Migraines, Perfume, and the Americans with Disabilities Act

By Megan Oltman Monday, April 20, 2009

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It happens to Migraineurs again and again - we go to work and the people around us wear perfumes or strong scented deodorants or lotions or aftershaves. Their scents trigger Migraines, and we can't work. We have to go home, use our sick leave, maybe our pay is docked. Our work performance suffers, our budget suffers. If we complain to our employer, we are often told to put up with it. Or we are told that the employer cannot restrict the other worker's freedom to wear the scents, or we're told to be a team player and not make waves. This issue has been raised here on My Migraine Connection dozens of times. The great news is that there is a recent Federal case which makes it clear that employers can indeed, and in fact must, restrict employees from wearing perfume if it impacts your health and makes it impossible for you to work!

*** This sharepost is legal education, not legal advice. No attorney-client relationship is created. ***

Recently Miles posted this question in the Q & A section of the site:

"Need women at work to quit wearing perfume: Perfume is a horrible migraine trigger for me. The women in the office where I work wear it all the time -- lots of it. Talked to my boss. He said "live with it," but gets ticked when I get a migraine. Isn't there some kind of law about workplaces that should protect me?"

Yes, Miles, there is a law that protects you. It is the Americans with Disabilities Act (ADA) as amended by the Americans with Disabilities Amendments Act of 2008. The ADA prohibits employment discrimination against persons with disabilities, and what is significant about that is that it is considered discrimination if you are unable to perform your job because your employer failed to make reasonable accommodations to your disability which would have made it possible for you to work.

Does this apply to Migraineurs and perfume? Until recently I would have said the jury was out on that question, but two things happened in the past few years. The first was McBride v. City of Detroit. Susan McBride worked for the City of Detroit and she sued her employer under the ADA when the City refused to institute a no perfume policy as an accommodation to her extreme chemical sensitivity. The City moved to dismiss her claim, stating that Ms. McBride had not made out a case for disability under the ADA. A coworker's perfume caused Ms. McBride to become ill, miss work, and receive medical treatment. Her employer had refused to recognize her chemical sensitivity as a disability, or to provide accomodations. The US District Court denied the motion for summary judgment, holding that Ms. McBride had made out a sufficient case for a disability under the ADA, and that enforcing a no perfume policy could have been a reasonable accommodation. Although the McBride case did not deal with Migraine specifically, the facts are exactly parallel to a Migraine case, and the court ruling is such that the door is open to future lawsuits brought by Migraineurs.

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Comments (40) | Add comment

Megan

4/20/09 4:21pm

Wondering if you are aware of any similar legislation that could potentially help migraineurs who have to travel on commercial airlines. I have found that perfume and other strong odors on commercial flights are almost unavoidable and requests to be reseated are not often accommodated on full flights. Do you have any advice on how to address the commercial airlines so that they might consider restricting the use of migraine triggering perfumes by other passengers?

Thanks!

Megan Oltman

4/20/09 5:48pm

Megan the ADA also provides that access to transportation shall not be restricted due to disability; that's why we now have disabled seating on public transportation. Whether that would require an airline to accomodate your request for a seating change is a more complex issue - it's not the same as employment where someone is prevented from doing their job on an ongoing basis. I don't know of any law directly on this point.

THEHECKERS

7/15/10 8:49am

We have a child with Aspergers Disorder who has a severe sensitivity to perfume. She hyperventilates when exposed to strong fragrences. Recently we were on a full 10 hour airline flight when the women seated behind us doused herself in perfume. My daughter asked for a bag and started to hyperventilate, breathing into the bag. I wish I had brought a mask for her. I also wish that spraying perfume or cologne or aftershave in a closed airplane was outlawed. Where can you go in a full plane?

Helkster

4/22/09 11:11am

Megan, what about fluorescent lighting? I work in a high school - all fluorescents - I walk around all day with my sunglasses on in order to work all day...just curious.

Thanks, Pam

Megan Oltman

4/22/09 12:12pm

Pam I will be discussing other accommodations Migraineurs have succeeded in getting, and can reasonably expect, in another sharepost on the ADA either at the end of this week or early next week. I'll definitely talk about lighting, so stay tuned!

