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Enforcement in New England

Federal Facilities Indoor Air

The past two decades have witnessed significant increases in requests for information concerning indoor environmental quality issues. While the U.S. Environmental Protection Agency (EPA) and the National Institute for Occupational Safety and Health (NIOSH) have addressed these issues for managers of public and commercial buildings, little has been suggested for Federal Facility (FF) managers. The goal of this brochure is to inform FF managers of potential concerns related with indoor environmental quality and to provide them with possible avenues for mitigating problems.

Overview

A healthy indoor environment is one in which the surroundings contribute to productivity, comfort, and a sense of well-being. The indoor air is free from significant levels of odors, dust, and contaminants; it is also well-circulated to prevent stuffiness and increase the air exchange rates. Temperature and humidity are equally important.

FF Managers should be recognized as leaders in the field of indoor environmental quality. They often encounter similar problems and/or situations that are normally associated with private office buildings. Thus, many of the same guidelines and procedures can be followed. Most problems can be mitigated using basic management strategies.

While FF vary greatly with respect to their operations, maintenance, and production capabilities, there are some indoor issues that are potentially common to most, if not all, FFs. In addition, some FFs will have their own particular indoor environmental problems that require special attention.

Why Worry About These Issues?

It has been shown through many studies that indoor work environments have a significant effect on building occupants' motivation, enthusiasm, and productivity while at work. A good indoor environment enhances occupant health, comfort, and helps to ensure that occupants are working under optimal conditions. To this end, EPA New England is incorporating IAQ management into the Partners For Change program, which addresses and mitigates problems. Furthermore, EPA would like to work with the Facility Manager or Environmental Coordinator in publicizing best management practices in internal newsletters, on letterhead, in marketing materials, and within the physical building itself.

Case Study

The spectrum of symptoms related to poor indoor air was well-documented in 1989 at EPA's own Waterside Mall Headquarters. Complaints ranged from insufficient air intake to carbon monoxide and fumes being drawn into offices to noxious vapors from new carpeting. In an EPA HQ survey, more than 60% of the employees who responded had complained of numerous ailments associated with the building. Health complaints encountered at this FF included headaches, fatigue, shortness of breath, eye, nose and throat irritation, nausea, and dizziness. Exacerbated cases of asthma, trouble concentrating, and allergic alveolitis were also associated with the poor indoor air. Pollutant concentrations in this indoor environment were at least an order of magnitude higher than were to be expected. Furnishings and carpeting were removed, all new equipment was aired out, improvements were made to the heating, ventilation, and air conditioning (HVAC) system, and the complex was re-roofed to prevent sources of biological contamination. Similar situations exist at other FFs. In particular, the Library of Congress, Department of Housing and Urban Development, and the Department of Transportation buildings had previous health concerns related to indoor air problems.

One of the more notable successes related to IAQ for Federal Facilities has been the prohibition of smoking, except in designated areas. The elimination of environmental tobacco smoke (ETS), as directed by Executive Order 13058, in the workplace is beneficial for all occupants of any Federal Facility.

Integrate All Environmental Components

Temperature and humidity must be appropriate for the season, clothing, and activities of the occupants. There must also be enough light to illuminate work surfaces without creating glare. Noise levels should be kept to a minimum so as not to interfere with normal activities. Water, sanitation, fire protection, hazardous wastes, asbestos-containing materials, integrated pest management (IPM), and other factors affecting health and safety need to be well-planned and properly managed. In addition, a good indoor environment does not have to compete with other building management priorities; in fact, it can enhance them. For example, the efficiencies gained by keeping the (HVAC) system clean and better controlled both enhance the indoor environment and reduce energy costs. This pro-active integration strategy is meant to bolster the comprehensive pollution prevention (P2) plan which should already exist at every FF.

Preventative Measures

Building Air Quality (BAQ), and its supplement, the BAQ Action Plan*, emphasize ways of changing how managers operate and maintain their building, not increasing the amount of work or cost of maintaining the building. These next seven steps provide a basic management strategy that can be followed to mitigate problems. For mitigation measures pertaining to specific pollutants, contact EPA or check out our website.

Step 1: Designate an Indoor Air Quality (IAQ) Manager– This Manager is responsible for being the central contact within the building and executing the remaining six steps. This person should be given authority to make decisions and implement improvements. The IAQ Manager should have a good understanding of the building's structure and function and should be able to communicate with facility personnel and owners, if needed, about IAQ problems. The designated person could possess knowledge from any number of disciplines, including engineering, environmental science, industrial hygiene, or public health. It should be noted that outside assistance from other specialists may be necessary under certain conditions.

