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Dr. Claudia Miller, M.D.
December 9, 2008
To the Missouri Green Cleaning Committee:
It was brought to my attention by Ms. Sue Carroll that the Missouri Department of Elementary and Secondary Education has been tasked with developing and providing guidelines for green cleaning in schools as a result of State Legislature SB 1181. I commend you for working to protect our Nation’s most valuable resource, our children, who are especially vulnerable to toxicants as a result of their smaller size, the amount of air they breathe relative to their size, the fact that their organ systems and brains are still developing, and differences in their ability to detoxify exposures, compared to adults’ ability. Protecting children will also protect the school personnel who care for them—teachers, custodians, administrators and school staff—resulting in a better environment for both learning and working.
I am a tenured full professor and physician at the University of Texas School of Medicine at San Antonio and have published extensively on the effects of low level exposures, including indoor air contaminants, and individual differences in susceptibility. In addition, I am board-certified in Internal Medicine and Allergy/Immunology and teach Environmental and Occupational Medicine, while serving as Vice Chair for Community Medicine and Assistant Dean for our MD/MPH program. I am also founder and Director of the South Texas Environmental Education and Research (STEER) Program, which trains physicians, medical students, and other graduate-level health professions students in environmental health.
For your consideration, I am enclosing a copy of the flyer for my book (Chemical Exposures: Low Levels and High Stakes, Wiley) (1), a chapter I wrote for the leading text on indoor air (Indoor Air Quality Handbook by Spengler and Samet, McGraw-Hill) (2), and several of my papers which explain Toxicant-Induced Loss of Tolerance (TILT), a new framework for understanding how low level exposures affect people. Schools are open to a full range of community members and children—individuals whose personal susceptibilities differ by orders of magnitude. Today, substantial portions of the general population suffer from asthma, migraines, ADHD, and a host of other disorders that are associated with TILT. For this reason, it is imperative that the decision-makers involved in your legislative efforts understand this disease mechanism, a mechanism that the environmental and occupational health communities have known about for a decade. TILT develops as a result of what are called "initiating exposures," for example, exposure to pesticides, mold, volatile organic chemicals (mVOCs), or to chemicals associated with remodeling (paints, adhesives, particle board outgassing formaldehyde, etc.). Once TILT occurs in an individual, extremely low levels of everyday exposures such as cleaning agents, fragrances, white board markers, floor polish, and myriad other substances that are present in the air of most schools can "trigger" symptoms in susceptible individuals.
A number of chemicals used in cleaning schools can initiate and/or trigger TILT and the symptoms and chronic illnesses associated with it. I am particularly concerned about the use of so-called "green" cleaning products that may in fact contain fragranced materials. Fragrances are complex chemicals. Often they are used to "mask" other odors and can give the false impression that air is clean. Truly clean air has no smell. There are approximately 3000 chemicals used in the manufacture of fragrances. Most of these are synthetic and derived from petroleum, not from the flowers or spices they emulate. Most remain untested, so we lack understanding of the potential health effects for those who are exposed and may be more susceptible. One major problem is that we usually don’t know who is more susceptible until after they become sick! Potentially hazardous chemicals found in fragrance formulations include toluene, alcohols, formaldehyde, styrene, benzene, limonene, musk, and phthalates. An individual fragrance formula may contain over 100 chemicals, but their identities are protected as trade secrets, so this information does not appear on product labels. Fragrances do not have to be tested for safety before they are put on the market (3).
Exposure to fragrances can trigger asthma attacks, migraine headaches, and can aggravate sinus conditions. Those who have chemical intolerances report that fragrances can trigger irregular heartbeat, memory loss, confusion, fatigue, and neurological, vascular, and other problems according to a 1986 U.S. House of Representatives Report: "In 1986, the National Academy of Sciences targeted fragrances as one of the six categories of chemicals that should be given high priority for neurotoxicity testing. The others include insecticides, heavy metals, solvents, food additives and certain air pollutants. The report states that 95 percent of chemicals used in fragrances are synthetic compounds derived from petroleum. They include benzene derivatives, aldehydes, and many other known toxics and sensitizers, which are capable of causing cancer, birth defects, central nervous system disorders and allergic reactions."(4).
