Date
To:     Office of Technical and Information Services
Architectural and Transportation Barriers Compliance Board
1331 F Street, NW, Suite 1000
Washington, D.C. 20004-1111
Email: docket@access-board.gov. (requires your full name and address)
Re:     36 CFR Parts 1190 and 1191
Americans with Disabilities Act (ADA) 
Accessibility Guidelines for Building and Facilities, Architectural;
Barriers Act (ABA) Accessibility Guidelines, Proposed Rule.
Located on the Board's internet site in HTML and PDF Format
( http://www.access-board.gov/ada-aba/guideprm.htm )

Docket No: 99-1

Dear Director Roffee and Members of the Access Board.

As a person having _______________________________________________________
(MCS disability, other autoimmune disorder, asthma, breathing disorders, cancer, other)
I would like to offer comments prior to the end of your comment period, May 15, 2000. I agree with the position of the Ohio Network for the Chemically Injured (ONFCI) and join them in urging the Architectural and Transportation Barriers Compliance Board to take steps to create minimum guidelines to reduce all unnecessary exposures to toxic chemicals in building materials and to design all buildings to provide access to all persons with disabilities.
 
The architectural Barriers Act of 1968 (ABA) (42U>S>C> 4151 et seg.) requires that facilities designed, built, altered or leased with certain Federal al funds be accessible to persons with disabilities. Thousands of people have been sensitized to chemicals including those with Multiple Chemical Sensitivity (MCS), Gulf War Illness, asthma, those with cancer undergoing chemotherapy and those with other autoimmune disorders. We are asking you to set minimum guideline to include this type of disability in your accessibility standards as required by law. Our exclusion, thus far, is these guidelines has caused us additional health injuries, stress and inability to be active members of society.
 
As a disability covered under the ADA, people with MCS must have their needs addressed under the ACT. The Access Board is the logical starting point to address the problems related to access issues. 
 
We suggest the following additions to the ADAAG that would accommodate the disabilities of MCS and others, including but not limited to, persons with cancer undergoing chemotherapy, asthma and other disorders requiring minimum exposures to toxic chemicals.
 
Below is a brief list of accommodations needed. Inclusion of any of these accommodations would be greatly beneficial
  1. Heating and ventilation systems. Provide better heating and ventilation systems that can be routinely and easily cleaned, provide more fresh air exchange, etc.
  2. Increase ventilation of parking garages which are part of the building structure so that gases cannot enter the bu9ilding. Install warning devices and alarms to monitor gas levels.
  3. Use less toxic building materials (i.e. no particleboard or require off-premises sealing of toxic building materials to prevent outgassing).
  4. Establish timelines for MCS accessibility, design and implementation.
  5. Set a number of MCS accessible rooms per building.
  6. Set a number of MCS accessible elevators (inert and less toxic floor and wall materials, no carpet or wallpaper - use sealed wood, non-toxic tile or suitable floor materials).
  7. All hallway floors used by those with MCS should be accessible (non-toxic or sealed flooring materials).
  8. Lighting fixtures (no florescent in MCS in MCS work areas).
  9. Mold resistant materials to be used in ceilings around AC vents. 
  10. Have at least some windows that can be opened in MCS rooms or on each floor of a building.
  11. Reduction in the use of plastic building materials that outgas. Use substitutes which are known to outgas less for wiring, etc. 
  12. Bathrooms - do not install or permit any type of air freshener or disinfection devices at all in any bathroom or any part of the building.
  13. Utilize ceramic tiles or other inert materials for bathroom floors land walls.
  14. Use of a "protecto zone" or similar structure to create a clean air zone so that those with MCS can have access in theaters, courtrooms, libraries, and numerous other public facilities. See Case Western Reserve School of Engineering unit designed for this purpose. (case Alumni Magazine - December 1999).
  15. Warning signs (indicating cleaning, painting, remodeling etc.) posted at all entrances showing what time these things will occur so that those with MCS will not unknowingly enter a toxic area. 
We are fully aware that the building and chemical industry lobby against these types of changes, as well as lobby against the fact that we are disabled from chemical exposures. Toxicology literature defies their conclusions and support ours. The above items are the types of things that prevent those with MCS and related disabilities from being a part of society.
The cost of health care has risen due to the escalating increases in illness, disease, and disability caused by chemical exposures. It is prudent and economical sense to address these issues while there are still those healthy enough to create the changes so badly needed, not only for those already disabled, but to prevent others from getting further disabled.
By copy of this letter to our federal Congressmen and Senators, we are letting them know about our concern fro the access issues which have not been met and have not been addressed and ask them to work with us for solutions to these problems and to address them with the ACCESS Board.

We hope these suggestions will offer the Access Board some solutions to prevent the exclusion of our disability in your guidelines.

Very Truly yours,

Address             ______________________________________
City, State, Zip   ______________________________________
Senator              ______________________________________