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Update on Industry Research

By Mark D. Gold

Late in 1994, the Journal, "Food and Chemical Toxicology" published aA study conducted by scientists of E.I. du Pont de Nemours and Co.,And the Monsanto Company. These industry scientists found no effectsfrom the carpet sample which Dr. Rosalind Anderson of AndersonLaboratories found to cause moderate to severe pulmonary irritation,slight to moderate sensory irritation, and neurotoxicity.

According to Mark Goldman, the manager of Anderson Laboratories, theindustry scientists change Dr. Anderson's protocol in such a way thatno adverse effects will be found. Two common techniques that theindustry uses, according to Dr. Goldman, are keeping the humidity toohigh so that the toxic chemicals are end up in the water as opposedto being inhaled, and to change the material which the exposure tankare composed of.

It is really a moot point as far as toxic carpeting causes anywherefrom mild to severe reactions in test animals using the ASTM E981testing procedure. Dr. Anderson has tested over 100 samples whichproved to be toxic. Dr. Yves Alarie, the inventor of the ASTM E981testing procedure reviewed Dr. Anderson's protocol and said it wasvalid. Dr. Alarie also repeated Dr. Anderson's tests on carpetsamples and verified her results *four* times in his laboratory. TheEPA was videotaped in a side-by-side test at Anderson Laboratoriesproving that the carpet sample they chose caused severe problems inanimals. The reactions in animals found in Dr. Anderson's test oftenmimiced the acute reactions that were found in humans exposed to thesame carpet.

The industry article appeared in the journal, "Food and ChemicalToxicology." In my opinion, this journal is heavily biased towardspublishing research which exonerates unhealthy and even dangerous foodand chemical products. The editor of this journal, Dr. JosephBorzelleca is a consultant scientist for the Carpet and Rug Institute(CRI).

The Consumer Product Safety Commission (CPSC), an organization whichhas already shown that it is in bed with the carpet and rug industry,recently gave $60,000 to Air Quality Sciences lab to perform carpettesting. According to Mark Goldman of Anderson laboratories, AirQaulity Sciences lab receives money from the carpet industry. ****NOTICE ****

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This series of articles is presented with the permission of theauthor, Cindy Duehring (per phone conversation on 10/4/95). Forconsiderably more extensive documentation on the hazards of toxiccarpeting 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 theauthor, Cindy Duehring (per phone conversation on 10/4/95). Forconsiderably more extensive documentation on the hazards of toxiccarpeting 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 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 DavidBuechler, a Sawyer, North Dakota carpet installer who has been layingcarpet for twenty-fie years. "I don't know any other carpet layerswhose health isn't affected by the job in some way."

Buechler experiences a number of adverse symptoms when he works withcarpet. "The fibers and the chemicals affect your lungs and yoursinuses," he says. "Every time I lay carpet I sound like I have acold by the end of the day. I get hoarse, shortness of breath, andmy sinuses clog up. I get sinus infections on a regular basis.Also, my doctors attribute the arthritis I developed to inhaling thefumes from the carpet glues."

He adds, "Cancer, especially lung cancer, is a big concern. I knowof about eight carpet layers in my area that were laying carpet whenI started out, who have all died of lung cancer. THey never made itto retirement."

Insurance companies are aware of the risks, according to Buechler."It's hard to get life insurance if you're a carpet installer, hestates. "And they require a really tough physical for medicalinsurance if they find out you lay carpet. I have also been toldthat if I hire a young guy to work for me I need to get a releasesigned so that if he's laying carpet and comes down with cancer yearsdown the road, I won't be held responsible."

Some of Buechler's customers have had adverse health effects fomcarpet. He now regularly cautions new customers to stay away duringinstallation, to keep off the carpet for several days during theinitial high offgas period, and to ensure the house is continuouslyventilated. He voices concern that some carpets appear to be moretoxic than others, and he advises people not to take any chances iftheir carpet causes chronic health problems. He would rather seesomeone remove their carpet than have serious long-term consequences.

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Buechler says he has found that some people who react to one carpetmay not react to another.

To reduce the todal amount of volatile organic compounds (VOCs) thatpeople are exposed to from carpet systems, "we are going almost onehundred percent away from the glue down carpet," says Buechler. "Wetack it down because the glues offgas a lot of toxic solvents and addto the toxicity that is already present from the latex backing.Rubber padding can be a toxicity problem, too." He tells of a timewhen a young neighbor girl laid on a roll of rubber padding whilewatching cartoons on TV: "She fell asleep and when she woke up, allshe had was slits for eyes because her face was so puffed up. Iwouldn't have recognized her if I hadn't known who she was. And shewas only on that rubber padding for just one hour."

Buechler no longer uses a van to haul carpet to his work sitesbecause he says fumes in the enclosed space were affecting him. Onsome days, "by the time I'd get to the job, I'd have such a headacheI 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 seamingprocess, according to Buechler, who explains, "The warnings I getalong with the carpet say do not breathe the fumes and do not burn orget near flames and so on. But you have to during the seamingprocess. You really get exposed to some nasty fumes because you usea hot seaming iron to melt the vinyl and plastic material. It'sabout 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, wasfinally forced to quit when his symptoms reached disablingproportions. He started laying carpet as an apprentice in 1966 inMinneapolis, Minnesota, then went into business on his own in 1968.Schmidt has noticed a change in the toxicity of carpet over theyears. "I've had a carpet warehouse for eighteen years," he says."When we first bought the warehouse, we used to have jute backedcarpet with the burlap on the back. Back then we had a terribleproblem with mice building nests in the carpet rolls and we had tokeep mouse traps out all the time. Now I haven't had a mouse inthere in twelve to thirteen years. There's no live bugs in thereanymore either. Not even ants. The only animals we've found in thewarehouse were a couple of dead squirrels. It's the same warehouse.Nothing has changed but the floor covering."

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After installing carpet for many years, he gradually developed avariety of neurological and respiratory symptoms including numbness,tingling, dizziness, ringing in the ears, shortness of breath, jointpain, forgetfulness, fatigue, irritability, and tremors.

I never dreamed my life would turn out this way," says Schmidt. "Iloved my work. It was a good job. All I ever wanted was to do anhonest days' work in a steady job to put a roof over my head, feed myfamily, 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 somuch that I can hardly function. I drop stuff, I can't hang on tothings, 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 byneuropsychiatrist Richard Nelson, M.D., in Billings, Montana. Bothevaluations found evidence of peripheral neuropathy. Blood tests atMayo Clinic revealed high levels of arsenic. Arsenical pesticidesare registered for use in carpets.(1) Further testing showedelevated benzene, a neurotoxic solvent found in carpet.(2) His bloodwork also showed various immune abnormalities consistent with thepatterns being found in chemical injury. (3,4) Schmidt has elevatedTA1 cells, decreased B lymphocytes, autoimmunity (meaning that thebody's immune system has mistakenly identified its own tissues orcellular components as foreign and has directed antibodies againstthem). He has autoantibodies to smooth muscle, central nervoussystem, and peripheral nerve myelin. Neurometric testing includingelectroencephalogram (EEG) P300 latency assessment evidencedcognitive 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'snot just me. I know of other carpet layers who are disabled from thechemicals in carpets." According to Schmidt, the CRI's response wassimply a denial of the problem, and claims that they had never heardof any problems from other carpet layers. "I was outraged," saysSchmidt. "I told them, we've given all the working years of ourlives to the carpet industry. We've supported you all the way andwe'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 leftus in limbo out here, unable to work, unable to pay our bills. I'vegot children to feed, and as long as you and the EnvironmentalProtection Agency (EPA) won't own up to the problem and acknowledgethat chemicals in carpeting are disabling some people -- especiallythe carpet layers who are getting sick -- then workers' compensationwon't even pay my medical bills for the neurological and

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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 hismedical testing reports, including the letters from his doctors, tothe CRI by certified mail and sent copies to Congressman Mike Synar[K-OK] and Vice President Al Gore. "I just wanted to have proof thatI told them so they can't deny that they've received complaints fromcarpet layers," states Schmidt.

Since then, has the CRI changed its tune? When asked if they hadheard of any health problems from carpet layers or whether any carpetlayers had complained, CRI Director of Public Relations, Kathryn Wisestated, "No. We're not aware of any." (5)

"Why are they turning their back on us?" asks Ron Braithwaite, acarpet installer from Perth Road Village, Ontario, Canada. "Icontacted the United States CRI about a year ago and told them I washaving 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'mthe only one.'" He later spoke with other carpet layers in Canadawho were experiencing adverse health effects from the carpet andfound they were being told the same thing. "So as long as they'retelling us that, then we think we're the only ones with the problemand that it's not affecting anybody else," he says.

Thirty-nine-year-old Braithwaite started laying carpet when he wasten years old, helping his father who was also a carpet layer. Hesays, "My dad died of lung cancer when he was fifty-eight. Anothercarpet layer who was a good friend of his died the same way. Thereare a lot of carpet layers in our area that died of cancer anddeveloped other serious health problems when they were relativelyyoung."

Other the years Braithwaite developed a number of symptoms whichgradually worsened to the point where he is now disabled.Neurological testing, including a SPECT scan (single photon emissioncomputed tomography) conducted in the nuclear medicine department ofOttawa General Hospital, verified damage to his brain, especially tohis posterior parietal lobes. His doctors are convinced that thesolvents and other chemicals in the carpets and glues Ron was workingwith 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 andneedles in his lower arms and hands. He has found that his symptoms

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worsen when he is around the low levels of petrochemicals commonlyfound in many public buildings, which limits him still further.

Braithwaite wants his health back. But that is not all he wants. "Iwant to know the names of all the chemicals I have been working withfor the past twenty plus years. I should have a legal right to knowwhat has been poisoning me," he says. "I want to know why I wasnever given any warnings about any of this all the years I laidcarpet. And I want to know how to tell my two young children thattheir daddy is too sick to go to their school play or go on the swingwith them, or help build a snowman. I want to know how to tell mychildren why mommy and daddy seem to be arguing all the time becausetheir 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 alocal corner store. Donna Braithwaite often works eight-hour weeksat their store in an effort to support their family. As Ronstruggles to cope with hsi disability, he spends his time gatheringinformation regarding the health effects of chemicals in carpets, andplant to start a support group. He wonders, "How many otherfamilies, including vulnerable little children, have to be madeseriously ill by carpet before the CRI honestly admits to the problemand stops putting out products that place people at risk?"

Nothing has been proven to date that links carpet and ill healtheffects," says the CRI's Kathryn Wise. (5)

"This type of denial is just exactly what the tobacco industry hasdone for years and to a large degree is still doing," attorney KevinMcIvers of Santa Barbara, California, states. "It is based on a typeof technical scientific nonsensical argument where they take theposition in court -- and in my mind this takes tremendous nerve forthem to say this -- that there is no scientific evidence that smokingcigarettes causes cancer. And then of course folks like us say 'Wellthen, why do people die of cancer three or four times as often w henthey smoke cigarettes than when they don't?'

You would think that finding is pretty scientific, but what they aretalking about is the technical argument. There is no one who cancompletely explain exactly what chemicals in cigarette smoke causeswhat precise biomolecular changes that actually mutate the cell andlead to that downward path to cancer. So because of that, they saythere is no evidence that it makes you sick, and that's nuts. Justbecause you don't understand the mechanism doesn't mean it's nothappening. People get around these products and they become

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dreadfully ill. But that is not enough for the tobacco industry andthe CRI."

