"Erode the credibility of the Anderson study ..." [ellipses in memorandum] --
This kind of statement written down in a document is dangerous from a
public relations viewpoint.  It is possible that this document could fall into
the wrong hands or be subpoenaed." (1) The words of this in-house Monsanto
memorandum proved to be prophetic as it was subpoenaed during a recent
lawsuit involving carpet toxicity.  The memorandum provides a glimpse of
some of the behind the scenes strategizing conducted by industry insiders
concerned about the public image of carpet as a safe floor covering.

As the memorandum indicates, and as reported in Informed Consent's
four part series on carpet, one major stumbling block to that safe
image is the testing of carpets conducted by Anderson Laboratories.
Using a standard industry test (ASTM E981), Rosalind Anderson, Ph.D.,
found a high percentage of carpet samples were causing serious
respiratory and neurological problems, including death, in lab
animals.  Their results correlated well with the types of health
effects -- confirmed by objective tests -- in people who have
experienced adverse reactions to carpet. (2-5) In addition, Anderson
states she has conducted approximately 100 tests without carpet in
the testing apparatus, and has never had any of the adverse effects
show up on the control tests as opposed to the carpet sample tests.

The ASTM E981 was developed by Yves Alarie, Ph.D., for use by the
U.S. Army in the 1960s.  It was specifically designed to provide
accurate extrapolation of rodent data to human health effects of
chemicals.  It measures the respiratory and irritant neurological
effects via the trigeminal nerve, which connects the nasal and oral
cavities to the brain.  The ASTM E981 has stood the test of time.  In
1984 it was adopted by the American Socity for Testing and Materials
(ASTM), an organization that creates consensus testing standards for
use by government and industry.  Used world wide by industry and
other governments, it is one of the most validated test methods in
existence. (6)

Before Anderson went pubic with her carpet test findings, she and her
lab had an excellent reputation with government and industry.
According to lab manager Mark Goldman, the U.S. Navy and the U.S.
Army had contracted their lab for combustion toxicity testing.  In
addition, he says 25 companies within the carpet industry had hired
the lab to perform biological testing of carpets in combustion
toxicity studies as required by New York state law.  In 1983 and
1984, Anderson was commissioned, while at Arthur D. Little Inc., to
prepare a report on combustion toxicity testing for the New York
state Office of Fire Prevention and Control.  Goldman reports that
the state office was so impressed with Anderson's report and her
testing methodology, they incorporated it into the New York state
building codes that took effect in 1986.  The ASTM combustion test
method Anderson used is related to the ASTM E981 in that it uses the
same exposure principles, restraints, and glass holder for mice.

In early spring 1992, when Anderson Laboratories independently
discovered the carpet toxicity problem, "we were astounded with the
findings," said Anderson.  "First, we approached the carpet and rug
industry to alert them to the problem so they could take action."

In August 1992, the Carpet and Rug Institute (CRI) hired Alarie, the
founder of the method, to check out Anderson's protocol and to try to
duplicate her results in his lab at the University of Pittsburgh.
Alarie reported her protocol was sound and that he was able to
duplicate her findings in his own lab. (2)

"Stil," says Goldman, "the CRI took no public action, and not once
did they approach us and ask us to prepare or recommend a research
proposal for them to fully address the issue."

Anderson says, "We were still finding results that could have a
profound public health impact.  Even though we knew we were risking
the wrath of the carpet and rug industry and would therefore probably
lose a lot of business, we felt an ethical obligation to bring it to
someone's attention that might do something about it and warn the
public quickly."

At a carpet toxicity hearing in October 1992, Congress challenged EPA
and the carpet and rug industry to take the problem seriously. (2)
This apparently created quite a dilemma for the carpet and rug
industry.  The November 11, 1992, Monsanto memorandum describes a
proposal "relating to carpet health hazards" submitted for
consideration by Fleishman Hillard, a pubic relations firm based in
Washington, D.C. (1) The memorandum states: "The proposal was read
by several people in the public affairs department and the comments
listed are a compilation of everyone's input.  The Fleishman thrust
is two-fold ... [ellipses in memorandum] to publicly refute
Anderson's research and repair damage to the image of carpeting.  The
program in both cases is built on the assumption that we will be
clearly able to prove her research is flawed.

"If we are forced to operate in a gray area where we're sure
carpeting is safe but can't prove Anderson's research is flawed, the
approach would be somewhat different.  Overall, the proposal is very
good.  It is relatively comprehensive and covers most of the areas we
feel are important.  There are some elements that deserve comment.

"p. 2 -- Industry & Allied Groups Outreach -- This is one area where
the individual CRI member companies can help by educating their
workforces.  At Monsanto we could initiate an employee awareness
program and make our employees spokespeople for the safety of carpet.

