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Progress Observed at Walter Reed’s Worst Building
By Steve Sauer
Two of Walter Reed’s military administrators and a spokesperson from the Army Medical Center’s public affairs office guided IE Connections on March 20 through a tour of vacated rooms, some of them newly restored and others untouched, at Building 18. The tour also included a walk on the roof, which had already undergone some minor patchwork but was going to undergo a full repair in the coming weeks, according to Master Sgt. Gary Rhett, building manager.
Evidence of water intrusion remains in the untouched room 416, where
a leak from the ceiling drips onto a table below it. Elsewhere in
the room is a water-stained lampshade. This room and all other
occupant rooms inside the former hotel building were vacated late in
February, after a series run in the Washington Post beginning on
Feb. 17 depicted poor indoor environmental conditions and a trend of
neglect mostly within Walter Reed’s Building 18.
The tour began in room 205, with the wall the Post had identified as
full of “black mold” when it was occupied by a recuperating Army
specialist. The Army had moved that occupant, Spc. Jeremy Duncan, to
a new room after the Post notified them that it intended to publish
the series. Six days after the first story appeared, freshly painted
rooms in Building 18 were made available to reporters, but
renovations would close the building to all occupants by the end of
February.
Rhett offered IE Connections entry into any room inside the
four-story building. When asked to provide access to a mechanical
room at Building 18, the other military tour guide said there was no
such area. “Because most of these [rooms] have in-room HVAC systems,
there would not be a mechanical room,” said Col. Mike Doherty, who
is Walter Reed’s director of safety, health and environment.
What Went Wrong
IE Connections: Is this building considered a
hospital?
Col. Doherty: It’s part of the garrison.
Master Sgt. Rhett: It’s a dorm.
Col. Doherty: So, actually, we’re not under the
control of Colonel [Virgil] Deal, the hospital commander. It comes
under the control of Colonel [Peter M.] Garibaldi, who is the
garrison commander. And then, it is essentially given to the
brigade, who then manages the operations within the building because
they’re the ones that are occupying it. Each building has a senior
building occupant, or a building manager in the case of Master
Sergeant Rhett here.
IEC: So then this building – is it actually exempt
from hospital standards, JCAHO standards?
Col. Doherty: I believe it would be because you’re not
performing any kind of treatment. JCAHO normally looks at treatment.
Now if this were a nursing home, for example, that would fall under
those kinds of regulations. It’s really essentially a dormitory
where it’s, you know – with the caveat that the personnel here were
primarily wounded warriors who were ambulatory, that could walk to
their patient rooms.
Master Sgt. Rhett: They’re in the final stages of
[their recuperation].
IEC: Was there such a thing as a baseline building
study ever performed in here to figure out things like the direction
of the airflow, pressure relationships between indoor and outdoor
areas?
Master Sgt. Rhett: I don’t know of any, and I’m newly
assigned as well. ...
Maintenance Contracts
IEC: February 4 was the official change in maintenance
at the Medical Center. Did that affect this building? I believe
that’s when IAP Worldwide Services stepped in.
Col. Doherty: On February 4, 2007, they then became
responsible for the maintenance of all of the garrison’s buildings,
with the exception of the hospital, the Armed Forces Institute of
Pathology, and the Walter Reed Institute of Research – all of those
have their own particular contractors for maintaining the building.
They also have separate janitorial contractors. Yes, this building
would then have been maintained, and minor repairs are done by IAP.
Prior to that, it was the directorate of public affairs.
IEC: You made a distinction there with minor
[repairs]. What about major repairs?
Col. Doherty: Major repairs, you’d have to contract
out.
IEC: For instance, the roof.
Col. Doherty: The roof repairs, right. That brings in
the Corps of Engineers because that’s beyond the scope of what IAP
has to do. Even when DPW [directorate of public works] managed this,
their workforce was primarily oriented toward building maintenance,
with some minor repairs – usually up to about $2,500 and at a
certain limit on man hours. Anything bigger than that ... For
example, if somebody punched in a wall, that would be within the
scope of what IAP or DPW would do. However, if a car crashed into
the building and demolished a portion of it, you would bring a
contractor in order to repair that.
IEC [pointing]: This hole in the wall ...
Col. Doherty: This could be done by IAP.
IEC: What caused the Army to want to seek out a
private company to handle maintenance?
Col. Doherty: It was really a DOD [Department of
Defense], congressionally mandated requirement under A-76, so it’s
above our pay grades. It was not a decision by Walter Reed per se.
It was mandated back in – I guess it was 2001 ... So, you go through
all of these procedures to determine workload and everything else
like that, [and] you arrive at an estimate for what the most
efficient organization under the government would be. The contractor
also determines what the workload is and what their existing staff
and all this other sort of stuff would be, and then you come up with
two estimates in cost. And it basically comes down to whoever the
lowest bidder is at that point gets the award. I believe that the
contractor had to achieve at least something like a 10 percent
difference. ...
IEC: Is it true that in the last three years of
getting this [maintenance] contract, “repairs went undone as the
nonmedical staff shrank from almost 300 to less than 50”? That was –
Associated Press reported that yesterday [March 19].
Col. Doherty: I couldn’t really say one way or the
other since I work in directorate of safety, health and environment.
DPW would probably have to address that. ... It is safe to say,
though, that as this – once the announcement was made that a
contractor would take over, a number of individuals began looking
for work elsewhere. We were, however, authorized by Major General
[George W.] Weightman [who had served as commander of the Medical
Center until he was fired on March 1] to come up with a contract
bridge that we could bring in under the Fed Source contract
temporary people to fill the roles of those government employees who
left. And in several instances, that was done. But I know that the
workforce did shrink, simply because we couldn’t keep up with
replacing those people that quickly.
IEC: Somebody mentioned to me the U.S. Army Center for
Health Promotion and Preventive Medicine. They have staff in
engineering and industrial hygiene [among other fields]. Was there
anything that their personnel might have been able to do to assist
in providing a consultation in environmental health risk?
Col. Doherty: Potentially, they could have. [Hands a
stapled printout of the “Army Facilities Management Information
Document on Mold Remediation Issues,” published February 2002.] This
is the CHPPM technical guide on mold issues. We, on the
environmental side, we utilize CHPPM for hazardous waste training.
And so they could provide services like that. If a request had been
made, yes. ...
Improving IEQ
IEC: What will the role of IAP be, or what is it now?
Col. Doherty: They’re still the base operations
contractor. So when this building goes back online, it will be their
responsibility to once again do the maintenance inside the building.
IEC: And then the [U.S. Army Corps of Engineers’]
function is ...
Col. Doherty: They do the contract awards. They also
will receive a contract, so when the roof contract, they would have
an inspector who would come in and inspect the work, make sure it is
done to the contract’s specifications. ... We do get unsolicited
offers from time to time. I just got one from a company that is
promoting ultraviolet light as a means of mold control, so things
like that come in, but again, if I wanted to do that, I simply can’t
go to that company, select them and bring them on board and do that.
I have to go through a competitive process. So that, let’s say, a
competing firm with a different – and we, we don’t always do scope
of work anymore, we issue a performance work statement, which says
the needs to conform to this level. I don’t, we’re no longer
specifying it has to do this, this, this, this and this, in exactly
that order. It says this is the performance standard you have to
meet – I don’t care whether it’s ultraviolet light, whether it’s
ozone, you know, whether it’s chlorine, you know. Whatever that
standard is, this is the standard you have to meet to remain
protective of human health in the environment.
IEC: Do you know what’s being done to fix the roof [at
Building 18]?