A quick scan of the medical and scientific literature reveals thefollowing:

- 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

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lab hired by the CRI (15), and by the U.S. EPA in a side-by-side testat Anderson Labs. (16) Mice exposed to air passing over a seven-inchsquare piece of carpet at room temperature exhibited respiratory andneurological symptoms, and some died. (17)

The ASTM E981 method was developed by Yves Alarie, Ph.D., in the1960s under the direction of the U.S. Department of Defense. It wasspecifically developed to reliably extrapolate mouse data to humans.It has been recommended as a reliable product test in a reportcommissioned by the Consumer Product Safety Commission (CPSC) andalso by Daniel Costa, of EPA's Health Effects Research Laboratory,Pulmonary Toxicology Branch. (2, 18) Costa wrote regarding the ASTME981, "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 uponexposure to a suspected indoor contaminant, then the atmosphere islikely to be irritating to humans." (18)

This method has been used extensively by both government and industryover the years to determine irritant effects of chemicals and toextrapolate those results to humans. A recent review article foundthat at least 295 chemicals had been evaluated by the ASTM E981method in the published scientific literature. Eighty-nine of thosechemicals have occupational exposure limit values (threshold limitvalues) against which the adequacy of the ASTM E981 tests werecompared. The ASTM E981 was found to be a reliable indicator forhuman 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 ofairborne chemicals. ... Certainly, the bioassay has withstood thetest of time and the various mechanisms by which sensory irritationoccur have now been well-delineated. ... Analysis of the now muchlarger database proves that the bioassay is even better at predictingsafe levels of exposure for humans than originally suggested byAlarie." (19)

At the CRI's request, Dr. Alarie visited Anderson Labs to review thequality and methodology of Anderson's handling of the ASTM E981, andfound that it was scientifically valid. The CRI then hired Alarie totry to duplicate Anderson's results. Alarie testified at a June 11,1993, carpet toxicity hearing before the House Subcommittee onEnvironment, Energy, and Natural Resources, that "her description ofthe effects observed was correct and her experimental design wasvalid," and that he was able to replicate her results four times.(15)

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Mark Goldman, manager of Anderson Labs, reports that autopsies onmice exposed to carpet fumes using the ASTM E981 method have shown avariety of lesions including brain and liver lesions, as well askidney degeneration. The consulting pathologist noted no predictablepattern for the lesions, "but, you don't expect to see lesions insuch a short-term low level exposure," Goldman says.

In spite of the evidence, the CRI distributed an April 1993memorandum throughout the carpet and rug industry, calling the testused by Anderson Labs into question and stating that the CPSC, EPA,and independent labs had all "failed to discover any evidence linkingcarpet and ill health effects." The memorandum, which wasdistributed to carpet retailers as well, assured them that a classaction lawsuit regarding carpet toxicity would be "defendedvigorously and successfully." (20)

Carpet installer Schmidt says that after he contacted the CRI, hereceived a call from a representative within the carpet industry, whotold him his problems couldn't possibly have come from carpet andthat the mouse tests run by Anderson Labs were ridiculous. Schmidtresponded to the man, "What? Do you think those mice just died oncue? They've run the test a number of times you know. Not all ofthe mice die, and other researchers have repeated the testsuccessfully. They must train those mice pretty well to just kickover and die."

Anderson labs reports that the respiratory and neurological symptomsin the mice have correlated well with the symptoms of the carpetowners. The preliminary results of one case are particularlystriking. Pulmonary specialist Ganesh Rhagu, M.D., associateprofessor of medicine, chief of the chest clinic and medical directorof the lung transplant program at the University of Washington Schoolof Medicine, Division of Pulmonary and Critical Care, had a patientwho was exposed to new carpet and developed hypersensitivitypneumonitis. Dr. Rhagu sent a piece of the patient's carpet toAnderson Labs to see what kind of effect it would have on the mice.

The tests have been run twice, both times with case controls. Labmanager Mark Goldman reports "Dr. Rhagu found the same type ofpathological changes and damage in the tissue biopsies from the lungsof the carpet exposed mice as in the patient who was exposed to thesame carpet. Normally hypersensitivity pneumonitis is a chronicdisease, but the mice developed it after only forty-eight hours ofexposure. The implications are so serious, we are not willing tomake 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

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way to confirm the data."

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

Hazardous Chemicals in Carpet

The Carpet and Rug Institute (CRI) has voluntarily agreed to a newcarpet 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 PublicRelations, Kathryn Wise, states, "All the scientific reports havetold us that there is nothing that they can prove that is harmful tohealth in carpet." (5)

However, an April 1991 New York Attorney General consumer alertregarding carpets warns that "many of the chemicals emitted are toxicand some are known or suspected to cause cancer and birth defects."(21)

Much of the difficulty in pinpointing the problem arises from thelarge number of chemicals involved. A toxicologist within the carpetand rug industry has revealed that there are at least one thousanddifferent chemicals in the manufacture of carpets. "In December of1992, at the request of one of the major chemical companies in thecarpet and rug industry, Dr. Alan Broughton and I met with one oftheir toxicologists and the attorney that represented the carpet

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industry," says immunotoxicologist Jack Thrasher, Ph.D. "We wereinterviewed regarding the abnormal immunologic test results we hadfound in numerous cases of carpet exposure. They also asked us whatour recommendations for research would be with respect to carpetproblems. We were told at that meeting that there are at least onethousand different chemicals used in synthetic carpeting and that tolook at the combinations and permutations would be a tremendoustask."

One example of a hazardous contaminant or possible permutationappears to be formaldehyde. According to the carpet and rugindustry, formaldehyde is not used in the manufacture of carpets.Wise states, "There is no formaldehyde in carpet, it has not beenused in the manufacture of carpet in over ten years." MichaelKronick, executive director of the Canadian Carpet Institute inOttawa, has gone on record stating that formaldehyde, benzene, andtoluene are not used in the manufacture of carpet. (22)

Yet, all three of these chemicals are emitted from carpet accordingto a number of emissions tests run on new carpet samples fresh fromthe mill. (2, 23, 24, 25) One study commissioned by the U.S.Consumer Product Safety Commission (CPSC) found formaldehyde was oneof the top eight emissions. Their report warns that the levels offormaldehyde, 4-PC, and butylated hydroxytoluene did not drop offrapidly, and may be "more important with respect to health andcomfort effects. (2)

After the initial installation period, the levels of the chemicalsemitted from carpets are usually low. However, many researchers areextremely concerned about the possible synergistic and cumulativeeffects of the multitude of chemicals involved in carpet. The healtheffects of specific combinations of chemicals in carpets have not yetbeen studied.

Listed below are just a few of the hazardous chemicals that have beenfound in carpet emissions tests. Not much is known about theirhealth effects from chronic low-level exposure. The health effectslisted are generally associated with higher exposure levels, butGrace Ziem, M.D., Dr.P.H., warns that sensitive individuals mayexperience adverse effects at lower exposure levels than the averageindividual. Further, the National Institute of Occupational Safetyand Health warns that there is no safe level of exposure to acarcinogen, as the cell damage can occur at extremely low exposurelevels.

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 testto determine human health effects from both individual chemicals andentire products. (2, 18)

Some of the following chemicals are also listed on EPA's CommunityRight to Know List which requires manufacturing facilities to prepareMaterial Safety Data Sheets and notify local authorities of thepresence of the chemicals.

A number of the following chemicals have been tested with the ASTME981 by labs other than Anderson's. Their published results indicatethat adverse effects in mice are a reliable indicator of adverseeffects in humans. Those chemicals are marked by the followingstatement, "Published studies indicate the ASTM E981 test is areliable 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 islisted on EPA's Community Right to Know List. It is considered asevere irritant. Human systemic effects by inhalation includechanges in electroencephalogram, changes in carbohydrate metabolism,nasal effects, respiratory system effects, nausea, vomiting, andmuscle weakness. Adverse reproductive effects have been reported inanimal experiments. Acetone can react vigorously with oxidizingchemicals. Published studies indicate the ASTM E981 test is areliable 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 islisted on EPA's Community Right to Know List. Benzene is a confirmedhuman carcinogen. It can produce myeloid leukemia, Hodgkin'sdisease, and lymphomas by inhalation. It is also considered a humanpoison by inhalation. It is a moderate skin irritant and a severe

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

Caprolactam (25)

It is moderately toxic by skin contact. Animal experiments haveshown it to be teratogenic. Other adverse reproductive effects havebeen reported in experiments. Human mutation data have beenreported. Exposure symptoms in humans include cough, skin and eyeirritation. (27)

Diethylene glycol (25)

It is included in EPA's Toxic Substances Control Act Inventory and islisted on EPA's Community Right to Know List. It is a suspectedcarcinogen, supported by experimental carcinogenic, tumorigenic andteratogenic 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 islisted on EPA's Community Right to Know List. It is a confirmedcarcinogen. Animal experiments have found teratogenic effects (birthdefects). In humans it can cause headache, eye irritation, swellingweight loss, nausea, vomiting, and cirrhosis of the liver. Publishedstudies indicate the ASTM E981 test is a reliable indicator ofadverse human health effects for p-dichlorobenzene. (19, 26, 27)

Formaldehyde (2, 23, 25)

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

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

Hexane (23)

It is included in EPA's Toxic Substances Control Act Inventory. Inhumans it can cause lightheadedness, nausea, headache, weakness, eyeand nose irritation, dermatitis, chemical pneumonia, giddiness,hallucinations, structural changes in nerves, motor neuropathy, andrespiratory irritation. Animal experiments have found adversereproductive effects and birth defects. Mutation data have beenreported. (26, 27)

Styrene (2, 24, 25)

It is included in EPA's Toxic Substances Control Act Inventory and islisted on EPA's Community Right to Know List. It is a suspectedcarcinogen and human mutation data have been reported. Animalexperiments have found adverse reproductive effects. In humans itcan cause eye and nose irritation, drowsiness, olfactory (smell)changes, and defatting dermatitis. Published studies indicate theASTM E981 test is a reliable indicator of adverse human healtheffects for styrene. (19, 26, 27)

Toluene (2, 23, 25)

It is included in EPA's Toxic Substances Control Act Inventory and islisted on EPA's Community Right to Know List. Mutation data havebeen reported. Animal experiments have found adverse reproductiveeffects. Human effects include fatigue, weakness, confusion,euphoria, dizziness, headache, dilated pupils, dermatitis, centralnervous system recording changes, hallucinations or distortedperceptions, motor activity changes, psychophysiological testchanges, and bone marrow changes. Published studies indicate theASTM E981 test is a reliable indicator of adverse human healtheffects for toluene. (19, 26, 27)

Vinylcyclohexene (28)

It is included in EPA's Toxic Substances Control Act Inventory. Itis considered to be moderately toxic by inhalation. Animalexperiments 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 islisted on EPA's Community Right to Know List. Animal experimentshave found adverse reproductive effects and birth defects. In humansit can cause dizziness, excitement drowsiness, weight loss, nausea,vomiting, abdominal pain, and dermatitis, coordination problems, andstaggering gate. Published studies indicate the ASTM E981 test is areliable 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

18

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).

19

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 tableeating a sandwich and reading People magazine, with my ten-month-oldson, Christopher, nearby on the carpet. All of a sudden, he wentinto 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 immediatelyhospitalized Christopher, whose reactions continued unabated. Aftera week of testing, the doctors ruled out multiple sclerosis, musculardystrophy, and tumors, but they couldn't identify the disorder.Christopher was then taken to the head of pediatric neurology atUCLA, who diagnosed "tremors of unknown origin."

"Christopher's EEG was normal, even during reactions, so his doctorsaid it was either something occurring in the deeper part of thebrain [subcortical] or something different altogether," said KevinMcIvers. "He told us their best guess was that there was somethingdreadful going on neurologically. We would just have to wait andsee, and eventually it would get worse and the root of the problemwould show itself." The doctors tried drugs to suppress the centralnervous system, but they didn't stop the tremors. "So we werewaiting, 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 apossible cause of the problem the new carpet they had installed intheir Santa Bar before the onset of the tremors. So Kevin andJocelyn, both lawyers, cautiously approached the carpet manufacturerfor information.

