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.




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:


  1. Prohibit onboard carrier personnel from wearing fragrances and educate them on the reasons for the provision.  Personnel in other work situations, including hospitals and other public places, have been successfully required to follow such a fragrance-free protocol.  Airplane cabins are small spaces with less ventilation than in typical buildings.
  2. Require flight attendants to assist anyone sickened by a nearby passenger’s fragrance to change her seat so that she is not seated next to/near anyone wearing fragrance.  This could be done in at least two ways:  By making an announcement (similar to that when families are trying to find seats together) asking for a volunteer to switch seats with

the affected passenger, or in some cases, moving the person into an open seat either in the main cabin or the first class section.

  1. While it is not really possible to require all the other passengers to be fragrance-free, a courteous request to avoid use of fragranced products before and during air travel could be included by the airlines in their information sent with flight confirmations.


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.


  1. On U.S. Air, a flight attendant reeked of perfume, and refused to switch with another employee in serving our section.  She then proceeded to stand in the aisle talking for about 15 minutes with a passenger right in front of me, leaving me with a splitting headache.


  1. I now fly only on Southwest Airlines, because they do not have assigned seats.  My husband and I pre-board and sit in the front section.  While I wear an “I Can Breathe” mask with a charcoal filter, my mate tries to encourage folks who appear fragrance-free to sit with us.  He also politely asks those who not to take a seat further down in the plane, because of my chemical sensitivities.  On various occasions:


    1. A passenger reeking of perfume changed seats with the person in front of me, making me quite ill.  I asked for help from the flight attendant, who brought in a supposed disability expert.  The latter kept the plane waiting for 20 minutes while she grilled me about whether I would be all right.  When I explained I’d be fine if the perfumed lady or myself were to move, she ignored that and told me if I wasn’t going to be OK she would refuse to allow me to fly.  I finally had to wear my latex paint mask all the way to Kansas City in great discomfort, when the problem passenger debarked.
    2. On another occasion, a flight attendant objected to our “screening” seatmates to see if they would make me sick.  She said we should have asked for help from the cabin personnel to do that.  (Although none has ever been willing to do so)
    3. While flying alone, I was accosted by a flight attendant who also objected to my asking people if they were wearing fragrance, and explaining my sensitivities. This person tried to get me to leave the plane to “discuss it”.  When I refused (fearing I would be stranded in, I think, Phoenix and not get to see my grand-twins) he threatened to call the police to remove me.  He then went and brought back another airline person who, fortunately was more reasonable.  We agreed that all passengers had a right to sit wherever they wished, but that I could politely request that they voluntarily move back if they were wearing something that made me sick. (Just what I was doing in the first place).
    4. On another occasion, a passenger refused my request and insisted on sitting near me – again requiring me to wear a mask for hours until she finally got off. 


NOTE:  I can neither eat nor drink while wearing either of my masks.




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.


Respectfully submitted,


Liberty Goodwin, Director

Toxics Information Project (TIP)

P.O. Box 40441, Providence, RI 02940

Tel. 401-351-9193, E-Mail: