaces” where they may have the same or even greater exposures as classroom teachers and bus drivers.
    o Children have no system of protection their “workplaces” – schools and child care centers; NIOSH and OSHA address only adult employees in those workplaces, not children who outnumber adults by a wide margin
    o Children are affected by their parents’ workplace exposures (not just take home, but fetal and preconception exposures)
    o Children are affected by “lifecycle” exposures (community exposures where manufacturing plants are located; exposures while using products; and exposures due to end of life handling such as leaching from landfills into water supplies and the transport of PCBs and C8 around the globe)
    o Children have unique environments: the womb, child care centers, schools that need to be specifically considered and are not in discussions of “worker” and “workplace” protections
    - Neither CDC’s Environmental Public Health Tracking nor the National Children’s Study is collecting any information regarding children’s exposures in schools or child care centers.
    Therefore, when EPHT and NCS are mentioned in various work group reports, it would be prudent to add that EPHT and NCS need to swiftly address these well-known issues with revised work plans that are developed with outside, knowledgageble assistance
    - Whenever NIOSH and OSHA are mentioned in various work group findings or recommendations (many locations), the report should also note that children have the same exposures – or greater– “on the job” in schools and child care centers than adults and outnumber adults by about ten to one (depending on age group and health status). But children/families have no recourse and no public services to intervene or to track or to research those exposures.

    OVERALL RECOMMENDATION. The deficits in the various work group reports regarding children’s environmental health are so widespread, and so difficult to edit into existing draft documents, we recommend that CDC convene a speical short-term task group focused just on children’s environmental health to craft child-specific recommendations into each of the reports.
    File: CDC_Conversationreportcomments-HSN_2010.doc

  16. Katie Weisman

    Coalition for SafeMinds

    The Coalition for SafeMinds was founded to raise awareness, support research, change policy and focus national attention on the growing evidence of a link between mercury and neurological disorders such as autism, attention deficit disorder, language delay and learning difficulties. Our mission is to restore health and protect future generations by eradicating the devastation of autism and associated health disorders induced by mercury and other man made toxicants.

    SafeMinds would recommend a strong emphasis on mercury monitoring in the draft report. Both the NHANES and the Canadian Health Measures Survey (CHMS) show increases in blood mercury in the general population in their most recent published reports. In 2004, Dr. Kathryn Mahaffey of the EPA estimated that as many as 1 in 6 children born in the United States could be at risk of developmental disorders due to maternal blood mercury levels. Environmental levels of mercury are rising as evidenced by the EPA listing mercury advisories for lakes and rivers in 48 states as of 2006. A study by Sunderland, in 2009, has shown that mercury levels in the North Pacific have risen by approximately 30% in the past 20 years. Studies by Palmer and Windham have linked environmental mercury levels to autism and special education rates.

    SafeMinds would like to see mercury monitoring of the general population carried out more vigorously and frequently. Specifically, we would like to see annual reporting of blood and hair mercury done in larger populations and pre-conception screening of young women for elevated mercury levels. In addition, we need to develop testing methods that are more indicative of body burden since individual metabolism of mercury varies significantly.

    SafeMinds also has concerns about the health effects of indoor mercury exposures as opposed to broader environmental exposures. As an example, coal-fired power plants are required to report mercury emissions but there is currently minimal monitoring of the disposal/recycling of fluorescent light bulbs which contain mercury. A Maine DEP report raised concerns about the air concentrations of mercury in a room where a fluorescent bulb has broken, particularly if a pregnant woman or young child inhabits the space. These sorts of individual exposures remain “off the radar”.

    Another area where work remains to be done is in establishing consistent national standards for consumption of mercury-containing fish. Currently the EPA and FDA use different standards which creates confusion. SafeMinds advocates for enforcing the most stringent standards that can be supported as a precautionary principal, particularly given the aforementioned environmental background levels of mercury we are seeing.

    In addition, we would like to see the FDA’s market basket include a broader range of fish species and more samples per species as several independent groups have found large variations between individual species, and individual fish within a species. Some attention should also be given to how to monitor specific populations that are at risk for specific exposures – for example, the rising level of mercury in arctic mammals poses a health risk to indigenous peoples. Breaking the country down into small regions and prioritizing chemicals to focus on for each region will probably yield the best results.

    We would also recommend creating moderated listserves for individual chemicals to facilitate communication between researchers, environmental groups and policy makers. For example, researchers looking at mercury emissions and reserchers looking at health effects of mercury rarely talk to one another. There is often significant lag between identification of potential problems and action taken to address them.