"p. 2 -- Media Outreach -- Responding to negatives is important but
even more important is creating positive feelings about carpeting.
What's required here is a proactive program about the comfort and
beauty of carpet.  I'm thinking of a program similar to the Cotton
Inc. 'feel good' campaign for cotton garments.

"p. 2 -- 'Erode the credibility of the Anderson study ...' [ellipses
in memorandum] -- This kind of statement written down in a document
is dangerous from a public relations viewpoint.  It is possible that
this document could fall into the wrong hands or be subpoenaed.
There are several references like this throughout the document that
could be phrased better.  It would be better to say something like:
'Determine the validity of Anderson's research and educate the public
concerning its scientific credibility.'

"p. 4 -- Last paragraph, last sentence -- 'The key is to discredit
her methodology, results and motives' We need to be careful with this
tactic.  It may be necessary to publicly discredit and disgrace her
but this is a risky endeavor.  Even if we can prove she is
incompetent, consumer advocates generally are difficult to discredit
and we would run the risk of turning her into a martyr.  That's not
to say it shouldn't be done, but we should be on very strong foodting
if we go this route." (1)

Attorney Kevin McIvers of Santo Barbara, California, responds,
"That's atrocious because what they're implying is that they're not
trying to objectively look at the validity of her work.  They're out
to destroy it.  I view her as a very honorable person doing her
humble best in her little laboratory to share her information with
people who are in a position to do something about it, and their
response is to personally discredit and disgrace her rather than take
what she has to offer."

The author of the Monsanto memorandum, Dallas A. Meneely, is also in
charge of public communications regarding the carpet issue.  Meneely
says the Monsanto public affairs department was not considering
adopting the proposal for their own use but was considering whether
to recommend it to CRI because "we have pretty much allowed the CRI
to carry the public issue parts of this program.  We felt it was
better for the industry to be answering these questions as a unit, as
opposed to individual companies getting out and trying to answer the
specific questions."

Meneely sees the memorandum in a different light than McIvers: "At
that point in time we didn't know who Anderson was.  We didn't know
if her testing was valid, if her testing was something that she was
doing to try to get personal gain out of it.  We needed to
investigate further, and that was just one of the alternatives that
was available if that indeed was the case -- if it turned out to be
the case that she was someone that was trying to do this for personal
gain."

However, Godman disputes this.  "Monsanto was well aware of Dr.
Anderson and our work history with the carpet and rug industry," he
says.  "In April 1991, Dr. Anderson and I visited Monsanto in St.
Louis and gave a presentation.  Even aside from that, at the time of
the memorandum, Dr. Alarie had already duplicated our test results
for CRI and had reported our testing protocol was sound."

McIvers states, "To some degree it's just the adversary process that
goes on in every litigation, trying to undermine the experts on the
other side.  But the memorandum wasn't about generating credible
evidence for the courtroom to attack the reliability of Anderson's
findings.  What they are talking about is a campaign to discredit her
in a number of forums and in the public eye.  To consider attacking
her personally and trying to destroy her career is a dreadful thing
to do.  It's cruel and inappropriate.  And that's where they are
stepping over the line.

"Unfortunately that's what has been happening to Dr. Anderson.  When
people call the CRI or EPA they are told that EPA and independent
researchers were unable to duplicate her results and that her
findings are not valid even though Alarie duplicated her results and
the EPA was videotaped duplicating her results with their own
equipment and their own choice of carpet samples in a side-by-side
test at Anderson Labs."

McIvers added, "CRI has mailed information out to industry
representatives and retailers discrediting Anderson's work by saying,
'The test using mice, known as the Anderson study, is inconsistent
with other research conducted to date and cannot tell us *why*
[emphasis in original] the reaction occurred.  The Environmental
Protection Agency, the Consumer Product Safety Commission,
independent laboratories worldwide, and the carpet industry have done
studies on carpet and health, and all of this research has failed to
discover any evidence linking carpet and ill health effects.  In
fact, the testing method used in the Anderson study is being
questioned by many scientists in the government, private industry,
and the academic community.  Many questions about the study remain
outstanding.'" (7)

The memorandum also refers to the actions of EPA and the Consumer
Product Safety Commission (CPSC): "p. 12 -- Expand Linkages with
EPA/CPSC -- This is an excellent tactic buy saying that they have
'effectively helped give the industry cover on this issue' is
dangerous to write down in a document that could become public.  If
this document were to fall into the hands of the press, that kind of
statement could ruin careers."

