Urge to Fund National Epidemiological Study on Causes of Toxic Chemical Injury to Humans

In accordance with The Constitution of the United States, we ask that the Federal Government of the United States of America establish, insure, provide, and promote the general Welfare of its citizens by taking the lead to educate and promote awareness of  toxic injury caused by, and causing a body burden of, chemicals found in everyday consumer products through executive order, proclamations, and programs funded by the Congress for the general welfare as follows: 

(1)   In accordance with recent research, draft and pass bills for Congress and the Executive Branch to revisit all laws that are outdated and have not kept up with the body of new science that shows that small exposures to mixtures of organic/toxic chemicals can cause cellular changes to the human body.  Exposure to these toxicants can cause teratogenic, respiratory, gastrointestinal, cardiovascular, hepatic, renal, and neurological effects.  They can also lead to various forms of cancer as well as learning disabilities.  Such effects can occur after short-term (acute) or long-term (chronic) exposure, depending on the toxicity of the chemicals.  It is currently held that once toxic chemical injury set in, there is no cure; there is only non-exposure to the toxicant(s).

Only a small percentage of chemicals out of over 80,000 found in commerce are tested.  Thousands more are being added each year.  About 15,000 have been tested, producing estimates of potential risks from exposure.  However, each chemical was tested individually rather than in combination.  In the real world, individuals are exposed to a cocktail of toxicants on a daily and nightly basis.  These chemicals need to be tested in combination, starting with fragrances.

Scientists estimate that everyone carries within him or her at least 700 contaminants (mostly toxicants) whether we live in the country, suburbs, or city.  We have become a receptacle for a multitude of industrial chemicals (such as pesticides, dioxins, furans, toluene, formaldehyde, phthalates, PCBs, VOCs, etc., not to mention that many of these toxic chemicals often coat the surface of dust particles (a daily event).

All such laws and regulations need to be carefully promulgated on the grounds that they promote the general welfare.

To be noted, according to Title 5, Section 553(e), “each agency shall give an interested person the right to petition for the issuance, amendment or repeal of a rule.”  According to Title 5, Section 551, the definition of “’person’ includes an individual, partnership, corporation, association, or public or private organization other than an agency.”

(2)  Make it mandatory for manufacturers to list the chemicals used in fragrances. Since most perfumes are compositions of chemicals, they should be patented under Class 512 so that consumers can determine if they are reactive to any of the chemicals or chemical mix to avoid toxic chemical injury.  Fragrances should no longer be held as proprietary by the chemical/fragrance industry.

(3)  For the Executive Branch to continue and expand actions adopted by Federal agencies such as the U.S. Social Security Administration, the Centers for Disease Control, the U.S. Access Board, etc. for implementing Fragrance-Free/No Smoking Zones without harassment or hindrance.  These agencies deserve exemplary recognition.  Further, to recognize States that have issued proclamations to raise awareness of toxic encephalopathy, chemical injury, multiple chemical sensitivities, toxic chemical injury, and the like.

(4)  There is a need for public policy on chemical exposure.  A national debate for a cohesive public policy for the welfare of a people is a moral imperative similar to climate change, for chemical exposure is increasingly identified as one of the major crises facing the international community in the 21^st century. 

From the authors of Chemical Exposures: Low Levels and High Stakes, Nicholas A. Ashford and Claudia S. Miller (1998, John Wiley & Sons, Inc., Canada), "We are at a critical crossroads to do something significant about the groundswell of activity that requires in-depth and thoughtful attention to chemical sensitivity. Chemical exposures are endemic to our modern industrial society. Public policy needs to focus on two distinct groups of individuals who suffer from [toxic chemical injury]…. There are those individuals who could be sensitized as a result of an initiating exposure, and there are those individuals who have already become sensitized and now report sensitivities to chemicals at extremely low levels. Regulations and policies need to be developed to prevent sensitization of individuals in the first place. Sensitizing events occur in domestic indoor, recreational centers, workplaces, and shops such as exposure to classical sensitizers such as toluene diisocyanate or to solvents…."

From the World Health Organization, “air pollution is the number one cause of cancer.”  Air pollution seeps into rivers, is carried by dust, lands on food crops. and enters the soil. The economic cost of such pollution is staggering as it affects health resources, productivity, and the like.  We do not need to find ourselves in a similar situation as China’s current toxic air pollution which is impeding phytosynthesis and weakening food supplies.  This year a leading Chinese scientist reports evidence that China’s toxic air pollution, if it persists, will resemble somewhat nuclear winter (He Dongxian, China Agricultural University, College of Water Resources and Civil Engineering).