Col. Doherty: I don’t know.
Master Sgt. Rhett: Exactly – they’re replacing the
whole roof. I don’t know what materials are – we don’t have that
information. ...
IEC: Do you know what the timeline would be for that,
for fixing the roof?
Master Sgt. Rhett: We’re looking at approximately
three or four weeks.
IEC: You said earlier that that contract was awarded
through the Army Corps to some private company?
Master Sgt. Rhett: That is correct.
IEC: One of you addressed earlier about sampling that
was done [in a second-floor room]. Do you know who actually did
that?
Col. Doherty: We have an industrial hygiene section
that can perform some sampling for that. They came in and did a
survey on the first of March, and that’s [hands a one-page
double-sided sheet dated March 12] the results of their survey. And
of course a lot of things were done in the meantime. I also have
under my control, the safety office, they did an inspection on the
26th of February [hands a one-page double-sided sheet dated March 9
that was clipped to 28 black-and-white photographs], and that
addresses the findings they have which were, again, primarily
oriented toward safety, so they dealt with more issues than just
mold. They’ve since re-inspected this facility, and the deficiencies
that were identified on the 26th of February have all been
corrected. ...
IEC: In the actual mold removal work, would that be
the same people doing that who were taking the samples?
Col. Doherty: Not necessarily, but if I were a
contractor I would probably have someone verify, or I might bring an
independent on board with them to make sure that the mold was
removed. If I am made to meet a standard of no mold, how can you
assess that you’ve met the standard unless you do some type of
sampling? Unless it’s a visible requirement.
IEC: Are people following any standards in the mold
removal process? For instance, there is an industry standard, the
IICRC S520 that our readers are familiar with.
Col. Doherty: Can’t say I’ve heard of it, and I don’t
know what the standard is that they’re following.
IEC: There’s also – the EPA has guidelines, and New
York City has guidelines. [To
Master Sgt. Rhett: You’re nodding your head there for
that.
Master Sgt. Rhett: There’s no choice in that matter.
Those standards have to be met, so we’re going to get the
appropriate people to handle that to a certain extent and to a
standard.
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Voices
“I am
so impressed with this milestone event, and the subject matter as
stated in the release, that I actually stroked a check and joined. I
believe this is the most positive move I’ve seen within our Industry
that I’ve witnessed since the Mold Rush of 2003, including the much
ballyhooed Unification.”
— Pete Carkhuff, a regional
manager with Emergency Response Solutions, describing how he
feels knowing that industry organizations are breaking their
silence to address the issue of conflicts of interests; his
words were posted March 9 to the Internet discussion group
Healthy Indoor Environments
Word
On The Street
TWO HEARINGS REQUESTED OF
S520 BODY
Carl Grimes, one of two former members of the committee revising the S520 mold remediation standard, has rejected the offer of an informal procedure toward resolving complaints about the standard-writing process he filed in December. His e-mail to a representative of the Institute of Inspection, Cleaning and Restoration Certification makes Grimes the second person formerly linked to the S520 Consensus Body to request a formal hearing before it to resolve complaints filed late last year. His message was sent March 22, two days after Grimes spoke with Larry Cooper, who represented the IICRC secretariat during a 90-minute meeting described as “cordial” and whose discussion was “both clear and informative.” Grimes, who is a member of the IE Connections Editorial Advisory Board, confirmed to the newspaper that he had chosen to pursue a formal hearing instead of accepting the conditions Cooper presented, which included submitting a fresh set of bullet points outlining his original complaints. He said Cooper’s approach at first appeared to be “a fresh start and a simplified approach” but that he later decided “the conditions were so restrictive as to make me complicit with their violation of ANSI procedures” to resolve an appeal. IICRC representatives did not comment by press time.
Another former S520
Consensus Body participant, Elisa Larkin, first requested a formal
hearing on Feb. 11 for unresolved issues concerning an appeal she
brought forth in November. As this issue went to press, Larkin said
no hearing had been scheduled for her but that she and Cooper had
recently scheduled a meeting to take place March 30 in Denver.
BILL SPONSOR BACKS
INDEPENDENT MOLD CERTS
Certifications provided by
independent certifying bodies and accredited by third parties are
“crucially important” in attempts to improve quality of
professionals providing mold-related services, Fla. Rep. Carl Domino
said last month. His comments on industry quality certifications
were delivered in an open letter addressing attendees of an Indoor
Air Quality Association chapter’s statewide meeting held March 7–8.
“I support the inclusion of such certifications as requirements for
individuals performing indoor air quality services in Florida,” said
Domino, who is the sponsor of a bill in the House of Representatives
that would regulate mold professionals. He identified three
components of a quality certification. “First, they verify the
knowledge and experience of their candidates using credible
instruments,” he said, giving as examples psychometrically qualified
exams, documented field experience and board-awarding by industry
peers. “Second, [quality certifications] are accredited by
nationally recognized, third-party accreditation bodies,” he said.
“Third, they are operated independently of training organizations
and industry associations.”
Charlie Wiles, executive
director of the American Indoor Air Quality Council and a member of
this newspaper’s Editorial Advisory Board, said in a press release
dated March 23 that Domino’s statement “goes to show that our work
in raising the standards for certification in the indoor air quality
industry is having an effect.” Wiles added, “We look forward to the
day when credible certifications are relied upon to support
licensing requirements in every state.”
STATE FARM TO RECONSIDER
KATRINA CLAIMS
State Farm has agreed to
reopen more than 35,000 insurance claims in Mississippi related to
Hurricane Katrina upon policyholders’ request. A March 19 news
release from the state’s Insurance Department said the insurer
“intends to make millions of dollars available for additional
payments to policyholders in Hancock, Harrison and Jackson
counties,” the state’s three counties on the Gulf Coast. In the
release, insurance commissioner George Dale said State Farm’s
actions would be “in the best interests of Mississippi
policyholders.” Terms of this new settlement are said to be similar
to one a court rejected earlier this year, but the settlement with
the state’s commissioner of insurance appears not to be subject to
court approval. A statement the insurer’s spokespeople provided to
reporters on March 19 compared the new settlement with an earlier
one rejected by a court but avoids having to be approved by a court.
“Unnecessary court battles and political rhetoric serve no one’s
interest,” reads a passage widely quoted in media.
ASHRAE LAUNCHES FIRST
CERTIFICATION
A program to certify
healthcare facility design professionals is being launched by the
American Society of Heating, Refrigerating and Air-Conditioning
Engineers. The first examination to earn the credential is to be
held June 28 in Long Beach, Calif., immediately following ASHRAE’s
Annual Meeting there. Subsequent examinations will be Web-based at
testing facilities nationwide. The HFDP certification will designate
understanding of a body of knowledge identified by ASHRAE as being
critical to successful facility design.
“An ASHRAE certification
will let employers know that the certification earner has mastered a
significant body of knowledge in a specific aspect of HVAC&R design,
as determined by industry professionals in that field and has met
specified eligibility requirements,” says ASHRAE President Terry
Townsend. “Firms who employ ASHRAE-certified engineers will be
better able to promote their services. This is an invaluable benefit
to ASHRAE members to help them stand out from the competition.”
Persons interested in
earning the certification must meet certain eligibility requirements
and submit a completed application. Membership in ASHRAE is not
required to participate. For more information, visit www.ashrae.org/certification
or e-mail
certification@ashrae.org.
Technical content for the
certification exam was developed in conjunction with the American
Society for Healthcare Engineering of the American Hospital
Association. ASHRAE says it will work with other industry
organizations to develop additional certification programs,
including sustainability, commissioning, and building operations and
management.
