As the most recent legislator to introduce a bill on “Toxics”, I have sent your office copies of the following correspondence because you and your colleagues in Washington need to know that we, the people, are unable to safe-guard our own health from one of the most common hazards around today—modern pesticides. While these chemicals may be effective in increasing crop yields, they have still found their way into our homes, offices, hospitals, schools and every location where people gather. Current laws to assess the success or failure of moving farm chemicals into non-agricultural locations do not allow citizens and their physicians to find out if this experiment has succeeded or failed. We have no means of learning this because of restrictions keeping laboratories from developing testing panels to learn about how pesticides affect human biochemistry and influence health.

In 2002, the CDC had researchers test the bodily fluids of 3000 Americans, confirming that 70% of them had been exposed to sufficient amounts of a class of pesticides called ‘pyrethroids’, to have those by-products (metabolites) identified in their urine. How much is too much? We don’t know because physicians are unable to order the same tests performed for CDC research. No labs exist for the medical monitoring of patients. When an individual demonstrates exposure related illness, it cannot be directly confirmed despite the existence of protocols to measure it as per the cited studies above. Veterinary laboratories can do this but not human laboratories. In humans, harm must be inferred through the temporal association of exposure, assuming one knows of it, with meeting descriptions of adverse effects cited directly on the pesticide labels. The EPA confirms the need for medical monitoring in their own publication, “The Recognition and Management of Pesticide Poisoning.” Beginning as ‘flu-like’ symptoms, with respiratory symptoms, nausea, cramping, headache and so forth, intensifying into more frank signs of central nervous system effects. These can include the inability to sleep, nervousness, attention deficits, tremor and convulsions. Irreversible damage can result if sufficient numbers of nerve cells are damaged.

These chemicals target nerve cells (of insects and people) to stop working by hyper-activating them. Nerve cells fire excessively due to alterations of the sodium ion channels on the nerve axons. The resulting over-stimulation of the nervous system leads to paralysis and death in insects. Applied to the skins of animals for flea and tick control, pyrethroids and pyrethrins are known to kill small animals. Veterinary toxicologists don’t actually know the lethal dosages for these products on animals and therefore don’t recommend their use on cats. If the animals suffer sub-clinical signs of damage, it doesn’t appear to be monitored in terms of behavior and learning ability. Do we really want to measure safety only in terms of lethal effects?

What about people? When pyrethroids and pyrethrins are applied indoors, these products not only contain the active ingredients designed to disrupt nerve cell functions but also ‘other’ chemicals called synergists, which keep targeted and untargeted life forms from swiftly eliminating the poisons from the body. One such ingredient, piperonyl butoxide targets the liver to accomplish this goal. It is also known that these products also affect the endocrine system which regulates hormonal activity. They can contain ingredients which are suspected or confirmed carcinogens. The nature of pesticides, from their active ingredients to the petrochemicals solvents used to deliver them in liquid sprays, guarantees an array of problems will be brought indoors which were of less concern when their use was limited to large, open areas, away from concentrations of residential properties. Bio-monitoring in research has been an invaluable tool for observing unexpected effects such as the affect of farm chemicals on entire communities. Bio-monitoring has permitted conclusions to be reached about the effects of dietary exposures in children. Unless we are aware of these levels, we cannot identify the points at which we need to be clinically concerned and corrective action taken for the health of patients.

I was at my doctor’s office yesterday and we had an interesting discussion about this because he was helpless to find a resource to determine if I was being exposed to these chemicals. Someone has been spraying substances on my car which make me feel sick and are sometimes visible to the eye. A couple of highway patrol officers have been kind enough to even photograph the visible residues and one police officer took a sample of it last summer. Unfortunately, the police laboratory did nothing with it because they don’t have the forensic capacities to do such analysis according to detectives. The CHP was most apologetic that the best they could do was take those photographs and note the incidents. Interestingly, one of these increasingly common incidents took place last month as I was returning to a friend’s home after meeting with Congressman Waxman’s staff (about toxic chemicals) in Los Angeles. Nothing more could be done in the absence of lab testing and it isn’t possible to have that done, contrary to movie and television scripts leading us to believe that the use of forensic science is common in law enforcement.

And that is simply wrong in this day and age of information which enables us to monitor our intriguing technologies. Where is the guiding wisdom of science when it comes to ensuring our tools are safe for us to use in each new application found for those products? Whether it’s smart-meters for calculating our electricity usage or a can of pesticides someone buys at a local store, we have the ability to find out if it is working to our advantage or to our disadvantage. Since our government is minimally ‘invasive’ in regulating commerce unlike Europe where chemicals are supposed to be tested now for safety before they are marketed, it is up to consumers to develop the body of evidence via experience and sometimes through the courts. That takes access to all information about the circumstances surrounding their use. Unless, for some reason, it is deemed by industry more desirable not to tell us.

Over the past five years, I have been attempting to obtain missing ‘paper discovery’, i.e. my records of employment by YAI/National Institute for People With Disabilities and their sub-division, the New York League for Early Learning based in New York City. I was employed there between 1995 and 2000, at which point I retired on disability with a diagnosis of “Toxic Effects of Chemicals”. The EPA actually suggested I file this suit because they have little or no authority to regulate where various registered pesticides are used and depend upon citizens to exercise our own legal rights in these matters. Civil procedure requires all parties in a suit to exchange information. All of it.

Those attempts have been unsuccessful to this day and my attorney has been reluctant to dispense with the polite formalities and file a motion to compel. I have written about this litigation as an example of how law suits aren’t an evil instrument for profit, but a means for evolving legal safeguards about our use of technology as experience teaches us more about it.

The School Environment Protection Act was introduced (and twice passed in the Senate) which not only endorsed our right to know and consent to the use of pesticides in and around schools, but limited or prohibited the use of the particular types that damage the central nervous system. It cannot be written into law simply because the House of Representatives has never had the opportunity to consider voting on it. The Committee on Agriculture has been ‘studying’ it for a decade although it has no connection with agriculture. That is a lot of study and very little action, requiring us to ask the question of why the Senate was convinced this was a sound measure while our representatives in congress aren’t allowed to reach their own conclusions about it. Had they done so in 1999, I might not be writing this now and there certainly would not have been a need to file this law suit.

My lawsuit asserts that I was poisoned by the use of chemicals actually invented for outdoor use but which are likely to be found in the majority of schools in American today for lack of information about their use (advance notification) and selection of more benign (least toxic) forms of pest control. To the best of my knowledge, my employers were not responsible for the use of these chemicals as they didn’t own the building rented to house our school program, nor did they hire the pest control company which applied the chemicals. The missing records should corroborate the testimony I provided many years ago as they became aware of the changes in my health and ultimate need to retire. Indeed, they supported my application for disability based upon chemical exposures. When I filed suit, the defendants were the ones to sue my employers and assert they might hold some degree of responsibility.

