1	Carbon Monoxide Conundra in Federal Policy & Regulation (Lessons in Misapplied Toxicology) Presented by Albert Donnay, MHS University of Maryland Dept of Epidemiology & Preventive Medicine Toxicology Seminar 14 April 2005
2	CARBON MONOXIDE “paradoxical or difficult problems”
3	U.S. Federal Agencies with CO-Related Conundra ATSDR CDC CPSC DOD DOE DOI’s NPS DOT’s NHTSA
4	Carbon Monoxide Realities, Regulations & Recommendations 0 to 1 ppm =Normal CO level in fresh air and exhaled breath of healthy non-smokers 2 to 3 ppm =Avg. outdoor ambient CO level associated with significant increases in ER visits and hospitalizations for asthma and cardio-vascular disease 5.5 ppm =Avg. outdoor ambient CO level in third trimester of pregnancy associated with significant increase in low birth weight babies. 5 to15 ppm = CO level in exhaled breath associated with many chronic diseases 9 ppm = Max 8-hour avg. outdoor ambient CO level allowed by EPA 10 to 30 ppm = CO level in exhaled breath of smokers more than one hour after smoking 30 ppm = Min. CO level allowed to be displayed in home CO detectors by CPSC 35 ppm = Max 1-hour avg. outdoor ambient CO level allowed by EPA, also Max 8-hour avg workplace ambient CO level recommended by NIOSH 50 ppm = Max 8-hour avg workplace ambient CO level allowed by OSHA (highest on earth) 70 ppm = Min. CO level for home CO detector alarm, but only if exceeded for 1 to 4 hours 100 to over 1000 ppm = CO level exhaled by smokers while smoking 200 ppm = CO level at which NIOSH recommends immediate evacuation of any workplace 400 ppm = Max CO level for home CO alarm, but only if exceeded for 4 to 15 minutes 800 ppm = CO level allowed from gas ovens & range tops (combined) by ANSI’s 1925 std 1200 ppm = CO level NIOSH considers “Immediately Dangerous to Life and Health” 3000 ppm (0.3%) = CO inhaled in DLCO test as part of standard lung function testing 5000 to 15,000 ppm = CO level in gas engine exhaust without working catalytic converter Pure CO (100 %) = single inhalation is lethal; used by veterinarians to euthanize animals
5	CO Conundrum of Agency for Toxic Substances and Disease Registry GIVEN that CO is the leading cause of unintentional toxic deaths and poisonings and the most ubiquitous air pollutant in USA … WHY has ATSDR not published a detailed Toxicological Profile on CO or even a “ToxFAQ” sheet on CO as it has for over 250 other toxic chemicals to which most people are less frequently and less significantly exposed?
6	CO Conundrum of Centers for Disease Control & Prevention GIVEN that CDC’s mission is “to insure that critical health information gets out to the people who need it most ... to protect public health and safety” ... WHY have no CDC Centers ever funded or published any research on CO’s role as an endogenously produced neurotransmitter (as only obscure US NIDCD has) or on the diagnosis or treatment of CO poisoning ?
7	CO Conundrum of Consumer Product Safety Commission GIVEN that CPSC’s mission is “Saving Lives and Keeping Families Safe”... WHY do CPSC statistics never include CO deaths from vehicles (only appliances) and why did it force UL to change its CO alarm standard in 1998 to prohibit home alarms below 70ppm and even any display of CO levels below 30ppm, when EPA’s limit for outdoor exposure is only 9ppm ?
8	CO Conundrum of Department of Defense GIVEN that DOD recognizes hazards of CO indoors, requiring CO alarms in all Navy, Air Force and Army base housing worldwide ... WHY has DOD not studied the effects of exposure to CO in the Gulf War from firing and exploding munitions, engine exhaust, and tent heaters, esp. since CO poisoning is known to cause all the “undiagnosed” symptoms of Gulf War Syndrome?
9	CO Conundrum of Department of Energy GIVEN that DOE funds weatherization programs in every state that reduce air leaks in low-income housing and upgrade gas appliances ... WHY doesn’t DOE require any standardized testing of appliances to find and correct any CO sources that may be made worse by weatherization ?
10	CO Conundrum of Interior Department’s National Park Service GIVEN that NPS recognizes the hazards of CO indoors, requiring CO alarms in all NPS staff housing & recommending them in all houseboats used in national parks... WHY doesn’t NPS recommend CO alarms in cars, motor homes and campers since these CO sources also kill people in national parks ?
