Update on Industry Research

By Mark D. Gold Late in 1994, the Journal, "Food and Chemical Toxicology" published a A study conducted by scientists of E.I. du Pont de Nemours and Co., And the Monsanto Company. These industry scientists found no effects from the carpet sample which Dr. Rosalind Anderson of Anderson Laboratories found to cause moderate to severe pulmonary irritation, slight to moderate sensory irritation, and neurotoxicity. According to Mark Goldman, the manager of Anderson Laboratories, the industry scientists change Dr. Anderson's protocol in such a way that no adverse effects will be found. Two common techniques that the industry uses, according to Dr. Goldman, are keeping the humidity too high so that the toxic chemicals are end up in the water as opposed to being inhaled, and to change the material which the exposure tank are composed of. It is really a moot point as far as toxic carpeting causes anywhere from mild to severe reactions in test animals using the ASTM E981 testing procedure. Dr. Anderson has tested over 100 samples which proved to be toxic. Dr. Yves Alarie, the inventor of the ASTM E981 testing procedure reviewed Dr. Anderson's protocol and said it was valid. Dr. Alarie also repeated Dr. Anderson's tests on carpet samples and verified her results *four* times in his laboratory. The EPA was videotaped in a side-by-side test at Anderson Laboratories proving that the carpet sample they chose caused severe problems in animals. The reactions in animals found in Dr. Anderson's test often mimiced the acute reactions that were found in humans exposed to the same carpet. The industry article appeared in the journal, "Food and Chemical Toxicology." In my opinion, this journal is heavily biased towards publishing research which exonerates unhealthy and even dangerous food and chemical products. The editor of this journal, Dr. Joseph Borzelleca is a consultant scientist for the Carpet and Rug Institute (CRI). The Consumer Product Safety Commission (CPSC), an organization which has already shown that it is in bed with the carpet and rug industry, recently gave $60,000 to Air Quality Sciences lab to perform carpet testing. According to Mark Goldman of Anderson laboratories, Air Qaulity Sciences lab receives money from the carpet industry. **** NOTICE ****

This series of articles is presented with the permission of the author, Cindy Duehring (per phone conversation on 10/4/95). For considerably more extensive documentation on the hazards of toxic carpeting and on other environmental/health hazards, please contact: Cindy Duehring Director of Research Environmental Access Research Network P.O. Box 1089 Minot, North Dakota 58702-1089 (701) 837-0161 **** NOTICE **** **** NOTICE **** This series of articles is presented with the permission of the author, Cindy Duehring (per phone conversation on 10/4/95). For considerably more extensive documentation on the hazards of toxic carpeting and on other environmental/health hazards, please contact: Cindy Duehring Director of Research Environmental Access Research Network P.O. Box 1089 Minot, North Dakota 58702-1089 (701) 837-0161 **** NOTICE ****

CARPET CONCERNS Part Two:

Carpet Installers Speak Out As the Medical Evidence Mounts by Cindy Duehring "This isn't a profession for a young man to go into," says David Buechler, a Sawyer, North Dakota carpet installer who has been laying carpet for twenty-fie years. "I don't know any other carpet layers whose health isn't affected by the job in some way." Buechler experiences a number of adverse symptoms when he works with carpet. "The fibers and the chemicals affect your lungs and your sinuses," he says. "Every time I lay carpet I sound like I have a cold by the end of the day. I get hoarse, shortness of breath, and my sinuses clog up. I get sinus infections on a regular basis. Also, my doctors attribute the arthritis I developed to inhaling the fumes from the carpet glues." He adds, "Cancer, especially lung cancer, is a big concern. I know of about eight carpet layers in my area that were laying carpet when I started out, who have all died of lung cancer. THey never made it to retirement." Insurance companies are aware of the risks, according to Buechler. "It's hard to get life insurance if you're a carpet installer, he states. "And they require a really tough physical for medical insurance if they find out you lay carpet. I have also been told that if I hire a young guy to work for me I need to get a release signed so that if he's laying carpet and comes down with cancer years down the road, I won't be held responsible." Some of Buechler's customers have had adverse health effects fom carpet. He now regularly cautions new customers to stay away during installation, to keep off the carpet for several days during the initial high offgas period, and to ensure the house is continuously ventilated. He voices concern that some carpets appear to be more toxic than others, and he advises people not to take any chances if their carpet causes chronic health problems. He would rather see someone remove their carpet than have serious long-term consequences.

Buechler says he has found that some people who react to one carpet may not react to another. To reduce the todal amount of volatile organic compounds (VOCs) that people are exposed to from carpet systems, "we are going almost one hundred percent away from the glue down carpet," says Buechler. "We tack it down because the glues offgas a lot of toxic solvents and add to the toxicity that is already present from the latex backing. Rubber padding can be a toxicity problem, too." He tells of a time when a young neighbor girl laid on a roll of rubber padding while watching cartoons on TV: "She fell asleep and when she woke up, all she had was slits for eyes because her face was so puffed up. I wouldn't have recognized her if I hadn't known who she was. And she was only on that rubber padding for just one hour." Buechler no longer uses a van to haul carpet to his work sites because he says fumes in the enclosed space were affecting him. On some days, "by the time I'd get to the job, I'd have such a headache I could hardly function," he says. "Now I have a pickup with a cab. I keep the carpet in the back away from me and I feel much better." One of the most dangerous aspects of carpet laying is the seaming process, according to Buechler, who explains, "The warnings I get along with the carpet say do not breathe the fumes and do not burn or get near flames and so on. But you have to during the seaming process. You really get exposed to some nasty fumes because you use a hot seaming iron to melt the vinyl and plastic material. It's about like throwing a record in the oven and letting it melt up. Think about what inhaling those fumes could do to a person." After twenty-six years of exposure to fumes from carpet laying, gluing, and seaming, Gerald Schmidt of Grand Forks, North Dakota, was finally forced to quit when his symptoms reached disabling proportions. He started laying carpet as an apprentice in 1966 in Minneapolis, Minnesota, then went into business on his own in 1968. Schmidt has noticed a change in the toxicity of carpet over the years. "I've had a carpet warehouse for eighteen years," he says. "When we first bought the warehouse, we used to have jute backed carpet with the burlap on the back. Back then we had a terrible problem with mice building nests in the carpet rolls and we had to keep mouse traps out all the time. Now I haven't had a mouse in there in twelve to thirteen years. There's no live bugs in there anymore either. Not even ants. The only animals we've found in the warehouse were a couple of dead squirrels. It's the same warehouse. Nothing has changed but the floor covering."

After installing carpet for many years, he gradually developed a variety of neurological and respiratory symptoms including numbness, tingling, dizziness, ringing in the ears, shortness of breath, joint pain, forgetfulness, fatigue, irritability, and tremors. I never dreamed my life would turn out this way," says Schmidt. "I loved my work. It was a good job. All I ever wanted was to do an honest days' work in a steady job to put a roof over my head, feed my family, and put aside a little -- just enough to retire on some day. I never counted on this. Now I'm in terrible pain and I shake so much that I can hardly function. I drop stuff, I can't hang on to things, I forget what I go to get. I'm weak and I get really tired. I can't sleep well. My temper and my mood swings are really bad." Schmidt was evaluated at Mayo Clinic in Rochester, Minnesota, and by neuropsychiatrist Richard Nelson, M.D., in Billings, Montana. Both evaluations found evidence of peripheral neuropathy. Blood tests at Mayo Clinic revealed high levels of arsenic. Arsenical pesticides are registered for use in carpets.(1) Further testing showed elevated benzene, a neurotoxic solvent found in carpet.(2) His blood work also showed various immune abnormalities consistent with the patterns being found in chemical injury. (3,4) Schmidt has elevated TA1 cells, decreased B lymphocytes, autoimmunity (meaning that the body's immune system has mistakenly identified its own tissues or cellular components as foreign and has directed antibodies against them). He has autoantibodies to smooth muscle, central nervous system, and peripheral nerve myelin. Neurometric testing including electroencephalogram (EEG) P300 latency assessment evidenced cognitive impairment. To express his concerns, Schmidt called the Carpet and Rug Institute (CRI) and told them, "Hey, we've got a big problem out here, and it's not just me. I know of other carpet layers who are disabled from the chemicals in carpets." According to Schmidt, the CRI's response was simply a denial of the problem, and claims that they had never heard of any problems from other carpet layers. "I was outraged," says Schmidt. "I told them, we've given all the working years of our lives to the carpet industry. We've supported you all the way and we've sold your product. And now when we've been made ill by it, where are you? You've abandoned us carpet layers and have just left us in limbo out here, unable to work, unable to pay our bills. I've got children to feed, and as long as you and the Environmental Protection Agency (EPA) won't own up to the problem and acknowledge that chemicals in carpeting are disabling some people -- especially the carpet layers who are getting sick -- then workers' compensation won't even pay my medical bills for the neurological and

immunological testing I had to do to prove I've got real damage." Motivated by the CRI's denials, Gerald Schmidt sent a copy of all his medical testing reports, including the letters from his doctors, to the CRI by certified mail and sent copies to Congressman Mike Synar [K-OK] and Vice President Al Gore. "I just wanted to have proof that I told them so they can't deny that they've received complaints from carpet layers," states Schmidt. Since then, has the CRI changed its tune? When asked if they had heard of any health problems from carpet layers or whether any carpet layers had complained, CRI Director of Public Relations, Kathryn Wise stated, "No. We're not aware of any." (5) "Why are they turning their back on us?" asks Ron Braithwaite, a carpet installer from Perth Road Village, Ontario, Canada. "I contacted the United States CRI about a year ago and told them I was having health problems from carpet. They told me I was the only one. Canada's carpet institute said the same thing. So I said, 'Okay, I'm the only one.'" He later spoke with other carpet layers in Canada who were experiencing adverse health effects from the carpet and found they were being told the same thing. "So as long as they're telling us that, then we think we're the only ones with the problem and that it's not affecting anybody else," he says. Thirty-nine-year-old Braithwaite started laying carpet when he was ten years old, helping his father who was also a carpet layer. He says, "My dad died of lung cancer when he was fifty-eight. Another carpet layer who was a good friend of his died the same way. There are a lot of carpet layers in our area that died of cancer and developed other serious health problems when they were relatively young." Other the years Braithwaite developed a number of symptoms which gradually worsened to the point where he is now disabled. Neurological testing, including a SPECT scan (single photon emission computed tomography) conducted in the nuclear medicine department of Ottawa General Hospital, verified damage to his brain, especially to his posterior parietal lobes. His doctors are convinced that the solvents and other chemicals in the carpets and glues Ron was working with are the cause. He experiences severe concentration problems, dizziness, memory loss, ringing in his ears, erratic heartbeats, shortness of breath, erratic sleeping patterns recurring nosebleeds, weakness, coordination problems, sharp pains, irritability, gastrointestinal problems, numbness and sensations of pins and needles in his lower arms and hands. He has found that his symptoms

worsen when he is around the low levels of petrochemicals commonly found in many public buildings, which limits him still further. Braithwaite wants his health back. But that is not all he wants. "I want to know the names of all the chemicals I have been working with for the past twenty plus years. I should have a legal right to know what has been poisoning me," he says. "I want to know why I was never given any warnings about any of this all the years I laid carpet. And I want to know how to tell my two young children that their daddy is too sick to go to their school play or go on the swing with them, or help build a snowman. I want to know how to tell my children why mommy and daddy seem to be arguing all the time because their daddy can't provide for his family the way he did for years, and because we are worried about the future of our children." Ron Braithwaite and his wife Donna remortgaged their home to open a local corner store. Donna Braithwaite often works eight-hour weeks at their store in an effort to support their family. As Ron struggles to cope with hsi disability, he spends his time gathering information regarding the health effects of chemicals in carpets, and plant to start a support group. He wonders, "How many other families, including vulnerable little children, have to be made seriously ill by carpet before the CRI honestly admits to the problem and stops putting out products that place people at risk?" Nothing has been proven to date that links carpet and ill health effects," says the CRI's Kathryn Wise. (5) "This type of denial is just exactly what the tobacco industry has done for years and to a large degree is still doing," attorney Kevin McIvers of Santa Barbara, California, states. "It is based on a type of technical scientific nonsensical argument where they take the position in court -- and in my mind this takes tremendous nerve for them to say this -- that there is no scientific evidence that smoking cigarettes causes cancer. And then of course folks like us say 'Well then, why do people die of cancer three or four times as often w hen they smoke cigarettes than when they don't?' You would think that finding is pretty scientific, but what they are talking about is the technical argument. There is no one who can completely explain exactly what chemicals in cigarette smoke causes what precise biomolecular changes that actually mutate the cell and lead to that downward path to cancer. So because of that, they say there is no evidence that it makes you sick, and that's nuts. Just because you don't understand the mechanism doesn't mean it's not happening. People get around these products and they become

dreadfully ill. But that is not enough for the tobacco industry and the CRI." A quick scan of the medical and scientific literature reveals the following: - A higher incidence of neuro-psychiatric illness including visuo-analytical and perceptual impairment was found in floorlayers than in controls. The effects were associated with glues and contact adhesives and their action on the central nervous system. (6) - A study of carpet and textile workers in northern Georgia found that compared to other Georgians, they had a higher incidence of deaths from lymphocytic leukemia and testicular cancer. (7) - An increased risk of oral and pharyngeal cancer was found for male carpet layers, as compared to control subjects, in a study conducted in four areas of the United States. (8) - A study found that carpet layers exposed to solvents are at increased risk for the types of neuropsychiatric disorders associated with solvent exposure, as compared to control subjects. The greater the exposure, in terms of number of years worked, the greater the risk. (9) - EPA researchers warn that carpet tends to provide a reservoir for tracked-in chemicals adsorbed to dust, including pesticides, lead, heavy metals, and polynuclear aromatic hydrocarbons. The amount of lead found in dust in carpet where a child plays has been found to be the best single predictor of the toddler's blood level of lead. (10,11,12) - The abstract of a Russian study states, "People working in modern carpet industry are exposed to a complex of factors in different origin, the most important among which are general vibration and styrene vapors. It has been found out in animal experiments simulating working conditions, that the central nervous system is the most sensitive" to chemical exposure in the carpet industry. (13) - The ASTM E981 method used by Anderson Laboratories in case-controlled studies has shown the presence of measurable concentrations of sensory and pulmonary irritant chemicals offgassing from carpet. Neuromuscular toxicity has also been measured with the test. (14) Anderson Lab's test results have been duplicated by an independent

lab hired by the CRI (15), and by the U.S. EPA in a side-by-side test at Anderson Labs. (16) Mice exposed to air passing over a seven-inch square piece of carpet at room temperature exhibited respiratory and neurological symptoms, and some died. (17) The ASTM E981 method was developed by Yves Alarie, Ph.D., in the 1960s under the direction of the U.S. Department of Defense. It was specifically developed to reliably extrapolate mouse data to humans. It has been recommended as a reliable product test in a report commissioned by the Consumer Product Safety Commission (CPSC) and also by Daniel Costa, of EPA's Health Effects Research Laboratory, Pulmonary Toxicology Branch. (2, 18) Costa wrote regarding the ASTM E981, "We support the use of the mouse irritancy test for detecting, and possibly for comparing potencies among, indoor air contaminants ... We believe that if the mouse irritancy test is positive upon exposure to a suspected indoor contaminant, then the atmosphere is likely to be irritating to humans." (18) This method has been used extensively by both government and industry over the years to determine irritant effects of chemicals and to extrapolate those results to humans. A recent review article found that at least 295 chemicals had been evaluated by the ASTM E981 method in the published scientific literature. Eighty-nine of those chemicals have occupational exposure limit values (threshold limit values) against which the adequacy of the ASTM E981 tests were compared. The ASTM E981 was found to be a reliable indicator for human occupational exposure limit values, and the author concluded, "There are no other toxicological methods that have been validated, calibrated, and used with results available on such a large number of airborne chemicals. ... Certainly, the bioassay has withstood the test of time and the various mechanisms by which sensory irritation occur have now been well-delineated. ... Analysis of the now much larger database proves that the bioassay is even better at predicting safe levels of exposure for humans than originally suggested by Alarie." (19) At the CRI's request, Dr. Alarie visited Anderson Labs to review the quality and methodology of Anderson's handling of the ASTM E981, and found that it was scientifically valid. The CRI then hired Alarie to try to duplicate Anderson's results. Alarie testified at a June 11, 1993, carpet toxicity hearing before the House Subcommittee on Environment, Energy, and Natural Resources, that "her description of the effects observed was correct and her experimental design was valid," and that he was able to replicate her results four times. (15)

Mark Goldman, manager of Anderson Labs, reports that autopsies on mice exposed to carpet fumes using the ASTM E981 method have shown a variety of lesions including brain and liver lesions, as well as kidney degeneration. The consulting pathologist noted no predictable pattern for the lesions, "but, you don't expect to see lesions in such a short-term low level exposure," Goldman says. In spite of the evidence, the CRI distributed an April 1993 memorandum throughout the carpet and rug industry, calling the test used by Anderson Labs into question and stating that the CPSC, EPA, and independent labs had all "failed to discover any evidence linking carpet and ill health effects." The memorandum, which was distributed to carpet retailers as well, assured them that a class action lawsuit regarding carpet toxicity would be "defended vigorously and successfully." (20) Carpet installer Schmidt says that after he contacted the CRI, he received a call from a representative within the carpet industry, who told him his problems couldn't possibly have come from carpet and that the mouse tests run by Anderson Labs were ridiculous. Schmidt responded to the man, "What? Do you think those mice just died on cue? They've run the test a number of times you know. Not all of the mice die, and other researchers have repeated the test successfully. They must train those mice pretty well to just kick over and die." Anderson labs reports that the respiratory and neurological symptoms in the mice have correlated well with the symptoms of the carpet owners. The preliminary results of one case are particularly striking. Pulmonary specialist Ganesh Rhagu, M.D., associate professor of medicine, chief of the chest clinic and medical director of the lung transplant program at the University of Washington School of Medicine, Division of Pulmonary and Critical Care, had a patient who was exposed to new carpet and developed hypersensitivity pneumonitis. Dr. Rhagu sent a piece of the patient's carpet to Anderson Labs to see what kind of effect it would have on the mice. The tests have been run twice, both times with case controls. Lab manager Mark Goldman reports "Dr. Rhagu found the same type of pathological changes and damage in the tissue biopsies from the lungs of the carpet exposed mice as in the patient who was exposed to the same carpet. Normally hypersensitivity pneumonitis is a chronic disease, but the mice developed it after only forty-eight hours of exposure. The implications are so serious, we are not willing to make a solid statement at this time, until more data are in. So, bear in mind that these are early results and more tests are under

10

way to confirm the data." Goldman has been contacted by some carpet installers who say they have been made ill by carpet, but he also hears from carpet installers who say they have had no problems. Goldman comments "Most of the time if a carpet layer is fairly sensitive, he will get out of the business. If he gets sick and nauseated doing the work when he first starts out, he's not going to stick around and he'll switch to another profession that doesn't make him sick. I hear carpet layers say, 'I've been doing this for twenty years and it hasn't bothered me at all.' So there is a self-selected group of people in the business who aren't sensitive, but they are also, in some cases, the ones who wind up coming down with caner."

