T. 6/8/92
SBO:MAF:RM:KF
                                                 JUN 15 1992

Ms. Leonora L. Guarraia
General Deputy Assistant Secretary
Office of the Assistant Secretary
  for Fair Housing and Equal Opportunity
U.S. Department of Housing and Urban
  Development
Washington, D.C. 20410-2000

Dear Ms. Guarraia:

        We have received your request for an interpretation of
section 504 of the Rehabilitation Act of 1973, as amended.
Specifically, you asked whether, for purposes of section 504, an
individual with multiple chemical sensitivity should be
considered an "individual with handicaps."

        The Department addressed a similar issue during the
development of regulations to implement the Americans with
Disabilities Act (ADA). The Department received numerous
comments detailing how exposure to various environmental
conditions restricts access for individuals who have a heightened
sensitivity to a variety of chemical substances. The commenters
asked that environmental illness be recognized as a disability
covered by the ADA.

        The Department declined to state categorically that
environmental illness is a disability. The preambles to both the
title II rule (which covers State and local governments) and
title III rule (which covers public accommodations and commercial
facilities) state that the determination as to whether an
impairment is a disability depends on whether, given the
particular circumstances at issue, the impairment substantially
limits one or more major life activities (or has a history of, or
is regarded as having such an effect). Sometimes respiratory or
neurological functioning is so severely affected that an

cc: Records, CRS, Oneglia, Friedlander, Mather, Foster
:udd:mather:ltr.guarraia

01-00923










individual will satisfy the requirements to be considered
disabled. In other cases, individuals may be sensitive to
environmental elements but their sensitivity will not rise to the
level needed to constitute a disability. For example, their
major life activity may be somewhat, but not substantially,
impaired. In such circumstances, these types of sensitivities
are not disabilities. (See 56 Fed. Reg. 35,699 (title II rule),
and 56 Fed. Reg. 35,549 (title III rule).)

        The same analysis would apply under section 504. Decisions
as to whether particular impairments are disabilities must be
made on a case-by-case basis.

        Copies of the title II and title III rules are enclosed. I
hope this information is helpful to you.

                                        Sincerely,

                                     Stewart B. Oneglia
                                          Chief
                              Coordination and Review Section
                                   Civil Rights Division

Enclosures (2)

01-00924





























                U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
                         WASHINGTON, D.C. 20410-2000

                                March 3, 1992

OFFICE OF THE ASSISTANT SECRETARY
FOR FAIR HOUSING AND EQUAL OPPORTUNITY

Ms. Stewart B. Oneglia
Chief, Coordination and Review Section
 Civil Rights Division
U.S. Department of Justice
10th and Pennsylvania Avenue, N.W.
Washington, D.C. 20530

Dear Ms. Oneglia:

        During the past year, the Department of Housing and Urban Development
(HUD) issued technical guidance on a controversial disability commonly
referred to as Multiple Chemical Sensitivity or "environmental illness." Those
who have Multiple Chemical Sensitivity claim to experience adverse reactions
after extremely low levels of chemical exposure. The scientific community, as
you are probably aware, does not recognize Multiple Chemical Sensitivity as a
physical disability because there exists no concrete scientific proof that the
illness has physical origins.

        Both the scientific community and various advocacy groups for those
who claim to have this disability are actively supplying me with literature 
supporting each position on the matter. I have enclosed the most recent 
information provided by the scientific community. This information suggests 
Multiple Chemical Sensitivity is an inaccurate term for the physical
disability we previously described in our guidance; they claim the correct
term is Chemical Sensitivity.

        I understand the Department of Justice, as the coordinating agency for 
Section 504 of the Rehabilitation Act of 1973, is developing guidance on this 
subject. It would be helpful if you would supply me with Justice's position on 
this matter so that HUD can be accurate and consistent in its own guidance. I 
may be reached on (202) 708-3855. 
 
                                       Very sincerely yours,

                                        Leonora L. Guarraia
                                        General Deputy Assistant Secretary

Enclosure

01-00925






bc
ia
        BUSINESS COUNCIL ON INDOOR AIR
1225 19th Street. N.W., Suite 300, Washington, D.C. 20036 (202) 775-5887

                        February 6, 1992

Ms. Leonora L. Guarraia
U.S. Department of Housing and Urban Development
Fair Housing and Equal Opportunity
451 7th Street, S.W.
Suite 5100
Washington, D.C. 20410

Dear Ms. Guarraia:

        Thank you for the opportunity to discuss your agency's position on 
multiple chemical sensitivity (MCS or environmental illness). As I related at 
our meeting of January 9, the Department of Housing and Urban Development has 
clearly confused the definitions of chemical sensitivity or hypersensitivity 
and MCS. The two examples cited in Mr. Mansfield's letter are examples of the 
former, not the latter, as suggested by Mr. Mansfield. I have enclosed a copy
of his letter for your reference.

