At Press Time -- FEMA's Latest Failure: Formaldehyde in Trailers

Word on the Street

Political Pressure Limits Science Awareness

A Broader Scope: An Interview With Environmental Information Association President B.J. Fungaroli

Ask Dr. Burge -- Can I Do Quantitative Cultural Tape Sampling for Mold?

Radon Corner -- EPA and AARST Share Vision for 2008

IAQ and Schools -- New School Checklist: Can We Head 'em Off at the Pass?

Monitoring -- VOCs: The Sheep in Wolf's Clothing
 

States to Regulate Mold Assessors and Remediators
By Jonathan Miller

New legislation in three states could spell big changes in the IEQ assessment and mold remediation industries.

In Florida, Governor Charlie Crist signed into law on June 27 Senate Bill 2234, which will require mold assessors and remediators to apply for examinations and two-year licenses when it takes full effect in July 2010, as well as hold $1 million insurance policies in general liability and errors-and-omission coverage with specific coverage for mold-related claims.

Other provisions apply to home and building inspectors, as well as a variety of other professionals, redefining warranties and setting new indemnity guidelines.
Governor Crist’s office was contacted for a statement for this story, but did not return phone calls.

Charlie Wiles, executive director of the American IAQ Council, welcomes the law. He stated in an email, “When everyone becomes licensed, licenses can no longer distinguish true industry professionals. That role will inevitably fall to independent certification bodies, like the American IAQ Council, who comply with national and international industry standards.”

Not everyone is convinced the new law will be good for industry. IAQA’s executive director, Glenn Fellman, noted that IAQA was “at least partly successful” in having two objectionable clauses removed from the bill.

The first would have “removed all corporate protection from licensed mold remediators and assessors, giving them personal liability akin to that of a medical doctor -- liability that is never transferred to individual consultants, contractors or others in construction trades.” Fellman noted IAQA’s particular leadership in having this provision removed.

The second clause “included definitions drawn directly from a draft standard that is under revision, and named a service mark trademarked by the same standard making organization whose draft work was quoted. ... Most of this language was in the definitions section of the bill and its inclusion simply wasn't necessary.”

Despite these successes, a third section could not be negotiated out. The language in question, which IAQA opposed, “did not adequately define the types of voluntary certification programs that would be permitted” for licensure without passing a state-administered exam. Fellman remarked, “IAQA pushed for amendments that would have required such certifications to be awarded by accredited certification bodies with no ties to training entities, and which work in accordance with nationally accepted standards for certification.” Nonetheless, the provision survived the cut and has been entered into law.

As DBPR is charged with interpreting the code and written regulations, “[i]f DBPR accepts credible certifications in lieu of state licensing, then the regulation becomes far less onerous on practitioners. By the same token, if DBPR sets lax requirements for voluntary certification programs it accepts, the industry will suffer and consumers will suffer,” Fellman said.

Wiles was more optimistic. In the same email, he stated, “The American IAQ Council feels the State of Florida would certainly recognize our certification over others since we are the only IAQ certification body accredited by an independent accreditation body outside the IAQ industry. While the American IAQ Council cannot ensure that Florida regulatory officials will recognize any certification program, we can certainly make them aware of how a quality program should operate and encourage them to exclude the man certification mills in existence today.”

Maurice Baum, of Environmental Research & Restoration, an IAQ company based in Hollywood, Fla., and chapter director of the Ft. Lauderdale chapter of IAQA, told IE Connections the bill could create a situation “as bad as or worse than what happened in Texas,” where the state opted to use state testing for licensure rather than existing certifications from independent bodies.

According to Mr. Baum, the most damaging aspect of the law, though, is that requiring “general liability and errors and omissions insurance coverage” of at least $1 million for both mold assessors and remediators, the latter’s policies required to include “specific coverage for mold related claims.” He noted that such large coverage requirements threaten to eliminate from the marketplace a substantial portion of currently certified assessors and remediators.

Another concern of Baum’s is the in-house interpretation of the law by DBPR rather than by a committee of independent third-party professionals, potentially leading to regulations friendly to the construction industry and independent contractors that could complicate assessment and remediation practices.

“If there’s ever been a need to get together, it’s now,” Mr. Baum stated, referring to the mold industry in Florida. He added that the IAQA Ft. Lauderdale chapter’s August 21 workshop will partly serve to dissect the new law and explain it to members.
Aaron Trippler, director of government affairs for the American Industrial Hygiene Assocation, noted AIHA’s position is one hoping for an emphasis on regulations rather than licenses, adding that the preference remains with certification from nationally accredited organizations rather than the state. He pointed out that by leaving open a portion of the bill to interpretation, the legislature created an opening by which AIHA and other bodies could influence the interpretation process and provide adequate consumer protection.

“It’s a start,” Trippler said, expressing concern over who would be considered qualified as assessors and how that determination would be made. “They key is how to set minimum qualifications,” he said. According to him, the most important aspect of the law is the regulations passed by DBPR – if they include more stringent training requirements than those currently listed, consumers will be protected.

He balked at the suggestion of exemptions for currently certified assessors. Although “we think most CIHs should be able to walk into the room and pass an exam,” he added that not all certified industrial hygienists and other IAQ professionals are sufficiently experienced to do so and should be required, along with holders of certifications from non-accredited bodies, to pass state-mandated examinations.

Minnesota
In Minnesota, House File No. 402 was also passed into law, albeit with significantly less immediate impact. It requires the state to study how and if persons who apply residential antimicrobial products should be subject to state licensing requirements as currently required of other pesticide applicators.

“The commissioners of agriculture and health must study the development and implementation of a new category of license for commercial pesticide applicators who apply antimicrobial pesticides in homes, apartments, or other residences. The commissioners must seek and obtain the consultation of a representative of the University of Minnesota qualified in mold and other fungal microbe pest control,” the bill reads.

It further requires the commissioners to prepare a report including a discussion of other federal and state laws governing commercial residential antimicrobial applicators; a literature review on the need for residential antimicrobial pesticides, as well as any potential dangers; a survey of laws and processes for licensing applicators in the rest of the country; and recommended procedures for licensure of applicators in Minnesota.

The report, along with an implementation plan, must be submitted by the commissioners to the state House and Senate committees with jurisdiction over agricultural policy, finance and environmental health no later than December 1, 2007.
The bill’s chief author, Representative Rick Hansen, told IE Connections his background in science and working in state bureaucracy informed his decision to propose the bill, hoping to create a “basic level of competency” in practitioners in order to protect consumers.

Hansen stressed that any new regulations for licensure will be “unnecessary” as the “regulatory umbrella” is already in place over pesticide application, requiring basic levels of insurance coverage, uniform testing and continuing education requirements. He plans to involve himself in the study hearings.

Robert G. Baker of RGB Group in Ruskin, Fla. is skeptical of the bill’s potential to affect the mold remediation industry in Minnesota. Noting that “most study bills go nowhere,” he allowed that “the game is changed” and, with more and more states examining licensure of the assessment and remediation industry, the general environment for licensure seems to be one requiring such legislation to be passed, perhaps specifically so in Minnesota given its proximity to Canada and the recent passage of strong national regulations.