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Legislative Update
CONNECTICUT
The stated purpose of Senate Bill 1051 is “to
monitor the quality of indoor air in state buildings.” The bill would
require the state’s Public Works Department to conduct a comprehensive
inspection and evaluation of the IAQ for each state building before 2009
and every five years thereafter.
MAINE
The nonbinding Legislative Directive 20 directs
carpet to be removed from all Maine schools. It was introduced Dec. 22
by Rep. Paulette Beaudoin, a first-term Democrat who represents the
state’s southwest region, which has been home to various mold problems
in schools.
Beaudoin can be reached by e-mail at
RepPaulette.Beaudoin@legislature.maine.gov or by phone at (800)
423-2900.
Jenn Mendez, who is lobbying against the bill for
the Carpet and Rug Institute, can be reached by e-mail at jmendez@carpet-rug.org
or by phone at (703) 875-0634.
MARYLAND
Senate Bill 639 requires national and state
criminal history records checks as a prerequisite to being granted a
license in heating, ventilating, air-conditioning and refrigerating.
The bill is sponsored by Sen. Katherine Klausmeier,
who can be reached by e-mail at katherine.klausmeier@senate.state.md.us
or by phone at (410) 841-3620 or (301) 858-3620.
MINNESOTA
House Bill 402, introduced Jan. 29, calls
for a study of whether the state should issue licenses for residential
microbial pesticide applicators. It specifies that the study consider
licensing programs existing in other states.
The bill is sponsored by Rep. Rick Hansen, who can
be reached by e-mail at rep.rick.hansen@house.mn or by phone at (651)
296-6828.
NEW JERSEY
Four IAQ-related bills filed last year carry over
to the current year in the state legislature’s two-year session.
Assembly Bill 973, introduced one year ago in January, calls for
the Department of Community Affairs to establish its own mold
remediation standards, a statewide certification program for mold
assessors and remediators. It would also require the department to
provide buyers and renters of real estate with information on
mold-related state programs.
Assembly Bill 1015, also introduced one year ago in January,
requires the registration of compensated mold inspectors and remediators
according to the provisions of this act, including the annual submission
of an application and registration fee.
Senate Bill 1249, also introduced one year ago in January,
establishes a “toxic mold commission” that would be required to make
recommendations for implementing a mold inspection program. The bill
would also require mold inspections be conducted as a condition of real
estate sales.
Assembly Bill 1787, introduced last May, establishes a “toxic
mold commission” and also requires mold inspection as a condition of the
sale of residential property.
NEW YORK
Assembly Bill 2006, introduced Jan. 11, would require that
building owners develop and maintain an indoor environmental plan and
respond to complaints about indoor air quality. The bill’s sponsor,
Assemblywoman Donna Lupardo, can be reached by e-mail at lupardd@
assembly.state.ny.us or by phone at (607) 723-9047 or (518) 455-5431.
Senate Bill 1752, introduced Jan. 25 as the Toxic Mold Safety and
Protection Act, provides for research on mold including standards for
the prevention, detection and remediation of mold; public education on
the topic; and housing provisions for the prevention and detection for
indoor mold hazards.
As for research, the Department of Environmental Conservation would be
required to conduct and submit “a comprehensive study on the health
effects of indoor mold growth and toxic mold.” The study is to identify
exposure levels and the hazards involved in mold remediation, methods
for mold detection, and “detailed information about harmful and/or toxic
strains of mold.”
The bill also requires the Division of Housing and Community Renewal to
“study and report the impact of construction standards on indoor mold
growth.”
Within a year of the above studies, the Department of Environmental
Conservation would be required to develop standards for mold inspection,
remediation and testing, and for the certification of mold inspectors,
remediators and assessors, and for laboratories that test mold and
industrial hygienists involved with the planning of mold remediation.
Standards for the design, installation and maintenance of ventilation
and air-conditioning systems “to prevent mold growth or the creation of
the conditions that foster mold growth” would also be required. The
legislation encourages participation from national organizations and
requires draft standards to be offered for 30-day public review and
comment.
The bill appropriates $250,000 toward the Toxic Mold Hazard Insurance
Program, which would be created as part of the state’s insurance law.
The bill’s sponsor, Sen. John D. Sabini, can be reached by e-mail via
his Web site, www.nyssenate13.com, or by phone at (718) 639-8469 or
(518) 455-2529.
RHODE ISLAND
House Bill 5259, introduced Jan. 31, requires the health
department to conduct annual IAQ inspections in public school buildings.
The Committee on Health, Education and Welfare, which is chaired by bill
coauthor Rep. Joseph McNamara, recommended Feb. 7 that the bill be held
for further study.
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Ask Dr. Burge: What Is the Difference Between Exposure and Dose?
What Is the Difference Between
Exposure and Dose?
Dr. Harriet Burge
Director of Aerobiology
Environmental Microbiology Laboratory Inc.
San Bruno, Calif.Q. What is
the difference between exposure and dose?
A. This is an important question. A lack of understanding of the
difference between these terms has resulted in misinterpretation of
dangers associated with fungal growth.
So, what do the terms mean? My definition for exposure is being in the
presence of an agent long enough that it enters the body. Dose is
specifically how much of an agent to which one is exposed reaches a site
in the body where it can have an effect.
Generally, all of the steps in an environmental investigation are
designed to evaluate exposure. That some dose of an agent actually is
achieved is assumed (often inaccurately). Let’s go through an
investigation and see where dose comes into the picture (if it does).
First is the visual observation. You see mold growing on a wall, and you
assume that the mold is producing something (e.g., spores, VOCs,
fragments, etc.) that could get into the air. You extrapolate from that
to exposure by estimating how much time occupants spend in the space. If
they are casual visitors, then you consider that exposure is low; if
they occupy the space for eight to 10 hours a day, then you assume that
more exposure could occur. In your mind, you relate this to the
possibility of a dose of some mold agent sufficient to cause symptoms.
You have, as yet, not actually documented that any exposure has
occurred. If you have been hired to find the mold and remove it, this is
probably enough information.
Second, you collect bulk samples. If you use microscopy or culture to
analyze these samples, you can document that the mold is producing
spores, and you can name the mold. This will give you some information
as to the agents that could be present. It does not increase your
knowledge of whether or not exposure is or is not occurring. If you
analyze the bulk sample chemically, you may be able to pinpoint an
actual agent (e.g., a specific mycotoxin or a specific allergen). This
still does not provide any more information about whether or not
exposure is occurring or how much.
Third, you collect air samples. If you use microscopy or PCR to analyze
these samples, then you can estimate airborne concentrations of total
spores (not particularly useful information), or you can calculate
concentrations of specific spore types such as Stachybotrys or
Alternaria. Combined with estimates of time spent in the space,
breathing rate of the occupants, and spore size, you can estimate
exposure to these spores. If the spore is produced by a potentially
toxigenic fungus and you can find literature that tells you how much
toxin is in each spore, then you can estimate how much toxin exposure
the occupants experienced. You still don’t know the dose they received
unless you know how soluble the toxin is, how fast it is metabolized and
how fast it may be removed from the system.
If you use culture to analyze air samples, then you will usually have
more accurate information on the species of fungi present but less
information on actual concentrations. As with microscopy, the process of
extrapolating to dose is a multi-step procedure that results in only a
rough estimate of potential dose. If you analyze cultured samples for
toxin, then you are documenting only that the captured fungus is capable
of producing the toxin, not that it actually was producing toxin in the
occupied space.
