Disability

Susan Molloy’s Presentation to Access Board 5/23/18

Susan Molloy’s Presentation to U.S. Access Board at Phoenix Meeting on 5/23/18

U.S. Access Board

1331 “F” Street NW

Washington, DC 20004

Dear President Robertson, Board Members, and Executive Director Mr. Capozzi:

First of all, we are honored by your visit to ABILITY360, our Phoenix Disability Empowerment Center. Thank you, and ABILITY360 Executive Director Phil Pangrazzio, for all your efforts organizing this meeting and for hearing our presentations. Please extend our appreciation to your staff members as well for their hard work.

We trust that you are as encouraged as we, by which I mean people facing environmental barriers to public spaces and facilities, by the Indoor Environmental Quality (“IEQ”) Report of 2005. It was published by the National Institute of Building Sciences, sponsored by the U.S. Access Board, and coordinated by the Access Board’s then Chief Counsel Jim Raggio.

Through this project, we developed concepts and language through which to make the Access Board’s work more comprehensive.

While implementation of the measures we suggest in that document, and in subsequent communications, may not all be immediately achievable, it is our responsibility to see that inadvertent barriers to our access do not go unnoticed and that we assist the Board in drawing up applicable specifications and policies in accordance with the IEQ Final Report.

We are at your service to make this happen.

Toward that end, I endorse the presentations of Mary Lamielle, Director of the National Center for Environmental Strategies, of Ann McCampbell, M.D., from whom you have just heard, from Libby Kelley regarding electrical hypersensitivities and related issues, and from our other colleagues who have participated in preparation for this meeting.

Now, I would like to familiarize you with a few bare-bones features that can enormously and immediately improve our access to public places, with little or no expense, while more extensive measures are developed for future implementation.

SHORTLIST of Free, Readily Achievable Structural and Design Considerations

Windows that open (consider air-to-air heat exchanger technology)

Daylight, skylights, and the option of incandescent lightbulbs (no fluorescents or LEDS) in at least some specified areas of the facility

Landscaping using plants, trees, ground covers that require no chemical maintenance, and no extensive watering (to minimize mold growth)

Non-chemical IPM inside facility, paths of travel, and outdoors (sidewalks, parking area, bus stop)

No Fragrance Emission Devices (“FEDS”) in at least designated restrooms, and no fragrance distribution systems in Heating, Ventilation, Air Conditioning (“HVAC”) systems

No smart meters for electricity, gas, or water installed in public areas of a facility unless thoroughly and effectively shielded

Separate electrical wiring and/or fiber optics, and kill switches, for at least some areas of the facility so that non-essential computers, printers, fluorescents, others can be shut down without impacting other areas of the facility

No carpet in designated areas

Maintain existing landline phones, and re-install the old ones

Independent variable fresh air ventilation system (aka “fan”), for at least certain areas of the facility, that can be operated by the room occupant without assistance

Signage on and around the facility, in pertinent formats, indicating where accessible (for our purposes) sidewalks, ramps, doors, restrooms, phones, conference rooms, parking are located, along with a posted, readily available schedule of recent maintenance and materials

Signage, in pertinent formats, to designate areas where wi-fi is present, to prevent inadvertent exposure to the degree possible

Designation of areas for re-charging wheelchair batteries, cell phones, computers, vehicles, others using wired electrical outlets

Essential: buzzer or intercom outside the facility to summon building occupants such as the clerk, doctor, child, police, social services employee, grocer, shopkeeper

Study the “Cleaner Air Room” concept and language as per the Indoor Environmental Quality (“IEQ”) Report, pages 47-55, 2005, which is posted on the Access Board’s website (www.access-board.gov/research/completed-research/indoor-environmental-quality)

 

Susan Molloy, M.A.

Hansa Trail, Snowflake, AZ 85937

928.536.4625

molloy@frontiernet.net

My Presentation to Federal Access Board 5/23/18

On May 23, 2018, the federal Access Board held a town hall meeting in Phoenix to hear from members of the public about their access needs.  I was honored to be on a panel, along with Susan Molloy, to make a presentation on the access needs of people with multiple chemical sensitivities (MCS) and electromagnetic hypersensitivities (EHS).

Click here to listen to my presentation (7.5 mins).

Susan Molloy and I, as well as several other people with MCS and/or EHS who made public comments, stressed the profound lack of access that people with these disabilities have to housing, health care, employment, and almost the entire built environment.  We urged the Board to take action to increase this access.

For specific next steps, Susan and I endorsed the National Center for Environmental Health Strategies (NCEHS) recommendations for action shown below:

NCEHS RECOMMENDATIONS FOR ACTION
US Access Board, January 8, 2018
 
Unfinished business from the IEQ (Indoor Environmental Quality) Project
(www.access-board.gov/research/completed-research/indoor-environmental-quality):
 
Work with our community to develop a plan to address IEQ and the disability access needs of people with chemical and electrical sensitivities or intolerances.
 
Fulfill the promises of the ADA Accessibility Guidelines for Recreational Activities, September 3, 2002:
 
Develop an action plan that can be used to reduce the level of chemicals and electromagnetic fields in the built environment;
 
Develop technical assistance materials on best practices to accommodate individuals with chemical and electrical sensitivities or intolerances;
      
Address recommendations in the IEQ Report including the need for research on cleaning products and practices that are effective and protective of occupant health.
 
New Initiatives:
 
Create a partnership or working group with the National Council on Disability (NCD) and other agencies as appropriate to address our issues.
 
Appoint a liaison from our community to work with the partnership or working group.
 
Appoint at least one staff member and one board member as a contact on these issues.
 
Support the appointment of an individual with knowledge of these issues to the U.S. Access Board and/or the National Council on Disability (NCD).
 
Facilitate efforts to educate members of the U.S. Access Board and staff, the NCD, and other agencies and organizations, as the opportunity presents.
 
Invite knowledgeable experts and advocates to work with the U.S. Access Board and the National Council on Disability to advance these issues.
 
Convene a meeting with the experts to formalize a plan of action to address the proposed initiatives. This plan should in part include joint hearings or stakeholder meetings sponsored by the U.S. Access Board, the NCD, and other agencies as appropriate, to get input from the community. Invite those with environmental sensitivities or intolerances to “SPEAK for themselves” about their health, access, and disability needs. 
 
 
National Center for Environmental Health Strategies, Inc. (NCEHS), Mary Lamielle, Executive Director, 1100 Rural Avenue, Voorhees, New Jersey 08043 (856)429-5358; (856)816-8820
 
 
 

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