Wisconsin
Although only introduced on May 7 of this year, Wisconsin Assembly Bill 312 may ultimately mean as much to mold assessors and remediators as Florida’s new law, calling on the state to regulate and license those who provide assessment and remediation services.

Analysis attached to the bill by the Legislative Reference Bureau states, “[e]ffective January 1, 2010, this bill establishes requirements for licensure by the Department of Health and Family Services (DHFS) of mold assessors and mold remediators for the performance of mold assessment and mold remediation, as defined in the bill. DHFS must issue biennial licenses and renewals of these licenses as mold assessors or mold remediators to individuals who submit applications, pay specified fees, and meet certain statutory requirements and DHFS rules requirements.”

Specifically, the bill lists requirements for the performance of professional mold assessors and remediators and calls on DHFS to “promulgate rules to specify, among other things, the scope of licensure activity, requirements for licensure, standards for continuing education requirements, practice standards, and information to be contained in written reports that mold assessors must provide to persons for whom they perform services,” as well as “to develop and administer examinations for licensure, maintain a publicly accessible registry of licensed mold assessors and mold remediators, and periodically conduct inspections.”

DHFS is further required to report annually on the number of current licenses, measures taken to disseminate information about licensees and education and research conducted in the past year or proposed for the next.

The bill goes on to prohibit “certain actions by mold assessors, mold remediators, and employers or contractors of mold assessors and mold remediators, including offering compensation, inducement, or reward for the referral of business, and prohibits performance after license expiration of a mold assessment or mold remediation activity that requires licensure.” It also specifies disciplinary actions for violations, including the limitation, suspension or revocation of licensure.

Tom Powell, research assistant for Representative Terese Berceau, the author of the bill, said the bill is necessary because “there is no clear way for an average consumer to deduce who is a true mold professional, and who is unqualified or a charlatan.”
After listing the bill’s various consumer protections, he noted that the concern for some people in the industry to remain in business “is a valid one.” “We purposefully wrote the bill with these considerations in mind, so that it does not favor one professional discipline over another, but tries to treat all fairly. ... [T]he only people that need to worry about losing business are those that are unqualified, irresponsible or criminal.”

Much like Florida’s law, AB 312 will create a deficit for the state. With licensing fees varying between $25 and $200, Powell said, “[t]he Department of Health and Family Services has estimated that if we charged a biennial license fee of $200, we would still need $83,950 a year in state assistance.” He added, “This is not unusual.”Wane Baker, director of air quality services for Michaels Engineering in La Crosse, Wisc., favors some measure of licensure for assessment and remediation professionals, but worries that AB 312, “if it passes, and the licensing program becomes reality, will probably hurt our business” because there will be no appreciative differentiation between holders of various certifications.

However, he feels the bill could “level the table” and “provide some minimum bar for people to prove their qualifications.” As this could potentially eliminate the presence of “charlatans” in the marketplace, the potential is there to help consumers make more intelligent decisions about the contractors they hire, he said.

In noting significant opposition among members of the mold assessment and remediation industry, he expressed a desire for the “community of interested parties [to] get together to reach consensus” on solutions to change the bill’s language rather than “lob bricks at it.”

Trippler feels policy-making has “slowed down” as state governments, in the wake of the late regulation boom, are unsure as to the extent of mold issues in their states and many are avoiding further exploration of mold industry licensure and regulation so as to avoid further confusing the public.

But with so much activity in various state legislatures, Baker wondered at what point it would prompt the U.S. Congress to draft federal remediation laws. While he emphatically stands against state licensure of antimicrobial applicators, he doubts continued Republican government in Washington will result in any such measures in the near future, he added that “it’s a real interesting regulatory target right now” despite any current federal regulation of volatile organic compounds, a matter still left to individual states.

FEMA’s Latest Failure: Formaldehyde in Trailers
By Jonathan Miller

Allergies, bronchitis, headaches, tumors. After living through Hurricane Katrina, Gulf Coast residents in trailers supplied by the Federal Emergency Management Agency have found they face a covert enemy – their homes.

Built only for short-term use, the mobile homes contain floors and cabinets made of pressboard containing formaldehyde, which off-gases in the hot, humid weather of Louisiana, Mississippi and Arkansas. When residents began to complain and one sued the agency, critical eyes began to fall.

According to testimony before the House Oversight and Government Reform Committee, one mother’s complaints led to an investigation in 2006 that showed formaldehyde in concentrations 75 times the NIOSH-recommended maximum. An independent investigation by the Sierra Club showed 83 percent of tested trailers contained formaldehyde concentrations above FEMA’s own recommended maximum for one-time exposure. However, agency officials issued no warning to other residents, instead standing by its earlier advisory to stay outdoors and use proper ventilation, practices now recognized as “impractical” in the summer environment.

Despite calls from field agents to test the trailers in bulk to determine the extent of the formaldehyde problem, FEMA’s Office of General Counsel recommended against it as it “would imply FEMA's ownership of this issue."

Committee Chairman Henry Waxman, D-Calif., called the news “sickening” and accused the agency of “premeditated ignorance.” Rep. Tom Davis, R-Va., said, “it appear[s] FEMA's primary concerns were legal liability and public relations, not human health and safety.”

FEMA director David Paulison denied a deliberate attempt to mislead residents. “The general counsel does not set policy for this organization,” he said. “The health and safety of residents is my primary concern.” He pledged proper testing and necessary evacuations.

The trailers in question aren’t only being used for Katrina victims, however. American Indian reservations in the West have seen deliveries of surplus Katrina trailers, originally pushed by Senator Tim Johnson, D-S.D., to alleviate shortages of adequate housing. He has since written to Paulison, “[e]very step possible must be taken to ensure that only safe and reliable housing is ever distributed to Indian Country. ... [E]fforts must to be taken to ensure no related threats arise in tribal mobile homes.”

Word on the Street

SECONDHAND SMOKE GOES TO THE DOGS
The American Veterinary Medical Association has launched a new initiative, One Health, to integrate human and animal medicine in various research and clinical faculties to improve the diagnosis and treatment of disease.

Although the association’s outgoing president, Roger Mahr, says 75% of new infectious diseases have come from animals, humans can have just as large an impact on animal health.

According to Ron Davis, president of the American Medical Association, smoking in the home can have a serious affect on one’s pets. “Dogs whose owners smoke are more likely to get lung cancer and nasal sinus cancer, and cats are more likely to get feline lymphoma,” he said.

There’s good news, though. When the Henry Ford Health System’s Center for Health Promotion and Disease Prevention surveyed 3,378 pet owners and told them of the dangers to their animals, 22.3 percent said they would think about quitting, 32.2 percent would try to quit, 42.5 percent would ask others not to smoke indoors and 33.1 percent would ban indoor smoking.

