INDOOR AIR QUALITY AND WORK
ENVIRONMENT STUDY
EPA HEADQUARTERS BUILDINGS
SUPPLEMENT TO VOLUME 1:
ADDITIONAL EMPLOYEE ADVERSE HEALTH EFFECTS
INFORMATION
NOVEMBER 20, 1989
NATIONAL FEDERATION OF FEDERAL EMPLOYEES
LOCAL 2050
AMERICAN FEDERATION OF GOVERNMENT EMPLOYEES
LOCAL 3331
Printed on Recycled Paper
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SUPPLEMENTARY INFORMATION RELATED TO
THE INDOOR AIR QUALITY ASSESSMENT OP EPA HEADQUARTERS
A three volume report on the indoor air quality at
headquarters, U.S. Environmental Protection Agency has been
undertaken. It attempts to be a thorough and comprehensive study
of the "perceived and actual" quality of the indoor air environment
at EPA Headquarters buildings. As of mid-November, 1989, only
Volume I has been completed. Volume I is a report on an employee
health survey conducted in February, 1989.
The unions believe that to make the three-volume study as
useful to the public as possible, to more completely reflect
employees' views on the state of air quality at EPA headquarters,
to make known the full extent and severity of injuries to
employees, and to promote effective and timely action by EPA
management on its indoor air problems, all available information
on the incident which prompted the three-volume study in the first
place (installation of certain new carpet and attendant employee
injuries) should be conveniently packaged and published forthwith.
The unions' preferred approach was to include the material
contained here as Appendix D to Volume I. This did not prove
possible, and this Supplement is therefore being co-produced with
Volume I as a companion document.
The unions believe that this Supplement is necessary because
Volume I reports only on employee responses to the health survey
questions, and therefore does not adequately address the most
serious injuries suffered by EPA employees over the period October,
1987 through the Summer of 1989—induction of multiple chemical
sensitivity. Further, other important information, including
medical/professional opinions as to the significance of employees'
health status is not included in Volume I. The unions believe that
waiting for six or more months for this information to be published
in subsequent Volumes of the report is not in the best interest of
EPA, its employees or the general public (many of whom suffer from
afflictions mimicking those of EPA employees).
The Supplement includes an analysis of data gathered by Local
2050, National Federation of Federal Employees and by Mr. Mark
Ennen, an industrial hygienist who interviewed employees during the
Winter/Spring of 1988. This analysis is in the form of a paper
titled, "Carpet/4-Phenylcyclohexene Toxicity: The EPA Headquarters
Case", presented before the Society for Risk Analysis, October 30,
1989. Also included are documents relating to petitions sent by
employees to EPA management, letters from public health
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professionals commenting on the implications of Volume I and on
the indoor air quality at EPA Headquarters, and narratives from 18
employees, most of whom suffered induction of multiple chemical
sensitivity at EPA Headquarters following exposure to new carpet
fumes from October, 1987 through Summer, 1988.
Bob Carton, Ph.D., President
NFFE Local 2050
Kirby Biggs, Steward
Health & Safety
AF6E Local 3331
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TABLE OF CONTENTS
SUBJECT PAGE
Letter: Bradley/Reilly. 6/25/89, and attachment
RE: Examinations of employees 11/88-4/89 1
Memo: Anderson Weitzman, 6/16/88
RE; Reproductive toxicity concerns 6
Memo: Day/Carra, 5/13/88
RE: Office of Health and Safety response to
employee and supervisor complaints 8
Petition to Thomas, 8/4/88 12
Testimony on Indoor Air Quality Act of 1989
by Bobbie Lively-Diebold, 7/20/89, and Appendix I,
personal histories of injured employees 14
Petition to Reilly, 10/20/89 39
Letter: Cannon, Clay, Holmes, Wayland/Reilly,
10/20/89. RE: Recommended evacuation of portions
of Waterside Mall 41
Letter: Bradley/Morison, 10/20/89
RE: Interpretation of Vol. I data 43
Letter: Davidoff/Morison,11/3/89
RE: Interpretation of Vol. I data 45
"Carpet/4-Phenylcyclohexene Toxicity: The EPA
Headquarters Case" by Bill Hirzy and Rufus Morison
Paper presented to the Society for Risk Analysis
October 30, 1989, San Francisco CA 46
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MARK E. BRADLEY. M.D.. M.P.H.
OCCur At ION At. MIOICINI
93 »• FALLS •nioai UANI
POTOMAC. MARYLAND
USA
OOU 2B»-«B2«
June 25, 1989
The Honorable William K. Reilly
Administrator
Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
Dear Mr. Reilly:
I am a physician whose specialty is occupational medicine.
From mid-November, 1988, until the en4 of hay, 1989, I worked as
a consultant physician at the EPA Hea)'d. Unit. I am writing to
you, because my previous attempts tc >:a.ise management concerns
have been ignored.
During the period that I worked at the EPA, I interviewed
and examined approximately 60 of your employees who work at the
EPA headquarters. I have very serious concerns about the health
and well-being of these individuals, and many others who I did
not examine. The purpose of this letter is to share these
concerns with you, and provide & first-hand, third party view of
the building related illnesses, which are occurring &t your
facility.
During the six and a half month period that I was a consul-
tant at the EPA Health Unit, at least 80% of the individuals who
I examined, had bone, fide medical problems, which I believe are
caused by working at the Waterside Mall complex. Fifty to sixty
percent of these folks had symptoms and physical findings which
were typical of a "Tight Building Syndrome", that is to say eye
and throat irritation, headaches, and so forth. Some of these
people were severely affected. Thirty to forty percent of the
patients that Z examined had symptoms and findings of airway
hyperreactivity which can be considered to be a form of occupa-
tional asthma. Ten percent of patients had evidence of allergic
alveolitis, an inflammatory reaction in the alveoli and bronchio-
les of the lung resulting from an immune interaction between
inhaled organic particles, circulating antibodies and sensitized
lymphocytes. This condition can be progressive, leading to
progressive pulmonary impairment and death. ( You will note that
these percentages total more than 80%. The reason for this is
that a fair number of these patients had more than one process
ongoing.)
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I am certain that during the period of time that I was
seeing patients at the EPA Health Unit, that I saw only a small
fraction of the people who are potentially, adversely affected by
the environment of the Waterside Mall complex. Based on my
experience with problems of this nature, as well as patients
reports of colleagues who were having difficulties, I estimate
that 10 to 20% of the personnel at your headquarters are ex-
periencing untoward health effects. I frankly consider that there
is a major public health situation at this location, and that
this is not being dealt with in a timely, positive and respon-
sible fashion. What is particularly unfortunate is that this is a
totally remedial situation.
On a monthly basis, I submitted reports which noted these
findings and expressed my concerns. I made multiple recommenda-
tions for investigative and remedial actions. I got absolutely no
response to these reports at all, and as far as I can determine
no* action of any sort has been taken to rectify this situation.
I have enclosed copies of my reports and other correspon-
dence during this period, as well as a copy of my resume which
describes my background and experience in occupational medicine.
I strongly recommend the following:
1. There are multiple instances of defective design and
maintainance of the air handling and conditioning systems in
the Waterside Mall, which may well be contributing to indoor
air quality problems. These need to be rectified.
2. The epidemiological data that Westat has collected should
be analyzed as soon as possible to determine those areas
b Are ^articular "hot spots".
3. A large scale pulmonary function screening program should
be implemented to detect affected individuals.
4. Simply increasing the ventilation to provide maximum
fresh air exchange would be immediately beneficial.
5. This situation does warrant consultation by a physician
experienced in building related illnesses. Consideration
should be given to requesting assistance from NIOSH and/or
CDC. Alternatively, Dr. Kay Price is internationally
recognized as an authority in this are*. Dr. Price is
currently Director of Occupational Medicine at the National
Jewish Center for Imrouno logical and Respiratory Diseases in
Denver .
1 will be happy to meet with you and your staff to discuss
this situation. I recognize that this it an extremely sensitive
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and emotional situation, and feel that you are in the best
position to address it.
Sincerely Yours,
>~5~_
Mark
E. Bradley, fat
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KEDICAL IN COKFIDENCB
February 21, 1989
Dr. Juan Pozo-Olano
Health Services International. Inc.
3101 South Street, N.W.
Washington, D.C. 20007
Dear Dr. Pozo-Olano:
This letter follows up on our recent conversation regarding
my occupational medical work at the Health Unit of the Environ-
mental Protection Agency. Since mid-November, 1988, I have
interviewed and examined between 35 and ' 40 patients at this
facility. The majority of these individuals have symptoms and
signs which are quite typical of a "building related illness".
A few of these individuals clearly have affective disorders, such
as depression, while a few others have situational adjustment
disorders in which there is job "burn-out" or employee - super-
visor conflict. I have unearthed a surprising amount of non-
occupationally related medical conditions, such as anemia,
prolapsed mitral valves, diabetes, hypercholesterolemia, carpal
tunnel syndromes, etc.
One extremely disturbing finding has emerged in the course
of this work. Two (and possibly a third patient) of the in-
dividuals that I have examined have shown moderate restrictive
defects on their pulmonary function studies. I would point out
that the likelihood of finding restrictive lung disease in 5 to
10% of the general population it very remote. Certainly, there
are non-occupational disorders such as sarcoidosis that can
produce restrictive lung disease. However, my concern is that
this may indeed represent an occupational pulmonary disorder in
these individuals. Hypersensitivity pneumonitis can cause the
sort of symptoms and findings that these patients have. The
etiology agent of hypersensitivity pneumonitis is frequently
biological, but it can be caused by exposure to certain chemicals
such as isocyanate, phthalic anhydride, etc. The fact is that the
potential antigens for hypersensitivity pneuroonitis is extremely
large, and our knowledge of which chemicals can cause this
phenomenon is quite small. For example, I have seen identical
findings in individuals who have been exposed to chemicals in
workplace situations as divers* as ice cream plants and research
laboratories. With prolonged exposure to these substances and
persistent chronic inflammation, the patient can, and often is,
left with permanent and debilitating lung disease.
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MEDICAL IN CQHFIDENCE
My work with these individuals has thus far consisted of a
evaluation of their disorders within the scope of the contract
that Health Services International, Inc. has with the EPA. This
has included physical examinations, chest x-rays, pulmonary
function studies, serum precipitins, and other appropriate blood
work. I have notified Ms. Rachel Gregory of my findings and
suspicions, and have recommended that mold and fungi cultures of
the work space of one individual be obtained and that an inspec-
tion of the air conditioning systems to that area be performed.
I strongly recommend that these individuals receive a more
comprehensive evaluation of their pulmonary status than can be
provided at the health unit. This should include examination by a
pulmonologist with extensive pulmonary function testing as well
as other tests that would be indicated. As luck would have it,
none of these individuals has health insurance, and as two are
AARP employees, there is some question regarding what organiza-
tion would be responsible for medical evaluation and treatment
under "Workman's Compensation", if these were determined to be
occupationally related disorders. I have two concerns about this
dilemma. The first relates to the health of these folks. The
second, to the impact that this would have on the EPA if these
are occupationally related. The "building related illness"
employees at EPA are quite militant and vocal, and the potential
for fanning the flames into a major conflagration is great.
This information is, of course, extremely sensitive, and
should be handled in confidence. Please ponder this. I look
forward to discussing this with you in further detail.
Sincerely Yours,
Mark E. Bradley, M.D.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
JUN I 6 I988
OFFICE OF
SOLID WASTE AND EMERGENCY RESPONSE
MEMORANDUM
SUBJECT: Additional Comments on OHSS Indoor Air Quality
Questionnaire
FROM: Kent Anderson ' xXX~/X^ ''•<..c.:'-'
Ventilation Comro-f'ttiefe'Ttepresentative
Land Disposal-^Branch, OSW (WH-565E)
TO: David Weitzman, Director
Office of Health and Safety Staff
In addition to my earlier comments on the questionnaire, I
have received additional concerns from our female employees.
They are particularly concerned over the importance of
identifying any long range chronic health effects as a result of
our working environment. Any acute health effects which we are
beginning to document may serve as an indicator to an even
greater long term health problem.
Specifically, several women, never making the connection
before, have identified a history of abnormal menstrual cycles
and/or gynecologic complications, after it was disclosed that
there were detectable concentrations of a chemical being emitted
from the carpets that affected both enzyme and estrogen levels.
The Office of Health and Safety should design and conduct a
thorough epidemiologic cohort study on health effects of women
in the EPA work environment. Although the problems that women
are having 'are something that has not been openly discussed,
several women are experiencing menstrual abnormalities. A
cohort study would not only document the incidence rate of these
problems, but would also determine whether the women in EPA
have a higher rate of problems than the rest of the working
female population. Given that EPA's female population is, on
average, a young population, in their reproductive years, it
is of great concern. Also, since this population is not in the
menopausal or pre-menopausal age group, this would not be a
significant confounding variable in the study.
Just in one OSW branch along, every women has had either
abnormal growth in fibroids (which are very sensitive to
estrogen levels), abnormal uncontrollable cycles (which are
dictated and controlled by estrogen levels), or an inability
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to conceive (also influenced by estrogen levels). This is
surprising, but raises concern, consider!..c, thai the majority
of people showing severe acute adverse health effects are
females.
There are several occupational physicians and epidemiolo-
gists who specialize in reproductive effects. There are
scientists within the Agency itself that also could lend
expertise. Please let me know if you are interested in pursuing
such a study, since our Office can provide references for such
an effort.
cc: Jack McGraw
John Chamber 1 in
Jim 0"Leary
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I, UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
? WASHINGTON, D.C. 20460
MAY 1 3 ;S38
OFFICE OF
MEMORANDUM SOLID WASTE AND I;MERGENCY RESPONSE
SUBJECT: Indoor Air Problems at EPA Headquarters
FROM: Arthur Day, Acting Chief
Land Disposal Branch
TO: Joseph S. Carra, Director
Waste Management Division
Numerous complaints have been voiced regarding the poor
indoor air quality in the area of the second floor mall, where
the majority of OSWER employees are located. Resulting health
effects range in severity and include headaches; burning eyes,
nose, throat, and skin; nausea; persistent cough; respiratory
infections; sinusitus; dizzy spells; difficulty breathing;
disorientation and confusion; numbness of limbs; and
constricting larynx.
At least two EPA employees from OSW have been hospitalized
due to severe reactions to contaminants which are being
circulated throughout the ventilation system at Waterside Mall.
At least four OSW employees have been advised by their
physicians not to return to Waterside Mall as a result of
building related illness.
Lack of adequate ventilation in the EPA building and
offgasing of chemicals from new carpet, wall board, dividers,
etc., may be resulting in relatively high levels of VOCs which
are not being effectively drawn out of office space, and once
drawn out, are being recirculated. Some employees have
apparently been sensitized .to concentrations in the air and are
now experiencing reactions to very low concentrations.
For the past two years complaints have been directed to
persons in the Occupational Health and Safety Staff (OHSS) who
are responsible for the protection of the health and safety of
EPA employees and to the Facilities Office at EPA that is
responsible for building maintenance. Both of these offices
have been unresponsive to comments and hostile to many.
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The agreement that was made on May 2, 1988, to discontinue
putting in new carpeting was a step in the right direction. It
seems fairly obvious that one of the contributing factors to
this problem is that much of Waterside Mall is improperly
ventilated, and building-related illnesses due to carpet instal-
lation have primarily taken place in locations of Waterside Mall
which have less circulation. Even though a strong correlation
exists between air circulation and illnesses related to the
renovation, the facilities office has begun to paint the walls
in many of the areas that have poor airflow. Employees have
recently complained of headaches, lightheadedness, and nausea in
newly painted areas. I would therefore suggest that all
renovation at Waterside Mall, including painting be stopped
immediately.
Another outcome of the May 2nd decision to stop laying new
carpeting was the decision to discontinue monitoring efforts
which were initiated by OSWER in an attempt to identify which
chemical(s) and concentration levels were causing employees to
become ill. I believe that monitoring efforts should be
continued whether or not carpet is being laid. Under no
circumstances should any renovation activities take place (e.g.,
carpeting or painting) in the future without monitoring before,
during, and after such activities.
Another issue which I would like to address concerns
the methodology used to monitor indoor air. On April 21,
Mark Ennen who is a private contractor "industrial hygienist"
(hired by EPA's Occupational Health and Safety Staff) set up
monitoring equipment to sample formaldehyde in Room 2817 of the
second floor mall. The monitoring was done in response to a
request that OSW had made subsequent to two severe reactions by
OSW employees to new carpeting in adjacent offices. OSW repre-
sentatives had requested that a special effort be made to air
out and monitor Room 2817. On Wednesday, April 2O, fans were
brought into Room 2817 and the ventilation system in this area
which is normally shut off after working hours was run all
night. On Thursday, April 21, formaldehyde monitoring equipment
was set up by Mark Ennen, directly below one fan in Room 2817.
I would like to point out that: (1) formaldehyde monitoring
equipment should not be set up beneath fans if accurate readings
are to be obtained, (2) such behavior hardly gives much
credibility to any industrial hygienist, and (3) a certification
program exists in the industrial hygiene profession which
generally involves a degree in industrial hygiene, at least two
years of experience in the field, and passing a rigorous
examination. Mr. Ennen, to my knowledge, is not a certified
industrial hygienist (CIH). Persons in the industrial hygiene
field who are not certified would seldom work independently
without a CIH. I am appalled that the EPA's Occupational Health
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and Safety Staff would hire an industrial hygienist who is not a
CIH to investigate this problem, which obviously has such
important consequences.