"Being a trial lawyer, I'm very aware of some of the shenanigans thatcan go on over semantics, so I was very careful how I worded myquestions to the industry. I wanted the correct information for my

20

son's benefit. I asked specifically, 'I don't want to know if theindustry believes that carpet can cause problems, or if it'sscientifically documented or anything like that. Just tell me,please, has anyone ever complained or claimed that they have had aneurological or neuromuscular reaction of any kind to carpet?' Andthe 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 someallergy-type symptoms since your new carpeting was installed," theJuly 18, 1991 letter stated. "We have not heard of any reactionssimilar 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 anindoor air consultant. He advised them to steam-clean the carpetseveral times and bake out the house by shutting the windows andheating it to speed up the offgassing of volatile organic compounds(VOCs), then airing it for several days. They went through thisroutine twice, while living at Jocelyn's mother's house for sixweeks. During that time Christopher's tremors had decreased. "So wereturned to our home and kept all the windows open. The tremors gotworse again but were still less frequent than before," said Jocelyn.

That October the CBS news program Street Stories did a segment aboutAnderson Laboratories in Dedham, Massachusetts. At the request of anumber of people, the lab had tested certain carpet samples forbiological effects and came up with some disturbing findings. Usinga standard testing method (ASTM-E981), Rosalind Anderson, Ph.D.,found that air blown across the samples was causing severerespiratory and neurological/neuromuscular abnormalities and death inmice. (2, 3) The television script highlighted the health problemsseveral families had experienced as a result of new carpeting. TheMcIverses saw the program.

"So we had our carpet tested and sure enough, the mice were rollingover and shaking just like our son did," said Jocelyn. "We werehorrified."

The McIverses immediately removed the carpet and pad, scraped off theadhesive, washed down the entire house, baked it out again, airedit, and moved back in December of 1992. "Since DecemberChristopher's tremors have entirely stopped," Kevin reports.

The more Kevin and Jocelyn learned about the history of toxic carpetproblems [see "Carpet Cover-Up Time Line" in this issue], the angrier

21

they became. "We felt utterly betrayed. The manufacturer we hadcontacted was a major player front and center in the carpet industryand had people on the board of the Carpet and Rug Institute [CRI],"said Kevin. "Long before we ever called them, the CRI was very muchinvolved in the episode where over a thousand complaints werereported by EPA workers made ill by new carpet in the EPAheadquarters building. (4) I know, at a minimum, they were wellaware of neurological complaints and very serious pulmonarycomplaints from a number of EPA workers."

The incident in Washington had brought CRI into the Carpet PolicyDialogue with the Environmental Protection Agency (EPA) and theConsumer Product Safety Commission (CPSC), as working agreementbetween government and industry that was restricted to studying totalvolatile organic compounds and not health effects. The dialogue hadbeen underway nearly a year, and the carpet industry was alreadystudying ways to reduce total VOCs in carpet and carpet-relatedproducts, when Kevin McIvers called to ask about carpet concerns. (4,5)

CPSC had received hundreds of complaints about carpet. In amemorandum attached to a CPSC report obtained by the McIverses, datednearly a year before they had bought their carpet, CPSC presented theresults of their evaluation of complaints from 206 households aboutrespiratory and central nervous system problems attributed to carpetand stated, "We are continuing to interact with the carpet industryand will provide them with copies of these tudies for theirinformation." (6)

Two months before Kevin McIvers called the manufacturer of theircarpet for help, the New York Attorney General, Robert Abrams, hadpetitioned CPSC to require warning labels on carpets. (7) Because ofthe large number of carpet complaints, the attorneys general oftwenty-five other states signed the petition as well. (9) CPSCrefused to even consider their petition. (7, 8, 9) According toKevin, numerous lawsuits had by then been filed against the carpetindustry by individuals injured by carpet: "The industryrepresentative that I spoke to repeatedly on the phone when I waslooking for information on carpet was very compassionate and alwaysasked about Christopher's health. It wouldn't surprise me at all ifthat guy sincerely believed carpet couldn't be a problem and therehadn't been any history of complaints, and simply had beenmisinformed by upper management. But somewhere in the corporationsomeone has been making decisions about what information gets to thepublic, and it is a real dishonest, hideous decision that is beingmade. The direct result was that our son continued to live with the

22

toxic carpet for another year and a half, continuing to havethousands of tremors, while my wife and I spent most of our time witha knot in our stomachs, wondering when he would go further downhill.And that's just unconscionable."

Although the tremors have stopped, testing on Christopher McIversshows that he has immune system damage consistent with chemicalsexposure, including autoantibodies (indicating that the body's immunesystem has mistakenly identified its own tissues or cellularcomponents as foreign and has directed antibodies against them) tothe myelin in his nervous system -- a sign that nerve tissue damagehas occurred. (10)

His mother reflects: "I was extremely careful about what my babycame into contact with. Organic chemical-free food and everything.Even though I know better, I still feel guilty about the carpet. Imean, I picked it out myself -- beautiful and expensive. I wantedthe house to be so nice, and then I poisoned my son with it. Lookingback at all this, we wished we had just ripped it out, but theyassured 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 inspite of two congressional hearings that have been held regarding thetoxic carpet issue (October 1, 1992, and June 11, 1993), the industryis still giving a very imbalanced picture to anyone who asks, andthat'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 samplescaused adverse health effects. EPA responded that the health hazardreported from 25 percent of carpets is not enough to require awarning label on all carpeting and that it would be "unfair" to doso. EPA was instructed by the congressional panel to replicateAnderson's tests. (4, 11)

"The carpet industry has mounted a massively deceptive merchandisingcampaign that intentionally misleads the public by implying that allcarpets with the green tag have met safety standards," say New YorkAttorney General Robert Abrams. "First of all, there are no suchrecognized standards of safety. CRI has sets its own arbitrarystandards. Secondly, CRI's testing program is completely inadequatebecause it measure only a small percentage of the chemicals emittedfrom carpets. Finally, a manufacturer can get a green tag for anentire product line simply by having one small piece of carpet testedonce a year."

23

One of the carpets to pass the green tag testing is associated withdisabling the members of the Charles Fitzgerald family of WestFriendship, Maryland, who were exposed to it in their lighting storein 1992. When tested by Anderson Labs, the Fitzgeralds' carpetcaused gross nervous system abnormalities in mice. It was thenanalyzed 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 haveincreasingly come under fire for not fulfilling their role asprotectors of the public interest. (4, 12) "The Consumer ProductSafety Commission receives hundreds of complaints and inquiries eachyear about the adverse health effects associated with the materialsused to make carpet," said Abrams. "Yet the government has chosen tosweep this problem under the rug by ignoring the public's healthconcerns as well as my request to disseminate meaningful informationabout potential carpet hazards."

When EPA investigated carpet complaints from its headquartersbuilding, it published a report showing a positive correlationbetween EPA worker complaints and new carpet, according to an EPASenior Scientist, Bill Hirzy. (4, 13, 14) Despite its own study, andthe removal of 27,000 square yards of carpet from the headquartersbuilding in 1989, EPA published a public information brochure,"Indoor Air Quality and New Carpet: What You Should Know," whichstates, "Limited research to date has found no links between adversehealth effects and the levels of chemicals emitted by new carpet."(15)

There was no scientific basis for the brochure's statement, admittedBob Axelrad of EPA during an interview on CBS "Evening News." (15)He went on to say that the brochure was formulated during theCarpet Policy Dialogue and constituted a compromise with industry.(16)

"My sense is that EPA is avoiding the issue because they don't wantto participate in a financial massacre of industry," said Hirzy,speaking as president of EPA Union Local 2050. "And there is acertain amount of investment in reputation by peopel in EPA who earlyon said carpet wasn't a problem. Industry won't publicly admitthere's a problem because of the liability. In the meantime, howmany lives have been and will be devastated?"

"To date we have tested over 400 carpet samples," said Dr. RosalindAnderson. "Of the carpets sent in by persons with health complaints,

24

at least 90 percent have shown severe neurological effects.Approximately 25 percent of new carpets, ones that have never beeninstalled, have been deadly. We've found death in mice from a newsample just sever square inches at room temperature."

In a side-by-side test conducted at Anderson Labs, EPA replicatedAnderson's work. "The EPA people even picked out a new carpet samplefor the test run themselves, so there couldn't be any accusation thatDr. Anderson deliberately picked a contaminated sample," said KevinMcIvers. The side-by-side test was videotaped with Anthony Pollina,aide to Rep. Bernard Sanders (I-VT), as a witness. "EPA found thesame neurological effects and death in mice as did Dr. Anderson,"said Pollina.

Then, when EPA returned to its own labs, "instead of duplicating whatRosalind Anderson did, as they were charged to do at the October '92carpet hearing, EPA created its own protocol," said Hirzy. "Theyreplicated Anderson's results at her lab, but when EPA scientistsused bottled air in their own lab and bubbled it through water to addhumidity, the humidity changed the result. What they found was thathumidity 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 thesame manner as EPA had done," we found it removed the toxic effect aswell," said Anderson. When they passed air over a toxic carpetsample and bubbled it through water, the air was not toxic to themice. So they took that water and exposed the mice to it in the formof a mist. "Lo and behold, the toxic effect had been removed fromthe air and put into the water. We were now seeing the sameenurotoxic effects from the water, including death, said Anderson.

"We found the same results when we injected the water into themuscles of the mice. We used appropriate control mice, which weretotally unaffected by water that wasn't exposed to the carpet air.So something very bad was coming off that carpet, which can betrapped in water. It's really an exciting finding, actually. Allthat needs to be done now if for someone to analyze the water and seewhat the chemicals are."

"It cries out for follow-up," said Hirzy. "what is in the waterthat's killing mice? The chemicals in the carpet have already beenisolated by the water, so all you have to do is test the water. Butit's a terribly expensive process, so a private lab couldn't fund iton its own."

25

"We did not independently replicate the severe toxicity described byAnderson Laboratories," reported EPA at the carpet hearing held onJune 11, 1993, before the House Subcommittee on Environment, Energy,and Natural Resources. (17) The hearing was held to discuss EPA'sfindings, according to Congressman Sanders' aid Pollina. But insteadof talking about the positive implications of its discovery, EPAsimply denied replicating Anderson's tests and then reiterated thestance taken in its brochure: "We do not have a sound basis forconcluding exposure to carpet emissions presents a health risk." (17)

Under corss-examination, EPA admitted having changed the protocol andhaving had problems monitoring humidity. (11, 18, 19) "EPA'spresentation before Congress was confusing at best," said New YorkEnvironmental Protection Bureau Assistant Attorney General GailSuchman. "It hasn't answered our request, which is to get the rightinformation out to the public."

Congressman Sanders and Subcommittee Chairman Mike Synar (D-OK) wereespecially critical of EPA for "dragging its heels." Said Sanders:"I am extremely disturbed that after months of promises to get towork on this issue, the EPA has failed to accurately replicate Dr.Anderson's tests, has failed to talk to a single doctor whosepatients have suffered ill health effects from carpeting, and hasfailed to make any serious effort to identify which chemicals arecausing the problem." (20)

At the hearing Ron VanGelderen, president of the Carpet and RugInstitute, testified that current research suggests that "carpetitself does not adversely affect public health." (21)

Pollina reports that under corss-examination "the three people fromindustry were kind of hedging and giving conflicting answers and thenthe chairman basically said, hey, wait a minute, you're under oath.There can be only one answer to this question. Either people aregetting sick from carpet or they're not. The industry guys kind oflooked at each other, and then one of them said something to theeffect of, well, if you consider an allergy-like reaction to be anadverse health effect, then yes, I suppose you could say carpetcauses 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 causeproblems in some people. The term allergy-like can mean just aboutanything, but at least they admitted that carpet could be the causeof it."