NYC SCHOOLS GOING GREEN
With the Green Building Law in New York City requiring most public school constructions to adhere to green building standards, the school system has put together its own guide, the New York City Green Schools Guide, so new constructions and renovations are assured of using sustainable construction and design.

The Guide is adapted from standards developed by the U.S. Green Building Council’s LEED rating system and the Best Practices Manual from the Collaborative for High Performance Schools. In an effort to move quickly to comply with the Green Building Law, the department of education couldn’t wait for the Council to finish its own schools-specific LEED system.

When the city’s Office of Environmental Coordination conducted an independent review of the Guide, it was found to be “at least as stringent as version 2.2 of the LEED standard for new construction,” according to Green School & University.

SICK OF GOING TO COURT
Elgin Jones of the Broward Times reported on a series of illnesses stemming from mold in the Broward Main Courthouse in Ft. Lauderdale, Fla. Administrators, attorneys and even the county sheriff have been stricken.

It’s not merely a matter of calling in the assessors and remediators, though. As Jones reported, sick employees are “quietly being relocated out of the building, but some can’t be moved elsewhere.” Further reporting indicates that “county officials have known about it for years.” “Workers in that building are getting sick every day,” wrote Jones. [I]t could reach a crisis situation soon.”

Indications are “county officials have known about [the problem] for years.” Jones has requested a detailed account of the problem from County Administrator Pam Brangaccio and will hopefully keep an eye on this as it develops.

“[I]t may be time to ask Gov. Charlie Crist to intervene,” Jones wrote.

DUCTZ DEAL DONE
After nearly a year of negotiations, one prominent duct cleaning company has found a buyer.

Service Brands International of Ann Arbor, Mich. Sold its air duct cleaning arm, Ductz International LLC to Belfor Holdings Inc. on July 24. Belfor, an insurance restoration company with its American base in Birmingham, Mich., saw the deal as a way to build on its billion-dollar annual business in the U.S.

Belfor CEO Sheldon Yeller called the move “... a very, very synergistic opportunity to grow the business.” By increasing the number of Ductz franchises from 61 to over 300 in the coming years, he hopes to bolster sales 400 percent, from $15 million to $60 million. He noted that Ductz’s corporate headquarters will be relocated to another location in southeast Michigan.

Terms of the deal were not disclosed. Ductz founder and president John Rotche noted subcontracting work performed by Ductz on Belfor’s behalf in the past, including cleanup work following Hurricane Katrina in 2005. He said, “It just made an enormous amount of sense for us to figure out how we can work together on a more permanent basis.” Rotche will remain with the company to oversee operations.

Yellen added that the deal puts Belfor in a position for significant growth and that the company is considering further acquisitions.

BILLABLE HOURS WORTH THE GREEN
The American Bar Association’s Section of Real Property, Probate & Trust Law, along with the Standing Committee on Environmental Law and others, is sponsoring “Hot Topics in Environmental Law,” to be held on August 10 at the Moscone West Convention Center in San Francisco.

Panels include “Green Building, Sustainable Development and Your Practice,” which will discuss the ins and outs of green building and sustainable development and how they affect legal practices, development certifications and current initiatives in California, and “U.S. Supreme Court Decrees in Favor of Cost of Cleanup Rights for Responsible Parties,” dealing with a June 11 decision by the Supreme Court on CERCLA cost recovery rights and how it will affect the future real estate environment as well as discussing “the rights of responsible private parties to clean up environmentally tainted real estate and recover costs incurred from others.”

The litigation panel will cover “U.S. Supreme Court Decisions in Flow Control and New Source Review,” which will offer insight into the impact of the Court’s decision “on both industrial developments and municipal law,” considering “both the actual holdings and the directions they suggest that law is headed in both these fields.”

OZONE EVEN WORSE FOR WOMEN
A Penn State University College of Medicine study suggests air pollution has a more significant effect on the immune systems of women than men.

After exposing mice to ozone, then infecting them with pneumonia bacteria, significantly more females than males died. “If we could extrapolate what we found to the human population, it would mean women with lung infections may be at higher risk for negative outcomes if they are exposed to high amounts of air pollution, and in particular, ozone,” said Professor Joanna Floros.

Given the prevalence of ozone-generating indoor air purifiers despite warnings as to the dangers of keeping them, further study along these lines bears watching.

Flanked by fellow former Surgeons General C. Everett Koop, who served under President Ronald Reagan, and David Satcher, who served under President Bill Clinton, Carmona told of arriving in Washington to serve under President George W. Bush with optimism and enthusiasm “to serve all people, and ... to carry on what I believed was a tradition of implementing non-partisan, evidence-based solutions to public health challenges,” despite warnings from past surgeons general “that partisan political agendas often undermine the public health and well-being of our nation.”

Carmona said, “I witnessed partisanship and political manipulation ... I was astounded but also unsure of what I was witnessing.” After asking past holders of the office about the environment, he was told they “had all been challenged and had to fight political battles in order to do their job as ‘the doctor of the nation.’

“But each agreed that never had they seen Washington, D.C. so partisan or a new Surgeon General so politically challenged and marginalized as during my tenure.”
“[T]he nation’s doctor has been marginalized and relegated to a position with no independent budget, and with supervisors who are political appointees with partisan agendas. Anything that doesn’t fit into the political appointees’ ideological, theological, or political agenda is ignored, marginalized, or simply buried.”

Carmona cited a long list of topics and activities for which he had to battle executive branch officials, including the prison health, stem cells, sexual education and second-hand smoke.

For the last, Carmona contended that the groundbreaking report, “Health Consequences of Involuntary Exposure to Tobacco Smoke,” was first delayed, then watered-down by top administration officials. Released in 2006, the report cited immediate harm to a person’s health with even brief exposure to second-hand tobacco smoke.

In his press conference announcing the report’s release, Carmona cited the 1986 report from former Surgeon General Koop, “The Health Consequences of Involuntary Smoking” and noted that 20 additional years of peer-reviewed research had created scientific consensus that “[s]econdhand smoke is a health hazard for all people ...”
An earlier report, “The Health Consequences of Smoking,” released by Carmona in 2004, noted the physical dangers of smokers themselves without elaborating on contact in non-smokers.

He listed the 2006 report’s main messages as: “Secondhand smoke exposure causes heart disease and lung cancer in adults and sudden infant death syndrome and respiratory problems in children,” “There is no risk-free level of secondhand smoke exposure, with even brief exposure adversely affecting the cardiovascular and respiratory system,” “Only smoke-free environments effectively protect nonsmokers from secondhand smoke exposure in indoor spaces” and “...while great strides have been made in recent years in reducing nonsmoking Americans’ secondhand smoke exposure, millions of Americans continue to be exposed to secondhand smoke in their homes and workplaces.”

Elaborating on these points, Carmona noted that, since Koop’s original report in 1986, “[l]evels of cotinine, the biomarker of secondhand smoke exposure, fell by 70 percent from 1988-91 to 2001-02. The proportion of nonsmokers with detectable cotinine levels has been halved from 88 percent to 43 percent.” However, “[m]ore than 126 million nonsmoking Americans, including both children and adults, are still exposed to secondhand smoke in their homes and workplaces.”

