Industry Strategizing Memorandum Comes to Light

by Cindy Duehring
(Part 5 of 5)

"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 Society 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)

"Still," 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 footing 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 some political 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 also 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."


  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)

Back to Part 4

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FOOTNOTE: Cindy Duehring, 36, internationally known researcher, activist and pesticide victim, died at her home in Epping, ND, on June 29, 1999, from injuries and complications sustained from severe pesticide poisoning in 1985.

Her work continues through the Chemical Injury Information Network (CIIN), which she founded in 1990 with Cynthia Wilson as a way to deal with her chemical poisoning. CIIN is a 501(c)(3), tax-exempt, non-profit, support and advocacy organization run by the chemically injured primarily for the benefit of the chemically injured. It focuses on education, credible research into Multiple Chemical Sensitivities (MCS), and the empowerment of the chemically injured.

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