New IAQ Regulations Being
By Robin &Audrey
Barrett, Healthy Homes Consulting
UPdate Summer 1995
I am going to take a slight tangent on a building related issue that will
effect all of us. The Nova Scotia Government is in the process of
developing regulations through the Department of Labour on Indoor Air Quality
Regulations for non-industrial workplaces.
In the past
it made no difference whether the building was a school or a steel plant
the air quality requirements were the same. The legislation did not
take into account the age or health of the people who would be working
in the building. To make matters worse, the guidelines adopted by
the government were often interpreted to mean “if you are below these threshold
limit values you are in compliance, so don’t worry.”
in the guideline’s introduction including “Such workers may not be
adequately protected from adverse health effects from certain chemicals
at concentrations at or below the threshold limits.” were seldom quoted.
Worst of all, the current and even proposed legislation does not give any
protection to non-employee occupants in the building. This means
that a child in a school or a patient in a hospital is not protected by
can even be used to prevent students, parents or patients from being part
of the occupational health and safety committee. Some schools have
invited parents to become part of the occupational health committees as
they see them as a source of additional information.
have bluntly stated that the legislative objective of the Occupational
Health and Safety committees is for the workers only and having a parent
on a school’s committee is not appropriate. Things obviously need
changing and now is your opportunity to help.
Due to the
detailed nature of the legislation there is only enough room to cover the
highlights. I have compiled a short list of comments which fit in
three categories. For more information request a copy of the draft
legislation. SEND IN YOUR COMMENTS!
your opportunity to change the future of this province. Take advantage
of it as the regulations may not be changed for another twenty years.
The Government of Nova Scotia needs to know what you feel is important.
non-consensus issues which have yet to be resolved. They need strong
support or innovative solutions to get these passed.
Non-Consensus Item “A”
What carbon dioxide level
1000 ppm was
suggested but building owners claim that this is not practical for older
non-mechanically ventilated buildings and suggest a level of 2000 ppm.
My own biased opinion is that
there is some truth to what they say, but carbon dioxide can be an indicator
of other problems if not a major concern in itself at these levels.
My suggestion is, if a building does not meet the 1000 ppm it should have
a total volatile organic compound scan (TVOC) once in every season for
the first year tested by an independent tester.
If these levels
are below the target level in “Item C” the level of 2000 ppm for carbon
dioxide should be acceptable as long as there are no changes in the building
such as the type of work, renovations or other factors which would impact
on the air quality.
Non-Consensus Item “B”
Setting exposure limits
standards for indoor air quality
There were four suggestions put forth,
none of which people can agree on.
1) 1/10 ACGIH TLV’s (that means
1/10 the current standard)
2) 80% of occupants are satisfied
with comfort and the applicable TLV’s are obeyed (basically the same as
the current standard)
3) whatever is the lowest reasonable
practicable level (cost/benefit taken into account) in each individual
4) A level at which no adverse
health effects occur to an employee in the particular workplace.
is too complex to cover here. It would be best to read the regulations
or I could fax you basic comments on it.
Non-Consensus Item “C”
Exposure limit for Total
Volatile Organic Compounds
TVOC action level 5 mg/m3
TVOC target level 1 mg/m3
about the cost of routinely monitoring TVOC’s at the target level.
The action level was thought to be acceptable.
is unless there is a major source of volatiles used in the building monitor
for Carbon dioxide (which is inexpensive) and only require TVOC monitoring
if the Carbon dioxide goes over 1000ppm (back to issue “A”). I suggest
the TVOC levels be taken from the work done in Europe by Lars Molhave:
0 – 0.16 mg/m3 No-effect level
0.2 – 3.0 mg/m3 Some effects may exist
3.0 – 25.0 mg/m3 Discomfort is expected
>25 mg/m3 Toxic effects may appear
and use TVOC target level 0.2
mg/m3 in conjunction with carbon dioxide to help determine the frequency
of testing in areas where VOC’s are not commonly used in the work space.
any workplace that was not scent-free would fall under the category of
an area where VOC’s are commonly used and have to be tested regularly.
I have likely passed the boundary
of acceptability on this issue and suggest you make up your own recommendation
because those that stretch things too much tend to have less effect.
Non-Consensus Item “D”
Complaint procedure and
The big stumbling
block here is what do you use as a yardstick. Any levels set during
this joint process could result in liability to the owner/employer if the
levels identified as those which should be achieved turn out to be unobtainable
with the current building design. The proposed approach could make
the owner/employer commit to air quality levels before they know what they
are dealing with.
use the levels suggested in “A” and “C”. If it is bad, it is bad,
but if a building owner commits to a better than achievable level due to
ignorance, what happens then?
Non-Consensus Item “E”
Thermal conditions for
Just how hot,
humid or dry is reasonable for existing buildings. You are on your
The second section covers items
AEHA put forth as areas they would like to see incorporated in these regulations
that are not in the draft regulations. These items need immediate
action to keep them alive.
The regulations should include
non-employee occupants of the building as they often spend equivalent amounts
of time in the building as employees and there is no parallel legislation
to protect them.
Employers and employees should
have the right to perform air quality tests at any time without advanced
notification. Some leases will not allow this and advance notice
gives unscrupulous building operators an opportunity to operate the building
in a non standard way during testing to prejudice the results.
Reporting of Infractions
Anyone performing air quality
inspections or testing must report any infractions of the labour laws to
the Department of Labour.
Access to Information
Anyone working in a building or
who is in a building for more than 20 hours per week should be able to
access any non-compliance reports which the Department of Labour has received
about that building.
Posting of Signs
Potential health hazard signs
should be required at the entrance of buildings when hazards such as pesticide
spraying, renovations etc. are taking place.
An indoor air quality ombudsman
or independent auditor should be established with an indoor air quality
The third section is issues that
were not incorporated but were acknowledged by the working group.
These issues need additional support to ensure they are acted upon.
1. Formation of an interdepartmental/intergovernmental
committee on IAQ issues.
2. Individuals doing air quality
inspection and testing should be certified.
Send your comments to:
Review Support Program
Nova Scotia Occupational Health &
Safety Advisory Council
P.O. Box 697
or fax to:
For those dedicated souls who
want to review the draft legislation you can receive a copy by calling