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D~welop a product labeling technique which will proTide meaningful information on individual ingredient8 as ~11 as total ~olatlle organic compounds. We would now lime to present a list of recommended prohibitions regarding the use of specific consumer products in public and commer- cial buildings. These prohibitions would significantly reduce indoor pollution; protec~ public health and ~ell-being; decrease the risk of illnesses associated with indoor exposures particularly for those who are chemlcally sensitive. These recommendations include~ * Prohibi~ indoor smoking in all public and commercial buildings. * Prohibit the prophylactic use of pesticides in favor of integrated pest management techniques for all federal facilities, indoors and outdoors, and promohe the use of integrated pest management techniques for all public and commercial buildings. Ban the use of the pesticide paradichlorobenzene from all deodorizer products and all non-pesticide products. EPA has known for some time that paradichlorobenzene is a p~ssible human carcinogen. EPA has c~Iculated the risk, and the risk is high. The pesticide has no known benefits. It merely hides poor hygiene. olfactory nerve anaesthetics, odor masking agents, or other perception blockers, as ~ell as the use of perfumes and scents in public buildings. Many people ~ith chemical sensitivity experience ~ebilitating symptoms from deodorizin~ agents being pumped through building ventilation systems or spritzed into rooms. In the event that I0 "1"10092-0232

disinfectants are required for health or hygiene purposes, they should not include addltional scents. For some people, "masking" potentially unhealthful odors may~induceapersunto remain in harmful situations that they would otherwise be alerted to via the sense of smell. There would need to be a compelling health reason, not simply a subjective cosmetic requirement, in order to override the individual's right to know and right to be free from unreasonable exposures to harmful substances. The marketplace is full of deodorizers that shake, spritz, spray or plug into electrical outlets. These products do not list ingre-- dients. Many consumers believe that these deoderizers and scents are absolutely safe products when indeed they additionally contaminate indoor air. The pesticide paradichlorobenzene is an ingredient in some of these products. Prohibit the use of scents and perfumes in public buildings for the purpose of altering the behavior or mood of the occupants. We lack the technology to identify the complete chemical makeup of these products. We have no knowledge on the potential adverse health impact on the a11ergic, hypersensitive, chemically sensitive, or cacosmic individuals. With relation to consumer products, we would also request that Congress: Mandate a "Right to Know" of toxic, sensitizing or allergenic substances in the contents of all consumer products. Mandate full disclosure to a treating physician of the contents of any consumer product or other source of indoor air quality concerns relative to an alleged exposur~ incident. 11 TI0092-0233

Pollutlng products and furnishings are impacting on our ability to create and maintain energy-efficlent buildlngs. Until we can minimize pollution levels from indoor sources, it is imperative that Congress mandate minimum ventilation standards. * Adopt the current ASHRAE ventilation standard as a minimum, national regulatory standard. The ASHRAE standard would be regarded as a minimum since the standard is no__~t designed to protect the health of al__l individuals, but just the health of 80% of the U.S. population. Any ASHRAE-based indoor air standard would have to be modified to-accommodate sus- ceptible populations including the allergic, asthmatic, chemically sensitive and those with breathing and lung disorders. Furthermore, compliance with the standard must not in any way limit liability of building owners or managers. It will not ensure a healthful building, but rather serve as a starting point toward that end. We would additionally recommend that ~ndoor air legislation prohlb~t the procurement or use of products that contain carcinogens and/or unreasonable or ~oxic substances by the General Services Administration and by all federal agencies. Such legislation should also fund research initiatives which would move toward establishing specific requirements for the purchase of building materials, furnish- ings, and supplies. For example, Washington state recently establish- ed emissions criteria regarding levels of formaldehyde, total VOCs and 4-PCH (4-phenylcyclohexene) in furnishings purchased for several new office buildings. We must also work toward establishing meaningful "permissible exposures levels" for public buildings and the office workplace. Again and again, people are sick in buildings for which the expo- sure levels for indoor contaminants are within the "normal" range. We need to act to establish realistic exposure levels rather than perpetuating a "blame the victim" attitude in such instances. In 12 Ti0092-0234