26

The same day of the hearing, CRI issued a press release stating:"The scientific evidence overwhelmingly demonstrates that carpetitself does not adversely affect public health." (22)

VanGelderen's testimony cited EPA and CPSC as not finding scientificevidence to warrant concern over carpet. He blasted Anderson's testmethod, calling it "irrelevant to the debate on indoor air quality."(21) Yet just six days before Anderson went public with her testfindings, CPSC had distributed a report recommending the use of thesame testing method (ASTM-E981) for carpet that Anderson was using.The report analyzed the final results of a carpet testing studyconducted by interagency agreement. It warned that measuring totalVOCs, 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 foundoffgassing from carpet are for the most part unknown, the CPSC reportstated. It then recommended the test founded by Yves Alarie, Ph.D.,the ASTM-E981, calling it a "standard method" that "could be used tomake reasonable predictions of effects in humans over a wide range ofconcentrations." (23).

"Dr. Alarie of the University of Pittsburgh was hired to develop theASTM-E981 in the 1960s by the U.S. Department of Defense to test forthe potency of nerve gases to be used by the U.S. Army in Vietnam forcleaning out tunnels," said Mark Goldman, manager of Anderson Labs."It was later used by the pesticide industry. It came from the campof the manufacturers frankly."

Alarie, who had been hired by CRI in the past, testified at the Junehearing that when Anderson first released her test results,VanGelderen asked him to verify her test protocol. After Alarievisited her lab and reported that "her description of the effectsobserved was correct and her experimental design was valid,"VanGelderen hired Alarie to see if he could replicate her work forCRI. (24)

Alarie testified that he replicated her results four time: "Herresults are perfectly reproducible in my laboratory." (20)

In his testimony Alarie expressed concern about the many rumors beingspread to try to discredit Anderson's work: "As results ofneurotoxic effects and death were reported by Dr. Anderson to be dueto volatile emissions from carpets, rumors were circulated that theseeffects were due to the exposure method -- i.e., placing the mice inrestraining tubes as described in the ASTM-E981 method." Alarie

27

conducted additional testing over even longer periods of time "inorder to satisfy those rumor generators," and proved the restraintswere absolutely not a problem. (24)

A CRI press release issued on the day of the hearing quoted one ofits experts regarding the restraint: "[The tests] are tantamount tolacing up a human being in a strait jacket and repeatedly choking himfor two days." (22)

"Cretins will continue to spread their rumors, and there is not muchI can do about it," testified Alarie at the hearing. "This methodASTM-E981 has been used all over the owrld and I have never receiveda complaint from a user of it that the method itself producesneurotoxic effects." (24)

Congressman Sanders went on record agreeing with Chairman Synar, whomhe quoted as saying that the testimony and evidence presented at thehearing "remind us of EPA's past failures to protect indoor airquality ... After years of complaints, consumers still havedifficulty in getting straight answers to questions about chemicalrisks if they ask carpet retailers, or frankly, even if they askgovernment officials." (20)

One week after the hearing, EPA's designated carpet spokesperson wasasked about the side-by-side EPA replication of Anderson's tests ather lab. "There was no side-by-side," said EPA's Charles Auer,director of the Chemical Control Division. He said the EPA hadobserved Anderson's testing but had not replicated it." (25)

"We submitted the videotape of the side-by-side test to Congress aspart of our testimony," said Mark Goldman. "It's part of theCongressional Record."

EPA plans workshops this fall with industry and Anderson Laboratoriesto discuss whether to pursue the test results any further. "That'sjust a government tactic for delay," said EPA Union President Hirzy."It's designed to keep the industry covered. There are some hotleads here. We have human evidence that people are gettingrespiratory, neurological, and immunological injury from carpet. IfI were industry, I'd be scurrying around behind the scenes trying tofind out what's in the air and the water that's killing thosecritters, and then working to reduce it. And if EPA can keep thingsstalled up by pushing for workshops and time-consuming quote 'peerreviews,' and all sorts of delay mechanisms, that mutes out a lot oflawsuits."

28

Congressman Sanders' office wants action. "Number one," said Pllina,"We'd like to see EPA sit down and have some serious talks with agroup of doctors who can help them make the connection to humanhealth. Number two: We'd like to see industry not just come up witha good warning label but also suspend the green tag program. Numberthree: The water that trapped the carpet fumes must be tested tofind what the toxins are so the manufacturing process can bechanged."

CRI has agreed to work on a new additional warning label with the NewYork attorney general's office, which recently published a report:"Carpet and Indoor Air: What You Should Know." The reportcounteracts the EPA brochure by warning about the possible hazards ofcarpet and calling for the suspension of the green tag program.

"Our focus has been to get the right information to the public. EPAand CPSC have been totally unresponsive to all of our requests to getthat information out to the public, which is why we wrote thereport," stated Gail Suchman of the New York attorney general'soffice. "We are willing to work with CRI to establish a new consumerinformation program, including some sort of warning or informationalcampaign so the public can make an informed decision."

Congressman Sander's office has been in touch with a number ofdoctors from a variety of specialties who all have one thing incommon. They are seeing an increase in chemical injuries, includingcases where people have been made ill by carpet. "Some of the dotorsare in the process of drafting short statements to present toCongressman Sanders," said Pollina. "The statements will say ineffect that in recent years toxic injuries have become more common,and as that has happened, their ability to diagnose chemical injurieshas improved. Further, based on what they are seeing and thediagnostic procedures they are using, including objectiveneurological testing, patient history and a process of elimination,it is their medical opinion that their patients, both children andadults, are being affected by the chemicals offgassing from carpetsand that there needs to be more research."

Sander's staff hopes that EPA and industry will meet with some ofthese doctors in the near future. Pollina added, "The carpetindustry has committed themselves to develop a whole array ofinformation for consumers, retailers, and installers, which we expectto be an improvement over the earlier information they werecirculating. They've also stated they will research the problem.We'll see what happens. Time will tell."

29

The following states have all signed the New York attorney general'spetition to CPSC, which would require warning labels on carpet and anadequate 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 overcarpet safety, contact your own state attorney general's office andask 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 carpetinstallation. Glenn and Sharon Beebe become ill from carpetinstallation at their business building in Cincinnati. (26) Theyhave now documented several thousand cases of carpet-relatedcomplaints 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 installationin its Waterside Mall headquarters building, and employees complainof ill health from the fumes. A total of 1,141 complaints arereceived. To date, at least twenty people are still unable to workin the building. (4, 27, 28)

May 1988--------Over 100 EPA emplyees hold a rally in front of EPA headquarters todemonstrate their concern over air quality, the toxic carpet in theirbuilding, and EPA's refusal to acknowledge the problem and takeaction. (4)

August 1988-----------EPA establishes a policy of not using carpet containing the chemical4-phenylcyclohexene (4-PC) in headquarters facilities and startsaccommodating 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 carpetcomplaints. EPA management tells EPA union they will not use datafrom their investigation into the air quality at the headquartersbuilding because they fear lawsuits. (4)

31

September 1989--------------As a result of its indoor air quality study, EPA removes the carpetfrom 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." EPAmanagement removes him from that job within a few weeks.

March 1990----------EPA management tells union "off the record" that because the union'spetition to EPA to start testing and regulating carpet emissionscould potentially cost the carpet industry "billions of dollars," itwill not grant the petition. (4)

April 1990----------EPA publicly denies the union petition. EPA's Indoor Air Divisiondirector privately tells attendees at an indoor air conference inVirginia that "everyone knows the new carpet made people sick," whilepublicly denying the same. (4)

June 1990---------The EPA union files suit over petition denial. Court grants EPA'smotion to kill the suit. (4)

August 13, 1990---------------The Consumer Product Safety Commission (CPSC) distributes amemorandum regarding the evaluation of carpet complaints from 206households. The memorandum states that they have been interactingwith 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 isrestricted 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 HealthHazards," is issued by New York Attorney General Robert Abrams. (29)

April 10, 1991--------------New York Attorney General Robert Abrams petitions CPSC to requireconsumer warning labels on carpet. (7) In time twenty-five otherstate attorneys general sign the petition. (9)

June 1991---------EPA publishes the result of the air quality investigation into workercomplaints in its headquarters building. Volume 4 establishes a linkbetween adverse effects and carpet. (4, 12, 28)

June 1991---------Kevin McIvers calls Monsanto carpet manufacturer when histen-month-old son, Christopher, develops tremors and has to behospitalized five days after carpet installation. Kevin reportsbeing told they had never heard of that type of complaint before andthat it could not be caused by the carpet.

September 6, 1991-----------------Carpet Policy Dialogue is concluded. A public information brochurehas been prepared, and industry has agreed to take steps to measureVOC 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 torequire warning labels (4, 8)

March 1992----------EPA brochure is published, claiming that no links have been foundbetween 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 atAnderson Laboratories (Dedham, Mass.) passes the carpet industry's

33

testing program and qualifies for a Green Tag. (30)

July 17, 1992-------------CRI announces its Green Tag program in a press release. (31) Theprogram tests only one carpet sample from each carpet type once ayear -- a test based only on total VOC emissions, not biologicalhealth 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 notadequate as a standard to protect health" and recommends theASTM-E981, developed by Dr. Yves Alarie. (23)

August 18, 1992---------------After presenting their findings to EPA management and industry andreceiving no response, Anderson Labs goes public with test results ofcarpet fumes killing mice, using the ASTM-E981 testing method. (2)

August 21, 1992---------------CRI has Dr. Alarie check out Dr. Rosalind Anderson's testingtechnique. Dr. Alarie reports that it is scientifically valid. CRIhires him to replicate Anderson's tests in his labs. He finds thesame neurotoxic results four times. (24)

September 1992--------------The EPA union files a complaint with the Federal Trade Commission andEPA's Indoor Air Division, claiming the Green Tag program to befraudulent and a danger to public health. (4)

October 1, 1992---------------Sen. Joseph Lieberman (D-CT) holds carpet hearings. Dr. Andersonsays 3 of 13 random, new carpet samples tested caused adverse healtheffects. EPA replies that the health hazard reported from 25 percentof carpets is not enough to require a warning label on all carpetingand that "it would be unfair" to do so. EPA is given a charge toexactly replicate Anderson's test exactly. (4, 11)

October 29, 1992----------------

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CBS "Evening News" and "Street Stories" air segments on problemcarpet, Anderson's findings, and the Fitzgerald story. Whenquestioned about EPA's carpet brochure, which states that researchhas found no link betwen adverse health effects and carpets, EPA'sBob Axelrad admits there is no scientific basis for that statementand that the brochure represents a compromise with industry. (16)

November 6, 1992----------------Testing of McIvers' carpet shows in mice the same type of tremors andneuromuscular 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 aside-by-side test at Anderson Labs with Rep. Bernard Sanders' aide,Anthony Pollina, as a witness. The mice have respiratory andneuromuscular reactions, and some die. (11)

January 27, 1993----------------Blood testing of Christopher McIvers shows immune system damageconsistent with chemical injury. (10)

February 1993-------------Anderson's paper "Toxic Emissions from Carpets" is presented at aninternational conference and accepted for publication in apeer-reviewed journal. (33)

March 1993----------In its own lab EPA changes Anderson's protocol instead of replicatingthe test.