The Occupational Health and Safety Staff have acted
irresponsibly on numerous occasions. OSW employees who resided
in Room 2627 (which has been reassigned a new number and is now
2631), from December 1986 to October 1987, experienced many
health problems, especially during the time between June and
August 1987. Such health problems included laryngitis, sore
throat, persistent cough, headaches, dizzy spells, fluid in
lungs, difficulty breathing, and general fatigue. Upon calling
Tony Brown of OHSS, OSW staff were told that OHSS recognized
that an indoor air problem existed and that they were
documenting all complaints. OSW staff in Room 2627 proceeded to
document all illnesses that they believed might be related to
poor indoor air quality in this area. All complaints were first
articulated over the phone, and the written documentation was
sent directly to Tony Brown of OHSS. On November 30, 1987,
staff from OSW sent Tony Brown as well as other members of OHSS
a copy of a memo which documents apparent building related
illnesses experienced by OSW employees in Room 2627.
The result of this documentation was that no action was
taken and OHSS representatives, including Tony Brown, flatly
denied ever receiving any complaints or memo on this subject.
Hundreds of complaints have been articulated to OHSS over the
past two years regarding poor indoor air quality at Waterside
Mall. OHSS has not responded to any of these complaints until:
1) several OSW employees experienced severe reactions
to toxic chemicals which are being circulated in
the ventilation system, and
2) two articles appeared in the Washington Times which
explained the indoor air problem at Waterside Mall.
The resulting reaction by OHSS was to merely discontinue laying
new carpet at Waterside Mall "for the time being."
I believe that such irresponsible and negligent behavior on
the part of OHSS is intolerable and has caused much suffering by
EPA employees. I would suggest that the federal program office
of OSHA be called in to oversee and evaluate the competency of
OHSS to carry out their mission.
In summary, I would suggest that the following be done in
an attempt to remedy the existing indoor air problem at EPA:
1) all renovation be discontinued at Waterside Mall,
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2) air quality and quantity monitoring be continued and
standard monitoring protocol be used for all
monitoring activities, with work to be performed by an
independent party experienced in indoor air investi-
gations,
3) a certified industrial hygienist (CIH) or team of
CIHs be hired to investigate this problem,
4) the OSHA Office of Federal Agency Programs be called
in to evaluate EPA's Occupational Health and Safety
Staff,
5) immediate renovations be made in the ventilation
system along at least the 2800 corridor,
6) serious consideration be given to removal of recently,
installed carpeting, and
7) serious and immediate determination be made as to
whether certain employees are at exceptional risk
(e.g., females taking estrogen), with a corresponding
decision on whether such persons should be temporarily
excused from attendance in the Mall.
I would be pleased to provide further information as needed.
cc: Kent Anderson
Bob Dellinger
Jim O'Leary
Mike Flynn
Joanne Bahura
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
AUG 4 1988
MEMORANDUM
SUBJECT: Petition on Ventilation
FROM: Myra Cypser, OAR
Mark Ante!!, OAR /.
Vanessa Musgrave, OSWER
TO: Lee M. Thomas
Administrator
Attached is a petition to you signed by 510 I employees,
It asks you to "provide a healthy indoor environment for EPA
employees and to establish a comprehensive indoor air program
for all the Headquarters buildings that can be a model for
the entire country". Note that jq employees wrote that
they disagreed with a portion of the petition but^signed
anyway.
Employees continue to be concerned about indoor
air/ventilation issues in Headquarters buildings. We hope
that you will give this matter further attention. We would
be happy to meet with you to discuss the petition and we look
forward to seeing your response to it.
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VENTILATION
PETITION
We petition the Administrator to provide a healthy indoor environment for EPA
employees and to establish a comprehensive indoor air program for all the
Headquarters buildings that can be a model for the entire country. Specifically,
we ask the Administrator to:
Ensure comfortable temperature and
humidity levels for EPA offices.
Ensure adequate fresh air and distribu-
tion of air.
Determine what pollution sources are in
the building and monitor pollution
levels.
Remove the newly installed carpet and
find alternatives to installing more of
this problem carpet.
Help employees who have sick building
symptoms receive compensation.
Conduct an in-depth health survey to
locate employees with sick building
symptoms•
Consult with employees and keep them
informed of the Agency's progress in
addressing ventilation issues on a
regular basis.
This petition has been endorsed by the National Federation of Federal Employees.
SIGNATURE
PRINT NAME
DATE
ROOM /> COMMENTS
return to: Myra Cypser, room 320IF
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TESTMONY OF
UVELY-DCBOLD
BEFORE THE
UMTB) STATES HOUSE OF REPRESENTATIVES
OOMMffTEE ON SOBCE. SPACE. AND TECHNOLOGY
SUBCOMMITTEE ON NATURAL RESOURCES.
AGRCULTURE RESEARCH AND ENURONMENT
JULY A 1MB
ON THE
MDOOR AR QUALITY ACT OF tM» (HA. tOO)
MY NAME • BOBBC UVELY-OBOLD. I AM EMPLOYED BY THE UMTEO
STATES CNVtlONMCNTAL PROTECTION AOENCY M WASHMQTON. D.C. I AM
APPEARMQ HERE TODAY NOT ON BEHALF OF MY AOENCY. BUT BECAUSE I
AM AMONO THOSE WHOSE HEALTH AND UFE HAS BEEN RAOCALLY
AFFECTED BY THE MDOOR AR AT EPA HEADQUARTERS. MY TESTMONY
MCLUDES MTOIWATION PRESENTED BY MY """P^ff. STEVE SHAPRO,
BEFORE THE SENATE CUMMIILL ON ENVnOMMCNT AND PUBLIC WORKS
MMAY.
LONQSTANDMG PROBLEMS RELATMG TO THE AR QUALITY AT
WATERSBC MALI. EPA* CENTRAL HEADQUARTERS SITE. CAME TO A HEAD
LAST YEAR WHEN OUSTERS OF PEOPLE M SEVERAL LOCATONS WHERE
NEW CARPET HAD BEEN LAD BECAME U- WHEN TWS WAS REPORTED TO
EPA FACUTES MANAOEMENT AT THE BEQMNMQ OF IBM. NO ACTION OF
ANY TYPE WAS TAKEN TO DENTFY AND REMOVE THE SUSPECTED
SOURCES OF POLUmOM. BULDMQ RENOVATIONS CONTMUED AND
ADOmONAL EMPLOYEES BECAME 11. WTTHM ONE BRANCH •* A OMSON
OF THE OFFICE OF SOLO WASTE AND EMERGENCY RESPONSE (OSWER).
EIGHT OUT OF » PEOPLE WERE AFFECTED. FOUR HAD TO STOP
WORKMQ AT THE BULDMG AND FOUR HAD SKMnCAHT HEALTH
PROBLEMS BUT CONTMUED TO WORK MSOE. M ANOTHER OMSON OF
OSWER WITH ABOUT S2 PEOPLE, AT LEAST NME WERE AFFECTED. FIVE
SEVERELY. ONE SOMEWHAT LESS. AND AT LEAST THREE HAD SK3NFICAMT
HEALTH PROBLEMS.
BY MAY. THERE WERE SEVEN OF US M THE MALL AND EAST TOWER
AREAS WHO HAD BECOME SO SEVERELY AFFECTED THAT OUR DOCTORS
ADVSED US TO TRY TO ARRANGE WORKMO OUT OF OUR HOMES OR AT
SOME OTHER LOCATION. A LARGER GROUP OF PEOPLE WHO WERE NOT
QUITE AS SEVERELY AFFECTED STRUGGLED TO CONTMUE TO WORK
MSDE THE BUUNNG. NONE OF THE SUSPECTED SOURCES OF TMS
OUTBREAK OF ILNESS. MCLUDMG THE NEW CARPETMG. WAS EVER
REMOVED, SUBSEQUENTLY. AT LEAST SEVEN OTHERS HAVE HAD TO STOP
WORKMO AT WATERSDE.
PROGRAM MANAGERS. PEOPLE SICK FROM MDOOR AR. AND VARIOUS
HEALTH PROFESSIONALS. AND UNION OFFICIALS HAVE HAD A GENERALLY
FRUSTRATES TME QETnNQ EPA TO ACT RESPONSBLY. RESPONSMELY.
AND COMPETENTLY.
IT S WONC THAT. M RESPONSE TO PREVDUS MCOENTS OF LLNESS
RELATED TO NEW CARPET. EPA A FEW MONTHS EARUER MCLUDED M ITS
EXCELLENT MTERNAL MDOOR AR POLICY (APPENDIX Q PROVB0NS FOR
PREVENTMQ JUST SUCH AN OUTBREAK.
Ml b* v^aMd to
to to iHdeor wntetf Irrttottg to
etwr phytlnl Ms to
11
to MI i
k
out or hat
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i BEUEVE THAT r EPA? ADMBBSTRATME MANAGEMENT HAD NTIMJ.V
TAKEN THE PROBLEM SOBDUBLY AND TAKEN MMEDMTE ACTION UNDER THE
I OF IT* OWN MOOCH AM POUCY. WE COULD HAVE BEEN SPARED THE
THE OVERALL AM QUALITY PROBLEMS AT WATERSDE ARE MANY AND
EVEN WITH THE MANY RESOURCES AT ITS COMMAND. EPA HAS AT
BEST HAD A UflCULT TBB1TRYMG TO DEAL WITH THESE PROBLEMS AND WITH
; M THE 8UUWQ OVER THE PAST YEAR. WHEN EPA RECENTLY
ATTEMPTED TO CONDUCT AN AM MOMTORMQ SURVEY. THE BULDMQ OWNER
REPORTEDLY MCREASED THE VENTTLATON RATES BY A FACTOR OF TWO OR
THREE DURMO THE TBg OF THE SURVEY.
HAVE VET TO LEARN THE
BY RENOVATDNS DONE
A HALF. BUT
HEALTH HAS
OVER THE PAST YEAR
AT LEASTS
WHO HAVE LEFT EPA FOR HEALTH
FROM MDOOR AM POLLUTON
AT LEAST ELEVEN EPA EMPLOYEES WHO ARE AT HOME OR M
FMPLOYtH WHO HAVE GONE TO THE HEALTH UMT
I FROM MDOOR AM POLLUTON
19 EPA EMPLOYEES WHO RfcPOHTfcU UMESS TO THE AGENCY*
HEALTH AND SAFETY MVESTKMTOR AT THE HEIGHT OF THE
CARPET CRS0
BUT THS 6 JUST THE TV OF THE CaERO. THERE ARE THOSE
WHO ARE NOT AWARE THAT IT S THE WDOOR AM AT EPA THAT B AFFECTMQ
THEM HEALTH AND PROOUCTMTTV. THROUGHOUT THE WORK WEEK THESE
PEOPLE POP SUDAFEDS AND GO THROUGH A BOX OF KLEENEX THERE ARE A
GOOD MANY WHOSE HEALTH AND PRODUCTIVITY HAD BEEN AFFECTED FOR A
TME OR STtl. ARE AFFECTED. BUT NOT TO THE EXTENT THAT THEY WERE
COMPELLED TO STAY OUT OF WATERSDE. THERE ARE THOSE WHO HAVE LEFT
EPA WITHOUT FORMALLY REPORTMQ THAT THEY LEFT DUE TO tlNBSS. SOME
FOUND UPON LEAVMQ THE 8ULDMQ THAT THEM HEALTH PROBLEMS
D6APPEARED. AND FOR ALL THE ABOVE SITUATONS. THERE ARE NUMEROUS
CONTRACT EMPLOYEES. RETMEES WORKMQ FOR EPA THROUGH THE AMERCAN
ASSOCIATION OF RETMEO PERSONS. STAY-WSCHOOLS BOOH SCHOOL AND
COLLEGE STUDENTS). CONTRACT BULDMQ SERMCE AND SECUHfTy STAFF. AND
THE WORKERS LAYMQ THE CARPET WHO HAVE NEVER EVEN BEEN COUNTED.
THE RANGE OF BUUMNOrRELATED SYMPTOMS MCLUDES A VARCTY OF
MODERATE AND ACUTE RESPMATORY PROBLEMS; HEADACHE; SORE THROAT;
BURMNQ EYES. LUNGS. AND SKM; RASHES; FATIGUE; LARYNQmS; CLUMSMESS;
WSOWEMTATON; LOSS OF BALANCE; NAUSEA; HUMDIC.gS M EXTREMmES AND
FACE; AND DTFICULTY WITH MENTAL TASKS. REPRODUCTIVE EFFECTS ARE A
CONCERN AS WELL. THE OCCUPATONAL HEALTH PHYSCMNS SOME OF US HAVE
SEEN SAY THE MOST COMMON PROBLEMS NCLUDE UPPER AND LOWER
RESPMATORY MWTATON. NTOXICATKW-TYPE SYNDROME. OCCUPATONAL
ASTHMA. AND CHRONC HYPDViBdTMTY PNCUMONmS. THE EFFECTS ON THE
CENTRAL NERVOUS SYSTEM EXPERBNCED BY MANY OF US DONT LEND
ui
i
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THEMSELVES TO READY DIAGNOSIS. SOME OF THE PEOPLE WHO HAVE BEEN
AFFECTED, BUT NOT TO THE POMT WHERE THEY HAVE BEEN COMPELLED TO
LEAVE THE BUILDING, EITHER SEE NO PHYSICIAN AT ALL OR SEE A FAMILY
DOCTOR OR ALLERGIST WHO IS NOT FAMRJAR WITH OCCUPATIONAL OR
ENVIRONMENTAL HEALTH
SOME ARE ABLE TO FUNCTION M MOST BUILDMGS OTHER THAN
WATERSDE. SOME HAVE NO PROBLEMS VISITMG HAZARDOUS WASTE SITES FOR
A WEEK AT A TIME, BUT BECOME U. AFTER 16 MINUTES MSIDE WATERSDE.
OTHERS HAVE BECOME PROGRESSIVELY REACTIVE TO TRACE AMOUNTS OF THE
MYRIAD VOLATLE ORGANIC COMPOUNDS M OUR ENVRONMENT WHICH MOST
PEOPLE TAKE FOR GRANTED. THERE ARE THOSE WHO SUFFER WHEN EXPOSED
TO THE PRESUMED BIOLOGICAL AGENTS M THE AIR AT WATERSIDE. WHEN
EXPOSED TO AREAS THAT WERE RENOVATED OR CARPETED DURING THE LAST
FEW YEARS, OR WHEN THE VENTOTON SYSTEM B NOT OPERATING NORMALLY
OR NOT OPERATMQ AT ALL - BUT WHO RECOVER OVER TIME.
APPENDIX I CONTAMS PERSONAL MSTORES REPRESENTATIVE OF THOSE
PEOPLE WHOSE HEALTH AND LIVES HAVE BEEN AFFECTED BY THE AIR QUALITY
AT EPA HEADQUARTERS.
WHAT HAPPENED TO US
THERE ARE PEOPLE WITH
WHO MAY BE AT SPECIAL RBK TO
MDOOR AM QUALITY PROBLEMS. AND IMS RISK SHOULD BE CONSDERED M THE
FORMULATION OF MDOOR AM QUALITY STANDARDS. BUT ILLNESS FROM MDOOR
AH DOES NOT RESPECT AGE OR HEALTH. MOST OF US WHO CAN NO LONGER
WORK INSIDE WATERSIDE HAVE NOT HAD A HISTORY OF ALLERGIES. OUR
GROUP INCLUDES PEOPLE IN THEIR PRIME. IN THEM TWENTIES, EX^JOGGERS, AN
EX-MARATHON RUNNER. A KARATE BLACK BELT. AND OTHERS WHO WERE M
GOOD HEALTH BEFORE THEY WERE AFFECTED. THERE ARE MDIVDUAL
CHEMICALS OR COMBINATIONS OF CHEMICALS FOUND M OFFICES AND OFFICE
BUIDMGS • NOT ALL NECESSARILY COME FROM CARPET AND RENOVATION
MATERIALS - WHICH CAN APPARENTLY PRODUCE SHORT- AND LONG-TERM
HEALTH EFFECTS. ALTHOUGH OUR ILLNESS WAS PREVENTABLE. NONE OF US,
EXCEPT FOR SOME OF THOSE WHO HAVE BECOME U. THIS YEAH, WERE
WARNED.
WHEN YOU FIRST FEEL LL. YOU TRY TO DENY IT BECAUSE YOU DONT
WANT TO MTERRUPT YOUR WORK AND YOUR HOME UFE. YOU WONDER WHAT
KMO OF BUG YOU HAVE • SOME OF US THOUGHT WE MIGHT HAVE HAD MONO,
AIDS. OR LYME DISEASE. SOME OF THOSE AFFECTED REACHED A TURNMO
PONT WHERE THEY IMPROVED OR THEY STABILIZED TO WHERE THEY COULD
FUNCTION AT A REDUCED LEVEL MSIDE WATERSDE. OTHERS GOT WORSE.
MOST OF US WHO CAN NO LONGER GO WTO WATERSOE. HAVE NOT BECOME
LESS REACTIVE. SOME HAVE BECOME PROGRESSIVELY MORE REACTIVE. CM
6PEAKNG OF REACTIONS TO PARTS PER MILLION, BUJON. OR EVEN TRILLION OF
SUBSTANCES OR COM8MATONS OF SUBSTANCES WHERE REACTIONS ARE
NORMALLY ASSOCIATED WITH PARTS PER THOUSAND.
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HOME LIFE AND OTHER ACTIVITIES. B IT SENSIBLE TO IGNORE THE SYMPTOMS •
YOU OFTEN REACT IN BULOMQS TO THMQS YOU CAN? EVEN SMELL OR YOU
8MELL BUT DONT RECOGNIZE • AND ENDURE THE PHYSICAL MBERY AND
TEMPORARY MENTAL DYSFUNCTION? OR B IT SENSIBLE TO DROP OUT OF YOUR
LIFE AND LIVE AS A RECLUSE AT HOME OR M A REMOTE AREA TO AVOD THE
VOLATU CHEMICALS OF THE 20TH CENTURYT THERE ARE NO GOOD ANSWERS
TO TH8 DLEMMA.
SUBSEQUENT DEVELOPMENTS
WHEN THE CARPET CRISIS BROKE M MAY 1988. A DIVISION Of THE OFFICE
OF SOLID WASTE AND EMERGENCY RESPONSE HAD BEEN SCHEDULED TO MOVE
•ITO NEWLY-RENOVATED SPACE M THE MALL AREA. THE MOVE WAS HELD UP
PENDtNQ AN EPA MANAGEMENT DECISION ON THE PROBLEM BATCH OF CARPET.