    Thank you for the chance to provide comments.

    Katie Weisman
    Coaltion for SafeMinds, Environmental Committee

  17. Tracy Morrow


    Over the past 12 years, the Auto industry has been consumed over new car gadgets. The space under the hood of a car is only so big that in many cases in order to add a gadget something else must suffer. And too many times it’s the Air-conditioning unit. The Auto industry has pushed, twisted, and shrunk this very important part of the automobile to the point where the complaints of mold & bacteria odor have sky-rocket out of control! We did not have this problem is the 60’s, 70’s, 80’s, or even early 90’s.

    The Auto industry knows this is a big problem and now they have created a new pesticide that they spray into the air-conditioner. According to the EPA there is NO approved chemical and/or pesticide approved for the use inside any air conditioning unit! Think about what spraying pesticides that blow in a small car cabin can do to your lungs!

    Many people don’t realize the “New car smell” is actually toxins coming of the materials used to make the interior of the car. With this new disrespect for the air we breathe, adding mold & bacteria into the small cabin of our automobiles, mixed with the chemical cocktail of the “New car smell”, I can personally tell you “it is no different than CORPRATE INDUCED BIOCHEMICAL WARFARE”!

    This environment gave me MCS. I stopped driving my new 2006 car and was forced to drive my 1994 automobile. As of today 10/26/2010 there is still not smell of mold or bacteria coming from my old 1994 air-conditioner. This proves to me it’s not the environment and/or climate we live in, it is that the auto industry needs to use the older technology when it come to the air-conditioning unit even if it means less gadgets.

  18. 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 – Monitoring.pdf[/file]

  19. Liberty Goodwin

    Toxics Information Project (TIP)


    I cannot express too strongly the need to dissociate EPA DFE Certification from industry influence. Last I heard, EPA was relying on industry research for data and conclusions.
    This is an awful way to seek reliable information on which to base product judgments! Note that Professor Van Sahl, examining all research done on Bisphenol-A (BPA), found that 100 per cent of industry funded or connected studies found no evidence of harm – yet of independent studies on the same substance, 100 per cent found serious health concerns with BPA!

    REGARDING AN EMPHASIS ON THE SPECIAL NEEDS OF CHILDREN I agree heartily with the Healthy Schools Network point that children should be the greatest concern in school environmental studies.

    So, why is it that, neither CDC’s Environmental Public Health Tracking nor the National Children’s Study are collecting any information regarding children’s exposures in schools or child care centers? EPHT and NCS need to swiftly address these well-known issues with revised work plans. NIOSH and OSHA should also be reminded that children have the same exposures – or greater– “on the job” in schools and child care centers than adults. Why, then, do children/families have no recourse and no public services to intervene, track or to research those exposures.

    - Primary Recommendation: All Work Group reports should incorporate children’s environmental health in all facets, and cite APHA policy as well as federal EO 13045 “Risks to Children’s health…”, and recommend a permanent Inter Agency Task Force to address Risks to Children’s Environmental Health and Risks to Safety.
    - Other Detailed Recommendations on closing some of these gaps in research, data collection, public education, preventive services/interventions appear in two journals:

    New Solutions, Spring 2010, “WHO’S IN CHARGE OF CHILDREN’S ENVIRONMENTAL HEALTH AT SCHOOL?”, J Paulson and C Barnett co-authors;

    Journal of Intellectual and Developmental Disabilities, “Children’s Environmental Health: The School Environment”, Trousdale, Martin, et al, April 2010.


    Chemical Emergencies Work Group Report
    - Training and capacity.
    o INSERT in opening graph – nation’s emergency response must include training in diagnosing and treating children’s exposures to chemical emergencies and spill events, including pesticide exposures. This threads through multiple recommendations. For starters, this work group might reference purpose and publications of HHS- National Commission on Children and Disasters.

    - P 14 ff Recommendations – there are too many to cite that are impacted.
    o Suggest that someone who is more familiar with the work group might be insert child-specific needs and recommendations regarding training of responders, diagnoses, tracking, med supplies, post-event remediation of child-serving facilities, etc.

