Request For Transparency In Government Funded Pediatrician Education Of Illness Caused by Water Damaged Buidlings

Thomas R. Frieden, M.D., M.P.H.
Director, Centers for Disease Control and Prevention
Administrator, Agency for Toxic Substances and Disease Registry
(ATSDR)
Fax: 404-639-7111

Henry Falk, M.D., M.P.H.
Acting Director, CDC National Center for Environmental Health
Agency for Toxic Substances and Disease Registry
(ATSDR)
Fax: 770-488-0702

Lewis S. Nelson, MD
President, American College of Medical Toxicology
(ACMT)
New York University School of Medicine
New York, NY
Fax: 212-447-8223

Ken Rosenman, MD
President, Association of Occupational & Environmental Clinics
(AOEC)
Michigan State University
Department of Medicine
East Lansing, Michigan 48824-1316
FAX 517-432-3606


Dear Dr. Frieden, Dr. Falk, Dr. Nelson and Dr.Rosenman,

It has recently come to our attention that the Fiscal Year 2011 Congressional Justification for the ATSDR budget of $76,000,000.00 includes funding for a collaborate effort with private sector medical associations to educate private sector pediatricians of the dangers of toxic substances. One of the areas being funded is to establish policies in medical teaching facilities located throughout the US to educate America's pediatricians who often examine children exposed to the contaminants and microbial toxins that are found in water damaged buildings (WDB).

Specifically the ATSDR FY 2011 Justification Budget states on page 23:

In collaboration with EPA, ATSDR will continue to support a six-year (2009-2015) cooperative agreement for 11 regional Pediatric Environmental Health Specialty Units (PEHSUs) and one satellite PEHSU in Ohio. The PEHSUs and partners at the American College of Medical Toxicology [ACMT] work to provide education, health consultation, and risk assessment to health care providers and the public on a range of environmental topics including toxic mold in homes, mercury in schools, and the health effects associated with imported drywall from China [http://www.cdc.gov/fmo/topic/Budget\%20Information/appropriations_budget_form_pdf/FY2011_ATSDR_CJ_Final.pdf Page 23]

In June of 2006, ATSDR's private sector partner, ACMT, issued their Position Statement on illnesses caused by exposure to WDB. Titled Institute of Medicine Report on Damp Indoor Spaces and Health the ACMT Position Statement may be read online at: [http://acmt.net/cgi/page.cgi?aid=12&_id=52&zine=show]

Within the ACMT Position Statement it is determined, While the allergic effects of fungi are well-summarized in the IOM report, there are still a number of misperceptions relating to mycotoxins or other chemicals produced by certain species of fungi, and their role in adverse health effects from exposures in water-damaged buildings. Although several epidemiological studies of building-related illness have implicated mycotoxins as a cause of health effects in water-damaged environments, their interpretation is complicated by limitations in their study design, exposure and dose assessment methods, and confounding effects. In fact, these issues have cast doubt on the causative role of inhaled mycotoxins for any toxic health effects in the indoor residential environment... With respect to mycotoxins in indoor air, exposure modeling studies have concluded that even in moldy environments, the maximum inhalation dose of mycotoxins is generally orders of magnitude lower than demonstrated thresholds for adverse health effects.(3,7,8)

References 3, 7 and 8 in support of the ACMT Position Statement inferring modeling theories scientifically conclude that mold toxins in WDB could play little to no role in occupant and worker ill health, are respectively:

Reference 3) Kelman BJ, Hardin BD, Saxon AJ American College of Occupational and Environmental Medicine. Evidence Based Statement: Adverse Human Health Effects Associated with Molds in the Indoor Environment. 2002. [http://www.acoem.org/guidelines/article.asp?ID=52]

The Position Statement of ACOEM upon which the ACMT Position Statement relies heavily, was the subject of a front page January 2007 Wall Street Journal (WSJ) expose. The WSJ article Court of Opinion, Amid Suits Over Mold Experts Wear Two Hats, Authors of Science Paper Often Cited by Defense Also Help in Litigation details how position papers carry much weight in physician perception, claims handling practices and when influencing the courts. They are sometimes biased in their conclusions for this purpose. The WSJ article may be read online at: [http://www.drcraner.com/images/suits_over_mold_WSJ.pdf]

Reference (7) "Kelman BJ, Robbins CA, Swenson LJ, Hardin BD. Risk from inhaled mycotoxins in indoor office and residential environments. Int J Toxicol 2004 January;23(1):3-10."

This paper, authored by the authors of the ACOEM Mold Position Statement, was disallowed in a legal proceeding in California in April of 2006 via a Kelly Frye ruling. The judge stated "Im hearing essentially this jump from a literature review to a postulated model to a no harm result." He found it to be not medical community accepted science to go from a modeling theory to professing proof of lack of causation of human illness from exposure to mold toxins in WDB. This ruling was detailed by Harris Martin Publishing in May 2006. The article may be read online in its entirety by subscription. Excerpts may be read on line at: [http://freepdfhosting.com/0260f26d42.pdf]


Reference (8) Islam Z, Harkema JR, Pestka JJ. Satratoxin G from the black mold Stachybotrys chartarum evokes olfactory sensory neuron loss and inflammation in the murine nose and brain. Environmental Health Perspectives.

This research paper by respected mold scientists concludes that research suggests neurotoxicity and inflammation of the nose and brain are potential adverse health effects of exposure to mold toxins in WDB, and clearly states that dose response before humans become ill from mold toxins in WDBs has not yet been established by modeling theories or any other means. This paper's conclusions appear to conflict with the above statement it is cited to support in the ACMT Position Statement. This may be read online at: [http://ehp03.niehs.nih.gov/article/info\%3Adoi\%2F10.1289\%2Fehp.8854]

The authors of the ACMT Position Statement of illness from WDB are Dr. Daniel Sudakin and Dr. Thomas Kurt. Both of these gentlemen generate income when serving as expert defense witnesses on behalf of insurers and employers and while aiding them to deny potential liability for causation of illness.

This in turn may aid insurers to cost shift potential financial responsibility of WDB injured workers and occupants off of themselves and onto taxpayers via state and federal social disability programs. This is because when those injured by WDB can no longer work yet are unable to receive insurer benefits, they and their families must turn to government assistance for survival.

We are certain that the directors of ATSDR; ACMT; and the Association of Occupational and Environmental Clinics, which oversees the funding for the PEHSU's; can understand our interest as citizens, taxpayers, physicians, scientists and parents; of ATSDR using taxpayer dollars in a three way partnership of ACMT, ATSDR and AOEC to educate Americas pediatricians as to the illnesses caused by WDB's.

We are certain the directors can understand our concerns when some of the policy writers involved in educating America's pediatricians of the causes, or lack there of, also generate income aiding insurers to deny WDB's can cause serious illness.

As such, we are requesting that in the name of integrity in policy of physician education and transparency for the public good, that ATSDR, ACMT and AOEC place on their websites for public view and public comment exactly what the pediatricians of America are being taught of WDB induced illnesses through the use of federal funds in the collaboration of EPA, DHHS,CDC, ATSDR, ACMT, AOEC and PEHSU.

Thank you for your attention to this matter that impacts the health and safety of our nation's children and impacts all US citizens and taxpayers.