Statement Of Nick Monreal, Jr.
Environmental Protection Agency Nick Monreal, Jr.
Bexar County Area Agency on Aging Ombudsman The Elderly and The EPA:
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Proposal Justification: EPA National Strategic Plan
Goal 4 Preventing Pollution and Reducing Risks in Communities, Homes, Workplaces and Ecosystems -
Objectives 01: Reduce Public Ecosystem Exposure to Pesticides;
Objective 02: Reduce Lead Poisoning
Objective 04: Healthier Indoor Air
Objective 05-01: Pollution Prevention
Goal 7 Expansion of Americans' Right to Know About their Environment -
Objective 07-01: Increase Quality/Quantity of Education/Outreach, Data Availability
Objective 07-01-01: Improve Environmental Education for K-12 (adaptable to elderly)
Objective 07-01-07: Increase Environmental Information
Project Correlation to EPA 2002 Priorities:
- Building Livable Communities - EPA will play a
key role in implementing the Administration's Livability Initiative.
Helping state and local governments take the initiative in safeguarding
their land and water for future generations.
- Clean Air Partnership - The Clean Air Partnership
will demonstrate locally managed programs that achieve early integrated
reductions in soot, smog, air toxics and greenhouse gases. Direct
new resources to state and local governments to find the most innovative,
cost-effective and protective ways to reduce soot, smog, air toxics
and greenhouse gases that contribute to climate change.
- Meeting the Climate Change Challenge - Administration's
commitment to reduce greenhouse gas emissions through partnerships
with businesses, schools, state and local governments, other organizations,
and investments in energy efficient technologies and tax incentives
for consumers who purchase energy efficient products.
- Protecting Children's Health - As part of the government-wide
interagency initiative on children's asthma, EPA is taking a leadership
role in reducing children's exposure to asthma-causing toxins, education,
outreach, research, and air monitoring activities.
- Ensuring Clean and Safe Water - Reducing non-point
source pollution. Pollution from non-point sources is now the leading
cause of water pollution. These sources of pollution are harder to
identify and control than those associated with point sources.
- Empowering Citizens with Knowledge about their Environment
(Right-to-Know) - The Agency is committed to enabling citizens to
assess the risks posed by their specific environments and allow them
to make better decisions on how to handle those risks. Ensure that
the public has basic health data for industrial chemicals released
in their communities due to a voluntary partnership with industry.
- Cleaning up Toxic Waste Sites - Reducing the effect
of uncontrolled releases on local populations and sensitive environments.
The Agency will continue to address clean-up efforts at over 89 percent
of Superfund sites.
- Revitalizing Communities through the Brownfields Initiative
- Promoting local cleanup and redevelopment of industrial sites, bringing
jobs to blighted areas.
- Strengthening Tribal Partnerships - Providing tribes
with program and technical assistance and will assure that tribes
have adequate information with which to make environmental decisions.
- Environmental Justice - Environmental justice is
the bridge that makes achieving the varied goals of clean air, clean
land, clean water, safer foods, better waste management, and full
enforcement of this nation's protective environmental laws for all
peoples and communities.
- Persistent Biaccumulative Toxics - Stop the transfer
of PBT pollutants across environmental media by using all of EPA's
tools: regulatory, compliance assistance, enforcement, research, voluntary
actions, prevention, and international negotiation.
Environmental Problems Identified:
Older Americans spend up to 100% of their time indoors
where pollutant levels often exceed outdoor levels of Particulate Matter
(EPA studies of human exposure to air pollutants indicate that indoor
levels of pollutants may be 2-5 times, and occasionally more than 100
times, higher than outdoor levels). Environmental risk indoors
includes exposure to air toxics, hazardous chemicals, water contaminants,
temperature extremes, carbon monoxide, molds, second hand smoke and pesticides.
NEEDED is a project which will evaluate the cumulative
environmental threats from all media indoors and offer a plan to prevent
potential future exposures and to reduce existing exposure where necessary.
"Currently, there
are no programs that develop environmental quality of care, specifically
addressing the quality of life and quality of care for the elderly".
At-risk Elder Population:
The Elderly residing in Long Term Care Facilities, have been historically subjected to poor conditions, regarding Indoor Air Quality.