I still have not been privileged to obtain those records and my suit is currently marked ‘disposed’ in the courts pending completion of discovery. Those documents are key yet remain unavailable to me after many years of waiting through the legal process which remains largely incomprehensible to me. In the absence of my ability to advance the legal questions surrounding product safety for certain current-use pesticides, we must return to the ability of citizens to assess health concerns which arise from their use.

Mr. Lautenberg, below is my latest correspondence with the EPA. That correspondence began with this blog post about pesticide regulation. I hope this letter will be the last needed to direct legislative efforts at the most basic level of safety monitoring. Just this morning, my reply from the EPA informs me that that agency has no interest or authority in ensuring their approved chemicals are actually safe for use by the public. Frankly, I can’t find a single agency which does so I imagine this is the type of situation our forefathers envisioned when they put a clause in the Constitution which allows Congress to legislate matters affecting commerce where they deem it necessary.

It is necessary. Just ask the American Association of Environmental Medicine about their frustration with regard to the limitations they face on assessing patient exposures. Review the testimony of an esteemed pediatric expert who testified before Congress on these matters, Dr. Phillip Landrigan. Let us have the ability to medically assess our exposures and correlate findings with symptoms. Forensic testing in the matter of ‘suspicious’ appearances of chemicals should not be limited to fiction seen on television shows, but a working reality. We are citizens first, and consumers second. Medical insurance isn’t useful to us if medical procedures to confirm the sources of our illnesses aren’t available to us.

Thank you for your attention.

Barbara Rubin

My recent correspondence with the EPA about laboratory testing for their approved chemicals received a reply recommending I contact other agencies:

Dear Ms. Rubin,

I contacted our EPA pesticide lab for assistance. They suggested that there are at least a few commercial laboratories that can test for pesticides in blood, urine and tissues. A quick Google search turned up
ABC Laboratories and Columbia Analytical Services as sources for those tests. However, the analytical testing would likely be expensive. In addition, your email said you were concerned about pyrethroid exposure.
They also pointed me to a listing of pesticides that have been found to be able to be tested for by clinical labs:

http://npic.orst.edu/mcapro/PesticidesTestingForExposure.pdf.

You might want to contact the National Pesticide Information Center (NPIC) if you have not spoken to them previously. They have a medical toxicologist available who might be able to advise your doctors. You
can reach them at 800-858-7378.

I hope this helps.

Claire Gesalman
Chief, Communication Services Branch
Office of Pesticide Programs
www.epa.gov/pesticides
Ask a question: http://pesticides.supportportal.com/

=========================

My reply to that detailed my prior contacts with those laboratories and pesticide information facilities:

Dear Ms. Gesalman,

Thank you for your note but I have spoken with the NPIC extensively and their list of labs is simply that – a list of labs who all tell me they are not equipped to do this kind of testing because there is no profit to be found in it. The listing in the file you provided doesn’t even name the current-use pesticides in the class I mention. I have spoken with the CDC and EPA criminal divisions and all I hear is that there are no known labs which do medical assessments outside of research. Even law enforcement can’t test for such chemicals in a tremendous breach of concern for homeland security. Indeed, conversations with FEMA and the office of Homeland Security indicated that they hadn’t even considered this question.

In the article posted at my blog addressing Administrator Jackson, I described the lack of facilities for bio-monitoring in the US and Canada for these ubiquitous chemicals. I called the researcher whose name appeared in a CDC study from 2002 in which 70% of Americans (sample size of 3,000) showed metabolites of these chemicals in urine. She confirmed the fact that she cannot carry out medical testing nor are there other facilities known to her. Without physician access to testing, there is no possible way for Americans to find out if these chemicals, known neurotoxins and endocrine disruptors, are present in large enough concentrations to be responsible for particular symptom constellations or rising rates in known diseases like Diabetes etc. Right now, the presumption is ‘no harm’ because there is no monitoring to indicate otherwise. An absence of data is not proof of safety and is a direct violation of the FIFRA laws, requiring some means of assessment.

Dursban was only banned because physicians were able to look at the enzyme suppression it caused in all exposed victims, many of whom suffered egregious and permanent damage. In fact, many labs have expressed an interest in running the necessary tests as these chemicals are widely used to fog entire neighborhoods in vector control operations. I’ve been told by at least one lab that their state demanded such exorbitant fees for the permit required to conduct such testing, that the lab would never be able to recoup their investment in that market. Such a fee structure would indicate that it is no accident that labs have never acquired the equipment needed for these panels.

If labs are competent, why are they paying any fees to be able to monitor chemicals approved for use by the EPA? Some exposures are by consumer choice but, like second hand smoke, even more individuals are affected merely being in the vicinity of treated locations. These are farm chemicals displaced for sale and use within indoor settings. Obviously, they behave differently outdoors, and humans have longer exposure times indoors with the slower rates of degradation and absorption by permeable materials.

This isn’t merely a disregard for the health of citizens but it is a detriment to the marketplace itself. Failure to monitor the performance of farm chemicals in this manner is inhibiting product R&D designed for indoor locations. People are not crops and the EPA, which is doing it’s best to tell consumers not to use these products (indirectly of course), are allowing ignorance to govern the marketplace for pesticides even as statistics record ever-increasing rates of illness in Americans.

At this time, I am in need of assessment for exposures to these chemicals and have wasted months in searching for facilities that even the government can’t locate. Can a research lab be given permission to do this testing? As for expense, my exposures to organophosphates were assessed under my Medicare plan. If I am forced to live in a society which uses pyrethroids without any restraint or notice to me, my insurance ought to cover such things. Medical costs actually drive reform in product safety. We legislated against the use of tobacco indoors because of the costs to society in medical care and discovered Avandia was a hazardous drug by looking at Medicare and Medicaid expenses for cardiac problems among Avandia users.

Let the system work for pesticides as well. And we shouldn’t be naïve about these chemicals harming our armed forces and numerous injuries to civilians in their homes and on the job. We know about the potential for damage. Only through medical monitoring can we learn about the parameters guiding safe use of these products. Can you help me get tested when I am next exposed?

