Employees with Multiple 

Chemical Sensitivity and 

Environmental Illness 

Accommodation and Compliance Series
Practical Solutions • Workplace Success 

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Preface 

The Job Accommodation Network (JAN) is a service of the Office of Disability 

Employment Policy of the U.S. Department of Labor. JAN makes documents available 

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The information is not intended to be legal or medical advice. If legal or medical advice 

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contact JAN. 

Authored by Tracie DeFreitas Saab, M.S. Updated 03/23/10.
Practical Solutions • Workplace Success 

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JAN’S ACCOMMODATION AND COMPLIANCE SERIES

Introduction 

JAN’s Accommodation and Compliance Series is designed to help employers determine 

effective accommodations and comply with Title I of the Americans with Disabilities Act 

(ADA). Each publication in the series addresses a specific medical condition and 

provides information about the condition, ADA information, accommodation ideas, and 

resources for additional information. 

The Accommodation and Compliance Series is a starting point in the accommodation 

process and may not address every situation. Accommodations should be made on a 

case by case basis, considering each employee’s individual limitations and 

accommodation needs. Employers are encouraged to contact JAN to discuss specific 

situations in more detail. 

For information on assistive technology and other accommodation ideas, visit JAN's 

Searchable Online Accommodation Resource (SOAR) at http://askjan.org/soar. 

Information about Multiple Chemical Sensitivity (MCS)/ 

Environmental Illness (EI) 

What is MCS/EI? 

Defining MCS/EI has been a difficult task for the environmental health community. 

MCS/EI is generally an inability to tolerate an environmental chemical or class of foreign 

chemicals. It develops from exposure to substances in the environment and may result 

in intolerance to even very low level exposure to chemicals. Symptoms can occur in 

more than one organ system in the body, such as the nervous system, the lungs, and 

the vascular system (heart problems). Exposures can come through the air, from food 

and water, or through the skin (What is . . ., 2005). 

What are the symptoms of MCS/EI? 

MCS/EI causes different symptoms in different people. Symptoms may include: 

headaches, dizziness, fatigue, nausea, breathing difficulties, tightening of the throat, 

difficulty concentrating, memory loss, learning disorders, eczema, arthritis-like 

sensations, and muscle pain. A person who experiences limitations due to MCS/EI may 

have any of the above mentioned symptoms when exposed to such irritants as 

fragrances, cleaning agents, smoke, pesticides, molds, office machines, car exhaust, 

paint, new carpeting, solvents, and poor indoor air quality among other irritants (What is 

. . ., 2005). 

 
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MCS/EI and the Americans with Disabilities Act 

Is MCS/EI a disability under the ADA? 

The ADA does not contain a list of medical conditions that constitute disabilities. 

Instead, the ADA has a general definition of disability that each person must meet. 

Therefore, some people with MCS/EI will have a disability under the ADA and some will 

not. 

A person has a disability if he/she has a physical or mental impairment that substantially 

limits one or more major life activities, a record of such an impairment, or is regarded as 

having such an impairment (EEOC, 1992). For more information about how to 

determine whether a person has a disability under the ADA, visit 

http://askjan.org/corner/vol02iss04.htm. 

For additional information regarding whether MCS/EI is a disability, see the following in 

EEOC informal guidance letter: 

http://askjan.org/letters/EEOCLetter_MCS_Disability_July_96.doc 
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Accommodating Employees with MCS/EI 

(Note: People with MCS/EI may develop some of the limitations discussed below, but 

seldom develop all of them. Also, the degree of limitation will vary among individuals. Be 

aware that not all people with MCS/EI will need accommodations to perform their jobs 

and many others may only need a few accommodations. The following is only a sample 

of the possibilities available. Numerous other accommodation solutions may exist.) 

Questions to Consider: 

1. What limitations is the employee with MCS/EI experiencing? 

2. How do these limitations affect the employee and the employee’s job performance? 

3. What specific job tasks are problematic as a result of these limitations? 

4. What accommodations are available to reduce or eliminate these problems? Are all 

possible resources being used to determine possible accommodations? 

5. Has the employee with MCS/EI been consulted regarding possible accommodations? 

6. Once accommodations are in place, would it be useful to meet with the employee 

with MCS/EI to evaluate the effectiveness of the accommodations and to determine 

whether additional accommodations are needed? 

7. Do supervisory personnel and employees need training regarding MCS/EI? 

Accommodation Ideas: 

Ventilation and Indoor Air Quality Issues: 

• Provide an office or workspace that has working windows. 

• Make certain the ventilation system is not distributing pollutants throughout the 

work-site from locations within or outside of the building. 

• Use HEPA filters in the ventilation system if possible and have ducts maintained. 

• Have an air quality test performed by an industrial hygiene professional to assess 

poor air quality, dust, mold or mildew accumulation, VOC concentration, etc. 

• Work with specialists in the industrial hygiene field by contacting resources like 

the American Industrial Hygiene Association for a member referral. 

• Use air purification systems throughout the building or in personal workstations. 