The traditional view of air pollution, focused principally in vehicular exhausts and smokestack emissions, must know be broadened to include toxins/toxicants found in consumer products and indoor air pollution.  

(5)  Conduct legitimate epidemiological studies, free from special interest tethers. 

A benchmark study conducted in 2004, “Prevalence of Multiple Chemical Sensitivities:  A Population-Based Study in the Southeastern United States by Drs. Stanley M. Caress and Anne C. Steinemann, needs to be expanded.  The abstract of the aforementioned study is as follows:  “We examined the prevalence of multiple chemical sensitivities (MCS), a hypersensitivity to common chemical substances. We used a randomly selected sample of 1582 respondents from the Atlanta, Ga, standard metropolitan statistical area. We found that 12.6% of our sample reported the hypersensitivity and that, while the hypersensitivity is more common in women, it is experienced by both men and women of a variety of ages and educational levels. Our prevalence for MCS is similar to that (15.9%) found by the California Department of Health Services in California and suggests that the national prevalence may be similar.”  In 1981, the National Academy of Sciences reported that 15% of the American population could have a heightened sensitivity to chemicals.”

Conservatively, this could easily mean that approximately 47.6 million Americans in 2014 are suffering from across the spectrum of chemical injury.

According to the Northwest ADA (Americans with Disabilities Act) Center, approximately 140 million Americans suffer from some form of toxic chemical injury and exposure that it is “the fastest growing segment of the disabled population.”  Those diagnosed with toxic chemical injury are not being protected, and their basic civil rights are being denied. 

Ensure that scientific studies are well-founded, well–formulated, and well-funded; that these studies be broadened to include other illnesses linked to chemical injury—toxic encephalopathy, asthma, Alzheimer, fibromyalgia, chronic fatigue syndrome, and the like; and that these studies explore the physiological origins of chemical injury as well as any psychological origins stemming from chemical injury.  Anecdotal evidence is to be used only to communicate what has been supported by evidence-based medicine and scientific evidence shorn of any cognitive bias.

It is imperative that funds from any chemical industry are not used with the expectant result that the origins are psychological in nature rather than physiological. Past and current tendencies to dismiss these disorders, illnesses, or diseases as psychological in origin should not be allowed to obscure findings of compromised human body filtering organs such as liver, kidneys, spleen, urinary bladder, lymphatic vessels as more and more studies now recognize toxic chemical injury.

Moreover, international studies should be included in such studies as original sourcing material.

The current confusion as to the cause(s) of substantial personal injury or substantial illness needs to be resolved so that the proper health services can be administered for the health and welfare of the citizenry.  Too much medical attention is on symptoms in lieu of causes.  Chemical injury needs to be recognized as causing substantial personal injury or substantial illness “during or as a proximate result of any customary or reasonably foreseeable handing or use, including reasonably foreseeable ingestion” by skin or mouth

(C.P.S.C. regulation).

Research in the past decade has shown that illnesses can be traced back to an overload of toxicity, creating chemical body burdens in individuals, and exposed communities through the manufacture, processing, interstate transportation, consumption of these toxicants in commercially available products.

(6)  Encourage each State to join in the effort to promote and fund without limitation for the general welfare of the Nation. 

(7)  To secure the blessings of [natural] liberty to ourselves and our posterity, recognize that liberty comes at a cost.  Whether it deals with the relationship between individuals and a civil society or with the relationship between the States and the Federal government, there is no relationship to be had if a law and implementing regulations results in selfish benefits for a few at the expense of the whole.  “Ourselves and our posterity” applies to individuals who make up the citizenry of a State and a country.

Consequently, recognize that the health of the entire population of the United States is at risk from chemical exposures because low toxic levels can lead to illnesses that may be preventable through reduction or avoidance of chemicals in the air water, soil, food in both the indoor and outdoor environment.

The moral obligation to protect the health of ourselves and our posterity must ensure equal treatment for everybody in need of health care and a healthy environment, free from political opposition, since we are all in it together.  In the words of our founding father, President George Washington, “the independence and liberty [we] possess are the work of  joint efforts, of common dangers, suffering and successes.” Caring for the health of a Nation by avoiding exposure or effectively restricting the use of toxicants is precautionary, progressive, a preventive measure, and not a privilege but a basic right.