Barbara Rubin

cc: Congressman Waxman
Senator Lautenberg
Senator Boxer
Senator Feinstein
Administrator Jackson

===============================

And my final response from EPA was received this morning, entirely dispensing with their role in safety monitoring of approved pesticides:

RE: Your email to EPA
Sent: Thu 12/09/10 9:16 AM

Dear Ms. Rubin,

Have you contacted commercial labs such as the ones listed in the email I sent you yesterday? Our lab thought labs such as those should be able to test for pyrethroids. We don’t have anything to do with fees for testing. That is not something EPA requires or would be involved with. You would have to contact the state that sets such fees to find out why they charge fees for labs to conduct testing. In terms of whether
medical testing is available, again, that is not in EPA’s purview. The agencies that set standards for medical monitoring, etc. would be part of Health and Human Services, I would think. You mention research
laboratories. EPA cannot “give permission” to labs related to doing studies, due to strict rules about research on human subjects. Other agencies also have to abide by similar rules. But again, there are no
restrictions on commercial labs, if you can find one that has the capability to do the testing you desire.

Perhaps your best bet the next time you believe you have been exposed to a pesticide would be to call the Poison Control Center at 800-222-1222 and ask their advice.

Sincerely,

Claire Gesalman
Chief, Communication Services Branch
Office of Pesticide Programs
www.epa.gov/pesticides
Ask a question: http://pesticides.supportportal.com/

============================
Final Note:

Legislators and Administrator Jackson – Bio-monitoring is not about using humans for research purposes. It is straightforward medical practice. Poison control has no recommendation to make other than to see your physician. We already know how that approach turns out.

Congress has the power to intervene in matters of commerce when the commercial sector fails to meet the need citizens believe meets our basic right to know or need for assurances of safety. This is a matter pertaining to the medical, as well as the chemical, industries When knowledgeable individuals like myself can’t obtain basic information regarding our health and safety or pursue legal recourse in a timely manner, what is the average citizen to do who is largely unaware of exposures, along with their physicians?

Will this take an executive order? Must I go to the President of the United States with this conundrum?

Most of you likely think this substance has been banned by now. Many of us recall the scandal of so many military personnel exposed to it at naval bases, on ships etc. Flame resistant, we chose it as a form of insulation for hot water pipes. School teachers recall ceiling tiles composed of the stuff. No, it has not been banned. Its use in this country has been greatly reduced but is still likely to be found in the brakes of your car or some other product you’ve not suspected. In fact, you may have it in your home but not realize it because many real estate deals included indemnification clauses (“I don’t know if it’s there and you can’t sue me later on if it turns up or you get cancer. So there!”).

Perhaps you know its encasing your older pipes but don’t realize it’s reached the friable stage requiring removal. I once rented a house on Long Island, only to find it all over the basement on my first day there. I camped out in the yard that month until I got a new place. Conditions were such that the home couldn’t be rented again until professional remediation was performed and the owner was very regretful. Probably more for her expense than my enforced period of camping but that’s the real estate game for you. Luckily for me, it was high summer. And it was just a little hurricane. I’ve never looked at the phrase, “Shelter from the storm”, in quite the same way since then.

This isn’t in the least funny. Nothing is more vital to our well-being than our dwellings. The substances in our homes, offices, schools and libraries; our clothing, food, fuels and other accouterments to our lives can contain some appalling materials. When are we going to take it seriously enough to hear all of those voices calling to us that they are literally ‘sick to death’ of vendors being allowed to sell frankly lethal products? We pay the costs of the associated losses in health care expenses, lost work productivity and benefits to survivors of those who die in the cause of what is mistakenly referred to as a ‘free marketplace’. NOTHING comes free. Everything comes with some responsibility attached to it and freedom of choice isn’t one of them when you are forced to ingest, breathe and absorb toxic materials.

While this post interrupts the thread on litigation, just look at what Jim Morris has to say about the legal costs of asbestos related suits. Not quite so unrelated as it might seem.

My commentary on this pieces was as follows:

Thank you for this analysis which infers a great deal about what Americans are prepared to tolerate in this country at our own expense. First, why is any asbestos still being sold today when we’ve known of its lethal properties since the sixties? Few consumers even know this substance is in current use in their cars. Apart from risk to workers, are fibers entering cars through vents or being inhaled on the streets by pedestrians?

Many real estate rental/sale agreements include indemnities for asbestos and chlordane contamination in a property. Why wouldn’t an owner be required to know about these two, potentially lethal conditions in their homes? I’ve personally tested residences with high levels of chlordane shown to be present and asbestos has no safe level of exposure at all. If consumers shared responsibility for acquiring property contaminated with such substances, a ban would be in high demand. Mortgage companies should be asking for proofs of this type just as they do for termite inspections. Invisible property damage exists if building conditions will produce illness in some of its occupants.

We must also ask the identities of those companies still marketing asbestos ‘aggressively’ overseas so we can boycott them. Such willful imposition of harm upon their customers would seem to make any of their products suspect in terms of safety. Under capitalism, consumer dollars should only reward the makers of the best products which means we all have an obligation in such matters.

Another trail of money to follow is in legal costs. This article cites industry losses of 70 billion in total, with 49 billion to victims and lawyers. Why don’t we have a registry for claims requiring medical proof alone and a basic judicial review? This would end costly court battles as lawyers are currently occupied with re-try the same cases over and over again and take large percentages of awards from needy victims. Lawyers would then be available to take more complex claims for those who might be excluded from the expedited process as well as fight new battles on the consumer health front.

That would save billions of dollars and likely make bans on patently harmful products more desirable.

Barbara Rubin

This is another case of drug makers enlarging the pool of patients to treat without thought to the consequences of such actions. According to reports by Alan Roses of GlaxSmithKline earlier in the decade (referenced above), Alzheimers drugs—like many others– are ineffective for half of patients due to genetic diversity within the population. On the other hand, earlier identification of cognitive decline and brain cell death is extremely valuable if findings are not dropped into an overly broad overly broad category of of ‘ Disease’. The bulk of it may well be due to injury. Exposures of citizens,(not patients), to neurotoxic substances occupationally and residentially, will have to be identified and ruled out as sources contributing to declining cognitive functions. Dr. Kaye Kilburn, former professor of medicine at the Keck School and VA epidemiologist, saw that occupational asthmatics frequently displayed such signs of central nervous system decline with changes in memory, learning and motor skills. Unfortunately, he also found the majority of ‘normal control’ subjects were also showing signs of CNS degradation far earlier than age-related decline should appear. His paperback , “Endangered Brains” and a medical text on chemically induced brain damage (no financial interest) indicates that neurologists begin to look for signs of preventable, and not just premature, losses in function.