Carmona closed with the report’s conclusion, that “smoke-free environments are the only approach that effectively protects nonsmokers from the dangers of secondhand smoke. The 1986 Surgeon General’s Report concluded that the simple separation of smokers and nonsmokers within the same air space may reduce, but does not eliminate, secondhand smoke exposure among nonsmokers. The current Report expands on that finding by concluding that even sophisticated ventilation approaches cannot completely remove secondhand smoke from an indoor space. Because there is no risk-free level of secondhand smoke exposure, anything less cannot ensure that nonsmokers are fully protected from the dangers of exposure to secondhand smoke.”

While this report was being held back from release, Carmona testified in the government’s racketeering lawsuit against the tobacco industry, which claimed a decades-long conspiracy by the industry to keep Americans smoking. His testimony on May 3, 2005, originally appeared to be for the purpose of bolstering the government’s argument that the tobacco companies should pay for a significant part of any remediation measures imposed by the court. During his cross examination, he denied that any restraints had been put upon his 2004 report.

But in his appearance before the congressional committee, Carmona noted that he was invited to testify at the 2005 trial by the government’s lawyers. Administration officials then discouraged him from doing so while also telling the lead government lawyer he was not competent to testify.

"What he said is all correct," said Sharon Y. Eubanks, director of the Justice Department's tobacco litigation team. "He was one of the most powerful witnesses. His testimony was very important."

In his testimony before the committee, Koop noted he was “embarrassed” that Dr. Satcher was less respected than he had been in the same office, and that “Dr. Carmona was treated with even less respect than Dr. Satcher.”

Similar accusations have been made by others. Former New Jersey governor and U.S. Environmental Protection Agency administrator Christine Todd Whitman has been forced into staunch denials in the face of reports alleging she made a misleading declaration as to the atmosphere surrounding the World Trade Center site after Sept. 11 under significant political pressure. Scientists from seven federal agencies, most notably the National Aeronautics and Space Administration, complained of political pressure on global warming data.

Whitman faced accusations of bowing to similar pressure during her tenure with the EPA. Following the Sept. 11 terrorist attacks in New York and Washington, D.C., amid fears that toxic materials released by the disintegrated buildings were dangerous to rescue workers and those living nearby, she issued a public report on Sept. 18, 2001, in which she stated “I am glad to reassure the people of New York and Washington, D.C. that their air is safe to breathe and their water is safe to drink.”

Two reports in 2003 – one from the EPA’s inspector general, the other from the EPA's Office of Solid Waste and Emergency Response – disputed that claim. The latter was particularly critical, noting that various toxins, especially asbestos, were prevalent in the air throughout Lower Manhattan in the weeks following the attack. This was reflected in the prevalence of respiratory ailments in those living and working in the vicinity – 70 percent of ground zero workers, according to a study by Mount Sinai Medical Center.

Whitman continues to defend her Sept. 18, 2001 statement. On June 25, 2007, she appeared before the House Judiciary Subcommittee on the Constitution, Civil Rights and Civil Liberties to testify as to the federal government’s response to the environmental risks associated with the collapse of the World Trade Center. Accused of giving people a “false sense of safety,” she claimed her statement only applied to those living and working in the area rather than those dedicated to cleanup. She then challenged the committee: “Was it wrong to try get the city back on its feet as quickly as possible in the safest way possible? Absolutely not.”

Whitman denies political pressure or interference behind her statement, but the evidence suggests otherwise. The 2003 report from the EPA inspector general noted political considerations, such as reopening Wall Street, motivated Whitman’s declaration and “[the EPA] did not have sufficient data and analyses to make such a blanket statement.”

A Sept., 2003 statement from 19 EPA union local heads added to the inspector general’s assessment: “Little did the Civil Service expect that their professional work would be subverted by political pressure applied by the White House. ... These workers reported to senior EPA officials their best estimate of the risks, and they expected those estimates and the accompanying recommendations for protective measures to be released in a timely manner to those who need the information. The public was not informed of all the health risks. ... This information was withheld ... under orders of the White House. The Bush White House had information released, drafted by political appointees, that it knew to contradict the scientific facts. It misinformed.”

According to a survey earlier this year by the Union of Concerned Scientists, 40 percent of government scientists responding to their questionnaire reported that some of their scientific papers had been edited in a way that changed their meaning, and roughly 50 percent had been ordered to delete references to “global warming” or “climate change.”

James E. Hansen, head of the NASA Goddard Institute for Space Studies, has been a vocal critic of what he feels is a concerted effort from executive appointees to downplay and obfuscate scientific research findings. In 2005 and 2006, he contented in the national media that NASA administrators tried to influence his public statements on the origins of climate change, claiming that public relations staff were ordered to review his findings.

“In my more than three decades in the government I've never witnessed such restrictions on the ability of scientists to communicate with the public,” he told 60 Minutes.

This was echoed the same year when anonymous press officers contended that NASA scientists were pressured by top politic appointees to withhold or delay press releases detailing data on climate change and other earth sciences during the 2004 election season. This prompted newly appointed administrator Michael D. Griffin to call for “scientific openness” and a review of communications policies.

Can I Do Quantitative Cultural Tape Sampling for Mold?

Dr. Harriet Burge
Director of Aerobiology
EMLab P&K
San Bruno, Calif.

We are receiving an increasing number of requests for quantitative cultural analysis of tape samples and, of course, we are accommodating those requests. However, I would not recommend the routine use of any kind of quantitative analysis for tape samples. A tape sample usually represents only a few square centimeters of surface. Regardless of how careful you are in choosing the spot to collect a sample, it is never going to be representative of the entire environment.

The biggest problem with surface fungal sampling is that the distribution of fungal colonies and/or spores is not random. As you know, the fungi form discrete colonies that range from pinpoints to those that cover several square feet of surface. They form only where there is sufficient water for their growth and the water distribution is generally also not random. Collecting representative samples from a surface with a non-random distribution of the things you are looking for represents a challenge that cannot be met with the limited resources available in incident mold investigations.

With sufficient resources, you could use tape sampling to estimate source strength for fungal spores. This is best done with microscopic examination, although culture could also be used if you are only interested in culturable spores. To do this, you would identify all fungal growth and carefully measure the surface area covered. You would then calculate how many tape samples you would have to collect to represent 10 percent of this area. Because of the non-random nature of fungal growth, you would then have to devise a way to select where to collect the tape samples. It is almost impossible to avoid bias if you are looking at the growth. The tendency will be to collect the samples in the worst areas (i.e., the blackest or fuzziest). In a research study, I would draw a diagram on a grid and select spots on it without looking at the growth itself. Then you can ask for quantitative analysis of these samples. You can see why this kind of sampling is rarely useful for most incident investigations.

Some people use tape sampling for clearance. Again, how do you collect a representative sample? This is even harder than when you have visible fungal growth. You would have to sample 10 percent of the entire space!