Gwyneth

4/24/09 1:42am

Sometimes I even will wear a wide-brimmed hat in the grocery store, in addition to the sunglasses for protection against the flourescent bulbs. The stores do need to use this type of bulb since the savings is so great, but the pain for us is also great. I used to not be able to get more than halfway thru my marketing without being stricken...

I have found that one can do better, when you wish to install flourescent bulbs at home, by using the full-spectrum flourescent bulbs. They are available in every kind/shape of bulb; used to be known as plant or grow bulbs. These bulbs, actually, are better in general.

Also, my eyes are very sensitive to light, but especially to bright white cloudy light. I find it helpful to have sunglasses in 2 shades of darkness + regular glasses of the self-darkening type...

Good luck to all of our group!!!

myachinghead

4/22/09 1:02pm

Thank you for posting this information. I have long had trouble with scents and despaired over ever having power to control my environment.

My BOSS insisted on placing an automatic aerosol air freshner not 10 feet from me and set it to run every 5 minutes. When I came to work Iwould simply turn it off. One day he told me he had switched to an "unscented" freshener since I obviously didn't like the smell. Of course that still bothered me. I tried to explain it wasn't a dislike of the smell but a sensitivity to the chemicals but he brushed me off telling me the place really stank.

I continued to turn off the freshener and also to unplug the glade oils they had in the wall outlets. Lately they haven't used them. I don't know if they finally got tired of me turning them off or if they just got tired of buying them.

Now I know I can approach him about this if they start again and bring your information to light. Hopefully he will finally get it!

Thank you!

smgibson

4/23/09 12:50pm

Unfortunately for me and I'm sure many others, it is not just the workplace that we have to be concerned about. It is EVERYWHERE.

We were outside at a Botanical Garden a few weeks ago and 3 young ladies walked past me about 10 feet away. BAM their perfumes hit me and within minutes a migraine was full blown. Thankfully my hubby was with us. We were at least an hour from home and I am not safe to drive when I have a migraine.

What can we do? I'm certainly not in favor of banning perfume, but again, sometimes I wonder...

shade

4/23/09 12:55pm

Yes, I knew this would come about. I battled with my employer and my work mates (men and women) for 5 years. I was thought to be a unhappy and troublesome worker. I believe I was about to be let go, as I was extremly ill daily and could not properly function due to all the scents in the workplace. My Dr. put me on a leave. I hired a lawyer to protect my job and my Dr. would not let me return to an unhealthy work place. My employer tried every trick in the book to get me back without changing anything. I was not allowed to return to work and after 6 months they caved and we are scent free in the work place. I am now a very, very healthy, happy and hard working asset to them.

It was extremly stressfull time and I was not paid for lost wages or compensated in any way. How ever I love my job and needed to work, so to make it a place I could go to every day I had to defend my self.

amigraineur52

4/23/09 1:25pm

This is a fascinating subject. I never thought I was overly sensitive to scents between migraine attacks, but I found that I cannot go down the laundry detergent aisle at the grocery store without holding my breath! We now buy unscented laundry soap.

Diana Lee

4/23/09 2:11pm

This is an excellent, informative post, Megan. I'm so glad you're sharing your expertise with the MMC family!

I was lucky when I was still in the workforce. I candidly told my coworker that the cheap cologne he used (to cover up his drinking!!!) made my migraines worse. He was very kind about it and immediately stopped using the cologne. I wish all such situations went that smoothly for migraineurs.

Anonymous

4/23/09 2:15pm

When I was a student at the University of Washington, a similar situation arose where sitting next to a student in class often gave me a migraine. Sometimes it was because that student was wearing perfume or aftershave, and sometimes it was because they had just finished smoking a cigarette, or were actually eating their lunch in class (I am very allergic to onions).

I wrote an article for the campus newspaper outlining the devastating effects these behaviors have on students and staff members who suffer from Multiple Chemical Sensitivity (MLS). My goal was not to ban fragrances from the campus entirely, but to establish "scent-free" study areas, such as classrooms, computer labs, and small sections of the library. Unfortunately, I graduated before I could see this goal become a reality, but I did notice a decrease in sensitivity after the article was published, as students became aware of MLS (many for the first time). Most students graciously volunteered to accommodated my request.

staceygray

4/23/09 2:47pm

Thank you for posting this. I work in a small accounting office (3 people including myself) and my supervisor is the Accounting Manager/Director of Human Resources. My supervisor and other co-work regularly use the plug in air fresheners and spray air fresheners as well as very strong perfumed hand lotion. I have stated to them many times that these scents really bother me. Luckily I haven't had the plug-ins to deal with for a while.