Hazardous Chemicals in Carpet The Carpet and Rug Institute (CRI) has voluntarily agreed to a new carpet label which states, in part: "IMPORTANT HEALTH INFORMATION: Some people experience allergic or flu-like symptoms, headaches, or respiratory problems which they associate with the installation, cleaning, or removal of carpet or other interior renovation materials. If these or other symptoms occur, notify your physician of the symptoms and all materials involved. SENSITIVE INDIVIDUALS: Persons who are allergy-prone or sensitive to odors or chemicals should avoid the area or leave the premises when these materials are being installed or removed." In spite of the warnings on the new label, CRI's Director of Public Relations, Kathryn Wise, states, "All the scientific reports have told us that there is nothing that they can prove that is harmful to health in carpet." (5) However, an April 1991 New York Attorney General consumer alert regarding carpets warns that "many of the chemicals emitted are toxic and some are known or suspected to cause cancer and birth defects." (21) Much of the difficulty in pinpointing the problem arises from the large number of chemicals involved. A toxicologist within the carpet and rug industry has revealed that there are at least one thousand different chemicals in the manufacture of carpets. "In December of 1992, at the request of one of the major chemical companies in the carpet and rug industry, Dr. Alan Broughton and I met with one of their toxicologists and the attorney that represented the carpet

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industry," says immunotoxicologist Jack Thrasher, Ph.D. "We were interviewed regarding the abnormal immunologic test results we had found in numerous cases of carpet exposure. They also asked us what our recommendations for research would be with respect to carpet problems. We were told at that meeting that there are at least one thousand different chemicals used in synthetic carpeting and that to look at the combinations and permutations would be a tremendous task." One example of a hazardous contaminant or possible permutation appears to be formaldehyde. According to the carpet and rug industry, formaldehyde is not used in the manufacture of carpets. Wise states, "There is no formaldehyde in carpet, it has not been used in the manufacture of carpet in over ten years." Michael Kronick, executive director of the Canadian Carpet Institute in Ottawa, has gone on record stating that formaldehyde, benzene, and toluene are not used in the manufacture of carpet. (22) Yet, all three of these chemicals are emitted from carpet according to a number of emissions tests run on new carpet samples fresh from the mill. (2, 23, 24, 25) One study commissioned by the U.S. Consumer Product Safety Commission (CPSC) found formaldehyde was one of the top eight emissions. Their report warns that the levels of formaldehyde, 4-PC, and butylated hydroxytoluene did not drop off rapidly, and may be "more important with respect to health and comfort effects. (2) After the initial installation period, the levels of the chemicals emitted from carpets are usually low. However, many researchers are extremely concerned about the possible synergistic and cumulative effects of the multitude of chemicals involved in carpet. The health effects of specific combinations of chemicals in carpets have not yet been studied. Listed below are just a few of the hazardous chemicals that have been found in carpet emissions tests. Not much is known about their health effects from chronic low-level exposure. The health effects listed are generally associated with higher exposure levels, but Grace Ziem, M.D., Dr.P.H., warns that sensitive individuals may experience adverse effects at lower exposure levels than the average individual. Further, the National Institute of Occupational Safety and Health warns that there is no safe level of exposure to a carcinogen, as the cell damage can occur at extremely low exposure levels. EPA's Dan Costa and a report commissioned by the CPSC both recommend

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the ASTM E981 test, used by Anderson Laboratories as a reliable test to determine human health effects from both individual chemicals and entire products. (2, 18) Some of the following chemicals are also listed on EPA's Community Right to Know List which requires manufacturing facilities to prepare Material Safety Data Sheets and notify local authorities of the presence of the chemicals. A number of the following chemicals have been tested with the ASTM E981 by labs other than Anderson's. Their published results indicate that adverse effects in mice are a reliable indicator of adverse effects in humans. Those chemicals are marked by the following statement, "Published studies indicate the ASTM E981 test is a reliable indicator of adverse human health effects." Partial Listing of Hazardous Chemicals Found in Carpet

Acetone (23) It is included in EPA's Toxic Substances Control Act Inventory and is listed on EPA's Community Right to Know List. It is considered a severe irritant. Human systemic effects by inhalation include changes in electroencephalogram, changes in carbohydrate metabolism, nasal effects, respiratory system effects, nausea, vomiting, and muscle weakness. Adverse reproductive effects have been reported in animal experiments. Acetone can react vigorously with oxidizing chemicals. Published studies indicate the ASTM E981 test is a reliable indicator of adverse human health effects for acetone. (19, 26, 27)

Bis(2-ethylhexyl)phthalate (25) It is a suspected carcinogen. (25, 29)

Benzene (2, 23, 25) It is included in EPA's Toxic Substances Control Act Inventory and is listed on EPA's Community Right to Know List. Benzene is a confirmed human carcinogen. It can produce myeloid leukemia, Hodgkin's disease, and lymphomas by inhalation. It is also considered a human poison by inhalation. It is a moderate skin irritant and a severe

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eye irritant. Human systemic effects by inhalation include blood changes and increased body temperature. Animal experiments have found teratogenic [birth defects] and adverse reproductive effects. Human mutation data have been reported. Research indicates that effects are seen at less than 1 parts per million (ppm). In one study, exposures needed to be reduced to 0.1 ppm before no toxic effects were observed. (27)

Caprolactam (25) It is moderately toxic by skin contact. Animal experiments have shown it to be teratogenic. Other adverse reproductive effects have been reported in experiments. Human mutation data have been reported. Exposure symptoms in humans include cough, skin and eye irritation. (27)

Diethylene glycol (25) It is included in EPA's Toxic Substances Control Act Inventory and is listed on EPA's Community Right to Know List. It is a suspected carcinogen, supported by experimental carcinogenic, tumorigenic and teratogenic data. It is an eye and human skin irritant. (27)

p-Dichlorobenzene (2, 25) It is included in EPA's Toxic Substances Control Act Inventory and is listed on EPA's Community Right to Know List. It is a confirmed carcinogen. Animal experiments have found teratogenic effects (birth defects). In humans it can cause headache, eye irritation, swelling weight loss, nausea, vomiting, and cirrhosis of the liver. Published studies indicate the ASTM E981 test is a reliable indicator of adverse human health effects for p-dichlorobenzene. (19, 26, 27)

Formaldehyde (2, 23, 25) It is included in EPA's Toxic Substances Control Act Inventory. It is a confirmed carcinogen. Animal experiments have reported adverse reproductive effects. Human mutation data has been reported. In humans it can cause eye, nose and throat irritation, bronchial spasm, lung irritation, dermatitis, agressive behavior, and olfactory (smell) changes. Frequent or prolonged exposure may cause hypersensitivity to subsequent lower level exposures. Published

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studies indicate the ASTM E981 test is a reliable indicator of adverse human health effects for formaldehyde. (19, 26, 27)

Hexane (23) It is included in EPA's Toxic Substances Control Act Inventory. In humans it can cause lightheadedness, nausea, headache, weakness, eye and nose irritation, dermatitis, chemical pneumonia, giddiness, hallucinations, structural changes in nerves, motor neuropathy, and respiratory irritation. Animal experiments have found adverse reproductive effects and birth defects. Mutation data have been reported. (26, 27)

Styrene (2, 24, 25) It is included in EPA's Toxic Substances Control Act Inventory and is listed on EPA's Community Right to Know List. It is a suspected carcinogen and human mutation data have been reported. Animal experiments have found adverse reproductive effects. In humans it can cause eye and nose irritation, drowsiness, olfactory (smell) changes, and defatting dermatitis. Published studies indicate the ASTM E981 test is a reliable indicator of adverse human health effects for styrene. (19, 26, 27)

Toluene (2, 23, 25) It is included in EPA's Toxic Substances Control Act Inventory and is listed on EPA's Community Right to Know List. Mutation data have been reported. Animal experiments have found adverse reproductive effects. Human effects include fatigue, weakness, confusion, euphoria, dizziness, headache, dilated pupils, dermatitis, central nervous system recording changes, hallucinations or distorted perceptions, motor activity changes, psychophysiological test changes, and bone marrow changes. Published studies indicate the ASTM E981 test is a reliable indicator of adverse human health effects for toluene. (19, 26, 27)

Vinylcyclohexene (28) It is included in EPA's Toxic Substances Control Act Inventory. It is considered to be moderately toxic by inhalation. Animal experiments have evidenced carcinogenic, tumorigenic, and adverse

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reproductive effects. (27)

Xylenes (2, 25) It is included in EPA's Toxic Substances Control Act Inventory and is listed on EPA's Community Right to Know List. Animal experiments have found adverse reproductive effects and birth defects. In humans it can cause dizziness, excitement drowsiness, weight loss, nausea, vomiting, abdominal pain, and dermatitis, coordination problems, and staggering gate. Published studies indicate the ASTM E981 test is a reliable indicator of adverse human health effects for xylenes. (19, 26, 27)

References: 1. National Federation of Federal Employees Local 2050, Environmental Protection Agency; Hirzy, W.B. "List of Pesticides Registered for Carpet and Indoor Uses." (Febraury 4, 1993). 2. Consumer Product Safety Commission memorandum and final report from interagency agreement on volatile organic chemical emissions from carpets. CPSC-IAG-09-1256 (August 13, 1993). 3. Heuser, G.; Vojdani, A.; Heuser, S. "diagnostic Markers of Multiple Chemical Sensitivity." in Multiple Chemical Sensitivities. Washington, DC: National Academy Press, National Research Council (1992) 4. Heuser, G. "Diagnostic Markers in Immunotoxicology and Neurotoxicology." Journal of Occupational Medicine and Toxicology 1(4):v-x (1992). 5. Kathryn Wise, Director of Public Relations, Carpet and Rug Institute. (Personal communication, December 17, 1993). 6. Ekberg, K.; Barregard, L.; et al. "Chronic and Acute Effects of Solvents on Central Nervous System Functions in Floorlayers." British Journal of Industrial Medicine 43(2): 101-106 (1986). 7. O'Brien, T.R.; Decoufle, P. "Cancer Mortality Among Northern Georgia Carpet and Textile Workers." American Journal of Industrial Medicine 14:15-24 (1988). 8. Huebner, W.W.; Schoenberg, J.R.; et al. "Oral and Pharyngeal

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Cancer and Occupation: A Case-Control Study." Epidemiology 3(4): 300-309 (1992). 9. Axelson, O.; Hane, M.; Hogstedt, C. "A Case-referent Study on Neuropsychiatric Disorders Among Workers Exposed to Solvents." Scandinavian Journal of Work Environment & Health 2:14-20 (1976). 10. Roberts, J.W.; Budd, W.T.; et al. "Chemical Contaminants in House Dust; Occurrentces and Sources." Indoor Air '93: Proceedings of the International Conference on Indoor Air Quality and Climate 2:27-32 (1993). 11. Davies, D.J.A.; Thorton, I.; et al. "Relationship Between Blood Lead and Lead Intake in Two Year Old Urban Children in the UK." Science of the Total Environment 90:13-29 (1990). 12. Budd, W.T.; Roberts, J.W., Ruby, M.G. "Field Evaluation of a High Volume Surface Sampler for Pesticides in Floor Dust." Environmental Protection Agency, EPA 600-3-90-030, PB 90-192006 (1990). 13. Rumiantsev, G.I.; Prokhorov, N.I.; et al. "Experimental Studies of the Combined Effect of Styrene in General Vibration." (in Russian) Gig Sanit 9:32-36 (1990). 14. Anderson, R.C., "Toxic Emissions from Carpets." Indoor Air '93: Proceedings of the International Conference on Indoor Air Quality and Climate 1:651-656 (1993). 15. Written submitted testimony of Yves Alarie before the Committee on Government Operations, Subcommittee on Environment, Energy, and Natural Resources, U.S. House of Representatives. Re: carpet research (June 11, 1993). 16. Anthony Pollina, Representative Bernard Sanders' aide and direct witness to the Environmental Protection Agency and Anderson Laboratory side-by-side ASTM E981 test. (Personal communication June 17, 1993). 17. Duehring, C. "Carpet. Part I: EPA Stalls and Industry Hedgest While Consumers Remain at Risk." Informed Consent 6-11, 30-32 (1993). 18. Tepper, J.S.; Costa, D.L. "Will the Mouse Bioassay for Estimating Sensory Irritancy of Airborne Chemicals (ASTM E981-84) be Useful for Evaluation of Indoor Air contaminants." Indoor

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Environment 1:367-72 (1992). 19. Schaper, M. "Development of a Database for Sensory Irritants and Its Use in Establishing Occupational Exposure Limits." American Industrial Hygiene Association Journal 54(9):488-544 (1993). 20. Memorandum from the Carpet and Rug Institute to the Carpet Industry and Retailers. Re: carpet toxicity, Anderson Laboratories test results, and a class action lawsuit. (April 1993). 21. New York State Department of Law, Abrams, R. "Chemicals in New Carpets Pose Potential Health Hazard." Consumer Alert (April 1991). 22. Kronick, M. "Helath Problems concerns Carpet Industry But Many Chemical Allegations Untrue." The Kingston Whig-Standard (november 8, 1993) p. 5. 23. Kirchner, S.; Karpe, P.; cochet, C. "Characterization of Volatile Organic Compounds Emission from Floor Coverings." Indoor Air '93: Proceedings of the International Conference on Indoor Air Quality and Climate 2:455-460 (1993). 24. Black, M.S.; Work, L.M.; et al. "Measuring the TVOC Contributions of Carpet Using Environment Chambers." Indoor Air '93: Proceedings of the International Conference on Indoor Air Quality and Climate 2:401-405 (1993). 25. Pliel, J.D.; Whiton, R.S. "Determination of Organic Emissions from New Carpeting." Appl. Occup. Environ. Hygiene 5:693-699 (1990). 26. National Institute for Occupational Safety and Health. NIOSH Pocket Guide to Chemical Hazards, Washington, D.C.: U.S. Government Printing Office (June 1990). 27. Lewis, R.J. Sax's Dangerous Properties of Industrial Materials, New York: Van Nostrand Reinhold (1989). 28. Kenneth Reed, Ph.D., Industrial Hygienist, Reed & Associates, (Personal communication with Jack Thrasher, Ph.D. regarding chemicals isolated from carpet via a water trap). 29. National Institute of Occupational Safety and Health. "Registry of Toxic Effects of Chemical Substances." DHHS (NIOSH) Pub. No. 87-114. Washington D.C.: Government Print Office (1988).

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CARPET ... Part One:

EPA Stall and Industry Hedges while Consumers Remain At Risk by Cindy Duehring "I'll never forget when it first started. I was sitting at a table eating a sandwich and reading People magazine, with my ten-month-old son, Christopher, nearby on the carpet. All of a sudden, he went into this strange seizure-like reaction. His upper body tensed up, and his arms started shaking, and his jaw moved kind of funny-like." Jocelyn McIvers rushed her son to the doctor. He immediately hospitalized Christopher, whose reactions continued unabated. After a week of testing, the doctors ruled out multiple sclerosis, muscular dystrophy, and tumors, but they couldn't identify the disorder. Christopher was then taken to the head of pediatric neurology at UCLA, who diagnosed "tremors of unknown origin." "Christopher's EEG was normal, even during reactions, so his doctor said it was either something occurring in the deeper part of the brain [subcortical] or something different altogether," said Kevin McIvers. "He told us their best guess was that there was something dreadful going on neurologically. We would just have to wait and see, and eventually it would get worse and the root of the problem would show itself." The doctors tried drugs to suppress the central nervous system, but they didn't stop the tremors. "So we were waiting, just watching our son have all these terrible episodes, forty to fifty a day, and not knowing the cause." Because Christopher had been perfectly healthy until this point, Jocelyn's father, a building contractor, suggested they consider as a possible cause of the problem the new carpet they had installed in their Santa Bar before the onset of the tremors. So Kevin and Jocelyn, both lawyers, cautiously approached the carpet manufacturer for information. "Being a trial lawyer, I'm very aware of some of the shenanigans that can go on over semantics, so I was very careful how I worded my questions to the industry. I wanted the correct information for my

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son's benefit. I asked specifically, 'I don't want to know if the industry believes that carpet can cause problems, or if it's scientifically documented or anything like that. Just tell me, please, has anyone ever complained or claimed that they have had a neurological or neuromuscular reaction of any kind to carpet?' And the answer was, 'No. We've never heard ot it.'" The manufacturer followed up their call with a letter a month later: "You reported that your 11-month-old son has been experiencing some allergy-type symptoms since your new carpeting was installed," the July 18, 1991 letter stated. "We have not heard of any reactions similar to what you describe." (1) Christopher's tremors seemed to lessen when they were away from home, so, on the advice of their doctors, the McIverses consulted with an indoor air consultant. He advised them to steam-clean the carpet several times and bake out the house by shutting the windows and heating it to speed up the offgassing of volatile organic compounds (VOCs), then airing it for several days. They went through this routine twice, while living at Jocelyn's mother's house for six weeks. During that time Christopher's tremors had decreased. "So we returned to our home and kept all the windows open. The tremors got worse again but were still less frequent than before," said Jocelyn. That October the CBS news program Street Stories did a segment about Anderson Laboratories in Dedham, Massachusetts. At the request of a number of people, the lab had tested certain carpet samples for biological effects and came up with some disturbing findings. Using a standard testing method (ASTM-E981), Rosalind Anderson, Ph.D., found that air blown across the samples was causing severe respiratory and neurological/neuromuscular abnormalities and death in mice. (2, 3) The television script highlighted the health problems several families had experienced as a result of new carpeting. The McIverses saw the program. "So we had our carpet tested and sure enough, the mice were rolling over and shaking just like our son did," said Jocelyn. "We were horrified." The McIverses immediately removed the carpet and pad, scraped off the adhesive, washed down the entire house, baked it out again, aired it, and moved back in December of 1992. "Since December Christopher's tremors have entirely stopped," Kevin reports. The more Kevin and Jocelyn learned about the history of toxic carpet problems [see "Carpet Cover-Up Time Line" in this issue], the angrier