    - P 16, insert:
    o Problem narrative- “Post BP Oil Spill (2010), just as post Katrina (2005) and post 9/11 (2001-02), no federal agency issued any public health advisories on preventing children’s exposures that cited examples of children’s symptoms from exposure to crude oil or benzene, or that urged local agencies to ensure that child-safe remediations of contaminated facilities were successfully conducted (homes, schools, playgrounds).”
    o The new recommendation is: HHS and EPA should collaborate with the congressionally authorized via HHS’ Natl Commission on Children and Disasters to ensure that one lead agency is required to issue timely, accurate public health advisories to all state and city public health agencies, health care providers, and schools that address: how prevent harm to children, how to recognize and treat symptoms of children’s exposures, provide medical tracking, and how to remediate chemical contaminants so that risks to children’s health are eliminated/reduced where they live, learn, and play.

    Policy and Practices Work Group Report
    - P 20, line 22, inaccurate description of EPA’s Design for Environment Program (DfE).
    o Products do not need to “meet” EPA’s criteria to get an EPA label, nor are the criteria “stringent”. The DfE criteria are LESS stringent and more flexible than existing, old, 3rd party certification standards, and DfE labeled products are not independently evaluated. EPA DfE collaborations with chemical manufacturers are actually undercutting better standards and used to lobby against strong standards in state bills pending.
    o Suggested rewording: Either 1) delete all references to DfE, or, 2) edit to read– “Examples of efforts to remedy this include … “technical assistance to manufacturers of chemical intensive products by EPA’s Design for the Environment Program should continue but its product recognition labeling should halt, until EPA restructures it to operate as a type-1eco-labeling body, and consistent with various federal laws” NYS and a five-state procurement cooperative in New England, and other states, have declined to include DfE labeled cleaning products since they cannot be relied upon to meet any known or verifiable standards.

    - P 21, add to Recommendation to Worker Protections “Improve worker protection …. by incentivizing prevention through the use of safer substitutes on jobs using hazardous chemicals (OSHA policy gives preference to safer substitutes, but employers rely on PPE and worker education)

    - P 21 New Recommendation: Improve children’s health protection from chemical exposures where they live, learn, and play. Incorporate prevention through requiring examples of safer substitutes in federal and state agency websites and publications on managing child care and households (ie, lock up toxics, vs buy and use safer substitutes); mandate IPM in all schools and child care centers; mandate the use of certified green cleaning products in all child care centers and schools; scale-up and fund EPA’s voluntary Schools Chemical Clean out Campaign and require it to fund state environment and health agencies to create robust school chemical cleanouts to rid all schools of old, outdated, hazardous flammable and explosive chemicals and heavy metals such as elemental mercury, and lead; require states agencies and school systems to adopt green procurement policies.

  20. Nsedu Witherspoon

    Children's Environmental Health Network


    The Network supports the emphasis in this report on protecting children and other vulnerable populations, such as:
    *The specific mention, in recommendation 2, of “all major microenvironments that people occupy, including residences, child care centers and schools, public access buildings, and workplaces (including offices)” (p. 19)
    * “Where appropriate non-invasive sample collection technology is available, biomonitoring studies should be expanded to include children of all age groups.” (p.20)
    *”populations with critical vulnerability, such as fetuses and infants, should be targeted for special investigations.” (p. 17)
    *” the development of non-invasive and highly sensitive new assays that will facilitate more widespread sampling and sampling of vulnerable populations like young children.” (p.16)
    *the opportunities offered by the National Children’s Study (p. 10)
    *raising the challenge of getting samples from children without using invasive techniques (p. 10)

    The Network urges the report to acknowledge more of the existing gaps in monitoring and recommend prompt action to correct the situation:
    * the National Children’s Study is not yet collecting information regarding children’s exposures in schools or child care centers
    *The CDC’s Fourth National Report on Human Exposure to Environmental Chemicals (mentioned on p. 10): while it is an extremely valuable resource (with exposure data for 212 chemicals and chemical metabolites in a sample of about 2400 participants), it does not represent “the U.S. civilian, noninstitutionalized population,” as the report currently states, since it does not generally include data on children under the age of 6. Studies show that the youngest children are quite often the group that has the highest exposures to chemicals in the environment.

    An important resource for protecting children is Executive Order 13045 on children’s environmental health and safety and the interagency task force it created, and the Network urges this resource be included in the report.

  21. Diane VanDe Hei

    Association of Metropolitan Water Agencies

    The Association of Metropolitan Water Agencies (AMWA) appreciates the opportunity to submit comment on the monitoring work group draft report. AMWA is an organization of the largest publicly owned drinking water systems in the United States. AMWA’s membership serves more than 130 million Americans with drinking water from Alaska to Puerto Rico.

    AMWA is the nation’s only policy-making organization solely for metropolitan drinking water suppliers. Member representatives to AMWA are the general managers and CEOs of these large water systems.

