4/15/16 Letter to CDC Director: ‘Please cease funding fraud over Toxic Mold Disabilities (Veritox Theory)

“It was with reckless disregard for public health and safety, and a poorly thoughtout plan in the early 2000’s to try to shut down mold litigations and liability for claims of causation of environmental disability from WDB, by concoction and promotion of a fraudulent risk assessment theory – the Veritox Theory”. ….Dr. Frieden, Will CDC continue funding American College of Medical Toxicology to dissiminate information to U.S. physicians, while ACMT is still promoting the scientifically void Veritox Theory on their website? Yes ____  No _____-

Dr. Shoemaker’s “State of the Art Mold Conference” November 2015, Phoenix, AZ re: Chronic Inflammatory Responses caused by exposure to biocontaminants & biotoxins found in  Water Damaged Buildings (CIRS-WDB)  (lay terminology: “Toxic Mold disabilities”)

The following 16.04.15 LETTER has been mailed to: CDC/ATSDR Director Tom Frieden, DHHS Secretary Burwell, US Atty General Lynch, Senators Sanders, Warren, Murray of U.S. Senate HELP Committee, Dr. Perry CDC Grant Programs Director, Dr. Mapp EPA Children’s Health Division Director, Ms. Milton Esq USDOJ Disability Rights Department Supervisor – Civil Rights Division and cc’d to: Dr. Dye Pres ACMT, Dr. Harrison Pres AOEC, Dr. Dreyer Pres AAP, Dr. Hodgson Medical Director OSHA.

Re: Dr. Frieden, the Public needs federal agencies to stop funding fraud (Veritox Theory)[1] that it’s proven “Toxic Mold” can’t disable people. Please cease funding the American College of Medical Toxicology (ACMT).

Dear Dr. Frieden, Dr. Perry, Ms. Milton and Dr. Mapp, et.al,

Thank you for the CDC/DHHS, USDOJ and EPA reply letters dated March 7th[2}, March16th[3], and April 4th[4], 2016. The CDC and EPA replies were informative of how nonprofit medical associations are chosen to be non-government-organizations (NGO) assisting to provide information to U.S. physicians and the public with the use of federal funds.

The disappointing but not surprising USDOJ reply stating “we regret that we cannot be of further assistance” indicates that “too big to jail” may still pervade our justice system. It is not an acceptable response. I will soon be refiling a request for USDOJ prosecution. Crimes have been committed[5], falsified court documents have been concealed, and Americans with Disabilities Act violations have occurred[6] by California Justice Judith McConnell’s unrepentant, coram non judice, case-fixing in Veritox, Inc.’s retaliatory litigations for my exposing those involved in the marketing of the bogus Veritox Theory as of 2005. [Veritox, Inc. used to be GlobalTox, Inc.] There is a concealed government party to the fixed-cases. To my knowledge it is not DHHS or EPA. This aspect is more about lack of government oversight of severe ethics problems in the California courts. (A known pervasive problem, not specific to only the Toxic Mold Issue)

[6] See 42 U.S.C. § 12201–12213. “III-3.6000 Retaliation or coercion. Individuals who exercise their rights under the ADA, or assist others in exercising their rights, are protected from retaliation.”

With regard to lack of government oversight of the ethics problems within the Toxic Mold Issue itself, both the CDC and EPA replies appear to indicate that Dr. Frieden, Director of DHHS/CDC Agency for Toxic Substance Disease Registry (ATSDR) is the final decision maker to eliminate funding of discriminatory fraud by NGO partners of the CDC & EPA.

Yet neither reply answered my January 12, 2016 posed-question [7] if the agencies are going to cease funding the NGO medical association, American College of Medical Toxicology (ACMT) – which is still marketing the scientifically void Veritox Theory. This means the federal government is still funding proliferation of discrimination of people environmentally disabled by biocontaminants and microbial toxins (lay terminology “Toxic Mold”) that are found in water damaged buildings (WDB).

In November of 2015, I requested that NGO ACMT cease marketing the science fraud of their own accord, while pointing out they are federally funded to facilitate dissemination of accurate information to other NGO’s and physicians. [8] I have received no reply or indication of their intent to cease promoting the Veritox Theory. Thus there is dire need for Dr. Frieden’s intervention to stop DHHS and EPA funding of an NGO which promotes discrimination of the environmentally disabled based on the debunked Veritox Theory, it continues to promote.

