A Red Herring in my Bonnet

[Guest guest]

Tony,

Interesting stuff! As I understand it, we are in agreement...for the most part. There are only two areas I see that our views differ widely:

1. You write that you are of the opinion the scientific concept the ACOEM White Paper was meant to portrayed to the world was, "The concept they do promote is that mycotoxins from mold in the air are not likely to be causing what is seen or what is expected to be observed."

I'm sorry, I have to go with the authors' own words as to what the "scientific concept" the ACOEM mold statement was meant to project to physicians, lay people and the world:

ACOEM author, when interpreting the "scientific concept" of the ACOEM White Paper for the US Chamber of Commerce - concluding sentence:

"They are two different documents, but the scientific concepts are the same."

Q: So you wrote the line, quote, 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? Those were your words?

A: They were either mine or Dr. Hardin's. I don't remember which. We both worked on the transcript. I'm sorry. I meant manuscript.

I see nothing in the ACOEM author's stated intended "scientific concept" of the ACOEM Mold Statement only addressing inhaled mycotoxins, do you? What I see is a concept being promoted by an influential medical association, a commerce organization and a think-tank that is intentionally misleading and meant to limit financial liability for stakeholders of moldy buildings at the expense of the sick.

Email September 8, 2002 From: Borak, Chair of the Scientific Committee, ACOEM To: Dean Grove, Past President, ACOEM CC: Bernacki, ACOEM President 2002; Barry Eisenberg, Executive Director ACOEM; Tim Key, ACOEM President 2003.

"Dean et al: I am having quite a challenge in finding an acceptable path for the proposed position paper on mold. Even though a great deal of work has gone in, it seems difficult to satisfy a sufficient spectrum of the College, or at least those concerned enough to voice their views. I have received several sets of comments that find the current version, much revised, to still be a defense argument. On the other hand, Hardin and his colleagues are not willing to further dilute the paper. The have done a lot, and I am concerned that we will soon have to either endorse or let go. I do not want to go to the BOD and then be rejected. That would be an important violation of . I have assured him that if we do not use it he can freely make whatever other uses he might want to make. If we "officially" reject it, then we turn is efforts into garbage. ...."

2. Past correspondence. Yours in blue italics, mine in red non-italics.

The support provided was poor. But it can be done – I have done it."

I know you can duplicate the calculations. But I also know you would never stand up in a court of law and say a specific child's symptoms of poisoning absolutely, unequivocably "could not be" caused by inhaled mycotoxins because the level at which you see effects in rodents is just too great. Right?

No, but I could easily state that are not probable. As an expert we need only provide a certain level of scientific certainty, 95% is easily accepted, and here it would be correct. The courtroom should not be utilized for weak cases that have poor merit, and on the other side public policy should be designed to minimize the number of cases that can get to this stage.

I am glad to hear you would not stand as witness to say these illnesses "could not be" based solely on these calculations....but I always knew you would never do that. Unfortunately, both of the "toxicologist" authors of the ACOEM mold statement have done this. Which is odd to me, because even the ACOEM statement will only go so far as to say "not plausible". So how do they write "not plausible" and state "could not be"?

I disagree that you can say "not plausible" with 95% certainty based on your calculations of an unattainable threshold level of airborne mycotoxins found within WDB's. I don't think you have enough relevant data to form that conclusion because toxicological studies that simulate conditions found in WDB's that more closely approximate human exposure have not been done. Although they are about to be by the NTP.

Also, is "inhaled" a red herring word when extrapolating out from toxicological study to human exposure of micotoxins found in WDB's? You are only looking at airborne mycotoxins, right? You are not taking into account that in WDB's people are exposed via all routes of exposure simultaneously, right?

I don't think it is current accepted scientific understanding that you can state an unattainable threshold level to cause human illness from WDB mycotoxin exposure with 95% certainty, based solely on extrapolations from a cellular model. For one thing, you don't know the minimum dose from human chronic low dose exposure via all routes of exposure before symptoms occur. So, if you don't know the minimum dose, you also don't know what threshold must be reached before the minimum dose kicks in. I have to go with the IOM on this one:

According to the IOM,

“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€

Extrapolation of risk exposure from animal experiments must always take into account species differences between animals and humans, sensitivities of vulnerable human populations, and gaps in animal data.â€

I think it is another red herring to do math calculations based on airborne mycotoxins and based solely on this, conclude an unattainable threshold level (with 95% certainty) before human illness occurs from mycotoxins present in WDB's.

I like these guys' website:

http://www.ecometrex.com/mycotoxins.htm

"Exposure to indoor fungi and their biochemical products may occur by means of one or more routes or 'pathways': 1) inhalation (breathing of inhaled spores, spore fragments, or volatile compounds), 2) absorption or dermal contact (contact with skin), and 3) ingestion (consuming contaminated materials). Inhalation and dermal contact represent the most probable exposure pathways for occupants under typical indoor conditions."