Work with specialists in the air filtration field by contacting resources like The 

National Air Filtration Association for a member referral. 

• Maintain a work environment which is free of pollutants such as fragrances, toxic 

cleaning agents, pesticides, exhaust fumes, tobacco smoke, etc. 

• Provide adequate exhaust systems to remove fumes from copiers and similar 

office machines. 
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Construction, Remodeling, and Cleaning Issues: 

• Provide pre-notification of events such as remodeling, painting, pesticide 

applications, floor waxing, and carpet shampooing by way of signs, memos, email or an employee register. A voluntary registry can be created for people to be 

notified on a regular basis. 

• Allow for alternative work arrangements for those people who may be sensitive to 

the chemical agents used in the above activities such as offering the use of 

another office, work on another floor of the building, work outside, or work from 

home. 

• Use non-toxic building materials, furnishings, and supplies. 

• Use non-toxic carpeting or alternative floor covering such as tile or cotton throw 

rugs. Products can be used to reduce the out-gassing of newly laid carpeting. 

• If industrial products are being used such as solvents, primers, stains, paints, 

lubricants, etc., consider any alternative products that could possibly be used that 

may not illicit an MCS/EI reaction. 

• If possible, have cleaning, maintenance, and remodeling activities performed 

when the building is not occupied to reduce employee exposure to these 

activities. 

• Discontinue the use of toxic pesticides and opt for an alternative pest 

management policy. Contact resources like the National Pesticide 

Telecommunications Network or the National Coalition Against the Misuse of 

Pesticides to find out more about alternative pest management practices. 

• Discontinue the use of synthetic lawn care products. 

Situations and Solutions: 

A clerical employee was having difficulty breathing due to coworker fragrances and new 

carpet fumes. The employee was placed in a more enclosed cubicle with an air 

purification system, coworkers were asked to decrease or eliminate the use of 

fragrances, and time the employee spent in the office was reduced by altering face-toface communication with coworkers to telephone, e-mail, or fax. It was also suggested 

that the carpet be detoxified or removed and replaced with a non-toxic floor covering 

like tile or wood. 

A teacher diagnosed with sick building syndrome was required to attend weekly faculty 

meetings in the school building. She usually taught class from a portable classroom 

outside of the building and could not be in the school building for extended time. JAN 

suggested that she use either a speakerphone or public address (PA) system from her 

classroom to listen in and participate in the meetings, be provided with meeting minutes, 

or attend the meetings and wear a respirator mask if she felt comfortable doing so. 

A graphic arts professional whose company was in the process of remodeling was 

having some difficulty working in the building due to paint fumes and construction 

materials. It was too far into the process to change the products that were being used 

so the company needed some other way to accommodate. The employee was able to 
Practical Solutions • Workplace Success 

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work from home on a temporary basis during the remodeling phase of her portion of the 

building. The employee already had a computer at home so the employer provided all 

of the necessary software, modem, and a new telephone line to be used for business 

purposes only. The company also provided a fax machine so the employee could fax 

materials back and forth between the work-site and her home office. To monitor her 

work performance, the employee was required to respond to e-mails in a given time 

period and to keep a log of all work completed. The employee attended weekly 

meetings by speakerphone. 

An outside laborer was having difficulty doing his job due to the fumes from the diesel 

equipment he was operating. A portion of his time was spent operating heavy 

equipment while the rest of his time was spent as a laborer. He was better able to 

function as a laborer as he was not as exposed to the fumes performing laborer 

functions. JAN suggested he consider the use of a respirator mask to filter out the 

diesel fumes. Alternatively, his job could be restructuring so he only worked as a 

laborer or he could be reassigned to a vacant position that would accommodate the 

need to avoid exposure to diesel fumes. 

Products: 

JAN's Searchable Online Accommodation Resource at http://askjan.org/soar is designed 

to let users explore various accommodation options. Many product vendor lists are 

accessible through this system; however, JAN provides these lists and many more that 

are not available on the Web site upon request. Contact JAN directly to discuss a specific 

accommodation situation, are looking for products, need vendor information, or are 

seeking a referral. 
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Resources 

Job Accommodation Network 

West Virginia University 

PO Box 6080 

Morgantown, WV 26506-6080 

Toll Free: (800)526-7234 

TTY: (877)781-9403 

Fax: (304)293-5407 

jan@askjan.org 

http://askjan.org 

The Job Accommodation Network (JAN) is a free consulting service that provides 

information about job accommodations, the Americans with Disabilities Act (ADA), and 

the employability of people with disabilities. 

Office of Disability Employment Policy 

200 Constitution Avenue, NW, Room S-1303 

Washington, DC 20210 

Toll Free: (866)633-7635 

TTY: (877)889-5627 

Fax: (202)693-7888 

http://www.dol.gov/odep/ 

The Office of Disability Employment Policy (ODEP) is an agency within the U.S. 

Department of Labor. ODEP provides national leadership to increase employment 

opportunities for adults and youth with disabilities while striving to eliminate barriers to 

employment. 