THAT SUMMER. EPA'S ADMINISTRATIVE MANAGEMENT DECDED TO GO AHEAD
WITH THE OSWER MOVE ON A VOLUNTARY BASB. EMPLOYEES WERE ANXIOUS
TO LEAVE THEW LOW-CEUNO. OVERCROWDED. TEMPORARY OFFICES. THESE
TEMPORARY OFFICES HAD ASBESTOS CRUMBLING FROM THE CEUNGS AND
WERE MFESTED WITH MICE AND ROACHES. UNDER THESE CIRCUMSTANCES.
MOST ELECTED TO TAKE THE* CHANCES M THE NEWLY-CARPETED SPACE. THE
VACATED TEMPORARY WORK SPACE WAS THEN REMODELLED DURMG WORKING
HOURS M SUCH A MANNER THAT FOR SEVERAL WEEKS ASBESTOS FEU ON
EMPLOYEES REMAINING M THAT SECTION OF THE BUILDING. SEVERAL PEOPLE
BROKE OUT WITH SEVERE SWN RASHES FROM THE ADHESIVE USED IN LAYING
FLOOR TEE.
•
THE WONY THAT SERIOUS MDOOR AIR QUALITY PROBLEMS HIT EPA
HEADQUARTERS OF ALL PLACES B LOST ON FEW PEOPLE. WHAT B DOUBLY
IRONIC B THAT THERE HAVE BEEN REPEATED INDOOR AIR QUALITY PROBLEMS
EXPERIENCED WITHM THE DIVISION RESPONSBLE FOR EPA'S INTERNAL
ENVIRONMENTAL HEALTH AND SAFETY. WHEN THIS AGENCY PROGRAM MOVED
OUT OF WATERSIDE TO THE HEADQUARTERS FACILITY M THE FABCHID
BULDMO M SUMMER 1M7. SOME STAFF DEVELOPED RESPHATORY AND OTHER
PROBLEMS THEY ASSOCIATED WITH NEW CARPET IN THE BUILDMa THEN THB
PAST APRIL. THB DtVBION MOVED BACK TO WATERSIDE. AGAM INTO NEWLY-
RENOVATED SPACE. AGAIN, MANY PEOPLE IN THIS DIVISION HAVE DEVELOPED
RESPBATORY SYMPTOMS. ONE PERSON WHO HAS DEVELOPED PROBLEMS WITH
BREATHMG HAS DECIDED TO STICK FT OUT M HER NEW OFFICE. ANOTHER
PERSON WHOSE SKM BROKE OUT IN RED SPLOTCHES WHENEVER SHE ENTERED
HER DIVISION'S NEW SPACE WAS RELOCATED TO AN OFFICE REMOVED FROM
HER DIVISION. SHE HAS SINCE LEFT EPA.
M APRL IBM. EPA IMPOSED A MORATORIUM AT HEADQUARTERS ON
FURTHER LAYMG OF THE BATCH OF CARPET ASSOCIATED WITH THE OUTBREAK
OF ILLNESS. BUT THB PAST WINTER EPA STATED THAT IT WOULD MSTALL SOME
OF THE REMANING CARPET AT EPA'S LABS IN EDBON. NEW JERSEY. AND
RESEARCH TRIANGLE PARK. NORTH CAROUNA.
THIS PAST APRIL, THE BULDINO OWNER AT WATERSIDE ALLOWED
ANOTHER TENANT. THE GENERAL ACCOUNTING OFFICE. TO INSTALL NEW CARPET
BELIEVED TO EMIT *4-PC*. A STYRENE SUBSTANCE SUSPECTED IN THE OUTBREAK
OF ILLNESS AT EPA. VAPORS FROM THB CARPET GO MTO EPA'S HALLWAYS.
EMPLOYEES ARE CONCERNED. BUT EPA SAYS THB B A MATTER BEYOND ITS
JURISDICTION.
10
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VARIOUS STUDIES RELATING TO THE CARPET AND INDOOR AIR QUALITY AT
EPA HEADQUARTERS HAVE BEEN INITIATED. A MODIFICATION IS PLANNED TO
THE AM SYSTEM M THE LIBRARY AREA. ALTHOUGH EPA* OFFICE OF
ADMtnSTRATION REPORTED THAT THIS QUARTER OF A MILLION DOLLAR PROJECT
WAS DESIGNED WITHOUT CONSIDERATION OF AH QUALITY STANDARDS.
DESPITE THE POOR AW QUALITY AT WATERSIDE AND CONTINUING
INCIDENCES OF EMPLOYEES BECOMING ILL. THE OFFICE OF ADMINISTRATION
ANNOUNCED ON MAY 23 THAT BUILDING RENOVATIONS WOULD BE DONE DURING
NORMAL WORK HOURS W ORDER TO CONTAIN COSTS. EMPLOYEES WERE
MCREDULOUS. THE UNIONS RESPONDED WITH A REQUEST TO BARGAIN OVER
TWS ISSUE. THE OFFICE OF ADMMOTRATON HAS AGREED TO BARGAIN. BUT
REITERATED TWO WEEKS AGO THAT IT 8TUL PLANNED TO CONDUCT SOME
RENOVATION ACTTVmES MVOLW4Q THE RELEASE OF TOXICS DURING NORMAL
WORK HOURS.
ON JUNE 1«. THERE WAS A RELEASE OF XYLENE FUMES M THE EAST
TOWER WHEN A CONTRACTOR APPLIED A SEALANT CONTAINMG XYLENE ON THE
ROOF NEAR AN AR INTAKE DAMPEa THE OFFICE OF ADMMISTRAT1ON
REPORTED THAT SEVEN EMPLOYEES BECAME VISBLY U_ AT LEAST ONE OF
THESE PERSONS HAS HAD SERIOUS CONTINUING PROBLEMS INSIDE THE
BULDMQ EVER SINCE. STAFF FROM THE AGENCY* INTERNAL ENVIRONMENTAL
HEALTH AND SAFETY DMSION RESPONDED TO THIS MCIDENT BY GOING AROUND
THE EAST TOWER WITHOUT RESPIRATORY PROTECTION OR
SAMPUNO/ANALYTICAL EOUPMENT. SNIFFING WITH THEIR NOSES TO TRACK
DOWN THE FUMES. OTHER STAFF FROM ENVIRONMENTAL HEALTH AND SAFETY
WERE ABLE TO OBTAIN A MATERIAL SAFETY DATA SHEET WITHIN AN HOUR AND A
HALF. WHICH IDENTIFIED THE FUMES AS XYLENE. THE OFFICE OF
11
ADMINISTRATION REPORTED THAT WTTHIN FOUR HOURS IT WAS ABLE TO COME
TO A DECISION ABOUT THE XYLENE. WHICH WAS NOT TO EVACUATE THE EAST
TOWER.
A GROUP OF SERIOUSLY AFFECTED EMPLOYEES REQUESTED LAST MARCH
TO MEET WITH THE AGENCY'S TOP ADMINISTRATIVE MANAGEMENT TO DISCUSS
ENSURING COMPETENT. RESPONSIBLE. AND RESPONSIVE MANAGEMENT FOR
DEALING WTTH THE MANY PROBLEMS ARISING FROM MDOOR AIR POLLUTION AT
HEADQUARTERS. THE ADMINISTRATION NEVER RESPONDED TO THIS REQUEST.
THE PRESSING AIR QUALITY PROBLEMS AT HEADQUARTERS ARE FAR FROM
BEING MASTERED. IT WILL TAKE COMMITTED ACTION ON THE PART OF THE
ADMINISTRATION TO ENABLE THE REINTEGRATION INTO WATERSDE OF AFFECTED
EMPLOYEES WHO HAD TO STOP WORKING INSIDE THE BUILDING. LAST WEEK. WE
WROTE TO THE NEW ADMINISTRATOR ABOUT THE CONTMUMQ PROBLEMS
ARISING FROM AIR QUALITY AT HEADQUARTERS AND ASKED THAT HE DESIGNATE
A PERSON IN HB IMMEDIATE OFFICE TO TAKE CHARGE.
APPENDIX III CONTAINS A MEMORANDUM FROM WITHN EPA* INDOOR AIR I
DIVISION DOCUMENTING SOME OF THE LONGSTANDMG PROBLEMS WITH THE
HEADQUARTERS VENTILATION SYSTEM STILL AWAITING SOLUTION BY EPA*
ADMINISTRATIVE MANAGEMENT. THIS REPORT COMES OUT OF A BROADER
EFFORT TO CHARACTERIZE THE DESIGN AND OPERATIONAL PROBLEMS WITH THE
VENTILATION SYSTEM AT WATERSDE.
SOME OF THOSE MOST AFFECTED BY THESE ILLNESSES ARE AT HOME.
SOME ARE WITHOUT WORK. APPROXIMATELY TEN PEOPLE HAVE BEEN
RELOCATED SINCE NOVEMBER TO WORK SPACE M AN APARTMENT BUILDING
12
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THE LONG ROAD OF DECISION-MAKING
WHEN SOMEONE WHO WORKS AT EPA COMES TO UNDERSTAND THAT HE
OR SHE IS BECOMING ILL FROM EXPOSURE TO A CHEMICAL OR A COMBINATION
OF CHEMICALS IN THE AIR. WORKER. SUPERVISORS. MANAGEMENT. AND
TREATING PHYSICIANS MAY EMBARK ON A LONG ROAD OF DECISION-MAKING. AS
A WORKER YOU HAVE TO CHOOSE WHETHER TO TOUGH4XJT FEELMG SICK IN
THE HOPE THAT IT WILL PASS. ALTHOUGH NOT ATTENDING TO YOUR ILLNESS
MAY RESULT M WORSE ILNESS; OR TRY TO TAKE CARE OF YOURSELF.
ALTHOUGH THIS MAY RESULT IN DSRUPTIONS TO YOUR WORK AND ULTIMATELY
YOUR CAREER, YOUR ORGANIZATION. YOUR PERSONAL WELFARE. AND YOUR
FAMLYS WELFARE. A COMMON CHOICE S TO DENY THAT YOU SHOULD DO
ANYTWNQ ABOUT THE PROBLEM.
SUPERVISORS FACE ISSUES OF HOW TO KEEP A WORKER MTEGRATED IN
THE ORGANIZATION. VARIOUS SUPERVSORS HAVE SAID THEY ARE AT A LOSS
OVER WHAT TO DO WITH SOMEONE WHO IS UNABLE TO WORK AT FULL CAPACITY
OR WHO CANT COME INTO THE OFFICE. ATTEND MEETINGS. AND WORK WITH
OFFICE DOCUMENTS AND EQUIPMENT. WHAT ARE A SECRETARY AND
SUPERVISOR TO DO WHEN THE SECRETARY CANT BE M THE OFFICE TO HANDLE
PAPERWORK AND TELEPHONES AND HELP OTHERS AS NEEDED?
WHEN SOMEONE CANT BE ON LOCATION TO CONTRIBUTE TO A PROJECT.
YOU CAN TRY WAYS TO GET AROUND THIS WITH TELECOMMUNICATIONS •
SPEAKER PHONES. FAXMG. AND MODEMS - BUT OFTEN THIS IS INCONVENENT,
INEFFICIENT. D6RUPTIVE. OR UNWORKABLE.
YOU GO TO A DOCTOR FOR ADVICE AND BOTH OF YOU ARE FACED WITH A
DILEMMA: DO YOU CONTINUE AT WORK AND RISK GETTING SICKER WITH AN IL-
DEF1NED ILLNESS THAT NO ONE UNDERSTANDS? DO YOU WITHDRAW FROM THE
WORKPLACE AND STOP GOING TO OTHER PLACES WHERE LOW EXPOSURES CAN
AFFECT YOU. IN THE HOPE THAT YOU MIGHT RECOVER FROM BOTH THE EFFECTS
OF THE SICKNESS AND FROM THE GENERAL CONDITION? THERE B NO WAY TO
PREDICT WHETHER OVER TIME YOU WILL RECOVER FROM THR CONDITION. DO
YOU GIVE UP YOUR JOB TO TRY OUT ANOTHER WORKPLACE ON A GAMBLE THAT
IT TOO WONT CAUSE YOU TO BE SICK? DO YOU AVOID OOMG TO NEW PLACES
BECAUSE THE AIR MIGHT MAKE YOU SICK?
WE EXCHANGE EXPERIENCES AMONG OURSELVES ABOUT OTHER OFFICE
BULOINGS. HOTELS. STORES. MALLS. INDOOR MARKETS. SCHOOLS. DOCTOR'S
OFFICES. HOSPITALS AND CLINICS. RESTAURANTS. PLACES OF WORSHF.
GREENHOUSES. AND OTHER PLACES THAT AFFECT US TO MINIMIZE THE RUSSIAN
ROULETTE EFFECT ON US OF BREATHING INDOOR AIR THIS B SOMEWHAT
HELPFUL. BUT WE ALL DONT REACT TO THE SAME THINGS. TO THE SAME
DEGREE, OR AT THE SAME RATE. '
VD
I
OUR LIVES ARE FULL OF SURPRISES. YOU WALK INTO A PLACE YOU
THOUGHT SAFE, ONLY TO BE CAUGHT IN FUMES FROM PAINT. CLEANING AGENTS.
PERFUME. NAIL POLISH, CIGARETTE SMOKE. COMMON TOLUENE/XYLENE MAGIC
MARKERS. WHITE-OUT. NEW FURNITURE, ELECTRONIC EQUIPMENT AND JET INK
PRINTERS. PLASTIC OBJECTS. PLASTC WRAPPING, GLUE. MASTICS - THE UST
NEVER ENDS.
WHEN YOU GET A REACTION. THE EFFECTS ARE OFTEN NOT CONFINED TO
WORK. THEY CAN STAY WITH YOU FOR DAYS OR WEEKS, AFFECTtNO YOUB
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NEAR THE EAST TOWER OTHERS NAVE l£FT THE* PROGRAMS AND EVEN THEIR
CAREERS AT EPA. THOSE AFFECTED MOST SEVERELY MCLUDE SECRETARIES.
PROFESSCNAL STAFF, AND SECTION AND BRANCH CHEFS. AS A GROUP.
SUPERVISORS WHO ARE AFFECTED SEEM MOST RELUCTANT OF ALL TO BE
(DENTFIED AS HAVMQ THESE PROBLEMS. BEUEVMQ THAT THIS CAN BE HIGHLY
DETRMENTAL TO THEM CAREERS AS MANAGERS. THE PERSONAL HISTORIES IN
APPENDIX I DOCUMENT SOME OF THE TRAUMA AND TURMOL THESE UNESSES
HAVE CAUSED M OUR VOCATIONAL AND PERSONAL LIVES.
. rxprjurncKS or BOBBTK
As the result or my personal commitment to the preservation
of the natural and human environment, I identified the
Environmental Protection Agency (EPA) mm the place where my
career efforts would be most effective. To mo, employment by
EPA was not just a job out the focus of my social concern. I
pursued »y career at EPA for eleven years both In Region V in
Chicago, Illinois and at Headquarters in Washington, D.C.
Although I experienced success in achieving protection of the
environment, EPA was not successful in protecting me from in
environment. As the result of having to perform my job in
unsafe conditions, my health has been damaged, perhaps
irreparably, my career potential has been destroyed, my life
choices compressed to a very small sphere. I have been socially
isolated, my ability to earn a living taken out of my control
and I am dependent upon the decisions of the Department of Labor
for income and payment of medical expenses. By August of this
year I will no longer have a job. The Agency responsible for my
condition may choose to no longer have any obligation toward
making accommodations for my problem.
Exposures to indoor air pollution in poorly ventilated
buildings such as Waterside Hall have turned a healthy, athletic
person who jogged twenty miles a week, lifted weights and did
aerobics into a person of limited activity. I can no longer jog
due to lung pain and have difficulty breathing while doing light
exercise or when exposed to low to moderate levels of
I
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pollutants, in addition. I now react to products that are
in common use. such as cleaning supplies. perfumed products.
paints, solvents. petroleuM-based compounds, cigarettes, and
chemicals found on fabrics, such as formaldehyde. To achieve
the clean environmental conditions I require to be reasonably
comfortable and free fro* pain and reactions. I spend most of my
time in a stripped room with two air filters and limit my
excursions from home. I must wear a respirator to travel in a
car and in buildings where X cannot avoid exposures. Every trip
outside my home must be planned to avoid or limit exposures.
These trips are spaced to keep my Immune system from being
overloaded. I avoid malls and shop mostly by catalog. I have
Very little social life since restaurants, theaters, and homes of
friends often have intolerable levels of pollutants. My husband,
a PhD. physicist most do the housework and assume many of my
former responsibilities.
I have not been able to travel to see my children or to
participate in milestone occasions in their lives. My grandson
was almost two years old before X saw him. I must read the
newspaper outdoors and wash my hands after each section to
prevent becoming ill. Ml new magaslnes, books and certain
photocopied documents must be aired out to allow solvents to
off-gas before X can read them.
^*" one of the most distressing consequences of my exposure is
the change from being considered a valued, effective employee
into one that is written off as •damaged goods*. and considered
unable to "do the job", some supervisors are at a loss on how
to keep employees integrated into the organisation while others
do not even try. I face the dual problems of being unable to
find a location where I can perform a job while protecting »y
health and also finding an employer without prejudice against a
person with my health handicap.
My problems are the direct result of my exposures in EPA over
two periods. The first was on January 20. l»8i and
intermittently over the next several weeks. I experienced loss
of voice, burning of my face, difficulty breathing, dlsslnesa.
loss of memory, mental confusion, facial rashes, and loss of
ability to concentrate. Mter five weeks out of the building
most symptoms disappeared. My doctor allowed me to return to
work with the restrictions that I must be placed in an area
without on-going renovations such as painting and carpet
installation and with fresh air Intake and ventilation that
would meet standards established by the American Society of
Heating, Refrigeration and Mr Conditioning Engineers (ASHRAE).
