As a member of ACHEMMIC ( Action Committee on the Health Effects of Mold, Microbes and Indoor Contaminants) please join me in supporting this organization in their February 16, 2010 letter of appeal to the EPA and in support their efforts to protect us from indoor air pollutants. Included below are the first pages of their letter. For the remainder please see ACHEMMIC February 16, 2010 letter
TO: Lisa Jackson, EPA Administrator
David Rowson, Indoor Environments Division, EPA
Federal Interagency Committee on Indoor Air Quality (CIAQ)
CIAQ Mold Work Group
Gene Dodaro, Acting Comptroller General, GAO
Nicholas Sloss, Mold Work Group Liaison, GAO
Michael Myers, Majority Senior Adviser, Senate HELP Committee
David Bowen, Director for Health Policy, Senate HELP Committee
February 16, 2010
RE Submission of Information and Request for Action
This letter is being submitted on behalf of the Action Committee on the Health Effects of Mold, Microbes and Indoor Contaminants (ACHEMMIC), along with many other individuals and organizations concerned about the health effects of indoor contaminants.
We are writing in follow-up to the February 3 meeting of the Federal Interagency Committee on Indoor Air Quality (CIAQ). Several members of our group and other interested parties (including scientists, physicians, nonprofit leaders, IAQ experts, and community members) were waiting for the opportunity to communicate with the representatives of the federal agencies included on the CIAQ. We were expecting a report on the progress of the CIAQ Mold Work Group (MWG), and we were waiting to receive updates from our government regarding their progress on this serious public health threat.
We were not given the opportunity to speak until the end of the meeting. Some of our group members were not able to stay on the phone for three hours as we waited to be heard. When the time came for us to comment, Mr. Philip Jalbert was the only member of the CIAQ/EPA still in the room. As a result, we felt compelled to send you this letter along with the written text of the comments we had planned to make during the meeting. We would like to address several issues, including our concerns about the lack of transparency and lack of action in the name of public health. We will also discuss scientific conclusions in the peer-reviewed literature and will share key statistics. In addition, we will propose specific actions that require implementation for proper advancement of U.S. public health policy.
First and foremost, we appreciate Mr. Jalbert’s courtesy in staying through the end of the meeting and giving some of us an opportunity to comment. We also appreciate his efforts over this past year to move the discussion forward in regard to the health effects of mold and mycotoxins. Our group is taking a broader view of this issue. We will be focusing on the health effects of mold, microbes and indoor contaminants. Throughout the rest of this letter, we will be referring to those three components collectively as “indoor contaminants.”
Second, we want to express our concerns about specific issues relating to the February 3 meeting.
ACTION COMMITTEE ON THE HEALTH EFFECTS OF MOLD, MICROBES AND INDOOR CONTAMINANTS
Email: firstname.lastname@example.org | Website: achemmic.com
Distributed on February 16, 2010
Letter to Lisa Jackson, CIAQ, MWG Page 2
1. We were concerned to hear that our comments will be moved to a separate tape and will not be included with the full audiotape of the February 3 meeting. This goes against President Obama’s mandate about transparency and open government. We request that you include our comments along with the full tape of the meeting.
2. We were concerned that the agenda did not include an update from the CIAQ Mold Work Group.
3. We were concerned that certain members of the CIAQ were evasive when asked about the status of the work being done by the CIAQ Mold Work Group. Eventually, we were told that the CIAQ Mold Work Group has not met since the last meeting of the CIAQ.
4. We were concerned that the minutes of the last meeting of the CIAQ are not available. That meeting was held on October 9, 2009. We would appreciate receiving the minutes of that meeting as soon as possible.
5. Since several members of our group were not able to stay on the call for three hours as we waited to give our comments, we are submitting the written text of our comments (see attached). We request that our written comments be included as part of the public record of the February 3 meeting.
These concerns are directly connected to EPA Administrator Lisa Jackson’s memorandum to all EPA employees dated April 23, 2009. The subject of that memo is “Transparency in EPA’s Operations.” In her memo, Ms. Jackson states:
“The success of our environmental efforts depends on earning and maintaining the trust of the public we serve. The American people will not trust us to protect their health or their environment if they do not trust us to be transparent and inclusive in our decision-making. To earn this trust, we must conduct business with the public openly and fairly.”
We are very encouraged to know that the EPA has a policy and commitment to this important principle of transparency and openness.
Third, for the benefit of all recipients of this letter, we want to highlight the scope and purpose of the CIAQ and the Mold Work Group. According to the September 30, 2008 report issued by the U.S. Government Accountability Office (GAO):
“The Federal Interagency Committee on Indoor Air Quality could provide a structured mechanism for coordinating research activities on mold and other indoor air issues by, for example, serving as a forum for reviewing and prioritizing agencies' ongoing and planned research. However, it currently does not do so. Despite limitations of scientific evidence regarding a number of potential health effects of exposure to indoor mold, enough is known that federal agencies have issued guidance to the general public about health risks associated with exposure to indoor mold and how to minimize mold growth and mitigate exposure. For example, guidance issued by the Consumer Product Safety Commission, EPA, the Federal Emergency Management Agency, HHS, and HUD cites a variety of health effects of exposure to indoor mold but in some cases omits less common but serious effects. Moreover, while guidance on minimizing indoor mold growth is generally consistent, guidance on mitigating exposure to indoor mold is sometimes inconsistent about cleanup agents, protective clothing and equipment,
Letter to Lisa Jackson, CIAQ, MWG Page 3
and sensitive populations. As a result, the public may not be sufficiently advised of indoor mold's potential health risks.”
GAO Report, Recommendation #1: “The Administrator, EPA, should use the Federal Interagency Committee on Indoor Air Quality to help articulate and guide research priorities on indoor mold across relevant federal agencies, coordinate information sharing on ongoing and planned research activities among agencies, and provide information to the public on ongoing research activities to better ensure that federal research on the health effects of exposure to indoor mold is effectively addressing research needs and efficiently using scarce federal resources.”
GAO Report, Recommendation #2: “The Administrator, EPA, should use the Federal Interagency Committee on Indoor Air Quality to help relevant agencies review their existing guidance to the public on indoor mold--considering the audience and purpose of the guidance documents--to better ensure that it sufficiently alerts the public, especially vulnerable populations, about the potential adverse health effects of exposure to indoor mold and educates them on how to minimize exposure in homes. The reviews should take into account the best available information and ensure that the guidance does not conflict among agencies.”
The remainder of the letter may be seen at February 16, 2010 letter to EPA Lisa Jackson