# Presentation: 359095

## Housing for People  with Chemical & Electrical Sensitivities/Intolerances Presented forU.S. HUD Departmental Task Force on Disability IssuesMarch 19, 2008

- Mary Lamielle, Executive Director
- National Center for Environmental Health Strategies, Inc. (NCEHS)
- 1100 Rural Avenue
- Voorhees, New Jersey 08043
- (856)429-5358; (856)816-8820
- _[marylamielle@ncehs.org](mailto:marylamielle@ncehs.org)__  _

## What is Multiple Chemical Sensitivity/Intolerance (MCS/MCI)?

- People with MCS/MCI react to low level everyday chemical exposures
- Reactions are triggered by various substances and products such as:
- Pesticides:  weed killers, bug sprays, treated wood products
- Solvents: paints, glues, gasoline, nail polish/remover
- Indoor Air VOCs: new carpet, formaldehyde, plasticizers, chlorine, fragrances and fragranced products
- Cleaners: bleach, ammonia, phenolic disinfectants, air fresheners
- Combustion-related:  auto and diesel exhaust, tobacco smoke, natural gas, tar/asphalt
- Drugs/Medical Devices: anesthetics, antibiotics, implants, vaccines
- Individual tolerances may vary

## What is MCS/MCI? (cont.)

- Symptoms:
- Neurological impairments:
- Headaches, migraines, difficulty thinking, seizures
- Respiratory involvement:
- Asthma, reactive airways, sinusitis, balance
- Muscular difficulties:
-  pain, weakness, fatigue
- Cardiovascular problems:
- Arrhythmias, hypertension, hypotension, edema
- Gastrointestinal complaints:
- Irritable bowel, reflux

## What are Electrical Sensitivities?

- People with electrical sensitivities react to electromagnetic fields (EMFs) from electrical devices and frequencies
- Reactions are triggered by:
- Electrical appliances and devices, microwaves, transformers, high tension wires, cell phones, cell towers, fluorescent lighting
- Symptoms:
- Neurological, loss of muscle control

## Who is Affected by CS/ES?

- 16 % of Californians are  “unusually sensitive” to chemicals
- 11.2% of Americans report chemical sensitivities according to a national survey
- Up to 4% of the U.S. population is chronically ill with CS based on a series of state and federal studies
- 6% of Californians have a diagnosis of MCS
- 3% of Californians report electrical sensitivities

- <date/time>

-    People with CS/ES
-  Must** **

## Housing Problems

- Crisis of homelessness:  population of *environmental refugees*
- Challenge:  sustain life and health; life is about survival on a day-to-day basis
- Serious lack of affordable, accessible, healthy/nontoxic housing
- Failure to accommodate in existing housing
- Failure of multifamily or integrated housing to work for those with CS/ES
- Extreme problems with harassment, discrimination, and retaliation

## US HUD Recognition of MCS

- October 26, 1990: Policy Statement
- Recognition of the disability
- Reasonable accommodations for those disabled under the Fair Housing Act and Rehabilitation Act of 1973
- June 6, 1991:  *Draft *Technical Guidance Memorandum 91-3
- Discusses HUD recognition of MCS as a handicap
- Provides examples of accommodations which are considered reasonable  (re:  carpeting, pesticides)
-  April 14, 1992:  HUD Legal Memorandum
- Recognition of MCS/EI as a physical disability entitling reasonable accommodations on a case-by-case basis
- Excludes allergies
- Extends coverage to those recognized as disabled by the Social Security Administration
- Lists other federal agencies that recognize MCS

## Typical Accommodation Requests

- Eliminate the use of structural (indoor) and landscape (outdoor) pesticides.  Adopt Integrated Pest Management  (IPM).
- Replace gas or propane stove and/or clothes dryer with electric units.
- Install washer and dryer in housing unit to eliminate the need to use common laundry areas.
- Flooring: Do not install new carpeting; or remove carpeting only as necessary for tenant; or leave old carpeting untouched; or install hard surface flooring.
- Retrofit inoperable windows so they can be opened.

- Clean ductwork for heating and air conditioning system.
- Construct or replace ramps, balconies, and decks with materials well-tolerated by tenant.
- Provide an extra room or bedroom for those with CS/ES to enable the tenant to isolate problematic belongings.
- Avoid remodeling activities such as painting in the living area or vicinity of those with CS.  If such activity is critical, arrangements must be made well in advance to house the affected individual for the length of time necessary to protect from further injury.  Involve tenant in selection of least toxic/problematic products.
- Designate nonsmoking homes and buildings.  Post no smoking signs in common areas and in the vicinity of building entrances, windows, and air intakes.

- Post signs to prohibit  idling in parking areas.
- Consult with CS tenants and their representatives for safer remodeling and maintenance practices.
- Post a non-discrimination policy to protect those with CS/ES.
- Discourage the use of toxic chemicals such as pesticides, air fresheners, scented candles, etc. by other tenants.
- Use least toxic/problematic cleaning products in common areas.
- Discourage the use of cell phones, microwaves, fluorescent lighting and other sources of EMFs in the vicinity of those with ES.