The only interventions mentioned in this news article – unless that is the fault of the reporter but I doubt it—are drugs which can actually damage the central nervous system (CNS) through hyperactivating it with anti-cholinergic pharmaceuticals. Earlier in the decade,. the EPA banned the most commonly used pesticide–Dursban–from residential use because it acted in such a manner. It killed insects through destruction of nerve cells firing themselves to death through suppression of the enzyme, acetylcholinesterase. Not only are those pesticides still in use in proximity to people but their replacement chemicals known as pyrethroids and pyrethrins also hyperactivate the nervous system by damaging neurons directly and amplified their toxicity with synergists. Those prevent the body from clearing such toxic substances from the body before they can do their killing work.
Alzheimer’s drugs would further damage the body’s ability to counter those substances. The CDC tells us our exposure to pesticides, primarily a class of neurotoxic substances, is ubiquitous. California is even now applying them aerially in the northern part of the state while many building owners have exterminators applying them 12 to 24 times per year to their buildings. Landscaping relies on numerous pesticides and herbicides with their multiplicity of actions.

It is time to stop counteracting chemical damage with more and earlier administrations of yet more chemicals. Occupational therapy to stimulate skills in decline, healthier diets and safer environments are what will halt the huge incidence of damage and disease. Technology has advanced. Exterminators have a wealth of profitable options in safer pest control now and drug makers are well aware of the hazards and limitations of various classes of drugs.

I was prematurely disabled by such substances and the cost to society of preventable illness is unsupportable.

Barbara Rubin

UPDATE:
http://www.ahrp.org/cms/content/view/726/9/

Corrections to the article have made by the Times after input from experts.

Meanwhile, Glaxo-Smith-Klein, maintains their earlier studies were conclusive in ruling out such adverse impacts for their product. However, if this item in the Triangle Business Journal is correct, legal settlements have already been made in more than 700 cases concerning this drug.

Wouldn’t it be cheaper to go to court and prove the drug did not have these adverse effects if the evidence were compelling? Or, are the costs of legal settlements merely part of the cost of doing business today? After all, given the enormous amount of dollars flowing into the coffers of some multi/trans-national corporations, settlements may be easily absorbed compared with the costs of further research and possible removal or modification of a product already in the marketplace.

This brings up important questions about plaintiffs’ attorneys. How moral it is to press for settlement after settlement in repetitive claims of harm for a product, rather than conduct a court-room trial on the matter? Trials set precedents and serve to limit future harm to those likely to repeat the experience of prior litigants and become the next generation of plaintiffs. Is litigation taken to the floor of a courtroom instead of a ‘back-room”, actually the most moral course of action?

Regardless, this may be indicative of how to best resolve discrepancies between a marketing firm’s data and the actual experiences of patients using a given product. The pool of available data about the incidence and nature of illnesses and injuries increases exponentially, when patients are enrolled in a public option for health care insurance. The potential savings alone from analysis of this data ought to pay for much of the costs for such coverage. This would certainly assist the FDA greatly in making tough decisions about approving drugs for sale, when to withdraw them or require further testing. As the public option would also be funding drug purchases, a great deal of attention would be paid to drug efficacy and the potential for adverse effects.

Here is the letter which went to the Times:

Re: NY Times editorial, “More Questions about Avandia” (7/5/10)

To the Editor,

Your editorial illustrates extremely important economic benefits to having a ‘public option’ in the provision of universal health care. Data regarding possible adverse outcomes from use of the drug Avandia, was only accessible because the 227,000 patients studied had Medicare coverage. Insured patients have records permitting impartial review of large numbers of cases.

Tallying the enormous price tag accompanying tobacco-related illnesses (CDC estimates $193 billion dollars annually in productivity losses, mortality and morbidity) led to ground-breaking legislation restricting smoking in workplaces. Diminishing rates of cardio-vascular disease have already reduced costs and much human suffering.

Universal health insurance in Europe brought about REACH, the requirement that vendors prove the safety of chemicals in products before marketing. The value of the ‘public option’ in matters of public health research and policy is clear.

Barbara Rubin

Postscript:

http://www.nytimes.com/2010/07/13/health/policy/13avandia.html?nl=health&emc=healthupdateema2

More history about the research and development of Avandia.

This post began with an ad for perfume. For infants.

The fragrance industry has been under scrutiny by various consumer watch-dog groups given the fact that they are not subject to FDA regulatory oversight for product safety. Nonetheless, some fragrance chemicals have been identified as reducing lung function, disrupting hormonal levels, affecting the function of various organs and central nervous system activity etc. A summary of adverse effects upon users and secondary ‘consumers’ passively inhaling these chemicals can be found here:

http://www.ieconnections.com/archive/feb_08/feb_08.htm#article3

It is to be assumed – as with smoking – that consumers would take care in selecting the safest among such products for personal use and to minimize imposing unwanted contact with them upon co-workers, family and friends. Many workplaces now request employees not use ‘plug-in’ air fresheners emitting these chemicals into the air on a constant basis. Some landlords request that scented candles and incense not be burned inside their rental units as chemical absorption into sheet rock and carpets might discourage future potential occupants from renting those units.

Until such time as the industry chooses to offer full disclosure of each product’s ingredients, the wisdom of the selections made by consumers remain unconfirmed in fact. Of course, advertising continues to bombard the public with urgent messages that our health is in danger if we don’t spray fragranced disinfectants all around us. Our social standing is dependent upon the scents and colorants added to our personal care products from hair dyes to moisturizing lotions. Our mental health cannot be optimized unless chemicals imitating the odors of flowers, spices or ‘fresh air’ are floating about our homes, schools and offices.

When this ad came to my attention recently, I was simply amazed to see even the suggestion that the smell of fruit – when paired with the activities of caring for an infant or child – will lead to increasingly loving memories of that time once it is past. The scent is to be applied to the child instead of the nursery or care-giver. Interestingly, directions are given to apply the perfume to the clothing because application to the skin might ‘importune’ the child, even though efforts were made to ‘minimize’ potentially allergenic content.

The company marketing this product is based in Canada but markets extensively throughout the USA. I sent the following letter to Health Canada and the FDA with copies to pediatric physicians and the American Lung Association. Turning infants into consumers of perfume for parental enjoyment and the imprinting of memories is simply something that does the entire system of marketing in these two countries a great disservice. To all of you ‘consumers’ reading this blog, I encourage you to assist our corporations in making their best choices among the products they sell by speaking to them directly with your comments and indirectly (but most powerfully) with your consumer dollars. Patronize companies offering full disclosure of ingredients, particularly when buying products which will directly or indirectly affect children. We shouldn’t be playing Russian Roulette with our children given recent statistics on the incredible rates of chronic illness and learning disabilities among these most precious of our natural resources. Patents protect businesses from having their formulas hijacked by competitors. Trade ‘secrets’ merely keep consumers in the dark while competitors ferret out the information through laboratory analysis.

We should just ask for the information or consider buying from those willing to share it openly on labels or MSDS sheets. It makes no sense to buy a product that is supposed to enhance our life-styles but which interferes with life processes – our bodies – instead. Further consumer dollars merely make their way into the coffers of physicians and pharmaceutical companies while we combat the side effects of our adopted ‘life-styles’. It is the work of a moment to look at a package and see if it offers full disclosure of ingredients.

