Submissions: Published response

Allergy and Environmental Sensitivity Support and Research Association Inc. (AESSRA)
30 Nov 2020

What is your organisation’s name? - Organisation name

Allergy and Environmental Sensitivity Support and Research Association Inc. (AESSRA)

What best describes you? - Interest in making a submission

I am an advocate for people with disability or work for a disability organisation

How familiar are you with the Disability (Access to Premises – Building) Standards 2010? - How familiar are you with the Disability (Access to Premises – Building) Standards 2010?

I am aware of the Standards and am somewhat familiar with the details in them

What has been your experience of access to and within public buildings? - Put your answer in the box

People with chemical sensitivities or fragrance sensitivity often can’t access any public buildings without suffering symptoms such as asthma or migraine. They find ways to live without accessing public buildings, eg shopping or studying online. Some are housebound. Our support group even holds our AGMs outdoors in parks because this is more accessible for our members than a public building.

Anne Steinemann, Professor of Civil Engineering, and Chair of Sustainable Cities, at the University of Melbourne and Professor of Engineering, and Chair of Sustainable Infrastructure, at James Cook University, has published a number of studies about fragranced products, chemical sensitivities and related issues.

Her study of multiple chemical sensitivities (MCS) in Australians aged 18-65 found that “across the country, 6.5% report medically diagnosed MCS, 18.9% report chemical sensitivity (being unusually sensitive to everyday chemicals and chemically formulated products), and 19.9% either or both. Among people with MCS, 74.6% also have diagnosed asthma or an asthma-like condition, and 91.5% have fragrance sensitivity, reporting health problems (such as migraine headaches) when exposed to fragranced consumer products (such as air fresheners and cleaning supplies). In addition, among people with MCS, 77.5% are prevented from access to places because of fragranced products, 52.1% lost workdays or a job in the past year due to fragranced product exposure in the workplace, and 55.4% report health effects considered potentially disabling [according to the criterion of the Australian Disability Discrimination Act].” (Steinemann, A., 2018. Prevalence and effects of multiple chemical sensitivities in Australia. Preventive Medicine Reports, 10, pp.191-194. https://www.sciencedirect.com/science/article/pii/S2211335518300457)

In another study of Australians, Professor Steinemann found that “When exposed to air fresheners or deodorizers, 16.4% experience health problems; these include respiratory problems (9.1%), mucosal symptoms (6.2%), skin problems (4.8%), asthma attacks (4.5%), migraine headaches (4.2%), neurological problems (2.2%), among other adverse effects. In addition, in other types of exposure situations, 15.3% reported health problems from being in a room after it was cleaned with scented products, 6.1% from the scent of laundry products from dryer vents, and 19.4% from being near someone wearing a fragranced product. For 17.1% of the population, the severity of the health problems was reported to “result in a total or partial loss of bodily or mental functions,” which is a criterion for determining disability under the Australia Disability Discrimination Act (DDA, 1992).
Fragranced products also hindered access in society. Of the general population, 11.6% are unable or reluctant to use the toilets in a public place, because of the presence of an air freshener, deodorizer, or scented product. Also, 10.3% are unable or reluctant to wash their hands with soap in a public place, because they know or suspect that the soap is fragranced. Further, 15.0% have been prevented from going to some place because they would be exposed to a fragranced product that would make them sick. Interestingly, 16.7% of the population reported that if they enter a business, and smell air fresheners or some fragranced product, they want to leave as quickly as possible. Finally, 7.7% have lost work days or a job (in the past 12 months) due to exposures to fragranced products in the workplace. …
Fragrance-free indoor environments received widespread support. Of the general population, 42.8% would be supportive of a fragrance-free policy in the workplace (compared with 22.2% that would not), 43.2% would prefer that health care facilities and health care professionals be fragrance-free (compared with 25.2% that would not). Also, 57.7% would prefer flying on an airplane without scented air pumped through the passenger cabin (compared with 16.3% with scented air), and 55.6% would prefer staying in a hotel without fragranced air (compared with 22.7% with fragranced air).” (Steinemann, A., 2017. Health and societal effects from exposure to fragranced consumer products. Preventive Medicine Reports, 5, pp.45-47. https://www.sciencedirect.com/science/article/pii/S2211335516301449)