McIvers says, "EPA and the CPSC certainly have been effectively
hiding the truth on these issues and are covering for the industry.
If it ruins careers, it's because of their own actions.  The public
needs to know about this kind of thing, and government officials
should be accountable to the public.  In my mind, it goes back to the
whole business about EPA's own workers becoming ill from new carpet
installation and renovation work in their own headquarters.  You know
when EPA scientists have to take their own employer to court to
get an issue taken seriously that something is wrong.  EPA's actions
have made it obvious they're trying to sweep it under the rug for
somepolitical or economic reason.  And that's not what the EPA is
supposed to be about."

Meneely didn't remember whether or not Monsanto recommended CRI adopt
that particular proposal addressed in the memorandum.  "There were a
number of different proposals that were generated about that time
frame and I'm not sure if this specific one was recommended," says
Meneely.  "There were some proposals that were adopted, now,
specifically whether that one was adopted by the CRI or not, I don't
know."

Ron VanGelderen, president of CRI, says, "CRI had engaged Fleishman
Hillard's services several years ago.  They are not currently our
public relations firm." VanGelderen doesn't know whether CRI
incorporated t he proposal referred to in the Monsanto memorandum.
"We get recommendations, suggestions, and proposals from all kinds of
sources," says VanGelderen.  "If you're talking about a couple of
years ago, we received those from Fleishman Hillard as well."

VanGelderen adds, "Just because we have received proposals and
recommendations that does not mean that all of them are accepted or
implemented, because they need to fall within our own policies.  And
if they don't fall within the policies, they are not implemented."

According to VanGelderen, the CRI's policy is not to discredit
researchers.  He states, "That's not our policy.  We don't discredit
anything -- our aim is simply to find out the facts on anyone's
research, find out under proper scientific protocol how that should
be replicated, what those results are -- and then the chips fall
wherever they may." What is CRI's current official position on
Anderson's research? "I think that the facts speak for themselves,"
says VanGelderen.  "Research was conducted by EPA Research was alsso
done by industry trying to replicate her protocol and those reports
were made at an EPA workshop last September, and they indicated that
they were unable to replicate her results."

Monsanto's public position is similar.  According to Monsanto's Verne
Rhodes, one of the recipients of the November 11, 1992 memorandum,
Monsanto's current position is as follows: "Our position is the
Anderson Lab tests are not valid and they are not telling us
anything."

Congressman Bernard Sanders (I-VT) says, "We're disappointed but
we're not surprised that when confronted with this serious health
problem, they chose to undertake a comprehensive public relations
campaign instead of a comprehensive effort to research the problem
and make changes that would protect the consumers."

"We're looking at the possibility of a follow-up hearing," says
Sander's aide Anothony Pollina.  "We're planning to meet with the
industry soon to get a specific update as to the progress they've
made in terms of the commitments they made to Congress for research
into health effects and consumer information and protection efforts."

Would Anderson have gone public again if she'd fully known the
repercussions? According to Anderson, "The attacks we've had from
industry have been vicious and clearly show the issues are not
technical, they're political.  Still, if I'd seen the same toxicity,
I'd have had to act on it.  I couldn't have lived with myself if I'd
have tried to cover it up knowing that real lives were at stake.  If
there's one thing I've learned in all my years of toxicity testing,
it's that when you have the bad luck of finding really serious data,
you have to follow it through to the very end."


References:

1.  Monsanto memorandum from Dallas A. Meneely to T.G. Iversen, L.J.
O'Neill, C.B. Beckmann, V.L. Rhodes, L.W. Wassell, and B.A.
Vanderbeck, regarding "Fleishman Hillard IAQ Proposal." (November 11, 1992).

2.  Deuhring, C.  "Carpet Concerns Part One: EPA STalls and Industry
Hedges While Consumers Remain at Risk; Carpet Time Line; What Do You
Do If You Want Carpet?" Informed Consent 1(1):6-1, 30-33 (1993).

3.  Deuhring, C.  "Carpet Concerns Part Two: Carpet Installers Speak
Out as the Medical Evidence Mounts; Hazardous Chemicals in Carpet"
Informed Consent 1(2):8-10, 44-48 (1993).

4.  Deuhring, C.  "Carpet Concerns Part Three: New Carpet Label
Receives Mixed Reviews; Carpet Industry Response Team, A Lawyer's
Perspective." Informed Consent 1(3):40-45 (1993).

5.  Deuhring, C.  "Carpet Concerns Part Four: Physicians Speak Up as
Medical Evidence Mounts." Informed Consent 1(4): 12-16 (1993).

6.  Schaper, M.  "Development of a Database for Sensory Irritants and
Its Use in Establishing Occupational Exposure Limits." American
Industrial Hygiene Association Journal 54(9): 488-544 (1993).

7.  Memorandum from the Carpet and Rug Institute to the Carpet
Industry and Retailers.  Re: carpet toxicity, Anderson Laboratories
test results, and a class-action lawsuit.  (April 1993).