Take that moment and transform our economy into one of true capitalism in which informed consumers dictate which products deserve to be sold in our marketplaces and those needing to be changed or removed from our store shelves. That is a truly ‘free market’ philosophy. This is about a lot more than just perfume. For infants. However, there is no reason why we shouldn’t begin there. Here’s the letter:

To Whom It May Concern,

An advertisement for perfumes to be used on babies as young as one month of age, touts the emotional benefits to be found by mothers. The ad speaks of mothers finding satisfaction in later years by memories evoked by this scent being associated with the early years of care-giving.

http://us.fruits-passion.com/order/item.aspx?idprod=584&idcat=0

The corporation is based in Quebec but markets throughout the United States as well:

http://corpo.fruits-passion.com/en/profile/index.asp

As a retired developmental disabilities specialist, I find this to be of some concern. The perfume industry is not regulated in North America to the point of having to disclose ingredients for their products. We know from many sources that fragrances are rife with thousands of possible ingredients, of which a significant number have never been tested for the full range of their possible health effects. We do know that some fragrance chemicals cause reductions in lung function even for healthy adults; some are associated with central nervous system depression, endocrine disruption or may have have sensitizing/allergenic properties.

http://www.ieconnections.com/archive/feb_08/feb_08.htm#article3

Instructions for using this product includes warnings not to ‘importune’ a baby by putting the solution directly onto skin but to apply it to baby’s clothing. Health statements appear saying that efforts were made to minimize allergenic ingredients but the only specific information offered is that the product contains no alcohol, parabens or colorants. Recent research from Germany cites measurements of emission from scented toys which exceed permitted concentrations for some ingredients by EU standards or have been banned.

http://www.ncbi.nlm.nih.gov/pubmed/20307885

I recommend that Health Canada and the USFDA review this advertisement and consider the manner in which it is advertised and health claims issued (does ‘importune’ mean ‘endanger’?). Since this fragrance is being advertised as beneficial to mothers, why apply it to a baby or their clothing where it will be inhaled by the infant even during periods of sleep when there is no contact with the parent? Do these chemicals come out in the wash so there are no cumulative effects increasing emissions over time and repeat applications?

We cannot know because the fragrance industry has no mandate to disclose ingredients to consumers or any government agency. This is problematic when very young children develop symptoms since they cannot act as informants to offer specific clues as to the nature of their ailments. If a registry of ingredients for all products directed for use on or around children exists, then pediatricians and parents could at least submit FOIA requests for information about possible sources of health problems arising around the same time as the use of a particular commenced in a household.

Given our current state of knowledge about known and potential toxicity/allergenicity effects of some fragrance constituents, it is only sensible to have such a registry. Fragrances are added to many products intended for use on children including skin lotions and medicants, toys, laundry products and room disinfectants etc. Improved access to possible sources of developing problems so common in childhood such as asthma and allergies, can only assist the fragrance industry in better designing its products for that targeted consumer groups. At the same time, it addresses issues pertaining to public health.

Thank you for your attention.

Barbara Rubin

In war, you know the identity of your enemy. Nicholas Kristoff asks an excellent question in this Op Ed piece for the NY Times, “Do We Really Want the Status Quo on Health Care?“. It identified lack of health care as part of the current status quo. The next question to ask here is just who or what is the enemy, taking out so many non-combatants each year? Is it health care costs? Certainly a single payer system would go far towards cost containment since the private sector is guilty of price fixing in setting values upon products and services – be it a mortgage or an MRI. Health care constitutes more than 17% of our gross domestic product for other reasons.

It’s a bit ridiculous to claim it is ‘overuse’ of services as we hear from the ‘party of No’. The last time I checked, people in the market for entertainment chose Disneyland over a visit to an orthopedist. Services are certainly not ‘overused’ by those without insurance and the many people who are ‘under-insured’. The latter individuals forgo many exams and medications due to co-pays and the need to cover that next health insurance premium which is really retained for catastrophic coverage. Nor are services ‘overused’ in the quest for a proper diagnosis in a culture of health care that is oriented to the control of symptoms instead identification of their source. Drugs may be ineffective for their intended purpose and many lead to serious adverse effects as well. Seeking out multiple physician opinions to obtain health care with a good outcome is not ‘over-use’ but a necessity until medicine matures sufficiently to return to cure-oriented treatments. This is well understood – and feared – by many Americans. I personally know one, very well insured person, who suffered a stroke rather than see a physician for check-ups to learn about having chronically high blood pressure and silent kidney damage.

If it is ‘just’ about sickness, then we need to utilize the renewed Patriot Act in order to force Congress to legislate universal health care. The enemy must find it incredibly comforting to know that Americans require huge amounts of health care because we are an exceedingly ill nation.

• One quarter of children have a chronic health condition.
• Nearly half of all adults have a chronic health condition.
• Our seniors, comprising more than 12% percent of our population will predictably require care and ‘end of life’ services. Medicare exists to provide them with a considerable degree of coverage for their conditions without the attendant blame for needing health insurance which is accorded to younger Americans without the funds to pay for it.

We are a nation of patients. Debating about caring for the sick is entirely based upon a premise that our country is first an economic system rather than a constitutional entity. The health care debate centers around the notion that offering a cost-effective public system of medical coverage to its citizens is unfair to industry because it removes a share of potential consumers from the marketplace. All discussion of competition between insurers (not even providers of care) relegates the science of medicine to an equal rung on the marketplace ladder with, say, that mysterious metal coil we call a ‘Slinky’. Are these really products and services we wish to consider identical to the marketing of toys within the marketplace?

If you can’t afford bread, it will be provided to you. However, you may have to ration those loaves carefully to last you for the requisite period necessary. Can a lesser tier of insurance provide a ‘half-cure’ for a disease? Ask any physician if you should take seven days of antibiotics for an infection which requires fourteen days of medication to achieve a cure. Patients have been known to cut short the length of treatment time for many infections in the hope that rationing their medication for their current illness will save costs for new prescriptions for their next illness. We know now that this approach merely leads to the growth of antibiotic resistant infections and far greater illness (not to mention costs) than had we assisted them with the full price of earlier treatments. Seizures are quite difficult to control in many patients without a minimum level of drug support and often combinations of drugs. The nervous system may not recognize the notion of ‘compromise’ based upon income. Should the acquisition of seizure medications be dependent upon the same economic system that markets Slinky toys? Does our national identity become so lost if medical care is provided to all that it is better to consign 45,000 people each year to death for lack of medical insurance? Any war with that level of annual casualties would have the public taking to the streets in protest. Of course, this figure doesn’t even factor in deaths due to being ‘under-insured’. Again, how much compromise can one safely make with costly high blood pressure medications?

