EHN [of California]
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A 501 (c) (3) non profit agency.

ATBCB Testimony
Monday, March 13, 2000
Washington D.C.

Require the Use of
Non-toxic Pest Control

Accessibility guideline meeting for proposals under the Americans with Disabilities Act (ADA) and the Architectural Barriers Act (ABA). (Timed to my five-minute limit.)

Good afternoon. Thank you for offering me speakerphone access opportunity to address this board. I would especially like to thank Mr. Yanchulis and the minority of Board members who have shown sensitivity to those with my disability.

My name is Elizabeth O'Nan. Since 1987 I have served as the founder and director for the pesticide injury support group, Protect All Children's Environment. The people I serve are often disabled by their toxic exposures, which result in a condition I shall refer to as Toxicant-Induced Loss of Tolerance or (TILT), commonly known as Multiple Chemical Sensitivity or (MCS). My 16-year-old daughter and I were disabled by TILT in 1985, as a result of a pesticide exposure in our home. I also developed an inoperable brainstem tumor as a result of my exposures. Thousands of children such as my daughter struggle with this unimaginable condition. TILT is extremely isolating, as the only effective treatment at the moment is avoidance of chemicals. The ubiquitous use of toxic chemicals in public spaces serves to unnecessarily isolate those with TILT.

While TILT in any form is disabling, some are far more affected than others due to the degree of their chemical injury. There is no question that people with TILT are disabled. It is not within the purview or mandate of this board to determine who is and is not disabled, rather to determine how best to meet the access needs of those who are disabled.

It would appear those disabled by TILT have suffered a tremendous civil rights abuse by being discriminated against by exclusion from the considerations of this board. Attempts to continue this environmental injustice by asking that we codify this misbehavior by restricting our comments to only the current guidelines under consideration, simply can not be tolerated. If this disability discrimination continues a Writ of Mandamus or other legal action should be brought against this board to enforce the laws.

Is there no shame; that this board would neglect the very basic architectural access needs of this entire class of disabled people? That by this neglect and abuse not only do you deny them access, but in this willful neglect contribute to their further injury?

This criminal abuse is especially egregious when one considers that by simply implementing the access needs of those with TILT millions of dollars could be saved by simply eliminating the costs of risky pesticides and bathroom deodorizers alone. Here it is not asked that any new device be provided such as wheel chair ramps or elevators or bathrooms stalls. Rudimentary knowledge of non-toxic pest control and cleaning methods could simply replace these present toxic architectural barriers.

Furthermore, by requiring this minimal assistance for those disabled by TILT, this board would be greatly reducing the very real probability of civil rights suits being filed against various governmental and public entities who allow these access barriers to continue.

Additionally, by accommodation of TILT disabilities this board would be helping to improve the indoor air quality for millions of people who do not have this specific disability but suffer nonetheless from neurologic and breathing impairments. By implementing access provisions for those with TILT, risk reduction will be achieved for all.

Finally, the recently drafted Executive Order on Toxic Chemical Reductions-
calls for banning organophosphates and carbamates from all federal facilities.

The Access Board should require the use of non-toxic pest control to grant access for people disabled by TILT as this would be in the best interests of all and would serve to implement this excellent Executive Order.

Thank you for your time and attention. If there are any questions I shall be happy to answer them at this time.

Protect All Children's Environment
E.M.T. O'Nan
Phone: (828) 724 4221
Fax: (828) 724 4177


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The Environmental Health Network (EHN) [of California] is a 501 (c) (3) non profit agency and offers support and information for the chemically injured. HomePage is