As an example, many of our members have difficulty accessing public toilets because air freshener and other fragranced products trigger asthma, migraines or other symptoms. In recent Australian research “The survey found 21.4% of asthmatics and 7.6% of non-asthmatics are unable or reluctant to use the restrooms in a public place, because of the presence of an air freshener, deodorizer, or scented product (χ2=(1, N=1098)=40.1, p<0.0001). In addition, 20.8% of asthmatics and 6.1% of non-asthmatics are unable or reluctant to wash their hands with soap in a public place if the soap is fragranced (χ2=(1, N=1098)=50.46, p<0.0001).” (Steinemann, A., Wheeler, A. and Larcombe, A., 2018. Fragranced consumer products: effects on asthmatic Australians. Air Quality, Atmosphere & Health, 11(4), pp.365-371. https://link.springer.com/article/10.1007/s11869-018-0560-x).
Fragrances in public toilet are even more of a problem for Australians with multiple chemical sensitivities (MCS). “64.8% are unable or reluctant to use public restrooms that have an air freshener, deodorizer, or scented product; 57.7% are unable or reluctant to wash hands in a public place if the soap is fragranced” (Steinemann, A., 2018. Prevalence and effects of multiple chemical sensitivities in Australia. Preventive Medicine Reports, 10, pp.191-194.
Supplementary material 2. Survey Data. https://www.sciencedirect.com/science/article/pii/S2211335518300457)
Another recent Australian study found that “16.4% [of the general population] reported health problems when exposed to air fresheners or deodorizers, 15.3% from being in a room after it was cleaned with scented products” and “Of the general population, 11.6% are unable or reluctant to use the toilets in a public place, because of the presence of an air freshener, deodorizer, or scented product. Also, 10.3% are unable or reluctant to wash their hands with soap in a public place, because they know or suspect that the soap is fragranced.” (Steinemann, A., 2017. Health and societal effects from exposure to fragranced consumer products. Preventive Medicine Reports, 5, pp.45-47. https://www.sciencedirect.com/science/article/pii/S2211335516301449)

There are a small number of public toilets that don’t use air freshener. These are generally freestanding buildings in parks that are designed with plenty of ventilation.

What do you think the Premises Standards Review should focus on? - Put your answer in the box

The Premises Standards Review needs to focus on making buildings accessible to people with chemical sensitivities or fragrance sensitivity as well as people with other disabilities.

Access to buildings and services: Guidelines and information, Updated April 2008 included this:

“Use of chemicals and materials
A growing number of people report being affected by sensitivity to chemicals used in the building, maintenance and operation of premises. This can mean that premises are effectively inaccessible to people with chemical sensitivity. People who own, lease, operate and manage premises should consider the following issues to eliminate or minimise chemical sensitivity reactions in users:
the selection of building, cleaning and maintenance chemicals and materials (see Note below);
the provision of adequate ventilation and ensuring all fresh air intakes are clear of possible sources of pollution such as exhaust fumes from garages;
minimising use of air fresheners and pesticides;
the provision of early notification of events such as painting, pesticide applications or carpet shampooing by way of signs, memos or e-mail.
For more information on ways to eliminate or minimise chemical and fragrance sensitivity reactions look at http://www.jan.wvu.edu/media/MCS.html and http://www.jan.wvu.edu/media/fragrance.html
Note: There are a number of relevant environmental and occupational health and safety regulations and established standards, however, as is currently the case with other standards referenced in building law, compliance with those standards may not necessarily ensure compliance with the DDA.”
https://www.humanrights.gov.au/sites/default/files/content/disability_rights/buildings/good/Guidelines.doc
(Note: The Job Accommodation Network (JAN) links have been changed to https://askjan.org/disabilities/Multiple-Chemical-Sensitivity.cfm and https://askjan.org/disabilities/Fragrance-Sensitivity.cfm)

There was nothing about chemical sensitivities or fragrance sensitivity in the 2010 standards so there are many people who are badly affected by disability discrimination do not think that Australia’s disability discrimination laws are there to help them. Ironically, they feel that the Australian Human Rights Commission discriminates against them.

A good example of ways to make a building accessible for people with chemical sensitivities and fragrance sensitivity is the Centers for Disease Control and Prevention (CDC) Indoor Environmental Quality Policy (available here: http://www.aessra.org/resources/CDC%20Indoor%20Environmental%20Quality%20Policy.pdf) that they developed for their own buildings. People with chemical sensitivities are specifically mentioned in that policy, but it is not just for their benefit.

As well as the choice the of maintenance, pest control and cleaning products, the choice of building materials, floor coverings and furniture affect indoor air quality. New buildings, extensions and renovations should be required to be designed to have better ventilation, especially in toilets, so that air quality is better and air fresheners are not wanted, and designed for chemical-free pest control.

If you have a problem with access to public buildings do you know what options there are to make a complaint? - Put your answer in the box

Our organisation tells people with chemical sensitivities or fragrance sensitivity about options for making complaints and a few have found it helpful. The reasons that many of them don’t make complaints include:
- They are struggling with chronic pain and other symptoms and cannot cope with anything extra.
- As they cannot work due to their fragrance or chemical sensitivities their financial and housing problems are their priority.
- They risk suffering more symptoms if people don’t fully understand or are uncooperative and they are accidentally or deliberately exposed to chemicals they are sensitive to.
- They have no confidence that the complaint system will work for them.

What has been your experience of complying with the Premises Standards via the National Construction Code? - Put your answer in the box

Not Answered

Where do you see opportunities for improvements in the Premises Standards? - Put your answer in the box

Not Answered

Do you want to include a video, audio, image or written submission? - Upload file 1

Do you want to include a video, audio, image or written submission? - Upload file 2

Response ID

ANON-B55U-HEW5-T

Unique ID

668555915