Our company has had many layoffs over the past year and we are now at half the size we were a year ago. In these tough economic times I'm afraid to say much or push too hard, afraid that I could be next on the lay off list officially because of the economy but unofficially because I complain (ask them not to wear) about these things. It's good to know that there is some protection out there for me and that maybe it would be a good idea to get something in writing from my neurologist to use for documentation if necessary.

Thank you for the informative information.

miles

4/23/09 5:06pm

Dear Megan,

Thank you for your answer! It's a great help.

Miles

Megan Oltman

4/24/09 5:14pm

Miles I'm glad you came back and saw this!

Hcampbell64

4/23/09 8:08pm

I work with Autistic Teenagers as a bus attendant. My kids, mostly boys, act like two year olds on steroids. My biggest problem is one who screams at the top of his lungs when he gets angry. Autistic kids can't verbalize very well, so the whole world knows when they are screaming. Excessive noise is a big trigger for me and on especially bad days I have gone home with a migraine after work because of this one child who screams. The problem is that our school district expects everyone to be perfect and not have any health problems. Is there anything I can do to deal with this one?

Megan Oltman

4/24/09 5:13pm

Hcampbell I will be addressing noise in the next sharepost about the ADA.

Hcampbell64

4/25/09 12:11am

Thanks. I look forward to reading and finding out more.

trinity1771

4/25/09 4:08am

I also work with Special Needs kids including Austistic Teens, totally understand the loud screams, it is sometimes a way of communication because they can not verbalize and are frustrated. I also have suffered migrains for 29 or so years. Please do not be offended, but did you not understand Autisitic behavior before you accepted your job? There are times we need to place blame on employers but sometimes we need to look at ourselves and decide if we made the right career/job choice. After years of working in an office with bad air and bad lighting and always being "sick", and no help from HR, I left. If I had knew then what I know now, maybe things would be different. But I found a career that makes a differance and makes me happy.

Trinity

Hcampbell64

4/25/09 9:24am

Yes, I knew what the kids behaviors were when I started the job and I am aware that they communicate this way when they are frustrated because they can't verbalize. I used to work in the dispatch office for a plumbing company and when the phones would all "ring off the hook at once" it would be worse than Autistic kids screaming. I have had fewer migraines since working with Autistic kids than I did working at the plumbing company. Thank you for asking about this, though, I appreciate it. I also have Fibromyalgia, which doesn't help much.

praeter13th

4/24/09 7:44am

Thank you for this article. I have suffered with this for years and people at work are generally very insensitive to this. I'm printing it out and having a talk with my supervisor if it arises again (lately no scented females have been working near me).

Anonymous

4/24/09 4:49pm

Wow, I find this all very interesting, and I don't need to be attacked, but not everyone is the same. One of my migraine triggers falls on the opposite end of the spectrum - body odor sets me off, cigarette smoke is not much better. I prefer that people wear perfumes, deodorant, aftershave, etc. It's especially bad in the summer, when people refuse to work out after work, and use their breaks and lunch to walk, run, etc, outside. They come back reacking, of body odor, and with wet arm pits, and backs, which I would think that everyone else would just plain hate to look at. Body odor and cigarette smoke both make me nauseous even before the migraine starts; I usually only get nauseous after the migraine, but the body odor and smoke trigger is worse. I think that the burden should be on us, the migraine sufferers, at least for starts to do as much as we can to overcome this. Rather than expecting hundreds of co-workers to adjust their lives for me, I have a portable air system, (it works in the car too), and I take allergy medication. I figure that if I am unwilling to do these things to work, then I have no right to ask hundreds of people to accommodate the one of me.

