No Value: Coakley-Rivera, Cheryl et al vs. Carey, Paula et al

On September 01, 2021 a No Value was filed involving a dispute between Coakley-Rivera, Cheryl, Potter, Judith, and Bello, John, Carey, Paula, Gladstone, Carol, O'Brien, Charles, for Equitable Remedies in the District Court of Hampden County.

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« Military service
* History of traumatic brain injury or engaging in contact sports

Only about 10% of ALS cases are linked to family history, making approximately 90% of cases
identified as “sporadic ALS.” There is a great deal of study of risk factors for ALS, including
genetic susceptibility combined with exposure risk factors to improve understanding of
conditions that may contribute to development of ALS (Mehta et al., 2018).

A well-known risk factor of ALS is a history of military service, which puts those individuals at
approximately double the risk of developing ALS as those that have not served in the military
(Mehta, 2018). Some research has also indicated that the incidence is increasing, which may be
due to the aging population, better diagnosis, and improved medical recordkeeping (Mehta et al.,
2018). Some studies have shown increased risk from traumatic brain injury (ALS Association,
2019). Additional factors that may contribute to the higher incidence among veterans are higher
exposures to environmental contaminants related to military activities, greater rates of smoking,
and intense physical activity (ALS Association, 2019).

Recent research shows that in Massachusetts some occupations may be associated with higher
incidence of ALS compared to the general population (Fraser et al., 2017). In particular, the ratio
of individuals with ALS working in the legal field was 2.4 times greater than in the general
population. These figures are not age-adjusted, which could bias the results if a greater fraction
of the population working in the legal field is in the 40 to 70 year age range. Additionally, the
total number of new cases identified in Massachusetts each year is approximately 600 to 700,
making estimates stratified by work history, for example, subject to additional forms of bias,
such as age or smoking status.

Search of the scientific literature identified numerous studies that examined potential
associations between environmental conditions and risk of ALS. These studies
have focused on exposures or conditions that may be associated with ALS including:*
* Blue-green algae, known as cyanobacteria
e Watersports / exercise
* Metals
Solvents
Occupational exposures (agricultural pesticides, solvents, military service)
Diesel emissions
Viruses
Radiation
Electromagnetic fields
smeeeeen
* httpy//www, ‘h/focus-areas/enyironmental-factors/

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6.2 ENVIRONMENTAL ASSESSMENT

The potential exposures related to a building worker were assessed as part of EH&E’s evaluation
in the Buildings. These included metals, cyanobacteria, diesel or traffic-related pollutants, and
solvents. As discussed in the following sections, there is no evidence of elevated levels of these
environmental risk factors in the Buildings. Other potential contributors related to individual
cases, such as lifestyle factors, virus exposure, or previous trauma could not be assessed as part
of this work.

6.2.1 Cyanobacteria

Cyanobacteria, also known as blue-green algae, are photosynthetic bacteria found in fresh and
saltwater. Under certain growth conditions cyanobacteria can produce “blooms” of algae growth
that can produce hazardous toxins. This can require water bodies to be closed to recreational
uses. One toxin, beta-methylamino-l-alanine (BMAA), is associated with cyanobacteria and with
health conditions, including ALS (Caller et al., 2009). A documented form of ALS endemic to
Guam has been associated with ingestion of a seed known to have high concentrations of BMAA
(Pablo et al., 2009). This toxin is also associated with cyanobacteria in water bodies. People can
be exposed to cyanobacteria toxins such as BMAA through inhalation (Banack et al., 2015;
Stommel et al., 2013) or ingestion of contaminated water or fish.

Several studies have shown associations between markers of cyanobacteria in water bodies and
ALS cases (Caller et al., 2013; Caller et al., 2015; Torbick et al., 2018). A mapping study of lake
regions in New England found an association between number of ALS cases and concentrations
of an indicator of cyanobacteria, using satellites to detect phycocyanin concentrations on the
surface of water bodies.

To assess potential exposures to cyanobacteria and its toxins, drinking water at the building was
tested for both cyanobacteria and BMAA, In addition, the location of the cooling tower directly
adjacent to air intakes for the 50 State Street Building identified another potential route of
exposure via inhalation. To address this, the cooling tower water was also tested for
cyanobacteria and toxins. As seen in Table 6.1, no BMAA was detected in water samples from
the Building. Cooling tower water is treated with chemicals to reduce fungal and bacterial
growth, so exposures related to a properly functioning cooling tower would be limited.
Maintenance of cooling towers is required to minimize stagnant, untreated water. Maintenance
records from the previous year indicated that the cooling tower water pump was not functioning
properly on several occasions. Past performance of the cooling tower has not been well
documented, but at the time of EH&E’s inspection, the cooling tower pump had been repaired.