Preliminary research, conducted by the Bexar Area Agency on Aging / Ombudsman Program, indicates that the main factor contributing to these poor air quality conditions, is the fact that most of the Nursing Homes in Bexar County (and this case can be made for most Nursing Homes around the state and U.S.), were built in the late 60's and 70's, and as recently stated during an interview with a Life Safety Code expert, these facilities are just plain "Tired Buildings", whose HVAC systems and building structures are aging, and are in dire need on renovations. The Nursing Facility Requirements for Licensure and Medicaid Certification, as set forth by the Texas Department of Human Services, outlines the "Minimum Standards" on:
- Environmental Conditions (19.309), "If
deodorant is used for air-freshening Purposes" that there is
no contra-indication on the label of the product indicating that the
product should not be used in the presence of aged or ill persons,
and that devices, such as ozone generators, ultra-violet generators,
and smoke eliminators, must be approved by TDHS;
- Heating, Ventilation, and Air-conditioning Systems (19.321) "Air systems must provide for the induction and mixing of at least 10% outside fresh air into the facility, unless otherwise approved by DHS", (19.340) "All air-supply and air-exhaust systems must be mechanically-operated. The ventilation rates shown on the table in clause (xi) of this subparagraph must be considered as minimum acceptable rates and must not be construed as precluding the use of higher ventilation rates".
Since these Minimum Standards apply primarily to the facility construction, and "while no federal mandate exists on this issue", the standards fall short of meeting 21st Century "Critical Indoor Air Quality Measures" especially as they relate to the aging, frail and ill (in comparison to those IAQ initiatives that are being "voluntarily addressed" by school districts, in partnership with the Association of School Administrators, the EPA and the Department of Energy); These standards, then actually become the "Maximum Standards", as they apply to the elderly in Texas and the United States.
Return to topThe proposed project will develop the resources to evaluate the various environmental exposures faced by the elderly in Long Term Care Facilities. The Project Design Team will examine existing EPA / IAQ programs which are presently addressing similar issues in U.S. Schools. This program research will include, but not be limited to projects such as the "National Indoor Air Quality Tools For Schools" program and the Region 6 "Healthy Environments and Living Places for Kids", which with some modifications, may be adapted to incorporate issues specific to the Elder Care Environment, an environment that is subjected to Pollutants that come from:
OUTDOOR SOURCES - Polluted Outdoor Air (pollen, dust, fungal spores, industrial emissions and vehicle emissions); Nearby Sources (loading docks, dumpsters, unsanitary debris or building exhausts near air intakes); Underground Sources (radon, pesticides, leakage from underground storage tanks).
BUILDING EQUIPMENT - HVAC Equipment (microbiological growth in drip pans, ductwork, coils, and humidifiers); Improper Venting (of combustion products and dust or debris in ductwork); Non - HVAC Equipment (emissions from office equipment / volatile organic compounds, ozone, emissions from shops, labs, cleaning process).
COMPONENTS / FURNISHINGS - Components (microbiological growth on or in soiled or water -damaged materials or furnishings); Dry Traps (that allow the passage of sewer gas); Materials (containing volatile organic compounds, or damaged asbestos, and materials that produce dust particles, emissions from new furnishings or flooring).
OTHER INDOOR SOURCES - (laboratories, arts and crafts areas, copy/print areas, food preparation areas, smoking lounges, cleaning materials, emissions from trash, pesticides, odors and volatile organic compounds from paints or adhesives, occupants with communicable diseases, office materials such as dry-erase markers and similar pens or markers, insects and other pests, and personal care products).
Return to topThe proposed demonstration project will set, as its "Benchmarks" to address, through research-based planning and program design, the EPA Aging Initiative's three-pronged priorities for the National Agenda on the Environment and the Aging (Which evolved from "The Differential Susceptibility of Older Persons to Environmental Hazards" workshop, as convened in 2002 by the National Academies of Sciences).
- To prioritize and study environmental health threats to older persons;
- To examine the affect that a rapidly growing aging population might
have on our environment;
- To encourage older persons to volunteer in their own communities
to reduce hazards and protect the environment.
The Project will be implemented through the Bexar Area Agency on Aging / Ombudsman Program, of the Alamo Area Council of Governments in San Antonio, Texas.