Finally, if you analyze air samples for toxin, then you come closest to
being able to estimate dose. In this case, you know how much of a
specific toxin is present and how long each occupant spends in the
space. You don’t know the size of the particle on which the toxin was
borne, and you still have to estimate dose in the ways discussed above.
Too often, the presence of a fungus such as Stachybotrys is assumed to
mean that occupants were receiving a sufficient dose to cause symptoms.
Unless you have thought through all of the above steps, this is somewhat
like assuming a shark will eat you if you swim in your swimming pool. In
order to prove such an assumption, you would have to document that there
actually were fish in your pool, that the fish were sharks, that the
sharks were man eating sharks, that they were big enough to eat you,
that they were hungry, and that you couldn’t fight them off or get out
of the pool in time.
Dr. Harriet Burge is director of aerobiology at Environmental
Microbiology Laboratory Inc. and associate professor and director of the
microbiology laboratory at the Harvard School of Public Health. Widely
considered the leading expert in IAQ, Burge pioneered the field more
than 30 years ago. She has served as a member of three National Academy
of Sciences committees for IAQ, including as vice chair of the Committee
on the Health Effects of Indoor Allergens.
To submit a question to Dr. Burge, write to her by e-mail at askdrburge@emlab.com.
All questions posed to Burge will receive a reply, although space
limitations prevent us from publishing them all. By submitting a
question, you agree to have your question and its answer published in a
future edition of IE Connections. |
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Radon Corner: Radon Mitigation Standards – Are We Overlooking Local Codes?
Radon Mitigation Standards:
Are We Overlooking Local Codes?
Douglas Kladder
Director
Center for Environmental Research & Technology Inc.
Colorado Springs, Colo.
There has been a lot of discussion over the past few years related
to what standards radon mitigation contractors should follow. These
discussions began as the U.S. Environmental Protection Agency
started phasing out their Radon Mitigation Standards, which have
been the primary standard of performance for many state radon
programs and certainly the national radon proficiency programs.
This pullback by EPA initiated a number of efforts by both the
American Society for Testing and Materials and the American
Association of Radon Scientists and Technologists to develop
standards that would replace the retiring EPA document. These
efforts resulted in ASTM’s E2121 and AARST’s Active Soil
Depressurization Standards, neither of which has been adopted for
use by radon mitigation contractors certified by the NEHA National
Radon Proficiency Program.
So, what standards should be followed? For those certified by the
National Radon Proficiency Program, the National Radon Safety Board
and many state-operated certification programs, the EPA radon
mitigation standards still apply. Even though EPA may not be
publishing this document anymore, many programs still recognize
EPA-402-R-93-078 as a prescriptive criterion for installations. This
statement is based upon the assumption that unless a credentialing
agency has specifically communicated a change in applicable
standards, the previous standard still applies, as is the case with
the NEHA-NRPP.
In some cases, the lack of formal adoption of alternate standards
has led to confusion. In other cases, it has provided an excuse not
to follow any standards.
It is hard to understand the basis for this confusion when previous
standards remain, by default, the basis of certification.
Furthermore, it is hard to understand the confusion when one
realizes that there are already standards in place, on a local
level, that govern many aspects of the installation of radon
mitigation systems.
Many Local Codes Currently Address
Radon Mitigation Practices
There are those currently in or entering the radon mitigation
field that look to national standards as the sole means of defining
acceptable practices. This misconception is perhaps perpetuated by
the manner in which individuals entering this field are taught. An
individual attending an entry-level mitigation course (with no
prerequisites) is educated on the EPA Radon Mitigation Standards and
tested on the content as a part of a certification exam. When
provided a certification card, the person believes he or she has
been given a license to mitigate with no further requirements.
However, there are a number of local requirements for contractors
offering services to the public. The least of these is to follow
local building codes!
Many individuals in the radon mitigation field would be surprised to
learn that provisions of the codes are specific to radon mitigation.
Some may even believe, mistakenly, that they are exempt from codes
because Appendix F of the International Residential Code, which
deals with the installation of radon systems in new homes may not
have been locally adopted. What they don’t realize, at least where
the 2003 International Mechanical Code has been adopted, is that
Section 512 is specific to sub-slab soil exhaust systems, a.k.a.,
active soil depressurization radon mitigation systems.
Section 512 also specifies aspects of the International Plumbing
Code that also apply to these types of systems. A quick review of
this section specifies the following:
- Exhaust systems ducts shall not be trapped and shall have a
1 percent slope.
- System ducts shall extend through the roof and terminate at
least six inches above the roof and at least 10 feet from any
operable openings or air intake.
- System to be permanently labeled within each floor.
- By reference, specifies the type of pipe to be used that is
more stringent than the EPA Radon Mitigation Standards.
Certainly, other aspects of the codes pertain to these systems –
not the least of which is the method by which power is provided to
fans, structural modifications, etc.
It is also interesting to note the following language that can be
found in several current or proposed national standards:
- EPA Radon Mitigation Standards (Section 7.2): “Where
discrepancies exist between provisions of the RMS and local
codes or regulations, local codes shall take precedence.”
- ASTM E2121 (Section 5.3): “… contractors shall also conform
to applicable local, state and federal regulations.”
- AARST Active Soil Depressurization Radon Mitigation
Standards: “Where discrepancies exist between provisions of the
ASD RMS and local or state codes that prevent compliance with
the ASD RMS, the local or state codes shall take precedence.”
In other words, local codes take precedence, and their
provisions apply now in many instances and will apply in the
future if any of the proposed standards are put in place.
With respect to how widespread these codes are, a review of the
International Code Council’s Web site indicates that the
International Mechanical Code has been adopted in jurisdictions
within 44 states and, more specifically, within over 1,100
individual jurisdictions. Given this widespread adoption of the
IMC, the practicing mitigator would be advised to confirm how
the local building department is handling Section 512 of the IMC.
Do Building Codes Offer Some
Assistance to Radon Certification Programs?
Over the last several years, one of the recurring
themes or comments at national radon meetings is that national
certification programs should do a better job of policing the
practices of radon contractors. This is especially true for states
where no local certification programs exist and, hence, there is a
reliance on the national boards. Without getting into definitions of
certification and what kind of policing can be reasonably expected
from nationally based organizations, the presence of local,
enforceable codes could provide a partial solution to this concern.
Local code agencies exist for the purposes of protecting consumer
safety in homes and other structures. They do this through
permitting processes, contractors’ licenses and inspections.
Furthermore, they have the infrastructure to do this on a local
basis far better than any national credentialing body can and, most
likely, better than a state-operated program can.
Local code agencies are also government bodies that have the ability
to fine and prosecute individuals who do not comply with local codes
and statutes. They also have the means by which actions can be
appealed and reviewed. Local jurisdictions have the means to take
action with a lot more bite than a voluntary credentialing program
would have.
This is not to suggest that national certification is unnecessary.
To the contrary, there are aspects of any profession that are not
covered by prescriptive codes. In the case of radon, there is a need
for business practices that deal with proper reporting, conflicts of
interest and additional installation parameters that would go beyond
the current building codes as needed (or until these can be
incorporated into the code revisions). However, we do not need to
wait for new codes such as Appendix F to be adopted when relevant
codes currently exist.
The point of this column is to suggest that if we want better
mitigation systems that are durable and safe, there is an
alternative to creating more national standards. Radon standards
could be significantly streamlined to build upon current codes and
regulations, rather than attempting to replace them. Of course, this
would have an impact on much of the current radon mitigation
industry in that it would cause many to become licensed contractors
prior to initiating their business (or perhaps even obtaining their
national credential). It could also mean that permits and
inspections might slow down the completion of a job. On the other
hand, if we are serious about quality installations that are
properly installed and do not present a larger hazard than the one
that is being addressed, then that may be the price that gets to be
paid.