Fragrances can affect the brain and nervous system in a few seconds or over the course of a day. Some effects may appear only after repeated exposures over weeks or even years. The presence of perfume, cologne, scented cleaners and other scented products contributes to poor indoor air quality and is one of the major access barriers for Americans with health disabilities like asthma and chemical intolerance. The Operations & Maintenance Committee for the U.S. Access Board identified pesticides (indoors & outdoors), fragrances (especially fragrance-emitting devices), air fresheners and deodorizers), and volatile cleaners (including citrus and pine phenolic cleaners whose names often end in "-ol") as the biggest access barriers for people with chemical intolerance related to operations and maintenance of a building (5). Other sources include potpourri, incense and scented candles (even when incense or scented candles are not burning). Sometimes fragrance is added to and dispersed via a building's ventilation system.
Many people with asthma receive recommendations from their health care provider to avoid fragrances to prevent inflammation of their airways and triggering of bronchospasm. Avoidance of fragranced products entails avoiding products that list fragrance as an ingredient or may have a fragrant odor. Even if the word "fragrance" does not appear on the label or material safety data sheet as an ingredient, fragranced chemicals may have been added to a product for another purpose such as an anti-microbial stabilizer, blending agent, or enhancer.
Fragrances and many other potentially toxic chemicals are present in janitorial cleaning supplies as well. These can emit volatile organic compounds (VOC's) (6), contribute to poor indoor air quality (IAQ), and create access barriers for people with asthma, allergies, and/or other chemical intolerance. Some cleaning products also contain disinfectants. The U.S. EPA has identified the increased incorporation of antimicrobial agents and fragrances in cleaners and air fresheners marketed to reduce indoor air contamination as a health concern (7).
In the school environment, chemicals in indoor air can react with one another to form other compounds that are more hazardous than the original chemicals. There is increasing evidence that ozone and hydroxyl radicals formed by other oxidants can react with alkenes (such as limonene found in citrus and fragrance formulations, as well as terpenes emitted by many wood products) to produce novel secondary pollutants including formaldehyde, as well as hydroxy radicals that can react with organics to form other potentially toxic air pollutants. The toxicity of many of these secondary pollutants is well-established although for others it has yet to be evaluated (8, 9, 10, 11).
Paradichlorobenzene and naphthalene are common ingredients in fragrance-emitting devices. Deodorizer products are often used in public bathrooms. Restroom and other deodorizer/re-odorizer products are unnecessary and can be avoided by increasing ventilation/air flow and by thoroughly cleaning the facilities with mild detergents followed by the use of safer disinfectants, preferably peroxide-based ones. In order to avoid limiting access to individuals with asthma, allergies, chemical intolerance and other health concerns and to protect the most susceptible children and adults, best practice recommendations for "green" cleaning in schools should be modeled after the National Institute of Building Sciences and The Architectural and Transportation Barriers Compliance Board (Access Board) Accessibility Guidelines for Indoor Environmental Quality (http://ieq.nibs.org/om/bi_intro.php).
It is my hope that this information will be shared among the Green Cleaning Committee Members and the Board of Education for educational purposes and for consideration of cost-effective, health-oriented best practices green cleaning recommendation for Missouri schools.
Sincerely,
CLAUDIA S. MILLER, M.D.,
M.S. Professor, Occupational and Environmental Medicine
Assistant Dean, MD/MPH Program
Vice Chair, Community Medicine, Department of Family and Community Medicine
Director, South Texas Environmental Education and Research (STEER) Program in Laredo & Harlingen
The University of Texas Health Science Center at San Antonio
7703 Floyd Curl Drive (MCS 222) San Antonio, TX 78229-3900
References:
1. Ashford NA, Miller CS. Chemical Exposures: Low Levels and High Stakes (2nd ed.). NY, John Wiley and Sons, Inc., 1998.
2. Miller CS. Multiple Chemical Intolerance and Indoor Air Quality. In Handbook of Indoor Air Quality. Samet JM and Spengler JD, eds., pp 27.1-27.30, 2001.