Non-quantitative tape samples are very useful for identifying whether discoloration represents fungal growth and for identifying the types of fungi growing in a space. Remember in the latter case that a tape sample collected from one part of a colony is likely to have different fungi than one collected in a different part, so that a single sample is not likely to be representative.

Finally, should you use culture or microscopy? If you want to know whether discoloration is fungal growth, then microscopy is sufficient. I also prefer microscopy for at least an initial identification of the types of fungi present. Generally, spore-bearing apparatuses are visible, so separating Penicillium and Aspergillus and other small-spored fungi is possible. On the other hand, if you want to know the species of any fungus, you will have to use cultural sampling.

Dr. Harriet Burge is director of aerobiology at EMLab P&K and associate professor and director of the microbiology laboratory at Harvard School of Public Health. Widely considered the leading expert in IAQ, Burge pioneered the filed 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.

US EPA Continues its Radon Reinvigoration Program
Mr. Tom Kelly, director of the Indoor Environments Division, was joined by Bill Long, director of the Radon and Air Toxics Center, and Phil Jalbert, Radon Team Leader, to enthusiastically share their thoughts and plans for the coming year during a telephone interview on June 26, 2007. Although new programs are being developed, there was a consensus among these gentlemen that the radon reinvigoration program the EPA initiated a few years ago is working well, and programs for 2008 will be a refinement of this initiative with a focus on accountability for federal funds and the need for hard results.

With respect to how well the EPA’s outreach program has been working, Phil Jalbert reported that a net increase of 63,000 existing homes had been mitigated in 2006 and an additional 110,000 homes had been constructed with radon reduction techniques in 2005 (note: a one year lag occurs from timing of survey results from the National Association of Home Builders). These results bring the total number of homes in the U.S. having radon reduction systems to approximately 2 million, which is halfway to the agency’s goal of 3.9 million homes by 2012.

Jalbert went on to remark that historically, the annual increase in the number of homes mitigated has ranged from about 8-12 percent. However, in 2006 this increase jumped to 18.9 percent. This may be due to a slower real estate market, which according to Jalbert, can result in sellers more inclined to address sales contract contingencies (such as radon reduction). On the other hand, it may also be due to increases in public outreach programs such as National Radon Action Month and a greater number of media stories such as Canada’s pending adoption of a new radon action level and Minnesota’s adoption of statewide codes for radon. Regardless of the reason there are encouraging signs of progress toward the national goal.

EPA’s Key Initiatives for 2008
According to Bill Long, the primary “pillars” of the EPA’s reinvigoration strategy are:

• Build new partnerships and increase outreach
• Increase state and local programs and their results
• Accelerate action in the marketplace
• Expand scientific knowledge and technology

While focus and energy will remain on these strategic themes, Long noted several areas where EPA is devoting particular attention this year.

Greater Transparency
in the SIRG Program
First, he stated there would be an increased accountability with respect to State Indoor Radon Grants, with an emphasis on results. He described the direction they received from the White House Office of Management and Budget (OMB) to show a greater amount of transparency on how grant funds are being used. “It’s about spending the taxpayer’s money effectively and in a way where they can see results they are getting.”

Tom Kelly reinforced the need for accountability, citing that with $8 million likely available next year for state grant activities, states need to be very selective to return the greatest public value from limited funding. “So, we at EPA are accountable to the Congress, but we need the states to share accountability with us. This is not accountability in the sense of top-down pressure; it is just increasing the assurance of results and transparency about how the money is spent. That is how we are using the term ‘accountability.’”

Fostering an Improved Alignment Between Industry and the States
Long stated that another key element for next year is fostering more alignment between industry and states. This endeavor is an outcome of concerns expressed by Tom Kelly during last year’s national meeting over friction between states and industry that, if left unresolved, might slow national progress toward reducing radon risk.

True to Kelly’s commitment to engage a third-party consensus building group to address such issues, two meetings were held over the past year with the intent of generating operating agreements between a number of organizations that have common, but also divergent interests in the radon arena. Indicating that cooperation is required despite organizational differences, there has been progress made over this past year with a third meeting that will occur during the September, 2007 National Radon Meeting.

With respect to how long the EPA would remain a steward in this consensus building process, Tom Kelly indicated:

“This is not just a ‘flash in the pan.’ There is a period now for intensive discussions aimed at creating understanding and reducing suspicion or mistrust. Misunderstandings arise through a lack of opportunity for concerned parties to step up in a public forum and have their questions answered. There are disagreements between and among states on radon policy and practice. There is competition between firms and across sectors within the radon industry. There are misunderstandings, disagreements and occasionally distrust between states and industry in almost any setting. At the same time, we are a very small national movement – none of us has the scope of resources or clout that we might wish to force consenus. The only way it is going to work is if we can talk to each other candidly, understand each other adequately, and come to some reasonable agreements about unified action. We don’t have to like each other if it comes to that, but we do need to work together. That is what this is about and I think the first meeting suggests that we have many people who are entering this process with open minds and positive attitudes. We will do this a few more times and then we will all sit down and agree on how much more we need to do. We can then set up some topic-based subcommittees to operate on a regular basis for a longer period.”

EPA’s Best Practices Campaign
According to Bill Long, the EPA is planning to launch a Best Practice Campaign that will help share tools and experiences that work among the state radon programs. “This all started in Kansas City at the last National Radon Meeting – we heard from the constituents and our stakeholders, especially the states, about a number of tools they need and want in order to do their jobs better. They told us they want to be able to share information better, talk to each other more, communicate more effectively, learn from each other… So we have a number of tools already in place that we have put out there that are proving to be very popular and successful.”

According to Long, this includes a listserv for states, webinars on hot-topic meetings and a mentoring program for state program staff members who may be assuming radon-related duties but are unfamiliar with the unique aspects of dealing with radon.
At the Jacksonville national meeting, it is Mr. Long’s intent that EPA will announce an initial group of best practices from various state model programs that can be shared and replicated around the country, not only for an improved success rate but also as a means of utilizing grant funds more effectively.

Promoting RRNC
to the Building Community
Bill Long went on to describe an enhanced effort for promoting the use of Radon Resistant New Construction practices within the building community by stating, “we are launching a new media campaign aimed at builders, hoping to encourage them to build homes radon resistant, and then target it towards consumers, encouraging them to ask their builders to provide this service. This is already out there. In fact, in this month’s Builder Magazine, we have a nice full page spread with our new PSA campaign. We are exploring – but still need to work through our management chain here – a couple of other exciting ideas about encouraging more RRNC in the country that are primarily about using our website to employ partnership approaches that some of our other voluntary programs and EPA use with regard to enrolling the private sector.”

Citing the newly adopted ASTM 1465 standard, Long felt the improved approaches in this document will be more protective of public health and should be promoted. However, he was quick to add that the EPA was not discounting all the good work that went into the adoption of Appendix F of the International Residential Code, but rather that the ASTM standard is an enhancement or resource for local code agencies to refer to as they determine how best to adopt or modify Appendix F in their jurisdictions.