        After consulting experts in the medical field, I would like to offer 
the following definitions:

   Chemical hypersensitivy is a state of ordered reactivity in which the
   body reacts with an exaggerated immune response to a foreign substance
   (some chemical agents, plant products, animal products). Symptoms
   may resemble hay fever, asthma, or contact dermatitis. The hyper-
   sensitivity reaction is repeatable with similar symptoms each time the
   individual is exposed to the same or a chemically similar substance. 
   This medical condition can readily be confirmed by using well-recognized 
   and accepted diagnostic techniques and laboratory studies.


01-00926

















Ms. Leonora L. Guarraia
February 6, 1992
Page 2

   Chemical hypersensitivity should not be confused with symptoms produced 
   by irritants such as sulfur dioxide, nuisance odors such as paint fumes, 
   or unpleasant odors such as sewer gas.

   Multiple chemical sensitivity has been described as an acquired disorder
   characterized by recurrent symptoms, referable to multiple organ 
   systems, occurring in response to demonstrable exposure to many 
   chemically unrelated compounds at doses far below those established 
   in the general population to cause harmful effect.

        The American Medical Association, as recently as December 1991, and 
other medical societies, including the American Association of Allergy and 
Immunology, the American College of Physicians, and the American College of 
Occupational and Environmental Medicine, agree that to date there is
inadequate scientific evidence to establish the existence of MCS as a
disorder. Research is currently being conducted by a number of institutions
and supported in part by federal agencies.

        For your information, I have enclosed BCIA's white paper on 
environmental illness, the American College of Physician's position on the 
syndrome, and a recent clinical study of 26 subjects demonstrating symptoms
that have been attributed to the syndrome. We would greatly appreciate a
correction of the guidance document sent previously to your district offices.
I will call you in a week or so to discuss this request.

                                        Sincerely,
                                        Paul A. Cammer, Ph.D.
                                        President
Enclosures

01-00927



















bc
ia
        BUSINESS COUNCIL ON INDOOR AIR
1225 19th Street, N.W., Suite 300, Washington, D.C. 20036 (202) 775-5887

                                                        May 1991

                                ENVIRONMENTAL ILLNESS

        "Environmental illness" is a term used to refer to a
collection of general symptoms. It is a controversial human
health phenomenon similar to other ill-defined syndromes which
have been described for over 100 years and has attracted
attention from such diverse groups as lawyers, physicians,
insurance companies, scientists, industry, and Congress. It is
known by at least 20 synonyms, including "multiple chemical
sensitivity," "total allergy syndrome," and "twentieth-century
disease." Those who suffer from environmental illness maintain
that the condition is an acquired disorder resulting in an
aversion to a wide variety of synthetic materials, ingested
foods, and drugs resulting in symptoms that may be multiple and
wide ranging.

        The concept of environmental illness is not a new issue. As
early as the 1950's, it was postulated that environmental illness
resulted from the failure of humans to adapt to modern-day
synthetic materials.1-3 According to this theory, the influx of
man-made materials has resulted in a new form of medically
unexplained, specific sensitivity. Once sensitized, the person
generally reacts to increasingly lower concentrations of the
causative agent as well as to other chemicals and foods.1-3 This
"spreading" effect is one area among many where the environmental
illness theory is inconsistent with medically-accepted doctrine
concerning allergic sensitivity to individual substances.

        Historically, the theory that environmental illness is
caused by chemical contact has only weak support. This causation
theory has received some attention in recent years, however,
because of anecdotal reports of the suffering of certain
individuals demonstrating symptoms attributed to this syndrome
(e.g., nausea, headaches, dizziness), there are very few symptoms
that have not been considered to be related to such an etiology.

