Questions posed to the CDC regarding mixed information of Mold Induced Illnesses

[Guest guest]

Questions posed to the CDC:

In light of the recent hurricanes and the levy breaks in city of New Orleans, the controversial issue of illnesses caused by mold and mold toxin (mycotoxin) exposure has come to the forefront. As the waters have subsided; many homes, schools and offices in the area are experiencing excessive fungal growth. From a variety of sources, many residents returning to the city are being provided a barrage of mixed messaging regarding necessary safety precautions when ridding structures of mold and what symptoms of illness they may expect if proper precautions are not taken.

As an example of the mixed messaging, on Oct 29, 2005, Dr. Redd, of the CDC, issued a public health advisory via many media outlets. The implication of the advisory was that mold and the toxins some molds produce are not an extreme health threat to those who have healthy immune systems. The CDC then published a more comprehensive document concerning ill health effects from mold exposure, CDC Mold/2005 Mold Report. This document, although still somewhat confusing, indicates there can indeed be serious health effects for not just those with weakened immune systems, but for anyone exposed to an excessive amount of mold and mold toxins. Yet, it indicates these illnesses are rare. We are not aware of any surveillance of the prevalence of these illnesses by the CDC. We are confused as to how they are able to determine the rarity or prevalence of these serious mold and mycotoxin induced illnesses.

In addition to conflicting information being provided by the CDC, many state health departments are parroting the confusing CDC advisories. They are then directing people who suspect mold and mycotoxin induced illnesses to seek treatment from occupational, environmental, allergy and mental health physicians. Yet, some of the medical and environmental associations which set policy protocols and train the physicians within these fields, appear to be providing their members messaging that differs from that of the CDC. In particular, the national associations that set protocol regarding the diagnosing and treatment of mold illnesses are The American College of Occupational and Environmental Medicine, (ACOEM) The American College of Allergy, Asthma and Immunology (ACAAI) and the American Industrial Hygiene Association (AIHA).

With the health and lives of so many at stake, attached are some questions for the CDC to address in an effort clear up any misconceptions and to assure the citizens of United States are able to receive proper medical care when made ill by molds and/or mold toxins.

Thank you for your assistance with this matter of grave, national significance.

Sincerely,

Sharon Kramer

Questions for the Centers for Disease Control (CDC) regarding mold and mold toxin induced illnesses, within the general population. For the purpose of these questions the term “general population†shall mean those individuals who, prior to an excessive exposure to mold and the toxins they may produce, were healthy, immunocompetent individuals. Some background information to assist the reader in understanding the reason for the questions:

The CDC has recently published a report entitled “CDC Mold/2005 Mold Reportâ€. Several employees of NIOSH, CDC contributed to the writing of this report. Two of the contributors, Elana Page, PhD; and Trout, PhD, have presented at educational seminars on the subject of mold and mold toxin induced illnesses with members of the private sector, who advise regarding mold and mold toxin induced illnesses.

In May of 2002, Drs. Page and Trout presented at a seminar sponsored by the International Center for Toxicology and Medicine (ICTM) principal of ICTM, Dr. Gots. Also presenting at this seminar was toxicologist, Bruce Kelman, PhD. Dr. Kelman is a co-author of the Evidence Based Statement, Adverse Human Health Effects Associated with Molds in the Indoor Environment, American College of Occupational and Environmental Medicine, (ACOEM Mold Statement, October 2002).

The ACOEM is the pre eminent medical association that educates those physicians who treat patients/injured workers from an occupational or environmental perspective.

The ACOEM Mold Statement authors concluded it is not plausible that people could become ill from mycotoxin exposure within homes, schools or offices based on the author’s mathematical extrapolations from acute, high dose exposure studies in rats.