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they became. "We felt utterly betrayed. The manufacturer we had contacted was a major player front and center in the carpet industry and had people on the board of the Carpet and Rug Institute [CRI]," said Kevin. "Long before we ever called them, the CRI was very much involved in the episode where over a thousand complaints were reported by EPA workers made ill by new carpet in the EPA headquarters building. (4) I know, at a minimum, they were well aware of neurological complaints and very serious pulmonary complaints from a number of EPA workers." The incident in Washington had brought CRI into the Carpet Policy Dialogue with the Environmental Protection Agency (EPA) and the Consumer Product Safety Commission (CPSC), as working agreement between government and industry that was restricted to studying total volatile organic compounds and not health effects. The dialogue had been underway nearly a year, and the carpet industry was already studying ways to reduce total VOCs in carpet and carpet-related products, when Kevin McIvers called to ask about carpet concerns. (4, 5) CPSC had received hundreds of complaints about carpet. In a memorandum attached to a CPSC report obtained by the McIverses, dated nearly a year before they had bought their carpet, CPSC presented the results of their evaluation of complaints from 206 households about respiratory and central nervous system problems attributed to carpet and stated, "We are continuing to interact with the carpet industry and will provide them with copies of these tudies for their information." (6) Two months before Kevin McIvers called the manufacturer of their carpet for help, the New York Attorney General, Robert Abrams, had petitioned CPSC to require warning labels on carpets. (7) Because of the large number of carpet complaints, the attorneys general of twenty-five other states signed the petition as well. (9) CPSC refused to even consider their petition. (7, 8, 9) According to Kevin, numerous lawsuits had by then been filed against the carpet industry by individuals injured by carpet: "The industry representative that I spoke to repeatedly on the phone when I was looking for information on carpet was very compassionate and always asked about Christopher's health. It wouldn't surprise me at all if that guy sincerely believed carpet couldn't be a problem and there hadn't been any history of complaints, and simply had been misinformed by upper management. But somewhere in the corporation someone has been making decisions about what information gets to the public, and it is a real dishonest, hideous decision that is being made. The direct result was that our son continued to live with the

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toxic carpet for another year and a half, continuing to have thousands of tremors, while my wife and I spent most of our time with a knot in our stomachs, wondering when he would go further downhill. And that's just unconscionable." Although the tremors have stopped, testing on Christopher McIvers shows that he has immune system damage consistent with chemicals exposure, including autoantibodies (indicating that the body's immune system has mistakenly identified its own tissues or cellular components as foreign and has directed antibodies against them) to the myelin in his nervous system -- a sign that nerve tissue damage has occurred. (10) His mother reflects: "I was extremely careful about what my baby came into contact with. Organic chemical-free food and everything. Even though I know better, I still feel guilty about the carpet. I mean, I picked it out myself -- beautiful and expensive. I wanted the house to be so nice, and then I poisoned my son with it. Looking back at all this, we wished we had just ripped it out, but they assured us the carpet wastn't the cause, and we just believed them -which was really stupid, but we did." "The general public needs to be aware," says Kevin McIvers, "that in spite of two congressional hearings that have been held regarding the toxic carpet issue (October 1, 1992, and June 11, 1993), the industry is still giving a very imbalanced picture to anyone who asks, and that's a great disservice." At the October hearing, chaired by Sen. Joseph Lieberman (D-CT), Dr. Anderson reported that three of thirteen random, new carpet samples caused adverse health effects. EPA responded that the health hazard reported from 25 percent of carpets is not enough to require a warning label on all carpeting and that it would be "unfair" to do so. EPA was instructed by the congressional panel to replicate Anderson's tests. (4, 11) "The carpet industry has mounted a massively deceptive merchandising campaign that intentionally misleads the public by implying that all carpets with the green tag have met safety standards," say New York Attorney General Robert Abrams. "First of all, there are no such recognized standards of safety. CRI has sets its own arbitrary standards. Secondly, CRI's testing program is completely inadequate because it measure only a small percentage of the chemicals emitted from carpets. Finally, a manufacturer can get a green tag for an entire product line simply by having one small piece of carpet tested once a year."

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One of the carpets to pass the green tag testing is associated with disabling the members of the Charles Fitzgerald family of West Friendship, Maryland, who were exposed to it in their lighting store in 1992. When tested by Anderson Labs, the Fitzgeralds' carpet caused gross nervous system abnormalities in mice. It was then analyzed by another independent lab, at the University of Pittsburgh, with results that duplicated those of Anderson. EPA and CPSC lent their names to the green tag program, and they have increasingly come under fire for not fulfilling their role as protectors of the public interest. (4, 12) "The Consumer Product Safety Commission receives hundreds of complaints and inquiries each year about the adverse health effects associated with the materials used to make carpet," said Abrams. "Yet the government has chosen to sweep this problem under the rug by ignoring the public's health concerns as well as my request to disseminate meaningful information about potential carpet hazards." When EPA investigated carpet complaints from its headquarters building, it published a report showing a positive correlation between EPA worker complaints and new carpet, according to an EPA Senior Scientist, Bill Hirzy. (4, 13, 14) Despite its own study, and the removal of 27,000 square yards of carpet from the headquarters building in 1989, EPA published a public information brochure, "Indoor Air Quality and New Carpet: What You Should Know," which states, "Limited research to date has found no links between adverse health effects and the levels of chemicals emitted by new carpet." (15) There was no scientific basis for the brochure's statement, admitted Bob Axelrad of EPA during an interview on CBS "Evening News." (15) He went on to say that the brochure was formulated during the Carpet Policy Dialogue and constituted a compromise with industry. (16) "My sense is that EPA is avoiding the issue because they don't want to participate in a financial massacre of industry," said Hirzy, speaking as president of EPA Union Local 2050. "And there is a certain amount of investment in reputation by peopel in EPA who early on said carpet wasn't a problem. Industry won't publicly admit there's a problem because of the liability. In the meantime, how many lives have been and will be devastated?" "To date we have tested over 400 carpet samples," said Dr. Rosalind Anderson. "Of the carpets sent in by persons with health complaints,

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at least 90 percent have shown severe neurological effects. Approximately 25 percent of new carpets, ones that have never been installed, have been deadly. We've found death in mice from a new sample just sever square inches at room temperature." In a side-by-side test conducted at Anderson Labs, EPA replicated Anderson's work. "The EPA people even picked out a new carpet sample for the test run themselves, so there couldn't be any accusation that Dr. Anderson deliberately picked a contaminated sample," said Kevin McIvers. The side-by-side test was videotaped with Anthony Pollina, aide to Rep. Bernard Sanders (I-VT), as a witness. "EPA found the same neurological effects and death in mice as did Dr. Anderson," said Pollina. Then, when EPA returned to its own labs, "instead of duplicating what Rosalind Anderson did, as they were charged to do at the October '92 carpet hearing, EPA created its own protocol," said Hirzy. "They replicated Anderson's results at her lab, but when EPA scientists used bottled air in their own lab and bubbled it through water to add humidity, the humidity changed the result. What they found was that humidity reduced the toxicity, so apparently whatever the toxins are, they are soluble in water at low levels." After Anderson Labs changed their protocol to humidify the air in the same manner as EPA had done," we found it removed the toxic effect as well," said Anderson. When they passed air over a toxic carpet sample and bubbled it through water, the air was not toxic to the mice. So they took that water and exposed the mice to it in the form of a mist. "Lo and behold, the toxic effect had been removed from the air and put into the water. We were now seeing the same enurotoxic effects from the water, including death, said Anderson. "We found the same results when we injected the water into the muscles of the mice. We used appropriate control mice, which were totally unaffected by water that wasn't exposed to the carpet air. So something very bad was coming off that carpet, which can be trapped in water. It's really an exciting finding, actually. All that needs to be done now if for someone to analyze the water and see what the chemicals are." "It cries out for follow-up," said Hirzy. "what is in the water that's killing mice? The chemicals in the carpet have already been isolated by the water, so all you have to do is test the water. But it's a terribly expensive process, so a private lab couldn't fund it on its own."

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"We did not independently replicate the severe toxicity described by Anderson Laboratories," reported EPA at the carpet hearing held on June 11, 1993, before the House Subcommittee on Environment, Energy, and Natural Resources. (17) The hearing was held to discuss EPA's findings, according to Congressman Sanders' aid Pollina. But instead of talking about the positive implications of its discovery, EPA simply denied replicating Anderson's tests and then reiterated the stance taken in its brochure: "We do not have a sound basis for concluding exposure to carpet emissions presents a health risk." (17) Under corss-examination, EPA admitted having changed the protocol and having had problems monitoring humidity. (11, 18, 19) "EPA's presentation before Congress was confusing at best," said New York Environmental Protection Bureau Assistant Attorney General Gail Suchman. "It hasn't answered our request, which is to get the right information out to the public." Congressman Sanders and Subcommittee Chairman Mike Synar (D-OK) were especially critical of EPA for "dragging its heels." Said Sanders: "I am extremely disturbed that after months of promises to get to work on this issue, the EPA has failed to accurately replicate Dr. Anderson's tests, has failed to talk to a single doctor whose patients have suffered ill health effects from carpeting, and has failed to make any serious effort to identify which chemicals are causing the problem." (20) At the hearing Ron VanGelderen, president of the Carpet and Rug Institute, testified that current research suggests that "carpet itself does not adversely affect public health." (21) Pollina reports that under corss-examination "the three people from industry were kind of hedging and giving conflicting answers and then the chairman basically said, hey, wait a minute, you're under oath. There can be only one answer to this question. Either people are getting sick from carpet or they're not. The industry guys kind of looked at each other, and then one of them said something to the effect of, well, if you consider an allergy-like reaction to be an adverse health effect, then yes, I suppose you could say carpet causes problems for some sensitive people." "One of the best things that happended at the hearing," Pollina adds, "was industry admiting under oath, that yes, carpet can cause problems in some people. The term allergy-like can mean just about anything, but at least they admitted that carpet could be the cause of it."

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The same day of the hearing, CRI issued a press release stating: "The scientific evidence overwhelmingly demonstrates that carpet itself does not adversely affect public health." (22) VanGelderen's testimony cited EPA and CPSC as not finding scientific evidence to warrant concern over carpet. He blasted Anderson's test method, calling it "irrelevant to the debate on indoor air quality." (21) Yet just six days before Anderson went public with her test findings, CPSC had distributed a report recommending the use of the same testing method (ASTM-E981) for carpet that Anderson was using. The report analyzed the final results of a carpet testing study conducted by interagency agreement. It warned that measuring total VOCs, the measure used by the carpet industry's green tag program, is "probably not adequate as a standard to protect health." (23) The health effects of the many chemicals the scientists found offgassing from carpet are for the most part unknown, the CPSC report stated. It then recommended the test founded by Yves Alarie, Ph.D., the ASTM-E981, calling it a "standard method" that "could be used to make reasonable predictions of effects in humans over a wide range of concentrations." (23). "Dr. Alarie of the University of Pittsburgh was hired to develop the ASTM-E981 in the 1960s by the U.S. Department of Defense to test for the potency of nerve gases to be used by the U.S. Army in Vietnam for cleaning out tunnels," said Mark Goldman, manager of Anderson Labs. "It was later used by the pesticide industry. It came from the camp of the manufacturers frankly." Alarie, who had been hired by CRI in the past, testified at the June hearing that when Anderson first released her test results, VanGelderen asked him to verify her test protocol. After Alarie visited her lab and reported that "her description of the effects observed was correct and her experimental design was valid," VanGelderen hired Alarie to see if he could replicate her work for CRI. (24) Alarie testified that he replicated her results four time: "Her results are perfectly reproducible in my laboratory." (20) In his testimony Alarie expressed concern about the many rumors being spread to try to discredit Anderson's work: "As results of neurotoxic effects and death were reported by Dr. Anderson to be due to volatile emissions from carpets, rumors were circulated that these effects were due to the exposure method -- i.e., placing the mice in restraining tubes as described in the ASTM-E981 method." Alarie

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conducted additional testing over even longer periods of time "in order to satisfy those rumor generators," and proved the restraints were absolutely not a problem. (24) A CRI press release issued on the day of the hearing quoted one of its experts regarding the restraint: "[The tests] are tantamount to lacing up a human being in a strait jacket and repeatedly choking him for two days." (22) "Cretins will continue to spread their rumors, and there is not much I can do about it," testified Alarie at the hearing. "This method ASTM-E981 has been used all over the owrld and I have never received a complaint from a user of it that the method itself produces neurotoxic effects." (24) Congressman Sanders went on record agreeing with Chairman Synar, whom he quoted as saying that the testimony and evidence presented at the hearing "remind us of EPA's past failures to protect indoor air quality ... After years of complaints, consumers still have difficulty in getting straight answers to questions about chemical risks if they ask carpet retailers, or frankly, even if they ask government officials." (20) One week after the hearing, EPA's designated carpet spokesperson was asked about the side-by-side EPA replication of Anderson's tests at her lab. "There was no side-by-side," said EPA's Charles Auer, director of the Chemical Control Division. He said the EPA had observed Anderson's testing but had not replicated it." (25) "We submitted the videotape of the side-by-side test to Congress as part of our testimony," said Mark Goldman. "It's part of the Congressional Record." EPA plans workshops this fall with industry and Anderson Laboratories to discuss whether to pursue the test results any further. "That's just a government tactic for delay," said EPA Union President Hirzy. "It's designed to keep the industry covered. There are some hot leads here. We have human evidence that people are getting respiratory, neurological, and immunological injury from carpet. If I were industry, I'd be scurrying around behind the scenes trying to find out what's in the air and the water that's killing those critters, and then working to reduce it. And if EPA can keep things stalled up by pushing for workshops and time-consuming quote 'peer reviews,' and all sorts of delay mechanisms, that mutes out a lot of lawsuits."

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Congressman Sanders' office wants action. "Number one," said Pllina, "We'd like to see EPA sit down and have some serious talks with a group of doctors who can help them make the connection to human health. Number two: We'd like to see industry not just come up with a good warning label but also suspend the green tag program. Number three: The water that trapped the carpet fumes must be tested to find what the toxins are so the manufacturing process can be changed." CRI has agreed to work on a new additional warning label with the New York attorney general's office, which recently published a report: "Carpet and Indoor Air: What You Should Know." The report counteracts the EPA brochure by warning about the possible hazards of carpet and calling for the suspension of the green tag program. "Our focus has been to get the right information to the public. EPA and CPSC have been totally unresponsive to all of our requests to get that information out to the public, which is why we wrote the report," stated Gail Suchman of the New York attorney general's office. "We are willing to work with CRI to establish a new consumer information program, including some sort of warning or informational campaign so the public can make an informed decision." Congressman Sander's office has been in touch with a number of doctors from a variety of specialties who all have one thing in common. They are seeing an increase in chemical injuries, including cases where people have been made ill by carpet. "Some of the dotors are in the process of drafting short statements to present to Congressman Sanders," said Pollina. "The statements will say in effect that in recent years toxic injuries have become more common, and as that has happened, their ability to diagnose chemical injuries has improved. Further, based on what they are seeing and the diagnostic procedures they are using, including objective neurological testing, patient history and a process of elimination, it is their medical opinion that their patients, both children and adults, are being affected by the chemicals offgassing from carpets and that there needs to be more research." Sander's staff hopes that EPA and industry will meet with some of these doctors in the near future. Pollina added, "The carpet industry has committed themselves to develop a whole array of information for consumers, retailers, and installers, which we expect to be an improvement over the earlier information they were circulating. They've also stated they will research the problem. We'll see what happens. Time will tell."

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The following states have all signed the New York attorney general's petition to CPSC, which would require warning labels on carpet and an adequate public information campaign: Alabama, Arizona, Connecticut, Florida, Iowa, Kansas, Massachusetts, Minnesota, Missouri, Nevada, New Jersey, New Mexico, North Dakota, Ohio, Oklahoma, Oregon, Pennsylvania, South Dakota, Tennessee, Texas, Utah, Vermont, Washington, West Virginia, and Wisconsin. To voice concerns over carpet safety, contact your own state attorney general's office and ask the staff to contact the New York attorney general's office. Write your state senators and representatives at: [your senator] Hart Senate Office Building Washington, DC 20510 [your representative] Rayburn House Office Building Washington, DC 20515 For more information on the hazards of carpet, consult: "Carpet and Indoor Air: What You Should Know," authored by four state attorneys general, June 1993, available free from: New York State Attorney General 120 Broadway New York, NY 10271 Citizens for Safe Carpet P.O. Box 39344 Cincinnati, OH 45239 (513) 385-1111 Glen and Sharon Beebe, authors of "Toxic Carpet III," provide a support group and information exchange. Environmental Access Research Network (EARN) 315 W. 7th Avenue Sisseton, SD 59645 For a list of carpet-related articles, studies, and reports available from EARN's photocopying service, send $1.00 and request "Carpet List." EPA Union NFFE 2050 P.O. Box 76082 Washington, DC 20013 (202) 260-2383

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Carpet Cover-Up Time Line 1980 ---First documented case of people becoming sick after carpet installation. Glenn and Sharon Beebe become ill from carpet installation at their business building in Cincinnati. (26) They have now documented several thousand cases of carpet-related complaints dating back to 1972. 1986 ---The Beebes send thousands of notices to industry, medical personnel, government agencies, and consumers. (26) October 1987 -----------The Environmental Protection Agency (EPA) begins carpet installation in its Waterside Mall headquarters building, and employees complain of ill health from the fumes. A total of 1,141 complaints are received. To date, at least twenty people are still unable to work in the building. (4, 27, 28) May 1988 -------Over 100 EPA emplyees hold a rally in front of EPA headquarters to demonstrate their concern over air quality, the toxic carpet in their building, and EPA's refusal to acknowledge the problem and take action. (4) August 1988 ----------EPA establishes a policy of not using carpet containing the chemical 4-phenylcyclohexene (4-PC) in headquarters facilities and starts accommodating injured employees. Officially denies they are "real" injuries and claims that carpet poses no problems. (4) May 1989 -------EPA is involved in a joint project with CPSC to study carpet complaints. EPA management tells EPA union they will not use data from their investigation into the air quality at the headquarters building because they fear lawsuits. (4)

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September 1989 -------------As a result of its indoor air quality study, EPA removes the carpet from its headquarters. A total of 27,000 square yards are replaced. (4, 13, 14) September 1989 -------------"The freshly manufactured carpet clearly caused the initial illness," EPA's Director of Health and Safety tells "Washington Times." EPA management removes him from that job within a few weeks. March 1990 ---------EPA management tells union "off the record" that because the union's petition to EPA to start testing and regulating carpet emissions could potentially cost the carpet industry "billions of dollars," it will not grant the petition. (4) April 1990 ---------EPA publicly denies the union petition. EPA's Indoor Air Division director privately tells attendees at an indoor air conference in Virginia that "everyone knows the new carpet made people sick," while publicly denying the same. (4) June 1990 --------The EPA union files suit over petition denial. Court grants EPA's motion to kill the suit. (4) August 13, 1990 --------------The Consumer Product Safety Commission (CPSC) distributes a memorandum regarding the evaluation of carpet complaints from 206 households. The memorandum states that they have been interacting with industry on the topic and will continue to do so. (6) August 21, 1990 --------------EPA convenes a Carpet Policy Dialogue with floor-covering industries (including CRI) and other government agencies. The dialogue is restricted to studying only total volatile organic compound (VOC) emissions and not health effects. (4, 5) April 1991