As noted by Bradley and colleagues (2018), the exposure period for developing ALS is not
understood, and “studying environmental exposures solely at the time of symptom onset is

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unlikely to reveal all that needs to be known, since the neurodegenerative disease process
probably began years prior to the onset of clinical symptoms.”(Bradley et al., 2018).
ect ttn epi srr een
Table 64 Water Testing Results for BMAA, 50 State Street, Sorin, Massechusets September 2019
on

228 - Employees Lounge Sink
sooner
i hroom Sink pene neni ND <5
| 2048 Bathroom Sink ND <5
G42 Sink a
G42 Sink ND <5

ND <5
Seen pinintie
BMAA beta-methylamino-I-alanine
ppb parts per billion
ND none detected
< less than

All samples were sent to EnviroScience (Stow, Ohio) for analysis of algae. The laboratory detection limit for BMAA is 5 ppb, Blank samples
were taken and were less than the 5 ppb.
wringer merece

6.2.2 Metals

History of lead and mercury exposures have been associated with ALS in some studies (Wang,
2017) while others have found no association (Vinceti et al., 2017; Parkin Kullmann and
Pamphlett, 2018). Mercury exposure can occur from metal-based dental fillings (dental
amalgam), seafood ingestion, and inhalation from airborne mercury sources, such as an
incinerator. The most common association between ALS and heavy metals has been found for
lead exposures, followed by mercury in a smaller number of studies (Wang et al., 2014).
Exposure to lead and mercury have also been shown to be associated with development of
multiple sclerosis (MS) (Napier et al., 2016). A systematic review of metals exposures and
neurodegenerative diseases including ALS, Parkinson’s and Alzheimer’s did not identify metal
exposure as consistent exposure risks for those conditions (Cicero et al., 2017). As discussed in
Section 4.10, no evidence of elevated heavy metals was found in the Buildings.

6.2.3 Particulate Matter

Some studies have shown associations between ALS and exposure to diesel or other indicators of
traffic, such as light absorbance of fine particles (Dickerson et al., 2018; Seelen et al., 2017).
Many studies of ALS exposures are very small, given the rare nature of the condition.
Neurodegenerative diseases, such as dementia, Parkinson’s Disease, and Alzheimer’s Disease,
have been shown to be associated with particulate matter exposures in studies as well
(Kiomourtzoglou et al., 2016). Truck drivers have been found to have increased risk for

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developing ALS in large occupational cohort studies (Pamphlet and Rikard-Bell, 2013;
Dickerson et al., 2018) and also workers with a history of diesel exposures (Dickerson et al.,
2018). As discussed, in Section 4, airborne particle monitoring results did not indicate the
presence of elevated levels of particulate matter, including PM2s. PM25 is a measurement of
smaller particles, including those potentially linked to outdoor sources such as vehicle or diesel
emissions.

6.3 CANCER

As detailed in Section 4, EH&E conducted an analysis of VOCs in the Buildings. Exposures to
some VOCs at high levels for long periods of time can be environmental risk factors for cancer.
Measured indoor VOC concentrations in the Buildings were consistent with those expected in
offices and well within health-based OELs. Measured indoor VOC concentrations were also
compared to guideline values from EPA, known as Regional Screening Levels (RSLs) for cancer
effects.° RSLs are levels of exposure considered to be extremely protective of human health and
unlikely to contribute to adverse health effects for even sensitive populations over a lifetime (70
years) of exposure, The approach taken by EPA to establish RSL values utilize a detailed
analysis involving deliberate, quantitative steps intended to ensure that actual risks to health will
not be underestimated. Median VOC concentrations measured in all locations of the Buildings
were below the screening-level RSL values. Taking direct measurements of the environment in
which, the occupants are experiencing concerns is one of the best ways of assessing potential
exposures. The indoor samples collected to assess VOCs that were present in the indoor
environment of the Buildings, did not indicate any VOCs that would be out of place in a typical
office.

6.3.1 Formaldehyde

Formaldehyde exposure is most often associated with eye, nose, and throat irritation, and nasal
cancer has been seen in highly exposed animals and people in occupational settings (WHO,
2000). Formaldehyde is a widely studied contaminant that is commonly measured in indoor air.
Previous studies have shown associations between occupational exposure to formaldehyde and
ALS incidence (Weisskopfet al., 2009). As discussed in Section 4.12, no elevated levels of
formaldehyde were detected in the Building.