April 1993----------CRI distributes a letter to members of the carpet industry, includingretailers, assuring them that "extensive research" by EPA and othersfailed to discover any link between carpet and ill health. Letterprovides sample statements for retailers to use in assuring thepublic 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 areport, "Carpet and Indoor Air: What You Should Know," which warnsthe public about the misleading nature of the green tag program. Thereport is sent to CRI and carpet manufacturers along with a requestthat 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 replicateAnderson's findings. Anderson submits the videotape showing EPA'sreplication of her findings in the side-by-side test. EPA admitshaving changed the protocol in its own lab. Under cross-examination,industry admits that some people may experience adverse effects fromcarpet, and the Carpet and Rug Institute agrees to work on a newadditional label with the New York attorney general's office. CRIalso agrees to fund more research into carpet and work with EPA onit. The same day, CRI issues a press release stating that "carpetitself does not adversely affect public health." (11, 17, 18, 19, 22,36)

June 18, 1993-------------Contradicting the videotape presented at the hearing, EPA's CharlesAuer, director of the Chemical Control Division and current officialspokesperson to the public on carpet, states when questioned aboutthe result of EPA's side-by-side test with Dr. Anderson: "We neverran a side-by-side." (25)

July 4, 1993------------When Dr. Anderson presents two papers at "Indoor Air '93, the SixthInternational Conference on Indoor Air Quality and Climate" inHelsinki, Finland, she is approached by many researchers from aroundthe world who tell her that they are seeing similar carpet-relatedhealth 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. Hestates: "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

36

keeping the industry going. Certainly, nobody wants to see theindustry destroyed. There is no question that the industry doesn'tdeliberately want to hurt people. Of course they don't. But they dohave legitimate concern that their stockholders will lose a lot ofmoney, and they may not survive if there is unlimited liability.What has to happen is that industry, EPA, and CPSC must own up topast 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 publicwithout bankrupting the industry. A conference needs to be held withthe possible plaintiffs, industry, a regulatory agency, and apublic-advocacy-type group. They need to sit down and hammer outways to compensate people who have been injured so far and begin avery aggressive and forthright program of warning consumers thatthere appear to be some individuals who, when exposed to certain lotsof carpeting, are in danger of profound adverse health effects.

"This conference would need to come to an agreement made binding by alegislative or judicial finding that limits the liabiilty ofindustry, compensates those already injured in a timely manner, andprotects the industry from future liability once they've come cleanand have issued accurate public service announcements and adequatewarning labels on each roll of carpet. Once industry has honestlyand forthrightly informed the public of the risk, then by purchasingtheir product, the public is consenting to take on that risk, and theindustry should be free of liability. Similar to the warning labelon a cigarette package. But right now the pubic is being stonewalledby a bunch of lies from industry and from the EPA, so they don't evenhave the opportunity to make informed decisions."

What Do You Do If You Want Carpet?

Not all carpets are problem carpets. Anderson Labs has found notoxic effects in about three-quarters of the new carpets tested (onesthat have never been installed). (18) For consumers the issue isknowing whether the carpet they want will pose a health risk. Thereis no easy answer to that question because the chemicals causingproblem carpets has not yet been determined.

If you wish to purchase carpeting, you can take steps to minimizetotal exposure to the chemicals found in it. But while reducingtotal volatile organic compound (VOC) exposure will lessen the amountof toxins the body has to deal with, it may not be an adequatemeasure for health protection, according to a Consumer Product Safety

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Commission (CPSC) report. (23)

"Based on what's happening out there and what we're seeing with ourcarpet testing," said Dr. Rosalind Anderson of Anderson Labs in atelephone interview, "I think we have to conclude that there must besome ongoing process that we don't know about yet, continuing togenerate fumes over times. Something is breaking down very slowlyand consistently and whatever it breaks down to is bad news. It'sprobably some combination of chemicals forming new compounds thatwe're not expecting."

A consumer alert put out in 1991 by New York Attorney General RobertAbrams advises caution: "People who smoke, have allergies, or sufferfrom respiratory disorders may be more prone to experiencing symptomswhen exposed to new carpeting. Further, the chemicals pose a greaterrisk to small children. Pregnant women should also avoid thesefumes, as they may be harmful to the child [in the womb." (29)

The following are suggestions for dealing with the problem-carpetquestion. No guarantee of safety is implied or intended. People'ssensitivities 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

38

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

39

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 Carpets1940 Olivera Rd.Suite CConcord, CA 94520(800) 227-3408woven wool carpet, jute backing or polypropylene backing

The Dasun CompanyP.O. Box 668Escondido, CA 92033(800) 433-8929"NonScents" molecular adsorber

Desso CarpetP.O. Box 1351Wayne, PA 19087(800) 368-1515woven wool carpet, just or polypropylene backing(further surface treatment is optional)

Foreign Accent2825E Boradbent Pkwy. N.E.Albuquerque, NM 87107(505) 344-4833woven 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 CarpetP.O. Box 1928Calhoun, Georgia 30703(800) 843-5138woven wool carpet

Hendricksen Naturlich Flooring Interiors6761 Sebastopol Ave., Suite 7Sebastopol, CA 95472-3805(707) 829-3959natural 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) 961-6891woven wool carpet

N.E.E.D.S.527 Charles Ave.Syracuse, NY 13209(800) 634-1380AFM Carpet Adhesive (low VOC carpet adhesive), air filters

CYA Products Inc.211 Robbins LaneSyosset, 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 theauthor, Cindy Duehring (per phone conversation on 10/4/95). Forconsiderably more extensive documentation on the hazards of toxiccarpeting 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 ****

45

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 carpetlabel and consumer information program.

CRI voluntarily agreed to teh new carpet label after months ofintense negotiations with Congressman Bernard Sanders' office [I-VT],the Consumers Union, the Consumer Federation of America, and thestate Attorneys General of New York, Connecticut, Oregon, andVermont. The four attorneys general entered into direct negotiationswith the carpet industry when the Consumer Products Safety Commission(CPSC) refused to even consider their petition, signed by a total of26 state attorneys general, requesting mandatory health warninglabels on carpet.

"The Consumer Products Safety Commission receives hundreds ofcomplaints and inquiries each year about the adverse health effectsassociated witht eh materials used to make carpets," said ConnecticutAttorney General Richard Blumenthal. "The agency has ignored thesehealth concerns and refused to take action. Under the revisedindustry program, consumers will at least be given information toprovide a basic awareness of the possible health risks. Before thisagreement, the industry's brochure said there was no reason forpeople to be concerned about carpet safety -- an absolute outrage.The program was misleading and meaningless. It gave consumers theimpression that the carpet they were purchasing had been thoroughlytested and would not pose any health hazard."

Kirsted Rand of the consumers Union said she would have preferredstronger wording on the label, but still sees it as a "huge stepforward" from the former green tage program which she believes"skirted the issue and was misleading because it implied that thecarpet was somehow safe, so if you were having problems, it had to besomething else. Most of us would have liked to see strongerlanguage, but CRI did come a long way."

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In spite of the progress, the Consumers Union and the ConsumerFederation 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 CRIbecause they were discussing more than one item prepared by CRI: thewarning label, the carpet Owner's Manual, and an informationalbrochure. "Each time we would edit out a lot of language we foundobjectionable on the label, it would appear in the Owner's Manual,and it was incredibly frustrating," said Rand. "We did not endorsethe final product and the Consumer Federation of America takes thesame position we do."

One of the disagreements throughout the negotiations was the labelsize. The final label was several inches smaller than the size CRIinitially agreed to use, according to Rand, who said, "They alsodumped on us at the last minute that this label was going to beincorporated on the back of carpet samples along with many otherlabels -- most of which are promotional, and most of which are muchlarger than the label with a warning on it. So based on the factthat 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 Unioncould not endorse the final product. Another bone of contention isthat CRI insists we describe it as a consumer information labelrather than a warning label. That's just a game of semantics thatobviously their lawyers want them to play."

CRI is relaly trying to be careful that they con't put themselves ina 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 corporateattorneys to protect against tort litigation. We still have a longway to go to protect the public adequately. The new warning isbetter than the old warning, however, it is clearly not the idealwarning."

Mark Goldman, manager of Anderson Laboratories, agrees. "It'sprogress, but it's an incomplete label," he said. AndersonLaboratories tested new carpet samples at room temperature using astandard testing method (ASTM E981) and found that offgassing fromsome samples -- even as small as sever square inches -- caused severerespiratory and neurological effects, including death, in mice.

The ASTM E981 test method was developed by Yves Alarie, Ph.D., in the1960's under the direction of the U.S. Department of Definse. It wasspecifically developed to reliably extrapolate mouse data to humans.It has been recommended as a reliable product test in a reportcommissioned by the CPSC and also by Daniel Costa, of theEnvironmental Protection Agency's Health Effects Research Laboratory,Pulmonary Toxicology Branch. (1, 2) Regarding the ASTM E981, Costawrote: "We support the use of the mouse irritancy test fordetecting, and possibly for comparing potencies among, indoor aircontaminants ... we believe that if the mouse irritancy test ispositive upon exposure to a suspected indoor contaminant, then theatmosphere is likely to be irritating to humans." (2) Based onAnderson's test results, which were duplicated by Alarie, Hirzystated: "It looks like there really needs to be some fundamentalchanges in the manufacturing processes for carpet and its rawmaterials. And there needs to be a substantial amount of researchinto actually pinpointing the causes of the toxicity that Andersonand Alarie are finding."

The health effects on the test animals have consistently correlatedwell with the health effects reported by the people submitting theircarpet samples for testing, according to Goldman. He expressedconcern 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 immediatelyafter installation, but it doesn't acknowledge that some carpets area long-term hazard and may continue offgassing low levels of thechemical 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 72hours. We have not denied that. There are a lot of volatilechemical compounds that leave in those 72 hours, but there are somepretty bad ones that still hang around. And we are seeing continuousdegradation in some carpets. So the label is not really addressingthe fact that with some carpets you're going to have long-termproblems. The real milestone that has to be passed is that they mustcreate a toxicologically safe product. Until that happens, peopleare still at risk."

Rosilind Anderson, Ph.D., director of Anderson Laboratories, believesthe label's ventilation message is very inadequate. "Anyone who hashad any kind of carpet problem knows that this is not something forwhich the response is simply ventilate for two or three days. Theirrecommendation to open your windows and run your exhaust fans willnot protect people if they have a problem carpet. Further, there arevery, very few doctors who are able to recognize the early signs ofcarpet toxicity," she said.

Other researchers have expressed concern about the label'slimitations. "I feel the label is inadequate for several reasons.When you read it, the label gives you the feeling that only peoplewho are sensitive will have an adverse response, and in all realitythat is not true," cautioned immunotoxicologist Jack Thrasher, Ph.D."It really is not giving the full message to the public. Anotherproblem with warning labels of this nature, is that it simply says tonotify your physician if you have problems. But if the doctor is noteducated regarding chemicals, then how is he going to know what teststo do, what symptoms to look for, and how to determine what iscausing those symptoms? In my personal opinion, with a label such asthis, it would be incombent upon the carpet industry to inform alltreating physicians in the countries where they market their productsthat there are health problems with carpeting and what those problemsare so the doctor would have an idea what to look for."

Thrasher is also concerned that the label implies thee is a treatmentfor the adverse reactions to carpet, while leaving the carpet inplace, "when in reality there is no treatment. If carpet is causingproblems, the only treatment is to remove it and get it out of thehouse. All a doctor can do is recognize the problem, run theappropriate 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 preventfurther illness. And again, the only way to prevent further illnessis to get the carpet out of the house and avoid further exposures,"stated Thrasher.

In spite of their concerns, Thrasher, Anderson, Goldman, Rand, andHirzy all believe the label represents a positive step because it atleast alerts consumers that symtpoms have been reported. This viewwas also expressed by the New York Attorney General's office. "I amreally hopeful that some people who otherwise would not have thoughttwice about any of these carpet safety issues will now have theopportunity to think about it because of the label, and willrecognize the connection and take steps to protect themselves if theyare experiencing symptoms," said Ronna Brown, assistant attorneygeneral at the New York Department of Law.

