Académique Documents
Professionnel Documents
Culture Documents
2010
Comments
of
Dr
Michal
A.
Berry
Regarding
Recent
Criticism
of
the
CRI
Seal
of
Approval
Program
I
have
reviewed
the
white
paper
titled,
“Discussion
Regarding
a
Novel
Method:
The
Use
of
X-‐Ray
Fluorescence
for
Quantitative
Analysis
of
Elements
in
Carpet”,
authored
by
Debra
Lema,
Racine
Industries.
I
find
that
the
paper
and
the
subsequent
public
comments
made
by
the
president
of
Racine
Industries
to
represent
an
unimpressive
and
unpersuasive
marketing
attempt
disguised
as
“science”
to
discredit
the
CRI
Seal
of
Approval
XRF
testing
program,
a
program
that
in
my
view
produces
significant
environmental
health
benefits
to
consumers.
The
reason
for
this
attack
on
the
Seal
of
Approval
program
is
blatantly
obvious.
The
Racine
Industries
criticism
rests
in
the
fact
that
the
Racine
Industries
cleaning
product
HOST
fails
to
demonstrate
“cleaning
effectiveness”
as
measured
and
required
by
the
CRI
Seal
of
Approval
test
method.
XRF
is
an
analytical
method
that
detects
different
elements
by
ionizing
their
constituent
atoms
and
recording
the
characteristic
energy
signatures
of
photons
given
off
by
the
elements
as
they
seek
to
regain
stability.
The
XRF
test
method
used
in
the
Seal
of
Approval
program
is
designed
to
measure
the
quantity
of
matter
removed
from
the
carpet
in
the
cleaning
process.
Previous
methods
used
to
evaluate
the
carpet
cleaning
effectiveness
of
vacuum
cleaners,
extraction
equipment,
and
cleaning
chemicals
relied
on
a
spectrophotometer
to
measure
the
amount
of
light
reflected
off
the
surface
of
the
carpet.
The
spectrophotometer
test
method
provides
only
an
indication
of
how
the
carpet
surface
might
appear
to
the
eye.
It
does
not
measure
the
fundamental
health
based
objective
of
cleaning
which
is
matter
(soil)
removal
from
the
carpet
and
the
resulting
reduction
in
exposure
and
risks
to
those
substances.
The
Seal
of
Approval
program
begins
with
a
definition
and
understanding
of
“clean”
and
“cleaning.”
“Clean”
is
an
environmental
condition
free
of
unwanted
matter.
“Cleaning”
is
the
process
used
to
achieve
the
clean
condition.
“Effective
cleaning”
is
the
removal
of
unwanted
matter
to
maximum
extent
with
minimum
cleaning
residue.
The
Racine
product
is
incompatible
with
the
basic
concept
of
effective
cleaning.
Among
other
environmentally
undesirable
attributes,
the
Racine
Industries
product
HOST
leaves
behind
large
amounts
of
cellulous
particle
residue,
photosynthesis
derived
matter
that
becomes
food
stock
for
a
variety
of
microorganisms.
In
addition,
the
residue
is
the
source
of
small
particles
that
can
under
normal
environmental
conditions
and
activities
transfer
from
carpet
to
indoor
air,
thus
creating
a,
an
undesirable
and
potentially
unhealthy
environmental
condition.
For
a
major
part
of
the
past
decade,
the
CRI
program
has
been
publically
transparent
and
widely
discussed.
The
Seal
of
Approval
program
and
test
method
has
been
published
and
presented
in
open
forum.
The
XRF
test
method
and
program
has
been
examined
and
reviewed
time
and
again
by
qualified
and
experienced
scientists
with
many
years
of
experience
with
product
and
environmental
testing
in
academia,
industry,
and
government.
It
is
my
research
experience
and
professional
judgment
that
the
CRI
Seal
of
Approval
program
has
made
a
tremendous
improvement
in
the
effectiveness
of
cleaning
and
health
of
indoor
environments.
Most
importantly
to
me
as
environmental
health
professional
and
scientist
is
the
fact
that
environmental
quality
and
healthiness
of
environments
in
which
the
CRI
Seal
of
Approval
product
or
service
is
applied
is
far
superior
to
that
over
environments
where
technologies
are
used
that
have
not
been
tested
or
evaluated.
I
have
previously
presented
and
published
data
to
support
this
finding.
The
Racine
Industries
white
paper,
press
releases,
and
media
presentation
are
without
any
meaningful
technical
merit.
1. The
author
of
the
paper
fails
to
indicate
her
technical
background,
experience
or
competence
with
product
or
environmental
testing
and
most
specifically
with
actual
experience
related
XRF
test
methods.
She
has
a
conflict
of
interest;
she
cannot
be
an
agent
of
Racine
Industries
and
at
the
same
time
be
a
credible
science
writer
without
having
her
objectivity
called
into
question.
2. The
“peer
reviewer”
and
his
or
her
technical
background,
professional
and
business
interests
and
affiliations
are
not
disclosed.
3. The
author
of
the
white
paper
has
in
several
places
misrepresented
the
XRF
test
method
and
constantly
speculates
of
errors
in
the
method.
Neither
the
author
nor
“peer
reviewer”
present
any
data
or
indication
of
experience
to
support
their
criticism
of
the
XRF
test
method.
4. The
author
and
reviewer
offer
nothing
new
to
our
body
of
knowledge
related
to
XRF
science
or
measurement.
It
is
well
known
fact
to
any
scientist
that
all
measurement
and
every
test
method
have
random
variation
and
limitations.
Statistical
sample
size
and
republications
address
these
limitations
and
biases.
These
were
well
understood,
addressed,
and
documented
at
the
time
XRF
method
was
developed,
reviewed,
and
accepted
by
CRI
and
the
inherent
biases.
5. The
author,
the
“reviewer,”
and
the
president
of
Racine
Industries
offer
no
alternative
method
to
scientifically
or
consistently
measure
and
evaluate
the
effectiveness
of
a
cleaning
process
to
remove
unwanted
matter
from
a
carpet
or
rug.
The
fact
remains
that
the
XRF
test
measurement
provides
a
science
based,
cost
effective,
best
available
means
of
consistently
measuring
the
efficiency
and
effectiveness
of
a
“cleaning
process”
to
remove
unwanted
matter
from
a
carpet
especially
before
that
cleaning
process
is
applied
to
an
environment
that
affects
health
of
its
occupants.
Dr.
Michael
A.
Berry
is
a
retired
Research
Professor
from
the
University
of
North
Carolina
at
Chapel
Hill
where
for
over
twenty
years
he
tough
environmental
science
and
business
and
environment
topics.
He
currently
serves
as
consultant
in
the
evaluation
of
environmental
quality
and
environmental
management
strategies
and
policy.
Dr.
Berry
retired
from
the
US
Environmental
Protection
Agency
in
1998
where
as
a
senior
manager
and
scientist
he
served
as
the
Deputy
Director
of
National
Center
for
Environmental
Assessment
at
Research
Triangle
Park,
NC.
During
his
28
year
career
with
EPA,
he
had
extensive
interactions
with
private
industry,
trade
associations,
environmental
organizations,
governments,
the
federal
courts,
US
Congress,
universities
world-‐wide,
and
institutions
such
as
the
National
Academy
of
Sciences,
the
World
Health
Organization,
and
the
North
Atlantic
Treaty
Organization.
Dr
Berry
is
recognized
internationally
as
an
expert
in
the
subject
of
indoor
environmental
quality.
Between
1986
and
1991
he
organized
and
managed
EPA’s
indoor
air
research
program