Established in 1967, the Alamo Area Council of Governments (AACOG) is a voluntary association of local governments and organizations that serves its members through planning, information and coordination activities. The agency is also designated as the regional clearinghouse that reviews and comments upon grant applications submitted to state and federal funding by organizations throughout its 12 county region. AACOG programs address critical issues, such as air quality, community revitalization, criminal justice, housing, human services, transportation, and workforce development.
Ombudsmen are Advocates for Elders' Rights:
| During Lyndon B. Johnson's presidency, the Older Americans Act of 1965 became law and in 1978 Congress amended this Act to establish the Ombudsman Program. |
The AACOG / Bexar Area Agency on Aging Ombudsman Program is composed primarily of Volunteers. The program is administered by the Managing Local Ombudsman, which supervises the Certified Volunteer Ombudsmen, Staff Ombudsman and Assisted Living Special Projects Ombudsman. The program staff is responsible for recruiting and training the volunteers, and educating others on the rights of residents. A specialized training program, Certified by the Texas Department on Aging, educates the volunteers on how to do their job.
Ombudsmen are extraordinary volunteers, that come from all walks of life, and bring with them a vast array of "life's work experience". Many are retired and/or active nurses, former nursing home administrators, teachers, military personnel, religious and civic leaders, homemakers, business executives. The common thread that brings these dedicated volunteers together is the desire to want to make a difference in the level of quality of care and quality of life for our community's elderly.
Ombudsmen visit the elderly in Nursing Homes and Assisted Living Facilities, and frequently are the only visitors or source of contact with the outside world for a resident. Volunteer Ombudsmen develop trusting relationships, advocate for quality of life and quality of care of the residents, and assist in the development of resident and family councils.
The BAAA Ombudsman Program will expand on its successful community networking with the Elders' Advocacy Network:
- Which represents a planned series of aging advocacy workshops, presented
by the AACOG / Bexar Area Agency on Aging.
- The E.A.N. goal is to offer scheduled monthly informative presentations
and forums, addressing the training needs of long-term care providers
and community advocates, by networking with local, state, and federal
elder care practitioners.
- To ensure that collaborative strategies are designed to provide
the best quality of life and care for the elderly in our community.
- The purpose of these regularly monthly scheduled public outreach
sessions is to expand the avenues available for resource development
for long-term care providers, community stakeholders, and family member/caregivers.
- Network participants include 54 Nursing Homes and 112 Assisted Living Facilities, Hospitals, Personal Care Homes, Home Health Care Providers, Military/Veterans Retirement Homes, City of San Antonio Senior Nutrition Centers, Adult Day Care Centers, and Residential Care Homes from the AACOG Urban and Rural Region.
In addition to the Elders' Advocacy Network, the Project will solicit input from / but not limited to and including professional stakeholders in the field of aging and health, mental health associations, long term care regulatory and adult protective services agencies, as well as academics and others.
The Project will collaborate with a special Aging Initiatives Committee from the Texas Health Care Association (composed of nursing home administrators and health science professionals), which combined with the Elders' Advocacy Network and other Stakeholder organizations, will participate in a series of Focus Group meetings, to design the necessary strategies and implementation instruments necessary to:
- Conduct Long Term Care Facility and participants Needs Assessments;
- Distribute EPA Aging Initiative IAQ outreach / communication materials
to aid in the education of nursing home and assisted living center
management and family stakeholders;
- Integrate interior air quality as an integral part of the overall
maintenance of the LTC Facilities;
- Purchase equipment that improves interior air quality;
- Develop "Voluntary" policies and administrative LTC Facility
procedures that address animals in the elder living environment, upholstered
furniture, use of floor coverings, housekeeping, use of space and
new construction and remodels;
- Conduct a semiannual evaluation of interior air quality issues / progress.
Nursing Homes, in particular, have special characteristics generally not shared by other public facilities and office buildings. Many of these facilities, including the brand new ones, were not designed with good interior air quality in mind. Shrinking construction budgets, and rising costs of staffing and operations, anticipated cuts in Medicaid Funding, work to the detriment of Indoor Air Quality, as owners and operators of these facilities trim expenditures by deferring critical maintenance and repairs. In addition facility personnel may simply be unaware of the effect that certain housekeeping and maintenance procedures have on Indoor Air Quality.