"This consumer warning label makes an important contribution toalerting the public about the range of symptoms many people associatewith exposure to the chemicals given off by new carpeting. I urgeall consumers to heed the carpet warning label," advised former NewYork Attorney General Robert Abrams.

In spite of the warnings on the new label, CRI still insists thee areno health hazards associated with carpet. "It's not a warninglabel," stated Kathryn Wise, CRI's director of public relations. "Itis a consumer information label. The word 'warning' infers thatthere is hazard in the product and there has been no proven hazardto carpet."

CRI reaffirms this stance in a "Question and Answer" sheet they aredistributing throughout the carpet and rug industry to guide salesrepresentatives' 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 anumber of studies indicating human health hazards from working withcarpets, including lympocytic leukemia, testicular cancer, oral andpharyngeal cancer, neuropsychiatric illness, and central nervoussystem damage. (4-8) EPA researchers warn that carpet tests toprovide a reservoir for tracked-in chemicals adsorbed to dust,including pesticides, lead, heavy metals, and poly-nuclear aromatichydrocarbons. The amount of lead found in dust and carpet where achild plays has been found to be the best single predictor of thetoddler's blood level of lead. (9-11)

In addition, published studies have shown that a large number ofchemicals offgassing from carpet are hazardous to human health. Forexample, formaldehyde is a confirmed carcinogen. Low-level exposuresmay cause hypersensitivity reactions in humans including eye, noseand throat irritation, bronchial spasm, lung irritation, anddermatitis. CRI's Wise denied that new carpet contains formaldehydefrom the manufacturing process, yet significant levels offormaldehyde have been found offgassing from new carpets straightfrom the mill. (1, 12-16)

Other hazardous chemicals found offgassing from new carpet includeacetone, benzene, styrene, toluene, and xylene, all of which areincluded in EPA's Toxic Substances Control Act Inventory and listedon EPA's Community Right to Know List. (1, 12-17) Independentresearchers have found the ASTM E981 test method (used by AndersonLaboratories) to be a reliable test for extrapolating human healtheffects from the mouse data derived from a number of the hazardouschemicals found offgassing from carpet. (1, 12, 14, 15, 17, 18)

CRI hired the founder of the ASTM E981 method, Dr. Alarie of theUniversity 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 onEnvironment, Energy, and Natural Resources, attended by VanGelderen,the president of CRI, Alarie testified that not only did he find

51

Anderson's test protocol to be scientifically valid, but he was alsoable to duplicate her test results four times in his own laboratory.(19) Congressman Sanders' aide Pollina was present at a videotapedside-by-side test conducted by the EPA at Anderson Laboratories. TheVideotape, which proved EPA duplicated Anderson's test results, wassubmitted as evidence at the Congressional hearing. (20)

In spite of CRI's Question and Answer sheet stating EPA was unable toduplicate the test results, Goldman is still willing to work withindustry and EPA as long as there are witnesses. "Let's run thestudies with EPA and industry, with observers to make sure that theprotocol is truly observed and we are all doing it exactly the sameway. Then let's take the samples that prove to be toxic, bring themto an independent laboratory and analyze the fumes that offgas fromthe sample to see what is in it," said Goldman. "In terms of gettingthe industry to act, I think they are motivated by the litigation,threat of regulation, and or course concern for economicrepercussion, such as loss of market share. I think positive changesare occurring, but very gradually."

Carpet Industry Response Team A Lawyer's Perspective

As part of their new "Consumer Information Initiative," the Carpetand Rug Institute (CRI) has assembled "response teams" to investigatecarpet complaints in people's homes and office buildings.

"CRI is proposing that if someone has a carpet complaint in a home oroffice building, then they will send a team to that building wherethey will gather information as to what may or may not be happeningin the building," says Congressman Bernard SAnders' [I-VT] aide,Anthony Pollina. "CRI's information says they have created sixresponse teams to investigate carpet complaints. Each team iscomposed of an independent industrial hygiene consultant, a carpetmill or fiber producer representative, and a CRI testing lab expert."

How do those response teams come into play? According to the CRI'sdirector of public relations, Kathryn Wise, when people reportcarpet-related health problems to CRI," right now we ask about all ofthe other things that are going on in their homes and what symptomsthey have, what kinds of effectss they are having, what kind ofcleaning they are doing on their carpet, what other allergies theyhave. We try to find out a much about what is going on in their workspace or home space as wel can, and then if we still have questionsabout the carpet, we have a team that can be sent -- of people who

52

are very adept at determining these things -- and they can determinewhat the problem is."

Attorney Kevin McIvers of Santa Barbara, California, offers thefollowing words of caution about the carpet industry response teams:

"How could the CRI possibly do an objective evaluation when theydon'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 wasmy sick spouse, child, or loved one that was involved and these guyswanted to come out and supposedly help me get to the bottom of theproblem, I would be mighty skeptical. And from a lawyer'sperspective, I wouldn't let them anywhere near a client of mine.

"I think it is ridiculous for them to consistently put outmisinformation 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 seriousproblem and we want to help,' then I would open the door and let themin. But not until that happens would I even consider it. And why onearth would they send in a carpet mill or fiber producerrepresentative? The role of industry representatives is to promotetheir products. What qualifications would they have to conductindoor air quality investigations? What kind of background wouldthey have in neurotoxicology and immunotoxicology?

"The timing of this is especially interesting in light of the carpetand rug industry's recent resolve to not concede a single thing onany particular legal claim, and to resist carpet claims at everypoint. An increasing number of carpet-related lawsuits have beenfiled. The carpet and rug industry has made an industry-widedecision to fight and win these cases, as evidenced by a memo the CRIsent 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 tohelp with a serious problem like this.

"It sounds like a little initial prediscoery. They could get in theperson's home or workplace and test the environment -- not to try tofigure out whether carpet is making the people sick -- but to try toidentify everything else that conceivably could. They can do thesame 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 anattorney and realizes that they're getting clobbered by theopposition. Again, since they don't recognize carpet can be aserious problem, how can they possibly be qualified to investigate acarpet complaint? This leads me to believe that the only thing they

53

could possibly be doing is trying to undermine what someone knows tobe a carpet problem, and undermine the eventual case if there is tobe a case -- at least put the person on the wrong track regarding thecause of their illness.

"I sincerely hope the day comes when the industry genuinelyrecognizes the serious health probelms some carpets pose. When thatday comes, I for one -- and a lot of other people that are seriouslyinterested, first and foremost, in helping other people avoid gettingthis type of illness -- will open my door and heart, and mind tothem. That was Jocelyn's [Kevin McIvers' wife, who is also anattorney] and my approach initially when we first contacted theindustry because of our son Christopher's carpet-induced tremors. Wewere wide open and wanted to work with the carpet and rug industryand we just got burned. They lied to use and misled us, and as aresult, our little boy was exposed to toxic carpet more than a yearlonger than he needed to be. And that is just the kind of thingthat is going to happen to a lot of other people with this team, I'msure. It's really sad because in an ideal world one should becompletely open with the industry that has a problem and try to helpthem learn what it's about and get some good case histories.However, while the industry is taking such a dishonest approach tothe whole issue, it is just in the best interest of the victims toprotect 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'

54

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

55

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 theauthor, Cindy Duehring (per phone conversation on 10/4/95). Forconsiderably more extensive documentation on the hazards of toxiccarpeting 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 ****

56

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 carpetlabel and consumer information program.

CRI voluntarily agreed to teh new carpet label after months ofintense negotiations with Congressman Bernard Sanders' office [I-VT],the Consumers Union, the Consumer Federation of America, and thestate Attorneys General of New York, Connecticut, Oregon, andVermont. The four attorneys general entered into direct negotiationswith the carpet industry when the Consumer Products Safety Commission(CPSC) refused to even consider their petition, signed by a total of26 state attorneys general, requesting mandatory health warninglabels on carpet.

"The Consumer Products Safety Commission receives hundreds ofcomplaints and inquiries each year about the adverse health effectsassociated witht eh materials used to make carpets," said ConnecticutAttorney General Richard Blumenthal. "The agency has ignored thesehealth concerns and refused to take action. Under the revisedindustry program, consumers will at least be given information toprovide a basic awareness of the possible health risks. Before thisagreement, the industry's brochure said there was no reason forpeople to be concerned about carpet safety -- an absolute outrage.The program was misleading and meaningless. It gave consumers theimpression that the carpet they were purchasing had been thoroughlytested and would not pose any health hazard."

Kirsted Rand of the consumers Union said she would have preferredstronger wording on the label, but still sees it as a "huge stepforward" from the former green tage program which she believes"skirted the issue and was misleading because it implied that thecarpet was somehow safe, so if you were having problems, it had to besomething else. Most of us would have liked to see strongerlanguage, but CRI did come a long way."

57

In spite of the progress, the Consumers Union and the ConsumerFederation 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 CRIbecause they were discussing more than one item prepared by CRI: thewarning label, the carpet Owner's Manual, and an informationalbrochure. "Each time we would edit out a lot of language we foundobjectionable on the label, it would appear in the Owner's Manual,and it was incredibly frustrating," said Rand. "We did not endorsethe final product and the Consumer Federation of America takes thesame position we do."

One of the disagreements throughout the negotiations was the labelsize. The final label was several inches smaller than the size CRIinitially agreed to use, according to Rand, who said, "They alsodumped on us at the last minute that this label was going to beincorporated on the back of carpet samples along with many otherlabels -- most of which are promotional, and most of which are muchlarger than the label with a warning on it. So based on the factthat the label could be buried, and the fact that they had tried to

58

just sneak by this label size change, I felt the Consumers Unioncould not endorse the final product. Another bone of contention isthat CRI insists we describe it as a consumer information labelrather than a warning label. That's just a game of semantics thatobviously their lawyers want them to play."

CRI is relaly trying to be careful that they con't put themselves ina 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 corporateattorneys to protect against tort litigation. We still have a longway to go to protect the public adequately. The new warning isbetter than the old warning, however, it is clearly not the idealwarning."

Mark Goldman, manager of Anderson Laboratories, agrees. "It'sprogress, but it's an incomplete label," he said. AndersonLaboratories tested new carpet samples at room temperature using astandard testing method (ASTM E981) and found that offgassing fromsome samples -- even as small as sever square inches -- caused severerespiratory and neurological effects, including death, in mice.

The ASTM E981 test method was developed by Yves Alarie, Ph.D., in the1960's under the direction of the U.S. Department of Definse. It wasspecifically developed to reliably extrapolate mouse data to humans.It has been recommended as a reliable product test in a reportcommissioned by the CPSC and also by Daniel Costa, of theEnvironmental Protection Agency's Health Effects Research Laboratory,Pulmonary Toxicology Branch. (1, 2) Regarding the ASTM E981, Costawrote: "We support the use of the mouse irritancy test fordetecting, and possibly for comparing potencies among, indoor aircontaminants ... we believe that if the mouse irritancy test ispositive upon exposure to a suspected indoor contaminant, then theatmosphere is likely to be irritating to humans." (2) Based onAnderson's test results, which were duplicated by Alarie, Hirzystated: "It looks like there really needs to be some fundamentalchanges in the manufacturing processes for carpet and its rawmaterials. And there needs to be a substantial amount of researchinto actually pinpointing the causes of the toxicity that Andersonand Alarie are finding."

The health effects on the test animals have consistently correlatedwell with the health effects reported by the people submitting theircarpet samples for testing, according to Goldman. He expressedconcern that the new carpet label does not address the chronic,long-term health problems being reported by some people. "The label

59

gives some cautions about installation and the few days immediatelyafter installation, but it doesn't acknowledge that some carpets area long-term hazard and may continue offgassing low levels of thechemical 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 72hours. We have not denied that. There are a lot of volatilechemical compounds that leave in those 72 hours, but there are somepretty bad ones that still hang around. And we are seeing continuousdegradation in some carpets. So the label is not really addressingthe fact that with some carpets you're going to have long-termproblems. The real milestone that has to be passed is that they mustcreate a toxicologically safe product. Until that happens, peopleare still at risk."