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---------A consumer alert, "Chemicals in New Carpets Pose Potential Health Hazards," is issued by New York Attorney General Robert Abrams. (29) April 10, 1991 -------------New York Attorney General Robert Abrams petitions CPSC to require consumer warning labels on carpet. (7) In time twenty-five other state attorneys general sign the petition. (9) June 1991 --------EPA publishes the result of the air quality investigation into worker complaints in its headquarters building. Volume 4 establishes a link between adverse effects and carpet. (4, 12, 28) June 1991 --------Kevin McIvers calls Monsanto carpet manufacturer when his ten-month-old son, Christopher, develops tremors and has to be hospitalized five days after carpet installation. Kevin reports being told they had never heard of that type of complaint before and that it could not be caused by the carpet. September 6, 1991 ----------------Carpet Policy Dialogue is concluded. A public information brochure has been prepared, and industry has agreed to take steps to measure VOC emissions in their products and to take steps to reduce them. (4, 5) October 1991 -----------CPSC refuses to docket the New York attorney general's petition to require warning labels (4, 8) March 1992 ---------EPA brochure is published, claiming that no links have been found between carpet and ill health. (15) May 1992 -------The carpet that disabled the Fitzgerald family of West Friendship, Maryland, and killed several mice with the ASTM-E981 testing at Anderson Laboratories (Dedham, Mass.) passes the carpet industry's

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testing program and qualifies for a Green Tag. (30) July 17, 1992 ------------CRI announces its Green Tag program in a press release. (31) The program tests only one carpet sample from each carpet type once a year -- a test based only on total VOC emissions, not biological health effects. EPA and CPSC lend their names to the program. (4, 31) August 13, 1992 --------------A CPSC report states that measuring total VOCs is "probably not adequate as a standard to protect health" and recommends the ASTM-E981, developed by Dr. Yves Alarie. (23) August 18, 1992 --------------After presenting their findings to EPA management and industry and receiving no response, Anderson Labs goes public with test results of carpet fumes killing mice, using the ASTM-E981 testing method. (2) August 21, 1992 --------------CRI has Dr. Alarie check out Dr. Rosalind Anderson's testing technique. Dr. Alarie reports that it is scientifically valid. CRI hires him to replicate Anderson's tests in his labs. He finds the same neurotoxic results four times. (24) September 1992 -------------The EPA union files a complaint with the Federal Trade Commission and EPA's Indoor Air Division, claiming the Green Tag program to be fraudulent and a danger to public health. (4) October 1, 1992 --------------Sen. Joseph Lieberman (D-CT) holds carpet hearings. Dr. Anderson says 3 of 13 random, new carpet samples tested caused adverse health effects. EPA replies that the health hazard reported from 25 percent of carpets is not enough to require a warning label on all carpeting and that "it would be unfair" to do so. EPA is given a charge to exactly replicate Anderson's test exactly. (4, 11) October 29, 1992 ----------------

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CBS "Evening News" and "Street Stories" air segments on problem carpet, Anderson's findings, and the Fitzgerald story. When questioned about EPA's carpet brochure, which states that research has found no link betwen adverse health effects and carpets, EPA's Bob Axelrad admits there is no scientific basis for that statement and that the brochure represents a compromise with industry. (16) November 6, 1992 ---------------Testing of McIvers' carpet shows in mice the same type of tremors and neuromuscular reactions their infant son had. They remove carpet, and their son's reactions stop. (32) January 1993 -----------EPA is videotaped replicating Anderson's test results in a side-by-side test at Anderson Labs with Rep. Bernard Sanders' aide, Anthony Pollina, as a witness. The mice have respiratory and neuromuscular reactions, and some die. (11) January 27, 1993 ---------------Blood testing of Christopher McIvers shows immune system damage consistent with chemical injury. (10) February 1993 ------------Anderson's paper "Toxic Emissions from Carpets" is presented at an international conference and accepted for publication in a peer-reviewed journal. (33) March 1993 ---------In its own lab EPA changes Anderson's protocol instead of replicating the test. April 1993 ---------CRI distributes a letter to members of the carpet industry, including retailers, assuring them that "extensive research" by EPA and others failed to discover any link between carpet and ill health. Letter provides sample statements for retailers to use in assuring the public that carpet is safe and to cast doubt on Anderson's testing. (34) June 1993

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--------Four state attorneys general (N.Y., Vt., Conn., and Oreg.) prepare a report, "Carpet and Indoor Air: What You Should Know," which warns the public about the misleading nature of the green tag program. The report is sent to CRI and carpet manufacturers along with a request that they withdraw the green tag program. (35) June 11, 1993 ------------A second carpet hearing is held before Congress regarding EPA's work. EPA testimony states that its scientists were unable to replicate Anderson's findings. Anderson submits the videotape showing EPA's replication of her findings in the side-by-side test. EPA admits having changed the protocol in its own lab. Under cross-examination, industry admits that some people may experience adverse effects from carpet, and the Carpet and Rug Institute agrees to work on a new additional label with the New York attorney general's office. CRI also agrees to fund more research into carpet and work with EPA on it. The same day, CRI issues a press release stating that "carpet itself does not adversely affect public health." (11, 17, 18, 19, 22, 36) June 18, 1993 ------------Contradicting the videotape presented at the hearing, EPA's Charles Auer, director of the Chemical Control Division and current official spokesperson to the public on carpet, states when questioned about the result of EPA's side-by-side test with Dr. Anderson: "We never ran a side-by-side." (25) July 4, 1993 -----------When Dr. Anderson presents two papers at "Indoor Air '93, the Sixth International Conference on Indoor Air Quality and Climate" in Helsinki, Finland, she is approached by many researchers from around the world who tell her that they are seeing similar carpet-related health problems that this is a worldwide dilemma. (18)

Bill Hirzy on Resolving Toxic Carpet Controversy Bill Hirzy, Ph.D., speaking as president of EPA Union Local 2050, believes the carpet issue could be resolved in a rational way. He states: "Carpet is a reasonable and important part of our society. There are a lot of jobs in it and there is a lot of economic value in

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keeping the industry going. Certainly, nobody wants to see the industry destroyed. There is no question that the industry doesn't deliberately want to hurt people. Of course they don't. But they do have legitimate concern that their stockholders will lose a lot of money, and they may not survive if there is unlimited liability. What has to happen is that industry, EPA, and CPSC must own up to past problems and take steps to prevent future ones in an honest way. "I think there is a way to address the issue and warn the public without bankrupting the industry. A conference needs to be held with the possible plaintiffs, industry, a regulatory agency, and a public-advocacy-type group. They need to sit down and hammer out ways to compensate people who have been injured so far and begin a very aggressive and forthright program of warning consumers that there appear to be some individuals who, when exposed to certain lots of carpeting, are in danger of profound adverse health effects. "This conference would need to come to an agreement made binding by a legislative or judicial finding that limits the liabiilty of industry, compensates those already injured in a timely manner, and protects the industry from future liability once they've come clean and have issued accurate public service announcements and adequate warning labels on each roll of carpet. Once industry has honestly and forthrightly informed the public of the risk, then by purchasing their product, the public is consenting to take on that risk, and the industry should be free of liability. Similar to the warning label on a cigarette package. But right now the pubic is being stonewalled by a bunch of lies from industry and from the EPA, so they don't even have the opportunity to make informed decisions."

What Do You Do If You Want Carpet? Not all carpets are problem carpets. Anderson Labs has found no toxic effects in about three-quarters of the new carpets tested (ones that have never been installed). (18) For consumers the issue is knowing whether the carpet they want will pose a health risk. There is no easy answer to that question because the chemicals causing problem carpets has not yet been determined. If you wish to purchase carpeting, you can take steps to minimize total exposure to the chemicals found in it. But while reducing total volatile organic compound (VOC) exposure will lessen the amount of toxins the body has to deal with, it may not be an adequate measure for health protection, according to a Consumer Product Safety

36

Commission (CPSC) report. (23) "Based on what's happening out there and what we're seeing with our carpet testing," said Dr. Rosalind Anderson of Anderson Labs in a telephone interview, "I think we have to conclude that there must be some ongoing process that we don't know about yet, continuing to generate fumes over times. Something is breaking down very slowly and consistently and whatever it breaks down to is bad news. It's probably some combination of chemicals forming new compounds that we're not expecting." A consumer alert put out in 1991 by New York Attorney General Robert Abrams advises caution: "People who smoke, have allergies, or suffer from respiratory disorders may be more prone to experiencing symptoms when exposed to new carpeting. Further, the chemicals pose a greater risk to small children. Pregnant women should also avoid these fumes, as they may be harmful to the child [in the womb." (29) The following are suggestions for dealing with the problem-carpet question. No guarantee of safety is implied or intended. People's sensitivities vary greatly, so caution and common sense are advised. 1) To have your sample tested for biological health effects before you install it, send a sample to Anderson Laboratories, Inc. (802) 295-7344. The Homeowner's Test costs $350.00. 2) Negotiate with your carpet supplier an advance signed agreement that should anyone in your household experience adverse symptoms after installation, the carpet will be removed free of charge immediately upon request. 3) Plan to have your carpet installed during a time of year when it's warm enough to keep the windows open. 4) Have the carpet installed while you are on vacation, or make arrangements to stay away from home for several days during and after installation. Ask the carpet installer to unroll the carpet and air it in a well-ventilated area for seventy-two hours before bringing it into your home. Run exhaust fans and keep windows open during installation. EPA and CPSC recommend leaving your windows open several days afterward. Bear in mind, however, that if it is a "problem carpet," according to health reports and testing at Anderson Labs, no amount of ventilation will solve the problem. An interagency carpet testing report warns: "Unfortunately, this strategy might not have a major impact on the emissions of compounds such as formaldehyde, 4-PC, and BHT, which do not decay rapidly and

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which are possibly more important with respect to health effects." (23) 5) According to Hendricksen Naturlich Flooring Interiors (see below), some people who have reacted adversely to synthetic carpet have fared better with woven wool carpet. Nearly all wool yarn, however, is treated with pesticide mothproofing in the manufacturing process. Naturlich recommends taking a samle home and testing it for adverse reactions before buying it. If you are sickened by inhaling fumes from a small sample, you might regret covering an entire room or house with it. Use caution and common sense. Woven carpets use far less latex than other carpet types because the weaving process avoids the heavy latex used for gluing the secondary backing to the primary backing. In general, woven wool carpets have fewer total volatile offgassing compounds than the average synthetic carpet with a glued back. Naturlich and Bremworth Carpet (see below) are both looking into sources for providing 100 percent organic wool carpet without mothproofing. As soon as this becomes available, "Informed Consent" will report on it. [Contact E.A.R.N. for the latest information.] 6) According to tests by the carpet industry, synthetic carpet pads and cushions commonly used under carpet have a VOC level of 1.24 (EPA's flooring guidelines say no product should have VOC levels of .6 or more). (37) Low VOC synthetic jute padding, constructed without glue, is available from Hendricksen Naturlich Flooring Interiors. 7) Tacking the carpet down, instead of gluing it, will eliminate at least one potent source of offgassing VOCs. 8) If you wish to use adhesives, use only a low VOC emitting product. "There are no standards for VOCs, but EPA flooring guidelines say that no product should have VOC levels of .6 or more," according to Frank O'Neill, editor of Carpet and Rug Industry. "The adhesives used in direct glue down installations present a much greater air pollution problem [than carpet itself, which generally falls below the .6 VOC level advocated by EPA], with a VOC emission rate of 88.6" (37) Among the low VOC emitting carpet adhesives are AFM Carpet Adhesive, available from N.E.E.D.S. (see below) and Envirotec Adhesive and Auro Adhesive, both available from Hendricksen Naturlich Flooring Interiors. 9) Steam-cleaning is not a solution for toxic carpets according to Dr. Anderson. The moisture seems to help for a few days, but as soon

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as the carpet dries, the problem comes back. 10) The least-toxic forms of flooring available are tile, true linoleum, and hardwood. For more information on pesticide-free hardwood and true linoleum sources, refer to the Home and Office Resoruce Forum in this issue. 11) Your home or office should have adequate ventilation on an ongoing basis. Airpurifiers can help reduce total VOCs. Carbon filters are avialable from N.E.E.D.S. "NonScents," a nontoxic molecular adsorber for air purification is available form The Dasun Co. "The Molecular Adsorber" is available from CYA Products Inc. The following are some of the companies that sell woven wool carpet, low VOC emitting carpet adhesive, air filters, and purifiers: Bremworth Carpets 1940 Olivera Rd. Suite C Concord, CA 94520 (800) 227-3408 woven wool carpet, jute backing or polypropylene backing The Dasun Company P.O. Box 668 Escondido, CA 92033 (800) 433-8929 "NonScents" molecular adsorber Desso Carpet P.O. Box 1351 Wayne, PA 19087 (800) 368-1515 woven wool carpet, just or polypropylene backing (further surface treatment is optional) Foreign Accent 2825E Boradbent Pkwy. N.E. Albuquerque, NM 87107 (505) 344-4833 woven wool area rugs Gordon T. Sands Ltd. 40 Torbay Rd. Markham, Ontario L3R 1G6 (416) 475-6380

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woven wool carpet, commercial felt carpet pad Helios Carpet P.O. Box 1928 Calhoun, Georgia 30703 (800) 843-5138 woven wool carpet Hendricksen Naturlich Flooring Interiors 6761 Sebastopol Ave., Suite 7 Sebastopol, CA 95472-3805 (707) 829-3959 natural wool carpet, jute padding constructed without glue, Auro Adhesive (contains no petrochemicals), Envirotec Adhesive, true linoleum H & I Carpet Corp. 115 Dupont St. Toronto, Ontario M5R 1V4 (416) 961-6891 woven wool carpet N.E.E.D.S. 527 Charles Ave. Syracuse, NY 13209 (800) 634-1380 AFM Carpet Adhesive (low VOC carpet adhesive), air filters CYA Products Inc. 211 Robbins Lane Syosset, NY 11791 (516) 681-9394

References

1. Letter to Jocelyn McIvers from Lori Grant, Monsanto Company, July 18, 1991. 2. "Carpet Offgassing and Lethal Effects on Mice." Anderson Laboratories press release, August 18, 1992. 3. CBS "Street Stories," October 29, 1992. Transcript by Burrelle's Information Services (pp. 17-23).

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4. "Chronology -- EPA and Its Professionals, Union Involvement with Carpet." Compiled by Bill Hirzy, Ph.D., EPA Senior Scientist, president of EPA Union Local 2050 (1992). 5. "Carpet Policy Dialogue Executive Summary and Compendium Report." Edited by R.W. Leukrothe, Jr., Office of Toxic Substances, U.S. EPA, Washington, D.C., September 27, 1991. 6. Memorandum from Susan E. Womble, Project Manage, CPSC Chemical Hazards Program: Evaluation of Complaints Associated with the Installation of New Carpet, August 13, 1990. 7. New York State Department of Law; Abrams, R.; et al. Petition to U.S. CPSC: "To Establish Mandatory Safety Standards for Rugs, Carpets, and Carpet Systems, and to Conduct Research to Determine Additional Safety Standards," April 10, 1991. 8. Letter from Jerry G. Thorn, Office of the General Counsel, U.S. CPSC, to Robert Abrams, Attorney General of the State of New York. Re: Response to Robert Abrams's April 10, 1991, Request for CPSC to Issue a Safety Standard for Carpet Systems, December 23, 1991. 9. Request form Dan Morales, Texas Attorney General, to Jerry Thorn, General Counsel of U.S. CPSC on Behalf of Attorneys General from 25 States that CPSC Docket the New York Attorney General's April 1991 Petition Regarding Carpet Safety Standards, December 23, 1991. 10. Testing results for Christopher McIvers from Immunosciences Lab., Inc., January 27, 1993. 11. Telephone interview with Anthony Pollina, Rep. Bernard Sanders's aide, June 17, 1993. 12. New York State Department of Law and Abrams, R. "Abrams calls Green Seal Program on the Carpet for Misleading Safety Claims." Press release, June 10, 1993. 13. "Indoor Air quality and Work Environment Study: EPA Headquarters Buildings," "Vol. 4: Multivariate Statistical Analysis of Health, Comfort, and Odor Perceptions as Related to Personal and Workplace Characteristics." (EPA Atmospheric Research and Exposure Assessment Laboratory, 21M-3004, June 1991). 14. Opening statement by Sen. Mike Synar, Chairman, Environment, Energy, and Natural Resources Subcommittee, Committee on Government

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Operations, U.S. House of Representatives. Re: carpet research, June 11, 1993. 15. "Indoor Air Quality and New Carpet--What You Should Know" (EPA/560/2-91/003, March 1992) 16. CBS "Evening News," October 29, 1992. Re: Toxic Carpet and Anderson Labs. Transcript by Burrelle's Information Services (pp. 7-9). 17. Testimony of Victor J. Kimm, Acting Assistant Administrator for Prevention, Pesticides and Toxic Substances, U.S. EPA, before the Committee on Government Operations, Subcommittee on Environment, Energy, and Natural Resources, U.S. House of Representatives. Re: carpet research, June 11, 1993. 18. Telephone interview with Rosalind Anderson, Ph.D., Anderson Labs, June 17, 1993. 19. Telephone interview with Bill Hirzy, Ph.D., Senior Scientist and President of EPA Union Local 2050, June 23, 1993. 20. "Carpet Industry Agrees to New Warning Labels at U.S. House Hearing, Sanders Criticizes Environmental Protection Agency for Dragging Its Heels." Press release from Rep. Bernard Sanders, June 11, 1993. 21. Testimony of Ronald E. VanGelderen, president of the Carpet and Rug Institute, before the Committee on Government Operations, Subcommittee on Environment, Energy, and Natural Resources, U.S. House of Representatives. Re: carpet research, June 11, 1993. 22. "CRI Calls for Meaningful Indoor Air Quality Research." Carpet and Rug Institute press release, June 11, 1993. 23. Consumer Product Safety Commission Memorandum and Final Report from Interagency Agreement on Volatile Organic Chemical Emissions from Carpets, (CPSC-IAG-90-1256, August 13, 1993, pp. 60-62). 24. Testimony of Yves Alarie before the Committee on Government Operations, Subcommittee on Environment, Energy, and Natural Resources, U.S. House of Representatives. Re: carpet research, June 11, 1993. 25. Telephone interview with Charles Auer, director of Chemical Control Division, EPA.