X returned to work at the end of March. 198* and was told that
there was not an area within Waterside Mall that would meet
ASHRAE standards. X had to work in an area where the rest of my
section had been moved while our original area was remodeled.
Although my supervisor assigned me tasks out of the building
whenever possible, I again experienced reactions that escalated
in severity. Within ten days after my return to work, all my
symptoms, including neurological problems had returned. On
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RECOMMENDATIONS
THE Ml YOU AflE CONSOERMQ S A GOOD ONE. WHAT FOLLOWS ARE
RECOMMENDATIONS FOR EMPHASB OR MCLUSK3N.
MOOOR AH QUAUTY
THERE IS A NEED FOR BETTER UNDERSTANDING OF THE RANGE OF MOOOR MR
CHEMICALS THAT CAN AFFECT PEOPLE, ESPECIALLY CHEMICALS M
COMBMATONS. RATHER THAN JUST SMQLE CHEMICALS.
-.,,*.
ALGORITHMS. PEOPLE WHO RUN BULDMQS NEED TO BE TRAINED M THE
RUOMENTS OF PUBLIC HEALTH AND NEED ALQORITHMS TO EVALUATE A
BUUDMQ AND TO EVALUATE PROBLEM AREAS WITHIN A BULDING.
AIR QUALITY STANDARDS. CONSENSUS STANDARDS FOR ACCEPTABLE INDOOR
AM QUALITY. SUCH AS ASHRAE. SHOULD BE REEVALUATED TO ACCOUNT FOR
BUUMNG RENOVATIONS. CARPETING. ELECTRONIC EQUIPMENT. AND BIOLOGICAL
AGENTS; AND ADDRESS AIR QUALITY FOR ALL PERSONS • HEALTHY. SICK.
ALLERGIC. AND CHEMICALLY HYPERSENSITIVE.
BUILDUP CODES. BUUINQ CODES SHOULD BE DEVELOPED TO WTEGRATE
GOOD MOOOR AM QUALITY PRINCIPLES.
INDOOR AIR QUAUTY AUTHORITY
AN INDOOR AM QUAUTY CERTIFICATION AUTHORITY SHOULD BE CREATED. SO
THAT BUILDING BUYERS. RENTERS. OCCUPANTS. AM) VISITORS CAN HAVE
STANDARDIZED SITE-SPECIFIC INFORMATION ABOUT THE QUALITY OF AIR MSOE
PUBLIC. COMMERCIAL AND MULTI-TENANT RESIDENTIAL BULOMGS.
IDENTIFYING HAZARDS
TESTING. MANUFACTURERS OF CONSUMER PRODUCTS. SUCH AS BUILDING AND
OFFICE PRODUCTS AND COSMETICS. CONTAWMG VOLATLE ORGANIC MATERIALS.
SHOULD TEST THESE MATERIALS UNDER A PROTOCOL MCORPORATMQ WORST-
CASE CONDITIONS. SUCH AS IN AN UNVENTLATED CUBBYHOLE OFFICE. THIS
WOULD BE COMPARABLE TO THE WAY BRIDGES ARE DESIGNED. RESULTS OF
TESTS SHOULD BE ON FIE WITH EPA.
LABELLING. THE HAZARDS OF CHEMICALS USED IN BUILDING CONSTRUCTION
AND RENOVATION AND MAINTENANCE. FURNISHMGS. OFFICE EOUPMENT AND
SUPPLIES. AND PERSONAL ITEMS SUCH AS NAM. POLISH. PERFUME/COLOGNE
SHOULD BE LABELLED. PRODUCTS CONTAINING VOLATLE ORGANIC MATERIALS
AND CARCINOGENS SHOULD LABEL ALL MGREDIENTS IN ORDER OF DECREASING
CONCENTRATION. BUILDING MANAGERS. OCCUPANTS. AND VISITORS HAVE A
RIGHT. NEED. AND RESPONSIBLE TO KNOW AND ADDRESS THESE HAZARDS.
INGREDIENT USTMG SHOULD ENCOURAGE REDUCED USE OF HARMFUL
MATERIALS.
NJ
N)
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April 7, itaa a carpet was installed in an adjacent corridor and
I experienced anaphylactic shock that was more severe than In
January. I was helped out of the building and on the advice of
my doctor, have not reentered since. (Additional details of My
exposure are in Appendix X, Personal History t5.» I now have
not worked 1$ Months. Some of My symptoms cleared up after a
few Months but I began to react to Many other low level
exposures. It took Months for My lung pain and neurological
dlsorientatlon to bscoms less severe. I was without normal use
of my voice for seven Months. Extensive speech therapy helped me
to regain normal function although I lose my voice upon exposure
to various pollutant*.
I have not bean offered any hope that I will ever return to
ay former level of health. There is little medical knowledge
about the health problems resulting from Indoor air pollution.
The swin medical treatment for my condition la avoidance,
although others like myself often take multiple Medications.
Avoidance Measures to protect My health are expensive and have
varying degrees of success, for example, the existing fuel oil
furnace in My house Must be Moved outside to prevent my
recurrent reactions. It will coat at leaat seven thousand
dollars. I have spent over one thousand dollars on air filters,
none of which is covered by insurance. Although avoidance has
ita cost, the worst impact ia not financial but the loss of the
ability that Most people take for granted - that of living a
normal life. Now will I be compensated for that loas?
1 look normal. My handicap is not visible. But I am not
alone, conditions such as Mine are becoMlng all too common.
Presently, no Individual is protected froM the dangers of Indoor
air pollution. This could happen to anyone, people are being
exposed in Federal agencies as well as the private sector.
Visitors froM other countries have been affected in our
buildings. I have been contacted by people fro» all over the
country with similar problem*. I have not been able to resolve
their problems nor My own. The problem of Indoor air pollution
that has adversely affected and continues to affect Millions of
»
people requires federal action such as set forth in this bill.
Delay in ita passage and Implementation will increase the toll
on people's lives, health, careers and financial livelihood.
Delay will also increase costs to business and Industry for
health care, loss in productivity and disability payments. For
these and other reasons in the submitted testimony I support
this bill.
I
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RIGHT TO KNOW. ALL NEED TO KNOW WHICH PRODUCTS CONTAIN CHEMICALS
WHICH ALONE OR IN COMBMATON CAN MAKE PEOPLE LL SPECIAL EFFORT
SHOULD BE MADE TO DENTFY CHEMICALS OR COMBINATIONS WHICH AT VERY
LOW CONCENTRATIONS CAN PRODUCE ADVERSE HEALTH EFFECTS IN HEALTHY
PEOPLE. M CHEMICALLY HYPERSENSITIVE PEOPLE. AND IN CHILDREN. AIR
SAMPUNQ IS A POOR SOLUTION FOR EVALUATMQ THESE HAZARDS. ITS
EXPENSIVE. ITS IMPRACTICAL. AND SAMPUNQ AND ANALYTICAL METHODS FOR
MANY CHEMICALS ARE NOT AVALABLE. M ADDITION. AH SAMPUNG DOESNT
ADDRESS CHEMICALS ACTMQ M COMBMATON.
EPA SHOULD DESIGNATE PRODUCTS TO BE AVOIDED BY PEOPLE WITH CHEMICAL
SENSITIVITIES. THIS DESIGNATION SHOULD BE INCLUDED ON PRODUCT LABELS.
BUUDMG OCCUPANTS SHOULD BE GIVEN ADVANCE NOTTICATION OF PESTICIDE
USAGE.
VOLATUTY UMJT8 SHOULD BE SET FOR CONSUMER PRODUCTS USED INDOORS.
ADDITIONAL TESTMQ SHOULD BE REOUHEO FOR PRODUCTS CONTAMMG
ACUTELY TOXIC SUBSTANCES AND CARCINOGENS. JUST AS RESPONSIBLE
MANUFACTURERS ALREADY DO OUT OF UABUTY CONSOERATONS. THE
REGULATION OF THESE PRODUCTS SHOULD BE MANDATED UNDER A STATUTORY
TME SCHEDULE.
CHEMICAL HYPERSENSITIVtTY
AN INITIATIVE SHOULD BE UNDERTAKEN TO RESEARCH THE CAUSES. NATURE.
INCDENCE, TREATMENT, AND PREVENTION OF CHEMICAL HYPERSENSITIVITY.
BUILDING MANAGEMENT
AIR QUALITY ADVOCATES. PROGRAMS SHOULD BE DEVELOPED TO ESTABLISH
AH QUALITY ADVOCATES IN BULDNQS. SUCH A PERSON SHOULD HAVE
AUTHORITY TO CONTROL WHAT MATERIALS ARE INTRODUCED WTO A BULDING
BY ANYONE. INCLUDING OCCUPANTS AND V6ITORS. AND TO DIRECT REMOVAL OF
SOURCES OF POLLUTION.
OUTBREAKS OF ILLNESS. CRITERIA SHOULD BE DEVELOPED FOR AN APPROACH
TO PREVENT. MONITOR, AND DEAL WITH MODENTS OF BULDING-RELATED
SICKNESS. THB SHOULD INCLUDE MEDICAL TREATMENT. CAREER AND PERSONAL
COUNSELLMG FOR VICTIMS; AND CRITERIA UNDER WHICH BULDMQ OWNERS
SHOULD BE REQUIRED TO RESPOND TO PROTECT PEOPLE'S HEALTH
CRIMINAL PENALTE8 SHOULD BE MPOSED WHEN NEGLIGENT OPERATION OF A
BULDNQ RESULTS M SERIOUS BUILDING-RELATED &UNESS.
HELPING VICTIMS
l
to
A FEDERAL PROGRAM SHOULD BE ESTABLISHED TO ADDRESS THE PERSONAL
CONDITION OF THOSE WHO BECOME SICK FROM MDOOR AH. SOME MAY BE IN
17
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A POSITION tO O6T COMPENSATION, OTHERS NOT. WHO SHOULD PAY FOR
LOSSES OF INCOME AND OTHER EXPENSES AND HOW « ONE TO RECOVER
THESE LOSSES?
SPECIAL ADVOCACY. MEDICAL TREATMENT. FINANCIAL ASSSTANCE. AND
VOCATIONAL REHABILITATION PROGRAMS SHOULD BE ESTABLISHED FOR
SERIOUSLY AFFECTED PEOPLE. IT WILL BE NICE TO HAVE DEFINITIVE MEDICAL
RESEARCH ON BULDM&RELATED ILLNESSES AND CHEMICAL HYPERSENSmvtTY.
BUT WE SHOULD NOT DEFER PROVKHNO HELP TO THE GROWING NUMBER WHO
ARE 8UFFERMQ FROM THESE PROBLEMS.
APPENDIX I
A BU. OF RIGHTS SHOULD BE ENACTED FOR ALL BULDMQ OCCUPANTS •
HEALTHY, ALLEROKX AND CHEMICALLY HYPERSENSITIVE.
Ul
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HISTORY II
I have been experiencing acute health effect* including eye
Irritation, headache*, eore throat, dicsineas, difficulty in
concentrating, mom* periodic breathing difficulties, occaelonal
nausea, and BOM neurological symptoms. I usually experience
these symptoms within an hour of arriving at ay work space. If I
•» able to be away fro* this space for SOB* hours, the symptoms
increasingly subside, although not totally. If I am on travel, I
do not experience these symptoms at all after I have recovered
frost being in my space. These acute symptoms first appeared
shortly after X saved to this space and have become exacerbated
since the renovation of the 8E273 suites. I have reported these
symptoms to the IPX Health Clinic.
I believe the fact that I am at greater risk than some
others in this space may potentially be because of »y current
health situation* I already have allergies to a number of
different common substances. Discussions with those employees
who are severely affected indicate that once hypersensltlsation
occurs, it could become irreversible and that the sore "minor"
symptoms precede major onsets. I have no desire to be a victim
of these larger problems.
ftlcia of Pmat MMltH Prattli
X have banoma alarmed by reports that Waterside Hall may be
a "sick building" and that the area of the Mail we occupy may be
worse than other parts of the Mall complex. X have long wondered
if the building may be the source of these problems, and if my
current problems with the area may be just an acute extension of
a problem which has been developing over the last several years,
exacerbated by the newly renovated space.
If the "sick building" theory is true, I have a deeper
concern than just myself— my son is in day care in the bottom of
'
By mid-1915 my health was deteriorating badly. I was
experiencing recurrent colds, sinus infections, coating of my
tongue, repetitive gastrointestinal difficulties, and fatigue so
severe that, even though it seemed completely impossible that I
had contracted AIDS, I had myself tested (negative result).
My health reached a nadir around early-1986. I began
visiting a HD/nutrltlonlat at that point, who suggested I be
tested for food allergies. I did ao and discovered I had become
allergic to a number of common food substances such aa wheat,
members of the nightshade family (white potatoes, bell peppers,
eggplant, tomatoes), end a number of other eubstances. My
existing but limited difficulty in processing cow's milk became
very severe, including reactions to the amount of cream
contained in the small 1/2 t 1/2 creamers used for coffee. I was
placed on and etlll observe a rigid elimination diet, avoiding
substances causing reactions. This diet has Improved my health
markedly, but I have not recovered completely, and may never.
X have else been tested for Bpeteln-Barr (low-medium
titers), and metals. I have had Heidelberg teets, have had my
blood tested for imbalances, and have undergone a number of other
tests to try to find the source of the problem—all to no evail.
I have consulted my ND/nutritionist and my doctor of
internal medicine on these matters and they both tell me I
consider the building es a possible source of these problw
(Nay 2«, 19M)
Subsequently, I was moved to several different rooms in
Waterside as EPA restored the space I wee occupying.
I moved out of Waterside in December 19M and worked at home
through February of this year. Since moving into EPA's
alternative workspace, X have experienced limited reactions to
the new workspace.
(SJ
i
X moved to 8E22« in January 1*13. In mid-June 1913 X
developed an intense irritation of the throat and began to get
recurrent sinus infections. X went to several doctors who were
unable to Identify the source of the problem, finally ending with
my current physician, who diagnosed the condition as allergic
rhinitis, gave me a Hast test to determine allergies to the local
ecology, then put me on weekly shots of allergy eerum for pollens
and inhalants. Before this time, X had never experienced any
allergic reactions to even the most univereal allergens such as
poison ivy.
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HISTORY 12
Following recarpeting at EPA, this psrson experienced
central nervous system and respiratory symptoms, including
bronchitis, burning lungs, headaches, dissiness, difficulty
concentrating, numbness, and a clinically measurable decrease in
nerve conduction velocity. Her physician told her not to reenter
waterside Hall. After leaving the building, ehe continued to
experience these symptoms when exposed to relatively low levels
of solvents such as those commonly found in office supplies,
paint, home cleaning products.
She tried working at horns, but these problems continued with
other exposnree. She interviewed for another job and did not
suffer adverse health effects in the office where she was
Interviewed. She relocated at her own expense ($4000).
Her new employer has a self-reporting disability procedure.
She reported she needed special accommodations, was provided an
air filter, and was allowed to crack open a window.
Even with these accommodations, she continued to get sick.
Near her desk were two laser printers, a copy machine, and
secretaries who used various office supplies, including whits-out
end carbonless paper. She got headaches almost everyday. There
were personal computers throughout the office. She had scute
health difficulties when copy machines wsre being repaired and
when she attended meetinge where special markers were ueed on
cbalklass boards.
After requesting furthsr accommodations, she was repeatedly
harassed by manaaement. Her supervisor told her that doctors'
lettere documenting her condition were not enough to justify
accommodations beyond the open window and air filter. The
supervisor requested shs relsass her medical records. She did
so. She now has a handicap discrimination grievance pending.
Her union has backed her up strongly.
Except Cor darmatitis, she had no previous allergies.
did not develop dermal problems at EPA. She has recently
developed various Coed allergies.
She
HISTORY |3
X left Maine and began working at EPA, waterside Mall, in
April 1986. I had last been checked for pulmonary function by
physicians in Maine. Results indicated normal range of vital
capacity and pulmonary function. Good health — ran marathons
until injured in 19S4.
I noticed respiratory problems, particularly during that
first winter, 1986-1987. Z often had flu-like problems, nasal
congestion, constant need to clear throat. Pulmonary function
tests revealed mild to moderate respiratory disease. I could not
function without Prevent11 inhaler as bronchial dilator. By that
time, Z wee working on the Sixth Floor of the Baet Tower.
During the summer of 1917 my problems worsened. Hold wee
growing on the carpet. The smell of mildew was pervasive.
Shoes and briefcase left over a weekend turned green.
I had previously had a good attendance record, seldom using
sick leavs. Z used every single day of sick leave Z had, used
annual leave, and had to borrow sick Issvs. My office mate, who
wae never sick before, was constantly sick. My branch chief, who
did not previously have headache problems, got hsadachss.
Z movsd to Crystal Hall ZZ to a stuffy interior office with
poor ventilation. Still, Z am now off Proventil except for
occasional use. Z have missed only ons day of work in nine
months, due to colds, flu. Z lost some other time for dental
surgery. Z no longer need Sudafed to sleep at nights.
I am firmly convinced that Waterside Nell damaged my health.
Tet Z am not one to complain very much and yon will not find my
name among Agency statistics.
I
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History 14
I MM employed at EM for thrtt years ind hid been In
excellent health prior to my Illness. In early December 1987, I
•oved Into newly renovated office space In EPA's third floor
•all. I Immediately sat lied a strong cheated odor that
nauseated sie. Four days later. I began experiencing syaptoas of
severe sort throat, headaches, nausea, and burning eyes while In
•y offlco. These symptoms would decrease overnight but would
reappear when I returned to the office the next day. Within a
few weeks. I was also experiencing facial burning, extreme
fatigue, coughing and chest pains, a chemical smell and taste In
•y nose and Mouth, and a facial rash, within the space of four
•onths. «y supervisor aioved m to throe locations within the EPA
complex to try and relievo my symptoms. I would not have any
reaction for a few days, and then the symptoms would reappear.
