This issue 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.”
 
     Statements 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 this law.
 
     The regulations 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.
 
     Other schools 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!

      Now is 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.
 
     First the 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 is acceptable.
     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 workplace.
  4) A level at which no adverse health effects occur to an employee in the particular workplace.
     This issue 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
 Suggested:
 TVOC action level 5 mg/m3
 TVOC target level 1 mg/m3
     Employer concern about the cost of routinely monitoring TVOC’s at the target level.  The action level was thought to be acceptable.
     My comment 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.
     Of course 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 investigations
     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.
     You could 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 existing buildings
     Just how hot, humid or dry is reasonable for existing buildings.  You are on your own again.

AEHA Proposals

 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.

Non-Employee Occupants

 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.

Impromptu Testing

 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.

IAQ Ombudsman

 An indoor air quality ombudsman or independent auditor should be established with an indoor air quality information line.

 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
Halifax, N.S.
B3J 2T8

or fax to:
(902) 424-3239

 For those dedicated souls who want to review the draft legislation you can receive a copy by calling (902) 424-5420.