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26. Beebe, G. "Toxic Carpet III." Available from P.O. Box 39344, Cincinnati, OH 45239. 27. Statement of Sen. Patrick Leahy before the Committee on Government Operations, Subcommittee on Environment, Energy, and Natural Resources, U.S. House of Representatives. Re: carpet research, June 11, 1993. 28. Duehring, C. "Unraveling the Carpet-Toxicity Problem." "Environment and Health" (Winter 1993). 29. Abrams, R. "Consumer Alert: Chemicals in New CArpets Pose Potential Health Hazard," April 1991. 30. Letter to Charles Fitzgerald from K. Burton, Claims Manager, Mannington Carpets, Calhoun, Ga., May 27, 1992, with enclosure: "Environmental Chamber Test Report" from Air Quality Services, Inc., May 19, 1992. 31. "Carpet Industry Program Steps out Front on Indoor Air Quality: Labeling for Consumers Now Underway." Carpet and Rug Institute press release, July 17, 1992. 32. Carpet Screening Test Report (ALI Test No. 79) by Anderson Laboratories, Inc., for Kevin and Jocelyn McIvers, November 6, 1993. 33. Anderson, R.C. "Toxic Emissions from Carpets." Indoor Air '93, Proceedings of the 6th International Conference on indoor Air Quality and Climate 1:651-56 (1993). 34. "To the Carpet Industry: Typically Asked Questions and Suggested Responses" (Carpet and Rug Institute, "CArpet/Indoor Air Quality Fact Sheet," April 1993). 35. Abrams, R.; Amestoy, J.L.; et al. "Carpets and Indoor Air: What You Should Know." (June 1993). 36. Testimony of Rosalind Anderson before Committee on Government Operations, Subcommittee on Environment, Energy, and Natural Resources, U.S. House of Representatives. Re: carpet research, June 11, 1993. 37. O'Neill, F. "The Environment and the Carpet Industry." Carpet and Rug Industry. Pp. 33-34, (January 1991).

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**** NOTICE **** This series of articles is presented with the permission of the author, Cindy Duehring (per phone conversation on 10/4/95). For considerably more extensive documentation on the hazards of toxic carpeting and on other environmental/health hazards, please contact: Cindy Duehring Director of Research Environmental Access Research Network P.O. Box 1089 Minot, North Dakota 58702-1089 (701) 837-0161 **** NOTICE ****

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CARPET CONCERNS Part Three:

New Carpet Label Receives Mixed Reviews by Cindy Duehring "This is the age of the informed consumer," said Ron VanGelderen, president of the Carpet and Rug Institute (CRI) at a November 15, 1993 press conference heralding the unveiling of their new carpet label and consumer information program. CRI voluntarily agreed to teh new carpet label after months of intense negotiations with Congressman Bernard Sanders' office [I-VT], the Consumers Union, the Consumer Federation of America, and the state Attorneys General of New York, Connecticut, Oregon, and Vermont. The four attorneys general entered into direct negotiations with the carpet industry when the Consumer Products Safety Commission (CPSC) refused to even consider their petition, signed by a total of 26 state attorneys general, requesting mandatory health warning labels on carpet. "The Consumer Products Safety Commission receives hundreds of complaints and inquiries each year about the adverse health effects associated witht eh materials used to make carpets," said Connecticut Attorney General Richard Blumenthal. "The agency has ignored these health concerns and refused to take action. Under the revised industry program, consumers will at least be given information to provide a basic awareness of the possible health risks. Before this agreement, the industry's brochure said there was no reason for people to be concerned about carpet safety -- an absolute outrage. The program was misleading and meaningless. It gave consumers the impression that the carpet they were purchasing had been thoroughly tested and would not pose any health hazard." Kirsted Rand of the consumers Union said she would have preferred stronger wording on the label, but still sees it as a "huge step forward" from the former green tage program which she believes "skirted the issue and was misleading because it implied that the carpet was somehow safe, so if you were having problems, it had to be something else. Most of us would have liked to see stronger language, but CRI did come a long way."

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In spite of the progress, the Consumers Union and the Consumer Federation of America did not officially endorse the final label, which states: Important Health Information: Some people experience allergic or flu-like symptoms, headaches, or respiratory problems which they associate with the installation, cleaning, or removal of carpet or other interior renovation materials. If these or other symtpoms occur, notify your physician of the symptoms and all materials involved. Sensitive Individuals: Persons who are allergy-prone or sensitive to odors or chemicals should avoid the area or leave the premises when these materials are being installed or removed. Note: You can reduce your exposure to most chemical emissions when carpets and other interior renovating materials are installed, cleaned, or removed by increasing the amount of fresh air ventilation for at least 72 hours. (See Installation and Maintenance Guideline or ask for Owner's Manual.) Installation Guidelines: Vacuum old carpet before removal. Vacuum floor after carpet and pad have been removed. Always ventilate with fresh air (open doors and/or windows, use exhaust fans, etc.) during all phases of installation and for at least 72 hours thereafter. When adhesives and/or pad are used, request those which have low chemical emissions. Follow detailed installation guidelines from manufacturer or from Carpet and Rug Institute. The manufacturer of this carpet participates in a program which seeks to develop ways to reduce emissions by testing samples of carpet. With fresh air ventilation, most carpet emissions are substantially reduced within 48-72 hours after installation. Rand expressed frustration about the negotiation process with CRI because they were discussing more than one item prepared by CRI: the warning label, the carpet Owner's Manual, and an informational brochure. "Each time we would edit out a lot of language we found objectionable on the label, it would appear in the Owner's Manual, and it was incredibly frustrating," said Rand. "We did not endorse the final product and the Consumer Federation of America takes the same position we do." One of the disagreements throughout the negotiations was the label size. The final label was several inches smaller than the size CRI initially agreed to use, according to Rand, who said, "They also dumped on us at the last minute that this label was going to be incorporated on the back of carpet samples along with many other labels -- most of which are promotional, and most of which are much larger than the label with a warning on it. So based on the fact that the label could be buried, and the fact that they had tried to

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just sneak by this label size change, I felt the Consumers Union could not endorse the final product. Another bone of contention is that CRI insists we describe it as a consumer information label rather than a warning label. That's just a game of semantics that obviously their lawyers want them to play." CRI is relaly trying to be careful that they con't put themselves in a position of liability with the wording," stated Bill Hirzy, Ph.D., speaking as president of the Environmental Protection Agency Union, Local 2050. "It was very carefully crafted, obviously, by corporate attorneys to protect against tort litigation. We still have a long way to go to protect the public adequately. The new warning is better than the old warning, however, it is clearly not the ideal warning." Mark Goldman, manager of Anderson Laboratories, agrees. "It's progress, but it's an incomplete label," he said. Anderson Laboratories tested new carpet samples at room temperature using a standard testing method (ASTM E981) and found that offgassing from some samples -- even as small as sever square inches -- caused severe respiratory and neurological effects, including death, in mice. The ASTM E981 test method was developed by Yves Alarie, Ph.D., in the 1960's under the direction of the U.S. Department of Definse. It was specifically developed to reliably extrapolate mouse data to humans. It has been recommended as a reliable product test in a report commissioned by the CPSC and also by Daniel Costa, of the Environmental Protection Agency's Health Effects Research Laboratory, Pulmonary Toxicology Branch. (1, 2) Regarding the ASTM E981, Costa wrote: "We support the use of the mouse irritancy test for detecting, and possibly for comparing potencies among, indoor air contaminants ... we believe that if the mouse irritancy test is positive upon exposure to a suspected indoor contaminant, then the atmosphere is likely to be irritating to humans." (2) Based on Anderson's test results, which were duplicated by Alarie, Hirzy stated: "It looks like there really needs to be some fundamental changes in the manufacturing processes for carpet and its raw materials. And there needs to be a substantial amount of research into actually pinpointing the causes of the toxicity that Anderson and Alarie are finding." The health effects on the test animals have consistently correlated well with the health effects reported by the people submitting their carpet samples for testing, according to Goldman. He expressed concern that the new carpet label does not address the chronic, long-term health problems being reported by some people. "The label

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gives some cautions about installation and the few days immediately after installation, but it doesn't acknowledge that some carpets are a long-term hazard and may continue offgassing low levels of the chemical mix for years, which is what we are seeing with our test," Goldman commented. "Most people won't notice that the new label says 'most' volatile organic chemicals are substantially reduced within 72 hours. We have not denied that. There are a lot of volatile chemical compounds that leave in those 72 hours, but there are some pretty bad ones that still hang around. And we are seeing continuous degradation in some carpets. So the label is not really addressing the fact that with some carpets you're going to have long-term problems. The real milestone that has to be passed is that they must create a toxicologically safe product. Until that happens, people are still at risk." Rosilind Anderson, Ph.D., director of Anderson Laboratories, believes the label's ventilation message is very inadequate. "Anyone who has had any kind of carpet problem knows that this is not something for which the response is simply ventilate for two or three days. Their recommendation to open your windows and run your exhaust fans will not protect people if they have a problem carpet. Further, there are very, very few doctors who are able to recognize the early signs of carpet toxicity," she said. Other researchers have expressed concern about the label's limitations. "I feel the label is inadequate for several reasons. When you read it, the label gives you the feeling that only people who are sensitive will have an adverse response, and in all reality that is not true," cautioned immunotoxicologist Jack Thrasher, Ph.D. "It really is not giving the full message to the public. Another problem with warning labels of this nature, is that it simply says to notify your physician if you have problems. But if the doctor is not educated regarding chemicals, then how is he going to know what tests to do, what symptoms to look for, and how to determine what is causing those symptoms? In my personal opinion, with a label such as this, it would be incombent upon the carpet industry to inform all treating physicians in the countries where they market their products that there are health problems with carpeting and what those problems are so the doctor would have an idea what to look for." Thrasher is also concerned that the label implies thee is a treatment for the adverse reactions to carpet, while leaving the carpet in place, "when in reality there is no treatment. If carpet is causing problems, the only treatment is to remove it and get it out of the house. All a doctor can do is recognize the problem, run the appropriate tests to determine the extent of the problem, and discuss

48

it with the patient so they realize what they must do to prevent further illness. And again, the only way to prevent further illness is to get the carpet out of the house and avoid further exposures," stated Thrasher. In spite of their concerns, Thrasher, Anderson, Goldman, Rand, and Hirzy all believe the label represents a positive step because it at least alerts consumers that symtpoms have been reported. This view was also expressed by the New York Attorney General's office. "I am really hopeful that some people who otherwise would not have thought twice about any of these carpet safety issues will now have the opportunity to think about it because of the label, and will recognize the connection and take steps to protect themselves if they are experiencing symptoms," said Ronna Brown, assistant attorney general at the New York Department of Law. "This consumer warning label makes an important contribution to alerting the public about the range of symptoms many people associate with exposure to the chemicals given off by new carpeting. I urge all consumers to heed the carpet warning label," advised former New York Attorney General Robert Abrams. In spite of the warnings on the new label, CRI still insists thee are no health hazards associated with carpet. "It's not a warning label," stated Kathryn Wise, CRI's director of public relations. "It is a consumer information label. The word 'warning' infers that there is hazard in the product and there has been no proven hazard to carpet." CRI reaffirms this stance in a "Question and Answer" sheet they are distributing throughout the carpet and rug industry to guide sales representatives' responses to consumers. The sheet states in part: (3) Is it really a warning label? Not at all. It is not a warning label because there is no cause for a warning. Scientists have consistently demonstrated that carpet is not a public health hazard. If carpet is not a public health hazard, why is the industry putting any labels on its products? This is the Age of the Informed Consumer. Increasingly consumers are becoming aware of indoor air quality issues and they wat us to be straightforward about carpet's role. The overriding reason for the

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label, brochure, and manual i s to inform the consumer. Haven't there been some tests with carpet that actually killed mice? One isolated laboratory purported last year to have killed mice with carpet emissions. Since then, the Environmental Protection Agency (EPA) and independent tests have been unable to duplicate the results. Scientists tell us that the isolated laboratory experimental tests were seriously flawed and irrelevant. How straightforward is this information? Scientists have published a number of studies indicating human health hazards from working with carpets, including lympocytic leukemia, testicular cancer, oral and pharyngeal cancer, neuropsychiatric illness, and central nervous system damage. (4-8) EPA researchers warn that carpet tests to provide a reservoir for tracked-in chemicals adsorbed to dust, including pesticides, lead, heavy metals, and poly-nuclear aromatic hydrocarbons. The amount of lead found in dust and carpet where a child plays has been found to be the best single predictor of the toddler's blood level of lead. (9-11) In addition, published studies have shown that a large number of chemicals offgassing from carpet are hazardous to human health. For example, formaldehyde is a confirmed carcinogen. Low-level exposures may cause hypersensitivity reactions in humans including eye, nose and throat irritation, bronchial spasm, lung irritation, and dermatitis. CRI's Wise denied that new carpet contains formaldehyde from the manufacturing process, yet significant levels of formaldehyde have been found offgassing from new carpets straight from the mill. (1, 12-16) Other hazardous chemicals found offgassing from new carpet include acetone, benzene, styrene, toluene, and xylene, all of which are included in EPA's Toxic Substances Control Act Inventory and listed on EPA's Community Right to Know List. (1, 12-17) Independent researchers have found the ASTM E981 test method (used by Anderson Laboratories) to be a reliable test for extrapolating human health effects from the mouse data derived from a number of the hazardous chemicals found offgassing from carpet. (1, 12, 14, 15, 17, 18) CRI hired the founder of the ASTM E981 method, Dr. Alarie of the University of Pittsburgh, to investigate Anderson Laboratories' carpet testing protocol and to try to duplicate their test results. At a June 11, 1993 hearing before the House Subcommittee on Environment, Energy, and Natural Resources, attended by VanGelderen, the president of CRI, Alarie testified that not only did he find

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Anderson's test protocol to be scientifically valid, but he was also able to duplicate her test results four times in his own laboratory. (19) Congressman Sanders' aide Pollina was present at a videotaped side-by-side test conducted by the EPA at Anderson Laboratories. The Videotape, which proved EPA duplicated Anderson's test results, was submitted as evidence at the Congressional hearing. (20) In spite of CRI's Question and Answer sheet stating EPA was unable to duplicate the test results, Goldman is still willing to work with industry and EPA as long as there are witnesses. "Let's run the studies with EPA and industry, with observers to make sure that the protocol is truly observed and we are all doing it exactly the same way. Then let's take the samples that prove to be toxic, bring them to an independent laboratory and analyze the fumes that offgas from the sample to see what is in it," said Goldman. "In terms of getting the industry to act, I think they are motivated by the litigation, threat of regulation, and or course concern for economic repercussion, such as loss of market share. I think positive changes are occurring, but very gradually."

Carpet Industry Response Team A Lawyer's Perspective As part of their new "Consumer Information Initiative," the Carpet and Rug Institute (CRI) has assembled "response teams" to investigate carpet complaints in people's homes and office buildings. "CRI is proposing that if someone has a carpet complaint in a home or office building, then they will send a team to that building where they will gather information as to what may or may not be happening in the building," says Congressman Bernard SAnders' [I-VT] aide, Anthony Pollina. "CRI's information says they have created six response teams to investigate carpet complaints. Each team is composed of an independent industrial hygiene consultant, a carpet mill or fiber producer representative, and a CRI testing lab expert." How do those response teams come into play? According to the CRI's director of public relations, Kathryn Wise, when people report carpet-related health problems to CRI," right now we ask about all of the other things that are going on in their homes and what symptoms they have, what kinds of effectss they are having, what kind of cleaning they are doing on their carpet, what other allergies they have. We try to find out a much about what is going on in their work space or home space as wel can, and then if we still have questions about the carpet, we have a team that can be sent -- of people who

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are very adept at determining these things -- and they can determine what the problem is." Attorney Kevin McIvers of Santa Barbara, California, offers the following words of caution about the carpet industry response teams: "How could the CRI possibly do an objective evaluation when they don't even believe carpet makes people sick in the first place? Their public line is that this is all a bunch of baloney. If it was my sick spouse, child, or loved one that was involved and these guys wanted to come out and supposedly help me get to the bottom of the problem, I would be mighty skeptical. And from a lawyer's perspective, I wouldn't let them anywhere near a client of mine. "I think it is ridiculous for them to consistently put out misinformation stating that carpet is not a hazard, and then offer to 'investigate' people's homes. If the day comes when CRI says, 'Yes, carpet does make some people dreadfully ill and it's a serious problem and we want to help,' then I would open the door and let them in. But not until that happens would I even consider it. And why on earth would they send in a carpet mill or fiber producer representative? The role of industry representatives is to promote their products. What qualifications would they have to conduct indoor air quality investigations? What kind of background would they have in neurotoxicology and immunotoxicology? "The timing of this is especially interesting in light of the carpet and rug industry's recent resolve to not concede a single thing on any particular legal claim, and to resist carpet claims at every point. An increasing number of carpet-related lawsuits have been filed. The carpet and rug industry has made an industry-wide decision to fight and win these cases, as evidenced by a memo the CRI sent around to all the retailers. (1) While that is their position, it would just be plain dumb to let those folks come in and try to help with a serious problem like this. "It sounds like a little initial prediscoery. They could get in the person's home or workplace and test the environment -- not to try to figure out whether carpet is making the people sick -- but to try to identify everything else that conceivably could. They can do the same thing that is done in the discovery process of a court case, only they just get a shot at doing it before the poor victim has an attorney and realizes that they're getting clobbered by the opposition. Again, since they don't recognize carpet can be a serious problem, how can they possibly be qualified to investigate a carpet complaint? This leads me to believe that the only thing they

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could possibly be doing is trying to undermine what someone knows to be a carpet problem, and undermine the eventual case if there is to be a case -- at least put the person on the wrong track regarding the cause of their illness. "I sincerely hope the day comes when the industry genuinely recognizes the serious health probelms some carpets pose. When that day comes, I for one -- and a lot of other people that are seriously interested, first and foremost, in helping other people avoid getting this type of illness -- will open my door and heart, and mind to them. That was Jocelyn's [Kevin McIvers' wife, who is also an attorney] and my approach initially when we first contacted the industry because of our son Christopher's carpet-induced tremors. We were wide open and wanted to work with the carpet and rug industry and we just got burned. They lied to use and misled us, and as a result, our little boy was exposed to toxic carpet more than a year longer than he needed to be. And that is just the kind of thing that is going to happen to a lot of other people with this team, I'm sure. It's really sad because in an ideal world one should be completely open with the industry that has a problem and try to help them learn what it's about and get some good case histories. However, while the industry is taking such a dishonest approach to the whole issue, it is just in the best interest of the victims to protect themselves from the carpet industry's agenda." Reference [to "Carpet Industry Response Team"]: 1. The Carpet and Rug Institute. "Typically Asked Questions and Suggested Responses; Carpet/Indoor Air Quality Fact Sheet; memorandum to the carpet industry." (April 1993)

References: 1. Consumer Product Safety Commission memorandum and final report from interagency agreement on volatile organic chemical emissions from carpets. CPSC-IAG-09-1256 (August 13, 1993) 2. Tepper, J.S.; Costa, D.L. "Will the Mouse Bioassay for Estimating Sensory Irritancy of Airborne Chemicals (ASTM E981-84) be Useful for Evaluation of Indoor Air Contaminants." Indoor Environment 1: 367-72 (1992) 3. The carpet and Rug Institute. "Questions and Answers About the CRI Consumer Information Initiative; Carpet and IAQ - CRI Consumer Information Kit Distribution Plan - Sales Representatives'