Hhllo this was happening at work. I was also having problems
at home. My fact burned In my kitchen, so I got rid of any
chemicals In my apartment — laundry detergent, cleaners,
ammonia, ttc. I bad the pilot lights In My gas stove turned off.
Ny In-laws Installed new carpet In their how and I could not
.enter their house for four months because I experienced the same
symptoms I had at work. I began to have symptoms while doing the
simplest things, such as reading newspapers; walking to the
grocery storet going Into a smoky restaurant. If I went on a
trip. 1 had trouble finding a hotel room where I did not react.
After five months In the EPA belldlng. I tried working
outside the building. I tried the D.C. public library next to
EPA. but they Had new rolls of carpet ready to be Installed and I
experienced the same symptoms. I tried working at several
contractor's offices, but after a few days the symptoms would
appoer.
In Hay 1981. I went to see an occupational physician.
underwent some pulmonary tests, and was diagnosed as having
developed a syndrome of asthmatic bronchitis and upper
respiratory Irritation secondary to exposures to emissions from
renovation and primarily from the new carpet applied at EPA. Ny
doctor recommended that I leave the source of contamination (the
EPA building) and take steroid Inhalants to see If the asthmatic
bronchitis would Improve. I was out of work for four months
during the summer.
After I left EPA. I tried to work at home and had my work
files moved there, but I reacted to whatever small amount of
chemical was still on the papers and files. I would also
experience the symptoms for no apparent reason: once a group of
sick EPA employees met with a Department of labor staffer In the
park next to the ftussell Senate Office Building. After an hour I
started experiencing all my symptoms. I never did find the
cause, but my fact broke out In welts and burned so badly that I
had to apply Ice packs to relieve the pain.
I eventually found another Federal job In the fall of 1988.
I had to spend two weeks there to see If I would react to the
building before accepting the position. I continued to be aore
sensitive to exposure to Irritants, such as cigarette saoke. but
by using an air filter I was able to reduce the level of ay
syaptoas. By late fall, all of my syaptoas had gradually
diminished at work. However. In April 1989. I was aoved to a
baseaent office which Is located above the garage. The second
day In the office I swelled car exhtust and within alnutes was
experiencing facial burning. Since that exposure 1 have again
becoae Increasingly sensitive to exposure to Irritants, so that 1
cannot read the newspaper without my face and eyes burning. 1
recently purchased a new car and I ta experiencing syaptoas of
eye end facial burning whenever I aa In It.
The point of ay testimony Is to get across the fact that my
life was -- and continues to be — drastically altered as a
result of exposure to a chealcal or pollutant In the EPA
building. Activities that I once took for granted, such as
reading the newspaper, were curtailed. Ny life becaae very
clrcuascrlbed during the sumer and fall of 1988 while I was
recovering. That suaaer the facial burning, coughing and chest
pain were so severe that I was afraid to go places for feer I
would react to soaethlng -- soaethlng I often could not even
saell. Ny doctor advised ae not to go outside If the air
quality Index was high because the otone and other pollutants
would affect me. That summer we had continuous weeks of poor air
quality, so I had to stay Inside my apartment during those days
when the AQI was over 100.
I became extremely depressed about my condition. It seeaed
so hopeless and no one had any answers. Mhlle my supervisor was
very supportive and sympathetic, there was little she could do
except move me from office to office. Ny doctor could only
advise ae to leave my Job at EPA and see If I would recover. I
began worrying about the long-term health effects. I felt my
life was completely out of control and 1 Just did not know what
to do. I eventually went to see a psychotherapist to help me
deal, on a rational basis, with what was happening to me.
I think this Is probably the most traumatic thing that I
have ever experienced In my 38 years. While my Worker's
Compensation ctala was eventually accepted, and I aa grateful to
have received soae monetary compensation. I wonder If I will ever
regain my health. Based on my experience. 1 believe there really
is nothing that can be done to help someone after exposure to
chemicals or Irritants. So the only solution is to prevent the
exposure. Anything that Congress con do to ensure that office
workers have a safe and healthy workplace will be gratefully
received.
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HISTORY 15
I am 52 yeare old. t have b«an employed by the Federal
government for twelve and one-half yaara and (or U.S. EPA for
eleven of these year*. I have both regional experience (Region
V, Chicago) and EPA Headquarter* experience (Superfund Program
alnce October UBS). Z have a history of high work ratings and
an outstanding work record.
On January 20, 19Ǥ, I sntersd my office at 7 a.m. and
noticed a atrong acrid smell fro* the carpet that had been
Installed with adhsslv* the previous afternoon. Within fifteen
minutes, my eyes, face, ear canals, and lungs ware burning. My
vole* became hoarse and disappeared and I had great difficulty
breathing. Z was disoriented and dizzy. My eyes and noae were
running. X found later I had gone into anaphylactic shock. I
left the building and stayed away for a number of days until I
felt somewhat better. My doctor said that I had a severe
allergic-type reaction to the carpet fumea.
Open my return Z was moved to two other spaces (the eub-
basement and an area that waa carpeted three months previously).
Z continued to become sicker and react more strongly everyday. I
could not remember things, z could not concentrate, and X had
other symptoms of neurological problems. Z was in sever* pain.
Z continued to be unable to talk after being in the building. On
the advice of my doctor, Z left the building for five to six
weeks until Z recovered. My doctor only allowed me to return to
work if Z was placed in an area without ongoing renovation that
was determined, to have fresh sir Intake, and ventilation
according to existing ASHRAE standards.
Z returned to work at the end of March and waa told by both
my supervisor and • contractor with EPA'a Health end safety
Office that there wasn't anywhere in the building that could meet
ASHRAE standards. My supervisor told me Z would have to work
where the rest of My section had been moved while our old work
area was renovated. Z experienced reaction* that continued and
became more severe from morning to afternoon and from Monday to
Friday. The ventilation in the area was poor. All my symptoms
war* documented on a daily basis by EPA's Health Unit. Within
ten days of my return to work (most of the day would be spsnt
outside), my symptoms were unbearable and neurological problema
returned. On April 7, 19S«, new carpet was Installed in a nearby
area. Z went into anaphylactic shock even more severe than 1
experienced on January 20 and was helped out of the building, on
edvlc* of my doctor, Z have not reentered it since.
Zt took months for my lung pain and neurological
disorlentatlon to become less severs. Z waa without normal use
of my vole* for eeven months (extensive speech therapy helped it
recover), although Z lose it upon exposure to indoor pollution.
Z became reactive to other compounds and chemicals, paints.
solvents of all kinds, gasollns fumes, fuel oil, perfumes in all
products, cleaning compounds, cigarette smoke, most indoor
environments, etc. I am limited on where 1 can go and must wear
a respirator to ride in a car.
Prior to ay exposure at EPA, I had problems with cigarette
smoke, but wao otherwise healthy. I jogged approximately 4 1/2
miles four or five times a week, lifted weights, did aerobics,
and had good lung capacity. I cannot jog now, due to severe lung
pains. I have been rushed to a hospital when exposed to paint
fumea, due to inability to breathe.
I have been on leave without pay and had no Income for ssven
months. Since then, I have gotten workers compensation. Other
EPA employees who were directed by their doctor not to enter
Waterside were allowed to work at home or eleewhere, but I was
not. The alternative work apace recently acquired by EPA has a
whole-building ventilation systsm where palnte and solvsnts
reoirculate and cause me to react again. After my leave without
pay ends in August, EPA has no obligation toward me and Z will
not have a job.
On* time, Z tried to find a job elsewhere, but no on* would
hire me due to my health problems. There is a high probability
that I will be unable to find an office in which Z could work
without damaging my health.
Z have 21 years of education. Z have invested thousands of
dollars in my education, as has EPA. My career, my private life,
and that of my family have been Irreversibly affected. My health
and my income are tenuous. X am at risk whenever Z leave my
houae. Due to Indoor air pollution at EPA, my lit* is no longer
within my control or what it should be at this stags of my lif*.
to
<£>
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HISTORY |«
During Spring 1988 whan my office on the Ninth Floor of the
Eaat Tower was recarpeted, S developed Irritating symptoms which
laated four to six months. These included dry throat and Itchy
eyes. I was unable to alt at »y desk for long. I had h«adach«a
and troubla concentrating. I want to tha Library for fraah air,
but found tba air thara avan woraa.
I atlll find tha building Irritating, but no longar hava
thaaa symptoms.
BISTORT 17
Z am a vary aanaltlva parson to bagln with. In Nay 1988 I
want to a parson's offlca In tha basement of tha Kaat Towar to
glva raaaarch aaslstanca. Tha offlea had baan earpatad In
January. Mithln minutes, hives startad to braak out on »y
f Ingara and an.
X aakad him, "Do you hava a eat?"
•Ho."
•Havei you baan in someone's houaa who has?"
Some paopla raaot
Tba hives want away in a ooupla of hours.
Around this time X attandad a meeting In tha Fifth Floor
East Towar Conference ROOM. Tha naw turnitura thara gave off a
•new" small. I want in tha room perfectly normal. Within 13
•Inutas X lost my voice and startad coughing. X couldn't stop
coughing and bad to laava.
HISTORY |8
Whan my work araa was racarpatad in aarly 1988 X experienced
aavara headache, body waaknass and pain, and aya and throat
irritation. My symptoms ara spaciflc to Wataralda Mall.
This paat wintar X hava baan working in tha altarnativa work
apaca. X am abla to go to hazardous waata facllitias with no
affact. X hava no ganaral ehamical hyparsansitivlty.
HISTORY |9
At 4:30 P.M. on Friday. April 22, 1988, EPA raaovad tha old
ruga from my offlca 932B In tha Eaat Towar and replaced tham with
naw onaa. Tha antira half of tha 9th floor had Ita ruga raplacad
with naw onaa. I obaarvad tha procaaa whlla I waa packing my
offica ao that tha workman could mova my offlca and paraonal
balonglnga.
I raturoad to work at 6 A.M. on tha following Monday. X had
auatainad a vary aavara haadacha by 3s30 and want homa. Tha
haadacha amalloratad ovar tha avanlng. I want to work at 6 A.M.
on Tuaaday and by noon tha haadacha had raturnad, my throat had
swelled, I had difficulty braathlng and waa diixy and llght-
haadad. I had ahortnaaa of braath, my voica bacama hoaraa and my
ayaa wara rad and Irritated. I lost my atamlna to work for
parloda of graatar than ona to two houra at a tlma. On April
26th I waa raaaslgnad to tha library to work, similar problama
davalopad, so I attamptad to work in tha baaamant of tha Baat
Towar, far ramovad from tha araaa being earpatad. I bacama
prograssivaly woraa in that araa. It turned out that tha
baaamant araa had baan racarpatad a faw months aarliar.
I waa exposed onca again on May 15th whan my auparvisor
against my doctor's explicit Instructions required that I meat
him in an offlca that had recently been carpeted. After 20
mlnutaa of exposure, my lunge felt aa If they ware on fira, my
ahortnaaa of braath bacama acute, my hoaraanaaa worsened markedly
ao that my voica became unrecognisable and X waa not abla to
carry on conversations for more than 30 minutes. X baoama light-
headed and confused.
On or about June 20th at tha insistence of my auparvisor, I
attamptad to work in tha public library. Southwest Branch, next
to EPA. Aftar about 10 minutes, I had shortness of breath,
tightness in my cheat, hoarseness, confusion, headaoha. X looked
around tha library and found at leaat six new rolls of carpet. I
aakad my auparvisor if he waa aware of tha carpet in the library
and ha said that, yes, he had observed them earlier before he
suggested that X attempt to work there.
After that I remained at home working on aeaignments.and
turning them in to branch chiefs In my office. My stamina has
not returned. My hoarseness, though better, returns from time to
time. If I become exposed to any new or fairly new carpet my
aymptoma return Immediately. I cannot go into buildings without
wondering If X will become 111. Tha Fairchild building had
carpets laid in the hallways and corridors and that made me ill.
Tha EPA offices in Crystal Mall 12 had carpets Installed on a
different floor from where I waa at a two hour meeting and I
became ill. I entered a newly-constructed building to pick up a
letter and remained for leas than ten minutes and became ill.
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HISTORY 110
Z have worked without Incident at Mater side Mall for
several yeara. About 3 months ago, I vae suddenly afflicted with
irritation of the optical and respiratory mucosa. My eymptoae
appear only in the building In which X work, and are apparently
due to aome-environmental agent In the building air. Over a
period of two' montha, the eyaptoma progreaaively woraaned until
episodes of acute ahortneaa of breath and prolonged eye
irritation occurred. Vialta to a aeriea of phyaiciana and
nuBaroua expensive Medical teata including lung, heart, and blood
analyaee, diacloaed only that I waa in perfect health, except for
a lung function which improved upon exposure to bronchodllator,
which la consistent with a hiatorieal aathmatie condition which
had net troubled me for many yeara.
t am senior level non-Managerial ataff, a respected expert
in my field, conaultad regularly by many inaide of government and
out. Suddenly, X can no longer enter »y office without
debilitating eymptoms. My management, upon recommendation of
ita occupational health phyaician, brought in to treat workers
with indoor air coaplainta, haa generously provided alternative
workspace) in a nearby building. The air in thia alternative
building, however, which alao haa a forced-air ventilation ayatem
in addition to operable windows, also caused irritation of ay
mucoua membranae. Only after the ventilation ducta were Baa led
off and outdoor air brought in by a window fan, did the eymptome
alleviate.
At this stag*, it has been 3 montha elnce the onset of
symptoms, and X have consulted S physicians and undergone teata
in two hoapitals. Both the government and ay private physician
advlaed aw to either clean up the building or stay out of it,
that allergy injections will be of no avail. X a* faced with
the continuing prospect of Isolation from ay work group. In
addition, my auperviaor has coaplalned that ay work productivity
haa been declining, and although he sympathicee with ay plight,
ha auggeatad that working longer houra and more attention to work
will be necessary to avoid adverse consequences such aa a
disability retirement. Vet I em fatigued from my health
problems, and have to work harder Just to maintain acceaa to
ordinary information and servicea, aa wall aa cope with setting
up a new office with leaa acceaa to the means of production than
before.
!•!•» ••! •
X face recurring, aymptoma whenever X enter the building,
isolation, job insecurity, medical billa, financial insecurity
(with children in college and a mortgage to pay), and if I should
change Jobe I have no guarantee that I will not encounter another
problem building. Moreover, changing jobs may mean I can no
longer purane my apeclaliied aree of expertise. A disability
retirement meens • vary large reduction in income. Like many
alck building victims, I face continuing stress, fatigue,
frustration, anger, isolation, fear, uncertainty, and the
prospect of being written off by my management, as well aa the
possibility of financial dlaaatar. Although thie problem haa
been cauaed by the building environment, the probability of
auccaaa of a lawsuit, given the current lack of underetandlng off
these phenomena, appeare low.
In sum. there ie clearly a need for an understanding by
management of what happena to victims of sick Building Syndrome.
some eyetem of public health training and accountability for
thoae who run buildinga, and a need for development of an
organized aupport ayatam to aid individuals handicapped by aick
building ayndrome.
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HISTORY 111
trier to March 19M X had no problema working in any
building. In early !»•• new carpet was laid in the halla on tha
Cloora wham my branch and division ara located. During lata
Nintar, building renovations, including new carpeting, occurrad
in tha balla outaida my branch*a and division's spaca. Halt my
branch moved into newly-renovated spaos in aarly April.
•time in late March 19M X began to faal occasional
•mono-Ilka" symptoms st work, which cleared up aftar work. Theaa
aymptoma worsened over time and Included headache, fatigue, head
swimming, and piquedness. By mid-April, X waa feeling sick by
midweek and would not feel better until lete Sunday. By May, tha
time during the week before the symptoms would appear became
shorter and the time away from Rsadguartare it took to feel
better became longer. By Hay, Z continued to have difficulty
concentrating, even after X would no longer otherwiae faal sick.
X triad working in the Neat Tower, limiting my travel to
other parta of the building; but X experienced reactions within a
day and a half. Upon medical advice and with my management's
support, Z started working at home in mid-May.
Zn August, X was stationed at tha office of a subcontractor.
X experienced mild to moderate effects from the building within a
half hour to 45 minutes, but since my symptoms didn't usually get
worse, X was hopeful that this arrangement would work out. Major
renovations began on the building in October, although not on my
floor. X started getting sicker and sicker.
With the support of my program management and tha office of
EPA's Assistant Administrator for Administration and Resources
Management, I started working in Cryatal Hall 12. Typically, Z
get mild to moderate reactions to the building after a half hour
to 45 minutes. These get much worse during building sctivitlss,
such aa painting, work above drop ceilings, and when people use
jet-ink printers, markers, nail polish remover, and yellow
highlighter.
Z want to continue working for EPA, even though Z never know
what surprise is next in store. EPA's facilities coordinator at
thia building is sympathetic and cooperative. Ma haa triad to
alert me to various activities going on in the building, but his
jurisdiction is limited.
Zn my branch here at Cryatal, when new furniture, which had
been on order for over a year, arrived, Z became very ill and
continued to react for a month whenever Z went into my branch
chief's office. When Z hava gone to the chopping and dining area
underneath my office building, 1 have on occaalon gotten ill from
emissions into the open sreaa from the continual store
renovations and from other activities, such aa gluing at a ahoa
repair shop.
1 hava had to change how 1 go about things at work and away
from work sines laat May. Short exposures from seconds to
minutes can make ma very ill for hours, days, and even a week at
a time.
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HISTORY 112
One day in Ifil, I got eft the elevator on the Third Floor
of tha Bast Tower at Waterside Hall. Maw carpet had just bean
inatallad. My eyes atartad burning and tearing and got acratehy
and red; ay throat and lunge atartad burning; and Z became abort
of breath. I wee alok for thraa waeka.