6.3.2 Solvents or Agricultural Chemicals

Occupational exposure to agricultural chemicals and/or solvents have been shown in some
studies (Andrew et al., 2017; Malek et al., 2015) to be associated with ALS but not in others
(Weisskopf et al., 2009), A recent large scale review study concluded that exposure to pesticides
iterates!
6 https://www.epa.gov/risk/regional-screening-levels-rsls

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is potentially associated with ALS and is supported by the scientific literature (Wang et al.,
2017). One study evaluated estimated exposures to aromatic hydrocarbons (2,4-dinitrotoluene,
benzene, ethyl benzene, styrene, toluene, and xylene) and showed weak associations between
aromatic HCs estimated at home address and ALS (Malek et al., 2015). Exposure to aromatic
compounds, such as benzene, is well-documented, with cancer being the main health endpoint of
concern. As discussed in Sections 4.11 and 4.12, no elevated levels of VOCs or aldehydes were
detected in the Buildings.

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7.0 _ DISCUSSION
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EH&E identified multiple issues with cleanliness in the Buildings that should be addressed.
Sampling results from surfaces in occupied spaces in both Buildings indicated that the levels of
certain types of particles accumulated on surfaces is elevated compared to those expected in
typical offices. Cellulose was the most common particle type detected on surfaces, which is not
considered unusual given the relatively high use of paper in the Buildings. Levels of fiberglass
were elevated compared to levels normally seen in offices. Fiberglass on surfaces has the
potential to cause irritation. EH&E also identified excessive dust accumulations and mold
growth on and around supply air diffusers in many areas of the Buildings. Levels of common
environmental allergens, including dust mite, cat, dog, rat, mouse, and cockroach, in dust
collected from carpets in the Buildings were below detection and/or proposed thresholds, except
in one location where cockroach allergen was detected. EH&E recommends conducting a
detailed cleaning of surfaces throughout the Buildings using the procedures in Appendix D.
MTC should also implement a regular surface cleaning program in the Buildings.

Mold growth and water damage was identified in various locations. In most areas, mold growth
was limited and localized (e.g., less than 10 square feet). EH&E recommends remediating the
mold growth in the Buildings and addressing the underlying moisture sources. Appendix D
provides detailed recommendations to addressing mold impacted materials. Although mold
growth was identified in multiple locations and should be remediated, sampling for total airborne
mold spores did not indicate that sources of mold were impacting the indoor air in most locations
of the Buildings.

In addition, EH&E found that ductwork was dirty in many areas of the Buildings. Based on these
results, EH&E recommends that MTC clean the ducts in both Buildings. Cleaning should be
conducted by a professional duct cleaning contractor in accordance with procedures outlined by
NADCA with systems appropriately isolated (NADCA, 2013). Prior to the work, the contractor
should conduct a thorough assessment of ducts in the Buildings to determine an appropriate
access and cleaning plan.

At times, temperatures in various areas of the Buildings were outside of recommended ranges for
occupant comfort. Thermal comfort conditions should be reviewed and adjusted, as feasible. In
50 State Street, temperature control is limited in many areas in the summer months because hot
water reheat systems that provide local temperature control are not available. EH&E understands
that original electrical reheats have been converted to hot water in many areas as part of energy
conservation efforts. Hot water boilers are not operated in this Building in the summer and,
therefore, these reheats do not function during this season. This results in limited temperature
control in most areas. The reheat operation and control strategy should be reviewed and modified

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to provide year-round thermal comfort. Modifications to the existing systems will likely require
the need for significant financial investment into the Buildings.

Although ventilation rates in most areas were within recommended guidelines, carbon dioxide
readings in a few areas indicated that ventilation rates were slightly below recommended rates.
Detailed information and recommendations to improve operation of the HVAC-system are
discussed in Section 3.

No CO was detected during occupied hours in the Buildings. A few low, but detectable, CO
readings were recorded during unoccupied hours (nights/weekends). Although no unusual odors
were observed by EH&E during our inspections in the Buildings, combustion-like odors have
been periodically reported by staff in some areas. It is possible that CO detections recorded
during unoccupied hours are related to vehicles idling in close proximity to the Buildings or in
the garage. EH&E recommends that MTC investigate these odors further and ensure idling is
minimized near the Buildings. As part of this assessment, MTC should maintain a log of odor
incidents. Also, providing occupants with grab air sampling devices so they can collect air
samples during odor events should be considered.