Rosilind Anderson, Ph.D., director of Anderson Laboratories, believesthe label's ventilation message is very inadequate. "Anyone who hashad any kind of carpet problem knows that this is not something forwhich the response is simply ventilate for two or three days. Theirrecommendation to open your windows and run your exhaust fans willnot protect people if they have a problem carpet. Further, there arevery, very few doctors who are able to recognize the early signs ofcarpet toxicity," she said.

Other researchers have expressed concern about the label'slimitations. "I feel the label is inadequate for several reasons.When you read it, the label gives you the feeling that only peoplewho are sensitive will have an adverse response, and in all realitythat is not true," cautioned immunotoxicologist Jack Thrasher, Ph.D."It really is not giving the full message to the public. Anotherproblem with warning labels of this nature, is that it simply says tonotify your physician if you have problems. But if the doctor is noteducated regarding chemicals, then how is he going to know what teststo do, what symptoms to look for, and how to determine what iscausing those symptoms? In my personal opinion, with a label such asthis, it would be incombent upon the carpet industry to inform alltreating physicians in the countries where they market their productsthat there are health problems with carpeting and what those problemsare so the doctor would have an idea what to look for."

Thrasher is also concerned that the label implies thee is a treatmentfor the adverse reactions to carpet, while leaving the carpet inplace, "when in reality there is no treatment. If carpet is causingproblems, the only treatment is to remove it and get it out of thehouse. All a doctor can do is recognize the problem, run theappropriate tests to determine the extent of the problem, and discuss

60

it with the patient so they realize what they must do to preventfurther illness. And again, the only way to prevent further illnessis to get the carpet out of the house and avoid further exposures,"stated Thrasher.

In spite of their concerns, Thrasher, Anderson, Goldman, Rand, andHirzy all believe the label represents a positive step because it atleast alerts consumers that symtpoms have been reported. This viewwas also expressed by the New York Attorney General's office. "I amreally hopeful that some people who otherwise would not have thoughttwice about any of these carpet safety issues will now have theopportunity to think about it because of the label, and willrecognize the connection and take steps to protect themselves if theyare experiencing symptoms," said Ronna Brown, assistant attorneygeneral at the New York Department of Law.

"This consumer warning label makes an important contribution toalerting the public about the range of symptoms many people associatewith exposure to the chemicals given off by new carpeting. I urgeall consumers to heed the carpet warning label," advised former NewYork Attorney General Robert Abrams.

In spite of the warnings on the new label, CRI still insists thee areno health hazards associated with carpet. "It's not a warninglabel," stated Kathryn Wise, CRI's director of public relations. "Itis a consumer information label. The word 'warning' infers thatthere is hazard in the product and there has been no proven hazardto carpet."

CRI reaffirms this stance in a "Question and Answer" sheet they aredistributing throughout the carpet and rug industry to guide salesrepresentatives' 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

61

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 anumber of studies indicating human health hazards from working withcarpets, including lympocytic leukemia, testicular cancer, oral andpharyngeal cancer, neuropsychiatric illness, and central nervoussystem damage. (4-8) EPA researchers warn that carpet tests toprovide a reservoir for tracked-in chemicals adsorbed to dust,including pesticides, lead, heavy metals, and poly-nuclear aromatichydrocarbons. The amount of lead found in dust and carpet where achild plays has been found to be the best single predictor of thetoddler's blood level of lead. (9-11)

In addition, published studies have shown that a large number ofchemicals offgassing from carpet are hazardous to human health. Forexample, formaldehyde is a confirmed carcinogen. Low-level exposuresmay cause hypersensitivity reactions in humans including eye, noseand throat irritation, bronchial spasm, lung irritation, anddermatitis. CRI's Wise denied that new carpet contains formaldehydefrom the manufacturing process, yet significant levels offormaldehyde have been found offgassing from new carpets straightfrom the mill. (1, 12-16)

Other hazardous chemicals found offgassing from new carpet includeacetone, benzene, styrene, toluene, and xylene, all of which areincluded in EPA's Toxic Substances Control Act Inventory and listedon EPA's Community Right to Know List. (1, 12-17) Independentresearchers have found the ASTM E981 test method (used by AndersonLaboratories) to be a reliable test for extrapolating human healtheffects from the mouse data derived from a number of the hazardouschemicals found offgassing from carpet. (1, 12, 14, 15, 17, 18)

CRI hired the founder of the ASTM E981 method, Dr. Alarie of theUniversity 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 onEnvironment, Energy, and Natural Resources, attended by VanGelderen,the president of CRI, Alarie testified that not only did he find

62

Anderson's test protocol to be scientifically valid, but he was alsoable to duplicate her test results four times in his own laboratory.(19) Congressman Sanders' aide Pollina was present at a videotapedside-by-side test conducted by the EPA at Anderson Laboratories. TheVideotape, which proved EPA duplicated Anderson's test results, wassubmitted as evidence at the Congressional hearing. (20)

In spite of CRI's Question and Answer sheet stating EPA was unable toduplicate the test results, Goldman is still willing to work withindustry and EPA as long as there are witnesses. "Let's run thestudies with EPA and industry, with observers to make sure that theprotocol is truly observed and we are all doing it exactly the sameway. Then let's take the samples that prove to be toxic, bring themto an independent laboratory and analyze the fumes that offgas fromthe sample to see what is in it," said Goldman. "In terms of gettingthe industry to act, I think they are motivated by the litigation,threat of regulation, and or course concern for economicrepercussion, such as loss of market share. I think positive changesare occurring, but very gradually."

Carpet Industry Response Team A Lawyer's Perspective

As part of their new "Consumer Information Initiative," the Carpetand Rug Institute (CRI) has assembled "response teams" to investigatecarpet complaints in people's homes and office buildings.

"CRI is proposing that if someone has a carpet complaint in a home oroffice building, then they will send a team to that building wherethey will gather information as to what may or may not be happeningin the building," says Congressman Bernard SAnders' [I-VT] aide,Anthony Pollina. "CRI's information says they have created sixresponse teams to investigate carpet complaints. Each team iscomposed of an independent industrial hygiene consultant, a carpetmill or fiber producer representative, and a CRI testing lab expert."

How do those response teams come into play? According to the CRI'sdirector of public relations, Kathryn Wise, when people reportcarpet-related health problems to CRI," right now we ask about all ofthe other things that are going on in their homes and what symptomsthey have, what kinds of effectss they are having, what kind ofcleaning they are doing on their carpet, what other allergies theyhave. We try to find out a much about what is going on in their workspace or home space as wel can, and then if we still have questionsabout the carpet, we have a team that can be sent -- of people who

63

are very adept at determining these things -- and they can determinewhat the problem is."

Attorney Kevin McIvers of Santa Barbara, California, offers thefollowing words of caution about the carpet industry response teams:

"How could the CRI possibly do an objective evaluation when theydon'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 wasmy sick spouse, child, or loved one that was involved and these guyswanted to come out and supposedly help me get to the bottom of theproblem, I would be mighty skeptical. And from a lawyer'sperspective, I wouldn't let them anywhere near a client of mine.

"I think it is ridiculous for them to consistently put outmisinformation 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 seriousproblem and we want to help,' then I would open the door and let themin. But not until that happens would I even consider it. And why onearth would they send in a carpet mill or fiber producerrepresentative? The role of industry representatives is to promotetheir products. What qualifications would they have to conductindoor air quality investigations? What kind of background wouldthey have in neurotoxicology and immunotoxicology?

"The timing of this is especially interesting in light of the carpetand rug industry's recent resolve to not concede a single thing onany particular legal claim, and to resist carpet claims at everypoint. An increasing number of carpet-related lawsuits have beenfiled. The carpet and rug industry has made an industry-widedecision to fight and win these cases, as evidenced by a memo the CRIsent 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 tohelp with a serious problem like this.

"It sounds like a little initial prediscoery. They could get in theperson's home or workplace and test the environment -- not to try tofigure out whether carpet is making the people sick -- but to try toidentify everything else that conceivably could. They can do thesame 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 anattorney and realizes that they're getting clobbered by theopposition. Again, since they don't recognize carpet can be aserious problem, how can they possibly be qualified to investigate acarpet complaint? This leads me to believe that the only thing they

64

could possibly be doing is trying to undermine what someone knows tobe a carpet problem, and undermine the eventual case if there is tobe a case -- at least put the person on the wrong track regarding thecause of their illness.

"I sincerely hope the day comes when the industry genuinelyrecognizes the serious health probelms some carpets pose. When thatday comes, I for one -- and a lot of other people that are seriouslyinterested, first and foremost, in helping other people avoid gettingthis type of illness -- will open my door and heart, and mind tothem. That was Jocelyn's [Kevin McIvers' wife, who is also anattorney] and my approach initially when we first contacted theindustry because of our son Christopher's carpet-induced tremors. Wewere wide open and wanted to work with the carpet and rug industryand we just got burned. They lied to use and misled us, and as aresult, our little boy was exposed to toxic carpet more than a yearlonger than he needed to be. And that is just the kind of thingthat is going to happen to a lot of other people with this team, I'msure. It's really sad because in an ideal world one should becompletely open with the industry that has a problem and try to helpthem learn what it's about and get some good case histories.However, while the industry is taking such a dishonest approach tothe whole issue, it is just in the best interest of the victims toprotect 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'

65

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

66

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 theauthor, Cindy Duehring (per phone conversation on 10/4/95). Forconsiderably more extensive documentation on the hazards of toxiccarpeting 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 carpetlabel and consumer information program.

CRI voluntarily agreed to teh new carpet label after months ofintense negotiations with Congressman Bernard Sanders' office [I-VT],the Consumers Union, the Consumer Federation of America, and thestate Attorneys General of New York, Connecticut, Oregon, andVermont. The four attorneys general entered into direct negotiationswith the carpet industry when the Consumer Products Safety Commission(CPSC) refused to even consider their petition, signed by a total of26 state attorneys general, requesting mandatory health warninglabels on carpet.

"The Consumer Products Safety Commission receives hundreds ofcomplaints and inquiries each year about the adverse health effectsassociated witht eh materials used to make carpets," said ConnecticutAttorney General Richard Blumenthal. "The agency has ignored thesehealth concerns and refused to take action. Under the revisedindustry program, consumers will at least be given information toprovide a basic awareness of the possible health risks. Before thisagreement, the industry's brochure said there was no reason forpeople to be concerned about carpet safety -- an absolute outrage.The program was misleading and meaningless. It gave consumers theimpression that the carpet they were purchasing had been thoroughlytested and would not pose any health hazard."

Kirsted Rand of the consumers Union said she would have preferredstronger wording on the label, but still sees it as a "huge stepforward" from the former green tage program which she believes"skirted the issue and was misleading because it implied that thecarpet was somehow safe, so if you were having problems, it had to besomething else. Most of us would have liked to see strongerlanguage, but CRI did come a long way."

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In spite of the progress, the Consumers Union and the ConsumerFederation 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 CRIbecause they were discussing more than one item prepared by CRI: thewarning label, the carpet Owner's Manual, and an informationalbrochure. "Each time we would edit out a lot of language we foundobjectionable on the label, it would appear in the Owner's Manual,and it was incredibly frustrating," said Rand. "We did not endorsethe final product and the Consumer Federation of America takes thesame position we do."