    AMWA supports the concepts outlined in the report and the recommendations that seek to leverage and link the data and information collected from TSCA and other chemical monitoring efforts with efforts aimed at discerning chemical exposures and disease in the U.S. population. AMWA recommends that the report include a discussion of the importance of ensuing that there are sound, comparable data quality practices in place for the many data collection programs that would be linked together. It would be important to ensure that the data used and compared across programs is of comparable quality.

  22. Barbara Warren

    Citizens Environmental Coalition

    See attached comments.
    [file] Workgroup Comments.doc[/file]

  23. Kathy Curtis

    Oregon Toxics Alliance...

    Oregon Toxics Alliance, Northwest Indiana Toxics Action Project, Alliance of Nurses for Healthy Environments, Alaska Community Action on Toxics, University of Alabama Hospital Highlands, Oregon Environmental Council, Clean New York, Environmental Health Fund, Citizens’ Environmental Coalition

    Comments to the Centers for Disease Control & Prevention regarding National Conversation on Public Health and Chemical Exposures

    Workgroup Reports

    General Comments:

    The Massachusetts TURI program should be made into a federal program, using a similar structure. It is funded by a user fee that companies pay based on the amount of hazardous materials they use. The fees are used to support programs that work with companies to help them reduce their use of hazardous chemicals, which then reduces the fees they have to pay to the program. In addition, companies that reduce their hazardous chemicals also reduce costs to store, ship, and dispose of them, which usually saves them money overall.

    Children are generally not called out in any of the work group reports, yet they are a specific vulnerable population: they cannot identify risks, remove themselves from harm, or describe exposures or events. Neither CDC’s Environmental Public Health Tracking nor the National Children’s Study collect information regarding children’s exposures in schools or child care centers, but they should be. When those are mentioned in various work group reports, it would be prudent to add that EPHT and NCS need to swiftly address these well-known data gaps with revised work plans. Children have exposures “on the job” in schools and child care centers and outnumber adults by about ten to one (depending on age group and health status) in those settings, but children/families have no recourse and no public services to intervene or to track or research those exposures.

    Monitoring Work Group:

    This report is excellent, and we sincerely thank the members who produced it. It makes an effort to combine action recommendations under a single heading. This report cites REACH and recommends a similar policy, but language about the Toxic Chemical Safety Act (H.5280) TSCA reform bill should be inserted instead.

    Biomonitoring Issues

    The biomonitoring of disproportionately exposed communities should happen regularly, and individuals and communities should have access to their information so they can use it to make choices, rather than just researchers using it as baseline data, but not to make policy changes.

    We note particularly the important recommendation for sample banks, which is not highlighted in the introductory heading of Recommendation #3 for expanding biomonitoring capacity. We recommend adding the sample banks into the heading. Also, to maximize the utility of biomonitoring, we need to know what the biomarker is measuring. How representative is the biomarker of all biodegradation/ detoxification pathways operative for this chemical in the body? Does it represent 100%, 50% or 10% of biodegradation? How many other biodegradation pathways exist for this chemical? Do any of the degradation pathways result in the creation of more toxic metabolites? Does this test show a snapshot in time of exposure or is it more representative of long term chronic exposure? In the interest of disclosure and transparency, we need good descriptions that answer all these questions, when reporting results.

    Environmental Monitoring

    Environmental Monitoring also raises questions about environmental transformations of the released chemical into more or less toxic forms. Atmospheric chemical transformations are rained down onto the landscape and into water supplies. Persistent bioaccumulative toxins can continue to cycle in the environment for decades– from water bodies, to air, to rain, to land and water bodies.

    It is critically important to highlight the unique nature of PBTs in the environment– that many chemicals banned 50 years ago and their metabolites are still found in the environment, while newer kinds of PBTs are entering the environment. Given persistence in the environment and biomagnification, it is crucial to understand total human dosing of PBTs based on current exposures, comparison to adverse effect levels and margins of safety and their possible individual and combined health effects. Some PBTs, such as heavy metals, never degrade. We recommend a major effort focusing on PBTs and trends in environmental levels.

    Understanding Acute Exposure Incidents and Health Outcomes

    A careful scientific protocol is needed for responding to chemical emergencies and releases so that useful monitoring data is obtained in conjunction with contact information for exposed workers, emergency responders and the public. Right now, we learn about health impacts after the fact and are unable to draw conclusions, because no or inadequate monitoring was performed, and there is no tracking of those most exposed.