Ulla w perfume sensitivity

6/18/09 2:57pm

I have been suffering from a sensitivity to perfumes for about 5 years now. Unless you actually experience the devastating effects such sensitivity triggers, you will not be able to appreciate how crippling it can be in a work place. I would like to dispute your statement that the sufferers must adjust to their disability and not subject "hundreds" of their co-workers to giving up on fragrances. I really, really disagree with your recommendation. As with many triggers, you cannot take a pill to stop a reaction from happening. There is a difference between an allergic reaction to, let's say animal dander, and a sensitivity to volitile synthetic compounds such as perfumes. You may be able to take Claritin before visiting a friend who has a cat, but the same Claritin will not help you if you are exposed to perfumes. Synthetic fragrances are detrimental to the health of everyone, the wearers and the sniffers (voluntary or involuntary). Persons like me, who react violently to frangrances, just have a lower treshold to what their bodies are willing to put up with. Fragrances are not essential to everyday life, they don't heal, they don't nourish, they don't play any role in humanity's great good. They are nasty chemical creations that damage our pulmonary and immune systems. They may trigger severe asthma attacks, autoimmune response and may even lead to death. On the other hand, no one, that I have heard of, has ever died from inhaling another person's body odour. It is not pleasant and at times repugnant but hardly lethal. All persons with disabilities are entitled to a safe work environment. If that demands that all coworkers stop using non-essential synthetic fragrances (and believe you me, they are all non-essential) so be it. A little sensitivity to disabilities of others would go a long way. The same would apply to the stinky guy who runs on his lunch brake and doesn't take a shower; however, the issue of synthetic fragrances sensitivities is much more pressing than the issue of sweaty coworkers.

It is not fair to say that person' with a multiple chemical sensitivity take a pill, get an oxygen tank or flat out stay at home rather than work with everyone on awarness and compassion. Clean air hasn't killed anyone yet but air full of synthetic chemicals may. If someone had an allergy to peanuts would you tell them to take a pill and get over it? Would you bring peanuts to work because it is your god given right to eat peanuts wherever you please? I didn't think so. Keep in mind that knowing that someone is severly allergic/sensitive to something, and then deliberately exposing that person to that trigger, may be seen as an assault and you may be criminally liable should anything happen to the ill person. Just a thought.

Megan Oltman

6/18/09 4:28pm

I agree with you wholeheartedly, Ulla, and so does prevailing law!

parisbabe

6/21/09 4:02pm

Everything you said I completely agree with and applaud you for standing up and saying. I just wish we could get more people to say these things.

I have had to quit my last 3 jobs because I could not get people to stop wearing perfume. And the saddest thing is these women claimed to be Christians! Where was their love for their fellow sister? I went to HR in the last 2 and was told there was nothing they could do. You are so right, that unless someone experiences the devastating effects, they will not be able to appreciate how crippling it can be. I would be sick for days!! And all because they wanted to wear the latest perfume or hand or body lotion!! And even after I told them I had migraines that was triggered by fragrances. I even bought one an unscented hand lotion to use since that was what she kept putting on many times a day.

Now I am trying to find a work from home job. But it is so hard. I am going thru my savings and worry I will not be able to keep my home. And all because people feel they have the right to make me sick!!

It's all I can do not to get angry when I read what this woman wrote about how it's the migrainuer's responsibility to take a pill or do something. There is no pill or I would gladly be taking it. I have searched and searched to try and find something that would help me with my fragrance trigger. I am about to try hypnosis to see if that will work. I went to a doctor and asked him to remove the organ that regulates the sense of smell. And of course, he said he wouldn't do that.

This Zicam that the FDA is removing because it's causing permanent loss of smell in people. I should have gone and got some before they removed it. But I still would have gotten sick as it's the chemicals in the fragrances that I am reacting to, not the smell. I have survived breast cancer and it was much easier than this. Because there was a beginning and an end. And I was not a prisoner in my own home. Yeah, this woman has no idea!!! I wish she could be as sick as we are for one day and then she would not be so quick to judge!!

Thank you for standing up for those of us who suffer from the ones in this country who feel they have the right to make us sick with their fragrances. Kinda like second hand cigarette smoke. The world FINALLY got wise to that, maybe someday it will get wise to what fragrances are doing to our health.

Ulla w perfume sensitivity

6/21/09 7:51pm

Thank you for replying to my post, ladies. This issue is very near and dear to my heart and I wish that it would get as much publicity and awareness as it deserves.

parisbabe: I am a breast cancer survivor myself, and I sometimes suspect that the chemotherapy had something to do with my sensitivities, which developed about a year after the treatments were over. I guess for now, we just have to try and educate those around us. We will win some over and will lose many more. Please keep your head up and keep trying. Good luck on finding a new, healthier, job.

Megan: Thank you for the great article and, please, keep them coming.