As with most issues which appear to be full of contradictions, philosophy dictates that we must check our assumptions. The ‘right’ side of the legislative debate (or the wrong side for purposes of this blog post) relegates the art and science of medicine to a commodity instead of a life preserving or life-saving practice. If medicine is strictly a commodity then it will remain available only to those with sufficient income for a comprehensive tier of medical insurance. The minimum wage only offers sufficient income to deprive earners of federal medical coverage granted to the ‘legally’ poor. The majority of insured Americans will eventually find themselves ‘under-insured’ in a marketplace where every buyer is guaranteed to need their full investment back when they get sick. With the escalating numbers of sick and disabled Americans, no insurance company can be considered a sustainable entity as fewer healthy people purchase their policies.

Since capitalism invites unsustainable businesses to go out of business, should medical care be considered part of that process at all? Medical care for humans isn’t a ‘choice’ as it is with veterinary care for pets. One can put down a sick Doberman or withhold treatment but is that option open to you with Aunt Edith? It would seem that regarding medical care as a commodity is the surest way to create death panels based upon income levels alone. Only the poorest, the elderly and the wealthy will be able to access care unless the insurance risk pool grows to include everyone AND we begin to deal with the excessive rates of illness. Controlling environmentally induced ailments will not just slow the rate of inflation but reverse it.

Let’s move on to another radical assumption about ourselves as Americans. Requiring a basic level of wealth in order to access health care services says that we are first and foremost consumers, rather than citizens. Our last administration was fond of terming us, “consumers” and the presidency as akin to the CEO of America. As consumers, we become subservient to corporations which claim they must not be required to compete with a government capable of offering the same essential medical services to its legal residents at a lower cost, i.e. Medicare. Why can’t they compete? Is there some reason corporations are supposed to be underwritten by the government to ensure the availability of customers or a particular profit margin? If the products and services of a company are out of range of most consumer’s wallets, wouldn’t any company naturally diversify or go out of business? Isn’t it corporate welfare to consign American citizens to the mercies of private insurers with no other options? Does that even guarantee any level of competition will exist?

By the time G.W. Bush left the gubernatorial chair of Texas, medicaid payments were so reduced that doctors could not afford to maintain a practice in poorer areas. United States ‘consumers’ were crossing the Mexican border to obtain services from clinics in Mexico. The government failed to meet even the meanest corporate standard of payment for essential services and certainly health care professionals are entitled to a living wage! A definite end to any government challenge to business.

No economic system should be confused with determinations of basic morals and ethics. Canada and European nations don’t classify medicine in the same category as other commodities. For the average commodity such as housing, food and clothing, one budgets according to one’s income. Those who can’t own, rent. Those who can afford to do so choose lobster over tuna. The cost differences between various brands of clothing is quite broad. Consumers choose accordingly but still remain housed, fed and clothed for the most part. Citizens in dire straits however, do receive food, clothing and housing. Why then is medicine assigned a lower rung on the ladder of necessary products and services? National identity is at the heart of this debate, not capitalism and competition. Further erasing the notion of competition being at the heart of this debate – revealing as such a position may be – true competition no longer appears to be part of our major industries. Price fixing is common today, as I recently found when looking at independent and assisted living facilities. Astonished by the notion that a small room in such a facility was deserving of a monthly, $2,100 price tag, even with a meal plan. I was informed by one manager that it was only fair not to undercut the prices of their competition too greatly. The presence of government options with little or no profit margin restores an absolute value to such products and services once more. All we’ve known in recent decades is relative value – the minimum profits agreed upon by trade associations without regard for demand in relation to production costs (varying according to quality).

Price fixing is the purposeful undermining of capitalism in order to restrict ‘fairness’ to corporate entities instead of the consumer. It restricts efforts to promote increased quality among similarly priced services wherever there appears to be sufficient numbers available to feed at the shared trough. Only when the numbers of ‘consumers’ available to take these small rooms in senior communities decreases, can a fall in charges can be expected. These ‘homes’ have many rooms going empty which is not, apparently, a threat to their continued operation. This is not a function of competition but of tacit agreement between corporate entities that one must take every last penny from a consumer’s wallet before declaring one’s profit to be at an acceptable level. Rooms go empty rather than be accorded an actual value which would be within the means of far more consumers and still be profitable for the vendor.

I had a similar experience with used car dealers. None would disclose what a car was worth until they learned of how much money I had to spend – carefully calculated by them according to my income. The worth of the car appeared to change with each successive journey the salesman made into his boss’s office during negotiations. I believe Saturn became a popular car based upon its sales policy of one price for all customers. Imagine that – a product with a singe value accorded to it regardless of consumer income. Comparing that view to that of the salesman in that assisted living facility is the best illustration of how capitalism has mutated into a form of gangster capitalism. When politicians begin expounding about maintaining a ‘free marketplace’, we must remember that the marketplace is never free when profit margins are pre-determined by official or unofficial trade associations. Instead of increasing quality and advancing new technology, vendors band together to break any newcomer so foolish as to actually exceed their level of service quality for the money in a sustainable manner.

Capitalism was supposed to spur the pursuit of excellence in industry. Progress depends upon it instead of solely relying upon tax incentives for industry to embrace new developments as older – and often hazardous – products and services are banned.

We must further go to the nature of our justice system which promises injuries can be redressed. With so much illness either known or suspected to be the result of pollution – a byproduct of industry which is largely ignored by government regulators – how can we permit it to go untreated? How can we wrest the costs from the victims of pollution? We’ve seen lead removed from paint and the outrage over of imported toys possessing that toxic ingredient. We’ve seen anti-smoking legislation reduce cardiac events by one third in participating municipalities. Pollution emanating from many uncontrolled sources is also causing asthma, heart disease, autoimmune disorders and cancers among other disorders. Why is the individual held responsible for their medical treatments when causation goes undeterred? This is an issue of justice as much as it is one of national identity. Are we citizens or consumers? If the elderly are allowed medical care, it is ageism to declare younger citizens to be dispensable in all matters medical.

Obviously, the real enemy is sickness. We have consistently failed to meet it on the honorable battlefield of medicine because – that’s right – we left the field of battle to lobbyists and their corporate sponsors telling dying people that it is better to be dead than participate in ‘socialist’ medicine. What, pray tell, should we do when reaching retirement age? Commit hara-kiri rather than accept evil, government-sponsored Medicare?