In closing, all three EPA representatives expressed a great deal of enthusiasm for the upcoming year.

AARST Shares Vision for 2008
Since the national radon meeting has a shared agenda with the private radon industry, as represented by the American Association of Radon Scientists and Technologists, Peter Hendrick, executive director of AARST, was happy to provide the following written comments.

“One of the AARST’s primary goals is to increase a renewed discussion of public policy regarding radon risk reduction at the state level. We are working with key leaders within the radon community to further the adoption of model legislation that will assist in creating more activity in the realms of measurement and mitigation.

“Since becoming recognized as an ANSI Accredited Standards Organization, the AARST Standards Consortium will be focusing on three measurement standards, including adoption of a Multi-family Radon Measurement Standard.

“Another area that AARST is focusing on is the issue of sustainability within the radon community – both in terms of policy and the economics of risk reduction. An overview of the radon industry shows less than 1,000 certified or licensed mitigators in the United States as compared to close to 1 million real estate agents and 48,000 residential home contractors. So, sustainability and the viability of qualified radon professionals as a successful business people is a high priority for the AARST.

“Some of AARST’s goals relating to sustainability include:

• Improved reporting of industry field activity (testing and mitigation)
  
  
• Increasing membership services to help our members improve their business practices
  
  
• Supporting radon legislative and code adoption initiatives through the National Conference of Legislative Assemblies and other organizations
  
  
• Supporting recognition of certified and licensed professionals
  
  
• The promulgation of new AARST standards through the AARST National Radon Standards Consortium
  
  
• Increasing the international exchange of science and technology
  
  
• Training and mentoring leadership roles within the radon professional community”
  
  

NEHA National Radon
Proficiency Program
Since AARST is administering the National Radon Proficiency Program on behalf of the National Environmental Health Association, we asked Hendrick to share additional insights regarding this national certification program as well.

“AARST staff is continuing to work with NEHA and the NEHA-NRPP’s Policy Advisory Board to improve outreach and administration program. Currently, two staffers in North Carolina work full time on the NRPP administration. The Policy Advisory Board will be advising NEHA on a number of matters, including updating the program’s Policy Manual. One possible item that the PAB may begin to address is advising NEHA-NRPP on new standards that have been promulgated over the last several years and what effect (if any) this will have on certified professionals and their training and accreditation. The program recently passed the 2,000 mark in the number of certified professionals who are enrolled in NEHA-NRPP. The staff is working to improve communications with these certified members and has begun a dialogue with many state radon offices on issues such as continuing education, program content and professional compliance.”

Hopefully, this will provide an insight into the coming year. Even better would be attending the meeting itself in Jacksonville, where the hallway discussions are as interesting as the formal presentations. If you can’t be there, look for a recap of the meeting in the October edition.

As always, who says there is nothing new in radon?

New School, Time to Move in!
We’ve seen many new schools during their break-in period in the past 30 years. You all know that because of opening day schedules, people are frequently moved in before the buildings are fully commissioned and sometimes with temporary occupancy permits. We all read about 30 day out-gassing periods; however, with some construction schedules, it’s difficult to achieve. From indoor air quality and human comfort perspectives, let’s look at the range of where the school may be on move-in day and discuss the bare minimums that are “musts” on opening day” versus having the HVAC commissioning completed 30 days ago and all systems working perfectly.We’ll assume the school is 100 percent new, built on the other side of the athletic fields, one-quartermile away from the 60-year-old facility that is scheduled to be torn down due to financially unresolvable moisture problems and pending structural failure. Based on the schedule, it’s 30 days before the children arrive and teachers will be allowed in 15 days from now. Delays at this point are not acceptable to the owner.
According to the Maine Indoor Air Quality Council’s “IAQ Checklist for New Residential Construction,” the school must be: clean, dry, pollutant- and pest-free and comfortable.

The time proven principles for accomplishing the above basics include keeping sources out, design for proper ventilation and energy use as well as thermal and humidity control, using spaces for intended loading, ensuring occupants don’t introduce unusual contaminants and planning for long-term good IAQ.’

Keep Sources Out
Let’s review the construction details that were accomplished with regard to moisture, insects and fumes. These include a vapor barrier and two inch insulation under the slab, either no crawlspace or a warm, dry crawlspace without venting, termite and other insect shields, rain drainage under the cladding, air sealing around windows and doors as well as at the wall/roof joints and interface, flashing above and below the windows, a perimeter drain to daylight, insulated basement walls, either a tall chimney or a combustion-free heat source such as a geothermal heat pump or solar panels, air intakes high off the ground, a 5 percent pitch around the school building and keeping the dumpster 50 feet away from any building openings.

Design for proper ventilation and energy use: In designing for proper ventilation and energy use, the checklist includes a light-colored roof, flat computer screens, some daylighting, economizer cooling, a dedicated outside air drying unit, enthalpy energy recovery, a peaking boiler, VAV with minimums and displacement ventilation and cooling. The tall chimney or combustion-free heat source also helps to serve these purposes.

Design for comfort: Controlling temperature, humidity and outside air are key to designing for comfort. These can be controlled with thermostats in classrooms with 4 degrees Fahrenheit of control (between 68 and 72 in winter, 74-78 in summer), carbon dioxide sensors, north/south zoning and operable windows.

Designed for planned use: Design for planned use requires consideration of potential contaminants such as art classes, janitors’ closets, copying and laminating. Use of dedicated exhausts with planned make-up air, operable windows, cleanable floors and a walk-off mat system can alleviate these concerns.

30 Days and Counting
All the above items have been planned for and it looks like they were achieved within the new facility’s budget.

Commissioning the HVAC has been started; there are good air filters in place and the outside air supply, air conditioning and exhaust fans work, but some balancing remains. Painting is mostly completed, flooring is mostly installed and both should be done before teachers start their move in 15 days from now.

Make Sure Occupants
Don’t Bring in Unusual Contaminants
Let’s discuss the materials that are to be moved into the green school from the one that is being closed.

We had a building abandoned because of financially unresolvable moisture and structural problems. Roofs and walls leaked, carpets and paper treasures got wet. The vinyl composition tiles would not stay stuck to the floor. Some books in the library were wet and others smelled musty. Prior to the decision to permanently close the school and build a new green facility a year and a half ago, asthma rates in teachers were determined to be elevated 30 percent compared to the norm.’

Discards? Or To Be Saved?
Were the paper and fleecy sofa and chair treasures discarded? Yes. After some objections, many trash-container loads were taken away after school ended.
Have the solid nonporous objects been cleaned? Yes. A contained cleaning area was set up in the gym over the summer and as items were moved from classrooms, they were cleaned with a detergent wash and stored in the clean area where two large commercial dehumidifiers and two air scrubbers were run continuously all summer every night when the building was closed up.

