EHN [of California]
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ATBCB Testimony
Monday, March 13, 2000
Washington D.C.

"Zone" Concept

My name is Mary-Margaret Lytle. I live in Houston, Texas.

I am a person with Multiple Chemical Sensitivity.

I speak from a professional background that spans environmental interior design and architecture, real estate property management, and disability advocacy. Ìve talked with persons from all over the nation who have MCS. For over two years I have worked with my employer to establish my own workplace accommodations.

From the wisdom gained on this journey, I now identify for you two huge, looming factors that we are forced to face, together:

    FACTOR #1:
    there are an unreasonably great number of elements being allowed in todaỳs buildings that trigger persons with MCS and unnecessarily block their access, elements which are not essential to the ultimate functioning of buildings. These elements CAN be remedied.

    FACTOR #2:
    to provide the needed architectural remedies, 100% of the time in 100% of the space of 100% of all buildings, is a task simply too overwhelming and too complex for most building managers to deem feasible. I believe this is a hard reality which has been the major reason access for persons with MCS has not been achieved as readily as it has already been achieved for other populations.

I ask you today to consider that policy CAN be constructed that will grant access to persons with MCS.

  1. I propose that we establish architectural "zones", which would be located within facilities, and clearly demarcated with appropriate signage, and which would provide a "safe path of travel" for persons with MCS.

  2. I propose that we establish the most stringent protocol possible within these zones, so that all persons with MCS could have access, especially the most severely disabled who are in most need of access to facilities.

Such zones would omit all elements known to trigger persons with MCS and would utilize alternative architectural solutions. For example, such zones would omit fluorescent lighting, carpet, and plastics. All elements would be constructed of hard surfaces such as stone, ceramic tile, glass, porcelain, or steel; and zones would be served by independent HVAC systems. The zones would contain two-way communication devices so the most seriously disabled could interact with service providers in other parts of the building. In short, EVERY architectural element within the zone, without exception, would be addressed; and persons with MCS would be able to leave their parked cars, enter a safe path of travel, walk to the building and enter rooms in which they could conduct business and have access to plumbing facilities.

I ask the Board to re-examine its own ability to set standards for these zones which would address ALL elements--elements which, due to their inherent nature and very existence, function as barriers to persons with MCS. This type of regulation would be clearly separate and distinct from OSHA-type regulation. OSHA-type regulations of hazardous materials and indoor air quality were intended for general population application and were NEVER intended to address barrier removal for persons with disabilities.

In summary, the "zone" concept would be more practical than the "whole-building" concept, would limit liability, would grant mainstream access to persons with MCS, and simply put, would address the concerns of all parties and still be very achievable.

Thank you.

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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