We know that voters began demanding universal health care, preferring a single payer option just one year ago, before slogans and tea parties began to frighten the average person into believing they are better off without health care than with an incomplete plan of action – as if any taxes paid towards that effort would ever even approach the charges of the average health care plan in America. That would not be the case if healthy Americans were paying reasonable premiums to, say, Medicare instead of a private insurer where overhead would automatically be greater lest an American CEO be left behind. Paul Krugman gives an excellent synopsis of the insurance game lest anyone remain in denial of how this process works.

Sickness may be the enemy but ignorance and denial leaves us without the weapons to fight it. We are thus far unarmed in a battle which is not about life. It is about ideologies which are counter to both the ideological basis upon which we are governed and to capitalism, our presumed economic system. There isn’t much more you can get wrong in politics.

Once the public realizes that freedom of speech does not ensure accuracy of content, we may begin to take our personal responsibilities more seriously, having fiddled while the District of Columbia burned. But don’t expect treatment at your local ER for your wounds unless you have great insurance. When Massachusetts voters decided that, having attained universal health care for their fellow Bay Staters, the remainder of the country could go without lest any part of that cost devolve upon them, it was clear that Americans no longer wondered about what was to happen the day AFTER tomorrow.

Perhaps the new conservatives they elected will be happy to suspend their health care once their state’s allotments no longer cover their citizens. Pretending you aren’t part of a larger nation is always a mistake. It takes an entire nation, not a village. Villages are razed all around the globe daily by the bullies and their minions- who also don’t think about the day after tomorrow.

Re: NY Times Editorial, “Evidence and Health Care Reform

Dear Dr. Editor,

Costs do not determine the appropriateness of a medical procedure like virtual colonoscopy. Physicians do, based upon deliberation of options for optimal outcomes. Immediate and delayed problems can occur from mechanical injury, anesthesia, infection and the use of particular agents during preparatory cleansing.

There are those of us who know patients who suffered adverse effects. I still miss my friend, very much.

By removing any procedure as an option for Medicare patients, you are tying the hands of those who are best qualified to make that determination. Austerity budgets have to be honest. Virtual colonoscopy is not unproven. If it is no longer reimbursed, let’s be honest about the reason.

My newspaper, the doctor! I’m so proud…

Barbara Rubin

Just a couple of references chosen at random on the topic:

• Computed Tomographic Virtual Colonoscopy to Screen for Colorectal Neoplasia in Asymptomatic Adults
• Differing views on virtual colonoscopy accuracy

UPDATE: Another virtue of virtual colonoscopy appears to be a reduction in the risks of contracting hepatitis and HIV. Thousands of patients, subjected to conventional colonoscopy procedures, have been required to undergo testing for these diseases after having this procedure performed with improperly sterilized equipment. May I cynically point out that if the conventional procedure began requiring the use of sterile operating rooms instead of outpatient or office quarters, we might see the scales tip in terms of recommendations for virtual exams given the increased costs involved?

• TN, GA and FL.: 10 colonoscopy patients have hepatitis, VA says
• Miami: Colonoscopies suspended at Miami VA Hospital as investigation opens
• …and last year in Nevada: Hepatitis C outbreak springs from Endoscopy Center of Nevada; 40,000 at risk

Public concern continues as more unwelcome ingredients, such as asbestos and lead in children‘s toys, are discovered in a variety of imported products. A longer-running dispute continues domestically between consumers and vendors of many products boasting undisclosed ingredients.

Among them is the class of widely marketed products known as synthetic fragrances. The older question about consumers’ right to know about the contents of any purchase is now entering a new realm of debate about the need to know all about the chemically laden manufactured goods on the market.

As reports about the adverse health impacts of commonly encountered products mount, the current American version of “free” enterprise seems to be traveling a collision course with the growing public outcry for greater regulatory oversight. Basic marketing philosophy for materials concocted in modern laboratories appears to be in conflict with the original vision of capitalism as a consumer-driven process, in which demand shapes supply. What happens to the nature of consumer demand in an era of consumer ignorance regarding the items they buy? Let’s examine this question using as a microcosm the debate surrounding the production of synthetic fragrances.

As many as 5,000 different chemicals are incorporated within various fragrance formulas, according to the American Academy of Dermatology. Industry asserts that fragrances have been used safely for hundreds of years. Such claims are belied by the fact that chemical compounds appearing in the products (e.g., benzaldehyde and linalool found to be present in a 1992 EPA laboratory study), have not been known for very long. Today’s fragrances rarely contain only those natural ingredients used in earlier centuries; hence the adjective, “synthetic.”

The public is prone to assume that all these chemicals have been thoroughly vetted for their safety prior to sale. Many chemicals have multiple uses across industries, appearing in cosmetics, medications, cleaning products and even food flavorings. The intended use of a product determines what agency, if any, has jurisdiction for inquiring into its business.

For instance, the U.S. Food and Drug Administration states that it has no oversight duties with regard to the ingredients used in cosmetics. These consist of products intended to enhance attractiveness whether the product is ingested, topically applied or inhaled. The only exception is with colorants (as in hair dyes). Otherwise, unless some claim is made regarding benefits to health, as opposed to self-esteem, there is no requirement for registration of these products with the FDA. This means that recalls of products suspected of containing potentially harmful ingredients are essentially a voluntary act on the part of vendors.

How complex is the task of developing appropriate testing protocols for fragrance chemicals? There are multiple avenues for their internalization apart from direct application and absorption through the skin. Fragrances are intended to be inhaled, which would seem to make assessment of their potential as respiratory irritants or sensitizers a priority at least equal to the more commonly cited skin testing. Once airborne, fragrance chemicals are going to be absorbed by all in their vicinity, not just the intentional user. A class of secondary, unintentional fragrance consumers is created via the same mechanisms by which secondhand cigarette smoke has become an issue before the general public. Therefore, the societal impact of these products is far greater than basic consumer demand summarized in sales statistics.

Measurable reductions in lung function, to a moderate degree, have been observed upon exposure to the chemical 1,4 dichlorobenzene, which is commonly found in deodorizing compounds. Ninety-six percent of subjects in a 2006 study (Elliot et. al.) showed evidence of exposure via blood sampling. Exposure by persons with pre-existing respiratory problems or by healthy individuals in combination with other common environmental irritants would have an even greater impact upon intentional and unintentional consumers.

A thoroughly tested synthetic chemical can provide data accounting for factors of carcinogenicity, central nervous system effects, reproductive and developmental toxicity, cardiovascular and endocrine effects, and specific organ vulnerabilities (e.g. liver or kidney damage). While the industry may have dispensed with a few harmful substances formerly incorporated in fragrances, manufacturers do not speak of the thousands currently in use. These include petrochemicals, aldehydes, phenols and esters, which are all known to have wide-ranging adverse effects when studied in isolation. Their effects in combinations have yet to be addressed in research models.