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Participation." Memorandum (December 7, 1993) 4. Ekberg, K.; Barregard, L.; et al. "Chronic and Acute Effects of Solvents on Central Nervous System Functions in Floorlayers." British Journal of Industrial Medicine 43(2): 101-106 (1986). 5. O'Brien, T.R.; Decoufle, P. "Cancer Mortality Among Northern Georgia Carpet and Textile Workers." American Journal of Industrial Medicine 14:15-24 (1988). 6. Huebner, W.W.; Schoenberg, J.R.; et al. "Oral and Pharyngeal Cancer and Occupation: A Case-Control Study." Epidemiology 3(4): 300-309 (1992). 7. Axelson, O.; Hane, M.; Hogstedt, C. "A Case-referent Study on Neuropsychiatric Disorders Among Workers Exposed to Solvents." Scandinavian Journal of Work Environment & Health 2:14-20 (1976). 8. Rumiantsev, G.I.; Prokhorov, N.I.; et al. "Experimental Studies of the Combined Effect of Styrene in General Vibration." (in Russian) Gig Sanit 9:32-36 (1990). 9. Roberts, J.W.; Budd, W.T.; et al. "Chemical Contaminants in House Dust; Occurrentces and Sources." Indoor Air '93: Proceedings of the International Conference on Indoor Air Quality and Climate 2:27-32 (1993). 10. Davies, D.J.A.; Thorton, I.; et al. "Relationship Between Blood Lead and Lead Intake in Two Year Old Urban Children in the UK." Science of the Total Environment 90:13-29 (1990). 11. Budd, W.T.; Roberts, J.W., Ruby, M.G. "Field Evaluation of a High Volume Surface Sampler for Pesticides in Floor Dust." Environmental Protection Agency, EPA 600-3-90-030, PB 90-192006 (1990). 12. Kirchner, S.; Karpe, P.; cochet, C. "Characterization of Volatile Organic Compounds Emission from Floor Coverings." Indoor Air '93: Proceedings of the International Conference on Indoor Air Quality and Climate 2:455-460 (1993). 13. Pliel, J.D.; Whiton, R.S. "Determination of Organic Emissions from New Carpeting." Appl. Occup. Environ. Hygiene 5:693-699 (1990). 14. Schaper, M. "Development of a Database for Sensory Irritants and Its Use in Establishing Occupational Exposure Limits." American

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Industrial Hygiene Association Journal 54(9):488-544 (1993). 15. National Institute for Occupational Safety and Health. NIOSH Pocket Guide to Chemical Hazards, Washington, D.C.: U.S. Government Printing Office (June 1990). 16. Lewis, R.J. Sax's Dangerous Properties of Industrial Materials, New York: Van Nostrand Reinhold (1989). 17. Black, M.S.; Work, L.M.; et al. "Measuring the TVOC Contributions of Carpet Using Environment Chambers." Indoor Air '93: Proceedings of the International Conference on Indoor Air Quality and Climate 2:401-405 (1993). 18. Anderson, R.C., "Toxic Emissions from Carpets." Indoor Air '93: Proceedings of the International Conference on Indoor Air Quality and Climate 1:651-656 (1993). 19. Testimony of Yves Alarie before the Committee on Government Operations, Subcommittee on Environment, Energy, and Natural Resources, U.S. House of Representatives. Re: Carpet research (June 11, 1993). 20. Duehring, C. "Carpet. Part I: EPA Stalls and Industry Hedgest While Consumers Remain at Risk." Informed Consent 6-11, 30-32 (1993). **** NOTICE **** This series of articles is presented with the permission of the author, Cindy Duehring (per phone conversation on 10/4/95). For considerably more extensive documentation on the hazards of toxic carpeting and on other environmental/health hazards, please contact: Cindy Duehring Director of Research Environmental Access Research Network P.O. Box 1089 Minot, North Dakota 58702-1089 (701) 837-0161 **** NOTICE ****

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CARPET CONCERNS Part Three:

New Carpet Label Receives Mixed Reviews by Cindy Duehring "This is the age of the informed consumer," said Ron VanGelderen, president of the Carpet and Rug Institute (CRI) at a November 15, 1993 press conference heralding the unveiling of their new carpet label and consumer information program. CRI voluntarily agreed to teh new carpet label after months of intense negotiations with Congressman Bernard Sanders' office [I-VT], the Consumers Union, the Consumer Federation of America, and the state Attorneys General of New York, Connecticut, Oregon, and Vermont. The four attorneys general entered into direct negotiations with the carpet industry when the Consumer Products Safety Commission (CPSC) refused to even consider their petition, signed by a total of 26 state attorneys general, requesting mandatory health warning labels on carpet. "The Consumer Products Safety Commission receives hundreds of complaints and inquiries each year about the adverse health effects associated witht eh materials used to make carpets," said Connecticut Attorney General Richard Blumenthal. "The agency has ignored these health concerns and refused to take action. Under the revised industry program, consumers will at least be given information to provide a basic awareness of the possible health risks. Before this agreement, the industry's brochure said there was no reason for people to be concerned about carpet safety -- an absolute outrage. The program was misleading and meaningless. It gave consumers the impression that the carpet they were purchasing had been thoroughly tested and would not pose any health hazard." Kirsted Rand of the consumers Union said she would have preferred stronger wording on the label, but still sees it as a "huge step forward" from the former green tage program which she believes "skirted the issue and was misleading because it implied that the carpet was somehow safe, so if you were having problems, it had to be something else. Most of us would have liked to see stronger language, but CRI did come a long way."

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In spite of the progress, the Consumers Union and the Consumer Federation of America did not officially endorse the final label, which states: Important Health Information: Some people experience allergic or flu-like symptoms, headaches, or respiratory problems which they associate with the installation, cleaning, or removal of carpet or other interior renovation materials. If these or other symtpoms occur, notify your physician of the symptoms and all materials involved. Sensitive Individuals: Persons who are allergy-prone or sensitive to odors or chemicals should avoid the area or leave the premises when these materials are being installed or removed. Note: You can reduce your exposure to most chemical emissions when carpets and other interior renovating materials are installed, cleaned, or removed by increasing the amount of fresh air ventilation for at least 72 hours. (See Installation and Maintenance Guideline or ask for Owner's Manual.) Installation Guidelines: Vacuum old carpet before removal. Vacuum floor after carpet and pad have been removed. Always ventilate with fresh air (open doors and/or windows, use exhaust fans, etc.) during all phases of installation and for at least 72 hours thereafter. When adhesives and/or pad are used, request those which have low chemical emissions. Follow detailed installation guidelines from manufacturer or from Carpet and Rug Institute. The manufacturer of this carpet participates in a program which seeks to develop ways to reduce emissions by testing samples of carpet. With fresh air ventilation, most carpet emissions are substantially reduced within 48-72 hours after installation. Rand expressed frustration about the negotiation process with CRI because they were discussing more than one item prepared by CRI: the warning label, the carpet Owner's Manual, and an informational brochure. "Each time we would edit out a lot of language we found objectionable on the label, it would appear in the Owner's Manual, and it was incredibly frustrating," said Rand. "We did not endorse the final product and the Consumer Federation of America takes the same position we do." One of the disagreements throughout the negotiations was the label size. The final label was several inches smaller than the size CRI initially agreed to use, according to Rand, who said, "They also dumped on us at the last minute that this label was going to be incorporated on the back of carpet samples along with many other labels -- most of which are promotional, and most of which are much larger than the label with a warning on it. So based on the fact that the label could be buried, and the fact that they had tried to

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just sneak by this label size change, I felt the Consumers Union could not endorse the final product. Another bone of contention is that CRI insists we describe it as a consumer information label rather than a warning label. That's just a game of semantics that obviously their lawyers want them to play." CRI is relaly trying to be careful that they con't put themselves in a position of liability with the wording," stated Bill Hirzy, Ph.D., speaking as president of the Environmental Protection Agency Union, Local 2050. "It was very carefully crafted, obviously, by corporate attorneys to protect against tort litigation. We still have a long way to go to protect the public adequately. The new warning is better than the old warning, however, it is clearly not the ideal warning." Mark Goldman, manager of Anderson Laboratories, agrees. "It's progress, but it's an incomplete label," he said. Anderson Laboratories tested new carpet samples at room temperature using a standard testing method (ASTM E981) and found that offgassing from some samples -- even as small as sever square inches -- caused severe respiratory and neurological effects, including death, in mice. The ASTM E981 test method was developed by Yves Alarie, Ph.D., in the 1960's under the direction of the U.S. Department of Definse. It was specifically developed to reliably extrapolate mouse data to humans. It has been recommended as a reliable product test in a report commissioned by the CPSC and also by Daniel Costa, of the Environmental Protection Agency's Health Effects Research Laboratory, Pulmonary Toxicology Branch. (1, 2) Regarding the ASTM E981, Costa wrote: "We support the use of the mouse irritancy test for detecting, and possibly for comparing potencies among, indoor air contaminants ... we believe that if the mouse irritancy test is positive upon exposure to a suspected indoor contaminant, then the atmosphere is likely to be irritating to humans." (2) Based on Anderson's test results, which were duplicated by Alarie, Hirzy stated: "It looks like there really needs to be some fundamental changes in the manufacturing processes for carpet and its raw materials. And there needs to be a substantial amount of research into actually pinpointing the causes of the toxicity that Anderson and Alarie are finding." The health effects on the test animals have consistently correlated well with the health effects reported by the people submitting their carpet samples for testing, according to Goldman. He expressed concern that the new carpet label does not address the chronic, long-term health problems being reported by some people. "The label

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gives some cautions about installation and the few days immediately after installation, but it doesn't acknowledge that some carpets are a long-term hazard and may continue offgassing low levels of the chemical mix for years, which is what we are seeing with our test," Goldman commented. "Most people won't notice that the new label says 'most' volatile organic chemicals are substantially reduced within 72 hours. We have not denied that. There are a lot of volatile chemical compounds that leave in those 72 hours, but there are some pretty bad ones that still hang around. And we are seeing continuous degradation in some carpets. So the label is not really addressing the fact that with some carpets you're going to have long-term problems. The real milestone that has to be passed is that they must create a toxicologically safe product. Until that happens, people are still at risk." Rosilind Anderson, Ph.D., director of Anderson Laboratories, believes the label's ventilation message is very inadequate. "Anyone who has had any kind of carpet problem knows that this is not something for which the response is simply ventilate for two or three days. Their recommendation to open your windows and run your exhaust fans will not protect people if they have a problem carpet. Further, there are very, very few doctors who are able to recognize the early signs of carpet toxicity," she said. Other researchers have expressed concern about the label's limitations. "I feel the label is inadequate for several reasons. When you read it, the label gives you the feeling that only people who are sensitive will have an adverse response, and in all reality that is not true," cautioned immunotoxicologist Jack Thrasher, Ph.D. "It really is not giving the full message to the public. Another problem with warning labels of this nature, is that it simply says to notify your physician if you have problems. But if the doctor is not educated regarding chemicals, then how is he going to know what tests to do, what symptoms to look for, and how to determine what is causing those symptoms? In my personal opinion, with a label such as this, it would be incombent upon the carpet industry to inform all treating physicians in the countries where they market their products that there are health problems with carpeting and what those problems are so the doctor would have an idea what to look for." Thrasher is also concerned that the label implies thee is a treatment for the adverse reactions to carpet, while leaving the carpet in place, "when in reality there is no treatment. If carpet is causing problems, the only treatment is to remove it and get it out of the house. All a doctor can do is recognize the problem, run the appropriate tests to determine the extent of the problem, and discuss

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it with the patient so they realize what they must do to prevent further illness. And again, the only way to prevent further illness is to get the carpet out of the house and avoid further exposures," stated Thrasher. In spite of their concerns, Thrasher, Anderson, Goldman, Rand, and Hirzy all believe the label represents a positive step because it at least alerts consumers that symtpoms have been reported. This view was also expressed by the New York Attorney General's office. "I am really hopeful that some people who otherwise would not have thought twice about any of these carpet safety issues will now have the opportunity to think about it because of the label, and will recognize the connection and take steps to protect themselves if they are experiencing symptoms," said Ronna Brown, assistant attorney general at the New York Department of Law. "This consumer warning label makes an important contribution to alerting the public about the range of symptoms many people associate with exposure to the chemicals given off by new carpeting. I urge all consumers to heed the carpet warning label," advised former New York Attorney General Robert Abrams. In spite of the warnings on the new label, CRI still insists thee are no health hazards associated with carpet. "It's not a warning label," stated Kathryn Wise, CRI's director of public relations. "It is a consumer information label. The word 'warning' infers that there is hazard in the product and there has been no proven hazard to carpet." CRI reaffirms this stance in a "Question and Answer" sheet they are distributing throughout the carpet and rug industry to guide sales representatives' responses to consumers. The sheet states in part: (3) Is it really a warning label? Not at all. It is not a warning label because there is no cause for a warning. Scientists have consistently demonstrated that carpet is not a public health hazard. If carpet is not a public health hazard, why is the industry putting any labels on its products? This is the Age of the Informed Consumer. Increasingly consumers are becoming aware of indoor air quality issues and they wat us to be straightforward about carpet's role. The overriding reason for the

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label, brochure, and manual i s to inform the consumer. Haven't there been some tests with carpet that actually killed mice? One isolated laboratory purported last year to have killed mice with carpet emissions. Since then, the Environmental Protection Agency (EPA) and independent tests have been unable to duplicate the results. Scientists tell us that the isolated laboratory experimental tests were seriously flawed and irrelevant. How straightforward is this information? Scientists have published a number of studies indicating human health hazards from working with carpets, including lympocytic leukemia, testicular cancer, oral and pharyngeal cancer, neuropsychiatric illness, and central nervous system damage. (4-8) EPA researchers warn that carpet tests to provide a reservoir for tracked-in chemicals adsorbed to dust, including pesticides, lead, heavy metals, and poly-nuclear aromatic hydrocarbons. The amount of lead found in dust and carpet where a child plays has been found to be the best single predictor of the toddler's blood level of lead. (9-11) In addition, published studies have shown that a large number of chemicals offgassing from carpet are hazardous to human health. For example, formaldehyde is a confirmed carcinogen. Low-level exposures may cause hypersensitivity reactions in humans including eye, nose and throat irritation, bronchial spasm, lung irritation, and dermatitis. CRI's Wise denied that new carpet contains formaldehyde from the manufacturing process, yet significant levels of formaldehyde have been found offgassing from new carpets straight from the mill. (1, 12-16) Other hazardous chemicals found offgassing from new carpet include acetone, benzene, styrene, toluene, and xylene, all of which are included in EPA's Toxic Substances Control Act Inventory and listed on EPA's Community Right to Know List. (1, 12-17) Independent researchers have found the ASTM E981 test method (used by Anderson Laboratories) to be a reliable test for extrapolating human health effects from the mouse data derived from a number of the hazardous chemicals found offgassing from carpet. (1, 12, 14, 15, 17, 18) CRI hired the founder of the ASTM E981 method, Dr. Alarie of the University of Pittsburgh, to investigate Anderson Laboratories' carpet testing protocol and to try to duplicate their test results. At a June 11, 1993 hearing before the House Subcommittee on Environment, Energy, and Natural Resources, attended by VanGelderen, the president of CRI, Alarie testified that not only did he find

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Anderson's test protocol to be scientifically valid, but he was also able to duplicate her test results four times in his own laboratory. (19) Congressman Sanders' aide Pollina was present at a videotaped side-by-side test conducted by the EPA at Anderson Laboratories. The Videotape, which proved EPA duplicated Anderson's test results, was submitted as evidence at the Congressional hearing. (20) In spite of CRI's Question and Answer sheet stating EPA was unable to duplicate the test results, Goldman is still willing to work with industry and EPA as long as there are witnesses. "Let's run the studies with EPA and industry, with observers to make sure that the protocol is truly observed and we are all doing it exactly the same way. Then let's take the samples that prove to be toxic, bring them to an independent laboratory and analyze the fumes that offgas from the sample to see what is in it," said Goldman. "In terms of getting the industry to act, I think they are motivated by the litigation, threat of regulation, and or course concern for economic repercussion, such as loss of market share. I think positive changes are occurring, but very gradually."

Carpet Industry Response Team A Lawyer's Perspective As part of their new "Consumer Information Initiative," the Carpet and Rug Institute (CRI) has assembled "response teams" to investigate carpet complaints in people's homes and office buildings. "CRI is proposing that if someone has a carpet complaint in a home or office building, then they will send a team to that building where they will gather information as to what may or may not be happening in the building," says Congressman Bernard SAnders' [I-VT] aide, Anthony Pollina. "CRI's information says they have created six response teams to investigate carpet complaints. Each team is composed of an independent industrial hygiene consultant, a carpet mill or fiber producer representative, and a CRI testing lab expert." How do those response teams come into play? According to the CRI's director of public relations, Kathryn Wise, when people report carpet-related health problems to CRI," right now we ask about all of the other things that are going on in their homes and what symptoms they have, what kinds of effectss they are having, what kind of cleaning they are doing on their carpet, what other allergies they have. We try to find out a much about what is going on in their work space or home space as wel can, and then if we still have questions about the carpet, we have a team that can be sent -- of people who

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are very adept at determining these things -- and they can determine what the problem is." Attorney Kevin McIvers of Santa Barbara, California, offers the following words of caution about the carpet industry response teams: "How could the CRI possibly do an objective evaluation when they don't even believe carpet makes people sick in the first place? Their public line is that this is all a bunch of baloney. If it was my sick spouse, child, or loved one that was involved and these guys wanted to come out and supposedly help me get to the bottom of the problem, I would be mighty skeptical. And from a lawyer's perspective, I wouldn't let them anywhere near a client of mine. "I think it is ridiculous for them to consistently put out misinformation stating that carpet is not a hazard, and then offer to 'investigate' people's homes. If the day comes when CRI says, 'Yes, carpet does make some people dreadfully ill and it's a serious problem and we want to help,' then I would open the door and let them in. But not until that happens would I even consider it. And why on earth would they send in a carpet mill or fiber producer representative? The role of industry representatives is to promote their products. What qualifications would they have to conduct indoor air quality investigations? What kind of background would they have in neurotoxicology and immunotoxicology? "The timing of this is especially interesting in light of the carpet and rug industry's recent resolve to not concede a single thing on any particular legal claim, and to resist carpet claims at every point. An increasing number of carpet-related lawsuits have been filed. The carpet and rug industry has made an industry-wide decision to fight and win these cases, as evidenced by a memo the CRI sent around to all the retailers. (1) While that is their position, it would just be plain dumb to let those folks come in and try to help with a serious problem like this. "It sounds like a little initial prediscoery. They could get in the person's home or workplace and test the environment -- not to try to figure out whether carpet is making the people sick -- but to try to identify everything else that conceivably could. They can do the same thing that is done in the discovery process of a court case, only they just get a shot at doing it before the poor victim has an attorney and realizes that they're getting clobbered by the opposition. Again, since they don't recognize carpet can be a serious problem, how can they possibly be qualified to investigate a carpet complaint? This leads me to believe that the only thing they