Additionally, no reply has been received from the Senators of U.S. Senate HELP. As evidenced in my January 12th request for their help – HELP played a key role in causing the mass discrimination to be able to continue. In 2007, the Senate committee specifically deleted investigating who has conflicts of interest when promulgating standards over Toxic Mold illnesses, from federal audit. The resultant gutted-audit at taxpayers’ expense was originally comprehensive and ordered by the late Senator Edward Kennedy in 2006, at citizens’ urgings.[9]

I am aware that my liaison at HELP, Dr. David Noll, was hired by the CDC shortly after the HELP committee audit-gutting in 2007. I am aware that at the same point in time, Veritox, Inc. principals were contractors of the USDOJ. They were hired as expert defense witnesses in moldy, military housing litigation.  I am aware their testimony relied heavily of the scientifically void Veritox Theory (legitimized by ACOEM) as a reason the federal government should not be found financially responsible for causation of disabling military families.[10]

Perhaps my January 12th request to EPA and DHHS to stop funding ACMT for the sake of public health had too much attached documentation. Perhaps I provided too much detail of the vast discrimination and devastation caused by ACMT’s, other NGO nonprofits’ and Political Action Committees’ (PAC) proliferation of the scientifically void and discriminatory Veritox Theory for now fourteen years.

Perhaps my request was unclear, causing EPA and DHHS to be unable to ascertain what simple act must be taken to curtail an epic public-fleecing that is still occurring by those with access to federal funds. As such, the reasons for the need for federal intervention are explained again. This time succinctly in fifteen points with a “Yes” or “No” question that follows:

    1. Stated directly, the entire Scam that it is proven biocontaminants and microbial toxins (Toxic Mold) in water damaged buildings (WDB) can never reach a level to cause human disability (Chronic Inflammatory Responses (CIRS-WDB)) and death, is based on a scientifically void risk assessment theory (Veritox Theory) that was co-penned in 2002 by a CDC National Institute of Occupational Safety and Health (NIOSH) former deputy director. His name is Bryan D. Hardin and he has been a co-owner of Veritox, Inc. since the early 2000s. The other author of the scientific fraud is Bruce J. Kelman, President of Veritox, Inc.

    2. Continuing on with the defrauding fourteen years later, ACMT — which is still mass marketing Hardin’s and Kelman’s Veritox Theory — is a federally funded NGO medical association. As your reply letters, ACMT’s website and my initial request all confirm that ACMT is funded by DHHS and EPA. DHHS-ATSDR controls ACMT federal funding.

    3.  With regard to the NGO Pediatric Environmental Health Specialty Unit(PEHSU), ACMT is federally funded to manage PEHSU programs and to oversee their web-presence. According to the EPA reply letter, this function is jointly overseen by the NGO American Academy of Pediatrics (AAP). As such, and as accurately stated in my original request, ACMT isfederally funded by the EPA and CDC/ATSDR to disseminate scientific information to U.S. physicians which impact treatment (and mistreatment) of patients throughout the U.S.”

    4. On their website, ACMT proudly displays that it is federally funded to assist PEHSU in information dissemination. The ACMT website also displays a publication authored by ACMT members that is titled ”Institute of Medicine Report on Damp Indoor Spaces and Health”[11] hereafter referred to as the “ACMT Mold Statement”.

    5. The ACMT Mold Statement was co-authored in 2006 by expert defense witnesses in mold litigation. One of whom, Dr. Daniel Sudakin, was an associate of Veritox, Inc. at the time of authorship. It states:

      “With respect to mycotoxins in indoor air, exposure modeling studies have concluded that even in moldy environments, the maximum inhalation dose of mycotoxins is generally orders of magnitude lower than demonstrated thresholds for adverse health effects. (3,7,8)”

    6. In reality, and contrary to the concept ACMT has been marketing as legitimate science for now a decade, there is no “exposure modeling study” which “concludes” any “demonstrated threshold” before human illness occurs. Only Veritox’s extrapolations (Veritox Theory) applied to data from an exposure modeling study professes to make this conclusion. There is no scientifically established minimum “demonstrated threshold” before humans may become ill/disabled from exposure to mycotoxins in a WDB, inhaled or otherwise. The misleading word-smithing by federally funded ACMT is founded on extrapolations (Veritox Theory) applied to data taken from one modeling study of mold suddenly blasted into rat tracheas (a study by Dr. Carol Rao of the CDC).[12] As such, the Veritox extrapolations “concludes” nothing about humanadverse health effects” from chronic exposure to mycotoxins in WDB. It is a nonsequitor, a scientific fraud, and a False Claim to promote that lack of causation of human disability and death from exposure to Toxic Mold in WDB can be concluded solely by extrapolations applied to data from a rat study.

