By: Judith Claudy of Fresh Air Services
In recent years, building owners have reduced energy costs by adding insulation and
tightening buildings. With rising energy costs, we have now reduced the amount of fresh air
that is supplied into our work spaces to one tenth of what it used to be. This has resulted
in less fresh air ventilation and now indoor air quality contaminants are trapped inside the
building as a result. These air contaminants have accumulated indoors to levels up to 100
times greater than outside. Occupant complaints and legal claims have grown at an alarming
rate. And now both government and industry are responding to IAQ issues.
OSHA has now proposed an Indoor Air Quality rule.
Congress has introduced legislative bills
EPA has established an IAQ division and clearing house for research and information. They
have even written educational material titled "Building Air Quality", which is an alliance
program, for voluntary compliance for building owners and outside industry.
Architects and Engineers have changed specifications to meet the growing interest of IAQ
Building Managers have developed cost-effective solutions to help satisfy long-term leases
and minimize the potential for law suits.
This is probably "What's Really Bothering You". In fact, you have probably read more about
Indoor Air Quality (IAQ) in the last 10 years than any other proposed rule. And according to
Joe Deer, former OSHA Agency Chief and his apparent heir Charles Jeffress, indoor air quality
is not high on their priority list. So, that means you are going to hear more! What can we do
to eliminate this ongoing growing concern without incurring unreasonable budget increases?
Simple! Act now!
What Is Required?
Management is now required to teach employees about IAQ concerns and implement some type of a
plan that will, at the minimum, teach us how to prevent Indoor Air Quality (IAQ) problems
before they occur. The ultimate industry goal should be to assist clients with implementation
of a simple IAQ program that really works.
First of all, this is not going to happen over night. A good IAQ plan is going to take one
year to complete. Today, you should be introduced to sources and cost-effective solutions to
IAQ problems. And, by following a simple IAQ program, you will be able to practice the pro-
active measures to good Indoor Air Quality that will provide a safe and healthy environment
for everyone in your work place, and you will learn how to provide improvements thus avoiding
The following seven simple tasks are recommended to begin implementation of an IAQ Plan for
managing the indoor air quality.
Air Filtration Improvement
Monitoring of required Fresh Air Ventilation
Cleaning & Maintenance of Outside Air Intake, HVAC Air Handlers & Ductwork, and Exhaust
Pollution Source Management
IAQ Testing and Documentation
Responding To Occupant Complaints
Ongoing History Reporting and follow up
The first priority for engineers must be placed on demanding experts that provide quality
service and pro-active indoor air quality management for their facilities. You won't find
out "What's Really Bothering You", or anyone else in your building with one-
spot check. It's
not always just one source that causes IAQ problems. Cleaning the AC system is not always the
solution to all IAQ problems, nor is random IAQ testing as the sole solution. It can be a
combination of one or many issues that will plague the engineer or owner that has to deal
with the employee complaint or litigation. Fresh Air Services IAQ consultant's environmenta
background comes out of a hospital infection control program 20 years ago. Patrick Moffett
(CHMM, REA, who is both an Industrial Hygienist and General Contractor, and is also a
California Registered Environmental Assessor), and Fresh Air Services as separate entities
but working as a team, recommend looking for the source, making recommendations, providing
remediation, and contracting with trained experts to assist with an ongoing IAQ program for
continued IAQ control measures.
History and The OSHA Proposed Indoor Air Quality Rule:
The OSHA Proposed Rule has a long history, with most of it never leaving the paper it was
written on. ASHRAE Standards are more than 20 years old. In fact, modern science of air
quality goes back 102 years. In 1895, ASHRAE predecessors adopted a ventilation standard
calling for 30 cubic feet per minute (cfm) of outdoor air per occupant in buildings. By 1923
this value was adopted into regulation by 22 states. However, in the same year, the New York
commission on ventilation permitted up to two thirds of this rate to be "recirculated" air in
schools. During the 1930s the lower rate was adopted elsewhere across the country, but what
became lost in translation is the two- thirds of cfm being recirculated air. Thus, a 10-cfm
outside air ventilation standard became the norm throughout the country from the mid-1930s
through the 1960s. The lower rate became the standard when in 1946 the American Standard
Building Requirements for Lighting and Ventilation (A-5.3.1) was published. Their membership
felt air quality perception was based on a means of reducing odors produced by persons, more
so than the need for building occupants to inhale fresh air.
1973 was the official year that shook many of the building engineers when they were faced
with the energy crunch, crisis and oil embargo. Just prior to the embargo, ASHRAE, along with
a committee from the American National Standards Association, was to produce and specify
new "minimum and recommended ventilation air quantities for the preservation of the
occupants' health, safety, and well-being", as outlined in Standard 62-1973. The revised
standard called for 5 cfm of outdoor air with two-thirds re-circulated air in lieu of outdoor
air for suitable control of both space temperature and particulate concentration in the
supply air. 62-1981 became the most referred to Standard for air quality and ventilation for
many years. Then the Standard changed with revision 62-1989, with the largest revision being
a 3-fold increase in the prescription minimum outdoor ventilation rate from 5 to 15 cfm per
person in the building.