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could possibly be doing is trying to undermine what someone knows to be a carpet problem, and undermine the eventual case if there is to be a case -- at least put the person on the wrong track regarding the cause of their illness. "I sincerely hope the day comes when the industry genuinely recognizes the serious health probelms some carpets pose. When that day comes, I for one -- and a lot of other people that are seriously interested, first and foremost, in helping other people avoid getting this type of illness -- will open my door and heart, and mind to them. That was Jocelyn's [Kevin McIvers' wife, who is also an attorney] and my approach initially when we first contacted the industry because of our son Christopher's carpet-induced tremors. We were wide open and wanted to work with the carpet and rug industry and we just got burned. They lied to use and misled us, and as a result, our little boy was exposed to toxic carpet more than a year longer than he needed to be. And that is just the kind of thing that is going to happen to a lot of other people with this team, I'm sure. It's really sad because in an ideal world one should be completely open with the industry that has a problem and try to help them learn what it's about and get some good case histories. However, while the industry is taking such a dishonest approach to the whole issue, it is just in the best interest of the victims to protect themselves from the carpet industry's agenda." Reference [to "Carpet Industry Response Team"]: 1. The Carpet and Rug Institute. "Typically Asked Questions and Suggested Responses; Carpet/Indoor Air Quality Fact Sheet; memorandum to the carpet industry." (April 1993)

References: 1. Consumer Product Safety Commission memorandum and final report from interagency agreement on volatile organic chemical emissions from carpets. CPSC-IAG-09-1256 (August 13, 1993) 2. Tepper, J.S.; Costa, D.L. "Will the Mouse Bioassay for Estimating Sensory Irritancy of Airborne Chemicals (ASTM E981-84) be Useful for Evaluation of Indoor Air Contaminants." Indoor Environment 1: 367-72 (1992) 3. The carpet and Rug Institute. "Questions and Answers About the CRI Consumer Information Initiative; Carpet and IAQ - CRI Consumer Information Kit Distribution Plan - Sales Representatives'

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Participation." Memorandum (December 7, 1993) 4. Ekberg, K.; Barregard, L.; et al. "Chronic and Acute Effects of Solvents on Central Nervous System Functions in Floorlayers." British Journal of Industrial Medicine 43(2): 101-106 (1986). 5. O'Brien, T.R.; Decoufle, P. "Cancer Mortality Among Northern Georgia Carpet and Textile Workers." American Journal of Industrial Medicine 14:15-24 (1988). 6. Huebner, W.W.; Schoenberg, J.R.; et al. "Oral and Pharyngeal Cancer and Occupation: A Case-Control Study." Epidemiology 3(4): 300-309 (1992). 7. Axelson, O.; Hane, M.; Hogstedt, C. "A Case-referent Study on Neuropsychiatric Disorders Among Workers Exposed to Solvents." Scandinavian Journal of Work Environment & Health 2:14-20 (1976). 8. Rumiantsev, G.I.; Prokhorov, N.I.; et al. "Experimental Studies of the Combined Effect of Styrene in General Vibration." (in Russian) Gig Sanit 9:32-36 (1990). 9. Roberts, J.W.; Budd, W.T.; et al. "Chemical Contaminants in House Dust; Occurrentces and Sources." Indoor Air '93: Proceedings of the International Conference on Indoor Air Quality and Climate 2:27-32 (1993). 10. Davies, D.J.A.; Thorton, I.; et al. "Relationship Between Blood Lead and Lead Intake in Two Year Old Urban Children in the UK." Science of the Total Environment 90:13-29 (1990). 11. Budd, W.T.; Roberts, J.W., Ruby, M.G. "Field Evaluation of a High Volume Surface Sampler for Pesticides in Floor Dust." Environmental Protection Agency, EPA 600-3-90-030, PB 90-192006 (1990). 12. Kirchner, S.; Karpe, P.; cochet, C. "Characterization of Volatile Organic Compounds Emission from Floor Coverings." Indoor Air '93: Proceedings of the International Conference on Indoor Air Quality and Climate 2:455-460 (1993). 13. Pliel, J.D.; Whiton, R.S. "Determination of Organic Emissions from New Carpeting." Appl. Occup. Environ. Hygiene 5:693-699 (1990). 14. Schaper, M. "Development of a Database for Sensory Irritants and Its Use in Establishing Occupational Exposure Limits." American

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Industrial Hygiene Association Journal 54(9):488-544 (1993). 15. National Institute for Occupational Safety and Health. NIOSH Pocket Guide to Chemical Hazards, Washington, D.C.: U.S. Government Printing Office (June 1990). 16. Lewis, R.J. Sax's Dangerous Properties of Industrial Materials, New York: Van Nostrand Reinhold (1989). 17. Black, M.S.; Work, L.M.; et al. "Measuring the TVOC Contributions of Carpet Using Environment Chambers." Indoor Air '93: Proceedings of the International Conference on Indoor Air Quality and Climate 2:401-405 (1993). 18. Anderson, R.C., "Toxic Emissions from Carpets." Indoor Air '93: Proceedings of the International Conference on Indoor Air Quality and Climate 1:651-656 (1993). 19. Testimony of Yves Alarie before the Committee on Government Operations, Subcommittee on Environment, Energy, and Natural Resources, U.S. House of Representatives. Re: Carpet research (June 11, 1993). 20. Duehring, C. "Carpet. Part I: EPA Stalls and Industry Hedgest While Consumers Remain at Risk." Informed Consent 6-11, 30-32 (1993). **** NOTICE **** This series of articles is presented with the permission of the author, Cindy Duehring (per phone conversation on 10/4/95). For considerably more extensive documentation on the hazards of toxic carpeting and on other environmental/health hazards, please contact: Cindy Duehring Director of Research Environmental Access Research Network P.O. Box 1089 Minot, North Dakota 58702-1089 (701) 837-0161 **** NOTICE ****

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CARPET CONCERNS Part Three:

New Carpet Label Receives Mixed Reviews by Cindy Duehring "This is the age of the informed consumer," said Ron VanGelderen, president of the Carpet and Rug Institute (CRI) at a November 15, 1993 press conference heralding the unveiling of their new carpet label and consumer information program. CRI voluntarily agreed to teh new carpet label after months of intense negotiations with Congressman Bernard Sanders' office [I-VT], the Consumers Union, the Consumer Federation of America, and the state Attorneys General of New York, Connecticut, Oregon, and Vermont. The four attorneys general entered into direct negotiations with the carpet industry when the Consumer Products Safety Commission (CPSC) refused to even consider their petition, signed by a total of 26 state attorneys general, requesting mandatory health warning labels on carpet. "The Consumer Products Safety Commission receives hundreds of complaints and inquiries each year about the adverse health effects associated witht eh materials used to make carpets," said Connecticut Attorney General Richard Blumenthal. "The agency has ignored these health concerns and refused to take action. Under the revised industry program, consumers will at least be given information to provide a basic awareness of the possible health risks. Before this agreement, the industry's brochure said there was no reason for people to be concerned about carpet safety -- an absolute outrage. The program was misleading and meaningless. It gave consumers the impression that the carpet they were purchasing had been thoroughly tested and would not pose any health hazard." Kirsted Rand of the consumers Union said she would have preferred stronger wording on the label, but still sees it as a "huge step forward" from the former green tage program which she believes "skirted the issue and was misleading because it implied that the carpet was somehow safe, so if you were having problems, it had to be something else. Most of us would have liked to see stronger language, but CRI did come a long way."

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In spite of the progress, the Consumers Union and the Consumer Federation of America did not officially endorse the final label, which states: Important Health Information: Some people experience allergic or flu-like symptoms, headaches, or respiratory problems which they associate with the installation, cleaning, or removal of carpet or other interior renovation materials. If these or other symtpoms occur, notify your physician of the symptoms and all materials involved. Sensitive Individuals: Persons who are allergy-prone or sensitive to odors or chemicals should avoid the area or leave the premises when these materials are being installed or removed. Note: You can reduce your exposure to most chemical emissions when carpets and other interior renovating materials are installed, cleaned, or removed by increasing the amount of fresh air ventilation for at least 72 hours. (See Installation and Maintenance Guideline or ask for Owner's Manual.) Installation Guidelines: Vacuum old carpet before removal. Vacuum floor after carpet and pad have been removed. Always ventilate with fresh air (open doors and/or windows, use exhaust fans, etc.) during all phases of installation and for at least 72 hours thereafter. When adhesives and/or pad are used, request those which have low chemical emissions. Follow detailed installation guidelines from manufacturer or from Carpet and Rug Institute. The manufacturer of this carpet participates in a program which seeks to develop ways to reduce emissions by testing samples of carpet. With fresh air ventilation, most carpet emissions are substantially reduced within 48-72 hours after installation. Rand expressed frustration about the negotiation process with CRI because they were discussing more than one item prepared by CRI: the warning label, the carpet Owner's Manual, and an informational brochure. "Each time we would edit out a lot of language we found objectionable on the label, it would appear in the Owner's Manual, and it was incredibly frustrating," said Rand. "We did not endorse the final product and the Consumer Federation of America takes the same position we do." One of the disagreements throughout the negotiations was the label size. The final label was several inches smaller than the size CRI initially agreed to use, according to Rand, who said, "They also dumped on us at the last minute that this label was going to be incorporated on the back of carpet samples along with many other labels -- most of which are promotional, and most of which are much larger than the label with a warning on it. So based on the fact that the label could be buried, and the fact that they had tried to

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just sneak by this label size change, I felt the Consumers Union could not endorse the final product. Another bone of contention is that CRI insists we describe it as a consumer information label rather than a warning label. That's just a game of semantics that obviously their lawyers want them to play." CRI is relaly trying to be careful that they con't put themselves in a position of liability with the wording," stated Bill Hirzy, Ph.D., speaking as president of the Environmental Protection Agency Union, Local 2050. "It was very carefully crafted, obviously, by corporate attorneys to protect against tort litigation. We still have a long way to go to protect the public adequately. The new warning is better than the old warning, however, it is clearly not the ideal warning." Mark Goldman, manager of Anderson Laboratories, agrees. "It's progress, but it's an incomplete label," he said. Anderson Laboratories tested new carpet samples at room temperature using a standard testing method (ASTM E981) and found that offgassing from some samples -- even as small as sever square inches -- caused severe respiratory and neurological effects, including death, in mice. The ASTM E981 test method was developed by Yves Alarie, Ph.D., in the 1960's under the direction of the U.S. Department of Definse. It was specifically developed to reliably extrapolate mouse data to humans. It has been recommended as a reliable product test in a report commissioned by the CPSC and also by Daniel Costa, of the Environmental Protection Agency's Health Effects Research Laboratory, Pulmonary Toxicology Branch. (1, 2) Regarding the ASTM E981, Costa wrote: "We support the use of the mouse irritancy test for detecting, and possibly for comparing potencies among, indoor air contaminants ... we believe that if the mouse irritancy test is positive upon exposure to a suspected indoor contaminant, then the atmosphere is likely to be irritating to humans." (2) Based on Anderson's test results, which were duplicated by Alarie, Hirzy stated: "It looks like there really needs to be some fundamental changes in the manufacturing processes for carpet and its raw materials. And there needs to be a substantial amount of research into actually pinpointing the causes of the toxicity that Anderson and Alarie are finding." The health effects on the test animals have consistently correlated well with the health effects reported by the people submitting their carpet samples for testing, according to Goldman. He expressed concern that the new carpet label does not address the chronic, long-term health problems being reported by some people. "The label

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gives some cautions about installation and the few days immediately after installation, but it doesn't acknowledge that some carpets are a long-term hazard and may continue offgassing low levels of the chemical mix for years, which is what we are seeing with our test," Goldman commented. "Most people won't notice that the new label says 'most' volatile organic chemicals are substantially reduced within 72 hours. We have not denied that. There are a lot of volatile chemical compounds that leave in those 72 hours, but there are some pretty bad ones that still hang around. And we are seeing continuous degradation in some carpets. So the label is not really addressing the fact that with some carpets you're going to have long-term problems. The real milestone that has to be passed is that they must create a toxicologically safe product. Until that happens, people are still at risk." Rosilind Anderson, Ph.D., director of Anderson Laboratories, believes the label's ventilation message is very inadequate. "Anyone who has had any kind of carpet problem knows that this is not something for which the response is simply ventilate for two or three days. Their recommendation to open your windows and run your exhaust fans will not protect people if they have a problem carpet. Further, there are very, very few doctors who are able to recognize the early signs of carpet toxicity," she said. Other researchers have expressed concern about the label's limitations. "I feel the label is inadequate for several reasons. When you read it, the label gives you the feeling that only people who are sensitive will have an adverse response, and in all reality that is not true," cautioned immunotoxicologist Jack Thrasher, Ph.D. "It really is not giving the full message to the public. Another problem with warning labels of this nature, is that it simply says to notify your physician if you have problems. But if the doctor is not educated regarding chemicals, then how is he going to know what tests to do, what symptoms to look for, and how to determine what is causing those symptoms? In my personal opinion, with a label such as this, it would be incombent upon the carpet industry to inform all treating physicians in the countries where they market their products that there are health problems with carpeting and what those problems are so the doctor would have an idea what to look for." Thrasher is also concerned that the label implies thee is a treatment for the adverse reactions to carpet, while leaving the carpet in place, "when in reality there is no treatment. If carpet is causing problems, the only treatment is to remove it and get it out of the house. All a doctor can do is recognize the problem, run the appropriate tests to determine the extent of the problem, and discuss

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it with the patient so they realize what they must do to prevent further illness. And again, the only way to prevent further illness is to get the carpet out of the house and avoid further exposures," stated Thrasher. In spite of their concerns, Thrasher, Anderson, Goldman, Rand, and Hirzy all believe the label represents a positive step because it at least alerts consumers that symtpoms have been reported. This view was also expressed by the New York Attorney General's office. "I am really hopeful that some people who otherwise would not have thought twice about any of these carpet safety issues will now have the opportunity to think about it because of the label, and will recognize the connection and take steps to protect themselves if they are experiencing symptoms," said Ronna Brown, assistant attorney general at the New York Department of Law. "This consumer warning label makes an important contribution to alerting the public about the range of symptoms many people associate with exposure to the chemicals given off by new carpeting. I urge all consumers to heed the carpet warning label," advised former New York Attorney General Robert Abrams. In spite of the warnings on the new label, CRI still insists thee are no health hazards associated with carpet. "It's not a warning label," stated Kathryn Wise, CRI's director of public relations. "It is a consumer information label. The word 'warning' infers that there is hazard in the product and there has been no proven hazard to carpet." CRI reaffirms this stance in a "Question and Answer" sheet they are distributing throughout the carpet and rug industry to guide sales representatives' responses to consumers. The sheet states in part: (3) Is it really a warning label? Not at all. It is not a warning label because there is no cause for a warning. Scientists have consistently demonstrated that carpet is not a public health hazard. If carpet is not a public health hazard, why is the industry putting any labels on its products? This is the Age of the Informed Consumer. Increasingly consumers are becoming aware of indoor air quality issues and they wat us to be straightforward about carpet's role. The overriding reason for the

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label, brochure, and manual i s to inform the consumer. Haven't there been some tests with carpet that actually killed mice? One isolated laboratory purported last year to have killed mice with carpet emissions. Since then, the Environmental Protection Agency (EPA) and independent tests have been unable to duplicate the results. Scientists tell us that the isolated laboratory experimental tests were seriously flawed and irrelevant. How straightforward is this information? Scientists have published a number of studies indicating human health hazards from working with carpets, including lympocytic leukemia, testicular cancer, oral and pharyngeal cancer, neuropsychiatric illness, and central nervous system damage. (4-8) EPA researchers warn that carpet tests to provide a reservoir for tracked-in chemicals adsorbed to dust, including pesticides, lead, heavy metals, and poly-nuclear aromatic hydrocarbons. The amount of lead found in dust and carpet where a child plays has been found to be the best single predictor of the toddler's blood level of lead. (9-11) In addition, published studies have shown that a large number of chemicals offgassing from carpet are hazardous to human health. For example, formaldehyde is a confirmed carcinogen. Low-level exposures may cause hypersensitivity reactions in humans including eye, nose and throat irritation, bronchial spasm, lung irritation, and dermatitis. CRI's Wise denied that new carpet contains formaldehyde from the manufacturing process, yet significant levels of formaldehyde have been found offgassing from new carpets straight from the mill. (1, 12-16) Other hazardous chemicals found offgassing from new carpet include acetone, benzene, styrene, toluene, and xylene, all of which are included in EPA's Toxic Substances Control Act Inventory and listed on EPA's Community Right to Know List. (1, 12-17) Independent researchers have found the ASTM E981 test method (used by Anderson Laboratories) to be a reliable test for extrapolating human health effects from the mouse data derived from a number of the hazardous chemicals found offgassing from carpet. (1, 12, 14, 15, 17, 18) CRI hired the founder of the ASTM E981 method, Dr. Alarie of the University of Pittsburgh, to investigate Anderson Laboratories' carpet testing protocol and to try to duplicate their test results. At a June 11, 1993 hearing before the House Subcommittee on Environment, Energy, and Natural Resources, attended by VanGelderen, the president of CRI, Alarie testified that not only did he find

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Anderson's test protocol to be scientifically valid, but he was also able to duplicate her test results four times in his own laboratory. (19) Congressman Sanders' aide Pollina was present at a videotaped side-by-side test conducted by the EPA at Anderson Laboratories. The Videotape, which proved EPA duplicated Anderson's test results, was submitted as evidence at the Congressional hearing. (20) In spite of CRI's Question and Answer sheet stating EPA was unable to duplicate the test results, Goldman is still willing to work with industry and EPA as long as there are witnesses. "Let's run the studies with EPA and industry, with observers to make sure that the protocol is truly observed and we are all doing it exactly the same way. Then let's take the samples that prove to be toxic, bring them to an independent laboratory and analyze the fumes that offgas from the sample to see what is in it," said Goldman. "In terms of getting the industry to act, I think they are motivated by the litigation, threat of regulation, and or course concern for economic repercussion, such as loss of market share. I think positive changes are occurring, but very gradually."