        While there is a broad variety of claims regarding the
initiation of environmental illness, there are no reliable
statistics estimating its prevalence. Some people cite the
National Academy of Sciences (NAS) as estimating the incidence of
environmental illness in the United States. NAS has stated,
however, that they have never made this statement or published
such a conclusion.4

01-00928


                                     - 2 -

        Numerous professional medical associations have examined
available information regarding environmental illness and the
diagnostic criteria that have been proposed by clinical
ecologists (practitioners who diagnose and treat this
phenomenon). These medical groups have generally found
deficiencies in the scientific evidence for the syndrome as a
distinct clinical entity.5-13 Moreover, in double-blind studies,
the treatment (i.e., provocation- neutralization) of individuals
by clinical ecologists has not been indicated to relieve symptoms
any better than placebo treatment.14-15 Additionally, the
implication of a role for environmental illness in immune system
dysfunction has been criticized on both theoretical and empirical
grounds. Dr. Abba Terr (Division of Immunology, Stanford
University Medical School), whose views on environmental illness
have been supported by the American College of Physicians and the
American Academy of Allergy and Immunology, states the following:

                The pattern of symptomatology is too wide
                ranging, nonspecific, and variable to suggest
                a single pathogenetic mechanism, immunologic,
                or otherwise. The now well-established pathways
                for immunologic mediated forms of hypersensitivity
                each produce specific patterns of tissue
                inflammation and corresponding organ dysfunction,
                whereas no clinical or histopathologic evidence of
                inflammation has been demonstrated in patients with
                [environmental illness].16

        Though the medical profession expresses doubt that
environmental illness is, in fact, a distinct clinical entity, it
is clear that a small but significant number of people display
symptoms from whatever cause that do not conform to our present
understanding of allergic disease.17-21 While chemical exposure
has often been attributed as the cause of the symptoms, other
factors such as biological contaminants, noise, lighting,
interpersonal relationships, stress, work station design, and
psychological factors22,23 have not been ruled out. Whatever the
actual causes of environmental illness, baseline research aimed
at identifying the nature of claims for the etiology of symptoms
is necessary.

Recommendations
        Because of the controversy surrounding environmental illness
it is premature to develop any governmental policy based on the
vague and anecdotal information currently available. Accord-
ingly, the initial focus of environmental illness research should
be to seek clarification of the medical/physiological/psycholo-
gical nature of the syndrome. To this end, a few state
governments are conducting reviews of environmental illness and
NAS has conducted a workshop to discuss environmental
illness-related research needs.
01-00929

                                     - 3 -

        All people deserve quality medical care including correct
diagnosis and appropriate treatment. Our nascent understanding
of environmental illness, however, does not allow us to determine
proper diagnosis or treatment. Therefore, it is of paramount
importance that these issues for environmental illness be
resolved and the significance of environmental exposure, if any,
be established. To address this issue, only research of the
soundest scientific design should be supported, employing
double-blind, placebo-controlled techniques. A research agenda
could include the following:

        (1)     definition of the syndrome to be studied;

        (2)     investigation of the role of specific
                toxicologic (e.g., immunological) mechanisms
                for environmental illness or for the syndrome
                defined;

        (3)     determination of specific, measurable health
                effects, if any, that can be scientifically
                attributed to exposure to specific chemical
                substances and an estimation of the dose
                necessary to produce these symptoms;

        (3a)    determination of specific, measurable health
                effects, if any, that can be scientifically
                attributed to exposure to a variety of unrelated
                chemicals and an estimation of the dose necessary
                to produce these symptoms;

        (4)     determination of the role of biological
                contaminants in contributing to symptoms;

        (5)     determination of the clinical relationship,
                if any, between chemical hypersensitivity
                and environmental illness; and

        (6)     development of an epidemiological study of
                symptoms and clinical findings attributed
                to environmental illness, determining a
                distribution of prevalence by age, sex, race,
                education, occupational history, psychiatric
                status, and geographical region (this would
                include determination of age at onset of
                environmental illness). In addition, the
                natural history of environmental illness
                should be studied and documented.

01-00930



                                     - 4 -
References
1.      Randolph, T.G. (1952). Sensitivity to petroleum including
                its derivatives and antecedents [Abstract]. J Lab Clin
                Med. 40: 931-932.

2.      Randolph, T.G. (1954). Allergic-type reactions to industrial
                solvents and liquid fuels; mosquito abatement fogs and
                mists; motor exhausts; indoor utility gas and oil
                fumes; chemical additives of foods and drugs; and
                synthetic drugs and cosmetics. J Lab Clin Med. 44: 910.