Love and light...and clean air to all.

parisbabe

6/25/09 2:09pm

I asked for an accomodation at the last 2 places where I worked and I was told there was nothing there could do but ask in a "general way" for every one to be considerate of someone who was "sensitive" to fragrances. Several co workers were not happy with me for asking HR for any kind of accomodation. Since they were smokers, they were spraying cologne to cover up the smell of cigarettes after they came inside from their smoking break.

On one occasion, One woman grabbed my arm and put scented body lotion on it and when I reacted, she reported me and I was written up, not her. So, I just quit because I figured they were trying to get me to quit and it was obvious this incident was the means they were using. I was working around a lot of smells anyway and figured I would be better off somewhere else.

So, my next job was a front desk receptionist. Many women wore excessive perfume. When I asked my boss if I could put an air purifier on my desk as my doctor had written a prescripiton, she suggested it would be best I didn't as it would look bad. I then went to HR and asked for accomodation under the legal protection that you mentioned and that got their attention. They said they could put it in the newsletter for people to be more considerate about wearing excessive cologne and I could have my air purifier on my desk. But then my boss and the lady I job shared with, started wearing excessive fragrance where they had not done so before. My breaks that I was supposed to get were cancelled and just getting the one legal break that I was supposed to get was a job each day. And the women I had to call to relieve me would come wearing perfume or some fragrance and it would then be on the phone when they left and I would get a migraine. So, once again they were trying to get me to quit and I did.

I had met with a social worker and a counselor during the time all this was going on and they both agreed it was too hard to fight the system and my boss. If your employer is determined to get rid of you, you will have a huge fight on your hands, whether the law is on your side or not, and if you are sick and need to work, you don't have the time or energy to fight. So, they advised me to just go and find another job where a boss and company respects me. I am currently looking for a work from home job as it is obvious that I can't work out in public right now with this fragrance issue.

Until something actually becomes a law where it is clear cut, me and others like me, are in for a fight.

My relatives live in Canada and they are telling me that more and more places are becoming fragrance free there because of the health issues. My aunt says her doctor's office is and a friend says even her church is. Fragrances affect people with asthma, allergies, bronchitis, and migraines. To restrict it in a work area would reduce the illness factor and benefit employers. But untill that happens here in America, people like me are reduced to trying to work from home or just suffering. I pray this will soon change!

Teri Robert, Health Guide

6/25/09 2:57pm

Hi there!

You said, "Until something actually becomes a law where it is clear cut, me and others like me, are in for a fight."

Go back and take a look at the last paragraph of the first page of this SharePost. The ADA is the law you're looking for, and there IS a precedent of an employer having to accommodate for fragrance sensitivity.

Teri

Megan Oltman

6/25/09 3:08pm

Yes, Teri you were thinking along the same lines I was. Unfortunately the way our employment laws work is - the law entitles you to fight, and win the fight! Sounds to me like you had excellent lawsuit material on your hands.

Parisbabe, if you are looking for a law banning perfumes from public spaces, like we now have laws banning smoking from many spaces, I get your point, but look how many years it took to get laws passed aobut smoking, and people still have to fight about those issues as well!

- Megan

Ulla w perfume sensitivity

7/ 1/09 10:12pm

parisbabe: That's terrible what is happening to you. I am lucky that I live in Canada and work for a very accommodating employer. Even so, some people on my floor still insist on wearing perfume regardless of the signs and reminder e-mails from the director. I do have a great fight though if it ever comes to that. I am not the only one who reacts to fragrances at my workplace. I try to stay away from the "stinky" ladies as much as I can but I still get the odd asthma attack and a migraine.

I wish you luck in finding a home located job and I too think that you have a couple good law suits should you choose to take that route. Just document everything. Some lawyers may even do it pro bono. Good luck!

R - effected person seeks help

7/26/09 2:09pm

Good day. Can anyone point me to some scientific evidence that may have helped prove a case for the sufferer? Hopefully it will be credible evidence in the eyes of the litigators. For example, scans of peoples' brains prior to and during an episode of a reaction to fragrence, or information on fragrences' effecs on the immune system, or perhaps even evidence indicating what happens to circulation - blood - and oxygenation of the brain which then can impair function.

I would like to help myself and others.

Greatfully yours - R.

