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There is more to ADA than obvious disabilities

July 29, 1999

Dear Ms. Lomax:

I've reached you through the Dept of Transportation's contact page,

I read with much encouragement that U.S. Secretary of Transportation Rodney E. Slater, in a policy statement released on July 26, 1999, related that he wants "... the public and our partners to understand that accessibility is a vital civil rights issue." He goes on to state that "Section 504 of the Rehabilitation Act, the Americans With Disabilities Act of 1990 and the Air Carrier Access Act make this abundantly clear....We must demonstrate through our own programs and actions that a fully accessible transportation system -- pedestrian, rail, transit, highway, water and air -- is not only essential but attainable."

However, as encouraging as those words are to me, there is a group of people with hidden disabilities -- tens of MILLIONS strong! -- who are consistently ignored in Section 504 of the Rehabilitation Act and ADA policy statements, even though our disability is recognized by Social Security and Housing and Urban Development, among ever so many government entities.

Without our needs being taken into consideration by the Dept. of Transportation, we are discriminated against broadly. What's more, there cannot be a fully accessible transportation system as long as invisible barriers remain.

Transportation is not accessible to us because of all of the fragrances -- personal care and cleaning/maintenance products -- and pesticides used with gay abandon. Our barriers ARE invisible, yet nonetheless formidable.

People must be educated -- starting with the top of our government agencies -- to the fact that these fragrance chemicals are known toxins. There are fragrance-free products available and there are Integrated Pest Management practices to implement. Federal offices were to move to IPM practices as long ago as 1994. That policy should certainly have trickled down to local operators, airlines and trains by now. The Environmental Protection Agency (EPA) has even put together a poster including information on fragrance-free products to be used as a guide by purchasing officers. Steps have been made. But they've been baby steps and are not implemented as broad policy for interagency action. Those of us who are aware of the health problems caused by commonly used toxic fragrance products -- which have been unwittingly welcomed into lives -- are left without access. We have no safe paths of travel.

Fortunately, for the people in Halifax, Nova Scotia, fragrances are not welcome in public. The fact that flagrant fragrances are toxic products, adversely affecting the health of user and nonuser alike, is known and acted upon! (See July 28, 1999; "One City Turns Up Its Nose Against the Use of Perfumes;" By Larry M. Greenberg; Staff Reporter of The Wall Street Journal:

    " HALIFAX, Nova Scotia -- The perfume industry's worst nightmare is unfolding here in this scenic port city on a hill.

    " A school sends a substitute teacher home to shower off her perfume before she can return to work. Hospitals order patients to towel down if they're too heavily scented. A church asks parishioners to leave their "fragrant offerings" at home.

    " The fight against perfumes and scented products is a small but impassioned one. And nowhere else has it advanced quite as far as in this seaside provincial capital, population 350,000. Most of Halifax's public institutions, and a growing number of its private businesses, come right out and ask people to abstain from using perfume. Some even require that they be 'scent-free.' ..."

Until the US Dept. of Transportation begins to realize that they are contributing to -- causing as well as triggering! -- the disabilities of millions of people by continuing fragrant business as usual, there will be little hope that any of us can readily access transportation, be it with our local bus or light-rail systems, inter-regional or national bus and rail carriers, airlines, OR via paratransit. Those of us who need oxygen to fly, are too often charged an exorbitant amount of money. And the irony is, most of us would be able to fly without oxygen IF the airplanes were not polluted with fragrance products, which includes pesticides and fragrances worn and used by staff and passengers.

Passenger conveyances must remove petrochemically derived air "freshenersū or deodorizers from their restrooms. The products currently used are pollutants of serious magnitude. And staff and passengers, regardless of conveyance, must be educated to leave their fragrances at home.

Fragrances pollute the air for all, which means that all of us are subjected to the adverse effects of the toxic chemicals, whether we wear them or not and whether we know it or not. These chemicals enter the bodies of users and second hand users alike through the inhalation process as well as through absorption via the skin and eyes. Skin is not a barrier to these chemicals so users, of course, get dosed through skin absorption, but when users leave behind their fragrance residue, we nonusers absorb it through our skin also.

If these toxic chemicals were used in anything but personal care and cleaning/maintenance products, people would be thoroughly warned to use goggles, to not inhale, and to wash off skin. That cautionary information is available through the Material Safety Data Sheets (MSDS).

To view the chemicals in but one fragrance product, Eternity eau de parfum, please visit Analysis Summary at This information is part of the Environmental Health Network's petition of the US Food and Drug Administration to declare Eternity "misbranded." The basis of this petition is the lack of a warning label on the product informing consumers that all the materials in the product, and the product, have not been substantiated for safety. Additional information on fragrance products is available through EHN and through the Fragranced Products Information Network at

We could only afford to have one product analyzed so we selected the one we've received the most complaints about. However, we hope this petition opens the eyes and minds of FDA staff and they will then begin following their own mandate and declare ALL fragrances sent to market without adequate testing, "MISBRANDED." In my opinion, recall wouldn't be too strong a measure to protect public health, but the FDA should, at the very least, require its warning message be affixed to all labels of fragrances released to market without substantiation of safety.

We need interagency awareness and acknowledgement of this serious public health issue which impacts tens of millions of Americans -- actually millions more worldwide -- with adverse disabling reactions such as asthma, sinusitis and other respiratory problems, migraines, Central Nervous System (CNS) disorders such as Parkinson's and other mobility impairments, cancers, ... and includes those exhibiting the Many Chronic Symptoms of Multiple Chemical Sensitivity (MCS).

I look forward to hearing from you that the US Dept. of Transportation will begin educating the traveling public to leave their fragrances at home. And more importantly, will begin a nationwide educational campaign to enlighten all of the transportation entities about the toxicity of fragrances and pesticides. All should switch to IPM practices, and begin to eliminate air "fresheners" and fragranced cleaning and maintenance products. It is none too soon to develop policies for the use of fragrance-free personal care products when dressing for the transportation workplace. Additionally, public service announcements and posters could explain the wisdom of using fragrance-free products. There is a growing market of safer alternatives. We all should support it. "Free market" and all that!

Only with an educational campaign by government agencies can we begin to clear indoor air pollution so that Indoor Air Quality becomes more than a pipe dream. We all are stakeholders when it comes to breathing!

Thank you for your time and attention to my concerns.


Barbara Wilkie
(My convention is prevention)

The response?

    Date: 30 Jul 1999 04:08:41 -0400
    From: "Lomax, Margaret "
    Subject: There is more to ADA than obvious disabilities -Reply
    I am out of the office July 26-30. If you need immediate assistance, please dial 202-366-0653. Thanks.

    In case anyone is interested, I NEVER heard from anyone within DOT except the above
    autoresponder from Ms. Lomax.

    August 2003: I've just learned about:

    Toll-Free Hotline For Air Travelers With Disabilities
    " ... The line is staffed from 7 a.m. to 11 p.m. Eastern time, seven days a week. Air travelers
    who experience disability-related air travel service problems may call the hotline at
    1-800-778-4838 (voice) or 1-800-455-9880 (TTY) to obtain assistance. ... "

    Info available through: Aviation Consumer Protection Division

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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. EHN brings you topics on this page that need your immediate attention The URL for this page is