Once the Project Methodology has been created to assess these environments, the Bexar Area Agency on Aging Ombudsman Program will establish a "Model Program" within its jurisdiction. The Model will provide, technical assistance, systems, and tools on:
- Collecting and disseminating information that supports the National
Agenda on the Environment and the Aging, evidence-based research and
Best Practices, as collected through its repository function;
- Convening meetings, workshops, trainings, conferences, etc. on Long
Term Care Facility / Indoor Air Quality Issues;
- Coordinating regional replication activities, as exemplified by
the Model Program;
- Providing technical assistance in planning and program design, as
well as monitoring regional Program Replication progress;
- Developing a consultant database resource and provide access to
Model Program replication stakeholders;
- Access, availability, and promotion of current, reliable, and newsworthy
information on successes of replication activities;
- Provide access to web cast presentations, forums, and meetings both
live and archived on the Environment and the Aging strategies;
- Plan and implement initiatives that will promote the efficient use
of organizational resources to achieve optimal performance and bring
state-of-the-art practices to the transportability and replication
process and service its institionalization.
- Identify creative resources to provide IAQ improvements, especially when energy savings can be realized.
PROGRAM FUNDING AND RESOURCE DEVELOPMENT are paramount to successful transportability and replication efforts. Therefore, Model Program innovators will focus on resources from various local, state, federal, and private sector agencies, in developing a strategy for Environmental Health Protection for the Elderly.
This strategy will certainly include collaborative opportunity resources such as:
- The Energy Efficiency and Renewable Energy Clearinghouse (EREC)
- Clean Cities
- The President's Million Solar Roofs Initiative
- The State Energy Program
- EPA's Energy Star Buildings
- Rebuild America
- Energy Service Companies (ESCO)
- Quality Zone Academy Bonds (QZABs) for areas such as Empowerment
Zones / Enterprise Communities (EZ/EC)
This Proposed Project's Vision is to address an unmet need in protecting the health of Older Americans. It encompasses the three priorities set-forth in the National Agenda on the Environment and the Aging. The Project's Goals and Objectives center on improving Indoor Air Quality for the Elderly residing in Long Term Care Facilities. Upon completion of the Planning, Research, and Design Process, Project Developers propose to implement a research-based "Best Practices" Model Program, that will provide access for future Regional Transportability and Replication. Thereby incorporating and expanding on the successful Program Design created through the initial Planning and Research Process, of this IAQ based multidisciplinary and crosscutting model which meets the NAEA priorities.
It is conceivable to expect that by utilizing and expanding on the Regional Replication efforts of the Program Model, that Program Transportability can be achieved throughout the United States in a manner which will make training, education, media and information equally accessible throughout all 50 states, reaching all populations and stakeholders.
Working with the identified Long-Term Care Network, and the project's strategic partners and stakeholders, the Bexar Area Agency on Aging / Ombudsman Program, will implement programs that generate a multigenerational / sociocultural approach towards creating and implementing Indoor Air Quality Measures that are conducive to the improved Quality of Life, and Health Care of the Elderly in Long Term Facilities.
This Best Practice Replication Model will be provided through established linkages to the National Aging Network:
- DHHS;
- Administration on Aging;
- Nine (9) Regional AoA Offices (Indian Organizations, National Aging
Organizations);
- State Units on Aging (State Advisory Councils, Governors & State
Legislatures);
- Area Agencies on Aging (Area Advisory Councils, Unites of Local
Government, Education Institutions, Research Institutions);
- Local Service Providers (Multipurpose Senior Centers, Community-based Services, In-home Services, Institutional Services, Nutrition Services, Health Districts, Centers for Health Care Services, etc.).
Return to top
TALKING POINTS
"A Right to Breathe Better and Longer"
Older Americans spend up to 100% of their time indoors where pollutant levels often exceed from 2-5 times, and are occasionally more than 100 times higher than outdoor levels.
Environmental Risk indoors
includes exposure to air toxics,
hazardous chemicals, water contaminants,
temperature extremes, carbon monoxide,
molds, second hand smoke and pesticides.
NEEDED is a project which will evaluate the cumulative environmental threats from all media indoors and offer a plan to prevent potential existing and future exposures to the elderly.
"Currently, there are no programs that develop environmental quality of care, specifically addressing the quality of life and quality of health care for the elderly".
The Elderly residing in Long Term Care Facilities, have been historically subjected to poor indoor air quality conditions.