Yet, the National Institute of Health, Institute of Medicine found in the Damp Indoor Spaces and Health Report, (IOM Report) 2004 that:

“Except for a few studies on cancer, toxicologic studies of mycotoxins are acute or short-term studies that use high exposure concentrations to reveal immediate effects in small populations of animals. Chronic studies that use lower exposure concentrations and approximate human exposure more closely have not been done except for a small number of cancer studies.â€

The ACOEM Mold Statement was translated into a lay version to be shared with industries that are affected by medical understanding of mold and mold toxin induced illnesses. One of the industries, the National Association of Realtors (NAR) shared via their website, this lay translation with their members. The lay translation of the ACOEM Mold Statement says:

Moldy Claims:The Junk Science of “Toxic†Mold

This report was sponsored by the U.S. Chamber of Commerce. NAR is publishing this report with permission of the U.S. Chamber of Commerce. This report reviews the extensive scientific literature on the effects of mold on human health and assesses the current state of the science of mold. The report was researched and written by Hardin, Ph.D, Saxon, M.D., Coreen Robbins, Ph.D, CIH, and Bruce Kelman, Ph.D., DABT. Dr. Hardin, the lead researcher, formerly served as Deputy Director of the National Institute for Occupational Safety and Health (NIOSH), and Assistant Surgeon General in the Public Health Service.

Conclusion statement of Moldy Claims: The Junk Science of “Toxic†Mold

Nevertheless, except for persons with severely impaired immune systems, indoor mold is not a source of fungal infections, and current scientific evidence does not support the idea that human health has been adversely affected by inhaled mold toxins in home, school, or office environments. Thus, the notion that “toxic mold†is an insidious, secret “killer,†as so many media reports and trial lawyers would claim, is “junk science†unsupported by actual scientific study.

Along with the NIOSH employees and the co-author of the ACOEM Mold Statement, at the 2002 seminar was an additional presenter, allergist, Dr. Emil Bardana, Jr. Dr. Bardana is President of the American College of Allergy, Asthma and Immunology. (ACAAI). The ACAAI is the national pre-eminent association that educates its allergist members in the treatment of mold illnesses from an allergic and immunologic aspect.

Dr. Bardana recently published a study regarding mold induced illnesses in the Journals of Allergy and Immunology, the official publication of the ACAAI. Allergist, Dr. Abba Terr, an additional member of the ACAAI, also published a concurrent study to the Bardana findings determining psychological findings.

A recent health advisory, based on these two studies was broadly publicized through the media and was issued as a national health advisory on the website of WebMD. Within this advisory by the ACAAI it states:

"We know that mold can make people sick if they end up in the foods they eat," Oregon Health & Science University professor of medicine Emil J. Bardana Jr., MD, tells WebMD. "But there is little evidence that inhaled environmental mold exposure can cause the serious illnesses that have been attributed to it."

“Since these authors have determined that the patients they describe do not have a mold-related disease but are nevertheless seeking compensation for presumed illness through a legal process that has defined it in those terms, toxic mold disease is truly a diagnosis of litigation,†Terr concludes.

Drs Kelman and Hardin are principals in an environmental risk management company, VeriTox (formerly GlobalTox). They frequently perform assessments of properties containing mold on behalf of insurers and employers. The principals of VeriTox also frequently testify in mold litigation. We are not aware of these two co-authors of the ACOEM Mold Statement ever testifying on behalf of one who has been made ill from mold exposure. Dr. Hardin is also a retired employee of NIOSH.

Dr. Bardana frequently performs independent medical examinations (IME’s) on behalf of employers and insurers. Dr. Bardana also frequently testifies in mold litigation. We are not aware of Dr. Bardana ever testifying on behalf of one who has been made ill from mold exposure.

Dr. Terr is an allergist. We are not aware of Dr. Terr having training as an expert able to make psychological evaluations regarding those who have been exposed to an excessive amount of mold.

In addition, the Congressional Financial Services Committee awarded HUD ten million dollars to address and help educated the public regard the mold issue. Some of this funding was used in a joint venture with the National Association of Realtors to set up an educational website: Stopmold.org. On the cover page of this website, the statement is made “Studies on the health impacts of mold indicate that mold cause allergic reactions and aggravate existing respiratory illnesses such as asthma. To date, there is no evidence that mold causes more serious health problemsâ€.

In light of the above information, the expansive financial impact of the mold issue, potential for conflicts of interests by those who steer the national medical associations’ understanding of mold and mold toxin induced illnesses, and these entities close ties to the CDC; numerous health advocacy groups, physicians and researchers from across the United States are requesting clarification by the CDC as to the current state of understanding of mold induced illnesses - so all may feel confident that the public is being accurately informed and the physicians properly trained.

Questions for clarification by the CDC regarding state of the understanding of mold and mold toxin induced illnesses:

1. Is the CDC of the understanding that it is or is not current accepted scientific protocol

to be able to deduce absence of human illness brought on by mycotoxins, from

mathematical extrapolations of acute, high dose exposure findings in rats?