office environments, one can expect to find large numbers of people who are not In excellent health and who may be in one or more high risk groups for health effects of indoor pollutants. These include but are not limited to infants and children, the elderly, those with chronic respiratory or cardiovascular disease, those with known or unknown liver and kidney disorders, and those with allergies and chemical sensitivities. Permissible exposure levels must take these populations into consideration. Indoor air pollution is the health threat of the 90's. Action is needed. Those with chemical sensitivity suffer daily from polluted indoor air. We strongly support a legislative initiative. All Americans will benefit. This testimony is respectfully submitted by Mary Lamielle, Director and President, National Center for Environmental Health Strategies, Voorhees, New Jersey, [609)429-5358, and NCEHS advisor Eaton S. Davis, J.D., M.P.H., Evanston, Illinois, (708)475-8620. We thank you for the opportunity to present this testimony. We would be pleased to provide any additional information you may require. 13 T10092-0235

REPORT TO CONGRESS ON CHEMICKL SENSITIVITY~ We propose that EPA prepare a report to Congress to review the following aspects of chemical sensitivity disorders, including multiple chemical sensitivities, as a health effect of chemical ex- posure, both in terms of what may cause the underlying sensitivity disorders and what may cause or trigger symptoms ~n individuals who have these disorders: I. Epidemiologic data and other information regarding the prevalence, severity, and etiology of these types of illnesses. 2. Medical and scientific data pertinent to the etiology, presence of markers, biochemical mechanisms, and other scientific and quasi scientific data on these illnesses. 3. A complete survey and assessment of the policies of all federal agencies, including the military, regarding chemical sensitivity disorders, whether in written policy statements, patterns in administrative decisions, or in practice. 4. Past, current and planned research and other studies at the federa~ state, local and international levels on these illnesses. 5. Availability and usefulness of whatever methods of treatment, avoidance, or coping with these illnesses may exist. 6. A thorough explanation and consideration of the economic, social, psychological, housing, employment, legal, and other needs of people with various chemical sensitivity disorders, including multiple chemical sensitivities, whether of known or unknown etiology, including but not limited to the following: a. How the medical community is responding to people who claim to have these ~llnesses. b. Social and psychological ramifications of these illnesses. c. Economic impacts of these illnesses upon those suffering TI0092-0236

from them as well as upon employers, family members, parents, and society in general. d. How the various government and non-government entitlement, insurance, and other compensation systems [including federal and other disability retirement programs, state and federal workers compensation systems, etc.] are dealing with these illnesses. e. How people with these illnesses are faring in the legal systems, including personal injury, toxic tort, and products liability litigation. f. How people with these illnesses are faring in terms of securing reasonable accommodations in housing, work- place, and other settings. g. How people with these illnesses are faring in requests for supportive and rehabil~tative' services. 7. A debailed statement of the research needs in this area and a plan for the implementation of those specific research proposals, both within EPA and in other agencies. 8. Detailed recommendations on what various federal and state agencies can and should do to better meet the various needs of people with chemical sensitivity disorders, both in terms of prevention of these illnesses, proper early identification of those with the illness or those with high risk factors, and in the provision of medical and non medical services to those already with the illness. 9. A detailed evaluation of the legal, economic (both costs and benefits), and ethical implications of chemical sensitivity disorders for all curr~t ~deral regulatory systems and standards pertaining to chemicals, focusing on whether and how these regulatory systems can protect people with multiple chemical sensitivities. Systems and standards to be considered include, but are not limited to, all those involving the full range of outdoor environmental protection of the air, water, toxics, hazardous waste, etc., in addition to occupational, product, trans- portation, housing, food and drug, and military standards. T10092-0237