      In other words, DHHS-funded-ACMT is selling “garbage science” penned by a former DHHS employee whose company is a USDOJ-hired expert defense witness in toxic torts – where the “garbage science” DHHS is still funding has been used to avoid federal liability for causation of environmental disabilities and deaths. The intertwined conflicts of interest are astounding.

      [12] See fn. 1 page 2 for Veritox usage of Rao study.
    7. As accurately stated by Dr. Jonathan Borak in 2002, the above concept would have been appropriately deemed “garbage” fourteen years ago and never have been mass marketed in policies, courts, and physician education[13] had the American College of Occupational and Environmental Medicine (ACOEM) Board of Directors not voted to make it their position statement (2002) “Adverse Human Health Effects Associated with Mold in the Indoor Environment – an Evidence Based Statement”[14] hereafter referred to as the “ACOEM Mold Statement.” To quote Dr. Borak, Chair of ACOEM Scientific Advisory Board:

      “I do not want this to go to the BOD and then be rejected. That would be an important violation of Bryan [Hardin, retired Deputy Director of CDC NIOSH & owner of Veritox, Inc.] – I have assured him that if we do not use it he can freely make whatever other use he might want to make. If we ‘officially’ reject it, then we turn his efforts into garbage.”

    8. Unlike ACMT, ACOEM has since sunset their Mold Statement (2015) and has retracted it and its discriminatory “garbage” Veritox Theory from their websites. (See enclosed March 9, 2015 WorkCompCentral article, “ACOEM takes down paper commonly used in mold claims“)

    9. Like ACMT, the American Academy of Allergy, Asthma and Immunology (AAAAI) also put out a Mold Position Statement in 2006 that was co-authored by toxic tort defense witnesses. Like ACMT, the allergists simply parroted the garbage of ACOEM, while adding to the discrimination of the Toxic Mold injured in allergists’ and immunologists’ offices across the country. Unlike ACMT, AAAAI sunset their parroting of ACOEM in 2011.[15]

      With ACOEM and AAAAI now both having sunset their Mold Statements, the federally-funded-NGO ACMT is the last “nonprofit” medical association continuing to promote the garbage Veritox Theory as legitimate science and appropriate physician education. Last-man-standing ACMT needs to cease selling the fraudulent Veritox Theory because people are still being hurt by the willfully deceptive doubt-selling of causation of disability it provides to physicians, claims handlers, and courts.

    10. Dr. Harriet Ammann is a Senior Toxicologist, State of Washington (retired) & co-author of the 2004 Institute of Medicine’s “Damp Indoor Spaces and Health”[16]. In 2006, she was interviewed for the 2007 Wall Street Journal article “Court of Opinion, Amid Suits over Mold Experts Wear Two Hats, Authors of Science Paper Often Cited by Defense Also Help in Litigation”. [17] She accurately stated:

      They [Bruce Kelman and Bryan Hardin co-owners of Veritox, Inc.] took hypothetical exposure and hypothetical toxicity and jumped to the conclusion there is nothing there.” James Craner MD, MPH, FACOEM was quoted as saying “a lot people with legitimate environmental health problems are losing their homes and their jobs because of legal decisions based on this so-called ‘evidence-based’ statement.”

    11. As accurately stated by the Federal Government Accountability Office (GAO) in 2008 at the conclusion of their two year gutted audit, designed to hold no one accountable for the Veritox Theory, “Indoor Mold: Better Coordination of Research on Health Effects and More Consistent Guidance Would Improve Federal Efforts”[18]

      “The reviews we examined were largely consistent in their interpretations of the evidence for the role of mycotoxins in relation to adverse health effects. The Institute of Medicine reported in 2004 that (1) exposure to mycotoxins can occur via inhalation, contact with the skin, and ingestion of contaminated food and (2) research on Stachybotrys chartarum (a species of indoor mold that can produce mycotoxins) suggests that effects in humans may be biologically…………………….. plausible. (Emphasis added) Pg. 16 Para 2