Most of ay diviaion vaa away at a retreat, but one other
pereon did gat aick with chaalcal bronchitla. Thia paraon waa
•ick for two and one-half waaka. She continuaa to tbia day to
react with burning eyas in fabric atoraa and aha can't atand the
smell in the*. Mian aha goea into carpet atoraa, aha flnda the
avail ao noxious that aba gats physically ill.
My division ordered teata of the carpet at an EPA teat
facility. They dateralned that the glue for the carpet waa
involved. It contained pantaehlorophanol and other volatile
organic chemicals. Pantaehlorophanol is a aanaitising agent and
• auapected oncogen (cauaaa tumors) and fstotoxin (harss
fatuaaa).
Several wosan in our division ware pregnant at the time.
The other woman who got sick finally bad to revert to
Congressional preaaure to gat EPA to stop using this glue.
Except for some allergiea, acme sinus trouble, and broken
bones, X had not been sick before. Since this exposure, z have
had a lot of trouble getting rid of oolda and have had pnausonia
thraa times sines itSl. Since MSI, 2 react to apraying, new
carpet, and heavy perfume - and Z love perfume - with wheeling,
burning eyas, dliiineaa and nausea, z have lost parhapa two to
thro* smiths work sines l»sl baoauaa of this. Before thla, Z
used vary little sick leave.
HISTORY 113
In late October 1986, new carpeting waa inatallad in all of
the officea in ay dlvlaion in the West Tower. During the firat
two weeka after Installation, one* I had been In the office for
an hour, I would experience eye Irritation, aora throat, aching
lunge, haadachaa, and nauaaa. Thus* aymptoms ceaaed within an
hour of leaving the immediate office area. Aa time want by, ay
aenaltivity incraaaed, ao that Z could not apend acre than 15
•inutea In a newly carpeted area without reacting, and the degree
of reaction increaeed. Shaxpooing the carpeta helped somewhat,
but not enough for ae to be able to etay in the office. My
auparviaora ware extremely helpful and arranged alternative work
apace for ma. Becauaa of ay continued aenaitlvity to the
oarpata, Z was not able to return to ay office for three montha.
Since thia incident, my aenaitlvity to new carpeting haa
regained high, and I aa unable to spend core than a few alnutaa
in a newly carpeted area without aerioua dlecoafort.
Hare is how EPA"a admlnlatratlva management handled thia
situationt
On October 29, 1986, Z apoka on the telephone with a
repreaantative of EPA'a Office of Occupational Safety and Health
(OSH) about the problem Z was having with the carpet. He aaid ha
waa looking into keeping the ventilation daapara open at night
and would look into cleaning the carpata to el initiate odora. Re
referred aa to hia office's industrial hygianiat.
Z notified a union repraaentativa of the problaa aomatima
in November 19B6. she accoapanied M to a Meting with the
Industrial hygleniat of OSH on Hovaaber 17th. The industrial
hygianiat gave ua coplea of the indoor air quality readinga done
for Waterside Mall by a lab at FTP, Morth Carolina, aa well aa
material aafety data ahaete on the carpeta. She told ua that the
Agency had switched froa glue to padding in carpet inatallationa
in the early 1980's, but had recently returned to using glue.
The union representative told the induatrial hygleniat that aha
would like to aaa the Agency do a health aurvay to determine if
Indoor air quality waa causing employee health problama.
On November 1*, 1986, my Dlvlaion Director called EPA'a
Director of OSH to discuss the problem. The Director of
Occupational Health and Safety aaid ha thought the problems ware
cauaed by phenolic aolvents and formaldehyde, and that these
aubatancaa ahould finiah offgaaaing after about 2 waekei the
problems cauaad by thia offgaaaing ware worse if gluing waa not
"done right.* He aaid that if there waa adequate ventilation in
araaa where new carpata ware inatallad, there ahouldn't be a
problem with them.
u>
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•istory (19
Prior to 11 Inaaa
I mm 26 ysare eld. I have a BA in Reclamation and Spanish
from Frostburoj State University and • Master of Environmental
8tudl«> fro* ¥•!• University. I began working at EPA in July
1917. X anjoyed my work very audit it wae challenging and
interesting. Z had a great deal of responsibility and found that
rewarding. Z was also fortunate enough to work with people
whose coapany Z enjoyed. Thinking about »y future was exciting.
Z wae also very active, had a great social life and excellent
health.
The doctor referred •• to an Occupational Health Specialist
who advised M not to return to Waterside Mall until the
•environment is more clearly defined." That was just the
beginning of my visits to doctors and my sedlcal bills. I've
s«an other Occupational Health specialists, an allergist, a
gynecologist, a neurologist, my general practitioner, and a
clinical ecologlet. I have alao researched this Medical problem
extensively and discussed it with many people. The diagnosis? I
have multiple chemical sensitivities reaulting from an exposure
to something at work. The treatment? Avoid the source of the
problem and other irritants. There le not much else I can do,
except eliminate ae many eourcee of irritation ae poeeible.
•hen 1 Became 111
Zn February and March !»••, Z started to experience health
problems, such as unusual fatigue, emenorrhea, abnormal acne,
nausea, headache, burning eyee, runny nose, sore throat,
diarrhea, dissiness, clumslneas, memory lapses. Irritability and
difficulty concentrating. These symptoms coincided with
progressive renovations on my floor, but Z didn't associate the
two.
My symptom* continued end Z often felt mentally dull and
overwhelmed by the type of work Z had completed eucceesfully
before. Z elso found that Z always felt better in the evenings,
in the early morning and on weekends - when I was not at work.
Me moved to a newly renovated office on Monday, March 2«.
The chemical odor was very strong end Z began to feel awful. All
my symptoms grew worse and Z became more disoriented and
confused. Z began to realise that my problems were related to
the materiale uaed in the renovations, ee with people who are
often effected by fresh paint fumee. On Friday I began to feel
worse than ever and literally could not perform my duties. That
afternoon Z ended up sitting at my dssk, eyee and noes running,
arms and legs numb, throat closing up, gasping for breath and
barely able to speak or move. Someone happened by, and I
gestured for help. Z was helped outside and we encountered my
boas, whose only question was, "Are you reacting to that stuff?"
After reaching the outdoors and alttlng for a few minutes, X
began to feel better. Over the weekend my suedes ached, Z.felt
weak, and Z slept a lot.
On Monday, my boss advised me to avoid the new office until
the fumes had dissipated. Z worked in the library and other
parts of the building, but still felt poorly; On Thursday, April
1, Z arrived at work feeling fine. Ninety minutes later Z wae
helped outside again. The nurse was summoned end told me not to
go back inside. She sent me to the hospital. Of course, by the
time Z saw a doctor, Z was feeling much better. He found nothing
wrong except that Z was slightly "out of it."
Since My Illness Began
Z have been working at home. Zn fact, I have spent the
majority of time at home. At first Z tried working in other
buildings, where we have additional offices, contractors,
training classes, etc. Z alwaye ended up reacting to something
and leaving very ill. My exposure to the renovation materials at
EPA caused ae to become sensitive, or allergic, to many other
substances, aoae of which I can identify, others Z cannot. For
example, Z cannot tolerate natural gas and 1 have to avoid all
buildings where gaa ie used so that Z don't become ill. Z have
juat purchased a home and had to renovate so that it le
completely electric. 1 feel ill at gaa stations, storea,
department stores, office buildings, others' hoses, restaurants,
malls, etc. Some placee make me react worse than others, but
there are only a few safe havens where Z can spend an entire day
without experiencing eoma adverae symptoms. Some reactlone are
caused by things like cleaning products, building materials,
carpete, paints, and finiahes and preservatives on new products.
Most buildings are ao energy-efficient that all aorta of
irritants have built up and are not dlepersed with enough fresh
air. The most frustrating reactions are those that I have in
such buildings, where I don't know exactly what la caualng the
problem, and thoee that 1 have outside, caused by construction,
exhaust, air pollution. Even my akin is sxtremely sensitive to
sunlight nowl Before this problem at EPA, I didn't even have
hayfever end my only allergy waa to poison ivy.
The Present
Now 1 apend most of my time at home. I try to uae nontoxlc
producte and avoid irritants and problem places. 1 become ill on
the Metro end on busee, and Z have no car, ao Z am reetricted by
transportation as well as by problem places. My social life is
not ss satisfying and Z do not feel as healthy aa Z uaed to. Z
also do not feel aa mentally sharp and find it difficult to
concentrate on mental tasks. My memory ie not as good.
CO
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Sometime during November, t alao »et wittl th* parson in
char?* of carpal installation in EPA'a racilitiaa office. Th«
racilitiaa pereon aaid that tha carpata wara not glued down,
•xcapt that avail amounts of glue wara baing uaad in tha
protective atrlpa underlying tha carpata in aach doorway. Ha
called tha carpat manufacturer to obtain information on tha
conatituanta in tha glua. Wa laarnad that athylana glycol and
morphollne wara in tha flu*, and that tha carpata wara rolled and
packaged whan they war* at ill wam tha manufacturer aald that
whan they wara reopened, pent-up gases might be released which
could cauaa eye irritation. Tha racilitiaa paraon had tha carpat
in my office ehaapooed in an attempt to alleviate the problem I
waa having.
HISTORY 114
My branch'a office la on tha third floor of tha Hall at
Waterside. The office waa remodelled and new carpata were
inatalled during Winter 1907-1988. Me moved back to our oftic*
in January 1988.
There waa a noticeable odor in tha office. Wa triad to vent
tha office by leaving tha corridor doora open and running fane
for a couple of weeka. Tha odor laetad for over aix montha.
Around the corner fifty yarda from our office, a aanaitive paraon
who la not in our branch had to leave her office becauae of the
amiaaiona coming from our remodelled apace.
Throughout tha flrat half of 198*, five oat of the seven
people in my branch complained of headaches and throat and ay*
irritation*.
We heard that EPA'* Facilities Management Division had *aid
that the carpat had not bean glued down because the uaa of glu*
had been discontinued for eome time, but I personally watched the
carpat being glued. The glu* had a golden to orange-brown color.
My peraonal ilineea haa continued to this day. I had no
previous health problems, except for occasional flu brought horn*
from school by my kids. Now Z catch anything that cornea by. I
have had an ear Infection, atrep throat five times, and five or
alx rounda of flu. zn between illneaaas Z run a low-grade fever
for which my doctor cannot find a cauae. Z now sweat easily,
which is awkward in a professional aatting, auch aa In meetinga.
Z walk down the hall for a drink of water and Z break out in a
aweat. When others in my office have heaters on, Z get in front
of a fan. Z feel like Z am now known aa "Mr. Sick." People are
always asking me if Z feel better.
Z have no direct information saying that my illness** are
related to my office, but tha coincidence with the timing of tha
renovation is strong.
Z have not reported my health problem* to n>A** Health Onlt
becaus* Z am uneasy about my anonymity baing preserved.
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Hy caraet baa auffarad. I •• working at ho«a. t waa dua
for a broBotlon in August 198S, but »y boM Mid that ay
•ituatlon »ada •? 1°" **• * •1«*»r """o* «•«* a. affactivaly
•t hoM •• I could at th« office. Sine* I can hardly go
anyvh.r., it's hard to find another Job. Now, whan 1 think about
•y caraar future, ifa not aitciting. it'a acary.
IIITOKT fl6
HEALTH STATUS
I have tuffercd Mjor lllncM which aty bt pcraanently debilitating,
•I • direct reiuU of carpet Instillation and construction it EM.
Since September 1988, I hive taken over $1.500.00 of prescription drug*
Including systemic and Inhaled tterlods and a natal ipray containing
a fterlod. I have experienced a variety of side effects as a result of
taking these drugs Including partial supresslon of ay adrenal systea
(no* noraal). severe respiratory systea Inflaaatlon, other severe respiratory
Insults, and possible stress to ay heart. My condition has progressed
so that I no« experience syaptoas of acute chalet) hypersensltlvlty.
Ny personal physician's diagnosis Is that I ai In a hypersensitive
allergic state.
Specific examples of ay syaptoas of chealcal hypersensltlvlty Include
respiratory tract InflaMtlon fro* exposure to volatile Missions fro»
lenlth coaputers and volatile missions fro™ other plastic products such
is the hard, saooth black plastic used In nany Radio 9iack products. I
have also stopped reading newspapers and soat other types of printed
Materials because of a reaction to the Inks. I have not experienced
syaptoas of hypersensltlvlty prior to ay exposures froa ay work environment
at the EM BitersIde Nail Coaplox.
Ny.physic Ian has reconended • aultlple aodallty treatocnt for ay
condition which Includes a three to five year series of allergic
desensltliatlon Injections. The shots are very expensive; 1 have yet
to start one especially costly series because of lack of Tunds. Additionally.
I now take tlae froa ay workday twice a week In order to take these
shots. Spending tlac during the workday to travel to the allergist's
office to receive these shots Is fapactlng ay ability to get ay job done In
a tlMly aanner.
flMAMCIAl IMPACTS
I have Incurred aedlcal bills of over 12,750.00 since Septaaber 1*88
•s a direct result of exposures In the EM Headquarters Waterside Nail Goaplei.
The outlay of thousands of dollars In aedlcal expenses has caused great
h«ra to ay financial well-being. I have been on a very tight budget and
have not been able to sustain the outlay of thousands of dollars la
aedlcal expenses.
mm DETAIL
After a Multistage negotiation. The Office of Personnel arranged •
detail for ae to the Army Niterlei Coaaand where three-fourths of ay salary
would be paid by EPA and the Aray would pay for the reaalntng quarter FTE.
This detail was on Ideal short-tora solution to the situation at EPA end
CTi
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•mild allo» me i year to tcik permanent employment elsewhere. However,
tht Department of Defense has Mde • blanket purchase of Zenith computers
to which I have an allergic reaction. Upon entering the Army office to
which I was assigned, I experienced an Immediate blockage of my ears.
foltoned by a burning throat and SMllIng of my neck. Later In the day
my lungs began to burn and tighten. The Amy management responded to my
problem by locating another office *lth a lesser number of computers, t
returned about two weeks later for a day to check out that space. The
severity of my response ««as of the sane order of Magnitude as that to
the first Any offlct. Ik* Army folks were »ery disappointed that the
detail fell through, as I was. especially after having spent many hours
over several aontbs negotiating this detail. The Army requested that I
be replaced by Mother [M person because they had structured a job
specifically far • person with • one-year tow of duty.
CAf.EE« IMPACTS
I have never boon allergic to plastics or Inks prior to my EPA
building exposures. I have bocoae chemically hypersensitive as a result
of my EPA building exposures, and my employment opportunities have become
greatly reduced because of my newly acquired, building caused, chemical
hypersenslttvlty, specifically to Missions from Materials used In Zenith
computers. The possibility of employment by the Department of Defense
Has been greatly reduced duo to their blanket purchase of Zenith computers.
tmmiTunE/iHvtsmiiT OF UNITED STATES TAI DOCIMS
The direct tnvesteent of time and money the United States Governaent
has Md* In support of my education and employment Is substantial. The
United States Navy supported a* and research for my dissertation for
three Md one-half years while I completed the requirements for My PhD.
Since receiving my PhD In OecMber of 1982 I have worked In the environmental
field for the Navy (one year} Md for EPA (five years). The United
States Government Investment In my dissertation research and employment,
using an overhead factor of 1.0, 1s over SMO.OOO.OO, not M amount to
b* taken lightly or to be thrown away.
m
The monetary costs of the potential loss of professional careers
at EPA Headquarters resulting from exposures to $300,000.00 of faulty
carpeting are clearly M order of magnitude higher than the cost of the
carpet. It is not cost effective to throw away or get rid of affected employees
and their expertise' Instead of the carpeting. Additional);, the much
discussed possibility for disability status for affected employees should
be for those Individuals Incapcttated by accident or standard Illness.
not from assult by carpet exposure. Moreover, disability was never
•cant to b* used as • surrogate for proper building operation and maintenance
or product safety liability, standards and procedures. Although Waterside
Hill exhibits characteristics of 'sick building syndrome/ the acute
and severe Illnesses experienced by EPA Headquarters employees since the
Installation of the affected carpet Implicate the carpet as a causal
ageat and Initiator af many severe health affects.
The next day, February 14, 1989, 2 returned to my HMO and
wan finally referred to an Internist. I was diagnosed aa having
an upper respiratory infection. Congestion in my left inner ear
most likely caused the vertigo episode the pravloua evening.
However, the doctor waa puzzled by my red, painful eyea.
Several x-rays of my head were taken to determine If therm might
be some congestion around my eyes that would have caused the
radnaaa and pain. Ho congestion waa found in the arena around my
eyes, i waa prescribed a decongeatant and was advised to
continue with the antlbiotica. The doctor also recommended that
I atay homo from work for the remainder of the weak. I did not
go in to work the following day.
Since I waa foaling bettor, I decided to return to work that
Thursday. Within three hours of being back in tha building, my
eyea were not only throbbing with pain but alao became awollen.
Tha severe headaches alao returned. 2 spent tha following day
aick in bad.
On March 1, 1989, I waa examined by EPA'a contract doctor
who atatad, in a lattar to my Division Director, that he found
evidence of aevera conjunctivitie and bronchltla and that my
aymptoma ware indicative of an occupationally-related medical
disorder. He alao atated in tha letter that ha waa concerned
about tha severity of my illness and •etrongly" recommended that
I be provided with alternate work space aa eoon aa possible.
Although moat of tha painful symptoms have dlmlniahed, I
occaaionally feel tha pain around my ayea and have headachae if I
atay in tha building too long. X am alao experiencing other
aymptoma, such aa tha inability to concentrate, memory loaa,
confusion and occasional difficulty in apeaklng.
Due to my •illnaam," I hava had to restrict my social lifa
curricular activltlea. Thie Included my re
I
ui
and extracurr
a board member of my State Society.
my resignation aa
Tha raquaat for alternate work apaca ia atlll being
processed. (It has bean about two months now.) At any rate, I am
actively aeeking other employment either at tha crystal City
Office of EPA or outalda of tha Agency.