As always, who says there is nothing new in radon?
Douglas Kladder is director of the Center for Environmental Research
and Technology Inc. He can be reached by e-mail at dougkladdr@aol.com
or by phone at (719) 477-1714.
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IAQ and Schools: Look at HVAC, Sources to Settle Enduring Trouble
William A. Turner, P.E.
President/CEO
Turner Building Science & Design LLC
Concord, N.H.
Steve M. Caulfield, P.E., CIH
Vice President
Turner Building Science & Design LLC
Harrison, Maine
We have been dealing with IAQ for 20-plus years each. That means we
are getting old by some standards or wiser by others.
About 12 years ago, we had the opportunity to contribute to the U.S.
Environmental Protection Agency’s Building Air Quality Guide, which
we feel was a major step forward in assisting certified industrial
hygienists and building facility operators in understanding how to
approach and deal with IAQ concerns in non-industrial settings. In
the face of unresolved concerns, a take-a-close-look approach often
yields useful information that can assist with resolving concerns.
Recently, it has been somewhat of a surprise to us that some
facility managers and industrial hygienists seem to think that if
the numbers from random testing look normal, then they are done with
the investigation or evaluation. That is, if the carbon dioxide
numbers are OK, and if the thermal numbers look reasonable, and if
the PM-10 (breathable dust) is less than 50 micrograms per cubic
meter, and if the airborne mold spore counts (during short-term
testing) are less than 1,000 spores per cubic meter, then they
believe all is OK. Furthermore, they believe this indicates that we
are doing the best anyone can expect to accommodate a teacher or
office person who continually raises IAQ concerns; that is, the
problem must be in their head, or they are just way too sensitive to
work in the environment we can offer for them.
But this cannot and should not be the end of the investigation. In
fact, a more logical starting point may be to look at the equipment.
Acceptability criteria: You all likely know and understand by
now that there are few specific federal laws that specify a battery
of acceptable parameters for air quality in non-industrial
exposures. Design and operation standards and guidelines by the
American Society of Heating, Refrigerating and Air-Conditioning
Engineers are most frequently cited when dealing with non-industrial
settings.
The typical diagnostic test result numbers look reasonable for IAQ
upon data-logging for a week or more if:
- the carbon dioxide numbers are between 700 and 900 parts per
million and decrease at night or when unoccupied;
- the carbon monoxide numbers are below three parts per
million;
- the PM-10 Dust levels are lower inside than outside during
the occupied period;
- the thermal comfort logging suggests typical temperatures of
70–74 degrees Fahrenheit, and relative humidity of 30–55
percent; and
- the short-term mold spore counts indoor are less than
outdoors and mostly the same species as outdoors.
If all of the above is true, then one could suggest there are no
obvious problems upon first look. However, the investigation or
observations are certainly not over at this point if the concerns
and complaints continue. This statement is especially true if the
occupants have been complaining for multiple years and this is just
another spot or week-long look at possibly the same situation that
has been going on intermittently for a long, long time.
What’s Next to Consider?
Likely, a couple of things:
History and sources: One could carefully review the
history of complaints and what was done to address them, other than
standard testing that likely did not reveal too many problems. Or
maybe there are new or recurring problems. Useful clues could be
found by asking questions like: Is there a history of musty odors or
any other odors that occupants notice? Are there short or long term
foul odors like sewer gas, or boiler/gas/diesel smells? It is often
useful to look for things that would not show up with standard CO2,
CO, PM-10, airborne mold spore counts, and thermal diagnostics.
Are there known chemical irritants or microbial reservoirs anywhere
to be found in the immediate vicinity of the concerned individual,
or within the facility anywhere near this person or this group of
people, or near the air intakes that serve these areas? Classic,
often overlooked indoor sources include high-use photocopiers or
printers, sewer gas leaks, and HVAC condensate pans and drains in
hard-to-access, above-ceiling mounted equipment such as water source
heat pumps. Other classic issues include grease traps and those
traps that serve art or science rooms. Classic, outdoor overlooked
sources include short-height boiler stacks or other rooftop air
discharges such as sewer pipes, and also nearby rooftop air intakes
or nearby manhole covers over sewers, and operable windows nearby.
HVAC operation: Perhaps the first step in some of
these investigations should be to take a really careful look at the
HVAC system serving the area. Start with the outside air. Do the
outdoor air intakes really open, and under what conditions do they
open, and how much? Are they open too often and causing excess
dryness in the winter? Does their operation change as part of a
freeze protection system? Are the rooftop air intakes pulling air
from immediately above a dark-colored roof? Have the air filters
been good ones – minimum-efficiency reporting value of 8 or slightly
more and two inches thick so that they cannot be seen through
easily? Have they been maintained well? Are the controls working as
designed? Does the building operator really understand what he or
she is supposed to do? Does someone know for what the space usage
was originally designed where the complaints are occurring? Is
the boiler room somehow impacting the air in the facility via
adjacent walls or connecting metal ceiling flutes? Did someone
actually design an air handler to be located within the boiler room,
not understanding this can’t work? Is the air supply to the area or
exhaust from the area somehow mining soil gas or air from a
below-floor pipe trench?
Knowing how air gets to the room in a planned manner and unplanned
manner is likely key in understanding if short-term, non-measurable
exposures to irritants are occurring. HVAC hygiene: Is
there a condensate drain pan, and is it clean – or at least clean
enough that you wouldn’t mind eating your lunch out of it? Is there
some type of preventative maintenance on the condensate pans and
drain lines in the above-ceiling water source heat-pumps, as well as
the rooftop or built-up units? What does the acoustical liner
in the HVAC unit near the condensate pan look like: clean, moldy,
falling apart, or missing? Where does the condensate drain line go:
to a not-so-great-smelling area? Is it clean and reasonably
nice-smelling wherever it goes; i.e., what is the actual
construction of the condensation drainage system? Does the heat pump
suck foul material from the drain line if the trap dries out, or
does it somehow blow air into the drainage system where it shows up
someplace else?
Additional Diagnostic Tools
Particles: One can tell a lot about what is going on with
the use of a continuously running laser particle counter. It, along
with some wind direction data, can likely reveal the impact of
boiler emissions, either from the roof or via internal conveyance.
Knowing the size, distribution and periodic nature of particulate
goes a long way toward identifying a source.
Pressure mapping and tracer testing: One can often understand
where air comes from and goes to by doing pressure diagnostics at
each door with a digital micromanometer. It, along with tracer gas
testing or use of tracer smoke, can often solve pathway
identification challenges.
Problems resolution: So long as the complaints and occupant
concerns continue, one needs to expend reasonable efforts to rule
out irritants and exposures that likely would not be picked up with
routine parameter monitoring. Although limited sampling that shows
results within “acceptable levels” is a good short-term feel-good
result, it does not get you any closer to resolving the real issues
causing the complaints. William A. Turner, P.E.,
is president and CEO of Turner Building Science & Design LLC. He has
more than 25 years of experience in IAQ/HVAC evaluation and
development of solutions for building system problems. He supervises
a group of engineers, industrial hygienists and building scientists
who serve owners, architects, general contractors and construction
managers. Turner can be reached by e-mail at bturner@turnerbuildingscience.com
or by phone at (207) 583-4571 ext. 11.