    12. As accurately stated in 2015 by reference when discrediting his own highly-profitable-nonsequitor-of-garbage-science Veritox Theory; Bruce J. Kelman who is President of Veritox Inc. and co-author of the Theory with Brian D. Hardin, cited the following source for his Environmental Health Perspective’s publication “A Standard of Knowledge for the Professional Practice of Toxicology”[19]: Cited reference: “National Research Council’s (NRC) Committee on Science, Technology, Law, Policy and Global Affairs’ third edition of Reference Manual on Scientific Evidence”[20]

      (Page 658) “…the court stated: ‘Humans are not rats, and it is far from clear how readily one may generalize from one mammalian species to another. But in light of the epidemiological evidence that was not the main problem. Rather it was the absence of data at low levels.” (Page 662) “Note that many subjective symptoms are poorly modeled in animal studies. Thus, complaints that a chemical has caused nonspecific symptoms, such as nausea, headache, and weakness, for which there are no objective manifestations in humans, are difficult to test in laboratory animals.”

    13. Going back in time to the year 2003. While taking the Veritox Theory clearly into the realm of intentionally marketing scientific fraud for profit thirteen years ago — while causing mass discrimination of the Toxic Mold disabled on behalf of financial stakeholders of WDB (Veritox litigation clients); Mr. Kelman and Mr. Hardin accepted no less than $25,000.00 [21] to author the U.S. Chamber of Commerce’s Mold Statement. It is titled “A Scientific View of the Health Effects of Mold”[22] and makes the False Claim that their Theory proves:

      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.” Bruce J. Kelman & Brian D. Hardin, Veritox, Inc., published July 17, 2003

      [21] 2003 contract between Manhattan Institute and Veritox (formerly GlobalTox, Inc) http://freepdfhosting.com/da1f816865.pdf & 2003 canceled checks from Manhattan Institute to Veritox (formerly GlobalTox) equal to the hours that Kelman and Hardin billed for their work. http://freepdfhosting.com/8e5c4c5a36.pdf
      [22] 2003 U.S Chamber Mold Statement in most relevant parts http://freepdfhosting.com/a8baea5e37.pdf & in its entirety http://www.uschamber.com/sites/default/files/legacy/reports/ilr_mold.pdf
    14. And coming back to the future. At the bottom of each page of this letter there is a short-link provided to the blog, Katy’s Exposure. Please go to the link and watch the embedded half hour presentation I gave in November 2015 at the “State of the Art Mold Conference” [23] in Phoenix, Arizona. It explains the devastation still being caused for those experiencing CIRS-WDB, by NGO “nonprofit” medical associations being allowed to promote the Veritox Theory as legitimate physician education with the use of federal funds.

      I discuss impoverished families and the elderly living in substandard housing who are being treated like liars and scammers by U.S. physicians, et.al. for stating they are sick beyond asthma and allergy from WDBs. I discuss a child’s suicide caused by the horrific discrimination. (I also explain the criminal acts under the color of law in the California courts by Veritox president Kelman, his attorney Keith Scheuer, and multiple jurists — and the relentless harassment I have experienced which has aided and abetted the public defrauding over the Toxic Mold Issue to continue to this day.)

    15.  For a greater understanding of the importance of last-man-standing-ACMT being made to sunset their Mold Statement and retract it from their website, please read the enclosed 2015 WorkCompCentral article titled “ACOEM Takes Down Position Paper commonly Used to Defend Against Mold Claims”[24]; and/or contact Dr. Michael Hodgson, Medical Director of U.S. Occupational Safety and Health Administration, Department of Labor (OSHA).Dr. Hodgson has been instrumental in causing ACOEM to sunset their Mold Statement and to retract all reference to it and the bogus Veritox Theory it is founded upon, from their websites


It was with reckless disregard for public health and safety, and a poorly thoughtout plan in the early 2000’s to try to shut down mold litigations and liability for claims of causation of environmental disability from WDB, by concoction and promotion of a fraudulent risk assessment theory – the Veritox Theory.

Traveling further down the rabbit hatch under the concept that no crime is complete without the cover-up, it was an even less thoughtout plan to sue me for the words “altered his under oath statemens“, frame me for libel for those words, falsify court documents, continue to use the void docuemtns to harass me, financially ruin me and try to silence me of how the scam was being marketed. All covered up by use of retaliatory criminal acts under the color of law in the California courts.  I will not be shutting up until justice is served for me and the American public.