3.      Randolph, T.G. (1955). Depressions caused by home exposure
                to gas and combustion products of gas, oil, and coal.
                J Lab Clin Med. 46: 942.

4.      Omenn, G.S. (1989). Letter to The Amicus Journal; Goldstein,
                B.D. (1989). Letter to The Amicus Journal; Silbergeld,
                E. (1989). Letter to The Amicus Journal.

5.      Golbert, T.M. (1975). A review of controversial diagnostic
                and therapeutic techniques employed in allergy.
                J Allergy Clin Immunol. 56: 170-190.

6.      Grieco, M.N. (1982). Controversial practices in allergy.
                J Amer Med Assoc. 247: 3106-3111.

7.      Van Metre, T.E. (1983). Critique of controversial and
                unproven procedures for diagnosis and therapy of
                allergic diseases. Pediat Clin North Am. 30: 807-817.

8.      Health Care Financing Administration. (1983). Medicare
                program. Exclusion from medicare coverage of certain
                food allergy tests and treatments. Fed. Reg. 48: 162,
                37716-37722.

9.      American Academy of Allergy and Immunology. (1981). Position
                Statements - Controversial Techniques. J Allergy Clin
                Immunol. 67: 333-338.

10.     American Academy of Allergy and Immunology. (1986). Position
                Statements - Clinical Ecology. J Allergy Clin Immunol.
                78: 269-270.

11.     American Academy of Allergy and Immunology. (1986). Position
                statements - Candidiasis hypersensitivity syndrome.
                J Allergy Clin Immunol. 78: 271-273.

12.     California Medical Association Scientific Board Task Force
                on Clinical Ecology. 1986. Clinical Ecology - A
                Critical Appraisal. West J Med. 144: 239-245.

01-00931

                                     - 5 -
13.     American College of Physicians. (1989). Clinical Ecology.
                Annals of Internal Medicine. 111: 2.

14.     Jewett, D.L., Phil, D., Fein, G. and Greenberg, M.H. (1990).
                A Double-Blind Study of Symptom Provocation to
                Determine Food Sensitivity. The New England Journal of
                Medicine 323: 7.

15.     Kailia, E.W. and Collier, R. (1971). Relieving therapy for
                antigen exposure. J Amer Med Assoc. 217: 78.

16.     Terr, A.I. (1987). Clinical Ecology. Journal of Allergy and
                Clinical Immunology. 79(3): 423-426.

17.     Randolph, T.G. (1962). Human Ecology and Susceptibility to
                the Chemical Environment. Charles C Thomas, Publisher.
                Springfield, IL.

18.     Dickey, L.D. (1976). Clinical Ecology. Charles C.
                Thomas, Publisher Springfield, IL.

19.     Bell, I.R. (1982). Clinical Ecology: A New Medical Approach
                to Environmental Illness. Common Knowledge Press.
                Bolinas, CA.

20.     Committee on Environmental Hypersensitivities. (1985).
                Report of the Ad Hoc Committee on Environmental
                Hypersensitivity Disorders. Ministry of Health.
                Toronto, Ontario.

21.     Cullen, M.R. (1987). The Worker with Multiple Chemical
                Hypersensitivities: An Overview. State Art Rev Occup
                Med. 2: 655-661.

22.     Black, D.W., Rathe, A. and Goldstein, R.B. (1990).
                Environmental Illness: A Controlled Study of 26
                Subjects with '20th Century Disease.' J. American
                Medical Association. 264: 24.

23.     Ashford, N.A. and Miller, C.S. (1989). Chemical Sensitivity.
                A Report to the New Jersey State Department of Health.

01-00932










                                June 6, 1991

OFFICE OF THE ASSISTANT SECRETARY
FOR FAIR HOUSING AND EQUAL OPPORTUNITY

MEMORANDUM FOR: All Regional PHEO Directors

FROM: Leonora L. Illegible General Deputy Assistant Secretary
       for Fair Housing and Equal Opportunity, ED

SUBJECT: Technical Guidance Memorandum 91-3:
           Multiple Chemical Sensitivity Disorder

        HUD has recently seen an increase in housing discrimination
complaints from people with Multiple Chemical Sensitivity
Disorder (MCSD), sometimes referred to as "environmental
illness." HUD presently recognizes MCSD as a "handicap" under
the Fair Housing Act. People with this disability are also
considered "individuals with handicaps" under Section 304 of the
Rehabilitation Act of 1973. Accordingly, PHEO investigators
should become familiar with this disability and how those who
have this disability are protected by the law.