One of the disagreements throughout the negotiations was the labelsize. The final label was several inches smaller than the size CRIinitially agreed to use, according to Rand, who said, "They alsodumped on us at the last minute that this label was going to beincorporated on the back of carpet samples along with many otherlabels -- most of which are promotional, and most of which are muchlarger than the label with a warning on it. So based on the factthat 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 Unioncould not endorse the final product. Another bone of contention isthat CRI insists we describe it as a consumer information labelrather than a warning label. That's just a game of semantics thatobviously their lawyers want them to play."

CRI is relaly trying to be careful that they con't put themselves ina 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 corporateattorneys to protect against tort litigation. We still have a longway to go to protect the public adequately. The new warning isbetter than the old warning, however, it is clearly not the idealwarning."

Mark Goldman, manager of Anderson Laboratories, agrees. "It'sprogress, but it's an incomplete label," he said. AndersonLaboratories tested new carpet samples at room temperature using astandard testing method (ASTM E981) and found that offgassing fromsome samples -- even as small as sever square inches -- caused severerespiratory and neurological effects, including death, in mice.

The ASTM E981 test method was developed by Yves Alarie, Ph.D., in the1960's under the direction of the U.S. Department of Definse. It wasspecifically developed to reliably extrapolate mouse data to humans.It has been recommended as a reliable product test in a reportcommissioned by the CPSC and also by Daniel Costa, of theEnvironmental Protection Agency's Health Effects Research Laboratory,Pulmonary Toxicology Branch. (1, 2) Regarding the ASTM E981, Costawrote: "We support the use of the mouse irritancy test fordetecting, and possibly for comparing potencies among, indoor aircontaminants ... we believe that if the mouse irritancy test ispositive upon exposure to a suspected indoor contaminant, then theatmosphere is likely to be irritating to humans." (2) Based onAnderson's test results, which were duplicated by Alarie, Hirzystated: "It looks like there really needs to be some fundamentalchanges in the manufacturing processes for carpet and its rawmaterials. And there needs to be a substantial amount of researchinto actually pinpointing the causes of the toxicity that Andersonand Alarie are finding."

The health effects on the test animals have consistently correlatedwell with the health effects reported by the people submitting theircarpet samples for testing, according to Goldman. He expressedconcern 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 immediatelyafter installation, but it doesn't acknowledge that some carpets area long-term hazard and may continue offgassing low levels of thechemical 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 72hours. We have not denied that. There are a lot of volatilechemical compounds that leave in those 72 hours, but there are somepretty bad ones that still hang around. And we are seeing continuousdegradation in some carpets. So the label is not really addressingthe fact that with some carpets you're going to have long-termproblems. The real milestone that has to be passed is that they mustcreate a toxicologically safe product. Until that happens, peopleare still at risk."

Rosilind Anderson, Ph.D., director of Anderson Laboratories, believesthe label's ventilation message is very inadequate. "Anyone who hashad any kind of carpet problem knows that this is not something forwhich the response is simply ventilate for two or three days. Theirrecommendation to open your windows and run your exhaust fans willnot protect people if they have a problem carpet. Further, there arevery, very few doctors who are able to recognize the early signs ofcarpet toxicity," she said.

Other researchers have expressed concern about the label'slimitations. "I feel the label is inadequate for several reasons.When you read it, the label gives you the feeling that only peoplewho are sensitive will have an adverse response, and in all realitythat is not true," cautioned immunotoxicologist Jack Thrasher, Ph.D."It really is not giving the full message to the public. Anotherproblem with warning labels of this nature, is that it simply says tonotify your physician if you have problems. But if the doctor is noteducated regarding chemicals, then how is he going to know what teststo do, what symptoms to look for, and how to determine what iscausing those symptoms? In my personal opinion, with a label such asthis, it would be incombent upon the carpet industry to inform alltreating physicians in the countries where they market their productsthat there are health problems with carpeting and what those problemsare so the doctor would have an idea what to look for."

Thrasher is also concerned that the label implies thee is a treatmentfor the adverse reactions to carpet, while leaving the carpet inplace, "when in reality there is no treatment. If carpet is causingproblems, the only treatment is to remove it and get it out of thehouse. All a doctor can do is recognize the problem, run theappropriate 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 preventfurther illness. And again, the only way to prevent further illnessis to get the carpet out of the house and avoid further exposures,"stated Thrasher.

In spite of their concerns, Thrasher, Anderson, Goldman, Rand, andHirzy all believe the label represents a positive step because it atleast alerts consumers that symtpoms have been reported. This viewwas also expressed by the New York Attorney General's office. "I amreally hopeful that some people who otherwise would not have thoughttwice about any of these carpet safety issues will now have theopportunity to think about it because of the label, and willrecognize the connection and take steps to protect themselves if theyare experiencing symptoms," said Ronna Brown, assistant attorneygeneral at the New York Department of Law.

"This consumer warning label makes an important contribution toalerting the public about the range of symptoms many people associatewith exposure to the chemicals given off by new carpeting. I urgeall consumers to heed the carpet warning label," advised former NewYork Attorney General Robert Abrams.

In spite of the warnings on the new label, CRI still insists thee areno health hazards associated with carpet. "It's not a warninglabel," stated Kathryn Wise, CRI's director of public relations. "Itis a consumer information label. The word 'warning' infers thatthere is hazard in the product and there has been no proven hazardto carpet."

CRI reaffirms this stance in a "Question and Answer" sheet they aredistributing throughout the carpet and rug industry to guide salesrepresentatives' 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 anumber of studies indicating human health hazards from working withcarpets, including lympocytic leukemia, testicular cancer, oral andpharyngeal cancer, neuropsychiatric illness, and central nervoussystem damage. (4-8) EPA researchers warn that carpet tests toprovide a reservoir for tracked-in chemicals adsorbed to dust,including pesticides, lead, heavy metals, and poly-nuclear aromatichydrocarbons. The amount of lead found in dust and carpet where achild plays has been found to be the best single predictor of thetoddler's blood level of lead. (9-11)

In addition, published studies have shown that a large number ofchemicals offgassing from carpet are hazardous to human health. Forexample, formaldehyde is a confirmed carcinogen. Low-level exposuresmay cause hypersensitivity reactions in humans including eye, noseand throat irritation, bronchial spasm, lung irritation, anddermatitis. CRI's Wise denied that new carpet contains formaldehydefrom the manufacturing process, yet significant levels offormaldehyde have been found offgassing from new carpets straightfrom the mill. (1, 12-16)

Other hazardous chemicals found offgassing from new carpet includeacetone, benzene, styrene, toluene, and xylene, all of which areincluded in EPA's Toxic Substances Control Act Inventory and listedon EPA's Community Right to Know List. (1, 12-17) Independentresearchers have found the ASTM E981 test method (used by AndersonLaboratories) to be a reliable test for extrapolating human healtheffects from the mouse data derived from a number of the hazardouschemicals found offgassing from carpet. (1, 12, 14, 15, 17, 18)

CRI hired the founder of the ASTM E981 method, Dr. Alarie of theUniversity 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 onEnvironment, 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 alsoable to duplicate her test results four times in his own laboratory.(19) Congressman Sanders' aide Pollina was present at a videotapedside-by-side test conducted by the EPA at Anderson Laboratories. TheVideotape, which proved EPA duplicated Anderson's test results, wassubmitted as evidence at the Congressional hearing. (20)

In spite of CRI's Question and Answer sheet stating EPA was unable toduplicate the test results, Goldman is still willing to work withindustry and EPA as long as there are witnesses. "Let's run thestudies with EPA and industry, with observers to make sure that theprotocol is truly observed and we are all doing it exactly the sameway. Then let's take the samples that prove to be toxic, bring themto an independent laboratory and analyze the fumes that offgas fromthe sample to see what is in it," said Goldman. "In terms of gettingthe industry to act, I think they are motivated by the litigation,threat of regulation, and or course concern for economicrepercussion, such as loss of market share. I think positive changesare occurring, but very gradually."

Carpet Industry Response Team A Lawyer's Perspective

As part of their new "Consumer Information Initiative," the Carpetand Rug Institute (CRI) has assembled "response teams" to investigatecarpet complaints in people's homes and office buildings.

"CRI is proposing that if someone has a carpet complaint in a home oroffice building, then they will send a team to that building wherethey will gather information as to what may or may not be happeningin the building," says Congressman Bernard SAnders' [I-VT] aide,Anthony Pollina. "CRI's information says they have created sixresponse teams to investigate carpet complaints. Each team iscomposed of an independent industrial hygiene consultant, a carpetmill or fiber producer representative, and a CRI testing lab expert."

How do those response teams come into play? According to the CRI'sdirector of public relations, Kathryn Wise, when people reportcarpet-related health problems to CRI," right now we ask about all ofthe other things that are going on in their homes and what symptomsthey have, what kinds of effectss they are having, what kind ofcleaning they are doing on their carpet, what other allergies theyhave. We try to find out a much about what is going on in their workspace or home space as wel can, and then if we still have questionsabout 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 determinewhat the problem is."

Attorney Kevin McIvers of Santa Barbara, California, offers thefollowing words of caution about the carpet industry response teams:

"How could the CRI possibly do an objective evaluation when theydon'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 wasmy sick spouse, child, or loved one that was involved and these guyswanted to come out and supposedly help me get to the bottom of theproblem, I would be mighty skeptical. And from a lawyer'sperspective, I wouldn't let them anywhere near a client of mine.

"I think it is ridiculous for them to consistently put outmisinformation 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 seriousproblem and we want to help,' then I would open the door and let themin. But not until that happens would I even consider it. And why onearth would they send in a carpet mill or fiber producerrepresentative? The role of industry representatives is to promotetheir products. What qualifications would they have to conductindoor air quality investigations? What kind of background wouldthey have in neurotoxicology and immunotoxicology?

"The timing of this is especially interesting in light of the carpetand rug industry's recent resolve to not concede a single thing onany particular legal claim, and to resist carpet claims at everypoint. An increasing number of carpet-related lawsuits have beenfiled. The carpet and rug industry has made an industry-widedecision to fight and win these cases, as evidenced by a memo the CRIsent 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 tohelp with a serious problem like this.

"It sounds like a little initial prediscoery. They could get in theperson's home or workplace and test the environment -- not to try tofigure out whether carpet is making the people sick -- but to try toidentify everything else that conceivably could. They can do thesame 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 anattorney and realizes that they're getting clobbered by theopposition. Again, since they don't recognize carpet can be aserious problem, how can they possibly be qualified to investigate acarpet 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 tobe a carpet problem, and undermine the eventual case if there is tobe a case -- at least put the person on the wrong track regarding thecause of their illness.

"I sincerely hope the day comes when the industry genuinelyrecognizes the serious health probelms some carpets pose. When thatday comes, I for one -- and a lot of other people that are seriouslyinterested, first and foremost, in helping other people avoid gettingthis type of illness -- will open my door and heart, and mind tothem. That was Jocelyn's [Kevin McIvers' wife, who is also anattorney] and my approach initially when we first contacted theindustry because of our son Christopher's carpet-induced tremors. Wewere wide open and wanted to work with the carpet and rug industryand we just got burned. They lied to use and misled us, and as aresult, our little boy was exposed to toxic carpet more than a yearlonger than he needed to be. And that is just the kind of thingthat is going to happen to a lot of other people with this team, I'msure. It's really sad because in an ideal world one should becompletely open with the industry that has a problem and try to helpthem learn what it's about and get some good case histories.However, while the industry is taking such a dishonest approach tothe whole issue, it is just in the best interest of the victims toprotect 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 readthe 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 fromMonsanto, Dupont, and others as scientists and the generalpopulation 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) wouldall be so immoral and heartless that they would continue to let somany people suffer serious damage to their health (includingchildren) simply so the industry can make more money and avoidlawsuits. These groups are abusing the scientific processes and theyare abusing the population.

I sincerely hope people will, unlike the organizations mentionedabove, look out for each other by passing this information alongto 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.)