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HISTORY 117
In aid-Deceaber 1911, I accepted a position with the
Environaental Protection Agency and looked forward to a new and
challenging job. To the beet of ay recollection, I do not
reaeaber ever being warned about the "sick building syndroae,"
being advlaed about eaployeea who have becoae 111 aa a result of
working in the building, or being told that new carpet Installed
In ay offlea the previous Spring had adveraely affected aoae
people.
The office in which I aa working ia located on the 2nd Floor
in Southaaat Mall at EPA Readquartera.
Whan I fIret atartad working at Wateraida in aid-January
1989, renovation activltlee were occurring in the EPA guard area
by the "Safeway" entrance. Within a week after I oeae on board,
I becaae ill with flu-like eyaptoaa which included fever, body
ache, and headaches, and had to atay hoaa for two days. Given
that thia occurred in the aiddla of winter and the "flu season,"
I did not think it waa anything unusual. However, Boat of the
eyaptoas reaainad and continued to progress. Both of ay ayea
ware blood red and painful and ay headachea were excruciating.
Aa far aa I can raaaahisr, I have never before experienced such
debilitating pain. v
On Friday, February 3, 1989, I went to see the Advice Nuree
et the HMO to which I belong. I waa given a prescription for the
treataent of conjunctivitia and was told to .return if the
abdication did not affect any laprovaaent. I waa back to aea the
Advice Nurae within four daya on February 7, 1989. I waa alao
running a low-grade fever. I waa given another aedlcatlon for ay
ayea as wall as an antibiotic.
Although I felt vary ill, I continued to coaa in to work, as
I had just atartad thia job, waa in the aiddla of training, and
felt guilty about ataylng hoaal The eyaptoas continued, and I
alao began to experience new eyaptoaa. I becaae ao congested
that I could hardly hear out of ay left ear. I alao felt
naueaated at tiaes end experienced diisinesa. There waa a
•tingling" feeling on ay acalp and aoae nuabneaa in ay eras. Not
only were ay eyea red and painful, but I alao began to sse black
apota and "waves," particularly out of ay left eye. There waa
alao a galatinoua growth on the eaae eye.
About an hour after arriving hoae froa work on February 13,
1989, I alaost fainted. Fortunately, thia did not occur while I
waa driving hoae froa work on I-6C. I recall talking to ay
aiatar about how painful ay eyea were and that the headaches just
did not aeea to dialnleh, whan the rooa I waa in suddenly
appeared to be spinning and I felt ay body going liap.
APPENDIX II
KPA'a INDOOR *ra PQLJCT
CD
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Petition to Administrator William Reilly
Indoor Air Quality at Waterside Mall
Attached is a letter to Bill Reilly expressing concerns
regarding the quality of air at Waterside Mall. The goal of
the petition is to obtain as many of the signatures of
concerned employees as possible in order to demonstrate the
breadth of this problem to Mr. Reilly.
Mulitiple copies of the petition are being circulated within
most offices of EPA. Please review the letter to Mr. Reilly
and if you support its message, please sign the petition.
Whether or not you choose to sign, please pass the petition on
to fellow employees.
The goal is to obtain all signatures by Friday, October 13,
1989. Please return all petitions to the Mr. Robert Knox of
the Human Resources Council (mail code » OS-130, room number =
2111). signed petitions will be submitted to Bill Reilly as
soon as possible.
Thank you for your interest and support for this very
important issue!
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~40~
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
The Honorable Willis* K. RtlUy
Aotaiinistrator
Environmental Protection Agency
401 H Street, S.U.
Washington, DC 20460
Dear Mr. Reilly:
The purpose of this petition is to express our concern regarding the indoor air quality at Waterside
Hall, and to encourage you to become personally involved with the expeditious resolution of this issue. Whether
the effects of the air quality in the building are real or perceived, the controversy surrounding this issue
has demoralized Agency employees and distracted them from their important mission of protecting the nation's
public health and environment. The current conditions at Waterside Hall present a confusing and ironic message
to those outside the Agency, and undercut our credibility with regard to the mission of the Agency.
Over the course of the past year, a number of EPA employees have had severe reactions to working in
the Waterside Hall complex, and as a result, these employees have been reassigned to office space outside of
the building, while difficult to prove, it is strongly suspected that these reactions have been caused by
conditions related to poor indoor air quality. There are many other employees who have experienced other less
severe reactions, such as; headaches, dizziness, respiratory irritations, including shortness of breath. In
addition to the physical problems experienced by these employees, there is added anxiety that their conditions
may worsen to the point that they too, will not be able to work in the building, and perhaps be limited in their
career paths.
In response to this issue, a number of studies have been performed to identify and resolve the air
quality problem. While study of the problem is important, it appears that some of these studies may not have
been comprehensive in nature, and may in fact have raised more questions than they answered. Additionally, the
results of some of these studies and other pertinent information have not been made available to employees at
Waterside Hall, further undercutting the confidence level of many. For example, the employees were not made
aware of the concerns and recommendations raised in the June 25, 1989, letter from Dr. Hark Bradley. There is
also concern that the Agency will continue to study the problem, and take no interim measures to ameliorate the
situation.
Indoor air quality at Waterside Mall remains a very serious issue which EPA must address. There is
little doubt that a limited number of employees have already been seriously affected, while many others are
experiencing less severe problems but are worried about future effects. In either case, the result is a less
productive and effective workforce and a dampening of our ability to attract and retain qualified personnel.
AS evidenced by numerous articles in the press, and concern expressed by Congress, the current conditions at
waterside Hall raise questions regarding our ability to fulfill EPA's mandate to protect human health and the
£nvi ronment.
We hope that this petition will demonstrate to you hou seriously the employees of Waterside Nail view
this issue. We strongly encourage you to make this issue one of your top priorities and take immediate actions
to address these problem. We regret having to bring this to your personal attention and would greatly
appreciate hearing frost you directly in the very near future.
Attachment (Petition signed by EPA Employees)
656 EPA EMPLOYEES SIGNED THIS PETITION
RJC
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UNITED STATES ENVIRONMENTAL PROTECTION Af.ENCV
WASHINGTON. D C 20460
Honorable William K. Reilly
Administrator
US Environmental Protection Agency
Dear Bill:
We are forwarding a letter initiated in OSWER and signed by 656 staff and
84 managers from several Agency organizations which seeks your immediate
assistance in remedying a wide variety of building-environment problems with
Waterside Mall. We have recently toured most of the OSWER office space on
the second and third floors of the Mall, met with employees in alternate space in
the adjacent apartment building, and conducted a meeting with all our managers
to explore the full dimensions of the problems and consider actions to rectify
them.
These meetings and our personal examination of working conditions
convince us that several employees have experienced significant health problems
for which the building environment seems to be the most likely explanation.
Many other staff have experienced less severe symptoms that may be associated
with the building and which give them concern about possible chronic or
subchronic effects. Almost all employees frequently suffer discomfort due to
fluctuations in temperature and uneven air circulation, noise, lack of natural
light, and crowding.
In addition to concerns about our employees' physical and mental well-being,
there can be no doubt that the working environment in many areas of Waterside
Mall prevents our staff from performing to their full potential and are a liability to
us in today's very competitive climate of employee recruitment and retention. As
senior managers, we are acutely aware of the size and difficulty of the job we
expect the OSWER staff to do, the climate of high expectations and controversy in
which they operate, and the potentially serious implications for our programs of
any loss in productivity. Our staff members are proud of their accomplishments,
Pruiud on Ricycbd Paptr
-------
-42-
as evidenced by the citations posted in many of their workspaces we visited, and
want to do their best for the Agency. We also sensed that many of those affected
by the working conditions have been reluctant to press their concerns on senior
managers whom they know are grappling with many difficult and controversial
issues of national importance. They don't wish to be another "problem" on our
list. But as the potential occupancy date for the new building has been pushed into
the future, the frustration with OARM and Town Center Management's efforts to
"stay even" with deteriorating conditions has grown, and concern for the well
being of colleagues seeking medical attention or alternate work space has built.
Personnel at all levels are respectfully urging us to act.
While many areas of Waterside Mall are beset with problems, we think the
conditions on the second floor and some portions of the third floor of the Mall
warrant extraordinary measures. We believe that employees in these areas should
be relocated to space of quality comparable to or better than the tower space, as
quickly as possible. The space which is vacated could be converted to conference
space, file storage, and other uses which would not require permanent occupancy.
OSWER managers and staff do not want their problems alleviated at the expense
of other agency staff.
We recognize that there will be management challenges for OSWER from
having some units in the Waterside complex and others in another facility.
However, when balanced against the health concerns and management problems
posed by existing conditions, we believe that relocation is the proper course. We
can also appreciate that there will be substantial costs and effort involved in
procuring space elsewhere and are prepared to go to great lengths to assist you
and Office of Administration and Resources Management and the General
Services Administration in resolving this difficult problem expeditiously.
We have had initial discussions of our findings with Charlie Grizzle and he
has been supportive of our request, and would like to join us in meeting with you
in the near future to discuss next steps.
Sincerely,
. Cannon Don EL Ga Christian Holmes Robert H. Wayland III
Enclosure
cc: OSWER Managers
-------
-43-
MARK E. BRADLEY. M.D., M.P.H.
OCCUPATIONAL MCDICINI
9316 FALLS BRIDGE LANE
POTOMAC MARYLAND 2O8SA
USA
I3O1I 299-8826
October 20, 1989
Dr. Rufus Morison
NFFE Local 2050
EPA UN-200
Washington, DC 20460
Dear Dr. Morison;
In this letter I am responding to five questions asked by
the Union in reference to your requested review of the Westat-EPA
Health Survey.
la. Are EPA employees in immediate health danger?
Yes. Some EPA employees are at immediate health risk,,
particularly those with respiratory illnesses. There is
strong indication that many employees have hypersensitivity
pneumonitis, occupational asthrtva and irritant-intoxication
syndromes.
b. If so, what are your recommendations?
My letter to Administrator William Reilly contains several
recommendations that directly address this question: 1)
bring in outside experts: NIOSH, Dr. Kay Kreiss and/or
university experts in occupational health to make recommen-
dations for the immediate and longer term problems, ( peer
selected occupational health experts engaged to assess the
range of problems); 2) The use of alternate workspace is not
an adequate solution to mitigate these health hazards; 3)
thoroughly clean the HVAC units, replace air ducts, relocate
air intakes away from pollution sources, increase ventila-
tion rates to ensure maximum fresh air exchange, and correct
the design deficiencies in all of the buildings and; 4)
reduce the population density in the buildings from the
present 5-6000 to the 1200 to 1500 level for which the WSM
buildings are designed. (This would be expensive but it
would solve many of the current crisis level health hazards
in the building).
2a. Do you think there will be long term health effects?
Yes.
-------
-44-
Page 2
b. What long term effects do you project from the
information from the survey?
I would project that members of the employee population
will experience in increasing numbers, restrictive
and/or obstructive lung disease, and post traumatic
stress disorders. There may well be long term effects on
other organ systems such as reproduction.
3. How do the prevalence (of symptoms) rates compare to
expected rates for putatively "healthy" work space?
The prevalence of symptoms from the survey is astonish-
ingly high. It is higher by an order of magnitude than
I expected.
4. From the study what is your view of the EPA workplace'
as to morale, motivation, productivity, etc.?
r
The EPA HQ workplace is dirty and underventilated in
places. It is overcrowded and poorly maintained. It is
surprising that the workforce is able to maintain
morale. Employees are amazingly dedicated under
extremely adverse circumstances.
5. What are the major design flaws in the study?
The study shows very little direction and focus in
terms of the design. It fails to address major areas of
long term health problems related to pollution,
ventilation, etc. It fails to address standard epidemi-
ologic questions such as morbidity (number of visits
per year to medical practitioners, hospitalizations,
etc) and mortality rates. It does not identify specific
"hot spots".
Sincerely,
Mark E. Bradley, MIX MPH
-------
-45-
11/03/89 17:07 £53819551811 JHU OCC MED
From: Linda Lee Davldoff, Ph.D,
To: Rufus Morrison, Ph.D.
fax: 382-7886
Re: EPA Employees Indoor A1r Quality Survey
1. I believe that employees at EPA are at Increased risk for
Illness. The survey suggests that many employees are already
experiencing acute effects, Including headaches, respiratory
complaints, sinus congestion, mucuous membrane Irritation, and
central nervous system dysfunctions.
My recommendations would be to remove people temporarily to a
building that 1s well ventilated while the current headquarters
are remodeled so as to greatly Increase air exchanges, vent fumes
from specifiable sources of pollution, remove sources of
pollution that cannot be vented, and adopt stringent policies to
minimize all sources of Indoor air pollution.
2. The health effects of chronic low level exposures to
pollutants are not always reversible. The data from the TEAM
study suggest that chronic exposures to low levels of VOCs
contribute to the risk of reproductive problems and cancer. Such
levels may also contribute to hypersensltlvlty disorders
Including hyperreactlve airways and an 111 defined condition,
which we ara studying, called multiple chemical sensitivity.
See recommendations under #1.
3. The data suggest that at least 1 out of every 3 workers feels
that their health 1s effected to a substantial degree by the work
environment at EPA. While I am not familiar with studies of
worker health and morale 1n "healthy work spaces," I would guess
that the rate of perceived health effects at EPA 1s very high
relative to a healthy work space.
4. The survey suggests that worries about health due to Indoor
air contaminants and Illnesses, which are perceived as work
related, contribute to missed work and to leaving work early 1n a
substantial number of employees. It 1s Ironic that the agency
that 1s supposed to be protecting the quality of the air 1s
perceived as doing the precise opposite. I would guess that
cynicism 1s high and morale low and that productivity must suffer
as a consequence.
5. Design flaws: The survey did not focus enough on health
effects, which were the ultimate topic of Interest. There should
have been 1n depth Information on Illness 1n the workers who
perceive their health to be compromised by the work place.
-------
-46-
THIS PAPER REPRESENTS THE VIEWS OP THE AUTHORS AND THE
NATIONAL FEDERATION OF FEDERAL EMPLOYEES LOCAL 2050. THIS UNION
REPRESENTS THE PROFESSIONAL EMPLOYEES AT HEADQUARTERS, U.S.
ENVIRONMENTAL PROTECTION AGENCY. THIS PAPER DOES NOT REPRESENT THE
OFFICIAL VIEWS OF THE AGENCY. THE DATA USED IN THIS PAPER WERE
GATHERED BY THE UNION AND BY STAFF SCIENTIST OF THE AGENCY DURING
AN ON-GOING INVESTIGATION OF AN OUTBREAK OF ILLNESSES AT THE
WATERSIDE MALL OFFICES OF EPA, AND WERE USED BY THE UNION IN
PURSUING REMEDIES FOR THE INJURED EMPLOYEES.
-------
-47-
CARPET/4-PHENYLCYCLOHEXENE TOXICITY:
THE EPA HEADQUARTERS CASE
Bill Hirzy, Ph.D. and Rufus Morison, Ph.D
National Federation of Federal Employees Local 2050,
Washington, DC
Introduction
This is a paper about the interfaces among science, public
policy, occupational health and labor relations.
For the past 24 months the Environmental Protection Agency
has been conducting an unusual experiment. The question under
study was: "Let's see what happens when we introduce a source of
4-phenylcyclohexene into a marginal indoor air environment in which
ca. 5000 people work for 8 to 10 hours per day. The results are
in, and we, as union officials responsible for representing the
test animals in this study, now publish the first portion of them.
In a nutshell, according to Dr. Mark Bradley, a well known
occupational physician specializing in pulmonary and immune systems
f
disorders, who was on subcontract to EPA to investigate employee
health complaints from November 1988 through April 1989, we now
have a health emergency at EPA headquarters with adverse health
effects likely in the long term among EPA employees. Based on a
health survey conducted in February. 1989, results of which will
be released in mid -November, Dr. Bradley concludes, "There is
strong indication that many employees have hypersensitivity
pneumonitis, occupational asthma and irritant-intoxication
syndromes'*.
Background
Now for the background and experimental details of the
Agency's testing of carpet safety/toxicity on its employees. A
clipping from the September 15, 1989 issue of The Washington Times.
reporting the agency's decision to start removing the carpet, is
included here to give the reader a flavor for the experimental zeal
of EPA's Environmental Health and Safety Office in the work. You
will notice in this clipping the two voices of EPA management: the
first is spoken as one might expect a potential defendant to speak,
-------
feGE B6/ FRIDAY. SF.IVF.MRER K. 1989
FEDERAL REPORT
EPA to remove troublesome carpet at Waterside
By Marie Beison
OtON !«• S
The Environmental I*roiccii
actions and inactions that have so
angered the puWic. the Congress
and EPA's own staff"
Management said il tried to re-
solve air-quality problems by spend-
ing SI 2 million on equipment over
the past four years.
EPA's Waterside Mall lease wn*
Bresler and Reiner, Inc., end* In
1992, but the General Services Ad-
ministration will most likely renew
the contract and the liea
-------
WSM 2ND FLOOR MALL
FIG. 1
935
-------
WSM 3RD FLOOR MALL
o
i
-------
-51-
"Although unable to establish a scientific link between the carpet
and employee problems, EPA decided to remove the carpeting ....";
the second is spoken as one might expect a thoughtful, observant
scientist to report interim findings of a toxicology experiment,
"The freshly manufactured carpet clearly caused the initial
illness I'm very interested in seeing if the rate of
complaints changes after removal" (of the carpet).
EXPO,sure./Health Complaint Data
Beginning in October, 1987 EPA installed at Waterside Mall
ca. 27,000 square yards of Grand Entrance III and Tuff One II,
manufactured by Ebsco Mills, Dalton GA.
Diagrams of the Waterside Mall (WSM) complex are included as
Figures l and 2 to help orient the reader and to point out the
locations where air monitoring took place. Table 1 shows the total
areas of the various sections of the WSM complex and the percent
of those areas carpeted with the material in question.