American Industrial Hygiene Association 

2700 Prosperity Ave., Suite 250 

Fairfax, VA 22031 

Direct: (703)849-8888 

Fax: (703)207-3561 

infonet@aiha.org 

http://www.aiha.org 

AIHA promotes, protects, and enhances industrial hygienists and other occupational 

health, safety, and environmental professionals in their efforts to improve the health and 

well- being of workers, the community, and the environment. 
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Anderson Laboratories, Inc. 

Box 323 

West Hartford, VT 05084 

Direct: (802)295-7344 

http://www.andersonlaboratories.com 

A source of information about the health effects of indoor air pollution with toxic 

chemicals and Sick Building Syndrome. Offers printed materials, videotapes, 

consultations, site visits, and laboratory testing services. 

Chemical Injury Information Network 

P.O. Box 301 

White Sulphur Springs, MT 59645 

Direct: (406)547-2255 

Fax: (406)547-2455 

http://ciin.org/ 

The Chemical Injury Information Network (CIIN) focuses primarily on education, credible 

research into Multiple Chemical Sensitivities (MCS), and the empowerment of the 

chemically injured. 

Environmental Health Network 

P.O. Box 1155 

Larkspur, CA 94977-1155 

Direct: (415)541-5075 

http://www.ehnca.org 

EHN was one of the first organizations to support and advocate on behalf of the 

chemically injured. The agency dates back to around 1982. They have a Support and 

Information Line (SAIL), a newsletter, The New Reactor, and a web site with extensive 

resources pertaining to chemical injury, including fragrance sensitivity. 

Fragranced Products Information Network 

fpinva@fpinva.org 

http://www.fpinva.org/ 

Owned, maintained, and financed by Betty Bridges, RN. The Fragrance Products 

Information Network website was developed to help fill the void of information that exists 

regarding scented products. 
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Human Ecology Action League, Inc. 

P.O. Box 29629 

Atlanta, GA 30359-0629 

Direct: (404)248-1898 

Fax: (404)248-0162 

HEALNatnl@aol.com 

http://members.aol.com/HEALNatnl/index.html 

HEAL's purpose is to serve those whose health has been adversely affected by 

environmental exposures, to provide information to those concerned about the health 

effects of chemicals, and to alert the general public about the potential dangers of 

chemicals. HEAL's goals are to encourage healthy lifestyles that minimize potentially 

hazardous environmental exposures, and to establish chapters that implement HEAL's 

purpose at the local level. 

MCS Referral & Resources, Inc. 

10145 Falls Rd 

Lutherville, MD 21093 

Direct: (410)889-6666 

Phone: (410)889-4944 

adonnay@mcsrr.org 

http://www.mcsrr.org/whoweare.html 

MCS Referral & Resources, Inc., is a non-profit (501(c)3) organization engaged in 

professional outreach, patient support, and public advocacy devoted to the diagnosis, 

treatment, accommodation, and prevention of Multiple Chemical Sensitivity disorders. 

National Air Filtration Association 

PO Box 68639 

Virginia Beach, VA 23471 

Direct: (757)313-7400 

Fax: (757)497-1895 

nafa@nafahq.org 

http://www.nafahq.org/ 

Promotes and advances the common interest of those engaged in the air filtration 

industry. 

National Coalition Against the Misuse of Pesticides 

Beyond Pesticides 

701 E. St., SE #200 

Washington, DC 20003 

Direct: (202)543-5450 

Fax: (202)543-4791 

info@beyondpesticides.org 

http://www.beyondpesticides.org/ 
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A national, non-profit membership organization of groups and individuals formed in 

1981 to serve as a national network committed to pesticide safety and the adoption of 

alternative pest management strategies to reduce or eliminate dependencies on toxic 

chemicals. 

National Institute of Environmental Health Sciences 

P.O. Box 12233, MD NH-10 

Research Triangle Park, NC 27709-2233 

Direct: (919)541-3345 

Fax: (919)541-4395 

webcenter@niehs.nih.gov 

http://www.niehs.nih.gov/ 

The National Institute of Environmental Health Sciences (NIEHS) is one of 27 Institutes 

and Centers of the National Institutes of Health (NIH),which is a component of the 

Department of Health and Human Services (DHHS). The mission of the NIEHS is to 

reduce the burden of human illness and disability by understanding how the 

environment influences the development and progression of human disease. 
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References 

Equal Employment Opportunity Commission. (1992). A technical assistance manual on 

the employment provisions (title I) of the Americans with Disabilities Act. 

Retrieved September 5, 2008, from http://askjan.org/links/ADAtam1.html 

What is MCS? MCS referral & resources. Retrieved September 5, 2008, from 

http://www.geocities.com/HotSprings/Spa/4415/index.html 
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This document was developed by the Job Accommodation Network, funded by a 

contract agreement from the U.S. Department of Labor, Office of Disability Employment 

Policy (DOL079RP20426). The opinions expressed herein do not necessarily reflect the 

position or policy of the U.S. Department of Labor. Nor does mention of trade names, 

commercial products, or organizations imply endorsement by the U.S. Department of 

Labor.