"Nonetheless, many mycotoxin-related effects may actually involve mechanisms not explained by conventional dose-response models. In other words, the mycotoxins could act as irritants or allergens. The synergistic effects of mycotoxins, VOCs, and fungal glucans also remain unknown and it is conceivable that such complex mixtures could account for effects that are otherwise unsubstantiated by quantified mycotoxin concentrations in sampled spores."

Sharon

Sharon:

Let me Post responses to your 2 previous posts that I emailed you off-line. [i have edited these slightly to go from html to Text so that folks can still more clearly see the differences in responses]

A. REPLY TO – 16179 Re: Bee in My Bonnet

1. I read it, and saw that part.

The Position Paper does NOT promote the concept. People who read it the way they want promote the concept.

So you need to show something more tangible on the promotion idea, as in educational material from ACOEM indicating such or editorials from ACOEM officially.

2. Statement:

As to the physician question you wrote:

"Not a great question, any scientist would "consider their moldy working/living environment as a possible cause of their symptoms indicative of poisoning?" [Note word possible] and then work on determining the source clearly enough to treat the issue."

NO!!! That is not what is happening out here in the real world by any stretch of the imagination. If you watched the Nightline program of Dr. Rea and allergist, Dr. Kahn, Dr. Kahn represents the mainstream physicians of America. When asked why 30,000 people have gone to see Dr. Rea for environmental illnesses, his response was that it is all psychological. And THAT is what is really occurring in the physicians offices of America. THAT is what the physicians are being taught.

Response:

Perhaps they are not good scientists.

I have Dr. Rea’s books. He is not a good source to rely on, regardless of motive.

An interesting side note: The word Doctor comes from the Latin “doctorâ€, a teacher, usually a religious teacher.

Perhaps they should re-examine their roots.

3. Statement:

“And we both know that even on the point of just inhaled mycotoxins, it was garbage to use just those calculations while c-o-n-c-l-u-d-i-n-g the implausibility of human illness because toxicological studies that examine cellular and animal models cannot be used by themselves to determine human health. Right? You yourself called it a "red herring"

Response:

The models are acceptable and reasonable (even under a stricter Daubert [remember this is a white paper], a reasonable methodology is acceptable)

The support provided was poor. But it can be done – I have done it.

The mycotoxin bit is a red herring.

4. Statement:

“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.â€

Response:

The Chamber is NOT the ACOEM.

The authors had the white paper reviewed by others. It is the position statement of the ACOEM and they have not retracted it. And I don’t see a lot of physicians standing up to rebut it.

5. Questions:

a) “are you saying it is incorrect to teach the physicians of America that poisoning is not possible from WDB's exposure?

Are you saying it is incorrect to educate the physicians to ignore moldy working/living environments as a possible cause while attributing these illnesses to somatization and malingering disorders?

Response:

a) Poisoning implies intentionality and usually a synthetic aspect. So if you would let me reword your question:

“are you saying it is incorrect to teach the physicians of America that adverse effects are not possible from WDB's exposure?â€

Answer – It is Incorrect to teach them this.

From mycotoxins themselves inhaled only – NO. (in other words it is correct to teach them this.)

I gotta figure what you’re asking then I’ll reply.

B. REPLY TO 16192 RE: Bee in my bonnet

1. Regarding the Definition and use of Whitepaper

RESPONSE: For For-Profit companies these are used very very very much as marketing tools. For not-for-profit associations (professional in particular) this is not the case – they are intended to guide the more general audience with enough science to show they have policy positions, not necessarily even absolutes [usually they are a necessity to prevent disparities in direction].

2. Regarding:

You wrote, "The Position Paper does NOT promote the concept. People who read it the way they want promote the concept." meaning in regard to if the ACOEM Mold Statement has been used to promote the concept that it is not plausible people exhibit symptoms of poisoning from exposure to all of the microbial toxins (not just inhaled mycotoxins) that are found in water damaged buildings.

RESPONSE:

The concept they do promote is that mycotoxins from mold in the air are not likely to be causing what is seen or what is expected to be observed.

I

3. Regarding:

You also wrote, "The Chamber is NOT the ACOEM".

You, Tony, can interpret the meaning of the ACOEM Mold Statement and I, Sharon, can attempt to interpret the meaning of the ACOEM Mold Statement as what we think it says. But if one wants to know the true meaning of a writing, the authors of the writing would be the ones to answer the question and be the definitive source as to the true intended understanding of their writings.

RESPONSE: I disagree Sharon. A white paper is to speak for itself where it can, and the language here does not express that.

....................................................................... "Tony" Havics, CHMM, CIH, PEpH2, LLC5250 E US 36, Suite 830Avon, IN 46123www.ph2llc.comNeed a new ride? Check out the largest site for U.S. used car listings at AOL Autos.