        MCSD is a condition, the origin of which is currently
unknown. Adverse symptoms are caused by exposure to various
chemical substances at exposure levels so low that for most
people, they are considered harmless. Symptoms appear after a
person with MCSD comes into contact with the air, water, food,
medication or surface that contains the chemicals to which the
individual is sensitive. The most common substances that are
believed to cause adverse reactions in people with MCSD are
solvents and other volatile compounds, pesticides, formaldehyde,
natural gas, disinfectants, detergents, plastics, tobacco smoke,
and perfumes. The adverse reactions of individuals with MCSD
often include extreme tiredness and an inability to carry out
major life activities such as manual tasks and walking. For
housing providers, acts which are necessary and accepted business
practices, such as cleaning, painting, exterminating the building
or fertilizing the lawn, may be threatening events to people with
MCSD since exposure to the various chemicals involved can cause
severe symptoms.

        As with other handicaps, housing providers are required by
the Fair Housing Act to provide reasonable accommodations to
individuals with MCSD. Housing providers are also required to
comply with all other requirements of the Fair Housing Act
including the obligation to permit people to make, at their own
expense, reasonable modifications to the existing premises, if
the proposed modifications are necessary to afford them the full
enjoyment of the housing premises.

01-00933


INTERNAL:NOT FOR RELEASE)

        Additionally, under Section 504 of the Rehabilitation Act of
1973, housing providers who receive Federal financial assistance
are required to modify their housing policies and practices to
ensure that these policies and practices do not discriminate on
the basis of handicap against qualified individuals with MCSD.
Housing providers who receive Federal financial assistance are
also obligated to carry out all other requirements of Section
504. This includes operating each housing program or activity
receiving Federal financial assistance so that the program or
activity, when viewed in its entirety, is readily accessible to
individuals with handicaps.

        Because people with MCSD suffer adverse reactions as a
result of exposure to a wide variety of substances, reasonable
accommodations for this disability, as with all disabilities,
should be based on the particular circumstances of the tenant or
applicant. To the extent that the elements which trigger adverse
reactions in the individual can be identified, requests for
reasonable accommodations may be sought to enable the individual
to minimize or avoid exposure to these elements.

        Although the reasonableness of a particular accommodation
request will depend on the circumstances of the individual and an
assessment of the feasibility, practicality, and burdens involved
in making the accommodation, it is possible to provide examples
of accommodations which are considered reasonable:

        -- A tenant with MCSD has a sensitivity to chemical
pesticides. He requests that the housing provider
notify him in advance before fumigating the apartment
building and substitute boric acid for the chemicals
normally used to spray his apartment.

        -- An applicant with MCSD has a sensitivity to the
chemicals found in certain types of carpeting. She
inquires about an available apartment located in a
building in which all the apartments have wall-to-wall
carpeting. She requests that the housing provider
inform her as to the type of carpeting used throughout
the building so that she may determine whether the
apartment would suit her needs before renting it.

        If you have any questions about this guidance, please
contact Mary-Jean Moore, Section 504 Branch Chief, Office of HUD
Program Compliance at FTS 458-0015 (TDD).

01-00934






                        U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
                                WASHINGTON, D.C. 20410-2000

OFFICE OF THE ASSISTANT SECRETARY                 September 6, 1991
FOR FAIR HOUSING AND EQUAL OPPORTUNITY

Paul A. Cammer, Ph.D.
President
Business Council On Indoor Air
1225 19th Street, N.W., Suite 300
Washington, D.C. 20036

Dear Dr. Cammer:

        Thank you for your letter of July 16, 1991 regarding the
Department's policy on multiple chemical sensitivity and its
guidance on this issue to regional and field offices.

        As noted in the Department's letter to Senator Lautanberg,
HUD presently recognizes Multiple Chemical Sensitivity Disorder
(MCSD), sometimes referred to as "environmental illness," as a
"handicap" under the Fair Housing Act. People with this
disability are also considered "individuals with handicaps" under
Section 504 of the Rehabilitation Act of 1973.

        Accordingly, the Department has instructed its regional and
field investigators to become familiar with this disability which
is extremely complex and difficult to comprehend. Individuals
with MCSD are protected by the law and the Department has
provided its regional offices with some general guidelines to
ensure compliance with non-discrimination laws and regulations.

