Office of Technical and Information Services
Architectural and Transportation Barriers Compliance Board
1331 F Street, NW., Suite 1000
Washington, DC 20004-1111
Dear Director Roffee and Members of the Access Board:
RE: 36 CFR Parts 1190 and 1191; [Docket No. 99-1]; RIN 3014-AA20
Americans with Disabilities Act (ADA) Accessibility Guidelines for Buildings and Facilities;
Architectural Barriers Act (ABA) Accessibility Guidelines
I am a person living with at least one of the following disabilities --
___ Multiple Chemical Sensitivity; ___ Other autoimmune disorder; ___ Asthma or other respiratory disorder; ___ Cancer; ___ Other "hidden" disability ____________________________________; and/or, ___ I have great concern about my child or other individual who is disabled and whose life functions are adversely affected by chemical or electromagnetic exposures in buildings, and/or on public transit vehicles.
Please set standards that would take into consideration the following suggestions. By providing this list, there is no intent to limit the scope of the board in its endeavor to establish enforceable regulations to protect access for the millions of people who face invisible, yet nonetheless formidable, chemical or electromagnetic barriers.
- Reduce/eliminate exposures to superfluous toxic chemicals in building materials for the built environment, be it in/around buildings or within public transportation conveyances. Use low-emitting VOC (volatile organic compound) products such as paints, carpets, adhesives, wall-coverings, vehicle seats, et al., for rehab/remodelling and new construction. Set standards for their use, just as standards are set for carpet pile depth and density to enable access for people using mobility aids, and as turnaround space is defined to accommodate a wheelchair.
- Remove the "FEDS" or fragrance emission devices/systems and all perfume/deodorizer "stick-ons" from restrooms and heating, ventilation and air conditioning (HVAC) systems in buildings and vehicles.
- Install buzzers/intercoms/TTYs/housephones outside at wheelchair-accessible entrances, and other likely entrances, in a sheltered, exhaust- and smoke-free area, which is not chemically treated for pests. We need to phone into a facility to announce our arrival, ask for assistance outdoors, or directions about how to get to the safest nearby designated area within the structure. People disabled by chemical and electromagnetic field-triggered sensitivities must be able to summon assistance in a safe area.
- Require signage boards (permanent) on which notices can be posted such as: "No smoking here at all. Really!" "Do not idle your motor." "Leave this designated area now if you, your clothes or your hair product contains fragrance, or if you have just been treated with a chemical product for lice." Also, clear signage indicating a communication device, which we can use from outdoors (see 3, above). Also, require temporary signage such as: "Don't enter if you are chemically sensitive -- we just waxed" (cleaned, painted, carpeted, applied pest control chemicals); include substance/date/time information. This is of utmost importance if even "least-toxic" products were used.
- Increase ventilation of parking garages; increase number of handicap slots near safe exits.
- Landscape and build/remodel according to established practices that eliminate the need for maintenance with chemical weed, insect, or mold control substances.
- Utilize ceramic tiles and other safe materials; use mold-resistant materials around plumbing and HVAC systems; install only ventilating systems that can be easily cleaned; set standards for proper placement of exhaust vents and air-intakes so foul air isn't drawn back into the building.
- Create a cleaner-air zone for healthcare facilities, government agencies, and other entities charged with serving the public. In a room or pathway meant to be accessible to people with chemical/electromagnetic injury-related symptoms, give people the option to turn off the fluorescent lighting, and instead use incandescent lights or daylight; make provisions enabling occupants and visitors to unplug computers and other electrical gear; be able to open windows; do not require use of elevators or escalators to reach the cleaner-air zone.
The number of people with environmental illnesses has soared -- not just among the MCS community, but including those living with other EI disabilities such as asthma, cancer and Parkinson's. Our children are exhibiting various chemical injuries/disabilities as well. Attention must be paid to indoor air quality as an adjunct to access.
The Access Board can change society's attitude, and institutionalized practices, toward overt discrimination against people who are chemically injured by acknowledging our right to access and setting standards accordingly. While helping us gain access, you will protect everyone. You will make strides in turning the tide on the burgeoning environmental illnesses that are affecting all ages, genders and races. At this moment in history, you have the opportunity to begin to right major wrongs. Please act on behalf of the chemically/electromagnetically injured. Now. In the year 2000. Thank you.
cc: Representative ____________________________________________________
EHN thanks Toni Temple, Ohio Network for the Chemically Injured and Susan Molloy for their contributions to this letter.
[If you send this letter via email, you must include your name and address in the body of your letter for it to be considered. Send to firstname.lastname@example.org .]
See EHN's Write Now! to link out to addresses for your representative and senators
Environmental Health Network
P.O. Box 1155
Larkspur, CA 94977-1155
EHN at http://www.ehnca.org/ehnindex.htm
Additional reference information:
Dalhousie University - Statement on the Use of Scented Products
"Perfume and Fragrance Exposure During Pregnancy: Links to Learning Disabilities, ADD and Behavior Disorders" http://www.chem-tox.com/pregnancy/perfume.htm
The California Air Resources Board states in "Consumer Products and Smog" http://www.arb.ca.gov/html/brochure/consprod.htm:
"In 1990, consumer products emitted about 265 tons of smog-forming pollution into California's air every day-more than all the refineries and gas stations in the state. Until 1990, the amount of VOCs in these products wasn't regulated."
[10 long years ago -- I'm seeking more up-to-date figures.]
For more information, please visit the web site of Betty Bridges, RN
Fragranced Products Information Network
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