- Provide prenotification of building events such as cleaning, painting, roofing, and similar activities.  Use the least toxic materials in consultation with the affected tenant.
- Management should educate staff and tenants regarding the goal of maintaining a pollution-free environment to the extent possible for the health and well-being of all tenants.

## National Council on DisabilityAchieving Independence, July 26, 1996

- RECOMMENDS:
- Promotion of clean air and nontoxic substances in public places
- An extra room “to isolate toxic products within dwellings (for people with multiple chemical sensitivities.)”
- Research and data collection on the “ways to expand the effective design of housing for people with multiple chemical sensitivities.”

## National Council on Independent LivingHousing Position Paper,  Rev. August 2006 

- Identified “a critical lack of affordable, accessible, **healthy/nontoxic** and *integrated* housing for persons with disabilities.”
- Recommendations include:
- Commitment of funds from all housing programs including 811 set-asides for people with CS/ES
- Mandatory education and training on the housing needs of those with CS/ES
- HUD should adopt and promote IPM for all housing
- Congressional and administration initiatives to create  effective design and data collection on housing for people with CS/ES

## Designing & Maintaining Healthier Housing

- Design, construct, maintain, and landscape to prevent or minimize pest problems, molds, and allergens.
- Use nontoxic or least toxic pest control practices in consultation with tenant.  Ban the use of organophosphates,  carbamates, and pyrethroids.
- Design and construct with operable windows.  Retrofit inoperable windows in existing structures as requested.
- Install adequate ventilation with ductwork free of interior fiberglass insulation. Install localized exhausts for the kitchen, bathroom, and laundry.  Use air filtration systems if possible.

## Designing & Maintaining (cont.)

- Install water filtration system to remove chlorine, at minimum.
- Do not use carpeting and adhesives.  Use hard surface flooring with low VOCs.
- Use low or no VOC paints, glues, and finishes.  (Even these products as with flooring are likely to cause reactions for people with CS and should be tested for tolerance prior to use.)
- Do not use combustion-based appliances such as natural gas or propane for stoves or clothes dryers. Avoid natural gas, oil, and  wood-burning stoves for heating.

## Designing & Maintaining (cont.)

- Do not use composite wood, particleboard, or other formaldehyde or phenol-emitting wood product for kitchen or bathroom cabinets, shelving, closets, etc.  Do not use pressure-treated, CCA, creosote, cedar, pine, or vinyl for ramps, balconies, or decks unless otherwise tolerated by tenant.  Use metal siding or autoclaved aerated concrete for exterior.
- Design and construct with extra room or storage area, separate from the living space, with a window or localized exhaust.
- Do not use fluorescent or halogen lighting.  Permit individual control of lighting and ventilation systems.

## Designing & Maintaining (cont.)

- Avoid construction in the vicinity of chemical or electrical pollution sources.
- Construct and design to minimize or avoid the use of combustion-fueled maintenance and yard equipment.

## Recommendations for Action by HUD

- Survey the CS/ES communities regarding housing needs.
- Support and fund 811 housing projects for people with CS/ES.
- 	(See Ecology House:  _[www.tikvah.com/cc/eh](http://www.tikvah.com/cc/eh)__ )_
- Support and fund Section 8 home ownership for CS/ES.
- Rehabilitate/remodel existing housing stock to make it healthier for all and accessible for people with CS/ES.
- Fund mandatory education and training on the housing needs of people with CS/ES to be given to public housing authorities, developers, and others in the housing community.

## Recommendations (cont.)

- Engage in research and data collection on healthier housing, particularly for people with CS/ES.
- 	(See U.S. Access Board, Indoor Environmental Quality Project Report:  _[http://ieq.nibs.org](http://ieq.nibs.org/)__ ) _
- Support healthier housing by using existing housing  programs (HOPE, ALA Healthy House, Energy Star IAQ Label) as  models to begin to identify healthier housing practices for people with CS/ES.
- 	“Green” products and practices are not always “healthy”.
- Fund alternative housing and housing projects for people with CS/ES:  Lustron Houses, porcelain trailers, halfway houses.

## Recommendations (cont.)

- Adopt Integrated Pest Management (IPM) practices agency-wide for all housing.
- Lower permissible formaldehyde levels for manufactured homes given the FEMA trailer findings.
- Involve representatives of the CS/ES communities in HUD disability and housing program activities.
- Establish a Committee at HUD on  CS/ES to facilitate and guide research, disability policy, and healthy housing practices.
- Provide information on CS/ES and HUD policies on these disabilities on the agency’s website and 800 line.

## Mary Lamielle, Executive DirectorNational Center for Environmental Health Strategies, Inc.1100 Rural AvenueVoorhees, New Jersey 08043(856)429-5358; (856)816-8820ncehs@ncehs.org; marylamielle@ncehs.org