Testing results for VOCs, aldehydes, and heavy metals were within applicable health-based
guidelines and consistent with levels expected in typical offices. Also, all drinking water test
results were within established standards and guidelines.

Multiple [EQ issues were identified and should be corrected as summarized above. Addressing
these issues will likely decrease the high rates of IEQ concerns in the Buildings as reported in the
2018 occupant survey. This includes some of the frequently reported work-related symptoms,
dissatisfaction among survey respondents related to thermal comfort, the numerous occupant-
noted concerns regarding mold issues, HVAC systems, and dust accumulations. Although
multiple IEQ issues were identified and should be corrected, EH&E’s assessment did not identify
conditions that would support an environmental work-related cause for the cases of chronic
health conditions reported in the Buildings, including ALS or cancer. Our analysis did not
identify evidence of unusual sources of relevant potential environmental risk factors associated
with workplace conditions in the Buildings.

Analysis of the environmental history of the property and surrounding sites indicated a history of
commercial and industrial use consistent with many sites in Springfield, other cities in New
England, and urban areas in general. The findings of the environmental database search and review
of historic documentation revealed a density of sites listed on environmental databases consistent
with an urban setting. Overall, the historical review did not indicate evidence of sources or
conditions considered likely to pose an environmental hazard in the Buildings.

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8.0
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Stommel EW, Field NC, Caller TA. 2013. Aerosolization of cyanobacteria as a risk factor for
amyotrophic lateral sclerosis. Medical Hypotheses, 80:142-145.

Torbick N, Caller T, Ziniti B, Haney J et al, . 2018. Assessing Cyanobacterial Harmful Algal
Blooms as Risk Factors for Amyotrophic Lateral Sclerosis. Neurotox Res, 33:199-212.

Vinceti M, Filippini T, Mandrioli J, Violi F et al., . 2017. Lead, cadmium and mercury in
cerebrospinal fluid and risk of amyotrophic lateral sclerosis: A case-control study. Journal of
Trace Elements in Medicine and Biology, 43:121-125.

Wang M-D, Gomes J, Cashman NR, Little J et a/., . 2014. A meta-analysis of observational
studies of the association between chronic occupational exposure to lead and amyotrophic lateral
sclerosis. J Occup Environ Med, 56(12):1235-42.

Wang M, Little J, Gomes J, CashmanN et al., . 2017. Identification of risk factors associated
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Weisskopf M, Morozova N, O’Reilly E, McCullough M et al., . 2009. Prospective study of
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WHO. 2000. Air Quality Guidelines for Europe: Second Edition. WHO Regional Publications
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APPENDIX A
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LIMITATIONS.
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LIMITATIONS
Environmental Health & Engineering, Inc.'s (EH&E) indoor air assessment described in the
attached report number 22799, Indoor Environmental Quality Assessment, Roderick L.
Jreland Courthouse and Hampden Juvenile Court, Springfield, Massachusetts (hereafter
“the Report"), was performed in accordance with generally accepted practices employed by
other consultants undertaking similar studies at the same time and in the same geographical
area; and EH&E observed that degree of care and skill generally exercised by such other
consultants under similar circumstances and conditions. The observations described in the
Report were made under the conditions stated therein. The conclusions presented in the
Report were based solely upon the services described therein, and not on scientific tasks or
procedures beyond the scope of described services, nor beyond the time and budgetary
constraints imposed by the client.

Observations were made of the site as indicated within the Report. Where access to
portions of the site was unavailable or limited, EH&E renders no opinion as to the
condition of that portion of the site.

The observations and recommendations contained in the Report are based on limited
environmental sampling and visual observation and were arrived at in accordance with
generally accepted standards of industrial hygiene practice. The sampling and observations
conducted at the site were limited in scope and, therefore, cannot be considered
representative of areas not sampled or observed,

When an outside laboratory conducted sample analyses, EH&E relied upon the data
provided and did not conduct an independent evaluation of the reliability of these data.

The purpose of the Report was to assess the characteristics of the subject site as stated
within the Report. No specific attempt was made to verify compliance by any party with all
federal, state, or local laws and regulations.
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APPENDIX B
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BACKGROUND AND MONITORING METHODS
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BACKGROUND AND MONITORING METHODS _
MOISTURE SURVEY METHODS

The moisture survey was intended to identify potentially wet building materials in inspected
locations. This survey was performed by inspection to identify visual evidence of moisture
(e.g., staining, discoloration, and/or liquid water) and the use of the infrared (IR) camera to
detect any potential wet materials. Direct moisture meter measurements were then used to
quantify actual moisture levels in building materials.