3. Bridges B. Fragrance: emerging health and environmental concerns, Flavour and Fragrance Journal 2002; 17: 361-371.
4. Neurotoxins: At Home and the Workplace, Report by the Committee on Science and Technology, U.S. House of Representatives, Sept. 16, 1986, Report 99-827.
5. NIBS IEQ committee: Indoor Environmental Quality, Report by The Architectural and Transportation Barriers Compliance Board (Access Board), National Institute of Building Sciences, 2006.
6. McCampbell A. Pesticide Sensitivities, pp. 606-609, in Encyclopedia of Pest Management, Pimentel D, Ed., New York: Marcel Dekker, 2002.
7. Program Needs for Indoor Environments Research (PNIER), U.S. EPA, 402-B-05-001, March 2005.
8. Nazaroff WW, Weschler CJ. Cleaning products and air fresheners: exposure to primary and secondary air pollutants, Atmospheric Environment 38 (2004) 2841-2865.
9. Nojgaard JK, Christensen KB, Wolkoff P. The effect on human eye blink frequency of exposure to limonene oxidation products and methacrolein, Toxicology Letters 156 (2005) 241-251.
10. Weschler CJ. Reactions among indoor pollutants: what's new, Paper #291, Proceedings of the Annual Meeting of the Air and Waste Management Association, Orlando, FL, June, 2001.
11. Weschler, CJ. Ozone in indoor environments: concentration and chemistry, Indoor Air 2000; 10:269-288. Note:
This letter contains excerpts from the National Institute of Building Sciences and The Architectural and Transportation Barriers Compliance Board (Access Board) Accessibility Guidelines for Indoor Environmental Quality. http://ieq.nibs.org/om/bi_intro.php
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To the Missouri Green Cleaning Committee:
It was brought to my attention by Ms. Sue Carroll that the Missouri Department of Elementary and Secondary Education has been tasked with developing and providing guidelines for green cleaning in schools as a result of State Legislature SB 1181. I commend you for working to protect our Nation’s most valuable resource, our children, who are especially vulnerable to toxicants as a result of their smaller size, the amount of air they breathe relative to their size, the fact that their organ systems and brains are still developing, and differences in their ability to detoxify exposures, compared to adults’ ability. Protecting children will also protect the school personnel who care for them—teachers, custodians, administrators and school staff—resulting in a better environment for both learning and working.
I am a tenured full professor and physician at the University of Texas School of Medicine at San Antonio and have published extensively on the effects of low level exposures, including indoor air contaminants, and individual differences in susceptibility. In addition, I am board-certified in Internal Medicine and Allergy/Immunology and teach Environmental and Occupational Medicine, while serving as Vice Chair for Community Medicine and Assistant Dean for our MD/MPH program. I am also founder and Director of the South Texas Environmental Education and Research (STEER) Program, which trains physicians, medical students, and other graduate-level health professions students in environmental health.
For your consideration, I am enclosing a copy of the flyer for my book (Chemical Exposures: Low Levels and High Stakes, Wiley) (1), a chapter I wrote for the leading text on indoor air (Indoor Air Quality Handbook by Spengler and Samet, McGraw-Hill) (2), and several of my papers which explain Toxicant-Induced Loss of Tolerance (TILT), a new framework for understanding how low level exposures affect people. Schools are open to a full range of community members and children—individuals whose personal susceptibilities differ by orders of magnitude. Today, substantial portions of the general population suffer from asthma, migraines, ADHD, and a host of other disorders that are associated with TILT. For this reason, it is imperative that the decision-makers involved in your legislative efforts understand this disease mechanism, a mechanism that the environmental and occupational health communities have known about for a decade. TILT develops as a result of what are called "initiating exposures," for example, exposure to pesticides, mold, volatile organic chemicals (mVOCs), or to chemicals associated with remodeling (paints, adhesives, particle board outgassing formaldehyde, etc.). Once TILT occurs in an individual, extremely low levels of everyday exposures such as cleaning agents, fragrances, white board markers, floor polish, and myriad other substances that are present in the air of most schools can "trigger" symptoms in susceptible individuals.