What about the athletic floor mats from the gym area? The mats were a hard decision for the district. Four very old fabric-filled mats were discarded. The new ones, only two years old, were solid foam inside and were purchased after a fundraiser, but had some visible mold growth after the roof leaked most of the winter. A decision was made to scrub off the surface growth (which had likely occurred on organics from sweating and dirt accumulation) and all other surfaces to see if the musty smell could be eliminated. They were then stored off site in another school over the summer with a commercial dehumidifier running in the room. Currently, they do not stink and are planned to be moved to the new facility.

Are the library books moldy? Has someone thought about this prior to now? The classroom and library books were the hardest issues for the teachers and administration folks to deal with. Books in the lower level classrooms where roof leaks, ground moisture and summer condensation had occurred for too many years were discarded. Books within the area of the library where roof leaks did not occur were considered salvageable if they had no odors associated with them. All old newspapers and magazines, which clearly had odors, were also discarded. Before any books were moved from the old school, they were HEPA vacuumed within the cleaning area and their jackets were damp wiped. Ultimately, if they smelled musty after this, they were discarded.

Plan for Good Long-term IAQ
Educate the occupants:
A week prior to children arriving, meetings were set up for parents and teachers on three evenings. They were used to inform parents where their ’children’s new classrooms would be and to educate the attendees regarding which precautions had been taken to clean any materials that were being reused from the old facility. Additionally, the features of the new school were explained.

Implements IAQ Tools for Schools:
The U.S. Environmental Protection Agency’s IAQ Tools for Schools, or some other type of long-term accountability program involving all the stakeholders for addressing IAQ and thermal comfort concerns, should be implemented. At a minimum, the program needs to address whom to contact when there is a concern and how the concerns are followed up and resolved. It also likely needs to address future recommissioning of critical systems. Somewhere in the overall program, radon should be checked for if the school is located in a region where radon from soil gas or well water is known to be a concern.

Conclusion
Occupying new construction is a time for celebration and enjoyment, but rushing to occupy the building can lead to operational issues that are never resolved. When potentially contaminated materials are being salvaged from a previous school building, some tough decisions may need to be made to avoid problems in moving from one facility to another. With careful planning and follow through, the move will usually be successful.

William A. Turner, MS, P.E., is president and CEO of Turner Building Science, 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.

In the somewhat tumultuous history of the science of indoor air quality, homeowners, business owners and the general public have been beset by alarms one after the next. There always seems to be a crisis du jour. References to poor IAQ date back to ancient Greece and Rome but the problem probably existed back to the time of the cavemen; however, the recorded history for this period is sparse. Of late, IAQ issues have included, among other things, formaldehyde in carpets and foam insulation, asbestos, air “ionization,” ozone insertion, radon, mold, soil vapor and now volatile organic compounds in general. Some of these issues are real, some imagined, some handled scientifically and expeditiously, some exaggerated and most exploited in some way or another by hysteria-mongering charlatans. The objective of this discourse is to shed some light on the issue of VOCs from a chemist’s perspective to help dispel some of the myths surrounding them and to help IAQ investigators tackle this dimension of their work.

Even the term “volatile organic compounds” sounds rather daunting to an individual without a degree in chemistry or a lot of experience because measurement and interpretation of VOCs is wholly different from nearly all other IAQ measurements. Radon, CO2, humidity, etc. are just what they say they are and no interpretation is required. Not so with VOCs. What is measured are chemical compounds with strange sounding names like geraniol, citronellyl formate and limonene, which must be translated into Japanese Beetle attractant, rose scent and citrus, respectively. Even after the translation has been made, interpretation is required to answer questions such as: “What is a normal level for this compound?” “Is this level hazardous?” and “Do I need to do something to manage it and, if so, what?” As complex as this issue appears, it can be simplified by understanding a few basic concepts.

There are many “hand-held” on-site monitors that can be useful on occasion, but they have limited utility, especially in addressing odor problems. The most effective way to assess VOCs is to take a sample and send it to a laboratory for analysis, usually performed using gas chromatography-mass spectrometry (GC-MS). This technique has the advantage of separating the VOCs from each other and then using the MS fingerprints (cracking patterns) of the compounds to determine their identity. While GC-MS is the principal workhorse for this analysis, Fourier transform-infrared (FT-IR) Spectrometry has also been used effectively to augment the GC-MS analysis because of its wide dynamic range and its effectiveness at identifying simple organics that do not have a singular, well-defined mass spectral fingerprint.

The first step in understanding VOCs is to get a feel for total VOCs, or TVOCs,, the sum of all VOCs present. TVOC should not to be confused with the simple sum of all identified compounds in the chromatogram. Many sources of VOCs produce a vast array of low-level overlapping peaks that, when viewed in a chromatogram, appear to be a “hump” as shown on the right hand side of Figure 1. The most common sources of these “humps” include fuels (gasoline, kerosene, or diesel), paints and varnishes, natural gas, low-quality solvents, decaying organic matter and rotting flesh. These “humps” can make up a very significant fraction of the TVOC load and should not be ignored.

Setting aside the impact of individual compounds for now, the TVOC load can have significant deleterious effects on building occupants. Currently, there is no specific U.S. standard for the permissible exposure level for TVOC. Even though research and opinions have been published for more than 30 years, questions regarding safe levels or whether or not methane, ethane and similar low molecular weight compounds should be included still remain and are currently being debated. However, it is still possible to establish reasonable, workable limits for TVOCs. The LEED (Leadership in Energy and Environmental Design, USGBC) has set the standard for Green Buildings at less than 500 nanograms per liter. The European Community has established a TVOC limit of 300 ng/L with no single compound contributing more than 10 percent of the total. One U.S. chemical company uses the standard of less than 500 ng/L as their target for non-manufacturing areas, 500̶,1,000 ng/L as their “action level” and greater than 1,000 ng/L as their “immediate action level.” The literature generally seems to agree that less than 300 ng/L represents an “acceptable” TVOC level and that greater than 3,000 ng/L represents a “hazardous” TVOC level; however, few seem to want to address the hazards involved with levels between 300 and 3000 ng/L.

The recognized symptoms above 3,000 ng/L generally include drowsiness, eye and respiratory irritation, general malaise, headache, nausea and exacerbation of symptoms of respiratory ailments. Some data suggest that high TVOC levels amplify the hazardous effects of specific harmful VOCs. In addition, there is some empirical information from industrial hygienists who perform medically driven environmental investigations that indicates typically acceptable levels are too high by a factor of two or more for chemically sensitive individuals.

Table 1 was developed using available literature, data from numerous companies and industrial hygienists active in the IAQ field, together with empirical data from many personal investigations. It provides a workable definition of the limits and effects of C3 C15 TVOC concentrations and has proven to be a good predictor of the level of expected symptoms of non-chemically sensitive people.

The next step in understanding VOCs is to consider collections of compounds that give indications of the five most common VOC problems: gasoline, paint, odorants, personal care and lifestyle.

