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Submission for Discussion
Paper on Indoor Air Quality
The Nova Scotia Branch of the Allergy and Environmental Health Association has prepared the following comments on the Discussion Paper on Indoor Air Quality. We have many members who have been made ill by poor Indoor Air Quality and other members whose health is adversely affected by the air in public buildings. In order that these buildings be accessible to people affected by poor air quality and to prevent others from becoming disabled, we would like to see a combined approach of legislated regulations and non-regulated measures. We are pleased to have this opportunity to provide input based on our experience. 1) This problem is much broader than the scope of Labour Legislation because people who are not employees (for example school children and hospital patients) are affected by the air in public buildings. We suggest that a NS government interdepartmental committee as well as an interprovincial committee be formed by various government departments in order to cooperate in air quality issues. The following departments should be included: a) Department of
Labour
2) The Department of Labour should develop and administer Indoor Air Quality legislation for public buildings. Department of Labour Inspectors should insure the enforcement of regulations which require all employers and building owners/operators to take precautions to protect the health and safety of all those using the building. Complaints should be investigated by qualified personnel. The Department of Labour is the logical choice for providing this protection. A system of fines and penalties for noncompliance with regulations would be administered similar to regulation of industrial workplaces. 3) Air Quality Testers and Inspectors should be certified by the Dept. of Labour. Air Quality tests would be taken according to Dept. of Labour Protocols. Many variables affect the accuracy of Air Quality testing. Proper timing of tests and placement of test units requires training for accurate results. Tests must be taken under normal conditions. This means that the building must be functioning with the usual set of circumstances. (For example a school in the Valley had a mould problem. Testing prior to school opening showed almost no mould in the air. When the children returned in the fall, subsequent testing indicated extremely high levels under the normal operating conditions.) Certification must require both a written and a field examination. 4) Certified testers would be required to report test results which do not meet required safety standards to the Department of Labour. Testers who do not report such incidents to the Dept. of Labour would lose their license or certification. 5) Legislation should include the right to access for testing. It would be illegal to have lease clauses which interfere with air quality testing. Testing should not require prior notice. 6) Legislation should include public access to test results. There should be stiff penalties for withholding test data (one month is the maximum time required for lab reports) or misrepresenting test data. 7) All public buildings would be required to have certified maintenance staff and a Maintenance Log. The Maintenance Log would be produced on request of the Dept. of Labour for regular inspections or be available for public inspections. It would detail normal operating procedures, maintenance, renovations, changes in layout, and cleaning records. HVAC units should be operated according to manufacturers recommendations to maintain comfortable temperature, humidity, and required outside air. In many cases units are turned off at night and on weekends in order to save energy. This is done with no check to verify if there are people in the building at these times. The systems are often not started up early enough before people enter the building and there is not enough time to dilute the pollutants which accumulated during the “off” time. This tends to begin a cycle of poor air quality. 8) Responsibilities of Occupational Health and Safety Committees would be broadened to include the concerns of everyone using the building as well as the workers. The certified maintenance staff person should be a member of the Occupational Health and Safety Committee. 9) Indoor Air Quality regulations should require buildings to be safe for all people using them. It is our belief that public places should be safe. The ACGIH 8 hour Limits would not be reasonably safe for anyone who doesn’t meet the criterion of being a healthy male with an average body weight of 175 pounds. Public buildings such as schools, day care centers, nursing homes, and hospitals are used by people with reduced tolerance due to poor health and/or small size. There is no research on safe levels for children because it is unconscionable to test children with possible dangerous exposures. Since ACGIH Values are presently used, it amounts to uncontrolled testing of children. Hypersensitive individuals may be affected y lower levels because of age, genetic factors, medications, and previous exposures. It is difficult to determine the effects of exposure on hospital patients because of preexisting conditions. There is also inadequate data on the synergistic effects of simultaneous exposures. Studies showing the combined effects of two known health hazards indicate that much lower levels will cause problems. Examples
Modern buildings contain many biological contaminants, chemicals, and particles which could be producing a synergistic effect that makes very low level exposures dangerous. Based on the limited research available, it appears that synergistic effects from combined exposures can easily be over 10 times as dangerous as the single exposure. It is our belief that ACGIH Limits are not suitable for non-industrial workplaces for these reasons. Performance Standards should take priority over numerical standards with numerical standards being tested over an extended period of time as a way to verify conformance. 10) All renovations should be monitored as they have often been a major source of health problems. We suggest that Renovations be defined to include painting, caulking, roof tarring, replacement of flooring, structural changes to walls, fixtures, etc. Building occupants should be removed from the area being renovated and from the adjoining area. The “adjoining area” should be defined as the area sharing the same heating and ventilation system. The renovation area should then be controlled by a negative pressure system with an alarm. The certified maintenance person would be required to monitor the renovations to see that air quality remains good. 11) Sources of air contaminants should also be regulated. All public buildings should be smoke-free. Anti-idling laws should stop exhaust fumes from entering buildings. Perfumes, cleaning products, carpets, and other chemicals should be considered potential sources of poor air quality. 12) Potential Health Hazard Signs should be required in all public buildings. This would be similar to the microwave oven signs which warn people with heart pace-makers. Factors which affect Indoor Air such as pesticide spraying, renovations, cleaning of ventilation systems, etc. may constitute a health hazard to sensitive individuals. Employees who may be sensitive should be warned prior to potentially hazardous events. 13) Suggested Activities for the Dept. of Labour complimentary to Regulations. a) Annual Contest for the
building with the best Indoor Air
It is our belief that the benefits of good Indoor Air Quality for outweigh the cost of regulation. For the taxpayers of NS, there should be immediate and future savings in health care and workers compensation costs. For employers there would be higher productivity, improved employee morale, reduced costs for health care benefits and workers compensation contributions to compensate for higher heating costs. We do not think that CSA and ASHRAE standards which aim for 80% satisfaction with air quality are affordable. The 20% of building occupants who are unsatisfied could translate into 20% of the population requiring unnecessary health care, workers compensation, or disability pensions. We really can’t imagine the cost of such a future being acceptable to any government. Employers could anticipate lost productivity from 20% rates of absenteeism. Prevention of air quality problems will be much cheaper. #
by AEHA Committee
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