Preliminary research, by the Bexar Area Agency on Aging / Ombudsman Program, indicates that the main factor contributing to these poor Indoor air quality conditions;
Is the fact that most of the Nursing Homes in Bexar County were built in the late 60's and 70's. An opinion expressed by a Life Safety Code expert, is that these facilities are just plain "TIRED BUILDINGS", whose Heating, Ventilation, and Air-conditioning systems and building structures are aging, and are in dire need on renovations.
(This case can be made for most Nursing Homes around the state and U.S.),
The Nursing Facility Requirements for Licensure and Medicaid Certification, set forth by the Texas Department of Human Services, outlines the "Minimum Stadards"
MOST GLARING:
Environmental Conditions (section 19.309)
The use of deodorants is for air-freshening Purposes that there is no contra-indication on the label of the product indicating that the product should not be used in the presence of aged or ill persons, and that devices, such as ozone generators, ultra-violet generators, and smoke eliminators, must be approved by TDHS;
Heating, Ventilation, and Air-conditioning Systems (section 19.321)
Air systems must provide for the induction and mixing of at least 10% outside fresh air into the facility, unless otherwise approved by DHS. This is unacceptable
(section 19.340) "All air-supply and air-exhaust systems must be mechanically-operated, that ventilation rates shown on table (11) of that subparagraph must be considered as "minimum acceptable rates" and must not be construed as precluding the use of higher ventilation rates.
Since these Minimum Standards apply primarily to the facility construction, and "while no federal mandate exists on this issue", the standards fall short of meeting 21st Century "Critical Indoor Air Quality Measures" and actually represent the "Maximum Standards", as they apply to the elderly in Texas and the United States.
In comparison, the IAQ initiatives that are being "voluntarily addressed" by U.S. School Districts, in partnership with the Association of School Administrators, the EPA and the Department of Energy, set an exemplary precedence, on how government agencies and local stakeholders can work together to ensure safe and comfortable indoor environments for At-Risk Populations.
The Bexar AAA Ombudsman Program is proposing a demonstration project, which will set as its major "Benchmarks" to address, through research-based planning and program design, the EPA Aging Initiative's three-pronged priorities for the National Agenda on the Environment and the Aging.
A product of "The Differential Susceptibility of Older Persons to Environmental Hazards" workshop, as convened in 2002 by the National Academies of Sciences).
- To prioritize and study environmental health threats to older persons;
- To examine the affect that a rapidly growing aging population might have on our environment;
- To encourage older persons to volunteer in their own communities to reduce hazards and protect the environment.
This Project's Vision is to address an unmet need in protecting the health of Older Americans. The Project's Goals and Objectives center on improving Indoor Air Quality for the Elderly residing in Long Term Care Facilities.
Upon completion of the Planning, Research, and Design Process, Project Developers propose to implement a research-based "Best Practices" Model Program.
It is conceivable to expect that by utilizing and expanding on the Regional Replication efforts of the Program Model, that Program Transportability can be achieved throughout the United States in a manner which will make training, education, media and information equally accessible throughout all 50 states, reaching all populations and stakeholders.
This can be achieved by working with the Long-Term Care Network, and the project's strategic partners and stakeholders, through programs that generate a multigenerational / sociocultural approach towards creating and implementing Indoor Air Quality Measures that are conducive to the improved Quality of Life, and Health Care of the Elderly in Long Term Facilities.
This Best Practice Replication Model will be provided through established linkages to the National Aging Network:
- DHHS;
- Administration on Aging;
- Nine (9) Regional AoA Offices (Indian Organizations, National Aging
Organizations);
- State Units on Aging (State Advisory Councils, Governors & State
Legislatures);
- Area Agencies on Aging (Area Advisory Councils, Unites of Local
Government, Education Institutions, Research Institutions);
- Local Service Providers (Multipurpose Senior Centers, Community-based
Services, In-home Services, Institutional Services, Nutrition Services,
Health Districts, Centers for Health Care Services, etc.).
NOTE:
The development of this Demonstration Project Concept is subject to the successful attainment of Capacity Building Funding. Interested agencies or private-sector underwriters that would like to offer information on possible funding opportunities, please contact:
Nick Monreal, Jr.
Managing Local Ombudsman
Long Term Care Services
Bexar Area Agency on Aging
Alamo Area Council of Governments
8700 Tesoro Drive, Suite 700
San Antonio, Texas 78217
(210) 362-5236 or email at: nmonreal@aacog.com
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