Dear Mr. Quinn, Missouri School Board Members and Missouri Green Cleaning Committee Members,

It has come to my attention that the Missouri Department of Elementary and Secondary Education has been tasked with developing and providing guidelines for green cleaning in schools as a result of state legislature SB 1181.  It is also my understanding that these guidelines must be in place by February 24, 2009.  Interest in this kind of legislation goes well beyond the Missouri borders.  The focus on protecting our nation’s most valuable resource, our children, is a concern and a national trend all across America.

I am happy to see that Missouri is addressing cleaning products in the school setting and coming up with best practice policies.  However, I have some concerns regarding the structure of this committee and issues that I think need to be addressed.  They are as follows:

1.  This committee is over represented by members of the cleaning industry creating an imbalance in the committee and issues of conflict of interest.  These industry members are pitchmen for their products and for the companies they represent and while I appreciate their transparency and understand why they want to promote the products that are sold by the company's they represent, it's for this very reason, why their findings, conclusions and recommendations need to be treated skeptically by the Department of Education, other committee members, the media and consumers.  

2. Guidelines suggested for Missouri that are still being debated, based on Illinois' green cleaning guidelines were presented as the committee’s template.  According to an email from Mark Bishop, from the Healthy Schools Campaign, the Illinois guideline includes oversights regarding the use of fragrances.  The inclusion of fragrances and air fresheners in the Illinois guide and potential Missouri guide, can create barriers for some children, staff, parents and other building visitors with disabilities including but not limited to asthma, chemical intolerance and developmental disabilities (1).  According to a 1986 U.S. House of Representatives Report: "In 1986, the National Academy of Sciences targeted fragrances as one of the six categories of chemicals that should be given high priority for neurotoxicity testing. The other groups include insecticides, heavy metals, solvents, food additives and certain air pollutants. The report states that 95 percent of chemicals used in fragrances are synthetic compounds derived from petroleum. They include benzene derivatives, aldehydes, and many other known toxics and sensitizers, which are capable of causing cancer, birth defects, central nervous system disorders and allergic reactions” (2).

3. There is an under-representation of advocates for disabled students, staff, parents and visitors such as developmental disabilities, asthma, etc.  With more than 17% of the children in the U.S. under age 18 (that's nearly 12 million children) suffering from one of more learning, behavioral or developmental disabilities and another 6.3 million children (roughly 8%) suffering with Asthma these issues are extremely important to Missouri families, the healthcare system and our school systems.  Asthma is the leading cause of hospitalization and school absenteeism in the U.S.  In 2001, 4 million children had asthma attacks. Worldwide, deaths from asthma have reached more than 180,000 annually.  Cleaning supplies including fragrances and air fresheners affect the indoor air quality and contain ingredients that have been linked to these illnesses and to asthma attacks.  These factors make it vital that there is a good understanding how these issues affect our children and their ability to attend school, learn in school, and reach their full potential (3, 4).

4. There is under-representation in this committee make-up of children's health and medical experts who have no vested financial interests.  These voices are important for the same reasons the advocates need to provide input.  It is vital that our children are able to breathe, think clearly, remember what is learned and be free of illness and not at increased risk of the disabilities and health problems associated with poor air quality exposures which are preventable causes of harm (5, 6).

5. There is under-representation of scientists and other professionals who are fragrance and chemical experts who have no financial conflicts of interests.  We need these professionals who understand the chemicals in the products and have no financial interest working with the medical experts to come up with what is best for our children.

6. There is no representation of Missouri School Nurses Association or the National School Nurses Association who are in charge of our children’s health while they are in the school setting. 

7. There is no representation of any minority group in this committee and there was limited representation of women. Minorities and women suffer a disproportionate amount of illnesses related to indoor environmental quality health issues.

8. Issues have been raised that there is not enough transparency in committee activities and communications causing concerns of possible sunshine law violations and possible biased decisions.  Let’s let the sun shine on this committee’s activities, meetings and discussions so all can participate in our children’s health and welfare and so there are no behind the scenes, or outright special interest being able to tilt the voice of reason and inhibit the precautionary approach to such an important topic.

9. The unnecessary time constraints put on this legislative task as a result of procrastination and low priority creates inadequate time for review of current science, inadequate compilation of a balanced and educated committee, very limited time to spread the word and get input from the public, and is not conducive to determining best quality recommendations and the best product being produced.  This is an important topic that deserves appropriate time spent coming up with what is best for the children.

10. There is a need for more generic guidelines in this recommendation with no brand stamping to eliminate the 3rd party certification to keep prices down and so we do not eliminate competition and small business development in Missouri and around the nation.

11. Another reason why we need generic guidelines with no product recommendations is to eliminate the 3rd party certification keeping prices down for school districts and making it financially feasible for all schools at all economic levels to make their schools equally healthy,  accessible and conducive to learning.  This would also eliminate financial conflicts of interest.

12. There are concerns that there was no education completed for committee members regarding children's health issues involved in indoor air quality and cleaning product ingredients to enable educated decisions.  According to the statute, “guidelines and specifications shall be established after a review and evaluation of existing research…” Education is a vital component in making paradigm changes and making informed decisions.

In order to avoid limiting access to individuals with asthma, allergies, chemical intolerance and other health concerns and to keep our nation’s children, who are a vulnerable population by their very nature out of harm’s way, a best practices recommendation for “green” cleaning in schools would best be modeled after the National Institute of Building Sciences and The Architectural and Transportation Barriers Compliance Board (Access Board) Accessibility Guidelines for Indoor Environmental Quality  http://ieq.nibs.org/om/bi_intro.php  Using this indoor environmental quality guideline from the access board for our schools is my recommendation to provide a generic, cost-effective, health oriented, all inclusive, best practices in green cleaning guide for schools.  I would like my letter and this information to be shared among the green cleaning committee members, the Missouri State School Board of Education and treated as public record.

Let’s get our priorities in order – let us truly leave no child behind.

Sincerely,

Name

Address

References

1. NIBS IEQ committee: Indoor Environmental Quality, Report by The Architectural and Transportation Barriers Compliance Board (Access Board), National Institute of Building Sciences, 2006 http://ieq.nibs.org/om/bi_intro.php 
2. Neurotoxins: At Home and the Workplace, Report by the Committee on Science and Technology, U.S. House of Representatives, Sept. 16, 1986, Report 99-827
3. Key Facts About Asthma, American Lung Association, Accessed November 29, 2008 http://www.lungusa.org/atf/cf/%7B7A8D42C2-FCCA-4604-8ADE-7F5D5E762256%7D/key_asthma.pdf
4. In Harm’s Way: Toxic Threats to Child Development, Report by the Greater Boston Physician’s for Social Responsibility http://www.igc.org/psr/
5. Behavioral Measures of  Neurotoxicity, National Research Council, National Academy Press, Washington, D.C. 1990
6. Neurotoxicity: Identifying and Controlling Poisons of the Nervous System, U.S. Office of Technology Assessment Congressional Report, OTA-BA-436, April 1990 http://www.princeton.edu/~ota/ns20/alpha_f.html