Step 2: Develop an IAQ Profile of the Building– Purpose is to gain a comprehensive understanding of the current IAQ situation, including factors that could influence IAQ. The profile should feature the building's structure, function, and occupancy which impact IAQ. In addition, this entails identifying and reviewing previous documents that should exist for the building, such as blueprints and operating instructions, and conducting a walk-through inspection to assess the current IAQ situation.

Step 3: Educate Building Personnel About IAQ Management– Purpose is to identify and educate staff about IAQ issues so that they can become valuable agents in identifying, preventing, and solving problems.

Step 4: Develop and Implement a Plan for Facility Operations and Maintenance– IAQ can be affected both by the quality of maintenance and by the materials and procedures used in operating and maintaining the building's components. Keeping IAQ in mind when planning for operations and maintenance is a good way to prevent IAQ problems. This includes upgrades and/or cleaning of HVAC and energy recovery systems as well as general house- keeping duties. Having written procedures, knowledge of equipment and products, good purchasing practices, and a preventative maintenance plan aid in reducing IAQ problems.

Step 5: Manage Processes with Potentially Significant Pollutant Sources– The purpose is to control potential contaminant sources within a building during special activities. These could include: remodeling and/or renovation, painting, pest control, shipping and receiving, and smoking.

Step 6: Communicate with Occupants– The object is to open the communication lines between building owners, managers, and occupants so that they all may help in eliminating IAQ problems.

Step 7: Establish Procedures for Responding to IAQ Complaints– This ensures an adequate and timely response to occupant complaints and also prevents small complaints from becoming major health or comfort problems.

*These measures have been taken from the BAQ Action Plan.

Mitigation Measures

  • managing sources through removing or reducing the source, sealing or covering the source, or modifying the environment;
  • improving ventilation to provide outside air to occupants and to dilute and/or exhaust pollutants;
  • improving air filtration to clean air from outside and inside the building; or
  • controlling occupant exposure through administrative approaches.

In addition to these general strategies, ‘best practice' preventative and/or mitigation measures that can be followed are found in ASHRAE publications, specifically:

  • ASHRAE Standard 62 (1989), Ventilation of Acceptable Indoor Air Quality
  • ASHRAE Standard 55 (1992), Thermal Environmental Conditions for Human Occupancy
  • ASHRAE Guideline 1 (1989), Guideline for the Commissioning of HVAC Systems

Training

It is necessary for managers and workers to understand how to work safely and efficiently. Managers, supervisors, and workers have an obligation to ensure that all persons have a safe workplace. It would be particularly useful for EPA staff if we knew of any areas where FF managers would like additional training and/or assistance. These sessions are meant to generate ideas for pollution prevention techniques, exchange information, and envision new partnerships.

Partners For Change

Under the EPA award program Partners For Change (PFC), EPA is demonstrating that voluntary goals and commitments which go beyond regulatory compliance achieve real environmental results in a timely and cost-effective way. The PFC Program encourages responsible and pro-active environmental practices, including the development of a permanent IAQ plan. The program ensures that FFs which achieve their goals are recognized in the community for their efforts. For more information, visit our website at: www.epa.gov/region01/

Useful EPA Publications:

  • Building Air Quality--A Guide for Building Owners and Facility Managers -by EPA/NIOSH, 1991
  • Building Air Quality Action Plan -by EPA/NIOSH, 1998
  • The Inside Story: A Guide to IAQ -by EPA

To order copies of these or other publications related to IAQ issued by EPA:
Indoor Air Quality: Publications and Resources

Region I Customer Call Center
1-888-372-REG1

US EPA Region I Contacts:
Mary Beth Smuts, Ph.D. Toxicologist, IAQ Coordinator: (617) 918-1528
Eugene Benoit, Environmental Engineer: (617) 918-1639
Anne Fenn, Federal Facility Program Manager: (617) 918-1805

Professional Organizations:

American Industrial Hygiene Association Exit EPA. Click for disclaimer.
2700 Prosperity Ave., Suite 250
Fairfax, VA 22031
(703) 849-8888
Fax: (703) 207-3561

The American Society of Heating, Refrigeration and Air Conditioning Exit EPA. Click for disclaimer.
1791 Tullie Circle, N.E.
Atlanta, GA 30329
(404) 636-8400
Fax: (404) 321-5478

Check out these websites:

Indoor Air Quality Chart

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