        As with other handicaps, housing providers are required by
the Fair Housing Act to provide reasonable accommodations to
individuals with MCSD. Housing providers are also required to
comply with all other requirements of the Fair Housing Act
including the obligation to permit people to make, at their own
expense, reasonable modifications to the existing premises, if
the proposed modifications may be necessary to afford them the
full enjoyment of the housing premises.

        Additionally, under Section 504 of the Rehabilitation Act of
1973, housing providers who receive Federal financial assistance
are required to modify their housing policies and practices to
ensure that these policies and practices do not discriminate on
the basis of handicap against qualified individuals with MCSD.
Housing providers who receive Federal financial assistance are
also obligated to carry out all other requirements of Section
504. This includes operating each housing program or activity
receiving Federal financial assistance so that the program or
activity, when viewed in its entirety, is readily accessible to
individuals with handicaps.

01-00935
                                        2

        Finally, because people with MCSD suffer adverse reactions
as a result of exposure to a wide variety of substances,
reasonable accommodations for this disability, as with all
disabilities, should be based on the particular circumstances of
the tenant or applicant. To the extent that the elements which
trigger adverse reactions in the individual can be identified,
requests for reasonable accommodations may be sought to enable
the individual to minimize or avoid exposure to these elements.

        Although the reasonableness of a particular accommodation
request will depend on the circumstances of the individual and an
assessment of the feasibility, practicality, and burdens involved
in making the accommodation, it is possible to provide examples
of accommodations which are considered reasonable:

        -- A tenant with MCSD has a sensitivity to chemical
pesticides. He requests that the housing provider notify him in
advance before fumigating the apartment building and substitute
boric acid for the chemicals normally used to spray his
apartment.

        -- An applicant with MCSD has a sensitivity to the
chemicals found in certain types of carpeting. She inquires
about an available apartment located in a building in which all
the apartments have wall-to-wall carpeting. She requests that
the housing provider inform her as to the type of carpeting used
throughout the building so that she may determine whether the
apartment would suit her needs before renting it.

        I hope the information provided is helpful.

                                        Very sincerely yours,

                                        Gordon H. Mansfield
                                        Assistant Secretary

01-00936















                U.S. Department of Housing and Urban Development
                        Washington, D.C. 20410-1000


OFFICE OF THE ASSISTANT SECRETARY FOR
LEGISLATION AND CONGRESSIONAL RELATIONS

Honorable Frank R. Lautenberg
United States Senate
Washington, D.C. 20510-3002

Dear Senator Lautenberg:

        Thank you for your letter of October 11, 1990 regarding your
constituent, Mary Lamielle, and her request that the Department
of Housing and Urban Development (HUD) prepare a written policy
acknowledging those people who are chemically sensitive as a
disabled population deserving reasonable accommodation with
regard to exposure to chemicals.

        HUD presently recognizes Multiple Chemical Sensitivity (MCS)
as a disability entitling those with chemical sensitivities to
reasonable accommodation under Section 504 of the Rehabilitation
Act of 1973. People with MCS are also recognized as disabled
under Title VIII of the Fair Housing Amendments Act of 1988.
However, because of the unique nature of MCS and the limitless
variety of chemical sensitivities possible, HUD has not written a
policy that sets forth specific required reasonable accommodation
for this disability. Instead, we have acknowledged chemical
sensitivity as a disability and accommodated those with various
hypersensitivities on a case-by-case basis. As with all
disabilities, housing providers are required to provide
reasonable accommodations to chemically sensitive individuals,
unless those accommodations would cause an undue financial and
administrative burden or would result in a fundamental alteration
in the nature of the program or activity.

        Information about MCS has been disseminated at recent HUD
Section 504 Town Meetings in an effort to make housing providers
more aware of the needs of those with this disability. To better
assure that HUD staff and the public are aware of the need to
treat this condition as a disability, HUD is also planning to
issue formal guidance on this matter to its Regional and Field
Offices.

01-00937
                                                                2







        HUD welcomes any information that the National Center for
Environmental Health Strategies can provide and will keep
Ms. Lamielle informed as new guidance is issued.

        I hope that this information has been helpful.

                                        Very sincerely yours,

                                        Timothy L. Coyle
                                        Assistant Secretary

01-00938