Steve M. Caulfield, P.E., CIH, is senior vice president of Turner
Building Science. Caulfield can be reached by e-mail at scaulfield@turnerbuildingscience.com
or by phone at (207) 583-4571 ext. 14.
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Labs and Testing: Inter-laboratory Variability in Spore Trap Analysis
Dr. Bob Brandys
President
Occupational and Environmental Health Consulting Services Inc.
Hinsdale, Ill.
The two main methods used for microbial air sampling today are
culturable and total spore air samples. The culturable method, which
collects spores on an agar plate, has been used for over 150 years.
Similarly, spore impingement on a glass slide dates back to the
1870s. For each of these sampling methods, the samples are analyzed
by a laboratory and a trained microscopist.
Most of the time, we assume that the data from the lab is an exact
and reliable number. However, we need to remember that any sample is
a statistical approximation, fraught with both quantifiable and
unquantifiable errors. First, the equipment introduces errors when a
sample is taken. This is sampling error, or SE. Second, there are
analytical errors introduced when the technician analyzes the slide.
This is analytical error, or AE. Both types of errors can be summed
together into the SAE, or sampling and analytical error of a sample.
This SAE is rarely quantified or even considered in reporting
microbial sampling results to clients.
First, let’s tackle sampling error. When taking air samples, it is
important to realize that flow rates are never held perfectly
constant. Measurements of the sample volume are dependent upon the
accuracy of the flow calibration device and the timer. These errors
in the sample volume measurement contribute to the SE, and have a
variance of less than 10 percent with the use of a primary standard
calibration device.
A second component of the sampling error is one of collection
efficiency. The collection efficiency of mold spore sampling devices
varies considerably and is highly dependent upon the size of the
mold spores being sampled. The collection efficiency of the various
spore trap samplers is still something of considerable debate.
Once a spore trap sample is collected and sent off to the lab with a
reported flow rate and understood collection efficiency, the
laboratory has to analyze the sample under the microscope. This
process introduces a certain amount of analytical error.
Published research has not compared inter-laboratory variation on
the identification and interpretation of total spore sampling
results, nor has research calculated the SAE. This is not
surprising, since each laboratory has its own identification and
counting methods for spore traps.Some indoor environmental
consultants justify ignoring the issue of the analytical error in
spore trap analysis, claiming that the “normal” variation in the
concentration of total mold spores in the air far exceeds the
variation introduced at the laboratory. This assumption is not based
on the scientific research. It is also inconsistent with published,
long-term microbial studies of controlled indoor environments.
Granted, there can be a large variation in indoor mold spore
concentration when mold spores are disturbed, but most monitoring is
done prior to or after mold spores have been disturbed.
Spore trap analysis is highly dependent upon the visual skills of
the microscopist in both identifying and quantifying the mold spores
and other materials. In fact, this source of error is probably most
significant. If the analyst misidentifies or undercounts the mold
spores, misinterpretation and erroneous conclusions could be drawn
from their analysis.
How significant is this spore trap analytical error issue? Testing
this question is difficult. It is highly dependent upon the level
and types of mold spores in the air. If one has low levels of big
spore genera, it is easy to count the slides. Conversely, if one has
high levels of small spore genera, it can be very difficult and
time-consuming to adequately count the slides.
An interesting aspect of this counting question is that many
commercial labs typically allow the microscopist six to eight
minutes to count a spore trap slide. Ironically, for counting fibers
for asbestos monitoring, which is much simpler, NIOSH specifies at
least 10 minutes for counting each slide.
This research study has concluded that a majority of the SAE is a
result of analytical error at the laboratory, not sampling error on
the jobsite.
Spore Trap Counting Variability
Research Project
During the summer of 2006, my company encountered an environment
that was contaminated with mostly Aspergillus niger. These spores
are relatively small, which makes them an ideal test for lab
counting variability. The presence of Aspergillus niger was
identified in the first round of sampling that included four
culturable air samples and four total mold spore samples.
The building owner allowed us to come back and do a second round to
evaluate the question of inter-laboratory variability in spore trap
counting methods. He was not occupying the space and had an interest
in research. At the same time, a number of laboratories agreed to
volunteer their analysis services. Without the help of all these
companies and individuals, this research would not have been
possible.
In this research project, four spore trap sample slides were
prepared and read by the first laboratory. These same four slides
were then sent to six other laboratories starting in August 2006.
This research evolved into two projects. This first project focuses
on analysis error, and identifies the laboratory variation in the
analysis results. A second research project will focus on sampling
error and collection efficiency of four different spore trap devices
including the Air-O-Cell, Micro 5, Allergenco-D and Cycle D spore
traps. Analysis of 28 samples for the second project is still in
progress.
After the initial mounting and analysis of the four slides in this
first project, each laboratory knew it was doing a recount as part
of a research project. It is therefore likely that they used a more
experienced microscopist to count these slides. In fact, if I ever
send a set of slides for a second opinion, I would expect the second
laboratory to use a more experienced microscopist.
Each volunteering laboratory had a different report format. Some
included additional analysis for algae, hyphae, insect fragments,
etc. The comparable analysis data for particular mold genera were
extracted from the various lab reports and are shown in Tables 1
through 4.
As one can see in the tables, there was considerable variation in
each analysis of the spore traps. Not only was there significant
variance in the counts, but there was differing interpretation as to
the identification of the genera.
For example, some labs identified some of the less frequently
found spores while others did not. The only mold genera for which
there is fairly consistent data from all six labs are
Cladosporium and Penicillium/Aspergillus-type spores.
Obviously, the high variability of the data indicates that many
complex factors are involved in spore trap counting. For example,
where the microscopist views the trace appears to make a
difference. In Table 2, two labs found some Trichoderma. It
appears this genus was only in one spot on the trace, and these two
labs happened to view that portion of the trace. A similar condition
appears to have been present for Nigrospora in Table 3.
Realistically, there is so much variance in this data that little
statistically useful information can be gained by a detailed
analysis. However, some limited information can be gained by
simplifying the information in the tables.
The first simplification that we can make in analyzing these results
is just to look at the number of spores counted, rather than the
concentration of spores in the air. We can do this because the
sample volumes were all equal. The volume of air sampled is just a
mathematical adjustment to the actual spore counts.
The second simplification would be to initially analyze the
variability in counting the most common or frequently encountered
mold spores, such as Cladosporium and Penicillium/Aspergillus-type
spores. The assumption here is that since these are the most common
genera encountered by the laboratories, the variability in
identification and counting should be less than for other genera.
These two simplifications were used to develop Tables 5 and 6.
Table 5 shows the Cladosporium spore counts for all four
slides, while Table 6 shows the Penicillium/Aspergillus-type
spore count data for all four slides. Each table also shows the
statistical parameters of the average spore count and the
standard deviation. The standard deviation is a statistical measure
of the variance in the data.
Lastly, the standard deviation is shown as a percent of the average.
This is known as the relative standard deviation. For a normal
distribution, the relative standard deviation is 33 percent of the
average. Here, the relative standard deviation is at least 50
percent of the average. Therefore, the data are not normally
distributed.
For a normally distributed data set, adding or subtracting one
standard deviation from the average of a data set will give you the
numerical range for 66 percent of the data. Adding or subtracting
two standard deviations from the average will give you the numerical
range for 95 percent of the data.
For example, for sample 1 in Table 5, the average Cladosporium
spore count is three spores. Adding one standard deviation to the
average gives a maximum spore count of 4.5, while subtracting one
standard deviation from the average gives a lower spore count of
1.5. This means that 66 percent of the lab counts were between 1.5
and 4.5. Adding two standard deviations to the average gives a
maximum spore count of 6.0, while subtracting two standard
deviations from the average gives a lower spore count of 0. This
means that 95 percent of the lab counts were between 0 and 6.0.