Anonymous

10/ 7/09 5:00pm

This I understand, but how about when an employer tells only one employee that they cannot wear cologne and the rest of the employees are aloud to. Sounds like discrimination to me. Banning the use of perfume or cologne in the work place is okay, but make sure that you are doing it properly and are not discriminating against one sole individual.

cantbreathe

9/21/10 9:37am

I am having a similar problem with a girl at work wearing Carmax lip balm , which triggers my asthma and closes me up! I work at a hospital and they have a policy in place, but she keeps wearing it and others have witnessed it. HR has threatened to move me to another department. She has filed a complaint against me that I only wear a mask around her and I am "singling" her out. Well, she keeps wearing the scent and I am only trying to protect my health and don't want to have an asthma attack, yet I am plagued as the "trouble maker" go figure!! Please be aware of others and the air that they need to breathe to live!! Thanx

htre

1/ 6/11 8:33am

Thanks to Miles re: ADA law for us

Hope people with migraines will contact support groups for asthmatics and people with multiple chemical sensitivites and ban together to get the ADA law
"on people's radar"...we need media support.

I have asthma and it is a BIG trigger for me. There is alot of heavy marketing of "fragrances" AKA chemicals to the public. Fragrance sensitivity prohibts one from leading a normal life..church, theaters, restaurants, sporting events, hair salons, and the like are off limits. It is egregious that people are not more understanding about this issue..I believe their rights end where my nose begins!

jenna12

1/19/11 7:31am

Thank you for finally giving my answers to my migraine problems. I get a migraine whenever i hear people whine about problems they have, or in general, conversate about any unsettling topic. I'm hoping i can waste more time and money for the company i work for and for the general public, for if im not 100 % happy, no one should be, i mean heaven forbid someone should be given the right to conversate frealy, while at the same time, hurting my head just because that was the way i was made. Just lucky i wasn't born with no legs, otherwise id be trying to force people to walk in crutches or a wheelchair.

Listen people, everything, and i mean damn near everything, causes distress in some way, shape, or form to someone, but have you tried removing yourselves from the problem instead of forcing a new problem on other people because of your pre-existing problem. Just because YOU have a problem, doesn't mean THEY should have to change. Wear a gas mask, and for heaven sake, don't post on your period bitches.

Helen311

4/ 4/11 10:30am

What are you even doing on this sight? I see no "whining" on this site or in the comments. I see a shared frustration with personal yet similar medical ailments. Your blatantly rude, sarcastic and nasty comments are as offensive as I suspect you intended.

For those who suffer migraines and/or allergies where the common triggers are inevitable in daily life, discussing the frustration and lack of solutions is merely that - it doesn't qualify as whining.

Please show the respect for others that you would want shown to you.

Stacey

10/20/11 2:09pm

I work in a scent free workplace. My question is "How come the person with the scent problem does nothing to help themselves? She was offered a fan - No, it was too noisy and would make the supervisor in the same cubicle too cold. She was offered an air purifier - Nope - too big. How about the agency purchase a supply of masks. Nope - that would be singling her out. How come the person with the scent problem can have her daughter come and visit her in the office reaking of some Bath and Body Works fragrance??? This is the same person who would spray lemon scented Oust when someone heated something in the microwave that she didn't like the smell of. So everyone in the Agency (we occupy floors 2-6 and 18) has to abid by this scentfree workplace policy but she doesn't have to do anything to try and help herself.

Abi A

10/20/11 5:51pm

Stacey,

Who are you talking about? I searched this page for "fan" and the only place it appears is in your post. There's one that mentions an air purifier, and the person who mentioned it tried it. The only place I see anyone talking about a daughter is the woman who posted about her daughter on an airplane.

Abi

Stacey

10/21/11 7:55am

I was talking about someone I work with not anyone commenting on this site

teacher

10/24/11 2:10pm

My doctor acknowledges that perfume is a trigger, but won't give me a note because he doesn't want to get involved! My boss says even though I ask my students not to wear scented anything, if they do, I can't ask them to leave, I have to leave! I teach at a community college part-time, so if I leave, I forfeit my pay! I don't want to sue anybody, I just want to work and not get a headache. Today I had a sinus infection and a boy decided to wear cologne. I had him for 2 classes. Tomorrow I have a student who usually wears perfume and she was out today, so I couldn't find her to remind her to leave it off. I can't refuse to assist her if she needs help either. Whatever happened to common courtesy?

Migraines, Perfume, and the Americans with Disabilities Act

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