A number of chemicals used in cleaning schools can initiate and/or trigger TILT and the symptoms and chronic illnesses associated with it. I am particularly concerned about the use of so-called "green" cleaning products that may in fact contain fragranced materials. Fragrances are complex chemicals. Often they are used to "mask" other odors and can give the false impression that air is clean. Truly clean air has no smell. There are approximately 3000 chemicals used in the manufacture of fragrances. Most of these are synthetic and derived from petroleum, not from the flowers or spices they emulate. Most remain untested, so we lack understanding of the potential health effects for those who are exposed and may be more susceptible. One major problem is that we usually don’t know who is more susceptible until after they become sick! Potentially hazardous chemicals found in fragrance formulations include toluene, alcohols, formaldehyde, styrene, benzene, limonene, musk, and phthalates. An individual fragrance formula may contain over 100 chemicals, but their identities are protected as trade secrets, so this information does not appear on product labels. Fragrances do not have to be tested for safety before they are put on the market (3).
Exposure to fragrances can trigger asthma attacks, migraine headaches, and can aggravate sinus conditions. Those who have chemical intolerances report that fragrances can trigger irregular heartbeat, memory loss, confusion, fatigue, and neurological, vascular, and other problems according to a 1986 U.S. House of Representatives Report: "In 1986, the National Academy of Sciences targeted fragrances as one of the six categories of chemicals that should be given high priority for neurotoxicity testing. The others include insecticides, heavy metals, solvents, food additives and certain air pollutants. The report states that 95 percent of chemicals used in fragrances are synthetic compounds derived from petroleum. They include benzene derivatives, aldehydes, and many other known toxics and sensitizers, which are capable of causing cancer, birth defects, central nervous system disorders and allergic reactions."(4).
Fragrances can affect the brain and nervous system in a few seconds or over the course of a day. Some effects may appear only after repeated exposures over weeks or even years. The presence of perfume, cologne, scented cleaners and other scented products contributes to poor indoor air quality and is one of the major access barriers for Americans with health disabilities like asthma and chemical intolerance. The Operations & Maintenance Committee for the U.S. Access Board identified pesticides (indoors & outdoors), fragrances (especially fragrance-emitting devices), air fresheners and deodorizers), and volatile cleaners (including citrus and pine phenolic cleaners whose names often end in "-ol") as the biggest access barriers for people with chemical intolerance related to operations and maintenance of a building (5). Other sources include potpourri, incense and scented candles (even when incense or scented candles are not burning). Sometimes fragrance is added to and dispersed via a building's ventilation system.
Many people with asthma receive recommendations from their health care provider to avoid fragrances to prevent inflammation of their airways and triggering of bronchospasm. Avoidance of fragranced products entails avoiding products that list fragrance as an ingredient or may have a fragrant odor. Even if the word "fragrance" does not appear on the label or material safety data sheet as an ingredient, fragranced chemicals may have been added to a product for another purpose such as an anti-microbial stabilizer, blending agent, or enhancer.
Fragrances and many other potentially toxic chemicals are present in janitorial cleaning supplies as well. These can emit volatile organic compounds (VOC's) (6), contribute to poor indoor air quality (IAQ), and create access barriers for people with asthma, allergies, and/or other chemical intolerance. Some cleaning products also contain disinfectants. The U.S. EPA has identified the increased incorporation of antimicrobial agents and fragrances in cleaners and air fresheners marketed to reduce indoor air contamination as a health concern (7).