In these times of attempting to standardize medical practices in the U.S. for the sake of efficient and effective public health measures, it is difficult enough for honest U.S. physicians to navigate and treat patients based on ever-changing current accepted practices. They do not need DHHS & EPA continuing to fund bogus science interjected into the complicated equation by a long-term conflicted NGO partner.

Unless EPA and DHHS/CDC/ATSDR are saying that the U.S. government is A-OK with funding known discrimination of the environmentally disabled by giving federal tax dollars to ACMT who is still marketing the discriminatory Veritox Theory fraud; then it seems it would be Choosing Wisely to cease federally funding ACMT for any type of involvement of disseminating information to U.S. physicians – particularly pediatricians.

As such, a simple “Yes” or “No” answer is required in reply to my letters:

Will the federal agencies you represent continue funding ACMT to disseminate information to U.S. physicians while they are still promoting the scientifically void Veritox Theory on their website?  Yes ____ No ____.

If the answer is “Yes” then the additional questions which require answers are: “Why?” and “What does DHHS & EPA intend to do to mitigate the damage to the public from government funded discrimination of the environmentally disabled based on known scientific fraud?” (Just making laws that WDBs must be cleaned up doesn’t solve the problem of poor medical care for the CIRS-WDB-disabled by misinformed U.S. physicians.)

Thank you for your prompt attention to this matter. I look forward to your reply (or seeing the results of your actions on the ACMT website[25]). It is my hope that you will act, Dr. Frieden, to protect the American public from discrimination in medical practices by U.S. physicians who use (sometimes conflicted) NGO medical associations and their web-presence to obtain information. Please make ACMT sunset their bogus Mold Statement and retract it from their website before giving them any more federal funds used to portray that they are here for the benefit of America’s children.  [26]

[25] Current website list of ACMT Position Statements, including “Institute of Medicine Report on Damp Indoor Spaces and Healthhttp://www.acmt.net/resources_position.html


Mrs. Sharon Noonan Kramer

Enclosure: 1

CC: Leslie R. Dye, MD, FACMT, President, ACMT

Benard P. Dreyer, MD, FAAP, President, American Academy of Pediatrics (AAP)

Dr. Michael Hodgson, Medical Director, OSHA

Robert Harrison, MD, President, Association of Occupational and Environmental Clinics (AOEC) (same locations at medical schools around the country as PEHSUs with shared physicians)[28]

P.S. I currently have a permanent injunction issued from a California court with no subject matter jurisdiction, not to speak or write of what the California courts and Veritox, Inc. did to me to aid this public defrauding to continue. Needless to say, I am ignoring the void order because it’s an additional criminal act under the color of law — causing the continued profitable discrimination of the environmentally injured American public.

“The Pediatric Environmental Health Specialty Units (PEHSUs) are a source of medical information and advice on environmental conditions that influence reproductive and children’s health. PEHSU are academically based, typically at university medical centers, and are located across the United States, Canada and Mexico. These PEHSU form a network that is capable of responding to requests for information throughout North America and offering advice on prevention, diagnosis, management, and treatment of environmentally-related health effects in children. Because children’s environmental health covers a wide variety of issues, the PEHSU network has experts in pediatrics, allergy/immunology, neurodevelopment, toxicology, occupational and environmental medicine, nursing, and other specialized areas….The PEHSU website is supported by the American College of Medical Toxicology (ACMT) and funded (in part) by the cooperative agreement FAIN: U61TS000238 from the Agency for Toxic Substances and Disease Registry (ATSDR). Acknowledgement: The U.S. Environmental Protection Agency (EPA) supports the PEHSU by providing partial funding to ATSDR under Inter-Agency Agreement number DW-75-95877701.” http://www.pehsu.net/About_PEHSU.html

16.03.16 DHHS Reply Letter16.03.16 DOJ reply letter

16.04.04 EPA reply letter



About Sharon Kramer

Hi, I'm an advocate for integrity in health marketing and in the courts.
This entry was posted in Civil Justice, Environmental Health Threats, Fourth District Division One Appellate Court, Health - Medical - Science, Mold and Politics, Toxic Mold, US Chamber of Commerce and tagged , , , , , , , , , , , , , , . Bookmark the permalink.

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