What this research is trying to quantify is that given a specific
laboratory result, how much variation in that number can be
expected? For example, based on Table 5, should the laboratory then
report Cladosporium results as plus or minus 50 percent?
Further, based on Table 6, should one report Penicillium/Aspergillus
results as plus or minus 72 percent?
So, which lab result is actually correct? Is a higher spore count
the most accurate, or is it possibly misidentified and over counted?
For example, the uniqueness of Cladosporium spores makes
misidentification unlikely. A number of other factors can lead to
higher spore counts, probably the most significant of which is
whether the slide was examined at 400× or 600×. There is good
scientific evidence showing that increasing the level of
magnification during examination of a spore trap slide will yield
higher spore counts.
A second factor is the wideness of the field of the objective lens
of the microscope. With a wider field, the microscopist can
see a larger area and, hence, more spores.
A third factor is that most labs read about 25 percent of the trace
and then multiply that count by four to estimate the total count on
the trace. Many also read up to 100 percent of the trace looking for
genera with a single-digit spore count. Reading more of the trace
can result in more accurate, higher counts.
A fourth factor is the visual acuity of the microscopist.
Some people are able to see finer detail because they have more
cells in their retinas. Fifth, experienced microscopists are
more likely to properly identify and count spores than novice
readers.
Could one have sent these slides to a laboratory and had the whole
slide counted to get the “correct” count? At what magnification,
etc.? The problem with having this done is that it is not a normal
analysis method. This project was to see how much variability exists
in the methods currently used by laboratories.
Based on this data, one could draw the conclusion that, most of the
time, spore counts are undercounted. This would mean that one should
typically report Cladosporium results as possibly being up to
50 percent higher and Penicillium/Aspergillus results
as being up to 76 percent higher. In our data, this assumption was
accurate half the time.
Clearly, this research raises serious and significant questions
about using only spore traps to evaluate and classify the mold spore
character of an environment. It also raises serious questions as to
the scientific accuracy of using only spore trap data in legal
cases.
Recommendations for Indoor
Environmental Consultants and Analysis Laboratories
Based on this research, a few recommendations for consultants and
analysis laboratories are provided below:
- Laboratories should offer a “replicate” spore trap analysis
service for legal cases. This service would use two
microscopists to evaluate each spore trap slide. The results of
the two microscopists would then be reported as a range. This
would better quantify the variance associated with visual
identification and give the IEP higher confidence in the data.
- Laboratories should consider establishing a special
“recounting” or “expanded” counting service. This service would
involve counting a much larger portion of the slide. For
example, one technician would read one area, and the other
technician would read a different area. A much greater portion
of the trace would be read in this manner. The special analysis
results would be reported with a variance (e.g., plus or minus
25 percent) for the counts for each genus.
- Laboratories should notify clients whenever clusters of
spores were present. In this study, one lab reported clusters as
potentially being the reason for such high variability amongst
the labs. Clusters provide one of those time consuming counting
challenges. Also, clusters can be broken up in Andersen samplers
and result in higher reported culturable levels.
Lastly, we have undertaken a much broader study in the
variability of spore trap counting along with various types of spore
trap samplers. This study involves 28 slides taken at three
different spore concentrations with four different types of spore
trap media. The results of this research will be published later
this year. If you are with a laboratory that wants to participate in
this study, please contact me.
Dr. Bob Brandys has served as president of his own
environmental consulting firm since 1984 and has authored numerous
publications on chemical safety and microbial control for the
hospital and healthcare manufacturing sector as well as the mold
consulting and remediation industries. He can be reached by e-mail
at bobb@safety-epa.com or by phone at (630) 325-2083.
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Contractor’s Toolbox – Antimicrobial Products: Robots to Replace Manual Application in Air Ducts
In any industry, the use of robotics such as this antimicrobial sprayer has primarily been driven by considerations of productivity, quality and safety.
Robots to Replace Manual Application in Air Ducts
Lance Weaver
President, Chief Operating Officer
Lloyd’s Systems Inc.
Rapid City, S.D.
Bernt Askildsen
Marketing Director
Lloyd’s Systems Inc.
Rapid City, S.D.
Antimicrobials play an important role in public health and
safety. While providing health benefits of pathogen removal as well
as duct liner preservation, the same antimicrobials involve risks of
potential efficacy failure and exposure hazards. This is why the
effectiveness and proper use of these products are of widespread
concern.
To ensure proper application of antimicrobial products, contractors
should be in compliance with any safety and regulatory requirements.
Therefore, it is important to make sure that the antimicrobial
action has been approved and registered by the U.S. Environmental
Protection Agency or is covered by an exemption from registration
for use in HVAC ducts. In this regard, note that any pesticide
originally registered before November 1984 has to be reregistered,
thus older EPA-issued documents may no longer be valid.
Duct systems are designed with materials that do not support
microbial growth as manifested in the Underwriters Laboratories 181
standard. However, as dirt and organic matter accumulates in the
ducts over time, the situation dramatically changes. Such buildups
are perfect food sources for microbial growth when combined with
high moisture levels. Fiberglass lined duct is usually more prone to
dirt buildup than galvanized just because of the holding capacity of
the fiberglass blanket. However, even galvanized duct will support
microbial growth if enough organic matter is available.
With more than 100,000 mold species in the world, it is no wonder
molds can be found everywhere. In nature, mold plays a key role in
the decomposition of leaves, wood and other plant debris. Without
mold, everybody would be wading neck-deep in dead plant matter. Due
to the wide diversity of mold types, there are molds that can grow
on wood, ceiling tiles, wallpaper, paints, carpet, gypsum wallboard
and insulation, to mention a few.
A microbial problem first arises when more than one mold species
starts digesting organic materials indoors and they release toxins
when attempting the fight off competing mold species. Realistically,
there is no way to rid all mold and mold spores from a building. The
best defense is proper maintenance that includes a combination of
changing filters, moisture control, source removal of any potential
food sources and antimicrobial treatment. If a proper maintenance
plan is followed, the probability that microbial growth will occur
even in environments with permanent high moisture content, is very
low.
Productivity
Productivity can be dramatically improved by
working smarter and not harder. Today’s robots allow cleaning and
antimicrobial application in sections up to 200 feet, or about 60
meters, between access openings such as preexisting fire-damper
doors or other access holes such as those required for manual
cleaning and spraying of turning veins. This range significantly
reduces the labor need of cutting and patching approximately 50
access holes that is required for manual cleaning and antimicrobial
application of a duct 400 feet long.
A quick work-study of such duct system comprised of 15×30 inch
insulated duct shows that proper preparation, cutting and patching
of each access hole takes approximately 30 minutes. Furthermore,
manual cleaning and application take approximately 200 minutes each
for the same 400-foot section. Thus, the manual approach requires a
total of 32 man-hours to complete the job.
In contrast, newer design robotic systems may provide 20 feet
cleaning per minute and 40 feet spraying per minute. With a total
setup time of less than one hour, the same job takes approximately
three man-hours from start to finish, reducing the total labor by at
least a factor of 10.
If the cost per man-hour is $20, then the manual procedure is $640
compared to $60 when using robotics.
In order to reap these benefits, it is very important to assess what
robot to use, as some of the older robotic technology can be quite
inefficient. One-pass application robots are superior in performance
and are the ones used in the above cost study.