In the school environment, chemicals in indoor air can react with one another to form other compounds that are more hazardous than the original chemicals. There is increasing evidence that ozone and hydroxyl radicals formed by other oxidants can react with alkenes (such as limonene found in citrus and fragrance formulations, as well as terpenes emitted by many wood products) to produce novel secondary pollutants including formaldehyde, as well as hydroxy radicals that can react with organics to form other potentially toxic air pollutants. The toxicity of many of these secondary pollutants is well-established although for others it has yet to be evaluated (8, 9, 10, 11).
Paradichlorobenzene and naphthalene are common ingredients in fragrance-emitting devices. Deodorizer products are often used in public bathrooms. Restroom and other deodorizer/re-odorizer products are unnecessary and can be avoided by increasing ventilation/air flow and by thoroughly cleaning the facilities with mild detergents followed by the use of safer disinfectants, preferably peroxide-based ones. In order to avoid limiting access to individuals with asthma, allergies, chemical intolerance and other health concerns and to protect the most susceptible children and adults, best practice recommendations for "green" cleaning in schools should be modeled after the National Institute of Building Sciences and The Architectural and Transportation Barriers Compliance Board (Access Board) Accessibility Guidelines for Indoor Environmental Quality (http://ieq.nibs.org/om/bi_intro.php).
It is my hope that this information will be shared among the Green Cleaning Committee Members and the Board of Education for educational purposes and for consideration of cost-effective, health-oriented best practices green cleaning recommendation for Missouri schools.
Sincerely,
CLAUDIA S. MILLER, M.D.,
M.S. Professor, Occupational and Environmental Medicine
Assistant Dean, MD/MPH Program
Vice Chair, Community Medicine, Department of Family and Community Medicine
Director, South Texas Environmental Education and Research (STEER) Program in Laredo & Harlingen
The University of Texas Health Science Center at San Antonio
7703 Floyd Curl Drive (MCS 222) San Antonio, TX 78229-3900
References:
1. Ashford NA, Miller CS. Chemical Exposures: Low Levels and High Stakes (2nd ed.). NY, John Wiley and Sons, Inc., 1998.
2. Miller CS. Multiple Chemical Intolerance and Indoor Air Quality. In Handbook of Indoor Air Quality. Samet JM and Spengler JD, eds., pp 27.1-27.30, 2001.
3. Bridges B. Fragrance: emerging health and environmental concerns, Flavour and Fragrance Journal 2002; 17: 361-371.
4. Neurotoxins: At Home and the Workplace, Report by the Committee on Science and Technology, U.S. House of Representatives, Sept. 16, 1986, Report 99-827.
5. NIBS IEQ committee: Indoor Environmental Quality, Report by The Architectural and Transportation Barriers Compliance Board (Access Board), National Institute of Building Sciences, 2006.
6. McCampbell A. Pesticide Sensitivities, pp. 606-609, in Encyclopedia of Pest Management, Pimentel D, Ed., New York: Marcel Dekker, 2002.
7. Program Needs for Indoor Environments Research (PNIER), U.S. EPA, 402-B-05-001, March 2005.
8. Nazaroff WW, Weschler CJ. Cleaning products and air fresheners: exposure to primary and secondary air pollutants, Atmospheric Environment 38 (2004) 2841-2865.
9. Nojgaard JK, Christensen KB, Wolkoff P. The effect on human eye blink frequency of exposure to limonene oxidation products and methacrolein, Toxicology Letters 156 (2005) 241-251.
10. Weschler CJ. Reactions among indoor pollutants: what's new, Paper #291, Proceedings of the Annual Meeting of the Air and Waste Management Association, Orlando, FL, June, 2001.
11. Weschler, CJ. Ozone in indoor environments: concentration and chemistry, Indoor Air 2000; 10:269-288. Note:
This letter contains excerpts from the National Institute of Building Sciences and The Architectural and Transportation Barriers Compliance Board (Access Board) Accessibility Guidelines for Indoor Environmental Quality. http://ieq.nibs.org/om/bi_intro.php
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