A newer area of concern is that of “mutagen” effects, or how chemicals around us alter the ongoing activity of our genes, cuing them to turn themselves on or off as they go about the daily business of regulating our bodily functions. The interactions of the environment with gene functions (referred to as gene expression), indicates that one need not have a genetic predisposition or defect for harm to occur.

The identification of hazardous or potentially hazardous ingredients in a product is usually followed by assurances that the amount present is negligible. Unfortunately, the determination of how much is too much is highly variable. Relevant factors include age, gender, weight, general health status and cumulative levels of exposure to multiple chemicals.

Practically speaking, this position is irrelevant to the very large numbers of people who report that a product has harmed, rather than enhanced, their quality of life. Science has also progressed beyond the old saw “the dose makes the poison.” It is now recognized that small amounts of a substance can sneak under the radar of one’s physical defenses while larger amounts of the material would alert the body to implement damage control procedures.

The American Academy of Dermatology also informs us that fragrance ingredients, along with preservatives, are respectively the first and second most frequent causes of contact dermatitis. Physicians warn us that contact can be from airborne particles and not just occur in primary users of a product. Between 40 and 50 million Americans (20 percent of the population) have allergies to one or more substances. Health care costs and losses in productivity are estimated at $6 billion annually from this widespread problem.

Approximately 35 million Americans suffer from some form of chronic lung ailment. The majority are diagnosed with asthma (over 22 million) and a majority report fragrance as being a common trigger for attacks. Asthma costs the public over $19 billion per year in direct healthcare costs and lost productivity. It is the most frequent cause of missed school days in children.

Migraine headaches are experienced by some 28 million Americans at an annual cost of $14 billion in medical costs and lost productivity. Among the majority, who report triggering events for their attacks, a sizable percentage count olfactory stimuli among them (perfume and/or strong odors).

Subgroups of chronically ill persons like those on chemotherapy and people who became ill following incidents of exposures to toxic chemicals are particularly vigilant in attempting to avoid such products. There is a sizable body of evidence that synthetic fragrances are a burden upon very large numbers of people.

According to sufferers, reactivity ranges in severity from annoying to disabling. Advice by vendors to individuals with adverse reactions to such products has simply been to avoid them. These consumers may choose to leave fragranced products untouched on store shelves, yet are still exiting stores, offices, hospitals, schools and libraries with molecules from these products left adhering to their nasal passages and lungs. These particles may later be deposited in other organs or stored in adipose (fatty) tissue and subject to gradual release over time. The indoor air of our typical environments is heavily laced with fragranced products emitted from store merchandise, cleaning products, air fresheners and the individuals we encounter throughout the day. Residues from various laundry and personal care products cling to their skins and clothing articles. Products may now include phthalates, those plasticizers which can act as perfume “fixatives,” making them longer lasting. The FDA plans to assess their safety in the near future, although other researchers classify them as endocrine disruptors.

Since general avoidance of fragrance chemicals is frankly impossible, consumers are left to try to identify key offending ingredients. This, too, is impossible, since industry is legally permitted to label the often-complex conglomeration of ingredients with a single term, namely “fragrance.” This does not allow individuals to collaborate with their physicians and isolate causes for environmentally triggered problems. It does not allow proactive, health-conscious individuals to discriminate among the varieties of fragranced products on the market today.

Only disclosure of ingredients offers consumers the opportunity to select preparations which are truly benign. The absence of such information makes it impossible to select products best suited to an individual’s particular health challenges, even by the expensive process of trial and error. Some adverse effects may be delayed and therefore not easily recognized.

Ostensibly, this withholding of information from consumers is done to protect trade secrets. One wonders what consumers are expected to do with such revelations if they became available. Certainly, competitors already analyze one another’s products in their own laboratories as a matter of course. In Europe, where labeling is required, companies do not appear to be going out of business because of competition from the man (or woman) on the street, who might choose to make such products at home!

Clearly, we need greater assistance from the fragrance industry to help consumers make appropriate selections from among thousands of fragranced products. These were created to enhance the quality of life rather than detract from it. Patents serve to protect industry interests, but only full disclosure of product ingredients will allow consumers to protect their own interests. Of course, this raises the question of why the interests of consumers and vendors would ever truly come into conflict with one another. Satisfied, healthy consumers generate more disposable income. This in turn enriches the makers of products that satisfy the demand for that level of quality in composition. If competition relies less on consumer ignorance and more on informed consumer preference, the marketplace can only become a source of healthy competition in a capitalist society.

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Barbara Rubin holds an MA in speech/language pathology and worked in the field of developmental disabilities for 25 years within educational and medical settings. In addition to her role as a therapist and supervisor of clinical programs, she also taught in several colleges and universities in her field of expertise.

Following her retirement in 2000, Rubin became a freelance writer about the human health effects of pollutants commonly encountered within indoor settings. She has published several magazine articles and numerous commentaries in various newspapers and journals. She would like to thank Barb Wilkie and Alison Johnson for their gracious editorial assistance with this article.

This article announces how a school was relocated so its building could be tested for an explanation of employee illnesses. Has anyone looked at student attendance records? I was poisoned in a school but have no notion of what, if any, effects there were for others. These are not mysteries. We have the technology for discovering what is around us and the ability to comprehend our physical intolerances for the follies of our fast food/quick construction society. The cost of health care today, and the huge demand for it, tells the tale.

My letter:

To the Editor,

Every public building requires toxicological testing. Not an impotent OSHA checking on carbon dioxide levels and merely cracking a window. A competent assessment examines mold for potential toxicity. It assays airborne volatile and semi-volatile compounds from fuels, cleaning solvents, construction materials, and furnishings.

I have tested a variety of residences and offices with shocking results. Mid to high levels of pesticides banned decades before that foundation was even dug; formaldehyde exceeding levels found in FEMA trailers; methylene chloride from chemicals stored in a garage below an apartment. Not unlike any other residence or office. I became disabled in a school I was supervising after applications of multiple pesticides.

The human genome was not designed with PCBs in mind. Many common synthetic chemicals are less than sixty years old. We cannot survive the onslaught, unscathed.

Test and build, or rehab carefully. Sometimes you don’t get a second chance.

I should know.

Barbara Rubin

The Inquirer informed me they were interested in printing my letter to them on this subject but, lo and behold, today we see this breaking news. It appears that there was sufficient outcry to delay the ban on truth in labeling for milk derived from cows treated with synthetic hormones:

http://www.philly.com/inquirer/breaking/business_breaking/11886772.html

The Pa. Department of Agriculture is reconsidering its actions. However, the consumers still need to know that their right-to-know continues to be a subject of debate.  Anyone want to write about it and let them know?