As EPA-approved antimicrobials with additional material preservation
benefits cost $30–40 per gallon, significant cost savings can also
be achieved by using the same one-pass application robotics. For
example, several studies have shown chemical savings of
approximately 30 percent when applied robotically versus manually.
Using these numbers with the previous cost study for the 400-foot
duct section, manual application would require approximately 21
gallons versus 16 when applied robotically.
Considering a popular antimicrobial coating for HVAC ducts, the
savings for this small duct would be $200. Comparing the cost of the
two approaches, the difference of $780 translates into a total
savings of $1.95 per linear foot for 15”×30” ducts. Cleaning and
spraying only 5,100 linear feet of ductwork can therefore realize
the return of investment of a robot costing $10,000.
Ergonomics studies have verified that muscle
fatigue is significant when individuals work overhead during manual
cleaning and antimicrobial application in HVAC ducts. Fatigued
muscles make it impossible to keep arms raised overhead for even
short periods of time. This makes reliable performance calculations
more challenging, making each job susceptible for cost overruns.
Contractors using manual cleaning and spraying methods should
allocate an additional quality-control person responsible to verify
that all cleaning and application have been properly completed. The
rationale behind this is that persons who experience muscle fatigue
have reduced motivation to complete the task properly. Furthermore,
fatigued muscles increase the risk of labor-related injuries as
addressed under safety.
Quality
Quality guarantees for the customer should
be the main objective for professional contractors. In this aspect,
the main objective should first be to ensure proper source removal
before properly executing the antimicrobial application. A robotic
system enables a contractor to view and digitally record both the
cleaning and application sequences for real-time quality assurance
and customer documentation. Spraying or coating lined duct manually
requires many new access openings, and each opening creates a new
frayed edge in the fiberglass liner. So, even though the microbial
problem has been successfully addressed, a new hazard has been
created where fiberglass particles are now continuously released
into the indoor air. Various countries have recommended exposure
limits that typically range from 1.0 to less than 0.5 fibers per
cubic centimeters based on an eight-hour workday.
Furthermore, an increased number of access holes will create more
turbulent airflow and, therefore, become new areas that will
accumulate dirt and debris. All of these new openings, especially if
improperly sealed, will cause increased air leakage from the duct
system over time. These factors could significantly affect the
energy efficiency of a building. When more scientific studies become
available, it is possible that building owners will file civil
lawsuits against contractors who have severely damaged the duct
system’s integrity in a building.
According to UL 181, fibrous glass duct systems, when installed
according to manufacturer’s recommendations, are virtually leak-free
before the access holes are cut. Building owners may sue to recover
energy losses and maybe even for the entire duct replacement cost if
the damage is severe enough.
Robotic cleaning and coating, on the other hand, offers a secondary
benefit to building owners. Coating tends to smooth the surface and
seal air leakage, providing a more energy-efficient duct system.
This provides an additional financial benefit to building owners in
that energy savings may pay for an aggressive maintenance program.
Tests are underway that will quantify the energy savings related to
general duct-maintenance procedures.
Robotics allow access to ducts over inaccessible areas such as
gypsum wallboard, plaster ceilings or those ceilings high over
atriums. In these cases, robotic is the only method that can
accomplish the objective with guaranteed quality assurance.
Furthermore, using robotics, the contractor avoids uneven
application. This translates not only into wasted chemicals as
described earlier, but also into longer drying time and increased
release for volatile organic compounds.
Robots exist that enable proper cleaning, spraying, coating and/or
sealing of square, rectangular and circular ducts from 6×8 inches to
48×48 inches. Duct that is larger than 4×4 feet can be cleaned and
coated manually if no confined space issue exists and the system is
properly structurally supported. For ducts smaller than 6×8 inches,
the most effective method for cleaning and application of
antimicrobials is still manual.
Safety
Safety issues are and will be even more
prevalent in the future as better scientific knowledge becomes
widespread. It will be easier for employees to prove that their
employer acted with intent, exposing them to unacceptable hazard
levels. This, in conjunction with the government’s increasing
enforcement of machine safety, falls from elevations, and chemical
exposure standards will continually increase employer liabilities.
This applies to all occupational areas concerning contactors
providing cleaning and antimicrobials application to HVAC ducts.
Reducing the excessive access hole cutting required by manual
cleaning and application can minimize machine safety liabilities.
There are three main methods of cutting sheet metal:
- Shears are efficient, but they leave a
dangerously sharp edge, which is a significant safety hazard.
- Circular access cutters operate as a
drill bit of varied diameters and make a more smoothly cut edge
compared to shears, but the hot dangerous metal chips created
are extreme eye hazards.
- Nibblers are the fastest cutting device
and leave the smoothest edge, but these also produce small
crescent shaped metal chips that are extreme eye hazards too.
Many eye and cut injuries are reported
yearly due to the exposure during sheet metal cutting. Therefore,
robotic techniques that eliminate the need for many access holes
provides the best worker compensation insurance.
Any unprotected side or edge that is six feet or more above a lower
level should be protected from falling by the use of a guardrail
system, safety net system, or personal fall arrest system. These
hazardous exposures exist in many forms. From changing a light bulb
with a step ladder to something as high-risk as connecting bolts on
steel beams 200 feet in the air. These requirements make it
challenging if the ductwork is more than 12 feet above the floor.
The cost of a duct cleaning and antimicrobial spraying job increases
exponentially with widespread secure scaffold or ladder entry
points. To reduce these risks and costs, robotics can get the job
done with only a few elevated scaffold or ladder entry points, and
the robot operator can work from the floor.
Recommended or mandatory occupational exposure limits have been
developed in many countries for airborne exposure to gases, vapors
and particulates. The most widely used, threshold limit values, are
issued by the American Conference of Governmental Industrial
Hygienists. The purpose of such limits for antimicrobial application
is to avoid harmful aerosol particle exposure when using paint
sprayers for manual application. To stay safely under the limits,
respiratory protection should be used in conjunction with capturing
those particles that would otherwise escape into the building space.
Robotics solve this occupational exposure limit hazard as the duct
is under negative pressure from HEPA-filtered negative-air machines.
Also, there are very few access holes where exposure may happen.
Furthermore, a significant distance between the robot’s spray nozzle
and the operator ensures no direct exposure.
Conclusion
Trends in indoor environmental robotics show a dramatic change as
small handheld digital video displays with standard SD card
recording systems rapidly replace the previous generation of bulky
systems. Many of the previous generation’s systems have large TV
monitors and VCRs that require two people to set up and operate,
whereas newer systems provide a dynamic capability whereby one
system may be used for inspection, cleaning and application of
antimicrobials operated by one person.
Furthermore, increasing focus has been on autonomous operation that
significantly simplifies the operator interactions with the robotics
and minimizes operator error. Autonomous operation allows the robot
to automatically self center in the duct, adjust travel speed and
raise or lower the spray head to ensure even application of
antimicrobial coating.
Robotic cleaning and antimicrobial application can now be executed
in ducts from 6×8 inches up to 4×4 feet providing a powerful video
guided platform that document the work process and expose any
internal issues of the HVAC system. Some vendors have already
announced similar solutions for smaller ducts and for vertical
chases. The availability of complete suites of video guided HVAC
maintenance procedures will significantly improve delivered quality
to the building owners thus provide better indoor quality for its
occupants.
Lance Weaver, president and chief operating officer of Lloyd’s
Systems Inc., has been pioneering robotic technologies for IAQ
purposes for over 15 years. Bernt Askildsen is responsible for the
corporation’s domestic and global marketing strategy. They can be
reached by e-mail at info@lloydssystems.com or by phone at (800)
872-8753. |
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