As more and more carpet was laid, more and more complaints
began to be registered by employees with their management and the
EPA Health Unit. By January 1988, several employees had suffered
severe reactions requiring hospital treatment, and EPA hired an
industrial hygienist to compile reports of complaints and assess
them. EPA also brought in its Emergency Response Team to monitor
WSM air for volatile organic compounds usually measured at Super
Fund sites, and measurement of formaldehyde levels were also made.
Presence of 4-phenylcyclohexene was not suspected at that time, and
it was not measured. (See Structure-Activity Considerations
section.)
Table 2 gives a list of symptoms most commonly reported by
employees. Hypersensitivity to a range of environmental factors
began to appear in some of the most severely affected people. A
meeting was held on April 27, 1988 at which the results of the ERT
monitoring and the industrial hygienist's analysis of complaints
were reported. The hygienist reported that some 60 or so employees
had complained of health effects ranging in severity from
irritation of eyes, nose and throat to induction of multiple
chemical sensitivity (MCS), a topic we were to learn much about
-------
-52-
TABLE 1
DISTRIBUTION OF CARPET AND EMPLOYEES
Building
Segment
East Tower
West Tower
Nall-2
Mall-3
NE Mall
SE Mall
Total Area
Sq. Ft.
240,000
220,000
150,000
150,000
132,000
48,000
Area Newly
Caroeted Sq . Ft .
56,100
41,000
29,100
11,300
16,900
33,900
Employees
945
737
490
615
536
274
-------
-53-
TABLB 2
SYMPTOMS EXPERIENCED BY EMPLOYEES
Burning Eyes
Chills
Chest Wheezing
Runny Nose
Sneezing
Cough
Fever
Chest Tightness
Hoarseness
Sore Throat
Joint Pain
Menory Difficulty
Unusual Fatigue
Nausea
Nervousness
Difficulty Concentrating
Depression
Dizziness
Ligtheadedness
Blurred or Double Vision
Nuabness
Menstrual Problems
AND
Hypersensitivity to environmental agents resulting in one or
more of the above syvptoas
-------
-54-
TABLE 3
EMPLOYEES WITH SYMPTOMS BY LOCATION
Building Percent Newly Employees in New Symptomatic Symptoms
Segment Carpeted Carpet Offices Employees Linked
toCarpet
East Tower
West Tower
Mall-2
Mall-3
NE Mall
SE Mall
23
18
19
8
13
71
220
137
95
46
68
193
16
8
is
16
13
' 10
(198)*
(103)
(98)
(135)
(70)
(96)
10
5
14
8
5
9
* Parenthetical numbers derived from February 1989 survey
(The 10/30/89 presentation did not include these parenthetical
data)
-------
-55-
over the following months. EPA contended to complaining employees
that the monitoring showed WSM air to be "as good as the air in
your living room, so what's the beef?" This management attitude
predictably precipitated a firestorm of protest, especially when
it was reported next day in The Washington Times by a reported who
attended the meeting.
The union immediately upon the conclusion of the meeting wrote
to Assistant Administrator Charles Grizzle asking for a halt in
carpet installation. This was done. However, management refused
at that time, and continued to refuse until September 14, 1989, to
remove any of the carpet in question.
In May, 1988 and again in June, August and November, air
monitoring was conducted for a range of VOCs in selected carpeted
and un-carpeted rooms. 4-Phenylcyclohexene was measured during
these sessions. These May-November measurements complemented those
taken in March, 1988 of formaldehyde levels. The formaldehyde and
4-PC results are shown in Table 4. Results for other VOCs are
shown in Table 5. (Documents from which the data in Tables 4 and
*
5 were taken are cited in the Data Sources and Pertinent Literature
Section.) The most remarkable finding was that 4-PC was the single
chemical uniquely associated with carpet in WSM, and that 4-PC was
the only chemical found whose levels declined significantly over
the period of monitoring. In essence, 4-PC was the single chemical
uniquely tied to the appearance of the illnesses that employees
reported began with installation of the carpet.
The results of 4-PC measurements showed that employees who
worked in carpeted areas were exposed to initial concentrations in
the range of ca. 1-15 ppb. This is explained in Figure 1, which
shows the levels of 4-PC in SE-226 from May through August, 1988.
Employee* generally did not re-enter carpeted space for about 7-io
days following carpet laying. SE-226 was carpeted in late April,
1988, one month prior to the monitoring. Extrapolating the decay
curve back ca. 30 days gives our estimate of the likely initial
exposure level in that room. (A pro-lection to the November level
in SE-226 is shown, derived from 4-PC measured in a nearby office
[SE-274] in November, because SE-226 was not monitored in November.
-------
0.\
-56-
F1O. 3
4-PHEKJYLCYClCmeXE.NE LEVELS
MAY
_Q
O.
O.
OTJNC 28
11
50 75" '00
£LAP5ED TIMC -f
-------
-57-
TABLE 4
FORMALDEHYDE AND 4-PC LEVELS IN SELECTED ROOMS
MAY THRU NOVEMBER 1988
Room Carpet Formaldehyde (ppb)
Laid Mav June Nov.
4-Phenylcyclohexene (ppb)
Mav June Aua. Nov.
SE-216
SE-226
SE-274
M-2710
none
4/88
4/88
none
M-2708.5 link.
M-2827
M-3304
M-3241
E-1015
E-935
* carpet
mn\ — ••«««>
3/88
none*
4/88
none
4/88
laid
JlA+'m*
NS
<4
7-49
ND-59
<4-37
ND-46
<4
6-59
<4
<4
across
»*4wl
NS
NS
NS
2.4
NS
NS
NS
NS
NS
NS
the
NS
NS
ND-20
ND
NS
ND
NS
NS
NS
NS
hall, M-3305
.04-.
3.7-6.
0.7-1.
ND
2.6-3.
0.4
0.2
1.7-1.
.03-0.
2
7
3
9
8
3
0.6-0.9
NS
0.8
NS
ND
0.6
NS
NS
ND
NS
NS
NS
0.2
NS
ND
NS
NS
NS
NS
NS
NS
NS
NS
.07
ND
NS
ND-0.1
NS
NS
NS
NS
in 3/88
NS = present, but not quantifiable
-------
-58-
TABLB 5
VOLATILE ORGANICS IN SELECTED ROOMS
Carpet - Compound in
CH,Ci, - 1.1.1-C1.C.H. _ CJL
MOV. Max MOV. May Mov.
SE-216 none .04-1.7 MS .2-6.3 MS .1-0.8 MS
SE-226 4/88 2.1-4.9 MS 1.1-5.8 MS .6 MS
SE-274 4/88 MD-1.1 .9-4.5 .5-3. .3-1.9 .3-. 5 .5-1.2
M-2710 none .3 .9-8. .3-3.3 .5-1. MD .6-1.1
M-2708.5 unk 1.9-2.1 NS .2-1. NS HQ-.2 MS
N-2827 3/88 1.2-6.3 1.5-8.9 .5-3. .3-1.7 .3-. 8 .6-. 7
M-3304 none* 1.4-2.6 NS 1.7-12 NS .3-. 8 NS
M-3241 4/88 .4-1.3 NS .3-5.1 NS .1-.2 NS
E-1015 none .3-9.1 NS .3-4. NS .1 NS
E-935 4/88 .5 NS .2-. 3 NS .02-.! NS
*Carpet laid across the hall in K-3305, 3/88
ND - not detected
NS - not sampled
NQ =• present, but not quantifiable
-------
-59-
TABLE 5 CONTINUED
_ConuDound in oob
CH..C1CH.C1
Mav
SE-216
SE-226
SE-274
ND
ND
ND
li
Nov.
NS
NS
ND-,4
CHC1CC1.
May.
ND
.1
ND-.l
Mov.
NS
NS
NQ-.3
CJI,CH,
May.
1.3-2.
4.9-11
4.3-5.9
CGI
Nov.
9 NS
NS
1.7-4.
.CC1,
May
.2-.
.6-.
3 .8
Nov.
5
9
NS
NS
ND-1
M-2710 ND ND-.6 ND ND-.3 .3-10 1.3-3 1.3-5 NQ-.4
M-2708.5 ND-NQ NS ND-.l NS 3-6.7 NS 1-5.3 NS
M-2827 ND ND-.7 ND ND-.4 .1-3.1 1.8-3 .4-.6 NQ-.9
1.2-13 NS
.1-1.5 NS
M-3304
M-3241
E-1015
E-935
ND-.l
ND
ND
ND
NS
NS
NS
NS
.03-.!
ND-.l
ND-.3
»-'
ND~
NS
NS
MS .
NS
5-8.7
.6-8.9
.7-4.7
5.7-5.8
NS
NS
NS
NS
.7-. 8
.8
NS
NS
-------
-60
TABLE S CONTINUED
XVlenaa* Stvran*
SE-216
SE-226
SE-274
M-2710
N-2708.
M-2827
N-3304
N-3241
E-1015
E-935
MAX
.9-2.5
2-2.3
2.6-3.7
2.1-3.2
5 1.3-3.4
2-4
2.6-2.7
3.1-3.5
1.4-3.2
2.4-4.2
Nov.
NS
NS
1.3-3.3
.6-1.7
NS
1.4-2
NS
NS
NS
NS
May
.2-. 9
.2-. 3
.5-. 6
.3-. 5
.2-. 5
.4
.3
.5-. 6
.1-.4
.5
Nov.
NS
NS
NQ-.3
NQ-.3
NS
ND-NQ
NS
NS
.NS
NS
Other
May
4-22
37-52
36-41
12-13
48-54
15-182
70-161
31-40
14-49
35-43
VOCB**
Mov.
NS
NS
14-52
10-38
NS
8-32
NS
NS
NS
NS
* Includes ethylbenzene
"Chiefly unspecified alkanes, alcohols, and < 5 ppb acetone
-------
-61-
FIGURE 4»
*« • • •lO.QO to 3OO.OO *'«u . >•''• o /.. lH
10001
\
OOCi-
->'/ '"
? / / S
• *
5Q
"New" Carpet
."ft
IJM .»n,i« .10.00 ca 100.00 a-.*i
TB-
hooo
a>.
hono^
1GOO
>•/
130. OJ»
..A.
>v
/y ^
/
f
f *
J t «
"Old" Carp«t
-------
-62
MILM
NH
NH.
WTOIOT
Figure 5
-------
-63-
Figure 4 shows a comparison of 4-PC levels in new vs. ca. 6-month-
old carpet.)
Structure-Activity Considerations
By April, staff of the Office of Toxic Substances (OTS) had
uncovered a 1987 submission (see Data Sources and Pertinent
Literature section) by Mark Van Ert linking 4-PC to complaints
about building environments and new carpeting and reporting limited
toxicological testing on the compound. The Agency's OTS structure-
activity team, which analyzes limited data on new chemicals
submitted under the premanuf.acture notification program of TSCA,
reviewed Van Ert's submission and literature on structural
analogues of 4-PC and its likely primary metabolite, 3,4-
epoxycyclohexyl-1-benzene. We also reviewed literature citations
from TOXLINE on cyclohexene and epoxycyclohexene, and we considered
the difference in carcinogenic potency between aniline (weak) and
4-aminobiphenyl (strong). This latter point speaks to a steric
similarity in the comparisons between cylcohexene/4-PC vs.
aniline/4-aminobiphenyl as regards reactivity toward genetic matter
and de-toxifying enzyme systems. These reviews lead us to conclude
that the likely primary metabolite of 4-PC would be expected to be
a fairly potent inhibitor of certain enzymes and to be reactive
toward DNA and\or cellular proteins.
Based on the temporal and spacial link between carpet, 4-PC
and employee illnesses, the initial 4-PC exposure levels, and
generally accepted criteria for establishing putatively "safe"
levels.for toxic agents, we propose that indoor air standards be
set for 4-PC that would protect against induction of MCS and
against acute irritancy responses. The derivation of those
recommended levels is shown below:
-------
-64-
RECOMMENDED INDOOR AIR STANDARD FOR
4-PHENYLCYCLOHEXENE
TO PROTECT AGAINST INDUCTION OP MULTIPLE CHEMICAL SENSITIVITY
Lowest Observed Effect Level = 5 ppb
Factor to derive No Observed Effect Level = 10
Factor to account for more sensitive individuals = 10
Factor to account for uncertainty re: cumulative dose effects,
actual LOEL and severity of multiple chemical sensitivity effect
= 10
DERIVED INDOOR AIR STANDARD = .005 PPB
TO PROTECT AGAINST ACUTE IRRITANCY EFFECTS
Lowest Observed Effect Level = 5 ppb
Factor to derive No Observed Effect Level » 10
Factor to account for more sensitive individuals = 10
Factor to account for uncertainty in LOEL, lesser severity of
irritancy compared to NCS - 3
DERIVED INDOOR AIR STANDARD « .017 PPB
In addition to the indoor air standard, we recommend, via a
TSCA section 21 petition that: 1) testing be required on finished
latex and carpeting to establish a product-content standard for 4-
PC that will assure compliance with the indoor air standard; 2)
quality control records be maintained and procedures put in place
to assure compliance with product-content standards; and 3)
notification be given of the risks associated with 4-PC levels
above those specified in the standards; and 4) products containing
4-PC at levels greater than the standards be re-called.
We do not content that 4-PC is the cause of every case of MCS,
nor do we contend that all carpet or all styrene-butadiene latex
is hazardous, nor that these products cannot be manufactured, sold
and used safely. We do contend that under the conditions existing
at WSM in the time period in question, exposure to 4-PC at levels
of ca. 10 ppb resulted in induction of MCS and irritancy responses
in EPA employees.
-------
-65
DATA SOURCES AND PERTINENT LITERATURE
Data :
1 . A Final Summary Report: on the Indoor Air monitoring Performed
at US EPA Headquarters, Washington, D.C. on November 6-8, 1988.
Singhvi, R. , Turpin, R.D., and Burchette, S.M. U.S. EPA, Edison,
NJ. February 17, 1989.
2. A Final Summary Report on the Indoor Air Monitoring Performed
at USEPA Headquarters, Washington, D.C. on May 24, 25 and June 29,
1988. Singhvi, R. , Turpin, R.D. and Burchette, S.M. U.S. EPA,
Edison, NJ. October 25, 1989.
3. A Final Summary Report on the Indoor Air Monitoring Performed
at USEPA Headquarters, Washington, D.C. on March 4 and 5, 1988.
Singhvi, R. , Turpin, R.D., and Burchette, S.M. U.S. EPA, Edison,
NJ. August 18, 1988.
4. An Indoor Air Quality Measurement Study at the Headquarters
Facility in Washington, DC. Highsmlth, V.R. , Rodes, C.B., Hoffman,
A. J. , and Pleil, J.D. U.S. EPA Research Triangle Park, NC. July
15, 1988.
5. Evaluation of Organic Emissions from Waterside Mall Carpets
and Office Partitions. Memorandum from Bruce A. Tichenor to David
J. Weitzman. August 25, 1988.
6. Identification and Characterization of 4-Phenylcyclohexene — An
Emission Product from New Carpeting, PYI Submission No. OTS-0288-
0596 to U.S. EPA, Washington, DC. January 8, 1987.
EPA RvnlovAA Tn^u
1. Testimony of Stave Shapiro before the U.S. Senate Committee on
Environment and Public Works, Subcommittee on Superfund, Ocean and
water Protection, on S. 657, The Indoor Air Quality Act of 1989.
2. Interview Summaries Collected by Nark Ennsn. Received by NFFB
Local 2050 from EPA Management August 18, 1988.
3. Analysis of Short Form Health Survey of NFPE Local 2050. Hirzy,
J.W. Juno 1988.
1. Report of the Ad Hoc Committee on Environmental
Hypersensitivity Disorders. Thomson, G.N., et al. Ministry of
Health, Ontario, Canada. 1985.
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2. Workers with Multiple Chemical sensitivities, occupational
Medicine, State of the Art Reviews. Vol. 2 Mark R. Cullen, Ed.
(Philadelphia, Hanley and Belfus, 1985).
3. Nervous and Immune System Disorders Linked in a Variety of
Diseases. Barnes, D.M. Science 232f 160, 1986.
4. Asthma as an Axon Reflex. Barnes, P.J. T^e Lancet 242, 1986.
5. Pavlovian Conditioning of Rat Mucosal Cells to Secrete Rat Mast
Cell Protease II. MacQueen, G., Marshall, J., Perdue, M. Siegel,
S., Bienenstock, J. Science 243 83-85, 1989.
6. Toxic Carpet II. Beebe, G. Available through Glen Beebe, c/o
Toxic Carpet, P.O. Box 399086, Cincinnati OH 45239.
Structure,— Activity Relationships; 4—PC and Cyclohexenei
The following are exemplary of 30 references cited on TOXLINE.
1. The Significance of Multiple Detoxification Pathways for
Reactive Metabolites in the Toxicity of 1,1-Dichloroethylene.
Anderson, M.E., Thomas, O.E., Gargas, M.L., Jones, R.A., Jenkins,
L.L. Toxicol Appl. Pharmacol,. 52f 422-432, 1980.
2. Excretion of Methyl Mercury in Rat Bile: the Effect of Diethyl
Maleate, Cyclohexene Oxide and Aery1amide. Refsvik, T. Acta
Pharmacol. Toxicol. 12, 135-141, 1978.
3. Isolation and Characterization of an Active DMA-Binding
Metabolite of Benzo(a)pyrene from Hamster Liver Microsomal
Incubation System. Hang, I.Y., Rasmussen, R.B., Crocker, T.T.
11, 1142-1149, 1972.
ens* o"
1. Telephone/Nail Logs of J. W. Hirzy, 1988-1989. 43 Phone calls,
4 letters involving 77 individuals self -reporting MCS, plus a
clinical psychologist reporting "many patients" presenting with
self -reported MCS.
2. Tftfl RtflgtflTi Editor: Susan Ma Hoy. P.O. Box 575, Corte Madera,
CA 94925.
3. Response* to advertisements by G. and S Beebe. See above for
contact address.
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