From ASHRAE engineering standards being a foundation, the Proposed IAQ Rule became alive when
an Indoor Air Quality bill was drafted by Senators Waxman and Kennedy, who proposed
legislation in 1994 with Senate bill (H.R. 1994 and H.R. 1977). The bill appears to have far
reaching effects on the U.S. economy, but has not been enacted by the Senate or Congress.
While unions applauded the bill, building owners and managers fought the bill as written. It
contains restrictions and regulations on such topics as carbon monoxide and passive cigarette
smoke. OSHA then backed the proposed rule and introduced into the Federal Register (59 FR
15968-16039 on April 5, 1994), the same language which Senators Waxman and Kennedy proposed
for their bill on indoor air quality.
Currently, ASHRAE is attempting to resurrect parts of the OSHA proposed Rule through another
revision Standard 62. For part of the past two years, Standard 62 revisions have had a hard
time getting out of ASHRAE subcommittee. Peer and public review has bogged down both OSHA and
ASHRAE attempts to standardize an Indoor Air Quality Rule. We do not see either of these
organizations soon passing a standard that will greatly change current IAQ recommendations.
What To Avoid
The Indoor Air Quality Guidelines getting most of the public's attention are Litigation, no
Legislation driven. Courts are looking at sick buildings and their damaging health effects,
and they are awarding persons large sums of money in many cases. Over the past several years
many cases have involved settlements greater than $1,000,000 each. Persons can sue for
anything they feel is irritating or compromising their health. This includes leaving their
job site for work-related injuries due to poor indoor air quality.
How Will Hospitals Be Affected By The Indoor Air Quality Rule?
Hospitals already have their own set of IAQ Rules to govern medical buildings by. The
California Office of Statewide Health Planning and Development (OSHPD), part of the FREER
Manual, as revised January 14, 1997, as written:
All Acute Hospitals, Psychiatric Hospitals, Skilled Nursing Facilities and Intermediate Care
Facilities, must deal with environmental and indoor air quality pollutant issues, and when
there is a recognized problem, provide steps for both short and long-term correction.
In some instances, facilities already should have a minimum of 20 cfm of incoming air per
person. This air must be scrub through pleated or bag filters, allowing for clean air
exchanges, and sometimes, the air quality must be contained and eliminated from all its
potentially harmful indoor and outdoor exposures to airborne chemicals, toxins, vapors, and
pollutants which potentially can effect the patient setting or hospital employee and staff
work environment through HEPA filtration.
Medical facilities are already mandated by statutory authority through the State of
California Health Code Sections 129875 et. seq., along with county and state codes,
suggesting and mandating building engineers to develop ongoing criteria that permanently
protects the health and well being of all its building occupants and patient populations.
Recognizing that this is an engineering nightmare, and that in many hospitals and other
medical facilities indoor air quality violations are not easily noticed until someone becomes
ill, it is imperative that pro-active versus re-active, is the choice for preventative
measures . Through proper monitoring for HVAC cleaning and maintenance and through visual
inspections by building and mechanical engineers, along with visual observations of damaged
building materials, and finally through scientific measurements, management will recognize
indoor air quality issues, before they move to litigation.
On more than one occasion we have seen building concerns that required engineer's immediate
attention. If the building engineer does not heed those concerns, nosocomial and
opportunistic diseases and illnesses are known to result. Visual inspections of water
coolers, deterioration of internal insulation and contamination of HVAC equipment and
ductwork, excess moisture in the building envelope, bad air handling designs, closure of
dampers and vents, no humidity control in the air-conveyance system, potable hot water
systems, to high levels of carbon monoxide/dioxide have been reported as being the causation
for Legionella, Hypersensitivity pneumonitis. Additionally, Dirt and debris left in the HVAC
system has been a known source of Pontiac fever, and Aspergillosis affecting patients and
employees in hospitals and healthcare settings, and are not uncommon. A recent 1997 science
article reports currently there is "An Epidemic of Fungal Growth in Health Care Facilities."
Finally, building engineers already have their hands full with too much work and supervision.
They do not need to be bothered with all of these other issues management gives them. Yet,
indoor air quality is the large part of the breath and lifeblood of the building. Without
good indoor air quality, the building ceases to be functional as a medical facility. The
responsible building engineer will have in his or her pocket a trained and certified
specialist who can immediately assess and diagnose IAQ issues effecting their building.
So, Now What's Really Bothering You?
The occupants say the building is "What's Bothering Them!"
You say money? Budget? Realistically speaking, the cost of a complete Indoor Air Quality
Program is far below the cost of today's reports on IAQ litigation costs.
Outline for Implementing an Effective IAQ Plan
Article By: Judith Claudy-Fresh Air Services,