Carpet Industry Response Team A Lawyer's Perspective As part of their new "Consumer Information Initiative," the Carpet and Rug Institute (CRI) has assembled "response teams" to investigate carpet complaints in people's homes and office buildings. "CRI is proposing that if someone has a carpet complaint in a home or office building, then they will send a team to that building where they will gather information as to what may or may not be happening in the building," says Congressman Bernard SAnders' [I-VT] aide, Anthony Pollina. "CRI's information says they have created six response teams to investigate carpet complaints. Each team is composed of an independent industrial hygiene consultant, a carpet mill or fiber producer representative, and a CRI testing lab expert." How do those response teams come into play? According to the CRI's director of public relations, Kathryn Wise, when people report carpet-related health problems to CRI," right now we ask about all of the other things that are going on in their homes and what symptoms they have, what kinds of effectss they are having, what kind of cleaning they are doing on their carpet, what other allergies they have. We try to find out a much about what is going on in their work space or home space as wel can, and then if we still have questions about the carpet, we have a team that can be sent -- of people who

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are very adept at determining these things -- and they can determine what the problem is." Attorney Kevin McIvers of Santa Barbara, California, offers the following words of caution about the carpet industry response teams: "How could the CRI possibly do an objective evaluation when they don't even believe carpet makes people sick in the first place? Their public line is that this is all a bunch of baloney. If it was my sick spouse, child, or loved one that was involved and these guys wanted to come out and supposedly help me get to the bottom of the problem, I would be mighty skeptical. And from a lawyer's perspective, I wouldn't let them anywhere near a client of mine. "I think it is ridiculous for them to consistently put out misinformation stating that carpet is not a hazard, and then offer to 'investigate' people's homes. If the day comes when CRI says, 'Yes, carpet does make some people dreadfully ill and it's a serious problem and we want to help,' then I would open the door and let them in. But not until that happens would I even consider it. And why on earth would they send in a carpet mill or fiber producer representative? The role of industry representatives is to promote their products. What qualifications would they have to conduct indoor air quality investigations? What kind of background would they have in neurotoxicology and immunotoxicology? "The timing of this is especially interesting in light of the carpet and rug industry's recent resolve to not concede a single thing on any particular legal claim, and to resist carpet claims at every point. An increasing number of carpet-related lawsuits have been filed. The carpet and rug industry has made an industry-wide decision to fight and win these cases, as evidenced by a memo the CRI sent around to all the retailers. (1) While that is their position, it would just be plain dumb to let those folks come in and try to help with a serious problem like this. "It sounds like a little initial prediscoery. They could get in the person's home or workplace and test the environment -- not to try to figure out whether carpet is making the people sick -- but to try to identify everything else that conceivably could. They can do the same thing that is done in the discovery process of a court case, only they just get a shot at doing it before the poor victim has an attorney and realizes that they're getting clobbered by the opposition. Again, since they don't recognize carpet can be a serious problem, how can they possibly be qualified to investigate a carpet complaint? This leads me to believe that the only thing they

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could possibly be doing is trying to undermine what someone knows to be a carpet problem, and undermine the eventual case if there is to be a case -- at least put the person on the wrong track regarding the cause of their illness. "I sincerely hope the day comes when the industry genuinely recognizes the serious health probelms some carpets pose. When that day comes, I for one -- and a lot of other people that are seriously interested, first and foremost, in helping other people avoid getting this type of illness -- will open my door and heart, and mind to them. That was Jocelyn's [Kevin McIvers' wife, who is also an attorney] and my approach initially when we first contacted the industry because of our son Christopher's carpet-induced tremors. We were wide open and wanted to work with the carpet and rug industry and we just got burned. They lied to use and misled us, and as a result, our little boy was exposed to toxic carpet more than a year longer than he needed to be. And that is just the kind of thing that is going to happen to a lot of other people with this team, I'm sure. It's really sad because in an ideal world one should be completely open with the industry that has a problem and try to help them learn what it's about and get some good case histories. However, while the industry is taking such a dishonest approach to the whole issue, it is just in the best interest of the victims to protect themselves from the carpet industry's agenda." Reference [to "Carpet Industry Response Team"]: 1. The Carpet and Rug Institute. "Typically Asked Questions and Suggested Responses; Carpet/Indoor Air Quality Fact Sheet; memorandum to the carpet industry." (April 1993)

References: 1. Consumer Product Safety Commission memorandum and final report from interagency agreement on volatile organic chemical emissions from carpets. CPSC-IAG-09-1256 (August 13, 1993) 2. Tepper, J.S.; Costa, D.L. "Will the Mouse Bioassay for Estimating Sensory Irritancy of Airborne Chemicals (ASTM E981-84) be Useful for Evaluation of Indoor Air Contaminants." Indoor Environment 1: 367-72 (1992) 3. The carpet and Rug Institute. "Questions and Answers About the CRI Consumer Information Initiative; Carpet and IAQ - CRI Consumer Information Kit Distribution Plan - Sales Representatives'

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Participation." Memorandum (December 7, 1993) 4. Ekberg, K.; Barregard, L.; et al. "Chronic and Acute Effects of Solvents on Central Nervous System Functions in Floorlayers." British Journal of Industrial Medicine 43(2): 101-106 (1986). 5. O'Brien, T.R.; Decoufle, P. "Cancer Mortality Among Northern Georgia Carpet and Textile Workers." American Journal of Industrial Medicine 14:15-24 (1988). 6. Huebner, W.W.; Schoenberg, J.R.; et al. "Oral and Pharyngeal Cancer and Occupation: A Case-Control Study." Epidemiology 3(4): 300-309 (1992). 7. Axelson, O.; Hane, M.; Hogstedt, C. "A Case-referent Study on Neuropsychiatric Disorders Among Workers Exposed to Solvents." Scandinavian Journal of Work Environment & Health 2:14-20 (1976). 8. Rumiantsev, G.I.; Prokhorov, N.I.; et al. "Experimental Studies of the Combined Effect of Styrene in General Vibration." (in Russian) Gig Sanit 9:32-36 (1990). 9. Roberts, J.W.; Budd, W.T.; et al. "Chemical Contaminants in House Dust; Occurrentces and Sources." Indoor Air '93: Proceedings of the International Conference on Indoor Air Quality and Climate 2:27-32 (1993). 10. Davies, D.J.A.; Thorton, I.; et al. "Relationship Between Blood Lead and Lead Intake in Two Year Old Urban Children in the UK." Science of the Total Environment 90:13-29 (1990). 11. Budd, W.T.; Roberts, J.W., Ruby, M.G. "Field Evaluation of a High Volume Surface Sampler for Pesticides in Floor Dust." Environmental Protection Agency, EPA 600-3-90-030, PB 90-192006 (1990). 12. Kirchner, S.; Karpe, P.; cochet, C. "Characterization of Volatile Organic Compounds Emission from Floor Coverings." Indoor Air '93: Proceedings of the International Conference on Indoor Air Quality and Climate 2:455-460 (1993). 13. Pliel, J.D.; Whiton, R.S. "Determination of Organic Emissions from New Carpeting." Appl. Occup. Environ. Hygiene 5:693-699 (1990). 14. Schaper, M. "Development of a Database for Sensory Irritants and Its Use in Establishing Occupational Exposure Limits." American

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Industrial Hygiene Association Journal 54(9):488-544 (1993). 15. National Institute for Occupational Safety and Health. NIOSH Pocket Guide to Chemical Hazards, Washington, D.C.: U.S. Government Printing Office (June 1990). 16. Lewis, R.J. Sax's Dangerous Properties of Industrial Materials, New York: Van Nostrand Reinhold (1989). 17. Black, M.S.; Work, L.M.; et al. "Measuring the TVOC Contributions of Carpet Using Environment Chambers." Indoor Air '93: Proceedings of the International Conference on Indoor Air Quality and Climate 2:401-405 (1993). 18. Anderson, R.C., "Toxic Emissions from Carpets." Indoor Air '93: Proceedings of the International Conference on Indoor Air Quality and Climate 1:651-656 (1993). 19. Testimony of Yves Alarie before the Committee on Government Operations, Subcommittee on Environment, Energy, and Natural Resources, U.S. House of Representatives. Re: Carpet research (June 11, 1993). 20. Duehring, C. "Carpet. Part I: EPA Stalls and Industry Hedgest While Consumers Remain at Risk." Informed Consent 6-11, 30-32 (1993). Toxic Carpeting Important Points to Remember

Negative Health Affects ----------------------1. Lack of acute reactions to toxic carpeting are common, but the chemicals may be causing serious damage nonetheless. The ASTM E981 tests on carpeting are *short-term* exposure which tests for respiratory and neurological reactions. It is of note that some carpeting was so toxic that short-term exposure to animals caused serious reactions, including death. The ASTM E981 test *does not* measure immunological problems caused by carpet exposure according to Mark Goldman of Anderson laboratories. The mouse would not be the best model for testing immunological repsonse. Nor does the test measure health effects from long-term exposure to

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toxic carpeting. Therefore, the lack of acute adverse reactions (e.g., headaches, breathing difficulties, seizures, etc.) does not mean that the chemicals coming off of the toxic carpet is not causing slow, silent damage. One can see from the health affects suffered by carpet installers that the carpeting can and does cause serious adverse effects from long-term exposure -- from neurological problems to possibly contributing to or causing cancer. Many people are developing disorders such as Chronic Fatigue Syndrome, Lupus, Fibromyalgia, psychological illnesses, etc. None of these people *expected* to get their illness. I believe that carpeting will make a person much more susceptible to getting a chronic illness in the future. Therefore, whether or not you are one of the many who have adverse to reactions to carpet immediately, you are setting yourself up for future problems by dosing yourself with dangerous chemicals on a regular basis with carpeting. Please pay attention to this warning. Sucking down toxic chemicals may seem okay now, but you may pay a very heavy price in the future. 2. Health Problems Linked to Carpeting -- What To Do? If you think that your health problems may be caused or contributed to by toxic carpeting, first contact the Citizens for Safe Carpet (P.O. Box 39344, Cincinnati, OH 45239, 513/385-1111). They can help walk you through the steps you need to take. In addition, your may want to contact the Environmental Access Research Network (EARN) (P.O. Box 1089, Minot, North Dakota 58702-1089, 701/837-0161). You will need to contact your healthcare practitioner immediately. You will also need to be tested to see if the carpeting is the cause of the problem. Contact the groups mentioned above so that you don't forget any important steps. Whatever you do, *do not* contact the Carpet and Rug Institute to have them send out a team to "help" you with the problem. They are not there to help you, only to put the blame on everything but the carpet. Of course, looking at other possible causitive factors is important, but the CRI will never admit the carpet causes a serious problem. Do not contact the EPA or Consumer Product Safety Commission (CPSC) with the expectation of getting help with

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the problem. While they may do good work on other issues, they are in bed with the industry on this issue, so do not trust anything they say. If you or your family has suffered serious adverse effects from toxic carpeting, you may want to consider being part of a class action lawsuit. While I am not a big fan of lawsuits, this appears to be the only leverage we have in protecting the public, as the agencies sworn to protect the public are doing more to help the industry poison the public than they are to protect the public as far as the carpeting issue is concerned. In addition, many people deserve compensation for the damage that the carpeting has caused.

Testing ------1. Testing carpet emissions *does not* necessarily help assure lack of toxicity. As mentioned earlier, there are thousands of chemicals used in the manufacture of carpeting. Many of them stop offgassing after a few days or a few months. Other *dangerous* chemicals often continue to offgas for years (despite what some "industry experts" say). While one can test for common chemicals that come off of carpeting, it is impossible to know what chemicals might be coming off the carpet that can cause health problems over time. They may be chemicals used in the manufacture of the carpeting, or they may be chemicals that are formed through chemical reaction. Testing for chemical emissions are probably not that helpful in the sense of showing lack of toxicity. So what if one does not find formaldehyde or toluene! There can be an endless number of chemicals that can cause problems. Testing for chemical emission may help provide clues as to what is causing a health problem caused by toxic carpeting -- if one can guess correctly as to what chemicals to test for. Terminology ----------1. "Non-toxic" or "low-toxicity" carpeting refers to the carpeting mentioned in the resources section of Part One of Cindy Duehring's article. 2. "Toxic Carpeting" refers to the carpet sold in most carpeting stores. Please get this terminology correct -- it's "toxic carpeting," not "carpeting." Of course, the toxicity varies between carpet rolls, but how is one to know how toxic the carpeting is? The ASTM E981 test can help, but only in the case of short-term,

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neurological and respiratory problems caused by carpeting.

Things To Be Expected From the Carpet Industry (e.g., Monsanto, CRI, etc.) ---------------------------------------------1. They will probably flood the scientific community with flawed studies "proving" the safety of carpeting. Some of these companies have down similar things with other toxic products. (See the Aspartame Review at: http://www.holisticmed.com/aspartame/ for a good example of the abuse of science in the name of protecting a toxic product.) They may fund studies which are flawed or their researcher may obtain public funding for flawed studies. Remember, it has already been proven that animals can suffer from severe neurological and respiratory problems from exposure to carpeting. In addition, these tests do not even begin to address the dangers of long-term exposure to these toxic chemicals. Anytime you read in the news that "such and such" university or team of "researchers" has proven that toxic carpeting or "new" toxic carpeting or "new, low-emission" toxic carpeting (or whatever their PR department decides to call it) does not cause health problems, it is probably a typical, flawed industry study. Contact E.A.R.N. or Citizens for Safe Carpet or Anderson Laboratories for an *honest* evaluation of this new research. 2. They will probably come out with new "non-toxic", or "low-emission" products. In all liklihood, this will probably be more of a creation of their PR departments than a quality product. The real low-toxicity products were listed in Part One of the article by Cindy Duehring. Reducing the number of chemicals used in the carpeting industry from 1,000s to 100s or even to just a few is a possible improvement, but it is also very possible that these carpets are still quite toxic. Don't be conned by their marketing terms. Look into *real* non-toxic carpeting or flooring (using low-toxicity glues or tacking down the carpet). If Monsanto actually comes out with completely non-toxic carpeting, I'll be happy to congradulate them and recommend their product for those who have to have carpeting. Until then, see the resources in Part One of Cindy Duehring's article

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for non-toxic solutions. 3. They may send out inaccurate information to the retailers. I strongly recommend not putting any faith in information provided by the retailers as it comes directed from the manufacturers of these toxic products or from the CRI. If you want to read a fairy tale, go to a good children's book store. Now the retailer may very well think that they are getting accurate information from the manufacturer, so they are not necessarily to blame. 4. The industry may agree to a large warning label on the toxic carpet. Even if the label contains a strong warning, detailed recommendations, a list of doctors (worldwide) who are experienced in dealing with the effects of toxic carpeting, and the Encyclopedia Britanica, you are still left with *toxic carpeting*. Of course, a decent information label is useful, but the label *will not* protect you or your family unless it covers the whole carpet and doubles as a heavy-duty air filter. Therefore, if you hear news about the "great new carpet label," please realize that it's still a toxic carpet with a "great new carpet label." 5. The industry may try to discredit certain individuals in order to get the public to ignore the serious warning that they are presenting. Their memorandum and the vicous attacks on Dr. Anderson's credibility are examples of this. Even if they do discredit an individual's reputation, the message is still valid and the health problems caused by toxic carpeting are still occuring. 6. The industry will probably continue to enhance their apparent close ties to the EPA policymakers and the Consumer Product Safety Commission (CPSC). Therefore, anytime you see the industry quoting the EPA or CPSC, it is probably extremely biased information *if* it is accurate at all. 7. My experience tracking how industry helps protect their toxic products is by giving money to the campaigns of key senators and representatives. In this way, hearings can be blocked, bills can get stalled in Committees or gutted so that they are meaningless. This is what happens when extremely powerful lobbying groups decide they want something. Money comes before public health in some cases unless the public puts alot of pressure on their Congressional Representatives. To understand how PR techniques are sometimes used to by Monsanto,

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Dupont and others to con the general public, please purchase and read the excellent new book: Toxic Sludge is Good For You! (Lies, Damn Lies and the Public Relations Industry by John Stauber and Sheldon Rampton Common Courage Press, Monroe, Maine (USA), c1995 ISBN 1-56751-061-2 or ISBN 1-56751-060-4 (pbk.) This book will help you understand what tricks to expect from Monsanto, Dupont, and others as scientists and the general population recognizes the dangers from exposure to toxic carpeting.

Things To Be Expected From the EPA and the CPSC ----------------------------------------------1. In my opinion, as public pressure mounts, they will try to create the appearance of protecting the public, but still do what they can to protect industry. I would strongly recommend that you take any statement from these organizations on the carpeting issue as if it came from the carpeting industry even if it appears they are comprimising. Please contact the reputable organizations mentioned earlier for an honest review of any new information.

Things You Can Do ----------------1. If your employer or children's school or daycare are planning on getting a toxic carpet, be very firm with them that you insist upon *NO* toxic carpeting. Give a copy of the articles to all of the employees or parents so that everyone is aware of the dangers. 2. While toxic carpeting may be one of the biggest sources of indoor air pollution, there are other sources. Please become aware of products that are toxic even in small amounts and those products developed by *consciencious* manufacturers which are *non-toxic*. What follows is a list of books that can be very helpful. "The Healthy Home: An Attic-To_Basement Guide to Toxin-Free Living" by Linda Mason Hunter Pocket Books, c1989 ISBN 0-671-70819-8 Very good reference to have on hand for avoiding toxic substances in the home. Contains a resources chapter for nontoxic products.

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"The Nontoxic Home" by Debra Lynn Dadd Jeremey P. Tarcher, Inc., c1986 ISBN 0-87477-401-2 A classic book by Debra Lynn Dadd on how to avoid toxic chemicals in the home. "The Nontoxic Home & Office" by Debra Lynn Dadd Jeremey P. Tarcher, Inc., c1992 ISBN 0-87477-676-7 A classic book by Debra Lynn Dadd on how to avoid toxic chemicals in both the home and the office. Very helpful for persons trying to avoid "sick building syndrome" at the office. "Nontoxic, Natural, & Earthwise" by Debra Lynn Dadd Jeremey P. Tarcher, Inc., c1990 ISBN 0-87477-584-1 This book does not contain as much discussion as her other books, but does contain an enormous list of resources for nontoxic products. I highly recommend all of her books, especially this one. "Clean & Green" by Annie Berthold-Bond Ceres Press, Woodstock, NY, c1990 ISBN 0-9606138-3-8 One of the best books available for nontoxic and environmentally safe housekeeping products. The resources section of this book is outstanding. It contains the following sections: - Manufacturers and Distributors - Mail Order Suppliers - Organizations Geared Toward the Development of Healthy, Practical and Earth-Safe Practices in the Home - Consultations on Environmentally Safe Cleaning For Industry, Business and the Home - Scientific Testing Devices - Consultations for Nontoxic and Environmentally Safe Building - Pesticide Alternative Resources - Pet Care Resources - Clean Water Organizations - Alternative to Chemicals Brought Into the House - Information on Chemicals in Our Foods - Information on Recycling

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- Education, Seminars, and Correspondence Course on the Construction of Healthy Homes and Workspaces Final Note ---------I find it reprehensible that the carpet companies such as Monsanto, the Carpet and Rug Instute (CRI), the U.S. Environmental "Protection" Agency (EPA) and the Consumer Product Safety Commission (CPSC) would all be so immoral and heartless that they would continue to let so many people suffer serious damage to their health (including children) simply so the industry can make more money and avoid lawsuits. These groups are abusing the scientific processes and they are abusing the population. I sincerely hope people will, unlike the organizations mentioned above, look out for each other by passing this information along to people who are interested in flooring. Best regards, - Mark mgold@holisticmed.com http://www.holisticmed.com/ (Web articles on Food & Nutrition, Yoga, aspartame, sweetener resources, stevia, toxic carpeting, rBGH. Lots of links to medical and holistic healing sites.)

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