11	CO Conundrum of Transportation Department’s National Highway Traffic Safety Administration GIVEN that NHTSA has known since 1991 that both suicides and unintentional deaths from CO could be prevented at cost of less than $12 per vehicle ... WHY has NHTSA done nothing about this since 1991 as over 15,000 more people have died? Why has it not responded to a petition filed by Donnay and others in 2001 asking that all vehicles be required to have a CO detector with an engine cut-off switch ?
12	CO Conundrum of Environmental Protection Agency GIVEN that EPA concluded a 10-year review of its Air Quality Criteria for CO in 2000, including a review of recent CO literature showing many adverse affects at levels below the current outdoor limit of 9ppm, especially among asthmatics... WHY did EPA not propose lowering either its 8 hour average limit of 9ppm or its 1 hour average limit of 35ppm? Why does EPA still not post or publish any info about the role of CO in asthma ?
13	CO Conundrum of Federal Aviation Administration GIVEN that FAA requires passenger planes to be equipped with smoke detectors ... Why doesn’t FAA require or even allow the installation of real CO detectors with digital displays or audible alarms on any planes? (Since 1972, it has allowed only “CO Spots” that change color when exposed.)
14	CO Conundrum of Food and Drug Administration GIVEN that FDA’s mission is to regulate all medical drugs and devices used to diagnose, treat or prevent disease ... WHY does FDA regulate oxygen and nitric oxide gases but not CO, despite the widespread use of CO by respiratory therapists in DLCO lung function testing at 3000 ppm? 3000ppm is more than twice the 1200ppm that NIOSH deems “Immediately Dangerous to Life & Health” and 15 times the level at which NIOSH recommends the immediate evacuation of any workplace!
15	CO Conundrum of Housing and Urban Development GIVEN that HUD requires all the homes it finances to have smoke detectors to protect against a deadly hazard that can be seen, smelled and tasted ... WHY does HUD not require CO detectors for a deadly hazard that is invisible, odorless and tasteless ?
16	CO Conundrum of the NIH’s National Institute of Environmental Health Sciences GIVEN that Environmental Health Perspectives, the journal of NIEHS, has published many studies showing CO is more significantly associated with asthma than any other pollutant... WHY has NIEHS not required any of the many asthma researchers it funds to study or even control for CO exposures ?
17	CO Conundrum of the NIH’s National Institute of Occupational Safety and Health GIVEN that NIOSH recognizes the hazard posed by CO on houseboats, which it investigated at the request of DOI’s NPS in 2000, and given that it now recommends CO detectors in all motor boats ... WHY has NIOSH refused to recommend CO detectors in motor vehicles or even to investigate the issue when CO in vehicles causes 100 times more deaths per year ?
18	CO Conundrum of Occupational Health and Safety Administration GIVEN that OSHA tried to lower its occupational limits for CO from 50ppm avg over 8 hours to 35ppm (NIOSH’s recommended limit) in 1988 but was stopped from doing so by the US Circuit Court of Appeals, which remanded the rule for reconsideration... WHY has OSHA still not reconsidered it under Presidents Bush, Clinton or Bush Jr. ?
19	CO Conundrum of Social Security Administration GIVEN that supplemental oxygen is widely recognized in medicine as the only effective treatment for CO poisoning... WHY do SSA’s Medicare and Medicaid guidelines not permit the prescription of supplemental oxygen for chronic CO poisoning (only allowed for people with low arterial PO2, not high venous PO2) ?
20	Albert Donnay’s Conundrum GIVEN that so many federal agencies have so many inadequate CO policies & regulations based on such limited awareness of CO literature WHAT changes should Donnay try to achieve? Change how motor vehicles are designed Change how ovens and ranges are designed Change how home garages are designed Change how home CO detectors are designed Change awareness of endogenous CO Change how CO-related disorders are screened, diagnosed and treated
21	ACOEM’s AOHC, May 3 2005, Washington DC Session 2301-Creative Presentations for OEM Physicians Historic Grand Rounds: The Illness & Death of Edgar Allan Poe Edgar Allan Poe, the creator of the detective story, left the greatest mystery of his life unsolved —the cause of his recurring illness and early death at the age of 40. Presented here by Poe himself in the format of a Historic Grand Rounds are the many clues that Poe left for us in the words of his own letters and his tales, along with the diagnoses offered by his family, friends and the physicians who knew him. As in a traditional Grand Rounds, the audience will be invited to guess the cause of Poe’s illness at the conclusion of his remarks. This play was written in 2000 to educate health professionals about what is still a very common cause of illness and death in America. A review in the NIH Record of a 2002 performance at the National Library of Medicine described the play as “riveting” and “spellbinding” – don’t miss it!