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
-
- Heating and ventilation systems. Provide better heating and
ventilation systems that can be routinely and easily cleaned,
provide more fresh air exchange, etc.
-
- 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.
-
- Use less toxic building materials (i.e. no particleboard or
require off-premises sealing of toxic building materials to
prevent outgassing).
-
- Establish timelines for MCS accessibility, design and
implementation.
-
- Set a number of MCS accessible rooms per building.
-
- 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).
-
- All hallway floors used by those with MCS should be accessible
(non-toxic or sealed flooring materials).
-
- Lighting fixtures (no florescent in MCS in MCS work areas).
-
- Mold resistant materials to be used in ceilings around AC
vents.
-
- Have at least some windows that can be opened in MCS rooms or
on each floor of a building.
-
- Reduction in the use of plastic building materials that
outgas. Use substitutes which are known to outgas less for
wiring, etc.
-
- 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.
-
- Utilize ceramic tiles or other inert materials for bathroom
floors land walls.
-
- 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).
-
- 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
______________________________________
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