The IR camera used was a FLIR Model T420bx (FLIR Systems, Inc., North Billerica,
Massachusetts). This camera displays relative surface temperatures of materials in the visual
field. Under most conditions, building materials that contain higher moisture content are
relatively cooler than dryer materials and can be differentiated in the camera display.

The moisture meter used during the evaluation was a GE Protimeter® Surveymaster (GE
Infrastructure Sensing, Inc., Billerica, Massachusetts). This instrument displays readings as
percent moisture content, referenced to a wood standard. When non-wood materials such as
gypsum wallboard are measured, the results are expressed as percent wood moisture equivalent
(% WME). Moisture levels in building materials are considered elevated when they are higher
than levels measured in similar materials in unaffected areas (e.g., dry, not damaged by
moisture). Direct moisture meter measurements obtained from wallboard materials that did not
exhibit evidence of water damage were less than approximately 15% WME, a moisture content
that was considered dry. Materials with higher moisture content were considered wet. Wet
materials had moisture content readings of between 25 — 100%.

SURFACE SAMPLING METHODS FOR MOLD

Surface samples were collected by applying a clear adhesive slide (Bio-Tape) to the surface
being tested. Blank samples were collected for quality assurance purposes. After sampling, the
slides were transmitted under chain of custody to Eurofins EMLab P&K (Fairfax, Virginia), an
American Industrial Hygiene Association accredited laboratory for examination by light
microscopy.

Surface sampling differentiates mold from dust or other non-biological debris.'* These results
provide assessment of whether there is mold growth on the surface (indicated by the presence of

' AIHA, 2005. Field Guide for Determination of Biological Contaminants in Environmental Samples.
Second Edition. Hung LL, Miller JD, Dillon HK, eds. Fairfax, VA: American Industrial Hygiene
Association,
? ACGIH. 1999, Bioaerosols: Assessment and Control. Macher J, ed. Cincinnati, OH: American
Conference of Governmental Industrial Hygienists.

B-1
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growth structures), the density of the growth (indicated using a 1 to 4 numerical ranking), the
type of growth, and the presence of spores. Samples are designated as “normal trapping” if they
contain only a few spores with no indication of active growth.

DUCT CLEANLINESS TESTING METHODS

Dust samples were collected from selected duct locations using the Vacuum Method outlined in
the National Air Duct Cleaners Association (NADCA).° Test results were compared to an
acceptance criterion of 0.75 milligrams per 100 square centimeters (mg/100 cm’) as outlined by
NADCA. Samples were collected from a 100 cm? area in accordance with the NADCA vacuum
test method. This involved using a vacuum sampling cassette with filter media attached to an air
sampling pump at a flow rate of 15 liters per minute. Pre-weighted 37-millimeter diameter, 0.5
micrometer pore-size polyvinyl chloride filter cassettes provided by the analytical laboratory
were used, Pump flows were verified with a calibrated primary flow meter. During sampling, the
open face of the filter cassette was passed over two 2 cm by 25 cm openings within the template.
The template was specifically designed to allow the cassette to ride above the surface being
tested (the vacuum cassette was never in contact with the surface being tested). In addition,
replicates and blanks were collected and analyzed.

Following collection, the dust samples were sealed and transported under chain of custody to the
analytical laboratory. Samples were analyzed by Liberty Mutual Industrial Hygiene Laboratory,
an American Industrial Hygiene Association accredited laboratory located in Hopkinton,
Massachusetts. Samples were analyzed for total dust mass in accordance with National Institute
for Occupational Safety and Health Method 0500.* The laboratory limit of quantification was
0.050 milligrams per sample.

CARBON DIOXIDE

Case Info

Judge

Jane E. Mulqueen Track Judge’s New Case

Case No.

(Subscribe to View)

Document Filed Date

September 01, 2021

Case Filing Date

September 01, 2021

County

Parties

Bello, John Defendant
Carey, Paula Defendant
Coakley-Rivera, Cheryl Plaintiff
Gladstone, Carol Defendant
Green, Esq., Julie Elisabeth Attorney for the Defendant
Mangini, Esq., Laura Attorney for the Plaintiff
O'brien, Charles Defendant
Potter, Judith Plaintiff
Robert DiTusa Attorney
Ryan Alekman Attorney
Jeffrey Morneau Attorneys for Plaintiffs
Chelsea Choi Attorney
Thomas Kenefick Attorneys for Plaintiffs

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