Gasoline has six marker compounds associated with it. They are benzene, toluene, ethylbenzene and the three xylene isomers. The source of gasoline can be ambient air (especially in urban environments), but it is generally the office occupants themselves who supply the contamination. Remember that for every gallon of gas pumped into an automobile, one gallon of air saturated with gasoline vapor is dumped into the lap of the person filling the tank. This person then goes to the office and off gasses the rest of the day. The gasoline levels in homes are generally higher than in offices because, in addition to the personal off gassing, the most common source of gasoline vapors is the collection of gas cans, mowers, trimmers, etc. in the attached garage.

Paints are very complex and can have several different markers, but they typically include methylcyclohexane, substituted cyclics, butylcellosolve, substituted alcohols, unsaturated C9-C12 hydrocarbons and the straight-chain hydrocarbons nonane (C9) through dodecane (C12). Paint VOCs can linger at significant levels for as long as 18 months after application; however, even though the paint may be fully cured, leaking paint cans often contribute to the VOC load for years.

Odorants are chemicals that are supposed to smell good. They are in air fresheners, potpourri, scented oils, perfumes/colognes and nearly all cleaning and personal care products. In a typical office, especially in an office or home where an IAQ problem exists that the occupants think they can eliminate by covering it up, odorants can make up a significant fraction of the TVOC load. These odorants include many aldehydes, alcohols, ketones, pinenes and complex esters.

Personal care products are the primary sources of acetone, typically associated with nail care (nail polish remover is nearly 100 percent acetone). Other compounds associated with personal care include the C2-C5 acetates (nail care), isopropanol and ethanol (cosmetics and hair spray) and menthol, camphor, and methylsalicylate (topical ointments).

Lifestyle chemicals are many and varied, but the three primary compounds are ethanol from antiseptic wipes (although the occasional leaking bottle of scotch cannot be ruled out), tetrachloroethylene or PCE from garments that have been dry cleaned and 1,4-dichlorobenzene from mothballs.

What has been presented thus far serves as a primer of sorts but covers only 25–50 percent of the problems that will be encountered in the real world. The rest are far more complex and require close cooperation between the laboratory and the investigator. For example, consider a four-storey apartment building constructed in the early 1920s in which sulfur dioxide is indicated in the analysis. When it was built, the apartment was equipped with centrally pressurized refrigerant, which was piped to each apartment to cool the refrigerator. Guess what was used as the refrigerant.

After electric refrigerators became commonplace, the compressor and piping were sealed off and walled over. Corrosion due to a water intrusion event formed a pinhole in one of the pressurized pipes, releasing sulfur dioxide into the building. Or consider the asthmatic child of a wealthy couple. The plasticizer used in the hordes of plastic toys with which the child was playing was causing his asthma attacks.

When assessing VOC contamination, the general tendency is to run a USEPA TO-15 or TO-17 analysis; however, experience has shown that this type of analysis will solve fewer than 10 percent of the VOC problems typically encountered because fewer than 75 compounds are typically reported (at many laboratories, fewer than 50 compounds) and they are mostly substituted benzenes and halogenates. By far, the better analysis is a full spectrum analysis. Thermal desorption tubes generally provide the best collection medium for this purpose because of their small size, long shelf life, broad versatility and low acquisition, storage and shipping costs. In addition, they can be applied to other analytical techniques such as FT-IR. Recent advances in FT IR technology coupled with the fact that VOCs from 40 L of air can be trapped on a tube and desorbed into a 1 L IR cell work together to expand the effective range of FT-IR down to the 1-10 ppb range. But by far the most attractive attribute of thermal desorption tubes is their ability to quantitatively trap compounds that are generally considered to be semivolatiles. These include the diesel/kerosene markers (naphthalene and the methylnaphthalene isomers), medicinal compounds (camphene, menthol and methylsalicylate), phenolics (including the cresols) and many characteristic odors and scents including compounds like citronellyl acetate (rose), eugenol (clove), cedrol (cedar or sandalwood), geosmin (fungal and musk), α Cedrene (exotic woods) and skatole (fecal material).

NIOSH 2549 is an excellent method for thermal desorption tube analysis. A great deal of credit goes to NIOSH for writing a performance-based method rather than a detailed cookbook that is outdated before it is promulgated. In addition to the compounds they report quantitatively, most laboratories that use this method to perform a full spectrum analysis will determine many of the compounds they report semiquantitatively – i.e., the concentration is estimated rather than based on a calibration curve. Usually, though, this level of accuracy is sufficient to determine the source(s) of VOC contamination.

At this point, a discussion is warranted as to how the identification of compounds reported semiquantitatively is made. There is a distinct difference between running a computer-generated library search to identify compounds in a full spectrum analysis and having the analysis performed by a competent chemist well trained in mass spectral interpretation and who has available a large in-house collection of reference compounds. Any laboratory can produce a report based on a computer-generated library search in under a minute. Virtually no operator training is required. However, what appears to be an effective application of computer technology frequently results in incorrect compound identification. Misidentification causes several problems. When a hazardous compound is erroneously cited, it can mandate unnecessary and expensive follow-up testing, cause grave concern when it is unwarranted and embarrass the investigator. Equally problematic is failing to correctly identify critical compounds. Misidentification arises primarily because every computer-generated library search routine selects a single best match – oftentimes, the second best match, which may be the correct compound, is only minutely lower in search quality.

Also, different search criteria result in different best matches, or the computer may select an outlandish compound totally inconsistent with the retention time, fail to account for distorted mass spectra or fail to differentiate overlapping compounds. This uncertainty is seldom, if ever, transmitted to the submitter as part of the analytical report. As a result, the submitter has no idea whatsoever of the validity of the results.

A good laboratory report should give the name of the compound, synonyms, the concentration determined in weight/volume as well as ppb, comments by the analyst (including uncertainty in identification), the molecular weight of the compound and the Chemical Abstract Service (CAS) number. The CAS number is critical when searching the Web for information on a specific compound. For example, 4-methyl-2-pentanone can be called MIBK, or methyl isobutyl ketone, but it has only one CAS number, 108-10-1. Then, the only problem in searching the Web will be sorting through a few old hockey win/loss records. In addition, the laboratory report should include hydrocarbons, even if their exact structure cannot be determined, because their presence constitutes a hydrocarbon fingerprint that is very useful in chemical profile interpretation and comparisons among samples.

With all the intricacies of sampling (media, sampling parameters), laboratory analysis (type of instrument, choices of analytical parameters), translation (translating chemical compounds into substances, materials and products) and chemical profile interpretation (figuring out what the analysis means in practical terms), it is critical that a laboratory be selected that is capable of working with the investigator in all phases of the project, including everything from planning the very start of the project through the chemical profile interpretation. Choose your laboratory carefully!

Randall S. Fike, Ph.D., is the chief technical officer of Prism Analytical Technologies Inc., a consultative air testing laboratory in Mount Pleasant, Mich. He has spent the last 12 years in the research and development of air testing systems and gas sample delivery systems. He has developed several products and analytical protocols for the analysis of VOCs in air and has designed and developed gas handling and chromatography subsystems to expand and enhance the capability of GC MS and FT IR analysis. Fike can be reached by e-mail at rsfike@pati-air.com or by phone at (989) 772-5088.