In 1995, The Environmental Health Policy Committee, Department of Health and Human Services, formed an Interagency Working Group on Multiple Chemical Sensitivity (MCS). MCS is a health outcome, with a debatable validity, that poses policy and medical challenges to federal agencies and health practitioners. From the interagency collaboration, a draft report entitled "A Report on Multiple Chemical Sensitivity (MCS)" was developed, and considered relevant scientific literature, previous recommendations of various experts and current as well as past federal actions. After assessment by a panel of experts, the report was made available to the public for review and comment.
The purpose of this project was to summarize and categorize the comments received from
individuals and organizations. By reviewing and summarizing the comments received in response to the
MCS report, the extent and nature of this complex problem can be examined. This project report may
serve as a foundation for recommendations on future actions for federal agencies to consider.
An inventory of the 460 public comments was taken, and the comments were marked with the appropriate public inquiry number. This public inquiry number, which was assigned by ATSDR, appears throughout this report. An inventory number was developed for each comment, which not only serves to protect the identity of the individual, but also accounts for numerous comments submitted by the same individual or organization. The index, which is included as Appendix A, links the public inquiry number to the inventory number. Comments are identified by the public inquiry number.
Once the inventory of the comments was developed, the process of sorting, abstracting, and summarizing the comments was completed. For each comment the index identifies the source of the comment, such as a health care professional or an individual reporting that they have MCS or a related condition. Comments received from organizations are identified by name and include support groups for people with MCS, private industry, governmental organizations, or other non-governmental organizations.
Each comment was read and a short abstract that summarized the content of the comment was prepared. These abstracts include a brief summary and indicate the tone and substance of the comment. These comments appear in Appendix B of this report. The comment medium (written, video tape, e-mail); the overall nature and degree of support provided by the comment; and inclusion of new references (including peer reviewed literature and other MCS publications and literature) are provided in Appendix A. New references cited in the comments appear in Appendix C. The citations appear as cited in the comment. In some instances incomplete citations were provided. In reviewing the comments, it was determined that a large number of letters came from a similar source, as the content and frequently the format were identical. These responses have been defined as form letters, and appear in their entirety in Appendix D. The form letters appearing in Appendix D are identical to those received, and any grammatical or spelling errors were not corrected. In total, 144 form letters were received including 130 from individuals, 11 from individuals with MCS, and 3 from organizations.
Charts and graphs depicting the nature of comments that were received are included in Appendix E. Categories include: source of comments (Exhibit E-1a and 1b), comment medium (Exhibit E-2a and 2b), comments citing additional references (Exhibit E-3a and 3b), overall nature and degree of support provided by comments (Exhibit E-4a and 4b), additional references cited most frequently (Exhibit E-5a and 5b), and degree of support stratified by source (Exhibit E-6a through 6i).
Approximately 87% (n=402) of respondents chose to send a written comment, whereas only 13% (n=57) choose to use email. This is noteworthy, as numerous citizens complained of the reactions they were having to paper products as they were responding. The solitary video entry represents less than 1% (n=1) of the comments received.
The breakdown of respondents was as follows: 4% (n=19) of the respondents were health care professionals, 37% (n=174) were individuals who identified themselves as having MCS, 11% (n=47) came from organizations, and 48% (n=220) came from individuals who did not identify themselves as having MCS.
Comments with attached references not in the initial report made up 40% (n=183) of respondents. Not only was more recent literature called for, but less biased literature was also requested. These references are attached, and the accompanying chart (Exhibit E-5a and 5b) illustrates the references most frequently cited. The work of Landrigan was cited most frequently. The number of times his work was cited may be skewed, as it was referenced in one of the form letters.
When including form letters, approximately 70% (n=282) of the responses were not supportive of the report and recommended substantive changes, or that no final report be produced (Exhibit E-4a). The other 30% (n=110) included those who were supportive of the report as written or with editorial changes (Exhibit E-4a). After excluding the form letters, the breakdown was more evenly divided with 55% (n=138) not supportive of the report, and 45% (n=110) supportive of the report (Exhibit E-4b). Comments with no opinion on the report as well as requests for copies of the report were not included. The degree of support varied among groups submitting comments. Government agencies were the most supportive in which 4/4 (100%) comments expressed some degree of support (Exhibit E-6i), and individuals, as a category, were the least supportive because 183/208 (88%) comments expressed a lack of support (Exhibit E-6b).
In response to the Interagency draft report on MCS, 460 comments were received. Comments were received from health care professionals, individuals, individuals with MCS, and organizations. Government agencies were the most supportive and individuals were the least supportive. Many of the comments citing limitations of the report can be generalized as follows: Frank Mitchell's involvement in the writing of the report is a conflict of interest, and ultimately biases the report; the report should include information from other government agencies as well as findings of MCS doctors who study/treat those with MCS; the bibliography is incomplete and more literature needs to be reviewed and included in the report; the report should recommend avoidance measures; and the report should be used as a tool for health care professionals, government agencies, employers, and the general public, and as such, it should be free of any and all biases.
Public comments citing the strengths of the report can be generalized as follows: the report is a good start to recognizing MCS, the report is a comprehensive review of the issues encompassing MCS, and the document is a useful tool for those who deal with MCS.