2. If not, what has the CDC done to inform the occupational and environmental

physicians of this?

3. Is the CDC of the understanding that the notion that “toxic mold†is an insidious,

secret “killer,†as so many media reports and trial lawyers would claim, is

“junk science†unsupported by actual scientific study?

4. If not, what has the CDC done to inform physicians and the public of this

error in statement?

5. Is the CDC of the understanding that there is little evidence that inhaled

environmental mold exposure can cause the serious illnesses that have been attributed

to it.?

6. If not, what has the CDC done to inform the allergists and the public?

7. Is the CDC of the understanding that allergists are qualified to comment and teach

other allergists of psychological, rather than psysiological findings regarding mold and

mold toxin induced illnesses?

8. If not, what has the CDC done to inform the public and physicians of this?

9. Is the CDC of the understanding that "studies of the health impacts of mold, indicate

that mold cause allergic reactions and aggravate existing respiratory illnesses such as

asthma. To date, there is no evidence that mold causes more serious health

problems?"

10. If not, what has the CDC done to inform the physicians and the public of this?

11. Thousand of citizens have anedotally complained of neurological, cognitive and

immune dysfunction after an atypical exposure to mold and mold toxins. No less

than three news articles per week of people complaining of these symptoms from

around the United States have run in local newpapers over the past two years. What

survallience efforts of the general population that are reporting serious mold or mold

toxin induced illnesses has the CDC made to determine the prevelence and validity of

these thousand of complaints within the general population?

12. Within the Mold 2005 document, it states no less than fifteen times, that serious

mold and mold toxin induced illnesses are rare in the general population. If no

survallence efforts have been made of the general population, then on what stastical

data is the CDC basing these statements?

13. It is well documented that complete protective gear, such as HasMat suits and N95

respirators, are required when one is handling clean up of large amount of mold.

What public announcement methods are being used by the CDC to assure citizens

are aware of this?

14. Within the CDC Mold 2005 Report, it acknowledges the limitations of skin prick

tests in determining mold and mold toxin induced illnesses that are beyond the scope

of IgE mediated classic allergy. Many within the general population, who have

tested negative from skin prick methods, have then been told their illnesses could not

be mold induced. What is the CDC doing to inform physicians of the known

limitations of skin prick testing when determining illnesses caused by molds and mold

toxins?

15. A document authored from the CDC in July of 2005, lists the names of several

physicans and researchers from across the United States that are reporting success

in understanding and treating mold and mold toxin induced illnesses that are more

serious that simple allergic reaction. Much of this information has been published in

peer reviewed scientific journals. What is the CDC doing to better understand the

findings and treatment protocols of these physicians and researchers?

16. Through the University of Conneticutt, with funding from the EPA, a guidance for

clinicians was published to teach physicians how to recognize, diagnose and treat

mycoses and mycotoxicoses. Why is this document not found on the website of the

CDC? Why is this physician educational tool not being given to health care

providers?

Sources of information for the sixteen above questions, available upon request:

Evidence Based Statement, ACOEM

ACOEM - Evidence Based Statements

National Association of Realtors, Moldy Claims: The Junk Science of Toxic Mold

Moldy Claims - Conclusion

Stopmold.org. HUD/NAR Website

StopMold.org | Stop the Mold Guys!

Public Health Advisory, Dr. Redd, CDC September 29, 2005http://communitydispatch.com/artman/publish/article_2249.shtmlUpdate on Health Issues Related to Mold, Mildew and Mud in Hurricane

CDC Mold/ 2005 Mold Report

http://www.bt.cdc.gov/disasters/mold/report/

CDC Mold/2005 Mold Report with specific questions –

(rough draft format, pdf attached)

WebMD, Existance of Toxic Mold Syndrome Questioned

Study Questions Reality of 'Toxic Mold' Illness

Atlantic Legal Foundation, ICTM Mold Seminar, 2002

Atlantic Legal Foundation

IOM Damp Indoor Spaces and Health Report, 2004

Nat' Academies Press, Damp Indoor Spaces and Health (2004)

CDC Document from July 2005, names of fungal treating physicians.

(Please contact the CDC for more information of this document)

UConn, Guidance for Clinicians

http://oehc.uchc.edu/clinser/MOLD%20GUIDE.pdf