COMMENTS ON DOCKET # 19482, July 20, 2005
Although the comment period has closed for the OST NPRM proposing revision of 14 CFR Part 382 to update, reorganize and clarify the rule, I have been encouraged by a DOT official to submit late comments.
I speak on behalf of myself and as the Director of the Toxics Information Project (TIP), a non-profit organization based in Providence, RI. In my work, I encounter many people who suffer serious health effects from exposure to common household chemicals, including fragrance, cleaning products and pesticides. I can provide extensive documentation of the problems experienced by those with asthma and other respiratory disorders, chemical sensitivities, and other immune system impairment.
The most common and significant barrier to access is the scented products worn by airline personnel and other passengers. Additional concerns may include diesel fumes from the engine, deodorizers in airplane bathrooms, and pesticides applied in the plane before boarding.
Individuals who react to fragrance, which by some estimates may be as many as 15 or 20 per cent of the population, have a very difficult time attempting to travel by air. The asthmatic is at particular risk, since 72 per cent of people with asthma react to fragrance, and in some cases such an attack may even result in anaphalactic shock, a life-threatening condition.
QUICK AND EASY ACCOMMODATIONS
I have three suggestions re: how to quickly and easily help accommodate this disability that would not be covered by the current rule. Because a person who reacts to fragrance chemicals wouldn't be able to tell if an assigned seat was good for her until her seatmates sat down, she wouldn't be able to specify a seat in advance. However, airlines could take the following actions:
the affected passenger, or in some cases, moving the person into an open seat either in the main cabin or the first class section.
I believe all these could be done with minimal effort and no expense, and would make a real difference to people like myself – the “canaries”. We are truly like the birds the miners used to employ to let them know there were toxic fumes in the mine shaft. Being more vulnerable, we react to unhealthy air of which others may be unaware. It is entirely possible that the airlines might see at least a small decrease in sick days among personnel if the policies I propose were implemented!
I strongly urge you to consider adopting the three “quick and easy” suggestions above as part of the current rule-making process! Many will thank you for making air travel accessible to them.
FYI: Below is a brief log of some of my experiences while trying to visit my grandchildren. All of them live in California, and I am in Rhode Island, so the journey is a real challenge.
NOTE: I can neither eat nor drink while wearing either of my masks.
OTHER POSSIBLE ACCOMMODATIONS
There are a couple of other things that could be done to protect both disabled persons and the general public from toxic chemicals on airplanes, that would require a bit more effort and time to implement. These would include removing deodorizers and/or fragranced soap products from lavatories and replacing them with less toxic alternatives. It would also mean finding other ways to deal with pest control than routine pesticide applications on some flights.
Liberty Goodwin, Director
Toxics Information Project (TIP)
P.O. Box 40441, Providence, RI 02940
Tel. 401-351-9193, E-Mail: email@example.com